NEOPAK COMBINED HEAT AND POWER (CHP) PLANT, ROSSLYN, …

ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

BASIC ASSESSMENT REPORT

NEOPAK COMBINED HEAT AND POWER

(CHP) PLANT,

ROSSLYN, GAUTENG

FEBRUARY 2017

Prepared for:Neopak (Pty) Ltd

37 Homestead Road

Sandton

2128

Prepared by:

Savannah Environmental (Pty) Ltd

First Floor, Block 2, 5 Woodlands Drive Office Park

Woodmead

Johannesburg, 2191

Tel: +27 (0)11 656 3237

Fax: +27 (0)86 684 0547

E-mail: [email protected]

www.savannahsa.com

(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, 2014 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. This report format is current as of 08 December 2014. It is the responsibility of the applicant

to ascertain whether subsequent versions of the form have been published or produced

by the competent authority.

3. 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.

4. Where applicable tick the boxes that are applicable in the report.

5. An incomplete report may be returned to the applicant for revision.

6. 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.

7. This report must be handed in at offices of the relevant competent authority as determined

by each authority.

8. No faxed or e-mailed reports will be accepted.

9. The signature of the EAP on the report must be an original signature.

10. The report must be compiled by an independent environmental assessment practitioner.

11. 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.

12. A competent authority may require that for specified types of activities in defined situations

only parts of this report need to be completed.

13. Should a specialist report or report on a specialised process be submitted at any stage for

any part of this application, the terms of reference for such report must also be submitted.

14. Two (2) colour hard copies and one (1) electronic copy of the report must be submitted to

the competent authority.

15. Shape files (.shp) for maps must be included on the electronic copy of the report submitted

to the competent authority.

NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017

Project Details Page i

PROJECT DETAILS

When used as a reference this report should be cited as: Savannah Environmental (2017) Basic

Assessment Report: Neopak Combined Heat and Power (CHP) Plant, Rosslyn, Gauteng.

COPYRIGHT RESERVED

This technical report has been produced for Neopak (Pty) Ltd. The intellectual property contained in this report

remains vested in Savannah Environmental (Pty) Ltd and Neopak (Pty) Ltd. No part of the report may be

reproduced in any manner without written permission from Neopak (Pty) Ltd or Savannah Environmental (Pty) Ltd.

Title : Environmental Assessment Process

Basic Assessment Report: Neopak Combined Heat and

Power (CHP) Plant, Rosslyn, Gauteng

Authors : Savannah Environmental

Lisa Opperman

Karen Jodas

Gabriele Wood

Specialist : uMoya-NILU Consulting

Applicant : Neopak (Pty) Ltd

Report Status : Basic Assessment Report for Review

Review Period : 28 February 2017 – 31 March 2017


Table of Contents Page ii

TABLE OF CONTENTS

PAGE

PROJECT DETAILS .................................................................................................................................... i

TABLE OF CONTENTS.............................................................................................................................. ii

APPENDICES .......................................................................................................................................... iv

SUMMARY AND OVERVIEW OF THE PROJECT...................................................................................... v

1.1. NEED AND DESIRABILITY FOR THE COMBINED HEAT AND POWER (CHP) PLANT .......... ix

1.2. REQUIREMENTS FOR A BASIC ASSESSMENT PROCESS ...............................................x

1.3. DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER AND EXPERTISE TO CONDUCT

THE BASIC ASSESSMENT .................................................................................... xiv

1.4. ASSUMPTIONS AND LIMITATIONS ....................................................................... xvi

BASIC ASSESSMENT REPORT FOR REVIEW ........................................................................................ xvii

SECTION A: ACTIVITY INFORMATION................................................................................................... 1

1. PROJECT DESCRIPTION ...................................................................................... 1

a) Describe the project associated with the listed activities applied for ........................1

b) Provide a detailed description of the listed activities associated with the project as

applied for...............................................................................................................................3

2. FEASIBLE AND REASONABLE ALTERNATIVES........................................................... 3

a) Site alternatives ......................................................................................................................4

b) Technological alternatives...................................................................................................6

c) Layout alternatives ................................................................................................................7

d) Other alternatives (e.g. scheduling, demand, input, scale and design alternatives)

...................................................................................................................................................7

e) No-go alternative ..................................................................................................................8

3. PHYSICAL SIZE OF THE ACTIVITY ........................................................................... 8

4. SITE ACCESS ..................................................................................................... 9

5. LOCALITY MAP ................................................................................................. 9

6. LAYOUT/ROUTE PLAN .......................................................................................10

7. SENSITIVITY MAP...............................................................................................10

8. SITE PHOTOGRAPHS .........................................................................................14

9. FACILITY ILLUSTRATION ......................................................................................14

10. ACTIVITY MOTIVATION ......................................................................................14

11. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES .....................................20

12. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT .......................................27

a) Solid waste management................................................................................................. 27

b) Liquid effluent ...................................................................................................................... 28

c) Emissions into the atmosphere ......................................................................................... 29

d) Waste permit........................................................................................................................ 31

e) Generation of noise ........................................................................................................... 31

13. WATER USE ......................................................................................................32

14. ENERGY EFFICIENCY .........................................................................................32

SECTION B: SITE/AREA/PROPERTY DESCRIPTION...............................................................................33

1. GRADIENT OF THE SITE ......................................................................................34

2. LOCATION IN LANDSCAPE ................................................................................34

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE.............................34

4. GROUNDCOVER..............................................................................................35

5. SURFACE WATER ..............................................................................................35


Table of Contents Page iii

6. LAND USE CHARACTER OF SURROUNDING AREA .................................................36

7. CULTURAL/HISTORICAL FEATURES .......................................................................37

8. SOCIO-ECONOMIC CHARACTER .......................................................................37

a) Local Municipality............................................................................................................... 37

b) Socio-economic value of the activity ............................................................................ 38

9. BIODIVERSITY ...................................................................................................39

a) Indicate the applicable biodiversity planning categories of all areas on site and

indicate the reason(s) provided in the biodiversity plan for the selection of the

specific area as part of the specific category)............................................................ 39

b) Indicate and describe the habitat condition on site .................................................. 40

c) Complete the table to indicate: ..................................................................................... 40

d) Please provide a description of the vegetation type and/or aquatic ecosystem

present on site, including any important biodiversity features/information identified

on site (e.g. threatened species and special habitats).............................................. 41

SECTION C: PUBLIC PARTICIPATION...................................................................................................42

1. ADVERTISEMENT AND NOTICE............................................................................42

2. DETERMINATION OF APPROPRIATE MEASURES......................................................42

3. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ...........................................43

4. COMMENTS AND RESPONSE REPORT ..................................................................43

5. AUTHORITY PARTICIPATION................................................................................43

6. CONSULTATION WITH OTHER STAKEHOLDERS .......................................................44

SECTION D: IMPACT ASSESSMENT ......................................................................................................46

1. 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 .....46

Planning Phase.........................................................................................................46

1.1 Construction and Operation Phase ...................................................................47

1.2 Decommissioning Phase...................................................................................53

1.3 The No-Go Alternative .....................................................................................55

2. ENVIRONMENTAL IMPACT STATEMENT.................................................................55

SECTION E: RECOMMENDATION OF PRACTITIONER .........................................................................59

SECTION F: APPENDICES .....................................................................................................................61


Appendices Page iv

APPENDICES

Appendix A: A3 Maps

Appendix A1: Locality Map

Appendix A2: Layout Map

Appendix A3: Sensitivity Map

Appendix A4: Sensitivity Map of the broader area

Appendix B: Site Photographs

Appendix C: Facility Illustration

Appendix D: Specialist(s)

Appendix D1: Atmospheric Impact Report

Appendix E: Public Participation

Appendix E1: Site Notices and Newspaper adverts

Appendix E2: Proof of Stakeholder Correspondence

Appendix E3: Authority Consultation

Appendix E4: I&AP Database

Appendix E5: Comments Received – to be included in the Final BAR

Appendix E6: Comments and Responses Report – to be included in the Final BAR

Appendix F: Impact Assessment

Appendix G: Environmental Management Programme (EMPr)

Appendix A: Layout Map

Appendix B: Grievance Mechanism for Public Complaints and Issues

Appendix C: Project Team CVs

Appendix H: EAP Declaration, Affirmation and CVs

Appendix I: Specialist Declaration


Summary and project overview Page v

SUMMARY AND OVERVIEW OF THE PROJECT

Neopak (Pty) Ltd propose to develop a Combined Heat and Power (CHP) gas turbine at the

existing Neopak Facility in Rosslyn, Gauteng. The project is known as the Neopak CHP Plant. The

existing Neopak paper mill facility in Rosslyn is located on a site located within Portion 3 of Erf 39,

Portion 1 of Erf 41 and Erf 40 (the affected properties)1. The development area2 proposed for

the CHP Plant is located within the existing Neopak paper mill facility (project site)3, and is the

area within which the construction and operation of the CHP Plant will take place. These

properties are considered to be a brownfields site4 which has been transformed through

industrial development (refer to Figure 1 and Table1 for more detail). A development footprint5

of approximately 675m2 has been identified within the existing Neopak facility and the

development area for the construction and operation of the CHP Plant (refer to Figure 2). The

general area is of an industrial nature, as Rosslyn is an industrialised area and includes industries

such as the BMW factory and the Nissan South Africa factory.

Table 1: Location of the Neopak CHP Plant project site, within the existing Neopak Paper Mill

Province Gauteng Province

Municipality City of Tshwane Metropolitan Municipality

Ward number(s) 98

Nearest town(s) The project site is located within Rosslyn which is an industrial area

within Pretoria. The project site is located ~23km north of the Pretoria

Central Business District.

Farm name(s) and number(s) Surveyor-General Database

» Portion 3 of Erf 39


» Erf 40

City of Tshwane City Planning and Development Department

» Parcel 514 Rosslyn, 6953 Hendrik van Eck Street

SG 21 Digit Code Surveyor-General Database

» T0JR02220000003900003

» T0JR02220000004100001

» T0JR02220000004000000

1The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced fromthe Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrikvan Eck Street as per the City of Tshwane City Planning and Development Department.

2 The development area is the identified location within the project site within which the CHP Plant will be sited. The

development area will include the development footprint, which will house the CHP turbine as well as the associated

linear infrastructure including gas lines and cabling. The development area is approximately 1.3ha in extent.3 The project site is defined the existing Neopak paper mill facility located in Rosslyn, Gauteng. The project site includes

three affected properties namely Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40.4 A brownfields site can be described as land previously or currently developed and used for industrial purposes or

commercial purposes. Such land is considered to be transformed, and degraded to an extent that the natural

environmental attributes are considered to be minimal.5The development footprint is the area identified within the development area to house the CHP Plant. The development

footprint is approximately 0.0675ha / 675m2 in extent.


Summary and project overview Page vi

The Neopak Facility currently uses natural gas in a gaseous form and coal to generate steam for

use in the current paper mill operations. Neopak are now proposing the development of a CHP

Plant to pass the same gas through a gas turbine to generate both steam and electricity. This

development will be aiding and adding to the production of steam which is currently being

produced by coal and gas fired boilers on-site and also generate electricity. The purpose of the

project is, therefore, to produce both power and steam, rather than just steam which is currently

being produced by existing boilers located within the plant:

1. The steam produced by the CHP plant will be used for the operations of the paper mill

facility,

2. The electricity produced will be evacuated via an 11kV cable to an existing substation

located within the Neopak Facility.

The development will provide the opportunity for a more efficient use of the available energy,

effectively delivering a proportion of “free” conversion to electricity generation. The basic

operation of the proposed CHP Plant includes the following:

» Inlet air is filtered and ducted into multiple compression stages.

» Natural gas is fed into the combustion chamber, mixed with the compressed air and then

combusted.

» The combustion exhaust drives a series of turbine blades to provide rotational force to the

drive shaft.

» Electricity is produced through a generator connected to the drive shaft, which generates

the power component of the plant.

» Hot gases exiting the turbine at 500°C, contain a high level of energy and are ducted to a

heat recovery steam generator which generates the steam component of the plant.

» Final products of the combustion is exhausted to the atmosphere via flue.

The Neopak Facility site can be accessed via the regional road (R556) located to the north of

the project site and various secondary roads surrounding the area. The area surrounding the

project site and the site itself is of a highly industrial nature and is currently being used for the

operation of a paper mill, specifically for the production of cardboard boxes.

As the generation capacity of the CHP Plant (9.9 to 12MW) exceeds the threshold as stipulated

in Listing Notice 1 of the EIA Regulations, 2014, Savannah Environmental (Pty) Ltd has been

appointed by Neopak (Pty) Ltd in order to make an Application for Environmental Authorisation

in terms of the EIA Regulations, 2014 for the construction and operation of the CHP Plant.

The nature and extent of the plant, and the potential environmental impacts associated with

the construction, operation and decommissioning phases are explored in more detail in this

Basic Assessment Report. This report has been compiled in accordance with the requirements

of the EIA Regulations, 2014 and includes details of the activity description; the site, area and

property description; the public participation process; the impact assessment; as well as the

recommendations proposed by the Environmental Assessment Practitioner.


Summary and Project Overview Page vii

Figure 1: Locality map indicating the affected properties and the project site proposed for the Neopak CHP Plant


Summary and Project Overview Page viii

Figure 2: Locality map indicating the development area and the development footprint of the Neopak CHP Plant in the existing Neopak Facility


Summary and Project Overview Page ix

1.1. NEED AND DESIRABILITY FOR THE COMBINED HEAT AND POWER (CHP) PLANT

Globally there is increasing pressure to optimise energy usage in order to reduce

environmental impacts associated with the use of non-renewable energy resources. The

development of the CHP plant at the existing Neopak Facility will provide the opportunity to

optimise and fully utilise an available energy resource (natural gas is currently piped to the

site), as well as reduce the facility’s dependence on coal (which is combusted in the process

of raising steam for use at the current facility). Also, natural gas produces fewer emissions than

oil and coal and CHP systems capture and utilise heat that would otherwise be wasted from

the production of electricity. The CHP Plant will provide the opportunity to maximise and

optimise the use of the already available natural gas at the site.

The Combined Heat and Power (CHP) Plant proposed for the Neopak facility will not only fulfil

the role of raising steam required for use in the paper mill, but will also generate electricity for

own-use and/or export via the local electricity grid. The plant will combust natural gas to drive

a series of turbine blades and generates electricity (the power component of the plant). Hot

gases exiting the turbine at 500°C contain a high level of energy and are to be ducted to a

heat recovery steam generator which will generate the steam component of the plant. This

method of steam generation requires a considerably less amount of fuel in relation to the

conventional boilers currently installed and operating at the site.

