localizacion e impacto

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MEGA Project: J - 262- 04 JUNE, 2006

Department of Environmental Affairs andDevelopment PlanningReference No: 16/3/1/2/F4/17/3053/12

PO Box 26870, Hout Bay, 7872, Cape Town, South AfricaSuite 1, 6 Sandpiper Place, Hout Bay, 7806, South Africa

Tel & Fax: +27 (0)21 790 5793Email: [email protected]

Web: www.megateam.co.za

Reg No. 1999/069163/23

Vat No. 412 0186921

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FOR CHLOR-ALKALI HOLDINGS (PTY) LTD

FINAL SCOPING REPORT FORTHE PROPOSED CHLORINE,

CAUSTIC SODA ANDHYDROCHLORIC ACIDFACILITY, SALDANHA
mailto:[email protected]:[email protected]:[email protected]://www.megateam.co.za/http://www.megateam.co.za/http://www.megateam.co.za/http://www.megateam.co.za/mailto:[email protected]


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CHLOR-ALKALI HOLDINGS

FINAL SCOPING REPORT

PROPOSED CHLORINE, CAUSTIC SODA ANDHYDROCHLORIC ACID FACILITY IN SALDANHA

MEGA REPORT NUMBER: J1-612-1-13February 2014




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MEGA: Siyaphambili = 'moving forward together for a sustainable environment Page 1

Report J-612-1-13 February 2014

PROPOSED CHLORINE, CAUSTIC SODA AND HYDROCHLORIC ACID FACILITY,SALDANHA

FINAL SCOPING REPORT

1 Introduction and Background

A chlorine, caustic soda and hydrochloric acid (HC) facility is proposed by Chlor- Alkali Holdings (CAH). CAH is a holding company concerned with operationsinvolved in the manufacture and supply of chemical products. There are threedivisions within CAH, namely NCP Chlorchem, Walvis Bay Salt Holdings andBotswana Ash. Walvis Bay Salt Holdings and Botswana Ash supply industrial saltto the chlor-alkali industry and household salt within Southern Africa. Botswana

Ash also produces sodium carbonate for the glass and mining industries. NCPChlorchem is based in Kempton Park in Gauteng and has been involved in themanufacture of chlorine and related downstream chemical products as well ascaustic soda lye and flakes for over 60 years. They operate a manufacturing plantout of Chloorkop in and have storage depots in Cato Ridge (Durban) as well as

Atlantis in Cape Town. The proposed facility is modelled on the existing plant atChloorkop.

The proposed facility is primarily required for the purposes of supplying HC andcaustic soda lye over the fence to the proposed Frontier Separation Pty Limited(FS) separation plant, which would undertake the refining of rare earth mineralsoriginating from the Zandkopsdrift rare earth deposit mine in the Northern Cape

Province. Currently, there is no adequate source of the required chlorine productsin the vicinity and these would otherwise have to be transported from Gauteng. While the proposed chlor-alkali facility will primarily serve the needs of the FSseparation plant, it is intended that it would also supply the current and futurerequirements of other users in the Saldanha area.

It should be noted that the rare earths separation plant proposed by FS is subjectto a separate EIA process being undertaken by AGES (Pty) Ltd. This FinalScoping Report is concerned solely with the proposed CAH chlorine, caustic sodaand hydrochloric acid ( HC ) facility. An application for environmental

authorisation in this regard was submitted to the Department of Environmental Affairs & Development Planning in July 2012.




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1.1 Why does the project require an Environmental Impact Assessment (EIA)?

In terms of the National Environmental Management Act (No. 107 of 1998) andthe 2010 EIA Regulations, listed activities have been identified which requireenvironmental authorisation from the competent authority. The proposed facilityinvolves the following listed activities:

GN R544 (Listing Notice 1)

Activity 9:The construction of facilities or infrastructure exceeding 1000 metres in length for the btransportation of water, sewage or storm water -(i) with an internal diameter of 0,36 metres or more; or(ii) with a peak throughput of 120 litres per second or more,excluding where:(a) such facilities or infrastructure are for bulk transportation of water, sewage or storm wate

storm water drainage inside a road reserve; or(b) where such construction will occur within urban areas but further than 32 metres fromwatercourse, measured from the edge of the watercourse.

Activity 22:The construction of a road, outside urban areas,(i) with a reserve wider than 13,5 meters or,(ii) where no reserve exists where the road is wider than 8 metres, or(iii) for which an environmental authorisation was obtained for the route determination in termactivity 5 in Government Notice 387 of 2006 or activity 18 in Notice 545 of 2010.

Activity 23:The transformation of undeveloped, vacant or derelict land to (i) residential, retail, commercial, recreational, industrial or institutional use, inside an urbarea, and where the total area to be transformed is 5 hectares or more, but less than 20 hectaror(ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urbarea and where the total area to be transformed is bigger than 1 hectare but less than 20 hecta-except where such transformation takes place for linear activities.


Activity 3:The construction of facilities or infrastructure for the storage, or storage and handling dangerous good, where such storage occurs in containers with a combined capacity of mor500 cubic metres.

Activity 5:The construction of facilities or infrastructure for any process or activity which requires a perlicense in terms of national or provincial legislation governing the generation or release of em

pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the

ANENVIRONMENTAL

IMPACT ASSESSMENT IS

NECESSARY


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of waste management activities published in terms of section 19 of the National Environme Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

Activity 26:Commencing of an activity, which requires an atmospheric emission licence in terms of sectof the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004),except where such commencement requires basic assessment in terms of Notice of No. R52010.


Activity 2:

The construction of reservoirs for bulk water supply with a capacity of more than 250 cmetres . In the Western Cape:(i) In an estuary;(ii) All areas outside urban areas;(iii) In urban areas:(aa) Areas zoned for use as public open space within urban areas; and(bb) Areas designated for conservation use in Spatial Development Frameworks adopted bycompetent authority, or zoned for a conservation purpose.

Activity 4:The construction of a road wider than 4 metres with a reserve less than 13,5 metres.(d) In the Western Cape:(i) In an estuary;(ii) All areas outside urban areas;(iii) In urban areas:(aa) Areas zoned for use as public open space within urban areas; and(bb) Areas designated for conservation use in Spatial Development Frameworks adopted bycompetent authority, or zoned for a conservation purpose.

Given that the project involves activities listed in GN R545, a Full Scoping andEnvironmental Impact Reporting process must be undertaken as described in theEIA Regulations (GN R543 of 18th June 2010) to obtain the necessaryenvironmental authorisation.

The classification of the brine effluent that will be produced on site falls within thedefinition of waste1 in the National Environmental Management Waste Act (Act

1 waste means any substance, whether or not that substance can be reduced,re-used, recycled and recovered (a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of;(b) which the generator has no further use of for the purposes of production;(c) that must be treated or disposed of; or(d) that is identified as a waste by the Minister by notice in the Gazette , and includes waste generated bythe mining, medical or other sector, but (i) a by-product is not considered waste; and(ii) any portion of waste, once re-used, recycled and recovered, ceases to be waste


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59 of 2008) NEMWA. Since the brine will be temporarily stored in a bulk tank,before disposal to sea outfall this constitutes a Listed Waste Activity in terms ofsection 19(1) of NEMWA (GNR 718 of 3 July 2009). With the publication of theNational Norms and Standards for the Storage of Waste, it is no longer required toobtain a waste licence in respect of the Listed Waste Activities relating to wastestorage (GNR 926 of 29 November, 2013). It will be necessary for the wastestorage facility to comply with the specifications set out in these National Normsand Standards.

1.2 What does the EIA Process entail?

An EIA is an investigation that is aimed at determining the environmentalconsequences of a proposed development. Both the natural and socialenvironment needs to be considered in the EIA. The EIA Regulations set out thesteps that must be undertaken. There are three main steps in the process (see alsoFigure. 1 overleaf):

1. Application phase : This involves completion of information in an applicationform for submission to the environmental authority, namely the provincialDepartment of Environmental Affairs and Development Planning (D:EA&DP).

