Draft Environmental Impact Report for the Secunda Growth ... SGP-Draft EIR... · DRAFT...

17/2/3/GS-59

Draft Environmental Impact Report for the Secunda Growth Programme (SGP) 1B (New): Proposed Retrofitting of Two Gas Turbines, Mpumalanga

December 2012 A Project for: Sasol Synfuels (Pty) Ltd

Tel: +27 (0) 12 367 5973 Email:[email protected] Fountain Square, 78 Kalkoen Street, Monument Park Ext. 2, Pretoria, 0181

DOCUMENT DESCRIPTION

Client: Sasol Synfuels (Pty) Ltd Project Name: Draft Environmental Impact Report for the Proposed Retroffiting of Two Gas Turbines, Secunda SSI Environmental Reference Number: E02.PTA.000407 Authority Reference: 17/2/3/GS-59 Compiled by: Phyllis Kalele Date: December 2012 Location: Pretoria Reviewer: Prashika Reddy

_____________________________ Signature

Approval: Prashika Reddy ______________________________ Signature

© SSI Environmental 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 SSI Environmental.

TABLE OF CONTENTS

1 INTRODUCTION 1 1.1 NEED AND BACKGROUND 1 1.2 APPROACH TO THE EIA STUDIES 2 1.2.1 ENVIRONMENTAL SCOPING STUDY 2 1.2.2 ENVIRONMENTAL IMPACT STUDY 2 1.3 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER 3 1.4 STRUCTURE OF THE REPORT 4

2 PROJECT DESCRIPTION 5 2.1 PROJECT LOCATION 5 2.2 ELECTRICITY GENERATION FROM AROMATIC NAPHTHA 7 2.3 FACILITIES FOR RETROFITTING THE GAS TURBINES 8

3 PROJECT ALTERNATIVES 11 3.1 SITE ALTERNATIVES – AROMATIC NAPHTHA TANK 11 3.1.1 SITE 1 (PREFERRED) 11 3.1.2 SITE 2 (ALTERNATIVE 1) 11 3.2 NO‐GO ALTERNATIVE 11

4 GENERAL DESCRIPTION OF THE STUDY AREA 12 4.1 GEOLOGY 12 4.2 TOPOGRAPHY AND SOILS 12 4.3 WATER RESOURCES 12 4.3.1 GEOHYDROLOGY (GROUNDWATER) 12 4.3.2 HYDROLOGY (SURFACE WATER) 12 4.4 CLIMATE AND LOCAL WEATHER CONDITIONS 13 4.4.1 WIND 13 4.4.2 ATMOSPHERIC STABILITY 15 4.4.3 TEMPERATURE AND HUMIDITY 16 4.4.4 PRECIPITATION 17 4.5 AIR QUALITY 18 4.5.1 IDENTIFIED SENSITIVE RECEPTORS 18 4.5.2 EXISTING SOURCES OF AIR POLLUTION 18 4.5.3 AGRICULTURE 19 4.5.4 DOMESTIC FUEL BURNING 19 4.5.5 MINING ACTIVITIES 20 4.5.6 VELD FIRES 20 4.5.7 POWER STATIONS 21 4.5.8 OTHER SASOL OPERATIONS 21 4.5.9 AIR QUALITY SITUATION 21 4.6 NOISE 30 4.7 SOCIAL 30 4.8 LAND‐USE 30 4.9 HEALTH AND SAFETY 30 4.10 HERITAGE 30

5 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY AND APPROACH 31 5.1 APPROACH TO UNDERTAKING THE STUDY 31

5.2 ENVIRONMENTAL SCOPING STUDY 31 5.3 AUTHORITY CONSULTATION 31 5.3.1 CONSULTATION WITH DECISION‐MAKING AUTHORITY 31 5.3.2 ENVIRONMENTAL IMPACT ASSESSMENT 31 5.3.3 METHODOLOGY – ASSESSMENT OF IMPACTS 32 5.3.4 IMPACT ASSESSMENT METHODOLOGY 32 5.4 EIA REPORT (EIR) 34 5.5 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 35 5.6 SPECIALIST STUDIES 35 5.7 ASSUMPTIONS AND LIMITATIONS 35

6 PUBLIC PARTICIPATION PROCESS 37 6.1 AIMS OF THE PUBLIC PARTICIPATION PROCESS 37 6.1.1 CONSULTATION WITH RELEVANT AUTHORITIES AND KEY STAKEHOLDERS 37 6.1.2 ADVERTISING 38 6.1.3 IDENTIFICATION OF INTERESTED AND AFFECTED PARTIES 38 6.1.4 I&AP DATABASE 38 6.1.5 ISSUES TRAIL 38 6.1.6 PUBLIC REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT REPORT 39 6.1.7 AUTHORITY REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT REPORT 39 6.1.8 ENVIRONMENTAL AUTHORISATION 39

7 POTENTIAL IMPACTS ASSOCIATED WITH THE PROJECT 40 7.1 CONSTRUCTION PHASE IMPACTS ‐ AROMATIC NAPHTHA TANK 40 7.1.1 GEOLOGY 40 7.1.2 SOILS 40 7.1.3 WATER RESOURCES 42 7.1.4 DUST AND EMISSIONS DURING CONSTRUCTION 43 7.1.5 NOISE 44 7.1.6 WASTE 45 7.1.7 HEALTH AND SAFETY 46 7.1.8 SOCIAL 47 7.2 CONSTRUCTION PHASE IMPACTS – ADDITIONAL INFRASTRUCTURE 48 7.3 OPERATIONAL PHASE IMPACTS ‐ AROMATIC NAPHTHA TANK 51 7.3.1 SOILS 51 7.3.2 GEOHYDROLOGY (GROUNDWATER) AND HYDROLOGY (SURFACE WATER) 52 7.3.3 AIR QUALITY ‐ EMISSIONS 53 7.3.4 WASTE 54 7.3.5 SAFETY 55 7.4 OPERATIONAL PHASE IMPACTS – ADDITIONAL INFRASTRUCTURE ( 56 7.5 CUMULATIVE IMPACTS 59 7.5.1 EMISSIONS 60 7.6 DECOMMISSIONING PHASE 60

