ENVIRONMENTAL SCOPING REPORT FOR THE PROPOSED SCC …

ENVIRONMENTAL SCOPING REPORT FOR THEPROPOSED SCC COLD SIDE CAPACITY ENABLEMENTMT-9: HEAVIES AND OXYGENATE REMOVAL AT THESASOL SECUNDA INDUSTRIAL COMPLEX,MPUMALANGA

Draft

Sasol Synfuels (Pty) Ltd

DEA REF: 12/9/11/L1197/6

MDEDET REF: 17/2/3 GS-166

March 2013

DOCUMENT DESCRIPTIONClient:

Sasol Synfuels (Pty) Ltd Project Name:

Environmental Scoping Report for the Proposed SCC Cold Side Capacity Enablement MT-9: Heavies and Oxygenate Removal at the Sasol Secunda Industrial Complex, Mpumalanga

Royal HaskoningDHV Reference Number:

T01.PTA.000505

Authority Reference:

DEA Ref: 12/9/11/L1197/6

MDEDET Ref: 17/2/3 GS-166

Compiled by:

Phyllis Kalele

Date:

March 2013

Location:

Pretoria

Reviewed by:

Prashika Reddy

Approved by:

Prashika Reddy

_____________________________

Signature

© Royal HaskoningDHV

All rights reserved.

No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written permission from Royal HaskoningDHV

TABLE OF CONTENTS

1 INTRODUCTION 1 1.1 PROJECT NEED AND JUSTIFICATION 1 1.2 APPROACH TO THE ENVIRONMENTAL SCOPING STUDY 1 1.3 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER 2 1.4 STRUCTURE OF THE REPORT 3

2 PROJECT DESCRIPTION 5 2.1 PROJECT LOCATION 5 2.2 HEAVIES AND OXYGENATE REMOVAL 6

3 PROJECT ALTERNATIVES 7 3.1 TECHNOLOGY ALTERNATIVES 7 3.2 SITE ALTERNATIVES 7 3.3 DO NOTHING / NO‐GO ALTERNATIVE 8

4 LEGAL REQUIREMENTS 9 4.1 THE CONSTITUTION OF SOUTH AFRICA 9 4.2 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NO 107 OF 1998) 9 4.3 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (NO 59 OF 2008) 10 4.4 NATIONAL ENVIRONMENTAL MANAGEMENT ACT: AIR QUALITY ACT (NO. 39 OF 2004) 10 4.4.1 LISTED ACTIVITIES AND ATMOSPHERIC EMISSION LICENSING 11 4.4.2 OCCUPATIONAL HEALTH AND SAFETY ACT (NO 85 OF 1993) 12 4.4.3 HAZARDOUS SUBSTANCE ACT (NO 15 OF 1973) AND REGULATIONS 12 4.5 RELEVANT ACTS, GUIDELINES, POLICIES & ENVIRONMENTAL MANAGEMENT INSTRUMENTS 12

5 PUBLIC PARTICIPATION 13 5.1 CONSULTATION WITH THE COMPETENT AUTHORITY 14 5.2 CONSULTATION WITH OTHER RELEVANT STAKEHOLDERS 15 5.3 ADVERTISING 16 5.4 IDENTIFICATION OF INTERESTED AND AFFECTED PARTIES 17 5.5 BRIEFING PAPER 17 5.6 ISSUES TRAIL 17 5.7 PUBLIC AND AUTHORITY REVIEW OF THE DRAFT SCOPING REPORT 17 5.8 FINAL ENVIRONMENTAL SCOPING REPORT 17

6 GENERAL DESCRIPTION OF THE STUDY AREA 18 6.1 GEOLOGY 18 6.2 TOPOGRAPHY AND SOILS 18 6.3 WATER RESOURCES 18 6.3.1 GEOHYDROLOGY (GROUNDWATER) 18 6.3.1.1 GROUNDWATER QUALITY 18 6.3.2 HYDROLOGY (SURFACE WATER) 18 6.3.2.1 SURFACE WATER QUALITY 19 6.4 CLIMATE AND LOCAL WEATHER CONDITIONS 19 6.4.1 WIND 19 6.4.2 ATMOSPHERIC STABILITY 23 6.4.3 TEMPERATURE AND HUMIDITY 24 6.4.4 PRECIPITATION 25 6.5 AIR QUALITY 25 6.5.1 IDENTIFIED SENSITIVE RECEPTORS 26 6.5.2 EXISTING SOURCES OF AIR POLLUTION 26 6.5.3 AGRICULTURE 27

6.5.4 DOMESTIC FUEL BURNING 276.5.5 MINING ACTIVITIES 28 6.5.6 VELD FIRES 28 6.5.7 POWER STATIONS 29 6.5.8 OTHER SASOL OPERATIONS 29 6.5.9 SASOL SCC PROJECT ON THE EXISTING AMBIENT CONCENTRATIONS 29 6.5.10 OTHER – MOTOR VEHICLES 29 6.5.11 AIR QUALITY STATUS QUO 29 6.5.12 PM10 CONCENTRATIONS 30 6.5.13 SO2 CONCENTRATIONS 33 6.5.14 NO2 CONCENTRATIONS 36 6.6 NOISE 39 6.7 SOCIAL 39 6.8 LAND‐USE 39 6.9 HEALTH AND SAFETY 39 6.10 HERITAGE 39

7 POTENTIAL IMPACTS ASSOCIATED WITH THE PROJECT 40 7.1 CONSTRUCTION PHASE 40 7.2 OPERATIONAL PHASE 41 7.3 DECOMMISSIONING PHASE 42 7.4 CUMULATIVE IMPACTS 42

8 CONCLUSIONS AND RECOMMENDATIONS 43

9 PLAN OF STUDY FOR ENVIRONMENTAL IMPACT ASSESSMENT 44 9.1 APPROACH TO UNDERTAKING THE EIA PHASE OF THE PROJECT 44 9.1.1 AUTHORITY CONSULTATION 44 9.1.2 AIMS OF THE ENVIRONMENTAL IMPACT ASSESSMENT 44 9.1.3 DETAILED STUDIES TO BE UNDERTAKEN IN THE EIA PHASE – AIR QUALITY IMPACT ASSESSMENT 44 9.1.3.1 AERMOD DISPERSION MODEL 44 9.1.3.2 MODEL REQUIREMENTS 45 9.1.3.3 EMISSIONS INVENTORY 45 9.1.4 IMPACT ASSESSMENT METHODOLOGY 45 9.1.5 ENVIRONMENTAL IMPACT ASSESSMENT REPORT 47 9.1.6 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) 48 9.2 PUBLIC PARTICIPATION PROCESS 49 9.2.1 ADVERTISING 49 9.2.2 IDENTIFICATION OF AND CONSULTATION WITH KEY STAKEHOLDERS 49 9.2.3 I&AP DATABASE 49 9.2.4 CONSULTATION AND PUBLIC INVOLVEMENT 49 9.2.5 ISSUES TRAIL 49 9.2.6 PUBLIC AND AUTHORITY REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT 49 9.2.7 AUTHORITY REVIEW OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT 50 9.2.8 ENVIRONMENTAL AUTHORISATION AND WASTE MANAGEMENT LICENSE 50

LIST OF TABLES

TABLE 1: DETAILS OF THE EAP 3 TABLE 2: ESR REQUIREMENTS ACCORDING TO SECTION 28 OF GN R. 543 3 TABLE 3: COORDINATES OF THE SITE BOUNDARY WITHIN THE SASOL COMPLEX 5 TABLE 4: ALTERNATIVES FOR THE DISPOSAL OF OXYGENATES 7 TABLE 5: LISTED ACTIVITIES ACCORDING TO LISTING NOTICE 2 OF THE EIA REGULATIONS (2010) 9 TABLE 6: LISTED ACTIVITIES ACCORDING TO CATEGORY B OF NEM:WA GN R.718 10 TABLE 7: MINIMUM EMISSION STANDARD FOR CATEGORY 8 11 TABLE 8: COMPETENT AUTHORITIES & OTHER RELEVANT AUTHORITIES 14 TABLE 9: ATMOSPHERIC STABILITY CLASSES 23 TABLE 10: IDENTIFIED SENSITIVE RECEPTORS SURROUNDING THE SITE 26 TABLE 11: AIR QUALITY SUMMARY 38 TABLE 12: POTENTIAL CONSTRUCTION PHASE IMPACTS 40 TABLE 13: POTENTIAL OPERATION PHASE IMPACTS 41 TABLE 14: CRITERIA TO BE USED FOR THE RATING OF IMPACTS 46 TABLE 15: SIGNIFICANCE RATING OF CLASSIFIED IMPACTS 47

LIST OF FIGURES

FIGURE 1: ENVIRONMENTAL STUDIES FLOWCHART 2FIGURE 2: LOCATION OF THE PROPOSED PROJECT 5 FIGURE 3: SIMPLIFIED FLOW DIAGRAM OF OXYGENATE REMOVAL PROCESS 6 FIGURE 4: PERIOD WIND ROSES ‐ SASOL CLUB & LANGVERWACHT STATIONS (JAN 2011 – DEC 2012) 20 FIGURE 5: DIURNAL WIND ROSES ‐ SASOL CLUB & LANGVERWACHT STATIONS (JAN 2011 – DEC 2012) 21 FIGURE 6: SEASONAL WIND ROSES SASOL CLUB & LANGVERWACHT STATIONS (JAN 2011 – DEC 2012) 22 FIGURE 7: STABILITY CLASS FREQUENCY DISTRIBUTION ‐ SASOL CLUB & LANGVERWACHT STATIONS 24 FIGURE 8: AVERAGE MONTHLY TEMPERATURE & HUMIDITY ‐ SASOL CLUB (JAN 2008 – DEC 2012) 25 FIGURE 9: AVERAGE MONTHLY TEMPERATURE & HUMIDITY ‐ LANGVERWACHT (JAN 2008 – DEC 2012) 25 FIGURE 10: LOCATION OF THE SASOL & DEA AIR MONITORING STATIONS 30 FIGURE 11: DAILY AVERAGE PM10 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 31 FIGURE 12: DIURNAL PM10 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 32 FIGURE 13: SEASONAL DIURNAL PM10 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 33 FIGURE 14: DAILY AVERAGE SO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 34 FIGURE 15: DIURNAL SO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 35 FIGURE 16: SEASONAL DIURNAL SO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 36 FIGURE 17: HOURLY AVERAGE NO2 CONCENTRATIONS ‐ SASOL STATIONS (JAN 2011 – DEC 2012) 36 FIGURE 18: DIURNAL NO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 37 FIGURE 19: SEASONAL DIURNAL NO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 38

APPENDICES APPENDIX A: LOCALITY MAP

APPENDIX B: ACCEPTANCE OF APPLICATIONS APPENDIX C: PUBLIC PATICIPATION DOCUMENTS

ACRONYMS

AEL Atmospheric Emission License

AQIA Air Quality Impact Assessment

DEA Department of Environmental Affairs

EA Environmental Authorization

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EIAR Environmental Impact Assessment Report

EMPr Environmental Management Programme

ESS Environmental Scoping Study

GMLM Govan Mbeki Local Municipality

GSDM Gert Sibande District Municipality

LIDP Local Integrated Development Plan

MDEDET Mpumalanga Department of Economic Development, Environment and Tourism

MRG Methane Rich Gas

MTOP Medium Term Optimisation Program

NEMA National Environmental Management Act

RHDHV Royal HaskoningDHV

SCC Superflex Catalytic Cracker

WML Waste Management License

DRAFT ENVIRONMENTAL SCOPING REPORT FOR THE PROPOSED SASOL SCC COLD SIDE CAPACITY ENABLEMENT MT-9: HEAVIES AND OXYGENATE REMOVAL AT THE SASOL SECUNDA INDUSTRIAL COMPLEX, MPUMALANGA

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1 INTRODUCTION Unleaded fuel specifications necessitated the construction of the Superflex Catalytic Cracker (SCC) plant. The SCC plant beneficiates low octane products to higher value gasoline and chemicals in order to enable a viable Synfuels fuel pool. The SCC unit was commissioned in November 2006 and reached beneficial operation in February 2008. Since commissioning, the unit has experienced several design challenges, such as fouling in the acid gas removal systems and gas absorbers. Thus, the SCC Medium Term Optimisation Program (MTOP) was launched to address throughput limitations and operational sustainability of the SCC. In addition, Sasol Synfuels initiated the MT-9: SCC Cold Side Capacity Enablement project to resolve the fouling in the SCC acid gas removal and gas absorber systems. The proposed project will result in de-bottlenecking the SCC plant to enable instantaneous feed as per original design. The MT-9 project aims to reduce the current caustic consumption at the SCC plant significantly. As a result, MT-9 will significantly reduce the spent caustic which is currently sent to the API and or Unit 52/252 plants. The site of the proposed project is in the existing Synfuels Primary Area, U293 at the Sasol Secunda Industrial Complex (refer to Appendix A for the Locality map).