2. Scoping phase : This stage involves the identification of environmental issues andconcerns that are associated with the project. These issues then need to beinvestigated in the impact assessment. Issues and concerns are identifiedthrough consultation with the authorities, interested and affected parties(I&APs) and specialists. In addition, the project team will also identify issuesbased on their experience on similar projects. The applicant or developer willalso provide input on potential issues as they operate similar facilitiesthroughout southern Africa. Scoping serves three key purposes:

To determine the scope of work for the EIA, namely the issues andalternatives that need to be investigated and assessed.

To initiate a public participation process to inform I&APs about theproject and to obtain their input on issues and concerns that they mayhave about the project.

To identify, based on existing information, whether potentialenvironmental impacts can be avoided or minimised through makingchanges to the project design.

3. Environmental Impact Assessment : This is the stage where issues and concerns areinvestigated to determine their significance. In general this involves theundertaking of a number of specialist studies a specialist study is undertakenfor each issue that needs further investigation. Both the significance ofenvironmental impacts and measures to avoid or minimise these (i.e.mitigation measures) are investigated in the EIA. There is ongoing public

participation, in order to feedback findings to I&APs.

EIA ANSWERS THEQUESTION:

WHAT ARE THEPOSSIBLE

CONSEQUENCESOF THIS

DEVELOPMENT?

SCOPING ANSWERSTHE QUESTION:

WHAT NEEDS TO BEINVESTIGATED?


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There are three other studies that will be required in terms of other legislation but which will form part of the EIA process as well. From an EIA perspective, these will serve as specialist studies. They are as follows:

Given the nature of the project, it will be necessary to undertake a riskassessment as required by the Major Hazard Installation (MHI) Regulations,promulgated under the Occupational Health & Safety Act (Act 85 of 1993).

The proposed facility operations (i.e. primary production of chlorine andhydrochloric acid) require an Atmospheric Emissions Licence (AEL) in termsof the National Environmental Management: Air Quality Act (Act 39 of 2004).

An AEL application must be submitted to the District Municipality along withan Air Quality Impact Assessment.

The size of the property is such that it is necessary to determine whether aHeritage Impact Assessment is required. A Notification of the Intention toDevelop is required for any site that is 0.5ha or more in size in terms of theNational Heritage Resources Act (Act 25 of 1999). This information would bereviewed by the heritage authority to determine whether an additionalinvestigation is required.

The National Environmental Management Biodiversity Act (Act 10 of 2004), theNational Water Act (Act 36 of 1998) and the Noise Control Regulations publishedunder the Environmental Conservation Act (Act No. 73 of 1989) are alsoconsidered relevant to the application. While authorisations are not required interms of these statutes, they need to be considered in the context of the projectsimpacts on biodiversity, water resources and noise respectively.


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FLOW DIAGRAM OF THE EIA AND MHI RISK ASSESSMENT PROCESS

SCOPING PH

ASE

EIAPHASE

Submit to the

authorities

Risk issues identification

MHI Risk Assessment Establish risk scenarios Undertake

consequence analysis Assess risks Propose mitigation

measures

APPLICATION

Complete application formFeedback from DEA&DP isprovided

Submit final Scoping Report and anycomments received

Advertisement Consult authorities Review environmental information Identify issues Public participation Identify alternatives

DECISIONProject approved

or refused

M H I R I S K A S S E S S M E N T P R O C E S S

MHI Risk Assessment Submit notification

Comment period

Draft Scoping Report

Revise Scoping

DEA&DP reject ScopingReport

DEA&DP accept ScopingReport

Specialist studies Assess impacts Evaluate alternatives Determine mitigation measures Assess significance of impacts for each issue Assess impacts between issues (links) Public participation Authority consultation Provide overall impact significance

explanation for project

Submit final EIA Report and anycomments received

Comment period

Draft EIA Report

Revise EIA Report


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1.3 What did scoping entail?

The scoping activities are shown in the table below.

ITEM ACTIVITIES TIMING

Identification of

interested andaffected parties

This was done through:

Placing an advertisement in the Weslander (the local newspaper in the area) andthe Cape Argus. The advertisement described the project proposal and invitedthe public to register as Interested & Affected Parties (I&APs) and to provideinitial comment.

Development of a database of organisations based on knowledge of project teammembers and past projects in the area.

9 th August 2012

Identification ofenvironmentalissues

Issues were identified through: Review of initial project design information and of case studies from similar

installations in South Africa and overseas. Input from the public participation process. Knowledge of project team members as well as the applicant, CAH

Holdings.

Throughout process

Identification of

alternatives

Alternatives have been identified through:

Input from the public participation process. Knowledge of project team members as well as the applicant, CAH.

Throughout process

Initiation of baselinestudies

Gathering of relevant baseline information Botanical scan of the study area by specialist, Nick Helme

Throughout processOctober 2012

Public participation The following was undertaken: Posting and emailing a notification letter to all identified potential I&APs; the

letter described the project proposal and invited registration on the I&APdatabase

Placement of a signboard on the proposed site Preparation of a Background Information Document (BID), which was forwarded

to all those who registered on the database Presentation to the Saldanha Bay Water Quality Forum

Meetings with DWA and DEA: Oceans & Coasts Making the draft scoping report available to I&APs for comment for a period of 40

days Conducting of an Open House on the draft scoping report

Still to be undertaken in the Scoping Phase is: Circulating the final scoping report for a 21 day public review period

9th August 2012

9 th August 2012

August 2012

November 2012

July 20134 October 15 November20139 October 2013

February 2014

Scoping report Completion of draft scoping report Revision the draft scoping report, based on feedback received during 40 day

public review Submission of final scoping report to DEA&DP

September 2013November December2013End Feb/beginning March2014

1.4 What is the purpose of the scoping report?

The purpose of the scoping report is to:

1. Describe a proposed new development, involving a chlorine, caustic soda andhydrochloric acid production facility in the Greater Saldanha area.

2. Identify feasible alternatives for the project in terms of factors such as designand layout and technology used.

3. Explain the environmental issues that would be expected to be relevant to aproject of this nature.


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4. Establish whether there are any sensitive environmental features (natural andsocial) in the area where it is proposed to locate the project.

5. Describe the issues raised by interested and affected parties in relation to theproposed project.

6. Determine which of the environmental issues that have been identified requirefurther investigation.

7. Set out the Terms of Reference for the EIA, referred to as the Plan of Studyfor EIA.


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2 Description of the project

2.1 Where will the project be located?

It is proposed to locate the project within an area earmarked for future industrialuse, in the conceptual development corridor between Vredenburg and the Port ofSaldanha as set out in the Saldanha Bay Spatial Development Framework (SDF).(Refer to the map below). The site, located on Portion 6 of Farm 188 Langeberg,consists of previously and currently cultivated land. It is intended that theproposed facility will share the site with the FS separation plant.

FIGURE 1: Locality Map (Source: AGES Scoping Report for FS Plant..

2.2 What is the purpose of the project?

The project was initiated based on the signing of a memorandum of understandingbetween the applicant and FS for the supply of HC and caustic soda lye. FSrequires a supply of HC and caustic soda lye for their proposed separation plantin Saldanha Bay which will be concerned with rare earth concentrates transported

from the Zandkopsdrift mine in the Northern Cape. As such, the proposeddevelopment would be located adjacent to the separation plant such that HC would be produced and supplied over the fence to this facility.

MAIN PURPOSE ISTO SUPPLY

CHLORINE ANDRELATED

PRODUCTS TO THE

FS SEPARATIONPLANT AND OTHERUSERS IN THE AREA


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In addition to supplying the needs of FS, it is envisioned that the facility could alsosupply product, namely caustic soda, chlorine and HC to existing users in the

Western Cape. The facility would effectively form a chlorine-based chemical hubfor the region. Currently, chlorine is transported from Gauteng by road trucks toone of the companys regional storage facilities in major centres. The chlorinerequirements of the Western Cape, used primarily in bulk water treatment and to alesser extent in sewerage treatment, are currently supplied solely by the NCPChlorchem facility in Kempton Park, via their storage depot in Atlantis. It isfurther intended that the NCP Chlorchem storage depot in Atlantis would besupplied from the Saldanha facility once operational.

2.3 What are chlorine, caustic soda and hydrochloric acid?

Chlorine is produced from salt (NaC ). At normal temperature and pressurechlorine is a gas, which is green-yellow in colour. It is heavier than air, so ifreleased, chlorine gas tends to sink and spread along the ground.

