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FINAL ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED FIS BIODIESEL REFINERY, COEGA INDUSTRIAL DEVELOPMENT ZONE, EASTERN CAPE PART 1

First in Spec Biofuels Ltd

2014/07/31

DEDEAT Ref Nr (EIA): ECm1/LN2/M/12-47.

DEA Ref Nr (WML): 12/9/11/L1124/1

NMBM Ref Nr (AEL): 19/2/9/2/1/2/L024-2.2/6.1.

Quality Management

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks Final

Date 31 July 2014

Prepared by Robert Els

Signature

Checked by Elan Theeboom

Signature

Authorised by Jacqui Fincham

Signature

Project number 21813

Report number Part 1 of 2

File reference 21813_Part 1_Final EIR FIS Biofuels_2014-07-31.docx

21813_Part%201_Final%20EIR%20FIS%20Biofuels_2014-07-31.docx

Final Environmental Impact Report for the Proposed FIS Biodiesel Refinery, Coega Industrial Development Zone, Eastern Cape PART 1


2014/07/31

Client


Consultant

WSP Environmental (Pty) Ltd 3rd Floor 35 Wale Street Cape Town 8001 South Africa Tel: +27 21 481 8794 Fax: +27 21 481 8799 www.wspgroup.co.za

Registered Address

WSP Environment & Energy South Africa 1995/008790/07 WSP House, Bryanston Place, 199 Bryanston Drive, Bryanston, 2191, South Africa

Executive Summary

Project overview

First in Spec Biofuels Ltd. (hereafter FIS) wishes to establish a biodiesel refinery in the Coega Industrial Development Zone (IDZ), Eastern Cape. To this end, FIS has appointed WSP Environmental (Pty) Ltd to fulfil the role of independent Environmental Assessment Practitioner (EAP) to facilitate the environmental authorisation process. Biodiesel (methyl esters) is diesel fuel produced from organic sources such as corn oil or waste vegetable oils and fats such as those from fast food outlets or animal food processing facilities. These organic oils are transformed during a chemical process into fuel and have the ability to directly power diesel engine cars, trucks, and buses without modification.

The goal of the facility is to produce biodiesel using primarily waste vegetable oil (WVO) and, depending on future market supply, animal fats. The proposed facility will have a production capacity of approximately 170 000 tons per annum during which various reagents such as methanol, sodium methylate, silica, citric acid and sulphuric acid will be used to facilitate the manufacturing process. Solid waste generated on site during the operational phase will consist of domestic waste, mixed industrial (wood, plastic, non-contaminated material), oil contaminated waste, fluorescent light tubes, pre-filtration residue, silica cake, polishing filter socks, polishing filter cake, sterol glycosides and filter cake.

FIS is currently proposing to import the WVO feedstock from the United States of America (USA) and export the entire production supply to Europe. The reasons for this are the absence of a reliable local feedstock supplier in South Africa, the maturity of the US industry and the favourable European biodiesel market. Future plans include sourcing the feedstock from local suppliers and once legislation with regards to petroleum blending in South Africa has been promulgated FIS will re-assess whether it is economically attractive to supply biodiesel to the local petroleum industry. The following phases outline FIS’s plan:

■ Phase 1 entails importing the feedstock (consisting of WVO) from the USA and exporting the entire production supply to Europe;

■ Phase 2a entails obtaining reliable and economically viable feedstock of WVO as well as animal fat (i.e. tallow) from local sources; and

■ Phase 2b entails re-assessing the economic viability for supplying biofuel to the local market, once legislation for mandatory blending has been promulgated.

Reporting Format

The Environmental Impact Report (EIR) is divided into two parts:

■ Part 1 – Final Environmental Impact Report (this document) of the EIR contains the project background, description, legal review, and baseline environmental assessment. Part 1 also contains a summary of the specialist studies that have been undertaken as part of the Environmental Impact Assessment (EIA) process in order to inform the project design and to identify and assess the significance of potential impacts that may stem from the proposed project. Part 1 of the EIR includes the environmental impact significance table and mitigation and management measures that have informed the draft Environmental Management Programme (EMPr) compiled and attached in Appendix C of the EIR.

■ Part 2 – Appendices contains all of the appendices referred to in Part 1 of the EIR, including the draft Environmental Management Programme (EMPr) (Appendix C) that describes how the environmental aspects identified in the Environmental Impact Report (EIR) should be managed in the event of environmental authorisation being granted for the EIR. The Executive Summary presented here is a summary of both volumes (Part 1 and Part 2) of the EIR.

Project description

The proposed layout will be based upon the HeroBX plant located in the USA. A detailed design for the process elements of the plant is therefore available but would need to be adapted to the site’s specific conditions (i.e. piping requirements; geotechnical information and so forth) once environmental authorisation has been

obtained. The site will have a footprint of approximately 4ha; a preliminary site plan is attached in Appendix D. The site will have the following infrastructure present on site:

■ Buildings

Transesterification Building

Wastewater Treatment Building

Filter Building

Pre-treatment Building

Pre-treatment Building Tower

Office and Administration Building

■ 26 External Tanks (Total storage capacity of 25 760m3)

■ Additional infrastructure

Fuel Boilers (Two boilers, each with a maximum design capacity of 14.7 MW);

Aboveground internal pipelines (on-site);

Cooling towers;

Truck loading/offloading area;

Piping components; and

Aboveground external pipelines (±5km in length) from site to the Oiltanking Grindrod Calulo (OTGC) facility.

Site Description

The proposed site is located within Zone 7 of Coega IDZ, which is in close proximity to the Port of Ngqura, and is easily accessible from the N2. The IDZ is situated in close proximity to Motherwell and Port Elizabeth. The locality of the site means that materials and feedstock required for the production of biodiesel can either be sourced via road or via pipeline connected to the proposed OTGC tank farm located in Zone 8 (i.e. Port Area). The biodiesel produced on site will also be transported via pipeline (to the port, for export) and/or trucks (to the port for export, as a temporary measure until the OTGC facility and pipeline infrastructure is commissioned, or delivered nationally to local refineries).

Legal Requirements

The proposed project triggers scheduled activities in terms of the National Environmental Management Act (NEMA), National Environmental Management: Air Quality Act (NEMAQA) and National Environmental Management: Waste Act (NEMWA). While a number of different authorisations are required (an Environmental Authorisation (EA), a Waste Management Licence (WML) and an Air Emissions Licence (AEL), the assessment process must be undertaken in accordance with the requirements stipulated in the EIA Regulations. To this end, a single Scoping/EIA process is being undertaken which encompasses all the relevant legislative requirements.

Stakeholder Engagement

Stakeholder Engagement is being undertaken in accordance with Chapter 6 (Section 54) as stipulated within the NEMA EIA regulations. Potential Interested and Affected Parties (I&APs) were notified via advertisements (published in English and Afrikaans) in two newspapers, distribution of notification letters as well as the posting of a site notice on the electronic notice board at the entrance of Coega IDZ’s offices. All Registered I&APs were and will be afforded an opportunity to comment on the Draft and Final Reports compiled in support of the various licenses/authorisations that are required.

Scoping Process

The Scoping process identified the specialist studies that were required and set out the Plan of Study for the EIA phase. The scoping process commenced on the 7

th of March 2013. Comments received on the Draft

Scoping Report were incorporated into the Final Scoping Report which was distributed for a 21-day commenting period commencing on the 13

th of June 2013. The commenting period on the Final Scoping Report

ended on the 8th of July 2013. The Eastern Cape Provincial Department of Economic Development,

Environmental Affairs and Tourism (DEDEAT) issued a letter, dated the 23rd

of August 2013, accepting the Final Scoping Report and approving the Plan of Study outlined within the Scoping Report, subject to the considerations that would need to be taken into account that were highlighted within DEDEAT’s letter. The DEDEAT comments were incorporated within the draft Environmental Impact Report (EIR) and subsequently are contained in the final EIR (this report).

Alternatives

Alternatives that were assessed as part of the EIA are:

■ Site alternatives

The site selection process was driven by the following site requirements:

Access to both main roads and a port;

4ha of developable land available;

Industrial zoning; and

Economically feasible in terms acquiring the land and construction of infrastructure.

Since the proposal of transporting the feedstock to the site can rely on two main sources, i.e. local feedstock (transported via road) or international feedstock supply (transported via ship to port), access to both harbour and major roads played an important role in the site selection process undertaken by FIS. In addition, the facility requires a minimum area of 4ha for the facility’s development footprint. Based on the access requirements of the facility and the size of the development footprint, it was deemed that only a site located in an IDZ which has access to both a port and road will be suitable for this type of operation. The first IDZ that was deemed suitable for the specific requirements was the Richards Bay IDZ. However; the Richards Bay IDZ did not have a suitable site available that was 4ha. Further discussions were held with a company who wanted to establish a liquid bulk storage facility in the Richards Bay IDZ, which had already secured a site covering 35ha, of which they only required 30ha, and were willing to go into partnership with FIS. Following further investigations the partnership was not deemed economically feasible rendering the Richards Bay IDZ as an unsuitable location for the facility.

FIS then investigated the options available at the Coega IDZ. The Coega IDZ is a premier location for new industrial investments in South Africa. It covers an area of approximately 11 000ha of which approximately 8 690ha are available for development. The Coega IDZ constitutes a phased development which is focused around industry clusters and has been divided into a total of 14 different zones. Sectors which have been identified for the IDZ consist of Automotive, Agro-Processing, Metallurgical, Educational and Training, Petrochemical, General Manufacturing, Business Process Outsourcing, and Energy. The proximity of the IDZ to the newly established deep water Port of Ngqura, as well as major transport routes (such as the N2), creates a platform for global exports by attracting foreign and local investment in manufacturing, export orientated and other industries

1.

The preferred site has therefore been selected from within the Coega IDZ. The final site location selected within the Coega IDZ was driven by the Coega Development Corporation (CDC) and the development strategy proposed for the region. The original site considered was within Zone 5 (metallurgical cluster). This site was deemed unsuitable primarily due to the requirement for a pipeline from the berth or the OTGC tank farm to the site. For a site within Zone 5 the pipeline would have to traverse terrain which changes significantly in altitude and which crosses the Coega River twice. In addition, the distance of a site in Zone 5 to the berth or proposed OTGC tank farm is in excess of 10km. As such a site within Zone 5 was deemed unsuitable.

1 CSIR, 2012, PhytoAmanla Biofuel Processing Plant in the Coega IDZ. Draft Environmental Impact Assessment Report

A site within Zone 7 (Chemical and Petrochemical Cluster) was then considered which is in closer proximity to the Port. This Zone is specifically earmarked for medium to heavy industry and has adequate service provision to service the site, provided by the CDC. The site in Zone 7 is ideally situated to ensure that the feedstock and materials required as part of the production of biodiesel can be obtained either via a pipeline from the OTGC tank farm or transported via road to the site. In addition, this site is in close proximity to the OTGC tank farm proposed for the Coega IDZ which is located within Zone 8.

■ Design/Layout alternatives

Design alternatives

The design, layout, tank and pipeline specifications as well as the amount and type of materials that will be stored and used on site have been based on the capacities of the HeroBX plant. Changes to the design of the facility will be made to ensure that the material used for the construction of the tanks, pipelines, and bunding requirements are applicable to the FIS facility in terms of the availability of construction materials and South African building standards and regulations. The design will also be changed to ensure that the electrical supply and water supply lines connect to the services connection lines of the CDC. To this end, changes to the process engineering design of the facility will be minor and therefore the assessment of design alternatives as part of the EIA was deemed unnecessary since any design changes will have a minimal, if any, impact on the operation of the facility and the surrounding environment. In addition to the above the design of the facility will incorporate the CDC Architectural and Landscaping guidelines.

Layout alternatives

The FIS facility will be based on the process engineering design and layout of the HeroBX facility and will be modified to suit the site specific conditions. However, there is a set requirement in terms of the general layout of the site. From an environmental perspective, no additional impacts would be applicable to layout alternatives, since the amount of materials to be stored on site and the footprint of the site will remain unchanged. Therefore layout alternatives would have a minimal influence on the overall impacts arising from the facility, keeping in mind the small site footprint (4ha).

■ Pipeline route alternatives

The FIS facility will require the construction of pipelines to the OTGC facility (when the tank farm is operational). The assessment of pipeline route alternatives from the OTGC tank farm to the port berths will not be assessed as part of this EA process, since the determination and assessment of the fuel reserves (i.e. pipeline servitudes) have already been undertaken within a separate authorisation process. In addition, a further authorisation process is in place for the Transnet Fuel Reserve, which will run from the OTGC tank farm and connect to the CDC servitude reserve which runs adjacent to the proposed site of the FIS facility.

The relevant authorisation processes are the Basic Assessment for the proposed provision of landside structures and infrastructure to the bulk liquid storage and handling facility in the Port of Ngqura within the Nelson Mandela Bay Municipality (NMBM) (refer to Department of Environmental Affairs (DEA) EIA Reference Number 14/12/16/3/3/1/675 and NEAS Reference No: DEA/EIA/0001386/2012 which obtained Environmental Authorisation from DEA on the 8

th of January 2014) and the impact associated with the construction of the

pipelines to the berth assessed within the EIA for the Bulk Storage and Handling Facility (hereafter referred to as the bulk tank farm) in Zone 8 of the Coega IDZ (DEDEAT Reference No: ECm1/LN2/M/11-57).

Therefore, the pipeline route alternatives that ultimately need to be considered are the routing options on how to connect the proposed FIS facility to the Transnet Fuel Reserve. The precise pipeline routing from the FIS facility to the Transnet Fuel Reserve has not been determined, since it falls within the Coega IDZ (and, specifically, within the CDC servitude) and is therefore managed by the CDC. This means that FIS’s pipeline will need to run from the FIS site to the Transnet Fuel Reserve via the CDC’s servitude determined during the rezoning of the remainder of the IDZ. The pipeline from the facility will run through this CDC servitude at a precise route (which is to be determined by the CDC’s Zone developers in the future) and connect to the OTGC tank farm via Transnet’s Fuel Reserve. The pipeline routing from the facility across the servitude will need to be informed by the Ecological Impact Assessment undertaken as part of this EIA (discussed in Section 9). The Ecological Impact Assessment determined that there is an area comprising of thicket bushclumps which should be avoided when considering how to route the pipeline. The best pipeline option will therefore be a route that

has minimal disturbance on the sensitive vegetation types present in the servitude but will still be cost effective in terms of routing to the fuel reserve.

It is noted that should the FIS facility come online prior to the OTGC tank farm and related pipeline infrastructure being in place, as a temporary measure tanker trucks will be used to transport feedstock from the port to the FIS facility, and biodiesel product from the facility back to the port.

■ Production alternatives

The HeroBX facility’s pre-treatment facility and fatty acid stripper, which will also be applicable to the FIS facility, allows for the utilisation of various feedstocks, depending on their availability and affordability. This means that the facility can make use of various sources and are not restricted to only one type of feedstock. As a result of the ‘fuel versus food’ debate that has been ongoing since farmlands started diverting their crops from food supply to biofuel production and the high cost of using virgin oil, FIS determined that using WVO as a raw material will significantly decrease the raw material cost (and therefore the cost of the biodiesel produced) as well as avoid the controversies around this debate.

Currently, the FIS facility will make use of WVO and potentially animal fats. As discussed in Section 6 (Project Motivation) the type and source of feedstock used on site will depend on when the mandatory blending of biodiesel comes into play and the availability of local feedstock. Once a market has been established in South Africa for biofuels, FIS will be in a much better position to be able to source feedstock from local suppliers since market availability and subsidies from government will be in place. Therefore, currently the preferred alternative (and the only commercially viable option due the production requirements of the facility) is to import WVO from the USA, convert it to biodiesel through various processes and export the full production supply to Europe. The main advantage to this proposal is that FIS will be able to establish their company in South Africa, creating jobs and developing skills and infrastructure, which will mean that in the future, once the local market is more developed, FIS will be able to supply biodiesel to South African petroleum refineries as part of the mandatory blending requirement. The establishment of FIS will also provide a significant incentive for local industry to develop economic means for diverting from landfill some of the estimated 30 million litres per month of WVO that is created in South Africa. Because of a lack of a structured local market to obtain the WVO, the FIS facility will currently not be using local supply; however a locally based production facility will no doubt help encourage the creation of an economically viable local WVO supply sector in South Africa.

Therefore, future options which are not viable at the moment include getting local suppliers to provide WVO and animal fats to the facility. FIS’s longer term goal is to source feedstock from, and supply biodiesel to, local companies.

■ Technology alternatives

Biodiesel can be produced via four primary methods, namely:

Direct use and blending;

Micro-emulsions of oils;

Thermal cracking (pyrolysis); and

Transesterification.

The project is currently proposing to produce biodiesel based on the Transesterification process (Section 7). This is the process that takes place between vegetable oil, or animal fat, and an alcohol in the presence of a catalyst. Transesterification is the most widely used production method to produce biodiesel and because of the facility’s production capacity and needs, it is also the best production method for this facility.

■ No-Go alternatives

The No-Go alternative will mean that no development will take place. Therefore, the baseline conditions of the site are applicable. From an ecological perspective the main issue identified within the site boundary, should the development not take place and left unmitigated, is that it is likely that Acacia cyclops (an alien species) will

continue to spread and displace indigenous vegetation particularly associated with thicket and mini bushclumps.

From a socio-economic perspective, it is currently expected that 17 new job opportunities will be created during the operational phase. The construction of the facility will create several semi-permanent jobs through the contractors that will be procured to construct the site. Currently, the site is not creating any employment opportunities. There will also be a lost opportunity for development within the Coega IDZ. This does not take into account the economic benefits from the establishment of a profitable company in South Africa and the contribution to the local and national economy.

As previously stated, FIS is aiming to become established in the South African market and to be able to produce biodiesel that will feed into the mandatory blending requirements set by the Department of Energy. Fuel producers will be required to blend a minimum of 5 percent biodiesel with diesel fuel while between 2 and 10 percent of bioethanol will need to be blended with petrol. The new regulation is set to kick in on the 1

st of October 2015 as the energy department bids to reduce the country's reliance on imported fuel and to

reduce national greenhouse gas emissions associated with mobile combustion. To this end this will be a lost opportunity to South Africa to meet their blending objectives once promulgated.

The primary aim of the establishment of the Coega IDZ is to attract local and foreign investment to this area, should the FIS facility not be constructed on site, another type of facility will be established on site sometime in the future. The IDZ is continuing to develop and with the on-going developments to the Port of Ngqura the likelihood is good that this development trend will continue. The potential impacts of the FIS facility have been assessed as part of this EIA and therefore the impacts associated with the activity are anticipated to be suitably managed and mitigated.

Based on the findings of the EIA, the facility will not have a significant negative impact and therefore the no-go option is not considered to be the preferred alternative.

Assessment of the receiving environment

A baseline environmental assessment was undertaken in order to determine the current conditions present on site and to gain an understanding of the physical, biological, and socio-economic attributes of the proposed facility and surrounding areas. This has allowed for a better understanding of the environment in which the project is being considered as well as facilitated the identification of which specialist studies were required to be undertaken.

Environmental Issues and associated specialist studies

As a result of the key environmental issues identified and discussed in the Scoping Report, the following specialist studies where undertaken as part of the EIA phase.

Environmental Issue Specialist Study Specialist Organisation

Airborne Emissions Air Quality Impact Assessment

Kirsten Collett WSP Environmental

Water Management Storm Water Management Plan

Andrew Gemmell WSP Environmental

Waste Management Waste Management Best Practicable Assessment

Barry Roberts WSP Environmental

Handling of Hazardous Substances

Major Hazardous Installation (MHI) Risk Assessment

Terence Thackwray MHR Consultants

Traffic Generation Traffic Impact Assessment Christo Bredenhann WSP Group Africa

Ecological Impacts Ecological Impact Assessment

Tarryn Martin Coastal & Environmental Services

Environmental Issues and associated assessments undertaken by the EAP

As a result of the key environmental issues identified and discussed in the Scoping Report, the following environmental issues have been addressed by the EAP in consultation with the project team, consultants, specialists and engineers.

Environmental Issue Assessment Specialist

Heritage/cultural aspects Desktop assessment EAP

Socio-Economic Impacts Desktop assessment EAP

Noise Impacts Desktop assessment EAP

In addition to the above the following secondary potential environmental issues and associated impacts have been addressed by the EAP through standard mitigation measures (in line with the CDC’s specifications and guidelines) in the Environmental Management Programme, without an assessment of significance.

Environmental Issue Assessment Specialist

Visual impact Desktop assessment EAP

Summary of Significance of Impact Assessment

Issues that have been assigned a pre-mitigation impact rating of “medium” (negative) significance or worse are summarised in the table below (refer to each technical chapter for detailed mitigation measures and to the EMPr for a comprehensive list):

Impact Description Pre-Mitigation Significance

Post-Mitigation Significance

Recommended Measures

Air Quality

(A2) Impact of Boiler Emissions

Releases of boiler generated pollutants may be emitted to the atmosphere, creating impacts on the ambient air quality.

Medium Low-Medium - Installation of SO2 abatement technology in the form of wet gas scrubbers or similar flue gas desulphurisation systems.

(A4) Impact of Fuel Loading Emissions

Fugitive emissions during the loading of fuel to tankers may be emitted to the atmosphere, creating impacts on the ambient air quality.

Medium Low-Medium - The installation of a suitable vapour recovery unit at the loading bays;

- The use of submerged filling technique for loading tankers;

- The use of pipeline to dispatch product to the harbour instead of tankers. This will limit the losses of emissions associated with the loading to tankers.

Ecological Impacts

(E1) Loss of Thicket Bushclumps and Mini Bushclumps

The construction of the pipeline and FIS facility will result in the loss of some thicket bushclumps and mini bushclumps within the project site. This vegetation type is considered to be of moderate sensitivity due to the role it plays

Medium Low-Medium - Keep removal of vegetation to a minimum within the pipeline servitude;

- Ensure that the footprint of the pipeline and tank farm are

in providing islands of refuge for small mammals, birds and reptiles as well as housing species of special concern such as Sideroxylon inerme.

kept to a minimum; and

- Implement a search and rescue plan;

- Insert measures to control alien vegetation and remove existing alien species.

(E2) Loss of grassland and succulent patches

The construction of the pipeline and tank farm will result in the loss of grassland and succulent patches within the project site. This vegetation type is considered to be of moderate sensitivity due to the presence of species of special concern and its vulnerable conservation status.


- Ensure that the footprint of the pipeline and FIS facility are kept to a minimum;

- Where feasible, avoid locating infrastructure (particularly within the CDC servitude) on the succulent patches associated with the exposed calcrete as this is where a large number of species of special concern are likely to be found; and

- Implement a search and rescue plan to identify and relocate species of special concern.

(E3) Loss of plant species of special concern

There are twelve plant species of special concern confirmed on this study site. There may be many additional species of special concern that will be found on site during construction that were not observed during this study. The loss of these species could impact cumulatively on the genetic viability of these populations and result in the loss of area of occupancy within the region.

Medium-High Low-Medium - Keep removal of vegetation to a minimum within the pipeline servitude;


- Species of special concern must be marked prior to construction and a search and rescue plan must be developed in order to transplant these species. This may include seed collection and cultivation;

- Some SSC will not transplant. These individuals should, as far as possible, be left undisturbed; and

- Permits will be required to remove these species.

(E6) Fragmentation of communities and edge effects

Fragmentation is one of the most important impacts on vegetation, especially when this creates barriers in previously continuous vegetation or reduced habitat, causing a reduction in the gene pool and a decrease in species richness

Medium Low-Medium - All fences must have wide enough mesh to let small animals to pass through;

- If the pipeline is above ground then culverts must be installed at regular intervals to allow the passage of

and diversity. The landscape is already relatively fragmented, but the construction of the pipeline and tank farm in the area could exacerbate this for plants and small animals since there is the possibility that viable populations may be split or cut off from one another.

animals under the pipeline;

- Where feasible, existing roads should be utilised to prevent the further fragmentation of the site; and

- The clearing of vegetation for new roads must be kept to a minimum.

(E7) Invasion of alien plant and animal species

The removal of existing vegetation creates ‘open’ habitats that will inevitably and rapidly be colonised by pioneer plant and animal species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in the area. Once established, these species are typically very difficult to eradicate and may then pose a threat to the neighbouring ecosystem. This impact is likely to be exacerbated by careless management of the site and its facilities during construction and operation (e.g. inappropriate disposal of cleared alien vegetation that could harbour seeds) and inadequate monitoring. Many such species are however remarkably tenacious once they have become established.

Medium-High Low (positive)

- Mitigation measures to reduce the impact of the introduction of alien plant invaders, as well as mitigation against alien plant invaders that have already been recorded on the site, should be actively managed throughout both the construction and operation phases;

- Removal of existing alien species on site must be undertaken; and

- Rehabilitation of disturbed areas after construction must be undertaken as part of a Rehabilitation Plan as soon as possible after construction is completed.

The way forward

The final EIR has been made available to all registered I&APs and stakeholders who are given a final opportunity to ensure that the comments provided on the draft EIR have been adequately addressed in the final EIR (this report). The comment period will run for a period of 21 days, commencing on the 8

th of August 2014

and continuing until the 29th of August 2014. Following this, the final EIR will be updated with the comments

received (if applicable) and submitted to the DEDEAT in order for them to make a decision on the environmental acceptability of the proposed development and issue a Record of Decision (RoD).

The public are encouraged to review this final EIR (this report) to ensure that the comments received on the draft EIR have been adequately addressed in this report. Written comments are to be submitted to the details provided below by 12h00 on 29

th of August 2014 to:

Robert Els Postal Address: P.O. Box 2613, Cape Town, 8001

Email: [email protected] Fax: (021) 481 8799

Reference Number: Ref No: ECm1/LN2/M/12-47

mailto:[email protected]

Table of Contents 1. Introduction ................................................................................................................. 1

1.1. Details of the Project Applicant ............................................................................. 1 1.2. Details and Expertise of the Environmental Assessment Practitioners ................. 1 1.3. Project Team ........................................................................................................ 2 1.4. Legal Framework .................................................................................................. 2

1.5. Objectives and Contents of the Environmental Impact Assessment Report ....... 14 1.6. Approach to the EIA............................................................................................ 16 1.7. Assessment of Alternatives ................................................................................ 19 1.8. Technical Project Description ............................................................................. 19 1.9. Assumptions and Limitations .............................................................................. 19

1.10. Assessment of the report ................................................................................. 20

1.11. Structure of the report ...................................................................................... 20

2. Project Description .................................................................................................... 22

2.1. Terms of Reference ............................................................................................ 22 2.2. Need and Desirability.......................................................................................... 22 2.3. Project Motivation ............................................................................................... 25 2.4. Site Determination .............................................................................................. 26

2.5. Site Locality ........................................................................................................ 27 2.6. Facility Description.............................................................................................. 30

2.7. Process Description ............................................................................................ 40 2.8. Assessment of Alternatives ................................................................................ 44

3. Description of Receiving Environment ...................................................................... 54

3.1. Climate ............................................................................................................... 54 3.2. Air Quality ........................................................................................................... 57

3.3. Topography, Geology and Soils ......................................................................... 58 3.4. Surface water ..................................................................................................... 59

3.5. Groundwater ....................................................................................................... 60 3.6. Ecology ............................................................................................................... 61

3.7. Heritage, Archaeological and Cultural Sites ....................................................... 65 3.8. Social and Economic Environment ..................................................................... 67

4. Public Participation Process ...................................................................................... 71 4.1. Objectives and Approach .................................................................................... 71 4.2. Authority Consultation ......................................................................................... 71 4.3. Stakeholder Engagement ................................................................................... 72

5. Environmental Impacts .............................................................................................. 74

5.1. Identification of Potential Impacts ....................................................................... 74

5.2. Impact Rating Methodology ................................................................................ 75

6. Air Quality Impact Assessment ................................................................................. 77 6.1. Introduction ......................................................................................................... 77 6.2. Study specific assumptions and limitations ......................................................... 77 6.3. Atmospheric Emissions and Impacts .................................................................. 77 6.4. Relevant legislation............................................................................................. 80 6.5. Methodology ....................................................................................................... 83

6.6. Summary of findings ........................................................................................... 88

6.7. Impacts identified ................................................................................................ 96 6.8. Conclusions and Recommendations .................................................................. 98

7. Storm Water Management Plan .............................................................................. 100

7.1. Introduction ....................................................................................................... 100 7.2. Approach .......................................................................................................... 100 7.3. Study specific assumptions and limitations ....................................................... 100 7.4. Numerical Modelling ......................................................................................... 100 7.5. Conceptual Storm Water Management Plan .................................................... 100

7.6. Conclusions and Recommendations ................................................................ 101

8. Solid Waste Generation .......................................................................................... 103 8.1. Introduction ....................................................................................................... 103 8.2. Findings ............................................................................................................ 103

8.3. Potential Impacts .............................................................................................. 109 8.4. Recommendations/mitigation measures proposed ........................................... 112

9. Ecological ................................................................................................................ 113 9.1. Introduction ....................................................................................................... 113

9.2. Study specific assumptions and limitations ....................................................... 113

9.3. Methodology ..................................................................................................... 113 9.4. Summary of findings ......................................................................................... 113

9.5. Potential Impacts .............................................................................................. 115 9.6. Recommendations/mitigation measures proposed ........................................... 120

10. Traffic Generation and Site Access ......................................................................... 121

10.1. Introduction .................................................................................................... 121 10.2. Baseline conditions ........................................................................................ 121

10.3. Summary of findings ...................................................................................... 124

10.4. Potential Impacts ........................................................................................... 126

10.5. Conclusions and Recommendations ............................................................. 126

11. MHI Quantitative Risk Assessment ......................................................................... 128

11.1. Introduction .................................................................................................... 128 11.2. Study specific assumptions and limitations.................................................... 128 11.3. Hazard identification ...................................................................................... 128 11.4. Summary of findings ...................................................................................... 129

11.5. Potential Impacts ........................................................................................... 133 11.6. Recommendations and Conclusions ............................................................. 133

12. Heritage Statement ................................................................................................. 134 12.1. Introduction .................................................................................................... 134 12.2. Methodology .................................................................................................. 134

12.3. Summary of findings ...................................................................................... 134

12.4. Potential Impacts ........................................................................................... 137

12.5. Recommendations ......................................................................................... 137

13. Socio-economic....................................................................................................... 139 13.1. Introduction .................................................................................................... 139 13.2. Potential Impacts ........................................................................................... 139

14. Noise Impacts ......................................................................................................... 140

14.1. Introduction .................................................................................................... 140

14.2. Baseline Conditions ....................................................................................... 140 14.3. Potential Impacts ........................................................................................... 140 14.4. Conclusions and Recommendations ............................................................. 141

15. Visual Impact Statement ......................................................................................... 142 15.1. Introduction .................................................................................................... 142 15.2. Visual Impact Statement ................................................................................ 142 15.3. Recommendations/mitigation measures proposed ....................................... 149

16. Environmental Impact Statement ............................................................................ 150

16.1. Evaluation ...................................................................................................... 150 16.2. Principle findings and key decision making factors ........................................ 151 16.3. Authorisation Opinion .................................................................................... 155

17. The Way Forward.................................................................................................... 156

Appendices Appendix A: CVs of EIA project team

Appendix B: Correspondence with DEA regarding Waste License Application

Appendix C: Draft Environmental Management Programme

Appendix D: Site Locality Map & Layout Plan

Appendix E: Correspondence between FIS and OTGC

Appendix F: Specialist Studies

Appendix G: Authority Confirmations of applications

Appendix H: Public Participation Process

List of Tables Table 1: Details of Project Applicant .......................................................................................................................1 Table 2: Details of the Environmental Assessment Practitioners ...........................................................................1 Table 3: Project Team and Role within the team....................................................................................................2 Table 4: Activities applicable in terms of NEMA EIA Regulations ..........................................................................4 Table 5 South African National Ambient Air Quality Standards applicable to the biodiesel processing plant .......7 Table 6: Storage specifications for petroleum liquids products (NEMAQA, listed activities, Category 2: Petroleum Industry, Subcategory 2.4) ....................................................................................................................8 Table 7: International air quality standards and guidelines for methanol ...............................................................9 Table 8: International air quality standards and guidelines for hexane ..................................................................9 Table 9: Minimum emission standards associated with the organic chemicals industry (NEMAQA, listed activities, Category 6: Organic Chemicals Industry) ...............................................................................................9 Table 10: Waste Management License triggers .................................................................................................. 10 Table 11: Listed activities as per GN 921 ............................................................................................................ 11 Table 12: Section 6 of the NMBM: Air Pollution Control by-laws ........................................................................ 14 Table 13: Contents of the EIR ............................................................................................................................. 15 Table 14: Need and Desirability of the Proposed FIS Biodiesel Facility ............................................................. 23 Table 15: Coordinates of the site ......................................................................................................................... 27 Table 16: Effluent Water Quality Requirements .................................................................................................. 33 Table 17: Materials Summary .............................................................................................................................. 35 Table 18: Projects proposed in the Coega IDZ relevant to the FIS facility ......................................................... 36 Table 19: Landside Structure and Infrastructure Basic Assessment project components and applicability to the FIS facility ............................................................................................................................................................ 38 Table 20: Services availability in Zone 7 ............................................................................................................. 48 Table 21: Technology alternatives assessment .................................................................................................. 51 Table 22: Quaternary catchment information (WRC, 1994) ................................................................................ 60 Table 23: Rainfall station summary (ICFR, 2004) ............................................................................................... 60 Table 24: Nelson Mandela Bay population trend ................................................................................................ 68 Table 25: Newspapers and date of publication ................................................................................................... 72 Table 26: Specialist Studies ................................................................................................................................ 74 Table 27: Environmental Issues addressed by the EAP ..................................................................................... 74 Table 28: Environmental Issues addressed by the EAP through standard mitigation measures ....................... 75 Table 29: Assessment and Rating of Severity..................................................................................................... 75 Table 30: Assessment and Rating of Duration .................................................................................................... 75 Table 31: Assessment and Rating of Extent ....................................................................................................... 75 Table 32: Determination of Consequence ........................................................................................................... 76 Table 33: Assessment and Rating of Frequency................................................................................................. 76 Table 34: Assessment and Rating of Probability ................................................................................................. 76 Table 35: Determination of Likelihood ................................................................................................................. 76 Table 36: Determination of Environmental Significance ...................................................................................... 76 Table 37: Location of sensitive receptors surrounding the proposed biodiesel production plant. ....................... 78 Table 38: South African National Ambient Air Quality Standards applicable to the biodiesel processing plant . 80 Table 39: Storage specifications for petroleum liquids products (NEMAQA, listed activities, Category 2: Petroleum Industry, Subcategory 2.4) ................................................................................................................. 81 Table 40: International air quality standards and guidelines for methanol .......................................................... 82 Table 41: International air quality standards and guidelines for hexane ............................................................. 82 Table 42: Minimum emission standards associated with the organic chemicals industry (NEMAQA, listed activities, Category 6: Organic Chemicals Industry) ............................................................................................ 82 Table 43: Vent Recovery System stack specifications and emission rates. ....................................................... 83 Table 44: Emission factors for fuel oil combustion .............................................................................................. 84 Table 45: Modelling Domain coordinates ............................................................................................................ 86 Table 46: Background pollutant concentrations utilised in the dispersion model ................................................ 87 Table 47: VOC emissions from the biodiesel production vent recovery system ................................................. 96 Table 48: Impacts rating table of air quality impacts from the proposed biodiesel production plant ................... 97 Table 49: Waste management options .............................................................................................................. 104 Table 50: Waste Management Impact Assessment .......................................................................................... 109 Table 51: Impact assessment table for ecological impacts ............................................................................... 116

Table 52: Estimated trip generation ................................................................................................................... 123 Table 53: Parking requirements ........................................................................................................................ 126 Table 54: Potential Heritage Impacts ................................................................................................................ 137 Table 55: Potential Socio-Economic Impacts .................................................................................................... 139 Table 56: Typical rating levels for noise ............................................................................................................ 140 Table 57: Potential Noise Impacts ..................................................................................................................... 140 Table 58: Compliance to Section 7 and 8 of the Architectural Design Guidelines ............................................ 144 Table 59: Impact Rating Summary for the proposed FIS biodiesel facility ........................................................ 150

List of Figures Figure 1: Environmental Impact Assessment (EIA) Process ............................................................................... 17 Figure 2a: Project locality map of the proposed site. .......................................................................................... 28 Figure 3: Conceptual layout model of the proposed FIS facility (BCS Holding Company (Pty) Ltd, 2012)......... 30 Figure 4: Photo pallet of the HeroBX plant. The photos show what the FIS facility will look like, from clockwise from top left, picture of the pre-treatment area, biodiesel storage tanks, office/administration building and internal pipelines. ................................................................................................................................................. 31 Figure 5: Site layout plan (1:1500) of the proposed FIS refinery......................................................................... 32 Figure 6: Basic process water flow diagram (based on the HeroBX facility) ....................................................... 34 Figure 7: Pipeline route option from the bulk storage tank farm to the berths .................................................... 39 Figure 8: Simplified Process Block Diagram ....................................................................................................... 41 Figure 9: Coega IDZ Map showing zones in which the alternative site options were located. ........................... 46 Figure 10: Site options within the Coega IDZ that were considered ................................................................... 47 Figure 11: Pipeline route option from the FIS facility to connect to the fuel reserve and sensitive vegetation type to take into account (Map source: CES Ecological Impact Assessment for the FIS Biodiesel Facility, September 2013) .................................................................................................................................................................... 50 Figure 12: Monthly average, maximum and minimum temperature data for Coega for 2010 – 2012................. 54 Figure 13: Monthly rainfall and humidity recorded at the Coega SAWS station ................................................. 55 Figure 14: Surface wind rose plot for Coega for the December 2010 to November 2011 period ....................... 55 Figure 15: Seasonal surface wind rose plots for Coega for the period January 2010 to December 2012 ......... 56 Figure 16: Diurnal surface wind rose plots for Coega for the period January 2010 to December 2012 ............. 57 Figure 17: The project area is underlain by the Sundays River formation (CES, 2013) ..................................... 59 Figure 18: National Vegetation Map (Mucina and Rutherford, 2006) indicating that the project site occurs within the Coega Bontveld vegetation type (CES, 2013) ............................................................................................... 63 Figure 19: The map shows the route where “spot checks” were undertaken as part of the Phase 1 AIA. The blue circles spot checks and survey areas and the pink dots mark where Later and Middle Stone Age materials were found (Map source: Binneman, 2010). The yellow square indicates the locality of the proposed FIS site. 66 Figure 20: Employment levels in the NMBM (Statistics SA, 2008)...................................................................... 68 Figure 21: Income category in the NMBM (Statistics SA, 2008) ......................................................................... 69 Figure 22: Occupation categories of the NMBM population (Statistics SA, 2008) .............................................. 69 Figure 23: Industry sectors of the NMBM population (Statistics SA, 2008). ....................................................... 70 Figure 24: Level of education in the NMBM (Statistics SA, 2008)....................................................................... 70 Figure 25: FIS Biodiesel facility plant layout and main emission sources (WSP, 2013) ..................................... 79 Figure 26: Location of receptors used in dispersion model ................................................................................. 88 Figure 27: Annual average PM10 emissions (left) and worst case daily PM10 emissions (right) from the FIS facility. .................................................................................................................................................................. 89 Figure 28: Annual average NOx emissions from the FIS facility .......................................................................... 90 Figure 29: Worst case hourly NOx emissions (left) and predicted number of exceedences of the hourly standard (right) for the FIS facility ....................................................................................................................................... 91 Figure 30: Annual average SO2 emissions from the FIS facility .......................................................................... 92 Figure 31: Annual average SO2 emissions from the FIS facility with a 75% emission reduction efficiency (left) and 90% emission reduction efficiency (right) applied to SO2 emissions from the boilers ................................. 93 Figure 32: Worst case (i.e. NO ABATEMENT) hourly SO2 emissions (left) and predicted number of exceedences of the hourly standard (right) for the FIS facility ............................................................................ 93 Figure 33: Worst case (I.e. NO ABATEMENT) daily SO2 emissions (left) and predicted number of exceedences of the daily standard (right) for the FIS facility ..................................................................................................... 94

Figure 34: Annual average VOC emissions from the FIS facility during the truck dispatch scenario (left) and pipeline dispatch scenario (right) ......................................................................................................................... 95 Figure 35: Conceptual Storm Water Management Plan .................................................................................... 102 Figure 36: Sensitivity map showing the entire project area is of moderate sensitivity ...................................... 115 Figure 37: Locality plan showing road network ................................................................................................. 121 Figure 38: Existing (2013) weekday AM peak ................................................................................................... 122 Figure 39: Existing (2013) weekday PM peak ................................................................................................... 122 Figure 40 Base year (2013) weekday AM peak hour traffic, including trips generated by the proposed development: ..................................................................................................................................................... 123 Figure 41: Base year (2013) weekday PM peak hour traffic, including trips generated by the proposed development ...................................................................................................................................................... 123 Figure 42: Horizon year (2018) weekday AM peak hour traffic, including trips generated by the proposed development ...................................................................................................................................................... 124 Figure 43: Horizon year (2018) weekday PM peak hour traffic, including trips generated by the proposed development ...................................................................................................................................................... 124 Figure 44: Radiation flux from all fires ............................................................................................................... 129 Figure 45: Potential Overpressure ..................................................................................................................... 131 Figure 46: Individual risk .................................................................................................................................... 132 Figure 47: The map shows the route where “spot checks” were undertaken as part of the Phase 1 AIA.* ...... 135 Figure 48: Photo of the operational HeroBX facility. ......................................................................................... 142

List of Abbreviations ABP Animal By-Product AE Acid Esterification AEL Atmospheric Emissions License

APPA Atmospheric Pollution Prevention Act (Act No. 45 of 1965)

AIA Archaeological Impact Assessment CBA Critical Biodiversity Area

CO Carbon Monoxide CDC Coega Development Cooperation DEDEAT Department of Economic Development, Environmental Affairs and Tourism

DWA Department of Water Affairs EA Environmental Authorisation

EAP Environmental Assessment Practitioner ECBCP Eastern Cape Biodiversity Conservation Plan

ELC Environmental Liaison Committee EMPR Environmental Management Programme EIA Environmental Impact Assessment FS Fatty Acid Stripping

FIS First in Spec Biofuels Ltd GN Government Notice I&APs Interested and Affected Parties

IDZ Industrial Development Zone MONG Matter Organic Non-Glycerine NEMA National Environmental Management Act (Act No. 107 of 1998) NEMAQA National Environmental Management: Air Quality Act (Act No 39 of 2004)

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

NMB Nelson Mandela Bay

NMBM Nelson Mandela Bay Municipality

NHRA National Heritage Resources Act (Act No. 25 of 1999) NOx Nitrogen oxides OSMP Open Space Management Plan

OTGC Oiltanking Grindrod Calulo (Pty) Ltd

PM Particulate Matter PT Pre-treatment RDB Red Data Book SANBI South African National Biodiversity Institute SANS South African National Standards SO2 Sulphur Dioxide SWMP Stormwater Management Plan TE Transesterification USA United States of America VOCs Volatile Organic Compounds WML Waste Management License

WVO Waste Vegetable Oil WWTW Waste Water Treatment Works

a

Outline of the Environmental Impact Report

The Environmental Impact Report (EIR) is divided into two parts:

■ Part 1 – Final Environmental Impact Report (this document) of the EIR contains the project background, description, legal review, baseline environmental assessment. Part 1 also contains a summary of the specialist studies that have been undertaken as part of the Environmental Impact Assessment (EIA) process in order to inform the project design and to identify and assess the significance of potential impacts that may stem from the proposed project. Part 1 of the EIR also contains the environmental impact significance table and mitigation and management measures that informed the draft Environmental Management Programme (EMPr) compiled and attached in Appendix C of the EIR.

■ Part 2 – Appendices contains all of the appendices referred to in Part 1 of the EIR, including the draft EMPr (Appendix C) that describes how the environmental aspects identified in the EIR should be managed in the event of environmental authorisation being granted of the EIR. The Executive Summary presented here is a summary of both volumes (Part 1 and Part 2) of the EIR.

