clariter pilot scale waste plastics refining facility ... re050216_163/clariter eir_draft... ·...

Clariter Pilot Scale Waste Plastics Refining Facility

ENVIRONMENTAL IMPACT ASSESSMENT REPORT

DEDEAT REF: AM/A/5, 6, 12/L24/15

Prepared for:

Prepared by:

Clariter ZA (Pty) Ltd EOH Coastal & Environmental Services 16 Wrench Road

Isando, Gauteng 1609 PO Box 506

Tel: +27 11 977 5003 Fax: +27 11 392 5885

P.O. Box 8145, Nahoon

East London 5210

October 2016

DRAFT Environmental Impact Assessment Report – October 2016

EOH Coastal & Environmental Services Clariter (Pty) Ltd 2

This Report should be cited as follows: EOH Coastal & Environmental Services, October 2016: Clariter Pilot Scale Waste Plastics Refining Facility, Environmental Impact Assessment Report, EOH-CES, East London.

Copyright

This document contains intellectual property and propriety information that are protected by

copyright in favour of EOH Coastal & Environmental Services (CES) and the specialist consultants.

The document may therefore not be reproduced, used or distributed to any third party without the

prior written consent of CES. The document is prepared exclusively for submission to Clariter, and

is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and

practices of South Africa.



TABLE OF CONTENTS 1 INTRODUCTION ..................................................................................................................... 5 1.1 BACKGROUND TO THE STUDY ........................................................................................... 5 1.2 THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS ............................................... 6

1.2.1. Listed activities triggered ......................................................................................... 6 1.3 SCOPING PHASE .................................................................................................................. 8 1.4 NATURE AND STRUCTURE OF THIS REPORT ................................................................... 9 1.5 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER . 9 2 PROJECT DESCRIPTION .................................................................................................... 11 2.1 PROPERTY LOCALITY ........................................................................................................ 11 2.2 THE PROCESS .................................................................................................................... 13

2.2.1. Process Inputs ....................................................................................................... 13 2.2.1. Process Outputs .................................................................................................... 16 2.2.2. Possible future activities ........................................................................................ 22

2.3 THE INFRASTRUCTURE ..................................................................................................... 22 3 RELEVANT LEGISLATION ........................................................................................................... 26 3.1 RELEVANT LEGISLATION USED IN THE COMPILATION OF THIS ENVIRONMENTAL IMPACT REPORT ........................................................................................................................ 26 4 PROJECT NEED & DESIRABILITY ..................................................................................... 29 4.1 REDUCTION OF WASTE TO LANDFILL ............................................................................. 29 4.2 SKILLS TRANSFER ............................................................................................................. 29 5 ALTERNATIVES ................................................................................................................... 30 5.1 REASONABLE AND FEASIBLE ALTERNATIVES .............................................................. 30 6 DESCRIPTION OF THE AFFECTED ENVIRONMENT ......................................................... 34 6.1 THE BIO-PHYSICAL ENVIRONMENT ................................................................................. 34

6.1.1. Current land use .................................................................................................... 34 6.1.2. Topography ........................................................................................................... 35 6.1.3. Geology ................................................................................................................. 35 6.1.4. Watercourses and Wetlands .................................................................................. 35 6.1.5. Climate .................................................................................................................. 36

6.2 VEGETATION AND FLORISTICS ........................................................................................ 37 6.2.1. South African National Biodiversity Institute ........................................................... 37 6.2.2. Eastern Cape Biodiversity Conservation Plan ........................................................ 37

6.3 SOCIO-ECONOMIC PROFILE ............................................................................................. 37 6.3.1. Population .............................................................................................................. 37 6.3.2. Economy ................................................................................................................ 38 6.3.3. Employment ........................................................................................................... 38

7 PUBLIC PARTICIPATION .................................................................................................... 40 7.1 NOTIFICATION OF INTERESTED AND AFFECTED PARTIES ........................................... 40 7.2 COMMENTS AND RESPONSES.......................................................................................... 40 8 KEY FINDINGS OF THE SPECIALIST STUDIES ................................................................. 44 8.1 AIR IMPACT REPORT - AIRSHED ...................................................................................... 44

8.1.1. Introduction and Scope .......................................................................................... 44 9 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT .................................... 47 9.1 ASSUMPTIONS AND LIMITATIONS .................................................................................... 47 9.2 POSSIBLE ENVIRONMENTAL ISSUES AND IMPACTS ..................................................... 47 9.3 GENERAL IMPACT ASSESSMENT ..................................................................................... 48 9.4 SPECIALIST IMPACT ASSESSMENTS ............................................................................... 48 9.5 METHODOLOGY FOR ASSESSING IMPACTS AND ALTERNATIVES .............................. 48

9.5.1. Introduction ............................................................................................................ 48 9.5.2. Description of criteria ............................................................................................. 48

10 IMPACT ASSESSMENT ....................................................................................................... 51 10.1 SUMMARY OF FINDINGS AND COMPARATIVE ASSESSMENT OF IMPACTS ................ 52

10.1.1. DEVELOPMENT IMPACT ASSESSMENT ............................................................ 52 10.1.2. NO-GO IMPACT ASSESSMENT ........................................................................... 53

11 ENVIRONMENTAL IMPACT STATEMENT .......................................................................... 54



11.1 SUMMARY OF THE KEY FINDINGS OF THE EIA ............................................................... 54 11.2 CONSIDERATION OF ALTERNATIVES .............................................................................. 54 12 EAP OPINION AND RECOMMENDATIONS ........................................................................ 56 12.1 RECOMMENDATIONS OF THE EAP ................................................................................... 56 12.2 OPINION OF THE EAP ......................................................................................................... 56 12.3 ENVIRONMENTAL AUTHORISATION VALIDITY ............................................................... 57 12.4 EAP DECLARATION ............................................................................................................ 57 13 OTHER ................................................................................................................................. 58 APPENDIX A: PUBLIC PARTICIPATION DOCUMENTS .................. ERROR! BOOKMARK NOT DEFINED. APPENDIX B: INTERESTED AND AFFECTED PARTIES DATABASE ... ERROR! BOOKMARK NOT DEFINED. APPENDIX C: IMPACT ASSESSMENT TABLES.............................. ERROR! BOOKMARK NOT DEFINED. APPENDIX D: SPECIALIST STUDIES ........................................... ERROR! BOOKMARK NOT DEFINED. APPENDIX E: ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR)........ ERROR! BOOKMARK NOT

DEFINED. APPENDIX F: CV’S ................................................................... ERROR! BOOKMARK NOT DEFINED.