Caustic soda lye (NaOH) is an almost colourless liquid produced as a co-productduring the chlorine production process. It is a strong alkali, highly corrosive and issoluble in water.

Hydrochloric acid (HC ) is a corrosive chemical and has a colourless to slightlyyellow hue. It exists as both a gas and as an aqueous solution and has a pungentodour.

2.4

What are the main uses of chlorine, caustic soda and hydrochloric acid?Chlorine is used in the treatment of water to make it safe for domestic use and asdrinking water. It has been used for the purpose of disinfecting water for well overa century. Chlorine kills bacteria that cause water borne diseases such as choleraand typhoid. Another important use is in treatment of sewage effluent at

wastewater treatment facilities. The purpose of using chlorine is to improve thequality of the effluent, especially in terms of bacterial content, to an acceptablestandard. Chlorine is also used to maintain the cleanliness and water quality oflarge public swimming pools (e.g. municipal swimming pools). Finally, it serves asa chemical for a range of industries including the bleaching of paper, fabrics andfor the production of other types of chemicals (e.g. PVC, hydrochloric acid, causticsoda, sodium hypochlorite). In South Africa, municipalities are the main users ofchlorine, since they are responsible for treating the public drinking water supply,the management of municipal swimming pools and for treating sewage at their

wastewater treatment plants.

Caustic soda is widely used in a variety of sectors. It serves as a reactant in theproduction of organic chemicals and is also used in the making of paints, glass,ceramics and fuel cell production. Caustic soda has historically been used in themanufacture of soaps and detergents and is prevalent in the pulp and paperindustry for the purpose of separating cellulose fibres from lignin that originate inplant material. As a strong base it is also frequently used in the neutralisation ofacids or simply to increase the alkalinity of a mixture. Other uses include the

CHLORINE ISMAINLY USED TOTREAT DRINKING

WATER


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production of mineral oils (e.g. greases), bleaching in the textiles sector andcreation of pharmaceutical compounds and in the mining industry for metallurgicalextraction processes.

HC similarly functions as a neutralizing agent although for basic systems.Fertilizers and dyes require HC for their manufacture and it is used in thepreparation of food products for the purpose of breaking down starch andproteins. Further to this it is used in leather processing, synthetic rubberproduction, pickling of metals and metallurgical extraction processing. It is oftenused in the manufacture of other chemicals and of pharmaceuticals. The removalof scale from boilers is undertaken with this chemical.

2.5 Why are these chemicals considered dangerous?

There are various definitions for hazardous substances and Dangerous Goods.For example, the Environment Protection Agency in the United States of Americauses the following definition: Any substance which poses a threat to humanhealth and/or the environment. Generally hazardous substances are consideredto be materials that have properties such as being explosive, flammable, chemicallyreactive, corrosive, or toxic.

A number of classification systems for hazardous substances have been developed.In terms of the United Nations Classification System on Dangerous Goodschlorine is Class 2.3 (toxic gas) as a primary risk and Class 8 (corrosive) as asecondary risk. Chlorine is a respiratory irritant and it is a reactive chemical.Exposure to chlorine at levels of around 15 ppm (ppm=parts per million) over aperiod of time leads to irritation of the mucous membranes of the eyes and nose,and especially of the throat and lungs. This means that strict internationalexposure limits have been established for chlorine. These will be applied in theMajor Hazard Installation risk assessment (Section 1.2) ort. Accordingly, this study

will report on the risks on the basis of internationally accepted standards.

Hydrochloric acid and caustic soda are both classed as corrosive (Class 8). TheMHI risk assessment will consider the site as a whole, thereby taking account of allchemicals that will be produced, handled and stored.

2.6 What will the chlorine production facility involve?

Operations at the CAH facility will comprise a number of sections, namely:

Salt offloading and storage Brine Production and Purification Section; Electrolysis Section; De-chlorination Section; C2 Liquifaction and Storage Section; HC Production Section ; Caustic Concentration and Drying Section; Chlorine Gas Absorption Section; Sodium Sulphate Removal Section

CHLORINE ISCATEGORISED AS A

TOXIC GAS ANDCORROSIVESUBSTANCE

INTERNATIONALGUIDELINES &

STANDARDS ARE INPLACE


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Chlorine Packing Section; and Utility Section

A typical process description is contained in Appendix A and is summarisedbelow. The equipment, process and standards currently used by NCP Chlorchemat the Chloorkop plant in Kempton Park, Gauteng formed the basis of the designfor this facility.

Salt will be supplied in crystalline form by Walvis Bay Salt Holdings. About230 000 tons/annum will be transported by ship and offloaded directly into trucksin the harbour from where it will be transported to the facility via the existinggravel haul road and stored. Raw salt is dissolved in depleted brine returned fromthe Electrolysis Section to form a saturated salt brine solution. Chemicals such assodium carbonate and caustic soda are then added to the brine solution in order toprecipitate and remove impurities originating from the raw salt.

A second round of purification by means of a brine filter and an ion exchange unitis then undertaken in order to obtain the level of purity required for the brine.From this point the purified brine is passed through an electrolysis unit to producechlorine and hydrogen gas. 32% caustic soda lye in solution is also generatedduring this process. Once this stage is complete, depleted brine from theelectrolysers is de-chlorinated and recycled back into the brine production andpurification process; while the chlorine and hydrogen gases are washed and cooledand sent on to the HC Production Section. The chlorine and hydrogen gasesreact exothermically in an HC burner to form HC gas which is then absorbed in

water to produce 31% hydrochloric acid. Most of the HC product will be used bythe FS plant through an over the fence supply system. Provision will be made forstorage of HC with a total capacity of 7 days worth of production.

Chlorine gas which is not used in the HC production process will be liquefied. Itis intended that some of the liquefied chlorine will be stored on site (up to 2 000tons) and the remainder will be packaged and distributed by road in bulkcontainers, drums or cylinders to where it is needed. The maximum volume thatmay be stored on site needs to take account of the annual shutdowns when plantmaintenance and statutory inspections are undertaken (e.g. pressure vesselinspections). This means that sufficient product needs to be stored to ensure thatan uninterrupted supply to municipalities is maintained. As previously noted, thechlorine is required for water purification as well as sewerage effluent treatment.

In a separate process, the 32% caustic soda solution generated in the electrolysissection is concentrated to a 50% solution with the use of an evaporation system.Caustic soda that is not used by the FS separation plant will be transported by roadto Cape Town for distribution. Heat (generated by LPG) may also be applied to50% caustic soda lye solution to produce caustic soda pellets or flakes (i.e. in solidform) which would be packed into 25kg bags for onward distribution. The designincorporates storage for 7 days worth of production of caustic soda lye.

An overview of the process is provided in the flow diagram overleaf.


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2.8 What safety systems will be put in place for the site as a whole?

The entire facility will be designed to meet all international standards (e.g. TheChlorine Institute Guidelines.). Typical safety measures that would beimplemented include:

Automatic shutdown of the plant in the case of an emergency A planned maintenance programme to ensure regular inspection of all

equipment. This programme includes the scheduling of regular testing andmaintenance of all critical instrumentation.

EH&S (Environment, Health and Safety) Management systems that are in line with international best practice. This will assist the management ofenvironmental impacts and health and safety risks.

A comprehensive emergency plan will be compiled which will cover on-siteand off-site requirements.

Chlorine detection sensors will be installed that will be set to sound an alarm atconcentrations well below the limit from a safety point of view.

The MHI risk assessment will serve to review all proposed safety measures. Additional measures, if required, will be implemented on the basis ofrecommendations from the MHI risk assessment. A HAZOP (hazard andoperability study) will be undertaken prior to the commencement of construction.

This involves a detailed analysis of all production processes and safety systems.

MHI RISK ASSESSMENT WILL

REVIEWPROPOSED SAFETY

MEASURES


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ISSUE RESPONSE

2. Issues related to risks for the community

What emergency procedures will be in place in theevent of a disaster?

What are the risks of pollution to people downwind ofthe facility?

Will there be any chlorine monitoring both down anduphill of the facility or only at the facility itself?The direction of the wind cant always be guaranteedto be only downhill.