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1. Introduction

1.1. Details of the Project Applicant

Table 1: Details of Project Applicant

Applicant: First in Spec Biofuels Ltd

Contact Person: Louis Nyiri

Physical Address: 23 Fourth Avenue, Flamboyant Park, Queensburgh, Durban, 4093

Telephone: 031 463 2805

E-mail: [email protected]

1.2. Details and Expertise of the Environmental Assessment Practitioners

WSP Environmental (Pty) Ltd was appointed by First in Spec Biofuels Ltd (FIS) to fulfil the role of independent Environmental Assessment Practitioner (EAP) to facilitate the environmental authorisation process. WSP is a leading international environmental consultancy with a broad range of expertise in the environmental industry. WSP has successfully project managed a number of high profile environmental projects in South Africa over the past 20 years. CVs of the EAPs are attached in Appendix A of this report. Details of the relevant WSP team members are shown in Table 2 below.

Table 2: Details of the Environmental Assessment Practitioners

Environmental Assessment Practitioner: WSP Environmental (Pty) Ltd

Contact Person

Nigel Seed Jacqui Fincham Robert Els

Physical Address

WSP House, 1 on Langford, Langford Road, Westville, Durban, 3629

3rd

Floor, 35 Wale Street, Cape Town, 8001

3rd

Floor, 35 Wale Street, Cape Town, 8001

Postal Address

PO Box 1442, Westville, 3630 PO Box 2613, Cape Town, 8000

PO Box 2613, Cape Town, 8000

Telephone 031 240 8860 021 481 8795 021 481 8722

Fax 031 240 8861 021 481 8799 021 481 8799

E-mail [email protected] [email protected]

[email protected]

Project Role Project Director Project Manager Lead Consultant

Years’ experience

13 15 2

Qualification BSc. (Social Science), Environmental Management & Geography, University of Natal, Durban

BSc (Honours) Biotechnology, Rhodes University, Grahamstown

BSc (Honours) Geography, University of Pretoria

Professional Registration

EAPSA, IWMSA, IAIA EAPSA IAIA



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1.3. Project Team

The project team who has participated and provided input into the EIA Report are detailed in the table below:

Table 3: Project Team and Role within the team

Project Role within Team Name Company

Environmental Assessment Practitioner

Jacqui Fincham

Robert Els

WSP Environmental (Pty) Ltd

Technical Review Nigel Seed

Elan Theeboom

WSP Environmental (Pty) Ltd

Sub-consultants

Traffic Impact Assessment Christo Bredenhann WSP Group (Pty) Ltd

Ecological Impact Assessment Tarryn Martin Coastal & Environmental Services (Pty) Ltd

Risk Assessment Terence Thackwray Major Hazard Risk Consultants cc

Waste Management Best Practicable Environmental Assessment

Barry Roberts WSP Environmental (Pty) Ltd

Air Quality Impact Assessment Kirsten Collett WSP Environmental (Pty) Ltd

Stormwater Management Plan Andrew Gemmell WSP Environmental (Pty) Ltd

1.4. Legal Framework

The following legislation, guidelines and information series documents have been taken into account for the assessment of the potential impacts of the proposed FIS facility on the receiving environment as described in this report.

1.4.1. National Legislation

Section 24 of The Constitution of the Republic of South Africa;

National Environmental Management Act (NEMA) (Act 107 of 1998);

EIA Regulations published under Chapter 5 of the NEMA on 18 June 2010 (GN R543, GN R 544, GN R 545 and GN R 546 in Government Gazette 33306);

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

Guidelines published in terms of the NEMA EIA Regulations, in particular:

Guideline on Transitional Arrangements (August 2010);

Guideline on Alternatives (August 2010);

Guideline on Public Participation (August 2010);

Guideline on Exemptions (August 2010);

Guideline on Need and Desirability (August 2010);

Guideline on Appeals (August 2010);

National Environmental Management: Biodiversity Act (NEMBA) (Act 10 of 2004);

National Environmental Management: Air Quality Act (NEMAQA) (Act 39 of 2004);

National Water Act (NWA) (Act 36 of 1998);

National Heritage Resources Act (NHRA) (Act 25 of 1999);

Hazardous Substance Act (Act 15 of 1973);

Road Traffic Act (Act 93 of 1996);

Occupational Health and Safety Act (Act 85 of 1993);

Promotion of Administrative Justice Act (Act 2 of 2000);

Draft Biofuels Industrial Strategy of the Republic of South Africa (December 2007);

Draft Position Paper on the South African Biofuels Regulatory Framework (Notice 24 of 2014);

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National Climate Change Response White Paper (October 2011);

National Strategy for Sustainable Development (November, 2011); and

Records of Decision issued by national DEA and/or the provincial Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) for activities in the Port of Ngqura and Coega IDZ.

The following legislation and its applicability to FIS Biodiesel project have been considered. The section below provides a summary of the prevailing legislative framework and its application to the proposed activity.

1.4.2. National Strategy for Sustainable Development (NSSD)

The NSSD puts into action, the National Framework for Sustainable Development (NFSD) outlining the common vision of sustainable development in South Africa. The NFSD outlined the vision, principles, trends, strategic priority areas, and a set of implementation measures that were intended to enable and guide the development of the national strategy and action plan.

The NSSD was developed and approved by Cabinet on the 23rd November 2011. All sectors, including all elements of the government plus civil society, organised labour and business, are called upon to take part in the social contract to implement the NSSD and Action Plan 2011 – 2014.

The following five strategic priorities are identified in the NSSD:

Priority 1: Enhancing systems for integrated planning and implementation

Priority 2: Sustaining our ecosystems and using natural resources efficiently

Priority 3: Towards a green economy

Priority 4: Building sustainable communities

Priority 5: Responding effectively to climate change

The NSSD identifies 113 interventions that can be monitored for implementation. The twenty headline indicators have been identified to monitor progress in the implementation of NSSD (2011–2014). These headline indicators are selected from existing indicators including the Development Indicators, the Millennium Development Goals and the 12 government outcomes.

Adherence to the NSSD is not a legally binding requirement for business, either at the corporate or project lev-el. While the NSSD is not specifically envisaged as a project-level framework, the principles are however broadly applicable at the policy, programme and project levels.

1.4.3. Draft Biofuels Industrial Strategy of the Republic of South Africa (December 2007)

In November 2006 the Department of Energy published the Draft Biofuels Industrial Strategy of the Republic of South Africa. The strategy was approved by Cabinet on 5 December 2007. This document states that “Biofuels provide the opportunity to achieve comprehensive sustainable developments benefits, addressing social, economic and environmental aspects, at local and global levels, and renewable energy needs. The extent of these benefits and value thereof are determined by national priorities, as is evidenced by the diversity of drivers of international biofuels programmes. Prioritization of goals enables regulations and incentives to be optimised to enable greater benefits”. The strategy envisaged a five-year pilot phase, from 2008 to 2013, during which a 2% infiltration level of biofuels in the liquid fuels pools was to be achieved. A Draft Position Paper on the South African Biofuels Regulatory Framework was published (dated 15

th January 2014) to assist with the First Phase

of the Implementation of the Biofuels Industrial Strategy.

South Africa hosted the World Summit on Sustainable Development (WSSD) in 2002, and its outcome, the Johannesburg Plan of Implementation (JPoI) commits the country to develop renewable energy technologies, which included transportation related renewable energy sources, such as biofuels.

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1.4.4. Petroleum Products Act (Act No. 120 of 1997) and applicable Regulations

1.4.4.1. Regulations regarding petroleum products manufacturing licences

FIS will be required to obtain a manufacturing licence from the Department of Energy. The application will require a positive Environmental Authorisation in terms of the EIA Regulations, and will therefore be undertaken on conclusion of the EIA process.

1.4.4.2. Regulations regarding the mandatory blending of biofuels with petrol and diesel

The South African government has gazetted regulations on the 23rd

of August 2012 regarding the mandatory blending of biofuels with petrol and diesel. The regulations envisage that all petrol and diesel supplied to a blending facility should allow for blending of biofuels with a minimum concentration of 5% of biodiesel. The Department of Energy stated on the 2

nd of October 2013 that the mandatory blending of fuels will be effective

from the 1st of October 2015.

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

The NEMA provides the environmental legislative framework for South Africa. The EIA Regulations (GN. R543) were promulgated in terms of NEMA and became effective on the 2

nd of August 2010. The 2010 EIA

Regulations contain three Listing Notices (GN.R544, R545 and R546) of activities that either require a Basic Assessment or Scoping and EIA procedure in order to obtain EA from the competent authority. Activities listed within Listing Notice 1 require a Basic Assessment process and activities listed within Listing Notice 2 require a Scoping and EIA process. The FIS facility triggers activities within Listing Notice 1 and 2 (see Table 4) and therefore the more intricate Scoping and EIA process applies to the proposed activity. Please note that the additional activities that have been identified and that were not included in the EIA application form, which was submitted to DEDEAT 30 July 2012, have been included in the table below. The additional activities were identified after input obtained from the Coega Development Corporation (CDC) Environmental Liaison Committee (ELC) meeting (held on the 23

rd of August 2012) and confirmation on the proposed pipeline

routes that would need to be considered during the EIA. In addition, following the submission of the Final Scoping Report (FSR), DEDEAT commented in the letter dated the 23

rd of August 2013 that certain activities

are not applicable or that certain sub-activities are wrongly quoted. The table below has been updated to ensure that the activities and sub-activities applicable to the facility are reflecting this input and are therefore included in the Environmental Authorisation. These amendments made are shown in italics text.

Table 4: Activities applicable in terms of NEMA EIA Regulations

Activity No: Description of activity Applicability of activity:

GN. 544 (Listing Notice 1) (BA required)

11 The construction of (xi) infrastructure covering 50 square metres or more;

Where such construction occurs within a watercourse or within 32m of a watercourse, measured from the edge of the watercourse, excluding where such construction will occur behind the development setback line.

The alternative pipeline route may be constructed within 32m of the Coega River/Estuary.

16 Construction of earth moving activities in the sea, an estuary, or within the littoral active zone or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever is greater, in respect of (vi) infrastructure covering 50 square metres or more.

The alternative pipeline route may be constructed within 32m of the Coega River/Estuary.

5

18 The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock from (i) a watercourse (iv) the littoral active zone of, an estuary or a distance of 100m inland of the high-water mark of the sea or an estuary, whichever is greater.

Infilling or depositing of more than 5m3

of material

within the Coega River/Estuary may

occur as part of the construction of the proposed pipeline.

GN. 545 (Listing Notice 2) (Scoping/EIA required)

3 The construction of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 cubic metres.

Several substances that will be stored on site that are deemed hazardous in terms of SANS 10234:2008.

This includes substances such as sodium methylate, hydrochloric acid, sulfuric acid, phosphoric acid and sodium hydroxide.

4 The construction of facilities or infrastructure for the refining, extraction or processing of gas, oil or petroleum products with an installed capacity of 50 cubic metres or more per day.

It is proposed that WVO be imported (approximately 166 900 tons per year) and processed to produce biodiesel (approximately 170 000 tons per year).

5 The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in notice no 544 of 2012 or included in the list of waste management activities published in terms of section 19 of NEMWA in which case that Act will apply.

In terms of the NEMAQA Section 21, an application for an Air Emissions Licence (AEL) will be required for the site.

26 Commencing of an activity, which requires an atmospheric license in terms of Section 21 of NEMAQA except where Activity 28 Notice 544 of 2010 applies.

In terms of the NEMAQA Section 21, an application for an AEL will be required for the site.

GN. 546 (Listing Notice 3) (BA required)

10 The construction of facilities or infrastructure for the storage or the storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres.

ii. Outside urban areas, in:

(ee) Critical Biodiversity Areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans;

(gg) Areas within 10km from national parks or world heritage sites or 5km from any other protected area identified in terms of the National Environmental Management Protected Areas Act

The site is located outside an urban area since the Municipal Spatial Development Framework has not been adopted by DEDEAT.

The site falls within a Critical Biodiversity Area as described within the Eastern Cape Biodiversity Conservation Plan (ECBCP).

The site is located within 10km from the Greater Addo Elephant National Park.

6

(NEMPAA) or from core areas or a biosphere reserve.

13 The clearance of vegetation of an area of 1 hectare or more of vegetation where 75% or more of vegetative cover constitutes indigenous vegetation

Critical biodiversity areas and ecological support areas as identified in systematic biodiversity plans adopted by the competent authority

(c) Areas within 10km from national parks or world heritage sites or 5 km from any other protected area identified in terms of NEMPAA or from core areas or a biosphere reserve.

The site falls within a Critical Biodiversity Area (CBA) described within the ECBCP.

The site is located within 10km from the Greater Addo Elephant National Park.

16 The construction of:

(iii) buildings with a footprint exceeding 10 square metres in size;

(iv) infrastructure covering 10 square metres or more

Where such construction occurs within a watercourse or within 32 metres of a watercourse, measures from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

iii. Outside urban areas

(ff) Core areas in biosphere reserves;

(hh) Areas within 10km from national parks or world heritage sites or 5km from any other protected area identified in terms of NEMPAA or from core areas or a biosphere reserve.

Basic Assessment for the proposed provision of landside structures and infrastructure to the bulk liquid storage and handling facility in the port of Ngqura within the Nelson Mandela Bay Municipality (NMBM) municipality in the Eastern Cape. DEA EIA Reference Number 14/12/16/3/3/1/675.

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

The new NEMAQA, which repeals the Atmospheric Pollution Prevention Act of 1965 (APPA), came into effect on 11 September 2005, with the promulgation of regulations in terms of certain sections resulting in the APPA being repealed entirely on 1 April 2010. Persons undertaking such activities are required to possess an AEL, essentially the equivalent of a Registration Certificate under the APPA.

Key features of the current legislation include:

A decentralisation of air quality management responsibilities;

The identification and quantification of significant emission sources that then need to be addressed;

The development of ambient air quality targets as goals for driving emission reductions;

The use of source-based (command-and-control) measures in addition to alternative measures, including market incentives and disincentives, voluntary programmes, and education and awareness;

The promotion of cost-optimized mitigation and management measures;

Stipulation of air quality management planning by authorities, and emission reduction and management Planning by sources; and

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Access to information and public consultation.

The NEMAQA introduced a management system based on ambient air quality standards and corresponding emission limits to achieve them. Two significant regulations stemming from NEMAQA have been promulgated recently, which are:

GNR 1210 on 24 December 2009 (Government Gazette 32816) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) National Ambient Air Quality Standards; and

GNR 893 on 22 November 2013 (Government Gazette 33064) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) List of Activities Which Result in Atmospheric Emissions Which Have or May Have a Significant Detrimental Effect on the Environment, Including Health, Social Conditions, Economic Conditions, Ecological Conditions or Cultural Heritage, an update to the original GNR 248.

The new national ambient standards for air quality were based primarily on guidance offered by two standards set by the South African National Standards (SANS), namely:

SANS 69:2004 Framework for implementing national ambient air quality standards; and

SANS 1929:2005 Ambient air quality – Limits for common pollutants.

SANS 69:2004 makes provision for the establishment of air quality objectives for the protection of human health and the environment as a whole. Such air quality objectives include limit values, alert thresholds and target values.

SANS 1929:2005 uses the provisions in SANS 69 to establish air quality objectives for the protection of human health and the environment, and stipulates that limit values are initially set to protect human health. The setting of such limit values represents the first step in a process to manage air quality and initiate a process to ultimately achieve acceptable air quality nationally. The limit values presented in this standard are to be used in air quality management but have only become enforceable as revised under GNR 1210 since 24 December 2009. National ambient air quality standards for criteria pollutants generally have specific averaging periods; compliance timeframes, permissible frequencies of exceedance and reference methods.

Pollutants of concern from the proposed biodiesel plant include nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), particulate matter (PM), volatile organic compounds (VOCs), methanol (CH4O) and hexane. The relevant South African standards against which the concentrations from the proposed plant will be assessed are presented in Table 5.

Table 5 South African National Ambient Air Quality Standards applicable to the biodiesel processing plant

Nitrogen Dioxide (NO2)

Averaging Period Concentration (µg/m3) Frequency of Exceedance Compliance Date

Hourly 200 88 Immediate

Annual 40 0 Immediate

Sulphur Dioxide (SO2)


10 min 500 526 Immediate


Daily 125 4 Immediate


Carbon Monoxide (CO)


Hourly 30 000 88 Immediate

8 Hourly 10 000 11 Immediate

Particulate Matter (PM10)

8


Daily 120 4 Immediate – 31/12/2014

Annual 50 0 Immediate – 31/12/2014

According to the NEMAQA listed activities, VOC emissions from the biodiesel storage tanks onsite are regulated under subcategory 2.4: The Storage and Handling of Petroleum Products. Category 2 relates to the production of gaseous and liquid fuels as well as petrochemical from crude oil, coal, gas and biomass. Where biomass is described as “non-fossilised and biodegradable organic material originating from plants, animals and microorganisms”. WVO will therefore be seen as originating from plants and the animal fat from animals. The feedstock used on site will therefore fall within the definition of biomass. According to the Petroleum Product Act (Act No. 120 of 1977), a petroleum product is “any petroleum fuel and any lubricant, whether used or unused, and includes any other substance which may be used for a purpose for which petroleum fuel or any lubricant may be used”. The biodiesel produced on site can either be used as fuel for vehicles in its pure form or used as part of a petroleum product blend (consisting out of petroleum petrol or diesel and biodiesel). The biodiesel produced on site is therefore seen as a petroleum product since it can be utilised for the purpose for which a petroleum fuel is used for. The special arrangements that apply for storage vessels of any petroleum products are presented in Table 6.

Table 6: Storage specifications for petroleum liquids products (NEMAQA, listed activities, Category 2: Petroleum Industry, Subcategory 2.4)

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

True vapour pressure of contents at product storage temperature

Type of tank or vessel

Type1: Up to 14 kPa Fixed-roof tank vented to atmosphere, or as per Type 2 and 3

Type 2: Above 14 kPa and up to 91 kPa with a throughput of less than 50,000 m³ per annum

Fixed-roof tank with Pressure Vacuum Vents fitted as a minimum, to prevent “breathing” losses, or as per Type 3

Type 3: Above 14 kPa and up to 91 kPa with a throughput greater than 50,000 m³ per annum

a) External floating-roof tank with primary rim seal and secondary rim seal for tank with a diameter greater than 20 m, or

b) Fixed-roof tank with internal floating deck / roof fitted with primary seal, or

c) Fixed-roof tank with vapour recovery system.

Type 4: Above 91 kPa Pressure vessel

The biodiesel storage tanks at the FIS facility will have a cumulative tankage capacity of greater than 1 000m³ (i.e. 25 760m

3), thus the above specifications will need to be followed.

Minimum emission standards for VOCs as set out in the listed activities apply to all installations with a throughput of greater than 50 000m³ per annum of products and with a vapour pressure of greater than 14kPa. These installations also need to be fitted with vapour recovery units. Although the biodiesel throughput at the FIS facility exceeds the 50 000m³ threshold, the biodiesel stored has a vapour pressure of less than 14kPa, thus the minimum emission standards will not apply to the FIS facility.

Methanol and hexane are listed as hazardous air pollutants (HAP) in the United States Clean Air Act Amendments of 1990 (US EPA, 1994), however, there are currently no South African standards for their assessment in ambient air. Concentrations will therefore be assessed against international environmental and occupational health and safety guidelines as presented in Table 7 and Table 8.

9

Table 7: International air quality standards and guidelines for methanol

Averaging Period UK IPPC Environmental Assessment Level

Occupational Safety and Health Administration (OSHA)

National Institute for Occupational Safety and Health (NIOSH)

Ontario’s Ambient Air Quality Criteria

Government of Alberta Air Quality Guidelines

Immediate danger to life and health

7 860 000 µg/m3

15 minute 325 000 µg/m3

Hourly 33 300 µg/m3 2 600 µg/m

3

8-hr 260 000 µg/m3 260 000 µg/m

3

Daily 4 000 µg/m3

Annual 2 660 µg/m3

Table 8: International air quality standards and guidelines for hexane

Averaging Period US EPA Vermont Agency of Natural Resources

OSHA NIOSH

8-hr 1,800,000 µg/m3 180,000 µg/m

3

Daily 4,300 µg/m3

Annual 200 µg/m3

According to the NEMAQA listed activities, methanol and hexane as VOCs are regulated under Category 6: Organic Chemical Industry. The relevant standards for cumulative VOC emissions from the biodiesel production process are presented in Table 9.

Table 9: Minimum emission standards associated with the organic chemicals industry (NEMAQA, listed activities, Category 6: Organic Chemicals Industry)

Description: The production or use in production of organic chemicals not specified elsewhere including acetylene, acetic, maleic, phtalic anhydride or their acids, carbon disulphide, pyridine, formaldehyde, acetaldehyde, acrolein and its derivatives, acrylonitrile and synthetic rubber.

The production of organometallic compounds, organic dyes and pigments, surface-active agent.

The polymerisation or co-polymerisation of any unsaturated hydrocarbons, substituted hydrocarbon (including vinyl chloride).

The manufacture, recovery or purification of acrylic acid or any ester of acrylic acid.

The use of toluene di-isocyanate or other di-isocyanate of comparable volatility; or recovery of pyridine.

Application: All installations producing or using more than 100 tons per annum of any of the listed compounds.

Substance or mixture of substances mg/Nm3 under

normal conditions of 273 Kelvin and 101.3kPa.

Common name Chemical symbol Plant status

Total volatile organic compounds (thermal)

N/A New 150

Existing 150

Total volatile organic compounds (non -thermal)

N/A New 40 000

Existing 40 000

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

NEMWA is subsidiary and supporting legislation to NEMA. The Act seeks to give legal effect to the White Paper on Integrated Pollution and Waste Management, and is a framework legislation that provides the basis for the regulation of waste management. The Act also contains policy elements and gives a mandate for further regulations to be promulgated. Of relevance to the project was GN: 718 (July 2009) which comprises a list of waste management activities that have or are likely to have a detrimental effect on the environment – activities contained in this list require a Waste Management Licence (WML) and in turn a Basic Assessment (Category A activities) or Scoping and EIA (Category B activities) in terms of the NEMA EIA Regulations.

1.4.7.1. New Waste Management License listed activities

On the 29th of November 2013 the Minister of Water and Environmental Affairs promulgated new Government

Notices (GN) in terms of the National Environmental Management: Waste Act (NEMWA) (Act No. 59 of 2008) and the National Environmental Management Act (NEMA) (Act No. 107 of 1998). The Government Notices that were promulgated are detailed below:

■ GN 921 NEMWA List of waste management activities that have, or are likely to have, a detrimental effect on the environment;

■ GN 922 NEMA Amendment to Environmental Impact Assessment Regulations, Listing Notice 1 of 2010; ■ GN 923 NEMA Amendment to Environmental Impact Assessment Regulations, Listing Notice 2 of 2010; ■ GN 924 NEMWA National Standards for the extraction, flaring or recovery of landfill gas; ■ GN 925 NEMWA National Standards for the scrapping or recovery of motor vehicles; and ■ GN 926 NEMWA National Standards for the storage of waste.

GN 921 repeals GN 718 which regulated waste activities that require a WML prior to the commencement of a listed waste activity. Two major changes have been made within the new GN regulating waste management activities. The first change is the addition of Category C which contains activities that, if triggered, do not require a WML but require adherence to the relevant Norms and Standards GN 924, 925 or 926. The activities relating to the storage of hazardous and/or general waste were moved to Category C (1-3). The Norms and Standards GN 926 regulates the storage of waste on site and stipulates that a site must be registered with the Department within 90 days prior to commencement of construction of the waste storage facility and adhere to the specifications listed within the Norms and Standards.

The second major change that has been made is the removal of activities Category A 3(11) and Category B 4(7) relating to the treatment of wastewater, sewage or effluent. These activities have been moved to the NEMA Regulations GN 922 (insertion to Listing Notice 1) and 923 (insertion to Listing Notice 2). The wording of the activities has changed so that only the construction of an effluent, wastewater or sewage treatment facilities with an exceedance of a certain throughput capacity require an authorisation and not the treatment activity itself. In addition to this, the thresholds have changed from 2 000m

3 per annum for a Basic

Assessment and 15 000m3 per annum for a Scoping/EIA process to 2 000m

3 per day and 15 000m

3 per day,

respectively.

Following the promulgation of the new GN pertaining to WML activities, some activities have been removed from the WML listed activities. The applicability of the activities that were initially included within the WML application according to GN 718 and the applicability thereof following the promulgation of GN 921 are outlined in Table 10.

Table 10: Waste Management License triggers

Clause GNR.718

Description Applicability and relevance in terms of GNR.921

Category A (1) The storage including the temporary storage of general waste at a facility that has the capacity to store in excess of 100 m

3 of

general waste at any one time, excluding the storage of hazardous waste in lagoons.

This activity is now listed as Category C (1) in the GN 921 and requires adherence to GN 926 NEMWA National Standards for the storage of waste.

Category A (2) The storage including the temporary storage of hazardous waste at a facility that has the capacity to store in excess of 35 m

3 of

This activity is now listed as Category C (2) in the GN 921, the threshold has been increased to 80m

3 of hazardous waste at

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Therefore according to GN 921 the FIS Biodiesel facility requires a waste management license in terms of the following listed activities:

Table 11: Listed activities as per GN 921

Activity No: Description of activity Applicability of activity:

Category B 3 The recovery of waste including the refining, utilisation, or co-processing of the waste at a facility that processes in excess of 100 tons of general waste per day or in excess of 1 ton of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises.

The FIS Biodiesel facility will process in excess of 100 tons of general waste (feedstock) per day and as such requires a WML.

As per section 1.4.7.2 animal fats are deemed general waste, based on the information provided, and as such the competent authority for this application the DEDEAT.

hazardous waste at any one time, excluding the storage of hazardous waste in lagoons.

any one time, and requires adherence to GN 926 NEMWA National Standards for the storage of waste.

Category A (7) The recycling or re-use of general waste of more than 10 tons per month.

Recycling of general waste has been moved to Category A (3) in GN 921. WVO is a general waste and, as per section 1.4.7.2, and animal fats are deemed general waste based on the information provided.

Awaiting response from the DEA Waste Directorate for confirmation (Section 1.4.7.3)

Category A (18) The construction of facilities for activities listed in Category A of this schedule.

The activity is still triggered and listed under Category A (12) in GN 921.

Category B (2) The reuse and recycling of hazardous waste.

Recycling of hazardous waste has been moved to Category B (2) in GN 921. As per section 1.4.7.2 animal fats are deemed general waste, based on the information provided, and as such this activity is no longer applicable.


Category B (7) The treatment of effluent, wastewater or sewage with an annual throughput capacity of 15 000 m

3 or more.

This activity is no longer listed within GN 921. The construction of a waste treatment facility has been moved to the NEMA EIA regulations and will be triggered if the treatment capacity of the treatment facility exceeds 2 000 m

3 per day. The

WWTW on the FIS facility will only be treating ~141 m

3 per day and therefore does

not trigger the listed EIA activities.

Category B (11) The construction of facilities for activities listed in Category B of this schedule.

As per section 1.4.7.2 animal fats are deemed general waste, based on the information provided, and as such this activity is no longer applicable.


12


Category B 10 The construction of a facility for a waste management activity listed in Category B of this schedule (not in isolation to associated waste management activity).

The FIS Biodiesel facility is a new facility that is required to be constructed and as such requires a WML.

Category C 1 The storage of general waste at a facility that has the capacity to store in excess of 100m

3 of general waste at any one time,

excluding the storage of waste in lagoons or temporary storage of waste.

The facility will have a storage capacity in excess of 100m

3 of general waste and as

such requires adherence to GN 926 NEMWA National Standards for the storage of waste.

As per section 1.4.7.2 animal fats are deemed general waste, based on the information provided, and as such does not trigger Category C 2 of GN 921 for the storage of hazardous waste.


1.4.7.2. Waste classification of feedstock

Waste Vegetable Oil

The current proposal for the FIS refinery is to import WVO from the USA. The current guideline used for the classification of waste is the Waste Classification and Management Regulations (GN 634, August 2013) which promulgates the methodology prescribed in South African National Standard (SANS) 10234:2008 ‘Globally Harmonised System of Classification and Labelling of Chemicals (GHS) (SANS 10234) for the classification of waste. WVO is not applicable to any of the classes listed within the SANS 10234 code and is not listed within the Basel convention as a hazardous substance and is therefore deemed general waste.

Animal Fats

It is suggested that future feedstock supply may include processed animal fats (i.e. tallow) derived from cattle, chicken, pigs and so forth. Animal fats are part of a wider group of animal by-products (ABPs) and are divided into three categories in terms of quality:

■ Category 1- High risk for human health;

■ Category 2- ABPs include manure and digestive tract content;

■ Category 3- ABPs that can be used for animal feed and cosmetics; and

■ Animal fats intended for human consumption.

Category 1 products contain Transmissible Spongiform Encephalopathy (TSE) which may affect the brain and nervous systems of animals and is not intended for human consumption. When products of different categories are mixed, the entire mix will be classified according to the lowest category in the mix. WSP consulted the following entities to further clarify what the waste classification of animal fats that may be used by FIS is:

■ South African Meat Industry Company (SAMIC), Mr Johan Heunis (Eastern Cape Inspector) confirmed that animal fats that are sourced from inspected and authorised abattoirs and chicken farms will not contain diseases. Therefore, if the animal fats are sourced from reputable and inspected abattoirs and chicken farms, then the animal fats will not be deemed hazardous. Animal fats from these sources are further used in other foods such as “boerewors”.

■ Department of Agriculture, Food Safety and Quality Assurance, Mr At van Wyk (Veterinarian Technician) said that the two factors to take into account are what animal fats will be used and how it will be stored on site. He further said that when a disease, such as foot-and-mouth disease breaks out in a certain area, any

13

animal meat/product supply from that area is banned. Therefore, if animal fats from those areas are not used, then the animal fats will not be deemed hazardous.

FIS confirmed that should they source animal fats, they will ensure that the proper supply chain management and control are in place in terms of storage and handling to manage the waste. Based on the information from SAMIC and the Department of Agriculture and confirmation from FIS that controls will be in place, it is assumed that the animal fats used at the FIS refinery will be deemed general waste.

1.4.7.3. Summary of WML application process

Initially, the Scoping Report indicated that WVO is deemed general waste while the animal fats that may be used on site in the future may contain diseases and therefore, following the precautionary approach, the animal fats waste stream was deemed hazardous (WSP, 2013)

2. As such, the WML application was submitted to the

DEA, the designated competent authority. The DEA acknowledged receipt on the 13th of December 2012

(Appendix B). Following the submission of the Scoping Report to the DEA, the DEA Waste Directorate queried the waste classification of the animal fat (tallow). More research was undertaken in terms of the source of the animal fats that may be used on site in the future. Following this, it was determined that if the animal fats are sourced from a controlled environment, the risk of any contamination, which would deem the animal fats to be hazardous, will be low (discussed below). Following this research, WSP sent a letter to DEA on the 23

rd of July

2013 detailing why the animal fats used on site will not be deemed hazardous waste, but would be classified as general waste (Appendix B). It was further requested that the WML application be withdrawn from the DEA, since the waste on site will be deemed general waste and according to NEMWA, the Member of the Executive Council (MEC) of a province is the licensing authority in respect of all activities listed in Category A and B of Schedule 1 of NEMWA pertaining to general waste, which would mean that the provincial authority, DEDEAT, is the competent authority. Proof of this letter being sent to the DEA is attached in Appendix B.

Subsequent to the letter being sent to the DEA, it was determined that the treatment of hazardous waste (treatment of approximately 51 000m

3 per annum of wastewater containing acids, methanol, biodiesel) will

occur on site which exceeds the 15 000m3

per annum treatment threshold of the listed activity Category B(7) relating to the treatment of wastewater. This activity therefore needed to be added to the WML application. Because of the treatment of hazardous waste, the WML application moved back to the DEA’s jurisdiction. A letter detailing this process was sent to the DEA on the 9

th of September 2013 (Appendix B). In this letter, it

was requested that the WML application not be withdrawn from the DEA. However, following the promulgation of GN 921 the construction of a waste treatment facility has been moved to the NEMA EIA regulations and as such is no longer applicable to the WML application.

The classification of animal fats was discussed at the CDC ELC meeting held on the 20th of February 2014

during which it was advised that written confirmation was to be obtained from the DEA clarifying this matter. It was concluded that the ELC would discuss the issue and revert to WSP with a response regarding the submission of the WML (refer to issues trail in Appendix H). To date WSP has not received any feedback from the ELC in this regard. WSP has attempted to obtain written confirmation from the DEA Waste Directorate confirming that animal fat is not deemed hazardous however; the DEA has not been willing to provide written confirmation, despite agreeing telephonically that animal fats are not deemed hazardous. WSP subsequently sent a letter to the DEA Waste Directorate, on the 15

th of May 2014 (Appendix B), again requesting

confirmation as to the competent authority to assess the WML application. WSP has not received a response from the DEA in this regard and as such the WML application will remain with the DEA Waste Directorate for assessment until such time as the EAP is advised otherwise.

2 Final Scoping Report, FIS Biofuels Facility, August 2013, WSP Environmental (Pty) Ltd

14

1.4.8. National Heritage Resources Act (Act No. 25 of 1999)

The National Heritage Resources Act (NHRA) stipulates within Section 38 (1)(c)(i) that any development which will change the character of a site exceeding 5 000m

2 in extent must notify the responsible heritage authority of

the proposed development and supply the authority with details regarding the project. The proposed project will be approximately 4ha (40 000m

2) in extent and would therefore require the Eastern Cape Provincial Heritage

Resources Authority (ECHRA) to comment on the proposed project. Proof of notification to ECHRA is attached in Appendix H. No comment has been received.

1.4.9. Nelson Mandela Bay Metropolitan Municipality: Air Pollution Control By-laws (LAN 33, GN 2322 of March 2010), Section 6

FIS will be installing two Heavy Fuel Oil (HFO) boilers on site; as such the relevant section of the by-law (Section 6) states the following:

Table 12: Section 6 of the NMBM: Air Pollution Control by-laws

6. Installation of fuel-burning equipment

(1) No person shall install, alter, extend or replace any fuel-burning equipment on any premises without the prior written authorisation of Council, which may only be given after consideration of the relevant plans and specifications.

(2) Any fuel-burning equipment installed, altered, extended or replaced on premises in accordance with plans and specifications submitted to and approved for the purposes of this section by the Council, shall be presumed until the contrary is proved to comply with the provisions of subsection (1).

(3) Where fuel-burning equipment has been installed, altered, extended or replaced on premises in contravention of subsection (1):

a) The owner and occupier of the premises and the installer of the fuel-burning equipment shall be guilty of an offence;

b) The municipality may, on written notice to the owner and occupier of the premises, order the removal of the fuel-burning equipment from the premises at the expense of the owner and operator and within the period stated in the notice.

According to the by-law “fuel burning equipment” is defined to means any furnace, boiler, incinerator, or other equipment, including a chimney —

(a) designed to burn or capable of burning liquid, gas or solid fuel;

(b) used to dispose of any material or waste by burning; or

(c) used to subject liquid, gas or solid fuel to any process involving the application of heat.

No person may use or operate any fuel-burning equipment on any premises contrary to the above authorisation; as such FIS will need to register the boilers with the municipality.

1.5. Objectives and Contents of the Environmental Impact Assessment Report

1.5.1. Objectives of the Environmental Impact Assessment Report

This Final EIA Report was preceded by a comprehensive scoping process that led to the submission of a Final Scoping Report (and Plan of Study for the EIA) to the Eastern Cape Provincial DEDEAT for approval. Approval was received on 23

rd August 2013 which marked the end of the Scoping phase, after which the EIA process

moved into the impact assessment and reporting phase.

15

The primary objective of this Final EIA Report is to present the competent authority, the DEDEAT, with an overview of the predicted impacts and associated management actions required to avoid or mitigate the negative impacts; or to enhance the benefits of the proposed project.

In terms of legal requirements, a crucial objective of the EIA Report is to satisfy the requirements of Regulations 31, 32 and 33 of the NEMA EIA Regulations of 18

th June 2010 which came into effect on

2nd

August 2010. These regulations regulate and prescribe the content of the EIA Report and specify the type of supporting information that must accompany the submission of the report to the authorities. An overview of where the requirements are addressed in this report is presented in Table 13.

Furthermore, this process is designed to satisfy the requirements of Regulations 55, 56 and 57 of the NEMA 2010 EIA Regulations relating to the public participation process and, specifically, the registration of and recording of submissions from interested and affected parties (I&APs).

The Draft Environmental Management Programme (EMPr) that is required as part of the EIA process (Regulation 33) is provided in Appendix C of the EIR.

1.5.2. Contents of the Environmental Impact Assessment Report

NEMA (Act No. 107 of 1998) and the EIA Regulations 2010 stipulate what should be contained within an Environmental Impact Report (EIR) in order for the competent authority to consider the application and reach a decision. Regulation 31(2) stipulates the details that should be included within an EIR; these are shown in Table 13.

Table 13: Contents of the EIR

Regulation 31(2) Requirement Reference in the EIR

(a)(i)(ii) Details of the EAP who compiled the report; and

The expertise of the EAP to carry out an environmental impact assessment

Section 1.2

CVs are attached in Appendix A

(b) A detailed description of the proposed activity Section 6

(c) A description of the property on which the activity is to be undertaken and the location of the activity

Section 2.5

(d) A description of the environment that may be affected by the activity and the manner in which the physical, biophysical, social, economic and cultural aspects of the environment may be affected by the proposed activity

Section 3

(e) Details of the public participation process (PPP) conducted in terms of sub regulation (1) including,

Steps to be undertaken in accordance with the Plan of Study

A list of persons, organisations and organs of state that were registered as interested and affected parties

A summary of comments received from, and a summary of issues raised by registered interested and affected parties, the date of receipt of these comments and the response of the EAP to those comments; and

Copies of any representations and comments received from registered interested and affected parties

Section 4

Proof of PPP Appendix H

(f) A description of the need and desirability of the proposed activity Section 2.2

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

Section 2.8

16

Regulation 31(2) Requirement Reference in the EIR

(h) An indication of the methodology used in determining the significance of potential environmental impacts

Section 5.2

(i) A description and comparative assessment of all alternatives identified during the environmental impact assessment process

Section 2.8

(j) A summary of the findings and recommendations of specialist reports or report on a specialised process

Section 6 to 12

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

Section 6 to 14

(l) An assessment of each identified potential significant impact, including-

Cumulative impacts

The nature of the impact

The extent and duration of the impact

The probability of the impact occurring

The degree to which the impact can be reversed

The degree to which the impact may cause irreplaceable loss of resources; and

The degree to which the impact can be mitigated

Section 6 to 14

(m) A description of any assumption, uncertainties and gaps in knowledge

Section 1.9

(n) A reasoned option as to whether the activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect to the authorisation

Section 16.4

(o) An environmental impact statement which contains

Summary of the key findings of the EIA; and

A comparative assessment of the positive and negative implications of the proposed

Section 16

(p) A Draft Environmental Management Programme containing the aspects contemplated in Regulation 33.

Appendix C

(q) Copies of any specialist studies that may be required by the competent authority

Appendix F

(s) Any other matters required in terms of sections 24(4)(1) and (b) of the Act.

N/A

1.6. Approach to the EIA

The Scoping and EIA processes have been undertaken in accordance with GN. R543 pertaining to applications subject to Scoping and EIA. The EIA process followed is depicted in Figure 1.

17

Figure 1: Environmental Impact Assessment (EIA) Process

The activities that have been carried out thus far as part of this EIA are as follows:

Submission of an application for Environmental Authorisation to the DEDEAT

o The prescribed EIA form (in terms of the activities identified within Section 4.2) was

submitted to the DEDEAT on the 24th of July 2012.

o DEDEAT acknowledged receipt of the application form in a letter dated 14th of August

2012 (reference number: ECm1/LN2/M/12-47)

Submission of an application for a WML to the DEA

o The WML application form was submitted to the DEA on the 4th of December 2012.

The DEA acknowledged receipt of the application form in a letter dated 13th of

December 2012 and provided the following reference number - DEA Reference:

12/9/11/L1124/1.

18

o The WML application will remain with the DEA Waste Directorate until such time as the

EAP is advised otherwise, refer to section 1.4.7 for further information regarding the

WML application.

Submission of an application for an AEL to the NMBM

o The AEL application form was submitted to the NMBM on the 4th of December 2012.

The NMBM acknowledged receipt of the application form in a letter dated 18th of

December 2012 (NMBM Reference: 19/2/9/2/1/2/L024-2.2/6.1).

o Part B of the AEL application form shall be submitted to the NMBM in due course.

Placement of advertisements of the EIA process in:

o The Herald (English) on 26th of July 2012; and

o Die Burger (Afrikaans) on 26th of July 2012.

Screening of E-Notice on the CDC’s electronic notice board in the foyer of the Coega Business

Centre from 26th of July 2012.

Recording of all issues raised in the CDC ELC meeting held on the 23rd

of August 2012 at the

DEDEAT’s offices in Port Elizabeth ;

Distribution of a Background Information Document (BID) to surrounding land owners and other

potential I&APs; the table of registered and notified I&APs is given in Appendix H.

Recording of all issues raised in the CDC ELC meeting held on the 14th of February 2013 at the

DEDEAT’s offices in Port Elizabeth (see summary of issues raised and responses to these in

Appendix H ;

Recording of all issues raised in response to the BID (see summary of issues raised and responses

to these in Appendix H);

Preparation of a Draft Scoping Report (DSR);

Notification of all registered I&APs and Stakeholders of the availability of the DSR and provided

with a 40 day comment period (5th of March 2013 to the 17

th of April 2013);

Recording of all issues raised in response to the DSR (see issues trail in Appendix H);

Collation of Stakeholders and I&APs comments on the DSR, and incorporation of these into the

Final Scoping Report (FSR);

Submission of the FSR and the Plan of Study for the EIA to DEDEAT for consideration and

approval. A copy of the letter of approval of the plan of study for the EIA is attached as

Appendix G

Notification of all registered I&APs and Stakeholders of the availability of the FSR on the 13th of

June 2013 for a period of 21 days (13th of June 2013 to the 4

th of July 2013). All Registered I&APs

were notified of the process of submission of comments related to the Final Scoping Report. Any

issues or comments on the Final Scoping Report were submitted directly to the authority, with

copies being provided to WSP. The comments received on the Final Scoping Report are included

in issues trail attached in Appendix H.

Appointment of specialists to conduct specialist studies, as per the terms of reference included in

the Plan of study for EIA, namely:

Specialist Study Specialist Organisation

Air Quality Impact Assessment


Storm Water Management Plan


Waste Management Best Barry Roberts WSP Environmental

19

Specialist Study Specialist Organisation

Practicable Assessment

Ecological Impact Assessment Tarryn Martin Coastal & Environmental Services

Traffic Impact Assessment Christo Bredenhann WSP Group

Major Hazardous Installation Terence Thackwray MHR Consultants

Compilation of the draft Environmental Impact Report (DEIR)

The specialist studies undertaken during the EIA phase were informed by the issues identified in

the FSR as well as the comments from DEDEAT in the acceptance letter of the FSR and Plan of

Study for the EIA. Results from those studies were incorporated into the draft EIR, particularly into

the impact assessments (Sections 6 to 14) and the draft EMPr (Appendix C).

Recording of all issues raised in the CDC ELC meeting held on 22nd

of August 2013 (Appendix H);

Recording of all issues raised in the CDC ELC meeting held on 20th of February 2014 in which the

findings of the draft EIR were presented (Appendix H);

Submission of draft EIR to authorities and notification of all registered I&APs, Stakeholders,

identified government departments and all other members of the CDC ELC on the 21st

of May 2014

and provision of a 40-day comment period;

Responding to all comments received on the draft EIR by means of an Issues Trail in the final EIR

(Appendix H), and where required, making amendments in the EIR to accurately reflect

responses;

Notification of all registered I&APs of the availability of the FEIR for a final 21 day comment period

for all registered I&APs and stakeholders to ensure that the comments provided on the draft EIR

have been adequately addressed in the final EIR (this report).

Activities that will still be carried out in completing this EIA process are as follows:

Submission of Part B of the Atmospheric Emissions License Application to the NMBM;

Submission of the FEIR to DEDEAT for a decision, and notifying all registered I&APs of the

submission and the responses to comments received; and

Notifying all registered I&APs of DEDEAT’s decision.

1.7. Assessment of Alternatives

In terms of Chapter 3, Section 29 (1)(c) of the NEMA EIA Regulations, a description of all feasible and reasonable alternatives were identified; these include alternative sites, alternative technologies, as well as fundamental alternatives viz. the no-project option. Alternatives are detailed in Section 2.8 below.

1.8. Technical Project Description

A review of available project information was undertaken to develop an understanding of its technical aspects. This involved correspondence with the technical project team, and a review of technical documents and process flow diagrams (Section 2).