1.1 Project Need and Justification The key objectives of the MT-9 project are to: Resolve the fouling in the SCC acid gas removal and gas absorber systems. De-bottleneck the SCC plant to enable instantaneous feed as per original design. Reduce the current caustic consumption at SCC plant significantly. To ensure compliance with the EIA regulations (2010) made under section 24 (5) of the National Environmental Management Act - NEMA (Act No. 107 of 1998) (as amended) and the National Environmental Management: Waste Act (Act No. 59 of 2008), Sasol Synfuels (Pty) Ltd appointed Royal HaskoningDHV (RHDHV) as the independent Environmental Assessment Practitioner (EAP) to conduct the necessary studies to obtain an Environmental Authorisation and a Waste Management License to undertake the proposed project.

1.2 Approach to the Environmental Scoping Study The environmental impacts associated with the proposed project require investigation in compliance with the EIA Regulations (2010) published in Government Notice No. R. 543 to No. R. 545 and read with Section 24 (5) of the National Environmental Management Act - NEMA (Act No 107 of 1998) as amended, as well as Government Notice No. 718 of the National Environmental Management: Waste Act – NEM:WA (Act No 59 of 2008). A two-pronged licensing process for the proposed project will be followed, namely: (a) The Mpumalanga Department Of Economic Development, Environment and Tourism (MDEDET) is the

competent authority for the issuing of an environmental authorisation applied for in terms of the EIA Regulations, 2010 promulgated under NEMA; and

(b) The Department of Environmental Affairs (DEA) is the licensing authority for the waste management license in terms of NEM:WA.

The rationale behind this two-pronged licensing process is that, the Minister of Environmental Affairs is the licensing authority in respect of all activities listed in terms of Section 19 of NEM:WA pertaining to hazardous waste. MDEDET is the competent authority in respect of the GN R545 listed activities as it is the environmental authority in the province in which the activity is to be undertaken.


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The required environmental studies include the undertaking of an Environmental Impact Assessment (EIA) process. This process is being undertaken in two phases (see Figure 1) that will ultimately allow the competent authorities (DEA and MDEDET) to make an informed decision: Phase 1 - Environmental Scoping Study (ESS) including Plan of Study for EIA; and Phase 2 - Environmental Impact Assessment (EIA) and Environmental Management Programme (EMPr).

Figure 1: Environmental studies flowchart

The ESS provides a description of the receiving environment and how the environment may be affected by the development of the proposed project. The ESS will also identify alternatives and mitigation options to be evaluated and investigated during the EIA phase of the project.

Desktop studies making use of existing information are used to highlight and assist in the identification of potential significant impacts (both social and biophysical) associated with the proposed project. A baseline Air Quality Impact Assessment (AQIA) study will be conducted by RHDHV in order to further identify both potentially positive and negative environmental impacts. Additional issues for consideration will be extracted from feedback during the public participation process, which commenced at the beginning of the Scoping phase, and will continue throughout the duration of the project. All issues identified during this phase of the study will be documented within the Environmental Scoping Report (ESR). Thus, this ESR provides a record of all issues identified as well as any fatal flaws, in order to make recommendations regarding the project and further studies required to be undertaken within the EIA phase of the proposed project.

1.3 Details of the Environmental Assessment Practitioner RHDHV is the appointed independent EAP by Sasol Synfuels, to undertake the appropriate environmental studies for this proposed project. The professional team of RHDHV have considerable experience in the environmental management and EIA fields. RHDHV has been involved in and/or managed several of the largest Environmental Impact Assessments undertaken in South Africa to date. A specialist area of focus is on the assessment of multi-faceted projects, including the establishment of linear developments (national and provincial roads, and power lines), bulk infrastructure and supply (e.g. wastewater treatment works, pipelines, landfills), electricity generation and transmission, the mining industry, urban, rural and township developments, environmental aspects of Local Integrated Development Plans (LIDPs), as well as general environmental planning, development and management.


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The particulars of the EAP are presented in Table 1 below:

Table 1: Details of the EAP

Details Consultant: Royal HaskoningDHV Contact Persons: Phyllis Kalele and Prashika Reddy Postal Address PO Box 25302, Monument Park, 0105

Telephone: 012 367 5916 / 012 367 5973 Facsimile: 012 367 5878 E-mail: [email protected] / [email protected] Expertise: Phyllis Kalele is a Senior Environmental Consultant with a MSc.

Environment and Development. Ms. Kalele has experience in various facets of environmental management including conducting the Public Participation process; compiling Environmental Impact Reports and Environmental Management Programmes; conducting environmental awareness training; and conducting legal compliance audits. She is a registered Professional Natural Scientist (Pr Sci Nat 400456/11) with the South African Council for Natural Scientific Professions (SACNASP). Prashika Reddy is a Principal Associate / Senior Environmental Scientist (Pr Sci Nat 400133/10) with a BSc Honours in Geography. Ms Reddy has the necessary experience in various environmental fields including: environmental impact assessments, environmental management plans/programmes, public participation and environmental monitoring and auditing. Ms Reddy has extensive experience in compiling environmental reports (Screening, Scoping, EIA and Status Quo Reports). Ms Reddy is/has been part of numerous multi-faceted large–scale projects, including the establishment of linear developments (roads, and power lines); industrial plants; electricity generation plants and mining-related projects.

1.4 Structure of the Report This draft ESR is being compiled according to the guidelines provided in Government Notice R.543 of the EIA Regulations (2010) – refer to Table 2.

Table 2: ESR requirements according to section 28 of GN R. 543

ESR Requirements according to Section 28 of GN R. 543 Section / Comment

(a) details of (i) the EAP who prepared the report; and (ii) the expertise of the EAP to carry out scoping procedures

1.3

(b) a description of the proposed activity 2

(c) a description of any feasible and reasonable alternatives that have been identified

3

(d) a description of the property on which the activity is to be undertaken and the location of the activity on the property, or if it is (i) a linear activity, a description of the route of the activity; or (ii) an ocean-based activity, the coordinates where the activity is to be undertaken

2.1


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ESR Requirements according to Section 28 of GN R. 543 Section / Comment

(e) a description of the environment that may be affected by the activity and the manner in which the activity may be affected by the environment

6

(f) an identification of all legislation and guidelines that have been considered in the preparation of the scoping report

4

(g) a description of environmental issues and potential impacts, including cumulative impacts, that have been identified

7

(h) details of the public participation process conducted in terms of regulation 27 (a), including (i) the steps that were taken to notify potentially interested and affected parties of the application; (ii) proof that notice boards, advertisements and notices notifying potentially interested and affected parties of the application have been displayed, placed or given; (iii) a list of all persons or organizations that were identified and registered in terms of regulation 55 as interested and affected parties in relation to the application; and (iv) a summary of the issues raised by interested and affected parties, the date of receipt of and the response of the EAP to those issues

5

(i) a description of the need and desirability of the proposed activity 1.1

(j) a description of identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity

3

(k) copies of any representations, and comments received in connection with the application or the scoping report from interested and affected parties

Will be included in the final ESR

(l) copies of the minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants

Will be included in the final ESR

(m) any responses by the EAP to those representations and comments and views

Will be included in the final ESR as part of the Issues Trail

(n) a plan of study for environmental impact assessment which sets out the proposed approach to the environmental impact assessment of the application, which must include (i) a description of the tasks that will be undertaken as part of the environmental impact assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken (ii) an indication of the stages at which the competent authority will be consulted (iii) a description of the proposed method of assessing the environmental issues and alternatives, including the option of not proceeding with the activity; and (iv) particulars of the public participation process that will be conducted during the environmental impact assessment process

9

(o) any specific information required by the competent authority; and Not applicable at this stage

(p) any other matters required in terms of sections 24(4)(a) and (b) of the Act

Not applicable


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2 PROJECT DESCRIPTION

2.1 Project Location The site of the proposed project is in the existing Synfuels Primary Area, U293 at the Sasol Secunda Industrial Complex. Figure 2 below shows the boundaries of the area within which the proposed project will be implemented.

Figure 2: Location of the proposed project

The coordinates of the site boundaries are shown in Table 3 below.

Table 3: Coordinates of the site boundary within the Sasol Complex

Corner Coordinates

1 26°33’12.58"S; 29°9'40.18"E

2 26°33'17.19"S; 29° 9'39.47"E

3 26°33’19.10"S; 29° 9'54.30"E

4 26°33'14.39"S; 29°9'54.98"E


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2.2 Heavies and Oxygenate Removal As indicated in Section 1.1, the key objectives of the MT-9 project are to: Resolve the fouling in the SCC acid gas removal and gas absorber systems. De-bottleneck the SCC plant to enable instantaneous feed as per original design. Reduce the current caustic consumption at SCC plant significantly. To prevent polymer fouling in the acid gas removal sections, a water wash and oxygenate stripper column will be installed to remove oxygenate species in the process gas feeding these units. A new water wash column will be installed to water wash the SCC’s process gas upstream of the existing acid gas removal section. The oxygenate-rich wash water will be sent to an oxygenate stripper column to separate the water and oxygenates. Oxygenate-lean water will be combined with make-up water and fed to the water wash column for washing of the process gas. From the oxygenate stripper reflux drum, non-condensables (oxygenates) will be routed for incineration. It is estimated that 1250 kg/hr of oxygenates will be incinerated. Preliminary investigations have shown that these oxygenate species cannot be economically processed for further value addition in the Synfuels processes. Flue gas produced from incineration will be vented to the atmosphere via a stack. It is currently proposed to use the existing SCC stack.

Figure 3 below provides a simplified flow diagram of the oxygenate removal process.

Figure 3: Simplified flow diagram of oxygenate removal process

Oxygenate Free

Process Gas

Oxygenate Rich

Process Gas

Water

make-up

Oxygenate Rich Oxygenate Lean

Wash Water Wash Water

Water Wash Column Oxygenate Stripper

Reflux

Refluxdrum

Oxygenates

for disposal

Blown down to Water

Treatment facilities


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3 PROJECT ALTERNATIVES In terms of the EIA Regulations, Section.28 (1) (c) feasible alternatives are required to be considered as part of the environmental investigations. In addition, the obligation that alternatives are investigated is also a requirement of Section 24(4) of the National Environmental Management Act (Act 107 of 1998) (as amended). An alternative in relation to a proposed activity refers to the different means of meeting the general purpose and requirements of the activity (as defined in Government Notice R.543 of the EIA Regulations, 2010), which may include alternatives to:

a) the property on which or location where it is proposed to undertake the activity;

b) the type of activity to be undertaken;

c) the design or layout of the activity;

d) the technology to be used in the activity;

e) the operational aspects of the activity; and

f) the option of not implementing the activity.