Exposure to HC poses a risk to the public. How is thepublic protected in case of emergency?

A comprehensive emergency plan will be compiled.What about the surrounding area?

The use of international design standards mustconsider the local context.

All risks will be identified and evaluated in the MHI risk assessment withproposed mitigation measures. International standards relating to publicrisk levels will be applied in the MHI risk assessment.

The design of the facility will be in accordance with international standards. The design will include automatic shutdown of the plant in case of an

emergency The need for off-site monitoring will be determined from the air quality and

the MHI Risk Assessment studies. Recommendations to minimise risks to the public will be identified through

the MHI Risk Assessment. Monitoring is normally done on the perimeter of the site. This practice is

followed at NCP Chlorchem;s facility at Chloorkop, Cato Ridge and Atlantis. It is a legal obligation for a facility that is classed as a Major Hazard

Installation to compile and regularly test an emergency plan. Theemergency plan would make provision for on-site and off-site requirementsas well. In other words the plan must be co-ordinated with that of the localDisaster Management (municipality) emergency plans thereby addressingon-site and off-site procedures.

International safety standards are the minimum applied by CAH and localconditions (through the MHI Risk Assessment) serve to inform the need foradditional measures. The adequacy of these international design standardsin the local context is therefore evaluated via the MHI Risk Assessment.

3. Issues related to air pollution

What is the potential for air pollution?

It is understood that these types of facilities emit someor all of the following: chlorine, hydrogen chloride,sodium chloride, nitrogen oxides, VOCs, particulatematter and sulphur dioxide.

What about emissions of chlorine gas?

Emissions from the production process are made up primarily of carbondioxide generated from coal fired boilers and the LPG burner of the causticsoda drying plant.

Off gas would be treated with scrubbers before being released into theatmosphere in order to comply with the relevant standards

The potential for and types of air emissions will be addressed in the AirQuality study and mitigation measures will be recommended accordingly.

There are no chlorine gas emissions associated with normal / routine

operations. The facility will be designed to minimise the potential foremission of chlorine into the environment in the event of an incident /accident involving chlorine. On-site monitoring serves as an early warningsystem of any releases so that emergency shutdown systems can beactivated to prevent the release of chlorine.

The MHI Risk Assessment will take account of prevailing wind directionsand thus all wind direction scenarios and their frequency are considered.

4. Issues related to biodiversity

Both site alternatives were historically covered withSaldanha Flats Strandveld which is an endangeredvegetation type. Although Saldanha Flats Strandveld islisted as Vulnerable, it meets the criteria for

Endangered status. Farm Langeberg 188/6 has been previouslytransformed by agricultural activities. Part of FarmUyekraal 189/0 is designated a Critical Biodiversity

Area (CBA).

A botanical scan has been undertaken on both sites by specialist NickHelme.

Uyekraal 189/0 was found to have areas of low, medium and high botanicalsensitivity.

Langeberg 188/6 was found to have low botanical sensitivity and is the site

option being taken forward into the assessment. The Scoping Report was updated to include the fact that this vegetationtype meets the criteria for an Endangered listing. This is the alternativesite that was under consideration in the initial stages of the project.

5. Issues related to roads and access

Trunk Road 77/1, Trunk Road 85/1 and Minor Road7644 could be affected by the development. Buildingrestriction lines apply to these roads and must betaken into consideration.New access points and/or changes to existing accesspoints off these roads must be approved by themunicipality and the Department of Transport andPublic Works.

Details of the anticipated trip generation and load sizeswill be required to determine whether a traffic study isnecessary.Transportation of hazardous substances on the roadnetwork must comply with the relevant standards

These restrictions will be considered in the project layout design Any approval required for access onto existing roads will need to be

addressed in the land use application (rezoning) which is being undertakenby the landowner (Trans African Murals). CAH will provide any relevantinformation that may be required for this application (e.g. trip generationdata). Information on trip generation will be determined and provided tothe authorities so as to determine whether a traffic study is needed.

A Transport Risk Assessment has been planned for the EIA Phase.


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ISSUE RESPONSE

6. Issues related to water demand

Does the facility require a large amount of water tofunction?

Water demand is concerning given that the Saldanha isa water scarce area. Has the municipality confirmedwater supply capacity?

A water demand / availability study has been identified for the EIA Phasewith a view to determining the cumulative impact of the facility on watersupply.

Confirmation of water supply will be required for the purposes of the finalEIA submission to the authorities and this will be sought during the EIAPhase.

7. Issues related to waste water

Where will the waste brines and sludge be disposed?

What will the nature and quantities of heavy metalimpurities be in the effluent which might be dischargedinto Danger Bay?

A number of alternatives for effluent disposal are being considered.Effluent treatment and disposal will be undertaken in conjunction with theproposed FS and Frontier Saldanha Utilities projects and which are thesubjects of separate EIA processes.

Where possible, effluent streams will be recycled back into the productionprocess.

The quality of the effluent is expected to be the same as that produced bythe chlorine facility in Chloorkop, since the Saldanha project will be basedon the same technology. The effluent is saline in character.

8. Issues related to cultural resources

Any excavation works may impact on fossil materialand will require careful mitigation processes

The proposed sites proximity to the West Coast FossilPark, a Provincial Heritage Site, tourism and educationfacility is a concern

This will be addressed in the Heritage NID submission and/or any furtherheritage processes should these be requested by Heritage Western Cape.

9. Issues related to the marine environment

While it is noted that the impact of the sea outfall onthe marine environment is the subject of a separateEIA process, the cumulative impact contributed by thisfacility should be addressed as part of this application.

What will the cumulative impact be on shipping trafficas a result of the delivery of salt from Walvis Bay.

The cumulative impacts of effluent discharge will be assessed within thecontext of the EIA being undertaken for the sea outfall project. Thecumulative impact will be assessed by virtue of the fact that the sea outfallEIA will consider the effects of the effluent discharged from both the FSand CAH facilities and also WCDM (West Coast District Municipality). Theeffluent from the CAH facility will be combined with that from the FS plantand WCDM and this combined effluent will then be discharged via theproposed sea outfall.

Salt for the operation will be transported by ship from Walvis Bay. Theaverage ship load is 30 000 tons and a total of 240 000 tons will berequired per year. This equates 6 ships per year. Ships will be required tofollow any HSE (Health, Safety and Environment) protocols / standards thatare applicable at Saldanha Bay harbour. .

10. Other issues

The impacts of the facility in question, the adjacentseparation plant and the marine outfall pipeline shouldbe assessed jointly given their inter-connectivity.

The teams for each of these projects are liaising with each other andsharing relevant information. Information from the EIA processes for theFS plant and for the sea outfall will be drawn into the CAH project EIA, asappropriate.

The studies have to be conducted separately because each project has a

unique applicant. In accordance with the applicable legislation, eachproject requires environmental authorisation in its own right. As there are3 different Applicants, environmental authorisation needs to be issued toeach Applicant for the project that is being undertaken by that Applicant.


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4 Description of the location of the project

Given the nature of the project as described in Section 2, there are specificenvironmental characteristics that would clearly be of interest. The purpose of this

section is to provide a brief introduction in this regard, with the focus on thoseelements of the environment which are of particular relevance in the context of theproposed project. Specialist studies that are to be conducted during the EIA Phase

will serve to examine these issues in more detail so as to enable the potentialenvironmental impacts of the project to be adequately assessed.

4.1 What is the land use in the area of the proposed project?

The site is currently zoned for Agricultural Use; an application for rezoning of theproperty is being undertaken by the current landowner. The proposed location of

the project is in an area that is predominantly vacant at the current time, although asignificant level of industrial development is expected in the short to medium term,in line with the local municipality Spatial Development Framework (SDF), and theproposed Saldanha Bay Industrial Development Zone (IDZ):

Saldanha Bay SDF: According to Plan 45 of the SDF, the site lies within theproposed conceptual development corridor between the Port of Saldanha and

Vredenburg, which is earmarked for possible future industrial use. The Port ofSaldanha and the Back of Port area have been identified as the economicengine room of the municipal area and as zones of major economic growth

for the Western Cape Province. Saldanha Bay IDZ: The IDZ feasibility study identified several clusters that

have development potential in the area designated as the industrial corridor. These are a Renewable Energy Production and Manufacturing cluster, an Oiland Gas Servicing and Maritime Ship Building and Repair cluster and a Steeland Minerals Production and Manufacturing cluster. As such, industriesassociated with these clusters can be expected to establish in the surroundingarea in the future.

