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Application for an Environmental Authorisation for the Clean Fuels 2 (CF 2) Proposed Tanks Expansion Project at the Sasol Synfuels Operations in Secunda, Mpumalanga Province

Submitted for Comment

Report Prepared for

Sasol South Africa Limited

Report Number 539945/Basic Assessment Report

Report Prepared by

June 2019

SRK Consulting: 539945: Sasol CF 2 Tank Expansion Project Page i

CADD/coes 539945.2019.06.26.R.Sasol Tanks EIA.Final June 2019

Application for an Environmental Authorisation for the Clean Fuels 2 (CF 2) Proposed Tanks Expansion Project at the Sasol Synfuels Operations in Secunda, Mpumalanga Province

Sasol South Africa Limited Private Bag X 1000, Secunda 2302, South Africa

SRK Consulting (South Africa) (Pty) Ltd. Block A, Menlyn Woods Office Park

291 Sprite Avenue

Faerie Glen

Pretoria 0081

South Africa e-mail: [email protected] website: www.srk.co.za

Tel: +27 (0) 12 361 9821 Fax:+27 (0) 12 361 9912

SRK Project Number 539945/Basic Assessment Report

June 2019

Compiled by: Peer Reviewed by:

Andrew Caddick Senior Environmental Scientist

Dr Laetitia Coetser Associate Partner

Email: [email protected]

Authors:

Andrew Caddick

mailto:[email protected]

http://www.srk.co.za/

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Executive Summary A significant contributor to greenhouse gas emissions is the transport sector posing a risk to the

environmental and human health. More stringent fuel specifications and standards have been

developed aimed at the reduction of emissions from vehicles as well as improved air quality.

New fuel specifications (Clean Fuels (CF) I) were developed and introduced in 2006 in the form of

regulations under the Petroleum Products Act (Act No. 120 of 1977) (PPA) and revised South African

National Standards (SANS) 342:2016 specifications relating to petrol and diesel.

These new petrol specifications prohibited the addition of lead in unleaded petrol, but allowed the use

of other metals, such as manganese and phosphorus in metal-containing unleaded petrol (lead

replacement petrol) to cater for the older vehicles that might suffer from valve seat recession with the

removal of lead from petrol.

The diesel specifications required the sulphur levels in diesel to be dropped from a maximum of 3 000

parts per million (ppm) to 500 ppm, with a niche grade of 50 ppm being introduced. This resulted in an

improvement in the diesel exhaust emissions of vehicles.

Regulations regarding the introduction of Clean Fuels 2 were gazetted in June 2012 which indicated

that it would come into operation on 1 July 2017. These regulations, among other legislation, indicates

specifications to conform to, such as those contained in the SANS 342: 2016 for petrol and diesel.

These specifications are currently being finalised. The regulations also require other specifications to

conform to such as those contained in the national standards for petrol and diesel.

In line with these expected changes, Sasol South Africa Ltd (Sasol) has launched the CF 2 program

to lead and coordinate Sasol’s response to accommodate changes in the market. A combination of

technical options has been identified to ensure that an optimal integrated solution is achieved to

convert Secunda Synfuels Operations to CF 2.

Who is conducting the Environmental Impact Assessment?

SRK Consulting (Pty) Ltd (SRK) has been appointed by Sasol to conduct the Basic Assessment

Process (BAP) and compile the Basic Assessment Report (BAR) for the CF 2 proposed Tanks

Expansion Project in terms of Sections 21 – 25 and 59 of the National Environmental Management

Act (Act No 107 of 1998) (NEMA), and the Stakeholder Engagement Process in accordance with

General Notice Regulations (GNR) 982 published in terms of the NEMA.

This BAR is provided for comment to registered Interested and Affected Parties (I&AP) prior to

submission to the Competent Authorities for assessment and authorisation decision making.

The CF 2 proposed Tanks Expansion Project will further require an Air emissions Licence (AEL) in

accordance with Section 21 of the National Environmental Management: Air Quality Act (Act No. 39

of 2004) (NEM:AQA) and as such an AEL application process to amend the existing Secunda Synfuels

AEL will be undertaken by Sasol as part of the AEL review process. The BAP was completed to fulfil

the requirements of NEMA.

Who will evaluate the Environmental Impact Assessment?

MDARDLEA have been identified as the Competent Authority for the Environmental Authorisation

(EA).

Approval of the BAR and Environmental Management Programme (EMPr) is being sought from the

MDARDLEA prior to the implementation of the CF 2 proposed Tanks Expansion Project. Following

public involvement and inputs on the BAR, the BAR will be submitted to the MDARDLEA, who will

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decide whether to authorise the listed activities associated with the proposed CF 2 Tanks project

based on the final findings of the BAR and EMPr.

Various Organs of State have been consulted and taken into consideration during the decision-making

process. Other legislation, guidelines and policies pertaining to the proposed improvements CF 2 Tank

Expansion Project whereby activities have been regulated, have been considered. These include the

National Water Act (Act No. 36 of 1998) (NWA), National Environmental Management: Waste Act (Act

No. 59 of 2008) (NEM:WA), National Heritage Resources Act (Act No. 25 of 1999), and others.

Environmental Assessment Process

The Environmental Impact Assessment (EIA) seeks to identify the potential impacts of the CF 2

proposed Tanks Expansion Project from the planning phase and helps to ensure that the project, over

its life cycle, will be environmentally sustainable. Activities undertaken during the BAP are detailed in

this report and the findings and recommendations for mitigation and management of identified impacts

incorporated into the EMPr.

Two parallel processes were followed during the BAR and EMPr Phase of this project. These include

an EIA and the Stakeholder Engagement Process.

Environmental Technical Process

Activities undertaken during the BAR Phase as part of the environmental technical process included:

• Project meetings between the client and SRK;

• Identification of information needs in respect to the CF 2 proposed Tanks Expansion Project and

assessment of potential environmental impacts;

• Collation of technical information in respect to the CF 2 proposed Tanks Expansion Project and


• Review of background information for the CF 2 proposed Tanks Expansion Project;

• Consultation with the MDARDLEA;

• Assessment of potential environmental impacts and review of proposed mitigation and

management measures to prevent or minimise potential impacts;

• Preparation of the BAR and EMPr.

Stakeholder Engagement Process

Stakeholder Engagement Process forms a key component of the EIA process and is governed by

GNR 982 of 4 December 2014, published in terms of the NEMA. The Stakeholder Engagement is the

Process whereby parties who may be potentially affected by the CF 2 proposed Tanks Expansion

Project, directly or indirectly, or those who have an interest in the CF 2 proposed Tanks Expansion

Project, are involved during all stages of the EIA process. The project was publicised through media

advertisements placed in two local newspapers namely the Bulletin (English, Afrikaans, and IsiZulu)

(25 June 2019) and Echo Ridge newspapers (English) (26 June 2019). The public was invited to

comment on the CF 2 proposed Tanks Expansion Project through the placement site notices (English,

Isi-Zulu and Afrikaans) as listed in Table ES–1. The public was invited to register as I&APs.

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Table ES-1: Location of site notices

No Description Coordinates

Longitude Latitude

1 Govan Mbeki Local Municipality 29° 11' 5.00" E 26° 30' 13.80" S

2 Govan Mbeki Library 29° 11' 5.16" E 26° 30' 16.95" S

3 At the entrance to the Sasol Synfuels Operations (Charlie 1)

29° 9' 25.20" E 26° 31' 30.00" S

4 Sasol Recreational Club 29° 11' 2.84" E 26° 31' 17.00" S

The Draft BAR has been made available for public review for a period of thirty days (30) from 28 June

2019 to 29 July 2019, for I&APs and Organs of State. Hard copies of the BAR have been placed in

the Secunda Public Library, Sasol Recreation Club, SRK Offices in Pretoria, and on the SRK website

(http://www.srk.co.za/en/library/za-public-documents).

I&APs will be notified of the availability of Draft BAR for comment. Following the 30-day commenting

period, all comments received from registered I&APs will be collated into the Final BAR prior to

submission to the MDARDLEA.

Process for the Remainder of the Study

The following activities will still be undertaken during finalisation of the application for authorisation:

• Incorporation of comments received from the public and other stakeholders and commenting

authorities into the BAR;

• Submission of the Final BAR to the MDARDLEA; and

• Authorities' decision about the project. After review of the BAR, the MDARDLEA will issue a

decision. The decision will be communicated to stakeholders in writing and will be notified on the

timeframes and process to appeal the decision.

The project decision-making process should ensure that affected parties’ inputs are being considered.

Summary of Key Environmental Impacts

Concerns and issues regarding the CF 2 proposed Tanks Expansion Project were gathered from

stakeholder comments and assessed according to professional judgement of the Environmental

Assessment Practitioner (EAP) and specialist studies undertaken for the CF 2 Tank Expansion Project.

Table ES–2 illustrates the possible environmental impacts that have been identified during the Impact

Assessment Phase of the CF 2 proposed Tanks Expansion Project:

The CF 2 proposed Tanks Expansion Project has been assessed and limited negative environmental

impacts have been identified. The identified impacts will largely be short term during the construction

activities and can be mitigated and managed to an acceptable level. The spatial extent of the project

will be activity specific with a short to medium term construction duration.

http://www.srk.co.za/en/library/za-public-documents

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Table ES–2: Potential environmental impacts and ratings associated with the CF 2 proposed

Tanks Expansion Project

POTENTIAL ENVIRONMENTAL IMPACT (NATURE OF THE IMPACT)

ENVIRONMENTAL SIGNIFICANCE

BEFORE MITIGATION


AFTER MITIGATION

CONSTRUCTION PHASE

Social-Economic

National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy.

VERY HIGH (+) VERY HIGH (+)

Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations.

HIGH (+) HIGH (+)

Opportunity to keep pace with improved vehicle engine technology and addressing environmental degradation as a result of harmful emissions from vehicles

HIGH (+) HIGH (+)

Possible boost in short term employment and local small business opportunities.

LOW (-) LOW (-)

Generation of dust potentially resulting in a health and nuisance impact.

LOW (-) VERY LOW (-)

Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly.

LOW (-) LOW (-)

Clearing of land which may potentially impact on the sense of place.

VERY LOW (-) VERY LOW (-)

Possible impact on service provision as a result of construction of temporary ablution facilities, storage areas, and site establishment.


Potential squatting of job seekers. VERY LOW (-) VERY LOW (-)

Surface Water Quality

Potential deterioration in water quality as a result of accidental spillages of hazardous substances such as hydrocarbons from construction vehicles and machinery.


Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality.


Debris from poor handling of materials and/or waste blocking watercourses may result in flow (-) impediment and pollution.


Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the construction footprint area.


Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources.


Debris from poor handling of materials and/or waste blocking watercourses nay result in flow (-) impediment and pollution.


Increase of surface runoff and potentially contaminated water that needs to be maintained in the areas where site clearing occurred.


Groundwater

Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination.


Improper storage and handling of hazardous materials leading to groundwater contamination.


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BEFORE MITIGATION


AFTER MITIGATION

Wetlands and Aquatic Ecosystems

Potential impacts on wetlands and aquatic ecosystems including: • Localised changes to the riparian areas as a result of vegetation clearing; • Sedimentation of riparian resources leading to smothering of wetland and aquatic flora; • Loss of habitat and riparian zone ecological structure as a result of site clearance activities and uncontrolled riparian zone degradation; • Deterioration of wetland water quality due to accidental spillages of hydrocarbons and poor waste management; • Impact on the riparian systems as a result of changes to the sociocultural service provision of wetlands; • Increased runoff due to topsoil removal and vegetation clearance leading to possible erosion and sedimentation of riparian resources; • Uncontrolled movement of vehicles and construction personnel may result in soil compaction and levelling as well as loss of riparian habitat.


Air Quality

Dust generating activities associated with the construction phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.


Emissions of Green House Gases as a result of the use of construction vehicles and machinery.


Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil.


Clearing of vegetation outside of the Tank Farm footprint area. LOW (-) VERY LOW (-)

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials.

MEDIUM LOW (-) LOW (-)

Potential compaction and erosion of soils removed and stockpiled during excavation activities.


Climate Change



Overall climatic benefits as a result of the production and utilisation of fuels that meet new stringent specifications (cleaner fuels).


Geotechnical Consideration

Potential geotechnical constraints impacting on engineering design of access roads and foundations as a result of collapsible and compressible soil.

Medium High (-) Very Low (-)

Potential degradation of geo-sites. Very Low (-) Very Low (-)

Potential degradation of bedrock and topography as a result of excavations for foundations, pipelines, tanks and other associated infrastructure.

Low (-) Very Low (-)

Potential safety risk as a result of inappropriate founding methods.


Potential groundwater, surface and soil contamination as a result of: • High settlements of structures if soils have a low in situ bearing capacity if not compacted or engineered properly; • Using contaminated material as bulk fill in material; • Ground distortion (settlement) caused by construction activities (earthworks, retaining structures etc.); and • Change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level.


Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated soil and building material for the construction of the Tertiary Amyl Methyl Ether (TAME), creosote diesel and Cold Tar Naphtha / Benzene (CTN) tanks.


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BEFORE MITIGATION


AFTER MITIGATION

Cultural and Heritage

Although no additional resources of cultural and/or heritage importance that will be affected by the project, a possibility remains that there may be some resources that may be affected.


Flora

Loss of vegetation species including vegetation species of conversational concern due to site clearance.


Direct loss of habitat and indirect loss of habitat quality. LOW (-) VERY LOW (-)

Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer alien species are provided with a chance to flourish.


Generation of waste and incorrect disposal from construction material leading to disturbance of natural vegetation.


Fauna

Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general construction activities.


Loss of faunal diversity and ecological integrity as a result of construction activities, erosion, poaching and faunal species trapping.


Movement of construction vehicles and machinery may result in collision with fauna, resulting in loss of fauna.


Visual

Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure.


Indirect visual impact due to dust generation as a result of the movement of vehicles and materials, to and from the site area.


Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings.


Traffic

Increase in traffic volumes as a result of construction activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the construction site.


Operational Phase

Socio-Economic

National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy.


Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations.

HIGH (+) HIGH (+)

Opportunity to keep pace with improved vehicle engine technology and addressing environmental degradation as a result of harmful emissions from vehicles.

HIGH (+) HIGH (+)

Risk to the safety of surrounding amenities due to the explosion risk of the stored flammable products.

MEDIUM HIGH (-) VERY LOW (-)

The generation of dust and other gaseous emissions i.e. VOCs resulting in a health and nuisance impact.

MEDIUM LOW (-) VERY LOW (-)

Surface Water

Contamination of runoff by poor materials/waste handling practices, including accidental spillages of hazardous substances from vehicles/pipelines/tanks etc.


Uncontrolled runoff containing suspended solids, sediments and fuel residue may contaminate surface water resources.


Groundwater

The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils.


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BEFORE MITIGATION


AFTER MITIGATION

Contamination of soil and groundwater and possibly bedrock as a result of overspills from the storage tanks.


Leakage of hazardous materials from the transportation pipelines etc.


Improper storage and handling of hazardous materials. MEDIUM LOW (-) VERY LOW (-)

Air Quality

Gaseous emissions i.e. VOCs will arise from the tanks within the project area.


Climate Change



Overall climatic benefits as a result of the production and utilisation of fuel meeting more stringent specifications (cleaner fuels)


Soil, Land Use and Land Capability

The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils.


Contamination of soil as a result of overspills from the storage tanks.




Potential hydrocarbon spillages resulting from a leakage caused by a fracture/crack/corrosion or rupture in the fuel storage tanks may lead to contamination of the soil in and around the site area.


Improper storage and handling of hazardous materials. MEDIUM LOW (-) VERY LOW (-)

Geotechnical Considerations

Potential groundwater, surface water and soil contamination as a result of change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level.


Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to: • Seismic activities; and • The formation of sinkholes or subsidence caused by the presence of water-soluble rocks (dolomite or limestone).

Very Low (-) Very Low (-)

Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to differential settlement as a result of foundations placed across different soil types or rock which may settle differently.


Topography

Permanent altering of the ground level due to excavation activities and tank erection.


Heritage

Although no additional resources of cultural and/or heritage importance that be affected by the project, a possibility remains that there may be some resources that may be affected.


Flora

Uncontrolled movement of vehicles outside the designated access roads may result in the destruction of potential floral habitats for species of conservational concern.


Failure to initiate an alien species control plan during the construction phase may lead to further impacts during the operation phase.


Fauna

Uncontrolled movement of vehicles may lead to loss of faunal habitat and ecological structure.


Loss of faunal species due to collisions with vehicles transporting the materials to the site.


Failure to initiate an alien species control plan during the construction phase may lead to further impacts on faunal habitat during the operation phase.


Visual

Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure.


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BEFORE MITIGATION


AFTER MITIGATION



Noise

Localized and temporary increase in noise levels due to the presence of delivery/transporting vehicles in the immediate surroundings.


Traffic

Increase in traffic volumes as a result of delivery which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the operational site.


DECOMMISSIONING AND CLOSURE PHASE

Social-economic

Possible boost in short term employment and local small business opportunities.

LOW (-) LOW (-)

Generation of dust potentially resulting in a health and nuisance impact.


Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly.

LOW (-) LOW (-)

Clearing of land which may potentially impact on the sense of place.


Potential squatting of job seekers. VERY LOW (-) VERY LOW (-)




Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality.


Debris from poor handling of materials and/or waste blocking watercourses may result in flow (-) impediment and pollution.


Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the footprint area.


Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources.


Debris from poor handling of materials and/or waste blocking watercourses nay result in flow (-) impediment and pollution.




Groundwater

Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination.


Improper storage and handling of hazardous materials leading to groundwater contamination.


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BEFORE MITIGATION


AFTER MITIGATION


Potential impacts on wetlands and aquatic ecosystems including: • Localised changes to the riparian areas as a result of vegetation clearing; • Sedimentation of riparian resources leading to smothering of wetland and aquatic flora; • Loss of habitat and riparian zone ecological structure as a result of site clearance activities and uncontrolled riparian zone degradation; • Deterioration of wetland water quality due to accidental spillages of hydrocarbons and poor waste management; • Impact on the riparian systems as a result of changes to the sociocultural service provision of wetlands; • Increased runoff due to topsoil removal and vegetation clearance leading to possible erosion and sedimentation of riparian resources; • Uncontrolled movement of vehicles and construction personnel may result in soil compaction and levelling as well as loss of riparian habitat.


Air Quality

Dust generating activities associated with the decommissioning and closure phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.


Climate change



Soils Land Capability and Land Use impacts

Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil.


Clearing of vegetation outside of the Tank Farm footprint area. LOW (-) VERY LOW (-)

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials.

MEDIUM LOW (-) LOW (-)

Potential compaction and erosion of soils removed and stockpiled during excavation activities.


Loss of topsoil due to erosion of areas exposed following excavation and stockpiling.



No additional impacts identified.

Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated materials, structures and building material from the decommissioning of the CF 2 Expansion Project.





Flora



Generation of waste and incorrect disposal from decommissioning material leading to disturbance of natural vegetation.


Fauna

Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general decommissioning activities.


Loss of faunal diversity and ecological integrity as a result of decommissioning activities, erosion, poaching and faunal species trapping.




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BEFORE MITIGATION


AFTER MITIGATION

Visual

Visual intrusion as a result of the movement of machinery and the decommissioning of the required infrastructure.




Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings.


Traffic

Increase in traffic volumes as a result of decommissioning activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the site.


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Environmental Management Program

SRK has compiled an EMPr for the CF 2 proposed Tanks Expansion Project. The EMPr specifies the

control and mitigation measures that are recommended in order to effectively manage the identified

biophysical and social impacts resulting from the CF 2 proposed Tanks Expansion Project.

Monitoring and assigned responsibilities are also stipulated in the EMPr for environmental aspects

that could possibly give rise to environmental impacts. The EMPr together with the BAR has been

made available for public comment and will subsequently be amended to incorporate any issues

identified by I&APs or stakeholders.

No – Go Alternative

Sustainable domestic production and supply of cleaner fuels is essential in order to realise a

competitive South African economy since liquid fuels remain the most prominent energy carrier for

transportation in the country. The CF 2 proposed Tanks Expansion Project will ensure the continued

production of fuels in-line with legislative and market related changes, which in turn will allow for the

continuation of considerable economic benefits, both locally and within the greater area of the province

and country as Sasol contributes significantly to the South African economy. Over 27 000 people are

employed by the Sasol groups, while approximately 140 000 people are supported by these staff

members. The conversion of the Sasol Synfuels Operations to CF 2 in response to the changes in

regulations will also have a positive impact on cumulative air quality.

Without the conversion of the Sasol Synfuels Operations to CF 2, Sasol Secunda will not be able to

continue with the production of fuels, as it will not be in line with legislative requirements. This could

potentially result in unemployment of a large number of residents in Secunda and the surrounding

communities accumulating to the current 40% unemployment rate in the Gert Sibande Local

Municipality. The opportunity to keep pace with improved vehicle engine technology and address

environmental degradation as a result of harmful emissions from vehicles will also be lost.

The Socio-economic studies conducted for the construction and operation of the CF 2 Tanks found

that it will have positive impacts on economic status due to the prolonged activities of Sasol Group of

Companies, maintaining the current employment statistics. It will further have a positive socio-

economic benefit by providing a sustainable domestic supply of cleaner fuels to support a more

competitive South African economy.

Authorisation Opinion

The management of the impacts identified in the BAR for the construction, operation and

decommissioning phases is through a comprehensive range of programmes and plans contained in

the EMPr. Implementation of these plans and programmes together with mitigation measures

stipulated in the EMPr will be institutionalized through regular monitoring and auditing.

It can be concluded that the CF 2 proposed Tanks Expansion Project will comply with the principles of

the NEMA, which embraces sustainability. The Stakeholder Engagement Process has been

undertaken as per NEMA and the EIA Regulations (2014, as amended in 2017) and it is believed that

stakeholders have been provided with sufficient time to raise any comments or concerns, and those

that have been raised have been adequately addressed.

It is the opinion of the EAP that the proposed alternative is the Best Practical Environmental Option,

as described in the NEMA, to realize the objectives of the project. Taking cognisance of the context of

the CF 2 Tank Expansion Project within the established Sasol Synfuels Operations, no additional

alternatives were assessed in detail.

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Recommendations

Once MDARDLEA has reviewed the BAR, they will need to determine whether the proposed CF 2

Tank Expansion project may be undertaken and whether there is sufficient knowledge and information

pertaining to the proposed project available so that a decision can be made. Following the decision

made by the Competent Authorities, a positive or negative EA will be issued detailing the reason

therefore and any conditions applicable to the proposed CF 2 Tank Expansion project. This decision

will be communicated to the I&APs, stipulating the period available to appeal the decision in terms of

the NEMA.

Should the BAR and EMPr be approved, SRK advocate that the following recommendations

summarised below be considered and adhered to:

• Where relevant, the mitigation measures as suggested in the EMPr should be implemented during

all phases of the proposed CF 2 Tank Expansion project;

• The approved EMPr should be implemented and audited by Sasol to ensure compliance. This

may be incorporated into Sasol’s existing auditing and monitoring procedures.

Way Forward

The Draft BAR (this document) is available for viewing at the following venues:

• Govan Mbeki Library;

• Sasol Recreation Club;

• SRK Offices (Pretoria);

• SRK Website (http://www.srk.co.za/en/library/za-public-documents).

In addition, digital copies of the report without appendices may be emailed to l&APs on request.


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Table of Contents

Executive Summary ..................................................................................................................................... ii

List of Abbreviations .................................................................................................................................. xxi

1 Introduction .................................................................................................................. 1

1.1 Background ......................................................................................................................................... 1

1.2 Approach to the Basic Assessment Study .......................................................................................... 2

1.3 Study Objective ................................................................................................................................... 4

1.4 Report Structure .................................................................................................................................. 5

1.5 Report Index in Relation to the NEMA Regulations ............................................................................ 7

1.6 Details of the Proponent ..................................................................................................................... 8

1.7 Details of the Environmental Assessment Practitioner ....................................................................... 8

2 Regulatory Framework ............................................................................................... 10

2.1 Constitution of the Republic of South Africa ..................................................................................... 10

2.2 The National Environmental Management Act (Act No. 107 of 1998) as Amended ........................ 10

2.3 EIA Regulations (GNR. 982) of the NEMA ....................................................................................... 11

2.4 National Environmental Management: Waste Act (Act No. 59 of 2008) ........................................... 11

2.5 National Environmental Management: Air Quality Act (Act No. 39 of 2004) .................................... 12

2.5.1 Air Quality Standards ............................................................................................................ 13

Particulate Matter .............................................................................................................................. 13

2.5.2 Sulfur Dioxide ........................................................................................................................ 14

2.5.3 Nitrogen Dioxide .................................................................................................................... 14

2.6 National Water Act (Act No. 36 of 1998) ........................................................................................... 15

2.7 Occupational Health and Safety Act (Act No. 85 of 1993) ................................................................ 15

2.8 Promotion of Access to Information Act (Act No. 2 of 2000) ............................................................ 15

2.9 Major Hazard Installations ................................................................................................................ 15

3 Policy Framework ....................................................................................................... 17

4 Project Description ..................................................................................................... 18

4.1 Creosote Diesel ................................................................................................................................. 18

4.2 Cold Tar Naphtha / Benzene ............................................................................................................ 20

4.3 Tert-amyl Methyl Ether ...................................................................................................................... 20

4.4 Medium Fuel Oil ................................................................................................................................ 21

4.5 Ethylhexyl Nitrate .............................................................................................................................. 22

4.6 Services and Infrastructure ............................................................................................................... 23

4.7 Employment ...................................................................................................................................... 23

4.8 Location and Context of the Project Area ......................................................................................... 24

4.8.1 Regional setting ..................................................................................................................... 24

4.8.2 Directions and approximate distances to the towns near the CF 2 proposed Tanks Expansion Project ................................................................................................................................... 24

5 Project Alternatives .................................................................................................... 27

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5.1 Location, Activity, and Operation Alternatives .................................................................................. 27

5.1.1 Cold Tar Naphtha / Benzene Storage ................................................................................... 27

5.1.2 TAME Storage Tanks ............................................................................................................ 27

5.1.3 Diesel Creosote ..................................................................................................................... 28

5.1.4 Medium Fuel Oil .................................................................................................................... 28

5.2 Design and Technology Alternatives ................................................................................................ 28

5.2.1 Underground Storage Tanks ................................................................................................. 28

5.3 No – Go Alternative ........................................................................................................................... 28

5.4 Alternative Conclusion ...................................................................................................................... 29

6 Description of the Affected Environment ................................................................. 30

6.1 Socio – Economic ............................................................................................................................. 30

6.2 Geology ............................................................................................................................................. 30

6.2.1 Site Specific Geology (SRK, 2019) ....................................................................................... 31

6.3 Geotechnical Investigation (SRK, 2019) ........................................................................................... 31

6.3.1 Berm ...................................................................................................................................... 31

6.3.2 Plant ...................................................................................................................................... 31

6.3.3 Geotechnical Environmental Impact Assessment ................................................................. 32

6.4 Surface Water and Wetlands ............................................................................................................ 34

6.5 Geohydrology .................................................................................................................................... 37

6.5.1 Site Specific Groundwater Chemistry (SRK, 2019) .............................................................. 39

6.6 Air Quality .......................................................................................................................................... 39

6.6.1 SO2 Monitoring Data ............................................................................................................. 41

6.6.2 NO2 monitoring data ............................................................................................................. 41

6.6.3 CO monitoring data ............................................................................................................... 44

6.6.4 PM10 and PM2.5 monitoring data ............................................................................................ 44

6.6.5 Dispersion Modelling Results ................................................................................................ 49

6.6.6 Predicted VOC concentrations .............................................................................................. 49

6.7 Climate .............................................................................................................................................. 54

6.7.1 Description of South African Climate .................................................................................... 54

6.7.2 Climate Conditions at the Project Site ................................................................................... 56

6.7.3 Rainfall................................................................................................................................... 58

6.7.4 Temperature .......................................................................................................................... 60

6.7.5 Wind Field ............................................................................................................................. 62

6.7.6 Bosjespruit Station Data ........................................................................................................ 62

6.7.7 Lakes Environmental ............................................................................................................. 65

6.8 Visual ................................................................................................................................................ 68

6.9 Cultural and Heritage ........................................................................................................................ 68

6.10 Noise ............................................................................................................................................... 68

6.11 Topography ....................................................................................................................................... 69

6.12 Land Use and Land Capability .......................................................................................................... 71

6.13 Soils ............................................................................................................................................... 71

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6.13.1 Site Specific Soil Chemistry (SRK, 2019) ............................................................................. 71

6.14 Biodiversity ........................................................................................................................................ 72

6.15 Health and Safety.............................................................................................................................. 74

7 Stakeholder Engagement Process ............................................................................ 75

7.1 Objectives of the Stakeholder Engagement Process ....................................................................... 75

7.2 Objectives of this Section .................................................................................................................. 75

7.3 Stakeholder Engagement Process Followed .................................................................................... 76

7.4 Authority Consultation ....................................................................................................................... 76

7.5 Placement of Site Notices and Newspaper Advertisements............................................................. 76

7.6 Summary of Interested and Affected Party Issues ........................................................................... 77

7.7 Notification on the Availability of the Basic Assessment Report ....................................................... 77

7.8 Process for the Remainder of the Study ........................................................................................... 77

7.9 Public Participation Conclusion ......................................................................................................... 77

