dedeat reference: ec/7/a/ln1/13/13-19 400m3 lpg facility lbri31.1.14/mbsa afrox... · reviewer dr...

BASIC ASSESSMENT REPORT

MERCEDES-BENZ SOUTH AFRICA 400m3 LPG INSTALLATION Page 1 of 98

BASIC ASSESSMENT REPORT PROPOSED MERCEDES-BENZ SOUTH AFRICA

400M3 LPG INSTALLATION,

EAST LONDON, BUFFALO CITY METRO MUNICIPALITY, EASTERN CAPE PROVINCE

DEDEAT Reference: EC/7/A/LN1/13/13-19

Prepared for:

Mercedes-Benz South Africa Mr Pierre Bezuidenhout

Mercedes Benz South Africa Ltd Project Engineer

Product Planning Division 7 Settlers Way, East London

Phone: 0027 43 7062851 Fax: 0027 43 7062323

E-mail: [email protected]

Prepared by:

Coastal & Environmental Services

EAST LONDON

PO Box 8145 Nahoon 5210 South Africa Ph: 043-726-7809 Cell: 083-379-9861 Fax: 086-672-4339

E-mail: [email protected]

Also in Grahamstown, Johannesburg, Cape Town, Port Elizabeth and Maputo

www.cesnet.co.za

March 2014

mailto:[email protected]://www.cesnet.co.za/



CES Report Revision and Tracking Schedule Document Title

BASIC ASSESSMENT REPORT MERCEDES-BENZ SOUTH AFRICA 400M3 LPG INSTALLATION

Client Name & Address

Mercedes-Benz South Africa (Ltd) Mr Pierre Bezuidenhout 7 Settlers Way, East London

Document Reference

EC/7/A/LN1/13/13-19

Status

Final

Issue Date

7/03/2014

Lead Author

Ms Louise Bryson

Reviewer

Dr Alan Carter

Study Leader or Registered Environmental Assessment Practitioner Approval

Dr Alan Carter

Report Distribution Circulated to No. of hard copies

No. electronic copies

DEDEAT 2 1

BCMM Disaster management 1

BCMM Fire and Rescue 1

BCMM Health 1

Transnet National Ports Authority, East London

1

BCMM: Integrated Environmental Management Unit

1

DWAF: Water Quality Management

1

This document has been prepared in accordance with the scope of Coastal & Environmental Services (CES) appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared exclusively for use by CES’s client. CES accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of CES. The document is subject to all confidentiality, copyright and trade secrets rules, intellectual property law and practices of South Africa.

Coastal & Environmental Services

16 Tyrell Road, Berea

East London 5241

+27 43 722 5812 [email protected] www.cesnet.co.za

Also in Grahamstown, Johannesburg, Cape Town, Port Elizabeth and Maputo

mailto:[email protected]://www.cesnet.co.za/



PROVINCE OF THE EASTERN CAPE

DEPARTMENT OF ECONOMIC DEVELOPMENT

AND ENVIRONMENTAL AFFAIRS

BASIC ASSESSMENT REPORT (For official use only)

File Reference Number:

Application Number:

Date Received:

Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2010, promulgated in terms of the National Environmental Management Act, 1998(Act No. 107 of 1998), as amended. Kindly note that: 1. This basic assessment report is a standard report that may be required by a competent authority in terms of the EIA

Regulations, 2010 and is meant to streamline applications. Please make sure that it is the report used by the particular competent authority for the activity that is being applied for.

2. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily

indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing.

3. Where applicable tick the boxes that are applicable or black out the boxes that are not applicable in the report. 4. An incomplete report may be returned to the applicant for revision. 5. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material

information that is required by the competent authority for assessing the application, it may result in the rejection of the application as provided for in the regulations.

6. This report must be handed in at offices of the relevant competent authority as determined by each authority. 7. No faxed or e-mailed reports will be accepted.



8. The report must be compiled by an independent environmental assessment practitioner. 9. Unless protected by law, all information in the report will become public information on receipt by the competent

authority. Any interested and affected party should be provided with the information contained in this report on request, during any stage of the application process.

10. A competent authority may require that for specified types of activities in defined situations only parts of this report

need to be completed.



SECTION A: ACTIVITY INFORMATION

Has a specialist been consulted to assist with the completion of this section?

YES NO

If YES, please complete form XX for each specialist thus appointed: Any specialist reports must be contained in Appendix D. 1. ACTIVITY DESCRIPTION Describe the activity, which is being applied for, in detail MERCEDES-BENZ SOUTH AFRICA 400m3 LPG INSTALLATION

BACKGROUND Mercedes-Benz South Africa (MBSA) proposes to install a 400m3 Liquid Petroleum Gas (LPG) facility to supply LPG vapour to the paint shops at its East London plant located on the West Bank of East London, Buffalo City Metro Municipality in the Eastern Cape Province. The scope of the current EIA also includes the decommissioning of the two existing 45m3 LPG tanks. MBSA requires authorisation from the Department of Economic Development, Environmental Affairs & Tourism (DEDEAT), in terms of the Environmental Impact Assessment Regulations, 2010 promulgated in terms of the National Environmental Management Act 107 of 1998 (NEMA), as amended. Coastal and Environmental Services (CES) has been appointed by MBSA as the independent Environmental Assessment Practitioner (EAP) to undertake the necessary environmental investigations for the new LPG Facility and decommissioning of the old facility, and to apply for the required authorisation from DEDEAT.

LOCATION MBSA is located adjacent to Settlers Way in Gately Industrial Area, on the West Bank of the Buffalo River, East London (Figure 1). The site of the proposed installation is, in the northern corner of the MBSA plant, on Erf 26196 (Surveyor Generals 21 digit reference number: C02300040002619600000) (Figure 2). The area of the LPG facility is about 3,200 m2 (Figure 3).



Figure 1. Location of the MBSA plant in East London, Eastern Cape, South Africa.

Figure 2. Location for the 400m3 LPG facility in the MBSA plant.

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Figure 3. Technical detail for the 400m3 LPG facility (as per Afrox specifications).

DESCRIPTION OF A 400M3 LPG STORAGE VESSEL

According to the Afrox Product Reference Manual, LPG is the term applied to hydrocarbons which are vapours at room temperature and pressure but that can be liquefied by light compression. LPG is composed of a mixture of propane and butane (60:40 ratio) but may contain some propylene and butylene as well as traces of ethane, ethylene, pentane and butadiene. As LPG liquid has a much decreased volume, it needs much less storage space. The user of the stored LPG can converted it to gas by opening a valve on the storage vessel which causes the liquid to vapourise as a result of a drop in cylinder pressure.

LPG vapour has a density heavier than air and as such in the event of a leak the vapour will flow along the ground to the lowest level and remain there for considerable periods of time, acting as a significant explosion hazard. The thermal rate of expansion of liquid LPG is about 10 times that of water and since liquids cannot be compressed, this acts as an important property affecting how LPG is stored, handled and filled. With reference to the proposed LPG installation the LPG tank has been designed to have a limit of 95% of the internal volume.