LIST OF FIGURES Figure 1.1 Locality of Erf 60843 in Zone 1B. .......................................................................................................... 5 Figure 1.1: The EIA Process flow chart .................................................................................................................. 8 Figure 2.1. The site for the proposed plastics refining facility is indicated in red. Surrounding landmarks

include the East London Airport, and the R72. ............................................................................................ 11 Figure 2.2: Photographs of the proposed site: Dominant grassland with scattered Acacia natalitia ............... 12 Figure 2.3: Forklift transporting a bag similar to those to be used in the Clariter facility. ................................. 14 Figure 3.1. Proposed facility layout. ...................................................................................................................... 24 Figure 3.2: The Process Flow Diagram for the plastic waste refining facility. .................................................... 25 Figure 6.1. Current state of the site. ..................................................................................................................... 34 Figure 6.2. Surrounding land uses within 5 km of the proposed site. ................................................................. 35 Figure 8.1. Average rainfall and temperature patterns in East London. ............................................................. 36 Figure 8.2. Wind data for East London (www.windfinder.com) ........................................................................... 37 Figure 8.2: Unemployment Rates in BCMM 1996 to 2011 .................................................................................. 39 Figure 8.1: Simulated annual average SO2 GLCs. Note the limit is 50 µg/m

3, and even at the site itself, the

simulated concentration is only 1.7 µg/m3. ................................................................................................... 46

LIST OF TABLES Table 1.1: Listed activities triggered by the plastics refining facility. .................................................................... 6 Table 2.1. Property locality and associated attributes. ........................................................................................ 12 Table 2.2: Parameter limits set by the BCMM Water Services By-law for Trade Effluent release and

comparison with the predicted effluent quality of the respective effluent streams to be discharged to the

municipal sewers. ........................................................................................................................................... 19 Table 3.1: Environmental legislation considered in the preparation of the report ....................................................... 26 Table 5-1. NEMA Environmental Management Principles .................................................................................. 26 Table 6.1: The alternatives for the proposed Clariter Waste Plastics Refining Facility ..................................... 31 Table 7.1. Comments and Responses ................................................................................................................. 41 Table 8.1: Potential impacts identified in the Scoping Phase. ............................................................................ 47 Table 9-1: Significance Rating Table .................................................................................................................... 48 Table 9-2 Impact Severity Rating .......................................................................................................................... 49 Table 9-3 Overall Significance Rating ................................................................................................................... 50 Table 10.1: Identification of issues and impacts and the relevant phases in which the impacts will be felt. ... 51 Table 10-1 Impact Assessment for impacts identified by the General Impact Assessment ............................. 52 Table 10-2. Impacts associated with the No-go alternative ............................................................................... 53



1 INTRODUCTION

1.1 Background to the Study Clariter Recycling and Refining Centre Ltd (Clariter) has developed a technology for converting different types of polyolefin plastics into hydrocarbon liquid materials. The Company proposes to establish a pilot-scale Industrial Scale Plant (ISP) in the East London Industrial Development Zone (ELIDZ) as a precursor to the establishment of a Full Scale Plant (FSP) at a location not yet determined. The ELIDZ has an existing Environmental Authorization for light industry issued in 2001, which allows for the development of a light industrial zone. Additional activities specific to a particular facility must still obtain Environmental Authorisation. The facility is proposed to be constructed on erf number 60843 in ELIDZ Zone 1 B.

Figure 1.1 Locality of Erf 60843 in Zone 1B. A primarily research and development (R&D) facility, the facility will accept pre-sorted and cleaned mixed plastic waste from specific industries, and refine these to produce up to nine pure hydrocarbon compounds for sale to organic chemicals consumers. The construction and operation of the facility triggers activities listed under the EIA regulations (2014), the Waste Act regulations (2013) and the Air Quality Act (AQA) regulations (2013). As such, an integrated application form for authorisation of both the waste and EIA activities has been submitted to the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT). An additional application has been made to the Air Quality Officer at the Buffalo City Metropolitan Municipality (BCMM) for authorisation of the activities listed under the AQA regulations. EOH Coastal and Environmental Services (CES) have been appointed by Clariter as the Environmental Assessment Practitioner (EAP) to secure the necessary environmental authorisations.

60843



1.2 The Environmental Impact Assessment Process The regulation and protection of the environment within South Africa occurs mainly through the application of various items of legislation, within the regulatory framework of the Constitution (Act 108 of 1996). The primary legislation regulation for Environmental Impact Assessments (EIA) within South Africa is the National Environmental Management Act (NEMA, Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to the authorisation from either the Minister or the provincial Member of the Executive Council (MEC). In addition, NEMA provides for the formulation of regulations in respect of such authorisations. The EIA regulations (2014) allow for a Basic Assessment process for activities with limited environmental impact (listed in GN R. 983 and GN R.985, as amended in 2014) and a more rigorous two-tiered approach to activities with potentially greater environmental impact (listed in GN R. 984, 2014). This two-tiered approach includes both a Full Scoping and EIA process.

1.2.1. Listed activities triggered

The proposed development activities trigger the need for a Full Scoping and EIA process under the EIA Regulations of 2014 (Government Notices No. R. 983, R. 984 and R.985), the Waste Act Regulations of 2009 (Government Notice 921), and the Air Quality Act Regulations ( Government Notice 983). The listed activities that have been applied for are provided in Table 1.1 below. Table 1.1 also lists the activities requiring authorisation in terms of the NEM: Air Quality Act and the NEM: Waste Act regulations. Both of these Acts use the EIA process as described in GN R982 as the main tool for assessment of the potential impact of the triggered activities. As such, this Environmental Impact Report is compiled to fulfil the requirements of all licensing authorities. Table 1.1: Listed activities triggered by the plastics refining facility.

ACTIVITIES TRIGGERING LICENCE REQUIREMENTS

Legislation Listing Description Scope of EIA

EIA Regulations 2014 (GNR 984)

4 The development of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 m3.

Full scoping and EIA

EIA Regulations 2014 (GNR 984)

28 Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004


Waste Act Regulations (GNR 921)

Category A – 2

Recycling or recovery of waste The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility that has an operational area in excess of 1000m2.

Basic Assessment

Category A – 5

Recycling or recovery of waste The recovery of waste including refining, utilization or co-processing of waste in excess of 10 tons but less than 100 tons per day

Category A – 6

Treatment of waste The treatment of general waste using any form of treatment at a facility that has the capacity to process in excess of 10 tons but less than 100 tons.

Category A - 12

Construction, expansion or decommissioning of facilities and associated structures and infrastructure The construction of a facility for a waste management activity listed in Category A of this Schedule.