3.1 Technology Alternatives During the feasibility stage, a number of operational alternatives will be studied in detail and an option will be selected at the end of feasibility once the actual flow rate and composition of oxygenates is finalized. The operational alternatives to be considered entail the disposal of oxygenates by means of incineration and are further discussed in Table 4.

Table 4: Alternatives for the disposal of oxygenates

Incineration Alternative Description

Existing Feed Fired Heater

The SCC has a 55 MW feed-fired heater using Methane Rich Gas (MRG) as fuel source. The expected heat duty available from the oxygenate-rich stream is approximately 6 MW, reducing the need to use MRG as fuel for the heater (to be confirmed during the feasibility phase).

Existing Thermal Oxidizer This existing thermal oxidizer is designed to incinerate the acid gas from Diethylamine unit and the regeneration effluent from the oxygen removal reactor. Indications are that modifying the existing thermal oxidizer for increased capacity will be un-economical (to be confirmed during the feasibility phase). The foreseen required modifications for the thermal oxidizer include: New incinerator vessel and burners and Modifications to air fan for increased capacity.

New Thermal Oxidizer Should the feasibility study indicate that it is un-economical or unfeasible to

dispose the oxygenates in a modified thermal oxidizer, a new thermal oxidizer will be installed. It is proposed that this new thermal oxidiser will cover an area of 40 m2 and will operate 24 hours a day, 7 days a week.

3.2 Site Alternatives Should the new thermal oxidiser option go ahead, then two alternative locations will be considered:

The first location is in the south-eastern corner of the existing SCC unit, and is close to the existing Acid Gas Thermal Oxidizer (293HT-1003) and SCC Stack (293ME-1001).


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The second location is north of the existing SCC unit, and is close to the proposed location for the new equipment to be installed as part of the SCC Capacity Enablement MT9 Project.

3.3 Do Nothing / No-Go Alternative If the project does not go ahead, the SCC plant will continue to experience operational challenges namely:

(a) Fouling in the Superflex Catalytic Cracker (SCC) acid gas removal and gas absorber systems. The Diethylamine plant and caustic sections foul with polymers as a result of reaction of oxygenates species in the alkaline environment.

(b) In addition, bottlenecks will persist thus preventing instantaneous feed of 120 tonnes per hour as per original design.

(c) Lastly, there will be no reduction in the current caustic consumption of approximately 3 tonnes per hour.


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4 LEGAL REQUIREMENTS In order to protect the environment and ensure that this development is undertaken in an environmentally responsible manner, there are a number of significant pieces of environmental legislation that will need to be complied with. They include the following:

4.1 The Constitution of South Africa The Bill of Rights, in the Constitution of South Africa (No. 108 of 1996), states that everyone has a right to a non-threatening environment and requires that reasonable measures be applied to protect the environment. This protection encompasses preventing pollution and promoting conservation and environmentally sustainable development. These principles are embraced in NEMA and given further expression.

4.2 National Environmental Management Act (No 107 of 1998) The National Environmental Management Act (No 107 of 1998, “NEMA”)(as amended) states that the principles of Integrated Environmental Management (IEM) should be adhered to in order to ensure sustainable development. A vital underpinning of the IEM procedure is accountability to the various parties that may be interested in or affected by a proposed development. Public participation is a requirement of the IEM procedure, in terms of the identification of potentially significant environmental impacts during the Scoping Phase. The IEM procedure aims to ensure that the environmental consequences of development proposals are understood and adequately considered during all stages of the project cycle, and that negative aspects are resolved or mitigated and positive aspects enhanced. Furthermore, Section 28(1) of the Act states that “every person who causes or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring”. If such pollution cannot be prevented then appropriate measures must be taken to minimise or rectify such pollution. In June 2010, new EIA Regulations were promulgated in order to revise the procedure and criteria relating to environmental authorisations for the commencement of activities in order to avoid detrimental impacts on the environment or, where it cannot be avoided, to mitigate and effectively manage these impacts and optimise positive environmental impacts. These Regulations and a revised set of Listed Activities (Listing Notices 1, 2 and 3) came into force on 02 August 2010. The listed activities applicable to the project are listed in Table 5 below.

Table 5: Listed activities according to Listing Notice 2 of the EIA Regulations (2010)

Listing Notice 2

(GN R.545)

Activity

Description Applicability

5

The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

An Atmospheric Emissions License (AEL) will be required for the proposed project due to the incineration of the hazardous waste (oxygenates). In addition, a Waste Management License will be applied for the incineration of the hazardous waste.

26

Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where [Activity 28 in Notice No. R. 544 of 2010 applies] such commencement requires basic assessment in terms of Notice of No. R544 of 2010.

An Atmospheric Emissions License (AEL) will be required for the proposed project due to the incineration of the hazardous waste (oxygenates).


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4.3 National Environmental Management: Waste Act (No 59 of 2008)

On 03 July 2009, under section 19 (1) of the National Environmental Management: Waste Act (No 59 of 2008) [NEM:WA], a list of waste management activities (GN R.718) which have, or are likely to have a detrimental effect on the environment were published. No person may commence, undertake or conduct a waste management activity listed GN R.718 unless a license is issued in respect of that activity. This list of waste activities requiring a Waste Management License in terms of the NEM:WA as a result of the proposed project are included in Table 6.

Table 6: Listed activities according to Category B of NEM:WA GN R.718

Category B

Activity

Description Applicability

5 The treatment of hazardous waste using any form of treatment regardless of the size or capacity of such a facility to treat such waste.

Oxygenates which are hazardous will be treated by incineration.

8 The incineration of waste regardless of the capacity of such a facility

Oxygenates which are hazardous will be treated by incineration.

11 The construction of facilities for activities listed in Category B of this schedule (not in isolation to associated activity).

An incinerator may be installed for the incineration of oxygenates.

4.4 National Environmental Management Act: Air Quality Act (No. 39 of 2004)

The National Environmental Management (NEM): Air Quality Act (No. 39 of 2004) (AQA) has shifted the approach of air quality management from source-based control to receptor-based control. The main objectives of the Act are to:

Give effect to everyone’s right ‘to an environment that is not harmful to their health and well-being’.

Protect the environment by providing reasonable legislative and other measures that (i) prevent pollution and ecological degradation, (ii) promote conservation and (iii) secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

The AQA makes provision for the setting and formulation of national ambient air quality standards for ‘substances or mixtures of substances which present a threat to health, well-being or the environment’. More stringent standards can be established at the provincial and local levels. The control and management of emissions in the AQA relates to the listing of activities that are sources of emission and the issuing of emission licenses. Listed activities are defined as activities which ‘result in atmospheric emissions and are regarded as having a significant detrimental effect on the environment, including human health. Listed activities have been identified by the Minister of the Department of Environmental Affairs and atmospheric emission standards have been established for each of these activities. These listed activities now require an atmospheric emission license (AEL) to operate. The issuing of emission licenses for Listed Activities is the responsibility of the Metropolitan and District Municipalities. In addition, the Minister may declare any substance contributing to air pollution as a priority pollutant. Any industries or industrial sectors that emit these priority pollutants will be required to implement a Pollution Prevention Plan. Municipalities are required to ‘designate an air quality officer to be responsible for co-ordinating


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matters pertaining to air quality management in the Municipality’. The appointed Air Quality Officer is responsible for the issuing of atmospheric emission licenses.

4.4.1 Listed Activities and Atmospheric Emission Licensing

The Air Quality Act requires all persons undertaking listed activities in terms of Section 21 of the AQA to obtain an AEL. The Listed Activities and Associated Minimum Emission Standards were issued by the Department of Environmental Affairs on 31 March 2010 (Government Gazette No 33064). Some activities at the Sasol Secunda Industrial Complex are categorised as listed activities and therefore require an AEL to operate. Sasol Synfuels has air registration certificates for all applicable listed activities. Applications have been submitted as part of the APPA review process to ensure compliance to the new legal requirements. The following activities are applicable to the proposed activities to be undertaken for the project: Category 8: Disposal of hazardous and general waste

The emission limits for the above listed activity is given below in Table 7.

Table 7: Minimum Emission Standard for Category 8-Disposal of Hazardous and General Waste

Description Facilities where general and hazardous waste including health care waste, crematoria, veterinary waste, used oil sludge from treatment of used oil are incinerated.

Application Facilities with an incinerator capacity of 10 kg of waste processed per hour or larger capacity.

Substance or mixture of substances Plant status

mg/Nm3 under normal conditions of 10% O2, 273 Kelvin and 101.3 kPa Common name

Chemical symbol

Particulate matter N/A New 10 Existing 25

Carbon monoxide CO New 50 Existing 75

Sulphur dioxide SO2 New 50 Existing 50

Oxides of nitrogen NOx expressed as NO2

New 200 Existing 200

Hydrogen chloride HCl New 10 Existing 10

Hydrogen fluoride HF New 1 Existing 1

Sum of Lead, arsenic, antinomy, chromium, cobalt, copper, manganese, nickel, vanadium

Pb+AS+Sb+Cr+ Co+Cu+Mn+Ni+V

New 0.5

Existing 0.5

Mercury Hg New 0.05 Existing 0.05

Cadmium Thallium Cd+Tl New 0.05 Existing 0.05

Total organic compounds TOC New 10 Existing 10

Ammonia NH3 New 10 Existing 10

Mg I-TEQ/Nm3 under normal conditions of 10%


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O2, 273 Kelvin and 101.3 kPa

Dioxins and Furans PCDD/PCDF New 0.1 Existing 0.1

(a) The following special arrangements shall apply –

(i) Compliance with the requirements specified under Schedule 4, Section 11.4 of the National Policy on Thermal Treatment of General and Hazardous Waste (GG No. 32439, Notice No. 777 of 24 July 2009)

(ii) Compliance time frames for health care risk waste incineration will be as specified in Section 5 unless specific compliance time frames for health care risk waste incineration have been set under health care risk waste regulations, in which case, the specific compliance time frames for health care risk waste incineration set under health care risk waste regulations shall apply.

New plants must comply with the new facilities minimum emission standards on the date of publication of the Notice (i.e. 1 April 2010). Existing plants must comply with the minimum emission standards for existing plants within 5 years of the date of publication of the Notice (i.e. 31 March 2015). Existing plants must comply with minimum emission standards for new plants as within 10 years of the date of publication of the Notice (i.e. 31 March 2020). In terms of regulation 6, an application can be submitted for the postponement of the compliance timeframes as set out above and the procedure to follow should a person wish to submit a postponement application.

4.4.2 Occupational Health and Safety Act (No 85 of 1993) The Occupational Health and Safety Act provides for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery; the protection of persons other than persons at work, against hazards to health and safety arising out of or in connection with the activities of persons at work.

4.4.3 Hazardous Substance Act (No 15 of 1973) and Regulations

Provides for the definition, classification, use, operation, modification, disposal or dumping of hazardous substances.

4.5 Other Relevant Acts, Guidelines, Departmental Policies and Environmental Management Instruments

OTHER RELEVANT ACTS, GUIDELINES, DEPARTMENTAL POLICIES, ENVIRONMENTAL MANAGEMENT INSTRUMENTS

Gert Sibande District Municipality Spatial Development Framework (2009)

South African National Standard SANS 10103:2008 (The Measurement and Rating of Environmental Noise with Respect to Annoyance and Speech Communication)

National Noise Control Regulations (1998)

Sasol Safety, Health and Environmental Policy


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5 PUBLIC PARTICIPATION One of the general objectives of integrated environmental management laid down in Section 23(2)(d) of NEMA is to “ensure adequate and appropriate opportunity for public participation in decisions that may affect the environment”. An inadequate and non-transparent public participation process (PPP) has the potential to provide a negative decision and perception regarding the proposed project.

The EIA Regulations (2010) places a lot of emphasis on the public participation process and have been revised to contain comprehensive guidelines to involve the public in the EIA study.