Risks associated with LPG An important issue of concern with regards to LPG, as identified above is leakage. This is a HIGH risk due to the significant difference between LPG and air densities. This means that LPG can travel along the ground. As a result of the relationship between vapour pressure and temperature a temperature drop will occur when there is a leak. A phenomenon known as Boiling Liquid Vapour Explosion




(BLEVE) may result. This occurs when a liquid substance stored in a pressurised container is exposed to temperatures higher than the boiling point of the substance at atmospheric pressure (Figure 4). In the case of there being a fire near the container the temperature of the container increases, as does the pressure in the container. If the container is damaged, gas may escape and the pressure in the container will reduce to atmospheric pressure instantaneously. The equilibrium in the container is broken and BLEVE results.

Figure 4. Explanation of BLEVE.

Environmentally sensitive chemicals used in the LPG plant that pose a risk are ethylene glycol and ‘pyrocrete’ used to coat the tanks. These chemicals may pose a hazard if they enter the surface or groundwater resources of the area. Decommissioned tanks may have paint in the tank coatings scraped in the excavation process, contaminating groundwater.

Mitigation of risks for LPG storage A Major Hazard Review Program (MHRP) was conducted on three alternative LPG tank sizes being 150m3, 300m3 and 400m3 mounded LPG tanks. A rupture of 38 mm was considered for each tank as well as for a flange or pipeline with the release assumed to be liquid LPG. The protection precautions installed in the LPG tanks are indicated in table 1. The best option for MBSA was considered as a 400m3 LPG mounded vessel due to it having the lowest risk level. Table 1. The LPG tanks have the following protection installed.

Item no.

Protection Feature Comments

1 Over filling protection Gauges are installed to prevent the LPG tank filling to above 92%. There are also level indications at the decant point so that the operator can monitor the level.

2 Fire The vessel is mounded and the road tanker decant point includes a deluge system.

3 Isolation System Automatic ESOV.



4 Over pressure Protection (PSV)

There are four safety relief valves on the vessel.

TECHNICAL DETAIL OF A 400M3 LPG STORAGE VESSEL The LPG installation includes the following main elements (Figure 5):

Road tanker decanting, with road tanker deluge

One 400m3 LPG vessel, mounded.

Four WB300-V Ely vertical vaporisers

Instrumentation for control and monitoring

Fire detection and suppression (FD&S)

Telemetry system

Figure 5. Plan view of the location and elements incorporated in the 400m3 LPG facility.

OPERATING PARAMETERS Liquid LPG will be fed to three vaporisers using the vapour pressure inside the storage vessels. The vaporisers will be connected in parallel, which will provide the vapour at about 40°C. The outlet vapour will be on pressure control so that the required pressure will be maintained for any demand by MBSA up to the maximum flow rate of 1000kg/hr.

The operating parameters are based on the following requirements by MBSA:

Supply pressure A pressure of 1.2 to 1.4 barg will be supplied at the Afrox boundary limit, to achieve a pressure of 0.8 to 0.9 barg at the points of use.

Supply temperature The temperature of the gas exiting the vaporisers is at an average of 40°C.

FD&S

Vaporisers and regulator

Road Tanker decanting



Flow rate The maximum flow will be maximum 1000kg/hour and an average of 600kg/hour (to be confirmed).

Plant availability The plant is designed to achieve maximum reliability of 365/24/7.

FACILITY ELEMENTS Road Tanker Decanting LPG will be delivered to the site by road tanker. r A 50mm Andrew’s coupling is to be provided (TBC). The amount of product off-loaded into the vessel will be recorded by a weight-bridge. The level indication for the storage vessel will be installed at the decant point. The design of the decant point is such that the road tanker is able to drive through the site after off-loading and not need to reverse on site. LPG Storage Vessel One 400m3 LPG mounded vessel will be installed (Figure 6). Figure 6. A conceptualisation of the 400 m3 LPG mounded vessel to be installed.

Every nozzle on the vessel is fitted with excess flow valves and emergency shut-off valves, linked to the sites FD&S system. The design for the 400m3 vessel allows for the normal fill level of the vessel to be 92%. The vessel will have over-fill protection which will close the actuated valve of the fill nozzle should a high level condition be reached. Vaporisers The vaporisers will use a water-ethylene glycol solution heated to 71oC - 80oC to transfer the thermal energy required for vaporisation. LPG vaporisation will occur in the single pass helical coil(s) immersed in the water bath. During operation, an atmospheric burner will heat the water bath, via jet burner tips that will premix the necessary air to provide complete burner fuel combustion in the vaporisers combustion chamber. Products of combustion will pass upward through multiple vertical flues as heat transfers to the water bath. Turbulators installed in the vaporisers will help to ensure maximum heat transfer. The atmospheric burner will be controlled by a water bath temperature switch and will cycle ON-OFF in response to the water bath temperature. The normal water bath operating range is (71oC-80oC). The temperature will be monitored by a temperature bulb sensing device. The burner will ignite for each ON cycle via a burner pilot ignition assembly. A UV Scanner will assure that the pilot flame is established prior to allowing the burner gas train to supply LPG fuel to the burner. The burner gas train includes a combination HI-LOW Pressure switch. The switch will ensure that the burner fuel pressure is neither too high nor low. This HI-LOW Pressure switch requires manual reset if tripped. Burner fuel will be sourced from the LPG vaporiser coil. The burner gas will pass through a burner regulator at 11” WG (2.75 kPa).

400m3

LPG

Earth

Mound



Burner and pilot manual shutoff valves will allow isolation of the gas trains for maintenance as required. Flame control relay will ignite pilot and be proved “on” by a pilot assembly. Main gas valve(s) will then open and on IR systems, the vent valve will close. Burner will ignite within four seconds after gas reaches burner ports. The water bath must be filled with a mixture of fresh, clean water and glycol that contains anticorrosion additives. The product being used for these vaporisers is Nacool 2000 which has anti-corrosive and anti-freeze properties.

Regulating station The regulating station consists of two Fischer model 99-901PH regulators. They will be installed in parallel, with one regulator leading. Set points are 140kPa and 120Kpa (TBC). Liquid separator pot and filter The function of the separator pot will be to collect any liquid passing through the vaporiser. This should not happen since the LPG should be vaporised. However, if for any reason LPG liquid passes through, it would cause freezing in the pipeline as it vaporises, which could be hazardous. Liquid carry-over will be detected by a temperature switch set at 5°C. A detection of this low temperature will be sent by telemetry to Bulk Scheduling Centre and several personnel in Afrox Customer Engineering Services (Afrox-CES) East London and Port Elizabeth. The LPG also contains a very small proportion of non-volatile “heavy ends”. These will also collect in the separator pot and will need to be drained off from time to time. A cartridge filter will be installed in series with the separator pot, which will absorb any vapour mists that may be carried over. Fire Detection & Suppression system (FD&S) The FD&S system will consist of:

Main air supply from a compressor and cylinder back-up

FD&S panel

FD&S manifold housing with two zones: o Zone 1 – LPG vessel, vaporisers and piping o Zone 2 – Road tanker decant point

8mm scad tubing

Deluge system at road tanker decant point

Vessel mounded i.e. buried under a layer of soil, 1.5 metre deep.