Air Quality Act Regulations (GNR 893)

Category 2 – 2.4

Storage and Handling of Petroleum Products Full scoping and EIA

Category 6

Organic Chemicals Industry All installations producing or using more than 100 tons per annum of any of the listed compounds:

Organic chemicals not specified elsewhere in the regulations


The facility proponent is initially required to submit a report detailing the scoping phase (Scoping Report), and set out the terms of reference for the EIA process (Plan of Study for EIA). This is then followed by a report detailing the EIA phase (EIR). The competent authority will issue a final decision subsequent to their review of the final EIR. A flow diagram outlining the EIA process is shown in Figure 1.1. The competent authority, that must consider and decide on the application for authorisation in respect of the activities listed in Table 1.1, is the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) for the EIA and Waste Act triggers, and the BCMM Air Quality Officer for the AQA triggers.



Figure 1.1: The EIA Process flow chart

1.3 Scoping Phase The Scoping Phase is designed to determine the “scope” of the subsequent Environmental Impact Assessment (EIA), conducted in fulfilment of the application for authorisation. The overall aim of the Scoping Phase is to determine the environmental issues and impacts associated with the proposed housing development that require further investigation in an EIA. The purpose of scoping is therefore to identify:

Issues

Impacts

Alternatives

Contextualise Proposed Development

Pre-Application Planning (Determine assessment process using NEMA, 1998 and G/N 983, 984 and 985 of 2014)

Adopt the Scoping & Environmental Impact Assessment Process

Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping Report and Plan of Study of the EIA

Accept

Request Amendment

s

Conduct Environmental Impact Assessment. Compile EIR and EMP

Public Review of EIR and EMP

Authority Review of EIR and

EMP

Accept

Request Amendments

Issue Environmental Authorisation and notify

applicant of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any

We are here



An integral part of the Scoping Phase is the initial public participation process (PPP). This process ensures that all possible interested and affected parties (I&APs) are informed of the proposed activity and are provided with an opportunity to comment and identify issues.

1.4 Nature and Structure of this Report This report fulfils the requirement of the EIA Regulations (2014) for the documentation of the EIR Phase. The structure of this report is based on APPENDIX 3 of GN No. 982, of the Environmental Impact Assessment Regulations (2014), which clearly specifies the required content of an Environmental Impact Report.

1.5 Details and Expertise of the Environmental Assessment Practitioner In fulfilment of the above-mentioned legislative requirements, the details of the Environmental Assessment Practitioner (EAP) that prepared this draft EIR as well as the expertise of the individual members of the study team are provided below. CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Plans (EMPs), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes (www.cesnet.co.za). CES has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries. We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning Dr Alan Carter Alan holds a PhD in Plant Sciences and is a Certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has over 20 years of experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions and is a certified ISO14001 Environmental Management Systems Auditor.

In terms of APPENDIX 3 of the EIA Regulations (2014), an environmental impact 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 (ii) The expertise of the EAP , including a curriculum vitae;

http://www.cesnet.co.za/



Dr Cherie-Lynn Mack Principal Environmental Consultant, holds a PhD and MSc (with distinction) degrees in Environmental Biotechnology, with a BSc degree in Microbiology and Biochemistry. She has postgraduate research experience in industrial and domestic wastewater treatment technologies, with particular emphasis on the coal and platinum mining industries. Her interests lie in the water sector, with experience in ecological reserve determination and water quality monitoring and analysis. She has experience in water quality analysis and industrial wastewater treatment research. Cherie-Lynn is a registered Professional Natural Scientist (No. 400323/14).

Airshed – Air Emissions Modelling Airshed Planning Professionals (Pty) Ltd, a South African company, was established in 2003, specialising in all aspects of air quality, ranging from nearby neighbourhood concerns to regional air pollution impacts. Airshed comprises a team of professional air quality scientists drawn from a range of disciplines including chemical and mechanical engineering, meteorology, geography and environmental management. The Airshed team holds extensive expertise and experience in all aspects of air pollution impact assessment and air quality management. Airshed is at the forefront of air quality science encouraging and facilitating further study and skills development among our staff and through our association with Universities and research organisations. The team are motivated, capable and well equipped to meet the challenge of managing air quality within the sustainable development concept.



2 PROJECT DESCRIPTION

2.1 Property Locality The site proposed for the Clariter plastics refinery facility is located within the East London Industrial Development Zone, within the BCMM. Figure 2.1 indicates the property in relation to landmarks in the general vicinity. Table 2.1 lists property attributes such as the 21 digit Surveyor General code, the size of the property and the GPS co-ordinates of the four corners of the site.

Figure 2.1. The site for the proposed plastics refining facility is indicated in red. Surrounding landmarks include the East London Airport, and the R72.

ELIDZ

Zone 1 B

In terms of APPENDIX 3 of the EIA Regulations (2014), an environmental impact 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 -

b) The location of the activity, including – i. The 21 digit Surveyor General code of each cadastral land parcel;

ii. Where available, the physical address and farm name; iii. Where the required information in terms of (i) and (ii) is not available, the coordinates of the

boundary or properties; c) A plan which locates the proposed activity or activities applied for at an appropriate scale; 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 associated structures and infrastructure related to the development;



Table 2.1. Property locality and associated attributes.

Attribute Property

21 digit SG code C02300040006084300000

Size 25 727.91 m2

North corner 33.055244° S; 27.835491° E

East corner 33.056390° S; 27.836196° E

South corner 33.057083° S; 27.834690° E

West corner 33.056058° S; 27.833839° E

Property Owner Clariter have bought the land, transfer is in progress

Dominant grassland with scattered Acacia natalitia

Figure 2.2: Photographs of the proposed site: Dominant grassland with scattered Acacia natalitia



2.2 The Process The plastic material (plastic feedstock) is transported to the facility in the form of shreds (ground/shred) packed into bags weighing approximately 0.5 tons per bag. A single truckload would constitute approximately 9 tons of feedstock; sufficient to supply the facility for 3 days at a daily production capacity of 2.9 tons. Pre-sorted, cleaned and shredded plastic material (plastic feedstock consisting of polyethylene, polypropylene and small amounts of polystyrene) is transported via truck to the plant in large bags. The conversion of plastics into hydrocarbons is based on a relatively mild thermal cracking process, whereby the plastics are converted into a so-called semi solid “paraffin mass” hydrocarbon mixture, which can then be further refined. The subsequent refining processes will result in the production of nine different hydrocarbon products. A detailed description of the chemical processes involved in the refining process is attached as Appendix A. Figure 3.2 indicates the process flow, from pelletised and shredded plastic feedstock to final storage of the nine hydrocarbon product compounds. Triggered listed activity:

NEMA Regulations 2014 (GNR 984)



Category A – 5

Recycling or recovery of waste The recovery of waste including refining, utilization or co-processing of waste in excess of 10 tons but less than 100 tons per day

Category A – 6

Treatment of waste The treatment of general waste using any form of treatment at a facility that has the capacity to process in excess of 10 tons but less than 100 tons.