In terms of the existing development which surrounds the site, activities are largelyindustrial such as the ArcelorMittal Steel Works (4km to the south west),Namakwa Sands smelter (1km to the west), the iron ore conveyor and railwayline (5km to the west) and the Transnet multi-purpose terminal at the Port ofSaldanha (8km to the south west).

4.2 What environmental characteristics are of particular relevance?

The following environmental characteristics will be considered:

1.

Climatic conditions, specifically wind conditions, will be considered in theMHI risk assessment. It is necessary to consider the prevailing wind directionsand speeds in determining the effects of an accident, since this is the keyinfluence in the movement and dispersion of any emergency incident involving


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a gaseous release. Data will be obtained from local weather station(s) in thisregard. The same weather data as that applied in the air quality study will beused.

2. Water is an important resource in the Saldanha region, given that it is a waterscarce area. Accordingly, surface and groundwater conditions will beinvestigated with a view to identifying measures to ensure that these resourcesare not polluted by any activities on the site and to understand the impact ofthe facility on water supply, particularly in the context of cumulative impacts.

3. Economic growth and the improvement of social conditions are importantpriorities in the Saldanha area. It is therefore necessary to understand thesocial environment to enable the opportunities to utilize local business servicesand labour to be identified.

4. Surrounding land uses, both current and future need to be investigated for thepurposes of the MHI risk assessment and Air Quality Impact assessment. Inparticular, the location of residential areas and community facilities is animportant consideration. The site is about 5 kilometres away from the nearestresidential area.

4.3 Are there any known sensitive natural features or resources?

4.3.1 Biodiversity

The West Coast region has a relatively dry climate, with an average rainfall ofapproximately 300mm per year (Draft EMF, 2013). It is a winter rainfall area andexperiences a relatively small variation in temperature given the coastal influence.

The region is considered water scarce and there are no significant surface waterfeatures in the study area; the closest major river is the Berg River (16km northeast) and the Bok River is situated on the far side of the multi-purpose terminal,approximately 9km west of the site. Groundwater systems are important formaintaining surface water ecosystems in this low rainfall area. According to theDraft EMF for the Greater Saldanha area, the preferred site is located within thegroundwater discharge zone on Map 23 (Zone 2 Be careful).

In terms of regional botanical characteristics, the study area lies within the Fynbosbiome and the Cape Floristic Region, which is designated a global biodiversityhotspot. A significant percentage (67%) (Helme, 2012) of the threatened plantspecies in South Africa occur only in the Fynbos biome and it is thus aconservation priority, however many of the lowland habitats of this region areunder threat from agriculture, urbanisation and alien species invasion.

The preferred site (Farm Langeberg 188/6) would have originally comprisedSaldanha Flats Strandveld (classified as Vulnerable2) but during a site visitundertaken by a botanist in August 2012, it was found that the site has been

2 Although classified as Vulnerable in the National List of Threatened Ecosystems, this vegetation type nowmeets the criteria for Endangered given its remaini ng extent (CapeNature, Oct 2013)


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previously (and recently) cultivated in its entirety and that a low diversity ofindigenous plant species is supported. No plant Species of Conservation Concern

were identified. Although woody alien invasive species are not present given therecent cultivation activities, several alien invasive herbs and grasses were identified.

The preferred site is considered to have low botanical sensitivity and does not fall within a Critical Biodiversity Area (CBA), Critical Ecological Support Area orOther Ecological Support Area.

The alternative site (Farm Uyekraal 189/0) was found by the botanist to have areasof high and medium botanical sensitivity as well as areas of low sensitivity that

would be suitable for development. A portion of the alternative site also falls within a designated CBA. The alternative site is no longer under considerationgiven the potentially high botanical impacts associated with this location. Refer to

Appendix C for the botanical screening study.

The Draft EMF suggests that the study area is situated in the Indicative BirdCorridor between the Berg River Estuary and the West Coast National Park (referto Map 10 of the Draft EMF). Birds found in the Greater Saldanha area include arange of seabirds as well as several endemic species. Other faunal species likely tooccur in the greater study area range from mammal species such as Van ZylsGolden Mole ( Cryptochloris zyli ), Cape Dune Molerat ( Batyergus suillus ), Cape Gerbil( Tatera afra ), Grants Golden Mole ( Eremitalpa granti ), the Honey Badger ( Mellivoracapensis ), the Cape Horseshoe Bat ( Rhinolophus capensis ) and the White-tailed Mouse( Mystromys albicaudatus) to a number of endemic lizard and tortoise species.

According to the Draft EMF, preliminary studies indicate that the level of diversityand endemism in insect species is likely to be comparable to that of botanicalspecies in the region.

The study area and surrounds fall within the Cape West Coast Biosphere Reserve which stretches from the Diep River in Cape Town to the Berg River. There are anumber of formally protected areas in the region of which the closest to the studysite is the West Coast National Park (which includes the Langebaan LagoonRamsar site) approximately 10km from the property.

4.3.2 Water resources

The Saldanha Bay area is recognized as being water- stressed. The West CoastDistrict Municipality (WCDM) provides bulk potable water to the Saldanha BayMunicipality through the Bergrivier Saldanha Water Supply Scheme. It is notedin the municipalitys Local Economic Development (LED) strategy that theSaldanha Bay Municipal area has an extensive water shortage.3 Water from theLangebaan Road Aquifer (LRA) is used together with surface water in the bulk

water supply system in the Saldanha area.

Based on the 2010 WCDM Draft Water Master Plan (WCDM, 2010) 4, demand isexpected to exceed supply (authorised allocations) in 2012. The WCDM has a

3 Saldanha Bay Municipality Local Economic Development Strategy (LED, 2005), Urban Econ: Development Economists(October 2005)

4 Cited in the BKS Status Quo Report Water Supply (Section 3).


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total authorised allocation of 23 140 000 m 3/annum (63 397 m 3/day) from theDepartment of Water Affairs. A 30 year planning horizon (up to 2040) has beenapplied in the aforementioned Master Plan. It does not take account of theproposed industrial development in the area, such as the Saldanha Bay IDZ.

There are no significant surface water features on the site. Groundwater is,however, an important water resource. There are two regional aquifers whichoccur in the area, namely the Langebaan Road Aquifer System (LRAS) and theElandsfontein Aquifer System. The LRAS is regarded as a strategic water resource.

4.4 Are there any known important cultural features or areas?

The geology of the area comprises bedrock of Malmesbury Group shales intrudedby Cape Granites. This bedrock is overlain by several formations which make upthe Sandveld Group of coastal deposits namely, the Elandsfontyn Formation, the

Varswater Formation, the Prospect Hill Formation, the Langebaan Formation, the Velddrif Formation, the Springfontyn Formation and the Witzand Formation.(Pether, 2012). Palaeontology resources may be uncovered in the fossilferousSandveld Group during the course of bulk earthworks. While discoveries in the

Witzand Formation are usually archaeological in nature, fossil bones of highsignificance have been known to occur in the Springfontyn Formation, VelddrifFormation and Prospect Hill Formation albeit very sparsely. Fossil bones aremore commonly found in the calcareous aeolianites of the Langebaan Formation

while shell fossils of local significance have been uncovered in the VelddrifFormation. Deeper excavations may encounter local exposures of the VarswaterFormation and the Uyekraal Formation (a sub-category of the aforementioned, notformally adopted). The West Coast Fossil Park is located 3km from the site.

From an archaeological perspective, evidence of human occupation of the greaterSaldanha area in the Early Stone Age (between 2 million and about 200 000 yearsago) has been found at Elandsfontein and Anyskop. The Saldanha skull ofElandsfontein is the oldest known evidence of humans in the Cape dated from700000 400000 years ago. Middle Stone Age (MSA) and Late Stone Age (LSA)tools and pottery have previously been found at the site of the ArcelorMittal Steel

Works and there are records of flakes from the same periods uncovered at theDuferco Steel Mill site, south west of the ArcelorMittal Works. Further afield,evidence of early human exploitation of coastal resources has been found along thecoast. However, this will be dealt with further by the heritage specialist during theNID process.