1.9. Assumptions and Limitations

The following assumptions have been made during the EIA process and in the compilation of this document:

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That, due to the cost of preparing detailed designs and plans, such detailed design/planning information would only be developed in the event of Environmental Authorisation being granted. As such, it is anticipated that, as is typically the case in an EIA process, the EIA will assess preliminary engineering / process designs based on the HeroBX plant located in USA;

That the comments received in response to the public participation programme so far, are representative of comments from the broader community.

1.10. Assessment of the report

Before the proposed project can proceed, the Environmental Impact Assessment must be considered and DEDEAT must make a decision regarding the acceptability of the project, based on the available information identified and obtained during the EIA process.

In the spirit of cooperative governance, DEDEAT will consult with the Environmental Liaison Committee (ELC) which includes the following organisations:

Department of Environmental Affairs (DEA);

DEA: Ocean and Coast;

Coega Development Corporation (CDC);

Transnet National Ports Authority (TNPA);

Nelson Mandela Bay Municipality (NMBM); and

Department of Water Affairs (DWA).

WSP has therefore also distributed an electronic copy of the FEIR to all the members of the ELC.

1.11. Structure of the report

Chapter 1 Introduction

Provides an introduction and background to the proposed project, summarises the qualifications and experience of the EAPs and outlines the approach to the study. Also provides a brief summary and interpretation of the relevant legislation.

Chapter 2 Project Description

Describes the various components of, and the motivation for, the proposed FIS Biodiesel facility including the process description and the assessment of alternatives.

Chapter 3 Description of the Receiving Environment

Briefly describes the biophysical and socio-economic receiving environments that DEDEAT will consider in their assessment of the project.

Chapter 4 Public Participation Process

Describes the PPP followed, and the issues & concerns that have been raised by I&APs.

Chapter 5 Assessment of Environmental Impacts

Identification of potential environmental impacts associated with the proposed project and the Impact Rating Methodology.

Chapter 6 Air Quality Impact Assessment

Chapter 7 Storm Water Management Plan

Chapter 8 Solid Waste Generation

Chapter 9 Ecological Impact Assessment

Chapter 10 Traffic Generation and Site Access

Chapter 11 MHI Quantitative Risk Assessment

21

Chapter 12 Heritage Statement

Chapter 13 Socio-economic Impacts

Chapter 14 Noise Impacts

Chapter 15 Visual Impact Statement

Chapter 16 Findings, Evaluation and Recommendations

The principal findings are presented in this chapter, followed by a discussion of the key factors DEDEAT will have to consider in order to make a decision in the interests of sustainable development.

Chapter 17 The Way Forward

Describes the subsequent steps to be undertaken in the EIA process.

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2. Project Description

2.1. Terms of Reference

FIS wishes to establish a biodiesel refinery in the Coega Industrial Development Zone (IDZ), Eastern Cape. The goal of the facility is to produce methyl esters (biodiesel) using WVO and possibly processed animal fat. The proposed facility will have a production capacity of approximately 170 000 tons per annum and various reagents will be used to facilitate the manufacturing process.

Biodiesel is diesel fuel produced from organic sources such as corn oil or waste oils and fats such as those from fast food outlets or animal food processing facilities. These organic oils are transformed during a chemical process into fuel that has the ability to directly power diesel engine cars, trucks, and buses without modification. Biodiesel is important because it is a renewable fuel that produces significantly less greenhouse gas and carbon emissions than traditional fossil-based diesel fuel.

In the absence of a reliable local feedstock supplier and the maturity of the United States of America (USA) industry, FIS will import the feedstock consisting primarily of WVO from the USA and export the entire production supply to Europe. FIS has future plans to investigate the potential for local sources of reliable feedstock which will consist of WVO and animal fat. WVO are generally processed and used in the production of products and do not contain toxic substances. Animal fats are part of a wider group of ABPs and are divided into three categories in terms of quality and health risk to humans. FIS has confirmed that the animal fats to be used at the facility will be sourced from a controlled environment and appropriate supply chain management to ensure that the animal fats to be used on site are from controlled environments.

The current project proposal is to import the feedstock from the USA, pump it from the Port of Ngqura via a pipeline from the berth to the Oiltanking Grindrod Calulo (Pty) Ltd (OTGC) tank farm and then to the FIS site in Zone 7 of the Coega IDZ. Should the local feedstock supply become more viable, FIS will consider sourcing the feedstock locally in future. This will be dependent on the quality and quantity of feedstock available as well as the South African Government’s legislation relating to biodiesel and biodiesel blending. The feedstock, which will consist of a combination of WVO and animal fats, will be transported via pipeline, however; should the FIS facility become operational prior to the OTGC tank site being in operation, trucks will be used as a temporary measure to transport the feedstock to the site. All materials used on site to facilitate the production of biodiesel will be transported mainly to site via trucks. Several storage tanks will be constructed on site which will store the various materials required for the production of biodiesel. The biodiesel produced will be transported via pipeline (or via trucks as a temporary measure, if required) to the Port for export to Europe. The site will have a Storm Water Management Plan (SWMP), an Environmental Management Programme (EMPr) and an Alien Invasive Management Plan to manage key environmental impacts associated with the facility.

The proposed project triggers scheduled activities in terms of the NEMA and EIA Regulations 2010. Listed activities are also triggered in terms of the NEMAQA (Act No 39 of 2004) and the (NEMWA (Act No 59 of 2008). The project will therefore require Environmental Authorisation (EA) from the DEDEAT, a WML from the National DEA and an AEL from the NMBM.

While a number of different authorisations are required (an EA, a WML and AEL), the assessment process must be undertaken in accordance with the requirements stipulated within the EIA Regulations. To this end, a single Scoping/EIA process will be undertaken which encompasses all the relevant legislative requirements.

2.2. Need and Desirability

The DEDEAT published a guideline on August 2010 that lists specific questions to determine the need and desirability of proposed developments. While this is currently not a strict requirement at national level (i.e. not one of the national DEA requirements), this checklist is a useful tool in addressing specific questions relating to the need and desirability of the project. Table 14 discusses the need and desirability of the proposed FIS biodiesel facility.

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Table 14: Need and Desirability of the Proposed FIS Biodiesel Facility

Is the land use (associated with the activity being applied for) considered within the timeframe intended by the existing approved Spatial Development Framework (SDF) agreed to by the relevant environmental authority? (i.e. is the proposed development in line with the projects and programmes identified as priorities within the Integrated Development Plan (IDP).

Both the IDP (2006 – 2011) and SDF speak of the IDZ (i.e. the vision for an IDZ is incorporated within and aligned to these strategic documents). Within the IDZ, the facility is proposed for Zone 7, intended as the chemical and petrochemical industrial cluster. Hence the proposed FIS facility is appropriately aligned with the SDF and IDP.

Should development, or if applicable, expansion of the town/area concerned in terms of this land-use (associated with the activity being applied for) occur here at this point in time?

FIS wishes to establish the biodiesel facility in the Coega IDZ (appropriately zoned for this type of land-use) and to commence with construction and operation prior to October 2015 in order to be able to contribute to the Department of Energy’s mandatory blending regulations which will come into effect on this date. Therefore, the development needs to take place for FIS to be able to contribute to this. In addition, the FIS facility requires both access to port and roads for material and feedstock transfer which makes the site selected within the IDZ ideally located.

Does the community/area need the activity and the associated land-use concerned (is it a societal priority)? This refers to the strategic as well as local level (e.g. development is a national priority, but within a specific local context it could be inappropriate).

Locally, the facility will create 17 permanent jobs and a number of semi-permanent jobs. Further jobs may be created in future should the facility switch to local suppliers of WVO. The proposed development will contribute to the overall IDZ development, which is key for the local economy. Furthermore, the Eastern Cape Development Corporation (ECDC) is in the process of establishing a biofuels strategy for the Eastern Cape, and having the FIS facility located in the province will no doubt help strengthen this vision.

From a national perspective the South African government gazetted regulations on the 23rd

of August 2012 regarding the mandatory blending of biofuels with petrol and diesel. The regulations envisage that all petrol and diesel supplied to a blending facility should allow for blending of biofuels with a minimum concentration of 5% of biodiesel. The Department of Energy (DoE) stated on the 2

nd of October 2013 that the mandatory blending of

fuels will be effective from the 1st of October 2015. To this end, FIS seeks to establish a significant presence in

South Africa for the refinement and sale of biodiesel prior to the South African government mandated 5% blend being legislated. Following this, FIS will re-examine its position to potentially supply biodiesel to the South African market. Therefore, the establishment of the facility will contribute to the objectives set by the DoE.

It is further noted that the establishment of a biofuel facility using waste product as feedstock is well aligned with the general principles of sustainable development, and is also aligned with various strategic national policy documents including the National Climate Change Response White Paper (DEA, 2011) (i.e. reducing greenhouse gas emissions) and the NSDS (DEA, 2011) (i.e. Priority 3: Towards a Green Economy and Priority 5: Responding Effectively to Climate Change).

Are the necessary services with appropriate capacity currently available (at the time of application), or must additional capacity be created to cater for the development?

The CDC will provide the site with the necessary services. All the services are not in place at this moment but the CDC have intermediate plans until the service is up and running.

Is this development provided for in the infrastructure planning, and if not what will be the implication on the infrastructure planning (priority and placement of services)?

The development falls within the Coega IDZ which is a premier location for new industrial investments in South Africa. The IDZ covers an area of approximately 11 000 hectares of which approximately 8 690 hectares are available for development. The IDZ constitutes a phased development which is focused around industry clusters and has been divided into a total of 14 different zones. Sectors which have been identified for the IDZ consist of Automotive, Agro-Processing, Metallurgical, Educational and Training, Petrochemical and Chemical, General Manufacturing, Business Process Outsourcing and Energy. The proximity of the IDZ to the newly established deep water Port of Ngqura, as well as major transport routes connecting to other predominant

24

development centres such as Johannesburg and Cape Town, creates a platform for global exports by attracting foreign and local investment in manufacturing as well as export orientated and other industries

3.

The preferred site is located within Zone 7 (Chemical and Petrochemical Cluster). This Zone is specifically earmarked for medium to heavy industry and has adequate service provision to service the site (implementation of services to be finalised by CDC). These services are provided by the CDC. The site in Zone 7 is ideally situated to ensure that the feedstock and materials required as part of the production of biodiesel can be either obtained via a pipeline from the OTGC facility/berth or transported via road to the site.

Is the development the best practicable environmental option (BPEO) for this land/site?

The site selection process was based on the following criteria, in line with FIS’ main needs:

■ Access to both main roads and a port; ■ 4ha of developable land available; ■ Industrial zoning; and ■ Economically feasible in terms acquiring the land and construction of infrastructure.

The preferred site is located within Zone 7 (Chemical and Petrochemical Cluster). This Zone is specifically earmarked for medium to heavy industry. Broadly speaking, the FIS facility aligns strongly with national sustainability objectives, namely the development of the Green Economy within South Africa. In this sense, the FIS facility may be viewed as a superior environmental option to “traditional” chemical industrial facilities that may otherwise be established in the IDZ.

Would the approval of this application compromise the integrity of the existing approved IDP and SDF agreed to by the relevant environmental authority.

The proposed project will be situated within the chemical cluster zone within the CDC IDZ, and hence the initiative is fully aligned with local spatial and strategic planning initiatives, as agreed to by the environmental and other authorities. It will be constructed and will operate in line with relevant national and international specifications and best practice procedures. The proposed project will also follow the guidelines and specifications compiled for tenants within the IDZ compiled by CDC.

Do location factors favour this land-use (associated with the activity applied for) at this place? (this relates to the contextualization of the proposed land use on this site within its broader context).

The proposed site location (Zone 7 chemical cluster within the CDC IDZ) is specifically earmarked for industrial developments such as FIS. The site in Zone 7 is ideally situated to ensure that the feedstock and materials required as part of the production of biodiesel can be either obtained via a pipeline from the berth or transported via road to the site.

How will the activity or the land use associated with the activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

The Ecological Impact Assessment attached in Appendix F shows that due to the small footprint of the proposed project, it is anticipated that many of the impacts will be reduced with effective management of the site as well as the utilization of rehabilitation post-construction. Species of Special Concern (SSC) were noted within the site boundary. These plant SSC will be identified and rescued before building commences, which will mean that there will be a low-medium impact and not a medium to high (pre-mitigation impact significance rating) impact on the vegetation.

From a cultural/heritage aspect, is has not been found that the site will have an impact on any cultural/heritage areas/sites presented within the Coega IDZ, however; mitigation measures have been included in the EMPr to minimise or prevent any potential impacts that may occur.

How will the development impact on people’s health and wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc.)?

Emissions from the onsite boilers include nitrogen oxides, carbon monoxide (CO), sulphur dioxide and particulate matter, which are emitted as a result of the combustion of HFO within the boilers. Emissions from the atmospheric vent system include VOCs, methanol and hexane. Methanol is created during the biodiesel

3 CSIR, 2012, PhytoAmandla Biofuel Processing Plant in the Coega IDZ. Draft Environmental Impact Assessment Report

25

production process and may escape the vent recovery system and be emitted into the atmosphere. Trace amounts of hexane may be emitted from the vent recovery system. Hexane is used in the oilseed production process to remove oil from seeds/beans and some residual hexane may remain in the oil feedstock that is then utilised in the biodiesel production process. With the appropriate abatement measures proposed to be implemented on site, the health impacts are considered to be low.

Although the probability of a visual impact is definite, the proposed refinery is in keeping with the intended use, activities and industries proposed to occur within this zone and the CDC Architectural and Landscaping guideline will be complied with during the design phase of the facility. The refinery will therefore fit into the future “sense of place”. Based on correspondence received from the HeroBX plant, the facility on which the FIS facility will be based on, no complaints have been received from their neighbouring properties in terms of noise and/or odours.

Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs?

The site location is zoned specifically for the type of industry represented by FIS (i.e. the chemical and petrochemical cluster). The FIS facility aligns to national objectives such as the development of the Green Economy within South Africa (Priorities 3 and 5 of the NSDS). Should the facility not go ahead, there is no guarantee that any replacement facility will align to the NSDS in such a fashion. As stated before, FIS is aiming to establish themselves in the South African market and to be able to produce biodiesel that will feed into the mandatory blending requirements set by the Department of Energy. To this end, this will be a lost opportunity to South Africa to meet their blending objectives, once promulgated in October 2015.

Will the proposed land-use result in unacceptable cumulative impacts?

Specialist studies have been undertaken covering the following areas of concern:

■ Air Quality ■ Ecological ■ Waste Management ■ Traffic Generation

■ MHI Risk Assessment

■ Heritage ■ Visual Impact ■ Storm Water Management

The cumulative impacts are deemed acceptable with all impacts being considered of less than “medium” (or moderate) significance, post-mitigation.

2.3. Project Motivation

The production and supply of biodiesel is a controversial subject because crops such as maize (corn), sugar cane or other vegetable oil producing crops can either be used as food or in the production of biofuels. The biodiesel to be produced at the proposed FIS refinery will utilise feedstock sourced from organic sources such as WVO and fats from fast food outlets or animal food processing facilities. These are classified as waste and are unfit for human consumption. Consequently, the production of biodiesel from waste products such as WVO, largely sidesteps any such controversy related to the “fuel versus food” debate, and may be viewed as best environmental practice whereby waste is recycled rather than disposed of, in accordance with the waste management hierarchy (NEMWA 2008). In the case of biodiesel, such waste recycling has the additional benefit of reducing global greenhouse gas emissions associated with fuel combustion for mobile transport. In this regard, the project may also be viewed as supporting broader national government policy such as the National Climate Change Response White Paper and two of the five key priorities of the NSSD, as approved by cabinet, which talk to the development of the Green Economy and the effective management of climate change impacts.

The current proposal is to import the feedstock required for the production of the biodiesel from the USA. The feedstock will be converted through various processes (transesterification) to biodiesel and the current plans are for the full production supply to be exported to Europe. The European Union (EU) has set itself the binding target of sourcing 10% of its fuel from renewable sources which include biofuels by 2020 (Keating, 2012)

4.

There is therefore a market to export biodiesel to the EU in order for it to meet its targets. Thus, under this

4 Keating, D. (2012) Second thoughts on biofuel, EuropeanVoice, 27 September 2012, p 24.

26

scenario, while the project would not directly benefit local suppliers or diesel consumers, the project nevertheless has the economic benefit of boosting South African exports.

Future plans for the refinery entail using local supply of feedstock in FIS’s biodiesel manufacturing process which will consist out of WVO and, potentially, processed animal fats. Both of these are wastes which currently either end up on waste disposal sites or are used in pet food, cow fodder and chicken feed. Currently, the supply-side component of the WVO and animal fats to biofuel market is not regarded as sufficiently well developed to provide a commercially secure resource for FIS. However the establishment of FIS in the Coega IDZ will provide an incentive for the development of such a supply-side market by ensuring that there is a local buyer available for these wastes. There are therefore significant opportunities for the South African market to supply WVO and animal fat feedstock, even if the current supply is not sufficiently well developed to meet FIS’s production and commercial requirements.

Biodiesel contains no petroleum but can be blended into petroleum diesel to create a biodiesel blend (Wilson et al., 2005)

5. The South African government has gazetted regulations on the 23

rd of August 2012 regarding the

mandatory blending of biofuels with petrol and diesel. The regulations envisage that all petrol and diesel supplied to a blending facility should allow for blending of biofuels with a minimum concentration of 5% of biodiesel. The Department of Energy stated on the 2

nd of October 2013 that the mandatory blending of fuels will

be effective from the 1st of October 2015. To this end, FIS seeks to establish a significant presence in South

Africa for the refinement and sale of biodiesel once the South African government mandated 5% blend has been legislated. Following this, FIS will re-examine its position to potentially supply biodiesel to the South African market.

2.4. Site Determination

Since the proposal of transporting the feedstock to the site can rely on two main sources i.e. local feedstock (transported via road) or international feedstock supply (transported via ship to port), access to both harbour and major roads played an important role in the site selection undertaken by FIS. In addition, the facility requires a minimum area of 4ha for the facility’s development footprint. Based on the access requirements of the facility and the size of the development footprint, it was deemed that only a site located in an Industrial Development Zone (IDZ) which has access to both a port and road will be suitable for this type of operation. The first IDZ that was deemed suitable for the specific requirements was the Richards Bay IDZ. The IDZ did not have a site available that was 4ha in size and discussions were undertaken with another company who wanted to establish a liquid bulk storage facility in the IDZ and had 35ha area, of which they only required 30ha, and who were consequently willing to go into partnership with FIS. Following investigation, the partnership was deemed commercially feasible and therefore the Richards Bay IDZ was deemed to be a non-viable option.

The Coega IDZ was then investigated as a potential option and was deemed suitable for FIS’s requirements. The Coega IDZ is a premier location for new industrial investments in South Africa. It covers an area of approximately 11 000ha which approximately 8 690ha are available for development. The Coega IDZ constitutes a phased development which is focused around industry clusters and has been divided into a total of 14 different zones. Sectors which have been identified for the IDZ consist of Automotive, Agro-Processing, Metallurgical, Educational and Training, Petrochemical and Chemical, General Manufacturing, Business Process Outsourcing, and Energy. The proximity of the IDZ to the newly established deep water Port of Ngqura, as well as access to major overland transport routes (i.e. the N2) to other predominant development centres, such as Johannesburg and Cape Town, creates a platform for global exports by attracting foreign and local investment in manufacturing as well as export orientated and other industries

6.

The preferred site is therefore located within Zone 7 (Chemical and Petrochemical Cluster). This Zone is specifically earmarked for medium to heavy industry and has adequate service provision to service the site. These services are provided by the CDC. The site in Zone 7 is ideally situated to ensure that the feedstock and materials required as part of the production of biodiesel can be either obtained via a pipeline from the berth or transported via road to the site.

5 Wilson, S. C., Matthew, M., Austin, G. & von Blottnitz, H. 2005. Review of the Status of Biodiesel Related Activities in South Africa. Report for the City of Cape

Town, South Africa. pp 76.

6 CSIR, 2012, PhytoAmandla Biofuel Processing Plant in the Coega IDZ. Draft Environmental Impact Assessment Report

27

2.5. Site Locality

The proposed site (Figure 2) is located within Zone 7 of the Coega IDZ (coordinates provided in Table 15), which is situated in close proximity to Motherwell and Port Elizabeth (A site locality map is attached in Appendix D). The IDZ has fourteen zones, each of which are earmarked for specific clusters and activities; Zone 7 is the Chemical and Petrochemical cluster. This zone will have medium to high intensity industries which will include activities such as the handling of bulk commodities, petrochemical works and refineries. The site is easily accessible from the N2 and is located within close proximity to the Port of Ngqura. The locality of the site means that materials and feedstock required for the production of biodiesel on site can either be sourced via road or via pipeline connected to the proposed OTGC tank farm located in Zone 8 (Port Area) or pumped directly from the port to site. The biodiesel produced on site will also be transported via pipeline and/or trucks.

Table 15: Coordinates of the site

Corner Point Latitude Longitude

Northern corner 33°46'09.34"S 25°42'03.73"E

Western corner 33°46'14.16"S 25°41'55.43"E

Southern corner 33°46'20.55"S 25°42'00.42"E

Eastern corner 33°46'14.55"S 25°42'09.06"E

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Figure 2a: Project locality map of the proposed site.

29

Figure 2b: Boundary of the proposed site.

30

2.6. Facility Description

The proposed layout will be based upon the HeroBX plant located in the USA. A detailed design of the plant process is therefore available but would need to be adapted to the site’s specific conditions (such as piping requirements and geotechnical information) once Environmental Authorisation has been obtained. The site will have a footprint of 4ha. A conceptual layout model of the proposed facility is provided in Figure 3.

Figure 3: Conceptual layout model of the proposed FIS facility (BCS Holding Company (Pty) Ltd, 2012)

2.6.1. Facility layout and design

The following infrastructure will be present on site:

■ Buildings

Transesterification Building (17m in height);

Wastewater Treatment Building (13m in height);

Filter Building (7m in height);

Pre-treatment Building (13m in height);

Pre-treatment Building Tower (31m in height); and

Office and Administration Building (6m in height).

■ 26 External Above Ground Storage Tanks (ASTs) (Total storage capacity of 25 760 m3)

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■ Additional infrastructure

Fuel Boilers (Two boilers with a combined input capacity of less than 29MW), each individual boiler will have a maximum design capacity of 14.7 MW.

Aboveground internal pipelines (on-site);

Cooling towers;

Truck loading/offloading area;

Piping components; and

Aboveground external pipelines (±1km in length) from site to the OTGC tank farm.

The FIS facility will consist of three main areas, namely the pre-treatment area, the transesterification area and the tank farm, as shown in Figure 5. All these areas will be separately bunded. Bunding capacity will accommodate 110% of the largest tank’s volume present within the bund (as per SANS 10089), as a minimum. The various construction codes/standards that will be adhered to during the design and construction of the facility will include, inter alia, API650 for tanks, ASME B16.9 or 31.3, SANS 10089.

The contained tank farm area will have a secondary container liner underlying the entire tank farm. Leak detection under the tanks is a passive monitoring system consisting of pipes which pass through the ring wall foundation. No leak detection system will be on the pipelines but all pipelines (with the exception of the drainage lines within the containment area) will be above ground and therefore any leaks will be easily detected. Regular inspection of these lines will therefore occur to ensure that no leaks/spillages are present.

The site will have a fire detection system present on site. Seven units will be present on site, with five units present within the tank farm area and two units present at the loading/offloading area. Each one of these units has a 100m

2 coverage. The exact location of these units will be finalised during final engineering. As stated

previously, the proposed site will be based upon the design of the HeroBX plant located in the USA. Pictures taken of the HeroBX plant providing an indication of what the FIS facility will look like are presented in Figure 4. A preliminary site plan (Figure 5) is attached in Appendix D.

Figure 4: Photo pallet of the HeroBX plant. The photos show what the FIS facility will look like, from clockwise from top left, picture of the pre-treatment area, biodiesel storage tanks, office/administration building and internal pipelines.

32

Figure 5: Site layout plan (1:1500) of the proposed FIS refinery.

33

2.6.2. Operational hours

The project feasibility study (and hence the EIA) is based on an assumption that the facility will operate on a 24hr per day operating cycle. It is anticipated that the facility will be operational for 330 days per annum.

2.6.3. Wastewater management

Effluent produced by the facility will include, inter alia:

■ Boiler blow-down;

■ Pre-treatment wastewater;

■ Transesterification wastewater;

■ Tank farm area decanted water;

■ Air compressors; and

■ Sanitary sewer.

Effluent will be directed to the wastewater treatment building on site where it will be treated prior to discharge into the sewer. The water and sewage from the office building will connect to the treated wastewater line prior to discharge to the sewer. A basic water flow diagram showing approximate water requirements, basic water flow and processes connected to the wastewater treatment facility are shown in Figure 6. The daily water usage rates are based on the HeroBX’s process requirements, which will closely represent the amount of water required by the FIS facility. The water will be supplied by the NMBM.

A Wastewater Treatment Works (WWTW) is proposed to be constructed within Zone 9 of the Coega IDZ. FIS has considered the option of using Category 4 (industrial classification) return effluent generated by the WWTW on site, however; more testing and laboratory sampling would need to be undertaken to determine whether the quality of the Return Effluent is suitable to use for the production of biodiesel on the FIS site. The Category 4 compliance envelope in which the return effluent generated by the WWTW must fall is detailed in Table 16.

Table 16: Effluent Water Quality Requirements

Constituent Unit Industrial Cat 4 General Limit

Max Value Max Value

Alkalinity mg/l 1200 -

COD mg/l 75 75

pH 5-10 5.5-9.5

Suspended Solids mg/l 24 25

Total Dissolved Solids mg/l 1600 -

Total Hardness mg/l 1000 -

Electrical Conductivity mS/m - ≤150 above intake

Ammonia mg/l - 6

Nitrate mg/l - 15

O-phosphate mg/l - 10

Chlorides mg/l 500 -

34

Figure 6: Basic process water flow diagram (based on the HeroBX facility)

35

Sumps will be present at the truck loading/off-loading area, fatty acid stripping process tanks, transesterification area and pre-treatment area to collect wastewater, spills and/or oils that may occur within the bunded areas. The exact location of the sumps will be determined following the geotechnical study, site survey and final engineering services. As shown in Figure 6 all wastewater, which includes boiler blow-down, contents of the sumps and decanted water from the tank farm, will be piped to the onsite Wastewater Treatment (WWT) building. It is currently estimated that 141m

3 of wastewater will be treated daily. Wastewater will be treated to

an acceptable water quality level, according to the South African Water Quality Guidelines, so that it conforms to the NMBM’s effluent discharge quality standards so that is can be discharged into the municipal sewer system. The treatment process entails the adjustment of the pH of the wastewater to approximately 2.0 in order to split the oils from the water. The stream then goes into a separation tank where the oil comes off the top and is introduced back into the process while the water is pH adjusted to approximately 6.0 prior to being discharged to the municipal sewer. An effluent discharge permit from the CDC will be required prior to the discharge of effluent into the CDC sewer, it is noted that the CDC effluent standards are the same as required by the NMBM sewerage by-law. Other requirements for effluent water quality will be as per the CDC requirements

7 i.e. temperature of 44 degree Celsius or less, electrical conductivity of less than

500 milli-Siemens per m3 (at 25 degree Celsius). These requirements will form part of the CDC discharge

permit.

2.6.4. Materials Management

The main raw materials, intermediate products and final products associated with the project and stored in external tanks on site are summarised in Table 17. There will be three main tank farm areas, namely the Pre-Treatment Area, Transesterification Area and the Field Tank Farm. The materials and quantities of the materials required are only estimates and are based on HeroBX’s production information. The final list of materials stored on site will be finalised during the detailed design phase of the FIS facility, which will be undertaken following obtaining all the necessary approvals.

Table 17: Materials Summary

Material Storage Capacity (m

3)

Location on site Means of Transport Raw/ material/ Intermediate/ product/ Final product

Feedstock 2760.2 Field Tank Farm Pipeline/trucks Raw material

Feedstock 5286.7 Field Tank Farm Pipeline/trucks Raw material

Pretreating mix/hold of feedstock

260.9 Pre-treatment Tank Farm

N/A In process

Pretreating mix/hold of feedstock

93.2 Field Tank Farm N/A In process

Pretreating buffer tank of feedstock


N/A In process

Pretreated soybean oil tank*


N/A In process

Stripped oil tank 798.9 Pre-treatment Tank Farm

N/A In process

Esterified oil tank 430.4 Transesterification Tank Farm

N/A In process

Biodiesel quality control tank


Biodiesel finished 2671.2 Field Tank Farm Pipeline/trucks Final product

7 ref. Appendix C of the CDC Environmental Questionnaire for Investors, Oct 2012.

36

Material Storage Capacity (m

3)

Location on site Means of Transport Raw/ material/ Intermediate/ product/ Final product

product tank

Biodiesel finished product tank

5425.8 Field Tank Farm Pipeline/trucks Final product

Glycerine tank 361.7 Field Tank Farm Taken off site via truck/pipeline

In process

Methanol tank 554.6 Transesterification Tank Farm

Truck Raw material

Sodium Methoxide tank

199.9 Transesterification Tank Farm

Truck Raw material

98% high FFA tank 455.5 Pre-treatment Tank Farm

N/A In process

Boiler fuel tank 95.4 Pre-treatment Tank Farm

Truck Raw material

Glycerine rework tank


*these figures are based on the HeroBX plant. The FIS facility will not be using soybean as a feedstock.

2.6.5. Additional infrastructure: external pipelines

The current proposal is to pump the feedstock and biodiesel via pipelines from the OTGC tank farm to/from the FIS facility, and from the OTGC tank farm to/from the port berths. FIS will construct ±1km of pipelines within the adjacent CDC servitude and then within the Transnet Fuel Reserve to the OTGC tank farm. Because of the quality requirements applicable to biodiesel, the biodiesel produced cannot be contaminated (i.e. mixed with other substances) and therefore, a common line cannot be used for the import of feedstock and the export of biodiesel. The lines from the port will carry WVO for refining and will leave deposits in the line that cannot be cleaned easily. This requirement is also applicable to glycerine, although currently the proposal is to truck the glycerine to local buyers. Therefore at least two pipelines would need to be constructed from the OTGC tank farm to the FIS facility.

There are currently two studies being undertaken in the Coega IDZ, specifically within Zone 8 (located adjacent to Zone 7) that are applicable to the FIS facility proposed pipeline routing. Because the pipeline routes and impacts associated with the establishment of fuel reserves (i.e. fuel pipeline servitudes) have been assessed as part of other authorisation processes, no additional studies have been undertaken as part of this EIA. Details of the two assessments are provided in Table 18 below.

Table 18: Projects proposed in the Coega IDZ relevant to the FIS facility 8

Provision of Landside Structures and Infrastructure to the Proposed Bulk Liquid Storage and Handling Facility in the Port of Ngqura

Project Applicant Transnet SOC Limited

Project Reference Numbers

DEA EIA Reference Number: 14/12/16/3/3/1/675

NEAS Reference Number: DEA/EIA/0001386/2012

Type of application Basic Assessment

Status Environmental Authorisation issued on the 8th of January 2014

8 CSIR, 2013. Environmental Impact Assessment for the proposed Bulk Liquid Storage and Handling Facility in Zone 8 of the Coega Industrial Development

Zone (IDZ): Final Environmental Impact Assessment Report. CSIR Report Number: CSIR/CAS/EMS/ER/2011/0027/B.

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Link to the FIS Biodiesel EIA

This Basic Assessment was undertaken to assess the impacts of the following landside structures:

■ A new entrance facility towards the east of the Port of Ngqura; ■ An access road extending from the entrance facility to the proposed tank farm and

towards the berth in the Port of Ngqura; ■ Water, sewer and stormwater infrastructure (within the road reserve); ■ Servitude and reserve road for Bulk Liquids pipelines; ■ Fuel reserve for the proposed tank farm users; ■ Boundary fencing; and ■ Electrical services.

The fuel reserve that has been approved as part of the Basic Assessment will be used by the FIS facility as a routing area for the construction of their pipelines. The pipeline will either be constructed through the fuel reserves area to the OTGC tank farm or constructed to one of the berths.

EIA for the proposed Bulk Storage Liquid Storage and Handling Facility in Zone 8 of the Coega IDZ

Project Applicant Oiltanking Grindrod Calulo (Pty) Ltd

Project Reference Number

DEDEAT Reference Number: ECm1/LN2/M/11-57

Type of application Scoping/EIA

Status Environmental Authorisation issued on 27 March 2014

Link to the FIS Biodiesel EIA

The proposed bulk tank farm will be constructed within Zone 8 of the IDZ. FIS is proposing to connect to the bulk tank farm. The bulk tank farm will utilise the fuel and road reserves provided for by Transnet (the landowner) and the construction of these reserves were assessed within the Basic Assessment.

FIS is currently in negotiations with OTGC to connect to the bulk tank farm to be constructed in Zone 8. Please refer to letter attached in Appendix E.

2.6.5.1. Proposed bulk liquid storage and handling facility

Table 199 is taken from the Basic Assessment for the provision of landside structures and infrastructure to the

proposed bulk liquid storage and handling facility in the port of Ngqura within the Coega IDZ, Nelson Mandela Bay Municipality. The highlighted sections (in yellow) are the components of the project that are applicable to the FIS facility. These project components show that Transnet has made provision for additional tank farm users within the fuel reserves’ corridor width, this corridor is anticipated to be sufficient to accommodate all future additional investor pipelines.

It should be noted that the Basic Assessment only assessed the impacts associated with the construction of the fuel reserves and that the impact of the construction and operation of the pipelines within these reserves fell outside the scope of the Basic Assessment.

9 CSIR, 2013. Final Basic Assessment Report for the Provision of Landside Structures and Infrastructure to the Bulk Liquid Storage and Handling Facility in the

Port of Ngqura within the Coega IDZ, Nelson Mandela Bay Municipality, CSIR Report No. CSIR/CAS/EMS/ER/2012/0017/B.

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Table 19: Landside Structure and Infrastructure Basic Assessment project components and applicability to the FIS facility

2.6.5.2. Bulk Storage and Handling Facility

The EIA for the Bulk Storage and Handling Facility (hereafter referred to as the bulk tank farm) in Zone 8 of the Coega IDZ (DEDEAT Reference No: ECm1/LN2/M/11-57), will utilise the fuel and road reserves provided for by Transnet (the landowner) and the construction of these reserves were assessed within the Basic Assessment discussed above. Due to the fact that FIS’s pipelines will go over Transnet’s land, FIS will utilise these fuel reserves to connect to the bulk tank farm. FIS will either connect to the bulk tank farm, should the tank farm be operational and able to service FIS (and assuming a services agreement is concluded between OTGC and FIS), or FIS will truck the feedstock and materials from the berth to the facility.

There are two possible pipeline route options from the tank farm to the various berths, as shown in Figure 7. The Final EIA of the bulk tank farm indicates that the proposed pipeline can be routed via ‘Option 1’ to either A-Series Berth (which has not been constructed) or routed via ‘Option 2’ to the existing Berth B100 (shown on the map with the green and blue lines, respectively). The routing of the pipeline to Berth B100 (Option 2) will require that the pipelines cross over the Coega River. On the other hand, should the pipeline be routed to the A-Berth (Option 1), the pipeline will be much shorter, compared to the Berth B100 option, and will not need to cross the Coega River

10. As mentioned previously, the pipeline routing options have not been assessed within

this EIA since the construction of the pipelines and pumping of feedstock and materials to and from the tank farm have been assessed within the OTGC EIA. The pipeline routing options are therefore shown for indicative purposes only.

It is noted that should the FIS facility come on line prior to the OTGC tank farm and related pipeline infrastructure being in place and operational, tanker trucks will be used as a temporary measure for the transport of feedstock and biodiesel product to and from the FIS facility. The timing of when the proposed bulk tank farm is constructed within Zone 8 will therefore determine whether FIS will connect to the tank farm or whether FIS will truck feedstock, materials and from site from the Port of Ngqura and biodiesel to the Port for export. Should FIS obtain all the necessary authorisations to construct the facility, this will be undertaken in a phased approach, commencing with the construction of the facility and lastly the construction of the external pipelines.

10

CSIR, 2013. Environmental Impact Assessment for the proposed Bulk Liquid Storage and Handling Facility in Zone 8 of the Coega Industrial Development Zone (IDZ): Final Environmental Impact Assessment Report. CSIR Report Number: CSIR/CAS/EMS/ER/2011/0027/B.

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Figure 7: Pipeline route option from the bulk storage tank farm to the berths

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2.7. Process Description

The objective of the proposed facility is the production of methyl esters (ME), or ‘biodiesel’, using waste oils comprising used cooking oils, yellow grease, and animal fats (pork, poultry, fish, beef).

The proposed facility will have a production capacity of approximately 170 000 tons per annum and various reagents such as methanol, sodium methylate, silica, citric acid and sulphuric acid will be used to facilitate the manufacturing process. Solid waste generated on site during the operational phase will consist of domestic waste, mixed industrial waste (wood, plastic, non-contaminated material and so forth), oil contaminated waste, fluorescent light tubes, pre-filtration residue, silica cake, polishing filter socks, polishing filter cake, sterol glycosides and filter cake.

FIS is currently proposing to import the feedstock from the USA and export the entire production supply to Europe. The reasons for this are the absence of a reliable local feedstock supplier in South Africa, the maturity of the USA industry and the favourable European biodiesel market. Future plans included sourcing the feedstock from local suppliers and once the legislation with regards to petroleum blending in South Africa has been legislated, FIS will re-assess whether it is economically feasible to also supply biodiesel to the local petroleum industry. The envisaged phases of the project are outlined as follows:

■ Phase 1 entails importing the feedstock (consisting of WVO) from the USA and exporting the entire production supply to Europe;

■ Phase 2a entails obtaining reliable and economically viable feedstock of WVO as well as animal fat (i.e. tallow) from local sources; and

■ Phase 2b entails re-assessing the economic viability for supplying biofuel to the local market, once legislation for mandatory blending has been promulgated.

The biodiesel production process is segregated into four distinct sub-processes:

1. Pre-treatment (PT);

2. Fatty Acid Stripping (FAS);

3. Transesterification (TE); and

4. Acid Esterification (AE).

A detailed description of the biodiesel production process is provided in the sections below. As the animal fats are to be received in rendered form the process is the same for both WVO and animal fats feedstock. Reference is made to the simplified process block diagram contained in Figure 8.

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Figure 8: Simplified Process Block Diagram

2.7.1. Pre-treatment (PT)

The purpose of the pre-treatment (PT) stage is to equalise and remove impurities from the incoming waste oil feedstock in order to create a consistent and homogeneous feed for the transesterification (TE) stage. This is crucial for maximising the efficiency and effectiveness of the TE sub-process.

The PT stage comprises the following sub-unit processes viz. chemical pre-treatment, filtering, drying, and stripping the fatty acids. The order of the pre-treatment steps may vary depending on the type and quality of the feedstock, and would also be based on an economic breakpoint where it is beneficial to strip the fatty acids due to its high energy intensity. The PT steps are described as follows:

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■ Filtration: The raw feedstock is subjected to a pre-filtration process comprising rotating physical screens with micron diameter ~100. The filters are self-cleaning involving the use of steam washing. Filtered material is removed from the process as a waste stream.

■ Pre-heating & Acid Dosing: Feedstock is preheated via a series of heat exchange systems (recovering heat from the outgoing oil from the process) into an acid dosing tank. Phosphoric acid is dosed via ratio control into the oil stream and mixed via an acid mixer.

■ Hydration and Caustic Treatment: The acid treated oil is agitated for a predetermined timeframe resulting in conversion of the non-hydratable phosphatides to hydrated gums. The oil is pumped from the tank and cooled, then dosed with a sodium hydroxide / water solution and mixed. The sodium hydroxide neutralizes any unreacted phosphoric acid and free fatty acids (which are converted to soap) and the water serves to act as a carrier which removes the impurities in the oil stream as it passes through a centrifuge.

■ Centrifuge: The oil is centrifuged in order to separate the hydrated gums (heavy phase) from the oil (light phase). Water is added, if necessary, in order to aid the separation of soaps. The gums, containing predominantly soap, water, hydratable metals and neutral oil (also referred to as soap stock), are sent to designated storage facilities for onward sale as a by-product; the oil is directed to the silica treatment system.

■ Silica Treatment: The purpose of the silica treatment system is to remove residual soaps and phosphatides from the oil. Oil from the centrifuge is heated and sent to the oil/silica mixer where it is mixed continuously with silica. The resultant slurry is pumped to a vacuum tank for a predetermined retention time resulting in reduction of moisture content to ~0.2%.

■ Filtration: The oil/silica slurry is pumped from the silica vacuum tank to the silica filters (one operating, one standby) for the removal of silica. The filters comprise vertical leaf pressure filters coated with diatomaceous earth to reduce filter size to ~1micron. The filters are self-cleaning involving the use of steam washing. Filtered silica cake is removed from the process as a waste stream.

■ Oil drying & polishing filtration: TE reactions are adversely affected by the presence of water, therefore the purpose of the oil drying step is to further reduce the moisture content of the oil coming from the silica treatment step to less than 0.05%. The removal of water is accomplished by flash drying the oil under vacuum. The dry oil leaving the dryer is pumped through an oil/oil heat economizer where it gives up its heat to the incoming feedstock. The oil is passed through a further filtration stage comprising two duplex/sock filters for removal of trace contaminants. Filtered solids are removed from the process as a waste stream.

■ The vapours leaving the final oil dryer are evacuated by a two stage vacuum system and are made up of non-condensables and water.

2.7.2. Free Fatty Acid (FFA) Stripping / Acid Esterification (AE)

Depending on the chemical content of the feed material it may be necessary to remove free fatty acids (FFA) prior to the TE process (typically where >2% content). The FFA removed is either processed as a separate stream into biodiesel, or as a FFA by-product for third party use. The FFA removal steps are described as follows:

■ De-aeration: Oil from a designated buffer tank passes through polishing filters to remove any solids. The oil passes through an oil heater where it is heated and sprayed into a de-aerator which is under a vacuum. The de-aerated oil is pumped through a heat exchanger where it picks up heat from oil discharging from the fatty acid stripper, and is then introduced into the fatty acid stripper.

■ Stripping: The purpose of the fatty acid stripper is to remove fatty acids from the pre-treated oil. This is accomplished by preheating the oil in a heat exchanger and then further heating the oil using steam in the first stripping compartment. The high pressure steam is supplied by a high pressure steam boiler. As the oil passes through the next two compartments, it is exposed to direct steam under vacuum. The steam vaporises the free fatty acid content of the oil to <500 ppm. The oil is initially cooled in a heat exchange system, and then further with a water cooling system. The fatty acids vapours are scrubbed out of the vapour stream in a stripper. The recovered distillate (consisting primarily of fatty acids) is filtered and sent

43

to storage; this is an intermediate product that can either be sold into the market or be converted to methyl ester in the acid esterification process.

■ Acid Esterification: The purpose of the AE process is to convert fatty acids recovered from the fatty acid stripper into methyl esters. The esterification reaction is carried out under positive pressure and at high temperature (steam heated) in the presence of methanol and sulphuric acid catalyst to produce methyl ester. Methyl ester leaving the reactor passes through a flash vessel where most of the unreacted methanol and some water flash-off in the form of vapours, while the methyl ester remains in liquid form. Vapours are condensed and returned to process for methanol recovery. The methyl ester is cooled and pumped to a settling tank where separation occurs between the unreacted methanol, some free glycerine, water (light phase) and methyl esters (heavy phase). The light phase is pumped to the glycerine clean-up system while the methyl ester phase is stored for future introduction to the TE sub-process.

2.7.3. Trans-esterification (TE)

The outputs from PT and AE are blended (as required) then mixed with methanol and sodium methylate catalyst (referred to as sodium methoxide) and fed into a series of three reactors operating under high pressures and temperature. The main reaction products are methyl ester and glycerol, whilst side reactions produce fatty acid, soap and methanol. Once adequate conversion has been achieved, the two main product streams of methyl ester and glycerine are evacuated from the reactors as separate streams.

2.7.3.1. Methyl Ester Stream

The methyl ester stream from the TE reactors (containing free glycerine traces, soaps, and unreacted catalyst) is heated and sent to an evaporator where methanol is vaporised, condensed and recovered; thereafter the methyl ester is sent for further processing as follows:

■ Citric acid dosing: The methyl ester is mixed with low pH water (containing citric acid) in order to enhance soap removal.