8 Motivation for the Need and Desirability .................................................................. 79

9 Methodology for Impact Identification and Assessment ........................................ 80

10 Assessment of Environmental Impacts .................................................................... 83

10.1 Potential Environmental Issues Identified for the Project ................................................................. 83

10.2 Pre-Construction and Construction Phase ....................................................................................... 83

10.2.1 Socio – Economic Impacts .................................................................................................... 84

10.2.2 Surface Water ....................................................................................................................... 85

10.2.3 Groundwater .......................................................................................................................... 86

10.2.4 Wetlands................................................................................................................................ 86

10.2.5 Air Quality .............................................................................................................................. 87

10.2.6 Climate Change ..................................................................................................................... 87

10.2.7 Soils, Land Use and Land Capability .................................................................................... 87

10.2.8 Geotechnical Considerations ................................................................................................ 88

10.2.9 Topography ........................................................................................................................... 89

10.2.10 Cultural and Heritage ........................................................................................................ 89

10.2.11 Biodiversity ........................................................................................................................ 90

10.2.12 Visual ................................................................................................................................ 90

10.2.13 Noise ................................................................................................................................. 90

10.2.14 Traffic ................................................................................................................................ 91

10.2.15 Waste Management .......................................................................................................... 91

10.3 Operation Phase ............................................................................................................................... 98

10.3.1 Socio – Economic Impacts .................................................................................................... 98

10.3.2 Surface Water ....................................................................................................................... 99

10.3.3 Groundwater .......................................................................................................................... 99

10.3.4 Wetlands................................................................................................................................ 99

10.3.5 Air Quality ............................................................................................................................ 100

10.3.6 Climate Change ................................................................................................................... 100

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10.3.7 Soils, Land Use and Land Capability .................................................................................. 100

10.3.8 Geotechnical Considerations .............................................................................................. 101

10.3.9 Topography ......................................................................................................................... 101

10.3.10 Cultural and Heritage ...................................................................................................... 101

10.3.11 Biodiversity ...................................................................................................................... 101

10.3.12 Visual .............................................................................................................................. 102

10.3.13 Noise ............................................................................................................................... 102

10.3.14 Traffic .............................................................................................................................. 102

10.3.15 Waste Management ........................................................................................................ 102

10.4 Decommissioning Phase ................................................................................................................ 109

10.4.1 Socio Economic ................................................................................................................... 109

10.4.2 Surface Water ..................................................................................................................... 110

10.4.3 Groundwater ........................................................................................................................ 110

10.4.4 Wetlands.............................................................................................................................. 110

10.4.5 Air Quality and Climate Change .......................................................................................... 111

10.4.6 Soils, Land Use and Land Capability .................................................................................. 111

10.4.7 Geotechnical Considerations .............................................................................................. 111

10.4.8 Topography ......................................................................................................................... 112

10.4.9 Cultural and Heritage .......................................................................................................... 112

10.4.10 Biodiversity ...................................................................................................................... 112

10.4.11 Visual .............................................................................................................................. 113

10.4.12 Noise ............................................................................................................................... 113

10.4.13 Traffic .............................................................................................................................. 113

10.4.14 Waste Management ........................................................................................................ 113

10.5 Cumulative Impacts......................................................................................................................... 121

10.5.1 Hydrological and Surface Water Impacts ............................................................................ 121

10.5.2 Air Quality Impacts .............................................................................................................. 122

10.5.3 Noise Impacts ...................................................................................................................... 122

11 Summary of the Findings of the Specialist Studies .............................................. 123

11.1 Summary of the Air Quality Assessment ........................................................................................ 123

11.2 Summary of the Geotechnical Assessment .................................................................................... 123

12 Opinion and Conditions on Authorisation ............................................................. 124

13 Environmental Impact Statement ............................................................................ 125

14 Assumptions, Uncertainties and Gaps in Knowledge ........................................... 126

15 Environmental Objectives of the CF 2 proposed Tanks Expansion Project ....... 127

16 Undertaking of Oath by the EAP ............................................................................. 128

17 Conclusion ................................................................................................................ 129

18 Way Forward ............................................................................................................. 130

19 References ................................................................................................................ 131

Appendices .................................................................................................................... 132

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Appendix A: Curriculum Vitae of the Project Team .................................................. 133

Appendix B: SRK Project Experience ........................................................................ 134

Appendix C: List of Interested and Affected Parties ................................................ 135

Appendix D: Proof of Newspaper Adverts ................................................................ 136

Appendix E: Background Information Document ..................................................... 137

Appendix F: Interested and Affected Parties Notification Letter ............................. 138

Appendix G: Environmental Management Programme ............................................ 139

Appendix H: Specialist Studies .................................................................................. 140

Appendix I: MDARDLEA Correspondence ................................................................ 141

List of Tables Table 1-1: Additional tanks required by Sasol .................................................................................................... 2

Table 1-2: Requirements of Section 22 of GNR 982 .......................................................................................... 7

Table 1-3: Details of the proponent .................................................................................................................... 8

Table 1-4: Details of the EIA/EMPr project team ................................................................................................ 9

Table 2-1: NEMA listed activities as applicable for the CF 2 Tank Expansion Project .................................... 11

Table 2-2: Listed Activity in terms of the NEM:AQA ......................................................................................... 13

Table 2-3: Ambient air quality standards for PM10 ............................................................................................ 14

Table 2-4: Ambient air quality standards for PM2.5 ........................................................................................... 14

Table 2-5: Ambient air quality standards for SO2 ............................................................................................. 14

Table 2-6: Ambient air quality standards for NO2 ............................................................................................. 15

Table 3-1: Instruments considered during the EIA/EMPr process ................................................................... 17

Table 4-1: Farm affected by the CF 2 proposed Tanks Expansion Project ..................................................... 24

Table 4-2: Coordinates of the proposed tankage ............................................................................................. 24

Table 4-3: Nearby towns to the CF 2 proposed Tanks Expansion Project ...................................................... 25

Table 6-1: Annual SO2 concentrations for the period 2016 to 2018 ................................................................. 41

Table 6-2: Annual NO2 concentrations for the period 2016 to 2018 ................................................................. 41

Table 6-3: Annual CO concentrations for the period 2016 to 2018 .................................................................. 44

Table 6-4: Annual PM10 concentrations for the period ..................................................................................... 44

Table 6-5: Annual PM2.5 concentrations for the period ..................................................................................... 45

Table 6-6: Predicted VOC concentrations at the sensitive receptors ............................................................... 50

Table 6-7: Weather station ............................................................................................................................... 56

Table 6-8: Monthly rainfall ................................................................................................................................ 58

Table 6-9: Monthly temperatures for Bosjespruit and Lakes Environmental .................................................... 60

Table 7-1: Location and coordinates of the sites notices ................................................................................. 77

Table 9-1: Criteria for assessing significance of impacts ................................................................................. 81

Table 9-2: Significance rating matrix ................................................................................................................ 82

Table 9-3: Positive/negative mitigation ratings ................................................................................................. 82

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Table 10-1: Impact assessment of the identified impacts arising during the pre-construction and construction phase.......................................................................................................................................... 92

Table 10-2: Impact assessment of the identified impacts arising during the operational phase .................... 104

Table 10-3: Impact assessment of the identified impacts arising during the decommissioning phase .......... 115

List of Figures Figure 1-1: Locality map of the proposed Sasol recovery optimisation project .................................................. 3

Figure 1-2: Flow diagram of the EIA process to be followed for the proposed authorisation ............................. 4

Figure 4-1: Illustration of the Creosote Diesel Tanks ............................................................................................ 19

Figure 4-2: Preliminary design of the Creosote Diesel Tanks .......................................................................... 19

Figure 4-3: Close up illustration of the CTN tank ............................................................................................. 20

Figure 4-4: Close up Illustration of the TAME Tanks ........................................................................................ 21

Figure 4-5: Close up illustration of the MFO Tanks .......................................................................................... 22

Figure 4-6: Close up illustration of the EHN Tanks .......................................................................................... 23

Figure 4-7: Regional map illustrating the CF 2 proposed Tanks Expansion Project ........................................ 26

Figure 6-1: Illustration of the test pits conducted for the CF 2 proposed Tanks Expansion Project. ............... 33

Figure 6-2: Illustration of the surface water resources in and around the CF 2 proposed Tanks Expansion Project. ....................................................................................................................................... 35

Figure 6-3: Illustration of the surface water monitoring points around the CF 2 proposed Tanks Expansion Project. ....................................................................................................................................... 36

Figure 6-4: Illustration of the groundwater monitoring points around the CF 2 proposed Tanks Expansion Project. ....................................................................................................................................... 38

Figure 6-5: Illustration of the air quality monitoring stations ............................................................................. 40

Figure 6-6: 1-hour SO2 concentrations ............................................................................................................. 42

Figure 6-7: 1-hour NO2 concentrations ............................................................................................................. 43

Figure 6-8: 1-hour CO concentrations .............................................................................................................. 46

Figure 6-9: 24 hour PM10 concentrations .......................................................................................................... 47

Figure 6-10: 24 hour PM2.5 concentrations ....................................................................................................... 48

Figure 6-11: 1 hour VOC concentration isopleths for the proposed tanks ............................................................... 51

Figure 6-12: 24 hour VOC concentration isopleths for the proposed tanks ..................................................... 52

Figure 6-13: Annual VOC concentration isopleths for the proposed tanks ...................................................... 53

Figure 6-14: Annual variations in the positions of the South Atlantic and South Indian anticyclones (Source: Preston-Whyte et al., 2000) ....................................................................................................... 55

Figure 6-15: Important features of the surface atmospheric circulation over southern Africa (Source: Preston-Whyte et al., 2000) ..................................................................................................................... 55

Figure 6-16: Location of weather stations ....................................................................................................... 57

Figure 6-17: Rainfall data for Bosjespruit and Lakes ....................................................................................... 59

Figure 6-18: Comparison of temperature data ................................................................................................. 61

Figure 6-19: All hours, daytime and night-time wind roses (Bosjespruit weather station data) ....................... 63

Figure 6-20: Seasonal wind roses (Bosjespruit weather station data) ............................................................. 64

Figure 6-21: Wind class frequency distribution (Station Data) ......................................................................... 65

Figure 6-22: All hours, daytime and night-time wind roses (Lakes Environmental) ......................................... 66

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Figure 6-23: Seasonal wind roses (Lakes Environmental) ............................................................................... 67

Figure 6-24: Wind class frequency distribution (Lakes Environmental, 2017) ................................................. 68

Figure 6-25: Illustration of the site topography ................................................................................................. 70

Figure 6-26: Illustration of the biodiversity habitat in an around the proposed CF 2 Tanks Project ................. 73

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List of Abbreviations

AEL Air Emission License

BAR Basic Assessment Report

BAP Basic Assessment Process

BID Background Information Document

CBA Critical Biodiversity Areas

CNT Cold Tar Naphtha / Benzene

DEA Department of Environmental Affairs

DEAT Department of Environmental Affairs and Tourism

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EHN Cetane Enhancer

EIA Environmental Impact Assessment

EMPr Environmental Management Programme

ESA Ecological Support Areas

GNR Government Notice Regulation

HDPE High density polyethylene

HPA Highveld Priority Area

I&APs Interested and Affected Parties

IDP Govan Mbeki Integrated Development Plan

MDARDLEA Mpumalanga Department of Agriculture, Rural Development, Land and

Environmental Affairs

MFO Medium Fuel Oil

NAAQA National Ambient Air Quality Standards

NEMA National Environmental Management Act (Act No. 107 of 1998)

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

NEM:WA National Environmental Management Waste Act (Act No. 59 of 2008)

NWA National Water Act (Act No. 36 of 1998)

PAIA Promotion of Access to Information Act (Act No. 2 of 2000)

PM10 Particulate Matter 10

ppm Parts per Million

SANBI South African National Biodiversity Institute

SDF Govan Mbeki Spatial Development Framework

SHE Safety, Health and Environment

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SRK SRK Consulting South Africa (Pty) Ltd

TAME Tertiary Amyl Methyl Ether

VOC Volatile Organic Compounds

WMA Water Management Area

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1 Introduction Sasol South Africa Ltd (Sasol) is situated in close proximity to the town of Secunda in the Mpumalanga

Province, and approximately 16 km south-east of Kinross and 26 km south-west of Bethal. Sasol

produce liquid fuels (petrol, diesel and paraffin), as well as industrial pipeline gas and a range of

chemical feedstock compounds, including the building blocks for industrial solvents and polymers,

through the gasification process of approximately 40 million tons of coal per annum. The gasification

is done with steam at high pressure to produce hydrogen and carbon monoxide, followed by the

conversion of this gas mixture to hydrocarbons via the Fischer-Tropsch process.

The main products Sasol produce are:

• Fuel components;

• Chemical components; and

• Co-products.

From these main products and further value-adding processes, Sasol deliver diesel, petrol (gasoline),

naphtha, kerosene (jet fuel), Liquid Petroleum Gas, olefins, alcohols, polymers, solvents, surfactants,

co-monomers, ammonia, methanol, crude tar acids, sulphur, illuminating paraffin, bitumen and fuel oil.

Even further processing produces numerous additional products (Sasol South Africa (Pty) Ltd, 2018).

The area of Mpumalanga in which Sasol is located was historically a rural farming area. The Highveld

Ridge has since been modified by mining and industrial activities related to coal and gold mining,

power generation and agriculture. In turn, the land-use in the Secunda region has changed significantly

over the last 50 years from a rural agricultural setting to being highly industrialised.

1.1 Background

A significant contributor to greenhouse gas emissions is the transport sector posing a risk to the

environmental and human health. More stringent fuel specifications and standards have been

developed aimed at the reduction of emissions from vehicles as well as improved air quality.

New fuel specifications (Clean Fuels (CF) I) were developed and introduced in 2006 in the form of

regulations under the Petroleum Products Act (Act No. 120 of 1977) (PPA) and revised South African

National Standards (SANS) 342:2016 specifications relating to petrol and diesel.

These new petrol specifications prohibited the addition of lead in unleaded petrol, but allowed the use

of other metals, such as manganese and phosphorus in metal-containing unleaded petrol (lead

replacement petrol) to cater for the older vehicles that might suffer from valve seat recession with the

removal of lead from petrol.

The diesel specifications required the sulphur levels in diesel to be dropped from a maximum of 3 000

parts per million (ppm) to 500 ppm, with a niche grade of 50 ppm being introduced. This resulted in an

improvement in the diesel exhaust emissions of vehicles.

Regulations regarding the introduction of CF 2 were gazetted in June 2012 which indicated that it

would come into operation on 1 July 2017. These regulations, among other legislation, indicates

specifications to conform to, such as those contained in the SANS 342: 2016 for petrol and diesel.

These specifications are currently being finalised. The regulations also require other specifications to

conform to such as those contained in the national standards for petrol and diesel. The target date of

July 2017 has been postponed to a date to be determined in the future, once various aspects relating

to the financial implications of producing the cleaner fuels have been finalised.



A market led change to Clean Fuels (CF) 2 fuel quality is currently foreseen to occur by 2021. It is

further predicted that the Department of Energy will regulate the conversion to CF 2 between 2023

and 2025. In line with these expected changes, Sasol has launched the CF 2 program to lead and

coordinate Sasol’s response to accommodate changes in the market.

To ensure future sustainability it is imperative that the Sasol Synfuels Operations are converted to CF

2. To support these technical solutions, Sasol will require various additional tankage in the existing

Synfuels Tank Farm located in Secunda. The location and layout of the proposed tanks is illustrated

in Figure 1-1. The following tanks, as detailed in Table 1-1, will be required:

Table 1-1: Additional tanks required by Sasol

Product Storage Volume (m3)

Number of Tanks

Tank Diameter (m)

Tank Height

Cold Tar Naphtha / Benzene (CTN) 12 000 1 26 25

Tertiary Amyl Methyl Ether (TAME) 30 000 2 29 20

Creosote Diesel 30 000 3 26 21

Medium Fuel Oil (MFO) 3 000 2 13 13

EHN (Cetane Enhancer) 300 2 5 10

Total 75 300 10

1.2 Approach to the Basic Assessment Study

SRK Consulting South Africa (Pty) Ltd (SRK) has been appointed by Sasol to conduct the Basic

Assessment Report (BAR), Environmental Management Programme (EMPr), and associated

Stakeholder Engagement for the CF 2 proposed Tanks Expansion Project. The required environmental

study for the proposed establishment, operation, and future closure of the CF 2 proposed Tanks

Expansion Project will be conducted in terms of the following legislative mandate:

• BAR and EMPr in terms of the Environmental Impact Assessment (EIA) Regulations (2014)

published in Government Notice Regulation (GNR) 982 and read with Sections 21 – 25 and 59 of

the National Environmental Management Act (Act No 107 of 1998) (NEMA); and

• Stakeholder Engagement in fulfilment of Sections 41-44 of GNR 982 promulgated in terms of the

NEMA;

• The CF 2 proposed Tanks Expansion Project will further require an Air emissions Licence (AEL)

in accordance with Section 21 of the National Environmental Management: Air Quality Act (Act

No. 39 of 2004) (NEM:AQA) and as such an AEL application process will be undertaken in a

separate process by Sasol as part of the AEL review.

The EIA Regulations promulgated in terms of NEMA in December 2014 published in GNR 982 list a

number of activities that may not commence prior to obtaining an Environmental Authorisation (EA).

The listed activities that are more relevant to this project, as well as the EIA requirements associated

with these activities, are described in more detail in Section 2.2. The regulations have set out the

requirements for the assessment of these activities.

The Competent Authority identified by NEMA with evaluating the EIA and subsequently making a

decision, in the case of the CF 2 proposed Tanks Expansion Project, will be the Mpumalanga

Department of Agriculture, Rural Development, Land and Environmental Affairs (MDARDLEA).

The prescribed EIA process is graphically illustrated in Figure 1-2.



SASOL CF 2 TANKS PROJECT

LOCALITY MAP Project No.

539945

Figure 1-1: Locality map of the proposed Sasol recovery optimisation project



SASOL CF 2 TANKS PROJECT BASIC ASSESSMENT PROCESS

Project No. 539945

Figure 1-2: Flow diagram of the EIA process to be followed for the proposed authorisation

1.3 Study Objective

The aim of the BAR was to assess the significance of the potential impacts, to assess the preferred

alternatives and to determine measures to mitigate the negative impacts and enhance the benefits on

the positive impacts relating to the CF 2 proposed Tanks Expansion Project.

The Basic Assessment Process (BAP) includes the development of an impact assessment and EMPr.

This documents the management, mitigation and monitoring measures that need to be incorporated

during construction, operation and decommissioning of the CF 2 proposed Tanks Expansion Project.

The EMPr strives to effectively mitigate the impacts and enhance the positive benefits of the project.

The Stakeholder Engagement Process has been an integral component of the BAR, in order to gain

local knowledge on the current issues and concerns in the area. This BAR strives to meet objectives

of the NEMA and associated regulations stipulated in Appendix 1, 3, 4 of GNR 982.

The detailed objectives of the BAR are to:

• Inform the relevant Authorities of the CF 2 proposed Tanks Expansion Project;

• Inform the broad range of Interested and Affected Parties (I&APs) in the area on the possible

impacts and mitigation measures of the CF 2 proposed Tanks Expansion Project, and explain the

EIA process that was followed;

Approximate

scheduling

Basic Assessment Process Public Participation

Communicate the application

for the proposed CF 2 project.

I&APs are required to register

their interest on the project

database and raise issues of

concern, within 30 days.

I&APs will have the

opportunity to comment to the

Basic Assessment Report.

January 2019

June/July 2019

Novem

I&APs are informed about the decision and proceeding steps. Project construction may only commence once approval has been received from the MDARDLEA.

The comments received from I&APs will be included in the Basic Assessment Report before it is submitted to MDARDLEA for their decision making.

November 2019

August/September 2019

May 2019

Step 4: Submit Basic Assessment Report

Collate issues and concerns from I&APs into the BAR. After commenting period, update report and submit to MDARDLEA for

decision.

Step 5: Notification of Environmental

Authorisation and Appeals Period.

MDARDLEA to either grand /refuse authorisation or require submission

of additional information or specialist studies.

Stage 3: Basic Assessment (BAR) for Public

Comment

The Basic Assessment is undertaken in order to identify and

assess potential environmental impacts.

Stage 2: Submission of Application The proposed project is registered with the MDARDLEA. A

reference number has been obtained from the authorities.

Stage 1: Pre Application Public Consultation The proposed project has been advertised and the I&APs given

the opportunity to register and comment on the report.



• Indicate how I&APs were afforded opportunities to contribute to the project, verify that the issues

they raised were considered, and comment on the findings of the impact assessment studies;

• Provide information on the alternatives considered;

• Describe the baseline receiving environment;

• Describe the environmental issues and concerns identified and the methodology used to assess

the significance of the impacts;

• Present the findings and recommendations in a coherent way, facilitating the Competent Authority

to make a clear and informed decision;

• Obtain contributions to the report from I&APs (including the Applicant, Authorities and Organs of

State) and ensure that all these issue or concerns are documented and addressed in the BAR

submitted to the Competent Authorities;

• Assess the receiving environment in the immediate vicinity of the CF 2 proposed Tanks Expansion

Project;

• Identify and assess the significant impacts associated with the CF 2 proposed Tanks Expansion

Project;

• Formulise mitigation measures to minimise the negative impacts identified and issues raised by

I&APs; and

• Enhance the positive impacts of the CF 2 proposed Tanks Expansion Project.

1.4 Report Structure

This BAR has been prepared to meet the requirements of the NEMA and have included the following

information:

Section 1: Introduction

This section provided a background to the basis of the BAR and introduced the CF 2 proposed Tanks

Expansion Project. This section also provided an overview of, and approach to, the EIA process and

sets out the objectives of the report. Details of the Environmental Assessment Practitioner (EAP) and

of the applicant are provided in this section in adherence to Appendix 1, Regulation 3(1)(a) of GNR

982.

Section 2: Regulatory Framework

This section provided a summary and interpretation of the relevant legislation pertaining to the

construction and operation of the CF 2 proposed Tanks Expansion Project in adherence to Appendix

1, Regulation 3(1)(e) of GNR 982.

Section 3: Policy Framework

This section provided a summary of the relevant policies and planning documentation pertaining to

the construction and operation of the CF 2 proposed Tanks Expansion Project in adherence to

Appendix 1, Regulation 3(1)(e) of GNR 982.

Section 4: Project Description

This section provided an overview of the project area, the proponent’s motivation for undertaking the

project, and an overview of the process revolving around the CF 2 proposed Tanks Expansion Project.

Furthermore, this section provides details on the location of the activity which will include a location

map, in order to fulfil the requirements of Appendix 1, Regulation 3(1)(b)(c) and (d) of GNR 982.



Section 5: Project Alternatives

A description of the alternatives that are assessed, including the No-Go option is provided in this

section. A motivation for the preferred alternative is further described together with the site selection

matrix, where necessary, in order to fulfil the requirements of Appendix 1, Regulation 3(1)(g),

(h)(i)(ix)(x) and (xi) of GNR 982.

Section 6: Description of the Affected Environment

This section briefly described the receiving environment in terms of the biophysical and socio–

economic conditions in accordance with Appendix 1, Regulation 3(1)(h)(iv) of GNR 982.

Section 7: Stakeholder Engagement Process

This section described the detailed approach that was adopted for the Stakeholder Engagement

Process, and the way forward in notifying the registered I&APs. A summary is provided detailing the

issues and concerns raised by the I&APs in accordance with Appendix 1, Regulation 3(1)(h)(ii) and

(iii) of GNR 982.

Section 8: Motivation for the Need and Desirability

This section provided a motivation on the need and desirability of the CF 2 proposed Tanks Expansion

Project in accordance with Appendix 1, Regulation 3(1)(f) of GNR 982.

Section 9: Methodology for Impact Identification and Assessment

This section provided a description on the methodology used for the impact assessment relating to

the CF 2 Tank Expansion Project in accordance with Appendix 1, Regulation 3(1)(h)(vi) and (i) of GNR

982.

Section 10: Assessment of Environmental Impacts

This section identified and assessed the potential positive and negative biophysical and social impacts

of the CF 2 proposed Tanks Expansion Project and its alternatives, taking into consideration the direct,

indirect and cumulative impacts. Possible mitigation measures are further described in accordance

with Appendix 1, Regulation 3(1)(h)(v)(vii)(viii), (i) and (j) of GNR 982.

Section 11: Summary of the Findings of the Specialist Studies

This section provided a description of the findings and impact management measures identified in the

specialist reports, indicating how these findings and recommendations have been included in the BAR

in accordance with Appendix 1, Regulation 3(1)(k) of GNR 982.

Section 12: Opinion and Conditions on Authorisation

This section provided an opinion of the EAP on the authorisation of the CF 2 proposed Tanks

Expansion Project. Conditions which should be associated with the conditions of the authorisation are

also explained in this section. The timeframe for which the EA is required is described. This section

fulfils the requirements of Appendix 1, Regulation 3(1)(n)(p) and (q) of GNR 982.

Section 13: Environmental Impact Statement

This section provided a summary of the key findings from the impact assessment and highlighted the

most favourable alternative. The environmental impact statement will be compiled in accordance with

Appendix 1, Regulation 3(1)(l) of GNR 982.

Section 14: Assumptions and Limitations

This section provided a description of any assumptions and limitations pertaining to the CF 2 proposed

Tanks Expansion Project. All gaps in knowledge are made known, and areas indicated where

assumptions are necessary in accordance with Appendix 1, Regulation 3(1)(o) of GNR 982.



Section 15: Impact Management Objectives

This section provided a description of the proposed impact management objectives and outcomes for

the CF 2 proposed Tanks Expansion Project in accordance with Appendix 1, Regulation 3(1)(m) of

GNR 982.

Section 16: EAP Undertaking Under Oath

This section provided the EAP’s declaration of undertaking under oath or affirmation in relation to the

correctness of information provided, inclusion of stakeholder comments, inclusion of specialist

recommendations, and any information provided to the EAP by I&APs in fulfilment of Appendix 1,

Regulation 3(1)(r) of GNR 982.

Section 17-19: Conclusion, Recommendations and the Way Forward

This section summarized the key findings and recommendations of the impact assessment and

provided a summary on the way forward for the remainder of the EIA process, particularly the public

review of the BAR.

1.5 Report Index in Relation to the NEMA Regulations

Regulation 3, Appendix 1 of GNR 982 published in terms of NEMA precisely stipulates the minimal

requirement and issues that need to be addressed in the BAR. This report strives to address all these

requirements as per regulations. Table 1-2 indicates the regulations that have been addressed and

the section of the BAR where these requirements can be found.

Table 1-2: Requirements of Section 22 of GNR 982

GNR 982 Appendix 1 (3)

Description of Regulation Section Page

(1)(a) Details and expertise of the EAP Section 1.7 Page 8

(1)(b) Location of the activity Section 4.8 Page 24

(1)(c) A plan which locates the proposed activity Section 1.2, 4 Page 2, 18

(1)(d) Description of the scope of the proposed activity including the triggered listed activities

Section 2.2, Page 10

(1)(e) Identification and description of legislation, policies, and guidelines that have been considered

Section 2 Page 10

(1)(f) Motivation for the need and desirability Section 8 Page 79

(1)(g) Motivation for the preferred site Section 5 Page 29

(1)(h)(i)(x)(ix) Description of the proposed alternatives Section 5 Page 27

(1)(h)(ii)(iii) Details of the Stakeholder Engagement Process

Section 7 Page 75

(1)(h)(v) and (j) Description and assessment of the significance of any environmental impacts

Section 10 Page 83

(1)(h)(iv)(v)(vi)(vii)(xi) and (i)

Description of the environmental attributes and methodology for the assessment of the significance of any environmental impacts

Section 6, 9 , 80



GNR 982 Appendix 1 (3)

Description of Regulation Section Page

(1)(k) Summary of the findings of specialist reports

Section 11 Page 123

(1)(l) Environmental Impact Statement Section 13 Page 125

(1)(m) Description of the objectives of the impact management outcome.

Section 15 Page 127

(1)(n)(p) Opinion on the authorisation of the proposed activity.

Section 12 Page 124

(1)(o) Description of the assumptions, uncertainties and gaps in knowledge

Section 14 Page 126

(1)(q) Period for which environmental authorisation is required

Section 12 Page 124

(1)(r) EAP undertaking of oath Section 16 Page 128

(1)(s) Details of financial provision Not Applicable Not Applicable

(1)(t) Specific Information required by the Competent Authority

Not Applicable Not Applicable

(1)(u) Any other matters required in terms of Section 24 (4)(a) and (b) of the NEMA

Not Applicable Not Applicable

1.6 Details of the Proponent

For the purpose of this EIA the following person in Table 1-3 may be contacted at Sasol:

Table 1-3: Details of the proponent

Details Name

Name Simon van Renssen

Address Private Bag X 1000

Secunda

2302

Telephone (017) 610 5056

E Mail [email protected]

1.7 Details of the Environmental Assessment Practitioner

SRK commenced its practises in 1974 and has since been involved in a large variety of environmental

studies. SRK is a South African founded international organisation of professionals providing a

comprehensive range of consulting services to natural resource industries and organisations. South

African offices are staffed with over 400 professional consultants in nine offices, operating in a range

of disciplines, mainly related to the environment, water, social and mining sectors. Back-up and

peripheral expertise are available within these offices for all environmental projects. SRK has been

appointed by Sasol as the lead Environmental Assessment Practitioner (EAP). The project team

members as stipulated in Table 1-4 can be contacted at SRK for the purposes of this project.