Category A - 12

Construction, expansion or decommissioning of facilities and associated structures and infrastructure The construction of a facility for a waste management activity listed in Category A of this Schedule.


Category 6 Organic Chemicals Industry Organic Chemicals Industry All installations producing or using more than 100 tons per annum of any of the listed compounds:


2.2.1. Process Inputs

Plastic feedstock The refining process is based on the conversion of polyolefin plastics such as polyethylene (PE), polypropylene (PP) and polystyrene (PS) into pure hydrocarbon liquids. Plastics such as polyvinylchloride (PVC), polyacrylate (PA) and polyethylene terephthalate (PET) should not be present, or extremely limited as these compounds compromise the quality of the final products. The plastic feedstock is separated, washed, dried and shredded/ground before being transported to the facility in sealed bags such as that shown in Figure 2.3. Once delivered, the bags will be moved around using forklifts (Figure 2.3)



Figure 2.3: Forklift transporting a bag similar to those to be used in the Clariter facility.

BOX 1: FACILITY FEEDSTOCK The feedstock for the facility will look something like this:

And will be composed of the following plastic compounds: Polypropylene (PE) is the most widely used plastic in the world. Products made from this substance range from clear food wrap and shopping bags to detergent bottles and automobile fuel tanks. The main problem with PE is that it is not readily biodegradable without special treatment, and thus accumulates in the environment. PE can be separated into two types; high density and low density.



Polypropylene (PP) is used in a wide variety of applications including packaging and labelling, textiles, stationery and reusable containers. It is rugged and resistance to many chemical solvents, bases and acids. It is readily recyclable.

Polystyrene(PS) is one of the most widely used plastics worldwide, the scale of its production being several million kilograms per year. Uses include protective packaging, containers, lids, bottles, trays, and disposable cutlery. PS is very slow to biodegrade, and is abundant as a form of litter, especially in its foam form.

Thermal energy The energy required for the various unit processes within the facility will be predominantly supplied by a boiler to generate steam. It is proposed that the boiler be fuelled using diesel (18 kg/h). It is proposed that a boiler with a 196 kW capacity should suffice for the needs of the facility. A Hot Oil system (max 406 kW with max 30 kg/h diesel consumption) will also be used for heating within the process train. A standby power generator will also be housed on site. This generator will also use diesel, at an approximate rate of 25 kg/h.



The steam generator capacity is far below the 50 MW threshold for an Air Emissions License, and is still 10 times lower than the 10 MW threshold for declaration of a Small Boiler (controlled emitter as per GN R 831, 2013). Similarly, the hot oil heating system also falls below any thresholds for declaration or application for AEL. Triggered listed activity: NONE

2.2.1. Process Outputs Liquid hydrocarbon products The intermediate and final liquid hydrocarbon products are considered to be hazardous substances, primarily due to their volatility. Table 3.1 indicates the volumes of the tanks proposed for storage of both the intermediate and final products. The total volume of hazardous substance to be stored is estimated to be approximately 93 m3 at full capacity. The entire process is conducted in pressurized vessels, and the intermediate and final storage tanks are also pressurized. As required by the conditions for obtaining an atmospheric emissions license, a Leak Detection and Repair (LDAR) programme has been developed and will be implemented as part of the operation of the facility. The final product filling station (where products are decanted into saleable containers) will be equipped with a vapour recovery unit (VRU) similar to those used in commercial fuel filling stations. This will ensure that the smallest possible vapour releases will occur, thus minimising the potential for odours to reach any surrounding land users. The proprietary process produces a wide range of high purity and quality hydrocarbon products. The products are divided into families of solvents, oils and waxes. The following paragraphs provide general descriptions of the product types to be produced at the facility proposed for the ELIDZ: This group of products represents a diversity of aliphatic hydrocarbon fluid fractions after deep hydrorefining. The products are characterized by low aromatic (dearomatized) content, a low level of heteroatom impurities (e.g. sulphur, nitrogen, chloride), and a negligible reactive compound content (e.g. olefins), and low odour. Solventra The potential applications for the SOLVENTRA® group of products are diverse; e.g. as solvent for premium paints, resins and coatings, special degreasing fluids, car cosmetics products, printing & dying fluids, performance fluids in agriculture (herbicide and pesticide carrier), household cleaning fluids, etc. Oilter This group of products represents the light paraffinic mineral oil / light mineral white oil fractions deeply hydrorefined. It is characterized similarly to the Solvents with regards to the low aromatics and impurities. The OILTER® product has very low pour point, light viscosity, are colourless, and white in water. Typically, white oil products are applied in food processing (bakeries, granaries) and packaging, textile industry (impregnates), paper industry (additive carrier), shoe polish & waxes, speciality lubricants formulation as light white oils, agriculture for spray oil formulation and crops protection fluids and more. Clariwax Similar to Clariter's other products, its waxes are also characterized by the low level of aromatics and impurities. Its waxes are characterized by high melting point and have a high penetration giving the waxes good elastic properties and adhesive properties that is characteristic for microcrystalline waxes. Triggered listed activity:

http://wpedia.goo.ne.jp/enwiki/Solvent

http://wpedia.goo.ne.jp/enwiki/Oil

http://wpedia.goo.ne.jp/enwiki/Wax

http://wpedia.goo.ne.jp/enwiki/Herbicide

http://wpedia.goo.ne.jp/enwiki/Pesticide

http://wpedia.goo.ne.jp/enwiki/Mineral_oil

http://wpedia.goo.ne.jp/enwiki/Viscosity

http://wpedia.goo.ne.jp/enwiki/Microcrystalline




Category 2 – 2.4

Storage and Handling of Petroleum Products

Category 6 Organic Chemicals Industry All installations producing or using more than 100 tons per annum of any of the listed compounds:

Organic chemicals not specified elsewhere in the

regulations

Process residues The initial thermal cracking process results in two material streams; the process stream to be refined further, and a waste stream. The waste stream is a viscous liquid that is cooled and then discharged into drums for collection and utilization at a separate facility. This residue has a high calorific value, and could be burnt for energy recovery within the facility. This will be implemented in the full scale facility, but at the current pilot scale facility it will be collected and disposed of by a suitably licensed service provider. Triggered listed activity: NONE Wastewater The current design capacity for the facility indicates that at maximum, the facility will dispose of 19 m3 of wastewater per day at a rate of 0.8 m3/hour. This flow is made up of four liquid streams, emanating from different areas of the process. These streams are: 1. Brine effluent from the reverse osmosis (RO) water treatment plant

Treated water from the RO process will be used in the cooling tower and for steam generation.