8 CONCLUSIONS AND RECOMMENDATIONS 61 8.1 CONCLUDING REMARKS 61 8.2 FINAL RECOMMENDATIONS 62

TABLE OF FIGURES FIGURE 1: ENVIRONMENTAL STUDIES FLOWCHART 3

FIGURE 2: LOCATION OF THE AROMATIC NAPHTHA, MFO, CETANE & OCTANE TANKS AND FLARE 6 FIGURE 3: EXAMPLE OF AN ENCLOSED GROUND FLARE (COURTESY: JOHN ZINK®) 9 FIGURE 4: EXAMPLE OF AN ELEVATED FLARE (COURTESY: JOHN ZINK®) 10 FIGURE 5: PERIOD WIND ROSE FOR SASOL CLUB & LANGVERWACHT STATIONS (JAN 2006 – DEC 2010) 14 FIGURE 6: DIURNAL WIND ROSES FOR SASOL CLUB & LANGVERWACHT STATIONS (JAN 2006 – DEC 2010) 14 FIGURE 7: SEASONAL WIND ROSES FOR SASOL CLUB & LANGVERWACHT STATIONS JAN 2006 – DEC 2010 15 FIGURE 8: STABILITY CLASS FREQUENCY DISTRIBUTION FOR SASOL CLUB & LANGERWACHT STATIONS 16 FIGURE 9: AVERAGE MONTHLY TEMPERATURE & HUMIDITY FOR SASOL CLUB & LANGVERWACHT (JAN 2006

– DEC 2010) 17 FIGURE 10: ANNUAL AVERAGE BENZENE CONCENTRATION (PPB) RECORDED AT TWO SASOL STATIONS 22 FIGURE 11: DAILY AVERAGE PM10 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 23 FIGURE 12: DAILY AVERAGE PM10 CONCENTRATIONS RECORDED AT THE DEA STATION 24 FIGURE 13: DIURNAL PM10 CONCENTRATIONS RECORDED AT THE SASOL STATIONS 24 FIGURE 14: HOURLY AVERAGE NO2 CONCENTRATIONS RECORDED AT THE SASOL STATIONS (JAN – DEC 2009)

25 FIGURE 15: HOURLY AVERAGE NO2 CONCENTRATIONS (PPB) RECORDED AT THE DEA STATION (JAN – DEC

2009) 26 FIGURE 16: DIURNAL NO2 CONCENTRATIONS (PPB) RECORDED AT THE SASOL STATIONS 27

LIST OF TABLES TABLE 1: DETAILS OF THE EAP 3

TABLE 2: REPORT STRUCTURE 4 TABLE 3: COORDINATES OF THE DIFFERENT COMPONENTS OF THE PROPOSED PROJECT 5 TABLE 4: ATMOSPHERIC STABILITY CLASSES (PASQUILL GIFFORD) 15 TABLE 5: IDENTIFIED SENSITIVE RECEPTORS SURROUNDING THE SITE 18 TABLE 6: ANNUAL AVERAGE BENZENE (PPB) CONCENTRATIONS FOR ALL MONITORING STATIONS FOR THE

PERIOD 2006 – 2010 22 TABLE 7: MAXIMUM HOURLY, DAILY AND ANNUAL AVERAGE PM10, SO2 AND NO2 CONCENTRATIONS FOR

ALL MONITORING STATIONS FOR THE PERIOD 2006 – 2010 28 TABLE 8: ANNUAL AVERAGE PM10, SO2 AND NO2 CONCENTRATIONS FOR ALL MONITORING STATIONS FOR

THE PERIOD 2006 – 2010 29 TABLE 9: EXCEEDANCES OF THE NATIONAL STANDARDS (WHERE APPLICABLE) AT ALL MONITORING

STATIONS FOR THE PERIOD 2006 – 2010 29 TABLE 10: CRITERIA FOR THE RATING OF IMPACTS 33 TABLE 11: CRITERIA FOR THE RATING OF CLASSIFIED IMPACTS 34 TABLE 12: KEY STAKEHOLDERS CONTACTED AS PART OF PP PROCESS 37 TABLE 13: SUMMARY OF CONSTRUCTION PHASE IMPACTS 48 TABLE 14: SUMMARY OF OPERATIONAL PHASE IMPACTS 56

APPENDICES APPENDIX A: LOCALITY MAP

APPENDIX B: PROCESS FLOW DIAGRAM APPENDIX C: PROPERTIES OF AROMATIC NAPHTHA APPENDIX D: APPROVAL OF SCOPING STUDY APPENDIX E: AIR QUALITY IMPACT ASSESSMENT APPENDIX F: PUBLIC NOTIFICATIONS APPENDIX G: I&AP DATABASE AND ISSUES TRAIL APPENDIX H: ENVIRONMENTAL MANAGEMENT PROGRAMME

ACRONYMS CCR Continuous Catalyst Regeneration (part of the Platforming units) CO Carbon monoxide CTN Coal Tar Naphtha DHT Distillate Hydrotreater DSC Distillate Selective Cracker H2S Hydrogen sulphide EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment EMPr Environmental Management Programme ESS Environmental Scoping Study ESR Environmental Scoping Report I&AP Interested and Affected Party MDEDET Mpumalanga Department of Economic Development, Environment and Tourism MFO Medium Fuel Oil NEMA National Environmental Management Act NHT Naphtha Hydrotreater NO Nitrogen monoxide NO2 Nitrogen dioxide O3 Ozone PHT Poly Hydrotreater RON Research Octane Number SCC Synfuels Catalytic Cracker SCF2 Secunda Clean Fuels 2 SGP Secunda Growth Programme SO2 Sulphur dioxide TAME Tertiary Amyl Methyl Ether

DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED RETROFITTING OF TWO GAS TURBINES AT SASOL, SECUNDA

E02.PTA.000407 Page 1 SSI Environmental

1 INTRODUCTION Due to the new fuel specifications, Sasol Technology proposes the retrofitting of two existing gas turbines as the basis for the Secunda Growth Programme (SGP) 1B (new) project (also referred to as Secunda Clean Fuels (SCF2) project. The turbines will be retrofitted for co-firing using aromatic naphtha and gas simultaneously, as these were originally designed only for gas firing. Currently 100 MW of electricity (per turbine) is generated in a closed cycle system in the turbines and it should be noted there will be no change in the amount of electricity generated. Aromatic naphtha is the liquid fuel hydrocarbon stream that contains approximately 40% benzene. The sources of the aromatic naphtha streams are the Synfuels Catalytic Cracker (Unit 293) gasoline and the Coal Tar Naphtha (CTN) Hydrogenation units (Units 15 and 215). Each of these stream sources will be sent to separate fractionators to obtain a benzene-rich stream which will be combusted in the gas turbines to generate electricity. In support of the retrofitting of the two gas turbines, Sasol Synfuels therefore proposes to install: i. A hold up tank with a capacity of approximately 11500 m3 to store aromatic naphtha. The hold up tank will be

located in the Eastern tank farm. ii. A Medium Fuel Oil (MFO) tank with a capacity of approximately 2000 m3 in the Western tank farm. iii. A tank with a capacity of approximately 6000 m3 for the Octane booster system in the Western tank farm. iv. A tank with a capacity of approximately 100 m3 tank for the Cetane booster system in the Western tank farm.

After the Environmental Scoping Study was concluded and subsequently accepted by the Mpumalanga Department of Economic Development, Environment and Tourism (MDEDET) on 07 February 2012, the Sasol engineering team indicated that the liquid feed systems required on the gas turbines, to enable electricity generation, will require protection systems on the process equipment. The Pressure Safety Systems will need to be routed to a safe location/system. It was originally proposed that a vapour line from the liquid knock-out system will be routed to the existing LP flare header. Routing this vapour to this destination requires significant civil work (foundations) and a new pipe rack to be installed for an ad hoc vapour flow from the safety systems. Routing such a line to the LP Flare header would hinder access (for cranes during turnarounds) to various units in the vicinity and therefore is not deemed suitable or practical to deal with relief loads. Therefore, it was proposed to install a flare on the Closed Cycle Power Generation Plant (Unit 543) (already authorised MDEDET Ref. No. 17/2/22/3/GS 2) plot plan to handle the ad hoc vapours flows, due to emergency conditions, from the liquid hydrocarbon feed system. This would protect the unit and maintain its safety integrity. The flare will require pilots to be lit to ensure that it is available at all times, the fuelling gas to keep these pilots lit is likely to be natural gas (NG) and/or Methane Rich Gas (MRG). It should be noted that no new listed activities in terms of the Environmental Impact Assessment Regulations (2012) GN R 544 – 546 will be triggered by the addition of the flare. The proposed project is situated within the Sasol Industrial Complex in Secunda (refer to Appendix A for the locality map).

1.1 Need and Background The purpose of the SGP 1B (new) project is to achieve compliance with the clean fuel specifications (Euro V specifications effective, 01 July 2017)) which were published in Government Notice R.421 of 31 May 2012. According to the Euro V specifications, South Africa has to comply with international best practice and specify the content of benzene in fuel. For the Petrol pool, the intent is to reduce the benzene content in fuel from 3 volume% to a maximum of 1 volume% and achieve the 18 volume% olefins specifications, while for the Distillate pool the T95 specification of 360 °C is to be met. The 1 volume% benzene content of the fuel pool will be met by generating electricity from the aromatic naphtha stream. The 18 volume% olefin specification will be met within the existing operational parameters of the Synfuels complex. The future T95 specification will be met by fractionation optimisation and minor modifications of the existing Distillate Hydrotreaters and the Distillate Selective Cracker.



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 environmental best practice, Sasol Synfuels (Pty) Ltd appointed SSI Environmental as the independent Environmental Assessment Practitioner (EAP) to conduct the necessary studies to obtain Environmental Authorisation to undertake the proposed project. It should be noted, that the retrofitting of the gas turbines is not the trigger for the EIA but rather the construction of the various tanks mentioned in points i – iv as the installation of the gas turbines and generation of electricity was authorised as part of the Power Generation from Waste Energy project (MDEDET Ref. No. 17/2/22/3/GS 2).

1.2 Approach to the EIA Studies The environmental impacts associated with the proposed project require investigation in compliance with the Environmental Impact Assessment Regulations (2010) published in Government Notice No. R. 543 and No. R. 545 and read with Section 24 (5) of the National Environmental Management Act (NEMA-Act No 107 of 1998) (as amended). The required environmental studies include the undertaking of an Environmental Impact Assessment (EIA) process. This process is being undertaken in two phases: Phase 1 - Environmental Scoping Study (ESS) including Plan of Study for EIA - complete; and Phase 2 - Environmental Impact Assessment (EIA) and Environmental Management Programme (EMPr).

1.2.1 Environmental Scoping Study The ESS provided a description of the receiving environment and how the environment may be affected by the development of the proposed project. Desktop studies making use of existing information were used to highlight and assist in the identification of potential significant impacts (both social and biophysical) associated with the proposed project. Additional issues for consideration were extracted from feedback from 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 Scoping study were documented within the final Environmental Scoping Report (ESR) which was accepted by the MDEDET on 07 February 2012.

1.2.2 Environmental Impact Study The Environmental Impact Assessment phase will aim to achieve the following: to provide an overall assessment of the social and biophysical environments of the affected area by the

proposed project; to undertake a detailed assessment of the preferred site/alternatives in terms of environmental criteria

including the rating of significant impacts; to identify and recommend appropriate mitigation measures (to be included in an EMPr) for potentially

significant environmental impacts; and to undertake a fully inclusive public participation process to ensure that I&AP issues and concerns are

recorded and commented on and addressed in the EIA process.



FIGURE 1: ENVIRONMENTAL STUDIES FLOWCHART

1.3 Details of the Environmental Assessment Practitioner SSI Environmental has been appointed as the independent Environmental Assessment Practitioner (EAP) by Sasol Synfuels, to undertake the appropriate environmental studies for this proposed project. The professional team of SSI Environmental has considerable experience in the environmental management and EIA fields. SSI Environmental 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 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.