4.5 What are the social characteristics of the study area?

The Saldanha area falls within the West Coast District Municipality which is thefastest growing District in the Western Cape Province. The population of theSaldanha Bay Municipality increased 41% between 2001 and 2011 and totalled99193 in the 2011 Census. This high level of growth is likely due to theestablishment of an increasing number of large industries in the area as well as ageneral trend in relocation to coastal areas. Most of the municipal population


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resides within urban areas, however approximately 9% of people in themunicipality live in informal housing.

The Saldanha Bay Municipality has the highest unemployment rate in the District. According to the 2011 Census, of those who are economically active 23.4% areunemployed. Nevertheless, a comparison of household income as recorded in the2001 Census and the 2007 Community Survey suggests that household income isimproving; there has been a decrease in the number of households with no incomeand the proportion of households with an annual income of less than R38000 hasdropped from 59.22% to 34% (Draft EMF, 2013)

Education levels have improved in the municipality over the past ten years. 2.4%of the population has no schooling on contrast to 5.1% at the time of the 2001Census. The proportion of the population with Matric (28.5%) and HigherEducation (9.3%) has similarly increased from 22.2% and 7.7% respectively in2001.

The Saldanha Bay municipality contributes the greatest amount to the DistrictGDP. The most dominant sectors are manufacturing, transport and services whichcontribute 30%, 16% and 15% respectively. There has however been a steadyincrease in employment in the mining, transport, finance and service sectorsaccording to the Saldanha IDP (2012-2017).

4.6 Is the timing of the proposed development appropriate?

Currently, industries that require chlorine and related products in theirmanufacturing process are being proposed in the Saldanha area. This is within thecontext of promoting industrial growth, which includes a proposed IndustrialDevelopment Zone (IDZ). It is considered to be in line with the relevant strategicobjective of the Saldanha Bay municipality IDP concerned with industrialisation asa means to diversify the economic base and the departmental objective specifiedthereunder which requires the creation of an enabling environment for increasedindustrial potential and job creation.

The local availability of chemicals such as chlorine, caustic soda and hydrochloricacid means that these substances would not have to be transported from afar.Further the development is consistent with the priority to establish the SaldanhaIndustrial Development Zone.

Furthermore, it is anticipated that up to 130 persons will be required to operate thefacility. Dependent on availability it is expected that most of this labour will besourced locally and trained although highly skilled positions may be filled fromelsewhere. As such, the proposed development would make a contribution toemployment creation in the area.

Water supply is noted as a significant concern in the municipality and has been thesubject of various studies, including a Water Demand Study by the West CoastDistrict Municipality. While the IDP does identify projects aimed at addressing

water supply demands such as increasing the capacity of several water reservoirs in

THIS HELPS US TOUNDERSTAND THE

NEED FOR THEPROJECT


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the area, the anticipated increase in industrial development is likely to have anassociated significant increase in water demand. In addition, a desalination plant isbeing established to augment existing water supplies.

4.7 Is the proposed location suitable?

According to Plan 45 of the Saldanha Bay SDF, the site lies within the proposedconceptual development corridor between the Port of Saldanha and Vredenburg,

which is earmarked for possible future industrial use. The Port of Saldanha andthe Back of Port area have been identified as the economic engine room ofthe municipal area and as zones of major economic growth for the Western CapeProvince. In addition to its conformance with the SDF, the proposed site is not inproximity of residential nodes. Given the nature of the activity it is desirable tosituate the development at a distance from urban areas to avoid potential impactsthat can be expected to be associated with the operation such as health, safety,nuisance from odours etc. Further to this, the facilitys initial purpose (i.e. over thefence transfer of hydrochloric acid and caustic soda to the FS separation plant)dictates its placement alongside the aforementioned establishment which isproposed on this site.

As described above, Map 23 (Be careful zone 2) of the Draft EnvironmentalManagement Framework for the Greater Saldanha area indicates that the site islocated within both an important bird corridor and a groundwater discharge zone.It avoids the sensitive environments identified for Zone 1 Keep Assets Intact.

The site also falls within the IDZ Maximum Extent of Highest Daily PM10Concentrations on Map 25. The necessary specialist input will be sought toinvestigate the potential impacts on these attributes and to ensure that theirassociated management objectives would not be compromised by the CAH facility.

CONSIDERING THEPLACEMENT OFTHE ACTIVITY

ENABLES US TODETERMINE THE

PROJECTS

DESIRABILITY


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5 Plan of Study for EIA

The scoping process has served as the first stage of the EIA process to:

Identify the environmental issues that need to be investigated and assessed.

Identify feasible alternatives that need to be evaluated in terms of their relativemerits or otherwise from an environmental perspective.

The purpose of this section of the Scoping Report is to describe the environmentalissues that are of relevance to the project and to determine which of these requireadditional investigation. A description of the specialist studies and the approach tothe assessment of impacts as provided. In summary, this section sets out the

Terms of Reference for the EIA, also called the Plan of Study for EIA.

5.1 What studies are required?

Issues were identified from the following:

Questions and issues raised in the public participation process Project team discussions and expertise Experience and expertise of the applicant / developer Review of baseline environmental information

The issues that have been identified, thus far, as requiring further investigation areshown in the table overleaf. These proposed studies may be altered and additionalstudies identified depending on the inputs from the public participation process.


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ISSUE FURTHERINVESTIGATION

NEEDED

REASON

Risk-relatedissues

Yes Chlorine is a toxic and hazardous substance. It may have adverse health impacts if inhaled athigh concentrations for an extended period of time. This means that a risk assessment must beundertaken to establish potential risks associated with the project and to identify if additionalsafety measures need to be included in the design. The risk assessment is also important fordeveloping the emergency response plan for the site.

Air Qualityissues

Yes The primary production of chlorine and hydrochloric acid have been identified as activities whichcould have a significant effect on air quality. An air quality impact assessment is thereforerequired to understand the potential impacts on the air quality of the surrounding area as aresult of the project operations and to ascertain any design and/or management measures thatcould be implemented at the facility to ensure that emissions are kept at an acceptable level.

Water issues Yes Liquid chemicals that are required for the production process will be stored on site. Thepotential for pollution of soil and groundwater from spills and leaks needs to be considered.This means that the potential impact of the project on groundwater and surface water must beinvestigated. Given the lack of water availability in the area, a water availability study is alsoproposed with a view to assessing the cumulative impacts of the facility on water resources.

Given that water is a scarce resource in the Saldanha area, the impact of the project in thiscontext needs to be assessed.

Transportissues

Yes Since chlorine is a hazardous material, the transport of this substance falls under the DangerousGoods Transport legislation. It is necessary to determine whether any significant risks would beposed along transport routes and also identify the safest possible transport routes.

Social issues Yes It is necessary to understand the social environment in which the project will be located. Forexample, knowledge about the locally available skills and services will enable CAH Holdings touse local labour and businesses as much as possible. As described in Section 4, it is expectedthat the proposed facility would up to 130 jobs.

Heritageissues

Yes As per the legislative requirements a Notification of Intent to Develop (NID) must be submittedto the Heritage Authorities to determine if further heritage impact assessment will be required.The NID investigation needs to include consideration of paleontological resources that could beaffected by the development.

Ecology No A specialist botanical scan was undertaken at the start of the Scoping Phase on the proposedsite. It was concluded that the site has low botanical sensitivity and has been previously andrecently transformed through agricultural activity. As such, no botanical constraints wereidentified.The significant bird corridor that is noted in the Draft EMF indicates the preferred flight /movement paths of these animals. It is thus relevant to development types that could impacton birds whilst in flight such as wind farms. This environmental attribute is not of concern inrelation to the proposed CAH project, since it does not comprise structures located at heightwith moving parts such as wind farm towers.