■ Centrifuge: The methyl ester containing acidic water is heated and fed to a centrifuge where a light stream (containing clean methyl ester and small amounts of unreacted methanol) and a heavy stream (containing water and impurities such as soaps, unreacted methanol, neutralized catalyst salts, and glycerine). The heavy phase is sent to the glycerine treatment system; the light phase is stored prior to final drying.

■ Drying: The methyl ester from the centrifuge is heated in a counter current heat exchange process and then enters a flash dryer where any remaining moisture and residual methanol is vaporised, condensed and recovered.

■ Cold / polish filtration: Methyl ester from the flash dryer is cooled and fed to a retention tank where it is continuously stirred / agitated for 8-10 hours. This process leads to the formation of sterol glycosides which are filtered out using pressure filters coated with diatomaceous earth (to reduce filter size to ~1micron). The filters are self-cleaning involving the use of steam washing. Filter cake is removed from the process as a waste stream.

Following the above steps, the processed / filtered methyl ester is designated as biodiesel product, and is fed to on-site storage and despatch facilities.

2.7.3.2. Glycerine Stream

The glycerine stream from the TE reactors (containing free glycerine, unreacted catalyst, methanol and soaps) is sent to a crude glycerine holding tank for downstream cleaning. Glycerine cleaning/purification consists of the following steps:

■ Methanol pre-flash: Glycerine is heated and then enters a flash tank where any remaining moisture and residual methanol is vaporised, condensed and recovered.

■ Acidification and fatty acid separation: Glycerine is pH adjusted by hydrochloric acid dosing in order to convert soaps to fatty acids. The mixture is fed to a decanter where fatty acids float to the surface are returned to the TE process or sold as fatty acids.

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■ pH neutralisation: The remaining glycerine is dosed with sodium hydroxide in order to achieve a pH target of 6.

■ Final demethylating: The glycerine is fed to a distillation column where any residual methanol and water is separated out. Pure methanol from the top of the distillation vessel is returned to the process methanol stream. Water from the bottom of the vessel is also recovered back into the process for biodiesel washing purposes.

Following the above steps the concentrated glycerine which is composed of approximately 85% glycerine, 10% moisture, and 5% MONG (matter organic non-glycerine) is fed to on-site storage and despatch facilities.

2.7.4. Vent condensation and water / methanol recovery

Vent gasses generated by process vessels are condensed in order to maximise the recovery and re-use of raw materials, as well as to ensure that atmospheric emissions are controlled.

■ Vacuum System: Vent gasses from vessels which are operated at sub-atmospheric absolute pressures (vacuum) are recovered through systems comprising cooling water condensers, chilled water condensers and a vacuum pump unit. In this process, some of the methanol is entrained in raw feedstock and used as sealing fluid on the vacuum pump – the methanol is condensed and recovered internally as part of the unit process.

■ Methanol Rectification: The purpose of the rectification system is to dry the wet methanol streams recovered from the methyl ester and glycerine purification steps. Thereafter the recovered methanol can be reused in the TE sub-process. Removal of moisture is accomplished by rectification which occurs in a column equipped with structured packing. In the rectification column the wet methanol is heated causing the methanol to vaporise and leave the column. The methanol vapour that is condensed is recovered. The methanol free water from the column is fed to a holding tank, from where it is re-used in the process as washing water, or sent to sewer if there is surplus.

■ Vent Condensation and Recovery: All vessels and tanks operating at atmospheric pressure in the TE sub-process, and containing liquids which can or do contain methanol (storage tanks, reactors, decanters, holding tanks) are vented to the atmospheric vent system. This vent recovery system consists of a cooling water condenser, a chilled water condenser, a vent blower, and a final absorption column where the last traces of methanol are removed from the vent gases by absorption in water. The excess water leaving from the bottom of the absorption column is pumped under level control to the wet methanol holding tank for processing through the methanol rectification system for methanol recovery.

2.8. Assessment of Alternatives

The NEMA EIA Regulations stipulate that feasible and reasonable alternatives must be identified and assessed as part of an EIA process. The alternatives considered must include a description on the advantages and disadvantages associated with each alternative.

Alternatives that have been considered as part of the EIA process and discussed in detailed below are:

■ Site alternatives;

■ Design and layout alternatives;

■ Pipeline route alternatives;

■ Technological alternatives;

■ Production alternatives; and

■ No-go alternative.

2.8.1. Site alternatives

The site selection process was based on the following criteria:

■ Access to both main roads and a port;

45

■ 4ha of developable land available;

■ Industrial zoning; and

■ Economically feasible in terms acquiring the land and construction of infrastructure.

As discussed in Section 2.3, since the proposal of transporting the feedstock to the site can rely on two main sources namely; local feedstock (i.e. transported via road) or international feedstock supply (i.e. transported via ship to port), access to both harbour and major roads played an important role in the site selection process undertaken by FIS. In addition, the facility requires a minimum area of 4ha for the facility’s development footprint. Based on the access requirements of the facility and the size of the development footprint, it was deemed that only a site located in an Industrial Development Zone (IDZ) which has access to both a port and road will be suitable for this type of operation. The first IDZ that was deemed suitable for the specific requirements was the Richards Bay IDZ. The Richards Bay IDZ did not have a suitable site available that was 4ha in size making Richards Bay IDZ unfavourable. Discussions were held with a company who wanted to establish a liquid bulk storage facility in the Richards Bay IDZ whom had already secured a site covering 35ha, of which they only required 30ha, and who were willing to go into partnership with FIS. Following further investigations the partnership was deemed to be economically unfeasible rendering the Richards Bay IDZ as an unsuitable location for the facility.

FIS then investigated the options available at the Coega IDZ. The Coega IDZ is a premier location for new industrial investments in South Africa. It covers an area of approximately 11 000ha of which approximately 8 690ha are available for development. The Coega IDZ constitutes a phased development which is focused around industry clusters and has been divided into a total of 14 different zones. Sectors which have been identified for the IDZ consist of Automotive, Agro-Processing, Metallurgical, Educational and Training, Petrochemical and Chemical, General Manufacturing, Business Process Outsourcing, and Energy. The proximity of the IDZ to the newly established deep water Port of Ngqura, as well as major transport routes, creates a platform for global exports by attracting foreign and local investment in manufacturing as well as export orientated and other industries

11.

Four main site options within the Coega IDZ were deemed as feasible site options. The layout of the Coega IDZ is provided in Figure 9 below. The two zones that were being considered were Zone 7 and 5, shown with a red circle and a yellow circle, respectively.

11

CSIR, 2012, PhytoAmanla Biofuel Processing Plant in the Coega IDZ. Draft Environmental Impact Assessment Report

46

Figure 9: Coega IDZ Map showing zones in which the alternative site options were located.

Site option 1 and site option 2 are both located in Zone 5 and site option 3 and 4 are located in Zone 7 (Figure 10). The site options within Zone 5 were deemed economically unfeasible since access to Zone 8 and the berth would mean that a ~10km pipeline would have needed to be constructed and routed over the Coega River. This was deemed unacceptable from an engineering and costing perspective. Although Zone 5 also has a link to a railway line, the facility’s current and future scenarios do not require access to rail. Hence, Zone 7 was deemed the best option from a financial and engineering perspective.

Zone 7 is ideally situated to ensure that the feedstock and materials required as part of the production of biodiesel can be either obtained via a pipeline from the berth or transported via road to the site and therefore preferred site is located within Zone 7 (Chemical and Petrochemical Cluster). This Zone is specifically earmarked for medium to heavy chemical and petrochemical sector industry and has adequate service provision to service the site. These services are provided by the CDC. Service provision by the CDC is detailed in Table 20 with comments from the CDC on how the service will be provided to the site, should the proposed services not be fully in place when the FIS facility is operational. Within this zone, option 3 and 4 were deemed

47

feasible in terms of access to the main road and pipeline routing the port. Site option 4 was deemed the preferred site following meetings with the CDC and accessibility to the site already available.

Figure 10: Site options within the Coega IDZ that were considered

48

Table 20: Services availability in Zone 7

Service required Service provision by CDC CDC comment on timeframe

Sewage Construction on the bulk sewer to service Zones 11, 6 and 7 and 10 commenced early in 2013.

This infrastructure is likely to be in place by the time FIS is operational. If for some reason that this is not operational, then the CDC would provide temporary conservancy tanks to bridge the gap in time.

The estimated completion date for the bulk sewer is December 2014.

Thereafter the pumpstation for the sewer must be installed. The estimated completion date for the pumpstation is December 2014.

Potable water The CDC is currently busy with a project in Zone 7 to connect Cerebos with permanent water. The supply of potable water will be from the existing Colchester Bulk waterline, which is not yet operational. The CDC is busy with a solution to repair the damaged sections and get it operational. This is likely to be completed by 2

nd quarter of 2014. Pipework at

the border of the site is in and complete to service FIS.

This will be in place to service the FIS site.

Electricity To be supplied from the Sonop substation (in Zone 7) at 11 000V.

Based on 170 000 ton/year biodiesel production it is estimated that the facility will require approximately 15 148 MWh of electrical power per year.

N/A

Storm water infra-

structure

Storm water infrastructure in Zone 7 will be completed by March 2014.

This will therefore be in place to service the FIS site.

ICT services ICT services are available in Zone 7. The type of services provided to the site will be determined by the customer requirements.

N/A

2.8.2. Design and Layout alternatives

2.8.2.1. Design alternatives

The FIS facility will be based on the HeroBX plant, located in the USA. HeroBX is managed by Erie Management Group, LLC and is owned by Black Family Holdings, LP. The Company was formed in September 2005 and began construction of its production facility in June 2006. HeroBX produced its first ASTM D6751 (standards for the specifications for biodiesels blended with middle distillate fuels) approved biodiesel on November 29, 2007. The HeroBX produces 170 000 tons of biodiesel per annum. The FIS facility’s proposal is to use the HeroBX design and layout as a blueprint and to only make some adjustments during the detailed engineering phase to ensure that the facility is compatible to the local factors such as geotechnical conditions. Final engineering has not been undertaken for the site since the cost of undertaking this will only be deemed justified following the relevant environmental approvals.

The design, layout, tank, pipeline specifications as well as the amount and type of materials that will be stored and used on site have been based on the capacities of the HeroBX plant. Changes to the final design of the facility will be made to ensure that the material used for the construction of the tanks, pipelines and bunding requirements are applicable to the FIS facility in terms of the availability of construction materials and South African building standards. The design will also be changed to ensure that the electrical supply and water supply lines connect to the services connection lines of the CDC.

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2.8.2.2. Layout alternatives

The FIS facility will be based on the design and layout of the HeroBX facility and will be modified to suit the site specific conditions. However, there is a set requirement in terms of the general layout of the site. From an environmental perspective, no additional impacts would be applicable to layout alternatives, since the amount of materials to be stored on site and the size of the site will remain unchanged. Therefore, layout alternatives would have a minimal influence on the overall impacts arising from the facility.

2.8.3. Pipeline route alternatives

Initially, the option of constructing a pipeline across Zone 8 (not within a fuel reserve) was considered in 2010. Even though this pipeline routing option would have been the shortest route and therefore, from an economical perspective, the preferred option, the proposed pipeline routing would have crossed several sensitive ecological areas. This option was not considered feasible in the end because of the fact that Transnet commenced with the tendering process to get an appropriate service provider (namely OTGC) to construct and operate a bulk storage and handling facility in the Port of Ngqura. Transnet in turn needed to supply the bulk storage facility with the necessary landside structures, which included road and fuel reserves (i.e. fuel pipeline servitudes). The establishment of a pipeline route that fell outside Transnet’s reserves would therefore have been undesirable.

As discussed in Section 2.6.5, the FIS facility will require the construction of pipelines to the OTGC facility (depending on when the tank farm is operational). The pipeline routing options from the OTGC to the port-side berths have not been assessed within this EIA since the construction of the pipelines and pumping of feedstock and materials between the tank farm and the port-side berths have been assessed within the OTGC EIA.

The pipeline route alternatives that need to be considered are therefore the routing options on how to connect the facility to the Transnet fuel reserve. This means that FIS’s pipeline will need to be routed across the CDC’s servitude determined during the rezoning of the remainder of the IDZ. The pipeline from the facility will cross this servitude at a precise location to be determined by the CDC’s Zone developers in the future and will then run to the OTGC via the TNPA’s fuel reserve. The pipeline routing from the facility across the CDC servitude will need to be informed by the Ecological Impact Assessment, undertaken as part of this EIA). The sensitive environmental considerations that would need to be taken into account during the determination of the exact routing are shown in Figure 11. From this it can be seen that within the servitude there is an area comprising of thicket and mini bushclumps which should be avoided when considering how to route the pipeline. The best pipeline option will therefore be a route that has a minimal disturbance on the sensitive vegetation types present in the servitude but will still be cost effective in terms of routing to the fuel reserve.

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Figure 11: Pipeline route option from the FIS facility to connect to the fuel reserve and sensitive vegetation type to take into account (Map source: CES Ecological Impact Assessment for the FIS Biodiesel Facility, September 2013)

2.8.4. Production alternatives

The HeroBX facility’s pre-treatment facility and fatty acid stripper, which will also be applicable to the FIS facility, allows for the utilisation of various feedstocks, depending on the availability and affordability of the feedstocks. This means that the facility can make use of various sources of feedstock (i.e. not restricted to one source). As a result of the ‘fuel versus food’ debate that has been ongoing since farmlands started diverting their crops from food supply to biofuels production and the high cost of using virgin oil (Supple et al., 1999)

12,

FIS determined that using WVO as a raw material will significantly decrease the raw material cost and therefore the cost of the biodiesel produced, as well as avoid the controversies surrounding the ‘fuel versus food’ debate.

Currently, the FIS facility will make use of WVO and, possibly in future, processed animal fats. As discussed in Section 2.3 the type and source of feedstock used on site will depend on when the mandatory blending of biodiesel comes into play and on the commercial availability of local feedstock. Once a market has been established in South Africa for biofuels, FIS will be in a much better position to be able to source feedstock from local suppliers since market availability and subsidies from government will be in place. Therefore, currently the preferred alternative (and the only commercially viable option due the production requirements of the facility) is to import WVO from the USA, convert it to biodiesel through various processes and export the full production supply to Europe. The main advantage to this proposal is that FIS will be able to establish their company in South Africa, create jobs and develop infrastructure, which will mean that in the future, once the local market is more developed, FIS will be able to supply biodiesel to South African petroleum companies as part of the

12

Supple, B., Howard-Hildige, R., Gonzalex-Gomex, E., Leahy, J.J. 1999. The effect of steam treating waste cooking oil on the yield of methyl ester. J. Am. Oil. Coc. Chem. 29 (2), 175-178

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mandatory blending requirement. In the interim, FIS will still contribute positively to the South African economy by boosting exports. The establishment of a local biodiesel facility can also be expected to significantly spur the development of a local WVO supply industry that can displace imported WVO (in future), keeping in mind that there is an estimated 30 million litres per month of WVO created in South Africa through various food industries and domestic use, most of which is being sent to landfill. The FIS facility will currently not be using local supply, because of a lack of a structured market to obtain the WVO, and therefore, the unused WVO in South Africa will not yet be recycled at the facility.

Future options, which are not viable at the moment, therefore include getting local suppliers to provide WVO and processed animal fats to the facility. FIS’s longer term goal is to source feedstock from and supply biodiesel to local companies.

2.8.5. Technology alternatives

Biodiesel can be produced via four primary methods, namely:

■ Direct use and blending

■ Micro-emulsions of oils

■ Thermal cracking (pyrolysis)

■ Transesterification

The project is currently proposing to produce biodiesel based on the process described in Section 2.7. This process is based on the Transesterification process which takes place between vegetable oil or animal fat and an alcohol in the presence of a catalyst. Even though the transesterification process is the preferred alternative when it comes to the methods that can be used to produce biodiesel, Table 21 provides a high-level literature review

13 of the advantages and disadvantages of each of the biodiesel methods and why the transesterification

process is deemed the preferred alternative.

Table 21: Technology alternatives assessment

Production Method

Advantages Disadvantages Relevance to the FIS Facility

Direct use and blending

■ Does not require any additives

■ High viscosity

■ Acid composition

■ FFA content

■ Gum formation

■ Sourcing virgin oil is not financially viable

■ Disadvantages of this method will mean that the biodiesel produced will not be up to standards

Micro-emulsion of oils

■ Forms micro-emulsions which solves the problem of high oil viscosity

■ Incomplete combustion during laboratory endurance tests

■ Irregular injector needle sticking

■ Micro-emulsion is not used for the synthesis of biodiesel but only a technique used to reduce the viscosity of oil. Therefore, it is not deemed a feasible process to use at the FIS facility

Thermal cracking (pyrolysis)

■ Best method where the hydroprocessing industry is well established because

■ Material used in pyrolysis is expenses compared to other methods

■ This facility is not located in an area where there is a well-established

13

Abbaszaadeh, A., Ghobadian, B., Omidkhah, M.R., Najafi, G. 2012. Current biodiesel production technologies: A comparative review. Energy Conversion and Management. 63 138-148

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Production Method

Advantages Disadvantages Relevance to the FIS Facility

the technology is very similar to that of conventional petroleum refining

14

■ In some instances produces more gasoline than diesel fuel

■ Removing oxygen during the thermal process removed the environmental benefit of using oxygenated fuel

hydroprocessing industry

Transesterification ■ Most common method used in the transesterification of oils

■ Various feedstocks and catalysts can be used

■ Slow reaction time because of poor surface contact between alcohol and feedstock and therefore require catalysts

■ Requires a large amount of infrastructure to produce biodiesel

■ Method that is mostly used in the biodiesel manufacturing industry

■ The use of alcohol (i.e. Methanol) has a low cost and can be re-used in the process

■ Using base catalyst (Sodium Methoxide), preferred catalyst for the FIS facility’s production, requires less methanol and transesterification reactors compared to using an acid catalyst

15

2.8.6. No-Go option

The No-Go alternative will mean that no development will take place. Therefore, the baseline conditions of the site are applicable. From an ecological perspective the main issue identified within the site boundary, should the development not take place and is left unmitigated, is that it is likely that the Acacia cyclops (an alien species) infestation within the FIS site footprint (4ha area) will continue to spread and displace indigenous vegetation both within and beyond the FIS site footprint.

From a socio-economic perspective, the site is currently not creating any employment opportunities. It is anticipated that 17 new permanent job opportunities will be created during the operational phase and the construction of the facility will create several semi-permanent jobs through the contractors that will be procured to construct the site. There will also be a lost opportunity for development opportunity within the Coega IDZ. This does not take into account the economic benefits from the establishment of a profitable company in South Africa and the contribution to the local and national economy.

As stated before, FIS is aiming to become established in the South African market and to be able to produce biodiesel that will feed into the mandatory blending requirements set by the Department of Energy. Fuel producers will be required to blend a minimum of 5 percent biodiesel with diesel fuel while between 2 and 10 percent of bioethanol will need to be blended with petrol. The new regulation is set to be applicable from the 1

st of October 2015 as the energy department bids to reduce the country's reliance on imported fuel. To this

14

Maher, K.D., Bressler, D.C. 2007. Pyrolysis of triglyceride materials for the production of renewable fuels and chemicals. ioresource Technology 98 2351–2368

15 Zhang, Y., Dube, M.A., McLean, D.D., Kates, M. 2003. Biodiesel production from waste cooking oil: 1. Process design and technological assessment.

Bioresource Technology 89 1-6

53

end, this will be a lost opportunity to South Africa to meet their blending objectives, once promulgated in October 2015. The facility will help spur the development of a commercially viable supply-side business for WVO, by establishing a user of such wastes in South Africa. Substantial quantities of WVO are currently disposed of to landfill in South Africa. The no-go opportunity would therefore represent a missed opportunity in this regard. It will also represent a lost opportunity to develop an industrial facility that is aligned with the concept of a “Green Economy” and which has the potential to contribute to reduced national greenhouse gas emissions associated with mobile combustion.

Based on the findings of the EIA, the facility will not have a significant negative impact and therefore the no-go option is not considered the preferred alternative.

54

3. Description of Receiving Environment

A description of the receiving environment for the Coega region in which the proposed site will be developed includes physical, biological and socio-economic factors. The purpose of this section is to gain a better understanding of the environment within and adjacent to the proposed site in order to identify potential impacts of the proposed development.

3.1. Climate

The Eastern Cape of South Africa is affected by both temperate and sub-tropical climatic regimes creating a large variety in temperature, winds and precipitation patterns.

3.1.1. Temperature

Please note that this information has been compiled from the Air Quality Impact Assessment (AQIA) of the Proposed FIS Biodiesel Production Plant attached in Appendix F of this report.

Figure 12 represents the minimum, maximum and average temperatures, as well as the humidity for Coega, calculated from 10-minute averaged readings from December 2010 to December 2012. Average temperatures remain around the 20°C-25°C mark during summer and drop to around 15°C during winter. Due to the coastal location, humidity is generally high (above 60%), and tends to increase as temperatures increase.

Figure 12: Monthly average, maximum and minimum temperature data for Coega for 2010 – 2012

3.1.2. Rainfall

As a result of the combined temperate and subtropical climates, the region experiences a bimodal rainfall which peaks in spring and autumn. Spring rainfall is associated with convection currents and autumn rainfall with the passage of cold fronts. The annual rainfall for the region is between 400mm and 700mm, with Coega only receiving approximately 400mm. Figure 13 shows the monthly rainfall and humidity recorded at the Coega SAWS station for the period from 2010 to 2012.

55

Figure 13: Monthly rainfall and humidity recorded at the Coega SAWS station

3.1.3. Wind

Wind roses are useful for illustrating the prevailing meteorological conditions of an area, indicating wind speeds and directional frequency distributions. In the following wind roses, the colour of the bar indicates the wind speed whilst the length of the bar represents the frequency of winds blowing from a certain direction (as a percentage).

In the Coega area, winds are predominantly from the west (13% of the time), north (12% of the time) and the east (9.5% of the time) (Figure 14). The strongest winds dominate from the westerly quadrant, with wind speeds of over 8 m/s experienced from this direction.

Figure 14: Surface wind rose plot for Coega for the December 2010 to November 2011 period

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Seasonal variations in winds are represented in Figure 15. During summer (December to February), winds predominantly originate from the east. Winds are moderate to strong at this time with winds speeds of greater than 8 m/s experienced. During autumn (March to May), the easterly component diminishes and winds are predominantly from the north and the west. Strongest winds (> 8 m/s) are experienced from the westerly sector. During winter (June to August), winds from the north and west still dominate, while the winds from the east disappear almost completely. During spring (September to November) the easterly wind component is re-introduced and winds from the west and east dominate. Winds from these sectors are moderate to strong. A smaller northerly component is also evident, although much weaker winds originate from this direction.

Figure 15: Seasonal surface wind rose plots for Coega for the period January 2010 to December 2012

Diurnal variations in winds are represented in Figure 16. After midnight, winds from the north-north-west, north and west dominate, with the strongest winds experienced from the west. Pollution dispersion would be limited during the early morning hours as a result of calmer wind speeds. During winter, the concentrations of pollutants experienced at the surface at this time may also be augmented by the formation of surface inversions which trap pollutants and prevent them from being dispersed into the atmosphere. After sunrise, winds from the westerly sector diminish and winds from the north dominate for 19% of the time. Wind speeds strengthen in comparison with the early morning hours. These higher speeds and the lifting of the inversion with sunrise will promote pollutant dispersion. In the afternoon, the strength and frequency of the northerly component decreases and strong winds develop from the south-west. Wind speeds of over 8 m/s are experienced from this sector for 4% of the time. Winds from the east and south-south-west are also over 8 m/s at times. Winds from the west and east dominate from 18:00 to 00:00, with the occurrence of high wind speeds decreasing in comparison to the afternoon.

57

Figure 16: Diurnal surface wind rose plots for Coega for the period January 2010 to December 2012

3.2. Air Quality

The Eastern Cape coast has a warm, temperate climate, predominantly controlled by the semi-permanent continental high pressure cell and low pressure systems in the form of westerly waves. Dispersion of pollutants can occur horizontally and vertically in the atmosphere. Horizontal dispersion is a result of wind speed and topography whilst vertical dispersion is controlled by the level of atmospheric stability. Dispersion is most effective with unstable conditions where vertical mixing is initiated. Stable conditions are conducive to shallow mixing depths and poor atmospheric dispersion. High pressure systems are associated with clear, calm and stable conditions as a result of subsidence. With persistent stable conditions, atmospheric dispersion is poor, resulting in the accumulation of pollutants. The occurrence of westerly waves is associated with unstable conditions and strong winds. These conditions promote the dispersion of pollutants

16.

The air quality in the Coega area is generally good, as a result of pristine ocean air that recirculates into the area, removing impurities and transporting pollutants offshore. The area is described as having generally good dispersion potential during summer as a result of a deepened mixing layer, a lower frequency of surface inversions and a higher occurrence of stronger winds. Surface cooling during winter, however, is conducive to the formation of surface inversions at night. This narrows the mixing layer and traps pollutants between the ground and the inversion layer. Associated light wind speeds exacerbate the accumulation of pollutants. After sunrise, convective mixing is initiated and the surface inversions break down such that pollutants may disperse.

16

Tyson, P.D. and Preston-Whyte, R.A. (2000): The Weather and Climate of Southern Africa, Oxford University Press, Southern Africa

58

Ambient air quality monitoring has been conducted in the Coega IDZ from 2000 to 2012. The monitoring network consists of three monitoring stations at Saltworks, Amsterdamplein and Motherwell. The data reported in the 2006 Annual Report

17 and the 2012 quarterly monitoring reports confirms that ambient concentrations of

criteria pollutants for the region are below the stipulated NEMAQA standards. It should be noted that various proposed developments within the Coega IDZ will cumulatively impact on the future air quality in the region, which will need to be closely monitored. As such, the Eastern Cape Air Quality Management Plan which is currently out for public review, indicates that such expansion within the Coega IDZ could result in deteriorations in the air quality of the Nelson Mandela Bay region and it is suggested that the Coega IDZ may be declared a Priority Area in terms of the National Environmental Management: Air Quality Act.

The existing emission sources in and around the Coega IDZ area include industrial activity, biomass burning for industrial purposes, domestic fuel burning, vehicles and agricultural activities. Within the Coega area and its surrounds, sparsely vegetated and denuded areas are common, as well as degraded areas associated with construction in the IDZ. With frequent moderate to strong winds, dust easily becomes entrained and is transported away from the area, impacting on regional air quality, particularly in winter.

3.3. Topography, Geology and Soils

The section’s information is summarised from the EIAs that were undertaken for the rezoning of the core development area from agricultural to special purposes and the final revised Scoping Report for the proposed change in land use of the remaining area within the Coega IDZ and the Ecological Report compiled by CES for this project (Appendix F).

3.3.1. Topography

The topography of the Eastern Cape is characterised by a variety of landscapes comprising semi-desert in the interior, mountain ranges to the north (Great Escarpment) and south (Cape Fold Mountains), rolling hills toward the ocean and deeply incised river valleys flowing parallel to each other. On a local scale, Coega and the associated Development Zone are generally flat with gentle undulating hills incised by the Coega River Valley toward the north east.

3.3.2. Geology

The Peninsula Sandstone Formation of the Table Mountain Group (member of the Cape Super Group) is the underlying bedrock of the Port Elizabeth Metropolitan and Coega area resulting in the characteristic topography. This formation is characterised by erosion resistant, super-mature quartzitic sandstone. The Sandstone formation emerges as outcrops, forming islands within Algoa Bay. The areas between these islands are filled with recent marine deposits (Alexandria Formation), which directly overlie the mudstones of the Kirkwood Formation.

The geology underlying Coega comprises coastal limestone overlain by calcareous sands blown onshore. These components are the result of the following four underlying formations;

■ Salnova Formation: Intermediate and low level fluvial terrace gravel, estuarine sand and gravel deposits;

■ Alexandria Formation: Calcareous sandstone, shelly limestone;

■ Kirkwood Formation: Reddish to greenish mudstone and sandstone; and

■ Sundays River Formation: Greenish to grey mudstone and sandstone.

The project area is underlain by the Sundays River formation which is a grey shale deposited in shallow marine embayments during Cretaceous times (Figure 17). The substrate overlaying this formation is characterised by coastal limestone, overlain by calcareous sands blown onshore. Calcrete is a calcium-rich hardened layer found on or in a soil. It is formed on calcareous materials as a result of climatic fluctuations in arid and semi-arid regions.

17

Ecoserv (2007): Coega Air Quality Reporting, Annual Report: 2006

59

Figure 17: The project area is underlain by the Sundays River formation (CES, 2013)

3.3.3. Soils

The geology of an area gives rise to the characteristic soils present in that area. The limestone and sandstone formations underlying Port Elizabeth and Coega have resulted in the production of lime-rich sandy soils with variable depth and deep lime-rich sandy clay loams.

The soils can contain fairly high concentrations of metals and hydrocarbons such as Fluorine, Manganese, Aluminium, Cadmium, Chromium, Copper, Lead, and Zinc. These are thought to be naturally occurring as they relatively low compared to Dutch Optimum Levels. In the south-eastern coastal region, sandy soils with variable depth and deep red sandy clay loams overlying limestone, are common. The southern coastal belt is characterised by coastal sands, sandy soils, lime-containing lithosols and weakly developed soils on rock. The soils of the area can be described as relatively deep, red, lime-rich sandy clay loams. In areas where the limestone is visible the geology and soils are a typical habitat for Bontveld vegetation.

3.4. Surface water

The Coega Catchment makes up an area of 550km2, and comprises the Coega River, agricultural land and

natural sub-tropical thicket vegetation. The Coega River is a relatively small sand-bed river and is the most significant surface water feature associated with Coega. The river is currently being used by a salt works facility in the lower reaches as well as for limited recreational purposes.

After rainfall events, there is a resultant rapid run-off toward the river channel and reduced recharge of the underlying low permeability aquifer. This is due to the limited vertical infiltration of rainwater as a result of underlying calcrete, sand, gravel and low permeability clays.

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A desktop review was conducted to determine the local and regional geo-environmental characteristics (i.e. climate, hydrology, landuse, vegetation, geology and soils). This review included the following information sources:

■ Water Research Commission (WRC), 1994. The Surface Water Resources of South Africa, 1990, Volume V, Eastern Escarpment (WRC Report No 298/5.1/94).

■ Coega Development Corporation (CDC), October 2010, Integrated Storm Water Master Plan for the eastern side of the Coega IDZ. Report reference J29161/7231.

■ SRK Consulting, May 2013. FIS Biofuels Plant Geotechnical Investigation. Report Number 457869/1.

■ Coastal & Environmental Services, September 2013. Ecological Specialist Report for the Proposed FIS Biodiesel Refinery, Coega Industrial Development Zone, Eastern Cape.

The site falls within the M30B Quaternary Catchment, within the Coega River catchment. The climatic conditions and runoff amounts for this quaternary catchment are presented in Table 22. The Mean Annual Precipitation (MAP) for the area is 434mm with a Mean Annual Evaporation (MAE) of 1,550mm. This results in a Mean Annual Runoff (MAR) of 5.3 million m

3 (WRC, 1994)

18.

Table 22: Quaternary catchment information (WRC, 1994)

Quaternary Catchment Area (km2) MAP (mm) MAE (mm) MAR (mm) MAR (m

3)

M30B 307 434 1,550 17 5,300,000

According to the CDC ISWMP, SRK (2006) defined the MAP of the Coega Area as 400mm. To confirm this value, a review of rain-gauges located in close proximity to the site was conducted using the database compiled by the Institute for Commercial Forestry Research (ICFR), and School of Bioresources Engineering and Environmental Hydrology (BEEH) associated with the University of the KwaZulu-Natal. Based on the Sondagriviermond Station (0035639W), located 15km east of the study site, and considered representative based on record length, altitude and distance (Table 23), the MAP in the vicinity of the site is 401mm. As a result, the SRK estimate of MAP is considered representative and was used for numerical modelling purposes.

Table 23: Rainfall station summary (ICFR, 2004)

Station Name

Station Number

Longitude Latitude Distance from site

(km)

Record (years)

Reliable data (%)

Patched data (%)

MAP (mm)

Altitude (mamsl)

Sondagriviermond 0035639W 25.851o 33.717o 15 122 26.5 73.4 401 10

The Coega River is located 2 km west of the site, and surface runoff is expected to flow towards this watercourse via a moderate topography. However, as described in the CDC ISWMP, runoff within Zone 7 is non-existent, with drainage occurring into isolated depressions which act as temporary wetlands where water eventually infiltrates.

Although there are no survey plans for the site, the site walkover and available regional mapping indicates that the on-site topography is expected to allow drainage in a general westerly to south-westerly direction towards the Coega River.

3.5. Groundwater

One of the country’s most important artesian aquifers lies beneath Coega, the Coega Ridge Aquifer Unit. It is the only aquifer in the country that is of practical economic importance as it is the source of large-scale abstraction. It has, however, already been heavily exploited by extractions for agricultural purposes.

The aquifer is formed by sandstones and quartzites of the Table Mountain Group and covers an area of approximately 525 km

2. It receives recharge from the exposed Winterhoek Mountains to the north-west of

Uitenhage and the Coega fault. The groundwater flow is largely in a north easterly direction due to the west-

18

Water Research Commission (WRC), 1994. The Surface Water Resources of South Africa, 1990, Volume V, Eastern Escarpment (WRC Report No 298/5.1/94)

61

north-west and east-south-east strike of the bedding which parallels the anticlinal fold axis and the strike of the Coega fault.

The groundwater quality in the aquifer is considered to be moderate to good with little deterioration along the flow path. The water is slightly acidic due to the oxidation of pyrite in the Table Mountain Group and high in iron and manganese with sodium chloride (NaCl) being the dominant ions.

The groundwater within the Coega Development zone lies 3-5 m below the surface of the earth between the permeable sand and impermeable clay zones. The shallow depth of the groundwater results in a high natural salinity and total dissolved solids content. This makes the groundwater, and surface water, of natural poor water quality and emphasises the importance of the Coega Ridge Aquifer as a water resource.

3.6. Ecology

The section’s information is summarised from the EIAs that were undertaken for the rezoning of the core development area from agricultural to special purposes and the final revised Scoping Report for the proposed change in land use of the remaining area within the Coega IDZ and the Ecological Report compiled by CES for this project (Appendix F).

3.6.1. Flora

Presently the land uses in the Coega IDZ consist of infrastructure, harbour facilities, industrial and commercially developed land, and vacant land. The vacant land is intended for a combination of future industrial land and open spaces, as per the CDC’s Open Space Management Plan (OSMP). The OSMP has identified environmental no-go areas that are to be protected from development with various functions ranging from natural areas where emphasis is on conservation to protect special vegetation types and preserve ecological processes, to recreational and visually attractive open space areas for relief in the built environment, screening off industrial buildings and softening the overall development.

The Coega IDZ property falls within the Albany Centre of Floristic Endemism; also known as the Albany Hotspot. This area was delimited as the ‘region bounded in the west by the upper reaches of the Sundays and Great Fish River basins, in the east by the Indian Ocean, in the south by the Gamtoos–Groot River basin and in the north by the Kei River basin’. This region is an important centre for plant taxa, and, according to van Wyk and Smith (2001), contains approximately 4000 vascular plant species with approximately 15% either endemic or near-endemic

19.

The vegetation of the Eastern Cape is complex and is transitional between the Cape and subtropical floras. Many taxa of diverse phytogeographical affinities reach the limits of their distribution in this region. The region is best described as a tension zone where four major biomes converge and overlap. The dominant vegetation type in the Eastern Cape is Succulent Thicket (Spekboomveld or Valley Bushveld), a dense spiny vegetation type unique to this region. While species in the canopy are of subtropical affinities, and generally widespread species, the succulents and geophytes that comprise the understorey are of karroid affinities and are often localised endemics.

There are three vegetation classifications pertinent to the area. These are:

1. The National Vegetation map developed by Mucina and Rutherford (2006);

2. The Subtropical Thicket Ecosystem Programme (STEP); and

3. The Nelson Mandela Bay Metro Municipality Municipal Open Space System (MOSS) vegetation map.

These classifications are discussed below:

National Vegetation Map (Mucina and Rutherford)

Mucina and Rutherford (2006) developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “It was compiled in order to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The

19

Victor, J. & Dold, A. (2003) Threatened plants of the Albany Centre of Floristic Diversity, South Africa. Biodiversity & Conservation

62

map was developed using a wealth of data from several contributors and has allowed for the best national vegetation map to date, the last being that of Acocks developed over 50 years ago. The SANBI Vegetation map informs finer scale bioregional plans such as STEP. This SANBI Vegmap project has two main aims:

■ to determine the variation in and units of southern African vegetation based on the analysis and synthesis of data from vegetation studies throughout the region; and

■ to compile a vegetation map. The aim of the map was to accurately reflect the distribution and variation on the vegetation and indicate the relationship of the vegetation with the environment. For this reason the collective expertise of vegetation scientists from universities and state departments were harnessed to make this project as comprehensive as possible.

The map and accompanying book describes each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important. This is the most comprehensive data for vegetation types in South Africa.

Mucina and Rutherford (2006) define the vegetation type found at the project site as Coega Bontveld (Figure 18). This vegetation type takes its name from the area in which it occurs. It is found the Eastern Cape Province northeast of Port Elizabeth in the Coega area as well as in a few small patches in Addo. This vegetation type is often found on moderately undulating plains and is characterised by the presence of a mixture of Fynbos (Acmadenia obtusata, Euryops ericifolius), Grassland (Themeda triandra, Eustachys paspaloides), Succulent Karoo (Pteronia incana), and Thicket element bushclumps. The distribution of this vegetation type is restricted to shallow stony soils strongly influenced by an underlying calcareous substrate

20.

The Coega Bontveld contains many highly localized endemics and has many Species of Special Concern, often in the form of small succulents and geophytes. Furthermore, the geophytes are often dormant for a large part of the year, and therefore effectively undetectable.

This vegetation type is classified as Least Threatened with a conservation target of 19%. 10% has been conserved in the Greater Addo Elephant National Park and 6% has been transformed by cultivation and urbanisation.

The previously assessed pipeline routes cross the Coega Bontveld (described above), the Sundays River Thicket and the Algoa Dune Strandveld. The Sundays River Thicket vegetation type occurs in the Eastern Cape Province and is characterised by undulating plains and low mountains and foothills covered with tall dense thicket. The thicket is composed of a mosaic of predominantly spinescent species that include trees, shrubs and succulents. It is classified as Least Threatened with a conservation target of 19%. 6% has been transformed by cultivation and urban development. The Algoa Dune Strandveld vegetation type occurs in the Eastern Cape Province along the narrow coastal belt between the mouth of the Tsitsikamma River and the Sundays River Mouth. It is characterised by tall dense thickets that occur on sand dunes outside of the influence of salt spray and is dominated by stunted trees, shrubs, lianas and sparse herbaceous and grassy undergrowth. It is classified as Least Threatened with a conservation target of 20%. 4% is statutorily conserved and more than 10% has already been transformed for cultivation, urban development and road building.

20 Watson, J.J. (2002) Bontveld ecosystem functioning, and rehabilitation after strip mining. Unpublished PhD. N.M.M.U. Port Elizabeth. 257 pp.

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Figure 18: National Vegetation Map (Mucina and Rutherford, 2006) indicating that the project site occurs within the Coega Bontveld vegetation type (CES, 2013)

Subtropical Thicket Ecosystem Programme (STEP)

The Subtropical Thicket Ecosystem Programme (STEP) (2003) aims to identify priority areas that would ensure the long-term conservation of the subtropical thicket biome and to ensure that the conservation of this biome is considered in the policies and practices of the private and public sector that are responsible for land-use planning and the management of natural resources in the region (Pierce et al. 2005). STEP identifies one vegetation type in the project area. Pierce and Mader (2006) define this vegetation type as Grass Ridge Bontveld, a vegetation type characterised by small patches of Sundays Valley Thicket which occur in a matrix of species characteristic of fynbos (Acmadenia obtusata, Euryops ericifolius), succulent karoo (Pteronia incana) and grassland (Themeda triandra, Eustachys paspaloides). This vegetation type contains many highly localized endemics and is listed as Currently Not Vulnerable.

Nelson Mandela Bay Metro Municipality Municipal Open Space System vegetation map

The Municipal Open Space System (MOSS) vegetation map (2009) was created for the Nelson Mandela Bay Municipality. Twelve habitats were defined and these divided into 58 vegetation types each of which was classified according to ecosystem status. The MOSS clearly follows the STEP vegetation classification, identifying the vegetation in the project area as Grass Ridge Bontveld. This vegetation type is classified as Vulnerable due to its localised distribution in the Eastern Cape and the threat from development (major development initiatives in the Coega IDZ area) in the region with a loss of 9.1% of habitat

21.

21

NMBM – Final Conservation Assessment and Plan, 2009

64

3.6.2. Fauna

Compared to its original state, there is a lack of pristine terrestrial environments present in Coega. This is primarily due to the presence of previous human activity, particularly the loss of indigenous vegetation by agricultural activities, alien plant invasion and various industrial developments in the area. The diversity of the terrestrial fauna in Coega, particularly large mammals, has therefore been greatly reduced.

Mammals

Large game makes up less than 15% of the mammal species in South Africa and a much smaller percentage in numbers and biomass. In developed and farming areas, this percentage is greatly reduced, with the vast majority of mammals present being small or medium-sized; nonetheless Kudu are often seen in the Coega IDZ on both the seaward and landward side of the N2. Sixty three mammal species are known or expected to occur in the area, 13 of which are Red Data Book species (four vulnerable, five rare and four intermediate species). Out of the sixty three species only the Duthie’s golden mole (Chlorotalpa duthiae) and the pygmy hairy-footed gerbil, (Gerbillurus paeba exilis) are endemic to the region. However, both are likely to be found in the dune areas with Duthie’s golden mole in the dune woodland and the pygmy hairy-footed gerbil in the open dune sand where there is little or no vegetation

22.

Large to medium size terrestrial mammals have been severely impacted by previous human activity, particularly the loss of vegetation, invasion of alien vegetation and varied industrial developments. Previous studies indicate that two species of special concern are likely to occur within the project site. These include the Fynbos golden mole (Amblysomus corriae) listed as Near Threatened and the Blue Duiker (Philantomba monticola) listed as Vulnerable, the latter is confined to forests, thickets or dense coastal bush and probably occurs in low numbers. The African wild cat, Felis lybica (Vulnerable) is found throughout the Eastern Cape and has a wide habitat tolerance and may occur in the Coega area. Additional wide-ranging mammals, listed as rare or vulnerable in the South African Red Data Book that may occur in the area are the aardvark, Orycteropus afer (Vulnerable), honey badger, Mellivora capensis, and the African hedgehod, Atelerix frontalis (Rare).

Birds

Nine bird species are endemic to South Africa, but there are no Eastern Cape endemics. However, there are 62 threatened species within the Eastern Cape Province. Most of these species occur in grasslands or are associated with wetlands, indicating a need to conserve what is left of these ecosystems.

The Coega region has a diverse avifauna, with over 150 species being resident or common visitors to the region. Most diversity occurs in the thicket clumps although the coastal area also supports specialised avifauna with a number of terrestrial birds being of conservation concern. Historical records indicate that there are six vulnerable bird species and twelve Near Threatened species likely to occur in the vicinity of the project site. These are the Roaseate tern, (Sterna dougalli) chestnut plover (Charadrius pallidus), white fronted plover (Charadrius marginatus), African black oyster catcher (Haematopus moquini), Damara tern (Sterna balaenarum) and the Caspian tern (Hydroprogne caspia). There is a nesting record for Damara terns to the east of the Coega River mouth and suitable breeding habitat occurs in the dune fields along the seaward margin of the port area. The RDB has the Damara Tern and African Oystercatcher species listed as Endangered and Near Threatened respectively. BirdLife International has revaluated these species’ Red Data status, using the latest set of IUCN criteria to rate their threat categories. The Damara Tern has been rated as Near Threatened, a lower risk category than in 2000, while the African Oystercatcher retains its rating as Near Threatened

23. Other species such as the Spotted Thick-knee (Burhinus capensis) and Kelp Gull (Larus

dominicanus), which are both rated as Least Concern, utilise the coastal area with nesting sites within the Cerebos and Port areas.

Other threatened occasional visitors to the region include the Stanley’s bustard (Neotis denhami), the Martial eagle (Polemaetus bellicosus) and the African marsh harrier (Circus ranivorus). All of which are considered Vulnerable in South Africa

24.