The main objectives for the generation of electricity is to reduce the Neopak Facility’s reliance

on the municipal electricity supply, stabilise the power supply to the Neopak operations (i.e.

secure electricity supply without disruption), and strengthen the electricity capacity within an

area where significant constraints are being experienced. The installation of the CHP Plant will

provide a more efficient solution to address Neopak’s steam generation needs, while

simultaneously generating power and strengthening current supply to the site.

The following benefits are also considered to be associated with the development of the CHP

Plant:

» A lower carbon footprint will be the result of the implementation of the CHP Plant at the

Neopak facility.

» There will be a significant increase in energy efficiency as the already available natural

gas utilised will be implemented for both the operation of the existing Neopak Facility and

for the generation of electricity for the facility itself and potentially the surrounding

businesses.

» The national grid will be strengthened due to the reduced supply pressure which is currently

applied by the Neopak facility.

» Positive economic growth through secured electricity supply.

» There will be an increase in cost competitiveness of the Neopak facility, enabling exports,

growth and job creation.

» The CHP Plant will also extend the life of the production line of the facility thereby assisting

in the safeguarding of local employment and economic growth within the local

communities and the country as a whole.


Summary and Project Overview Page x

» The introduction of innovative technology for the generation of both steam and electricity

being implemented in South Africa which provides the opportunity to move away from

conventional generation methods, including the use of coal. The associated skills transfer

and demonstration effects of the proposed technology provides a learning opportunity for

future developments of this nature.

From an overall sensitivity and planning perspective, the proposed project infrastructure is not

considered contrary to the broader strategic context of the surrounding area due to the

severely industrialised nature of the area as a whole. The plant is also considered to be in line

with broader societal needs and the public interest as it is linked to electricity generation

without the use of coal as the energy source. No exceedance of environmental limits will result

from the development of the Neopak CHP Plant, and no impacts of significance would be

associated with the project due to the location of the plant within a highly transformed area

within the Rosslyn industrial area.

1.2. REQUIREMENTS FOR A BASIC ASSESSMENT PROCESS

In terms of the Environmental Impact Assessment (EIA) Regulations published in terms of

Section 24(5) of the National Environmental Management Act (NEMA, Act No. 107 of 1998),

Neopak (Pty) Ltd requires Environmental Authorisation for the development of the CHP Plant.

In terms of Sections 24 and 24D of the National Environmental Management Act (No 107 of

1998), as read with the EIA Regulations of GN R982 – R985, a Basic Assessment process is

required to be undertaken in support of the application for authorisation for the proposed

project.

The primary Listed Activity triggered under GN R983 is Activity 2 which relates to the

development and related operation of facilities or infrastructure for the generation of

electricity from a non-renewable resource where the electricity output is more than 10MW but

less than 20MW. The CHP Plant will, through the installation of a gas turbine, generate

electricity of 9.9 to 12MW, therefore triggering the listed activity and requiring an application

for Environmental Authorisation.

In terms of Section 24(1) of NEMA, the potential impact on the environment associated with

the activity must be considered, investigated, assessed and reported on to the competent

authority that has been charged by NEMA with the responsibility of granting environmental

authorisations. As the application is related to the generation of electricity, the National

Department of Environmental Affairs (DEA) is the competent authority6, and the Gauteng

Department of Agriculture and Rural Development (GDARD) will act as the commenting

authority. This project will be registered with the DEA through submission of an Application for

Environmental Authorisation.

The nature and extent of the CHP Plant at the Neopak Facility is explored in more detail in this

Basic Assessment Report. This report has been compiled in accordance with the requirements

of the EIA Regulations of December 2014 (as per Table 2 below), and includes details of the

6 In terms of the Energy Response Plan and Government Notice 779 of 01 July 2016, the DEA is the competent authorityfor all energy related applications.


Summary and Project Overview Page xi

activity description; the site, area and property description; the public participation process;

the impact assessment; and the recommendations of the Environmental Assessment

Practitioner (EAP).

Table 2: Legal Requirements of GN. R. 982, Appendix 1 included in the 2014 EIA Regulations

NEMA REGULATION GNR 982, SECTION 19 REQUIREMENTS FOR THE

CONTENT OF BASIC ASSESSMENT REPORTS AS PER APPENDIX 1

CROSS REFERENCE IN THIS REPORT

(refer to the following parts in the

report)

(1) A basic assessment report must contain the information that

is necessary for the competent authority to consider and

come to a decision on the application, and must include—

(a) details of—

(i) the EAP who prepared the report; and

Section 1.3

(ii) the expertise of the EAP, including a curriculum vitae; Section 1.3

Appendix H

(b) the location of the activity, including:

(i) the 21 digit Surveyor General code of each cadastral

land parcel;

Section B

(ii) where available, the physical address and farm name; Section B

(iii) where the required information in items (i) and (ii) is not

available, the coordinates of the boundary of the

property or properties;

Section A (2) (a)

(c) a plan which locates the proposed activity or activities

applied for as well as associated structures and infrastructure

at an appropriate scale;

Appendix A1 and Appendix A2

Appendix C

or, if it is—

(i) a linear activity, a description and coordinates of the

corridor in which the proposed activity or activities is to

be undertaken; or on land where the property has not

been defined, the coordinates within which the activity

is to be undertaken;

N/A – no linear activity requires

authorisation

(d) a description of the scope of the proposed activity,

including—

(i) all listed and specified activities triggered and being

applied for; and

(ii) a description of the activities to be undertaken including

associated structures and infrastructure ;

Section A (1) a and b

(e) a description of the policy and legislative context within

which the development is proposed including—

(i) an identification of all legislation, policies, plans,

guidelines, spatial tools, municipal development

planning frameworks, and instruments that are

applicable to this activity and have been considered in

the preparation of the report; and

Section A (11), Table 3.1

(ii) how the proposed activity complies with and responds

to the legislation and policy context, plans, guidelines,

tools frameworks, and instruments;

Section A(11), Table 3.1

(f) a motivation for the need and desirability for the proposed

development including the need and desirability of the

activity in the context of the preferred location;

Section 1.1


Summary and Project Overview Page xii





report)

(g) a motivation for the preferred site, activity and technology

alternative;

Section 1.1

(h) a full description of the process followed to reach the

proposed preferred alternative within the site, including:

(i) details of all the alternatives considered;

(ii) details of the public participation process undertaken in

terms of regulation 41 of the Regulations, including

copies of the supporting documents and inputs;

(iii) a summary of the issues raised by interested and

affected parties, and an indication of the manner in

which the issues were incorporated, or the reasons for

not including them;

Section A(2)

Section C

Appendix E

(iv) the environmental attributes associated with the

alternatives focusing on the geographical, physical,

biological, social, economic, heritage and cultural

aspects;

Section B

Section D

(v) the impacts and risks identified for each alternative,

including the nature, significance, consequence, extent,

duration and probability of the impacts, including the

degree to which these impacts—

(aa) can be reversed;

(bb) may cause irreplaceable loss of resources; and

(cc) can be avoided, managed or mitigated;

Section D

Appendix F

(vi) the methodology used in determining and ranking the

nature, significance, consequences, extent, duration

and probability of potential environmental impacts and

risks associated with the alternatives;

Appendix F

(vii) positive and negative impacts that the proposed activity

and alternatives will have on the environment and on

the community that may be affected focusing on the

geographical, physical, biological, social, economic,

heritage and cultural aspects;

Appendix F

Section D

(viii) the possible mitigation measures that could be applied

and level of residual risk;

Appendix F

Section D

(ix) the outcome of the site selection matrix; N/A

(x) if no alternatives, including alternative locations for the

activity were investigated, the motivation for not

considering such; and

Section A (2)

(xi) a concluding statement indicating the preferred

alternatives, including preferred location of the activity;

Section D (2)

(i) a full description of the process undertaken to identify, assess

and rank the impacts the activity will impose on the preferred

location through the life of the activity, including—

(i) a description of all environmental issues and risks that

were identified during the environmental impact

assessment process; and

Appendix F

Appendix D


Summary and Project Overview Page xiii





report)

(ii) an assessment of the significance of each issue and risk

and an indication of the extent to which the issue and

risk could be avoided or addressed by the adoption of

mitigation measures;

Appendix F

Appendix D

Section D

(j) an assessment of each identified potentially significant

impact and risk, including—

(i) cumulative impacts;

(ii) the nature, significance and consequences of the

impact and risk;

(iii) the extent and duration of the impact and risk;

(iv) the probability of the impact and risk occurring;

(v) the degree to which the impact and risk can be

reversed;

(vi) the degree to which the impact and risk may cause

irreplaceable loss of resources; and

(vii) the degree to which the impact and risk can be

avoided, managed or mitigated;

Appendix F

Appendix D

Section D

(k) where applicable, a summary of the findings and impact

management measures identified in any specialist report

complying with Appendix 6 to these Regulations and an

indication as to how these findings and recommendations

have been included in the final report;

Section D (2)

(l) an environmental impact statement which contains—

(i) a summary of the key findings of the environmental

impact assessment;

(ii) a map at an appropriate scale which superimposes the

proposed activity and its associated structures and

infrastructure on the environmental sensitivities of the

preferred site indicating any areas that should be

avoided, including buffers; and

(iii) a summary of the positive and negative impacts and

risks of the proposed activity and identified alternatives;

Section D (2)

Appendix F

(m) based on the assessment, and where applicable, impact

management measures from specialist reports, the recording

of the proposed impact management objectives, and the

impact management outcomes for the development for

inclusion in the EMPr;

Section D (2)

Appendix F

(n) any aspects which were conditional to the findings of the

assessment either by the EAP or specialist which are to be

included as conditions of authorisation;

Section E

(o) a description of any assumptions, uncertainties, and gaps in

knowledge which relate to the assessment and mitigation

measures proposed;

Section 1.4

(p) a reasoned opinion as to whether the proposed activity

should or should not be authorised, and if the opinion is that it

should be authorised, any conditions that should be made in

respect of that authorisation;

Section D and Section E


Summary and Project Overview Page xiv





report)

(q) where the proposed activity does not include operational

aspects, the period for which the environmental authorisation

is required, the date on which the activity will be concluded,

and the post construction monitoring requirements finalised;

N/A

(r) an undertaking under oath or affirmation by the EAP in

relation to:

(i) the correctness of the information provided in the

reports;

(ii) the inclusion of comments and inputs from stakeholders

and I&APs;

(iii) the inclusion of inputs and recommendations from the

specialist reports where relevant; and

(iv) any information provided by the EAP to interested and

affected parties and any responses by the EAP to

comments or inputs made by interested and affected

parties; and

Appendix H

Appendix I

(s) where applicable, details of any financial provisions for the

rehabilitation, closure, and ongoing post decommissioning

management of negative environmental impacts;

N/A

(t) any specific information that may be required by the

competent authority; and

N/A

(u) any other matters required in terms of section 24(4)(a) and (b)

of the Act.

N/A

1.3. DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER AND EXPERTISE TO CONDUCT

THE BASIC ASSESSMENT

Neopak (Pty) Ltd has appointed Savannah Environmental (Pty) Ltd as the independent

environmental consultant to undertake the required Basic Assessment process and to identify

and assess all the potential environmental impacts associated with the proposed project,

including proposing appropriate mitigation and management measures in an Environmental

Management Programme (EMPr). As part of these environmental studies, interested and

affected parties (I&APs) have been notified and provided an opportunity to participate

through the public involvement process. Neither Savannah Environmental nor the specialist

sub-consultant on this project are subsidiaries of, or are affiliated to Neopak (Pty) Ltd. In

addition, Savannah Environmental does not have any interest in secondary developments

that may arise out of the authorisation of the proposed project.

Savannah Environmental is a specialist environmental consulting company providing holistic

environmental management services, including environmental impact assessments and

planning to ensure compliance and evaluate the risk of development and the development

and implementation of environmental management tools. Savannah Environmental benefits

from the pooled resources, diverse skills and experience in the environmental field held by its

team that has been actively involved in undertaking environmental studies for a wide variety

of projects throughout South Africa and neighbouring countries. Strong competencies have


Summary and Project Overview Page xv

been developed in project management of environmental processes, as well as strategic

environmental assessment and compliance advice, and the assessment of environmental

impacts, the identification of environmental management solutions and mitigation/risk

minimising measures.

The Savannah Environmental team has considerable experience in environmental impact

assessments and environmental management, and have been actively involved in

undertaking environmental studies for a wide variety of projects throughout South Africa,

including those associated with electricity generation and transmission.

The Savannah Environmental team in this project includes:

» Lisa Opperman - the principle author of this report holds a Bachelor degree with Honours

in Environmental Management and has two years of experience in the environmental

field. Her key focus is on environmental impact assessments, public participation,

environmental management plans and programmes, as well as mapping using ArcGIS for

a variety of environmental projects. She is currently involved in several EIAs for renewable

energy projects across the country.

» Karen Jodas - is a registered Professional Natural Scientist and holds a Master of Science

degree and is the registered EAP on the proposed project. She has 20 years of experience

consulting in the environmental field. Her key focus is on strategic environmental

assessment and advice; management and co-ordination of environmental projects,

which includes integration of environmental studies and environmental processes into

larger engineering-based projects and ensuring compliance to legislation and guidelines;

compliance reporting; the identification of environmental management solutions and

mitigation/risk minimising measures; and strategy and guideline development. She is

currently responsible for the project management of EIAs for several renewable energy

projects across the country.

» Gabriele Wood - the public participation consultant for this project, holds an Honours

Degree in Anthropology, obtained from the University of Johannesburg. She has 9 years of

consulting experience in public participation and social research. Her experience includes

the design and implementation of public participation programmes and stakeholder

management strategies for numerous integrated development planning and

infrastructure projects. Her work focuses on managing the public participation component

of the Environmental Impact Assessment processes undertaken by Savannah

Environmental.

In order to adequately identify and assess potential environmental impacts associated with

the proposed project, Savannah Environmental has appointed the following specialist to

conduct an Air Quality Assessment for inclusion in the Basic Assessment Report:

Specialist Report Specialist Name Company Appendix

Air Quality

Assessment

Sarisha Perumal

Mark Zunckel

uMoya-NILU Consulting D1

Curricula vitae for the Savannah Environmental project team and the specialist consultant

appointed for the Air Quality Assessment are included in Appendix H.