The brine effluent composition is indicated in Table 2.2, where it can be compared to the BCMM Trade Effluent By-law limits for disposal to the municipal sewer system.

2. Cooling tower effluent

The cooling tower will be fed with treated water from the RO plant.

Biocide will be added in small amounts to prevent bio-fouling of the internal pipelines

pH adjustment will be required periodically. This will be achieved using sulphuric acid (H2SO4)

Due to constant evapouration of the cooling tower water, effluent from the tower may be concentrated (in terms of salinity) to somewhere between the levels of municipal water and the RO brine effluent (indicated in Table 2.2).

3. Process wastewater

Process wastewater consists of municipal water that has come into contact with process intermediates or process effluents. The vast majority will be from air emission control devices such as quenching towers and scrubbers.

Process wastewater will contain small volumes of dissolved hydrocarbon compounds. 4. Domestic wastewater

Wastewater from ablution and kitchen facilities. Properly designed, installed, and operated, grease traps can provide a treatment system for handling oily wastewater that prevents the entry of unacceptable levels of contamination to a storm sewer or sanitary sewer system. A number of grease traps have been designed into the facility, for removal of hydrocarbons from the various waste streams prior to their collection into a buffer tank (below). The grease traps will be cleared and cleaned by a suitably qualified and licensed service provider as and when necessary.



All of these streams are collected in a buffer tank prior to disposal into the sewerage system. The buffer tank allows for mixing and dilution of components, and will result in a final effluent that is compliant with the BCMM Trade Effluent By-law limits (Table 2.2). The buffer tank will also be equipped with a sampling port and a cut-off valve. Samples will be taken and analysed frequently, and if any component level is noted to exceed the limit, the valve will immediately be closed, and the tank will be drained and the effluent disposed of via alternate methods.



Table 2.2: Parameter limits set by the BCMM Water Services By-law for Trade Effluent release and comparison with the predicted effluent quality of the respective effluent streams to be discharged to the municipal sewers.

Buffalo City Metropolitan Municipality: Water Services By-law for Trade Effluent. Influent water Effluent Streams

Substance Schedule A*

Limit Schedule B#

Limit

Municipal Water Supply to

the ELIDZ

RO Effluent Cooling tower effluent

Process wastewater

Calcium carbide 0 0

Yeast and yeast waste 0 0

Radioactive wastes and isotopes 0 0

Degreasing solvents, petroleum spirit, volatile inflammable solvents or any substance whatsoever which may or is likely to give off an inflammable vapour at a temperature of 21°C

0 0

Coarse solids (e.g. potato and pineapple peels, wood, sand, stone, etc.)

0 0

Textile fibres or wood pulp fibres 0 0

Any chemical compounds of carbon which are not amenable to treatment by normal biological processes, e.g. non-biodegradable detergents, dyes and dye process residues

0 0

Suspended solids (mg/L) 1500 1500

Animal and vegetable oils, fats, greases and waxes (mg/L) 400 400

Tar products, distillates, bitumen and asphalts (mg/L) 50 50

Mineral oils, greases and waxes (mg/L) 50 50

Sugars and starches (as sucrose) (mg/L) 1000 1000

Cyanogen compounds (as HCN) (mg/L) 20 10

Sulphides, hydrosulphides and polysulphides (as S) (mg/L) 50 1

Sulphates ( as SO4) (mg/L) 500 250 15 78 15 - 78 15

Chlorides (as Cl) (mg/L) 750 N/A 84 436 84 – 436 84

Fluorides (as F) (mg/L) 5 5 0.11 0.57 0.11 – 0.57 0.11

Copper (as Cu) (mg/L) 20 3 0.039 0.039

Iron (as Fe) (mg/L) 20 20 0 0

Nickel (as Ni) (mg/L) 20 10 0 0



Chromium (as Cr) (mg/L) 20 3 0 0

Zinc (as Zn) (mg/L) 20 20 0 0

Total of metals Cu, Fe, Ni, Cr and Zn (mg/L) 50 50 0.039 0.039

Arsenic (as As) (mg/L) 5 5

Boron (as B) (mg/L) 5 5

Cadmium (as Cd) (mg/L) 5 1.5 0 0

Lead (as Pb) (mg/L) 5 3 0 0

Selenium (as Se) (mg/L) 5 5

Mercury (as Hg) (mg/L) 1 0.5

Total of metals As, B, Cd, Pb, Se and Hg (mg/L) 15 15 0 0

Total phenols (as phenols) (mg/L) 20 20 0 0

Anionic surfactants (mg/L) 750 750

Total phosphates (as P) (mg/L) 25 10 0.57 0.57

Temperature (°C) <44 <44

pH >6.0; <12.0 >6.0; <11.0 7.99 8.3 7.99 – 8.3 7.99

Electrical conductivity (mS/m at 20°C) <400 N/A 46.6 46.6

Sodium (mg/L) 500 N/A 92 523 92 - 523 92



Triggered listed activity: NONE Non-condensable gas emissions A non-condensable gas is emitted from chemical or petroleum processing units (such as distillation columns or steam ejectors). These gases are typically not easily condensed by cooling, and consist mostly of nitrogen, light hydrocarbons, carbon dioxide, or other gaseous materials. Gaseous impurities released via the various processes include (but are not necessarily limited to): H2S, HCl, NH4Cl, and NH4HS. All of these components are treated using a scrubber. The scrubber receives condensed vapours at a temperature of approximately 40° C. Demineralised water is added to avoid any salt deposition. The scrubber operates as follows:

Cold water (DI Water) is fed at the top of the column, which absorbs the water soluble impurities (nitrogen, sulfur, chloride and oxygen compounds). The wastewater is disposed of as set out in the wastewater section.

The unabsorbed gas remaining is almost pure Hydrogen (~99%). This stream is recompressed and fed back into the Hydrotreating reactors.

The Scrubber’s Receiver separates the two liquid phases (wastewater and hydrocarbons). The bottom one (Waste Water) as mentioned before is disposed of, and the top one (hydrocarbons) is sent to Low Pressure Flash Tank for further refining.

All excess off-gases from the production process are diverted to a flare for destruction. The stack will be located at 33°03’21.9”S; 27°50’02.85”E, in the northwest corner of the property. Table 2.3 indicates the parameters of the flare operation. These parameters were submitted to the Air Quality Specialist for analysis and dispersion modelling (Specialist Report as Appendix D).