Table 1-4: Details of the EIA/EMPr project team

Details Name

Name Dr Laetitia Coetser Andrew Caddick

Designation Project Manager/Reviewer Project coordinator, Stakeholder Engagement and report preparation.

Address PO Box 35290

Menlo Park

PO Box 35290

Menlo Park

0081 0081

Telephone (012) 361 9821 (012) 361 9821

Fax (012) 361 9912 (086) 231 3497

E Mail [email protected] [email protected]

The project manager, Dr Laetitia Coetser is a Principal Environmental Scientist at SRK, with 18 years’

experience in the environmental consultancy industry. Dr Laetitia Coetser is appropriately qualified

and registered with the relevant professional bodies. Dr Coetser is a registered as Professional Natural

Scientists (Pr.Sci.Nat. 403312/06) with the South African Council of Natural Scientific Professions and

has extensive experience in compilation, amendment and assessing environmental compliance of a

diverse set of EIA’s and EMPr’ s in terms of the Minerals and Petroleum Resources Act (Act No 28 of

2002) and NEMA.

Mr Andrew Caddick holds a Master’s degree in Geography and Environmental Science. He is an

Environmental Scientist at SRK with 10 years’ experience in the environmental field. His experience

lies in the management and compilation of EIA and EMPr processes and associated amendments,

coordination and execution of Stakeholder Engagement Processes, and management of multi-

disciplinary project teams. He is also involved in conducting environmental audits, site assessments,

waste and water management plans and licenses. He has solid knowledge and understanding of the

current environmental legislation pertaining to mining and non–mining projects.

Appendix A contains the curriculum vitae of the impact assessment project team and Appendix B

contains background on experience gained by SRK in the field of Environmental Management.





2 Regulatory Framework In order to protect the environment and ensure that this development is undertaken in an

environmentally responsible manner, the following Acts and Regulations have been identified as being

applicable during the pre–construction, construction, operation and decommissioning of the CF 2

proposed Tanks Expansion Project. These requirements will be adhered to during the EIA process.

2.1 Constitution of the Republic of South Africa

In terms of Section 24 of the Constitution of the Republic of South Africa (Act No. 108 of 1996)

(Constitution), everyone has the right to an environment that is not harmful to their health or well-being

and to have the environment protected, for benefit of present and future generations, through

reasonable legislation and other measures that prevent pollution and ecological degradation, promote

conservation and secure ecologically sustainable development and use of natural resources while

prompting justifiable economic and social development. The needs of the environment, as well as

affected parties, should thus be integrated into overall project management in order to fulfil the

requirements of Section 24 of the Constitution.

This EIA process for the CF 2 proposed Tanks Expansion Project focuses on the minimization of

environmental impacts resulting from the construction, operation and decommissioning of the CF 2

proposed Tanks Expansion Project in order to fulfil the requirements of Section 24 of the constitution.

2.2 The National Environmental Management Act (Act No. 107 of 1998) as Amended

The NEMA provides the overarching legislation for environmental governance in South Africa, giving

effect to Section 24 of the Constitution of the Republic of South Africa. NEMA sets out the fundamental

principles of Integrated Environmental Management that must be adhered to in order to ensure

sustainable development. These principles should apply to environmental decision making. Of

particular importance is NEMAs ruling that the interpretation of any law concerning the protection and

management of the environment must be guided by the principles of NEMA. The core nature of the

NEMA principles is the principle on sustainable development. This principle strives towards promoting

development that is simultaneously meeting the needs of the present generations without

compromising the needs of future generations to come.

Section 4(b) of the NEMA states that environmental management must be integrated, acknowledging

that all elements of the environment are linked and interrelated, and it must consider the effects of

decisions on all aspects of the environment and all people in the environment by pursuing the selection

of the best practicable environmental option. According to the NEMA, the best practicable

environmental option, most preferred option, means the option that provides the most benefit or

causes the least damage to the environment as a whole, at a cost acceptable to society in the long

term as well as in the short term.

Section 28 of the NEMA includes a far reaching general “Duty of Care” whereby care must be taken

to prevent, control and rehabilitate the effect of significant pollution and environmental degradation.

This section stipulates the necessity to protect the environment from degradation and pollution,

irrespective of the operations taking place or activities triggered/not triggered under GNR 983, GNR

984 and GNR 985 published in terms of NEMA. This section places emphasis on the fact that it is a

criminal offense to cause significant pollution or environmental degradation and is punishable by this

legislative framework.



2.3 EIA Regulations (GNR. 982) of the NEMA

The new EIA Regulations (GNR 982) were promulgated in 2014 (amended 2017) in terms of Sections

24 of the NEMA, to revise and manage the process, methodologies and requirements for the

undertaking of an EIA.

The EIA Regulations were published on 4 December 2014 and came into effect on 8 December 2014.

The EIA Regulations stipulate that the applicant for a development, where activities listed under GNR.

983, 984 or 985 are triggered, must appoint an independent EAP to manage the EIA process. An EA

must be obtained from the Competent Authority prior to the commencement of the proposed activities.

The purpose of the EA is to avoid unfavourable environmental impacts, or where these impacts cannot

be avoided, mitigated and effectively managed, to strive to reduce negative harm and enhance positive

impacts resulting from the project. The EIA Regulations stipulate the requirements of such

assessments to assist the decision-making process.

The EIA Regulations define two broad categories of EIA, namely a basic assessment and a scoping

and EIA. A basic assessment is generally intended for smaller scale projects, or activities whose

impacts are well understood and can be easily managed. The process for a basic assessment is

described in Appendix 1 of GNR. 982 and the environmental consultant must conduct a Stakeholder

Engagement Process as set out in Regulation 41 to 44.

The CF 2 proposed Tanks Expansion Project triggers activities listed under GNR. 983 as illustrated in

Table 2-1, thus requiring a BAP.

Table 2-1: NEMA listed activities as applicable for the CF 2 Tank Expansion Project

Governmental Notice R 983

34 The expansion of existing facilities or infrastructure for any process or activity where such expansion will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions, effluent or pollution.

The proposed project involves the expansion of an existing Sasol Synfuels Operations Tank Farm. The expansion (increased capacity and footprint) thus requires an AEL1 as stipulated in the NEM: AQA scheduled activities hence the requirement for a Basic Assessment process.

51 The expansion and related operation of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such storage facility will be expanded by more than 80 m3.

The conversion of Sasol Synfuels Operations to CF 2 will require additional storage tankage in the existing Sasol Synfuels Operations Tank Farm located in Secunda. The total additional storage will have a combined capacity of approximately 75 300 m3.

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

The National Environmental Management: Waste Act (Act No. 59 of 2008) (NEM:WA) was

implemented on 1 July 2009 and Section 20 of the Environment Conservation Act (Act No. 73 of 1989),

under which waste management was previously governed, was repealed.

The NEM:WA reforms the law regulating waste management in order to protect health and the

environment by providing reasonable measures for the prevention of pollution and ecological

degradation and for securing ecologically sustainable development; and to provide for:

1 A separate AEL Application process will be undertaken by Sasol as part of the AEL review process.



• National norms and standards for regulating the management of waste by all spheres of

government;

• Specific waste management measures;

• The licensing and control of waste management activities;

• The remediation of contaminated land; to provide for the national waste information system; and

• Compliance and enforcement.

In terms of the NEM:WA, all waste management activities must be licensed. According to Section 44

of the Act, the licensing procedure must be integrated with an EIA process in accordance with the

Regulations GNR 982 published in terms of the NEMA. Government Notice 718 listed the waste

management activities that require licensing. On 29 November 2013, GNR 718 was repealed and

replaced by a new list of waste activities under GNR 921 and amended in July 2015 by GNR 633. A

distinction is made between Category A waste management activities, which require a basic

assessment, and Category B activities, which require a full EIA (scoping followed by impact

assessment), and Category C waste management activities which do not require a waste management

licence but compliance with relevant requirements or standards.

No waste listed activities will be triggered for the CF 2 proposed Tanks Expansion Project, however

during the construction and operation of the CF 2 proposed Tanks Expansion Project, the basis of the

NEM:WA hierarchy focusing on waste reduction and reuse will be implemented.

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

The NEM:AQA was implemented on 24 February 2005 and reforms the law regulating air quality in

order to protect the environment by providing reasonable measures for the prevention of pollution and

ecological degradation and for securing ecologically sustainable development while promoting

justifiable economic and social development; to provide for national norms and standards regulating

air quality monitoring, management and control by all spheres of government; for specific air quality

measures; and for matters incidental thereto.

The NEM:AQA states the following as its primary objective:

“To reform the law regulating air quality in order to protect the environment by providing reasonable

measures for the prevention of pollution and ecological degradation and for securing ecologically

sustainable development while promoting justifiable economic and social development; to provide for

national norms and standards regulating air quality monitoring, management and control by all spheres

of government, for specific air quality measures, and for matters incidental thereto.

Whereas the quality of ambient air in many areas of the Republic is not conducive to a healthy

environment for the people living in those areas, let alone promoting their social and economic

advancement, whereas the burden of health impacts associated with polluted ambient air falls most

heavily on the poor, whereas air pollution carries a high social, economic and environmental cost that

is seldom borne by the polluter, and whereas atmospheric emissions of ozone-depleting substances,

greenhouse gases and other substances have deleterious effects on the environment both locally and

globally, and whereas everyone has the constitutional right to an environment that is not harmful to

their health or well-being, and whereas everyone has the constitutional right to have the environment

protected, for the benefit of present and future generations, through reasonable legislative and other

measures that:

• Prevent pollution and ecological degradation;



• Promote conservation; and

• Secure ecologically sustainable development and use of natural resources.”

In terms of Section 21 of NEM: AQA, “The Minister must, or the Member of Executive Council (MEC)

may, by notice in the Gazette -

(a) publish a list of activities which result in atmospheric emissions and which the Minister or MEC

reasonably believes have or may have a significant detrimental effect on the environment, including

health, social conditions, economic conditions, ecological conditions or cultural heritage”

The list of activities was published in 2010 (GNR No. 248 31 March 2010) and was amended and

gazette in 2013 (GNR No. 893 – 22 November 2013). The list was amended again on 12 June 2015

and 31 October 2018.

The CF 2 Tank Expansion Project proposes the combined storage of approximately 75 300 m3 of

substances. Subcategory 2.4 of Category 2 in the NEM:AQA (as tabulated in Table 4) requires an AEL

be obtained prior to commencement of the said activity. As noted in GNR 983 listed activity 28, a Basic

Assessment process is required in order to obtain an AEL. Therefore, the AEL and BA process will be

undertaken concurrently. As the CF 2 proposed Tanks Expansion Project will require an AEL in terms

of the NEM:AQA, an amendment to Sasol existing AEL will be submitted to the Gert Sibande District

Municipality together with the submission of the final BAR.

Table 2-2: Listed Activity in terms of the NEM:AQA

Governmental Notice R 893

2.4 All permanent immobile liquid storage facilities at a single site with a combined storage capacity of greater than 1000 cubic meters.

The proposed expansion will result in a total capacity of approximately 75 300 m3, and therefore, this listed activity is relevant to the project.

2.5.1 Air Quality Standards

Particulate Matter

Particulate matter (PM) consists of airborne particles that include dust, smoke and soot. PM can either

be emitted naturally (e.g. windblown dust from stockpiles) or through human activity (e.g. stack

emissions). It is defined by size, with coarse particles being between 2.5-10 microns, fine particles

less than 2.5 microns, and ultrafine particles less than 0.1 microns in diameter.

PM can have adverse effects on humans such as respiratory illnesses (asthma and bronchitis) or

cardiovascular diseases. It can also affect vegetation in two ways, namely, by inhibiting the plant’s

photosynthetic properties by coating the leaves thereby blocking the penetration of natural light.

Furthermore, deposition onto soils of various metals that could be in the PM can be absorbed by

vegetation thereby hindering plant growth. The uptake of metals by plants also has the potential to

contaminate vegetables and fruit that may be consumed by humans and animals.

Ambient air quality guidelines and standards for inhalable particles or PM10 (i.e. particulates with an

aerodynamic diameter of less than 10 µm) are presented in Table 2-3. PM10 is important as it provides

a measure of respirable dust, which has the potential to affect human health.



Table 2-3: Ambient air quality standards for PM10

Standard 24-hour Annual Average

Units µg/m3 µg/m3

South African Standard (Effective from 1 January 2015)1 75 40

Frequency of exceedance 4 0

1) As listed in the NEM: AQA. Government Gazette No. 32816. 24 December 2009

Ambient air quality guidelines and standards for inhalable particles or PM2.5 (i.e. particulates with an

aerodynamic diameter of less than 2.5 µm) are presented in Table 2-4. PM2.5 also provides a measure

of respirable dust which has the potential to affect human health.

Table 2-4: Ambient air quality standards for PM2.5

Standard 24-hour Annual Average

Units µg/m3 µg/m3




1) As listed in the NEM: AQA. Government Gazette No. 35463. 29 June 2012

2.5.2 Sulfur Dioxide

Sulfur Dioxide (SO2) is a colourless gas with a strong odour. It is a primary pollutant, which can react

easily with other substances and form secondary pollutants such as sulfuric acid. SO2 is formed

through industrial processes that use sulfur.

SO2 is damaging to the human respiratory function when inhaled, causing coughing and shortness of

breath. Either long term exposure or exposure to a large dose can result in chronic respiratory disease

and the risk of acute respiratory illness. The relevant South African standards for ambient SO2 levels

are presented in Table 2-5.

Table 2-5: Ambient air quality standards for SO2

Standard

Averaging period

10 minute 1-hour 24-hour Annual Average Concentration

Units µg/m3 µg/m3 µg/m3 µg/m3

South African Standard1 500 (191 ppb) 350 (134 ppb) 125 (48 ppb) 50 (19 ppb)

Frequency of exceedance 526 88 4 0

1) As listed in the NEM: AQA. Government Gazette No. 35463. 29 June 2012

2.5.3 Nitrogen Dioxide

Nitrogen dioxide (NO2) is a natural gas with a strong odour. Small quantities can be produced by

plants, soil and water, but human activities such as the combustion of fossil fuels and biomass are the

major source of NO2 in the air. Human respiratory tract irritation could be a direct effect of NO2

exposure. Due to it being relatively insoluble (relative to SO2), NO2 can penetrate deep into the lungs,

causing potential tissue damage. Effects of NO2 exposure include alveolar tissue disruption and

obstruction of the respiratory bronchioles. Long term effects of exposure include increased potential

for lung infections. The relevant South African Standards for ambient NO2 levels are presented in

Table 2-6.



Table 2-6: Ambient air quality standards for NO2

Standard Maximum 1-hour

Concentration Annual Average Concentration

Units µg/m3 µg/m3

South African Standard1 200 (106 ppb) 40 (21 ppb)


1) As listed in the NEM: AQA. Government Gazette No. 32816 of 24 December 2009

2.6 National Water Act (Act No. 36 of 1998)

The major objectives of the National Water Act (Act No. 36 of 1998) (NWA) are to:

• Aid in providing basic human needs;

• Meet the growing demand of water in a sustainable manner;

• Ensure equal access to water and use of water resources;

• Protect the quality of water of natural resources;

• Ensure integrated management of water resources;

• Foster social and economic development; and

• Conserve aquatic and related ecosystems.

The CF 2 proposed Tanks Expansion Project will not require any further authorisations in terms of the

NWA.

2.7 Occupational Health and Safety Act (Act No. 85 of 1993)

The Occupational Health and Safety Act (Act No. 85 of 1993) 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. Health and safety issues will be

considered in the EMPr compiled for this project.

2.8 Promotion of Access to Information Act (Act No. 2 of 2000)

The Promotion of Access to Information Act (Act No. 2 of 2000) (PAIA) recognises that everyone has

a right of access to any information held by the state and by another person when that information is

required to exercise or protect any right. The purpose of the Act is to promote transparency and

accountability in public and private bodies and to promote a society in which people have access to

information that enables them to exercise and protect their right. The BAP will be undertaken in terms

of the NEMA, with the associated Stakeholder Engagement Process aligned with the PAIA in the

sense that all I&APs will be given an opportunity to register as an I&AP prior to the initiation of the

project and all registered stakeholders will in turn be provided a fair opportunity to review and comment

on any reports submitted to the competent authorities for decision making.

2.9 Major Hazard Installations

Any installation or quantity of substance on the site of, or under the control of the company, that could

cause a major incident is regulated by the Major Hazard Installation Regulations. These Regulations

impose registration requirements as well as a number of obligations aimed at minimising the risk

associated with hazardous installations and/or substances. The risks covered by the Regulations are

risks that affect the public and employees.



The term “major hazard installation” means an installation where more than the prescribed quantity of

any substance is or may be kept, whether permanently or temporarily; or where any substance is

produced, processed, used, handled or stored in such a form and quantity that it has the potential to

cause a major incident. A “major incident” means an occurrence of catastrophic proportions, resulting

from the use of plant or machinery, or from activities at a workplace.

The proposed and existing tanks will be completely bunded and not within close proximity to sensitive

receptors. These regulations will be taken cognisance of prior to the construction of the tanks.



3 Policy Framework There are a number of planning instruments and guidelines initiated by National, Provincial and Local

government that have been used to inform the BAP. These have been considered in the planning and

assessment of the EIA/EMPr where applicable. The instruments considered during compilation of the

EIA/EMPr are listed in Table 3-1.

Table 3-1: Instruments considered during the EIA/EMPr process

Policy/Instrument/Guideline Description

Govan Mbeki Integrated Development Plan (IDP) The CF 2 proposed Tanks Expansion Project

falls within the established Sasol Synfuels

Operations.

The Gert Sibande District Municipality Spatial

Development Framework (SDF), 2009

The CF 2 proposed Tanks Expansion Project

falls within the established Sasol Synfuels

Operations. No additional footprint will be

required.

Department of Environmental Affairs (DEA)

Integrated Environmental Management Guideline

Series, Guideline 3: General Guide to the EIA

Regulations, 2012

This guideline was taken cognisance of in

assessing the environmental impacts

envisaged from the CF 2 proposed Tanks

Expansion Project.

DEA Integrated Environmental Management

Guideline Series, Guideline 4: Public

Participation in support of the Environmental

Impact Assessment Regulations, 2012

This guideline was taken cognisance of during

the Stakeholder Engagement process

conducted for the CF 2 proposed Tanks

Expansion Project.


Guideline Series, Guideline 5: Assessment of

Alternatives and Impacts in support of the

Environmental Impact Assessment Regulations,

2012


determining the alternatives for the CF 2

proposed Tanks Expansion Project.


Guideline Series, Guideline 5: Companion to the

Environmental Impact Assessment Regulations,

2012


assessing the environmental impacts

envisaged from the CF 2 proposed Tanks

Expansion Project.

Western Cape Department of Environmental

Affairs and Tourism. 2010. EIA Guideline and

Information Document Series: Guideline on Need

and Desirability


determining the need and desirability of the CF

2 proposed Tanks Expansion Project.

Sasol Safety, Health and Environmental Policy The EIA/EMPr will address the objectives of this

policy to ensure the development is conducted

in alignment.

Mpumalanga Biodiversity Sector Plan Spatial data was obtained from the South

African National Biodiversity Institute (SANBI)

to assess the status quo of the proposed area.

All relevant Provincial regulations, Municipal by-

laws

The Contractor during the construction and

potential operational phase, as well as Sasol

throughout the life of the project, will be

expected to obey and abide by provincial and

municipal by-laws which are related to the CF 2

proposed Tanks Expansion Project.



Policy/Instrument/Guideline Description

SANS 10 089 (SABS 089) Design and

construction of Bulk Storage Tanks.

The CF 2 tanks will be constructed in

accordance with the relevant SANS code.

4 Project Description The CF 2 Tank Expansion Project initiated by Sasol will require additional tankage for the following

products:

• Creosote Diesel;

• CTN / Benzene;

• TAME;

• Medium Fuel Oil;

• EHN.

4.1 Creosote Diesel

Creosote diesel is an intermediate diesel product that is the main component used in the diesel blend.

Creosote diesel is produced in unit 228, located within the Sasol Synfuels Operations, from where it

is stored in the existing creosote diesel blending tank. The three new creosote diesel tanks will provide

an alternate storage location for the future.

The total additional storage of creosote diesel will be 30 000 m3. Three tanks will be constructed of

carbon steel with a fixed roof. Each tank will have a diameter of 26 m and a height of 21 m. The plot

space available measures 130 m x 52 m, giving a total area of 6 750 m2. Area required for three tanks

is 5 968 m2 with a concrete bund height of 2.8 m (including 0.3 m for crusher stones). There is sufficient

space available for a new pump bay (calculated at 33.1 m x 52.0 m for all three sets of pumps). New

pumps will be required since creosote diesel is a component product and different from the final

product in adjacent tanks. An additional access road of 6 m in width will be constructed on the outside

of the bunded area. An additional fence is proposed close to the existing road to control access to the

tank area, and the area will be fitted with new Close Circuit Television (CCTV) on of the proposed

creosote diesel tanks for further security. Figure 4-2 provides the preliminary design of the creosote

diesel tanks and the extended bunded area.



SASOL CF 2 TANKS PROJECT CREOSOTE DIESEL TANKS

Project No. 539945

Figure 4-1: Illustration of the Creosote Diesel Tanks

SASOL CF 2 TANKS PROJECT CREOSOTE DIESEL TANKS

Project No. 539945

Figure 4-2: Preliminary design of the Creosote Diesel Tanks



4.2 Cold Tar Naphtha / Benzene

CTN is produced in Unit 015, 215 and 293, located within the existing Sasol Synfuels Operations. The

rundown from the process unit area is currently sent via a header system. The new CTN tank will

receive feed from the existing header. A tie-in at Tank Farm west will provide for a new line routed to

the new tank.

The operator needs to manually align if he wants to rundown to the existing or the new CTN Tank.

Once high level is reached, an alarm in the control room will inform the operator to switch over to the

other tank. Failing to do so will activate the emergency shutdown valve to close the feed to the tank to

prevent overfilling.

Pumping to the process unit will be done using newly installed pumps.

The additional storage capacity required will be 12 000 m3. A single tank will be constructed of carbon

steel with a floating roof. The tank will be 26 m in diameter and 25 m in height. The CTN Tank will be

added to the bunded area where the TAME tanks are proposed to be located. The existing rundown

lines run close to this area, and the same utilities are required for the TAME and CTN Tanks. Figure

4-3 provides a close-up illustration of the CTN tank.

SASOL CF 2 TANKS PROJECT CLOSE UP ILLUSTRATION OF THE CTN TANK

Project No.

539945

Figure 4-3: Close up illustration of the CTN tank

4.3 Tert-amyl Methyl Ether

TAME is an octane booster used in gasoline blending. TAME is produced in unit 79, located within the

existing Sasol Synfuels Operations, from where it is stored in two existing TAME blending tanks. The

two new storage tanks will provide additional storage capacity required during the shutdown of the

TAME unit.

The operator needs to confirm which tanks the TAME will rundown to; either to the existing TAME tank

or any of the two new tanks.



During shutdown when there is no product rundown from the process unit, the existing TAME tanks

will be fed with new pumps from the new TAME storage at the same rate as produced by the process

unit.

The total additional storage requirements are 30 000 m3. Two tanks will be constructed, both of carbon

steel and supplied with an internal floating roof with a nitrogen blanket. The proposed new bund will

be built along the bund of the existing diesel storage tank bunds. A new service road (~ 6m in width)

will provide access for security to the TAME bunds. The bund will include TAME and CTN to allow for

greater bund volume.

Based on special requirements, the area will be 187 m x 52 m, giving a bund area of 9 464 m2. The

area required is based on a 2.8 m bund wall (allowing 0.3 m for crusher stone) and will be 8 587 m2,

based on the largest tank volume of 12 000 m3 for the CTN tanks in the bund. The bund layout is

determined based on tank spacing rather than bund length.

A close-up layout of the TAME tanks is illustrated in Figure 4-6.

SASOL CF 2 TANKS PROJECT Close up Illustration of the TAME Tanks

Project No.

539945

Figure 4-4: Close up Illustration of the TAME Tanks

4.4 Medium Fuel Oil

MFO is produced in unit 35, located within the Sasol Synfuels Operations. The fuel oil is then sent to

the existing storage tank. Fuel oil is currently exported via the existing road loading facilities. The

additional tankage will offer additional storage for the fuel oil. The new fuel oil tanks will send its product

to the same road loading facilities as is currently used (Sasol South Africa (Ltd), 2018).

A new tie-in at the east west pipe rack will provide for a new line routed to the new tanks. The operator

can remotely select if he wants to rundown the existing or the new tanks with the use of manual valves

provided (Sasol South Africa (Ltd), 2018).



The additional storage capacity required will be 3 000 m3. An additional two tanks will be constructed

of carbon steel and fitted with a fixed roof with a heating coil. Each tank will be 13 m in diameter and

13 m in height. The proposed area will utilize the existing bunded area as there is sufficient space in

the bund for the new tanks. The area is also close to the road loading facilities (Sasol South Africa

(Ltd), 2018).

SASOL CF 2 TANKS PROJECT Close up illustration of the MFO Tanks

Project No. 539945

Figure 4-5: Close up illustration of the MFO Tanks

4.5 Ethylhexyl Nitrate

Ethylhexyl Nitrate (EHN) is used as a Cetane Enhancer in the Diesel Blending. EHN will be imported

by truck to the proposed site. The product will be offloaded at the existing offloading station located to

the west of the Tank Farm. The offloading will utilise the existing rundown line where a tie-in will route

a new line into the bunded area to the new EHN Tanks. The outlet of the EHN tanks goes to the new

EHN Diesel Blending pumps located on the outside of the existing bund. The discharge line from the

EHN Diesel Blending Pumps are routed to the existing diesel blender where EHN is blended into the

diesel pool as required using flow control. The final product is then routed to the final product tanks

using existing infrastructure (Sasol South Africa (Ltd), 2018).

The proposed EHN tanks will have a total storage capacity of 300 m3. Each tank will be 5 m in diameter

and 10 m in height. The tanks will be constructed from stainless steel with a fixed roof (Sasol South

Africa (Ltd), 2018).

A close-up layout of the EHN tanks is illustrated in Figure 4-6.



SASOL CF 2 TANKS PROJECT EHN Tanks

Project No. 539945

Figure 4-6: Close up illustration of the EHN Tanks

4.6 Services and Infrastructure

The current facilities include a berm that was previously used to protect the Tank Farm from mortar

attacks. The current risks have changed to a high risk of theft, and therefore the berm area has been

selected as the site where the new tanks will be constructed. The exiting berm will therefore be

removed (Sasol South Africa (Ltd), 2018).

The current security features also include a 2.4-meter-high concrete wall secured with barbed wire on

top (primary fence). There is a wire fence with overhang located approximately 8 meters towards the

road, which acts as the secondary security fence (Sasol South Africa (Ltd), 2018).

With the construction of the TAME, Creosote Diesel and CTN tanks, a new fence on the road side of

the existing security fences will be constructed. This fence will serve to provide security for the access

road and the site establishment area. Once the new security fence is installed, the existing fence will

be removed to create space available for site establishment (Sasol South Africa (Ltd), 2018).

Once the security fence has been installed, provision has to be made for a new access road that leads

from the existing road to the Tank Farm. Once all security fences are in place, CCTV installed, lights

relocated, and new access road established, then the concrete wall can be broken down in a section

to allow for direct access to the proposed plot area for the new tanks (Sasol South Africa (Ltd), 2018).

4.7 Employment

The construction of the CF 2 proposed Tanks Expansion Project will be temporary and of short

duration. Additional employment opportunities during the construction phase will be required. It is not

envisaged that additional job opportunities will be required during the operation phase. The existing

operational team will take on the responsibilities following the construction of the CF 2 Tank Expansion

Project.



4.8 Location and Context of the Project Area

The CF 2 proposed Tanks Expansion Project is situated within the north western section of the Sasol

Synfuels Operations, south west from the town of Secunda, and surrounded by existing and

established industrial processes associated with Sasol operations. The CF 2 proposed Tanks

Expansion Project will be located on the following farm portion as illustrated in Table 4-1.

Table 4-1: Farm affected by the CF 2 proposed Tanks Expansion Project

Farm Portion Survey General Code Land Owner

Erf 8488, Secunda Extension 35 Remainder T0IS00190000848800000 Sasol

The middle coordinates of each tank section that will be upgraded are illustrated in Table 4-2.

Table 4-2: Coordinates of the proposed tankage

Point Longitude Latitude

CTNB 29° 8' 51.76" E 26° 32' 40.52" S

TAME Tank 1 29° 8' 52.33" E 26° 32' 36.80" S

TAME Tank 2 29° 8' 52.05" E 26° 32' 38.70" S

Creosote Diesel Tank 1 29° 8' 51.22" E 26° 32' 44.48" S



Medium Fuel Oil Tank 1 29° 8' 58.48" E 26° 32' 49.61" S

Medium Fuel Oil Tank 2 29° 8' 58.41" E 26° 32' 50.30" S

EHN Tank 1 29° 9' 6.26" E 26° 32' 38.10" S

EHN Tank 2 29° 9' 6.22" E 26° 32' 38.42" S

4.8.1 Regional setting

The project is located within the Gert Sibande and Govan Mbeki District and Local Municipality

respectively. The regional location of the Sasol Synfuels Operations is shown in Figure 4-7.

4.8.2 Directions and approximate distances to the towns near the CF 2 proposed Tanks Expansion Project

The nearby towns cities and residential areas to the CF 2 proposed Tanks Expansion Project are given

in Table 4-3 (line of sight distances).