TABLE 1: DETAILS OF THE EAP CONSULTANT: SSI ENVIRONMENTAL Contact Persons: Prashika Reddy and Phyllis Kalele Postal Address PO Box 25302, Monument Park, 0105 Telephone: 012 367 5973 / 5916 Facsimile: 012 367 5878 E-mail: [email protected] / [email protected] Expertise: Prashika Reddy is a senior environmental scientist / associate

(BSc Honours – Geography) with experience in various environmental fields including: environmental impact assessments, environmental management programmes, public participation and environmental monitoring and auditing. Ms Reddy has extensive experience in compiling environmental reports (Screening, Scoping, EIA and Status Quo Reports). She is a registered Professional Natural Scientist (Pr Sci Nat 400133/10) with the South African Council for Natural Scientific Professions (SACNASP). Phyllis Kalele is a senior environmental consultant with experience in various facets of environmental management. These include conducting the Public Participation process; compiling Environmental Impact Reports; compiling Environmental Management Programmes; conducting environmental awareness training; and conducting legal compliance audits. She is a registered Professional Natural



CONSULTANT: SSI ENVIRONMENTAL Scientist (Pr Sci Nat 400456/11) with SACNASP.

1.4 Structure of the Report

TABLE 2: REPORT STRUCTURE CHAPTER CONTENT

Chapter 1 – Introduction Introduction to project Chapter 2 - Project Description Provides the technical description of the project as well as a

description of the infrastructure Chapter 3 - Project Alternatives Consideration of alternatives (design/layout, site and do-nothing)

for the project Chapter 4 - General Description of the Study Area

A description of the biophysical and social environment

Chapter 5 – Environmental Impact Assessment Methodology and Approach

Methodology used in the assessment of significant impacts

Chapter 6 - Public Participation Process Overview of the public participation process conducted to date Chapter 7 – Potential Impacts associated with the Project

A description and assessment of construction, operations, decommissioning and cumulative impacts

Chapter 8 - Conclusions and Recommendations

Conclusions and recommendations of the Environmental Impact Assessment Study



2 PROJECT DESCRIPTION

2.1 Project Location The project will take place within the primary area of the Sasol Secunda Complex. The tanks proposed to be constructed will be located in the areas as shown in Figure 2 below. The coordinates of the different components of the project are shown in Table 3 below.

TABLE 3: COORDINATES OF THE DIFFERENT COMPONENTS OF THE PROPOSED PROJECT PROPOSED ACTIVITY COORDINATES

New Aromatic Naphtha Tank (Eastern Tank Farm) -Preferred site

26°32'49.14"S; 29°10'1.90"E

New Aromatic Naphtha Tank (Western Tank Farm) -Alternative site

26°32'37.45"S; 29°9'18.49"E

New MFO Tank (Western Tank Farm) 26°32'49.62"S; 29°8'57.98"E Modifications to the existing Refinery Plants (East) 26°33'8.23"S; 29°10'9.41"E Modifications to the existing Gas Turbines 26°33'55.63"S; 29°9'53.15"E Octane Booster tanks (Western Tank Farm) 26°32'37.45"S; 29°9'18.49"E Cetane Booster tanks (Western Tank Farm) 26°32’39.20”S; 29°9’11.74”E Flare 26°33’50.6”S; 29°09’56.8”E



FIGURE 2: LOCATION OF THE AROMATIC NAPHTHA, MFO, CETANE & OCTANE TANKS AND FLARE (Courtesy Google Earth, 2010)

Western Tank Farm

Eastern Tank Farm



2.2 Electricity Generation from Aromatic Naphtha Aromatic naphtha is the liquid fuel stream and it contains an average concentration of approximately 40% benzene. The sources of the aromatic naphtha streams are the Synfuels Catalytic Cracker - SCC (Unit 293), gasoline and the Coal Tar Naphtha (CTN) Hydrogenation units (Units 15 and 215). Each of these stream sources will be sent to separate fractionators1 to obtain a benzene-rich stream which will be combusted in the gas turbines to generate electricity. At Units 15 and 215 (CTN Hydrogenation units), new CTN fractionation columns will be installed to remove benzene from the CTN. The CTN aromatic naphtha (with benzene content of approximately 40wt%) will be recovered in the CTN fractionator overhead stream and pumped to the hold up aromatic naphtha storage tank. The CTN fractionation bottoms will be routed to the existing Naphtha Hydrotreatment (NHT) feed tanks. SCC aromatic naphtha is prone to gum formation and will be dosed with an additive to prevent gumming. This stream will be routed to an intermediate storage tank (256TK-1509) prior to being routed to the gas turbines. This will ensure that gas turbines receive a stable feed to minimise interruptions to power generation at Unit 543. The SCC aromatic naphtha and CTN aromatic naphtha are both fed to the Closed Cycle Power Generation Plant - Unit 543, via tanks, where it will be combusted in the gas turbines (to be retrofitted) for the purpose of electricity generation. At the NHT units (Units 30 and 230), new Dehexanizer columns will be installed to recover benzene precursors as an overhead product that will be routed to low octane fuel component tanks (256TK-3201/2) as a petrol blending component. Both 256TK-3201 and 256TK-3202 are currently in CTN service and the impact due to a change of service will be investigated. Dehexanizer overheads can also be routed to the gas turbines at Unit 543 should the need arise, typically during upset scenarios. Benzene, having a RON of 101, is contributing significantly to Secunda’s octane pool. Once the benzene content is reduced to 1 volume%, it will become increasingly difficult to meet the unleaded petrol (ULP) 93 RON target during upset conditions. In order to improve the petrol pool’s RON, it is proposed to implement side-draw streams on the Poly Hydrotreatment (PHT) splitters at both Units 33 and 233 (33/233VL-101). Despite the proposed efforts to improve the petrol pool’s RON, there is still a significant risk of a RON deficit during upset scenarios such as when the Tertiary Amyl Methyl Ether (TAME) block and SCC are offline. It was therefore proposed to make use of a chemical fuel additive to ensure that the RON target be met at all times. ChimecFA0612 was identified as the additive of choice. New offloading, storage and dosing facilities will be required to introduce this additive into the fuel pool. The Diesel Hydrotreater units (Unit 35 DHT and Unit 235 DHT) are the final processing step for distillate streams of the diesel value chain for the factory. Unit 35 is divided into the Distillate Hydrotreater (DHT) and the Distillate Selective Cracker (DSC). The DHT fractionation system produces naphtha, light diesel and a heavy stream. This heavy stream is the feed to the DSC unit. The DSC unit produces a naphtha stream, a heavy diesel and a Medium Fuel Oil (MFO). In order to meet the T95 diesel specification, the post SGP 1B (new) operation of the DSC fractionators will result in a higher yield of MFO. It is expected that the MFO production will increase from 4.0 m3/h to 12.8 m3/h. As a result, the MFO slate will also become lighter. To accommodate the expected increase in MFO production, additional storage (in the form of a new 2000 m3 tank in the Western tank farm) will be required. The process flow diagram in Appendix B illustrates the process of generating electricity from aromatic naphtha.