22

CEN, 2009. Final Environmental Impact Report: Roll-out phase of an Aquaculture operation for the grow-out of Litopenaeus vannamei prawn larvae for commercial purposes and a process plant in Zones 1 and 10 of the Coega IDZ respectively, Port Elizabeth.

23 SRK, 2013. Final Environmental Impact Report for the proposed cementitious material grinding plant, Coega Industrial Development Zone.

24 Barnes, K, 2000. The Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland.

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Reptiles

South Africa has 350 species of reptile, comprising 213 lizards, 9 worm lizards, 105 snakes, 13 terrestrial tortoises, five freshwater terrapins, two breeding species of sea turtle and one crocodile (Branch, 1998). Of those 350 reptile species, the Eastern Cape is home to 133 which include 21 snakes, 27 lizards and eight chelonians (tortoises and turtles). The majority of these are found in Mesic Succulent Thicket and riverine habitats. A total of 63 reptile species are believed to occur within the Coega IDZ, consultation of the Animal Demography Unit historical records indicates that 52 species of reptiles could occur within the project site. Although none of these species are listed as species of special concern on the IUCN Red Data List, five of these species appear on Appendix II of CITES and five are listed on the PNCO list with three being classified as protected species. The Snake skink (Scelotes anguina), a common burrower in sandy soils from Port Elizabeth to the Bushmans River and the Tasmans girdled lizard (Cordylus tasmani) which lives in old trees and aloe stems in the Sundays River Valley are endemic to the Algoa Bay coastal region.

The Eastern Cape has the richest diversity of land tortoises in the world and three of the five species can be found along the coastal belt, namely the mountain or leopard tortoise (Geochelone pardalis), angulate tortoise (Chersina angulate) and the parrot-beaked tortoise (Hompus areolatus) which is one of the smallest land tortoises in the world.

Amphibians

A total of 32 amphibian species and sub-species occur in the Eastern Cape, amounting to almost a third of the species recorded in South Africa, however; none of the species are endemic or RDB species. Amphibians are important in wetland systems, particularly where fish are excluded or of minor importance. In these habitats, frogs are dominant predators of invertebrates, many of which are disease vectors for malaria and bilharzia. Reports of declining amphibian populations continue to increase globally, even in pristine protected areas. These declines are not simple cyclic events; for example, frogs have been identified as bio-indicator species that reflect the wellbeing of aquatic ecosystems. Frog abundance and diversity is a poignant reflection of the general health and well-being of aquatic ecosystems.

Although no wetlands or streams were noted to occur within the project site, the proximity of the study area to the Coega River suggests that amphibians are likely to occur within this area during favourable conditions. Historical records indicate that 14 species of frogs have been documented in the Quarter Degree Squares that the project area falls within. However, none of these species are listed as species of conservation concern.

Terrestrial Invertebrates

The distribution of the terrestrial invertebrates found along the coast depends to a large degree on the extent and composition of the natural vegetation. One grasshopper species (Acrotylos hirtus) is endemic to the dune fields. Of nearly 650 butterfly species recorded within the borders of South Africa, 102 are considered of conservation concern and are listed in the South African RDB for Butterflies. Two have become extinct, whilst three rare butterflies are known from a number of scattered localities in the Coega region.

The small blue lycaenid butterfly (Lepidochrysops bacchus) is located in the Uitenhage and Coega areas. Another rare small copper lycaenid, Poecilimitis pyroeis, has a similar distribution to Lepidochrysops bacchus, extending from the Ssouthwestern Cape to Little Namaqualand. An isolated eastern race, P.p. hersaleki, was described from Witteklip Mountain (Lady’s Slipper) to the west of Port Elizabeth. It has also been recorded from St Albans and from the Baviaanskloof Mountains. There is currently no evidence that this rare butterfly occurs in the Coega area, or that a suitable habitat for the eastern race exists in the port area

25.

3.7. Heritage, Archaeological and Cultural Sites

The baseline section was compiled by specialists for studies conducted previously in the Coega IDZ. The Information for Zone 7 is based on a review of the Archaeological Assessment (AIA) by Dr Johan Binneman, the Paleontological Assessment (PIA) by Dr John Almond and the Historical (Burials) Assessment by Ms Jennie Bennie as part of the Heritage study for the Coega IDZ that was commissioned by the Coega Development Corporation in 2010. The information for Zone 8 was based on the Heritage Assessment (HIA)

25

Coastal and Environmental Services, 1997. Strategic Environemntal Assessment of the Coega IDZ – Terrestrial Specialists Report. Grahamstown.

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undertaken as part of the Basic Assessment for the Bulk Liquid Storage and Handling Facility (DEA EIA Reference Number 14/12/16/3/3/1/675 and NEAS Reference No: DEA/EIA/0001386/2012), compiled by CSIR

26.

Archaeological

The review of the archaeological features is based on findings from a Phase 1 Archaeological Impact Assessment (AIA) of the greater Coega Industrial Development Zone (IDZ) by Dr Johan Binneman, report dated May 2010

27 (Figure 19).

Finding archaeological materials or sites is made difficult in Zone 7 due to the dense grass, bush and alien vegetation occurring across the zone. Bush clearing is occurring mainly towards the western side of the zone for large scale development infrastructure, most noticeably a road running from east to west of the zone. The bush clearing activities for this road exposed a thin layer of grey dune sand, which covers the dominant geological formation of Calcrete, and thin scatters of archaeological material towards the eastern side of the zone. A thin spread of marine shell was noted over a fairly large area. Fragments of bone, a tooth and stone tools and pottery were also associated with the shell spread. The bulldozing activities associated with the building if the road exposed Middle Age stone tools. It is unknown how many archaeological sites were destroyed when these areas were bulldozed.

Figure 19: The map shows the route where “spot checks” were undertaken as part of the Phase 1 AIA. The blue circles spot checks and survey areas and the pink dots mark where Later and Middle Stone Age materials were found (Map source: Binneman, 2010). The yellow square indicates the locality of the proposed FIS site.

26

CSIR, 2013. Final Basic Assessment Report for the Provision of Landside Structures and Infrastructure to the Bulk Liquid Storage and Handling Facility in the Port of Ngqura within the Coega IDZ, Nelson Mandela Bay Municipality, CSIR Report No. CSIR/CAS/EMS/ER/2012/0017/B.

27 Binneman, J. 2010. A Phase 1 Archaeological Impact Assessment of the greater Coega IDZ, near Port Elizabeth, Nelson Mandela Bay Municipality, Eastern

Cape Province. Eastern Cape Heritage Consultants, Jeffreys Bay.

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Zone 8, similarly to Zone 7 and much of the Coega IDZ, is covered in dense vegetation making it difficult to locate archaeological sites or materials. The shallow topsoil covering the Coega region does not allow for any deep archaeological deposits or features.

It is predicted that mainly Earlier, Middle and Late Stone Age tools associated with exposed pebble/cobble gravels will be exposed during the construction/ laying of the pipes. However, other archaeological sites/ materials (such as human remains and shell middens) may be covered by soil and vegetation and there is the possibility that these may be exposed during development. In general the proposed area for development is of low archaeological significance and the proposed development will have little impact on possible archaeological sites/materials.

Paleontological

Zone 7, is situated between the N2 National road and Zone 10, which is adjacent to the coast. A secondary dune system stretches out across Zone 7. Large scale infrastructural development is taking place mainly towards the western side of the zone. These include the building of bridges, roads, a power substation power lines, a massive quarry and construction of bridges. A new road is being constructed east to west of the zone, parallel to the N2 on the boundary between Zones 7 and 10.

Zone 8 is located to the west of Zone 7 and is situated in the Port of Ngqura, East of the Coega River. It is located south east of the N2 and is approximately 15 km south east of Port Elizabeth, NMBM, Eastern Cape Province.

The review of the paleontological features is based on findings from a PIA done by Dr John Almond, report dated July 2013. The proposed pipelines are located in an area that is underlain by potentially fossil rich sedimentary rocks of Mesozoic and younger, Tertiary or Quaternary age. The construction of the pipelines with the berth in the Port of Ngqura will entail major excavations into the superficial sediment cover as well the underlying bed rock.

The paleontological areas of higher sensitivity can be found two areas of Zone 8 and part of Zone 7: 1. The outcrop of Sundays River Formation (this exists at depth beneath the tank footprint) as well as;

2. A zone along the Eastern bank of the Coega River Estuary with 18m masl where Pleistocene shell

beds of the Salnova Formation occur.

Historical and cultural

The historical report compiled by Jenny Bennie as part of the Heritage Assessment for the Coega IDZ (commissioned by the Coega Development Corporation in 2010) concluded that no culturally sensitive pre- 18

th

century structures were observed in the designated zones of the Coega IDZ. However, oral history could possibly show a variety of cultural groups such as Early, Middle and Stone Age man, San, Khoekhoen and black Xhosa speaking people passed through the area. The area was also inhabited by the Trekboer, Dutch and British 1820 settlers, who left some remnants of their cultures in the form of buildings and demarcated grave sites.

According to the historical assessment of the Coega Industrial Zone, the Hougham Park homestead is located in Zone 7. The Homestead consists of a house and cottage and has been identified as having potential heritage value. The Homestead belonged to Hougham Hudson, who bought the property, originally named Samson’s Kraal, from Ingnatius Stephanus Ferreria and renamed it Hougham Park in 1837. There are no reports of burial grounds and graves in this zone. The report also makes mention of three shipwrecked sailors, who were grounded in 1817. There remains have not been found and could be excavated in the dunes of Zones 1, 7 and 10.

3.8. Social and Economic Environment

Regional overview

Nelson Mandela Bay Municipality (NMBM) is situated in the Eastern Cape Province and covers an area of 1950km

2. Port Elizabeth, located within the NMBM, is South Africa’s second oldest city and is also the

commercial capital of the Eastern Cape. Uitenhage and Despatch also form a part of the NMBM.

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According to the Census carried out in 2011 the NMBM has a total population of approximately 1.15 million; which shows a 1.4% increase from the 2001 census of approximately 1.1 million

28. Table 24 shows an

estimated population trend for the period from 2006 to 2020. The city has a relatively youthful population, with 37% of residents between the ages of 15 and 34 years, indicating that education and job creation require serious attention. Altogether 26.2% of the population is below the age of 15 years, while 5.3% is 65 years and above.

Table 24: Nelson Mandela Bay population trend

Year Total Asians (%) Blacks (%) Coloureds (%) Whites (%)

2006 1 160 740 1.1 56.7 23.5 18.8

2010 1 193 430 1.1 56.2 23.7 19.0

2015 1 224 630 1.1 56.0 24.1 18.8

2020 1 243 930 1.0 55.9 24.4 18.7

The results of the 2007 Community Survey29

indicates that approximately 270 296 people are employed and 179 920 people are unemployed, which represents 25.72 % and 17.12 % of the total NMBM population respectively. Approximately 24.61 % of the total NMBM population is considered to be economically inactive. Figure 20 below illustrates the employment levels in the NMBM.

Figure 20: Employment levels in the NMBM (Statistics SA, 2008)

Economic profile of local municipality

In terms of the income levels of the NMBM population aged between 15 and 65 years, approximately 380 890 people had no form of formal income, whilst 356 people fell within the highest income bracket (R 294 801 or more) as illustrated in Figure 21. Comparatively, 95 922 people earn between R 801 and R 1 600. It can be derived from Figure 21 that a large amount of the population aged between 15 and 65 earn within the lower income brackets.

28

Statistics South Africa, Census 2011.

29 Statistics South Africa. Community Survey 2007: Statistical Release Basic Results Municipalities

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Figure 21: Income category in the NMBM (Statistics SA, 2008)

Figure 22 illustrates the occupation categories for the NMBM population aged between 15 and 65 years old based on the 2007 Community Survey. Derived from Figure 12, it is clear that the majority of the economically active population contain elementary occupations (a total of 14.44 %). On the other hand, 1.51 % of the total economically active population have occupations as skilled agricultural and fishery workers, which represents the minimum.

Figure 22: Occupation categories of the NMBM population (Statistics SA, 2008)

Figure 23 below indicates the main industrial and economic sectors that the economically active population are employed within based on the 2007 Community Survey. The Manufacturing Sector employs the highest number of people, whilst the minimum of the employed NMBM population is involved in the Mining and Quarrying Sector. The Electricity, Gas and Water Supply Sectors employ the second lowest number of people. The Construction Sector includes approximately 19 432 of the employed NMBM population.

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Figure 23: Industry sectors of the NMBM population (Statistics SA, 2008).

Level of education

The 2007 Community Survey assessed the level of education for the NMBM and approximately 11.96 % of the total population obtained a Grade 12 without a university exemption, and 2.49 % obtained Grade 12 with a university exemption (refer for Figure 24 below). Approximately 8.49 % of the total population acquired some form of higher education such as certificates, diplomas and degrees. In addition, only 3.87 % of the total population received no schooling.

Figure 24: Level of education in the NMBM (Statistics SA, 2008).

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4. Public Participation Process The PPP forms a key component of the EIA process. The objectives of the PPP are outlined below, followed by a summary of the approach taken, and the issues raised thus far.

4.1. Objectives and Approach

The overall aim of the PPP is to ensure that all I&APs have adequate opportunities to provide input into the process. More specifically, the objectives of the PPP are as follows:

Identify I&APs and notify them of the proposed project and of the EIA process;

Provide an opportunity for I&APs to raise issues and concerns;

Provide an opportunity for I&APs to review the draft Environmental Impact Report prior to its

finalisation; and

Provide an opportunity for I&APs to ensure the comments received on the draft EIR are

addressed adequately in the final EIR prior to submission to the competent authority for

authorisation.

4.2. Authority Consultation

4.2.1. Application for Authorisation

a) EIA application form

The prescribed EIA form (in terms of the activities identified within Section 4.2) was submitted to the DEDEAT on the 24

th of July 2012. DEDEAT acknowledged receipt of the application form in a letter dated 14

th of August

2012 and provided the following reference number:

DEDEAT Reference: ECm1/LN2/M/12-47

b) Waste Management License Application form

The WML application form was submitted to the DEA on the 4th of December 2012. The DEA acknowledged

receipt of the application form in a letter dated 13th of December 2012 and provided the following reference

number:

DEA Reference: 12/9/11/L1124/1

Please note that the WML application will remain with the DEA Waste Directorate for assessment until such time as the EAP is advised otherwise. Please refer to Section 1.4.7.2 for more information on the waste classification of the feedstock.

c) Air Emissions License Application form

The AEL application form was submitted to the NMBM on the 4th of December 2012. The NMBM acknowledged

receipt of the application form in a letter dated 18th of December 2012 and provided the following reference

number:

NMBM Reference: 19/2/9/2/1/2/L024-2.2/6.1.

Refer to Appendix G for copies of acknowledgement of receipt of the application forms.

4.2.2. Continued Authority Involvement

The draft Environmental Impact Report was circulated to all relevant authorities for comment. All comments received were considered and responded to within the issues trail (Appendix H).

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4.3. Stakeholder Engagement

The stakeholder engagement process has been, and will continue to be, undertaken in accordance with Chapter 6 of the NEMA 2010 EIA Regulations. The process was conducted to ensure that the widest range of potential stakeholders were identified and provided with an opportunity to review the details of the project. Refer to Appendix H for proof of the public participation that has been undertaken to date.

4.3.1. Stakeholder Database

The proposed project is located within the Coega IDZ. The IDZ provided the names of the surrounding landowners adjacent to the site. The CDC holds an ELC meeting every quarter which aims to inform the relevant environmental authorities from different tiers of government of the proposed projects undertaken in the Coega IDZ. These meetings assist with informing the EAP of potential impacts and processes which have to be undertaken. The ELC members were included in the distribution list. Other stakeholders included in the list are the surrounding companies as well as the applicable heritage authority.

The original stakeholder database was updated with those stakeholders who registered as a result of the newspaper adverts and electronic notice (e-notice). Names and contact details of all identified persons, groups, organisations and institutions are recorded in the stakeholder database list attached in Appendix H.

4.3.2. Legal Notices

A public notice was placed in a regional and local newspaper. The relevant newspaper and date of placement is indicated in Table 25. The notice was published in English and Afrikaans.

Table 25: Newspapers and date of publication

Newspaper Date of Publication

The Herald (English) 26th of July 2012

Die Burger (Afrikaans) 26th of July 2012

In addition to the placement of the legal notices in the above mentioned newspapers, a site notice was uploaded onto the e-notice board located in the foyer of the CDC’s head office in the Coega IDZ, affording interested and Affected Parties (I&AP) to provide comments and register as an I&AP for future notifications.

4.3.3. Stakeholder Engagement

An ELC meeting was conducted on the 23rd

of August 2012 at the DEDEAT’s offices in Port Elizabeth. The objective of the meeting was to present the respective projects requiring environmental authorisation currently being undertaken within the Coega IDZ. ELC meetings were also conducted on the 14

th of February 2013 and

the 22nd

of August 2013 in which the findings of the draft Scoping Report and the preliminary findings of the draft Environmental Impact Report (EIR) were presented to the ELC members respectively. Most recently an ELC meeting was held on the 20

th of February 2014 in which the findings of the draft EIR were presented. The

issues and comments received were incorporated into the draft EIR and subsequently into the final EIR (this report) and are reflected within the Issues Trail in included Appendix H.

4.3.4. Draft Environmental Impact Report Availability

All registered stakeholders and I&APs were provided with a 40 day comment period from the 20th of May 2014

to the 30th of August 2014. All Registered I&APs were notified of the process of submission of comments

related to the draft EIR. All issues or comments on the draft EIR that were received, and the appropriate responses, are included in the issues trail attached in Appendix H.

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4.3.5. Issues Trail

I&APs and stakeholders have raised issues and concerns regarding the proposed FIS Biodiesel facility. An issues trail was developed at the outset of the stakeholder engagement process. The issues trail contains all the issues, comments and queries received from stakeholders during the stakeholder engagement process and provides appropriate responses. The issues trail is attached in Appendix H, along with copies of written correspondence received from I&APs and the list of registered and notified I&APs.

4.3.6. Final Environmental Impact Report Availability


th of August 2014








WSP believes that the final EIR provides an accurate reflection of the public participation process and the issues identified.


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5. Environmental Impacts

5.1. Identification of Potential Impacts

Collection of baseline information was undertaken in order to establish the sensitivity of the environment to potential project impacts, and to determine constraints that the environment may have on the project. Information was obtained from existing reports such as the Coega Rezoning EIAs, aerial photography, and 1:50 000 topographical maps for the area as well as a site visit.

Using the information from the technical review and the environmental aspects of the project the resultant potential impacts were identified; where ‘issues’ and ‘impacts’ are clarified to mean:

■ Environmental Issues: Element of the project and associated activities that can interact with the environment. In the identification of issues, the following could be considered: discharges or releases to water and land, emissions to air, the use of raw material and natural resources as well as generation of waste and by-product.

■ Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or partially, resulting from an environmental aspect.

Following the identification of the main issues applicable to the proposed FIS facility, the following specialist studies (Table 26) were identified and the proposed methodology outlined within the Plan of Study that was approved by the DEDEAT. All the specialist studies undertaken as part of the EIA are included in Appendix F of the EIR.

Table 26: Specialist Studies

Environmental Issue Specialist Study Specialist Organisation

Airborne Emissions Air Quality Impact Assessment


Water Management Storm Water Management Plan


Waste Management Waste Management Best Practicable Assessment

Barry Roberts WSP Environmental

Ecological impacts Ecological Impact Assessment

Tarryn Martin Coastal & Environmental Services

Traffic generation Traffic Impact Assessment Christo Bredenhann WSP Group

Handling of Hazardous Substances

Major Hazardous Installation

Terence Thackwray MHR Consultants

Table 27 identifies the environmental issues that have been addressed by the EAP in consultation with the project team, consultants, specialists and engineers:

Table 27: Environmental Issues addressed by the EAP

Environmental Issue Assessment Section in report

Heritage/cultural aspects Desktop assessment Section 12

Socio-Economic Impacts Desktop assessment Section 13

Noise Impacts Desktop assessment Section 14

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In addition to the above the following secondary potential environmental issues (Table 28) and associated impacts have been addressed by the EAP through standard mitigation measures (in line with the CDC’s specifications and guidelines) in the Environmental Management Programme, without an assessment of significance.

Table 28: Environmental Issues addressed by the EAP through standard mitigation measures

Environmental Issue Assessment Section in report

Visual impact Desktop assessment Section 14

5.2. Impact Rating Methodology

The potential environmental impacts have been evaluated by the specialists according to their severity, duration, extent and significance of the impact. Furthermore, cumulative impacts were also taken into consideration. WSP’s Risk Assessment Methodology was used for the ranking of the impacts.

This system derives environmental significance on the basis of the consequence of the impact on the environment and the likelihood of the impact occurring. Consequence is calculated as the average of the sum of the ratings of severity, duration and extent of the environmental impact. Likelihood considers the frequency of the activity together with the probability of an environmental impact occurring. The following tables describe the process in more detail:

Consequence

Table 29: Assessment and Rating of Severity

Rating Description

1 Negligible / non-harmful / minimal deterioration (0 – 20%)

2 Minor / potentially harmful / measurable deterioration (20 – 40%)

3 Moderate / harmful / moderate deterioration (40 – 60%)

4 Significant / very harmful / substantial deterioration (60 – 80%)

5 Irreversible / permanent / death (80 – 100%)

Table 30: Assessment and Rating of Duration

Rating Description

1 Less than 1 month / quickly reversible

2 Less than 1 year / quickly reversible

3 More than 1 year / reversible over time

4 More than 10 years / reversible over time / life of project or facility

5 Beyond life of project of facility / permanent

Table 31: Assessment and Rating of Extent

Rating Description

1 Within immediate area of activity

2 Surrounding area within project boundary

3 Beyond project boundary

4 Regional / provincial

5 National / international

Consequence is calculated as the average of the ratings of severity, duration and extent of the environmental impact.

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Table 32: Determination of Consequence

Determination of Consequence (C) Equation

Consequence (C) = (Severity + Duration + Extent) / 3

Likelihood

Table 33: Assessment and Rating of Frequency

Rating Description

1 Less than once a year

2 Once in a year

3 Quarterly

4 Weekly

5 Daily

Table 34: Assessment and Rating of Probability

Rating Description

1 Almost impossible

2 Unlikely

3 Probable

4 Highly likely

5 Definite

Likelihood considers the frequency of the activity together with the probability of the environmental impact associated with that activity occurring.

Table 35: Determination of Likelihood

Determination of Likelihood (L) Equation

Likelihood (L) = (Frequency + Probability) / 2

Environmental significance

Environmental significance is the product of the consequence and likelihood values.

Table 36: Determination of Environmental Significance

Environmental Significance (Impact)

= C × L

Description

L (1 – 4.9) Low environmental significance

LM (5 – 9.9) Low to medium environmental significance

M (10 – 14.99) Medium environmental significance

MH (15 – 19.9) Medium to high environmental significance

H (20 – 25) High environmental significance. Likely to be a fatal flaw.

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6. Air Quality Impact Assessment

6.1. Introduction

As part of the EIA process, a specialist Air Quality Impact Assessment (AQIA) is required to determine the impacts of the proposed biodiesel plant on air quality in the region. This report details the expected impacts of such a plant on air quality in and around the Coega IDZ area.

An air quality study is essential in this project to assess the risk areas and identify mitigation options that may be necessary to ensure compliance with relevant standards.

6.2. Study specific assumptions and limitations

Various assumptions were made in this baseline air quality screening study. These assumptions and associated limitations include the following:

■ It was assumed that the plant capacity at Coega will be the same as the capacity at the HeroBX Erie plant (170,000 tons).

■ It was assumed that all processes that occur at the HeroBX Erie plant are representative of the proposed FIS site.

■ It was assumed that all specifications provided and used in the model for the proposed operations are representative of reality.

■ It was assumed that the meteorological data and ambient air quality data utilised in the assessment is representative of reality.

■ The stack test results for the vent recovery system from the HeroBX Erie plant are assumed to be representative of emissions from the FIS facility.

■ PM10, NOx and SO2 emissions from the boilers are uncontrolled with no abatement in place.

■ Boiler emissions in the assessment were based on two 700 hp Heavy Fuel Oil (HFO) boilers.

■ It was assumed that the methanol and sodium methylate tanks will be nitrogen blanketed, as is the case at the HeroBX plant.

■ Temperature of liquids in storage tanks was assumed to be ambient.

■ All biodiesel (170 000 tons per annum) enters the biodiesel tanks, biodiesel QC tanks and biodiesel retention tanks.

■ Maximum liquid height in the tanks was assumed as 95% of the tank height.

■ Average liquid height in the tanks was assumed as 60% of the tank height.

■ The height of release of emissions from the tanks was assumed the same as the tank height.

■ Vents from the tanks were assumed to have a standard diameter of 100 mm.

■ Emissions from the biodiesel storage tanks were based on diesel specifications, which produce a worst case scenario of emissions.

■ The emission reduction efficiency for the loading of fuel to tankers was assumed, as a worst case, to be 1%.

6.3. Atmospheric Emissions and Impacts

6.3.1. Airborne Emissions

Ambient air quality monitoring has been conducted in the Coega IDZ from 2006 to 2012. The monitoring network consists of three monitoring stations at Saltworks, Amsterdamplein and Motherwell. The data reported

78

in the 2006 Annual Report (Ecoserv, 2007) and the 2012 quarterly monitoring reports confirms that ambient concentrations of criteria pollutants for the region are below the stipulated NEMAQA standards. It should be noted that various proposed developments within the Coega IDZ will cumulatively impact on the future air quality in the region, which will need to be closely monitored. As such, the Eastern Cape Air Quality Management Plan which is currently out for public review, indicates that such expansion within the Coega IDZ could result in deteriorations in the air quality of the Nelson Mandela Bay region and it is suggested that the Coega IDZ may be declared a Priority Area in terms of the National Environmental Management: Air Quality Act.

6.3.2. Sensitive Receptors

The existing emission sources in and around the Coega IDZ area include industrial activity, biomass burning (industrial), domestic fuel burning, vehicles and agricultural activities. Within the Coega area and its surrounds, sparsely vegetated and denuded areas are common, as well as degraded areas associated with construction in the IDZ. With frequent moderate to strong winds, dust easily becomes entrained and is transported away from the area, impacting on regional air quality, particularly in winter.

Sensitive receptors are identified as areas that may be negatively impacted on by emissions from the proposed biodiesel plant. Examples of receptors include, but are not limited to, schools, shopping centres, hospitals, office blocks and residential areas. The sensitive receptors identified in the area surrounding the biodiesel plant, are presented in Table 37.

Table 37: Location of sensitive receptors surrounding the proposed biodiesel production plant.

Receptor Direction from nearest plant boundary

Distance from plant boundary (km)

Motherwell (residential area) WSW 7.9

St Georges Strand (residential area) SSW 6.8

Wells Estate (residential area) SW 7.7

Blue Water Bay (residential area) SSW 9.5

Colchester (residential area) NE 11.1

Port Elizabeth (residential areas and CBD) SSW 14.5

6.3.3. Key atmospheric pollutants

The main sources of emissions at the proposed biodiesel production facility include the two heavy fuel oil (HFO) fired boilers, the atmospheric vent system from the transesterification building, the onsite storage tanks, the idling of trucks during delivery/collection and the loading of fuel to tankers. Figure 25 shows the proposed site layout of the biodiesel facility, indicating the locations of the main emission sources.

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Figure 25: FIS Biodiesel facility plant layout and main emission sources (WSP, 2013)

Emissions from the onsite boilers include nitrogen oxides (NOx), carbon monoxide (CO), sulphur dioxide (SO2) and particulate matter (PM), which are all emitted as a result of the combustion of HFO within the boilers. Emissions from the atmospheric vent system include volatile organic compounds (VOCs), methanol and hexane. Methanol is created during the biodiesel production process and may escape the vent recovery system and be emitted into the atmosphere. Trace amounts of hexane may be emitted from the vent recovery system. Hexane is used in the oilseed production process to remove oil from seeds/beans and some residual hexane may remain in the oil feedstock that is then utilised in the biodiesel production process.

A key emission from the onsite storage tanks (including all biodiesel and HFO storage tanks) is VOCs that are emitted as fugitive vapours from the tanks. The methanol and sodium methylate tanks, although vented to the vent recovery system, will also be nitrogen blanketed which keeps the temperatures low and limits evaporation to the atmosphere. VOCs are also emitted at the facility during the loading of tanker trucks at the loading bays, although emissions can be minimal provided that the loading bays are fitted with vent recovery units. On delivery of feedstock and collection of product, trucks will idle, generating combustion emissions from the truck engines. Such emissions include VOCs, CO, NOx and PM10. It must be noted, that delivery and collection of feedstock and product may also occur via pipeline to and from the Port of Nqura, decreasing emissions associated with vehicles. As such, two emission scenarios (truck dispatch and pipeline dispatch) were presented in the AQIA and subsequently modelled.

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6.4. Relevant legislation

The new National Environmental Management: Air Quality Act 39 of 2004 (NEMAQA), which repeals the Atmospheric Pollution Prevention Act of 1965, came into effect on 11 September 2005, with the promulgation of regulations in terms of certain sections resulting in the APPA being repealed entirely on 1 April 2010. Persons undertaking such activities are required to possess an Atmospheric Emission License (AEL), essentially the equivalent of a Registration Certificate under the APPA.

The NEMAQA introduced a management system based on ambient air quality standards and corresponding emission limits to achieve them. Two significant regulations stemming from NEMAQA have been promulgated recently, which are:

GNR 1210 on 24 December 2009 (Government Gazette 32816) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) National Ambient Air Quality Standards.

GNR 893 on 22 November 2013 (Government Gazette 33064) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) List of Activities Which Result in Atmospheric Emissions Which Have or May Have a Significant Detrimental Effect on the Environment, Including Health, Social Conditions, Economic Conditions, Ecological Conditions or Cultural Heritage, an update to the original GNR 248.

The new national ambient standards for air quality were based primarily on guidance offered by two standards set by the South African National Standards (SANS), namely:

SANS 69:2004 Framework for implementing national ambient air quality standards.

SANS 1929:2005 Ambient air quality – Limits for common pollutants.

SANS 69:2004 makes provision for the establishment of air quality objectives for the protection of human health and the environment as a whole. Such air quality objectives include limit values, alert thresholds and target values.

SANS1929:2005 uses the provisions in SANS 69 to establish air quality objectives for the protection of human health and the environment, and stipulates that limit values are initially set to protect human health. The setting of such limit values represents the first step in a process to manage air quality and initiate a process to ultimately achieve acceptable air quality nationally. The limit values presented in this standard are to be used in air quality management but have only become enforceable as revised under GNR 1210 since 24 December 2009. National ambient air quality standards for criteria pollutants generally have specific averaging periods; compliance timeframes, permissible frequencies of exceedance and reference methods.

Pollutants of concern from the proposed biodiesel plant include nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), particulate matter (PM), volatile organic compounds (VOCs), methanol (CH4O) and hexane. The relevant South African standards against which the concentrations from the proposed plant will be assessed are presented in Table 38.

Table 38: South African National Ambient Air Quality Standards applicable to the biodiesel processing plant

Nitrogen Dioxide (NO2)

Averaging Period Concentration (µg/m3) Frequency of

Exceedance Compliance Date






10 min 500 526 Immediate


Daily 125 4 Immediate

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Hourly 30 000 88 Immediate

8 Hourly 10 000 11 Immediate







Averaging Period Concentration (µg/m3) Frequency of Exceedence

Compliance Date


Daily 40 4 01/01/2016 – 31/12/2029


Annual 20 0 01/01/2016 – 31/12/2029

According to the NEMAQA listed activities, VOC emissions from the biodiesel storage tanks onsite are regulated under subcategory 2.4: The Storage and Handling of Petroleum Products. Category 2 relates to the production of gaseous and liquid fuels as well as petrochemical from crude oil, coal, gas and biomass. Where biomass is described as “non-fossilised and biodegradable organic material originating from plants, animals and microorganisms”. WVO will therefore be seen as originating from plants and the animal fat from animals. The feedstock used on site will therefore fall within the definition of biomass. According to the Petroleum Product Act (Act No. 120 of 1977), a petroleum product is “any petroleum fuel and any lubricant, whether used or unused, and includes any other substance which may be used for a purpose for which petroleum fuel or any lubricant may be used”. The biodiesel produced on site can either be used as fuel for vehicles in its pure form or used as part of a petroleum product blend (consisting out of petroleum petrol or diesel and biodiesel). The biodiesel produced on site is therefore seen as a petroleum product since it can utilised for the purpose for which a petroleum fuel is used for. The special arrangements that apply for storage vessels of any petroleum products are presented in Table 39.

Table 39: Storage specifications for petroleum liquids products (NEMAQA, listed activities, Category 2: Petroleum Industry, Subcategory 2.4)

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

True vapour pressure of contents at product storage temperature

Type of tank or vessel

Type1: Up to 14 kPa Fixed-roof tank vented to atmosphere, or as per Type 2 and 3

Type 2: Above 14 kPa and up to 91 kPa with a throughput of less than 50,000 m³ per annum

Fixed-roof tank with Pressure Vacuum Vents fitted as a minimum, to prevent “breathing” losses, or as per Type 3

Type 3: Above 14 kPa and up to 91 kPa with a throughput greater than 50,000 m³ per annum

d) External floating-roof tank with primary rim seal and secondary rim seal for tank with a diameter greater than 20 m, or

e) Fixed-roof tank with internal floating deck / roof fitted with primary seal, or

f) Fixed-roof tank with vapour recovery system.

Type 4: Above 91 kPa Pressure vessel

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The biodiesel storage tanks at the FIS facility will have a cumulative tankage capacity of greater than 1 000m³, thus the above specifications will need to be followed and an atmospheric emission licence (AEL) is required.

Minimum emission standards for VOCs, that apply to the loading and offloading of petroleum products as set out in the listed activities (subcategory 2.4), as set out in the listed activities apply to all installations with a throughput of greater than 50 000m³ per annum of products with a vapour pressure of greater than 14kPa. These installations also need to be fitted with vapour recovery units. Although the biodiesel throughput at the FIS facility exceeds the 50 000m³ threshold, the biodiesel stored has a vapour pressure of less than 14kPa, thus a vapour recovery unit does not need to be installed for loading operations and the minimum emission standards will not apply to the loading operations at the FIS facility.

Methanol and hexane are listed as hazardous air pollutants (HAPs) in the United States Clean Air Act Amendments of 1990 (US EPA, 1994), however, there are currently no South African standards for their assessment in ambient air. Concentrations will therefore be assessed against international environmental and occupational health and safety guidelines as presented in Table 40 and Table 41.

Table 40: International air quality standards and guidelines for methanol

Averaging Period UK IPPC Environmental Assessment

Level

Occupational Safety and

Health Administration

(OSHA)

National Institute for

Occupational Safety and

Health (NIOSH)

Ontario’s Ambient Air

Quality Criteria

Government of Alberta Air

Quality Guidelines

Immediate danger to life and health

7 860 000 µg/m3

15 minute 325 000 µg/m3

Hourly 33 300 µg/m3 2 600 µg/m

3

8-hr 260 000 µg/m3 260 000 µg/m

3

Daily 4 000 µg/m3

Annual 2 660 µg/m3

Table 41: International air quality standards and guidelines for hexane

Averaging Period US EPA Vermont Agency of Natural Resources

OSHA NIOSH

8-hr 1,800,000 µg/m3 180,000 µg/m

3

Daily 4,300 µg/m3

Annual 200 µg/m3

According to the NEMAQA listed activities, methanol and hexane as VOCs are regulated under Category 6: Organic Chemical Industry. The relevant standards for cumulative VOC emissions from the biodiesel production process, i.e. emissions that exit the vent recovery system of the biodiesel production process, are presented in Table 42. The minimum emission standard that applies to the FIS facility will be for the non-thermal treatment of volatile organic compounds which, as per the NEMAQA, stipulates that non-thermal applies to “the removal of VOCs through non-combustion processes including but not limited to cryogenic cooling, scrubbing and vapour recovery”.

Table 42: Minimum emission standards associated with the organic chemicals industry (NEMAQA, listed activities, Category 6: Organic Chemicals Industry)

Description: The production or use in production of organic chemicals not specified elsewhere including acetylene, acetic, maleic, phtalic anhydride or their acids, carbon disulphide, pyridine, formaldehyde, acetaldehyde, acrolein and its derivatives, acrylonitrile and synthetic rubber.

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The production of organometallic compounds, organic dyes and pigments, surface-active agent.

The polymerisation or co-polymerisation of any unsaturated hydrocarbons, substituted hydrocarbon (including vinyl chloride).

The manufacture, recovery or purification of acrylic acid or any ester of acrylic acid.

The use of toluene di-isocyanate or other di-isocyanate of comparable volatility; or recovery of pyridine.

Application: All installations producing or using more than 100 tons per annum of any of the listed compounds.

Substance or mixture of substances

Plant status

mg/Nm3 under

normal conditions of 273 Kelvin and 101.3kPa. Common name Chemical symbol

Total volatile organic compounds (thermal) N/A

New 150

Existing 150

Total volatile organic compounds (non -thermal)

N/A

New 40 000

Existing 40 000

6.5. Methodology

Emissions from the plant were calculated using the US Environmental Protection Agency’s (EPA) AP42 emission factors. An emission factor is a value representing the relationship between an activity and the rate of emissions of a specified pollutant. The AP42 emission factors have been compiled since 1972 and contain emission factors and process information for over 200 air pollution source categories. These emission factors have been developed based on test data, material mass balance studies and engineering estimates.

6.5.1. Emissions inventory

The following sources and information were used to compile the emissions inventory:

6.5.1.1. Vent Recovery System

Emissions from the vent recovery system were obtained from stack test data provided for the Erie biodiesel plant. The stack specifications and emission rates utilised in the dispersion model for the vent recovery system are presented in Table 43. Table 43: Vent Recovery System stack specifications and emission rates.

Vent Recovery System Emission Rates

Stack/Vent Height 12 m

Stack/Vent Diameter 0.15 m

Exit Temperature 93.13 °C

Exit Velocity 5.97 m/s

VOC Emission Rate 0.04 g/s

Hexane Emission Rate 0.02 g/s

Methanol Emission Rate 0.02 /s

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6.5.1.2. Boilers

SO2, NOx, CO and PM10 emissions from the HFO boilers on site were calculated using the US EPA’s AP42 emission factors for fuel oil combustion in industrial boilers with a heat input capacity of less than 29 MW. It is envisaged that at nameplate capacity, there will be two 700hp boilers in operation at the site which is equivalent to a heat input capacity of 13 MW. The calculations for the boilers are uncontrolled, with no abatement in place, thus representing a worst case emission scenario.

Table 44: Emission factors for fuel oil combustion

Pollutant Emission Factor (lb/10³ gal) Calculated Emission Rate (g/s)

SO2 157S 23.06

NOx 55 2.31

CO 5 0.21

PM10 7.17A 1.29

6.5.1.3. Tanks

The estimation of emissions from the two biodiesel storage tanks, three biodiesel quality control (QC) tanks, biodiesel retention tank and the HFO storage tank onsite was performed using the US EPA’s TANKS 4.0.9 model.

Emissions from the methanol and sodium methylate tanks were not considered in these calculations as these tanks are vented to the main vent recovery system, so any residual emissions from these tanks will exit the plant from the main vent. These tanks will also be nitrogen blanketed so projected emissions will be minimal.

6.5.1.4. Idling trucks

Trucks will deliver and collect feedstock and product from the facility on a daily basis. Emissions from idling trucks were based on emission factors from the US EPA Emissions Fact Sheet for Idling Vehicle Emissions (EPA, 1998). These emissions are based on emissions from heavy duty diesel vehicles that are idling for specified time periods in an environment with an average ambient temperature of 23°C. On average, a time period of 60 minutes (worst case) was utilised for trucks idling at both the feedstock tanks and loading bays. This idling time was then applied to 6 477 feedstock delivery trucks entering the facility and 6 477 tankers exiting the facility on an annual basis.

6.5.1.5. Biodiesel loading to trucks

The emissions associated with the loading of diesel to tankers were calculated using the US EPA’s AP42 loading loss emission factor from the Transportation and Marketing of Petroleum Products section.

6.5.2. Dispersion Modelling

Atmospheric dispersion modelling mathematically simulates the transport and fate of pollutants emitted from a source into the atmosphere. Sophisticated software with algorithms that incorporate source quantification, surface contours and topography, as well as meteorology can reliably predict the downwind concentrations of these pollutants.

In accordance with the NEMAQA Draft Regulations Regarding Air Dispersion Modelling, a Level 2 Assessment is required for the AQIA for the FIS facility. As such, the ADMS (version 5) model, in conjunction with the built-in AERMOD View link, was selected for the assessment. A Level 2 assessment is utilised for AQIAs when: a standard/generic licence process is required; distribution of pollutants is required in time and space; pollutant dispersion via a straight-line, steady-state, Gaussian plume model with first order transformation is required; there is no complex terrain surrounding the proposed site; and impacts are in the order of a few kilometres (less than 50km). The use of a Level 3 Assessment would not be warranted on such a project, as this type of modelling is utilised in long range transport (> 50km) situations; in areas where highly complex terrain will influence the dispersion of pollutants; in assessments where deposition of species as well as secondary pollutant formation needs to be investigated; and is used in situations with multiple sources and buildings.

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While the FIS site is influenced by coastal climatic phenomena (with the coastline being 1.9km away from the site), this is not regarded as adding a level of complexity to the site assessment that would warrant the use of a Level 3 assessment.

The ADMS model was chosen for this assessment as it has been developed to offer a practical dispersion model that simulates a wide range of buoyant and passive releases to the atmosphere, whether individually or in combination. It draws on the latest plume dispersion mathematics and integrates a solid GIS platform. It is an advanced model which calculates concentrations of pollutants emitted both continuously from point, line, volume and areas sources; and discretely from point sources (as is the case with the tanks onsite at the FIS facility). The model is capable of simulating both horizontal dispersion and vertical dispersion, based on the vertical component of turbulence and the buoyancy frequency. As the FIS facility is located within an area of relatively simple terrain, with limited onsite sources and an impact area of well less than 50km, the ADMS model is a highly practical and suitable model to assess dispersion for a project of this nature. The ADMS version 5 model now has the functionality of running the main model options of the Lakes Environmental AERMOD View software concurrently with the ADMS model. Such a link enables output comparisons between the two models in order to validate results obtained. For this assessment, the ADMS model generally predicted slightly higher concentrations than the AERMOD model, indicating that the ADMS results indicate a worst case scenario of emissions which are subsequently used to assess compliance at the site.

The latest version (v5) of the ADMS dispersion model was chosen for this assessment based on previous experience. Cambridge Environmental Research Consultants (CERC) have developed ADMS to offer a practical dispersion model that simulates a wide range of buoyant and passive releases to the atmosphere, whether individually or in combination. It draws on the latest plume dispersion mathematics and integrates a solid GIS platform (ArcView 3.3 & ArcGIS 10.1). The model handles multiple point, line, area and volume sources to produce long- and short-term scenarios for comparison with measured values, guidelines, standards and objectives. The interface requires detailed geographic data, sequential meteorological data, efflux and emission parameters to produce optimal output.

ADMS is recognised as a leading dispersion model in the United Kingdom (UK), European Union (EU), Asia, Australasia, the Middle East and South Africa, The software is currently endorsed by the Climate Research Group (operating from the University of the Witwatersrand, University of KwaZulu-Natal & University of Cape Town) and is used by most metro councils in South Africa. Output for criteria pollutants has been extensively validated against field data sets in the EU and against the American Standard Test Methods.

The latest ADMS software also has the functionality of running the main model options of the Lakes Environmental AERMOD View software concurrently with the ADMS model. As such, long term (annual average) results from both the ADMS and AERMOD model are presented in this AQIA for comparative purposes.

6.5.2.1. Modelling scenarios

To calculate emissions from the FIS facility, two emissions scenarios were separately modelled:

1. The first scenario included emissions from the facility based on the truck dispatch of biodiesel and incoming feed stocks,

2. The second scenario included the pipeline dispatch of product and feedstock. Emissions associated with idling trucks and loading losses were therefore excluded from the pipeline dispatch scenario.

It is noted scenario 1 covers the possibility of trucks arriving from and departing to inland locations as well as the option for these trucks travelling to and from the Port of Ngqura (until such time as the proposed pipeline to the OTGC tank farm is established).