Table 4-3: Nearby towns to the CF 2 proposed Tanks Expansion Project

Town Distance (km)

eMbalenhle ~2.5 km West

Charl Cilliers ~12 km South

Winkelhaak ~12 km North West

Brendan Village ~15 km West

Secunda ~4 km North

Evander ~16 km North West

Trichardt ~18 km North East

Kinross ~23 km North West

Leandra ~32 km North West

Lebohang ~33 km North West

Ga Nala ~45 km North East

Bethal ~52 km East




REGIONAL MAP Project No.

539945

Figure 4-7: Regional map illustrating the CF 2 proposed Tanks Expansion Project



5 Project Alternatives According to Appendix 1, Regulation 3(1)(g), (h)(i)(x)(ix) and (xi) of GNR 982, published in terms of

the NEMA, feasible and reasonable alternatives must be considered and assessed in the EIA process,

along with the no – go alternative.

According to GNR 982 an alternative is defined as:

“an alternative in relation to a proposed Activity refers to the different means of meeting the genera l

purpose and requirements of the Activity, which may include alternatives to:

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

• the type of activity to be undertaken;

• the design or layout of the activity;

• technology to be used on the activity;

• the operational aspects of the activity”.

5.1 Location, Activity, and Operation Alternatives

The CF 2 proposed Tanks Expansion Project relates to the construction of additional tankage within

the Sasol Synfuels Operations. The tanks will be located within existing Tank Farm areas, with an

additional footprint to be constructed for the TAME, Diesel Creosote, and CNT/Benzene tanks. The

existing bunded area will be extended to accommodate these additional tanks. The remaining MFO

and EHN tanks will be constructed within the existing bunded areas.

5.1.1 Cold Tar Naphtha / Benzene Storage

The eastern Tank Farm was considered, which would also require an extension of the existing gasoline

tank bunded area by 35 m over a length of 70 m. The gasoline and CNT tank would be in a common

bund with a ¾ high intermediate bund separating the tanks for minor spillages.

5.1.2 TAME Storage Tanks

The area west of the north entrance car park was considered. This area is empty, the existing parking

area would need to be modified. This area was rejected since it is close to public roads and admin

buildings.

Repurposing of one of the large existing gasoline tanks was considered. These tanks have external

floating roofs and will need to be fitted with a roof. The existing shell is not strong enough to hold up

the weight of a fixed roof. A geodesic dome was considered but found that there is no zero-leakage

geodesic dome available. Since TAME will need nitrogen blanketing, repurposing a gasoline tank was

not possible.

Repurposing the fixed roof tanks currently used for Illuminating paraffin was considered. This would

involve fitting an internal floating roof since the current tanks are fixed roof dome tanks. This would be

possible if the fiberglass zero leak floating roof is selected rather than the pontoon type floating roof.

The problem with repurposing these tanks is that they are designed for 0.6 kPag (gauge pressure)

and a tank with nitrogen blanketing needs to be designed closer to the 17 kPag. The advantage would

be that the tanks become available sooner. There would be the need to provide a new TAME tank and

new tankage for the Illuminating Paraffin. Since there is no major difference in priority between the

products and the fact that the capacity for illuminating paraffin is currently required this option has

been rejected.



The Acrylo Nitrate site was considered as an alternative. Being in the corridor makes the site more

viable for refinery operations as an additional future process unit rather than a Tank Farm. By placing

one or more product tanks in the Acrylo Nitrate site, it would occupy the entire site. The site would

therefore be unavailable for future upgrades. The TAME lines do not run near the site and there would

be a mayor piping cost associated by locating the TAME tanks in the CAN site. A cost comparison

was done between the west berm plot space with 4 smaller tanks versus the 1 large TAME tank at the

Acylo Nitrate site and the cost for building the tanks at the berm turns out cheaper. The final number

of TAME tanks has been reduced to two, making the construction at the berm even more viable.

5.1.3 Diesel Creosote

As the proposed tanks will be constructed along the existing diesel storage tank bunded area, and the

piping is in close proximity, no additional location alternatives were found to be feasible.

5.1.4 Medium Fuel Oil

The proposed tanks will be located within an existing bunded area with sufficient space and capacity,

with minimal modifications. It was concluded that no location alternative was found to be feasible.

5.2 Design and Technology Alternatives

The propose tanks will cater for the storage of different products, which dictate the tank and roof

requirements, thus minimal leeway is available for design and technology alternatives. The following

design alternative was considered:

5.2.1 Underground Storage Tanks

The installation of underground storage tanks was considered. However, numerous limiting factors

identified dictated that this alternative was deemed unfeasible and as such was not considered further.

Some of the limiting factors included the need for excavation and associated equipment use during

the construction phase, along with the need for storage space to accommodate soil stockpiles.

Underground tanks are difficult to maintain, and leak detection may not be effectively implemented

resulting in possible soil and / or ground water contamination. In addition, monitoring and regular

inspection of tank integrity is not straight forward or practical. Should leaks or contamination occur,

these will only be identified once they have arisen and minimal opportunities exist for proactive leak

detection.

5.3 No – Go Alternative

Sustainable domestic production and supply of cleaner fuels is essential in order to realise a

competitive South African economy since liquid fuels remain the most prominent energy carrier for

transportation in the country. The CF 2 proposed Tanks Expansion Project will ensure the continued

production of fuels in-line with legislative and market related changes, which in turn will allow for the

continuation of considerable economic benefits, both locally and within the greater area of the province

and country as Sasol contributes significantly to the South African economy. Over 27 000 people are

employed by the Sasol groups, while approximately 140 000 people are supported by these staff

members. The conversion of the Sasol Synfuels Operations to CF 2 in response to the changes in

regulations will also have a positive impact on cumulative air quality.

Without the conversion of the Sasol Synfuels Operations to CF 2, Sasol Secunda will not be able to

continue with the production of fuels, as it will not be in line with legislative requirements. This could

potentially result in unemployment of a large number of residents in Secunda and the surrounding

communities accumulating to the current 40% unemployment rate in the Gert Sibande Local



Municipality. The opportunity to keep pace with improved vehicle engine technology and address

environmental degradation as a result of harmful emissions from vehicles will also be lost.

The Socio-economic studies conducted for the construction and operation of the CF 2 Tanks found

that it will have positive impacts on economic status due to the prolonged activities of Sasol Group of

Companies, maintaining the current employment statistics. It will further have a positive socio-

economic benefit by providing a sustainable domestic supply of cleaner fuels to support a more

competitive South African economy.

5.4 Alternative Conclusion

Taking cognisance of the assessment of the possible alternatives and the CF 2 proposed Tanks

Expansion Project, it is proposed that the preferred alternative be assessed in isolation with the no–

go alternative. The proposed project will largely be undertaken within the existing Tank Farm, justifying

that minimal alternatives can be identified, posing reduced impacts, and meeting the same objective

of the CF 2 Tank Expansion Project.



6 Description of the Affected Environment This section provides an overview of the status quo of relevant environmental (cultural and biophysical)

as well as social–economic parameters that required careful consideration in the analysis and

assessment of the potential impacts and benefits to which the project may give rise. Information

informing this section was obtained from municipal IDP, Spatial Development Plans (SDP), input from

I&APs, as well as data sources including aerial photographs, topographic maps, and provincial and

national databases. Two specialist studies (Air Quality and Geotechnical assessment) were further

conducted in order to inform the baseline environment status quo. The Geotechnical Assessment also

included some soil assessments and groundwater monitoring.

It is noted that the proposed project will be located within the already disturbed Sasol Synfuels

Operations area.

6.1 Socio – Economic

This site falls within the Gert Sibande District and Govan Mbeki Local Municipality. The demographics

of this study area are provided by the IDP of the Govan Mbeki Local Municipality (2017).

This Municipality is situated in the south western regions of the Mpumalanga Province, bordering the

Gauteng Province, being approximately 100 km from Johannesburg to the east and approximately

300 km south west of Nelspruit. The municipality is one of the seven local municipalities under the

jurisdiction of Gert Sibande District and one of the eighteen local municipalities within Mpumalanga.

The Govan Mbeki Local Municipality is comprised of 32 wards (Govan Mbeki Local Municipality, 2017).

This Municipality covers approximately 2958 km2 with a population of approximately 340 000 people.

The unemployment rate, according to the IDP, reaches a pronounced 26%. The average population

growth in the area is considered to be around 3% during the period between 2011 and 2016. The

municipality can mostly be described as industrial/agricultural /rural, although three urban corridors

have been identified. These include the following (Govan Mbeki Local Municipality, 2017):

• Leandra /Lebohang on the western edge;

• Greater Secunda in the centre (Trichardt, Evander, Kinross and Secunda/eMbalenhle);

• Bethal /eMzinoni on the eastern edge.

The Govan Mbeki Municipality is situated on the Gauteng Richards Bay corridor formed by the National

Road N 17 and the Richards Bay rail line running through the Municipality in an east west direction.

The Govan Mbeki Municipality has the most diversified economy within the Gert Sibande District,

dominated by the petrochemical industry (Sasol), coal and gold mining. According to the SDF, the

municipality has one of the largest coal mining complexes in the world, making the municipality an

important strategic area within the national context. The economy of the Govan Mbeki Municipality is

significantly diverse, dominated by the petrochemical industry (Sasol), coal, and gold mining in the

area (Govan Mbeki Local Municipality, 2017).

6.2 Geology

The Sasol Synfuels Operations is underlain by rocks belonging to the Vryheid Formation of the Ecca

Group, Karoo Supergroup. These rocks primarily consist of arenite, shales and coal beds. These rocks

are extensively intruded by dolerites of Jurassic age. The dolerites occur both as sills and linear dyke

structures that may extend over tens of kilometres. The CF 2 proposed Tanks Expansion Project will

not affect the geological aspect underlining the Sasol Synfuels Operations.



6.2.1 Site Specific Geology (SRK, 2019)

The site is underlain by dolerite fill of 1.0 m – 3.0 m thickness and is followed by residual dolerite;

residual sandstone and soft rock sandstone at approximately 20 m depth (SRK, 2019).

6.3 Geotechnical Investigation (SRK, 2019)

SRK was appointed to carry out a geotechnical investigation for the CF 2 proposed Tanks Expansion

Project (SRK, 2019) at the Sasol Synfuels Operations in Secunda, Mpumalanga Province.

The main objective of the geotechnical investigation was to:

1) Determine and assess sub-surface geotechnical conditions;

2) Determine the engineering properties of the material underlying the site;

3) Establish whether the berm material is suitable for use as founding/terrace fill material;

4) Provide foundation recommendations (including the possibility of using piles); and

5) Give an indication of the extent of contamination of soil and water.

The following conclusions and recommendations are based on field observations and available

laboratory test results from this Geotechnical Study (SRK, 2019). Additional Dynamic Probe Super

Heavy (DPSH) testing was also carried out and foundation recommendations provided. The findings

from the Geotechnical investigation are summarised in Sections 6.3.1 to 6.3.2. Figure 6-2 illustrates

the positions of the test pits.

6.3.1 Berm

From the field data captured and the available laboratory test results, the following can be concluded:

The soil chemistry tests confirm that the berm samples can be used on industrial land as it falls within

the Soil Screening Values (SSV) 2 limits for all the constituents according to South African SSV

standards.

According to Basson Index test results the soil material from the berm is corrosive towards to metals

and aggressive (moderate to high) towards concrete and fibre cement pipes.

The Plasticity Index (PI), the California Bearing Ratio (CBR) test (measurement of resistance of a

material to penetration) and linear shrinkage values indicates that the soil from the berm is not

adequate for use as material for structural layers in terrace construction unless the material is treated

with lime or cement to lower the PI. The soil will only be of use for bulk fill in embankment construction.

Laboratory testing will, however, have to be conducted to confirm if such treatment will adequately

improve its properties. SRK is, however, of the opinion that due to the excessively high PI values it is

expected that lime/cement treatment may be excessive and therefore expensive and that it will

demand a quality control intensive exercise should the laboratory testing prove it to achieve

improvement in this way.

The proposed locations of the TAME; CTN and Diesel Creosote tanks are next to the berm west of

the tankfarm. The results of the settlement calculations as derived from the DPSH data and done at

depths 1.5 m; 3.0 m and 4.5 m exceed the allowable settlement of 25.4 mm. An engineered fill of 50

MPa stiffness and 4.5 thickness also did not improve settlement significantly.

Medium hard rock sandstone was generally encountered at depths exceeding 20 m. Since the

settlement calculations are not favourable for conventional founding and the soil profile does not

significantly improves up to 20 m SRK recommends considering piling as founding method if the

calculated settlements are not acceptable to the design engineer.

6.3.2 Plant

From the field data captured and the available laboratory test results, the following can be concluded:



All the test pits excavated in the plant area only exposed a profile within the dolerite fill with rather poor

qualities as construction material. This mainly due to the decomposed soil structure of the fill and the

high content of clayey fines.

All detected organic and inorganic compounds proofed to be well within the allowable SSV limits

except for SRK TP04, which exceeded the SSV. Although the soil can be used on industrial land it will

have to be rehabilitated once removed from site.

The results of the groundwater samples collected across the plant area at boreholes WTF 9R; WTF

33R and SRK 10 were compared to the Sasol Secunda WUL and South African Drinking Water

Standards. In general, the majority of constituents detected in the water samples are within acceptable

range. There are, however, constituents which do exceed allowable limits.

The Basson Index test results from samples collected at each of the test pits confirmed that the soil is

corrosive towards metals and aggressive (very high) towards concrete and fibre cement pipes.

Four percussion boreholes were drilled at different positions across the plant area. The strata

encountered in these boreholes are typically the same to the geological strata encountered in the

boreholes drilled east of the berm.

The locations of the DFO / DSC and EHN tanks are within the plant area. The results of the settlement

calculations as derived from the DPSH data and done at depths 1.5 m; 3.0 m and 4.5 m are within the

allowable settlement of 25.4 mm.

Engineered fill foundations can be considered for these tanks.

Note: Since there are no available foundation designs SRK cannot comment on the suitability thereof

and the client must review the calculated settlements in terms of his existing foundation design

specifications and tolerances.

6.3.3 Geotechnical Environmental Impact Assessment

SRK Consulting was further requested to identify and assess anticipated Geotechnical environmental

impacts, which need to be considered. This report (Please refer to Appendix H) focusses on the

potential Geotechnical environmental impacts which needs to be considered as part of the BAR Impact

Assessment process.




Test Pit Locations Project No.

539945

Figure 6-1: Illustration of the test pits conducted for the CF 2 proposed Tanks Expansion Project.



6.4 Surface Water and Wetlands

The project falls within the Upper Vaal Water Management Area (WMA) and Upstream Vaal Dam sub-

WMA. The Sasol Synfuels Operations is located in the upper reaches of the Waterval River, affecting

the Klein and Groot Bossiespruit, Brandspruit, Klipspruit, and Trichardspruit.

The project further falls within the quaternary catchment of C12D. Secunda is at the northern boundary

of the WMA. The sub-WMA is comprised of several tributaries i.e. the Vlakspruit, Kleinspruit, the Groot

Bosjespruit, the Brandspruit, the lower reaches of the Klipspruit and Trichardtspruit.

The project footprint contains no wetlands and is a pre-developed site within the Sasol Synfuels

Operations. Within the wider context of the Sasol Synfuels Operations there are localised wetlands

that are not considered to be important in terms of the Freshwater Ecosystem Priority Areas database.

No South African Ramsar wetlands are indicated near or on the Sasol Synfuels Operations, and

specifically the pre-developed area of proposed site. The water quality and flow profile of the Waterval

River has changed substantially from the time the Sasol Synfuels Operations was established in the

late 1970’s, but the CF 2 proposed Tanks Expansion Project has no direct impact on the receiving

water courses.

The Sasol Synfuels Operations area is insignificant in terms of rare and endemic species conservation.

The ecology of the Sasol Synfuels Operations area is considered to be moderately sensitive to

changes in water quality. The catchment can be considered to be moderately sensitive to changes in

flow and has a low importance in terms of species richness in the area. An illustration of the surface

water resources in and around the CF 2 proposed Tanks Expansion Project is provided in Figure 6-2.

As from Figure 6-2 it can be clearly seen that no surface water resources will be directly threatened

as a result of the construction and operation of the CF 2 proposed Tanks Expansion Project. Figure

6-3 provides an illustration of the existing surface water monitoring points, which are deemed to be

sufficient to proactively identify any impacts that may arise from the construction and operation of the

proposed project.




ILLUSTRATION OF THE SURFACE WATER RESOURCES Project No.

539945

Figure 6-2: Illustration of the surface water resources in and around the CF 2 proposed Tanks Expansion Project.




SURFACE WATER MONITORING POINTS Project No.

539945

Figure 6-3: Illustration of the surface water monitoring points around the CF 2 proposed Tanks Expansion Project.



6.5 Geohydrology

On behalf of Sasol, the Institute for Groundwater Studies of the University of the Free State currently

conducts routine groundwater monitoring at the Sasol Synfuels Operations in terms of the existing

Water Use License and Waste Ash Disposal Sites License. Quarterly and bi-annually sampling

regimes are conducted. Laboratory analyses include organic and inorganic constituents.

The groundwater at the Sasol Synfuels Operations is characterised by two aquifers, including a

weathered aquifer occurring at a depth of between 12 and 35 m below existing ground level, and a

fractured rock aquifer occurring at depths greater than 60 m below existing ground level. The

weathered and fractured rock aquifer has a low permeability rate. The low permeability 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 based on topographical elevations.

It is noted that a 5 km exclusion zone has been established in terms of groundwater abstractive use

around the Sasol Synfuels Operations. Consequently, there are no direct users of groundwater in and

around the Sasol Synfuels Operations, and specifically in the vicinity of the CF 2 proposed Tanks

Expansion Project footprint.

Hydrogeological monitoring boreholes of the Secunda Synfuels Operations (>170 monitoring

boreholes) extend to a maximum depth of 36 m, with one borehole to 111 m depth. The majorities of

monitoring boreholes intersect the clay and highly weathered siltstone/shale layer, with occasional

sand lenses and dolerite intrusions.

The shallow aquifer consists of clayey overburden material and weathered sandstone or shales and

dolerite. The weathering depth of the Karoo Formations underlying the site varies between 5 m and

36 mbgl, with an average of 25 m. The depth to the water table in the shallow aquifer varies from 2 m

to 28.4 mbgl, with an average of 4.42 mbgl. The average saturated thickness of the shallow aquifer is

23.09 m. Aquifer permeability for the shallow aquifer has a mean value of 0.007 m/day, and water

strikes range between 2 m and 60 mbgl, with an average of above 15 mbgl and therefore within the

shallow weathered aquifer. Blow yields vary between 0.01 l/sec to 7 l/sec, with an average of 0.59

l/sec.

The dolerite intrusions and sill are weathered and fractured up to depths in excess of 10 mbgl. The

sandstone contact with the sill is fractured and baked, and boreholes drilled into this contact

intercepted water strikes with blow yields of 0.1 l/sec.

The deep fractured aquifer is considered to be a non-aquifer or minor aquifer. Only the major fractured

zones have hydraulic conductivity with the shallow weathered aquifer. The permeability of the fractured

rock is 0.002 m/day. A realistic storability for the prevailing geological conditions is between 0.001 and

0.05 m/day. Figure 6-4 shows the positions of the surface and groundwater sampling points of the

Sasol Synfuels Operations.




GROUNDWATER MONITORING POINTS Project No.

539945

Figure 6-4: Illustration of the groundwater monitoring points around the CF 2 proposed Tanks Expansion Project.



6.5.1 Site Specific Groundwater Chemistry (SRK, 2019)

The groundwater level varies considerably across the site. The groundwater direction is inferred to be

in a northerly direction. The pH across the boreholes is neutral while the Electrical Conductivity (EC)

ranges between 1 300 uS/cm and 1 770 uS/cm and do not indicate particularly elevated levels of salts.

The results have been compared to the Sasol Secunda Water Use Licence (WUL) (Licence No.

20032144) limits.

Both Gasoline Range Organics (GRO) and Diesel Range Organics (DRO) were present in the

groundwater at the CF 2 tank farm area. It is recommended that monitoring is undertaken of the

constituents elevated in the groundwater both at the CF 2 tank farm area and downgradient of the CF

2 tank farm area. The monitoring of the additional constituents is important to determine the extent of

the constituents in the groundwater and to determine if there is a potential risk to groundwater users

from the constituents.

6.6 Air Quality

On 23 November 2007, the Highveld was declared a priority area, referred to as the Highveld Priority

Area (HPA), in terms of section 18(1) of the NEM:AQA. This implies that the ambient air quality within

the HPA exceeds or may exceed ambient air quality standards with respect to one or more air quality

parameters.

In March 2012, the Department of Environmental Affairs (DEA) published the HPA Air Quality

Management Pan which identified that Industrial sources are by far the largest contributor of emissions

in the HPA, accounting for 89% of Particulate Matter 10 (PM10), 90% of NOx and 99% of SO2. Major

industrial source contributors were grouped into the following categories (Department of

Environmental Affairs, 2012).

Power generation; Coal mining; Primary metallurgical operations; Secondary metallurgical operations;

Brick manufacturers; and Petrochemical industry.

Secunda and eMbalenhle were identified as one of the five areas in the HPA where ambient air quality

monitoring is required. This area was chosen due to the extensive use of fuel sources, such as coal

for heating and cooking purposes, and the impacts associated with Sasol to the east. The area of

Secunda located in close proximity to the proposed CF 2 Tanks project has been identified as a hot

spot in terms of the HPA Air Quality Management Plan.

The detailed information on the air quality aspects of the project were obtained from the Air Quality

Impact Assessment conducted for the project (SRK Consulting (Pty) Ltd, 2019). As part of the current

monitoring program for the study, air quality monitoring data for the period January 2016 to August

2018 was available at the time of writing this report. There are three ambient air quality monitoring

stations located at Bosjespruit, Club and Embalenhle (Table 2-3).

The following datasets have been collated:

• Gaseous monitoring: SO2, NO2 and CO.




AIR QUALITY MONITORING STATIONS Project No.

539945

Figure 6-5: Illustration of the air quality monitoring stations



6.6.1 SO2 Monitoring Data

The annual SO2 concentrations are presented in Table 6-1 and the hourly concentrations in Figure

6-6. for the period January 2016 to August 2018. The annual SO2 results are compared against the

South African National Ambient Air Quality Standards (NAAQS) of 19 ppm. The annual SO2

concentrations at the monitoring stations did not exceed the NAAQS during the monitoring period,

hence each monitoring point is compliant with the NAAQS.

The hourly SO2 concentrations presented in Figure 6-6, shows 11 exceedances of the hourly NAAQS

of 134 ppb at Bosjespruit, 13 exceedances at the Club and 11 exceedances at Embalenhle. The

exceedances of the NAAQS occur over a 3 year period, hence the monitoring points are compliant

with the 1 hour NAAQS of 134 ppb.

Table 6-1: Annual SO2 concentrations for the period 2016 to 2018

Month Bosjespruit Club Embalenhle

Units ppb ppb ppb

2016 10.1 7.3 7.6

2017 8.1 7.9 6.7

2018 7.6 9.1 5.9

Annual NAAQS 19 19 19

6.6.2 NO2 monitoring data

The annual NO2 concentrations are presented in Table 6-2 and the hourly concentrations in Figure

6-7 for the period January 2016 to August 2018. The annual NO2 results are compared against the

South African NAAQS of 21 ppb for NO2. The annual NO2 concentrations at the monitoring stations

did not exceed the NAAQS during the monitoring period, hence each monitoring point is compliant

with the NAAQS.

The hourly NO2 concentrations presented in Figure 6-7, shows no exceedances of the hourly NAAQS

of 134 ppb at Bosjespruit, 5 exceedances at the Club and 7 exceedances at Embalenhle. The

exceedances of the NAAQS occur over a 3 year period, hence the monitoring points are compliant

with the 1 hour NAAQS of 106 ppb.

Table 6-2: Annual NO2 concentrations for the period 2016 to 2018


Units Ppb ppb ppb

2016 8.3 9.9 11.0

2017 7.6 10.6 12.0

2018 6.8 11.4 10.8





1-HOUR SO2 CONCENTRATIONS Project No.

539945

Figure 6-6: 1-hour SO2 concentrations

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Hourly SO2 concentrations for the period January 2016 to August 2018

Bosjespruit Club Emba 1-Hour NAAQS




1-HOUR NO2 CONCENTRATIONS Project No.

539945

Figure 6-7: 1-hour NO2 concentrations

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Bosjespruit Club Emba NAAQS 1-Hour



6.6.3 CO monitoring data

The annual CO concentrations are presented in Table 6-3 and the hourly CO concentrations in Figure

6-8 for the period January 2016 to August 2018 for Embalenhle. There are no annual CO standards,

hence the annual concentrations have not been compared to a standard or guideline. The hourly CO

concentrations presented in Figure 6-8, shows no exceedances of the hourly NAAQS of 26 ppm at

Embalenhle.

Table 6-3: Annual CO concentrations for the period 2016 to 2018

Month Embalenhle

Units ppm

2016 0.33

2017 0.30

2018 0.20

6.6.4 PM10 and PM2.5 monitoring data

The annual PM10 concentrations are presented in Table 6-4 and the hourly concentrations in Figure

6-9 for the period January 2016 to August 2018. The annual PM10 results are compared against the

South African NAAQS of 40 μg/m3. The annual PM10 concentrations at the Bosjespruit and Club

monitoring stations did not exceed the NAAQS during the monitoring period. However, the annual

concentrations at Embalenhle for 2016, 2017 and 2018 exceeded the NAAQS of 40 μg/m3. Hence,

the monitoring results are not compliant with the NAAQS at Embalenhle.

The 24 hour PM10 concentrations presented in Figure 6-9, shows 48 exceedances of the hourly

NAAQS of 75 μg/m3 at Bosjespruit, 39 exceedances at the Club and 208 exceedances at Embalenhle

over the 3 year period. PM10 concentrations at these monitoring points exceeds the frequency of

exceedance of four per year. The exceedances of the NAAQS occur over a 3 year period, hence the

monitoring points are non-compliant with the 24 hour NAAQS of 75 μg/m3.

Table 6-4: Annual PM10 concentrations for the period


Units μg/m3 μg/m3 μg/m3

2016 36.10 38.39 49.91

2017 36.73 29.57 53.62

2018 31.55 32.30 48.43


The annual PM2.5 concentrations are presented in Table 6-5 and the hourly concentrations in Figure

6-10 for the period January 2016 to August 2018. The annual PM10 results are compared against the

South African NAAQS of 20 μg/m3. The annual PM2.5 concentrations at the Club monitoring station did

not exceed the NAAQS during the monitoring period. However, the annual concentrations at

Bosjespruit (1 exceedance) and Embalenhle (2 exceedances) exceeded the NAAQS of 20 μg/m3.

Hence, the monitoring results are not non-compliant with the NAAQS at Bosjespruit for 2017 and

Embalenhle for 2017 and 2018.

The 24 hour PM2.5 concentrations presented in Figure 6-10, shows 54 exceedances of the hourly

NAAQS of 40 μg/m3 at Bosjespruit, 25 exceedances at the Club and 76 exceedances at Embalenhle

over the 3 year period. PM2.5 concentrations at these monitoring points exceeds the frequency of

exceedance of four per year. The exceedances of the NAAQS occur over a 3 year period, hence the

monitoring points are non-compliant with the 24 hour NAAQS of 40 μg/m3.



Table 6-5: Annual PM2.5 concentrations for the period


Units μg/m3 μg/m3 μg/m3

2016 19.9 16.5 19.7

2017 21.6 16.4 21.5

2018 18.9 17.4 21.1





1-HOUR CO CONCENTRATIONS Project No.

539945

Figure 6-8: 1-hour CO concentrations

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oncentr

ation (

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)

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Hourly CO concentrations at Embalenhle for the period January 2016 to August 2018

Emba 1-hour NAAQS



SASOL CF 2 TANKS PROJECT 24 HOUR PM10 CONCENTRATIONS

Project No. 539945

Figure 6-9: 24 hour PM10 concentrations

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24 hour PM10 concentrations for the period January 2016 to August 2018

Bosjespruit Club Emba 24-hours NAAQS




24 HOUR PM2.5 CONCENTRATIONS Project No.

539945

Figure 6-10: 24 hour PM2.5 concentrations

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Bosjespruit Club Emba 24-hours NAAQS



6.6.5 Dispersion Modelling Results

Predicted maximum hourly, daily and annual average concentrations for Volatile Organic Compounds

(VOCs) were simulated using the United States Environmental Protection Agency (USEPA)-approved

American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD)

dispersion modelling package. Isopleth maps showing VOC concentrations are presented in the

sections that follow. It should be noted that only the proposed tank sources that will be installed at

Sasol have been modelled.

Isopleth contour plots spatially represent modelled ground level concentrations at each of the specified

receptor points. The plots also reflect the highest average predicted ground level concentrations over

the entire meteorological data-period. Therefore, the highest daily concentration may be predicted to

occur at a certain location; however, this may only be true on one specific day during the year. The

maximum predicted concentrations are usually associated with extreme meteorological conditions

such as high winds and low-level inversions.

Prior to the interpretation of the results, it is important to reiterate the degree of uncertainty associated

with emissions inventory preparation and dispersion simulation in general. Various assumptions were

made regarding the nature, location and extent of certain activities during the operational phase of the

project. Of importance, however, are the trends and the areas that are likely to be impacted.