The primary aims of the public participation process include:

Meaningful and timeous participation of interested and affected parties (I&APs);

Identification of issues and concerns of key stakeholders and I&APs with regards to the proposed development, i.e. focus on important issues;

Promotion of transparency and an understanding of the proposed project and its potential environmental (social and biophysical) impacts;

Accountability for information used for decision-making;

Serving as a structure for liaison and communication with I&APs;

Assisting in identifying potential environmental (social and biophysical) impacts associated with the proposed development; and

Inclusivity (the needs, interests and values of I&APs must be considered in the decision-making process).

The minimum requirements for public participation as contained in Chapter 6 of the EIA Regulations (2010) are contained hereunder and are discussed in detail in subsequent sections:

Public Participation Requirements according to Section 54 - 57 of GN R 543

Specific Actions to Ensure Compliance

Section 54 (2) (b) – The person conducting a public participation process must give written notice to the owner or person in control of that land if the owner is not the owner or person in control of the land; owners and occupiers of land adjacent to the site municipal councilor; municipality; organ of state having jurisdiction and any other party required by the competent authority.

Compile introductory letters to owners, adjacent landowners, municipal councilor, municipality and organ of state.

Section 54 (2) (a) – Fix a notice board at the site boundary or any alternative site applicable to the application

The notice board accordingly must – (a) give details of the application subject to public participation (b) state –

i. that the application has been submitted to the CA ii. whether basic assessment or scoping procedures are

being applied for iii. the nature and location of the activity to which the

application relates iv. where further information on the application or activity

can be obtained v. the manner in which and the person to whom

representation in respect of the application may be made

The notice board must be – (a) Of a size of at least 60cm by 42cm (b) Display the required information in lettering and format

Section 54 (2) (c) & (d) – Place an advert in one local newspaper or official Gazette and or placing an

An advert will be placed in the local newspaper/s and any other paper decided by the applicant to advertise the availability of


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Public Participation Requirements according to Section 54 - 57 of GN R 543

Specific Actions to Ensure Compliance

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 metropolitan or local municipality.

the draft ESR and EIAR for review and public meetings as well advertising the environmental authorisation.

Section 55 (1) – An EAP managing a application must open and maintain a register which contains the names, contact details and addresses of – (a) All persons who as a consequence of the PPP have

submitted written comments or attended meetings (b) All persons after completion of the PPP have

requested in writing their names to be placed on a register

(c) All organs of state which have jurisdiction in respect of the application.

Comprehensive I&AP database/register will be opened and maintained.

Section 56 (1) a registered interested and affected party (I&AP) is entitled to comment, in writing, on all written submissions; including draft reports made to the CA within the timeframes that have been set by the CA or any extension of a timeframe agreed to by the EAP or applicant.

According to Section 56 (8) a timeframe of 40 days is provided to I&APs for comments on draft and final reports.

Section 56 (5) Registered I&APs must submit comments on draft reports to the EAP.

According to Section 56 (8) a timeframe of 40 days is provided to I&APs for comments on draft reports. All issues will be recorded in a Comments and Response Report.

Section 56 (6) Comments on final reports must be provided to the CA and a copy provided to the EAP.

A timeframe of 21 days is provided for registered I&APs to comment on the final reports. All comments must be forwarded to the CA and a copy furnished to the EAP.

Section 57 (1) The EAP must ensure that the comments of I&APs are recorded in reports and written comments including record of meetings are attached to the report submitted to the CA.

Compilation of Issues Trail/Comments and Responses Report that will form part of final reports.

5.1 Consultation with the Competent Authority The competent authorities issuing decisions regarding the project as well as consultation to date are presented in the table below.

Table 8: Competent Authorities and other relevant authorities associated with the project

Authority Role License / Approval Consultation to date

Department of Environmental Affairs (DEA)

Competent Authority for Waste Licensing process

Waste Management License

Submission on 01 March 2013 and acceptance of waste license application form received on 07 March 2013 (see Appendix B).

Mpumalanga Department of Economic Development,

Environment and Tourism (MDEDET)

Competent Authority for Environmental Authorisation

Environmental Authorisation

Submission on 01 March 2013 and acceptance of Environmental Authorization application received on 14 March 2013


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Authority Role License / Approval Consultation to date

(see Appendix B).

5.2 Consultation with Other Relevant Stakeholders Consultation with other relevant key stakeholders will be undertaken through telephone calls and written correspondence in order to actively engage these stakeholders from the outset and to provide background information about the project during the Environmental Scoping Study. These stakeholders include:

CONTACT PERSON ORGANISATION

NON-GOVERNMENTAL ORGANISATIONS (NGOs)

Andrew Rossaak WESSA: Regional Chairperson

Carolyn Ah Shene-Verdoorn Birdlife South Africa

Marianna Nieuwoudt Olifants River Forum

Siziwe Khanyile groundWork

Rico Euripidou groundWork

PROVINCIAL GOVERNMENT

Martha Mokonyane Department of Mineral Resources

JM van Aswegen Department of Water Affairs

Sibongisani Sibiya Department of Labour

Frans Krige Mpumalanga Tourism and Parks Agency

Thamsanqa Xesibe Department of Water Affairs

Israel Silinda Department of Agriculture, Rural Development and Land Administration

A Van Niekerk DEDET, Acting Director: Policy Planning and Information Management

Philip Hine SAHRA

Dan Hlanyane Eastvaal District Council

LOCAL MUNICIPALITY

SS Nkosi Govan Mbeki Municipality

Sibongile Zibakalala Govan Mbeki Municipality

Willie Coetzee Govan Mbeki Municipality

LH Mathunyane Govan Mbeki Municipality: Municipal Manager

Kamesh Rohan Govan Mbeki Municipality - Technical and Engineering section

Bongani Cedric Malaza Govan Mbeki Municipality

Albert Olivier Govan Mbeki Municipality

GOVAN MBEKI LOCAL MUNICIPALITY COUNCILLORS

Philisiwe Nzama Embalenhle: Ward 4


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CONTACT PERSON ORGANISATION

C Gwiji Embalenhle: Ward 7

D Mahlangu Embalenhle: Ward 9

Johana Ndlovu Embalenhle: Ward 10

A Motaung Embalenhle: Ward 11

Thabo Tsotetsi Embalenhle: Ward 8

Nick Mathabe Embalenhle: Ward 12

T Mtsweni Embalenhle: Ward 19

Simon Mabena Embalenhle: Ward 20

Timothy Denny Secunda: Ward 5

Angela van Royen Secunda: Ward 21

Naomi Victor Secunda: Ward 25

Tarnia Baker Secunda: Ward 30

OTHER STAKEHOLDERS

Attie Jankowitz Waterval Forum

Richard Morajane Secunda Cosatu Local

Len Roodtman Waterval Forum - Harmony

Johannes Nkosi Embalenhle Recreactional Environment Club

Hennie du Preez Goedehoop Primary School

FJ Papendorp Highveld Ridge Primary School

Francois Rohrbeck Secunda Fire Department

Nomsa Mahlangu Community Police Forum

5.3 Advertising In compliance with the EIA Regulations (2010), notification of the commencement of the EIA process for the project was advertised in English, Afrikaans and Zulu in the two local newspapers, namely the Ridge Times and Echo News on 22 March 2013 (refer to Appendix C). Interested and affected parties (I&APs) were requested to register their interest in the project and become involved in the EIA process. The primary aim of these advertisements was to ensure that the widest group of I&APs possible was informed and invited to provide input and questions and comments on the project. In addition to advertisements, A3 size site notices in English, Afrikaans and Zulu were placed at the following public places advertising the EIA process for the project: Charlie One - Main gate to Sasol Secunda Complex Offices of the Govan Mbeki Local Municipality Secunda Municipal Library Sasol Club Photos of the site notices placed at the various places are included in Appendix C.


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5.4 Identification of Interested and Affected Parties I&APs were identified primarily through an existing database as well as from responses received from the site notices mentioned above. Letters were sent to key stakeholders and other I&APs on the existing database, informing them of the application for the project, the availability of the draft Environmental Scoping Report (ESR) for review and indicating how they could become involved in the project. The contact details of all identified I&APs are updated on the project database, which is included in Appendix C. This database will be updated on an on-going basis throughout the EIA process.

5.5 Briefing Paper A briefing paper or Background Information Document (BID) for the project was compiled in English, Afrikaans and Zulu (refer to Appendix C). The aim of this document is to provide a brief outline of the application and the nature of the development. It is also aimed at providing preliminary details regarding the EIA process, and explains how I&APs could become involved in the project. The briefing paper was distributed to all identified I&APs and stakeholders, together with a registration/comment sheet inviting I&APs to submit details of any issues, concerns or inputs they might have with regards to the project.

5.6 Issues Trail Issues and concerns raised in the public participation process during the EIA process will be compiled into an Issues Trail. The ESS-phase Issues Trail will be included into the final Environmental Scoping Report, in which all comments will be captured. This Issues Trail will reflect the issues raised by I&APs during consultation, and will provide an indication of particular areas within which concerns were underscored.

5.7 Public and Authority Review of the Draft Scoping Report An advert will be placed in the Ridge Times and Echo News informing I&APs of the application and the availability of the draft ESR and Plan of Study for EIA for review and comment. The Echo News and Ridge Times are free weekly community newspapers. The advert will appear in both newspapers on 29 March 2013. A copy of the advertisements is included in Appendix C. Additionally, all registered I&APs were notified of the availability of the report in writing. The draft ESR, together with the Plan of Study for EIA is being made available for authority and public review for a total of 40 calendar days from 03 April 2013 to 22 May 2013. In addition, the report will also be made available at the following public locations (which are all readily accessible to I&APs) within the study area: Secunda Municipal Library Sasol Technology Library Embalenhle Municipal Library Offices of Royal HaskoningDHV (78 Kalkoen Street, Monument Park, Pretoria) Royal HaskoningDHV website (http://www.rhdhv.co.za/pages/services/environmental/current-projects.php)

The draft ESR will be submitted simultaneously to the DEA and MDEDET.

5.8 Final Environmental Scoping Report The final stage in the Environmental Scoping Study process will entail the capturing of responses and comments from I&APs on the draft ESR in order to refine the ESR, and ensure that all issues of significance are addressed. The final Environmental Scoping Report will be submitted to DEA and MDEDET for review and decision-making.

DRAFT ENVIRONMENTAL SCOPING REPORT FOR THE PROPOSED SASOL SCC COLD SIDE CAPACITY ENABLEMENT MT-9: HEAVIES AND OXYGENATE REMOVAL AT THE SASOL SECUNDA INDUSTRIAL COMPLEX,

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6 GENERAL DESCRIPTION OF THE STUDY AREA

6.1 Geology Sasol’s Secunda plant is underlain by rocks belonging to the Vryheid Formation of the Ecca Group, Karoo Supergroup. These rocks primarily consist of sandstones, shales and coal beds and are extensively intruded by dolerites of Jurassic age. The dolerites occur both as sills and linear dyke structures that may extend over tens of kilometers.

6.2 Topography and Soils The topography of the greater study area is relatively flat and stable with little agricultural potential. The greater study area falls within the Karoo Supergroup, however the proposed site is highly transformed. The highest point of the site elevation is 1600 m above sea level. Soils in the proposed area have been disturbed with the historical establishment of the Secunda Complex in the 1970’s where the existing soil was replaced with a 1:1 mixture of dolerite and ash. The importation and compaction of fill material has inherently created a near impermeable soil horizon, minimizing the potential for the ingress of contaminants from surface into the underlying subsoil.