Flare dimensions Flare height: 9.14 m Flare diameter: approx. 1.5 m

Flare operation parameters Normal Operation Emergency Operation

Operation time: approx. 8000 hrs/year Time of emission: 10 seconds per event

Volumes directed to flare for combustion:

7.1 kg/h Volumes directed to flare for combustion:

225 kg/h

Flow rate from flare: 140.2415 kg/h Flow rate from flare: 4437.9636 kg/h

Temperature of gases at exhaust:

200°C Temperature of gases at exhaust:

98 °C

Exhaust gas velocity: <1 m/s Exhaust gas velocity: 4.5 - 7 m/s

Exhaust gas composition (includes air component for combustion) Component Normal operation (kg/h) Emergency operation (kg/h)

N2 102 3230

O2 4 129

CO2 19.5 617

H2O 14.5 460

Carbon monoxide (CO) 0.025 1.5

NOx 0.005 0.31

Sulfur dioxide (SO2) 0.2 0.42

PM 0.0009 0.06

Hydrogen sulphide (H2S) 0.0004 0.0038

Aliphatic hydrocarbons (blend) (VOC)

0.01 0.64

Ammonia 0.0002 0.0034

tel:140.2415

tel:4437.9636

tel:0.025

tel:0.005

tel:0.0009

tel:0.0004

tel:0.0038

tel:0.0002

tel:0.0034



Hydrogen chloride (HCL) 0.024

The anticipated amount of gas emitted by the facility is 7.1kg/hour. This value is the sum of the maximum of all emissions from the process under normal operational conditions. Triggered listed activity:

NEMA Regulations 2014 (GNR 984)



Category 2 – 2.4

Storage and Handling of Petroleum Products

Category 6 Organic Chemicals Industry All installations producing or using more than 100 tons per annum of any of the listed compounds:


2.2.2. Possible future activities

In the future, it is possible that Clariter will set up a small demonstration facility for the education of new plastic feedstock suppliers in how the plastics must be processed before they can be used in the Clariter refinery process. This demonstration facility may include infrastructure for the sorting, washing, and pelletizing of the recovered plastic, but will only be capable of processing small amounts of waste plastic at any one time. It is not envisioned that the facility will operate continuously, or have an area for storage of unsorted plastic waste. This will be brought into the facility as and when it is required. In anticipation of this demonstration facility coming on line in the future, the following trigger has been included in the application:


Category A – 2

Recycling or recovery of waste The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility that has an operational area in excess of 1000m2.

2.3 The Infrastructure Infrastructure to be built on site includes the following:

Production and storage buildings: o Process Plant o Intermediate Product tanks o Final Products Warehouse and Filling Station

Offices and Administration Buildings: o Including ablutions and a laboratory

Services and Maintenance areas o Including refuse storage areas

Electrical Services: o Steam generator o N2 generation unit and compressor o Electrical switchboard room with transformer

Specialist production unit

tel:0.024



o Including H2 generator

Flare

Cooling tower system with pump station

Guard-house In total, the facility will comprise approximately 6070 m2, approximately 40 % of the total site area. The rest of the site will remain untransformed. Figure 3.1 indicates a proposed layout plan for the facility.



Figure 3.1. Proposed facility layout.



Figure 3.2: The Process Flow Diagram for the plastic waste refining facility.



3 RELEVANT LEGISLATION

3.1 Relevant Legislation used in the Compilation of this Environmental Impact Report

The table below summarises the legislation relevant to the proposed Clariter plastics refinery facility. Table 3.1: Environmental legislation considered in the preparation of the report

The Constitution Act 108 of 1996

This is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right: a) To an environment that is not harmful to their health or well-being. b) To have the environment protected for the benefit of present and future generations, through

reasonable legislative and other measures that:

(i) Prevent pollution and ecological degradation.

(ii) Promote conservation.

(iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

IMPLICATION FOR CLARITER: Obligation to ensure that the proposed development will not result in pollution and ecological degradation; Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development

RESPONSE TO LEGISLATION:

The EIA process supports the objectives of the Constitution. Clariter has undertaken an EIA process in terms of the National Environmental Management Act (107 of 1998).

National Environmental Management Act (NEMA) Act 107 of 1998

The objective of NEMA is: “To provide for co-operative environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote co-operative governance and procedures for coordinating environmental functions exercised by organs of state; and to provide for matters connected therewith.” A key aspect of NEMA is that it provides a set of environmental management principles that apply throughout the Republic to the actions of all organs of state that may significantly affect the environment. Section 2 of NEMA contains principles (see Table 5-1) relevant to the proposed project, and likely to be utilised in the process of decision making by DEA. Table 5-1. NEMA Environmental Management Principles

(2) Environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably.

(3) Development must be socially, environmentally and economically sustainable.

(4)(a) Sustainable development requires the consideration of all relevant factors including the following:

i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where

In terms of APPENDIX 3 of the EIA Regulations (2014), an environmental impact 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 -

e) A description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context;



they cannot be altogether avoided, are minimised and remedied; ii. That pollution and degradation of the environment are avoided, or, where they cannot be

altogether avoided, are minimised and remedied; iii. That waste is avoided, or where it cannot be altogether avoided, minimised and re-used

or recycled where possible and otherwise disposed of in a responsible manner.

(4)(e) Responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle.

(4)(i) The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment.

(4)(j) The right of workers to refuse work that is harmful to human health or the environment and to be informed of dangers must be respected and protected.

(4)(p) The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.

(4)(r) Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

As these principles are utilised as a guideline by the competent authority in ensuring the protection of the environment, the proposed development should, where possible, be in accordance with these principles. Where this is not possible, deviation from these principles would have to be very strongly motivated. NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons. In addition NEMA provides a framework for environmental impact assessments, the EIA Regulations (2014).

IMPLICATION FOR CLARITER: The developer must be mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate any potential impacts. The developer must also be mindful of the principles, broad liability and implications of causing damage to the environment. The Regulations promulgated in terms of NEMA identify three lists of activities which may not commence without an environmental authorisation from the competent authority.


The principles outlined in NEMA will be upheld in the construction and operation of the Clariter facility, through the EIA process and subsequent environmental management programme for the facility. A number of activities listed in the EIA Regulations are triggered in the Clariter facility proposal. As such, an EIA has been undertaken. The EIA process took the form of a Full Scoping and EIA.

National Environmental Management: Waste Act Act 59 of 2008

The National Environmental Management: Waste Act is the overarching legislation dedicated to the management of waste in South Africa. The Act defines waste as any substance, whether or not that substance can be reduced, re-used, recycled and recovered –

a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of; b) which the generator has no further use of for the purposes of production; c) that must be treated or disposed of; or d) that is identified as a waste by the Minister by notice in the Gazette, and includes waste generated

by the mining, medical or other sector, but - (i) a by-product is not considered waste; and



(ii) any portion of waste, once re-used, recycled and recovered, ceases to be waste. The Waste Act covers a wide spectrum of issues including requirements for a National Waste Management Strategy, definition of priority waste, waste minimisation, treatment and disposal of waste, Industry Waste Management Plans, licensing of activities, and waste information management. It now forms the central waste legislation for South Africa. This Act aims to enforce an integrated approach to waste management, with emphasis on prevention and reduction of waste at source and, where this is not possible, to encourage reuse and recycling in preference to disposal.