Instrument air supply from a compressor will be regulated to a pressure to 600 kPa(g) at the FD&S manifold. The back-up cylinder will be regulated at 500 kPa(g). Fire detection tubing comprises of single loops from the supply around the vessel emergency valves, around the LPG piping to the vaporiser and downstream vapour piping on one loop, and along the road tanker decant point and deluge system on the second loop, both returning to individual pressure switches on the FD&S manifold. A break in either of the fire detection loops will drop the pressure in the respective loop



causing the actuated valves on the respective loop to close. An actuated valve at the Afrox boundary limit will also close to stop supply to MBSA. Once the pressure reaches the low setting of 3 bar the detection pressure switch will set off the fire alarm, cut off the power to the plant and activate the road tanker deluge system. The system has been set up and tested to ensure actuation within 20 seconds of a break in the detection tubing. This has been achieved by use of solenoid dump valves which activate to dump any residual air in a detection loop, hence aiding in the de-pressurising of the loop. Telemetry system A telemetry system will be installed on site which relays the following alarms to Bulk Scheduling Centre and personnel from Afrox-CES East London and Port Elizabeth:

Storage tank low and high levels

Vaporiser trip

FD&S activation

Power trip Site emergency system There will be two fire alarm buttons installed – one at the road tanker decant point and the other near the storage vessel. Activation of these buttons will activate the FD&S system.

DECOMISSIONING Currently LPG is supplied to MBSA by means of Handigas Afrox road tankers. The existing LPG installation comprises of LPG road tanker off-loading facilities, 2 x 45 m3 capacity horizontal LPG bullets, evaporators and piping to transfer the LPG to the paint shop. The LPG Bullets are coated with fire proof “Pyrocrete” type material and have no fire water deluge systems installed.

The existing installation of the 2 x 45 m3 tanks will only be decommissioned after the new installation is installed and in operation. Decommissioning will involve emptying the existing vessels, flaring any excess gas in the vessels and pipelines, making safe with nitrogen, and then equipment would be dismantled and removed from site. Also the electrical supply to the existing installation would be disconnected. Ethylene gycol would be used in the water bath during operation and should be managed effectively as it is considered moderately toxic for human consumption. This chemical takes a few days to break down in air and a few weeks to break down in soil and water therefore the correct management is necessary in order to remove the risk of contamination in soil and water resources. Decommissioned tanks are coated with “Pyrocrete” which may be toxic in large quantities in ground and surface water. Coatings may be scraped in the excavation process, contaminating groundwater. After the decommissioned tanks have had gas removed the excess LPG must be flared. The system must be purged of residual vapours. Purging will be done with nitrogen. The tanks, vaporisers, compressors and other equipment will be dismantled and prepared for transport. The pipes will be cut and capped and hazardous material will be collected and properly disposed of. The site will then be regraded according to site specifications.

DESCRIPTION OF ENVIRONMENT

Climate The climate of the East London area is considered to be warm-temperate and moist with an average monthly rainfall of 921mm, occurring mainly in the summer. Temperatures vary



between 3OC and 42 OC, with an average daily minimum of 14OC and an average daily maximum of 23OC (South African Weather Service data for past 30 years – www.weathersa.co.za/climat/climstats).

Geohydrology The geology of West Bank area at the surface comprises shallow (< 3m) unconsolidated overburden grading from weathered to fresh Beaufort Group inter-bedded shales and sandstones. It has been impacted through construction activities including; cut-and-fill terraces, excavation for foundations, roads, backfilling etc. The MBSA East London plant is located on a watershed formed by Settlers Way and Military Road (Figure 7). Stormwater run-off would occur in both a north-westerly direction, towards Settlers Way, and the Buffalo River, and a south-easterly direction, towards Military Road, finally discharging into Buffalo River Harbour. The proposed site of the installation occurs in the latter storm-water runoff area, and hence any stormwater collected near to the site, will ultimately discharge into the Buffalo River Harbour. There are two stormwater drains that have been identified to be in the vicinity of the proposed 400m3 LPG site (Figure 8). This may pose a potential risk for the LPG facility due to the characteristic of LPG moving along the ground if leaked. LPG could reach the stormwater drain and pose a fire hazard. With reference to figure 5, the technical details indicate that the 400m3 LPG installation will occur 10.5 m from the storm water drains.

Figure 7: Surface run-off from MBSA (Proposed installation = orange star)

MBSA

http://www.weathersa.co.za/climat/climstatsjavascript:edit(84138)



Figure 8: The stormwater reticulation for MBSA (zoomed in to the proposed 400m3 LPG site-

site identified in orange) with red dots indicating associated stormwater drains.

A MBSA storm and surface water monitoring program is conducted annually, with the most recent available report being 2011. The monitoring programme for 2011 consisted of 11 surface water sites within and outside the perimeter of the MBSA plant (Figure 9). The closest site to the proposed installation would have been NBS1. NBS1 receives runoff from part F, K and C of the plant. In this regard it would receive runoff from the proposed installation site. In 2011 there were no inorganic, physical or organic results which exceeded the SANS or Dutch Standards. In general the programme acknowledged that MBSA had improved their management and environmental practices as there were noticeable reductions of contaminations within the storm water system.

Figure 9: MBSA plant area indicating the 11 storm water sample sites (Proposed installation =

orange).

Existing

LPG tanks



Current underground pollution status A Mercedes Benz AG due diligence audit in 2001 identified a gap in terms of the environmental risk of possible ground water at the East London Plant. A subsequent initial environmental risk evaluation found contamination of significance in one of the four on-site deep wells (MEGA, 2003). Upon this finding MBSA East London plant initiated an extensive soil and ground water investigation, with MBAG expert Michael Schwarz conducting a historical site characterisation. This investigation ultimately resulted in an annual soil and ground water monitoring programme for MBSA EL. MBSA have included an annual groundwater monitoring programme at the East London factory since 2003. Monitoring now occurs at key wells every second year. The latest groundwater monitoring report (MEGA, 2011) indicates that there are two deep wells in the vicinity of the site. The important sample sites that are in the vicinity of the proposed installation site are DCMW6 and DCMW5 (Figure 10). The fluctuation of the depth to water of these sites shows an upward trend since 2007 (Graph 1) as water is becoming shallower. The deepest groundwater occurs along the northern boundary which is where the installation site is. It is here that the topography drops off towards the river and thus the water table becomes deeper. The shallowest ground is at the paint shops (F site) where the fuel dispensing and car wash occurs. The deep fractured aquifer groundwater gradient in the eastern part of the MBSA plant increases towards the Buffalo River, with the velocity of groundwater increasing along the off-site boundary, resulting in a greater potential for an off-site groundwater plume in the eastern half of the plant.

Figure 10. The location of the groundwater monitoring wells and depth to groundwater in 2011

(MEGA, 2011).




Graph 1. Trends in depth to water for wells at MBSA (MEGA, 2011).

The groundwater pH and Electrical Conductivity (EC) are not considered to be a concern as they are within expected levels of groundwater within interbedded shales and sandstones, especially where shales dominate. There has been an improvement in the groundwater quality since 2005, which can be attributed to the good rains of 2006 and 2007, which flushed the shallow groundwater system, and since there have been no leaching of chemicals. Based on the Hydrogeological Map (Sheet 3324) the area has low groundwater potential with low borehole yields, in the region of 0.5 to 1.0l/s. Given the industrial nature of the surrounding area, there is no reliance on groundwater resources in the area, with the industrial area being supplied by bulk water by BCM. It is not known whether the ground at the proposed site is contaminated, but signs of contamination would be easily detected during excavation.