6.3 Water Resources

6.3.1 Geohydrology (Groundwater) The groundwater at the Sasol Complex is characterised by two groundwater aquifers, including a weathered aquifer occurring at a depth of between 8 and 14 m below existing ground level, and a fractured rock aquifer occurring at depths greater than 20 m below existing ground level. The weathered aquifer occurs within the weathered shale, siltstone and mudstones of the Karoo Formation, this aquifer consequently has a low permeability of, on average, 0.005 m/day, whereas the fractured rock aquifer has a very low permeability of, on average, 0.0004 m/day. The low permeability’s of the weathered and fractures rock aquifer will limit the movement of contaminants within the groundwater system. Groundwater flows in a northerly direction towards the Klipspruit with a relatively low hydraulic gradient of 0.08, based on topographical elevations.

6.3.1.1 Groundwater Quality Monitoring boreholes located within the factory and to the north of the Klipspruit have indicated the character of the groundwater quality to be dominated by inorganic components, calcium, sodium, nitrate, ammonia, sulphate, iron and manganese. As could be expected, groundwater quality monitoring boreholes in close proximity of contaminant sources reflect localized elevated contaminant levels. Usually, this occurs at a shallow depth of about 5 m. However, it should be noted that background total dissolved concentrations in boreholes within the greater Secunda area could reflect values up to about 850 mg/l. It is noted that a 5 km exclusion zone has been established in terms of groundwater abstractive use around the Complex. Consequently, there are no direct users of groundwater within the area of potential influence.

6.3.2 Hydrology (Surface Water) The Sasol Secunda Industrial and Mining Complex is located in the upper reaches of the Waterval River, affecting the following tributaries of this river: Klein and Groot Bossiespruit Brandspruit Klipspruit Trichardspruit


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The above streams combine into the Trichardspruit and after the confluence with the Grootspruit, the Trichardspruit joins the Waterval River. The water quality and flow profile of the Waterval River changed substantially from the time Sasol Industrial and Mining Complex was established in the late 1970’s. A notable portion of the salinity generated in the Waterval River catchment now originates from the Trichardspruit sub-catchment in which the Sasol Secunda Industrial and Mining Complex is located.

6.3.2.1 Surface Water Quality Sasol Synfuels monitors the quality of water in the adjacent surface water streams in accordance with license conditions. A review of Sasol Synfuels monitoring data for the Klipspruit (RESM 17) being the upper catchment, RESM 7 being midpoint of the Northern Boundary section of the Klipspruit of the Complex and RESM 6 being at the Charlie 2 Bridge exit of the Northern Boundary section of the Klipspruit, indicates some variability in water quality, principally associated with the seasonality of flow in the Klipspruit, and extended periods of no flow or low flow. The surface water qualities are principally characterised by the presence of inorganics. Elevated salts concentrations have been observed to occur during periods of relatively high flow, suggesting that salts accumulated in the upper catchment are washed into the Klipspruit at such times. It is noted that stormwater is not released directly to the Klipspruit from the Complex but routed through the API containment dams and quality checked for compliance before release, treatment or reuse. RESM 11 and 13 are surface water quality monitoring points on the Bossiespruit, forming the southern boundary of the Sasol Synfuels Complex. RESM 1 is the water use license compliance monitoring point after the convergence of the Bossiespruit and the Klipspruit and prior to the watercourse leaving the Complex boundary.

6.4 Climate and Local Weather Conditions Local meteorological data was obtained from Sasol which operates a network of monitoring stations in the area. Meteorological data for the period Jan 2011 – Dec 2012 was obtained from the Club and Langverwacht stations. Meteorological parameters recorded at these stations include wind speed, wind direction, temperature, humidity and solar radiation. Given the close proximity of these stations to the plant, data from these stations is considered to be representative of the prevailing meteorological conditions in the area.

6.4.1 Wind Wind roses comprise of 16 spokes which represent the directions from which winds blew during the period. The colours reflect the different categories of wind speeds. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. Based on an evaluation of the meteorological data provided, winds for both stations generally predominate from the north-easterly and north-westerly sectors ( Figure 4). However, winds at the Club station have a higher frequency of occurrence from the north-westerly sector than observed at the Langverwacht station. In general, moderate to fast winds are recorded at both stations, although faster winds are noted to occur at the Langverwacht station. Calm wind speeds, which are designated as wind speeds less than 0.5 m/s, occur infrequently at both stations.


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Figure 4: Period wind roses for the Sasol Club (left) and Langverwacht (right) monitoring

stations for the period Jan 2011 – Dec 2012 A diurnal trend in the wind field is recorded at both stations (Figure 5). At the Club station, winds originate predominantly from the north-east, east-north-east and east during the night–time (18:00 – 06:00). A shift is observed during the day-time (06:00 – 18:00), with a higher frequency of winds originating from the west-north-west over this period. At the Langverwacht station, winds originate predominantly from the east-north-east and north-east during the night-time (Figure 5). During the day-time, winds occur with a higher frequency of occurrence from the westerly and northerly sectors. As would be expected, faster winds are recorded during the day-time period compared to the night-time at both stations.


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00:00 – 06:00

06:00 – 12:00

12:00 – 18:00 18:00 – 24:00

00:00 – 06:00

06:00 – 12:00

12:00 – 18:00

18:00 – 24:00

Figure 5: Diurnal wind roses for the Sasol Club (top) and Langverwacht (bottom) monitoring

stations for the Period Jan 2011 – Dec 2012

The seasonal variability in the wind field at both stations is shown in Figure 6.

A similar wind field is recorded at the Club station during all seasons, with winds originating predominantly from the westerly and easterly sectors. Winds occur with a higher frequency of occurrence from the easterly sector during the spring (September, October and November) and summer months (December, January and February). At the Langverwacht station, winds originate predominantly from the north-east, south-west during the spring and summer months. During autumn


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and winter, a different wind field is observed with additional components recorded from the north-east and north-west during these seasons.

Summer

Autumn

Winter

Spring

Summer Autumn Winter Spring

Figure 6: Seasonal wind roses for the Sasol Club (top) and Langverwacht (bottom) monitoring stations for the period Jan 2011 – Dec 2012


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6.4.2 Atmospheric Stability The tendency of the atmosphere to resist or enhance vertical motion and thus turbulence is termed atmospheric stability. Stability is related to both the change of temperature with height and wind speed. A neutral atmosphere neither enhances nor inhibits mechanical turbulence. An unstable atmosphere enhances turbulence, whereas a stable atmosphere inhibits mechanical turbulence. The turbulence of the atmosphere is the most important parameter affecting dilution of air pollution as the more unstable the atmosphere, the greater the dilution of air pollution.

Atmospheric stability is commonly categorised into six stability classes (Table 9). The atmospheric boundary layer is usually unstable during the day due to turbulence caused by the sun's heating effect on the earth's surface. The depth of this mixing layer depends mainly on the amount of solar radiation, increasing in size gradually from sunrise to reach a maximum at about 5 - 6 hours after sunrise. The degree of thermal turbulence is increased on clear warm days with light winds. During the night-time a stable layer, with limited vertical mixing, exists. During windy and/or cloudy conditions, the atmosphere is normally neutral.

Table 9: Atmospheric stability classes

A Very unstable calm wind, clear skies, hot daytime conditions

B Moderately unstable clear skies, daytime conditions

C Unstable moderate wind, slightly overcast daytime conditions

D Neutral high winds or cloudy days and nights

E Stable moderate wind, slightly overcast night-time conditions

F Very stable low winds, clear skies, cold night-time conditions

G Most stable Associated with worst case dispersion conditions

In general, the site experiences the worst case scenario stablilty class (Class G) see Figure 7. This is expected given the predominance of a high-pressure anticyclone over South Africa which produces stable, clear conditions.


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Figure 7: Stability class frequency distribution for Sasol Club (top) and Langverwacht (bottom) monitoring stations

6.4.3 Temperature and Humidity Temperature affects the formation, action, and interactions of pollutants in various ways1. Chemical reaction rates tend to increase with temperature and the warmer the air, the more water it can hold and hence the higher the humidity. When relative humidity exceeds 70%, light scattering by suspended particles begins to increase, as a function of increased water uptake by the particles2. This results in decreased visibility due to the resultant haze. Many pollutants may also dissolve in water to form acids. Temperature also provides an indication of the rate of development and dissipation of the mixing layer. Average monthly temperature and humidity at both stations for the period Jan 2008 – Dec 2012 are given in Figure 8 and

Figure 9. Daily average summer temperatures range between ~18°C and ~19 °C while winter temperatures range between ~7 °C and ~12 °C. Relative humidity is lowest during autumn and winter and highest in summer and spring.

1 Kupchella, C.E. and M.C. Hyland, 1993. Environmental Science. Living Within the System of Nature. Prentice

Hall, New Jersey. 2 CEPA/FPAC Working Group, 1999. National Ambient Air Quality Objectives for Particulate Matter. Part 1:

Science Assessment Document. Minister, Public Works and Government Services, Ontario. Available at URL: http://www.hc-sc.gc.ca/bch.


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Figure 8: Average monthly temperature and humidity for Sasol Club for the period Jan 2008 – Dec 2012

Figure 9: Average monthly temperature and humidity for Langverwacht for the period Jan 2008

– Dec 2012

6.4.4 Precipitation The area under investigation lies in the summer rainfall region of South Africa, receiving a total annual rainfall of 418 mm for the Club site during 2006 and 603.6 mm for the Langverwacht site during the same period.

6.5 Air Quality On 23 November 2007, the Highveld was declared a priority area, referred to as the Highveld Priority Area, in terms of section 18(1) of the National Environmental Management: Air Quality Act, 2004 (Act No 39 of 2004). This implies that the ambient air quality within the Highveld Priority Area exceeds or


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may exceed ambient air quality standards, alternatively, that a situation exists within the Highveld Priority Area, which is causing or may cause a significant negative impact on air quality in the area, and that the area requires specific air quality management action to rectify the situation. The area declared as such, includes inter alia the local municipalities of Govan Mbeki, Dipaleseng, Lekwa, Msukaligwa, and Pixley ka Seme. Hence, five of the seven local municipalities constituting the District form part of the Highveld Priority Area.

6.5.1 Identified Sensitive Receptors A sensitive receptor for the purposes of the current investigation is defined as a person or place where involuntary exposure to pollutants released by the project could take place. Receptors surrounding Sasol were identified from satellite images and are given in Table 10. Local communities in close proximity to Sasol include the towns of Secunda, Evander and Trichardt with the informal area of Embalenhle to the immediate west of the Sasol Complex.

Table 10: Identified sensitive receptors surrounding the site

Receptor Name Distance from Plant Direction from Plant

Secunda ~3 km NNE

Embalenhle ~5 km W

Evander ~7 km NNW

Trichardt ~8 km NE

Kinross ~ 15 km NW

Standerton ~ 15 km SW

Springbokdraai ~13 km W

Brendan Village ~15 km NW

6.5.2 Existing Sources of Air Pollution The Sasol Complex falls within the Highveld Priority Area which was declared a priority area by the Minister of Environmental Affairs and Tourism on 23 November 2007. The Highveld area in South Africa is characterised by poor ambient air quality and elevated concentrations of criteria pollutants due to the concentration of industrial and non-industrial sources3. The priority area is comprised of parts of Gauteng and Mpumalanga Provinces4. Secunda was identified to be an air quality ‘hotspot’ in the Highveld Priority Area Air Quality Management Plan due to frequent exceedances of the SO2 standards, mainly due to emissions from the petrochemical industry and energy sector in the region. Emission reduction measures, not specific to each industrial sector, have been recommended in the Air Quality Management Plan5. Such measures include the: Development and maintenance of a site emission inventory, including greenhouse gases; Development and implementation of a plant maintenance plan; Development of a fugitive emission management plan; Implementation of appropriate interventions to reduce fugitive emissions; Installation and maintenance of appropriate abatement technologies; Research into improving abatement technology and reducing retrofitting costs.

3 Held G., Gore B.J., Surridge A.D., Tosen G.R., Turner C.R. and Walmsley R.D. (eds), 1996. Air pollution

and its impacts on the South African Highveld, Environmental Scientific Association, Cleveland, South Africa.