6.6.6 Predicted VOC concentrations

The 1-hour, 24-hour maximum predicted concentrations and annual concentration for VOCs occur on-

site, west of the Tank Farm (Figure 6-11 - Figure 6-13). Predicted model concentrations (Table 6-6)

cannot be compared to short-term NAAQS as there are none available for comparison, however the

predicted annual concentrations were compared to the annual benzene NAAQS. Should the annual

VOC concentrations be below the benzene NAAQS of 5 µg/m3, it is assumed that benzene in the

VOCs would be below the NAAQS, hence the proposed operations will be in compliance.

The maximum predicted 1-hour VOC concentration is 22.111 µg/m3 and occurs on-site to the west of

the Tank Farm (Figure 6-11). The predicted concentrations at the closest sensitive receptors are lower

than what is observed on-site, hence predicted concentrations are shown to decrease with distance

away from the site. The predicted 1-hour concentrations at the sensitive receptors located off-site are

< 2 µg/m3.

The maximum predicted 24-hour VOC concentration is 3.964 µg/m3 and similar to the 1-hour predicted

concentrations occurs on-site to the west of the Tank Farm (Figure 6-12). The predicted concentrations

at the closest sensitive receptors are lower than what is observed on-site, hence predicted

concentrations are shown to decrease with distance away from the site. There are no 24 NAAQS for

VOCs or benzene in South Africa hence the predicted concentrations could not be compared to

determine compliance. The predicted 24-hour concentrations at the sensitive receptors located off-

site are < 1 µg/m3.

Similarly, the annual predicted VOC concentrations are low and decrease with distance away from the

facility. The impact of the proposed Tank Farm on the surrounding environment is considered

negligible based on the predicted model results. The predicted model concentrations cannot be

compared to short-term NAAQS as there are none available for comparison. However, considering

that benzene forms part of VOCs, the annual benzene concentration was used a reference standard

to determine the impact of annual concentrations. The predicted annual VOC concentrations at the

sensitive receptors are below the benzene standard of 5 µg/m3, which would imply that the predicted

annual VOC concentrations are low.



Table 6-6: Predicted VOC concentrations at the sensitive receptors

Receptors

Co-ordinates 1 hour 24 hour Annual

X Y µg/m3 µg/m3 µg/m3

Maximum predicted concentration 713844.03 7062251.22 22.111 3.964 0.519

Roodebank Combined School 703391.72 7054462.14 0.381 0.041 0.003

Zamokuthle Primary School 706032.2 7062058.92 0.407 0.048 0.004

Osizweni Secondary School 705689.02 7065550.91 0.504 0.053 0.003

Isibanisesizwe Primary School 707603.23 7062594.16 0.495 0.050 0.005

Maphala-Gulube Primary School 709079.45 7059437.57 0.690 0.089 0.008

Kiriyatswane Secondary School 707960.41 7063495.49 0.930 0.074 0.005

Kusasalethu Secondary School 707224.18 7062617.78 0.517 0.053 0.005

Laerskool Oranjegloed 719527.83 7064701.75 1.219 0.074 0.003

Highveld Medi Clinic/Hydromed 722518.48 7067875.20 0.377 0.027 0.001

Tholukwazi Primary School 705784.22 7062533.12 0.391 0.040 0.003

TP Stratten Primary School 710209.14 7069983.79 0.172 0.011 0.000

Laerskool Goedehoop 720597.24 7066281.02 1.001 0.058 0.003

Laerskool Kruinpark 721803.94 7064904.31 0.158 0.016 0.001

Lifalethu Primary School 707230.14 7063117.15 0.556 0.069 0.005

Thorisong Primary School 706637.13 7062819.96 0.471 0.055 0.004

Secunda Medi Clinic 717498.20 7066262.20 0.699 0.059 0.003

Embalenhle Primary School 705792.09 7062592.75 0.392 0.039 0.003

Buyani Primary School 706554.11 7063174.58 0.437 0.054 0.004

Allan Makhunga Primary School 707944.64 7063141.51 0.631 0.075 0.005

Adullam Combined School 707159.37 7066740.01 0.876 0.075 0.003

Shapeve Primary School 708306.07 7063814.85 1.278 0.082 0.006

Qinile Primary School 734366.12 7062425.68 0.042 0.002 0.000

Evander Hospital 711326.84 7070850.63 0.170 0.010 0.000

Highveld Ridge Primary School 719393.48 7066172.33 0.282 0.028 0.001

Vukuzithathe Primary School 707501.41 7059754.28 0.474 0.054 0.005

Laerskool Hoëveld 710953.90 7070482.62 0.136 0.010 0.000

Thomas Nhlabathi Secondary School 706374.00 7062504.89 0.431 0.046 0.004

Hoërskool Evander 709677.59 7069695.52 0.170 0.013 0.001

Laerskool Secunda 718641.30 7066033.99 0.226 0.029 0.001

Hoërskool Secunda 718700.50 7065655.21 0.861 0.054 0.003

VOC NAAQS N/A N/A N/A

Benzene NAAQS N/A N/A 5




1 HOUR VOC CONCENTRATION ISOPLETHS FOR THE PROPOSED TANKS Project No.

539945

Figure 6-11: 1 hour VOC concentration isopleths for the proposed tanks




24 HOUR VOC CONCENTRATION ISOPLETHS FOR THE PROPOSED TANKS Project No.

539945

Figure 6-12: 24 hour VOC concentration isopleths for the proposed tanks




ANNUAL VOC CONCENTRATION ISOPLETHS FOR THE PROPOSED TANKS Project No.

539945

Figure 6-13: Annual VOC concentration isopleths for the proposed tanks



6.7 Climate

The project site lies to the south west of Secunda, which lies to the west on the Highveld of the

Mpumalanga Province. The climate in this area is usually moderate and wet during summer and cold

and dry during the winter. The key meteorological parameters are discussed in the following sections

of this report.

6.7.1 Description of South African Climate

South Africa has a temperate and pleasant climate with warm sunny days occurring most of the year.

South Africa’s summer occurs between November to February when most of the country experiences

hot weather and afternoon thunderstorms. The winter season, which occurs from May to August, is

usually mild and dry, except in the south-western parts of the country. South Africa is influenced by

two oceanic currents, the warm south flowing Mozambique-Agulhas current and the cold north flowing

Benguela current. These two currents influence the climate and vegetation between the eastern and

western sides of the country. The east coast generally has higher temperatures and rainfall when

compared to the west coast. Climate conditions in South Africa range from Mediterranean in the south-

western part of the country to temperate in the interior plateau and subtropical in the north-east. There

is also evidence of a desert climate in the north-western region of the country.

South Africa is located in the subtropical high pressure (HP) belt, where subsidence, HP and

atmospheric stability are predominant features. Three HP cells dominate over South Africa. The South

Atlantic HP cell is located off the west coast, the Continental HP cell reigns over the interior of the

country and the South Indian HP cell resides over the east coast. This results in the annual mean

circulation of the atmosphere over South Africa being anticyclonic (Steynor, 2006). During winter, the

anticyclonic circulation over South Africa is well established and is at its most intense. The Continental

HP cell migrates north over the country and the South Indian HP cell shifts westward towards the east

coast from the summer position of 88°E to 65°E in winter. The South Atlantic HP cell moves from its

summer position at 4°W to its winter position at 16°W, migrating away from the western coast (Preston-

Whyte et al., 1976). Anticyclones result in subsidence in the atmosphere, which increase the incidence

and duration of calm winds, clear skies, lowered humidity and little precipitation (Preston-Whyte et al.,

1980).




ANNUAL VARIATIONS

Project No.

516955

Figure 6-14: Annual variations in the positions of the South Atlantic and South Indian anticyclones (Source: Preston-Whyte et al., 2000)

Conversely, during summer, a low pressure system dominates over the interior of the country due to

the slight southward shift of the continental HP cell. The South Atlantic HP cell moves towards the

east, over the Western Cape, and the South Indian HP shifts eastwards, causing the HP conditions to

diminish over the eastern coast. Extremely stable atmospheric conditions that can persist for long

periods are the result of the semi-permanent and subtropical continental anticyclones. These

conditions are found to occur at a frequency of 70% in winter and 20% in summer.


SURFACE ATMOSPHERIC CICULATION

Project No.

516955

Figure 6-15: Important features of the surface atmospheric circulation over southern Africa (Source: Preston-Whyte et al., 2000)

The south-easterly trade winds generally affect South Africa throughout the year. However, during

winter, the HP cells shift northward, causing the circumpolar westerly waves to displace the easterly



trade winds and dominate over South Africa. The westerly belt is associated with the migration of

isolated low pressure cells and cyclones around the coast or across the country towards the east.

During summer, the HP belt shifts southwards and the easterly trade winds displace the westerly

waves to resume its influence over the country.

During summer, localised weather systems to the east of the south-easterly trade winds causes

turbulence and uplift and the potential for precipitation over the eastern part of the country, resulting

in summer rains. On the western side of the easterly waves, upper-level convergence and surface-

level divergence causes clear conditions with no precipitation over the western part of the country.

During winter, westerly waves significantly influence the weather of the country. Upper-level

divergence and surface-level convergence occurs to the rear of the trough, which causes uplift and

cloud formation resulting in precipitation and winter rains over the western coast. Rainfall will also

occur with the passing of cold fronts, which are associated with the westerly waves. Rainfall has a

positive effect on pollution control as the water droplets act as nuclei onto which dust and pollutants

will collect and deposit onto the ground. This is known as “scrubbing” of the atmosphere.

Along the coastline, sea and land breeze circulations influence the diurnal wind variation and ultimately

govern the transport of atmospheric pollutants. During the daytime, the land heats rapidly while the

sea retains its cool temperature. The warm air over the land rises causing a low pressure to develop.

The cool air over the sea subsides and flows down the pressure gradient, causing a sea-land breeze

to develop. The converse is true for night-time conditions, where the air above the land cools due to a

lack of insulation, while the air above the sea remains warm. A land-sea breeze will therefore prevail

during the night (Diab, pers comm., 2007).

6.7.2 Climate Conditions at the Project Site

According to the Koppen Climate Classification System the project area is classified as the Category

“C” climate type which is characteristically a moist mid latitude climate with mild winters. Annual

precipitation is less than 760 mm.

The project site itself falls into subcategory “Cwb” within the “C” category. The “Cwb” climate type can

be classified as mild temperate with cool dry winters and warm summers.

Climate data for Bosjespruit, for the years 2014 to 2018, was acquired from Sasol (Table 6-7) and is

summarised in the sections that follow. In additional modelled meteorological data was acquired from

Lakes Environmental for the period 2015 to 2017. Figure 6-16 indicates the location of the weather

stations in relation to the site.

Table 6-7: Weather station

Weather Station Location relative to the site Coordinates

Longitude Latitude

Bosjespruit NW 29°12'26.33"E 26°36'18.76"S

Sasol (Lakes modelled met data) On-site 29.167519 E 26.555214 S




LOCATION OF WEATHER STATIONS Project No.

539945

Figure 6-16: Location of weather stations



6.7.3 Rainfall

Rainfall is an important parameter with respect to air quality as air pollution is removed from the

atmosphere during the rainy season. During the rainy season, air pollution, and more specifically in

this case, dust particles, are removed from the atmosphere. Dust emissions are suppressed due to

increases in soil moisture content and increased vegetation cover during the rainy season. Dust

emission levels are generally higher during the cooler dry and hot dry seasons.

An annual average total of 620.5 mm of rainfall was received over the monitoring period from 2014-

2018 at the Bosjespruit monitoring stations. The month with the highest average rainfall is December

(133.7 mm) with the lowest average rainfall recorded in June (4.2 mm). The majority of rainfall is

observed from October to April with lowest rainfall observed in the months from May to September.

On average the highest rainfall is measured in December with the lowest rainfall measured in June.

In comparison, data acquired from Lakes Environmental for the Sasol site shows that total rainfall for

the area for the period from January 2015 to December 2017 at 883.0 mm. Similar to the data at

Bosjespruit, the majority of rainfall is observed from October to April with rainfall observed in the

months from May to September. The month with the highest average rainfall is January with 218.9

mm of rainfall and the lowest rainfall was measured in June (4.2 mm).

The rainfall data is detailed in Table 6-8and is presented in Figure 6-17.

Table 6-8: Monthly rainfall

Month Bosjespruit Monthly Rainfall Lakes Monthly

Rainfall

Units mm mm

January 92.5 218.9

February 60.4 89.7

March 105.1 73.8

April 37.9 29.1

May 12.7 3.3

June 4.2 7.9

July 12.3 5.3

August 6.7 5.3

September 14.4 37.1

October 58.1 71.5

November 82.6 152.9

December 133.7 188.0

Annual 620.5 883.0




RAINFALL DATA FOR BOSJESPRUIT AND LAKES Project No.

539945

Figure 6-17: Rainfall data for Bosjespruit and Lakes

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Bosjespruit Lakes Environmental



6.7.4 Temperature

Ambient air temperature is an important factor in determining the effect of plume buoyancy and in

determining the development of the mixing depths and inversion layers. The larger the temperature

difference between the emissions plume and the ambient air, the higher the plume is able to rise.

Temperature data has been sourced from the Sasol Bosjespruit weather station and Lakes

Environmental. The average monthly temperature data is summarised in Table 6-9 and is presented

in Figure 6-18.

The average temperatures at Bosjespruit range from 9.5 -19.4°C with a variance of up to 9.9°C. The

maximum temperatures reach a high of 37.2°C and minimum temperature of -1.0 °C.

The average temperatures from Lakes Environmental ranges from 8.6 - 20.7°C, with maximum

temperatures reaching a high of 30.1°C and minimum temperature of -7.4 °C.

Table 6-9: Monthly temperatures for Bosjespruit and Lakes Environmental

Month Bosjespruit Lakes Environmental

Ave Max Min Ave Max Min

Units °C °C °C °C °C °C

January 19.2 34.7 0.0 20.3 29.6 6.9

February 19.4 34.5 0.0 20.4 29.4 10.6

March 18.0 34.4 0.0 18.8 27.8 6.8

April 15.3 32.4 0.0 15.4 26.6 5.5

May 12.8 26.9 -1.0 11.7 26.2 1.4

June 9.8 24.8 -5.0 10.8 29.9 0.0

July 9.5 28.7 -7.4 8.6 18.1 -0.6

August 12.2 31.2 -4.0 11.4 23.6 -1.0

September 15.7 33.3 -3.5 15.2 25.1 3.1

October 16.9 37.2 0.0 17.4 29.4 2.5

November 13.8 35.1 0.0 18.8 28.6 4.1

December 19.1 34.2 0.0 20.7 30.1 9.8

Average 15.2 32.3 -1.7 15.8 27.0 4.1




TEMPERATURE DATA FOR BOSJESPRUIT AND LAKES Project No.

539945

Figure 6-18: Comparison of temperature data

-10-505

10152025303540

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(°C

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Temperature data from January 2014 to November 2018

Min Average Max

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Lakes Temperature for the period January 2015 to December 2017

Average Max Min



6.7.5 Wind Field

The wind field for an area is an important parameter with respect to air quality as winds can affect the

dispersion of a pollutant plume. The degree to which winds can influence dispersion is dependent on

the wind speed. Higher wind speeds result in longer travel distance and dilution of the pollutants and

lower, more stable wind conditions result in shorter travel distance and build-up of pollutant levels

(especially gases) over a smaller area.

6.7.6 Bosjespruit Station Data

Wind roses were created using the measured station data over different time-periods and seasons to

establish wind patterns as a function of time and weather conditions.

The wind roses for all hours, daytime and night-time for the period 2014-2018 are presented in Figure

5-7 (a-d). The prevailing wind direction throughout the data period is from the northeast and east-

northeast with lower occurrences of winds blowing from the north, west-northwest and east-southeast.

These wind patterns are also evident during the day-time (06:00-18:00) (Figure 6-19), however the

winds from the west-northwest are more frequent when compared to winds from the northeast and

east-northeast. The prevailing winds during the earlier parts of the night (18:00-00:00) (Figure 6-19)

and latter parts of the night (00:00-06:00) (Figure 6-19) are similar to the all hours wind rose.

The average wind speed measured for all hours is 3.12 m/s with maximum speeds greater than 11.1

m/s. The total percentage of calms (speeds lower than 0.5 m/s) is 3.98%. The average wind speed

during the daytime (06:00-18:00) is 3.41 m/s and the percentage of calms is 3.84%. The average wind

speed during the early night (18:00-00:00) is 2.93 m/s with calms of 3.67%. The average wind speed

decreases to 2.61 m/s during the latter part of the night with calms comprising 4.78% of all winds

during this period.

Seasonal wind roses were also created for the meteorological period. During spring (Figure 6-20),

there is a high frequency of high winds from the northerly quadrant. In summer (Figure 6-20) a high

frequency of high winds prevails from the north-easterly while a lower frequency blows from the

southeast. In autumn (Figure 6-20) the predominant wind direction is from the north-easterly and east-

north-easterly. In winter (Figure 6-20), winds blow predominantly from the northeast and west-

northwest.

The wind class frequency distribution in Figure 6-21 shows that 88.5% of winds are low speeds while

only 8.2% of winds can be classified as high speed winds.



(a): 2014-2018 (All Hours)

(b): 2014-2018 (Daytime 06:00 - 18:00)

(c): 2014-2018 (Night-time 18:00 - 23:00)

(d): 2014-2018 (Night-time 00:00 - 06:00)


WIND ROSES (ALL HOURS, DAYTIME, NIGHT-TIME)

Project No.

539945

Figure 6-19: All hours, daytime and night-time wind roses (Bosjespruit weather station data)



(a): Spring (All Hours)

(b): Summer (All Hours)

(c): Autumn (All Hours)

(d): Winter (All Hours)


SEASONAL WIND ROSES

Project No.

539945

Figure 6-20: Seasonal wind roses (Bosjespruit weather station data)




WIND CLASS FREQUENCY

Project No.

539945

Figure 6-21: Wind class frequency distribution (Station Data)

6.7.7 Lakes Environmental

The wind roses for all hours, daytime and night-time for the site for the period January 2015 to

December 2017 are presented in Figure 6-22. The prevailing wind directions are predominantly north

and north-westerly. During the daytime (06:00-18:00), most of winds blow from the northwest and

north (Figure 6-22). During the earlier parts of the night (18:00-00:00), there is a high frequency of

winds from the northwest, north, northeast and east-northeast (Figure 6-22) with winds blowing from

north during the latter part of the night (00:00-06:00) (Figure 6-10 (d)).

The average wind speed measured for all hours is 3.10 m/s with maximum speeds greater than 11.1

m/s. The total percentage of calms (speeds lower than 0.5 m/s) is 10.41%. The average wind speed

during the daytime (06:00-18:00) is 2.97 m/s and the percentage of calms is 12.63%. The average

wind speed during the early night (18:00-00:00) is 3.10 m/s with calms of 8.94%. The average wind

speed decreases to 3.26 m/s during the latter part of the night with calms comprising 6.90% of all

winds during this period.

Seasonal wind roses were also created for the three-year meteorological period. During spring (Figure

6-23), there is a high frequency of high winds from the north and north-westerly. In summer (Figure

6-23) a high frequency of high winds prevails from the northeast while a lower frequency blows from

the northwest and southwest. In autumn (Figure 6-23) and winter (Figure 6-23), the wind patterns are

comparable, with winds prevailing from the northwest and north. The wind class frequency distribution

in Figure 6-23 shows that 93.1% of winds can be classified as low winds, while 6.9% of winds can be

classified as high wind speeds.



(a): January 2015 to December 2017 (All Hours)

(b): January 2015 to December 2017 (Daytime 06:00 - 18:00)

(c): January 2015 to December 2017 (Night-time 18:00 - 23:00)

(d): January 2015 to December 2017 (Night-time 00:00 - 06:00)


Wind Roses (All hours, daytime, night-time)

Project No.

539945

Figure 6-22: All hours, daytime and night-time wind roses (Lakes Environmental)



(a): Spring (All Hours)

(b): Summer (All Hours)

(c): Autumn (All hours)

(d): Winter (All hours)


Seasonal Wind Roses

Project No.

539945

Figure 6-23: Seasonal wind roses (Lakes Environmental)




Wind Class Frequency

Project No.

539945

Figure 6-24: Wind class frequency distribution (Lakes Environmental, 2017)

6.8 Visual

The proposed CRF 2 Tanks project is situated within the existing, highly developed Sasol Synfuels

Operations, surrounded by industrial activities associated with the operations of Sasol.

6.9 Cultural and Heritage

The CF 2 proposed Tanks Expansion Project is situated within the already established Sasol Synfuels

Operations, which is a highly developed industrial area that has been in operation for more than 50

years. The landscape has been altered by the development in the 1970’s. There are no sites of

archaeological significance known in the project area. No extensive bulk earthworks are anticipated

for the CF 2 proposed Tanks Expansion Project; thus, no impact is predicated on archaeological

artefacts.

6.10 Noise

Ambient noise levels in the Sasol Synfuels Operations are monitored on a quarterly basis. No sensitive

noise receptors are near the CF 2 proposed Tanks Expansion Project; however certain ecological

units may experience a certain degree of impact during construction. Minimal additional noise level is

anticipated due to the operation of the CF 2 proposed Tanks Expansion Project. The major addition to

the current status quo will be experienced during construction activities, which can be effectively

mitigated and managed.



6.11 Topography

The regional topography at Secunda consists of flat plains and local shallow drainage valleys. The

Sasol Synfuels Operations topography is gently undulating with a very low gradient dropping down to

the east of the Operations. The site is flat with and elevation of 1600 masl.

The proposed CF 2 Tanks will be largely constructed on a prepared terrace, elevated and bunded

from the ingress of outside stormwater. Stormwater from the upper catchment is physically directed

around the Sasol Synfuels Operations, by engineered channels and the bunding of the Tank Farms,

to the process water collection dams, in the event that is could be considered potentially contaminated.

Rainwater falling on the Sasol Synfuels Operations processing areas is considered to be potentially

contaminated and is therefore contained within the Operations and directed by drainage channels to

collection sumps from which it is recovered into the wastewater treatment operations. An illustration

of the topography can be found in Figure 6-25.




ILLUSTRATION OF THE TOPOGRAPHY Project No.

539945

Figure 6-25: Illustration of the site topography



6.12 Land Use and Land Capability

The CF 2 proposed Tanks Expansion Project is situated with the Sasol Synfuels Operations which is

surrounded by several different land uses (industrial, residential, commercial and agricultural). The

middle to high-income residential area of Secunda is located approximately 5 km north-east of the

Sasol Synfuels Operations and includes a variety of commercial activities. 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. The Sasol Synfuels Operations currently has no capability for agriculture or cultivation. Given

the extended history of the site within the pre-developed Sasol Synfuels Operations, there is no

practical alternative land use for the proposed CF 2 footprints.

6.13 Soils

The soils in the area are strongly structured cracking soils, mainly dark coloured, and dominated by

vertic soils. These may occur associated with one or more of melanic and red structured soils. The

soils in the area have water holding capacities of between 20 and 40 mm with a moderate erodible

potential and a poor arable agricultural potential.

Within the Sasol Synfuels Operations the soils contain 35% clay, while sub-soils commonly display

more than 40% clay. Soils contain carbonates and are alkaline with a strong buffer capacity. The soils

in the area typically relate to soils with a high clay content ranging between 450 – 750 mm deep.

6.13.1 Site Specific Soil Chemistry (SRK, 2019)

Soil samples were collected from the test pits of the berms and from the test pits within the existing

tank farm area which were opened during the geotechnical investigation of the CF 2 tank farm area.

From the samples taken, three soil samples at varying depths were sent for analysis from the berms

and ten soil samples at varying depths were sent for analysis from the tank farm area to an accredited

laboratory, EXOVA Jones Environmental. The soil analysis has been compared to the South African

Soil Screening Values (SSVs).

Several countries, including South Africa, have created soil screening values/levels which are

guideline concentrations to assess the risk of contaminated soils. The South African SSVs which are

provided in the National Norms and Standards for the Remediation of Contaminated Land and Soil

Quality in the Republic of South Africa are derived from the Framework for the Management of

Contaminated Land which was developed in 2010.

Samples collected from the berms and the tests pits at the CF 2 Tank farm area have been compared

to the SSVs for industrial land (SSV2).

The berm results indicate that the soil quality of the berm, fall within the South African SSVs for

industrial land. The results further indicate that organics are not present above detection limit in the

berm samples and that the metal and inorganic concentrations are low. As a result, the soil from the

berm is considered uncontaminated and, from a contamination perspective, are suitable for use on

industrial land.

The sample analysed for the test pits has a neutral to slightly basic pH and low electrical conductivity.

There are low concentrations of metals present in each of the samples, especially aluminium, iron,

manganese and total chromium. All metals are below the SSV2 standards.

In terms of inorganic elements, fluoride, chloride and sulphate were detected at low levels while low

levels of nitrate were also present. All detected inorganics were below the SSV2 standards.

Traces of total petroleum hydrocarbons are detected, but well below SSV2 standards. Traces of

volatile organic compounds, semi-volatile organic compounds (specifically poly aromatic

hydrocarbons) and total petroleum hydrocarbons were detected in the samples. There was a slight



exceedance of the poly aromatic hydrocarbon benzo(a)pyrene SSV2 but only in an isolated area and

was the only occurrence where industrial land SSV2 limits were exceeded.

Benzo(a)pyrene is potentially carcinogenic but the SSV2 limits are highly conservative and there is

limited human access to this site, with very low potential exposure rates to the soil, therefore it is

unlikely that there will be any material liability associated with benzo(a)pyrene in this case.

6.14 Biodiversity

The Sasol Synfuels Operations is situated in the Soweto Highveld Grassland vegetation type.

However, the Sasol Synfuels Operations is a highly developed industrial area with minimal biodiversity

of importance. The Sasol Synfuels Operations is situated in an area classified as having no natural

habitats remaining according to the Mpumalanga Conservation Sector Plan (Mpumalanga Tourism

and Parks Agency, 2014). Figure 6-26 illustrates the status of the biodiversity habitats in and around

the Sasol Synfuels Operations. Given the extended history of the Sasol Synfuels Operations, there is

no practical biodiversity value remaining within the footprints of the CF 2 sites.



SASOL CF 2 TANKS PROJECT ILLUSTRATION OF THE BIODIVERSITY HABITAT IN AN AROUND THE PROPOSED CF 2 TANKS

PROJECT

Project No. 539945

Figure 6-26: Illustration of the biodiversity habitat in an around the proposed CF 2 Tanks Project



6.15 Health and Safety

The nature of Sasol’s business inherently brings safety, health and environmental risks. Sasol’s annual

sustainable development reporting includes a comprehensive list of these potential risks. Sasol strive

to understand the highest safety risks, to be better equipped to ensure zero harm. The main risks

identified 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 Procedures and Standards are compulsory and applicable to all new

projects including the CF 2 proposed Tanks Expansion Project.



7 Stakeholder Engagement Process Stakeholder Engagement Process forms a key component of the EIA process and is governed by

GNR 982 of 4 December 2014, published in terms of the NEMA. The Stakeholder Engagement is the

Process whereby parties who may be potentially affected by the CF 2 proposed Tanks Expansion

Project, directly or indirectly, or those who have an interest in the CF 2 proposed Tanks Expansion

Project, are involved during all stages of the EIA process.

The purpose of Stakeholder Engagement during the EIA phase is to ensure that the views, interests

and concerns of the project stakeholders are taken into consideration during the assessment process

of the anticipated environmental, social and economic impacts as well as the design of mitigation

measures for the CF 2 proposed Tanks Expansion Project. This process strives to minimise negative

environmental impacts and enhance the positive impact posed by the CF 2 proposed Tanks Expansion

Project.

7.1 Objectives of the Stakeholder Engagement Process

The Stakeholder Engagement Process as part of this stage of the EIA Process for the CF 2 proposed

Tanks Expansion Project aims to:

• Ensure timely distribution of information that is understandable and accessible to all stakeholders;

• Provide background information on the proposed CF 2Tanks project and environmental process

followed to the relevant stakeholders, to ensure that they are presented with enough information

to make an informed decision;

• Provide adequate opportunity for I&APs and Key Organs of Stage to provide their concerns and

comment on the CF 2 proposed Tanks Expansion Project;

• Ensure that all issues and concerns raised by the public are considered and appropriately

responded to in the EIA documentation;

• Ensure that all stakeholders are kept informed on the process of the EIA underway;

• Ensure and maintain relationships and channels of communication with all stakeholders for the

duration of the EIA, through which communication channels for the remainder of the CF 2

proposed Tanks Expansion Project can be built;

• Enable the project team to incorporate the needs, concerns and recommendations of I&APs into

the design, construction and operation of the project; and

• Comply with national and provincial legislative requirements for public participation, as well as

best practise guidelines.

7.2 Objectives of this Section

The objectives of Section 7 are to:

• Describe the steps taken to notify potential I&APs of the proposed application;

• To provide proof that the posters, advertisements and notices notifying potential I&APs of the

proposed application have been displayed, placed or given;

• Compile a list of all persons, organisations and organs of state that were identified and registered

as I&APs in terms of Chapter 6 of GNR 982; and

• Summarise the issues raised by I&APs, the date of receipt and the response of the EAP to those

issues; and



• Outline the way forward.

7.3 Stakeholder Engagement Process Followed

The initial stakeholder database was developed by Sasol from previous studies done in the area. The

database was communicated to SRK and was used for the CF 2 Tank Expansion Project. Additional

stakeholders were identified from previous projects in the area, giving them the opportunity to again

register for the CF 2 proposed Tanks Expansion Project.

Stakeholders were further provided an opportunity to register during the Stakeholder Engagement

Process for the CF 2 proposed Tanks Expansion Project.