5.2 What alternatives will be investigated?

It is a requirement of the EIA process to investigate feasible alternatives. Twoalternative locations for the project in Saldanha have already been investigated.Portion 6 of Farm 188 Langeberg and Portion 0 of Farm 189, Uyekraal wereassessed specifically from a botanical sensitivity point of view. The latter property

was found to have a high botanical sensitivity, based on a scan undertaken by NickHelme Botanical Surveys (Refer to Appendix C for the botanical scan report).

Accordingly, this site was not considered any further. Thus, from a locationperspective, only Portion 6 of Farm 188 Langeberg will be subject to assessment.

Alternative layouts of the facility on the site will be explored further during theEIA Phase and definitive layouts will be drawn-up once the findings of the MHIRisk Assessment and air quality assessments are available. Alternative layouts willalso need to take into account any specific requirements of the adjacent FSseparation plant, given the requirement to pump caustic soda and HC over thefence to this plant.

ALTERNATIVELOCATIONS /

SITES WERECONSIDERED

DURING SCOPING


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Another alternative that has been raised is that of the method of disposal of theeffluent generated by the project and the adjacent FS separation plant. Severaloptions for the disposal of the effluent brine produced by the CAH facility as wellas the effluent generated by the proposed FS separation plant were considerednamely: disposal at the existing waste water treatment works; the use of evaporation ponds to produce waste salt for onwards disposal at a

licensed facility; the use of evaporation ponds and evaporative crystallizers to recover water for

reuse and to produce waste salt for onwards disposal at a licensed facility; the use of evaporation and crystallization techniques to re-use salt in the

production process; and the disposal of effluent at sea.

It was found that the salt load of the effluent is not appropriate for treatment at

the WWTW because of the level of salinity. The re-use of salt in the CAHproduction process was considered in some detail, however it requires the refiningof waste salt to remove impurities (mainly salts) and involves the generation of a

waste sludge with no identified means of disposal. The cost of cleaning the wastesalt for reuse was also found to be uneconomical in comparison the costsassociated with sourcing salt from Walvis Bay to the facility. With respect to thedisposal of effluent at sea, the waste brine has a concentration of NaC that iscompatible with sea water. However, the effluent would have to be transported toDanger Bay, west of Saldanha, via a pipeline. The marine outfall and pipeline isbeing dealt with by Frontier Saldanha Utilities Pty Limited in an EIA process that

is being undertaken by the CSIR. Notwithstanding, the results of the sea outfallimpact assessment, insofar as these have relevance to the CAH plant, will beincluded in the EIA Report.

Alternative technologies will not be considered, since the project will be designedaccording to international best practice. This means that evaluation of atechnological alternative would essentially amount to an academic exercise, sincethis would involve lesser safety measures than those being proposed.Furthermore, the applicant is committed to best practice and so there is nopurpose in assessing an alternative that has fewer safety features.

5.3 Description of specialist studies

The environmental issues that have been identified as requiring additionalinvestigation cover the following:

Risk-related issues Air Quality Water issues Transport issues

Social issues Heritage


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5.3.1 Major Hazard Installation Risk Assessment

In the previous section, it was stated that the EIA is aimed at assessing thepotential implications or consequences of a proposed development on theenvironment, including people. Where projects involve the use of hazardoussubstances, one of the most important issues that require attention is that of the

potential risks posed to people. For this reason, a Major Hazard Installation(MHI) risk assessment needs to be undertaken because the project involves thehandling, storage and use of hazardous materials. This risk assessment is a legalrequirement in terms of the Major Hazard Installations Regulations (GN. 692, July2001), which were promulgated in terms of the Occupational Health and Safety

Act (Act 85 of 1993). The MHI Risk Assessment report must be made publiclyavailable. Various authorities must be notified that the facility is a MHI, namelythe Department of Labour and the Disaster Management Departments of theSaldanha Bay and West Coast District municipalities. For the purposes of the EIAprocess, the MHI risk assessment is the specialist study that will be used to

investigate the potential risks posed to people.

A risk assessment takes into account the potential hazards or consequence of anoperation together with the likelihood of an event actually occurring. For exampleconsider two sites each with 150 tons of the same hazardous chemical and the onesite has all the safety equipment in place to meet best practice standards and theother has no such measures in place. Although the hazard presented by the sites isexactly the same (150 tons of chemical) the risk (the chance of this chemicalactually causing damage) is not the same. When dealing with potentially hazardouschemicals, designers, operators and the authorities need to ensure that measures

are put in place to prevent the accident happening, i.e. reducing the likelihood of ithappening. This is an important role of the risk assessment that is, determining

what measures need to be put in place to minimise the chances of an accident andthe measures needed to mitigate the impact (i.e. reduce the severity) in the event ofan accident occurring.

Internationally accepted procedures and standards for safety and risk are applied inthe MHI risk assessment. This study will serve to review all proposed safetymeasures within the project and will serve to identify what additional measuresmay be required, if any. A quantified major hazard installation risk assessment will

be undertaken for the proposed CAH chlorine, caustic soda and HC facility . Theassessment will be carried out to comply with the Revised Major HazardInstallation Regulations of July 2001, under the Occupational Health and Safety

Act and well as any known requirements of the Local Authorities. Key steps in therisk assessment process are:

Determine risk scenarios or situations, based on international and local incidentinformation.

Undertake initial risk assessment. Review project design, based on initial findings. Adjust the project design as required to reduce risk levels.

A RISK ASSESSMENT IS

REQUIRED, WHICHUSES

INTERNATIONALSTANDARDS


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STEP 3 Assessment

Assess these risks by making value judgments in terms of internationallyrecognized quantitative acceptability criteria (use UK HSE as a basis) as well asany criteria available from the national, provincial and local authorities.

Review the on-site emergency plans (if they already exist) and safety featuresand provide recommendations on any improvements needed in the light of therisk assessment results. These recommendations may include changes to thedesign or positioning of the facility on the site.

Where additional risk reduction measures are required that need to beaddressed via the design and/or layout of the facility, once these changes havebeen made, the risk assessment modelling would be undertaken on the revisedproposals, to determine if the desired risk reduction results are being achieved.

5.3.2 Air Quality study

As is typical of any air quality impact investigation, the first step is to establish thestatus quo, which would serve to define the baseline . The establishment of thebaseline is followed by the prediction of proposed future developments ( incrementalimpacts ), which is then superimposed on the baseline, i.e. cumulative impacts .

In order to quantify the air pollution impact air quality criteria will be applieddrawing from South African Regulations and Standards, the World HealthOrganisation and the US Environmental Protection Agency. The air pollutionimpacts of the proposed development will be estimated using the predicted airconcentrations and fallout rates, based on dispersion modelling.

The terms of reference for the study are thus as follows:

1. BASELINE ASSESSMENT:

Collection of available air quality and meteorological data for the study area

Syntheses of air quality and meteorological data

Discussion of atmospheric dispersion potential

Description of study area in terms of Land use and topographical features,Identification of sensitive receptors and identification of existing industrial andother air polluting activities

Summary of Air quality assessment criteria and legal compliance

2. PREDICTED IMPACT ASSESSMENT

Identification of potential air pollutants from proposed plant


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Identification of air emission sources

Quantification of air pollutant rates and preparation of emissions inventory

Selection of appropriate dispersion model

Preparation of dispersion model input files, including base maps

Simulation of air concentrations of most significant air pollutants

Preparation of isopleth plots and calculation of air concentrations at selectedreceptor locations

Preliminary health risk assessment (World Health Organisation and USEnvironmental Protection Agency)

Compliance assessment (DEA Legal requirements)

3. MITIGATION AND MANAGEMENT PROGRAMME

Based on predicted air concentrations, recommend reductions of emission where necessary

Propose any monitoring of emissions and/or ambient air concentrations ofidentified air pollutants

4. ATMOSPHERIC EMISSIONS LICENCE (AEL)

Meet with relevant authority for requirements of AEL

Assist with the completion the AEL application.

5.3.3 Surface and Groundwater Resources study

The surface and groundwater study will focus on the following questions:

1. How vulnerable is surface water to pollution from the proposed project?

2. How vulnerable is groundwater to pollution from the proposed project?

3. Are proposed measures within the project design adequate to avoid potentialenvironmental impacts or to at least minimise such potential impacts?