Summary and Project Overview Page xvi

1.4. ASSUMPTIONS AND LIMITATIONS

The following assumptions and limitations are applicable to the studies undertaken within this

Basic Assessment Process:

» All information provided by the proponent to the environmental team was correct and

valid at the time it was provided.

» It is assumed that the development site identified by the proponent represents a

technically suitable site for the establishment of the proposed CHP Plant.

» This report and its investigations are project-specific, and consequently the environmental

team did not evaluate any other alternatives in terms of location and technology.


Basic Assessment Report for Review Page xvii

BASIC ASSESSMENT REPORT FOR REVIEW

This Basic Assessment Report has been prepared by Savannah Environmental in order to assess

the potential environmental impacts associated with the Neopak CHP Plant located in Rosslyn,

Gauteng. This process is being undertaken in support of an application for environmental

authorisation to the National Department of Environmental Affairs (DEA).

The 30-day review period for the Basic Assessment Report is from 28 February 2017 to 31 March

2017. The report is available for public review at the following locations:

» Neopak Facility Reception, Rosslyn

» www.savannahsa.com

To obtain further information, register on the project database, or submit written comment

please contact:

Gabriele Wood

Savannah Environmental

Tel: 011 656 3237

Fax: 086 684 0547

Email: [email protected]

Post: PO Box 148 Sunninghill, 2157

The due date for comments on the Basic Assessment Report is

31 March 2017


SECTION A: ACTIVITY INFORMATION Page 1

SECTION A: ACTIVITY INFORMATION

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

section?

NO

If YES, please complete the form entitled “Details of specialist and declaration of interest”

for the specialist appointed and attach in Appendix I.

1. PROJECT DESCRIPTION

a) Describe the project associated with the listed activities applied for

Neopak (Pty) Ltd propose to develop a Combined Heat and Power (CHP) gas turbine at the

existing Neopak Facility in Rosslyn, Gauteng. The project is known as the Neopak CHP Plant.

The existing Neopak paper mill facility in Rosslyn is located on a site located within Portion 3

of Erf 39, Portion 1 of Erf 41 and Erf 40 (the affected properties)7. The development area8

proposed for the CHP Plant is located within the existing Neopak paper mill facility (project

site)9, and is the area within which the construction and operation of the CHP Plant will take

place. These properties are considered to be a brownfields site10 which has been

transformed through industrial development. A development footprint11 of approximately

675m2 has been identified within the existing Neopak facility and the development area for

the construction and operation of the CHP Plant. The general area is of an industrial nature,

as Rosslyn is an industrialised area and includes industries such as the BMW factory and the

Nissan South Africa factory.

The Neopak Facility currently uses natural gas in a gaseous form and coal to generate steam

for use in the current paper mill operations. Neopak are now proposing the development of

a CHP Plant to pass the same gas through a gas turbine to generate both steam and

electricity. This development will be aiding and adding to the production of steam which is

currently being produced by coal and gas fired boilers on-site and also generate electricity.

The purpose of the project is, therefore, to produce both power and steam, rather than just

steam which is currently being produced by existing boilers located within the plant:

1. The steam produced by the CHP plant will be used for the operations of the paper

mill facility,

7 The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced from

the Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrik

van Eck Street as per the City of Tshwane City Planning and Development Department.

8 The development area is the identified location within the project site within which the CHP Plant will be sited. The

development area will include the development footprint, which will house the CHP turbine as well as the associated

linear infrastructure including gas lines and cabling. The development area is approximately 1.3ha in extent.

9 The project site is defined the existing Neopak paper mill facility located in Rosslyn, Gauteng. The project site includes

three affected properties namely Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40.10 A brownfields site can be described as land previously or currently developed and used for industrial purposes or

commercial purposes. Such land is considered to be transformed, and degraded to an extent that the natural

environmental attributes are considered to be minimal.11The development footprint is the area identified within the development area to house the CHP Plant. The

development footprint is approximately 0.0675ha / 675m2 in extent.



2. The electricity produced will be evacuated via an 11kV cable to an existing

substation located within the Neopak Facility.

The development will provide the opportunity for a more efficient use of the available

energy, effectively delivering a proportion of “free” conversion to electricity generation. The

basic operation of the proposed CHP Plant includes the following:

» Inlet air is filtered and ducted into multiple compression stages.

» Natural gas is fed into the combustion chamber, mixed with the compressed air and then

combusted.

» The combustion exhaust drives a series of turbine blades to provide rotational force to

the drive shaft.

» Electricity is produced through a generator connected to the drive shaft, which

generates the power component of the plant.

» Hot gases exiting the turbine at 500°C, contain a high level of energy and are ducted to

a heat recovery steam generator which generates the steam component of the plant.

» Final products of the combustion is exhausted to the atmosphere via flue.

The site can be accessed via the regional road (R556) located to the north of the project site

and various secondary roads surrounding the area. The area surrounding the project site

and the site itself is of a highly industrial nature and is currently being used for the operation

of a paper mill, specifically for the production of cardboard boxes.

The requirement for the basic assessment is based on the electricity generation capacity of

the CHP Plant which is 9.9 to 12MW.

The following construction, operation and decommissioning activities will be associated with

the CHP Plant:

Construction Phase

The construction phase will be 6 months. The construction phase will include the

transportation of the required equipment and building material to the Neopak Facility. No

excavation of any natural habitats or vegetation will be required for the construction phase

due to the already transformed nature of the site within an industrial area. The installation of

the CHP Plant will include the connection of the CHP Plant to the existing gas lines which

service the site, the installation of the CHP Plant in the existing Neopak Facility and the

laydown of the 11kV cable (within an already transformed area) for the evacuation of the

generated electricity to the existing substation located within the Neopak Facility boundary

and approximately 140m west of the proposed CHP Plant.

Up to 75 employment opportunities will be created during the construction phase of the CHP

Plant.

Operation Phase

The operation phase will be ~20 years in duration. The operation phase will include the

generation of steam and electricity through the use of natural gas (which is already available

on the site and already used for the Neopak Facility operating processes). The CHP Plant will



require maintenance as and when required, which will be determined through the

performance of the plant.

The nature of the impact of the development of the CHP Plant on ambient air quality during

the operation phase is largely dependent on emissions from the operation phase of the CHP

Plant associated with the combustion of natural gas in a gaseous form. Natural gas produces

fewer emissions than oil and coal and CHP systems capture and utilise heat that would

otherwise be wasted from the production of electricity. While there will be an increase in

concentrations of both CO and NOx, the impacts on ambient air quality are minimal relative

to the NAAQS. The release of the expected emissions, including carbon monoxide, nitrogen

dioxide, sulphur dioxide and particulate matter, will not reach any set limit as per the National

Ambient Air Quality Standards (NAAQS) and is therefore considered to be compliant with

the standards.

The operation phase is not anticipated to create additional full time employment

opportunities as the Neopak Facility already employs a significant number of staff who have

the required skill for the operation of the CHP Plant.

Decommissioning

The CHP Plant will be decommissioned once it has reached its economic viability (~20 years)

or the technology will be updated to continue the operation of the CHP Plant. If the CHP

Plant is decommissioned then the un-instalment of the CHP Plant will be the main activity.

Employment opportunities might be available during the decommissioning phase

depending on the requirements at the time.

All services required for the construction, operation and decommissioning phases are readily

available and will be provided by the existing Neopak Facility.

b) Provide a detailed description of the listed activities associated with the project as

applied for

The proposed development requires Environmental Authorisation in terms of Sections 24 and

24D of the National Environmental Management Act (No 107 of 1998), as read with the EIA

Regulations of 2014, GN R983, and therefore a Basic Assessment (BA) process will be required

for the project.

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—

Listed activity as described in GN R 983, 984 and 985 Description of project activity that triggers listed

activity

GN R 983 Item 2(1):

The development and related operation of facilities

or infrastructure for the generation of electricity from

a non-renewable resource where the electricity

output is more than 10 megawatts but less than 20

megawatts

The development and operation of a Combined

Heat and Power (CHP) gas turbine to generate

both steam and electricity to be evacuated into

the existing Neopak Substation located within

the boundaries of the Neopak Facility. The

generating capacity will be 9.9 to 12MW.



(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 as required by Regulation 22(2)

(h) of GN R.982. 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 a site and/or activity (including different processes, etc.) 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.

The identification of alternatives should be in line with the Integrated Environmental Assessment

Guideline Series 11, published by the DEA in 2004. Should the alternatives include different

locations and lay-outs, the co-ordinates of the different alternatives must be provided. The

co-ordinates should be in degrees, minutes and seconds. The projection that must be used in

all cases is the WGS84 spheroid in a national or local projection.

a) Site alternatives

A site alternative refers to the identification of more than one potential site which may be

suitable for the establishment of a proposed facility. However, the requirement of the CHP

Plant forms part of the needs for the development at the Neopak Facility and will be specific

to the operations of the Facility. Also, the location of the CHP Plant within the Neopak Facility

is limited by space requirements and the location of the existing gas lines. Therefore, the site

proposed for the development of the CHP Plant and the location of the CHP Plant within the

Neopak Facility is considered as preferred with no other feasible site alternative available.

Alternative 1: preferred site alternative

Description Lat (DDMMSS) Long (DDMMSS)

CHP Plant development area 25°37’38.05”S

25°37’40.01”S

25°37’41.64”S

25°37’40.74”S

28°04’50.25”E

28°04’57.55”E

28°04’50.95”E

28°04’49.00”E



Figure 3: Layout map indicating the location of the CHP Plant to be developed within the Neopak Facility in Rosslyn, Gauteng



In the case of linear activities:

Alternative: Latitude (S): Longitude (E):

• Starting point of the activity

• Middle/Additional point of the activity

• End point of the activity

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.

The 11kV cable for the connection between the CHP Plant and the existing substation will be

less than 140m.

b) Technological alternatives

The Neopak Facility currently uses natural gas and coal to generate steam for use in the current

paper mill operations. The development of a CHP Plant to pass the same gas through a gas

turbine (Combined Heat and Power Gas Turbine) to generate both steam and electricity (9.9

to 12MW) is a technology alternative to the current installed plant. The CHP is considered an

alternative technology as it would aid and add to the production of steam at the paper mill

as well as generate electricity. The purpose of the technology alternative is, therefore, to

produce both power and steam, rather than just steam which is currently being produced by

existing boilers located within the plant.

No other technology alternatives are being considered.

PREFERRED TECHNOLOGY ALTERNATIVE

Alternative 1 (preferred alternative) – Combined Heat and Power gas turbine

A combined heat and power (CHP) turbine integrates the production of usable heat and power

(electricity) in a single and highly efficient process. CHP generates electricity while also

capturing usable heat that is produced in this process. This contrasts with conventional ways of

generating electricity where vast amounts of heat is simply wasted (Association for

Decentralised Energy, 2017).

Through the use of heat (which would have been a wasted resource with a conventional

turbine), CHP Plants can reach efficiency ratings of up to 90%. In comparison to the efficiency

of gas power stations which have an efficiency of between 49% and 52%, CHP technology is

considered to be the most viable technology. And for this application at the Neopak Facility,

the CHP solution will co-generate electricity and steam, both of which are required and used

at the paper mill.

Figure 4 below provides a process diagram of the CHP plant proposed at the Neopak site.



Figure 4: CHP process

c) Layout alternatives

Only one layout is being considered for the development of the CHP Plant due to the following

reasons:

1. The Neopak Facility has existing infrastructure which needs to be considered in the position

and layout for the CHP Plant, which includes the points of connection of the existing gas

pipeline and grid connection.

2. The Neopak Facility has limited available space to accommodate the 675m2 development

footprint of the CHP Plant and therefore the location for the development is restricted to a

single location within the transformed industrial site.

Therefore no alternative layouts are being considered for the development of the CHP Plant.

Alternative 1 (preferred alternative)

The preferred layout for the CHP Plant is considered as the most appropriate and feasible

layout for the development. This layout takes into consideration the existing infrastructure

of the Neopak Facility and the best possible location of the CHP Plant within the Neopak

Facility. The preferred layout is included as Figure 3, and Appendix A2 and Appendix C.

d) Other alternatives (e.g. scheduling, demand, input, scale and design alternatives)

The design of the CHP Plant is based on widely proven and accepted industry standards and

does not affect the significance of environmental impacts (for example emissions to air). For

this CHP Plant located at the Neopak facility, the development footprint is located within a

highly transformed area characterised by industrial development and existing infrastructure.

No other alternatives are being considered for the development of the CHP Plant.

Fuel(natural gas available

at the NeopakFacility)

CombinedHeat and

Power(CHP Plant)

Power(evacuated to the

exsiting substation foroperational use at

the Neopak Facility)

Steam(evacuted to theNeopak Facility

through pipelines forthe operational use

at the Neopak Facility



e) No-go alternative

The no-go (or do nothing) alternative will result in the continuation of the use of the current

boilers at the Neopak Facility to raise steam, which operate on both gas and coal. A portion

of the energy input into the current boilers is wasted, and not used as an energy source to

generate electricity. The best practicable environmental solution is to introduce a technology

to the plant which can utilise heat that would otherwise be wasted.

As the current boilers are only able to raise steam, this no-go alternative is undesirable as the

Neopak Facility will still be reliant on coal as an energy resource. An in addition, electrical

energy potential from the boilers will still be wasted and no benefit arising from this energy. The

no-go alternative for the development of the CHP Plant is not considered as the desirable or

feasible alternative due to the following reasons:

a. The existing Neopak facility has natural gas in gaseous form readily available for use. A

new source of gas is, therefore, not required.

b. The development of the CHP Plant will ensure the efficient use of the natural gas through

the generation of both steam and electricity which are considered as essential

requirements for the operation of the paper mill.

c. The development of the CHP Plant ensures that all more of the energy released through

the combustion of natural gas in gaseous form is utilised for the operating process and that

a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising the

use of the energy resource.

d. The generated electricity will be evacuated to the existing substation located within the

Neopak facility boundaries via an 11kV cable. The electricity will be utilised for the

operation of the paper mill which in turn eliminates the dependence of the Neopak facility

on the national grid as well as strengthen the grid supply due to a reduced supply pressure

on the grid.

The opportunities presented by the development will be lost if the no-go alternative is applied,

and is therefore not considered desirable for the project. The negative impacts of the no-go

alternative are considered to outweigh the positive impacts of this alternative.