Stakeholders that raised comments in response to the Stakeholder Engagement Process were

recorded and addressed in this BAR. A list of I&APs consulted with can be found in Appendix C.

Activities undertaken during the initial phase of the environmental technical process included:

• Project meetings between the client and SRK Consulting;

• Identification of information needs in respect to the CF 2 proposed Tanks Expansion Project and


• Collation of technical information in respect to the CF 2 proposed Tanks Expansion Project and


• Review of EA requirements for the CF 2 proposed Tanks Expansion Project; and

• Consultation with the MDARDLEA.

Stakeholders were notified of the project as follows:

• Regulatory Authorities were provided with a Background Information Document (BID) and a

response sheet;

• Broader stakeholders (residents, neighbouring landowners/land uses and specialist interest

groups) were informed of the CF 2 proposed Tanks Expansion Project through email, fax and

postage of a BID document. A copy of the BID can be found in Appendix E;

• The project was publicised through media advertisement placed in two local newspapers namely

the Bulletin (English, Afrikaans and IsiZulu) and Echo Ridge newspapers (English);

• Placement of site notices in and around the project area.

Written notice was provided to I&APs, of which a copy can be found in Appendix F.

7.4 Authority Consultation

The competent authority, MDARDLEA, reviewing the BAR and providing a decision on the application

was consulted from the outset of the study. A pre-application meeting was held with Ms. Sindisiwe

Mbuyane on 30 November 2018. Proof of correspondence and the minutes of the meeting with

MDARDLEA can be found in Appendix I.

Notification of the proposed CF 2 was provided to the MDARDLEA on 28 June 2019.

7.5 Placement of Site Notices and Newspaper Advertisements

Site notices were placed at several pre-determined positions of the CF 2 proposed Tanks Expansion

Project. The site notices were placed at the same time as the submission of the BAR. Proof of

notification will be provided in the final BAR. The location and coordinates of the site notices placed

for the CF 2 proposed Tanks Expansion Project are provided in Table 7-1.



Table 7-1: Location and coordinates of the sites notices

No Description Coordinates

Longitude Latitude

1 Govan Mbeki Local Municipality 29° 11' 5.00" E 26° 30' 13.80" S

2 Govan Mbeki Library 29° 11' 5.16" E 26° 30' 16.95" S

3 At the entrance to the Sasol Synfuels Operations (Charlie 1)

29° 9' 25.20" E 26° 31' 30.00" S

4 Sasol Recreational Club 29° 11' 2.84" E 26° 31' 17.00" S

Taking cognisance that there is limited access within the Sasol Synfuels Operations, only one site

notice will be placed directly at the site, however a notice will be placed at the entrance to the Sasol

Synfuels Operations (Charlie 1) through which Sasol employees and visitors pass.

The newspaper advertisements served the purpose of inviting I&APs to register for the CF 2 proposed

Tanks Expansion Project and submit any issues or concerns they might experience relating to the CF

2 proposed Tanks Expansion Project. Following the initial commenting and registration period, issues

from I&APs have been captured, collated and addressed in the BAR. The BAR has been sent to all

key Departments, I&APs and Organs of State for a 30-day commenting period.

The project was publicised through media advertisement placed in two local newspapers (Bulletin

newspapers in isiZulu, English and Afrikaans respectively, and the Eco Ridge in English). Proof of the

placement of newspaper adverts can be found in Appendix D.

7.6 Summary of Interested and Affected Party Issues

Issues or comments raised by I&APs relating to the CF 2 proposed Tanks Expansion Project will be

included in the Final BAR.

7.7 Notification on the Availability of the Basic Assessment Report

The BAR and EMPr has now been made available for a 30-calendar day commenting period, from 28

June 2019 to 29 July 2019. The BAR and EMPr will be placed in the public domain and submitted to

the MDARDLEA. A letter was sent to registered I&APs to inform them of the availability of the BAR

and where the report may be obtained from and the period available for comment. In addition, the

report will also be made available at the following locations:

• Secunda Public Library;

• Sasol Recreational Club;

• SRK Offices in Pretoria;


7.8 Process for the Remainder of the Study

Further communication will be sent to registered I&APs on when the BAR has been submitted to the

MDARDLEA. Final communication with registered I&APs will be to inform them on the outcome of the

EIA process and the decision made by the MDARDLEA. Registered I&APs will be notified in writing

on the decision and will be informed on the timeframes to appeal the decision.

7.9 Public Participation Conclusion

No I&APs comments with regards to the CF 2 proposed Tanks Expansion Project were received,

however, it is concluded that the Stakeholder Engagement conducted to date is sufficient to provide

adequate information to I&APs, and to inform them on the purpose of the CF 2 proposed Tanks




Expansion Project. The Stakeholder Engagement Process was conducted in adherence to the

requirements stipulated in GNR 982 and regulatory guidelines. Further Stakeholder Engagement

activities will be conducted in line with the NEMA and associated guidelines for the remainder of the

BAP.



8 Motivation for the Need and Desirability The implementation of the proposed changes to the existing Sasol Synfuels Operations Tank Farm

will enable Sasol to meet the legislative requirements for fuel production and ensure alignment with

the government gazetted CF 2 programme.

The CF 2 Tank Expansion Project will be located largely within the Sasol Synfuels Operations and will

therefore not impact on the ecological integrity of the area. A portion of the TAME, MFO and CNT

tanks will require the extension of the existing bunded area, which will be extended on areas of least

concern ( (Mpumalanga Tourism and Parks Agency, 2014), therefore will not impact on sensitive areas

(Critical Biodiversity Areas (CBA) or Ecological Support Areas (ESA)). As most of the CF 2 Tank

Expansion Project will take place within the existing Sasol Synfuels Operations, no threatened,

sensitive, vulnerable, highly dynamic or stressed ecosystems were identified within the proposed

footprint.

The CF 2 proposed Tanks Expansion Project will not impact on any global or international

responsibilities to the environment. Numerous possible impacts have been identified in the impact

assessment (waste generation, spill management etc.) that can be mitigated and managed to an

acceptable level. Considering the environmental context of the surrounding areas, impacts will be of

a low significance. The CF 2 proposed Tanks Expansion Project will not impact on environmental

rights in terms of access to resources, nuisance odour, water quality and quantity, or loss of amenity.

The Govan Mbeki IDP stipulates that the competitive advantage of the manufacturing sector within

Govan Mbeki needs to be expanded through the provision of a Special Economic Zone providing for

the broadening of the economic base through exploiting specific business opportunities with Sasol.

Industrialisation of Govan Mbeki will focus on manufacturing of several products from Sasol petro-

chemical activities (Govan Mbeki Municipality, 2018). The CF 2 proposed Tanks Expansion Project is

in line with these initiatives.

The CF 2 proposed Tanks Expansion Project will complement the local socio-economic initiatives

through temporary job creation during the construction phase of the project.

The CF 2 proposed Tanks Expansion Project will not result in significant environmental impacts that

cannot be managed or mitigated.



9 Methodology for Impact Identification and Assessment The anticipated impacts associated with the CF 2 proposed Tanks Expansion Project have been

assessed according to SRK standardised impact assessment methodology which is presented below.

This methodology has been utilized for the assessment of environmental impacts where the

consequence (severity of impact, spatial scope of impact and duration of impact) and likelihood

(frequency of activity and frequency of impact) have been considered in parallel to provide an impact

rating and hence an interpretation in terms of the level of environmental management required for

each impact.

The first stage of any impact assessment is the identification of potential environmental activities2,

aspects3, and impacts which may occur during the commencement and implementation of a project.

This is supported by the identification of receptors4 and resources5, which allows for an understanding

of the impact pathway and an assessment of the sensitivity to change. Environmental impacts6 (social

and biophysical) are then identified based on the potential interaction between the aspects and the

receptors/resources.

The significance of the impact is then assessed by rating each variable numerically according to

defined criteria as outlined in Table 9-1.

The purpose of the rating is to develop a clear understanding of influences and processes associated

with each impact. The severity7, spatial scope8 and duration9 of the impact together comprise the

consequence of the impact and when summed can obtain a maximum value of 15. The frequency of

the activity10 and the frequency of the impact11 together comprise the likelihood of the impact occurring

and can obtain a maximum value of 10. The values for likelihood and consequence of the impact are

then read off a significance rating matrix table as shown in Table 9-2.

This matrix thus provides a rating on a scale of 1 to 150 (very low, low, low medium, medium high,

high, or very high) based on the consequence and likelihood of an environmental impact occurring.

2An activity is a distinct process or task undertaken by an organisation for which a responsibility can be assigned. Activities also include facilities or pieces of infrastructure that are owned by an organisation. 3An environmental aspect is an ‘element of an organisation’s activities, products and services which can interact with the environment’. The interaction of an aspect with the environment may result in an impact. 4Receptors comprise, but are not limited to, people or man-made structures. 5Resources include components of the biophysical environment. 6Environmental impacts are the consequences of these aspects on environmental resources or receptors of particular value or sensitivity, for example, disturbance due to noise and health effects due to poorer air quality. Receptors can comprise, but are not limited to, people or human-made systems, such as local residents, communities and social infrastructure, as well as components of the biophysical environment such as aquifers, flora and palaeontology. In the case where the impact is on human health or well-being, this should be stated. Similarly, where the receptor is not anthropogenic, then it should, where possible, be stipulated what the receptor is. 7Severity refers to the degree of change to the receptor status in terms of the reversibility of the impact; sensitivity of receptor to stressor; duration of impact (increasing or decreasing with time); controversy potential and precedent setting; threat to environmental and health standards. 8Spatial scope refers to the geographical scale of the impact. 9Duration refers to the length of time over which the stressor will cause a change in the resource or receptor. 10Frequency of activity refers to how often the proposed activity will take place. 11Frequency of impact refers to the frequency with which a stressor (aspect) will impact on the receptor.



Natural and existing mitigation measures, including built-in engineering designs, are included in the

pre-mitigation assessment of significance. Measures such as demolishing of infrastructure, and

reinstatement and rehabilitation of land, are considered post-mitigation.

The assessment of significance should be undertaken twice. Initial significance should be based on

only natural and existing mitigation measures. The subsequent assessment should consider the

recommended management measures required to mitigate the impacts.

Table 9-1: Criteria for assessing significance of impacts

SEVERITY OF IMPACT RATING

Insignificant/non-harmful 1

Small/potentially harmful 2

Significant/slightly harmful 3

Great/harmful 4

Disastrous/extremely harmful 5

SPATIAL SCOPE OF IMPACT RATING

Activity specific 1

Project specific (within the project boundary) 2

Local area (within 5 km of the activity boundary) 3

Regional 4

National 5

DURATION OF IMPACT RATING

One day to one month 1

One month to one year 2

One year to ten years 3

Life of operation 4

Post closure/permanent 5

FREQUENCY OF ACTIVITY/DURATION OF ASPECT

RATING

Annually or less/low 1

6 monthly/temporary 2

Monthly/infrequent 3

Weekly/life of operation/regularly/likely 4

Daily/permanent/high 5

FREQUENCY OF IMPACT RATING

Almost never/almost impossible 1

Very seldom/highly unlikely 2

Infrequent/unlikely/seldom 3

Often/regularly/likely/possible 4

Daily/highly likely/definitely 5

CONSEQUENCE

LIKELIHOOD



Table 9-2: Significance rating matrix

Table 9-3: Positive/negative mitigation ratings

Colour Code

Significance Rating

Value Negative Impact Management Recommendation

Positive Impact Management Recommendation

Very high 126-150 Improve current management

Maintain current management

High 101-125 Improve current management


Medium-high 76-100 Improve current management


Medium-low 51-75 Maintain current management

Improve current management

Low 26-50 Maintain current management


Very low 1-25 Maintain current management


The suitability and feasibility of all proposed mitigation measures will be included in the impact

assessment. This will be achieved through the evaluation of the significance of the impact before and

after the proposed mitigation measures are implemented. Mitigation measures identified for each

environmental variable will be included in an EMPr which will form part of the BAR.

CONSEQUENCE (Severity + Spatial Scope + Duration)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

2 4 6 8 10 12 14 16 18 20 22 24 26 28 30

3 6 9 12 15 18 21 24 27 30 33 36 39 42 45

4 8 12 16 20 24 28 32 36 40 44 48 52 56 60

5 10 15 20 25 30 35 40 45 50 55 60 65 70 75

6 12 18 24 30 36 42 48 54 60 66 72 78 84 90

7 14 21 28 35 42 49 56 63 70 77 84 91 98 105

8 16 24 32 40 48 56 64 72 80 88 96 104 112 120

9 18 27 36 45 54 63 72 81 90 99 108 117 126 135 LIK

EL

IHO

OD

(F

requ

ency

of

acti

vit

y

+ F

requ

ency

of

impac

t)

10 20 30 40 50 60 70 80 90 100 110 120 130 140 150



10 Assessment of Environmental Impacts This section contains the assessment of potentially positive and negative environmental impacts that

can be caused by the CF 2 proposed Tanks Expansion Project. The impacts are linked to the activities

conducted for the CF 2 proposed Tanks Expansion Project, broadly relating to planning, construction,

operations and decommissioning phases. Specific emphasis was placed on any relevant

environmental, social and economic impacts identified by the Air Quality and Geotechnical Specialists,

comments received during the Stakeholder Engagement Process, issues highlighted by relevant

authorities; as well as a professional judgement of the EAP team through appraisals on the project

description, listed activities and the receiving environment.

The objectives for each of the potential environmental impacts identified was to determine their

significance and to promote mitigation measures to reduce the impacts to an acceptable level where

required.

All the identified impacts are assessed in this section. Considering the general nature of the proposed

CF 2, this section will take cognisance of the construction, operational, and decommissioning phases.

This is intended to:

• Enable to facilitate the preferred alternative during the decision-making process of the

MDARDLEA; and

• Enable stakeholders to understand the potential impact of the project.

Identified potential environmental impacts have been addressed in this section, according to the

adopted methodology for assessing impacts as described in Section 9.

10.1 Potential Environmental Issues Identified for the Project

Key potential positive and negative environmental issues relating to the CF 2 proposed Tanks

Expansion Project were identified based on the finding from I&APs responses, Air Quality Assessment,

Geotechnical Assessment, as well as the professional judgement from the EAP conducting the EIA.

The following potentially significant environmental issues relating to the CF 2 proposed Tanks

Expansion Project were identified.

The mitigation measures have been incorporated into the EMPr (Appendix G) for all potential

environmental impacts identified as part of the different phases of the project.

10.2 Pre-Construction and Construction Phase

It must be noted that minimal biophysical, social or cultural impacts are envisaged during the pre–

construction and construction phases as the CF 2 Expansion Project will be located within the existing

Sasol Synfuels Operations Tank Farm area. The CF 2 Tank Expansion Project will largely entail the

trenching of base foundations and erection of the tanks and associated infrastructure. The construction

phase will be temporary in nature. Construction activities will include, but are not limited to the

following:

• Site preparation – selective clearing of vegetation in areas designated for the CF 2 Tank Expansion Project;

• Contractor site establishment;

• Earthworks ( if not already done as part of the existing Sasol Synfuels Tank Farm area)

• Stripping of topsoil and sub-soil;

• Stockpiling of topsoil and sub-soil;

• Digging of trenches and foundations;



• Establishing of stormwater controls as per the stormwater management plan;

• Use of soil material from collected from existing berm as backfilling material;

• Civil works:

• Provide a terrace for the CF 2 proposed Tanks Expansion Project;

• Provide a new fence on the road side of the existing security fences near the TAME, CNT

and Diesel Creosote tanks. This fence will serve to provide security for the access road and

the site establishment area;

• A new security fence topped with barbed wire will be installed in the existing diesel Tank

Farm area. This fence will demarcate the area between the primary and secondary area.

Demarcation of the secondary area will make it possible to sign out the area to the contractor

and eliminate working under permit conditions;

• Construction of a new access road that leads from the existing road to the different areas

within the Tank Farm;

• Piling and tank foundations. The tank walls will be founded on a concrete ring beam above

compacted fill material;

• Concrete work including the mixing of concrete;

• Steelwork including grinding and welding;

• Removal of a section of the existing bund wall;

• Construction of the extension to the existing bunded wall. The bund wall design would be a

reinforced concrete cantilever. The expansion joints between the bund wall panels will

consist of elastic filler material, stainless steel water-bar, fire retardant rope and hydrocarbon

resistant sealant;

• Bund sizing will be done at 110% of the largest tank volume minus the volume occupied by

any adjacent tanks in the same bund in accordance with SANS 10089-1, with an allowance

of an additional 300 mm used for ballast stones placed in the tank bunds;

• Bund floor sealing and drainage control. A High density polyethylene (HDPE) sheeting layer

will be provided under the bund floor;

• Amending the oily water drainage system;

• Construction and installation of tanks, pump bays, new pipeline routes, tie-ins to existing

pipelines and other associated infrastructure;

• Installation of pumps;

• Amendment of the fire protection system; and

• Rehabilitation of disturbed areas after general site construction is completed.

The new tanks would be designed in accordance with American Petroleum Institute (API) – 650 (latest

edition). The proposed work will be fully compliant with SANS 10089 –1.

10.2.1 Socio – Economic Impacts

The CF 2 proposed Tanks Expansion Project will require the use of specialised skills and will result in

the generation of some temporary employment during the construction phase. It is expected that

contractors will be appointed by Sasol for the construction of the CF 2 proposed Tanks Expansion



Project. The contractors are responsible for the recruitment of labour, both casual and specialised,

through the Department of Labour.

A possible boost in short term employment and local small business opportunities are expected. Due

to the fact that during construction there will be limited additional employment opportunities that will

be attributed to the construction of the CF 2 proposed Tanks Expansion Project, it is expected that the

positive impacts (creation of employment) are also expected to be of low (+) significance.

There are however regional economic benefits as a result of the on-going operation of the Sasol

Synfuels Operations (High – Very High (+)).

The construction of the proposed tanks could potentially result in the following negative socio-

economic impacts:

• Generation of dust potentially resulting in a health and nuisance impact;

• Impact on safety and security as a result of theft, the occurrence of additional trucks on the roads,

uncontrolled lighting of fires on site, littering and driving irresponsibly;

• Health and safety risk as a result of the movement of construction vehicles increasing the risk of

accidents;

• Possible impact on service provision because of construction of temporary ablution facilities,

storage areas, and site establishment;

• Clearing of land which may potentially impact on the sense of place; and

• Squatting of job seekers.

During the construction phase, the potential negative impacts on the socio-economic environment are

expected to be of low (-) to very low (-) significance.

The cumulative impact on the socio-economic environment during the construction phase of the CF 2

proposed Tanks Expansion Project will be negligible.

10.2.2 Surface Water

The potential impacts on surface water during the construction phase of the proposed project are as

follows:

• Accidental spillages of hazardous substances from construction vehicles used during construction,

as well as from hazardous storage areas;

• Contamination of runoff by poor materials/waste handling practices;

• Debris from poor handling of materials and/or poor waste management practises;

• Contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water

quality; and

• Increase of surface runoff and potentially contaminated water that needs to be controlled in the

areas where site clearing occurred.

Sedimentation could potentially occur in the surrounding watercourses as runoff is naturally anticipated

to pick up environmental debris as it crosses natural areas. Increased turbidity is reversible and surface

water should return to pre-impact turbidity levels once sediment levels entering the watercourse are

reduced. Settled sediments should naturally move downstream during periods of high flow flowing

storm events.



It is expected that without the implementation of mitigation measures, the impacts on the surface

hydrology will be of low (-) significance, which can be reduced to very low (-) significance with the

implementation of mitigation measures.

The cumulative impact on surface water during the construction phase of the construction of the CF 2


10.2.3 Groundwater

The CF 2 proposed Tanks Expansion Project will be located within the existing Sasol Synfuels

Operation’s Tank Farm.

Potential discharges to ground surface, and subsequent impact on the groundwater system, could

potentially occur as a result of:

• The use of earth moving machinery and construction vehicles on site poses the risk of chemical

spillages including fuel and oils;

• Improper storage and handling of hazardous materials.

It is noted that a 5 km exclusion zone has been established in terms of groundwater abstractive use

around the Sasol Synfuels Operations. Consequently, there are no direct users of groundwater in and

around the CF 2 proposed Tanks Expansion Project. The existing Tank Farm is provided with hard-

standing and containment facilities for spillages and leaks. Similarly, the Sasol Synfuels Operations is

provided with comprehensive clean and dirty water drainage and containment systems to minimise

risk of release to the groundwater environment.

It is expected that without the implementation of mitigation measures, the impacts on the geohydrology

will be of low (-) significance, which can be reduced to very low (-) significance with the implementation

of mitigation measures.

The cumulative impact on groundwater during the construction phase of the CF 2 proposed Tanks

Expansion Project will be negligible.

10.2.4 Wetlands

One tank of the Sasol Synfuels Operations CF 2 Tank Expansion project will be located at a distance

of approximately 450 metres from the delineated boundary of the Klipspruit wetland system. Due to

the nature and location of the activity, as well as the distance from the Klipspruit wetland system, the

potential impacts on the water quality, flow, habitat, biota and geomorphology characteristics of the

watercourse during either the construction or operational phases were deemed negligible. The

following aspects were taken into consideration as part of the assessment process:

• Excavation will be done in an already impacted area where excavations and compacting were

done previously;

• The tanks will be located within the existing bunded area; towards the south east of the U058 API

dams

• Tanks will form part of the existing statutory maintenance schedule; and

• A leak detection system will be installed.

The potential impact associated with the CF 2 proposed Tanks Expansion Project during the

construction phase on wetland areas will therefore be negligible. Further, the cumulative impact on

wetlands during the construction phase will be negligible.



10.2.5 Air Quality

Dust generating activities associated with the construction phase will cause an increase in atmospheric

dust and exposed loose material that may be mobilised by the wind. However due to the short-term

nature of the project it is expected that the impact will be low to negligible. Further, it is expected that

the implementation of dust suppressing mitigation measures will result in the reduction in nuisance

dust.

Activities which could potentially have an impact on air quality include:

• Materials handling;

• Vehicle entrainment of dust;

• Windblown dust from bare ground.

It is expected that without and without the implementation of mitigation measures, the impacts on the air quality will be of very low (-) significance.

The cumulative impact on air quality during the construction phase of the CF 2 proposed Tanks Expansion Project will be negligible.

10.2.6 Climate Change

The movement of vehicles and earth moving machinery may result in the production of carbon dioxide

(Green House Gas), which may have an impact on the climate in the area. The impact on climate

change was calculated to be of very low (-) significance with and without mitigation during the

construction phase.

The cumulative impact on climate change during the construction phase of the CF 2 proposed Tanks


Although, the impact on climate change as a result of activities directly associated with the construction

of the CF 2 proposed Tanks Expansion Project will be of very low (-) significance, there are however

overall climatic benefits as a result of the production and utilization of fuel that will meet the new more

stringent requirements (cleaner fuels)(Very High (+)).

10.2.7 Soils, Land Use and Land Capability


Operations Tank Farm area, which is provided with comprehensive clean and dirty water drainage and

containment systems to minimise risk of release to the soils environment. The expansion of the CF 2

Fuel Tank Farm will include the stripping of the topsoil for construction and will be permanently

occupied by the additional tanks, resulting in loss of soil potential.

There is further the potential for impacts on soil, land use and land capability to occur outside the

proposed footprint area of the CF 2 Tank Expansion Project as a result of the erection of contractor

camps and other uncontrolled activities.

Potential for impacts on soil, land use and land capability

• Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result

in compacting of the soil;

• Clearing of vegetation outside of the CF 2 Tank Expansion Project;

• Localized and temporary contamination of soil resources because of incorrect

storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous

substances/materials used during the construction of the CF 2 proposed Tanks Expansion Project.

This may lead to the sterilisation of the soils;



• Potential compaction and erosion of soils removed and stockpiled during excavation activities; and

• Loss of topsoil due to erosion of areas exposed following excavation and stockpiling.

During the construction phase, the impacts on soils, land use and land capability have been calculated to be of medium-low (-) to low (-) significance and can be mitigated to be of low (-) to very low (-) significance.

The cumulative impact on soils of CF 2 proposed Tanks Expansion Project during the construction phase will be negligible.

10.2.8 Geotechnical Considerations

Please refer to Appendix H for the Geotechnical Environmental Impact Assessment Report.

This section contains the assessment of potentially negative environmental impacts that can be

caused by the CF 2 proposed Tank Expansion Project, relating to Geotechnical considerations. The

impacts are linked to the activities conducted for the CF 2 proposed Tank Expansion Project, broadly

relating to planning, construction, operations and decommissioning phases.

In general, Geotechnical environmental impact considerations include:

• Potential impact on soils including:

• Contamination as a result of poor waste and hazardous materials management;

• Soil degradation as a result of excavation and removal of soils;

• Soil degradation as a result of compaction of soils during earth works;

• Soil degradation as a result of erosion by wind and water, and slope instability;

• Potential impact on surface and groundwater contamination including:

• Contamination as a result of poor waste and hazardous materials management;

• Contamination of surface water resources as a result of uncontrolled runoff containing

suspended solids and sediments;

• Potential impact on air quality as a result of dust generating activities causing an increase in

atmospheric dust and exposed loose material that may be mobilised by the wind.

It is noted that potential environmental impacts on soils, waste management and surface/groundwater

are assessed as part of the BAR Impact Assessment and therefore only impacts directly related to

Geotechnical conditions was assessed in this study.

• The CF 2 Tank Expansion Project will largely entail the trenching of base foundations, the

construction of a terrace and the erection of the tanks and associated infrastructure. The following

potential impacts have been identified as a result of the Pre-Construction and Construction

phases:

• Potential geotechnical constraints impacting on engineering design of access roads and

foundations as a result of collapsible and compressible soil;

• Potential degradation of geo-sites;

• Potential degradation of bedrock and topography as a result of excavations for foundations,

pipelines, tanks and other associated infrastructure;

• Potential safety risk as a result of inappropriate founding methods; and

• Potential groundwater, surface and soil contamination as a result of:



• High settlements of structures if soils have a low in situ bearing capacity if not compacted or

engineered properly;

• Using contaminated material as bulk fill in material;

• Ground distortion (settlement) caused by construction activities (earthworks, retaining

structures etc.); and

• Change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater

level.

SRK (2019), found that the calculated settlements exceeds the allowable settlement in some areas

and adjusted the design criteria for each of the components accordingly.

Geo-sites are interesting or academically important geological exposures or features that require

protection and the environmental impact assessment process needs to cater for these aspects, if they

occur on the site. No known geo-sites occur on the site.

The soil chemistry tests confirmed that the berm samples can be used on industrial land as it falls

within the SSV2 limits for all the constituents according to South African SSV2 standards. The soil

material from the berm is corrosive towards to metals and aggressive (moderate to high) towards

concrete and fibre cement pipes. The Plasticity Index (PI), the California Bearing Ratio (CBR) test

(measurement of resistance of a material to penetration) and linear shrinkage values indicates that

the soil from the berm is not adequate for use as material for structural layers in terrace construction

unless the material is treated with lime or cement to lower the PI. Without treatment, the soil from the

berm can only be of used for bulk fill in embankment construction (SRK, 2019).

During the construction phase, the potential negative impacts on the Geotechnical environment are

expected to be of very low (-) to very medium high (-) significance. Following the implementation of

appropriate mitigation measures all of the identified impacts can be reduced to very low (-) significance.

The cumulative impact on the geotechnical environment during the construction phase of the CF 2


10.2.9 Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated soil and

building material for the construction of the TAME, creosote diesel and CTN tanks may potentially

have an impact on topography.

During the construction phase, the impact on topography have been calculated to be of low (-)

significance and can be mitigated to be of very low (-) significance.

The cumulative impact on topography of CF 2 proposed Tanks Expansion Project during the

construction phase will be negligible.

10.2.10 Cultural and Heritage

As a result of excavations pertaining to the construction activities of the CF 2 proposed Tanks

Expansion Project there remains a chance that there may be cultural and heritage resources in the

area that have not been identified yet.

The impacts on cultural and heritage resources during the construction phase were classified as very

low (-) with and without the implementation of mitigation measures.

The cumulative impact on areas of archaeological importance during the construction phase of the CF

2 proposed Tanks Expansion Project is expected to be negligible.



10.2.11 Biodiversity


Operations Tank Farm area and will therefore not have significant additional impacts on biodiversity

in the area.

The project may result in the following impacts on the floral environment during the construction phase:

• Loss of vegetation species including vegetation species of conversational concern due to site

clearance;

• Direct loss of habitat and indirect loss of habitat quality;

• Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer

alien species are provided with a chance to flourish; and

• Generation of waste and incorrect disposal from construction material leading to disturbance of

natural vegetation.

The project may result in the following impacts on the faunal environment during the construction

phase:

• Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species,

erosion, and general construction activities;

• Loss of faunal diversity and ecological integrity as a result of construction activities, erosion,

poaching and faunal species trapping; and

• Impact on faunal species of conservational concern due to habitat loss and collision with

construction vehicles.

The significance of the biodiversity impacts will be of low (-) to very low (-) significance (without the

implementation of mitigation measures). The significance of the impacts can be further reduced to

very low (-) when the mitigation measures have been implemented.

The cumulative impact on biodiversity during the construction phase of the CF 2 proposed Tanks


10.2.12 Visual

The following potential impacts on the visual character of the area as a result of the proposed project

are envisaged during the construction phase:

• Visual intrusion as a result of the movement of machinery; and

• Indirect visual impact due to dust generation, as a result of the movement of vehicles and

materials, to and from the site area.