IMPLICATION FOR CLARITER: The listed waste activities under sections 19 and 20 of Chapter 4 of the Waste Act are published in Government Notice 921 of 2013 as Category A activities requiring a basic assessment process and Category B activities requiring a scoping and environmental impact reporting process set out in 24(5) of NEMA (No. 107 of 1998), as part of the waste management licence application contemplated in section 45 read with section 20(b) of the Act.


A number of activities listed in the Waste Act Regulations are triggered in the Clariter facility proposal. As such, an EIA has been undertaken. The EIA process took the form of a Full Scoping and EIA.

National Environmental Management: Air Quality Act Act 39 of 2004

The purpose of the Act is to set norms and standards that relate to:

institutional frameworks, roles and responsibilities;

air quality management planning;

air quality monitoring and information management;

air quality management measures;

general compliance and enforcement. The Act provides for the identification of priority pollutants and the setting of ambient standards with respect to these pollutants. The Act further provides for the establishment of a multi-stakeholder National Air Quality Committee, which will advise the Minister on the implementation of the Act. The Act ensures that air quality planning is integrated with existing activities. The implications of this are that plans that are required in terms of the NEMA must incorporate consideration of air quality. In addition, integrated development plans, developed by municipalities, also have to take air quality into account. The Act describes various regulatory tools that should be developed to ensure the implementation and enforcement of air quality management plans. These include a schedule of Listed Activities which require an Atmospheric Emission license.

IMPLICATION FOR CLARITER: The Regulations list activities which result in atmospheric emissions which have or may have a significant

detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage.


A number of activities listed in the Air Quality Act Regulations are triggered in the Clariter facility proposal. As such, an EIA has been undertaken. The EIA process took the form of a Full Scoping and EIA.

Other policy and documentation reviewed and found to be of relevance to the Clariter facility included:

The National Waste Management Strategy

The ELIDZ Environmental Management Framework

The BCMM Spatial Development Framework

The BCMM Trade Effluent By-law



4 PROJECT NEED & DESIRABILITY

In terms of APPENDIX 3 of the EIA Regulations (2014), an environmental impact 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 –

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

4.1 Reduction of waste to landfill Polyethylene, one of the plastic types to be refined, is one of the most common plastic products in the world, used for plastic packets, food packaging and many other applications in daily life. This plastic type alone could represent a significant share of the daily volume of waste sent to landfill. At present, only limited plastic recycling takes place within the BCMM. If the pilot-scale plant is successful, a large-scale facility would result in a significant reduction in the amount of plastic that is currently being sent to the l landfill sites throughout the Eastern Cape and even South Africa.

4.2 Skills transfer The intention of Clariter is to train local (South African) engineers, etc. in how to operate and manage the process. This will result in both job creation for newly graduated professionals and for semi-skilled and un-skilled workers in various aspects of the facility operation. Again, if the pilot-scale operation proves successful, the expansion to a large-scale facility would provide access to further skills development and job creation.



5 ALTERNATIVES


g) A motivation for the preferred development footprint within the approved site h) A full description of the process followed to reach the proposed development footprint within the

approved site, including: (i) Details of the development footprint alternatives considered

(ix) If no alternative development locations for the activity were investigated, the motivation for not considering such; and

(x) A concluding statement indicating the preferred alternative development location within the approved site;

One of the objectives of an EIA is to investigate alternatives to the proposed project.

5.1 Reasonable and Feasible Alternatives Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. “alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to; -

a) the property on which or location where it is proposed to undertake the activity; b) the type of activity to be undertaken; c) the design or layout of the activity; or d) the option of not implementing the activity.

The “activity” in this proposal, means the production of high value products from the refining of recovered waste plastic, thus all alternatives assessed must still seek to meet the requirements for undertaking THIS activity. Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following: • Alternative property or location where it is proposed to undertake the activity. • Alternative type of activity to be undertaken. • Alternative technology to be used in the activity.

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered with respect to the current wind farm project, including:

Alternative design or layout of the activity.

Alternative operational aspects of the activity. The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A “No-Go” alternative has been assessed for the proposed development.



Table 6.1: The alternatives for the proposed Clariter Waste Plastics Refining Facility

Alternative level Alternatives Advantages Disadvantages Reasonable

and feasible Further assessment

Comments

Property or location This refers to the fundamental location options, such as Greenfield vs. a Brownfield site, etc. and the environmental risks and impacts associated with such options.

Alternative location 1 – Zone 1 B erf 60843 (Preferred alternative)

Located close to required service infrastructure such as water services, electricity supply, sanitation, etc.

Located in an area zoned for light industry.

Located within the ELIDZ, so access to additional support provided by the ELIDZ to its tenants.

Located close to major industries for access to feedstock plastic waste.

Site is currently untransformed, but within an industrial development zone, this will not be the case indefinitely.

YES YES None

Alternative location 2 - None

NO NO None

Type of activity This refers to the fundamental land use options, such as industrial, residential, infrastructure, farming, conservation, etc. and the environmental risks and impacts associated with such options

Alternative activity 1 – Refining of plastic waste (Preferred alternative)

Contribute to reduction in waste to landfill

Beneficiation of waste to valuable hydrocarbon products.

Compliant with ELIDZ zoning

None YES YES None

Alternative activity 2 – None

The land is located within an IDZ, so alternative land uses such as residential or agricultural use will not occur on site.

NA NA NA None



Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comments

Type of technology This refers to the fundamental technology options, such as energy generation from wind vs. coal fired power plant, etc. and the environmental risks and impacts associated with such options.

Alternative technology 1 – proprietary waste plastics refining process: multiple products (Preferred alternative)

Clariter have a proprietary process for the refining of plastic waste, i.e. they are the experts when it comes to this process

YES YES None

Alternative technology 2 – proprietary waste plastics refining process: synthetic crude oil for fuel production

Proprietary process owned by Agilyx

YES NO Although this is a feasible alternative for the recycling of waste plastic, it is not a reasonable alternative to expect the applicant to buy the rights to a different proprietary process when they already own a waste plastic recycling process.

Design or layout This relates mostly to alternative ways in which the proposed development or activity can be physically laid out on the ground to minimise or reduce environmental risks or impacts

Alternative layout 1

The layout proposed will be designed to ensure maximum manufacturing efficiency with minimal unnecessary impact on the environment.