Ecological The site of the proposed installation is in the existing MBSA plant, on the West Bank, in the Gately Industrial Area. As such the site is already extensively transformed and utilised with little to no direct ecological importance. The activities on the MBSA plant do however impact on the neighbouring environment. The majority of this neighbouring environment is of a similar industrial nature. The two notable exceptions being:

the adjacent Gately Stream Park, and

the nearby Buffalo River and harbour. Gately Stream Park was a previously overgrown, invasive infested area that has been transformed through a combined MBSA and BCM rehabilitation project. The intention of the project is to rehabilitate the park and the Gately Stream that bisects it, so that it can be utilised by the surrounding communities for recreational purposes. This rehabilitation includes:

the implementation of a water monitoring programme for the stream,

the removal of invasive species, and

the planting of indigenous grass and trees. The Buffalo River is South Africa’s only river harbour. Due to poor catchment management and lack of adequate sanitation/water treatment/waste disposal upstream, the water discharging into the harbour from various sources, is loaded with sediment and bacteria. In addition to this, the local industrial and port related pollution further reduce the quality of the



water released into the Buffalo River Estuary. This water in the estuary is heavily polluted with high levels of heavy metals and contaminated run-off, and the high levels of faecal coliforms make the water unsuitable for human contact. The overall quality of the estuary is fair to poor (State of Rivers Report, 2004). These levels of pollution, together with other sources (e.g. Hood Point outfall) result in non-compliance to SA water quality guidelines for mariculture and bathing water quality standards, in the neighbouring coastal area (State of Rivers Report, 2004).

Socio-economic The site falls within a large industrial area in East London, within BCMM. This industrial area is well positioned to utilise the nearby harbour. The nearest residential areas cater for low income groups employed either within the East London Port or this adjacent industrial area. BCM as a whole has unemployment levels (38%) lower than the Eastern Cape’s average of 48%, but still represents significantly high levels of unemployment. Currently only 36% of BCM residents earn more than R1,500.00/month (BCM SDF, 2003). Resulting in generally a low level of affordability within the municipality. BCM is considered a net exporter of male labour to other economic centres. The overseas investment into MBSA represents one of the largest foreign investments in the country (R1,9 billion), with a turnover of R27,5 billion in 2005. Of the 4,000 staff employed by MBSA nationwide many receive housing benefits, bursaries, training and assistance with further education. Mercedes Benz has a strong tradition of social responsibility, through various social development projects. MBSA continued existence is critical to the economic growth of East London, East London Port and surrounds, with the economic spin-offs of the investment impacting locally, regionally and nationally.

MANNER IN WHICH ENVIRONMENT MAY BE AFFECTED

Physically On-site Above ground environment: The LPG installation will have very little impact on the already transformed site. Vaporised LPG is highly flammable and can form explosive mixtures with air. If the LPG tank and associated infrastructure are not appropriately maintained, operation may result in serious consequences. Surface water: If the LPG installation is not adequately controlled and mitigated, operation may have a negative effect on the surface water leaving the site. Ground: Construction/excavation may expose already contaminated soil which may run-off into stormwater. Ground water: If the LPG tank and associated pipelines are not adequately designed and monitored (testing), operation may result in the contamination of on-site ground water. Off-site



Above ground environment: Industrial areas are appropriate for construction/installation of this nature, and the noise and nuisance associated with construction should not be of significant concern. Surface water: Contaminated stormwater leaving the site may result in the contamination of stowmwater leaving the site, and ultimately the release of contaminated stormwater into the harbour. Groundwater: If contamination of groundwater on site is excessive this may result in the spread of this contamination off site through natural ground water flow.

Biologically On-site The LPG installation will have no significant on site biological effect, as the site is already very impacted and covered in concrete. Off site If however installed LPG is not of an appropriate standard or its maintenance or mitigation for possible accidental road tanker spillages are not sufficient, significant downstream negative biological effects may occur, as a result of polluted ground and surface water.

Economically Economically, the installation of these tanks could directly and indirectly significantly affect the local and regional economy. Direct The LPG facility will provide a supply of LPG vapour to the paint shops at MBSA. This will be used for cars heading for the export market, resulting in significant returns for MBSA, the ability to effectively produce these motor cars has greater strategic importance. MBSA can award the concession to produce these cars to a number of plants distributed worldwide. MB plants within SA are not assured of obtaining these opportunities, as it is primarily based on the specific plants track-record on delivery in the past. MBSA’s ability to demonstrate competence in this awarded contract, will hopefully secure further contracts in future. Indirect The economic spin-off both locally and regionally from this investment are very significant, with the East London Port, East London, Buffalo City and the Eastern Cape all benefiting.

Socially On site Possible exposure of employees to hazardous substances could occur should the site not be effectively managed. Off site

Should ground and surface water pollution occur due to inadequate design or maintenance, it may impact negatively on people utilising nearby coastal facilities.

This possible economic aspect has far reaching social implications, not only for the employees of MBSA, who benefit through housing and education schemes, but also the greater East London population, through the economic and social investment in the area.

LIST OF IMPACTS AND ALTERNATIVES ASSESSED Based on the manner in which the environment may be affected the following list of environmental issues and resulting impacts were identified (Table 4).



Table 4: Possible Environmental Issues & Associated Impacts

Issue Nature of Impact

Impact

Planning and Design Phase Geotechnical considerations Negative - The design of the installation of the mounded

LPG facility may present a hazard if it becomes unstable in the ground. The LPG vessel is sensitive to pressure change therefore if the tank movement is significant it could induce a leak resulting in a fire hazard.

Over filling of the LPG tank Negative - The design of the tank must not allow the tank to be filled to more than 95% of its capacity as this would lead to the rupture of the tank leading to a fire hazard.

Tanker deluge water management

Negative - The contaminated water from the tanker deluge system may reach the stormwater drainage system and cause pollution risks.

Surface water run-off Storm water management

Negative - Inappropriate planning for storm water management could result in erosion and pollution of the natural drainage line that lies adjacent the northern boundary of the proposed site.

Storage of Hazardous substances

Negative - Inappropriate planning for the storage of hazardous substances such as diesel, paint, pesticides etc, tools and equipment used on site could lead to surface and ground water pollution e.g. due to oil leaks, spillage of diesel etc. In addition, these hazardous substances could be washed off into the nearby drainage line.

Management of general waste Negative - Inappropriate planning for management and disposal of waste e.g. storage disposal could result in surface and ground water contamination.

Traffic & transport Negative - Inadequate planning for the transportation of LPG vessel and specialist construction equipment to the site by long and/or slow moving vehicles could cause traffic congestion, especially if temporary road closures are required.

Soil for mound Negative - Inadequate planning for the delivery and storage of the soil required for the soil mound may result in unnecessary risks of sedimentation of surface and ground water resources.

Corrosion of underground pipelines

Negative - Inadequate planning for the corrosion of underground pipelines may result in risks of the pipeline leaking.

Construction Phase Project contract and programme availability

Negative - During construction the project contract and programme need to be made available on site in order for contingencies to be managed in order to minimise negative impacts anticipated. Failure to do so may result in health and safety and environmental risks.

Appointments and duties of project team are neglected

Negative - During construction the project team need to understand their role in the implementation of



the EMP and the environmental risks involved with their particular roles. Failure to do so may result in health and safety and environmental risks.

Emergencies, non-compliance and communication method statements not provided

Negative - During construction communication in emergencies must follow the suggested lines of communication. Failure to do so may result in health and safety and environmental risks.

Safety and Emergency Plans not provided

Negative - There are significant risks associated with the installation of LPG vessels and experienced contractors and labourers need to be engaged with this knowledge. Inadequate awareness may result in inappropriate behaviour that may result in significant health and safety and environmental risks during installation.