As the CF 2 proposed Tanks Expansion Project will be located within the existing Sasol Synfuels

Operations Tank Farm area , the significance of the visual impacts will be of very low (-) significance

(before and after the implementation of mitigation measures).

The cumulative visual impact during the construction phase of the CF 2 proposed Tanks Expansion

Project will be negligible.

10.2.13 Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and

machinery related to the additional activities taking place within the immediate surroundings may

occur.




Operations Tank Farm area , the significance of the noise impacts will be of very low (-) significance


The cumulative impact on noise during the construction phase of the CF 2 proposed Tanks Expansion


10.2.14 Traffic

Most of the traffic will be associated with the daily transportation of construction workers through public

roads to site. Therefore, limited impact on public traffic is expected.

The significance of the impacts on traffic was classified as very low (-) significance, with and without

mitigation

The cumulative impact on traffic during the construction phase of the CF 2 proposed Tanks Expansion


10.2.15 Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste

disposal (general and hazardous), and housekeeping on the construction site requiring care and

attention. The construction of the CF 2 proposed Tanks Expansion Project may result in the increase

of waste which will be landfilled. This may have a negative impact on the environment if not correctly

managed. It is anticipated that minimal waste will be generated during the construction phase. Waste

generated will be directly related to the day to day activities of the construction sites, offices and

laydown areas, and off cuts from building material. Small amounts of hydrocarbon contaminated

waste, redundant equipment, paint, and insulation may be generated.

The significance of the impacts associated with improper waste management will be of low (-)

significance (without the implementation of mitigation measures). The significance of the impacts can

be further reduced to very low (-) when the mitigation measures have been implemented.

The cumulative impact associated with waste management during the construction phase of the CF 2


Table 10-1 provides a detailed impact assessment of the impacts identified during the construction

phase as per the methodology described in Section 9.



Table 10-1: Impact assessment of the identified impacts arising during the pre-construction and construction phase

ASPECT POTENTIAL ENVIRONMENTAL IMPACT (NATURE OF THE IMPACT)

ENVIRONMENTAL SIGNIFICANCE BEFORE MITIGATION

ENVIRONMENTAL SIGNIFICANCE AFTER MITIGATION

Consequence Likelihood (Probability)

Significance (Degree to

which impact may

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Social-economic National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy

4 5 5 5 5 140 Very High (+) 4 5 5 5 5 140 Very High (-)

Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations

4 4 4 5 5 120 High (+) 4 4 4 5 5 120 High (+)


4 4 4 5 5 120 High (+) 4 4 4 5 5 120 High (+)

Possible boost in short term employment and local small business opportunities

1 1 2 3 5 32 Low (-) 1 1 2 3 5 32 Low (-)

Generation of dust potentially resulting in a health and nuisance impact

3 2 2 2 3 35 Low (-) 2 2 2 2 2 24 Very Low (-)

Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly, as well as other construction activities

4 2 2 5 1 48 Low (-) 3 1 1 5 1 30 Low (-)

Clearing of land which may potentially impact on the sense of place

2 1 3 1 2 18 Very Low (-) 1 1 3 1 2 15 Very Low (-)

Possible impact on service provision as a result of construction of temporary ablution facilities, storage areas, and site establishment

2 3 3 2 2 32 Low (-) 1 1 3 1 2 15 Very Low (-)

Potential squatting of job seekers 2 1 3 1 2 18 Very Low (-) 1 1 3 1 2 15 Very Low (-)


Potential deterioration in water quality as a result of accidental spillages of hazardous substances such as hydrocarbons from construction vehicles and machinery

2 3 3 2 2 32 Low (-) 2 2 2 2 2 24 Very Low (-)

Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality

2 3 2 3 2 35 Low (-) 2 2 2 2 2 24 Very Low (-)








which impact may

cause irreplaceable

loss of resources)

SRK Methodology





resources)

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Debris from poor handling of materials and/or waste blocking watercourses may result in flow impediment and pollution

2 2 2 2 2 24 Very Low (-) 2 2 2 1 2 18 Very Low (-)

Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the construction footprint area.

2 3 2 3 2 35 Low (-) 2 2 2 2 2 24 Very Low (-)

Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources

2 3 2 2 2 28 Low (-) 2 2 2 2 2 24 Very Low (-)

Debris from poor handling of materials and/or waste blocking watercourses nay result in flow impediment and pollution

2 3 2 2 2 28 Low (-) 2 2 2 1 2 18 Very Low (-)

Increase of surface runoff and potentially contaminated water that needs to be maintained in the areas where site clearing occurred

2 3 2 2 2 28 Low (-) 2 2 2 1 2 18 Very Low (-)

Groundwater Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination

2 3 3 2 2 32 Low (-) 2 2 1 2 2 20 Very Low (-)

Improper storage and handling of hazardous materials leading to groundwater contamination

2 3 3 2 2 32 Low (-) 2 2 1 2 2 20 Very Low (-)








which impact may

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SRK Methodology





resources)

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Potential impacts on wetlands and aquatic ecosystems including: Localised changes to the riparian areas as a result of vegetation clearing; Sedimentation of riparian resources leading to smothering of wetland and aquatic flora; Loss of habitat and riparian zone ecological structure as a result of site clearance activities and uncontrolled riparian zone degradation; Deterioration of wetland water quality due to accidental spillages of hydrocarbons and poor waste management; Impact on the riparian systems as a result of changes to the sociocultural service provision of wetlands; Increased runoff due to topsoil removal and vegetation clearance leading to possible erosion and sedimentation of riparian resources; Uncontrolled movement of vehicles and construction personnel may result in soil compaction and levelling as well as loss of riparian habitat.

2 2 2 2 2 24 Very Low (-) 2 2 2 2 2 24 Very Low (-)

Air Quality Dust generating activities associated with the construction phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.

1 1 2 2 1 12 Very Low (-) 1 1 1 2 1 9 Very Low (-)

Climate change Emissions of Green House Gases as a result of the use of construction vehicles and machinery.

2 2 2 2 2 24 Very Low (-) 2 2 2 2 1 18 Very Low (-)

Overall climatic benefits as a result of the production and utilisation of fuels meeting more stringent specifications (cleaner fuels)

4 5 5 5 5 140 Very High (+) 4 5 5 5 5 140 Very High (+)








which impact may

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SRK Methodology





resources)

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Soils Land Capability and Land Use impacts

Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil

3 2 2 2 2 28 Low (-) 2 2 2 2 1 18 Very Low (-)

Clearing of vegetation outside of the Tank Farm footprint area

3 2 2 2 2 28 Low (-) 2 2 2 2 1 18 Very Low (-)

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials

3 2 3 4 4 64 Medium Low (-)

2 2 2 2 3 30 Low (-)

Potential compaction and erosion of soils removed and stockpiled during excavation activities

3 2 3 3 3 48 Low (-) 2 2 2 2 1 18 Very Low (-)


Potential geotechnical constraints impacting on engineering design of access roads and foundations as a result of collapsible and compressible soil.

4 3 4 4 4 88 Medium High (-)

3 2 1 2 2 24 Very Low (-)

Potential degradation of geo-sites. 4 1 5 1 1 20 Very Low (-) 4 1 5 1 1 20 Very Low (-)

Potential degradation of bedrock and topography as a result of excavations for foundations, pipelines, tanks and other associated infrastructure.

2 3 2 2 3 35 Low (-) 1 1 2 2 2 16 Very Low (-)

Potential safety risk as a result of inappropriate founding methods.

5 3 4 4 4 96 Medium High (-)

3 2 1 2 2 24 Very Low (-)

Potential groundwater, surface and soil contamination as a result of: • High settlements of structures if soils have a low in situ bearing capacity if not compacted or engineered properly; • Using contaminated material as bulk fill in material; • Ground distortion (settlement) caused by construction activities (earthworks,

4 3 4 4 4 88 Medium High (-)

2 2 1 2 2 20 Very Low (-)








which impact may

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SRK Methodology





resources)

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retaining structures etc.); and • Change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level.

Topography Temporary disturbance and alteration of ground level as a result of stockpiling of excavated soil and building material for the construction of the Tertiary Amyl Methyl Ether (TAME), creosote diesel and Cold Tar Naphtha / Benzene (CTN) tanks

2 3 2 2 3 35 Low (-) 1 1 2 2 2 16 Very Low (-)



2 1 2 2 1 15 Very Low (-) 2 1 2 1 1 10 Very Low (-)

Flora Loss of vegetation species including vegetation species of conversational concern due to site clearance

3 2 2 2 3 35 Low (-) 2 2 2 2 1 18 Very Low (-)

Direct loss of habitat and indirect loss of habitat quality

3 2 2 2 3 35 Low (-) 2 2 2 2 1 18 Very Low (-)


3 3 2 2 2 32 Low (-) 2 2 2 2 2 24 Very Low (-)

Generation of waste and incorrect disposal from construction material leading to disturbance of natural vegetation.

3 3 2 2 2 32 Low (-) 2 2 2 2 2 24 Very Low (-)

Fauna Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general construction activities

2 3 2 2 2 28 Low (-) 2 2 2 2 2 24 Very Low (-)








which impact may

cause irreplaceable

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SRK Methodology





resources)

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Loss of faunal diversity and ecological integrity as a result of construction activities, erosion, poaching and faunal species trapping

3 2 2 2 2 28 Low (-) 3 2 2 2 1 21 Very Low (-)


2 2 2 2 2 24 Very Low (-) 2 2 2 2 1 18 Very Low (-)

Visual Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure

2 1 2 2 2 20 Very Low (-) 1 1 2 2 1 12 Very Low (-)

Indirect visual impact due to dust generation as a result of the movement of vehicles and materials, to and from the site area

2 1 2 2 2 20 Very Low (-) 1 1 2 2 1 12 Very Low (-)

Noise Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings

2 2 2 2 2 24 Very Low (-) 2 1 2 2 2 20 Very Low (-)

Traffic Increase in traffic volumes as a result of construction activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.

2 2 2 2 2 24 Very Low (-) 2 1 2 2 2 20 Very Low (-)

Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the construction site

2 2 2 2 3 30 Low (-) 1 1 2 2 2 16 Very Low (-)



10.3 Operation Phase

The CF 2 proposed Tanks Expansion Project will be an extension to the existing Sasol Synfuels

Operations, specifically the Tank Farm Area.

The activities associated with the operational phase of the CF 2 Expansion Project includes, but is not

limited to:

• Transfer and storage of Creosote diesel produced in Unit 28 (located within the Sasol Synfuels

Operations) to new creosote diesel storage tanks;

• Transfer and storage of CTN produced in Unit 015 (located within the Sasol Synfuels Operations)

to new CTN storage tank;

• Transfer and storage of TAME produced in Unit 79 (located within the Sasol Synfuels Operations)

to new TAME storage tanks;

• Feeding of existing TAME tanks with TAME from the new TAME storage tanks during shutdown;

• Transfer and storage of MFO produced in unit 35 (located within the Sasol Synfuels Operations)

to the new storage tanks;

• Exporting of MFO via road loading facilities;

• Importing of additional EHN (used as a Cetane Enhancer in Diesel Blending) by truck;

• Transfer and storage of EHN in new EHN storage tanks;

• Transfer of EHN to new EHN Diesel Blending Pumps to existing Diesel Blender where EHN is

blended into the diesel pool as required using flow control. The final product is then routed to the

final product tanks using existing infrastructure;

• Maintenance of all tanks, pipelines, bunded areas and other associated infrastructure.

Environmental impacts on the biophysical and socio-economic environment, which could potentially

occur throughout the operational phase, are described in the following sections.

10.3.1 Socio – Economic Impacts

The construction and operation of the CF 2 proposed Tanks Expansion Project will result in the

continued operation of the Sasol Synfuels Operations. There are therefore regional economic benefits

as a result of the on-going operation of the Sasol Synfuels Operations (High (+)).

The operational phase of the CF 2 proposed Tanks Expansion Project could potentially result in the

following negative socio-economic impacts:

• Impact on safety. The operation and use of Tank Farm pose a number of hazards. The products

are highly flammable. The products may pose a hazard to the personnel working in the vicinity

and adjacent infrastructure. This impact may occur as a result of loss of containment or leaks in

the transportation or storage infrastructure; and

• The generation of dust and other gaseous emissions i.e. VOCs resulting in a health and nuisance

impact.

The significance of the negative socio-economic impacts associated with the CF 2 proposed Tanks

Expansion Project will be of high (-) to medium-low (-) significance (without the implementation of

mitigation measures). The significance of the impacts can be further reduced to between low (-) and




The cumulative impact on the socio-economic environment during the operational phase of the CF 2



The potential impacts on surface water during the operational phase of the proposed project are as

follows:

• Contamination of runoff by poor materials/waste handling practices, including accidental spillages

of hazardous substances from vehicles/pipelines/tanks etc.;

• Runoff containing suspended solids, sediments and fuel residue may contaminate surface water

resources.

It is expected that without the implementation of mitigation measures, the impacts on the hydrology

will be of medium-low (-) significance, which can be reduced to low (-) significance with the

implementation of mitigation measures.

10.3.3 Groundwater

As mentioned previously, the CF 2 proposed Tanks Expansion Project will be located within the

existing Sasol Synfuels Operations Tank Farm. Further, a 5 km exclusion zone has been established

in terms of groundwater abstractive use around the Sasol Synfuels Operations. Consequently, there

are no direct users of groundwater in and around the CF 2 proposed Tanks Expansion Project. The

existing Tank Farm is provided with hard-standing and containment facilities for spillages and leaks.

Similarly, the Sasol Synfuels Operations is provided with comprehensive clean and dirty water

drainage and containment systems to minimise risk of release to the groundwater environment.



• The use of vehicles delivering and transporting chemicals on site poses the risk of chemical


• Contamination of soil and groundwater and possibly bedrock as a result of overspills from the

storage tanks;

• Leakage of hazardous materials from the transportation pipelines etc.;





The cumulative impact on groundwater during the operational phase of the CF 2 proposed Tanks


10.3.4 Wetlands

No impact on wetlands are expected as:

• The tanks will be located within the existing bunded area;

• Tanks will for part of the existing statutory maintenance schedule; and

• A leak detection system will be installed.



10.3.5 Air Quality

Gaseous emissions i.e. VOCs will arise from the tanks within the project area. These pollutant

emissions from the project will occur during operations. The generation of gaseous pollutants has the

potential to impact on the health of adjacent communities. Considering the scale of the proposed Tank

Farm, the emissions from the project are expected to be low to negligible.

The topography as well as climatic conditions will provide for adequate dispersion of the pollutants in

the environment. Based on the dispersion modelling results for the tanks, emissions from this source

are expected to be low to negligible and will decrease with distance away from the sources. The

significance of the impact, with management measures, is considered very low (-) as the predicted

concentrations at the sensitive receptors will be unlikely to impact them, with mitigation measures in

place, due to the distance between the Tank Farm and the receptors.

The cumulative impact on air quality during the operational phase of the CF 2 proposed Tanks Expansion Project will be negligible.

10.3.6 Climate Change

The movement of vehicles may also result in the production of carbon dioxide (Green House Gas),

which may have an impact on the climate in the area. The impact on climate change was calculated

to be of very low (-) significance.

The cumulative impact on climate change during the operational phase of the CF 2 proposed Tanks Expansion Project will be negligible.

Although, the impact on climate change as a result of activities directly associated with the operation

of the CF 2 proposed Tanks Expansion Project will be of very low (-) significance, there are however

overall climatic benefits as a result of the production and utilization of fuel that will meet the new more

stringent requirements (cleaner fuels) (Very High (+)).



Operations Tank Farm area, which is provided with comprehensive clean and dirty water drainage and

containment systems to minimise risk of release to the soils environment.

Potential for impacts on soil, land use and land capability include:

• The use of vehicles delivering and transporting chemicals on site poses the risk of chemical


• Contamination of soil as a result of overspills from the storage tanks;

• Leakage of hazardous materials from the transportation pipelines etc.;

• Potential hydrocarbon spillages resulting from a leakage caused by a fracture/crack/corrosion or

rupture in the fuel storage tanks;


During the operational phase, the impacts on soils, land use and land capability have been calculated to be of medium-high (-) to medium-low (-) significance and can be mitigated to be of very low (-) significance.

The cumulative impact on soils of CF 2 proposed Tanks Expansion Project during the operational phase will be negligible.




Please refer to Appendix H for a copy of the Geotechnical Environmental Impact Assessment.

Permanent operational impacts may occur as a result of general day to day operation of the tank farm

impacting on soil and water resources. The following potential impacts have been identified as a result

of the Operational Phase:

• Potential groundwater, surface water and soil contamination as a result of change of groundwater

conditions, flow of groundwater, lowering (or rise) of groundwater level;

• Potential groundwater, surface water and soil contamination as a result of infrastructure failure

due to:

• Seismic activities;

• The formation of sinkholes or subsidence caused by the presence of water-soluble rocks

(dolomite or limestone);

• Potential groundwater, surface water and soil contamination as a result of infrastructure failure

due to differential settlement as a result of foundations placed across different soil types or rock

which may settle differently.

No dolomite or limestone occur within the tank farm area and therefore it is not expected that

subsidence as a result of the presence of water-soluble rocks will occur. It is further not anticipated

that seismic activities will have an impact on the tank farm area.

During the operational phase, the potential negative impacts on the Geotechnical environment are

expected to be of very low (-) to low (-) significance. Following the implementation of appropriate

mitigation measures all of the identified impacts can be reduced to very low (-) significance.

The cumulative impact on the geotechnical environment during the operational phase of the CF 2


10.3.9 Topography

Although the immediate topography of the areas will be altered as a result of excavation activities and

the erection of the tanks, it will still be aligned with the current land uses around the site. This impact

is of very low (-) significance.


operational phase will be negligible.


Although it is not expected that any resources of cultural and heritage importance will be affected

during the operational phase of the CF 2 proposed Tanks Expansion Project, there remains a

possibility that there may be some resources left that may be affected. The impact on cultural and

heritage resources is of very low (-) significance during the operational phase.


operational phase will be negligible.


The project may result in the following impacts on the floral environment during the operational phase:

• Uncontrolled movement of vehicles outside the designated access roads may result in the

destruction of potential floral habitats for species of conservational concern; and



• Failure to initiate an alien species control plan during the construction phase may lead to further

impacts during the operation phase.

The project may result in the following potential impacts on the faunal environment during the

construction phase:

• Uncontrolled movement of vehicles may lead to loss of faunal habitat and ecological structure;

• Loss of faunal species due to collisions with vehicles transporting the materials to the site; and

• Failure to initiate an alien species control plan during the construction phase may lead to further

impacts on faunal habitat during the operation phase.

The loss of biodiversity during the operational phase is expected be of short duration and has been

classified as low (-) significance, which can be mitigated to very low (-) significance.

10.3.12 Visual

The following potential impacts on the visual character of the area as a result of the proposed project

are envisaged during the operational phase:

• Visual intrusion as a result of the movement of vehicles; and






The cumulative visual impact during the operational phase of the CF 2 proposed Tanks Expansion


10.3.13 Noise

Localized and temporary increase in noise levels due to the presence of delivery/transporting vehicles

in the immediate surroundings may be experienced. The significance of the noise impacts will be of

low (-) significance and can be mitigated to very low (-) significance.

The cumulative noise impact during the operational phase of the CF 2 proposed Tanks Expansion


10.3.14 Traffic

Localized and temporary increase in traffic volumes due to the presence of delivery/transporting

vehicles in the immediate surroundings may be experienced. The significance of the traffic impacts

will be of very low (-) significance.

The cumulative traffic impact during the operational phase of the CF 2 proposed Tanks Expansion



Waste will be generated, in small quantities, during the operational phase of the CF 2 Tank Expansion

Project. Waste will typically consist of hydrocarbon contaminated material generated during

maintenance, redundant equipment, waste water generated from cleaning activities as well as from

operation of the Tank Farm which will link into the dirty water management system.



Poor waste management may result in the contamination of surface runoff resulting in the

deterioration of water quality of the water resources and soil. The significance of improper waste

management will be of medium low (-) significance and can be mitigated to very low (-) significance.

Table 10-2 provides a detailed impact assessment of the potential impacts identified during the

operational phase as per the methodology described in Section 9.



Table 10-2: Impact assessment of the identified impacts arising during the operational phase






which impact may

cause irreplaceable

loss of resources)

SRK Methodology


Significance (Degree to which

impact may cause


resources)

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act

Socio-Economic National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy

4 5 5 5 5 140 Very High (+) 4 5 5 5 5 140 Very High (+)

Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations

4 4 4 5 5 120 High (+) 4 4 4 5 5 120 High (+)


4 4 4 5 5 120 High (+) 4 4 4 5 5 120 High (+)

The operation and use of the tank farm poses several safety hazards. The stored product is highly flammable

5 4 4 5 3 104 High (-) 5 2 2 2 2 36 Low (-)

Risk to the safety of surrounding amenities due to the explosion risk of the stored flammable products

3 4 4 5 3 88 Medium High (-)

2 2 2 2 2 24 Very Low (-)

The generation of dust and other gaseous emissions i.e. VOCs resulting in a health and nuisance impact

3 3 4 3 3 60 Medium Low (-)

2 2 2 2 2 24 Very Low (-)

Surface water Contamination of runoff by poor materials/waste handling practices, including accidental spillages of hazardous substances from vehicles/pipelines/tanks etc.

2 3 3 3 3 48 Low (-) 2 1 2 2 2 20 Very Low (-)

Uncontrolled runoff containing suspended solids, sediments and fuel residue may contaminate surface water resources

3 3 3 3 3 54 Medium Low (-)

2 1 2 2 2 20 Very Low (-)

Groundwater The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils

3 3 3 4 4 72 Medium Low (-)

2 2 1 2 2 20 Very Low (-)








which impact may

cause irreplaceable

loss of resources)

SRK Methodology



impact may cause


resources)

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Contamination of soil and groundwater and possibly bedrock as a result of overspills from the storage tanks

4 3 3 4 4 80 Medium High (-)

3 2 1 2 2 24 Very Low (-)


4 3 3 4 4 80 Medium High (-)

3 2 1 2 2 24 Very Low (-)

Improper storage and handling of hazardous materials

3 3 3 4 4 72 Medium Low (-)

2 2 1 2 2 20 Very Low (-)



2 2 2 2 2 24 Very Low (-) 2 2 2 2 2 24 Very Low (-)

Air Quality Gaseous emissions i.e. VOCs will arise from the tanks within the project area.

1 1 2 2 1 12 Very Low (-) 1 1 1 2 1 9 Very Low (-)


2 2 2 2 2 24 Very Low (-) 2 2 2 2 1 18 Very Low (-)








which impact may

cause irreplaceable

loss of resources)

SRK Methodology



impact may cause


resources)

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Soils The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils

3 3 3 4 4 72 Medium Low (-)

2 2 1 2 2 20 Very Low (-)

Contamination of soil as a result of overspills from the storage tanks

4 3 3 4 4 80 Medium High (-)

3 2 1 2 2 24 Very Low (-)


4 3 3 4 4 80 Medium High (-)

3 2 1 2 2 24 Very Low (-)

Potential hydrocarbon spillages resulting from a leakage caused by a fracture/crack/corrosion or rupture in the fuel storage tanks may lead to contamination of the soil in and around the site area

4 3 3 4 4 80 Medium High (-)

2 2 2 1 1 12 Very Low (-)

Improper storage and handling of hazardous materials

3 3 3 4 4 72 Medium Low (-)

2 2 1 2 2 20 Very Low (-)


Potential groundwater, surface water and soil contamination as a result of change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level

3 3 2 2 3 40 Low (-) 2 2 1 2 2 20 Very Low (-)

Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to: • Seismic activities; and • The formation of sinkholes or subsidence caused by the presence of water-soluble rocks (dolomite or limestone).

3 3 1 1 1 14 Very Low (-) 3 3 1 1 1 14 Very Low (-)

Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to differential settlement as a result of foundations placed across different soil types or rock which may settle differently.

3 3 2 2 3 40 Low (-) 2 2 1 2 2 20 Very Low (-)








which impact may

cause irreplaceable

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SRK Methodology



impact may cause


resources)

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Topography Permanent altering of the ground level due to excavation activities and tank erection

1 1 2 2 2 16 Very Low (-) 1 1 2 2 2 16 Very Low (-)


Although no additional resources of cultural and/or heritage importance that be affected by the project, a possibility remains that there may be some resources that may be affected.

2 1 2 2 1 15 Very Low (-) 2 1 2 1 1 10 Very Low (-)

Flora Uncontrolled movement of vehicles outside the designated access roads may result in the destruction of potential floral habitats for species of conservational concern

3 2 2 2 3 35 Low (-) 2 2 2 2 1 18 Very Low (-)

Failure to initiate an alien species control plan during the construction phase may lead to further impacts during the operation phase

3 3 2 2 2 32 Low (-) 2 2 2 2 2 24 Very Low (-)

Fauna Uncontrolled movement of vehicles may lead to loss of faunal habitat and ecological structure

2 3 2 2 2 28 Low (-) 2 2 2 2 2 24 Very Low (-)

Loss of faunal species due to collisions with vehicles transporting the materials to the site

3 3 2 2 2 32 Low (-) 2 2 2 2 2 24 Very Low (-)

Failure to initiate an alien species control plan during the construction phase may lead to further impacts on faunal habitat during the operation phase

3 2 2 2 2 28 Low (-) 3 2 2 2 1 21 Very Low (-)

Visual Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure.

1 1 2 2 2 16 Very Low (-) 1 1 2 2 1 12 Very Low (-)


1 1 2 2 2 16 Very Low (-) 1 1 2 2 1 12 Very Low (-)








which impact may

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impact may cause


resources)

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Noise Localized and temporary increase in noise levels due to the presence of delivery/transporting vehicles in the immediate surroundings

2 1 4 4 2 42 Low (-) 1 1 2 2 2 16 Very Low (-)

Traffic Increase in traffic volumes as a result of delivery which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.

1 2 2 2 2 20 Very Low (-) 1 1 2 2 2 16 Very Low (-)

Waste Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the operational site.

3 3 3 3 3 54 Medium Low (-)

2 1 2 2 2 20 Very Low (-)



10.4 Decommissioning Phase

At this point in time, during the BAP, the planning and timing for decommissioning of the CF 2 proposed

Tanks Expansion Project is not known. It is likely that the infrastructure associated with the expansion

project will only be decommissioned as part of the closure process of the Sasol Synfuels Operations

as a whole. All appropriate legal procedures will be followed, which may include the need to apply for

a separate EA in terms of GNR 982 published in terms of the NEMA. The following potential

environmental impacts are anticipated during the decommissioning phase which coincide with the

construction phase.

Decommissioning activities will include, but are not limited to the following:

• Contractors site establishment;

• Disconnection of potable water supply;

• Disconnection of pipeline tie-ins to existing pipelines;

• Removal of fencing;

• Removal/dismantling of tanks, pump bays, new pipeline routes, tie-ins to existing pipelines and

associated infrastructure;

• Removal of piling, bunding and tank foundations;

• Removal/dismantling of steelwork;

• Rehabilitation of disturbed areas after general site decommissioning is completed.

Environmental impacts on the biophysical and socio-economic environment, which could potentially

occur throughout the decommissioning phase of the CF 2 proposed Tanks Expansion Project, if

viewed in isolation, are described in the following sections.

10.4.1 Socio Economic

Due to the fact that during decommissioning and closure there will be limited to no additional

employment opportunities that will be attributed to the CF 2 Expansion Project, it is expected that the

positive impacts (creation of employment) are also expected to be of low (+) significance.

The potential negative socio-economic impacts associated with the decommissioning and closure of

the CF 2 Expansion project are as follows:

• Generation of dust potentially resulting in a health and nuisance impact;

• Impact on safety and security as a result of theft, the occurrence of additional trucks on the roads,

uncontrolled lighting of fires on site, littering and driving irresponsibly;

• Health and safety risk as a result of the movement of vehicles increasing the risk of accidents;

• Clearing of land which may potentially impact on the sense of place; and

• Squatting of job seekers.

During the decommissioning and closure phase, the potential negative impacts on the socio-economic

environment are expected to be of low (-) to very low (-) significance after the implementation of

mitigation measures.

The cumulative impact on the socio-economic environment during the decommissioning and closure

phase of the CF 2 Expansion Project will be negligible.




The possible potential impacts on surface water during the decommissioning and closure of the CF 2

Expansion Project are as follows:

• Accidental spillages of hazardous substances from construction vehicles used during

decommissioning, as well as from hazardous storage areas;

• Contamination of runoff by poor materials/waste handling practices;

• Debris from poor handling of materials and/or poor waste management practises;

• Contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water

quality; and

• Increase of surface runoff and potentially contaminated water that needs to be controlled in the

areas where site clearing occurred.

It is expected that without the implementation of mitigation measures, the impacts on the hydrology



The cumulative impact on surface water during the decommissioning and closure of CF 2 Expansion


10.4.3 Groundwater

The CF 2 Expansion Project will be located within the Sasol Synfuels Operations footprint area. It is

noted that a 5 km exclusion zone has been established in terms of groundwater abstractive use around

the Sasol Synfuels Operations. Consequently, there are no direct users of groundwater in and around

the CF 2 proposed Tanks Expansion Project. The existing Tank Farm is provided with hard-standing

and containment facilities for spillages and leaks. Similarly, the Sasol Synfuels Operations is provided

with comprehensive clean and dirty water drainage and containment systems to minimise risk of

release to the groundwater environment.