1 Fractionation is a separation process in which a certain quantity of a mixture (solid, liquid, solute, suspension or isotope) is divided up in a

number of smaller quantities (fractions) in which the composition changes according to a gradient.



2.3 Facilities for Retrofitting the Gas Turbines The proposed retrofitting of the gas turbines will involve modifications in various sections of the Secunda plant; these include:

i. West Refinery Plant The plant will be modified by:

Routing of aromatic naphtha into Unit 32 (Cat Poly). Upgrading of side-draw on existing tower within Unit 33 (PHT). Installation of a Dehexaniser with associated equipment at Unit 30 (NHT). Modifications will be

required within the existing Unit 30 NHT, Platforming and Continuous Catalyst Regeneration (CCR) units to process the feedstocks to meet future fuel requirements.

Debottlenecking of the Medium Fuel Oil (MFO) product rundown line in Unit 35 Distillate Selective Cracking (DSC).

Construction of a new CTN fractionation tower and associated equipment in Unit 15 (Naphtha Hydrogenation) to generate a stream of aromatic naphtha.

ii. Western Tank Farm (Unit 56) Installation of a steam heated tank with a capacity of approximately 2000 m3 in Unit 56 for MFO.

The tank will be a thermal insulated fixed roof storage tank. Installation of an Octane booster system in Unit 56 which will be comprised of an off-loading

facility, a tank with a capacity of approximately 6000 m3 and blending pumps. The tank will be a thermal insulated fixed roof storage tank.

Installation of a Cetane booster system in Unit 56 which will be comprised of an off-loading facility, a tank with a capacity of approximately 100 m3 and blending pumps. The tank will be a thermal insulated fixed roof storage tank.

iii. Eastern Tank Farm (Unit 256) Installation of an approximately 11500 m3 hold up tank in Unit 256 to store aromatic naphtha. The

hold up tank will have a floating roof and the tank’s main role will be the storage of aromatic naphtha.

iv. East Refinery Plant The plant will be modified by:

Upgrading of side-draw on the existing tower within Unit 233 (Polymer Hydrotreater). Installation of a Dehexaniser with associated equipment in Unit 230 (Naphtha Hydrotreater).

Modifications will be required within the existing Unit 230 NHT, Platforming and CCR units to process the feedstocks to meet future fuel requirements.

Installation of a new charge heater in Unit 235 (Distillate Hydrotreater) and other modifications to ensure unit can maintain nameplate capacity with new fuel specification requirements.

Construction of a new CTN fractionation tower and associated equipment in Unit 215 (Naphtha Hydrogenation) to generate a stream of aromatic naphtha.

v. Closed Cycle Power Generation Units (Unit 543) The two existing gas turbines in Unit 543 will be retrofitted in order to utilise a liquid feed to

generate electricity.

vi. Handling of Relief Streams at the Gas Turbines using a Flare The liquid feed systems required on the gas turbines, to enable electricity generation, will require protection systems on the process equipment. The pressure safety systems will need to be routed to a safe location / system. It was originally proposed that a vapour line from the liquid knock-out system will be routed to the existing LP flare header. Routing this vapour to this destination requires significant civil work (foundations) and a new pipe rack to be installed for an ad hoc vapour flow from the safety systems. Routing such a line to the LP Flare header would hinder access (for cranes during turnarounds) to various units in the vicinity and therefore is not deemed suitable or practical to deal with relief loads. It is therefore proposed to install a flare – either enclosed ground flare or an elevated flare (see example in Figure 3 and Figure 4 ) on the U543 plot plan to handle the ad hoc vapours flows, due to emergency conditions, from the liquid hydrocarbon feed system. This would protect the unit and maintain its safety



integrity. The flare will require pilots to be lit to ensure that it is available at all times; the fuelling gas to keep these pilots lit is likely to be Natural Gas (NG) and/or Methane Rich Gas (MRG).

The dimensions of the enclosed ground flare are 6.8 m diameter, 21 m total height and the plot space requirements is 20 x 20 m2. The lined combustion chamber will be surrounded by a wind fence (approximately 11.1 diameter) which also encloses the pilot and burner manifolding. The wind fence would most probably be built out of concrete blocks supported on concrete pillars. The preliminary dimensions of an elevated flare are unknown at this stage therefore only the enclosed ground flare will be included in the air quality modelling, however, the impacts of both the ground and elevated flare will be included in the Air Quality Impact Assessment (AQIA).

FIGURE 3: EXAMPLE OF AN ENCLOSED GROUND FLARE (COURTESY: JOHN ZINK®)2

2 http://www.johnzink.com



FIGURE 4: EXAMPLE OF AN ELEVATED FLARE (COURTESY: JOHN ZINK®)3

3 http://www.johnzink.com



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. For this project, only feasible site alternatives are applicable and are discussed in further detail in the subsequent sections.