3. PHYSICAL SIZE OF THE ACTIVITY

a) Indicate the physical size of the preferred activity/technology as well as alternative

activities/technologies (footprints):

Alternative: Size of the activity:

Alternative A1 – Preferred (CHP Plant development area) ~1.3ha

Alternative A2

Alternative A3



b) Indicate the size of the alternative sites or servitudes (within which the above

footprints will occur):

Alternative: Size of the site/servitude:

Alternative A1

Alternative A2

Alternative A3

4. SITE ACCESS

Does ready access to the site exist? YES

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

Describe the type of access road planned:

Access to the site is readily available via the use of secondary roads located within the Rosslyn

industrial area, the Neopak Facility main access (514 Hendrick van Eck Street, Rosslyn) and

facility internal roads. The main access route to the site will be the regional road (R566) which

is located approximately 330m to the north.

Appendix A1 indicates the position of the access road to the site which is the R566.

5. LOCALITY MAP

An A3 locality map must be attached to the back of this document, as Appendix A. The scale

of the locality map must be relevant to the size of the development at least1:50000. For linear

activities of more than 25 km, a smaller scale e.g. 1:250 000 can be used. The scale must be

indicated on the map. The map must indicate the following:

• an accurate indication of the project site position as well as the positions of the alternative

sites, if any;

• indication of all the alternatives identified;

• closest town(s);

• road access from all major roads in the area;

• road names or numbers of all major roads as well as the roads that provide access to the

site(s);

• all roads within a 1km radius of the site or alternative sites; and

• a north arrow;

• a legend; and

• locality GPS co-ordinates (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)

An A3 Locality map has been included within Appendix A1



6. LAYOUT/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);

6.10 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

6.11 the positions from where photographs of the site were taken

A Layout Map has been included in Appendix A2

7. SENSITIVITY MAP

The layout/route plan as indicated above must be overlain with a sensitivity map that indicates

all the sensitive areas associated with the site, including, but not limited to:

• watercourses;

• the 1:100 year flood line (where available or where it is required by DWS);

• ridges;

• cultural and historical features;

• areas with indigenous vegetation (even if it is degraded or infested with alien species); and

• critical biodiversity areas.

The sensitivity map must also cover areas within 100m of the site and must be attached in

Appendix A.



An A3 sensitivity map of the site has been included within Appendix A3 and Figure 5 below.

This sensitivity map illustrates that no sensitive features are located within the site or directly

adjacent to the CHP Plant or the Neopak Facility due to the current transformed conditions

of the Rosslyn industrial area. An A3 sensitivity map of the site and the broader area has

been included within Appendix A4 and Figure 6 below. This sensitivity map illustrates

sensitive environmental features located well outside of the boundaries of the site and the

Neopak Facility and include:

» The Marikana Thornveld located to the south of the site which is classified as Vulnerable.

» Ecological Support Areas located north, west and east of the site as per the Gauteng

Conservation Plan (Gauteng CPlan).

» An area considered as irreplaceable located north east of the site.

» A Protected Area (known as the De Onderstepoort Private Nature Reserve) located

north east of the site.



Figure 5: Map illustrating the sensitivity of the CHP Plant site overlain with the CHP Layout



Figure 6: Map illustrating the sensitivity of the broader area surrounding the site, and that the sensitive environments are located well outside

of the Rosslyn industrial area



8. 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 report. It must be supplemented with additional photographs of

relevant features on the site, if applicable.

Site photographs are attached within Appendix B.

9. FACILITY ILLUSTRATION

A detailed illustration of the activity must be provided at a scale of at least 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

A facility illustration is included within Appendix C.

10. ACTIVITY MOTIVATION

a) Need and desirability of the activity

Motivate and explain the need and desirability of the activity (including demand for the

activity):

1. Is the activity permitted in terms of the property’s existing land

use rights?YES

Please

explain

The affected properties are currently zoned for industrial use. The proposed activity will be

located within the existing Neopak facility and the steam and power generated from the CHP

Plant will be utilised for the operation of the Neopak Facility. The proposed activity is therefore

permitted and appropriate in terms of the property’s land use rights

2. Will the activity be in line with the following?

(a) Provincial Spatial Development Framework (PSDF) YESPlease

explain

The activity is to be undertaken within the existing and fully operational Neopak facility in

Rosslyn which in terms of the Gauteng Spatial Development Framework (GSDF) is part of the

“Provincial Economic Core” which is anchored by Rosslyn to the north (Tshwane) and is linked

to the OR Tambo International Airport to the east (Ekurhuleni) via the N1/R21 and the Central

Business District of Johannesburg to the south via the N1/M1 highway. This emerging Gauteng

Urban Region and its strategic prominence is a very strong force that will shape Tshwane’s

future not only spatially, but also economically and institutionally over the next decade.

Therefore, the activity is in line with the Provincial Spatial Development Framework.

(b) Urban edge / Edge of Built environment for the area YESPlease

explain

The CHP Plant is proposed to be developed within the existing and fully operational Neopak

Facility in Rosslyn, Gauteng. The City of Tshwane Metropolitan Spatial Development

Framework locates the Neopak Facility inside the boundary of an area to be used for higher

density urban development therefore the activity is located within the edge of built

environment for the area.



(c) Integrated Development Plan (IDP) and Spatial

Development Framework (SDF) of the Local Municipality

(e.g. would the approval of this application compromise

the integrity of the existing approved and credible

municipal IDP and SDF?).

YESPlease

explain

The City of Tshwane Spatial Development Framework (2012) locates the existing Neopak

Facility in the north western quadrant of the City of Tshwane Metropolitan Municipality within

Region 1 of the 7 regions. This Region is known for its specialised nature of industrial areas

including the area within which the CHP Plant is proposed to be developed, therefore the

approval of this application would be in-line with and would not compromise the integrity of

the existing approved and credible municipal SDF.

In its strive towards energy security, the City of Tshwane Integrated Development Plan

(2016/17) acknowledges that the City of Tshwane is, through its long-term development plan

- Vision 2055, encouraging optimal energy management solutions, including those that

incorporate alternative energy, to be used in order to improve the resilience and resource

efficiency of the City. It has been stated amongst the Strategic Actions of the first Decade of

Change – by 2020, that focus should be on, amongst others, optimal energy management

solutions, including those that incorporate alternative energy, to be used. The CHP Plant is

aimed at using natural gas as an alternative energy source and to maximise and optimise the

use of the energy resource. Therefore, the development of the CHP Plant falls within the

municipality’s long term development plan and the approval of this application would

support the integrity of the Municipal IDP.

(d) Approved Structure Plan of the Municipality YESPlease

explain

The CHP Plant is to be developed within the existing and fully operational Neopak Facility

located within the Rosslyn Industrial Area. The structure plan of the City of Tshwane

Metropolitan Municipality fully accommodates the Rosslyn Industrial Area, therefore it can be

concluded that the CHP Plant development is in line with the structure plan. The Plant would

be considered to be additional to the existing infrastructure within the existing Neopak Facility.

(e) An Environmental Management Framework (EMF)

adopted by the Department (e.g. Would the approval of

this application compromise the integrity of the existing

environmental management priorities for the area and if

so, can it be justified in terms of sustainability

considerations?)

YESPlease

explain

The CHP Plant falls within the existing Neopak Facility which in terms of the Gauteng

Environmental Management Framework is located within a developed area that is zoned for

industry therefore the approval of this application would not compromise the integrity of the

of environmental management priorities for the area and will add to development in this

regard.

(f) Any other Plans (e.g. Guide Plan) YESPlease

explain

Tshwane Vision 2055:

The vision translates into six broad Outcomes that represent the areas that are key for the City

of Tshwane’s broad development logic over the next four decades. Outcome 1 is the City of

Tshwane’s commitment to implement the principles and interventions of a ‘smart

environment. The characteristics of a smart environment include the attractiveness of the

City’s natural environment, pollution reduction, protecting the environment and sustainable



resource management. The goal in achieving Outcome1 is to use the City’s natural resources

effectively to reduce the City’s impact on the environment. The proposed activity

encourages Objective 1 of the Vision through maximising and optimising the use of a natural

non-renewable energy resource.

3. Is the land use (associated with the activity being applied for)

considered within the timeframe intended by the existing

approved SDF agreed to by the relevant environmental

authority (i.e. is the proposed development in line with the

projects and programmes identified as priorities within the

credible IDP)?

YESPlease

explain

The City of Tshwane Spatial Development Framework (2012) locates the existing Neopak

Facility in the north western quadrant of the City of Tshwane Metropolitan Municipality within

Region 1 of the 7 regions. This Region is known for its specialised nature of industrial areas

including the area within which the CHP Plant is proposed to be developed, therefore the

land-use is considered to be agreed to by the relevant environmental authority.

4. Does the community/area need the activity and the

associated land use concerned (is it a societal priority)? (This

refers to the strategic as well as local level (e.g. development

is a national priority, but within a specific local context it could

be inappropriate.)

YESPlease

explain

The Rosslyn area is already an industrial area. The CHP Plant is consistent with the activities

which are already present in the industrial area. The main purpose of the CHP Plant is to

enable the Neopak Facility to maximise its current natural gas usage. The Combined Heat

and Power Gas Turbine will generate both steam and electricity (9.9-12MW). This

development will be aiding and adding to the production of steam which is currently being

produced by coal and gas fired boilers on-site and also generate electricity. This is beneficial

to the area as the municipal grid will be strengthened in this area as a result of the power

generated at the site.

5. Are the necessary services with adequate capacity currently

available (at the time of application), or must additional

capacity be created to cater for the development?

(Confirmation by the relevant Municipality in this regard must

be attached to the final Basic Assessment Report as Appendix

I.)

YESPlease

explain

All the services needed for the CHP Plant have been developed for the existing Neopak

Facility and is readily available to utilise. The requirement of the CHP Plant will not require

additional capacity to the existing services due to the nature of the development. This

includes the natural gas pipeline which already exists at the site.

6. Is this development provided for in the infrastructure planning

of the municipality, and if not what will the implication be on

the infrastructure planning of the municipality (priority and

placement of services and opportunity costs)? (Comment by

the relevant Municipality in this regard must be attached to

the final Basic Assessment Report as Appendix I.)

NOPlease

explain

The CHP Plant will not have any implications for the Municipality infrastructure planning. Water

and other services is already available to be utilised as part of the existing Neopak Facility.



7. Is this project part of a national programme to address an

issue of national concern or importance?YES

Please

explain

The introduction of natural gas into South Africa's mainstream energy supply is an important

step in the fulfilment of one of the major objectives of the White Paper on Energy Policy.

Natural gas burns cleaner than other fossil fuels, producing less carbon dioxide than both coal

and oil. Its use will therefore positively impact South Africa’s carbon emissions and is

considered as a manner of addressing issues of national concern even if the inputs therein are

only limited.

8. Do location factors favour this land use (associated with the

activity applied for) at this place? (This relates to the

contextualisation of the proposed land use on this site within

its broader context.)

YESPlease

explain

The location of the CHP Plant falls within the existing Neopak Facility (as the end-user) which

is located within a developed area that is zoned for industry (i.e. Rosslyn Industrial Area). The

site has been transformed and, therefore the location is highly suitable for the development

with negligible impact on the environment. The location of the proposed activity is therefore

considered to be the most feasible option taking technical issues and environmental aspects

into consideration.

9. Is the development the best practicable environmental option

for this land/site?YES

Please

explain

The Neopak Facility is an existing paper mill and processing plant which has been operational

over an extended period of time. The location of the CHP Plant falls within the existing Neopak

Facility (as the end-user) which is located within a developed area that is zoned for industry

(i.e. Rosslyn Industrial Area). The site has been transformed and, therefore the location is highly

suitable for the development with negligible impact on the environment. The CHP Plant would

be infill development within the Neopak industrial site. The location of the CHP Plant within

the Neopak Facility is therefore considered to be the best practicable environmental option

for this land/site.

10. Will the benefits of the proposed land use/development

outweigh the negative impacts of it?YES

Please

explain

The development of the CHP Plant will have a negligible environmental impact that can be

mitigated. The project is proposed within the existing Neopak Facility located within the

Rosslyn Industrial Area which has been transformed by various industrial developments. The

CHP Plant will facilitate the optimum usage of the natural gas supply to the site, with the CHP

Plant producing both electricity and steam for use the Neopak facility. The CHP Plant will

result in an overall reduction in carbon emissions, which will have positive impact at a local,

regional and national level and be in line with various national and provincial policies. No

significant negative impacts associated with the project have been identified, and the

project benefits are considered to outweigh any negative impacts (none of which are

considered fatal flaws or of a high significance).

11. Will the proposed land use/development set a precedent

for similar activities in the area (local municipality)?NO

Please

explain

There are numerous other industries operational in the existing Rosslyn industrial area and this

authorisation will not set a precedent for industrial developments. The CHP Plant may,

however, set a positive precedent to other industries which are able to also utilise similar

technology.



12. Will any person’s rights be negatively affected by the

proposed activity/ies?NO

Please

explain

The private landowner has initiated the project. The location of the CHP Plant within the

Neopak Facility (which is utilised for industrial development) eliminates the potential for

negative impact on other person’s rights.

13. Will the proposed activity/ies compromise the “urban

edge” as defined by the local municipality?NO

Please

explain

The CHP Plant is proposed within the existing Neopak Facility which already falls within the built

and industrial environment – the Rosslyn Industrial area. Therefore the project will not

compromise the urban edge.

14. Will the proposed activity/ies contribute to any of the 17

Strategic Integrated Projects (SIPS)?NO

Please

explain

The main purpose of the CHP Plant is to enable the Neopak Facility to optimise their power

and steam needs at the facility. This project will not specifically contribute to the 17 SIPs.

15. What will the benefits be to society in general and to the local

communities?

Please

explain

The construction phase of the CHP Plant will create short term employment opportunities

during the construction phase, which will enable employees to be skilled in the new

technology, and which will be beneficial for similar future developments. The CHP Plant will

facilitate the optimum usage of the natural gas supply to the site, with the CHP Plant

producing both electricity and steam for use the Neopak facility. The CHP Plant will result in

an overall reduction in carbon emissions, which will have positive impact at a local, regional

and national level. The project will therefore have a positive impact in terms of cleaner energy

utilisation and a positive impact on the surrounding communities.

16. Any other need and desirability considerations related to the proposed

activity?