4 Zunckel., M, Naicker, Y., Raghunandan, A., Fischer, T., Crouse, H., Ebrahim, A and Carter, W., 2011. The Highveld Priority Area Air Quality Management Plan, Department of Environmental Affairs, Pretoria.

5 Ibid. Footnote 4.


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Sources of air pollution within the immediate area surrounding the plant were identified from satellite imagery and a site description of the area. Surrounding sources were identified to be: Agriculture; Domestic Fuel Burning; Mining Activities; Veld Fires; Power stations; and Other Sasol operations. A qualitative discussion of each identified sources is provided in the subsections below. The aim is to highlight the potential contribution of surrounding sources to the overall ambient air quality situation in the area. These sources have not been quantified as part of this assessment, rather a qualitative assessment of impacts is provided.

6.5.3 Agriculture Agricultural activity can be considered a significant contributor to particulate emissions, although tilling, harvesting and other activities associated with field preparation are seasonally based. The main focus internationally with respect to emissions generated due to agricultural activity is related to animal husbandry, with special reference to malodours generated as a result of the feeding and cleaning of animal. The types of livestock assessed included pigs, sheep, goats and chickens. Emissions assessed include ammonia and hydrogen sulphide6. Little information is available with respect to the emissions generated due to the growing of crops. The activities responsible for the release of particulates and gases to atmosphere would however include: Particulate emissions generated due to wind erosion from exposed areas; Particulate emissions generated due to the mechanical action of equipment used for tilling and

harvesting operations; Vehicle entrained dust on paved and unpaved road surfaces; Gaseous and particulate emissions due to fertilizer treatment; and Gaseous emissions due to the application of herbicides and pesticides.

6.5.4 Domestic Fuel Burning

Due to the close proximity of residential developments, it is anticipated that low income households in the area are likely to combust domestic fuels for space heating and/ or cooking purposes. Exposure to indoor air pollution (IAP) from the combustion of solid fuels is an important cause of morbidity and mortality in developing countries. Biomass and coal smoke contain a large number of pollutants and known health hazards, including PM, CO, NO2, SO2 (mainly from coal), formaldehyde, and polycyclic organic matter, including carcinogens such as benzo[a]pyrene7. Exposure to indoor air pollution (IAP) from the combustion of solid fuels has been implicated, with varying degrees of evidence, as a causal agent of several diseases in developing countries, including acute respiratory infections (ARI) and otitis media (middle ear infection), chronic obstructive pulmonary disease (COPD), lung cancer (from coal smoke), asthma, cancer of the nasopharynx and larynx, tuberculosis, perinatal conditions and low birth weight, and diseases of the eye such as cataract and blindness8.

6 U.S Environmental Protection Agency, 1996. Compilation of Air Pollution Emission Factors (AP-42), 6th

Edition, Volume 1, as contained in the AirCHIEF (AIR Clearinghouse for Inventories and Emission Factors) CD-ROM (compact disk read only memory), US Environmental Protection Agency, Research Triangle Park, North Carolina. Also available at URL: http://www.epa.gov/ttn/chief/ap42/.

7 Ezzati, M. and D.M. Kammen, 2002. Environmental Health Perspective. The health impacts of exposure to indoor air pollution from solid fuels in developing countries: Knowledge, Gaps and data needs. Risk Resource and Environmental Management Divisions, Resources for the future, Washington DC, USA, Energy and Resources Group and Goldman School of Public Policy, University of California, Berkley California, USA.

8 Ibid. Footnote 7.


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Monitoring of pollution and personal exposures in biomass-burning households has shown concentrations are many times higher than those in industrialized countries. The latest International Ambient Air Quality Standards for instance, required the daily average concentration of PM10 to be < 180 µg/m3 (annual average < 60 µg/m3). In contrast, a typical 24-hr average concentration of PM10 in homes using bio fuels may range from 200 to 5000 µg/m3 or more throughout the year, depending on the type of fuel, stove, and housing. Concentration levels, of course, depend on where and when monitoring takes place, because significant temporal and spatial variations may occur within a house. Field measurements, for example, recorded peak concentrations of > 50 000 µg/m3 in the immediate vicinity of the fire, with concentrations falling significantly with increasing distance from the fire. Overall, it has been estimated that approximately 80% of total global exposure to airborne particulate matter occurs indoors in developing nations. Levels of CO and other pollutants also often exceed international guidelines9. Although a high percentage of households in the area are electrified, the burning of domestic fuels for heating and cooking purposes is likely to occur in informal areas surrounding Sasol. Even in electrified areas, households make use of domestic fuels due to high electricity costs and the traditional use of such fuels. Based on the Census 2001, coal and paraffin are predominantly also used in the nearby informal area of Embalenhle, which is located approximately 5 km to the west of Sasol.

6.5.5 Mining Activities Mining activities surrounding Sasol include Winkelhaak Mines (Evander Goldfield). Mining activities and the extraction of material results in the formation of discard or slimes dams to accommodate the waste material. The surrounding residential areas of Evander, Embalenhle, Secunda and Trichardt will likely be exposed to elevated dust levels from the neighbouring slimes dams. Dust originating from slimes dams has in recent times become more than a nuisance factor. The health implications of this dust are now being studied in more detail and as the information becomes available local communities are becoming more emotional and concerned in regards to their health.

6.5.6 Veld Fires A veld fire is a large-scale natural combustion process that consumes various ages, sizes, and types of flora growing outdoors in a geographical area. Consequently, veld fires are potential sources of large amounts of air pollutants that should be considered when attempting to relate emissions to air quality. The size and intensity, even the occurrence, of a veld fires depend directly on such variables as meteorological conditions, the species of vegetation involved and their moisture content, and the weight of consumable fuel per hectare (available fuel loading). Once a fire begins, the dry combustible material is consumed first. If the energy released is large and of sufficient duration, the drying of green, live material occurs, with subsequent burning of this material as well. Under suitable environmental and fuel conditions, this process may initiate a chain reaction that results in a widespread conflagration. It has been hypothesized, but not proven, that the nature and amounts of air pollutant emissions are directly related to the intensity and direction (relative to the wind) of the veld fire, and are indirectly related to the rate at which the fire spreads. The factors that affect the rate of spread are (1) weather (wind velocity, ambient temperature, relative humidity); (2) fuels (fuel type, fuel bed array, moisture content, fuel size); and (3) topography (slope and profile). However, logistical problems (such as size of the burning area) and difficulties in safely situating personnel and equipment close to the fire have prevented the collection of any reliable emissions data on actual veld fires, so that it is not possible to verify or disprove the hypothesis. The major pollutants from veld burning are PM, CO and VOCs. Nitrogen oxides are emitted at rates of from 1 to 4 g/kg burned, depending on combustion temperatures10. Emissions of SOx are negligible11. A study of biomass burning in the African savannah estimated that the annual flux of particulate

9 Ibid. Footnote 7. 10 Ibid. Footnote 6. 11 Ibid. Footnote 6.


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carbon into the atmosphere is estimated to be of the order of 8 Tg C, which rivals particulate carbon emissions from anthropogenic activities in temperate regions12.

6.5.7 Power Stations There are numerous Eskom coal powered stations such as Duvha, Kriel and Tutuka that are located within the Highveld Priority area. During power generation airborne pollutants such as particulate matter (PM10 and PM2.5),sulphur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO), carbon dioxide (CO2) and might contain traces of other metals including Mercury (Hg). The burning of coal for power generation results in significant emissions being generated, the majority of particulates, sulphur dioxide and nitrogen dioxide is emitted by power generation operations. Various mitigation measures have been put in place at the stations to reduce the emissions before entering the atmosphere, these include bag filters or electrostatic precipitator (ESPs) for the removal of particulate matter and ash, scrubbers for sulphur dioxide and over air burners for oxides of nitrogen, this is done to ensure that the goals set out in the Highveld Priority Area Air Quality Management Plan will be reached. .

6.5.8 Other Sasol Operations The Sasol chemical complex in Secunda operates numerous chemical processes in manufacturing of olefins, surfactants, polymers, solvents, ammonia, wax etc. The emissions released by the manufacturing processes (SO2, NO2, CO, CO2, PM10 and PM2.5) have a localised or micro-scale effect on the ambient air quality of the region. Thus the concentrations of the airborne pollutants will be higher at the source, next to the proposed new facility.

The final air quality impact assessment will need to investigate the impact these close to source emitters will have on the assessment. The airborne volatile organic compounds that are also released onsite will need to be investigated to accurately determine the total dispersion of these pollutants within the micro scale region of the study area.

6.5.9 Sasol SCC project on the existing ambient concentrations

The proposed project by Sasol will be within the Sasol Industrial plant boundary. The air quality impact is not likely to go beyond the property boundary, thus the cumulative effect beyond the property boundary will be minimal if any.

6.5.10 Other – Motor Vehicles

Motor vehicle emissions are composed of the by-products of fuel combustion that come out of the exhaust systems or from gasoline evaporation. These emissions contribute to air pollution and are a major ingredient in the creation of smog in some large cities. As the number of vehicles increase per year and the distance each vehicle travels increases the effect on the local air quality can be detrimental. The pollutants emitted by motor vehicles are: particulate matter (PM10, PM2.5 and PM1), hydrocarbons (HC’s), oxides of nitrogen (NOx), carbon monoxide (CO), sulphur dioxide (SO2), hazardous air pollutants (toxins) and Greenhouse gases (GHG’s).

6.5.11 Air Quality Status Quo Sasol operates meteorological and ambient air quality monitoring stations in Secunda (Club, Bossiespruit and Langverwacht). These stations measure meteorological and pollutant parameters including ambient CO, SO2, H2S, NO, NO2, O3, PM10 and BTEX concentrations. The Department of Environmental Affairs (DEA) also operates an ambient air quality monitoring station in eMbalenhle.

12 Cachier, H., Liousse, C., Buat-Menard, P. and Gaudichet, A. 1995. Particulate content of savanna fire

emissions. J. Atmos. Chem., 22(1-2), 123-148.


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For the purpose of this assessment, ambient PM10, SO2, and NO2 concentrations are summarised in the section below as these are the main pollutants released from the proposed activities for which there is available monitoring data. Reference is made to the National ambient air quality standards for compliance purposes.

Figure 10: Location of the Sasol and Department of Environmental Affairs’ air quality monitoring stations

6.5.12 PM10 Concentrations

Daily average PM10 concentrations generally fall below the current National daily standard of 120 µg/m3 at the Sasol stations, although nine and twelve exceedances were recorded at the Langverwacht station during 2011 and 2012 respectively, it resulted in a non-compliance (Figure 11: ) according to the NEM: AQA. Maximum daily average concentrations range from 86.7 – 97.9 µg/m3 at the Club station and 157.9 – 284.3 µg/m3 at the Langverwacht station. The seasonal trend can be seen in Figure 10, where ambient PM10 concentrations increase during the winter months due to the prevailing meteorological conditions which promote the stagnation of pollution. Annual average PM10 concentrations are in compliance with the annual standard at the Sasol stations.


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Figure 11: Daily average PM10 concentrations (µg/m3) recorded at the Sasol Stations. The dashed line represents the daily average PM10 standard of 120 µg/m3

A similar diurnal PM10 signature is observed at both Sasol stations, although a sharper morning and evening peak is recorded by the Sasol Langverwacht station (Figure 12: . This diurnal signature is consistent with domestic fuel burning and traffic volumes with elevated concentrations recorded in the early morning (05:00 – 09:00) and evening (17:00 – 21:00) periods. Increased domestic fuel burning together with stable meteorological conditions promotes the increase in pollution during these periods. The difference in the diurnal peaks between seasons can be seen in Figure 13 below.