3.1 Site Alternatives – Aromatic Naphtha Tank Currently, two site alternatives within the Sasol Industrial Complex are under consideration for the installation of the hold up tank with a capacity of approximately 11500 m3 for storing aromatic naphtha:

3.1.1 Site 1 (Preferred) This site is located in the Eastern tank farm and the tank is proposed to be located in Unit 256 within a footprint of approximately 35 m by 65 m. This site is preferred because of its proximity to the existing SCC aromatic naphtha tank, process feed and maintenance tanks which allows synergy. The proposed CTN and existing SCC aromatic naphtha tanks will be interchangeable with each other doing tank turnarounds.

3.1.2 Site 2 (Alternative 1) This site is located in the Western tank farm and the tank is proposed to be located in Unit 56 within a footprint of approximately 35 m by 65 m. Site 2 is some distance away from the process feed and maintenance tanks. This site has been selected as an alternative because it can accommodate the biggest size tank.

3.2 No-go Alternative Nationally, the reduction of benzene in fuel is being undertaken under the Clean Fuels 2 Programme. The anticipated deadline – 2017, is the year by which fuel produced in South Africa must adhere to the fuel specifications (i.e. reduce the benzene content in fuel from 3 volume% to 1 volume %), standards and Euro V emissions (Department of Energy, 2011)4. If this project does not go ahead, Sasol Synfuels will not be able to comply timeously with the fuel specifications, standards and Euro V emissions. As a result, South Africa will be restricted from exporting fuel to other countries that purchase fuel compliant to the Euro V emissions and this will in turn increase the country’s dependency on imported crude.

4 Department of Energy, 2011. Discussion document on the review of fuel specifications and standards for South Africa.



4 GENERAL DESCRIPTION OF THE STUDY AREA

4.1 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.

4.2 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.

4.3 Water Resources

4.3.1 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.

4.3.1.1 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.

4.3.2 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



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.

4.3.2.1 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.

4.4 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 January 2006 – December 2010 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 site under investigation, data from these stations is considered to be representative of the prevailing meteorological conditions in the area.

4.4.1 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 5). 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.



FIGURE 5: PERIOD WIND ROSE FOR THE SASOL CLUB (LEFT) AND LANGVERWACHT (RIGHT) MONITORING STATIONS FOR THE PERIOD JAN 2006 – DEC 2010

A diurnal trend in the wind field is recorded at both stations (Figure 6). At the Club station, winds originate predominantly from the north-east, east-north-east and east during the night–time (12:00 – 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 6). 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. Club Station

0:00 – 06:00

06:00 – 12:00

12:00 – 18:00

18:00 – 24:00

Langverwacht Station

00:00 – 06:00

06:00 – 12:00 12:00 – 18:00 18:00 – 24:00

FIGURE 6: DIURNAL WIND ROSES FOR THE SASOL CLUB AND LANGVERWACHT MONITORING STATIONS FOR THE PERIOD JAN 2006 – DEC 2010



The seasonal variability in the wind field at both stations is shown in Figure 7. 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 west-south-west and south-west, south-south-east during the spring and summer months. During autumn and winter, a different wind field is observed with additional components recorded from the north-east and east-north-east during these seasons.

Summer

Autumn

Winter

Spring

Summer

Autumn

Winter

Spring

FIGURE 7: SEASONAL WIND ROSES FOR THE SASOL CLUB (TOP) AND LANGVERWACHT (BOTTOM) MONITORING STATIONS FOR THE PERIOD JAN 2006 – DEC 2010

4.4.2 Atmospheric Stability Atmospheric stability is commonly categorised into six stability classes (Table 4). 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 4: ATMOSPHERIC STABILITY CLASSES (PASQUILL GIFFORD) 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 In general, the site experiences very stable (Class F) atmospheric conditions (Figure 8). This is expected given the predominance of a high-pressure anticyclone over South Africa which produces stable, clear conditions.



FIGURE 8: STABILITY CLASS FREQUENCY DISTRIBUTION FOR SASOL CLUB (TOP) AND

LANGERWACHT (BOTTOM) MONITORING STATIONS

4.4.3 Temperature and Humidity Temperature affects the formation, action, and interactions of pollutants in various ways5. 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 particles6. 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.

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

Jersey. 6 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.



Average monthly temperature and humidity at both stations for the period Jan 2006 – Dec 2010 is given in Figure 9. Daily average summer temperatures range between ~18°C and ~19 °C while winter temperatures range between ~7 °C and ~11 °C. Relative humidity is lowest during autumn and winter and highest in summer and spring.

FIGURE 9: AVERAGE MONTHLY TEMPERATURE AND HUMIDITY FOR SASOL CLUB (TOP) AND

LANGVERWACHT (BOTTOM) FOR THE PERIOD JAN 2006 – DEC 2010

4.4.4 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.



4.5 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 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.

4.5.1 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 5. 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 5: 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

4.5.2 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 sources7. The priority area is comprised of parts of Gauteng and Mpumalanga Provinces8. 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 Plan9. 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.

7 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. 8 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. 9 See reference above.



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.

4.5.3 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 sulphide10 (USEPA, 1996). 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.

4.5.4 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]pyrene11. 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 blindness12.

10 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/.

11 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.

12 See reference in Footnote 11 above.



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 5 000 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 guidelines13. 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.

4.5.5 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.

4.5.6 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.

13 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.



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 temperatures14. Emissions of SOx are negligible15. A study of biomass burning in the African savannah estimated that the annual flux of particulate 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 regions16.

4.5.7 Power stations There are numerous Eskom coal powered stations such as Duvha, Kriel and Tutuka that are located within the Highveld Priority area. The burning of coal for power generation results in significant emissions being generated. At the power stations surrounding the pipeline route, 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.

4.5.8 Other Sasol Operations The Sasol chemical complex in Secunda operates numerous chemical processes. The products manufactured include olefins, surfactants, polymers, solvents, ammonia, wax etc. Emissions released during refining as they relate to combustion processes include sulphur dioxide, carbon monoxide, carbon dioxide, oxides of nitrogen and particulate matter. Other pollutants released include various levels of volatile organic compounds or heavy metals.

4.5.9 Air Quality Situation 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. For the purpose of the study, benzene, NO2 and PM10 were assessed in the Air Quality Impact Assessment (AQIA).