Please

explain

The development of the CHP plant at the existing Neopak Facility will provide the opportunity

to optimise and fully utilise an available energy resource (natural gas is currently piped to the

site), as well as reduce the facility’s dependence on coal (which is combusted in the process

of raising steam for use at the current facility). Also, natural gas produces fewer emissions than

oil and coal and CHP systems capture and utilise heat that would otherwise be wasted from

the production of electricity. The CHP Plant will provide the opportunity to maximise and

optimise the use of the already available natural gas at the site.

The Combined Heat and Power (CHP) Plant proposed for the Neopak facility will not only fulfil

the role of raising steam required for use in the paper mill, but will also generate electricity for

own-use and/or export via the local electricity grid. The plant will combust natural gas to drive

a series of turbine blades and generates electricity (the power component of the plant). Hot

gases exiting the turbine at 500°C contain a high level of energy and are to be ducted to a

heat recovery steam generator which will generate the steam component of the plant. This

method of steam generation requires a lower amount of fuel in relation to the conventional

boilers currently installed and operating at the site.

The main objectives for the generation of electricity is to reduce the Neopak Facility’s reliance

on the municipal electricity supply, stabilise the power supply to the Neopak operations (i.e.

secure electricity supply without disruption), and strengthen the electricity capacity within an

area where significant constraints are being experienced. The installation of the CHP Plant

will provide a more efficient solution to address Neopak’s steam generation needs, while

simultaneously generating power and strengthening current supply to the site.



17. How does the project fit into the National Development Plan for 2030?Please

explain

By 2030 South Africa aims to reduce carbon emissions, promote economic development and

increase the GDP. To achieve this, the Provinces have aimed to improve Infrastructure and

Basic Services; Socio-economic Development; Institutional Transformation; Good

Governance and Public Participation; Financial viability and Management. The proposed

activity will assist in reducing the carbon footprint, as it will be utilising a cleaner energy source

than coal or oil.

The National Development Plan contains a plan aimed at eliminating poverty and reducing

inequality by 2030. The NDP identifies 9 key challenges and associated remedial plans.

Managing the transition towards a low carbon national economy is identified as one of the 9

key national challenges. Therefore the development of the CHP Plant will enable the Neopak

Facility to reduce its reliance on coal which will assist with achieving a low carbon economy

(even if the inputs are limited).

18. Please describe how the general objectives of Integrated Environmental Management

as set out in section 23 of NEMA have been taken into account.

The general objectives of Integrated Environmental Management have been taken into

account for this Basic Assessment report by means of identifying, predicting and evaluating

the actual and potential impacts on the biophysical environment.

The risks, consequences, alternatives as well as options for mitigation of activities have also

been considered with a view to minimise negative impacts, maximise benefits, and promote

compliance with the principles of environmental management.

19. Please describe how the principles of environmental management as set out in section

2 of NEMA have been taken into account.

Section 2 of NEMA states that environmental management must place people and their

needs at the forefront, and serve their physical, psychological, developmental, cultural and

social interests equitably. These principles of NEMA include the following:

» Development must be sustainable;

» Pollution must be avoided or minimised and remedied;

» Waste must be avoided or minimised, reused or recycled;

» Negative impacts must be minimised; and

» Responsibility for the environmental health and safety consequences of a policy, project,

product or service exists throughout its life cycle.

The principles of NEMA have been considered in this assessment through compliance with

the requirements of the relevant legislation in undertaking the assessment of potential

impacts, as well as through the implementation of the principle of sustainable development

where appropriate mitigation measures have been recommended for impacts which cannot

be avoided. In addition, the successful implementation and appropriate management of

this proposed project will aid in achieving the principle of minimisation of pollution and

environmental degradation, mainly due to the proposed location of the development. The

project also decreases the release of CO2 to air.

This process has been undertaken in a transparent manner and all effort has been made to

involve interested and affected parties, stakeholders and relevant Organs of State such that

an informed decision regarding the project can be made by the Competent Authority.



11. 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 (refer to Table 3 below.



Table 3: Applicable Legislation, Policies and/or Guidelines to the development of the CHP Plant

Legislation Applicable Requirements Relevant Authority Compliance requirements

National Legislation

National

Environmental

Management

Act (Act No.

107 of 1998)

The EIA Regulations have been promulgated

in terms of Chapter 5 of the Act. Listed

activities which may not commence without

an environmental authorisation are identified

within these Regulations.

In terms of S24(1) of NEMA, the potential

impact on the environment associated with

these listed activities must be assessed and

reported on to the competent authority

charged by NEMA with granting of the

relevant environmental authorisation.

In terms of GNR 983 and 985 of June 2010 a

Basic Assessment Process is required to be

undertaken for the proposed project.

» National Department of

Environmental Affairs (DEA)

– competent authority

» Gauteng Department of

Agriculture and Rural

Development (GDARD) –

commenting authority

The listed activity triggered by the proposed CHP Plant have

been identified and assessed in the EIA process being

undertaken (i.e. Basic Assessment).

This Basic Assessment Report will be submitted to the

competent and commenting authority in support of the

application for authorisation.

National

Environmental

Management

Act (Act No.

107 of 1998)

In terms of the Duty of Care provision in S28(1)

the project proponent must ensure that

reasonable measures are taken throughout

the life cycle of this project to ensure that any

pollution or degradation of the environment

associated with a project is avoided, stopped

or minimised.




While no permitting or licensing requirements arise directly,

the holistic consideration of the potential impacts of the

proposed project has found application in the EIA process.

The implementation of mitigation measures are included as

part of the EMPr (Appendix G) and will continue to apply

throughout the life cycle of the Project.

National

Environmental

Management:

Waste Act,

2008 (Act No.

59 of 2008)

The Minister may by notice in the Gazette

publish a list of waste management activities

that have, or are likely to have, a detrimental

effect on the environment.

The Minister may amend the list by –

» Adding other waste management

activities to the list.





Development (GDARD)

As no waste disposal site is to be associated with the

proposed CHP Plant, therefore no permit is required in this

regard.

Waste handling, storage and disposal during construction

and operation is required to be undertaken in accordance

with the requirements of the Act, as detailed in the EMPr

(refer to Appendix G).




» Removing waste management activities

from the list.

» Making other changes to the particulars

on the list.

In terms of the Regulations published in terms

of this Act (GN 921), A Basic Assessment or

Environmental Impact Assessment is required

to be undertaken for identified listed activities

(Category A and B) while Category C

Activities (such as storage of waste) must be

undertaken in accordance with the

necessary norms and standards.

Any person who stores waste must at least

take steps, unless otherwise provided by this

Act, to ensure that:

» The containers in which any waste is

stored, are intact and not corroded or in

any other way rendered unlit for the safe

storage of waste.

» Adequate measures are taken to prevent

accidental spillage or leaking.

» The waste cannot be blown away.

» Nuisances such as odour, visual impacts

and breeding of vectors do not arise; and

» Pollution of the environment and harm to

health are prevented.

National

Environmental

Management:

Air Quality Act

S18, S19, and S20 of the Act allow certain

areas to be declared and managed as

“priority areas.”




» City of Tshwane

Metropolitan Municipality

The CHP Plant is considered to be a Small Boiler with a heat

input of less than 50MW per unit. Therefore, an Atmospheric

Emission License (AEL) will not be required (declared in terms

of Section 24 of the National Environmental Management:

Air Quality Act. An Atmospheric Impact report has been




(Act No. 39 of

2004)

GN R 893 of 22 November 2013 – the raising of

steam for power generation using solid, liquid

or gaseous fuels is a listed activity.

GN R831 of 2013 - Boilers using solid, liquid or

gaseous fuels with a design capacity of more

than 10MW but less than 50MW heat input per

unit are classifie as Small Boilers.

Declaration of controlled emitters (Part 3 of

Act) and controlled fuels (Part 4 of Act) with

relevant emission standards.

» GN R 827 – National Dust Control

Regulations prescribes general measures

for the control of dust in all areas

undertaken as part of the Basic Assessment report and is

includes as Appendix D1.

Dust Control Regulations describe the measures for control

and monitoring of dust, including penalties. These

regulations might be applicable during the construction

phase of the project. Dust management have also been

accounted for in the EMPr (see Appendix G).

Air Quality

Amendment

Act (Act No. 20

of 2014)

The National Environmental Management: Air

Quality Amendment Act, 2014 amends

certain provisions under the National

Environmental Management: Air Quality Act,

2004, so as to provide for further alignment

with the provisions of the National

Environmental Management Act, 1998 (Act

No. 107 of 1998); to close regulatory gaps

within the atmospheric emission licensing

system and to delete certain obsolete

provisions.




» City of Tshwane


No gaps are considered to be associated with the

development of the CHP Plant due to the exclusion for the

need of an Atmospheric Emissions License based on the

classification of the CHP Plant as a Small Boiler.

National

Ambient Air

Quality

Standards

(NAAQS)

The standards provides limits for six

contaminants that are believed to be most

harmful to humans and the environment.

Contaminants are carbon monoxide, Lead,

nitrogen dioxide, Lead, particulate matter,

ozone, and sulphur dioxide




» City of Tshwane


The CHP Plant will emit carbon monoxide, nitrogen dioxide,

sulphur dioxide and particulate matter (PM10). However, as

per the results of the Atmospheric Impact Report (refer to

Appendix D1) none of the emissions associated with the

development will reach the set limits of the NAAQS.




Hazardous

Substances

Act (Act No. 15

of 1973)

This Act regulates the control of substances

that may cause injury, or ill health, or death

due to their toxic, corrosive, irritant, strongly

sensitising, or inflammable nature or the

generation of pressure thereby in certain

instances and for the control of certain

electronic products. To provide for the rating

of such substances or products in relation to

the degree of danger; to provide for the

prohibition and control of the importation,

manufacture, sale, use, operation,

modification, disposal or dumping of such

substances and products.

» Group I and II: Any substance or mixture

of a substance that might by reason of its

toxic, corrosive etc., nature or because it

generates pressure through

decomposition, heat or other means,

cause extreme risk of injury etc., can be

declared to be Group I or Group II

hazardous substance;

» Group IV: any electronic product;

» Group V: any radioactive material.

The use, conveyance, or storage of any

hazardous substance (such as distillate fuel) is

prohibited without an appropriate license

being in force.

» Department of Health It is necessary to identify and list all the Group I, II, III, and IV

hazardous substances that may be on the site and in what

operational context they are used, stored or handled. If

applicable, a license could be required to be obtained from

the Department of Health.

Take note that during construction, an estimated amount of

3000m3 solid construction waste will be produced over a one

month period, for the expected 6 month construction

period.

Compliance must take note that all construction waste must

be safely stored in containers and be removed from site on

an ad hoc basis by the appointed construction contractor,

as and when deemed necessary. The construction waste

will be disposed of at an appropriately licenced Municipal

landfill site.

National Road

Traffic Act (Act

No 93 of 1996)

The technical recommendations for highways

(TRH 11): “Draft Guidelines for Granting of

Exemption Permits for the Conveyance of

Abnormal Loads and for other Events on

Public Roads” outline the rules and conditions

which apply to the transport of abnormal

» Provincial Department of

Transport (provincial roads)

» South African National

Roads Agency Limited

(national roads)

An abnormal load/vehicle permit may be required to

transport the various components to site for construction.

These include route clearances and permits could be

required for vehicles carrying abnormally heavy or

abnormally dimensioned loads.




loads and vehicles on public roads and the

detailed procedures to be followed in

applying for exemption permits are described

and discussed.

Legal axle load limits and the restrictions

imposed on abnormally heavy loads are

discussed in relation to the damaging effect

on road pavements, bridges and culverts.

» The general conditions, limitations and

escort requirements for abnormally

dimensioned loads and vehicles are also

discussed and reference is made to

speed restrictions, power/mass ratio, mass

distribution and general operating

conditions for abnormal loads and

vehicles. Provision is also made for the

granting of permits for all other

exemptions from the requirements of the

National Road Traffic Act and the

relevant Regulations.

Depending on the trailer configuration and height when

loaded, some of the components may not meet specified

dimensional limitations (height and width) and would need

to apply for the relevant permit/ clearance.

Provincial Legislation

Gauteng

Provincial

Environmental

Management

Framework

The Gauteng Provincial Environmental

Management Framework is a legal instrument

in terms of the Environmental Management

Framework Regulations, 2010.

The purpose of the regulations is to assist

environmental impact management

including EIA processes, spatial planning and

sustainable development.



Development (GDARD)

The development of the CHP Plant will aid in the promotion

of sustainable development within an area where there are

low environmental concerns (i.e. highly transformed

industrialised area) and high development demand.




The objective of the framework is to promote

efficient urban development (including

associated service infrastructure) in defined

selected areas with lower environmental

concerns and high development demand.

Service

Delivery

Charter and

Standards for

the Gauteng

Department of

Agriculture,

Conservation

and

Environment

The following strategic objectives must be

implemented:

» The facilitation of sustainable

development in Gauteng by ensuring

sustainable land uses (including

infrastructure development) and land use

patterns.

» To contribute to sustainable development

and quality of life by promoting a safe

and healthy living environment.



Development (GDARD)

The development of the CHP Plant will contribute to

sustainable development in terms of energy efficient

infrastructure. The development of the CHP Plant will reduce

the need for coal based electricity generation.



12. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT

a) Solid waste management

Will the activity produce solid construction

waste during the construction/initiation

phase?

YES

If YES, what estimated quantity will be

produced per month?

The construction phase will create

approximately 3000m3 of spoil material (solid

waste) to be excavated over a period of

one month. Additional 1000m3 of general

waste will be generated during the 4 month

and will consist mainly of packaging

material and construction-related waste.

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

The construction waste generated by the construction of the CHP Plant will be disposed of

at acceptable and licensed facilities, in line with current industrial waste disposal practises

being practised by the Neopak Facility.

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

The construction solid waste will be disposed of at acceptable and licensed facilities which

forms part of the current industrial waste disposal practises being practised by the Neopak

Facility.

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

If YES, what estimated quantity will be produced per month? N/A – the amount will

be negligible and will

only result from plant

maintenance and

parts replacement.

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

Any solid waste resulting from the operation of the CHP Plant will be disposed of at

acceptable and licensed facilities, in line with current industrial waste disposal practises

being practised by the Neopak Facility.

If the solid waste will be disposed of into a municipal waste stream, indicate which registered

landfill site will be used.

The solid waste resulting from the operation of the CHP Plant will be disposed of at

acceptable and licensed facilities which forms part of the current industrial waste disposal

practises being practised by the Neopak Facility.

Where will the solid waste be disposed of if it does not feed into a municipal waste stream

(describe)?