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Figure 12: Diurnal PM10 concentrations (µg/m3) recorded at the Sasol Stations


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Figure 13: Seasonal diurnal PM10 concentrations (µg/m3) recorded at the Sasol stations

6.5.13 SO2 Concentrations

Maximum hourly daily SO2 concentrations are in compliance with the daily standard of 125 µg/m3 and allowable frequency of exceedance for all stations over the monitoring period, excluding the one exceedance occurrence at Sasol Langverwacht during 2011 (236.84 µg/m3). A seasonal trend is observed in ambient SO2 concentrations although the trend is not as distinct as observed with PM10 concentrations. Maximum daily average concentrations range from 39.0 - 70.8 µg/m3 at the Club station and 53.2 – 236.8 µg/m3 at the Langverwacht station. Annual average SO2 concentrations are in compliance with the annual standard at all stations.


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Figure 14: Daily average SO2 concentrations (ppb) recorded at the Sasol stations

Diurnal SO2 concentrations are given in Figure 15. At the Langverwacht station, an industrial signature is recorded in the diurnal SO2 concentrations, with elevated concentrations during the late morning and early afternoon periods. Pollution from tall stacks is emitted above the surface inversion which forms during the night and only during the day when the inversion is broken the pollutants will be able to reach the ground level. It can be seen that during the winter season months domestic fuel burning is more active, Figure 16.


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Figure 15: Diurnal SO2 concentrations (ppb) recorded at the Sasol stations


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Figure 16: Seasonal diurnal SO2 concentrations (µg/m3) recorded at the Sasol stations

6.5.14 NO2 Concentrations

Maximum hourly average NO2 concentrations are in compliance with the hourly standard of 200 µg/m3 with no exceedances occurring. A seasonal trend is also observed in ambient NO2 concentrations at all stations. Annual average NO2 concentrations are in compliance with the annual standard at all stations.

Figure 17: Hourly average NO2 concentrations (ppb) recorded at the Sasol Stations for the period Jan 2011 – Dec 2012

Diurnal NO2 concentrations are given in Figure 18. A similar diurnal signature is recorded at both stations, with elevated concentrations in the early morning (04:00 – 08:00) and evening (16:00 – 22:00) periods. However, a much sharper peak in concentrations is recorded in the morning at Langverwacht while the evening peak also extends much later at the Langverwacht station. These periods coincide with increased traffic volumes as well as possible emissions from domestic fuel burning (later during the afternoon).


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Figure 18: Diurnal NO2 concentrations (ppb) recorded at the Sasol Stations


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Figure 19: Seasonal diurnal NO2 concentrations recorded at the Sasol Stations

The table below summarises all the baseline air quality results presented above.

Table 11: Air quality summary

PM10 Average SO2 Average NO2 Average

Langverwacht 31.23 6.93 9.24

Club 25.13 6.61 10.12


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6.6 Noise The Sasol Synfuels Complex is a source of existing noise as a result of current industrial processes that are taking place. The noise at the Complex is within 85 dBA.

6.7 Social The proposed project falls within the Govan Mbeki Local Municipality (GMLM) which is located in the north west of the Gert Sibande District Municipality (GSDM). The GMLM has the most diversified economy within the GSDM, dominated by the petrochemical industry (Sasol II and III complexes) and coal and gold mining. Secunda and Embalenhle are the closest town / communities to the study area. The study area extends potentially across much of the Govan Mbeki Municipality, which consists of Secunda, Embalenhle, Kinross, Evander, Trichardt, Charl Cilliers, Leslie / Leandra, Lebohang, Eendracht, Bethal and eMzinoni. The Govan Mbeki Local Municipality has the largest number (53.8% or 99201 people)13 and highest level of employment within the District. This could be attributed to the fact that the GMLM is one of two local municipalities that hosts the majority of all the mining, manufacturing and agricultural activity taking place within the District.

6.8 Land-use The Sasol Synfuels Industrial Complex is surrounded by a number of different land uses i.e. industrial, residential, commercial and agricultural. The middle to high-income residential area of Secunda is located approximately 5 km north-east of the Complex and includes a variety of commercial activities. In turn, the low cost housing development of Embalenhle is located 10 km north-west of the site. Due to the highly industrialised nature of the area there is extensive infrastructural development including an extensive road and rail network.

6.9 Health and Safety The nature of Sasol’s business brings with it substantial inherent safety, health and environmental (SH&E) risks. The group’s annual sustainable development reporting includes a comprehensive list of these potential risks, the most substantial of which are: the risk of fire or explosion at sites that host inventories of flammable hydrocarbons above

ground; risks associated with extensive underground coal operations; and toxicity risks associated with the wide range of hazardous chemicals that are produced. Sasol’s Safety and Health Minimum Requirements are compulsory and applicable to all new projects such as the proposed heavies and oxygenate removal project.

6.10 Heritage The Sasol Synfuels Complex is a highly developed Industrial area that has been in operation for more than 50 years, the landscape has been changed by the development. None of the structures have aesthetic, historic, research or historical significance. There are no sites of archaeological or cultural significance known on the proposed study area.

Sasol will ensure that all requirements of Chapter II, Section 38 of the National Heritage Resources Act, Act 25 of 1999, are complied with in the EIA process and that the comments and/or recommendations of the relevant heritage resources authority responsible for the area in which the development is proposed, are considered.

13 Gert Sibande District Municipality, 2009. Spatial Development Framework.


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7 POTENTIAL IMPACTS ASSOCIATED WITH THE PROJECT

This Environmental Scoping Study (ESS) aims to identify the potential positive and negative impacts (both biophysical and social) associated with the proposed project. The following potential environmental impacts have been considered for the proposed project:

7.1 Construction Phase

Table 12: Potential construction phase impacts

AFFECTED ENVIRONMENT ANTICIPATED IMPACT

Geology Disturbance of surface geology for the development of foundations.

Soils Alteration of topography due to stockpiling of soil, building material, debris and waste material on site.

Removal and compaction of soil during construction activities.

Erosion, degradation and loss of topsoil due to construction activities as well as surface and stormwater runoff.

Contamination of soils due to spillage, leakage, incorrect storage and handling of chemicals, oils, lubricants, fuel and other hazardous material.

Geohydrology (groundwater) and Hydrology (surface water)

Contamination of surface and groundwater due to spillage, leakage, incorrect storage and handling of chemicals, oils, lubricants, fuel and other hazardous material.

Biodiversity (fauna and flora) The site is highly transformed with existing infrastructure. Impact on biodiversity is therefore negligible.

Air Quality During construction, it is expected that the main sources of impact will result due to vehicle movement within the plant area.

Construction usually consists of a series of different operations, each with its own duration and potential for dust generation. Dust emission will vary from day to day depending on the phase of construction, the level of activity, and the prevailing meteorological conditions14.

The following activities have been identified as possible sources of fugitive dust during construction operations at the site:

- Scraping; - Debris handling; - Set up and removal of construction

equipment; and

14 Ibid. Footnote 6.


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- Truck transport and dumping of debris.

Noise Noise will be generated during construction from sources such as vehicles and staff; however with the appropriate mitigation measures in place the impact will be minimal.

Waste The potential waste streams for the project include general and hazardous waste.

General waste generated on site includes domestic waste and building rubble. General waste will not have a significant impact on the environment provided that the correct waste streams are used for the disposal of the waste.

Hazardous waste will be generated through the spillage of raw material e.g. mixed concrete. All material cleared after a spillage must be treated as hazardous waste and disposed of at a hazardous waste disposal site.

Health and Safety The safety of the construction staff could be compromised unless adequate safety measures are implemented.

The safety measures outlined in the draft Environmental Management Programme (EMPr) must be adhered to during construction.

Employment Contractors sourced locally will as far as possible be used during construction.

7.2 Operational Phase

Table 13: Potential operation phase impacts


Soils Contamination of soils due to leakages.

Geohydrology (groundwater) and Hydrology (surface water)

Contamination of surface and groundwater due to spillage, leakage, incorrect storage and handling of oils, lubricants, fuel and other hazardous material.

Potential leaks from bunded areas that could contaminate surface water and groundwater resources.

Air Quality The possible emissions from the incineration of oxygenates will add more SO2 emissions into the ambient air, together with additional NO2.

Waste Generation of general and hazardous waste during operation and maintenance activities.

Health and Safety Hazards associated with the thermal oxidizer may


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include a fire, explosion or the release of toxic fumes, which may affect personnel, equipment and/or property.

Long-term effects on health of individuals due to exposure to aromatic naphtha.

Employment It is not foreseen that any new jobs will be created during operation as existing specialised personnel (e.g. engineers etc) will be used to operate new infrastructure.

Visual The visual impact is already established with the numerous chemical and process plants, pipelines, flares, stacks, roads, railway sidings, buildings and other associated infrastructure.

7.3 Decommissioning Phase At this point of the project planning process, the necessity for and timing of decommissioning of the proposed project is not known. However, like construction impacts, de-commissioning impacts are inherently temporary in duration. Impacts relating to de-commissioning and rehabilitation activities (demolition, landscaping, compaction etc.) will be addressed within the EIA phase and in the Environmental Management Programme.

7.4 Cumulative Impacts Cumulative impacts associated with the project will be further investigated in detail during the EIA study.


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8 CONCLUSIONS AND RECOMMENDATIONS This Environmental Scoping Study (ESS) for the proposed project has been undertaken in accordance with the Environmental Impact Assessment Regulations (2010) published in Government Notices R. 543 of 18 June 2010 read with Section 44, of the National Environmental Management Act, 1998 (Act No. 107 of 1998). In line with Regulation 28 (Part 3) of the EIA Regulations, this issues-based ESS aimed to identify and provide: A description of the proposed activity;

A description of the environment that may be affected by the activity and the manner in which the physical, biological, social, and economic aspects of the environment may be affected by the proposed activity;

The identification of all legislation and guidelines applicable to the development;

A description of environmental issues and potential impacts, including cumulative impacts, that have been identified;

Details of the public participation process conducted to date; and

A Plan of Study for Environmental Impact Assessment (refer to Chapter 9) including the methodology that will be adopted in assessing the potential impacts that have been identified, including specialist studies or specialised processes that will be undertaken.

Based on the Environmental Scoping Study (ESS) undertaken, it can be concluded that there are no fatal flaws associated with the project. Potential environmental impacts have been identified and will be further investigated in the EIA phase. The methodology that will be used for assessment of potential significant impacts is contained in Chapter 9 (Plan of Study for EIA).


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9 PLAN OF STUDY FOR ENVIRONMENTAL IMPACT ASSESSMENT

Potential environmental impacts (biophysical and social) associated with the proposed project have been identified in the Environmental Scoping Study (ESS). No fatal flaws have been identified to date. All potentially significant and cumulative impacts will be further investigated and assessed within the Environmental Impact Assessment (EIA) phase of the project. Mitigation measures will be contained in the Environmental Management Programme (EMPr) to be compiled during the EIA phase. The EIA phase will aim to adequately assess and address all potentially significant environmental issues in order to provide the Mpumalanga Department of Economic Development, Environment and Tourism (MDEDET) and Department of Environmental Affairs (DEA) with sufficient information to make an informed decision regarding the proposed project.

9.1 Approach to undertaking the EIA Phase of the Project The following points below outline the proposed approach to undertaking the EIA phase of the project. It is believed that the proposed approach will adequately fulfil the competent authority’s (MDEDET & DEA) requirements, the requirements of the EIA Regulations (2010) and the objectives of environmental best practice, so as to ensure transparency and to allow an informed decision regarding the project to be made.

9.1.1 Authority Consultation

Ongoing consultation with MDEDET, DEA, the Govan Mbeki Local Municipality, Ward Councillors, and all other authorities identified during the Environmental Scoping Study (ESS) phase of the project (and further ones that may be identified during the EIA phase) will continue throughout the duration of the project. Authority consultation is therefore seen as a continuous process that takes place until completion of the environmental investigations.