Visual intrusion Negative - Visual disturbance of the landscape during construction will be caused by the construction activity.

Dust generation Negative - Dust could to be a potential nuisance due to the construction activities.

Noise Negative - Adverse noise effects will occur during the construction of the development, e.g. from the movement of heavy goods vehicles and the use of heavy duty construction equipment for excavation of foundations, vegetation stripping, etc

Surface and Ground water contamination Stockpiles

Negative - During construction stockpiles may disturb the soil surface and land features.

- Nearby drainage lines may become silted up. - Storm water runoff may be contaminated.

Management of construction waste

Negative - Waste from construction activities e.g. excess concrete and cement mixture, empty paint containers, oil containers etc, could cause pollution of ground and surface water when they come into contact with run-off water.

Hazardous substances Negative - On-site maintenance of construction vehicles/machinery and equipment could result in oil, diesel and other hazardous chemicals contaminating surface and ground water.

- Surface and ground water pollution could arise from the spillage or leaking of diesel, lubricants and cement during construction activities.

Management of general waste

Negative - Littering by construction workers could cause surface and ground water pollution.

Degradation of drainage line from earthworks

Negative - Unplanned construction activities or earthworks that occur close to the drainage line to the north of the site could cause adverse impacts such as soil erosion, siltation, and blockage of the drainage line.

Storm water management Negative - Sediment is likely to be created during construction. This could be washed off into the nearby stormwater drain e.g. during the construction of the earth mound and stockpiling.

Crime, safety and security Negative - Unauthorised personnel may be present on site and cause potential crime incidents and environmental impacts.

- Safety and security considerations should always be adhered to.



Operational Phase Landscape Negative - The soil mound may develop alien invasive

vegetation. Excess vegetation may cause a fire hazard.

Safety and security

Negative - Fences may not be maintained - Emergency plans may not be adhered to in

the case of fires leading to a risk of BLEVE.

Infrastructure maintenance

Negative - Associated buildings may have leaks, causing pollution of soil, surface and groundwater resources.

Storage of chemicals, herbicides etc.

Negative - Inappropriate storage of chemical, herbicides, diesel and other hazardous substances on site could result in soil and water contamination and also pose a high accident danger risk.

Tanker deluge water management

Negative - The contaminated water from the tanker deluge system may reach the stormwater drainage system and cause pollution risks.

Increased storm water run off Storm water management

Negative - Failure to maintain the storm water system could increase the risk of surface water damage to the landscape and vegetation from increased rates of run-off and therefore the risk of localized flooding and increased erosion downstream due to the presence of the soil mound and impermeable areas of hard standing associated with the tanker deluge station.

- The water released at the tanker deluge may not be managed in an appropriate manner.

General pollution Hazardous waste disposal

Negative - Hazardous waste may not be removed resulting in site contamination.

Economic Positive - Further investment into the growth of MBSA. - The LPG facility will aid in the continued

development of the MBSA plant and in turn the economic growth of the BCM.

Decommissioning Phase Noise

Negative - Adverse noise effects will occur during

decommissioning of the site, e.g. from the movement of heavy goods vehicles and the use of heavy duty equipment.

Soil erosion

Negative - After the removal of the LPG vessel, the earth mound may not be rehabilitated and disturbed soils could become exposed, unstable and prone to erosion.

General pollution General Waste management

Negative - Pollution potential if deconstruction waste is not adequately disposed of (i.e. left on vacant site).

- Pollution of the remainder of the site due to poor waste disposal.

Hazardous Waste management

Negative - Ethylene glycol may cause contamination of soil, ground and surface water resources if not properly disposed of.

- Other hazardous waste may not be disposed of properly.

Air quality Odorant levels

Negative - The odorant levels of the gas may have faded which poses an environmental risk if there are any leaks.

Flaring of remaining gas Negative - The flaring of remaining LPG may become



hazardous if not done under controlled conditions.

Removal of associated infrastructure Abandoned pipelines

Negative - All associated infrastructure may not be removed from the site.

Issue Nature of

Impact Impact Nature of

Impact Impact

Decommissioning Phase for existing LPG tanks Noise

Negative - Adverse noise effects will occur during

decommissioning of the site, e.g. from the movement of heavy goods vehicles and the use of heavy duty equipment.

Soil erosion

Negative - After the removal of the LPG vessel, the earth mound may not be rehabilitated and disturbed soils could become exposed, unstable and prone to erosion.

General pollution General Waste management

Negative - Pollution potential if deconstruction waste is not adequately disposed of (i.e. left on vacant site).

- Pollution of the remainder of the site due to poor waste disposal.

Hazardous Waste management

Negative - Ethylene glycol may cause contamination of soil, ground and surface water resources if not properly disposed of.

- Other hazardous waste may not be disposed of properly.

Air quality Odorant levels

Negative - The odorant levels of the gas may have faded which poses an environmental risk if there are any leaks.

Flaring of remaining gas

Negative - The flaring of remaining LPG may become hazardous if not done under controlled conditions.

Removal of associated infrastructure Abandoned pipelines

Negative - All associated infrastructure may not be removed from the site.

CUMULATIVE IMPACTS

Currently there are 2 x 45m3 LPG tanks installed at the MBSA East London plant. These tanks will be removed in order to install a 400 m3 LPG tank. The larger 400m3 tank was deemed necessary due to the need to increase the volume of LPG at the MBSA plant..

ISO 14001:2004 Certificate

As MBSA is ISO 14001:2004 certified (appendix H) it can be assumed that they will take great care in mitigating the environmental risks associated with the LPG installation.



2. FEASIBLE AND REASONABLE ALTERNATIVES “alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to— (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity. Describe alternatives that are considered in this application. Alternatives should include a consideration of all possible means by which the purpose and need of the proposed activity could be accomplished in the specific instance taking account of the interest of the applicant in the activity. The no-go alternative must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. After receipt of this report the competent authority may also request the applicant to assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic alternatives have not been considered to a reasonable extent. Paragraphs 3 – 13 below should be completed for each alternative.

FEASIBLE AND REASONABLE ALTERNATIVES

Design alternatives As the proposed tank represents the highest standard of underground fuel tank installation, and surpasses the SANS requirements, no other material alternatives will be considered in this report.

Location alternatives The activity will be located immediately adjacent to the existing LPG facility. The proposed location is therefore considered appropriate therefore no other site locations are considered.

No-go Given the strategic importance of the cars being produced, it is not considered feasible to consider the no-go alternative. MBSA is positioned within an existing area, and as such the installation of a mounded LPG tank is not out of place. Refusal to authorise this tank would result in serious consequence for MBSA, its staff and East London’s economy in general.

Despite this the EIA Regulations require the consideration of the no-go alternative, and as such this alternative will be considered in the assessment of impacts.



3. ACTIVITY POSITION Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection. List alternative sites if applicable. Alternative:

Latitude (S):

Longitude (E):

Alternative S11 (preferred or only site alternative)

33o 01‘ 34.55 27o 53’45.79

Alternative S2 (if any) o ‘ o ‘

Alternative S3 (if any) o ‘ o ‘

In the case of linear activities: Alternative: Latitude (S): Longitude (E): Alternative S1 (preferred or only route alternative)

Starting point of the activity o ‘ o ‘

Middle point of the activity o ‘ o ‘

End point of the activity o ‘ o ‘

Alternative S2 (if any)




Alternative S3 (if any)




For route alternatives that are longer than 500m, please provide an addendum with co-ordinates taken every 250 meters along the route for each alternative alignment. 4. PHYSICAL SIZE OF THE ACTIVITY Indicate the physical size of the preferred activity/technology as well as alternative activities/technologies (footprints): Alternative: Size of the activity:

Alternative A12 (preferred activity alternative) 3,200 m2

Alternative A2 (if any) m2


or, for linear activities: Alternative: Length of the

activity:

Alternative A1 (preferred activity alternative) m

1 “Alternative S..” refer to site alternatives.