4. What water surface water monitoring needs to be undertaken, if any?

5. What effluent monitoring needs to be undertaken?

6. What groundwater monitoring system is needed (i.e. number and position ofmonitoring wells), if any?


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7. What groundwater monitoring programme is required, if any?

These questions will be addressed through reviewing existing information onsurface water and hydrogeology (baseline assessment). The need for the drilling ofboreholes to obtain more detailed groundwater information will be establishedonce the baseline assessment has been completed.

In order to understand the implications of the project in the context of waterdemand and supply, the water needs of the project will be assessed againstavailability. Impacts related to water demand will also be addressed in the contextof cumulative effects, particularly given that there are a number of proposedprojects in the area. Reference will be made to water demand studies that havebeen undertaken as a basis for assessing the potential impacts of the proposedproject. Consideration will be given to water conservation and water recycling andre-use options.

5.3.4 Transport Study and Risk Assessment

The scope of work will involve:

1. Establishing the trip generation associated with the project and providing thesedata for the purposes of the land use application that is being undertaken bythe landowner (Trans African Murals).

2. Undertaking a risk assessment on the transport of chlorine and relatedproduction in relation to the proposed facility location. In this regard, the

Transport Risk Assessment that was compiled for the NCP Chlorchem storagedepot in Atlantis will be used as a base. As such, only the elements of the route

which differ from those already addressed in the Atlantis depot assessment willbe investigated (such as the R27 northbound). This risk assessment must bebased on the typical volumes of chlorine that are transported per load.

3. Providing advice based on the best route/s to use from the facility tocustomers, based on risk criteria.

4. Reviewing the adequacy of loading and offloading activities, driver training andcompetence, emergency response planning in terms of minimizing potentialrisks. This will include liaison with the company who will be contracted forchlorine transport from the facility.

5. Reviewing transport incidents involving chlorine, both locally andinternationally, to determine if currently applied risk control measures areadequate and to recommend improvements if required.

6. Consultation of Disaster Management at municipalities to discuss potentialtransport routes and associated risks (if any) and to determine theirrequirements.

7. Identify the possible risk scenarios and model those that need to be quantified.


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8. Provide recommendations on additional measures required to reduce risks, ifany and on the most advisable transport routes to use, where more than oneroute option is available.

5.3.5 Social study

It is important that the social impacts and benefits be considered as these areimportant issues from a local community perspective. In this regard the followingissues will be addressed:

What risks does the project pose for the local community, if any?

What employment and local business opportunities does the project present?

What skills and services are available within the local area that could beprocured by the facility?

Are there any community-based projects within the area or in close proximityto the site that could be adversely affected by the project or that could benefitfrom the project?

What potential economic knock-on benefits does the project offer in thecontext of the local economy?

How should CAH set up its risk communication programme and what shouldthis programme comprise?

How should CAH deal with the potential social influences, especially negativeinfluences that may affect the workforce? What support systems may berequired?

The study will consider the communities in the vicinity of the site such asSaldanha, Vredenburg and Langebaanweg.

5.3.6 Heritage study

As mentioned elsewhere in this report, it is necessary to determine whether aHeritage Impact Assessment (HIA) is required for the site or not. A Notificationof the Intention to Develop will be lodged with Heritage Western Cape. Thissubmission will describe any heritage resources that could be encounteredincluding archeological and paleontological resources. If Heritage Western Caperespond indicating that a HIA is required, this will be undertaken in accordance

with the legal requirements and the Guideline for Involving Heritage Specialists inthe EIA Process, published by the DEA&DP in 2005.

5.4 Approach to evaluating impacts

Achieving a common understanding of significance in the EIA process can befacilitated by the use of generic approaches and judgemental criteria. Both


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professional judgement and the value judgements expressed by variousstakeholders should be taken into account when determining the significance ofenvironmental impacts. Hence, the assessment of impacts will be undertaken asfollows: Input from public participation process in respect of the values or judgements

expressed by I&APs. Project team working sessions where impacts will be subject to technical

review by the various specialists in the team, thereby facilitating an integratedand holistic approach.

The process and criteria that will be applied are summarised overleaf. Additionalcriteria will be developed, if warranted on the basis of I&AP and specialist input.

STEP CRITERIA

Step 1: Deciding whether the environmentaleffects are adverse

The quality of the existing environment is compared with the predicted quality of theenvironment once the project is in place. For example, negative effects on human health,well-being or quality of life.

Step 2: Deciding whether the adverseenvironmental effects are significant

Criteria used are: Geographic context Duration and frequency Degree to which the adverse environmental effects are reversible or irreversible Ecological context Degree of change relative to current situation Social values

Step 3: Deciding whether the significant adverseenvironmental effects are likely

Criteria used are: Probability of occurrence Scientific uncertainty

Step 4:Deciding whether proposed mitigationmeasures are adequate or not

Criteria used are: Residual risk/impact Scientific uncertainty

Source: Adapted from the Canadian Environmental Assessment Agency (1992)

It is proposed to present the impact assessment in a descriptive format, which isconsidered more reader friendly than tables. Furthermore, we do not propose toapply a rating system of High, Medium and Low because this leads to the loss ofimportant descriptive information. Internationally, impact assessment methods aremoving towards a descriptive approach due to the limitations associated with

weighting/rating systems.

Hence, we will present the impact assessment in a manner that answers thefollowing questions:

What are the impacts and benefits? What is the significance of each impact and benefit and why? What criteria have been used to determine significance? What information or knowledge gaps are there in relation to the impacts? What risks and uncertainties are there in the prediction, assessment and

evaluation of impacts? Can any of the impacts be avoided? Where impacts cannot be avoided, can they be minimised and if so, to what

extent?


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Are mitigation measures to minimise impacts known to be effective or arethere uncertainties?

Which alternative would be most appropriate from an impacts and benefitsperspective?

Can the development proposal be considered to be consistent with the NEMAprinciples?

Can the development proposal be considered to be consistent with strategicplans for the area, such as the Spatial Development Framework and theEnvironmental Management Framework?

5.5 Approach to public participation and authority consultation

Stakeholder engagement is an integral part of the EIA process and the public willbe provided with further opportunity to provide input into the investigation duringthe EIA Phase. Furthermore, consultation with the D:EA&DP throughout theprocess allows for the competent authority to raise any concerns during the courseof the investigation so that these can be addressed prior to the decision phase. Thefollowing activities are envisioned for the EIA Phase:

The D:EA&DP will consider the Scoping Report on submission. If thecontent of the document is satisfactory, the authority will issue a letter ofacceptance to the applicant and include any additional requirements for theEIA Phase.

Registered I&APs would be notified of the commencement of the EIA Phaseby means of a notification letter.

The Draft EIA Report will be made available for public review for a period of40 days. Registered I&APs will be notified of the availability of thedocumentation and will be invited to comment on it. In line with the legislativerequirements, the Draft EIA Report will be submitted to the competentauthority prior to public review.

During the course of the above-mentioned public review period a public event,probably in the form of an Open House, will be held to share the findings ofthe Draft EIR. The project team will be on hand to answer the queries ofattendees and any comments/issues raised will be recorded in the issues trailand considered. Similarly, a workshop for relevant authorities will be held todiscuss the findings of the Draft EIR.

The Final EIR will be circulated in the public realm for 21 days. Thereafter, theFinal EIA Report will be submitted to the D:EA&DP, together with anycomments received.

5.6 Approach to the Environmental Management Programme (EMP)

It is necessary to include a Draft EMP in the EIA Report. The EMP must detailmitigation measures for each environmental impact for:

Design; Pre-construction and construction activities; Operation; Rehabilitation; and


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Closure (where relevant).

The EMP is an action plan that deals with the measures required to mitigate andmanage impacts and will therefore detail:

The mitigation measures (what needs to be done and how). Roles and responsibilities for implementation (by whom actions need to be

undertaken). Timeframe or programme (by when actions need to be completed or if they are

ongoing).

Monitoring requirements must also be detailed in the EMP. The followinginformation is required in respect of monitoring:

A description of environmental standards applicable to monitoring activities; An overview of monitoring requirements and methods (what needs to be

monitored and how). An indication of the frequency of monitoring / monitoring programme (when

to monitor). A description of the purpose and use of monitoring data in the ongoing

management of environmental impacts.

localizacion e impacto

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