6.5.2.2. Statistical Modelling Descriptions

For the purposes of this investigation, various statistical outputs were generated, as described below:

■ Long-term scenario

The long-term scenario refers to an annual concentration, which is calculated by averaging all hourly concentrations. The calculation is conducted for each grid point within the modelling domain. The long-term concentration for each receptor point is presented in a results table.

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■ Worst-case scenario

The worst-case scenario refers to the 100th percentile concentration (P100), which is the maximum

concentration predicted at any grid point within the modelling domain. The worst case concentration at a point usually occurs only once per annum. The P100 results are graphically presented as concentration isopleths, indicating the worst-case concentrations at each grid point. However, in practice, the worst-case concentrations do not tend to occur simultaneously across the model domain and hence the P100 images do not depict a ‘worst-case contaminant plume’ but rather a distribution of worst case concentrations.

■ Predicted number of exceedences

This prediction is not a worst-case scenario, but rather indicates the total number of times that the standard is exceeded at a given point (grid cell). As an example, an hourly exceedence prediction considers all hourly concentrations (8,760 values when using a single year of met data) at a single point, and predicts the number of hours that would exceed the hourly standard.

6.5.2.3. GIS Input

ArcGIS 10 was used as the mapping interface for this study. Since the FIS site is surrounded by fairly flat terrain, a complex terrain file was not incorporated into the model calculations. The modelling domain selected for this campaign is 10 000m x 10 000m, with the FIS facility as the centre point; covering an approximate area of 10 000ha.

Since the FIS site is surrounded by fairly flat terrain, a complex terrain file was not incorporated into the model calculations. The modelling domain selected for this campaign is 10 000m x 10 000m, with the FIS facility as the centre point; covering an approximate area of 10 000ha. Table 45 presents the modelling domain coordinates.

Table 45: Modelling Domain coordinates

Domain Point x Coordinate (m) y Coordinate (m)

North-Western Point 59924.6 -3733448.7

North-Eastern Point 69924.6 -3733448.7

South-Western Point 59924.6 -3743448.7

South-Eastern Point 69924.6 -3743448.7

6.5.2.4. Meteorological Input

Meteorological conditions affect how pollutants emitted into the air are directed, diluted and dispersed within the atmosphere, and therefore incorporation of reliable data into an air quality impact assessment is of the utmost importance. In accordance with the Draft South African Air Dispersion Modelling Guidelines, a minimum of one year site specific data or at least three years of off-site data must be incorporated into a Level 2 assessment. Although there are three monitoring stations within the Coega region, data recovery from these stations was poor and a full representative years’ worth of data was not available. As such, data from the nearest South African Weather Service’s (SAWS) station was sourced. Although there are three monitoring stations within the Coega region, data recovery from these stations was poor and not representative of the region. As such data from the nearest South African Weather Service’s (SAWS) station was sourced. This station is located 4.5km south-west of the proposed FIS site and is positioned at a similar altitude, thus presenting a good comparative dataset for the plant. Cloud cover data was obtained from the SAWS meteorological station in Port Elizabeth, located 25km south-west of the proposed site, as the Coega station does not record cloud cover. This was the closest, most representative site available. In accordance with the Draft South African Air Dispersion Modelling Guidelines, three years of data for 2010, 2011 and 2012 was utilised with the following parameters being included: wind speed, wind direction, ambient temperature, humidity, rainfall, pressure and cloud cover. The wind speed and direction datasets were also used to generate wind roses using the Lakes Environmental Wind Rose software.

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6.5.2.5. Background Ambient Concentrations

As per the Draft South African Air Dispersion Modelling Guidelines, dispersion models need to be cumulative in nature, accounting for existing (background) pollutant concentrations in an area as well as emissions from the facility under assessment. As such, ambient concentrations of SO2, NOx and PM10 from the Saltworks air quality monitoring station were utilised. Raw data concentrations were obtained from C&M Consulting Engineers, the consultants responsible for maintaining the network. Raw data was only available from the end of 2009 to the end of 2011, with quarterly summary reports available for the first three quarters of 2012. In accordance with the Department of Environmental Affairs (DEA) and as per the South African National Accreditation System (SANAS) TR 07-02 requirements, a minimum data recovery of 80% is required for an accurate assessment of concentrations. Background ambient concentrations from quarter two and quarter three of 2012 were found to be most representative as this was the most recent available data as well as offering the best data recovery. These data averages were subsequently utilised as representative background concentrations in the dispersion model (Table 46).

Table 46: Background pollutant concentrations utilised in the dispersion model.

Pollutant Ambient Concentration (µg/m³)

SO2 3.14

NOx 12.81

PM10 8.48

The Coega ambient air quality monitoring network does not monitor VOC concentrations. Since there are currently not many industries located within the Coega IDZ, VOC concentrations are expected to be low.

Recently, two AQIAs have been performed for two newly proposed facilities in the Coega IDZ. Namely, the proposed Bulk Liquid Storage and Handling Facility in Zone 8 (CSIR, 2013) and the proposed PhytoAmandla Biofuel Processing plant in Zone 5 (CSIR, 2012). VOCs are a key emission from both of these facilities, so in order to account for the cumulative impact in the region; modelled output results from these studies have been consulted. Results from these studies have not been used as baseline concentrations for the FIS dispersion model, but rather as a comparative background dataset for interrogating the model results and discussion section.

6.5.2.6. Surrounding Industries

The baseline concentrations presented in Table 46 and subsequently utilised in the dispersion model, provide the current background conditions in the region, but do not account for additional emissions generated as a result of the rapid growth in the Coega IDZ. However; all newly proposed industries are located at some distance from the proposed FIS facility and it is envisaged that emissions from these industries will not directly impact on the air quality in the immediate vicinity of the FIS facility. With low to medium air quality impacts related to these new industries, the cumulative impacts on the baseline ambient air quality at the FIS facility are seen to be negligible.

6.5.2.7. Receptors

The impact of emissions from the FIS facility on surrounding communities is low, primarily as a result of the great distance of communities away from the Coega IDZ itself. As such, industrial receptors were selected for use in the dispersion model. As the Coega IDZ is sparsely developed at present, only four receptors within a 5km radius of the proposed site could be selected. These include the Coega Harbour to the south-west; the Saltworks to the south-south-west; a road intersection with the N2 highway to the north; and the Cerebos salt facility to the north (Figure 26).

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Figure 26: Location of receptors used in dispersion model

6.6. Summary of findings

This section presents the results of the dispersion model for the FIS facility. Long-term scenarios were run to predict the annual average concentrations of criteria pollutants, as health risks are primarily based on long-term exposure to pollutants. In addition, the long-term run also collates and calculates statistics for worst-case short-term concentrations, to assess the likely number of exceedences of standards over intervals of 1-hour and 24-hours, as applicable for various criteria pollutants.

The AERMOD application used in this assessment is used for comparative purposes between the ADMS and AERMOD long term (annual average) predicted concentrations. It must be noted that the application is not capable of calculating worst case daily or hourly concentrations. In this section the annual average results from both ADMS and AERMOD are presented while only the worst case daily or hourly concentrations from ADMS are presented.

Particulate Matter (PM)

Particulate emissions associated with both the truck dispatch and pipeline dispatch scenarios are presented here. The truck dispatch scenario is based on PM10 emitted from idling trucks and the boilers while the pipeline dispatch scenario accounts for PM10 only from the boilers.

PM10 concentrations are assessed against the NEMAQA annual and daily ambient air quality standards. Figure 27 presents the graphical outputs of the model results. It must be noted that all results include a background ambient concentration of 8.48µg/m³ and results presented are not only a result of activities at the FIS facility.

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Long term concentrations (annual averages) at each of the receptors are low for both the truck dispatch and pipeline dispatch scenarios, with concentrations remaining below the current annual standard (50µg/m³) and 2015 annual standard (40µg/m³). The highest PM10 concentrations are predicted at the neighbouring Cerebos facility, although concentrations at this point still remain compliant. There are very little differences in the predicted PM10 concentrations for the truck dispatch scenario versus the pipeline dispatch scenario, which is expected as PM10 is not a major source from vehicles, especially since the roads in and around the proposed facility will be paved. The ADMS and AERMOD results correlated well in both scenarios.

The worst case daily PM10 concentrations at all receptors are low and indicate compliance with both the current daily standard (120µg/m³) and the 2015 standard (75µg/m³).

As emissions of PM2.5 were not calculated or modelled in this assessment, compliance with the NEMAQA PM2.5 standards can be assessed using the PM10 concentrations. Compliance of PM10 emissions with the PM2.5 standard ultimately indicates compliance of PM2.5 with the standard.

At all receptors, the long term annual average PM10 concentrations during both the truck dispatch and pipeline dispatch scenarios are well below the NEMAQA PM2.5 current annual standard (25 µg/m³) and 2016 annual standard (20 µg/m³), indicating compliance of the PM2.5 concentrations. Similarly, the PM10 daily worst case concentrations during both scenarios are compliant with the NEMAQA PM2.5 current daily standard (65 µg/m³) and the 2016 daily standard (40 µg/m³) at all receptors. This confirms that PM2.5 emissions from the facility are not of significant concern.

Figure 27 presents the modelled outputs for the PM10 long term (annual average) concentrations (left) and worst case daily concentrations (right). Since results from the truck dispatch scenario and pipeline dispatch scenario indicate similar results, only one output plot is presented for each timeframe. The highest annual average concentrations are predicted to the northern edge of the FIS site, with plumes dispersing towards the west, east and south as per the dominant wind directions. Worst case daily PM10 concentrations disperse radially outward from the site, with no exceedences of the daily NEMAQA standard.

Figure 27: Annual average PM10 emissions (left) and worst case daily PM10 emissions (right) from the FIS facility.

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Nitrogen Oxides (NOx)

NOx associated with both the truck dispatch and pipeline dispatch scenarios are presented here. The truck dispatch scenario is based on NOx emitted from idling trucks and the boilers while the pipeline dispatch scenario accounts for NOx only from the boilers.

NOx concentrations are assessed against the NEMAQA annual and hourly ambient air quality standards. Figure 28 and Figure 29 present the graphical outputs of the model results. It must be noted that all results include a background ambient concentration of 12.81 µg/m³ and results presented are not only a result of activities at the FIS facility. Emissions calculated from the boilers represent a worst case scenario, with no abatement in place.

Long term concentrations (annual averages) at each of the receptors are low for both the truck dispatch and pipeline dispatch scenarios, with concentrations remaining below the annual standard (40µg/m³) at all receptor locations. The highest NOx concentrations are predicted at the neighbouring Cerebos facility, although concentrations at this point still remain compliant. There are very little differences in the predicted NOx concentrations for the truck dispatch scenario versus the pipeline dispatch scenario, with concentrations decreasing on average by 0.02µg/m³. Differences between the ADMS modelled concentrations and AERMOD modelled concentrations are minimal and indicate a good correlation between the two models.

The worst case daily NOx concentrations at all receptors are low and indicate compliance with the NEMAQA daily standard (200µg/m³).

Figure 28 presents the modelled outputs for the long term (annual average) concentrations. Since results from the truck dispatch scenario and pipeline dispatch scenario indicate similar results only one output plot is presented. The highest annual average concentrations are predicted to the northern edge of the FIS site, with plumes dispersing towards the west, east and south as per the dominant wind directions. Worst case daily PM10 concentrations and predicted number of exceedences are presented in Figure 29. As a worst case, emissions disperse radially outward from the site, with exceedences of the daily NEMAQA standard predicted within and just outside of the site boundary.

Figure 28: Annual average NOx emissions from the FIS facility

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Figure 29: Worst case hourly NOx emissions (left) and predicted number of exceedences of the hourly standard (right) for the FIS facility


SO2 associated with both the truck dispatch and pipeline dispatch scenarios are presented here. The truck dispatch scenario is based on SO2 emitted from idling trucks and the boilers while the pipeline dispatch scenario accounts for SO2 only from the boilers.

SO2 concentrations are assessed against the NEMAQA annual, daily and hourly ambient air quality standards. Figure 30, Figure 31, Figure 32 and Figure 33 present the graphical outputs of the model results. It must be noted that all results include a background ambient concentration of 3.14µg/m³ and results presented are not only a result of activities at the FIS facility. Emissions calculated from the boilers represent a worst case scenario, with no abatement in place.

Long term concentrations (annual averages) at each of the receptors are low for both the truck dispatch and pipeline dispatch scenarios, with concentrations remaining below the annual standard (50µg/m³) at all receptor locations except the neighbouring Cerebos facility. The AERMOD model, however, predicted compliance at this receptor. There are no noticeable differences in the predicted SO2 concentrations for the truck dispatch scenario versus the pipeline dispatch scenario, as the majority of the SO2 from the facility will be emitted from the boilers, which are operational in both scenarios. ADMS modelled concentrations and AERMOD modelled concentrations correlate well at receptors further from the source but exhibit a 25% difference in concentrations at receptors that neighbour the facility.

The worst case daily and hourly SO2 concentrations are low and indicate compliance with the NEMAQA daily and hourly standards (350µg/m³ and 125µg/m³ respectively) at all receptors except the neighbouring Cerebos facility. As this facility is in close proximity to the proposed FIS site, it is expected that emissions from such a boiler would create an impact. SO2 is emitted at a stack height of

10m and due to plume buoyancy, emissions

are brought down to ground level at a relatively short distance from the source, hence being detected at the Cerebos facility. Calculations from the boiler were uncontrolled, with no abatement technology in place. It is therefore recommended that abatement techniques, such as wet scrubbers be installed on the boilers to limit the resultant SO2 emissions. Installation of such abatement technology can result in SO2 emission reduction of up to 90% (US EPA, 2011), resulting in ambient concentrations that are well below the acceptable levels.

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Figure 30 presents the modelled outputs for the long term (annual average) concentrations. Since results from the truck dispatch scenario and pipeline dispatch scenario indicate similar results only one output plot is presented. The highest annual average concentrations are predicted towards the north-west of the FIS facility, with plumes dispersing towards the west, east and south as per the dominant wind directions.

Figure 30: Annual average SO2 emissions from the FIS facility

In order to illustrate the efficacy of abatement technology in diminishing the SO2 emissions from the boilers onsite, modelled annual average concentration plots, with an emission reduction efficiency of 75% and 90% being applied, are presented in Figure 31. In accordance with literature research and consultation with South African boiler abatement specialists, it is confirmed that the installation of SO2 abatement technology on the boilers can result in emission reductions of up to 90%. The best options for SO2 abatement from such a boiler include flue gas desulphurisation systems using a wet milk of lime solution as a scrubbing medium or dry sodium bicarbonate duct injection across a baghouse (Wu et al., 2004; Cleaver-Brooks, 2010; US EPA, 2011). In the model output results presented in Figure 31, an emission reduction efficiency of 75% was also applied in order to illustrate a more conservative reduction in emissions. In both cases (90% and 75%), emissions of SO2 are greatly reduced when compared to the unabated scenario, such that no exceedences are predicted at any of the receptors and the concentrations and concentration range are significantly lower and smaller respectively.

Worst case hourly PM10 concentrations (with no abatement in place) and predicted number of exceedences are presented in Figure 32. As a worst case, emissions disperse radially outward from the site, with exceedences of the daily NEMAQA standard predicted up to 500m from the FIS site boundary. Figure 33 presents the worst case hourly SO2 concentrations. Emissions disperse radially outwards, except towards the south-west. Exceedences are predicted at distances of greater than 500m from the site boundary.

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Figure 31: Annual average SO2 emissions from the FIS facility with a 75% emission reduction efficiency (left) and 90% emission reduction efficiency (right) applied to SO2 emissions from the boilers

Figure 32: Worst case (i.e. NO ABATEMENT) hourly SO2 emissions (left) and predicted number of exceedences of the hourly standard (right) for the FIS facility

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Figure 33: Worst case (I.e. NO ABATEMENT) daily SO2 emissions (left) and predicted number of exceedences of the daily standard (right) for the FIS facility


CO associated with both the truck dispatch and pipeline dispatch scenarios are presented here. The truck dispatch scenario is based on CO emitted from idling trucks and the boilers while the pipeline dispatch scenario accounts for CO only from the boilers.

CO concentrations are assessed against the NEMAQA hourly ambient air quality standard. Since the CO concentrations at receptors are so low, graphical outputs are not presented. No CO ambient data was available for the region, so background data was not included.

Long term concentrations (annual averages) at each of the receptors are low for both the truck dispatch and pipeline dispatch scenarios. The differences between the predicted CO concentrations for the truck dispatch scenario and the pipeline dispatch scenario are minimal, with concentrations decreasing on average by 0.02µg/m³. Differences between the ADMS modelled concentrations and AERMOD modelled concentrations are minimal and indicate a good correlation between the two models.

Worst case hourly CO concentrations are extremely low at all receptors, with concentration well below the NEMAQA hourly standard (30 000µg/m³). Due to such low receptor results, modelled output plots of predicted CO concentrations are not presented here.

Volatile Organic Compounds (VOCs)

VOCs associated with both the truck dispatch and pipeline dispatch scenarios are presented here. The truck dispatch scenario is based on VOCs emitted from the storage tanks, loading to tankers and the vent recovery system from the tansesterification building while the pipeline dispatch scenario accounts for VOCs only from the tanks and vent recovery system.

VOC concentrations are assessed against the NEMAQA annual benzene ambient air quality standard. Although not all VOCs are in the form of benzene, in this assessment compliance of total VOCs with the benzene standard ultimately indicates compliance of benzene with the standard. Figure 34 presents the long

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term (annual average) VOC concentrations at each specified receptor point calculated with the ADMS and AERMOD models graphical model results.

Long term concentrations (annual averages) at each of the receptors are low for both the truck dispatch and pipeline dispatch scenarios, with concentrations remaining below both the current annual standard (10µg/m³) and 2015 standard (5µg/m³) at all receptor locations. There are slight noticeable differences in the predicted VOC concentrations for the truck dispatch scenario versus the pipeline dispatch scenario, with a general decrease in VOC emissions during the pipeline dispatch scenario. This indicates that VOC emissions from the loading of tankers are noticeable, although concentrations at surrounding receptors are compliant. Minor differences between the ADMS modelled concentrations and AERMOD modelled concentrations are noted, although the concentration differences are of such small orders of magnitude.

Figure 34 presents the modelled outputs for the long term (annual average) concentrations from the truck dispatch scenario (left) and pipeline dispatch scenario (right). Since there is a difference in emissions predicted between the scenarios, two output plots are presented. During the truck dispatch scenario, maximum VOC emissions are centred within the FIS boundary, where the truck loading activities will occur. Dispersion is towards the south, west and east as per the dominant wind directions. Exceedences of the current standard (10µg/m³) are predicted up to 100m from the site boundary whereas exceedences of the 2015 standard (5µg/m³) are predicted up to 500m from the boundary. It is noted that a worst case of a 1% emission reduction efficiency for the vapour recovery unit connected to the loading bays was utilised in the emission calculations. Should an effective vapour recovery unit be installed on the loading bays at the facility, associated emissions can be reduced by between 70% and 90% (US EPA, 2011).

In the pipeline dispatch scenario, emissions of VOCs are significantly lower than during the truck dispatch scenario, with a maximum of 0.73µg/m³ predicted within the site boundary and no exceedences of the benzene standard being predicted.

In terms of cumulative impacts of VOC emissions in the Coega IDZ, concentrations from the AQIA performed for the Bulk Liquid Storage and Handling Facility in Zone 8 (CSIR, 2013) indicate that an increase in only 0.04µg/m³ in the area of the FIS facility is envisaged. Added to the predicted concentrations from the FIS facility, this cumulative concentration remains low and within the NEMAQA limits.

Figure 34: Annual average VOC emissions from the FIS facility during the truck dispatch scenario (left) and pipeline dispatch scenario (right)

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Emissions of VOCs from the biodiesel production process are regulated in terms of Category 6 of the NEMAQA listed activities. Compliance of these direct vent emissions need to be assessed against the relevant minimum emission standard to ensure that the requirements of the AEL are adhered to. With wet scrubber systems installed on the vent system, emissions of VOCs will be low, indicating compliance with the NEMAQA minimum emission standard for the non-thermal treatment of VOCs (Table 47).

Table 47: VOC emissions from the biodiesel production vent recovery system

g/s mg/Nm³ Minimum Emission Standard (mg/Nm³)

Compliant

VOCs 0.04 378.9 40,000 Yes

Methanol

Since methanol is only emitted from the vent recovery system, the use of trucks or pipelines for dispatch does not alter the methanol emissions to the atmosphere. Hence, results from both emission scenarios are not presented here. Methanol emissions are assessed against the annual UK IPPC Environmental Assessment Level (2 660µg/m³).

Long term concentrations (annual averages) at each of the receptors are low, with concentrations remaining well below the IPPC standard. Differences between the ADMS modelled concentrations and AERMOD modelled concentrations are minimal and indicate a good correlation between the two models.

Hexane

Since hexane is only emitted from the vent recovery system, the use of trucks or pipelines for dispatch does not alter the hexane emissions to the atmosphere. Hence, results from both emission scenarios are not presented here. Hexane emissions are assessed against the US EPA’s annual standard (200µg/m³).

Long term concentrations (annual averages) at each of the receptors are low, with concentrations remaining well below the US EPA standard. Differences between the ADMS modelled concentrations and AERMOD modelled concentrations are minimal and indicate a good correlation between the two models.

6.7. Impacts identified

The air quality study provides the necessary information in order to assess the impacts of the proposed biodiesel production plant on the surrounding ambient air quality. Impacts associated with both the truck dispatch and pipeline dispatch scenarios are assessed.

The identified impacts on surrounding receptors include:

1) Impact of vehicle emissions

2) Impact of boiler emissions

3) Impact of fugitive tank emissions

4) Impact of fuel loading emissions

5) Impact of biodiesel production emissions

In accordance with WSP’s impact rating methodology, the predicted air quality impacts of the proposed project are expected to be low (L) to medium (M) without mitigation in place and low (L) to low-medium (LM) with mitigation in place, as depicted in Table 48.

Such ratings clearly indicate the importance of implementing mitigation techniques in the form of the vent recovery system from the transesterification building; vent recovery on the loading bays; and abatement technology on the boilers.

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Table 48: Impacts rating table of air quality impacts from the proposed biodiesel production plant

Description of the Impact: Impact 1: Impact of Vehicle Emissions

Releases of truck generated pollutants may be emitted to the atmosphere, creating impacts on the ambient air quality

Nature of potential impact Severity Duration Extent Frequency Probability Pre-mitigation significance

Impact Rating 1 4 2 5 3 Low-Medium

Proposed mitigation:

- No mitigation measures are proposed specifically for the trucks, however, with the introduction of the pipeline dis-patch of product and feedstock, emissions will significantly reduce as presented below

Nature of potential impact Severity Duration Extent Frequency Probability Post-mitigation

significance

Impact Rating after mitigation

1 4 1 3 1 Low

Overall Significance:

With the pipeline dispatch scenario initiated, emissions associated with trucks can be reduced from Low-Medium to Low.

Description of the Impact: Impact 2: Impact of Boiler Emissions

Releases of boiler generated pollutants may be emitted to the atmosphere, creating impacts on the ambient air quality


Impact Rating 3 4 2 5 4 Medium


- The installation of SO2 abatement technology in the form of wet gas scrubbers or similar flue gas desulphurisation systems can greatly reduce SO2 emissions from the HFO boilers.


significance


2 4 1 5 2 Low-Medium


With the installation of SO2 abatement technology on the boilers, emissions associated with the boilers can be reduced from Medium to Low-Medium.

Description of the Impact: Impact 3: Impact of Fugitive Tank Emissions

Releases of fugitive VOC emissions may be released to the atmosphere from the tanks, creating impacts on the ambient air quality


Impact Rating 1 4 1 3 1 Low


- Fugitive emissions from the tanks are not of great concern due to the low vapour pressure of the tank contents, therefore no mitigation techniques have been suggested.


significance


1 4 1 3 1 Low


Fugitive emissions from the onsite storage tanks are low.

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Description of the Impact: Impact 4: Impact of Fuel Loading Emissions

Fugitive emissions during the loading of fuel to tankers may be emitted to the atmosphere, creating impacts on the ambient air quality




- The installation of a suitable vapour recovery unit at the loading bays - Use of submerged filling technique for loading tankers

- The use of pipeline to dispatch product to the harbour instead of tankers. This will limit the losses of emissions as-sociated with the loading to tankers.


significance




With the installation of a vapour recovery unit or use of pipelines for dispatch, loading loss emissions can be reduced from Medium to Low-Medium.

Description of the Impact: Impact 5: Impact of Biodiesel Production Emissions

Pollutants associated with the biodiesel production process may be emitted to the atmosphere, creating impacts on the ambient air quality

Nature of potential impact



- The installation of a vent recovery system (equipped with wet scrubbers) from the transesterification building will greatly reduce emissions

- Such technology is already planned for installation


significance


1 4 1 4 1 Low


With the installation of a vent recovery system, emissions associated with the biodiesel production process will be reduced from Low-Medium to Low.

6.8. Conclusions and Recommendations

From the dispersion modelling performed for the proposed FIS Biodiesel facility production facility, the following was predicted:

Particulate Matter

Sources of particulates at the facility will include the boilers and idling vehicles. Concentrations of PM10 and PM2.5 during both the truck dispatch scenario and pipeline dispatch scenario are low, indicating compliance with the NEMAQA standards.

Nitrogen Oxides

Sources of NOx include the boilers and idling vehicles. Long term (annual average) NOx concentrations during both the truck dispatch scenario and pipeline dispatch scenario are low, indicating compliance with the

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NEMAQA standards. Worst case (i.e. NO ABATEMENT) hourly concentrations indicate non-compliance with the NEMAQA hourly standard in the area directly surrounding the FIS facility.

Sulphur Dioxide

Sources of SO2 at the facility include the boilers and idling trucks. Predicted SO2 concentrations during both the truck dispatch scenario and pipeline dispatch scenario are elevated in the area directly surrounding the FIS facility, with various exceedences predicted in this area. Since there are no noticeable differences between the predicted concentrations during the truck dispatch scenario and pipeline dispatch scenario, it can be concluded that the main source of SO2 onsite, is the boilers. SO2 is emitted at a height of 10m and emissions are brought down to the ground at a distance from the source. Calculations from the boilers were uncontrolled, with no abatement in place, representing a worst case emission scenario. Should abatement technology be installed on the boilers, emission reductions of up to 90% can be expected resulting in ambient concentrations that are well below the acceptable levels. Such abatement technology includes the installation of wet scrubbers, flue gas desulphurisation systems or dry sodium bicarbonate duct injection across a baghouse.

Carbon Monoxide

Sources of CO include the boilers and idling trucks. During both the truck dispatch scenario and pipeline dispatch scenario, CO concentrations are low and well below the NEMAQA annual standard.

Volatile Organic Compounds

Sources of VOCs at the facility include the onsite storage tanks, loading of fuel to tankers and the vent recovery system from the transesterification building. During the truck dispatch scenario, VOC concentrations are slightly elevated in the area directly surrounding the facility, with exceedences of the current standards being predicted up to 100m from the site boundary, and future (2015) standard being predicted at up to 500m from site boundary. The dominant source of emissions during this scenario is the loading losses associated with the fuel loading to tankers. As a worst case, a 1% emission reduction efficiency was applied to the vapour recovery unit connected to the loading bays. Should an effective vapour recovery unit be installed on the loading bays at the facility, associated emissions should be reduced by between 70% and 90%, ensuring compliance at the nearest sensitive receptors for future (2015) VOC standards.

VOC emissions during the pipeline dispatch scenario are very low and well below the NEMAQA standards, indicating that vapour releases from the onsite storage tanks and vent recovery system from the transesterification building are not an issue from the FIS facility.

Methanol

Methanol is emitted from the vent recovery system of the transesterification building. Predicted concentrations are low and well below the international IPPC standards.

Hexane

Hexane is emitted from the vent recovery system of the transesterification building. Predicted concentrations are low and well below the US EPA standards.

From the dispersion model it is evident that all plumes disperse towards the south, east and west, as per the dominant wind directions. With proposed nitrogen blanketing on the methanol and sodium methylate tanks, and condensers and water scrubbers in the atmospheric vent system of the transesterification building, emissions will be significantly reduced at the plant.

Recommendations for decreasing emissions include:

■ Best practice in the control efficiency of the vapour recovery unit at the loading bays should be applied, should the truck dispatch scenario be implemented onsite; and

■ Installation of SO2 emission abatement technologies on the HFO boilers.

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7. Storm Water Management Plan

7.1. Introduction

Comment received from DEDEAT in the Scoping Report Approval Letter, dated 23rd

August 2012, (attached in Appendix G) requested that a Storm Water Management Plan (SWMP) must be undertaken as part of the EIA to manage the storm water and potential impacts associated with storm water contamination that may occur on site. To appropriately manage the storm water generated by the FIS operations, a SWMP has been developed. The objective of a SWMP is to prevent pollution of the receiving watercourses through the appropriate separation and containment of clean and dirty storm water.

7.2. Approach

The development of the SWMP specifically for the FIS site took into account the following guidelines:

7.2.1. CDC Integrated Storm Water Management Plan

The CDC ISWMP discusses the storm water design criteria and proposed storm water infrastructure specific to the eastern side of the Coega River, including Zone 7 in which the proposed FIS development is located. This includes Best Management Practices (BMPs) to be followed by each property tenant.

7.2.2. DWAF Best Practice Guideline – Storm Water Management

The DWAF Best Practice Guidelines (BPGs) were devised for water resource protection in the South African Mining Industry; however, the guiding principles are considered applicable to the management of storm water at industrial sites with the potential to contaminate surface water resources.


Various assumptions were made in the SWMP. These assumptions and associated limitations include the following:

■ It has been assumed that any neighbouring sites will appropriately manage their storm water, and that no dirty water contributions to the site will occur.

■ As per the CDC ISWMP, it has been assumed that the tank farm will be appropriately bunded and that the tank bunds will contain the 50 year storm event runoff; hence, should the bunds be appropriately managed as per the BMPs, no dirty runoff generation is expected.

■ It has been assumed that spillages will be appropriately contained and managed as part of the spill management plan.

7.4. Numerical Modelling

The HydroCube storm water drainage model was used to size the proposed storm water management infrastructure. HydroCube is a hydrological rainfall-runoff numerical simulation model suitable for application to both rural and urban environments. The SWMP was assessed in terms of the 2 year recurrence interval storm event as per the CDC ISWMP BMPs to determine the peak flow conditions for each of the drainage elements, and the capacity of these elements to contain the calculated flow

7.5. Conceptual Storm Water Management Plan

Clean and dirty water catchments were discretised based on the proposed development plan provided. This took into account the landuse and surface flow directions. Based on the discretised catchments, storm water

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management infrastructure was placed to ensure appropriate management of clean and dirty storm water runoff according to the requirements outlined in the CDC ISWMP BMPs and DWAF BPGs.

The SWMP (Figure 35) represents the clean and dirty water catchments and the expected surface flow directions. In addition, the SWMP represents the channels (prefix “C”), pipe (prefix “P”) and 438m

3 retention

facility (prefix “R”) used to manage the surface runoff for the catchment (prefix “K”). It should be noted that the SWMP has been purposefully kept high-level to allow for future updates based on any site specific storm water reticulation and due to final revisions to the initial site layout plan.


The general recommendations for the site to limit the pollution of storm water as defined within the CDC ISWMP BMPs need to be followed; however, with regards to the storm water infrastructure specifically, the following is recommended based both on the BMPs, as well as the DWA Best Practice Guidelines:

■ To limit the use of water on site, clean water contained within the attenuation pond may be used as irrigation water. This will also ensure that the pond capacity is available for subsequent storm events

■ Regular inspection, cleaning and maintenance of the storm water system on their site should be scheduled, particularly after rainfall events. This includes ensuring pipes, channels and the attenuation ponds are kept clear of sediment and debris, including vegetation. Signs of erosion and scouring should also be checked.

■ Since the attenuation paddock is expected to accumulate sediments arising from the runoff, the sediments either need to be routinely removed after storm events, or the facility capacity over-designed to allow for his accumulation.

■ Any spills outside of the bunds need to be appropriately cleared to prevent storm water pollution.

■ Should areas outside of the bunded area be designated as dirty areas, an update to the SWMP may be required.

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Figure 35: Conceptual Storm Water Management Plan

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8. Solid Waste Generation

8.1. Introduction

A Waste Management Best Practicable Environmental Option (BPEO) Assessment was undertaken by WSP (a copy of the report is attached in Appendix F) to provide specific waste management recommendations for the construction phase and operational phase prescribing the requirements for collection, storage, packaging, transport, treatment, disposal and reporting of general and hazardous waste associated with the project. This section describes the impacts that the proposed development will have on the surrounding area, the significance thereof as well as the recommended mitigation measures.

Activities associated with both the construction and operation of the facility are expected to generate a variety of wastes. In the construction phase, wastes are anticipated to be characteristic of greenfields industrial construction and commissioning projects, and hence will include a variety of packaging materials, surplus installation materials (e.g. pipe off-cuts) chemicals used for assembly and commissioning of equipment and general waste associated with the set-up of amenities such as offices and laboratories.

Once the facility becomes operational, the activities undertaken in support of manufacturing and maintenance will also generate a range of wastes, as well as by-products. Where certain materials have been considered as constituting by-products, this has been done in line with the definition of a by-product provided in the NEM:WA. On the basis of assumption that the facility’s by-products (such as soap stock and semi-purified glycerine) are able to be used as a raw-material elsewhere, (off-site) without further treatment, these were excluded from the assessment as they would not be considered wastes. As such, operational phase wastes will effectively include contaminants removed from the main process stream, the media used to effect this removal (i.e. filtration media), and any incidental waste materials associated with maintenance activities.

8.2. Findings

In Table 49 potential alternate waste options for the management of the waste streams have been identified and reviewed against the BPEO criteria. Due to similarities between some of the waste streams, some waste materials (e.g. different filter cakes) were grouped together, as the evaluation of these was closely comparable. The hierarchical approach has been applied to the evaluation of options, in conjunction with project-specific information pertaining to the availability of that option. Note that information on projected waste volumes are based on the HeroBX plant on which the FIS facility will be based, and that the worst case scenario would result in the entire estimated quantities needing to be disposed of to the relevant licenced landfill.

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Table 49: Waste management options

Waste Type Phase Quantity Management Category

Availability Method

a) General Waste (Domestic & Industrial)

Construction & Operational Phases

est. <10m

3/month

Avoidance / Reduction

Available Avoid waste generation predominantly through reduction of packaging materials; requires management at supply chain / procurement level.

Re-usage / Recycling

Available Formal sector recycling options exist for recyclables (paper, cardboard, non-contaminated metal) but should be reviewed on an on-going basis

30.

Disposal Available Dispose of the residual waste at a permitted landfill site. Current options considered viable include:

Arlington Landfill Site (Nelson Mandela Bay Metropolitan Municipality (NMBMM) owned; general class site; ±30 km away),

Koedoeskloof Landfill Site (NMBMM owned; hazardous (H;h) class site; ±30 km away),

Aloes Landfill Site (Privately owned; high hazardous (H:H) class site; ±20 km away).

It is worth noting however, that the working lifespan of landfill sites (based on remaining airspace in the design) is finite, and should not be automatically taken for granted as being a guaranteed long-term solution for waste management.

b) Oily Waste Construction Phase

volume unknown but likely <10m

3/month


Available Manage hydrocarbons with care during construction and commissioning. Pre-empt potential hydrocarbon spills where possible (e.g. through conducting risk assessments and HAZOP studies) and take appropriate measures to mitigate impacts (e.g. using spill trays, working in bunded areas etc.). Good management procedures and maintenance measures will assist in avoiding oily waste generation. As the facility is effectively a greenfields build, it is considered worthwhile to instil from the outset, a mentality amongst staff and contractors that spillage and mismanagement of oily waste is not only wrong, but can in many instances be avoided altogether.


Available Third party waste mineral oil re-processors are considered a feasible outlet for oily waste, if volumes are sufficient. Reputable re-processors (e.g. those registered as members of NORA-SA) should be preferred to demonstrate corporate responsibility in this respect. According to the current NORA member database, there is at least one such re-processor operating within close proximity to the site.

Disposal Available Failing the above (considered less preferable than the abovementioned

30 Segregation of recyclables (e.g. wood, cardboard etc.) is only required where this is demonstrated to be a viable commercial option.

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options), oily waste should be managed and safely disposed of via registered waste service providers. Disposal must be undertaken at a permitted / appropriate class of landfill site subject to waste risk profiling. Current viable options in the vicinity of the project site include:

Koedoeskloof Landfill Site,

Aloes Landfill Site.

c) Oil Contaminated Waste

Construction and Operational Phases

est. <1m

3/month


Available Potential contamination of solid materials by hydrocarbons could be minimised through good hydrocarbon management throughout the construction, commissioning and operational phases. This should be formalized through the compilation of written procedures detailing the scope and requirements, and effectively implemented across staff and contractors to raise awareness and foster buy-in. Cognizance of the fact that oil which is disposed of as waste is effectively a loss of either raw material or product, which ultimately affects the profitability (and thus viability) of the business-an important aspect in regard to employment tenure.


Future Consideration

Certain waste may be able to have the oil component extracted and subsequently re-processed (typically into fit-for-purpose industrial heating fuels, but also possibly for re-use) by third party specialist service providers. This will typically depend on a range of factors such as volumes of waste generated and the type and degree of oil contamination. Where possible, however, this option should be considered.

Disposal Available Failing the above (considered less preferable), oil contaminated waste should be managed and safely disposed of via permitted waste service providers. Ultimate disposal should be at a permitted / appropriate class of landfill site subject to waste risk profiling.

Currently, the only local option is the Aloes Landfill Site, which was recently granted authorisation to expand its capacity to extend its lifespan into the 2020’s. Additionally, a new regional H:H class facility has been applied for by the Coega Development Corporation in conjunction with the Nelson Mandela Bay Metropolitan Municipality (NMBMM). This proposed facility, proposed to be located approximately 30km away from the project site, is currently awaiting environmental authorisation (there would likely be a lag-in time for the proposed new facility to be constructed and become operational, hence any short-term option relating to this facility would be limited at best).

d) Fluorescent Light Tubes

Construction and Operational

small quantities


Available Alternative lighting technologies (e.g. LEDs which are non-hazardous, more energy efficient, but have a greater capital cost) could be considered for the refinery, especially as the facility is not yet built (no need to retrofit). Low-mercury fluorescent tubes are also available, which could reduce the amount of harmful material in the waste stream. Incandescent lamps present a traditional, lower-hazard alternative, but are generally not energy efficient, nor are they practical for industrial

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scale applications.

The design of the buildings at the facility should aim to take maximum advantage of the typically sunny climate by using natural lighting wherever possible. Not only would this have the effect of using fewer light bulbs/tubes (i.e. less waste), but there would be potentially significance energy (and thus cost) savings to be realised through this consideration.


Potentially Available

and / or


Although fluorescent lamp (mercury) recycling is relatively well-established in countries such as the USA, it is understood that permitted recyclers are still relatively scarce in South Africa.

In the Eastern Cape, drop-off centres for the recycler are currently maintained in collaboration with two major retail shopping outlet groups and WESSA. In the event that a third party waste management contractor is appointed by FIS Biofuels, they should be consulted on their options available to divert this waste for recycling.

Disposal Available This waste stream should be kept separate to others, as this mercury-containing waste should not be allowed to contaminate other streams. Dedicated and bespoke tube bins with subsequent disposal at a permitted hazardous waste landfill site (e.g. Aloes) are considered standard practice.

e) Pre-filtration Residue

Operational Phase

quantities unknown but likely <10m

3/month


Available

and


Reduction of this waste stream could be achieved through the procurement of feedstock with known lower filterable residues. A cost-benefit analysis which considers the price variation between feedstock of differing quality and the consequent benefits of reduced waste generation should be considered by FIS Biofuels. If determined to be feasible, procurement of better quality feedstock should be formally committed to in written operating procedures for the facility.

Furthermore, FIS Biofuels is expected to aim at minimising the amount of oil entrained in this waste stream (as this effectively represents a loss of feedstock). Equipment selection, operational parameters and practices and plant maintenance could all influence this waste aspect.


Potential Future Consideration

The quantities of waste expected to be generated from this aspect of the operation of the project were considered for use in energy recover (e.g. co-firing in a boiler). This option was concluded to currently not be viable based on the relatively small quantities expected, as well as uncertainties regarding inorganic (e.g. metal) constituents posing a further environmental hazard once released from the boiler flue.

Further to this, there would be the need to apply for, obtain and maintain compliance with the conditions an Atmospheric Emission License in terms of Section 21 of the National Environmental Management: Air Quality Act (39 of 2004) should on-site combustion of the waste be undertaken. This in turn would involve additional permitting processes.

In the future, emission control technologies may progress to a stage whereby combustion of the waste would not pose an environmental risk such as that posed today. Furthermore, the financial need to utilize

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alternative and otherwise un-tapped energy sources may also evolve over time, such that this option should be periodically reviewed.

Disposal Available Disposal at a permitted / appropriate class of landfill site subject to waste risk profiling. Currently, the only local option is the Aloes Landfill Site, although the proposed new regional H:H class facility mentioned above could present an alternative disposal option in the medium-term future.

f) Filter Cake Operational Phase

est. 5,400 tons/annum



The use of silica and filter aid (diatomaceous earth) to filter the process oil stream was identified as a necessary step in the overall biodiesel manufacturing method preferred by FIS Biofuels. Other options such as wet washing and ion exchange purification are available; however these may have other significant impacts (e.g. effluent generation and possible unintended secondary reactions in the product respectively).

FIS Biofuels will assumedly aim to use an optimal amount of silica and filter aid (such that raw material usage (and thus costs) are minimised) and this would have a secondary benefit of avoiding excess amounts of these materials ending up in filter cake. Similarly, FIS Biofuels is expected to aim at minimising the amount of oil entrained in this waste stream (as this effectively represents a loss of feedstock/product). Equipment and operational selections could influence this waste aspect.


N/A Although preliminary considerations of potential energy recovery activities from the oil entrained in the filter cake were undertaken, this was deemed to not be viable given the relatively low quantities of oil, and the largely inorganic matrix within which the oil is carried.


A study by Chen & Chou (2010) investigated the use of filter cake from biodiesel manufacture in the manufacture of fired building bricks. They found that formulations containing up to 10% of filter cake were able to meet certain relevant international specifications, and suggested that this was a feasible method for re-use of this waste.

There are brick manufacturing industries in close proximity to the study area, which may be appropriate outlets for the waste stream. Additional studies to confirm local technical applicability, as well as relevant environmental authorisations, would need to be undertaken prior to pursuing this potential option.

Treatment Future Consideration

Given the expected low concentrations of oil in the filter cake, there may be an opportunity to reduce this hazard even further through practices such as bio-remediation (land farming). In such a process, the filter cake would be mixed, in a semi-controlled environment, with specific types and quantities of microbes and nutrients which would lead to the biological breakdown of the oil in the silica/diatomaceous earth matrix over time. Eventually (typically over periods of six months or more), the potentially hazardous oil component of the waste would have been effectively eliminated.

Communications with a privately owned waste management company operating in close proximity of the site have revealed that they are

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currently facilitating the authorisation of a bio-remediation facility nearby, and are hoping to commence offering this service in the near future.

Disposal Available Disposal at a permitted / appropriate class of landfill site subject to waste risk profiling (dependent on factors briefly discussed in the previous section).

Should the filter cake be determined to be non-hazardous, then it would be able to be disposed of at Arlington, Koedoeskloof or Aloes landfill sites.

The local options available in the event that the cake is determined to be hazardous are the Aloes and Koedoeskloof landfill site, although the proposed new regional H:H type facility could present an alternative disposal option in the medium-term future.

It should be noted that it is considered good practice to minimise the hazard associated with the waste stream prior to disposal. Therefore, ideally, disposal should be considered in conjunction with the previous “treatment” step.

g) Polishing Filter Socks

Operational Phase

quantities unknown



These types of filters are well-known to be quite efficient in relation to the intended operation. Notwithstanding this, FIS Biofuels should consider any future new technologies which may offer even lower environmental impacts, while achieving similar performance.

Preventative maintenance schedules for the facility should be tailored such that useful service life of filters is maximised (less frequent replacement of filters) while not jeopardising the reliability of the equipment.


N/A Once having reached the end of its useful service life, the filters would not able to be re-used or recycled.

Disposal Available Disposal at a permitted / appropriate class of landfill site subject to waste risk profiling (dependent on factors briefly discussed in the previous section). The composition of the filter sock itself should not warrant hazardous classification, however the oil and other contaminant content may do so.