2 “Alternative A..” refer to activity, process, technology or other alternatives.



Alternative A2 (if any) m

Alternative A3 (if any) m

Indicate the size of the alternative sites or servitudes (within which the above footprints will occur): Alternative: Size of the

site/servitude:

Alternative A1 (preferred activity alternative) m2



5. SITE ACCESS

Does ready access to the site exist? YES NO

If NO, what is the distance over which a new access road will be built m

Describe the type of access road planned:

Access will be via the Settlers Way freeway on the West Bank

Include the position of the access road on the site plan and required map, as well as an indication of the road in relation to the site. 6. SITE OR ROUTE PLAN

A detailed site or route plan(s) must be prepared for each alternative site or alternative activity. It must be attached as Appendix A to this document. The site or route plans must indicate the following: 6.1 the scale of the plan which must be at least a scale of 1:500; 6.2 the property boundaries and numbers of all the properties within 50 metres of the site; 6.3 the current land use as well as the land use zoning of each of the properties adjoining the site or

sites; 6.4 the exact position of each element of the application as well as any other structures on the site; 6.5 the position of services, including electricity supply cables (indicate above or underground), water

supply pipelines, boreholes, street lights, sewage pipelines, storm water infrastructure and telecommunication infrastructure;

6.6 all trees and shrubs taller than 1.8 metres; 6.7 walls and fencing including details of the height and construction material; 6.8 servitudes indicating the purpose of the servitude; 6.9 sensitive environmental elements within 100 metres of the site or sites including (but not limited

thereto): rivers; the 1:100 year flood line (where available or where it is required by DWA); ridges; cultural and historical features; areas with indigenous vegetation (even if it is degraded or invested with alien species);

6.9 for gentle slopes the 1 metre contour intervals must be indicated on the plan and whenever the slope of the site exceeds 1:10, the 500mm contours must be indicated on the plan; and

6.10 the positions from where photographs of the site were taken.



7. SITE PHOTOGRAPHS Colour photographs from the centre of the site must be taken in at least the eight major compass directions with a description of each photograph. Photographs must be attached under Appendix B to this form. It must be supplemented with additional photographs of relevant features on the site, if applicable. 8. FACILITY ILLUSTRATION A detailed illustration of the activity must be provided at a scale of 1:200 as Appendix C for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity. 9. ACTIVITY MOTIVATION 9(a) Socio-economic value of the activity

What is the expected capital value of the activity on completion? Not known

What is the expected yearly income that will be generated by or as a result of the activity?

Not known

Will the activity contribute to service infrastructure? YES NO

Is the activity a public amenity? YES NO

How many new employment opportunities will be created in the development phase of the activity?

Not known

What is the expected value of the employment opportunities during the development phase?

Not known

What percentage of this will accrue to previously disadvantaged individuals? Not known

How many permanent new employment opportunities will be created during the operational phase of the activity?

Not known

What is the expected current value of the employment opportunities during the first 10 years?

Not known

What percentage of this will accrue to previously disadvantaged individuals? Not known

9(b) Need and desirability of the activity Motivate and explain the need and desirability of the activity (including demand for the activity):

The economic gain of installing a new LPG facility is important as the MBSA represents a significant economic driver in the BCMM. It is important to decommission the existing LPG tanks in order to reduce the risk of infrastructure failure as these tanks need to be replaced. The new LPG tank has technical specifications that use the latest technology to reduce environmental and health and safety risks.

Indicate any benefits that the activity will have for society in general:

Society will benefit from these tanks by the increased productivity of the MBSA plant as MBSA represents one of the largest foreign investments in the country. MBSA also has a strong tradition of social responsibility, through various social development projects.

Indicate any benefits that the activity will have for the local communities where the activity will be located:

The activity is located in an industrial area with the nearest residential areas catering for low income groups that are employed either within the East London Port or this industrial area.



10. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations, if applicable: Title of legislation, policy or guideline:

Administering authority:

Date:

Hazardous Substances Act No. 15 National Department of Health 1973

National Water Act No. 36 National Department of Water Affairs

1998

National Water Services Act No. 108 National Department of Water Affairs

1997

Occupational Health and Safety Act No. 85 National Department of Health 1993

National Environmental Management: Air Quality Act No. 39

DEDEAT: Regional Air Pollution Control Office

2004

National Environmental Management: Waste Management Act No. 59

DEDEAT: Regional Waste Management

2008

11. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT 11(a) Solid waste management

Will the activity produce solid construction waste during the construction/initiation phase?

YES NO

If yes, what estimated quantity will be produced per month? 12m3

How will the construction solid waste be disposed of (describe)?

Non-hazardous waste will be disposed of at Roundhill landfill and hazardous waste will be removed by a specialist waste contractor and disposed of in an appropriate landfill.

Where will the construction solid waste be disposed of (describe)?

Non-hazardous waste will be disposed of at Roundhill landfill and hazardous waste will be removed by a specialist waste contractor and disposed of in an appropriate landfill.

Will the activity produce solid waste during its operational phase? YES NO

If yes, what estimated quantity will be produced per month? m3

How will the solid waste be disposed of (describe)?

N/A

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

N/A

If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site or be taken up in a municipal waste stream, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the relevant legislation?

YES NO

If yes, inform the competent authority and request a change to an application for scoping and EIA.

Is the activity that is being applied for a solid waste handling or treatment facility?

YES NO

If yes, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA. 11(b) Liquid effluent



Will the activity produce effluent, other than normal sewage, that will be disposed of in a municipal sewage system?

YES NO

If yes, what estimated quantity will be produced per month? m3

Will the activity produce any effluent that will be treated and/or disposed of on-site?

Yes NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Will the activity produce effluent that will be treated and/or disposed of at another facility?

YES NO

If yes, provide the particulars of the facility:

Facility name:

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

11(c) Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO


If no, describe the emissions in terms of type and concentration:

N/A

11(d) Generation of noise

Will the activity generate noise? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO


If no, describe the noise in terms of type and level:

N/A

12. WATER USE Please indicate the source(s) of water that will be used for the activity by ticking the appropriate box(es)

municipal water board groundwater river, stream, dam or lake

other the activity will not use water

If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please indicate

the volume that will be extracted per month: litres

Does the activity require a water use permit from the Department of Water Affairs? YES NO



If yes, please submit the necessary application to the Department of Water Affairs and attach proof thereof to this application if it has been submitted. 13. ENERGY EFFICIENCY Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

none

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

none



SECTION B: SITE/AREA/PROPERTY DESCRIPTION Important notes:

1. For linear activities (pipelines, etc) as well as activities that cover very large sites, it may be necessary to complete this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section C and indicate the area, which is covered by each copy No. on the Site Plan.