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

NEM:WA?NO

If YES, inform the competent authority and request a change to an application for scoping

and EIA. An application for a waste permit in terms of the NEM:WA must also be submitted

with this application.

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

facility?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. An application for a waste

permit in terms of the NEM:WA must also be submitted with this application.

The machinery associated with the CHP Plant will require oil change every c.35000 hours of

operation. This is considered to be the only waste generated at the site. The oil will be disposed

of at a licensed oil disposal facility to be chosen at the time. Both oil processing (FFS Refiners

(Pty) Ltd 1 Neutron Road, Chloorkop - (011) 976 219) and landfill options will be considered

(Valhalla Landfill Site Stefanus Schoeman Road, Valhalla. Tel: 012 374 2612).

b) Liquid effluent

Will the activity produce effluent, other than normal sewage, that will be

disposed of in a municipal sewage system?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?

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?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:

Water use at the plant will be limited to process water. A wastewater treatment plant is also

proposed to be developed for the Neopak Facility to facilitate the reuse and recycling of

process water at the site. The application for Environmental Authorisation for the water

treatment plant has been submitted to the Gauteng Department of Agriculture and Rural

Development.

c) Emissions into the atmosphere

Will the activity release emissions into the atmosphere other than

exhaust emissions and dust associated with construction phase

activities?

YES

If YES, is it controlled by any legislation of any sphere of government? YES – it is

controlled

by the

NEM: Air

Quality

Act

If YES, the applicant must consult with the competent authority to determine whether it is


The raising of steam for power generation using solid, liquid or gaseous fuels is a Listed Activity

with a design capacity equal to or greater than 50 MW heat input per unit in terms of

Government Notice 893 of 22 November 2013 (Government Gazette No. 37054). Boilers

using solid, liquid or gaseous fuels with a design capacity of more than 10MW but less than

50MW heat input per unit are, however, classified as Small Boilers. The small boilers are

considered as Controlled Emitters (DEA, 2013: Government Gazette 38973, No. 831 1

November 2013).

The Government Notice which defines the emission standards for boilers and the reporting

requirements talks to “per unit” and so the interpretation is that if the unit remains below 50

MW thermal, that the need for an Air Emissions License (AEL) is not required.

In order assess the impact of the emissions to air, an Atmospheric Impact Report has been

undertaken (refer to Appendix D1) as part of this Basic Assessment Process.

The Neopak plant is currently consuming natural gas to generate steam. The project

proposes the passing of the same gas through a gas turbine to generate power and steam.

The five existing boilers at the Neopak facility operate by combusting a combination of

natural gas in gaseous form and coal. The current thermal input is circa a million gigajoules

per year. There is no gas stored on site as gas is currently supplied via pipeline.



Gas turbines, also called “combustion turbines”, are used in a broad scope of applications

including electric power generation. A gas turbine is an internal combustion engine that

operates with rotary rather than reciprocating motion.

The primary pollutants from gas turbine engines are nitrogen oxides (NOx), carbon monoxide

(CO), and to a lesser extent, volatile organic compounds (VOC). Particulate matter (PM) is

also a primary pollutant for gas turbines using liquid fuels. Nitrogen oxide formation is strongly

dependent on the high temperatures developed in the combustor. Carbon monoxide,

VOC, hazardous air pollutants (HAP), and PM are primarily the result of incomplete

combustion. Trace to low amounts of HAP and sulphur dioxide (SO2) are emitted from gas

turbines. Emissions of sulphur compounds, mainly SO2, are directly related to the sulphur

content of the fuel.

In South Africa ambient air quality is regulated in terms of the National Environmental

Management: Air Quality Act (No. 39 0f 2004) (NEM: AQA), the Air Quality Amendment Act

(Act No. 20 of 2014) and supporting regulations. Relevant to this assessment is the National

Ambient Air Quality Standards (NAAQS) and the dust fallout regulations.

The NAAQS for criteria pollutants consists of a limit value and a permitted frequency of

exceedance. The limit value is the fixed concentration level aimed at reducing the harmful

effects of a pollutant. The permitted frequency of exceedance represents the tolerated

exceedance of the limit value annually and accounts for high concentrations as a result of

process upsets and meteorological variation. Compliance with the ambient standard

implies that the frequency of exceedance does not exceed the permitted tolerance.

The following section provides the findings for two operation scenarios at the Neopak

Facility. Firstly a baseline scenario assesses the existing boilers 3, 4 and 5 running on natural

gas in gaseous form; and secondly, the future scenario considering the operation of boilers

3, 4 and 5 together with the CHP turbine running on natural gas (i.e. a cumulative

assessment, assuming that the existing boilers are still used during operation, even if only from

time to time).

» Carbon monoxide: The ambient 1-hour CO concentrations resulting from emissions from

the baseline scenario are low. The predicted CO concentrations are also well below

the 1-hour NAAQS of 30 mg/m3 (30 000 μg/m3) for the estimated future emission. The

maximum concentration of 44 μg/m3 is predicted to occur during the baseline

approximately 100m from the source. Similarly, the predicted 8-hour CO

concentrations for the future scenario are similar to the current operations. They are

well below the 8-hour NAAQS standard of 10 mg/m3 (10 000 μg/m3) for the estimated

future emission. The maximum concentration of 30.8 μg/m3 is predicted to occur

approximately 100m from the source.

» Nitrogen dioxide: The predicted 1-hour NO2 concentrations for the future scenario are

higher than the baseline scenario. They are however below the 1-hour NAAQS of 200

μg/m3. The maximum concentration of 135.5 μg/m3 is predicted to occur

approximately 1 200 m from the source. The predicted annual NO2 concentrations are



also well below the annual NAAQS of 40 μg/m3 for the estimated future emission. The

maximum concentration of 10.8 μg/m3 is predicted to occur approximately 1 400m

from the source.

» Sulphur dioxide: SO2 is emitted from Boilers 4 and 5 only. The predicted ambient

concentrations for the baseline are therefore the same for the future scenario. The

predicted 1-hour, 24-hour and annual average S02 concentrations are very low and

are below the respective NAAQS. The maximum concentration is predicted to occur

at the source in each averaging period and decrease consistently with increasing

distance from the source.

» Particulate matter (PM10): Similar to SO2, particulates are emitted from Boilers 4 and 5.

The predicted ambient concentrations for the baseline are therefore the same for the

future scenario. The predicted 24-hour PM10 concentrations are below the NAAQS of

75 μg/m3 for the estimated future emission. The maximum concentration of 0.22 μg/m3

is predicted to occur at the source and concentrations decrease consistently with

increasing distance from the source. The predicted PM10 concentrations are also well

below the 1 year NAAQS standard of 40 μg/m3. The maximum concentration of

0.02 μg/m3 is predicted to occur at the source and concentrations decrease

consistently with increasing distance from the source.

Refer to Section D, Appendix D1 and Appendix F for an assessment of the impacts relating

to emissions. Appendix G provides mitigation measures to be adhered regarding the

atmospheric impacts.

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

d) Waste permit

Will any aspect of the activity produce waste that will require a waste permit

in terms of the NEM:WA?NO

If YES, please submit evidence that an application for a waste permit has been submitted to

the competent authority

e) Generation of noise

Will the activity generate noise? NO

If YES, is it controlled by any legislation of any sphere of government?

If YES, the applicant should consult with the competent authority to determine whether it is


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



Noise impacts of acceptable levels will be generated. The CHP plant is ISO compliant with

regards to noise (ISO 10494: 1993 Gas turbines and gas turbines sets-measurements of

emitted air). It is expected that any new noise would meet these same levels in a free field

with no background noise.

13. WATER USE

Please indicate the source(s) of water that will be used for the activity by ticking the

appropriate box(es):

Municipal Water boardGroundwater River, stream,

dam or lakeOther

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:

Notapplicable

Does the activity require a water use authorisation (general authorisation

or water use license) from the Department of Water Affairs?YES NO

If YES, please provide proof that the application has been submitted to the Department of

Water Affairs.

Process water is to be sourced from the Municipal supply feeding the industrial area (supplied

by City of Tshwane (Rand Water)), as well as from the planned water treatment plant for the

recycling and re-use of process water currently being utilised as part of the operations of the

Neopak facility. The water requirements for operation of the CHP plant are small volumes used

for cleaning during maintenance, and they do not materially change Neopak’s current water

use levels. It is predicted that the cleaning of the CHP Plant will be required twice a year which

will require ~0.3m3.

14. ENERGY EFFICIENCY

Describe the design measures, if any that have been taken to ensure that the activity is energy

efficient:

The development of the CHP Plant is considered to be a process which will maximise the

use of natural gas through the generation of both steam and electricity for the operational

use at the existing Neopak Facility.

Describe how alternative energy sources have been taken into account or been built into the

design of the activity, if any:

Not applicable. The project in its very nature is aimed at providing alternative electricity to

the Neopak Facility for their operations.


SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 33

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 B and indicate

the area, which is covered by each copy No. on the Site Plan.

Section B Copy No. (e.g. A): 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? NO

If YES, please complete the form entitled “Details of specialist and declaration of interest” for

each specialist thus appointed and attach it in Appendix I. All specialist reports must be

contained in Appendix D.

Property

description/

physical

address:

Province Gauteng Province

District Municipality City of Tshwane Metropolitan Municipality

Local Municipality -

Ward number(s) Ward 98

Nearest town(s) The project site is located within Rosslyn which is a suburb of

Pretoria. The project site is located ~23km north of the Pretoria

Central Business District.

Farm name(s) and number(s) Surveyor-General Database



» Erf 40

City of Tshwane City Planning and Development12 Department

» Parcel 514 Rosslyn, 6953 Hendrik van Eck Street

SG 21 Digit Code Surveyor-General Database

» T0JR02220000003900003

» T0JR02220000004100001

» T0JR02220000004000000

The affected properties house the existing Neopak Facility and it is within these

properties and the Neopak Facility that the CHP Plant will be developed.

12 The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced from

the Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrikvan Eck Street as per the City of Tshwane City Planning and Development Department.



Where a large number of properties are involved (e.g. linear activities), please

attach a full list to this application including the same information as indicated

above.

1. GRADIENT OF THE SITE

Indicate the general gradient of the site.

The Preferred Site (total development area of ~1.3ha)

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?

Shallow water table (less than 1.5m deep) NO

Dolomite, sinkhole or doline areas NO

Current land-

use zoning as

per local

municipality

IDP/records:

Industrial use

In instances where there is more than one current land-use zoning, please

attach a list of current land use zonings that also indicate which portions

each use pertains to, to this application.

Is a change of land-use or a consent use application required? NO



Seasonally wet soils (often close to water

bodies)

NO

Unstable rocky slopes or steep slopes with

loose soil

NO

Dispersive soils (soils that dissolve in water) NO

Soils with high clay content (clay fraction

more than 40%)

NO

Any other unstable soil or geological

feature

NO

An area sensitive to erosion NO

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. 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 speciesEGardens

Sport field Cultivated land Paved surfaceBuilding or other

structureBare 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. SURFACE WATER

Indicate the surface water present on and or adjacent to the site and alternative sites?

Perennial River NO

Non-Perennial River NO

Permanent Wetland NO

Seasonal Wetland NO

Artificial Wetland NO

If any of the boxes marked YES or UNSURE is ticked, please provide a description of the relevant

watercourse



6. 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:

Natural area Reservoir Polo fields

Low density residential Hospital/medical centre Filling station H

Medium density residential SchoolLandfill or waste treatment

site

High density residential Tertiary education facility Plantation

Informal residentialA Church Agriculture

Retail commercial &

warehousingOld age home River, stream or wetland

Light industrial Sewage treatment plantA Nature conservation area

Medium industrial AN Train station or shunting yard N Mountain, koppie or ridge

Heavy industrial AN Railway line N Museum

Power station Major road (4 lanes or more) N Historical building

Office/consulting room Airport N Protected Area

Military or police

base/station/compoundHarbour Graveyard

Spoil heap or slimes damA Sport facilities Archaeological site

Quarry, sand or borrow pit Golf course Livestock Grazing

If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by

the proposed activity?

The existing railway line infrastructure located within the area will not impacted upon as a

result of the development of the CHP Plant. The CHP Plant will be located within the Neopak

Facility boundaries and will not have an effect on the railway lines located within the area.

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by

the proposed activity? Specify and explain:

The CHP Plant will be located within the Rosslyn industrial area and the project itself is

considered to be of an industrial nature. Therefore, no impact is expected to occur on the

CHP Plant from the industrial area and vice versa.

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by

the proposed activity? Specify and explain:

N/A

Does the proposed site fall within any of the following:

Critical Biodiversity Area (as per provincial conservation plan)? NO



Core area of a protected area? NO

Buffer area of a protected area? NO

Planned expansion area of an existing protected area? NO

Existing offset area associated with a previous Environmental

Authorisation?

NO

Buffer area of the SKA? NO

If the answer to any of these questions was YES, a map indicating the affected area must be

included in Appendix A.

7. 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 Archaeological or paleontological sites, on or close

(within 20m) to the site? If YES, explain:

NO

The site is located within a brownfields site which has been transformed to the extent that

no natural environmental attributes remain. The chance of a heritage find within the site will

be negligible due to historic transformation of the site.

If uncertain, conduct a specialist investigation by a recognised specialist in the field

(archaeology or palaeontology) to establish whether there is such a feature(s) present on or

close to the site. Briefly explain the findings of the specialist.

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

Is it necessary to apply for a permit in terms of the National Heritage

Resources Act, 1999 (Act 25 of 1999)?NO

If YES, please provide proof that this permit application has been submitted to SAHRA or the

relevant provincial authority.

A permit application will be submitted if necessary, after the final siting of the infrastructure

and walk through surveys.

8. SOCIO-ECONOMIC CHARACTER

a) Local Municipality

Please provide details on the socio-economic character of the local municipality in which the

proposed site(s) are situated.

Level of unemployment:

According to the 2011 Census data, 345 356 people are unemployed within the City of

Tshwane Local Municipality and 1 079 273 people are employed. The unemployment rate

was identified to be 24.2%.



Economic profile of local municipality:

The City of Tshwane Metropolitan Municipality economy is highly service-based with

community services and government, financial services and manufacturing as the most

significant sectors. The City has a well-established manufacturing sector with the

automotive industry being a key player in this sector. The City boasts the highest

concentration of automotive Original Equipment Manufacturers (OEMs) in the country.

Furthermore, the City’s economy is characterised by a favourable and rapidly growing

trade performance with exports

Level of education:

Approximately 4.2% of people aged 20 years or more have received no education.