Should the filter sock waste stream be determined to be non-hazardous, then it would be able to be disposed of at Arlington, Koedoeskloof or Aloes landfill sites.

Currently, the only local options available in the event that the cake is determined to be hazardous, are the Aloes and Koedoeskloof landfill site, although the proposed new regional H:H type facility mentioned above could present an alternative disposal option in the medium-term future.

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8.3. Potential Impacts

8.3.1. “No-go” Scenario

If the no-go scenario is pursued, the FIS Biofuels facility would not be built nor operated. Therefore there would be no waste generated, nor will any primary or secondary impacts to waste management within the area occur.

8.3.2. Project Scenario

There are several issues that will arise as a result of the proposed project, these include:

■ Issue 1 - Improper handling of waste: This issue pertains to the handling of waste at various stages of the project (including both construction and operational phases). This could further include the handling of waste both on-site and off-site.

■ Issue 2 – Recycling of waste: This issue encompasses the relevant re-usage or recycling management practices described in Section 3 above. The impacts associated with this issue are mainly of a secondary type.

■ Issue 3 – Disposal of waste: This issue relates to the disposal of the various waste streams described above. It is therefore associated with the disposal of waste at landfill site.

Table 50 identifies the potential impacts that may arise as a result of the construction and operation activities of the proposed FIS facility, and proposes mitigation measures that have been incorporated in the draft EMPr (Appendix C).

Table 50: Waste Management Impact Assessment

Description of the Impact: Impact 1: Littering of environment by general waste.

In the event that non-hazardous, general waste is inadequately stored or inappropriately handled, it may be released to the environment, causing a detrimental visual impact and possible interference with fauna.




- Ensure that adequate general waste receptacles are provided during both the construction and operational phases;

- Educate and encourage all employees and contractors about waste management, littering, housekeeping, etc.


significance


2 2 1 3 2 Low


With the mitigation measures described above applied, the overall significance of the impact can be reduced from Low-Medium to Low.

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Description of the Impact: Impact 2: Potential pollution of soil, air, water by hazardous waste (site based).

In the event that hazardous waste is inadequately stored or inappropriately handled, it may be released to the environment, causing pollution of soil, air or water.




- Ensure that adequate and secure hazardous waste receptacles are provided during both the construction and oper-ational phases;

- Ensure that appropriate procedures are in place dealing with the management of hazardous waste, and that all em-ployees and contractors are aware of these.



3 3 3 1 2 Low



Description of the Impact: Impact 3: Personal exposure to hazardous waste (health and safety).

Improper handling of hazardous waste could lead to personal exposure of staff or contractors.




- Ensure that appropriate procedures are in place dealing with the management of hazardous waste, and that all em-ployees and contractors are aware of these;

- Provide employees who may come into contact with hazardous waste with appropriate personal protective equip-ment, and appropriate training on its effective use;

- Hazardous waste moving off-site should be suitably labelled and managed, such that staff of downstream handlers of the waste (e.g. waste contractors or landfill site) are fully aware of the hazards of the waste.



2 1 3 2 2 Low



Description of the Impact: Impact 4: Legal non-compliance / risk in respect of waste recycling practices.

A number of waste re-use or recycling options described in Section 3 above may have legal ramifications / risk which would need to be adequately addressed to avoid non-compliance.




- Ensure that legal advice is sought prior to undertaking any waste recycling activities; - In line with due diligence, ensure that any contractors engaged in downstream waste re-use or recycling hold the

necessary environmental permissions/permits.

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4 2 2 1 2 Low



Description of the Impact: Impact 5: Consumption of landfill airspace.

Waste generated by activities at the FIS Biofuels facility in both the construction and operational phases that is sent to landfill site for disposal, will take up airspace in the landfill. This airspace which could have been used for disposal of other waste, or assuming all else the same, could have extended the useful life of the landfill.




- Minimise the amount of waste required to be disposed of at landfill; - Maintain a good standard of waste segregation, so that general waste (which has greater options for disposal) is not

contaminated with hazardous waste. This will minimise the amount of airspace within scarcer hazardous waste dis-posal sites.





With the mitigation measures described above applied, the overall significance of the impact remains Low-Medium.

Description of the Impact: Impact 6: Potential pollution of soil, air, water by hazardous waste (disposal site).

In the event that hazardous waste is inadequately labelled, it may be sent to an inappropriately designed/equipment disposal site, where it may in turn lead to uncontrolled pollution of soil, air or water.




- Hazardous waste leaving the FIS Biofuels site should be suitably labelled to avoid uncertainty regarding the waste type and its intended disposal site;

- Maintain a good standard of waste segregation, so that general waste (which has greater options for disposal) is not contaminated with hazardous waste. This will minimise the amount of airspace within scarcer hazardous waste dis-posal sites.



3 1 3 2 1 Low



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8.4. Recommendations/mitigation measures proposed

Bespoke waste management actions and mitigation measures relating directly to potential impacts associated with the generation, handling and downstream management of the waste streams discussed above have been included in the Environmental Management Programme (Appendix C).

On the basis of the BPEO review, there should be no major barriers to managing waste from the proposed facility to an acceptable standard. All wastes will need to be properly classified and SDSs developed, in line with NEM:WA, once the facility is operational. Due to constant advances in technology, the increasing access to such technology in local markets, and fluctuating costs of service, transportation and disposal, higher order waste management options should be continually evaluated by FIS Biofuels into the future. The BPEO should therefore be considered as a dynamic process that can be revisited at various future intervals in order to ensure that the selection of waste management options reflects current best available options. To this end, it is noted that best practice would entail the development of a Waste Management Plan once the facility is fully operational, as this would allow for an effective management mechanism by which the BPEO could be periodically reviewed and updated. It is also recommended that once the facility is fully operational, FIS undertake further assessment of the feasibility to potentially re-use the silica waste in local brick manufacturing operations.

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9. Ecological

9.1. Introduction

WSP contracted Coastal and Environmental Services (CES) to conduct a detailed Ecological Impact Assessment for the proposed FIS biodiesel refinery (a copy of the report is attached in Appendix F). The aim of the assessment was to identify areas of ecological importance and to evaluate these in terms of their conservation importance. In order to do so, the ecological sensitivity of the proposed site location was assessed as well as the species of special concern that may occur in the habitats in the area.

In addition, a desktop review was undertaken of the studies undertaken to assess the impact of the proposed pipeline routing to the berth. FIS’s proposed pipeline will link to Transnet’s fuel reserve and the OTGC pipeline routes. Transnet’s fuel reserve pipeline and the OTGC pipeline routes were assessed as part of two previous studies and were therefore not assessed during the survey. However, the findings from these studies were included in the report as part of the desktop analysis.


■ Species of special concern are difficult to find and difficult to identify, thus species described in this report do not comprise an exhaustive list. It is almost certain that additional species of special concern will be found during construction and operation of the development.

■ Sampling could only be carried out at one stage in the annual and seasonal cycle. Consequently, some plant species may therefore have gone undetected.

■ Time is a constraint in studies such as these and only a sample of the ecology of the area was taken.

■ Impacts are assessed based on the FIS tank and pipeline layout. Should the layout fall outside of the as-sessed area, the impacts and associated mitigation measures, will need to be revisited.

9.3. Methodology

A stratified random sampling approach was adopted, whereby initial assumptions were made about the diversity of vegetation, based on initial reconnaissance visits, previous studies or from aerial photographs and satellite imagery and the area stratified into these basic types.

Sample plots were analysed by determining the dominant species in each plot, as well as any alien invasive species and potential species of special concern occurring within the plots. Vegetation communities were then described according to the dominant species recorded from each type, and these mapped and assigned a sensitivity score. The full details on the methodology used are presented within the technical report (Appendix F).


9.4.1. Plant Species of Special Concern

Twelve species of special concern were identified within the project site. Three of these species are listed in Appendix HI of CITES. Two species are listed as endangered and three species as near threatened on the South African Red Data List. Euphorbia meloformis is listed as protected under the NEMBA and Sideroxylon inerme is listed as protected under the National Forests Act, 1998 (Act No 84 of 1998). Seven species are listed as Schedule 4 on the 1974 Provincial Nature Conservation Ordinance (PNCO). Species listed on the National Forests Act, NEMBA and the PNCO will all require permits for their removal.

Both the OTGC and the Transnet pipeline assessments recorded species of special concern within the respective study sites. The most important of these are endemics to the area and include Agathosma gonaquensis (Critically Endangered), Cyrtanthus spiralis (Endangered), Euryops ericifolius (Endangered), Syncarpha recurvata (Endangered) and Rhombophyllum rhomboideum (Endangered). It is possible that many SSC were not recorded during the on-site investigation. Possible reasons for these variations are that different

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vegetation occurs on the site, or many of the plants were currently dormant and so were not detected during the site visit.

9.4.2. Invasive and problematic species

Two alien plant species were noted to occur on site. Acacia cyclops (a category 2 weed) shows significant signs of encroachment into bush clumps within the project site. In addition, Opuntia ficus-indica was also noted to occur on the project site in the open grassland. Left unmitigated, both these species could result in the rapid transformation and degradation of the natural habitats found on site.

9.4.3. Animal Species

9.4.3.1. Amphibians

Although no wetlands or streams were noted to occur within the project site, the proximity of the study area to the Coega River suggests that amphibians are likely to occur within this area during favourable conditions. Historical records indicate that 14 species of frogs have been documented in the Quarter Degree Squares that the project area falls within. However, none of these species are listed as species of conservation concern.

9.4.3.2. Reptiles

Consultation of the Animal Demography Unit historical records indicates that 52 species of reptiles could occur within the project site. Although none of these species are listed as species of special concern on the IUCN Red Data List, five of these species appear on Appendix HI of CITES and five are listed on the PNCO list with three being classified as protected species.

9.4.3.3. Birds

The Coega region has a diverse avifauna, with over 150 species being resident or common visitors to the region. Most diversity occurs in the thicket clumps. A number of terrestrial birds are of conservation concern, some of which – Damara Tern, African Oystercatcher and Blue Crane- have been observed within the coastal region in the vicinity of the study area. Historical records indicate that there are six Vulnerable bird species and twelve Near Threatened species likely to occur in the vicinity of the project site.

9.4.3.4. Mammals

There is a general lack of pristine terrestrial habitats in the Coega region. Consequently, large to medium size terrestrial mammals have been severely impacted by previous human activity, particularly the loss of vegetation, invasion of alien vegetation and varied industrial developments.

Previous studies indicate that two species of special concern are likely to occur within the project site. These include the Fynbos golden mole (Amblysomus corriae) listed as Near Threatened and the Blue Duiker (Philantomba monticola) listed as Vulnerable. Evidence of small antelope was noted during the site visit.

9.4.4. Sensitivity mapping

A sensitivity map was developed by identifying areas of high, low and medium areas of sensitivity (Figure 36).

Areas of high sensitivity are assigned to areas such as rivers, wetlands and streams that are important for ecosystem functioning and animal and plant dispersal. In addition, high sensitivity is usually assigned to areas with high species richness and areas with a high concentration of species of special concern. No areas of high sensitivity were identified within the FIS project site.

Areas classified as moderate sensitivity are areas that although degraded, still provide a valuable contribution to biodiversity and ecosystem functioning and have a relatively high species richness. Areas of medium sensitivity may also contain species of special concern. The entire project site was classified as moderate sensitivity for the following reasons:

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■ Encroachment of alien species such as Acacia cyclops;

■ Habitat fragmentation due to construction activities occurring around the site and as a result of existing roads occurring through the site;

■ Evidence of dumping occurring on the site;

■ Although the vegetation is relatively intact, it was not considered to be in pristine condition.

Areas of low sensitivity are assigned to regions that have been transformed and no longer adequately serve ecosystem functioning and processes. These are generally areas that have been cleared for agriculture or have been overgrazed by livestock. No areas of low sensitivity were observed within the project site.

Overall the assessed site has been assigned a moderate sensitivity with no areas of high sensitivity being recorded. Placement of the FIS facility and pipeline is therefore flexible within the assessed area, provided mitigation measures are adhered to. From an ecological perspective, the current position of the FIS facility is ideal since it is located in an area that has already been impacted on by construction activities and there is a high invasion of alien species (Acacia cyclops) which needs to be cleared.

Figure 36: Sensitivity map showing the entire project area is of moderate sensitivity


9.5.1. “No-go” Scenario

If the no-go scenario is pursued, the FIS Biofuels facility would not be built nor operated. Therefore the existing impacts (status quo), associated with current ecological conditions would continue, in which case it is likely that Acacia Cyclops will continue to spread and displace indigenous vegetation, particularly that associated with the thicket and mini bushclumps.

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9.5.2. Project Scenario

There are several issues that will arise as a result of the proposed project, these include:

Issue 1 - Loss of vegetation communities: this includes the loss of each of the vegetation community types identified on the site, as a result of the clearing of the land for construction. This issue describes only the direct loss of the vegetation communities and no associated loss of animal nor plant species of special concern, nor the effect on ecosystem functioning or the loss of habitats.

Issue 2 - Loss of species of special concern and biodiversity: this includes loss of both animal and plant species of special concern over the entire site, including all vegetation community types. It also encompasses the loss of biodiversity as a whole, which includes all species that occur on site taking into account their contribution to the biodiversity of the surrounding area and within the site.

Issue 3 - Disruption of ecosystem function and process: this includes the impacts on process areas, and those areas important to ecosystem function either being completely eliminated by the proposed development, or secondary impacts on these systems as a result of the proposed development. This issue encompasses the effect of the inevitable introduction of alien vegetation on the site and the impact of edge effects; the change in vegetation as a result of large-scale clearing and exposing relatively undisturbed areas to transformation.

Impacts are assessed based on the current project boundary and pipeline routing. Should the area change the impacts and associated mitigation measures will need to be revisited.

Table 51 identifies the potential impacts that may arise as a result of the construction and operation activities of the proposed FIS facility, and proposes mitigation measures that have been incorporated in the draft EMPr (Appendix C).

Table 51: Impact assessment table for ecological impacts

Description of the impact: Impact 1: Loss of Thicket Bushclumps and Mini Bushclumps

The construction of the pipeline and tank farm will result in the loss of thicket bushclumps and mini bushclumps within the project site. This vegetation type is considered to be of moderate sensitivity due to the role it plays in providing islands of refugee for small mammals, birds and reptiles as well as housing species of special concern such as Sideroxylon inerme.


Extent Duration Severity Probability Frequency Pre-mitigation significance



- Keep removal of vegetation to a minimum; - Ensure that the footprint of the pipeline and FIS facility are kept to a minimum; - It is recommended that existing vegetation be rehabilitated to control for alien plant invasion and to provide ecolog-

ical corridors.


Extent Duration Severity Probability Frequency Post mitigation significance


1 4 3 5 1 Low to Medium


With mitigation measures such as keeping the clearing of vegetation to the minimum and actively clearing alien vegetation, the overall significance of the impact can be reduced from Medium to Low-Medium.

Description of the impact: Impact 2: Loss of grassland and succulent patches

The construction of the pipeline and FIS facility will result in the loss of grassland and succulent patches within the project site. This vegetation type is considered to be of moderate sensitivity due to the presence of species of special concern and its vulnerable conservation status.


Extent Duration Severity Frequency Probability Pre-mitigation significance


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- Keep removal of vegetation to a minimum within the pipeline servitude; - Ensure that the footprint of the pipeline and FIS facility are kept to a minimum;

- Where feasible, avoid locating infrastructure (particularly within the CDC servitude) on the succulent patches asso-ciated with the exposed calcrete as this is where a large number of species of special concern are likely to be found; and



Extent Duration Severity Frequency Probability Post mitigation significance




With mitigation measures such as keeping the clearing of vegetation to the minimum, the overall significance of the impact can be reduced from Medium to Low-Medium.

Description of the impact: Impact 3: Loss of plant species of special concern




Impact Rating 4 5 5 2 5 Medium to High


- Keep removal of vegetation to a minimum; - Ensure that the footprint of the pipeline and FIS facility are kept to a minimum; - Species of special concern must be marked prior to construction and a search and rescue plan must be developed

in order to transplant these species. This may include seed collection and cultivation. - Some SSC will not transplant. These individuals should, as far as possible, be left undisturbed. - Permits will be required to remove these species.






Mitigating against the loss of species of special concern is often difficult. However, by keeping the clearing of vegetation to a minimum and developing a search and rescue plan for species (particularly succulents), the overall significance of the impact can be reduced from a Medium-High to a Low-Medium.

Description of the impact: Impact 4: Loss of animal species of special concern

There are a number of species of special concern that occur within the study site. This development is unlikely to affect most of these as few are restricted to the site specifically and any found on site are likely to move away when construction begins. However, the Fynbos Golden Mole, if found on site, is likely to be negatively impacted as this species is not mobile and is dependent on its habitat remaining intact.



Impact Rating 1 3 3 2 4 Low to Medium

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- If any fencing is to be erected the fences must have enough space between wires for small animals to move across them uninhibited;

- If the pipeline is to be above ground then culverts underneath the pipeline must be installed at regular intervals to allow small animals to pass under it;

- Workers must also be educated on conservation and may not be allowed to trap or poach animals on site;

- The construction site must be monitored for animal traps and evidence of poaching; - If animals such as tortoises and Golden Moles are encountered during construction, these animals should be care-

fully relocated to a new and suitable habitat




1 3 2 1 3 Low


With mitigation measures in place, the overall significance of the impact will be reduced from Low-Medium to Low.

Description of the impact: Impact 5: Loss of biodiversity

Loss of biodiversity will occur as a result of the loss of the vegetation on site during construction. Species other than species of special concern will be affected, both floral and faunal. However, it must be highlighted that the footprint of the FIS facility and pipeline is relatively small and consequently the loss of biodiversity will be small.



Impact Rating 2 4 3 1 5 Low to Medium


- Keep removal of vegetation to a minimum; - Educate staff on the importance of not removing any animal or plant species from the site; - Prohibit staff from making fires on site;

- After construction, rehabilitate areas not required during the operational phase; - Implement an alien invasive management plan to remove existing species and prevent future infestation. This is

particularly important in this scenario as Acacia Cyclops will increase the fuel load and therefore the risk of fire;

- Where feasible, existing roads should be utilised to prevent the further fragmentation of the site; and - The clearing of vegetation for new roads must be kept to a minimum.




1 3 1 1 5 Low


With mitigation measures in place, the overall significance of the impact will be reduced from Low-Medium to Low.

Description of the impact: Impact 6: Fragmentation of communities and edge effects

Fragmentation is one of the most important impacts on vegetation, especially when this creates barriers in previously continuous vegetation or reduced habitat, causing a reduction in the gene pool and a decrease in species richness and diversity. The landscape is already relatively fragmented, but the construction of the pipeline and tank farm in the area could exacerbate this for plants and small animals since there is the possibility that viable populations may be split or cut off from one another.




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- All fences must have wide enough mesh to let small animals to pass through; - If the pipeline is above ground then culverts must be installed at regular intervals to allow the passage of animals

under the pipeline; - Where feasible, existing roads should be utilised to prevent the further fragmentation of the site; and - The clearing of vegetation for new roads must be kept to a minimum.






With mitigation measures in place, the overall significance of the impact will be reduced from Medium to Low-Medium.

Description of the impact: Impact 7: Invasion of alien plant and animal species

The removal of existing vegetation creates ‘open’ habitats that will inevitably and rapidly be colonised by pioneer plant and animal species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in the area. Once established, these species are typically very difficult to eradicate and may then pose a threat to the neighbouring ecosystem. This impact is likely to be exacerbated by careless management of the site and its facilities during construction and operation e.g. inappropriate disposal of cleared alien vegetation that could harbour seeds and inadequate monitoring. Many such species are, however, remarkably tenacious once they have become established.



Impact Rating 3 5 5 4 5 Medium to High


- Mitigation measures to reduce the impact of the introduction of alien plant invaders, as well as mitigation against alien plant invaders that have already been recorded on the site should be actively managed throughout both the construction and operation phases;

- Removal of existing alien species on site must be undertaken. This will also function to reduce the risk of fire; and - In addition, rehabilitation of disturbed areas after construction must be undertaken as part of a Rehabilitation Plan

as soon as possible after construction is completed.




1 3 1 1 3 Low POSITIVE


Mitigation measures will result in an overall positive impact since alien species will be controlled. The overall significance of the impact will be reduced from a Medium-High NEGATIVE to a Low POSITIVE.

9.5.3. Cumulative Impacts

Since a number of activities were noted to be occurring adjacent to the project site, it is reasonable to consider cumulative impacts. These have been identified as follows:

■ Loss of vegetation communities and biodiversity will be exacerbated;

■ Loss of Species of Special Concern will be exacerbated to the point where local extinctions in the area could be expected; and

■ A positive impact will be the removal of alien invasive plant species in the area.

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The entire study area falls within the Coega Bontveld vegetation type which is relatively intact within the project area however this area is heavily fragmented and there is evidence that the site is being rapidly encroached by Acacia cyclops (a category 2 weed). Left unmitigated, this species has the potential to transform the area from its current state into stands of alien invasive trees

There are no limitations on the development footprint of the FIS facility due to its small size, fragmentation by existing roads and invasion of alien species. Due to the small footprint of the proposed project, it is suspected that many of the impacts will be reduced with effective management of the site as well as the utilisation of rehabilitation during post-construction.

It is recommended that a botanist/ecologist undertakes a detailed survey once the final layout has been generated in order to identify and rescue/relocate the species of special concern or protected species occurring both along the pipeline route and within the footprint of the FIS facility and associated infrastructure. The plants are to be placed in a nursery for rehabilitation purposes on site or on confirmation from the CDC can be util ised for rehabilitation elsewhere in the Coega IDZ. Before the clearing of the site is authorised, the appropriate permission must be obtained from the relevant department. In addition to this, any extra land needed for the construction phase of the development that will not be used during the operation phase of the development should be rehabilitated after construction is completed.

It is also recommended that a strict monitoring plan be implemented to prevent the additional spread of alien invasive plants by continued removal of alien species such as Optunia ficus-indica and Acacia Cyclops, which are already present on site. Annual monitoring and eradication must be implemented.

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10. Traffic Generation and Site Access

10.1. Introduction

This section describes the associated impacts that the proposed FIS biodiesel facility could have on traffic volumes in the vicinity of the proposed site as well as the road network and associated intersections. A Traffic Impact Assessment (TIA) was undertaken by WSP Group Africa (Pty) Ltd, the purpose of which was to evaluate existing traffic, analyse traffic operating conditions and comment on road improvements, safety and maintenance of roads in the vicinity of the proposed plant. The assessment culminated in a specialist report which is attached to this report in Appendix F.

The current proposal for the operation of the plant is that all feedstock is to be imported via the Port of Ngqura, pipe to the facility, converted to biodiesel and piped back to the Port of Ngqura for export. However; for the purposes of the TIA, the worse-case scenario traffic impact was analysed in which all the feedstock and other chemicals required is transported to the plant via road, and all biodiesel produced is then transported from the plant via road to the local SA market. It should be noted that this transportation scenario is highly unlikely, however it was analysed to ensure a conservative approach to the TIA. Based on the number of trips which will be generated by the proposed development, a horizon of 5 years (2018) was analysed.

10.2. Baseline conditions

The proposed plant is to be located in Zone 7 of the Coega IDZ (Figure 37). The site is bounded by a future local access road, which takes access from the National Road N2 via Ring Road 1 interchange. The local access road will form part of the IDZ’s ‘zone splitter’ routes with a road reserve of 60m. Ring Road 1 is a Class 2 primary arterial; the route is partially constructed with access from the N2 via a new narrow diamond interchange. The portion of Ring Road that has been constructed is a two-lane single carriageway undivided route with a road reserve of 60m and can therefore be upgraded to a dual carriageway four-lane road in future.

Figure 37: Locality plan showing road network

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In order to establish the current peak hour traffic volumes on the roads adjacent to the site; weekday morning (AM 06h00 – 09h00) and afternoon (PM 15h30 – 18h30) traffic counts were conducted at the N2 access terminals (north and south) with Ring Road 1 (Figure 38 and Figure 39). The intersection of Ring Road 1 and the local access road was not counted as there is virtually no traffic. Based on the traffic data it was determined that the AM peak hour occurs between 07h45 – 08h45 and the PM peak hour occurs between 15h30 – 16:30.

Figure 38: Existing (2013) weekday AM peak Figure 39: Existing (2013) weekday PM peak The trip generation of the facility cannot be accurately calculated with the Department of Transport’s South African Trip Generation Rates (RR92/228 1995b). These guidelines stipulate a weekday peak hour (AM and PM) trip generation rate of approximately 0,8 vehicle trips per 100m² Gross Leasable Area for Large Industrial Areas (Land use code 130). According to these guidelines the development will generate approximately 504 veh/hr (378 veh/hr in and 126 veh/hr out) in the weekday peaks, based on an erf size of 42,000m², with a standard Floor Area Ratio of 1,5. The above number of trips is far in excess of the expected peak trip generation, as the plant will operate with a very low number of permanent staff, approximately 20 persons per shift, and limited visitors and/or contractors. The bulk of traffic will be the heavy vehicles (34 ton tankers) that deliver the feedstock and chemicals required, and to transport the final biofuels via the road network.

Trip generation rates were therefore generated based on calculations for similar types of facilities, and was undertaken by external engineers. Using a set of assumptions, an estimate total number of trips were generated by the full development during the weekday AM and PM peak hours. The total number of heavy vehicles was estimated at 6 477 (34-ton tankers) vehicles per year to deliver feed stock, and 14 (5-ton tankers) vehicles per year to deliver the required chemicals. The same number of tankers (6,477 vehicles per year) is required to transport the final biodiesel to the local and national market: this is for the ultimate worse–case scenario of all products transported only via road. The estimated total number of trips generated by the full development during the weekdays AM and PM peak hours was estimated to be 40 trips per peak hour (Table 52). It should be noted that these figures were calculated for the ultimate worse-case scenario, in practice the arrivals and departures will be spread through the day, and not be concentrated in the AM and PM peak hours. Furthermore, it is the intention to transport the feedstock and/or finished product to and from the plant via pipeline to the Port of Ngqura, which will also greatly reduce the trip generation.

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Table 52: Estimated trip generation

Land Use

Generated Trips

(veh/hr)

Weekday AM Peak Weekday PM Peak

In Out Total In Out Total

Heavy vehicles 20 0 20 0 20 20

Staff 15 5 20 5 15 20

Total 35 5 40 5 35 40

The National Department of Transport’s South African Manual for Traffic Impact Studies (1995) requires a Traffic Impact Statement for developments that generates more than 50 trips and less than 150 trips per peak hour, or if the surrounding road network is operating at or above capacity. The proposed development will generate less than 50 trips per peak hour as ultimate worse-case scenario, and the partially constructed local road network is operating far below capacity, therefore a Traffic Impact Statement is not warranted (i.e. not required).

It was however decided to undertake a full Traffic Impact Statement, with some additional capacity analysis of the affected local intersections, namely the N2 ramp terminal intersections with Ring Road 1. This ensures that any possible adverse traffic impacts by this development, on the local road network, is identified and addressed.

A 3% per annum growth rate for background traffic was applied to determine the estimated horizon year (2018) background traffic based on the level of development within the surrounding area. The assigned generated traffic was combined with the background traffic to produce the expected traffic volumes for the base and horizon years, 2013 and 2018 respectively (Figure 40 to Figure 43).

Figure 40 Base year (2013) weekday AM peak hour traffic, including trips generated by the proposed development:

Figure 41: Base year (2013) weekday PM peak hour traffic, including trips generated by the proposed development

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Figure 42: Horizon year (2018) weekday AM peak hour traffic, including trips generated by the proposed development

Figure 43: Horizon year (2018) weekday PM peak hour traffic, including trips generated by the proposed development


10.3.1. Operational Assessment

SIDRA Intersection Software (Version 6.0) was used to determine the impact of trips generated by the proposed FIS Biofuels refinery during the morning (am) and afternoon (pm) peak. The following scenarios were considered for analysis:

■ Scenario 1: Base Traffic (2013) weekday AM/PM peak- without development; and ■ Scenario 2: Base Traffic (2013) weekday AM/PM peak- with development; and ■ Scenario 3: Horizon year (2018) weekday AM/PM peak with development.

The results of the analysis of the intersections of the N2 ramp terminals and Ring Road 1 are summarised below.

N2 (eastbound terminal) and Ring Road 1

The exit terminal is Stop controlled. The analysis was undertaken with 15% heavy vehicles, which is considered appropriate for these intersections. The latest 2012 SANRAL yearbook indicate 15,5% heavy vehicles on this section of the N2 between the Motherwell and Ncanaha interchanges

Scenario Weekday AM Peak Hour Weekday PM Peak Hour

1: Existing traffic (2013) without development

The overall operation of the intersection is acceptable, with a very low

V/C ratio of 0.049,

indicating that the intersection has ample spare capacity

The overall operation of the intersection is acceptable, with a very low V/C ratio of 0.037, indicating that the intersection has ample spare capacity

2: Existing traffic (2013) with development

The overall operation remains acceptable, with a V/C ratio of 0.066.

The overall operation remains acceptable, with a V/C ratio of 0.049

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3: Horizon year (2018) with development



N2 (westbound terminal) and Ring Road 1

The exit terminal is Stop controlled. The analysis was undertaken with 15% heavy vehicles.

Scenario Weekday AM Peak Hour Weekday PM Peak Hour

1: Existing traffic (2013) without development



2: Existing traffic (2013) with development



3: Horizon year (2018) with development



According to the Manual for Traffic Impact Studies (Department of Transport, 1995), the traffic impact of any proposed development should be mitigated under the following circumstances:

If the level of service (LOS) of any element of the facility drops below D; or

If the volume to capacity (v/c) ratio of any element of the facility increases above 0.950; and

If the contribution of the development is at least 2% of the sum of the critical lane volumes of the element.

The above relates to peak hour conditions and based on these warrants, and taking the above analysis results into account, no mitigating measures are required.

10.3.2. Access – Local access road

A single full access will provide direct access to the facility from the Local Access Road. The staff and visitor parking area are directly accessible from this access. The access will have a dual entry lane and single out lane of 4.5m each. The entry lanes will be to separate the heavy vehicles and normal vehicles/visitors. Access control will be in operation, and the set-back of the security control mechanism will allow heavy vehicles to hold on-site without obstructing through traffic.

The access will be located approximately 260 m from the upstream intersection of the Local Access Road and Ring Road 1.

10.3.3. Accommodation of Public Transport and Pedestrians

Taking the nature of the proposed development and the adjacent land use into account, it is anticipated that no public transport trips will be generated. The provision of any public transport facilities is therefore not considered necessary.

Minimal to no non-motorised transport trips will be generated, as it is more than 10km away from the nearest suburbs of Port Elizabeth, and there are no public transport routes in the vicinity of the development. It is however recommended that a paved pedestrian walkway of 2m should be provided along the property frontage of the development with the Local Access Road.

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10.3.4. Parking Assessment

Table 53 shows the number of parking bays required for the development, as per the Department of Transports Parking Standards (1985), against the actual parking bays planned for on-site.

Table 53: Parking requirements

Land Use GLA

(m²)

Parking required

(bays/100 m²) *

Total parking required

Total parking provided

Industrial Area 31 500 2 630 40

*Source: Department of Transport, 1985, Parking Standards (Second Edition), PG3/85

From the above table it can be seen that the required parking provision cannot be accommodated on site with the outdated requirements of the National Department of Transport Parking Standards. However, as a maximum of 20 persons will be employed at the facility during a normal working day, the parking provision is regarded as more than adequate. The above parking bays exclude the heavy vehicles circulation and loading/off-loading on the site, which will be accommodated in dedicated areas.


10.4.1. ‘No Go’ Option

If the no-go scenario is pursued, the FIS Biofuels facility would not be built nor operated. Therefore the existing impacts (status quo), associated with current traffic conditions would continue; as the area is currently sparsely developed these impacts are minimal and the option will result in the local access road not being built at this period in time.

10.4.2. Project Specific

Based upon the triggers identified within the National Department of Transport’s South African Manual for Traffic Impact Studies (1995) a Traffic Impact Statement is not mandatory for the proposed FIS facility. Nevertheless, a traffic impact study was undertaken for the site and no significant issues were identified, although some recommendations have been made with regards to low impact issues.


10.5.1. Conclusions

From the results of the analysis the following can be concluded:

The N2 ramp terminal intersections with Ring Road 1 currently operates at an acceptable level of service

during both the weekday AM and PM peak hours.

The proposed development will cause minimal impact in the level of service for the base year (2013) and

horizon year (2018) scenarios.

No additional external road infrastructure, except for the local access road and completion of Ring Road 1

up-to the local access road, will be required for the Horizon year (2018) scenario. The infrastructure

requirements are the responsibility of the Coega Development Corporation.

Pedestrian access and on-site circulation is sufficient.

On-site parking provision is sufficient.

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10.5.2. Recommendations

It is therefore recommended that:

No mitigating measure are required with regards to the road infrastructure in the vicinity of the proposed FIS

Biofuels plant since the overall traffic impact of the facility will be low; and

A paved pedestrian walkway of 2m should be provided along the property frontage of the development with

the Local Access Road.

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11. MHI Quantitative Risk Assessment

11.1. Introduction

For the operation of the biodiesel facility various types of vegetable oils, Methanol, and Sodium Methoxide as well as the finished product (Biodiesel) will also be stored in bulk tanks. All these products are flammable, with the exception of the oils. As these flammable substances have the potential to cause onsite and offsite incidents, WSP appointed Major Hazard Risk Consultants CC (MHR Consultants) to conduct a risk assessment in accordance with the Major Hazard Installation (MHI) Regulations to determine the impact of the facility on the surrounding area (a copy of the report is attached in Appendix F).

The risk assessment was conducted in accordance with the MHI Regulations and could be used as notification to the facility:

■ To develop accidental spill scenarios for the storage facility;

■ Using generic failure rate data (tanks, pumps, valves, flanges, pipework, gantry, couplings) to determine

the probability of each accident scenario;

■ For each incident developed in Step 2, determine the consequences;

■ To calculate the Maximum Individual Risk (MIR) values taking into account all accidents, meteorological

conditions and lethality;

■ Using the population density near the facility, determine societal risk posed by the facility; and

■ To include an assessment of the adequacy of emergency response programmes, fire prevention and fire-

fighting measures.


■ Risk calculations are not precise. The accuracy of the predictions is determined by the quality of base data

and expert judgements. Omissions or inaccurate data in drawings or documentation used as base data

could result in inaccurate results;

■ The risk assessment was done on the assumption that the site is maintained to an acceptable level and

that all statutory regulations are applied.

■ It was also assumed that the detailed engineering designs were done by competent people and are

correctly specified for the intended duty.

11.3. Hazard identification

During the hazard identification component, the following considerations are taken into account:

■ Chemical identities;

■ Location of facilities that use, produce, process, transport or store hazardous materials;

■ The type and design of containers, vessels or pipelines;

■ The quantity of material that could be involved in an airborne release;

■ The nature of the hazard (e.g. airborne toxic vapours or mists, fire, explosion, large quantities stored or

process conditions) most likely to accompany hazardous material spills or releases.

Biodiesel, Methanol and Sodium Methoxide were identified as flammable materials. The General Machinery

Regulation 8 and its ‘Schedule A’ on notifiable substances, requires any employer who has a substance equal

or exceeding the quantity as listed in the regulation to notify the divisional director. A site is classified as a MHI

if it contains one or more notifiable substances or if the offsite risks are sufficiently high. The latter can only be

determined from a quantitative risk assessment. Methanol, biodiesel and sodium methoxide are not notifiable

substances as per Schedule A.

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11.4.1. Physical and Consequence modelling

In order to predict the impact following an accident, it is necessary firstly to estimate the physical process of the release (i.e. rate and size) and the subsequent atmospheric dispersion of the airborne cloud; or in the case of ignition, the burning rate, the resulting thermal radiation or the overpressure from an explosion.

The second step is to estimate the consequences of the release on humans, fauna, flora and structures. The consequences would be due to the toxicity, thermal radiation and/or explosion overpressures. The consequences may be described in various formats. The simplest methodology follows a comparison of predicted concentrations (or thermal radiation, or overpressure) to short term concentration (or radiation, or pressure) guideline values.

11.4.2. Fires

There are four bulk tanks containing flammable materials located inside a bund on the site. In the case of a spillage at the flammable installations, a spillage would be confined within the bunded area. A spillage from a road tanker could form a spreading pool and if ignited would cause an unconfined pool fire.

A fire at any of the flammable installations would be confined to that specific installation and could impact on a neighbouring installation. A fire at FIS biofuels could not impact beyond site boundaries.

The thermal radiation isopleths from all the fires for the site combined are shown in the Figure 44 below.

Figure 44: Radiation flux from all fires

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11.4.3. Explosions

11.4.3.1. Vapour cloud explosion consequences:

A release of flammable liquid could result in the formation of a vapour cloud. The concentration of the combustible component decreases from the point of release to the lower explosive limits (LEL), where the concentration of the component can no longer ignite. The material contained in the vapour cloud between the higher explosive limits (HEL) and LEL, if ignited will form a flash fire or fireball. The sudden detonation of the explosive mass of material causes an overpressure that can result in injury or damage to property. A confined gas explosion is where the exploding gas is restricted from expanding by physical barriers such as walls or equipment and obstacles.

A confined vapour cloud may give rise to any of the following effects: ■ Blast damage;

■ Thermal damage;

■ Missile damage;

■ Ground tremors;

■ Crater formation;

■ Personal injury.

These obviously depend on the pressure waves and proximity to the actual explosion. Of concern in this investigation are the “far distance” effects, such as limited structural damage and the breakage of windows, rather than crater formations. The possibility of a vapour cloud explosion impacting beyond the boundaries of FIS biofuels is highly unlikely.

11.4.3.2. Unconfined gas explosions:

An unconfined gas is a flammable gas cloud that detonates within an area that is uncluttered and the expanding gases can easily escape. The maximum overpressure from the unconfined gas explosion is much lower than that confined to the confined explosion and hence the overpressure distance to safety is lower.

11.4.3.3. Confined gas explosions:

A confined gas explosion is where the exploding gas is restricted from expanding by physical barriers such as walls or equipment and obstacles. The confined gas explosions were modelled by means of the multi- energy model using the explosion class of 10. The multi- energy model uses the energy available for explosions and setting the class between 1 and 10 can determine the effects of a weak deflagration to a confined detonation.

A fixed roof tank explosion is a confined gas explosion and is the explosion within a tank with the explosive mass calculated as the volume of the tank at its lower flammable limit (LFL). The blast overpressure from the tank top explosions are shown in Figure 45. A large fixed roof tank explosion could have impacts beyond the site boundary with damage to neighbouring property and a chance of fatalities.

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Figure 45: Potential Overpressure

11.4.3.4. Boiling Liquid Expanding Vapour Explosion (BLEVE):

A boiling liquid expanding vapour explosions (BLEVE) can occur when a flame impinges on the condensate vessels, particularly in the vapour space region where cooling by evaporation of the contained fluid does not occur. The vessel shell weakens, ruptures with a total loss of contents and the issuing mass of material burns as a massive fireball.

The possibility of a BLEVE occurring on the FIS biofuels site is remote and was not modelled.

11.4.4. Employee Risk

Scenarios considered with regard to risk to employees are toxic vapour clouds from ammonia and chlorine plant failures, vapour cloud explosions and BLEVEs from LPG vessel failures, and pool fires from fuel installations. Employees and the public are indoors and outdoors during the day and major events associated with these installations would occur outside of the building in the vicinity of the installation areas. When exposed to hazards such as toxic clouds, people who are indoors (sheltered) will generally be less vulnerable than those outdoors (unsheltered). The risks should not be more than one in a thousand.

11.4.5. Individual Risk

The total individual risk involving all the installations shows that the proposed FIS Biofuels refinery should not be declared an MHI, with the 1.0e-6 contour falling inside the property boundaries. This risk is acceptable as there is only a one in a million possibility of an off-site fatality (Figure 46).

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Figure 46: Individual risk

11.4.6. Site Societal Risk:

Societal risk evaluation is concerned with estimation of the chances of more than one individual being harmed simultaneously by an incident. The likelihood of the primary event (an accident at a major hazard installation) is still a factor, but the consequences are assessed in terms of level of harm and the numbers affected (severity), to provide an idea of the scale of an accident in terms of numbers killed or harmed. A key factor in estimating societal risk is the population around the site, in particular its location and density.

For the purpose of this assessment, the Groningen (Provinciale Waterstaat Groningen promulgated the former criteria in 1979) and Dutch Authority [Ale, 1991] criteria are referenced. According to these criteria, the societal risk associated with the facility is lower than the recommended value by the Dutch authorities, and falls within the “as low as reasonably practical” (ALARP) region defined by the Groningen curves. However, the societal risks may change and become unacceptable if more developments are approved within close proximity to the flammable installations.

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If the no-go scenario is pursued, the FIS Biofuels facility would not be built nor operated. Therefore the status quo would continue.


MHI Risk Assessments do not lend themselves to ‘significance ratings’ in the same way as other issues assessed within this document.

11.6. Recommendations and Conclusions

11.6.1. Conclusions

This investigation concluded that the risks from large fires at the proposed FIS Biofuels refinery in the Coega IDZ could not extend beyond the site’s boundaries, and this risk is acceptable.

The facility is not considered a Major Hazard Installation.


11.6.2.1. Emergency plan

The emergency plan must be developed to reflect the extent of the exposure of individuals and communities to the endpoint of the hazards.

11.6.2.2. Review of Risk Assessment

This risk assessment is valid for the duration of five years from the above date unless:

■ Changes have been made to the plant that can alter the risks on the facility;

■ The emergency plan was invoked or there was a near miss;

■ The changing neighbourhood could result in offsite risks;

■ There is reason to suspect that the current assessment is no longer valid.

11.6.2.3. Land Use

The development of land surrounding the FIS Biofuels refinery should be done with caution so as not to pose unnecessary risks on the surrounding communities. This caution is aimed at ensuring the adjacent developments are suitable for the risk imposed.

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12. Heritage Statement

12.1. Introduction

The heritage statement has been prepared by WSP in its capacity as the EAP. The heritage statement has been compiled from a desktop review of the following studies that have been undertaken in the area and are applicable to the FIS Biodiesel facility:

■ Binneman J, 2010a, A Phase 1 Archaeological Impact Assessment of the greater Coega Industrial Development Zone (IDZ), near Port Elizabeth, Nelson Mandela Bay Municipality, Eastern Cape Province.

■ Almond, J.E. 2010a. Palaeontological heritage assessment of the Coega IDZ, Eastern Cape Province.

■ Bennie, J., 2010, Historical component of heritage impact assessment relating to the built environment and graves of the greater Coega Industrial Development Zone (IDZ), near Port Elizabeth, Nelson Mandela Bay Municipality, Eastern Cape Province, Prepared for Coega Development Corporation.

■ CSIR, 2013. Environmental Impact Assessment for the proposed Bulk Liquid Storage and Handling Facility in Zone 8 of the Coega Industrial Development Zone (IDZ): Final Environmental Impact Assessment Report. CSIR Report Number: CSIR/CAS/EMS/ER/2011/0027/B.

■ CSIR, 2013. Final Basic Assessment Report for the Provision of Landside Structures and Infrastructure to the Bulk Liquid Storage and Handling Facility in the Port of Ngqura within the Coega IDZ, Nelson Mandela Bay Municipality, CSIR Report No. CSIR/CAS/EMS/ER/2012/0017/B.

12.2. Methodology

This statement provides an overview of the heritage (i.e. archaeological, paleontological as well as historical and cultural) resources in the vicinity of the proposed FIS Biodiesel facility and how these could potentially be impacted by the development. Specific management actions, as proposed by the South African Heritage Resources Agency (SAHRA), are recommended to avoid or mitigate any potential impacts.

Heritage Impact Assessments for the Coega IDZ were done for 14 zones of the IDZ in May 2010. These assessments excluded Zone 8. However, an EIA was conducted for Zone 8 in July 2013, for a bulk Liquid Storage and Handling Facility

31 and a Basic Assessment process for the landside infrastructure

32. Findings

from the above reports were transferred to this project, making an additional heritage impact assessment unnecessary.


12.3.1. Historical and Cultural Impact

The historical report compiled by Jenny Bennie, of the Albany Museum, as part of the Heritage Assessment for the Coega IDZ (commissioned by the CDC in 2010), concluded that no culturally sensitive pre- 18

th century

structures were observed in the designated zones of the Coega IDZ. However, oral history could possibly show a variety of cultural groups such as Early, Middle and Stone Age man, San, Khoekhoen and black Xhosa speaking people passed through the area. The area was also inhabited by the Trekboer, Dutch and British 1820 settlers, who left some remnants of their cultures in the form of buildings and demarcated grave sites.