Section C Copy No. (e.g. A):

2. Paragraphs 1 - 6 below must be completed for each alternative.

3. Has a specialist been consulted to assist with the completion of this section?

YES NO

If YES, please complete form XX for each specialist thus appointed: All specialist reports must be contained in Appendix D. 1. GRADIENT OF THE SITE Indicate the general gradient of the site. Alternative S1:

Flat 1:50 – 1:20

1:20 – 1:15

1:15 – 1:10 1:10 – 1:7,5

1:7,5 – 1:5 Steeper than 1:5

Alternative S2 (if any):

Flat 1:50 – 1:20

1:20 – 1:15

1:15 – 1:10 1:10 – 1:7,5

1:7,5 – 1:5 Steeper than 1:5

Alternative S3 (if any):

Flat 1:50 – 1:20

1:20 – 1:15

1:15 – 1:10 1:10 – 1:7,5

1:7,5 – 1:5 Steeper than 1:5

2. LOCATION IN LANDSCAPE Indicate the landform(s) that best describes the site: 2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront



3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE Is the site(s) located on any of the following (tick the appropriate boxes)? Alternative S1: Alternative S2

(if any): Alternative S3

(if any):

Shallow water table (less than 1.5m deep)

YES NO YES NO YES NO

Dolomite, sinkhole or doline areas


Seasonally wet soils (often close to water bodies)


Unstable rocky slopes or steep slopes with loose soil


Dispersive soils (soils that dissolve in water)


Soils with high clay content (clay fraction more than 40%)


Any other unstable soil or geological feature


An area sensitive to erosion


If you are unsure about any of the above or if you are concerned that any of the above aspects may be an issue of concern in the application, an appropriate specialist should be appointed to assist in the completion of this section. (Information in respect of the above will often be available as part of the project information or at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by the Council for Geo Science may also be consulted). 4. GROUNDCOVER Indicate the types of groundcover present on the site: 4.1 Natural veld – good condition E 4.2 Natural veld – scattered aliens E 4.3 Natural veld with heavy alien infestation E 4.4 Veld dominated by alien species E 4.5 Gardens 4.6 Sport field 4.7 Cultivated land 4.8 Paved surface 4.9 Building or other structure 4.10 Bare soil The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld - good conditionE

Natural veld with scattered aliensE

Natural veld with heavy alien infestationE

Veld dominated by alien speciesE

Gardens



Sport field Cultivated land Paved surface Building or other structure

Bare soil

If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to assist in the completion of this section if the environmental assessment practitioner doesn’t have the necessary expertise. 5. LAND USE CHARACTER OF SURROUNDING AREA Indicate land uses and/or prominent features that currently occur within a 500m radius of the site and give description of how this influences the application or may be impacted upon by the application: 5.1 Natural area 5.2 Low density residential 5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial 5.8 Medium industrial AN 5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility 5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N 5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland 5.35 Nature conservation area 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building



5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe) If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. There will be no impact. If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity. If YES, specify and explain: There will be no impact. If YES, specify: If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity. If YES, specify and explain: If YES, specify:

Figure 11: The surrounding area and properties within a 500m radius of the proposed 400m3 LPG facility.

Second Creek

Landfill site



6. CULTURAL/HISTORICAL FEATURES

Are there any signs of culturally or historically significant elements, as defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including

YES NO

Archaeological or palaeontological sites, on or close (within 20m) to the site?

Uncertain

If YES, explain:

N/A

If uncertain, conduct a specialist investigation by a recognised specialist in the field to establish whether there is such a feature(s) present on or close to the site.

Briefly explain the findings of the specialist:

N/A

Will any building or structure older than 60 years be affected in any way? YES NO

Is it necessary to apply for a permit in terms of the National Heritage Resources Act, 1999 (Act 25 of 1999)?

YES NO

If yes, please submit or, make sure that the applicant or a specialist submits the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application if such application has been made.



SECTION C: PUBLIC PARTICIPATION 1. ADVERTISEMENT

The person conducting a public participation process must take into account any guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of the application which is subjected to public participation by— (a) fixing a notice board (of a size at least 60cm by 42cm; and must display the required

information in lettering and in a format as may be determined by the competent authority) at a place conspicuous to the public at the boundary or on the fence of— (i) the site where the activity to which the application relates is or is to be undertaken; and

(ii) any alternative site mentioned in the application; (b) giving written notice to—

(i) the owner or person in control of that land if the applicant is not the owner or person in control of the land;

(ii) the occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

(iii) owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

(iv) the municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area;

(v) the municipality which has jurisdiction in the area; (vi) any organ of state having jurisdiction in respect of any aspect of the activity; and (vii) any other party as required by the competent authority;

(c) placing an advertisement in— (i) one local newspaper; or

(ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

(d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in subregulation 54(c)(ii); and

(e) using reasonable alternative methods, as agreed to by the competent authority, in those instances where a person is desiring of but unable to participate in the process due to— (i) illiteracy; (ii) disability; or (iii) any other disadvantage.

2. CONTENT OF ADVERTISEMENTS AND NOTICES A notice board, advertisement or notices must: (a) indicate the details of the application which is subjected to public participation; and (b) state—

(i) that the application has been submitted to the competent authority in terms of these Regulations, as the case may be; (ii) whether basic assessment or scoping procedures are beingapplied to the

application, in the case of an application for environmental authorisation;



(iii) the nature and location of the activity to which the application relates; (iv) where further information on the application or activity can be obtained; and (iv) the manner in which and the person to whom representations in respect of the

application may be made. 3. PLACEMENT OF ADVERTISEMENTS AND NOTICES Where the proposed activity may have impacts that extend beyond the municipal area where it is located, a notice must be placed in at least one provincial newspaper or national newspaper, indicating that an application will be submitted to the competent authority in terms of these regulations, the nature and location of the activity, where further information on the proposed activity can be obtained and the manner in which representations in respect of the application can be made, unless a notice has been placed in any Gazette that is published specifically for the purpose of providing notice to the public of applications made in terms of the EIA regulations. Advertisements and notices must make provision for all alternatives. Proof of advert placed in the Daily Dispatch 17 January 2014:



Proof of notice placed on site:

4. DETERMINATION OF APPROPRIATE MEASURES The practitioner must ensure that the public participation is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees, ratepayers associations and traditional authorities where appropriate. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was inadequate. 5. COMMENTS AND RESPONSE REPORT The practitioner must record all comments and respond to each comment of the public before the application is submitted. The comments and responses must be captured in a comments and response report as prescribed in the EIA regulations and be attached to this application. The comments and response report must be attached under Appendix E. 6. AUTHORITY PARTICIPATION Authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and the environmental sections of the local authority must be informed of the application at least 30 (thirty) calendar days before the submission of the application.



List of authorities informed: Organisation Contact Tel / Fax E-mail

BCMM: Health Alan McIntire (043) 705 2928 (043) 722 4840

[email protected]

BCMM: Integrated Environmental Management Unit

Jane K (043) 705 1010 (043) 705 1795

[email protected]

BCMM: Fire & Rescue Services

Darren Baulch (043) 705 9005 /6/7 [email protected]

BCMM: Disaster Management

Owen Bekker (043) 743 7118 [email protected]

Ward 46 Councillor Councillor Nontsikelelo Priscilla Peter

071 925 1350 None


Andrew Lucas (043) 722 3805 [email protected]


Landile Jack (043) 748 5340 [email protected]

Port of East London, Transnet National Ports Authority

Thys Coetzee (043) 700 1200/2420 [email protected]

List of authorities from whom comments have been received:

BCMM Disaster Management and BCMM Fire & Rescue (Please refer to Appendix E for comments and stakeholder meeting minutes).