4.5.9.1 Benzene Concentrations Annual average benzene concentrations are in compliance with the annual average standard of 3.2 ppb over the monitoring period at the Club and Langverwacht stations (Figure 10). Annual average concentrations for 2009 and 2010 at the DEA monitoring station are also in compliance. Annual average concentrations range from 0.34 – 0.56 ppb at the Club station and 0.60 – 0.95 ppb at the Langverwacht station. An annual average concentration of 0.01 and 1.66 ppb was recorded at the DEA station in 2009 and 2010, respectively. The annual average benzene concentration at all monitoring stations are presented in Table 6. 14 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/.

15 See reference in Footnote 14 above. 16 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.



FIGURE 10: ANNUAL AVERAGE BENZENE CONCENTRATION (PPB) RECORDED AT TWO SASOL

STATIONS

TABLE 6: ANNUAL AVERAGE BENZENE (PPB) CONCENTRATIONS FOR ALL MONITORINGSTATIONS FOR THE PERIOD 2006 – 2010. EXCEEDANCES OF THE ANNUAL STANDARDS ARE HIGHLIGHTED IN

BOLD

Pollutant Station Annual Average

2006 2007 2008 2009 2010

Benzene

Club 0.40 0.44 0.37 0.34 0.34

Langverwacht 0.60 0.70 0.77 0.69 0.74

Secunda x x - 0.01 1.66

Notes:

x indicates station was not operational

– indicates insufficient data is available to determine annual average

4.5.9.2 PM10 Concentrations Daily average PM10 concentrations generally fall below the current National daily standard of 120 µg/m3 at the Sasol stations, although five exceedances were recorded at the Langverwacht station in 2010, resulting in non-compliance (Figure 11). Maximum daily average concentrations range from 87 – 127.8 µg/m3 at the Club station and 85.16 – 192.5 µg/m3 at the Langverwacht station (Table 7). Higher concentrations are recorded at the DEA monitoring station, with exceedances of the daily standard frequently recorded at this site. The higher concentrations recorded at this site are interesting given the close proximity to the Langverwacht station (approx. 3 km). The DEA monitoring station is located in Embalenhle, the burning of biomass and domestic fuel in this area could contribute to the PM10 levels. Maximum daily average concentrations range from 321.29 - 537.04 µg/m3 at this station (Table 7). A similar pattern is recorded at all stations over the monitoring period, with a distinct



seasonal trend evident in the datasets. 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 and non-compliance at the DEA station.

FIGURE 11: DAILY AVERAGE PM10 CONCENTRATIONS (µg/m3) RECORDED AT THE SASOL STATIONS.

THE RED LINE REPRESENTS THE DAILY AVERAGE PM10 STANDARD OF 120 µg/m3



FIGURE 12: DAILY AVERAGE PM10 CONCENTRATIONS (µg/m3) RECORDED AT THE DEA STATION. THE

RED LINE REPRESENTS THE DAILY AVERAGE PM10 STANDARD OF 120 µg/m3 A similar diurnal signature is observed in diurnal PM10 concentrations at all three stations, although a sharper morning and evening peak is recorded by the DEA station (see Figure 12). This diurnal signature is consistent with domestic fuel burning 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.

FIGURE 13: DIURNAL PM10 CONCENTRATIONS (µg/m3) RECORDED AT THE SASOL STATIONS



4.5.9.3 NO2 Concentrations Maximum hourly average NO2 concentrations are generally in compliance with the hourly standard of 106 ppb and allowable frequency of exceedance for all monitoring stations (Table 7) However, hourly average concentrations were in non-compliance at the Sasol stations in 2009 (Figure 14), although this is not observed at the DEA station (Figure 15). Lower NO2 concentrations are recorded at the DEA station compared to the two Sasol stations. 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 (Table 9).

FIGURE 14: HOURLY AVERAGE NO2 CONCENTRATIONS (PPB) RECORDED AT THE SASOL STATIONS

FOR THE PERIOD JAN – DEC 2009. THE RED LINE REPRESENTS THE HOURLY AVERAGE NO2 STANDARD OF 106 PPB



FIGURE 15: HOURLY AVERAGE NO2 CONCENTRATIONS (PPB) RECORDED AT THE DEA STATION FOR THE PERIOD JAN – DEC 2009. THE RED LINE REPRESENTS THE HOURLY AVERAGE NO2 STANDARD OF

106 PPB Diurnal NO2 concentrations are given in Figure 16. A similar diurnal signature is recorded at all three 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.



FIGURE 16: DIURNAL NO2 CONCENTRATIONS (PPB) RECORDED AT THE SASOL STATIONS



TABLE 7: MAXIMUM HOURLY, DAILY AND ANNUAL AVERAGE PM10 (µg/m3), SO2 AND NO2 CONCENTRATIONS FOR ALL MONITORING

STATIONS FOR THE PERIOD 2006 – 2010. EXCEEDANCES OF THE STANDARDS AND ALLOWABLE FREQUENCY OF EXCEEDANCE (WHERE APPLICABLE) ARE HIGHLIGHTED IN BOLD

Pollutant Station Max Hour Average Max Daily Average

2006 2007 2008 2009 2010 2006 2007 2008 2009 2010

PM10

Club N/A N/A N/A N/A N/A 87.00 92.58 94.65 87.38 127.8

Langverwacht N/A N/A N/A N/A N/A 103.64 85.16 102.65 130.49 192.5

Secunda(1) N/A N/A N/A N/A N/A x x 321.29 362.31 537.04

SO2

Club 171.49 93.35 222.22 177.82 176.4 38.22 20.60 49.88 32.45 29.1

Langverwacht 234.43 272.47 241.64 324.34 185.3 43.64 54.34 41.62 39.48 31.1

Secunda x x 67.13 194.26 164.24 x x 18.11 38.11 44.61

NO2

Club 59.30 132.21 107.26 262.54 257.2 N/A N/A N/A N/A N/A

Langverwacht 186.08 84.57 124.01 370.80 72.7 N/A N/A N/A N/A N/A

Secunda x x 83.83 120.60 287.55 N/A N/A N/A N/A N/A

Notes: (1) Maximum daily average for 2008 is given for the period Aug – Dec 2008




TABLE 8: ANNUAL AVERAGE PM10 (µg/m3), SO2 AND NO2 CONCENTRATIONS FOR ALL MONITORING STATIONS FOR THE PERIOD 2006 – 2010. EXCEEDANCES OF THE ANNUAL STANDARDS ARE