Approximately 34% of people aged 20 years of older have a matric certificate.

Approximately 23.4% of people age 20 years or older have a higher education.

b) Socio-economic value of the activity

What is the expected capital value of the activity

on completion?

The expected capital value will be between R 200

million and R 230 million.

What is the expected yearly income that will be

generated by or as a result of the activity?

The value of the energy savings is dependent on

electricity, coal and gas prices, as well as any

export of power to either the grid or neighbouring

industrial facilities.

Will the activity contribute to service infrastructure? YES. The activity will

strengthen the power

grid, reduce grid load

(i.e. reduced power

required from the

municipal supply)

Is the activity a public amenity? NO

How many new employment opportunities will be

created in the development phase of the activity?

During the construction phase, up to 75

employment opportunities may be created across

civil, mechanical and electrical aspects. The jobs

are created during the design & engineering,

transport, construction and commissioning phases.

These functions are being commissioned through

service providers who will be managing the

employment process. Some jobs will be temporary

and/or part time depending the specific activity or

service required.

What is the expected value of the employment

opportunities during the development phase?

The expected value of employment opportunities

will be between R 20 million and R 50 million.

What percentage of this will accrue to previously

disadvantaged individuals?

The percentage that accrues to previously

disadvantaged individuals will vary according to

the category of work and final procurement plans.



How many permanent new employment

opportunities will be created during the operational

phase of the activity?

The operation phase is not anticipated to create

additional full time employment opportunities. The

Neopak Facility already employs a significant

number of staff. Job security is expected to improve

with increasing efficiency of operations. The

operators on site will also be increasing their skills in

learning to operate new technology associated

with the CHP Plant. The capability to operate gas

turbine power plants is a transferable skill that is

expected to become increasingly in demand as

South Africa increases use of natural gas for

electricity, as mandated for in the Integrated

Resource Plan.

What is the expected current value of the

employment opportunities during the first 10 years?

Not applicable, as the operation phase is not

anticipated to create additional full time

employment opportunities.

What percentage of this will accrue to previously

disadvantaged individuals?

Not applicable, as the operation phase is not

anticipated to create additional full time

employment opportunities

9. BIODIVERSITY

Please note: The Department may request specialist input/studies depending on the nature of

the biodiversity occurring on the site and potential impact(s) of the proposed activity/ies. To

assist with the identification of the biodiversity occurring on site and the ecosystem status

consult http://bgis.sanbi.org or [email protected]. Information is also available on compact

disc (cd) from the Biodiversity-GIS Unit, Ph (021) 799 8698. This information may be updated

from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is

used. A map of the relevant biodiversity information (including an indication of the habitat

conditions as per (b) below) and must be provided as an overlay map to the property/site

plan.

a) Indicate the applicable biodiversity planning categories of all areas on site and

indicate the reason(s) provided in the biodiversity plan for the selection of the

specific area as part of the specific category)

Systematic Biodiversity Planning Category

If CBA or ESA, indicate the

reason(s) for its selection in

biodiversity plan

Critical

Biodiversity

Area (CBA)

Ecological

Support Area

(ESA)

Other Natural

Area (ONA)

No Natural

Area

Remaining

(NNR)



b) Indicate and describe the habitat condition on site

Habitat Condition

Percentage of

habitat

condition class

(adding up to

100%)

Description and additional comments and observations

(including additional insight into condition, e.g. poor land

management practises, presence of quarries, grazing,

harvesting regimes etc.).

Natural 0%

No natural areas are located within the site due to the

industrial nature of the Neopak Facility and the surrounding

areas.

Near Natural

(includes areas with

low to moderate level

of alien invasive

plants)

0% No near-natural areas are located within the site due to the


areas.

Degraded

(includes areas

heavily invaded by

alien plants)

0% No degraded areas are located within the site due to the


areas.

Transformed

(includes cultivation,

dams, urban,

plantation, roads,

etc.)

100% The site and location of the CHP Plant has been completely

transformed and no natural features are present within the

site. The broader area and the site is characterised by

industrial development and infrastructure including

factories, warehousing, roads and electrical infrastructure.

c) Complete the table to indicate:

(i) the type of vegetation, including its ecosystem status, present on the site; and

(ii) whether an aquatic ecosystem is present on site.

Terrestrial Ecosystems Aquatic Ecosystems

Ecosystem threat status

as per the National

Environmental

Management:

Biodiversity Act (Act No.

10 of 2004)

Critical Wetland (including

rivers, depressions,

channelled and

unchanneled

wetlands, flats, seeps

pans, and artificial

wetlands)

Estuary CoastlineEndangered

Vulnerable

YES NO YES NO YES NOLeast

Threatened

No terrestrial or aquatic ecosystems occur within the site or the adjacent areas due to the

industrial nature of the area, the Neopak Facility and the operations thereof and the location

of the proposed CHP Plant within Neopak Facility.



d) Please provide a description of the vegetation type and/or aquatic ecosystem

present on site, including any important biodiversity features/information identified

on site (e.g. threatened species and special habitats)

Broad-Scale Vegetation

The original vegetation located within the project site was the Marikana Thornveld

vegetation type. This vegetation type has been classified as a vulnerable ecosystem.

However, due to the transformation of the Rosslyn area, which has been subject to heavy

industrial and infrastructure development over an extended period of time the vegetation

type is no longer present within the site, with the nearest portion of the vegetation located

over 650m to the south. Therefore, the impact of the CHP Plant on the vulnerable vegetation

will be negligible to none.

Site Sensitivity

No specialised natural habitat remains within the Neopak Facility boundaries due to the

built/transformed nature of the area including warehousing, processing infrastructure and

large paved surfaces. The location proposed for the CHP Pant within the Neopak Facility is

transformed and will be located between existing infrastructure associated with the Neopak

Facility. Refer to Appendix B for photos of the site.


SECTION C: PUBLIC PARTICIPATION Page 42

SECTION C: PUBLIC PARTICIPATION

1. ADVERTISEMENT AND NOTICE

Publication name Pretoria News

Date published 03 March 2017

Site notice position Latitude Longitude

25°37'45.40"S 28° 4'52.78"E

Date placed 16 February 2017

Include proof of the placement of the relevant advertisements and notices (refer to Appendix

E1).

2. DETERMINATION OF APPROPRIATE MEASURES

Provide details of the measures taken to include all potential I&APs as required by Regulation

54(2)(e) and 54(7) of GN R.982.

» A2 Site notices were placed on the existing Neopak Facility main gate.

» An advert was placed in one local newspaper to notify the public about the EIA process

and availability of the Basic Assessment Report for a 30-day review period.

» No Stakeholder and I&AP issues and comments have been raised at this time. Comments

received and responses will be included in the Comments and Responses Report in the

Final Basic Assessment Process.

Key stakeholders (other than organs of state) identified in terms of Regulation 40(2)(c) and (d)

of GN R.982 (refer to Appendix E4 for the I&AP Database).

Title, Name and Surname Affiliation/ key stakeholder status Contact details (tel number or

e-mail address)

Mr. Dave Adam BMW SA (Pty) Ltd – Adjacent

Landowner

CEZ Investments cc:

Managing Director

Adjacent Landowner

Mr. Kenneth Collins Imbali Props (Pty) Ltd – Adjacent

Landowner

Mr. Mark Balladon KAP Automotive – Adjacent

Landowner

Mr. Jens Dieter Schutte MA Automotive Tool and Die (Pty)

Ltd – Adjacent Landowner

Mr. Abdul Khalik Patel Moneda Investments – Adjacent

Landowner

Mr. Paul le Roux Neopak (Pty) Ltd – Impacted

Landowner

Mr. Francois Greeff Nissan South Africa (Pty) Ltd –

Adjacent Landowner

Mr. Johan Koegelenberg Sentech Ltd – Interested and

Affected Party



Tshwane North TVET

College: Head of Property

and Facilities Management

Adjacent Landowner

Include proof that the key stakeholders received written notification of the proposed activities

as Appendix E2. This proof may include any of the following:

• e-mail delivery reports;

• registered mail receipts;

• courier waybills;

• signed acknowledgements of receipt; and/or

• or any other proof as agreed upon by the competent authority.

Proof of written notification to key stakeholders have been included in Appendix E2.

3. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES

No comments have been received on the project to date. A focus group meeting will be held

during the review period with all adjacent landowners to provide a background to the project

and provide the opportunity for them to raise any issues of concern. All comments received

during the review period of the Basic Assessment report, as well as responses provided will be

captured and recorded within the Comments and Response Report attached as Appendix E6

in this Basic Assessment Report.

4. COMMENTS AND RESPONSE REPORT

The practitioner must record all comments received from I&APs and respond to each

comment before the Draft BAR 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

the Final BAR as Appendix E6.

A comments and responses report including all comments received from I&APs and responses

to the comments received during the 30-day review period of the Basic Assessment Report will

be attached to the Final Basic Assessment Report for consideration by the DEA as Appendix

E6.

5. AUTHORITY PARTICIPATION

Authorities and organs of state identified as key stakeholders - refer to the I&AP database

contained in Appendix E4.

Authority/Organ of State Contact person (Title,

Name and Surname)

Tel No Fax No e-mail Postal

address

City of Tshwane Metropolitan

Municipality

Ward Councillor

(Ward 98): Marnette

Sutherland


Municipality

Air Quality Officer:

Livhuwani Siphuma



Authority/Organ of State Contact person (Title,

Name and Surname)

Tel No Fax No e-mail Postal

address


Municipality

Acting City Manager:

Lindiwe Kwele

Department of Energy Program and

Projects: Wolsey Otto

Barnard

Department of Mineral

Resources

Regional Manager:

Mmadikeledi Malebe

Department of Water and

Sanitation

Acting Provincial

Head: Penutia

Ramunenyiwa

Eskom Holdings SOC Ltd Senior Environmental

Advisor: John

Geeringh

Gauteng Department of


Development

Chief Director: Loyiso

Mkwana

National Energy Regulatory

of South Africa (NERSA)

Senior Engineer:

Tamai Hore

Provincial Heritage Resources

Authority Gauteng (PHRAG)

Maphata Ramphele

South African Civil Aviation

Authority

Obstacle Specialist:

Lizell Stroh

Telkom SA Limited Leonard Shaw

Transnet Limited National Capacity

Planning and

Strategy: Futhi

Mathebula

Include proof that the Authorities and Organs of State received written notification of the

proposed activities as Appendix E3.

Proof of written notification to Authorities and Organs of State regarding the project is included

as Appendix E3.

In the case of renewable energy projects, Eskom and the SKA Project Office must be included

in the list of Organs of State.

6. CONSULTATION WITH OTHER STAKEHOLDERS

Note that, for any activities (linear or other) where deviation from the public participation

requirements may be appropriate, the person conducting the public participation process

may deviate from the requirements of that sub-regulation to the extent and in the manner as

may be agreed to by the competent authority.

Proof of any such agreement must be provided, where applicable. Application for any

deviation from the regulations relating to the public participation process must be submitted

prior to the commencement of the public participation process.



A list of registered I&APs has been included as Appendix E4.

Copies of any correspondence and minutes of any meetings held is to be included in

Appendix E2 and Appendix E3.


SECTION D: IMPACT ASSESSMENT Page 46

SECTION D: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations,

2014, 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. 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

Provide a summary and anticipated significance of the potential direct, indirect and

cumulative impacts that are likely to occur as a result of the planning and design phase,

construction phase, operation 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. This impact

assessment must be applied to all the identified alternatives to the activities identified in

Section A (2) of this report.

The construction and decommissioning phases will have similar impacts in terms of

disturbance, as well as associated mitigation measures. It is however unlikely that this CHP

Plant will be completely decommissioned and closed (depending on the operation of the

existing Neopak Facility). Appropriate mitigation measures, which may eliminate, reduce or

manage any potential impacts of the construction, operation, and decommissioning phases

of the CHP Plant are included in the EMPr for the project, which is attached as Appendix G.

Planning Phase

Activities associated with the design and pre-construction phase pertains mostly to feasibility

assessments undertaken at a desktop level. However, due to the nature of the site proposed

for the development it is not expected that any feasibility assessments would be required.



1.1 Construction and Operation Phase

Activity Impact summary Significance

(with mitigation)

Proposed mitigation/enhancement

Construction Impacts

Nuisance impacts

including dust and noise

during the construction

phase of the CHP Plant.

Direct impacts:

Limited dust and noise will be generated

by the construction activities for the

installation of the CHP Plant. There will not

be a significant impact to surrounding

areas due to the industrialised nature of

the area and the installation of the CHP

plant within the existing Neopak facility.

The impact can be considered as

negligible.

Low Dust impacts must be mitigated through the

implementation of appropriate dust suppression,

as required.

Indirect impacts:

Increased levels of noise, pollution,

disturbance within the broader area.

However, the impact will be limited due to

existing industrial elements and

disturbance already taking place within

the area.

Low

Cumulative impacts:

The cumulative impact will be low due to

the limited nature and extent of the

development within an already

industrialised area

Low

The generation of

construction waste

Direct impacts:

Limited waste will be generated during the

construction phase. All waste generated

Low All construction waste is disposed of at a licensed

facility and the disposal is supported with a waste

manifest.




(with mitigation)


during the construction phase is required

to be disposed of in an appropriate

manner.

Indirect impacts:

None

-

Cumulative impacts:

None

-

Impact on traffic

resulting from

transportation of the

equipment required for

the construction of the

facility to the site

Direct impacts:

Equipment and project components will

be transported to site during the six-month

construction period. The site for the CHP

Plant is located within the Rosslyn industrial

area which is has an adequate road

network to provide for the movement of

light and heavy vehicles in the area, and

can readily accommodate abnormal

loads.

Low All vehicles must be road-worthy and all drivers

must have a valid license.

If abnormal loads will be transported to site the

relevant permits or clearances must be in place.

Transporting of goods through the use of abnormal

loads need to take please during off-peak hours.

Indirect impacts:

Disturbance on the road networks not

located within the surrounding areas of the

site

Low

Cumulative impacts:

Cumulative impacts will be minimal due to

the short construction period (6-months)

for the CHP Plant

Low

Employment

opportunities during the

construction phase

Direct impacts:

The construction phase will create up to 75

employment opportunities. Skills transfer

Low The allocation of employment opportunities

should be undertaken on a fair basis.




(with mitigation)


will occur as the employees will be trained

in the construction of power generation

technology utilising gas.