9.1.2 Aims of the Environmental Impact Assessment

The EIA will aim to achieve the following: to supplement, where necessary, the assessment of the social and biophysical environments

affected by the development during the Scoping study; to assess impacts on the study area in terms of environmental criteria; to identify and recommend appropriate mitigation measures for potentially significant

environmental impacts; to complete an Environmental Management Programme (EMPr) for the inclusion of proposed

mitigation measures; and to undertake a fully inclusive public participation process to ensure that I&AP issues and concerns

are recorded and addressed.

9.1.3 Detailed Studies to be undertaken in the EIA Phase – Air Quality Impact Assessment

A detailed air quality assessment will be conducted in the EIA phase in order to provide a better indication of the extent of the impacts expected from the proposed treatment of oxygenates by incineration.. During the impact assessment phase a detailed emissions inventory will be compiled to determine the emissions released from the proposed activities. Dispersion modelling simulations will be undertaken using the AERMOD dispersion model and the impacts will be presented graphically as isopleths plots.

9.1.3.1 AERMOD Dispersion Model AERMOD, a state-of-the-art Planetary Boundary Layer (PBL) air dispersion model, was developed by the American Meteorological Society and USEPA Regulatory Model Improvement Committee (AERMIC). AERMOD utilizes a similar input and output structure to ISCST3 and shares many of the


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same features, as well as offering additional features. AERMOD fully incorporates the PRIME building downwash algorithms, advanced depositional parameters, local terrain effects, and advanced meteorological turbulence calculations. The AERMOD atmospheric dispersion modelling system is an integrated system that includes three modules: A steady-state dispersion model designed for short-range (up to 50 km) dispersion of air pollutant

emissions from stationary industrial sources. A meteorological data pre-processor (AERMET) for surface meteorological data, upper air

soundings, and optionally, data from on-site instrument towers. It then calculates atmospheric parameters needed by the dispersion model, such as atmospheric turbulence characteristics, mixing heights, friction velocity, Monin-Obukov length and surface heat flux.

A terrain pre-processor (AERMAP) which provides a physical relationship between terrain features and the behaviour of air pollution plumes. It generates location and height data for each receptor location. It also provides information that allows the dispersion model to simulate the effects of air flowing over hills or splitting to flow around hills.

9.1.3.2 Model Requirements Input data requirements for AERMOD include meteorological and geophysical (terrain) data, model grid specifications as well as emissions source data. Local meteorological data has been obtained from the Sasol Club and Langverwacht monitoring stations for the period Jan 2008 – Dec 2012 and includes hourly observations of wind speed, wind direction, temperature and humidity. Detailed source and emission parameters for input into the model will be obtained during the Impact Assessment phase.

9.1.3.3 Emissions Inventory The emission inventory as mentioned above will include all the necessary input parameters per emission source. The emission inventory will also contain the list of pollutants emitted with a given emission rate. These emission rates need to be provided by the client through a balance sheet or the emission rates will be calculated by proven and published calculations (US EPA AP-42, Australian NPI, or similar). The emission inventory will present the emission rates per pollutant per scenario, the emission inventory will include the origins of the information and if any assumptions were made during the calculations. The airborne pollutants that could arise from the incineration process include but are not limited to, are oxides of nitrogen, carbon monoxide and carbon dioxide.

9.1.4 Impact Assessment Methodology

The potential environmental impacts associated with the project will be evaluated according to it nature, extent, duration, intensity, probability and significance of the impacts, whereby: Nature: A brief written statement of the environmental aspect being impacted upon by a particular

action or activity. Extent: The area over which the impact will be expressed. Typically, the severity and

significance of an impact have different scales and as such bracketing ranges are often required. This is often useful during the detailed assessment phase of a project in terms of further defining the determined significance or intensity of an impact. For example, high at a local scale, but low at a regional scale;

Duration: Indicates what the lifetime of the impact will be; Intensity: Describes whether an impact is destructive or benign; Probability: Describes the likelihood of an impact actually occurring; and Cumulative: In relation to an activity, means the impact of an activity that in itself may not be

significant but may become significant when added to the existing and potential impacts eventuating from similar or diverse activities or undertakings in the area.


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Table 14: Criteria to be used for the rating of impacts

CRITERIA DESCRIPTION

EXTENT

National (4)

The whole of South Africa

Regional (3)

Provincial and parts of neighbouring provinces

Local (2)

Within a radius of 2 km of the construction site

Site (1)

Within the construction site

DURATION

Permanent (4)

Mitigation either by man or natural process will not occur in

such a way or in such a time span that the impact can be

considered transient

Long-term (3)

The impact will continue or last for the entire operational life of

the development, but will be mitigated by direct human action

or by natural processes thereafter. The only class of

impact which will be non-transitory

Medium-term (2)

The impact will last for the period of the construction phase,

where after it will be entirely negated

Short-term (1)

The impact will either disappear with mitigation or will be mitigated through natural

process in a span shorter than the construction phase

INTENSITY

Very High (4)

Natural, cultural and social functions and processes are

altered to extent that they permanently cease

High (3)

Natural, cultural and social functions and processes are

altered to extent that they temporarily cease

Moderate (2)

Affected environment is altered, but natural, cultural and social

functions and processes continue albeit in a modified way

Low (1)

Impact affects the environment in such a way that natural,

cultural and social functions and processes are not affected

PROBABILTY OF

OCCURENCE

Definite (4)

Impact will certainly occur

Highly Probable (3)

Most likely that the impact will occur

Possible (2)

The impact may occur

Improbable (1)

Likelihood of the impact materialising is very low


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Significance is determined through a synthesis of impact characteristics. Significance is an indication of the importance of the impact in terms of both physical extent and time scale, and therefore indicates the level of mitigation required. The total number of points scored for each impact indicates the level of significance of the impact.

Table 15: Significance rating of classified impacts

Low impact

(4 - 6 points)

A low impact has no permanent impact of significance. Mitigation measures are feasible and are readily instituted as part of a standing design, construction or operating procedure.

Medium impact

(7 - 9 points) Mitigation is possible with additional design and construction inputs.

High impact

(10 - 12 points)

The design of the site may be affected. Mitigation and possible remediation are needed during the construction and/or operational phases. The effects of the impact may affect the broader environment.

Very high impact

(13 - 16 points)

Permanent and important impacts. The design of the site may be affected. Intensive remediation is needed during construction and/or operational phases. Any activity which results in a “very high impact” is likely to be a fatal flaw.

Status Denotes the perceived effect of the impact on the affected area.

Positive (+) Beneficial impact.

Negative (-) Deleterious or adverse impact.

Neutral (/) Impact is neither beneficial nor adverse.

The suitability and feasibility of all proposed mitigation measures will be included in the assessment of significant impacts. This will be achieved through the comparison of the significance of the impact before and after the proposed mitigation measure is implemented. Mitigation measures identified as necessary will be included in an EMPr. The EMPr will form part of the Environmental Impact Assessment Report (EIAR).

9.1.5 Environmental Impact Assessment Report

The EIAR will contain the following:

Details of the EAP who compiled the report and their expertise to carry out an EIA;

Detailed description of the activity/ies;

A description of the environment that might be affected by the activity and the manner in which the physical, biological, social, economic and cultural aspects of the environment may be affected by the proposed activity;

Details of the public participation process conducted during the Scoping Phase and the ongoing consultation during the EIA phase;

Description of the need and desirability of the activity including advantages and disadvantages that the activity may have on the environment and the community that may be affected by the activity;

An indication of the methodology used in determining the significance of potential environmental impacts;

A summary of the findings and recommendations of any specialist report or report on a specialised process;


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A description of all environmental issues that were identified during the environmental impact assessment process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures;

An assessment of each identified potentially significant impact, including cumulative impacts, the nature of the impact, the extent and duration of the impact, the probability of the impact occurring, the degree to which the impact can be reversed, the degree to which the impact may cause irreplaceable loss of resources and the degree to which the impact can be mitigated;

A description of any assumptions, uncertainties and gaps in knowledge;

An opinion as to whether the activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation;

An environmental impact statement which contains a summary of the key findings of the environmental impact assessment; and a comparative assessment of the positive and negative implications of the activity.

A draft Environmental Management Programme (EMPr) and

Copies of any specialist reports and reports on specialised processes.

9.1.6 Draft Environmental Management Programme (EMPr)

During the compilation of the EIAR, a draft EMPr will be compiled in accordance with the EIA Regulations (2010). The draft EMPr will provide the actions for the management of identified environmental impacts emanating from the project and a detailed outline of the implementation programme to minimise and/or eliminate the anticipated negative environmental impacts. The draft EMPr will provide strategies to be used to address the roles and responsibilities of environmental management personnel on site, and a framework for environmental compliance and monitoring.

The EMPr will include the following:

Details of the person who prepared the EMPr and the expertise of the person to prepare an EMPr;

Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that have been identified in the EIAR, including environmental impacts or objectives in respect of operation or undertaking of the activities, rehabilitation of the environment and closure where relevant;

A detailed description of the aspects of the activity that are covered by the draft EMPr;

An identification of the persons who will be responsible for the implementation of the measures;

Where appropriate, time periods within which the measures contemplated in the draft EMPr must be implemented;

Proposed mechanisms for monitoring compliance with the EMPr and reporting thereon;

An environmental awareness plan; and

Procedures for managing incidents which have occurred as a result of undertaking the activity and rehabilitation measures.


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9.2 Public Participation Process The primary aims for the public participation process include the following: meaningful and timeous participation of I&APs;

promoting transparency and an understanding of the proposed project and its potential environmental (social and biophysical) impacts;

accountability for information used for decision-making;

serving as a structure for liaison and communication with I&APs;

assisting in identifying potential environmental (social and biophysical) impacts associated with the development; and

the needs, interests and values of I&APs must be considered in the decision-making process.

9.2.1 Advertising The primary aim of adverts in the EIA phase is to provide information regarding the availability of reports for public review, as well as, if necessary, the advertisement of dates of public meeting/s.

9.2.2 Identification of and Consultation with Key Stakeholders The identification of I&APs and key stakeholders will continue into the EIA phase of the project as the public participation process is a continuous process that runs throughout the duration of an environmental study.

9.2.3 I&AP Database All I&AP information (including contact details), together with dates and details of consultations and a record of all issues raised is recorded within a comprehensive database of I&APs. This database will be updated on an on-going basis throughout the project, and will act as a record of the communication/involvement process.

9.2.4 Consultation and Public Involvement Consultation with I&APs is considered to be critical to the success of any EIA process. Therefore, one-on-one consultation (via telephone calls, fax and emails) and a public meeting during the EIA phase will be undertaken. The aim of this process will be to provide I&APs with details regarding the process and to obtain further comments regarding the project. Minutes of all meetings held will be compiled and forwarded to all attendees. These minutes will also be included in the EIAR.

9.2.5 Issues Trail All issues, comments and concerns raised during the public participation process of the EIA study will be compiled into an Issues Trail. This Issues Trail will be incorporated as part of the EIAR.

9.2.6 Public and Authority Review of the Draft Environmental Impact Assessment Report

The draft EIAR will be made available at public places for public review and comment. The draft EIAR will also be submitted to MDEDET and DEA simultaneously. A 40 calendar day period will be allowed for this review process. An advertisement indicating the availability of this report for public scrutiny will be placed in the local newspapers (Echo News and Ridge Times). I&APs registered on the project database will be notified of the availability of this report by correspondence.


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9.2.7 Authority Review of the Environmental Impact Assessment Report After the public review period, all relevant comments received from the public will be considered and included into a final EIAR. This final document will be submitted to MDEDET and DEA for final review and decision-making. All registered I&APs will also be provided with an opportunity to comment on the final EIAR.

9.2.8 Environmental Authorisation and Waste Management License On receipt of the environmental authorisation and waste management license for the project, I&APs registered on the project database will be informed and its associated terms and conditions by correspondence.

Documents

ENVIRONMENTAL SCOPING REPORT FOR THE PROPOSED SCC …