HIGHLIGHTED IN BOLD

Pollutant Station Annual Average

2006 2007 2008 2009 2010

PM10

Club 28.08 25.62 30.54 - 30.4

Langverwacht 36.77 28.24 29.93 30.30 44.9

Secunda x x - 72.82 88.52

SO2

Club 6.36 2.82 6.01 6.99 7.2

Langverwacht 8.53 9.40 7.61 6.15 6.7

Secunda x x - 8.54 10.99

NO2

Club 3.92 6.99 5.89 13.20 10.8

Langverwacht 7.80 6.21 8.77 18.81 9.8

Secunda x x - 15.37 20.14

Notes:


– indicates insufficient data is available to determine annual average TABLE 9: EXCEEDANCES OF THE NATIONAL STANDARDS (WHERE APPLICABLE) AT ALL MONITORING

STATIONS FOR THE PERIOD 2006 – 2010

Pollutant Station Hourly Exceedances Daily Exceedances

2006 2007 2008 2009 2010 2006 2007 2008 2009 2010

PM10

Club N/A N/A N/A N/A N/A 0 0 0 0 1

Langverwacht N/A N/A N/A N/A N/A 0 0 0 3 5

Secunda N/A N/A N/A N/A N/A x x 21 64 98

SO2

Club 3 0 5 6 4 0 0 1 0 0

Langverwacht 13 21 16 4 7 0 1 0 0 0

Secunda x x 0 2 6 x x 0 0 0

NO2

Club 0 3 1 73 10 N/A N/A N/A N/A N/A

Langverwacht 1 0 3 190 0 N/A N/A N/A N/A N/A

Secunda x x 0 2 9 N/A N/A N/A N/A N/A

Notes:




4.6 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.

4.7 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)17 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.

4.8 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 an extensive infrastructural development including an extensive road and rail network. The project will not have an impact on the land-use.

4.9 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 Essential Requirements are compulsory and applicable to all new projects such as the proposed project retrofitting of the gas turbines. The properties of aromatic naphtha are attached as Appendix C.

4.10 Heritage The Sasol Synfuels Complex is a highly developed Industrial area that has been in operation for more than 30 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.

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



5 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY AND APPROACH

5.1 Approach to Undertaking the Study An EIA for the proposed SGP 1B (new) project has been undertaken in accordance with the Environmental Impact Assessment (EIA) Regulations published in Government Notice No. R. 543, R. 544 and R. 545 of 2010 in terms of Section 24 (5) of the National Environmental Management Act (Act No 107 of 1998) (as amended). The environmental studies are following a two-phased approach: Phase 1: Environmental Scoping Study (ESS) – complete. Phase 2: Environmental Impact Assessment (EIA) – this report, including an Environmental Management

Programme (EMPr) to address impacts identified during the ESS and EIA.

5.2 Environmental Scoping Study An issues-based ESS was first undertaken for the project. Existing information and input from the Authorities as well as Interested and Affected Parties (I&APs) were used to identify and evaluate potential environmental impacts (both social and biophysical) associated with the proposed project. No fatal flaws associated with the proposed project were identified through the ESS, although potentially significant environmental impacts were identified as requiring further in-depth study within the EIA. The Scoping Phase of the environmental studies provided I&APs with the opportunity to receive information regarding the project, participate in the EIA process and raise issues of concern. The draft Environmental Scoping Report (ESR) was made available at public places for I&AP review and comment from 15 November 2011 to 13 January 2012. All the comments, concerns and suggestions received during the public participation process for the Scoping Phase and from the draft report review period were included in the final Environmental Scoping Report, which was submitted to the MDEDET for review and decision-making and subsequently the acceptance was signed on 07 February 2012 and received on 11 April 2012.

5.3 Authority Consultation

5.3.1 Consultation with Decision-Making Authority The relevant authority (MDEDET) providing input into the proposed project has been consulted from the onset of this study, and will continue to be engaged throughout the project process. The consultation process to date with MDEDET aimed to determine specific authority requirements with regards to the project, and ensure inclusion of these in the environmental studies. Authority consultation to date also included the following activities: Submission of an application for environmental authorisation in terms of Section 26 of the EIA Regulations

(2010) on 14 September 2011. Approval of the application documentation by MDEDET was received on 04 October 2011. Site visit with MDEDET official, Mr Bheki Mndawe on 01 November 2011. Submission of the final Environmental Scoping Report and Plan of Study for EIA on 30 January 2012. Acceptance of the final Environmental Scoping Report and Plan of Study for EIA was received on

11 April 2012 (Appendix D).

5.3.2 Environmental Impact Assessment As part of the overall project planning process, this EIA aims to achieve the following: to supplement, where necessary, the assessment of the social and biophysical environments affected by the

proposed project 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.

5.3.3 Methodology – Assessment of Impacts Impact assessment must take account of the nature, scale and duration of effects on the environment, whether such effects are positive (beneficial) or negative (detrimental). Each issue/impact is also assessed according to the project stages from planning, through construction and operation to the decommissioning phase. Where necessary, the proposal for mitigation or optimisation of an impact is noted. A brief discussion of the impact and the rationale behind the assessment of its significance is provided below.

5.3.4 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.



TABLE 10: CRITERIA 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

OCCURANCE

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



Significance is determined through a synthesis of impact characteristics. Significance is also 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 11: CRITERIA FOR THE 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 (12 - 14 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. It is important to note that the status of an impact is assigned based on the status quo – i.e. should the project not proceed. Therefore not all negative impacts are equally significant. 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.

5.4 EIA Report (EIR) This Environmental Impact Assessment Report (EIR) contains the following: Details of the EAP who compiled the report and their expertise to carry out an EIA; Detailed description of the activity/ies; Description of the property on which the activity is being undertaken; 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 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; 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.

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