Indirect impacts:

Skills transfer will occur as the employees

will be trained in the construction of gas

technology.

Low

Cumulative impacts:

None

-

PM10 emissions from

construction activities

Direct impacts:

The construction will include activities will

lead to the emission of particulate matter

(PM10) which may impact any affected

parties. Emissions of air pollutants will be

very low and the associated ambient

concentrations will also be very low and

limited to the site.

Low Cover loads on vehicles carrying dusty

construction materials and limit access to

construction site to construction vehicles only.

Indirect impacts:

Exposure to PM10 concentrations

exceeding the NAAQS

Low

Cumulative impacts:

Particulate matter emissions from

construction will increase the ambient

concentrations, but it is unlikely that the

cumulative effect will result in

exceedances of the NAAQS.

Low

Operation Phase




(with mitigation)


Maximisation and

optimisation of natural

gas as an energy

resource

Direct impacts:

The CHP Plant will utilise natural gas (readily

available at the Neopak Facility) for the

generation of both steam and electricity.

Both the steam and electricity will be

utilised for the processes of the Neopak

Facility. This will reduce the dependence

of coal as an energy source for Neopak.

Low Maintenance on the CHP Plant should be carried

out regularly to ensure the efficient operation of

the plant and the efficient use of the natural gas

as an energy resource.

Indirect impacts:

None

-

Cumulative impacts:

Better use of natural gas in a gaseous form

as an energy resource without the loss of

energy through the combustion of the

natural gas

Low

Natural Gas Combustion

associated with the CHP

Turbine and the release

of CO

Direct impacts:

The nature of the impact on ambient air

quality is largely dependent on emissions

from the operation phase of the CHP Plant

associated with the combustion of natural

gas. Natural gas produces fewer emissions

than oil and coal and CHP systems

capture and utilise heat that would

otherwise be wasted from the production

of electricity. While there will be an

increase in concentrations of both CO and

NOx, the impacts on ambient air quality

are minimal relative to the NAAQS.

Low The CHP Plant should operate under optimal

conditions and carry out regular maintenance.




(with mitigation)


Indirect impacts:

Exposure to CO concentrations exceeding

the NAAQS

Low

Cumulative impacts:

There are limited sources of CO in the

vicinity of the site, the potential for

cumulative impact is therefore low.

Low

Natural gas Combustion

associated with the CHP

Turbine and the release

of NOx

Direct impacts:

The nature of the impact on ambient air

quality is largely dependent on emissions

from the operational phase of the CHP

System associated with the combustion of

natural gas. Natural gas produces fewer

emissions than oil and coal and CHP

systems capture and utilise heat that

would otherwise be wasted from the

production of electricity. While there will

be an increase in concentrations of both

CO and NOx, the impacts on ambient air

quality are minimal relative to the NAAQS.



Indirect impacts:

Exposure to NOx concentrations

exceeding the NAAQS

Low

Cumulative impacts:

There are limited sources of NOX in the

vicinity of the site, the potential for


Low




(with mitigation)


PM10 emissions from

natural gas boilers

Direct impacts:

Particulate matter (PM10) is emitted by the

existing boilers using natural gas. Emissions

are very low and the associated ambient

concentrations will also be very low and

limited to the site.



Indirect impacts:

Exposure to PM10 concentrations

exceeding the NAAQS

Low

Cumulative impacts:

There are exceedances of PM10 in Rosslyn,

but predicted concentrations from

Neopak are very low, the potential for


Low

SO2 emissions from

natural gas boilers

Direct impacts:

SO2 is emitted by the existing boilers using

natural gas. Emissions are very low and the

associated ambient concentrations will

also be very low and limited to the site.



Indirect impacts:

Exposure to SO2 concentrations exceeding

the NAAQS

Low

Cumulative impacts:

The limited sources of SO2 in the vicinity of

Nepoak and the predicted concentrations

from Neopak are very low, the potential for


Low




(with mitigation)


Maintenance of the

CHP Plant during the

operation phase

Direct impacts:

Maintenance will include the replacement

of oils utilised by the CHP Plant and the

replacement of parts. These project

components will be required to be

disposed of in a responsible manner and at

licensed waste disposal facilities.

Low Oils replaced at the plant must be disposed of in

an appropriate manner or recycled for re-use.

All parts replaced at the CHP Plant are required to

be disposed of at an appropriate disposal site or

recycled.

Indirect impacts:

None

-

Cumulative impacts:

None

-

1.2 Decommissioning Phase

Impacts associated with the decommissioning of the proposed infrastructure will be similar to those described and assessed for the construction

phase.

Decommissioning Phase

PM10 emissions from

closure activities

Direct impacts:

The decommissioning will include cutting

and general demolition. Emissions of

particulates will be very low and the

associated ambient concentrations will

also be very low and limited to the site.

Low Cover loads on vehicles carrying dusty

construction materials and limit access to site to

construction vehicles only.

Indirect impacts:

Exposure to PM10 decommissioning

exceeding the NAAQS

Low

Cumulative impacts: Low



PM10 emissions from decommissioning will

increase the ambient concentrations, but

it is unlikely that the cumulative effect will

result in exceedances of the NAAQS.



1.3 The No-Go Alternative

The no-go (or do nothing) alternative will result in the continuation of the use of the current

boilers at the Neopak Facility to raise steam, which operate on both gas and coal. A portion

of the energy input into the by the current boilers is wasted, and not used as an energy

source to generate electricity. The best practicable environmental solution is to introduce

a technology to the plant which can utilise heat that would otherwise be wasted.

As the current boilers are only able to raise steam, this no-go alternative is undesirable as the

Neopak Facility will still be reliant on coal as an energy resource, with no reduction in the

use thereof. An in addition, heat energy from the boilers will still be wasted and no benefit

arising from this energy. The no-go alternative for the development of the CHP Plant is not

considered as the desirable or feasible alternative due to the following reasons:







the combustion of natural gas in gaseous form is utilised for the operating process and

that a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising

the use of the energy resource.

d. The generated electricity will reduce the dependence of the Neopak facility on the

national grid as well as strengthen the grid supply due to a reduced supply pressure on

the grid.

The opportunities presented by the development will be lost if the no-go alternative is

applied, and is therefore not considered desirable for the project. The negative impacts of

the no-go alternative are considered to outweigh the positive impacts of this alternative.

The ‘No-Go’ alterative is an undesirable option for the project as it will result in a lost

opportunity for sufficient energy utilisation at the existing Neopak facility. The ‘No-Go’

alternative is, therefore, not a preferred alternative.

A complete impact assessment in terms of Regulation 22(2)(i) of GN R.982 is included as

Appendix F.

2. 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.



The overall significance rating of the impacts of the proposed development of the proposed

CHP Plant during the construction and operation phase is low significance (both with or

without the implementation of mitigation). The low significance of the impact is primarily due

to the location and nature of the site and the surrounding area which is characterised by

industrial developments and existing infrastructure. There are no natural features located

within the site or the existing Neopak Facility as the site has been completely transformed for

the operation of the Neopak paper mill. It is predicted through the air quality assessment that

the operations of the CHP Plant will generate low emissions, low ambient concentrations, and

low ambient air quality impacts, resulting in an impact of low significance (both with or without

the implementation of mitigation). Emissions to air from the operation of the CHP Plant will be

local in extent and long-term. The magnitude of the impact will be minor and is probable to

occur. The overall significance is therefore low (and remains low with the implementation of

the recommended mitigation measures).

Cumulative impacts associated with the development of the CHP Plant are considered to be

of a very low significance. The site is located within an industrial area, and in an area

dominated by industrial facilities. The existing Neopak Facility is an industrial development (i.e.

paper mill) and the location of the CHP Plant within the paper mill is characterised by paved

surfaces, buildings and heavy infrastructure. The development of the CHP Plant will not lead

to a whole-scale change of the area due to the current state of the Rosslyn Industrial Area and

the Neopak Facility. The development will also not significantly add to the current impacts of

the paper mill. Therefore, the development of the CHP is considered appropriate within the

proposed location without any significant cumulative impacts.

The impacts expected during the construction phase will be of a short duration (~6 months)

and of a local extent. The magnitude of the impacts will range from small to minor. The

impacts expected during the operation phase will be of a long duration (~20 years) and of a

local extent. The magnitude of the impacts will be minor.

Conclusion:

Overall the impact of the CHP Plant will be of low to negligible significance due to the already

heavily transformed nature of the site through the development of the existing Neopak Paper

Mill Facility. No natural features or habitats will be destructed during the life cycle of the facility.

Impacts associated with the construction phase (~6 months) will be negligible due to the

transformed nature of the site and the presence of the existing Neopak facility infrastructure.

The impacts associated with the operation phase (~20 years) will be the most prominent as

disturbance will take place within the paved (sealed)/transformed area, however only limited

due to the nature of the surrounding industrial area and the nature of the operational CHP

Plant. The impacts of the construction phase and operation phase have been assessed as

being of a low significance, both before and after the implementation of the recommended

mitigation measures.

With the implementation of appropriate mitigation measures the development of the CHP

Plant is considered to be appropriate, with negligible impacts on all activities and without any

fatal flaws.



If the recommended mitigation measures mentioned in Section E of the form below and those

contained in the attached EMPr (Appendix G) are applied, the significance of the impacts will

be low with no lasting significant negative environmental impacts arising from the

development of the CHP Plant (construction phase and/or the operation phase).

The project has significant benefits, and is considered the best practicable environmental

solution as this technology can utilise heat to generate electricity that would otherwise be

wasted. The long-term benefits include:







the combustion of natural gas in gaseous form is utilised for the operating process and that

a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising the

use of the energy resource.

d. The generated electricity will reduce the dependence of the Neopak facility on the power

grid as well as strengthen the grid supply due to a reduced supply pressure on the grid.

This section provides a summary of the environmental assessment and conclusions drawn for

the Neopak CHP Plant which will be developed for the generation of both steam and

electricity through the use natural gas already available at the Neopak Facility. In doing

so, it draws on the information gathered as part of the Basic Assessment process and the

knowledge gained by the environmental consultant during the course of the process, and

presents an informed opinion of the environmental impacts associated with the proposed

project. The following conclusions can be drawn from the Basic Assessment:

The development of the CHP Plant at the Neopak Facility in Rosslyn will result in positive

impacts and minor negative impacts.

The positive impacts relate to the optimisation of the use of a non-renewable energy

resource (i.e. natural gas) through the application of a CHP gas turbine. The use of this CHP

plant will ensure that the steam produced as part of the Neopak Facility operations is

produced in a more efficient manner than the current boilers. Also, the use of natural gas

produces fewer emissions than oil and coal and CHP systems capture and utilise heat that

would otherwise be wasted from the production of electricity. The fact that the

development will take place within an area which has been subjected to heavy industrial

development and whole-scale transformation is also considered to be a positive impact as

the construction and operation of the CHP Plant will not impact on any natural habitats and

features.

Therefore the development is considered to be a sustainable use of a site which has been

transformed to a point where no ecosystem functioning exists. Limited positive social



impacts are expected within the construction phase which includes up to 75 employment

opportunities and skills transfer in the construction phase of the gas turbine.

Impacts during the construction phase will primarily be minor nuisance impacts limited to

the site and the industrial area. These impacts are local in extent, short-term are of low to

negligible significance. Operation impacts will mainly relate to emissions to air, and all

impacts related to emissions have been assessed as being of low significance.

No-go alternative (compulsory)

The ‘Do nothing’ alterative is the option of not constructing the Neopak CHP Facility. This

option will result in no impacts occurring, including positive impacts which is mainly the

opportunity of sufficient energy generation of a non-renewable energy resource. The no-

go alternative for the development of the CHP Plant is not considered as the desirable or

feasible alternative due to the following reasons:







the combustion of natural gas in gaseous form is utilised for the operating process and

that a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising

the use of the energy resource.

d. The generated electricity will reduce the dependence of the Neopak facility on the

national grid as well as strengthen the grid supply due to a reduced supply pressure on

the grid.

The ‘No-Go’ alterative is an undesirable option for the project as it will result in a lost

opportunity for sufficient energy utilisation at the existing Neopak facility. The ‘No-Go’

alternative is, therefore, not a preferred alternative.


SECTION E: RECOMMENDATION OF PRACTITIONER Page 59

SECTION E: RECOMMENDATION 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

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).

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.

It is the recommendation of the environmental consultant that the development of the CHP

Plant be authorised, constructed and operated due to the positive impacts associated with

the development, as well as the negligible negative impacts arising for the implementation

of the project.

The construction and operation of the CHP Plant should be implemented according to the

specifications of the EMPr to ensure mitigation and management of potential impacts

associated with construction and operation activities. The activities should be monitored

against the approved EMPr, the Environmental Authorisation (once issued) and all other

relevant environmental legislation. Relevant conditions to be adhered to include:

» An Environmental Control Officer (ECO) should monitor compliance during construction.

» Stormwater runoff must be managed to control pollution and/or erosion within and

outside of the Neopak Facility boundaries.

» Register the plant with the Air Emissions Licensing Authority and/or the Local Municipality

and comply with relevant reporting requirements.

» All hazardous materials should be stored in the appropriate manner to prevent

contamination. Any accidental spills that occur at the site should be cleaned up in the

appropriate manner as related to the nature of the spill.


SECTION F: APPENDICES Page 61

SECTION F: APPENDICES

The following appendices must be attached:

Appendix A: A3 Maps

Appendix A1: Locality Map

Appendix A2: Layout Map

Appendix A3: Sensitivity Map

Appendix A4: Sensitivity Map of the broader area

Appendix B: Site Photographs

Appendix C: Facility Illustration

Appendix D: Specialist(s)

Appendix D1: Atmospheric Impact Report

Appendix E: Public Participation

Appendix E1: Site Notices and Newspaper adverts

Appendix E2: Proof of Stakeholder Correspondence

Appendix E3: Authority Consultation

Appendix E4: I&AP Database

Appendix E5: Comments Received – to be included in the Final BAR

Appendix E6: Comments and Responses Report – to be included in the Final BAR

Appendix F: Impact Assessment

Appendix G: Environmental Management Programme (EMPr)

Appendix A: Layout Map

Appendix B: Grievance Mechanism for Public Complaints and Issues

Appendix C: Project Team CVs

Appendix H: EAP Declaration, Affirmation and CVs

Appendix I: Specialist Declaration

Documents

NEOPAK COMBINED HEAT AND POWER (CHP) PLANT, ROSSLYN, …