• The use of earth moving machinery and vehicles on site poses the risk of chemical spillages

including fuel and oils;





The cumulative impact on groundwater during the decommissioning and closure phase of the CF 2


10.4.4 Wetlands

One tank of the Sasol Synfuels Operations CF 2 Tank Expansion project will be located at a distance

of approximately 450 metres from the delineated boundary of the Klipspruit wetland system. Due to

the nature and location of the activity, as well as the distance from the Klipspruit wetland system, the

potential impacts on the water quality, flow, habitat, biota and geomorphology characteristics of the

watercourse during either the construction or operational phases were deemed negligible.



It is therefore unlikely that any water use authorisation will be required for the decommissioning of the

CF 2 Expansion Project as:

• Decommissioning activities will be done in an already impacted area where excavations and

compacting were done previously;

• The tanks will be located within the existing bunded area.

The potential impact associated with the CF 2 proposed Tanks Expansion Project during the

decommissioning and closure phase on wetland areas will therefore be negligible. Further, the

cumulative impact on wetlands during this phase will be negligible.

10.4.5 Air Quality and Climate Change

The movement of vehicles and earth moving machinery will likely result in an increase in nuisance

dust, PM10 and PM2.5. There is also potential for increase in carbon emissions and ambient air pollution

due to the movement of vehicles and machinery. It is expected that the implementation of dust

suppressing mitigation measures will result in the reduction in nuisance dust.

The impacts on air quality is calculated to be of medium-low (-) significance and can be reduced to

low (-) significance when the mitigation measures have been implemented.

The movement of vehicles and earth moving machinery may result in the production of carbon dioxide

(Green House Gas), which may have an impact on the climate in the area. The impact on climate

change was calculated to be of very low (-) significance and can be mitigated to very low (-)

significance.

The cumulative impact on air quality and climate change during the decommissioning and closure of

the CF 2 Expansion Project will be negligible.


Prior to the construction of the CF 2 Expansion project, the area formed part of the Sasol Synfuels

Operations Tank Farm. Decommissioning and closure of the CF 2 Project may result in the following

impacts on soil potential:

• Localized and temporary contamination of soil resources as a result of incorrect

storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous

substances/materials used during the decommissioning of the CF 2 Tank Expansion Project. This

impact is considered likely but insignificant in nature;

• Erosion and disturbance of the soil profile as a result of turning of ground during the

decommissioning phase; and

• Pollution of soil resources as a result of incorrect/no remediation of contaminated soil.

Following decommissioning activities, the land will be rehabilitated to present the pre-land use

condition as far as feasible, taking in consideration that it is likely that the CF 2 Expansion Project will

probably be decommissioned as part of the larger complex. This will allow for the re-investigation into

alternative land uses which may finally alter the land capability.


Please refer to Appendix H for a copy of the Geotechnical Environmental Impact Assessment.

Similar potential environmental impacts are anticipated during the decommissioning and closure

phase with regards to waste management, surface/groundwater contamination and soil degradation.



Very little additional geotechnical environmental impacts in the decommissioning and closure phases

are expected.

10.4.8 Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated materials,

structures and building material from the decommissioning of the CF 2 Expansion Project may

potentially have an impact on topography.

During the decommissioning and closure phase, the impact on topography have been calculated to

be of low (-) significance and can be mitigated to be of very low (-) significance.


decommissioning and closure phase will be negligible.


As a result of excavations/removal of infrastructure pertaining to the decommissioning and closure

activities of the CF 2 proposed Tanks Expansion Project there remains a chance that there may be

cultural and heritage resources in the area that have not been identified yet.

The impacts on cultural and heritage resources during the decommissioning and closure phase were

classified as very low (-) with and without the implementation of mitigation measures.

The cumulative impact on areas of archaeological importance during the decommissioning and closure

phase of the CF 2 proposed Tanks Expansion Project is expected to be negligible.



Operations Tank Farm area and will therefore not have significant additional impacts on biodiversity

in the area.

The project may result in the following impacts on the floral environment during the decommissioning

and closure phase:

• Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer

alien species are provided with a chance to flourish; and

• Generation of waste and incorrect disposal from decommissioned material leading to disturbance

of natural vegetation.

The project may result in the following impacts on the faunal environment during the construction

phase:

• Loss of faunal habitat and ecological structure as a result of alien invasive species, erosion, and

general decommissioning activities;

• Loss of faunal diversity and ecological integrity as a result of decommissioning activities, erosion,

poaching and faunal species trapping; and

• Impact on faunal species of conservational concern due to habitat loss and collision with

construction vehicles.

The significance of the biodiversity impacts will be of low (-) to very low (-) significance (without the

implementation of mitigation measures). The significance of the impacts can be further reduced to




The cumulative impact on biodiversity during the decommissioning and closure phase of the CF 2


10.4.11 Visual

The following potential impacts on the visual character of the area as a result of the decommissioning

of the CF 2 Expansion Project are envisaged:

• Visual intrusion as a result of the movement of machinery and the decommissioning of the required

infrastructure; and






10.4.12 Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and

machinery related to the additional activities taking place within the immediate surroundings may

occur.


Operations Tank Farm area , the significance of the noise impacts will be of very low (-) significance

(before and after the implementation of mitigation measures) during the decommissioning and closure

phase.

The cumulative impact on noise during the decommissioning and closure phase of the CF 2 proposed

Tanks Expansion Project will be negligible.

10.4.13 Traffic

Most of the traffic will be associated with the daily transportation of construction workers through public

roads to site. Therefore, limited impact on public traffic is expected.

The significance of the impacts on traffic was classified as very low (-) significance, with and without

mitigation

The cumulative impact on traffic during the decommissioning and closure phase of the CF 2 proposed

Tanks Expansion Project will be negligible.


Possible impact on the surrounding environment as a result of waste generation, incorrect waste

disposal (general and hazardous), and housekeeping on the site requiring care and attention. The

decommissioning and closure of the CF 2 proposed Tanks Expansion Project may result in the

increase of waste which will be landfilled, if recycling and reuse of functional infrastructure are not

done. This may have a negative impact on the environment if not correctly managed.

Waste generated will be directly related to building material/demolished infrastructure and the day to

day activities of the construction sites, offices and laydown areas, and off cuts from building material.

Small amounts of hydrocarbon contaminated waste, redundant equipment, paint, and insulation may

be generated.



The significance of the impacts associated with improper waste management will be of low (-)

significance (without the implementation of mitigation measures). The significance of the impacts can

be further reduced to very low (-) when the mitigation measures have been implemented.

The cumulative impact associated with waste management during the decommissioning and closure

phase of the CF 2 proposed Tanks Expansion Project will be negligible.



Table 10-3: Impact assessment of the identified impacts arising during the decommissioning phase

ASPECT POTENTIAL ENVIRONMENTAL IMPACT (NATURE OF THE

IMPACT)





impact may cause


resources)

SRK Methodology





resources)

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Social-economic Possible boost in short term employment and local small business opportunities.

1 1 2 3 5 32 L Maintain Current

Management


Management

Generation of dust potentially resulting in a health and nuisance impact


Management

2 2 2 2 2 24 VL Maintain Current

Management

Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly


Management


Management

Clearing of land which may potentially impact on the sense of place


Management


Management

Potential squatting of job seekers 2 1 3 1 2 18 VL Maintain Current

Management


Management




Management


Management

Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality


Management


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IMPACT)





impact may cause


resources)

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resources)

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Debris from poor handling of materials and/or waste blocking watercourses may result in flow impediment and pollution.


Management


Management

Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the footprint area.


Management


Management

Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources


Management


Management

Debris from poor handling of materials and/or waste blocking watercourses nay result in flow impediment and pollution.


Management


Management



Management


Management

Groundwater Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination.


Management


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Improper storage and handling of hazardous materials leading to groundwater contamination


Management


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IMPACT)





impact may cause


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Management


Management

Air Quality Dust generating activities associated with the decommissioning and closure phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.


Management


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IMPACT)





impact may cause


resources)

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resources)

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Management


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Soils Land Capability and

Land Use impacts

Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil


Management


Management

Clearing of vegetation outside of the Tank Farm footprint area


Management


Management

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials

3 2 3 4 4 64 ML Maintain Current

Management


Management

Potential compaction and erosion of soils removed and stockpiled during excavation activities


Management


Management

Loss of topsoil due to erosion of areas exposed following excavation and stockpiling


Management


Management


No additional impacts identified.




IMPACT)





impact may cause


resources)

SRK Methodology





resources)

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Topography Temporary disturbance and alteration of ground level as a result of stockpiling of excavated materials, structures and building material from the decommissioning of the CF 2 Expansion Project


Management


Management




Management


Management

Flora Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer alien species are provided with a chance to flourish.


Management


Management

Generation of waste and incorrect disposal from decommissioning material leading to disturbance of natural vegetation.


Management


Management

Fauna Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general decommissioning activities


Management


Management

Loss of faunal diversity and ecological integrity as a result of decommissioning activities, erosion, poaching and faunal species trapping


Management


Management



Management


Management




IMPACT)





impact may cause


resources)

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resources)

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Visual Visual intrusion as a result of the movement of machinery and the decommissioning of the required infrastructure.


Management


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Management


Management

Noise Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings


Management


Management

Traffic Increase in traffic volumes as a result of decommissioning activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Management


Management

Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the site.


Management


Management



10.5 Cumulative Impacts

Incomparable activities can result in several complex effects on the natural biophysical and social

environment. These impacts are mainly identified as direct and immediate effects on the environment

by a single entity affecting a variable of the environment. These direct impacts have the potential to

combine and interact with other activities, depending on the surrounding environmental state and land

use. These impacts may aggregate or interact with other impacts to cause additional effects, not easily

quantified when assessing an individual entity.

The NEMA, 2014, specifically requires that cumulative impacts be assessed. This section provides a

description and analysis of the potential cumulative effects of the CF 2 proposed Tanks Expansion

Project, and past and present projects hereby considering the effects of any changes on the:

• Biophysical; and

• Socio – Economic conditions.

For the analysis of cumulative effects to be utilised as a useful tool for decision makers and

stakeholders, it must be limited to the effects that can be meaningfully evaluated, rather that expanding

on resources or receptors that are no longer affected by the development or are not of interest to the

stakeholders. Two important aspects require consideration prior to the evaluation of cumulative

effects:

• The determination of an appropriate spatial and temporal boundaries for evaluation of cumulative

effects of the project; and

• The evaluation of relevant projects for consideration in the cumulative effects analysis.

Spatial and temporal boundaries for analysis of cumulative effects are dependent on several factors,

including:

• The size and nature of the project and its potential effects;

• The size, nature and location of past and (known) future projects and activities in the area,

• The aspect of the environment impacted by the cumulative effect; and

• The period of occurrence of effects.

The spatial extent of the cumulative impact analysis is generally aligned with the zone of influence of

the project and other projects in the vicinity. Most impact will be localised; however, others may be

experienced on a regional scale. This is taken into consideration during the assessment of cumulative

impacts.

It is reasonably straightforward to identify significant past and present projects and activities that may

interact with the CF 2 Expansion Project and the bigger Sasol Synfuels Operations development to

produce cumulative impacts, and in many respects, these are considered in the descriptions of the

biophysical and socio- economic baseline.

10.5.1 Hydrological and Surface Water Impacts

The potential groundwater and surface water quality impact associated with the CF 2 proposed Tanks

Expansion Project relates to the potential contamination as a result of mismanagement of materials

stored and leakages from vehicles and machinery. Mitigation measures have been proposed for the

impacts on ground water and surface water contamination. It is expected that with the implementation

of the mitigation measures this impact will be reduced to an acceptable level. The construction and

operation of the CF 2 proposed Tanks Expansion Project contribution to cumulative impact will be

negligible.



10.5.2 Air Quality Impacts

The potential air quality impacts associated with the CF 2 proposed Tanks Expansion Project relate to

the potential generation of PM2.5, PM10 and fugitive dust emissions as a result of site clearance,

vehicular movements, and the emission of pollutants from the tanks during operation.

Mitigation measures have been proposed to mitigate these adverse impacts. It is expected that the

implementation of these mitigation measures will reduce this impact to an acceptable standard.

Mismanagement of dust generation sources at the Sasol Synfuels Operations Tank Farm may lead to

an increase in air quality contamination in the atmosphere surrounding the Sasol Synfuels Operations

but the cumulative impact will be negligible.

10.5.3 Noise Impacts

The potential noise nuisance associated with the CF 2 proposed Tanks Expansion Project relates to

the movement of vehicles and operation of machinery on site. Mitigation measures have been

proposed to avoid and/or reduce the nuisance noise impacts. It is expected that with the

implementation of the mitigation measures this impact will be reduced to an acceptable level.

The majority of the land use in the vicinity of the Sasol Synfuels Operations where the Tank Farm will

be located is mostly industrial and mining in nature, land uses associated with significant nuisance

noise levels. It is not anticipated that the CF 2 proposed Tanks Expansion Project will have a negative

impact on the cumulative noise impact in the area.

Other cumulative impacts have been described as part of the impact assessment discussions provided

under the different phases of the CF 2 proposed Tanks Expansion Project. None of the aspects were

found to have a negative impact on the cumulative impacts associated with the CF 2 proposed Tanks

Expansion Project.



11 Summary of the Findings of the Specialist Studies Taking cognisance of the nature of the CF 2 proposed Tanks Expansion Project, the only specialist

studies that were conducted was an Air Quality and a Geotechnical Assessment, which also included

a site specific soil study and groundwater quality study. The following summarised the findings and

impact management measures identified in the Air Quality Assessment. The Air Quality Assessment

can be found in Appendix H.

11.1 Summary of the Air Quality Assessment

Based on the findings of the assessment, the following were concluded:

• According to the Köppen Climate Classification System, the project area is classified as a sub-

category “Cwb” within the “C” category. The “Cwb” climate type can be classified as mild temperate

with cool dry winters and warm summers;

• The ambient air quality, as indicated through the available monitoring data, is a result of all

activities taking place in and around the Secunda Area in a cumulative context with other industrial

and commercial sources of particulates and gases in and around the area;

• The results of the dispersion modelling assessment indicate that all model-predicted

concentrations for VOCs are unlikely to result in adverse impacts to human health or the

environment. The predicted ambient VOC concentrations, and by extension benzene

concentrations, are negligible and is unlikely to result in a significant change in ambient

concentrations;

• The air dispersion model predicted that the areas affected by the plume are to the northwest and

southeast of the study area. The direction of plume dispersion is primarily influenced by the

predominant wind directions from the northeast and southwest;

• The topography in the area plays a significant role in pollutant dispersion. The operational

infrastructure lies in a fairly flat area which allows for adequate dispersion and dilution of pollutants.

This results in low levels of VOC concentrations from the operational activities. The modelled-

predicted concentrations could also be influenced by the occurrence of adverse meteorological

conditions; and

• Human receptors are present in close proximity to the project area and these include residential

areas, schools, hospitals, shopping malls etc. There are no significant impacts from the operations

on any of these identified sensitive receptors. Modelled VOC concentrations from the operations

are predicted to decrease substantially at distances away from the Sasol Synfuels Operations

Tank Expansion Project.

11.2 Summary of the Geotechnical Assessment

• Samples collected from the berms and the tests pits at the CF 2 Tank farm area have been

compared to the SSVs for industrial land (SSV2). The results indicate that the soil from the berm

is considered uncontaminated and, from a contamination perspective, are suitable for use on

industrial land;

• Poly aromatic hydrocarbon benzo(a)pyrene exceeded the SSV2 limits but only in an isolated area

and was the only occurrence where industrial land SSV2 limits were exceeded. Monitoring of

these constituents must be included in the Sasol Synfuels Operations Water Quality Monitoring

Programme;

• The groundwater level varies considerably across the site;



• Both GRO and DRO were present in the groundwater at the CF 2 tank farm area;

• SRK (2019), found that the calculated settlements exceeds the allowable settlement in some areas and adjusted the design criteria for each of the components accordingly.

• The soil material from the berm is corrosive towards to metals and aggressive (moderate to high)

towards concrete and fibre cement pipes. The PI, the CBR test (measurement of resistance of a

material to penetration) and linear shrinkage values indicates that the soil from the berm is not

adequate for use as material for structural layers in terrace construction unless the material is

treated with lime or cement to lower the PI. Without treatment, the soil from the berm can only be

of used for bulk fill in embankment construction (SRK, 2019);

• With the implementation of an appropriate and effective EMPr, the overall limit can be mitigated

effectively.

12 Opinion and Conditions on Authorisation The implementation of the proposed changes to the existing Sasol Tank Farm will enable Sasol to

meet the legislative requirements for fuel production and ensure alignment with the government

gazetted CF 2 programme. The CF 2 proposed Tanks Expansion Project will be located largely within

the Sasol Synfuels Operations and will therefore not impact on the ecological integrity of the area. A

portion of the TAME, MFO and CNT tanks will require the extension of the existing bunded area, which

will be extended on areas of least concern (Mpumalanga Tourism and Parks Agency, 2014), therefore

will not impact on sensitive areas ((Critical Biodiversity Areas (CBA) or Ecological Support Areas

(ESA)).

The CF 2 proposed Tanks Expansion Project will not impact on any global or international

responsibilities to the environment. Numerous possible impacts have been identified in the impact

assessment (waste generation, spill management etc.) that can be mitigated and managed to an

acceptable level. Considering the environmental context of the surrounding areas, impacts will be of

a low significance. The CF 2 proposed Tanks Expansion Project will not impact on environmental

rights in terms of access to resources, nuisance odour, water quality and quantity, or loss of amenity.

The Govan Mbeki IDP stipulates that the competitive advantage of the manufacturing sector within

Govan Mbeki needs to be expanded through the provision of a Special Economic Zone providing for

the broadening of the economic base through exploiting specific business opportunities with Sasol.

Industrialisation of Govan Mbeki will focus on manufacturing of a number of products from Sasol petro-

chemical activities (Govan Mbeki Municipality, 2018). The CF 2 proposed Tanks Expansion Project is

in line with these initiatives.

The CF 2 proposed Tanks Expansion Project will complement the local socio-economic initiatives

through temporary job creation during the construction phase of the project.

The CF 2 proposed Tanks Expansion Project will not result in significant environmental impacts that

cannot be managed or mitigated. The impacts identified are mainly related to the construction phase,

which are temporary in nature. To ensure sustainable development, it is imperative that the EMPr is

adhered to and management measures implemented during all phases of the project.

The Stakeholder Engagement has been undertaken as per NEMA and the EIA Regulations of 2014

(GNR 982) and it is believed that stakeholders have been provided with sufficient time to raise any

comments or concerns, and those that have been raised will be adequately addressed in the final

BAR. It is the opinion of the EAP that the CF 2 proposed Tanks Expansion Project is the Best Practical

Environmental Option to reach the objectives of the project.



13 Environmental Impact Statement This BAP for the CF 2 proposed Tanks Expansion Project has been undertaken in accordance with

the EIA Regulations amended in 2017 and published in GNR 982 of 4 December 2014 of the NEMA.

This process included the required Stakeholder Engagement Process as stipulated in GNR 982. This

study provides an assessment of the possible positive and negative impacts that may arise from the

CF 2 proposed Tanks Expansion Project. Taking into consideration that the CF 2 proposed Tanks

Expansion Project will be undertaken largely within the existing established Sasol Synfuels

Operations, no material alternatives were assessed.

Where potential biophysical or social impacts have been identified, mitigation and management

measures have been proposed to control and monitor the magnitude of impacts associated with the

various aspects of the CF 2 proposed Tanks Expansion Project.

The findings of the BAP concluded that there are no environmental fatal flaws that could hinder the

construction and subsequent operation of the CF 2 Tank Expansion Project. An EMPr has been

compiled to manage and control activities during the construction and operation phase (Appendix E)

with all the impact having a VERY LOW to LOW significance rating following mitigation and

management measures.

From the findings of this BAP, it is recommended that the EA be granted for the CF 2 proposed Tanks

Expansion Project in adherence to the EMPr as per the project description provided in Section 4.



14 Assumptions, Uncertainties and Gaps in Knowledge All the data and information supplied to SRK is assumed to be accurate and reflective of the current

condition of the affected area. It is assumed that the baseline information scrutinised and used to

explain the environmental profile is accurate.

Sasol Synfuels Operations will comply with all legislation pertaining to the activities of these CF 2

proposed Tanks Expansion Project and that all permits and licenses that may be required will be

identified and applied for prior to commencement of construction activities.

The Stakeholder Engagement Process has been sufficiently effective in identifying the critical issues

needing to be addressed in the EIA/EMPr by the EAP. The Stakeholder Engagement Process has

sought to involve key stakeholders and individual landowners. Wherever possible the information

requested, and comments raised by I&APs has been sufficiently addressed and incorporated into the

BAR for perusal and comment.

SRK assumes that Sasol will implement the measures contained in the EMPr and will adhere to any

monitoring procedures. A monitoring and evaluation system, including auditing, will be established and

operationalized to track the implementation of the EMPr ensuring that management measures are

effective to avoid, minimize and mitigate impacts and that corrective action is being undertaken to

address shortcomings and/or non-conformances.

The Screening phases of this project did not highlight potential issues or concerns. It is assumed that

all comments and concerns received by I&APs have been informed and considered. All key issues

pertaining to the project have been assessed in this draft BAR. Additional issues raised during the

review of the BAR by stakeholders will be addressed and included within the BAR prior to submission

to the MDARDLEA for approval.

Sasol will adopt a process of continual improvement when managing and mitigating negative

environmental impacts arising from the project. The EMPr will be used as the basis of environmental

management and will regularly be improved and refined where applicable to the CF 2 proposed Tanks

Expansion Project.

The EAP does not accept any responsibility in the event that additional information comes to light at a

later stage of the process. All data from unpublished research utilised for the purposed of this project

is valid and accurate. The scope of this investigation is limited to assessing the potential biophysical,

social and cultural impacts associated with the CF 2 Tank Expansion Project.



15 Environmental Objectives of the CF 2 proposed Tanks Expansion Project The key environmental objectives for the CF 2 proposed Tanks Expansion Project are:

• Formalise and disclose the programme for environmental and social management;

• Ensure that appropriate environmental management measures and requirements are

implemented from the start of the project;

• Ensure compliance to environmental legislation and guidelines which may be local, provincial

and/or national;

• Ensure sufficient resources are allocated on the project budget so that the scale of the EMPr

related activities are consistent with the significance of project impacts;

• Manage identified impacts;

• Verify environmental performance through information on impacts as they occur;

• Ensure precautions against damage and claims arising from damage are taken timeously;

• Provide feedback for continual improvement in environmental performance; and

• Provide a framework for the implementation of environmental and social management initiatives.

The EMPr serves as a stand-alone document to be disseminated to and used by the contractor/s and

project managers/supervisors during the construction phase of the project. By its very nature, the

EMPr is a dynamic document and updating may be required.

The EMPr has been compiled on the basis of the outcome of work undertaken during the BAP and

represents management commitments of Sasol once approved by the Competent Authorities, whereby

the EMPr will be legally binding.



16 Undertaking of Oath by the EAP Section 16 (1) (b) (iv), and Appendix 1 Section 3 (1) (r) of the EIA Regulations, 2014 (promulgated in

terms of the NEMA), require an undertaking under oath or affirmation by the EAP in relation to:

• The correctness of the information provided in the report;

• The inclusion of comments and inputs from stakeholders and I&APs;

• Any information provided by the EAP to I&APs and any responses by the EAP to comments or

inputs made by I&APs; and

• The level of agreement between the EAP and I&APs on the Plan of Study for undertaking the EIA.

SRK and the EAP managing this project hereby affirm that:

• To the best of our knowledge the information provided in the report is correct, and no attempt has

been made to manipulate information to achieve a particular outcome. Some information,

especially pertaining to the project description, was provided by the applicant and/or their sub-

contractors. In this respect, SRK’s standard disclaimer pertaining to information provided by third

parties applies.

• To the best of our knowledge all comments and inputs from stakeholders and I&APs have been

captured in the report and no attempt has been made to manipulate such comment or input to

achieve a particular outcome. Written submissions are appended to the report while other

comments are recorded within the report. For the sake of brevity, not all comments are recorded

verbatim, and in instances where many stakeholders have made similar comments, they are

grouped together, with a clear listing of who submitted which comment(s).

• Information and responses provided by the EAP to I&APs are clearly presented in the report.

Where responses are provided by the applicant (not the EAP), these are clearly indicated.

• With respect to EIA Reports, SRK will take account of I&AP's comments and, insofar as comments

are relevant and practicable, accommodate these during the BAP.



17 Conclusion The project involves the construction and operation of the CF 2 proposed Tanks Expansion Project.

With reference to the available information of the project cycle, the confidence in the environment

assessment undertaken is regarded as acceptable for decision making purposes.

Following the screening phases and the subsequent BAR, it has come to light that from a financial,

biophysical and social–economical perspective, the proposed alternative is the most preferable and

no other alternatives were assessed in detail.

SRK Consulting has undertaken a detailed assessment of this on the basis of impacts identified

through the Stakeholder Engagement, professional judgement of the SRK project team, the Air Quality

Specialist as well as the Geotechnical Specialist. It can therefore be concluded there are no fatal flaws

of the CF 2 proposed Tanks Expansion Project have been identified.

It is envisaged that it will be possible to effectively manage any identified biophysical, cultural or social

impacts in accordance with national and international industry standards. The current monitoring and

auditing program of Sasol will incorporate the CF 2 proposed Tanks Expansion Project.



18 Way Forward The BAR (this document) is available for viewing at the following venues from 28 June 2019 to 29 July

2019:

• Secunda Public Library;

• Sasol Recreational Club;

• SRK Offices in Pretoria;


In addition, digital copies of the report without appendices may be emailed to l&APs on request.

Prepared by.

Andrew Caddick

Senior Environmental Scientist

Reviewed by

Dr Laetitia Coetser

Associate Partner

Accepted by

Manda Hinsch

Partner

All data used as source material plus the text, tables, figures, and attachments of this document have

been reviewed and prepared in accordance with generally accepted professional engineering and

environmental practices.




19 References

BASF, 2008. n - Propanol Technical Leaflet M 5579 e. Johannesburg: BASF The Chemical

Company .

Department of Environmental Affairs, 2012. National Environmental Management: Air Quality Act,

2004, Highveld Priority Area Air Quality Management Plan. Pretoria: Government Gazette No.

35072.

Govan Mbeki Local Municipality, 2017. Govan Mbeki Local Municipality: A Model City and Centre of

Excellence, IDP. Secunda: Govan Mbeki Local Municipality.

Govan Mbeki Municipality, 2018. Integrated Development Plan (IDP) 2018 /2019. A48/05/2018 ed.

Secunda : Govan Mbeki Municipality.

MegChem (Pty) Ltd, 2014. NPA De - bottlenecking Project. Extended Basic Engineering Package

Issued Approval for Detailed Engineering, Secunda: MegChem (Pty) Ltd.

Mpumalanga Tourism and Parks Agency, 2014. Mpumalanga Biodiversity Sector Plan Handbook.

Compiled by Lötter M.C., Cadman, M.J. and Lechmere-Oertel R.G. Mpumalanga Tourism & Parks

Agency.. Mbombela (Nelspruit): Mpumalanga Tourism and Parks Agency.

Sasol South Africa (Ltd), 2018. Clean Fuels 2: Tankfarm Tank Project High Level Operating

Philosophy. Revision 1, Secunda: Sasol South Africa (Ltd).

Sasol South Africa (Pty) Ltd, 2018. Sasol Product Overview. [Online]

Available at: http://www.sasol.co.za/products/overview

[Accessed 13 July 2018].

SRK Consulting (Pty) Ltd, 2019. Sasol Tank Farm Air Quality Impact Report , Durban: SRK

Consulting.

University of Kwa - Zulu Natal, 2013. Sasol: An Industrial Perspective. Secunda: Sasol Technology

(Pty) Ltd.

World Weather Online, 2012. World Weather Online. [Online]

Available at: http://www.worldweatheronline.com/Secunda-weather-averages/Mpumalanga/ZA.aspx

[Accessed 20 July 2015].



Appendices



Appendix A: Curriculum Vitae of the Project Team



Appendix B: SRK Project Experience



Appendix C: List of Interested and Affected Parties



Appendix D: Proof of Newspaper Adverts



Appendix E: Background Information Document



Appendix F: Interested and Affected Parties Notification

Letter



Appendix G: Environmental Management Programme



Appendix H: Specialist Studies



Appendix I: MDARDLEA Correspondence



SRK Report Distribution Record

Report No. 539945 / Draft Basic Assessment Report

Copy No.

Name/Title Company Copy Date Authorised by

Valerie Carelse Sasol South Africa Ltd 1 (pdf) June 2019 L Coetser

Sindisiwe Mbuyane MDARDLEA 2 (HC) June 2019 L Coetser

Mr M.F. Mahlangu Govan Mbeki Local Municipality

3 (HC) June 2019 L Coetser

Mr C.A. Habile Gert Sibande District Municipality

4 (HC) June 2019 L Coetser

Head Liberian Secunda Public Library 5 (HC) June 2019 L Coetser

Secretary Sasol Recreational Club 6 (HC) June 2019 L Coetser

SRK Library SRK Consulting (Pty) Ltd 7 (pdf) June 2019 L Coetser

SRK File SRK Consulting (Pty) Ltd 8 (pdf) June 2019 L Coetser

Approval Signature:

This report is protected by copyright vested in SRK (SA) Pty Ltd. It may not be reproduced or

transmitted in any form or by any means whatsoever to any person without the written permission of

the copyright holder, SRK.

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