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]



7. CONSULTATION WITH OTHER STAKEHOLDERS Note that, for linear activities, or where deviation from the public participation requirements may be appropriate, the person conducting the public participation process may deviate from the requirements of that subregulation to the extent and in the manner as may be agreed to by the competent authority. Any stakeholder that has a direct interest in the site or property, such as servitude holders and service providers, should be informed of the application at least 30 (thirty) calendar days before the submission of the application and be provided with the opportunity to comment.

Has any comment been received from stakeholders? YES NO

If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application):



(Please refer to appendix E for comments and stakeholder meeting minutes)

BCMM- Disaster Management (Owen Bekker) A Major Hazards Investigation (MHI) is necessary for the new tank. This should include the risk of the substation as a risk factor if there is an explosion. Appropriate prevention, mitigation and preventative measures will need to be discussed to address the identified risks. SANS specifies that a drain must not occur closer than 3m to the installation. The proposed installation is more than 3m away but it may still be useful to note this detail. This is a problem as LPG will flow to the lowest point, which would include the stormwater drain.

BCMM- Fire & Rescue (Darren Baulch) There needs to be a MHI and that they need to review the report. The BCMM Fire & Rescue department has requested to be linked to the telemetry system. MBSA- Fire Department (Wayne Blair Brown) Requested to be linked to the telemetry system. Total South Africa (Shane Scheel)

While the calculations for a BLEVE have been based on the tank capacity of 400 m3, what if a BLEVE were to occur during delivery. As you have indicated the tank will be buried but has the delivery truck and it volume been taken into consideration along with the tank?

Will any fixed firefighting equipment be installed with the tank? I am aware that MBSA does have their own fire department but with this capacity there should be a fixed fire fighting system in place.

Engen South Africa (Nonhlanhle Taylor)

What is the exact Location /position of the Bullet on the Site. This position may have an impact if it is closer to BP building, I need to see the exact distance from the Bullet to the BP building.

The MHI document for the proposed Bullet? I need to see the radiation risks, societal Risks, FN Curve and the basis of their study including the software used for modeling.

Engenoil South Africa (Stephen Keddle)

In the assessment you have spoken about a BLEVE but you have not shown the effects of such an incident on the surrounding community.

If the tank is to be covered by an earth mound, what precautions are going to be taken to prevent corrosion taking place which could weaken the tank shell.



SECTION D: IMPACT ASSESSMENT The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2010, and should take applicable official guidelines into account. The issues raised by interested and affected parties should also be addressed in the assessment of impacts. 1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES List the main issues raised by interested and affected parties.

The main issue raised by the BCMM Fire and Rescue and BCMM Disaster Management has been the health and safety considerations with regards to the fire hazard and explosive risk the 400m3 LPG facility entails. It has been raised that a Major Hazard Investigation (MHI) is needed. The surrounding petrol stations have also voiced their concern, but have realised that they are far enough away from the LPG facility to limit their concern.

Response from the practitioner to the issues raised by the interested and affected parties (A full response must be given in the Comments and Response Report that must be attached to this report):

The 400m3 LPG tank represents the latest technology currently available, designed with this risk in mind. The tank will also be mounded to decrease the explosive risk. The site proposed for the installation has been determined to be appropriate.

2. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION, OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES List the potential direct, indirect and cumulative property/activity/design/technology/operational alternative related impacts (as appropriate) that are likely to occur as a result of the planning and design phase, construction phase, operational phase, decommissioning and closure phase, including impacts relating to the choice of site/activity/technology alternatives as well as the mitigation measures that may eliminate or reduce the potential impacts listed. 3. ENVIRONMENTAL IMPACT STATEMENT Taking the assessment of potential impacts into account, please provide an environmental impact statement that summarises the impact that the proposed activity and its alternatives may have on the environment after the management and mitigation of impacts have been taken into account, with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts. Alternative A (preferred alternative)

The preferred alternative involves the installation of the 400m3 LPG facility.

No-go alternative (compulsory)

The no-go alternative refers to the 400m3 LPG facility not being installed. Given the strategic importance of the cars being produced, it is not considered feasible to consider the no-go alternative. MBSA is positioned within an existing area, and as such the installation of a mounded LPG tank is not out of place. Refusal to authorise this tank would result in serious consequence for MBSA, its staff and East London’s economy in general.

SUMMARY OF THE PROPOSED DEVELOPMENT



MBSA proposes to install a 400m3 LPG facility to supply LPG vapour to the paint shops at its East London plant located on the West Bank of East London, Buffalo City Metro Municipality in the Eastern Cape Province. The facility would replace the existing 2 x 45m3 LPG facility, which would need to be decommissioned. CONSIDERATION OF ALTERNATIVES As the proposed tank represents the highest standard of underground fuel tank installation, and surpasses the SANS requirements, no other material alternatives will be considered in this report.

SUMMARY OF SIGNIFICANT IMPACTS (all impacts that are High pre-mitigation) The proposed development will result in a number of impacts, both positive and negative, during the Planning and Design, Construction and Operation Phases (see table below). The phase with the highest number of impacts is the design phase; however these impacts are not rated as significant. The following table provides a summary of the pre-mitigation impacts that were ranked as HIGH.

PLANNING & DESIGN PHASE

Impacts Significance

pre-mitigation

Significance post-

mitigation

Overfilling of the LPG tank HIGH LOW

Fire in the vicinity of the LPG tank HIGH LOW

Corrosion of pipelines HIGH LOW

CONSTRUCTION PHASE


pre-mitigation

Significance post-

mitigation

Project contract and programme availability HIGH LOW

Appointments and duties of project team are neglected

HIGH LOW

Emergencies, non-compliance and communication method statements not provided

HIGH LOW

Safety and Emergency Plans not provided HIGH MODERATE

OPERATIONAL PHASE


pre-mitigation

Significance post-

mitigation

Economic

HIGH HIGH (Positive)



SUMMARY OF IMPACT ASSESSMENT SIGNIFICANCE, PRE- AND POST-MITIGATION

PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH LOW MODERATE HIGH

Planning and

Design 5 2 3 10 0 0

Construction 3 7 4 13 1 0

Operation 2 10 1+1(+) 12 1 1(+)

Decommissioning 2 5 0 6 1 0

TOTAL 12 24 8+1(+) 41 3 1(+)



SECTION E. RECOMMENDATIONS OF PRACTITIONER

Is the information contained in this report and the documentation attached hereto sufficient to make a decision in respect of the activity applied for (in the view of the environmental assessment practitioner)?

YES NO

Is an EMPr attached? YES NO

The EMPr must be attached as Appendix F. If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA process before a decision can be made (list the aspects that require further assessment):

N/A

If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:

MITIGATION MEASURES

Planning and Design Phase Geotechnical considerations

- A geotechnical survey of the site may be necessary to determine whether the LPG tank will be stable on the ground.

Overfilling of the LPG tank

- No further mitigation is needed other that what is already included in the technical design.

- Ensure design safety features are effective.

Fire in the vicinity of the LPG tank

- No further mitigation is needed other than what is already included in the technical design.

- Ensure design safety features are effective.

Surface water run-off Storm water management

- The LPG facility should be l

dedeat reference: ec/7/a/ln1/13/13-19 400m3 lpg facility lbri31.1.14/mbsa afrox... · reviewer dr...

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