According to the historical assessment of the Coega IDZ, the Hougham Park homestead is located on Zone 7. The Homestead consists of a house and cottage and has been identified as having potential heritage value. The Homestead belonged to Hougham Hudson, who bought the property, originally named Samson’s Kraal,

31

CSIR, 2013. Environmental Impact Assessment for the proposed Bulk Liquid Storage and Handling Facility in Zone 8 of the Coega Industrial Development Zone (IDZ): Final Environmental Impact Assessment Report. CSIR Report Number: CSIR/CAS/EMS/ER/2011/0027/B

32 CSIR, 2013. Final Basic Assessment Report for the Provision of Landside Structures and Infrastructure to the Bulk Liquid Storage and Handling Facility in

the Port of Ngqura within the Coega IDZ, Nelson Mandela Bay Municipality, CSIR Report No. CSIR/CAS/EMS/ER/2012/0017/B

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from Ingnatius Stephanus Ferreria and renamed it Hougham Park in 1837. The report also makes mention of three shipwrecked sailors, who were grounded in 1817. Associated historical remains have not been found but could be excavated in the dunes of Zones 1, 7 and 10.

The FIS facility will be constructed more than 1km away from Houghman Park and therefore this facility will not have an impact on this site.

12.3.2. Archaeological Features

The review of the archaeological features is based on findings from a Phase 1 Archaeological Impact Assessment (AIA) of the greater Coega IDZ by Dr Johan Binneman, report dated May 2010. Finding archaeological materials or sites is made difficult in Zone 7 due to the dense grass, bush and alien vegetation occurring across the zone. Bush clearing has occured mainly towards the western side of the zone for large scale development infrastructure, most noticeably a road running from east to west of the zone. The bush clearing activities for this road exposed a thin layer of grey dune sand, which covers the dominant geological formation of Calcrete, and thin scatters of archaeological material towards the eastern side of the zone.

A thin spread of marine shell was noted over a fairly large area. Fragments of bone, a tooth and stone tools and pottery were also associated with the shell spread. The bulldozing activities associated with the building if the road exposed Middle Age stone tools. It is unknown how many archaeological sites were destroyed when these areas were bulldozed. A spot check was undertaken in very close proximity to where the FIS site is proposed to be constructed (Figure 47). The report indicates that no archaeological remains were found at that point. This could be due to the fact that the vegetation was too dense to determine the presence of any archaeological artefacts or that no artefacts are present on site. There is therefore a chance that archaeological artefacts may be uncovered following vegetation clearing.

Figure 47: The map shows the route where “spot checks” were undertaken as part of the Phase 1 AIA.*

*The blue circles spot checks and survey areas and the pink dots mark where Later and Middle Stone Age materials were found (Map source: Binneman, 2010). The yellow square indicates the locality of the proposed FIS site.

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Zone 8, similarly too Zone 7 and much of the Coega IDZ, is covered in dense vegetation making it difficult to locate archaeological sites or materials. The shallow topsoil covering the Coega region does not allow for any deep archaeological deposits or features.

It is predicted that mainly Earlier, Middle and Late Stone Age tools in secondary context associated with exposed peddle/cobble gravels will be exposed during the construction of, inter alia, the Transnet fuel reserve. However, other archaeological sites/materials (such as human remains and shell middens) may be covered by soil and vegetation and there is the possibility that these may be exposed during development. In general the proposed area for development is of low archaeological significance and the proposed development will have little impact on possible archaeological sites/materials. The construction of the fuel reserves will be monitored for archaeological sites/materials. This will fall under the responsibility of Transnet. The construction of aboveground pipelines within the reserve will have no impact.

12.3.3. Paleontological

An extract from the paleontological heritage assessment, undertaken by John Almond (Almond, J.E. 2010a. Paleontological heritage assessment of the Coega IDZ, Eastern Cape Province.) is detailed below:

Apart from the modern coastal sand dunes, most of the Coega IDZ landscape is mantled by dense vegetation – primarily Mesic Succulent Sundays Thicket along the valley slopes and drier Coega Bontveld on the calcareous plateau. Natural exposures of bedrock are therefore confined to occasional erosional dongas and low limestone cliffs along the steeper Coega Valley sides, small craggy outcrops on Coega Kop, as well as narrow rocky benches, low calcareous sandy cliffs and dunes in the coastal zone. Fresh exposures of the older geological units are for the most part only found in roadcuts, borrow pits, limestone quarries and clay-pits, as well as an extensive network of storm water channels and reservoirs. Most of these excavations have been made in recent years following the establishment of the Coega IDZ. Older excavations such as clay pits and limestone quarries, several of which have yielded important fossil material in the past, are in many cases already overgrown and difficult to access. Ongoing rehabilitation involving infilling of many of these excavations with rock waste, rubble and cleared vegetation further restricts opportunities to study the bedrock and to record fossils.

The Coega IDZ is entirely underlain by a range of terrestrial, coastal and marine sedimentary rocks that extend from modern times back to the Early Cretaceous Period, some 470 or so million years ago. These sediments are assigned to three major geological successions: (1) the Early Palaeozoic Table Mountain Group comprising Ordovician (c. 450 Ma) fluvial sandstones and quartzites of the Peninsula Formation that are only seen at Coega Kop; (2) the Mesozoic Uitenhage Group that was deposited within the Algoa Basin in a range of fluvial, estuarine and shallow marine settings during the Late Jurassic to Early Cretaceous Periods (c. 150-130 Ma), and (3) the Late Caenozoic Algoa Group that accumulated along the coast of Algoa Bay over the last seven million years in estuaries, lagoons, rocky and sandy shores, and aeolian dune fields. A rich fossil record has been found in several of the marine sedimentary formations found here, notably the Early Cretaceous Sundays River Formation, the Late Tertiary Alexandria Formation, and the Pleistocene Salnova Formation. The terrestrial formations tend to be far less fossil rich on the whole, but important fossil material – notably dinosaurs and plants in the Early Cretaceous Kirkwood Formation – may potentially be found here as well.

Zone 7, the zone on which the FIS Biofuels refinery will be constructed, is situated between the N2 National road and Zone 10, which is adjacent to the coast. A secondary dune system stretches out across Zone 7. Large scale infrastructural development is taking place mainly towards the western side of the zone. These include the building of bridges, roads, a power substation and power lines, a massive quarry and construction of bridges. A new road is being constructed east to west of the zone, parallel to the N2 on the boundary between Zones 7 and 10.

The review of the paleontological features is based on findings from a Paleontological Impact Assessment done by Dr John Almond, report dated July 2013 compiled in support of the Basic Assessment for the Provision of Landside Structure and Infrastructure to the proposed Bulk Liquid Storage and Handling Facility. The study found that the proposed pipelines are located in an area that is underlain by potentially fossil rich sedimentary rocks of Mesozoic and younger, Tertiary or Quaternary age. The construction of the pipelines with the berth in the Port of Ngqura will entail major excavations into the superficial sediment cover as well the underlying bed rock.

The proposed landside structures and associated infrastructure (which includes the fuel reserve) in Coega IDZ Zone 8 overlie sedimentary rocks of the Cretaceous Uitenhage Group and the Late Caenozoic Algoa Group.

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While most of the near-surface rocks here are of low palaeontological sensitivity, important fossil remains may be found in the Early Cretaceous Kirkwood and Sundays River Formations and the Pleistocene to Recent Salnova Formation, all of which are best exposed along the eastern margins of the Coega Estuary.

Many of the proposed infrastructure components have a small footprint and / or do not entail substantial bedrock excavations and / or overlie rocks of low palaeontological sensitivity. Their impact significance is therefore rated as very low and, pending the exposure of new fossil material during construction, no specialist mitigation is recommended here. General monitoring of deeper (> 2m) excavations for fossil heritage by the Environmental Control Officer (ECO) is adequate in this case.



If the no-go scenario is pursued, the FIS Biofuels facility would not be built nor operated as such the potential to find items of cultural or heritage value will be lost, until the property is developed for another industrial activity.


Table 54 identifies the potential impacts that may arise on heritage and cultural resources as a result of the construction activities of the proposed FIS facility, and proposes mitigation measures that have been incorporated in the draft EMPr (Appendix C).

Table 54: Potential Heritage Impacts

Description of the impact: Impact 1: Impact on heritage

Archaeological sites/ materials may be uncovered during the clearing of the site and excavations.



Impact Rating 2 1 2 1 2 Low (-ve)


- Construction managers/foremen must be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow should they find sites;

- If concentrations of archaeological heritage material, human remains or fossils are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the South African Heritage Resources Agency (SAHRA) (021 642 4502) so that systematic and professional investigation/ excava-tion can be undertaken.




2 5 5 1 2 Low-Medium (+ve)


The impact is considered to be Low (-ve), however with the implementation of mitigation measures the impact can be changed into an overall Low-Medium (+ve) due to the educational benefits from discovering archaeological assets.

12.5. Recommendations

The following recommendations need to be included within the EMPr developed for this project:

In the comment received from SAHRA on the AIA undertaken in 2010, SAHRA recommended that because of the higher sensitivity of the zone, the following should be implemented:

■ Short strips of vegetation be cleared carefully in Zones 1, 7 and 10 (due to the higher sensitivity of these zones), under supervision of an archaeologist or an ECO trained by an archaeologist.

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■ If artefacts are found, the archaeologist will examine and determine the necessity of a Phase 2 AIA.

■ If a Phase 2 AIA is not necessary the archaeologist, in consultation with SAHRA, will either collect the material or advise otherwise.

■ Should any fossils, artefacts, heritage material etc. be uncovered the Eastern Cape Province Heritage Resources Agency (ECPHRA) (Contact details: Mr. Sello Mokhanya, 74 Alexander Road, King Williams Town 5600; [email protected]) must be notified. A fossil collection permit must be obtained from ECPHRA and all fossil material should be curated at an approved institution (e.g. Albany Museum, Grahamstown). Any fossil material collected must be recorded according to best academic practice and properly curated in an accredited palaeontological collection, such as the Albany Museum, Grahamstown.

■ If any concentrations of material (especially concentrations of marine shell) are uncovered during development, construction work in that location must be halted and it should be reported to the Albany Museum (Tel: 046 622 2312) and the SAHRA (Contact details Tel: 021 462 4502, Fax: 021 462 4509, Email: [email protected]) immediately so that systematic and professional investigation/excavations can be undertaken. Sufficient time should be allowed to remove/collect such material before construction re-commences.

■ If an archaeologist or site monitor is not considered, then the construction managers/foremen must be informed, before construction starts, on the possible types of heritage sites which may be encountered during construction.

■ If any human remains and/or other archaeological and historical material are uncovered during the construction, such material must be reported to the nearest museum, archaeologist and to the SAHRA (or the South African Police Services) if exposed, so that a systematic and professional investigation can be undertaken. Sufficient time should be allowed to remove/collect such material before construction recommences.


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13. Socio-economic

13.1. Introduction

This section describes the impacts that the proposed development will have on the socio-economic quality in the surrounding area, the significance thereof as well as the recommended mitigation measures. During the Scoping Phase, it was not considered necessary that a specialist be appointed to assess this potential impact, it has therefore been assessed and rated by the Environmental Assessment Practitioner (EAP).


Table 55 shows the impacts that have been identified as a result of the construction and operation activities of the proposed FIS Biodiesel facility.

Table 55: Potential Socio-Economic Impacts

Description of the impact: Impact 1: Potential impact on job creation and skills development during construction

The proposed facility could result in job opportunities and skills development in the local area.



Impact Rating 1 2 3 1 2 Low (+ve)


- Maximise use of local skills and resources where practicable as per the Coega Zone Labour Agreement;

- Provide suitable training.




2 2 3 2 3 Low-Medium (+ve)


The impact is considered to be Low (+ve); however with the implementation of mitigation/optimisation measures the impact can be changed into an overall Low-Medium (+ve).

Description of the impact: Impact 2: Potential impact on job creation and skills development during operation

The proposed facility is envisaged to create 17 job opportunities during operation.



Impact Rating 1 3 3 1 3 Low (+ve)


- No mitigation measures proposed




N/A


The overall impact is considered to be Low (+ve).Any job creation within South Africa is considered positive. Seventeen new job opportunities in the context of a high unemployment rate is seen as a low positive.

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14. Noise Impacts

14.1. Introduction

This section describes the impacts that the proposed development will have on the noise quality in the surrounding area, the significance thereof as well as the recommended mitigation measures.

14.2. Baseline Conditions

Existing ambient noise levels within the IDZ are low due to the relatively low level of industrial activity within the IDZ at present. As industrial activity within the IDZ increases, the ambient noise within the IDZ will increase to a level more consistent with industrial areas. The closest residential areas to the site are St Georges Strand and Wells Estate, which are approximately 6.8km and 7.7km from the site respectively.

SANS 10103:2008 defines ‘daytime’ as 06:00 to 22:00 hours and ‘night time’ as 22:00 to 06:00 hours. The rating levels in Table 56 indicate that in industrial districts the ambient noise should not exceed 60 dB(A) at night and 70 dB(A) during the day. These levels can thus be seen as the target levels for any noise pollution sources in the IDZ.

Table 56: Typical rating levels for noise

ZONE MAXIMUM Lr (dBA)

Day Evening Night

Industry 70 70 60

Business; commercial 65 60 55

Residential; education; institute; hospital 55 50 45

Rural; recreational 45 40 35

Nature reserve 35 30 25

Source (SANS 10103:2008)

Furthermore the South African noise control regulations (GNR.154 and GN 2322) describe a disturbing noise as any noise that exceeds the ambient noise by more than 7 dB(A) and as a rule this is applied at the boundary of a site (although it is recognised that the receptor may be some distance from the boundary of the site). Therefore, if a new noise source is introduced into the environment, irrespective of the current noise levels, and the new source is louder than the existing ambient environmental noise by more than 7 dB(A), then the site would not be in compliance with the Noise Control Regulations.


Table 57 shows the impacts that have been identified as a result of the construction and operation activities of the proposed FIS Biodiesel facility.

Table 57: Potential Noise Impacts

Description of the impact: Impact 1: Potential noise impact during construction

Noise will result mostly from the increase in vehicular traffic on the roads to the site as well as from the movement of vehicles and use of machinery (plant) for construction related activities.



Impact Rating 2 2 3 5 3 Low-Medium (-ve)

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- Construction activities that have the potential to generate noise should be limited to 06h00 to 22h00 (Monday to Saturday);

- Maintenance of plant and machinery to be undertaken on a regular basis; - Speed limits should be implemented on site and adhered to off site; - Any complaints must be investigated and corrective actions implemented.



Impact Rating 1 2 2 3 1 Low (-ve)


The impact is considered to be Low-Medium (-ve), however with the implementation of mitigation measures the impact can be changed into an overall Low (-ve).

Description of the impact: Impact 2: Potential noise impact during operation

Noise will result mostly from the production machinery used in the production process. Should the facility become operational prior to the OTGC tank farm and pipeline infrastructure being installed the increased vehicular traffic in the form of trucks will result in increased noise in the vicinity.



Impact Rating 2 4 2 5 2 Low-Medium (-ve)


- Use Best Available Technology; - Maintain equipment/machinery in good working order; - Installation of pipelines for the transport of biodiesel and feedstock to and from site.




1 2 2 3 1 Low (-ve)


The impact is considered to be Low-Medium (-ve), however with the implementation of mitigation measures the impact can be changed into an overall Low (-ve).


The FIS Biodiesel facility is proposed to be established in a fairly undeveloped area (i.e. Zone 7) of the IDZ; furthermore the facility is not anticipated to exceed the noise limits stipulated in the NMBM by-laws for both the construction and operational phases. Implementation of the recommended mitigation measures is anticipated to sufficient in management of the potential noise impacts. It is however recommended that a once off representative noise monitoring investigation be undertaken approximately 3 months after the plant is operational to determine the noise levels at the boundary of the site for future planning within the CDC. Based on the limited development currently in the vicinity of the proposed site the cumulative noise impacts are anticipated to be negligible.

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15. Visual Impact Statement

15.1. Introduction

Comment received from the DEDEAT in the Scoping Report Approval Letter (dated 23 August 2012) requires that: “appropriate design alternatives are considered that can limit or soften the visual impact of the refinery especially taking into account the proximity of the Greater Addo Elephant National Park. In this regard one would expect that various design options should be looked at and that green design principles will be incorporated into the final design. Consideration should also be given to the architectural guidelines of the CDC”.

Based on the above comment, WSP has compiled a Visual Impact Statement which includes a review of the proposed design of the FIS Biodiesel facility and the Coega Development Corporation (Pty) Ltd Architectural and Landscape Design Guidelines (Document Number Coega/PH3/CDC/ALG0 Rev 2 30/08/2005).

15.2. Visual Impact Statement

15.2.1. Facility design

The FIS facility will be based upon the design of the HeroBX biodiesel plant in the USA. A photo of the facility is shown in the Figure 48.

Figure 48: Photo of the operational HeroBX facility.

The buildings that will be present on site and their respective heights are detailed below:

■ Pre-treatment Building Tower (31m in height);

■ Transesterification Building (17m in height);

■ Wastewater Treatment Building (13m in height);

■ Pre-treatment Building (13m in height);

■ Filter Building (7m in height); and

■ Office and Administration Building (6m in height).

Based on the heights shown above, it is anticipated that the facility will be seen from the N2. Since the final design of the facility has not been undertaken, the colours of the tanks and buildings are not confirmed. However, it is assumed that colours such as white, silver and/or aluminium will be used for the infrastructure. Because of the fact that the whole area has been through a rezoning process and zones determined for specific type of industries, the proposed facility will not go against the ‘sense of place’ of the immediate area (i.e. the CDC IDZ). Zone 7 specifically has been earmarked for petrochemical sector industrial development.

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15.2.2. Architectural and Landscape Design Guidelines

The Architectural and Landscape Design Guidelines seek to achieve an attractive and consistent development character without overly restricting designers or detracting from the corporate identity of individual developers and tenants.

The two sections in the guidelines that have been deemed most relevant to the facility’s design have been reviewed and compliance to the requirements set within these sections determined. These sections are:

■ Section 7 Architectural Design Guidelines which addresses the overall design and sets minimum standards for shared amenity for all buildings within the Coega IDZ. Key issues that are addressed in these guidelines are:

■ Architectural character;

■ Building design directives; and

■ Materials and treatment of elements.

■ Section 8 Landscaping Design Guidelines address the overall design and set minimum standards of shared amenity for all developments within the Coega IDZ. Key issues addressed in the guidelines are:

■ Landscape intentions;

■ Existing landscape;

■ Stockpiling of topsoil, planting, irrigation, lighting and boundary fences.

Compliance to these sections is detailed in Table 58.

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Table 58: Compliance to Section 7 and 8 of the Architectural Design Guidelines

ARCHITECTURAL DESIGN GUIDELINES

Architectural Character

To achieve an architectural integrity that extends over the entire Coega IDZ, it is necessary to specify building design directives and guidelines. The objectives of the directives and guidelines are to:

■ Create a cohesive and unifying architectural character while at the same time promoting architectural initiative that provides interest and variety and which reflects the individual identity of tenants.

■ Achieve buildings that relate positively to the common environment / pedestrian and vehicular routes, open spaces and to one another.

■ Establish a design approach that yields timeless qualities of architecture; is not fashion, theme or style specific but reflects the architectural character of the coastal area; that reflects the inherent use characteristics for which the buildings are intended; achieves buildings that have commercial value and can be re-tenanted over a long economic life span; can be adapted and modified as times and needs change.

■ Ensure that only building materials of high quality are used which will maintain their appearance over time and reduce maintenance to a minimum.

Due to the industrial activities to take place at FIS Biodiesel facility, characteristic biofuel production machinery will be used and therefore the facility will typify that of a biofuel production facility. The FIS Biodiesel facility will give the site its own characteristic appearance; while at the same time will optimize the space used so as to achieve maximum efficiency during the manufacturing process whilst trying to lessen the visual impact on the surrounding environment.

The highest quality materials will be used to reduce the frequency in which the facility need be serviced or upgraded.

The site will make use of smart and holistic landscaping and building colour schemes to allow the facility to blend into the surrounding environment as far as possible.

Building Design Directives

Without imposing any particular architectural style, the building design directives concentrate on aspects that are able to achieve the level of integrity sought. These are:

■ The adherence to directives dealing with the mass and form of buildings;

■ The relationship to existing buildings and the common environment to be carefully considered;

■ The prescription of materials of a high quality and enduring appearance;

■ The architectural treatment of specific elements of the buildings.

The building and visible facilities elements will be carefully constructed so that it has a sense of place and is as indistinguishable as it can be without imposing a misplaced architectural style. FIS Biodiesel facility will consider all the appropriate building design directives and relevant South African Building Standards during the detailed design phase of the facility.

Mass and Form of Buildings

In all respects the mass and form of the building are to respond to adjacent streets, common open spaces, existing buildings, contours and express the dignified sense of stature of an international IDZ environment.

The manner in which the building relates to the adjacent street space is critical. Buildings aligned with the streets Are encouraged in the Coega IDZ. The principles governing the setting-out of buildings on the site should achieve legibility, a sense of arrival for visitors and tenants alike, the optimisation of views and the shared relationship of buildings to one another.

The emphasis in mass and form is constantly placed on elegance, be this in the character of the building, its lightness in the topography or the dignified solidity of a strongly composed building.

Where neighbouring buildings exist, explicit reference in the design rationale of the building is to be made to the manner in which the mass and form of the

Due to the nature of FIS Biodiesel facility, the biofuels manufacturing plant will house cylindrical tank structures. No irregular or asymmetrical buildings or facilities will be built.

The office building will be a simple ground level building with walls running parallel to the adjacent streets. The design of the tank farm, office buildings and other buildings on site aims to create a sense of functionality, suppleness and elegance yet will stand apart from the neighbouring buildings owing to its own identity and character.

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subject building responds to these existing buildings.

Roofs The treatment of the roof is an essential element of the architecture.

The approach with which the roof is considered as an integral part of the buildings’ composition is vital and the architect is to demonstrate to the Committee the intentions implicit in how the building meets the sky, its relationship to the skyline and those of adjacent developments when viewed from various positions.

The roof treatments should be articulated, modulated and constructed to provide visual interest and delight to users and visitors of Coega. The expanse of roofs should be broken down and modulated in plan and section through the use of skylights, vents, angled or curved structural sections, space frames, or similar devices.

The roofs of buildings in Coega require careful consideration particularly related to the view from the N2 Freeway.

The roof of the office facility on FIS Biodiesel facility will be simple and plain and will act to blend into the landscape instead of creating an elaborate attention-drawing shape. The majority of the tanks and facilities at FIS Biodiesel facility will be flat or slightly pitched (office building).

Elevations The elevations should be contemporary reflecting a timeless quality. The exterior envelope of buildings should be treated with simplicity and order.

The mass and form intention of the architecture and the emphasis in elevational treatment is elegance with clearly articulated systems of proportioning, horizontal. Expression and vertical modulation. All apertures and fenestration should be consciously considered in a proportional system that brings all windows, doors and recesses into a relationship with the façade’s overall modulation. Whether deeply recessed or flush, vertically or horizontally accentuated, windows should be used to reflect the character of the building having an emphasis on abundant natural light.

The horizontal articulation of the building should clearly express the architect’s intentions of how the building meets the ground and those bands of the elevation that are systematic, and those that are unique. In the case of flat roofed buildings, the cornice line, whether expressed or understated, must be a consciously considered aspect of the building’s elevation.

Vertical modulation within the elevation and accentuation of entrances should reflect the proportioning system adopted for the building and be used to express Hierarchy in the elevation composition.

Buildings following design fashions that simply copy or reinterpret historical styles from by-gone eras will be discouraged.

The exterior appearance of the facilities at FIS will invoke simplicity and order as previously discussed. No elaborate or aesthetically over stimulating buildings or structures will be erected. The FIS Biodiesel facility will aim to keep the facilities and structures as discrete and simple.

The form and of the facilities will ensure that the vertical features of the facilities on site will accentuate the function thereof. The design of the facilities will therefore depend solely on functionality and purpose of the facility as a whole and therefore the design will be kept to a minimalistic and simple appearance so as to lessen the visual impact rather than serving to accentuate the features on the facilities.

The cornice line of the flat roofed buildings will be a consciously considered aspect of the buildings elevation.

Climatic Control Devices

With development aligned to the streets, it is necessary to deal with climatic control on some elevations in ways that make reliance on mechanical cooling and ventilation as minimal as possible. Priority in design is to be given to buildings that are energy efficient and favour passive approaches to climate control.

Due to simplicity of the office block at FIS Biodiesel facility, no extensive additions will be made to add to the building to act as climate control devices.

Shading structures may be erected in the parking lot, and will be constructed according to the Coega IDZ guideline as a

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Shade devices such as screens, pergolas or awnings, whether used as horizontal, vertical or angled projections from the façade line of the building should form an integral part of the building’s architecture and, as in the case of eaves projections, should become an important architectural feature.

Where sun control is achieved through deeply recessed fenestration, this should form an important aspect in the building’s elevational composition.

Where heat-retardant glass is used, and subject to materials specification set out in following paragraphs, reflective mirror glazing is discouraged.

supplementary outdoor climate control device.

No excessive artificial cooling systems or climate control devices will be installed on site unless otherwise necessary for the biofuel production process purposes.

Plant and Equipment

All plant and equipment, including antennae and satellite dishes, if not designed as an integral part of the architecture of the building, is to be hidden, suitably screened or made to appear as a designed element of the building.

Should plant and equipment be housed on the roof of the building, it must comply with the guidelines associated with roof design and be screened from the freeway and surrounding buildings.

All air-conditioning equipment, whether centralised, split or individual, must either be hidden within the architecture of the building or be expressed as a conscious intention within the building’s design.

As the design of the facility is to aim for simplicity and functionality, plant equipment will be hidden as far as possible

FIS Biodiesel facility is compliant with this requirement.

Materials Within the constraints imposed, a wide range of materials is possible.

■ In general, emphasis is to be placed on materials having a high quality and low maintenance and which accentuate the elegant, dignified quality of the architecture sought.

■ In selecting materials, clues should be considered from existing coastal buildings in Port Elizabeth.

■ All materials used and their application are to be reviewed by the Committee whose judgement will be directed by the extent to which any is integral to the achievement of a high quality of architectural design. All materials used should have an adequate record of application in the climatic conditions prevailing in Port Elizabeth. High quality materials such as suitably treated glass, coated aluminium, stainless steel, epoxy coatings and suitably treated wood are acceptable. Other high-quality products will be considered.

■ All surface coatings are to be long lasting, enduring in quality and appearance and requiring only low to moderate maintenance. Hence, where a coating is to be applied to a brick and plaster façade, the coating should be of an appropriate permanent variety.

■ Wall materials may vary from load-bearing brick or suitable stone, ceramics, granite or marble, to light-weight frames and panelled systems. The heavier-weight wall solutions should relate to their ground level support and not appear to be suspended in a light-weight frame.

■ Materials and elevations should reflect energy conservation consciousness and all materials used in screening and blinds should

The materials used for the construction will be according the quality and standards that are necessary to the type of facility being constructed at FIS Biodiesel facility.

FIS Biodiesel facility will use the most durable materials where applicable throughout the construction of the facility.

Any and all surface coatings to the facility will be long lasting and of the highest quality. The surface coatings will also aid in reducing the conspicuousness of the facility as a whole.

Local materials will be incorporated as much as possible to reduce the kilometres on transporting the constructing materials and supporting the local economy.

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comply with high-quality, well-tested specifications.

■ All roofs whether pitched or flat, particularly those viewed from the freeway, are to be dealt with as conscious elements of facade treatment. Even flat roofs, whether behind a parapet or not, are to be suitably treated with aggregate, pebble or tile.

Architectural Treatment of Elements

■ The ground floor of all buildings in Coega and their relationship to the street is critical. Where possible, activities should be located on ground floors that interact with the adjoining streets and parking forecourts. In this regard, office receptions, waiting, showrooms and sales areas, meeting and boardrooms and in certain areas of Zone 1 North; retail shop-fronts, restaurants and cafes are critical.

■ Blank or blind walls should be avoided at ground level adjoining streets and open spaces to avoid bare and uninteresting facades. Windows overlooking parking areas, streets and open spaces assist with ‘natural surveillance’ and thus lessen opportunity for crime.

■ Building entrances must be clearly visible from the street and architecturally celebrated. They must engage with the street space and relate to the building. Special canopy treatment, vertical emphasis and generous use of glass should be used to highlight the entrances. Sculpture and works of art could also relate to the building entrances.

■ External fire escapes and other elements on the outside of the building must be treated in a sculptural way and expressed as special elements on the facades.

■ Parking forecourts and pedestrian walkways on individual sites should complement the Coega IDZ urban and landscape design of the streets and open space environment.

The mentioned design elements are noted.

As discussed above, the office block on the FIS Biodiesel facility site will be integrated with the nature and orientation of the streets and will synergise with the surrounding buildings and immediate environment.

The office block facility will be the nearest structure to the main roads and access point to the facility. The design of this building will be that of simplicity and elegance and will thus avoid the facility from appearing boring or dull.

LANDSCAPING DESIGN GUIDELINES

Landscape Intentions

■ The landscaping undertaken by CDC is uncomplicated and with the emphasis on ensuring that a strong relationship is achieved between the built-form, hard surfaces, street and open space environment.

■ The CDC has developed the common street and open space environment. Buildings fronting onto these elements must relate landscape elements both hard and soft within the individual sites to be the same quality and standard.

■ Landscaping of individual sites is to complement that of adjoining street and open spaces to create a unified landscape running across boundaries rather than defining them. On certain sites parking forecourts are required to be provided. These must be designed and detailed to the same exacting standards as the remainder of the common environment.

■ The reconciliation of pedestrian movement with vehicular movement is important both in terms of arrival at the building and how one gets from parking areas to the building entrances.

Noted.

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■ All external areas related to the buildings, external devices whether attached to or removed from the buildings, exterior furniture and lighting are all essential elements in the integration of buildings both into the landscape and with adjacent developments.

Existing Landscape The existing landscape and street furniture of the Coega IDZ in terms of parks, open spaces and streets has been put in place by CDC. If any of this is affected by the construction it will have to be reinstated by the land owner at their cost. No adaptation or removal of the landscape infrastructure will be permitted.

Noted.

Stockpiling of Topsoil

Topsoil removed from site in the course of development is to be stockpiled for reinstatement. Where necessary, additional topsoil is to be imported and laid to sufficient depths to suit different planting requirements. Appropriate ground preparation techniques must be employed to ensure the establishment of vigorous, enduring growth.

Noted.

Planting The use of indigenous plants, a water-wise aesthetic and the selection of drought and disease resistant plant species inspired from the surrounding coastal environment are encouraged to minimise maintenance requirements and water use in the Coega IDZ.

Noted.

Irrigation All planted areas must include an irrigation system in order to ensure that proper maintenance can be guaranteed. All hard surfaces must be designed to accommodate appropriate storm water drainage.

An SWMP has been developed for the facility. The SWMP recommends using the stormwater from the attenuation pond for irrigation.

Lighting Well-designed lighting of the building exterior and surrounds is to be provided for security and aesthetic reasons and should complement the architecture and landscaping. The intensity of light should be carefully balanced between the need to create well-lit and safe areas and the desire to create an aesthetic evening environment marked by interplay of light and shadow.

On-site parking and service area lighting should be achieved by relatively low level, free standing and / or wall-mounted fixtures with cut-off light sources. The materials and colour of the fixtures must be compatible With the general landscaping of the Coega IDZ.

Noted.

Boundary Treatment A planting strip is necessary as a control device to ensure that the landscape treatment of individual sites meets and integrates with the common streetscape in a logical and tidy manner.

Where buildings, parking or loading docks are located adjacent to any street a landscaped planting strip adjoining the boundary at least 2.5m wide must be provided.

Noted.

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15.3.1. Conclusions

The FIS Biodiesel facility is proposed to be established in a fairly undeveloped area (i.e. Zone 7) of the IDZ and as a result will have an impact on the sense of space as the area is generally covered by vegetation. The facility will be seen from various viewpoints mostly because development in the CDC has not fully commenced. However; based on the growth of the IDZ it is anticipated that similar developments will be developed in the near future. These additional developments will add to the character of the IDZ, thereby reducing the visual impact of the FIS Biodiesel facility.

As per the Coega Development Zone Architectural Guidelines it is noted that the various operations to be established in the Core Development Area will result in tall or large structures that will have a visual impact on the area. In order to minimise negative impacts and create a positive built environment the Architectural and Landscape Design Guidelines were drawn up. These guidelines set out the design directives and guidelines within which individual sites with the IDZ are to be developed.


The following mitigation measures are recommended by the EAP:

■ Before construction all designs are to be drawn up by a registered architect according to the Coega Development Zone Architectural Guidelines and Landscaping Guidelines and approved by the Design Review Committee;

■ The Site must be kept clean and be well maintained during both construction and operation; and

■ The use of indigenous vegetation should be used wherever possible to screen buildings, structures or activities.

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16. Environmental Impact Statement This chapter evaluates the overall impact of the proposed FIS Biodiesel facility based on the findings of the Environmental Impact Assessment. The principal findings are presented in this chapter, followed by a discussion of the key factors the DEDEAT will have to consider in order to make a decision in the interests of sustainable development.

16.1. Evaluation

The evaluation is undertaken based on:

The information provided during the EIA;

The assumptions made for EIR;

The assessments provided by the specialists; and

The recommended mitigation measures which it is assumed will be effectively implemented.

A concise summary of the impacts identified during the assessment is provided in Table 59.

Table 59: Impact Rating Summary for the proposed FIS biodiesel facility

Impact No. Impact description +ve or

-ve)

without miti-gation

with mitigation

No-go

Air

Qu

alit

y

A1 Impact of vehicle emissions (-ve) Low-Medium Low N/A

A2 Impact of boiler emissions (-ve) Medium Low-Medium N/A

A3 Impact of fugitive tank emissions (-ve) Low Low N/A

A4 Impact of fuel loading emissions (-ve) Medium Low-Medium N/A

A5 Impact of biodiesel production emissions (-ve) Low-Medium Low N/A

So

lid W

aste

W1 Littering of environment by general waste (-ve) Low to Medium Low N/A

W2 Potential pollution of soil, are, water by hazardous waste (site based)

(-ve) Low to Medium Low N/A

W3 Personal exposure to hazardous waste (health and safety) (-ve) Low to Medium Low N/A

W4 Legal non-compliance / risk in respect of waste recycling prac-tices


W5 Consumption of landfill airspace (-ve) Low to Medium Low to Medium N/A

W6 Potential pollution of soil, air, water by hazardous waste (dis-posal site).


Eco

log

ical

E1 Loss of Thicket Bushclumps and Mini Bushclumps (-ve) Medium Low to Medium N/A

E2 Loss of grassland and succulent patches (-ve) Medium Low to Medium N/A

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Impact No. Impact description +ve or

-ve)

without miti-gation

with mitigation

No-go

E3 Loss of plant species of special concern (-ve) Medium to High Low to Medium N/A

E4 Loss of animal species of special concern (-ve) Low to Medium Low N/A

E5 Loss of biodiversity (-ve) Low to Medium Low N/A

E6 Fragmentation of communities and edge effects (-ve) Medium Low to Medium N/A

E7 Invasion of alien plant and animal species (-ve) Medium to High Low (+ve)

N/A

Her

it-

age

H1 Impact on heritage (-ve) Low Low-Medium

(+ve) N/A

So

cio

-

eco

no

mic

S1 Job creation and skills development during construction (+ve) Low (+ve) Low-Medium

(+ve) Low (-ve)

S2 Job creation and skills development during operation (+ve) Low (+ve) N/A Low (-ve)

No

ise N1 Potential noise impact during construction (-ve) Low to Medium Low N/A

N2 Potential noise impact during operation (-ve) Low to Medium Low N/A

16.2. Summary of Significance of Impact Assessment

Issues that have been assigned a pre-mitigation impact rating of “medium” (negative) significance or worse are summarised in the table below (refer to each technical chapter for detailed mitigation measures and to the EMPr for a comprehensive list):

Table 60: Summary for impacts assigned a pre-mitigation impact rating of medium (-ve) significance or worse.

Impact Description Pre-Mitigation Significance

Post-Mitigation Significance

Recommended Measures

Air Quality

(A2) Impact of Boiler Emissions

Releases of boiler generated pollutants may be emitted to the atmosphere, creating impacts on the ambient air quality.

Medium Low-Medium - Installation of SO2 abatement technology in the form of wet gas scrubbers or similar flue gas desulphurisation systems.

(A4) Impact of Fuel Loading Emissions

Fugitive emissions during the loading of fuel to tankers may be emitted to the atmosphere, creating impacts on the ambient air quality.

Medium Low-Medium - The installation of a suitable vapour recovery unit at the loading bays;

- The use of submerged filling technique for loading tankers;

- The use of pipeline to dispatch product to the

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harbour instead of tankers. This will limit the losses of emissions associated with the loading to tankers.

Ecological Impacts

(E1) Loss of Thicket Bushclumps and Mini Bushclumps

The construction of the pipeline and FIS facility will result in the loss of some thicket bushclumps and mini bushclumps within the project site. This vegetation type is considered to be of moderate sensitivity due to the role it plays in providing islands of refuge for small mammals, birds and reptiles as well as housing species of special concern such as Sideroxylon inerme.


- Ensure that the footprint of the pipeline and tank farm are kept to a minimum; and

- Implement a search and rescue plan;

- Insert measures to control alien vegetation and remove existing alien species.

(E2) Loss of grassland and succulent patches

The construction of the pipeline and tank farm will result in the loss of grassland and succulent patches within the project site. This vegetation type is considered to be of moderate sensitivity due to the presence of species of special concern and its vulnerable conservation status.



- Where feasible, avoid locating infrastructure (particularly within the CDC servitude) on the succulent patches associated with the exposed calcrete as this is where a large number of species of special concern are likely to be found; and


(E3) Loss of plant species of special concern


Medium-High Low-Medium - Keep removal of vegetation to a minimum within the pipeline servitude;


- Species of special concern must be marked prior to construction and a search and rescue plan must be developed in order to transplant these species. This may include seed collection and cultivation;

- Some SSC will not transplant. These individuals

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should, as far as possible, be left undisturbed; and

- Permits will be required to remove these species.

(E6) Fragmentation of communities and edge effects

Fragmentation is one of the most important impacts on vegetation, especially when this creates barriers in previously continuous vegetation or reduced habitat, causing a reduction in the gene pool and a decrease in species richness and diversity. The landscape is already relatively fragmented, but the construction of the pipeline and tank farm in the area could exacerbate this for plants and small animals since there is the possibility that viable populations may be split or cut off from one another.

Medium Low-Medium - All fences must have wide enough mesh to let small animals to pass through;

- If the pipeline is above ground then culverts must be installed at regular intervals to allow the passage of animals under the pipeline;

- Where feasible, existing roads should be utilised to prevent the further fragmentation of the site; and

- The clearing of vegetation for new roads must be kept to a minimum.

(E7) Invasion of alien plant and animal species

The removal of existing vegetation creates ‘open’ habitats that will inevitably and rapidly be colonised by pioneer plant and animal species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in the area. Once established, these species are typically very difficult to eradicate and may then pose a threat to the neighbouring ecosystem. This impact is likely to be exacerbated by careless management of the site and its facilities during construction and operation (e.g. inappropriate disposal of cleared alien vegetation that could harbour seeds) and inadequate monitoring. Many such species are however remarkably tenacious once they have become established.

Medium-High Low (positive)

- Mitigation measures to reduce the impact of the introduction of alien plant invaders, as well as mitigation against alien plant invaders that have already been recorded on the site, should be actively managed throughout both the construction and operation phases;

- Removal of existing alien species on site must be undertaken; and

- Rehabilitation of disturbed areas after construction must be undertaken as part of a Rehabilitation Plan as soon as possible after construction is completed.

16.3. Principle findings and key decision making factors

The principal findings of the EIA, assuming that the recommended mitigation measures will be effectively implemented, are as follows:

1. FIS proposes to develop a Biodiesel production facility within Zone 7 of the Coega Industrial

Development Zone (IDZ) in the Nelson Mandela Bay Municipality, Eastern Cape.

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2. The Coega IDZ was chosen by FIS as the preferred location for the development, amongst other

reasons due to the access to both harbour and major roads and specifically in Zone 7 to ensure that

the feedstock and materials required as part of the production of biodiesel can be either obtained via a

pipeline from the berth or transported via road to the site.

3. The FIS facility is to be located within Zone 7 (Chemical and Petrochemical Cluster). This Zone is

specifically earmarked for medium to heavy industry.

4. Broadly speaking, the FIS facility aligns strongly with national sustainability objectives, namely the

development of the Green Economy within South Africa

5. The biodiesel to be produced at the proposed FIS refinery will utilise feedstock sourced from organic

sources such as WVO and fats from fast food outlets or animal food processing facilities. These are

classified as waste and are unfit for human consumption. Consequently, the production of biodiesel

from waste products such as WVO, largely sidesteps any such controversy related to the “fuel versus

food” debate, and may be viewed as best environmental practice whereby waste is recycled rather than

disposed of, in accordance with the waste management hierarchy (NEMWA 2008). Furthermore this

redirects waste from landfill to an alternative use maintaining its inherent economic value. In the case of

biodiesel, such waste recycling has the additional benefit of reducing global greenhouse gas emissions

associated with fuel combustion for mobile transport.

6. The proposed development would contribute directly to economic development and employment

generation within the Nelson Mandela Bay Municipal area.

7. The development requires an Air Emission License as it falls within the description of Category 2.4

under the National Environmental Management: Air Quality Act. The potential emissions have been

modelled during the EIA and it has been identified that the emissions resulting directly from the process

are within the prescribed NEMAQA annual standards with the recommendations that best practice in

the control efficiency of the vapour recovery unit at the loading bays should be applied (should the truck

dispatch scenario be implemented onsite) and that the installation of SO2 emission abatement

technologies on the HFO boilers is implemented.

8. As with all industrial activities, waste will be generated during all phases of the proposed development.

A Waste Management Best Practicable Environmental Option Assessment was undertaken which

identified that the proposed development generates by-products as an inherent part of the production

process, and the type and volumes of wastes that would be generated can be readily accommodated

within the existing waste management industry.

9. A conceptual Storm Water Management Plan has been developed in which storm water management

infrastructure has been suitable proposed to ensure appropriate management of clean and dirty storm

water runoff.

10. Due to the small footprint of the proposed project, many of the impacts will be reduced with effective

management of the site as well as the utilisation of rehabilitation during post-construction.

11. A traffic impact study was undertaken for the site and no significant issues were identified.

12. This investigation concluded that the risks from large fires at the proposed FIS Biofuels refinery in the

Coega IDZ could not extend beyond the site’s boundaries, and this risk is acceptable. The facility is not

considered a Major Hazard Installation.

13. The development would change the existing visual character of the surrounding area, but as the Core

development area of the IDZ develops, the visual characteristics of the site will be consistent with the

surrounding land uses. The need to comply with the Coega Development Zone Architectural Guidelines

is highlighted and incorporated into the draft EMPr.

14. All impacts identified can be readily managed and measures to do so are captured within the EIR and

the EMPr.

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15. Post implementation of the proposed mitigation measures there are no residual impacts that exceed a

low to medium significance rating and as such the overall impacts emanating from the proposed FIS

Biodiesel facility are deemed acceptable

16.4. Authorisation Opinion

In terms of Section 31 (m) of NEMA the environmental practitioner is required to provide an opinion as to whether the activity should, or should not be authorised. In this section a qualified opinion is ventured and in this regard WSP believes that sufficient information is available for the DEDEAT to make a decision regarding authorisation.

With the above in mind, the EAP is of the view that the DEDEAT should authorise the development of the proposed FIS Biodiesel facility, subject to effective implementation of the mitigation measures and EMPr proposed in this EIA.

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17. The Way Forward This final Environmental Impact Report has identified and assessed potential impacts associated with the proposed FIS Biodiesel facility, and proposed measures to mitigate these impacts. The public participation process has given I&APs and stakeholders the opportunity to assist with the identification of issues and the potential impacts.


th of August 2014









WSP Environment & Energy South Africa 3rd Floor 35 Wale Street Cape Town 8001 South Africa Tel: +27 21 481 8794 Fax: +27 21 481 8799 www.wspgroup.co.za

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