YES YES None



Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comments

Operational aspects This relates mostly to alternative ways in which the development or activity can operate in order to reduce environmental risks or impacts

Alternative operational activity 1 (Preferred alternative)

The facility is designed to operate 24 hours per day, 7 days per week.

YES YES None

No-go option This refers to the current status quo and the risks and impacts associated to it.

Existing activities on site include: Untransformed land within an existing industrial development zone

Will remain relatively undisturbed until another tenant is found to develop the site.

YES YES None



6 DESCRIPTION OF THE AFFECTED ENVIRONMENT


h) A full description of the process followed to reach the proposed development footprint within the approved site, including: (iv) The environmental attributes associated with the development footprint alternatives

focussing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

6.1 The Bio-Physical Environment

6.1.1. Current land use

The site is currently unused and untransformed. Figure 6.1 indicates the current state of the property (adjacent to the green palisade boundary fence).

Figure 6.1. Current state of the site. Figure 6.2 indicates the major surrounding land uses. The site is indicated by the yellow polygon.



Figure 6.2. Surrounding land uses within 5 km of the proposed site.

6.1.2. Topography The topography of the site is generally flat, with a mild slope from south to north.

6.1.3. Geology The physical features of the site is typical of the BCMM coastline where dolerite outcrops occur (e.g. Kwelera, Gonubie, West Bank, Igoda, Christmas Rock) with the majority and remainder of the geological formations being primarily calcareous sandstones of the Algoa Group. A few deposits of grey and grey/red mudstone of the Beaufort Group also occur but are limited in their extent (e.g. Keiskamma, Gulu, Winterstrand, Gonubie). The marine origin of these formations results in the high salinity of groundwater found in the Amatole catchments and Fish River basin.

6.1.4. Watercourses and Wetlands The site lies between the Hickmans and Mvubukazi Rivers, both small, temporary open/closed systems of less than 8 km. The boundary of the site is approximately 400 m from the Hickmans River, and is separated from it by a number of vacant sites, and an arterial road. No wetlands occur on site.

A



6.1.5. Climate East London receives an average of 593mm of rain per year, with most occurring in the summer months (Figure 8.1a). The monthly distribution of average daily maximum temperatures (Figure 8.1b) shows that the average midday temperatures for East London range from 20°C in July to 26°C in February. The region is the coldest during July when the mercury drops to 9.3°C on average during the night (SA Explorer, 2015). Figure 8.2 indicates average wind data based on observations taken over the past 15 years at the East London Airport.

Figure 8.1. Average rainfall and temperature patterns in East London.

a b



Figure 8.2. Wind data for East London (www.windfinder.com)

6.2 Vegetation and Floristics

6.2.1. South African National Biodiversity Institute Mucina and Rutherford (2006) have classified the vegetation type on site as Albany Coastal Belt. This vegetation type is distributed within 15 km of the coastline, from Kei Mouth to the Sunday’s River. Typically the land is dominated by short grasslands punctuated by scattered bush clumps or solitary Acacia natalitia trees. It is categorised as LEAST THREATENED.

6.2.2. Eastern Cape Biodiversity Conservation Plan The site is classified by the ECBCP as a Critical Biodiversity Area (CBA 2). However, the land has been rezoned and authorisation given for the construction and operation of suitable light industry within the ELIDZ. In fact, a significant number of facilities have been constructed and are currently operating within the ELIDZ.

6.3 Socio-Economic Profile

6.3.1. Population

Based on the IDP, BCMM population has shown a steady growth over the years. It has grown from 704,855 in 2001 to 755,200 in 2011 (0.7% growth rate). The population demographic based on the 2011 census was 85% black, 7.71% white, 6.02% coloured, 0.83% Indian/Asian and 0.33% other. The gender distribution is 47.5% male and 52.5% female. Age distribution revealed that there is a relatively high youth component of the population, with 37.3% between the ages of 15 and 35.



6.3.2. Economy

Buffalo City is classified nationally as having “medium potential” and is therefore not seen to be a national development priority, with Coega and Nelson Mandela Metro receiving priority in terms of the allocation of national infrastructure funding. This situation exists partly because of a lack of national understanding regarding the critical importance of Buffalo City in servicing a broader regional and rural economy which contains about 4 million people. The success of the Buffalo City and regional economy cannot be separated. The City acknowledges that low economic growth and a high rate of unemployment are still prevalent and present a major challenge. This further translates to relatively high levels of poverty which is widespread within the City Historically, levels of development in the Buffalo City area have been negatively affected both by its comparatively distant location in relation to the major centres of economic activity in South Africa (Johannesburg, Cape Town and Durban) and by the previous socio-political and economic impact of policies. Consequently, while it is home to some 1,020,000 people, the majority of these are disadvantaged by their impoverished circumstances and low levels of skills. Disposable income, too, is scarce in Buffalo City as a whole and there is a consequent need to focus on overcoming the legacy of under-development affecting its people and the local economy. This legacy of uneven and relatively low economic growth in Buffalo City has resulted in, and compounded the consequences of, a land use and settlement pattern that is characteristically fragmented and predominantly of a low density. The following features are noted:

The Gross Value Added by the region is R30 billion (ECSECC, 2010).

The Gross Domestic Product by the Region is R34 billion (ECSECC, 2010).

There is a concentration of economic activity in centres such as the East London and King William’s Town Central Business Districts, and in areas such as Vincent and Beacon Bay (Regional Shopping Centres)

6.3.3. Employment

BCMM has high levels of unemployment, at around 30% or 75,000 people, associated with much reliance on survival in the second informal economy. This is related to high levels of poverty (60% of all households earned less than R1600/ month in 2001) which in turn constraints BCM’s ability to deliver basic services in a sustainable manner. Significant service delivery backlogs exist, including an estimated 130,000 housing units being required in the period of 2007 – 2027. The main perceived weakness of the business environment are distance from markets/ customers, transport costs and congestion, and lack of government services. While the two main perceived strengths of the business environment are location being accessible to clients, customers and markets, and the accessibility to logistics infrastructure such as the port, airport, and highways. The constraints on business growth include the lack of available labour force skills and availability of finances. In addition to low levels of economic growth, unemployment is also linked to skills levels of the labour force. Literacy levels stayed stagnant between 1996- 2001 at 77% and 9.5% of the population having no education. This challenge is seen by BCMM as one of the major contributors to systemic poverty and unemployment that the municipality experiences. With less than 10% of the population with no matric or post matric qualification and 37% with no schooling at all there is a need to energise efforts to improve education and skills development.



Figure 8.2: Unemployment Rates in BCMM 1996 to 2011



7 PUBLIC PARTICIPATION


h) A full description of the process followed to reach the proposed development footprint within the approved site, including:

(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 incorporating them;

7.1 Notification of interested and affected parties Please note that all proof of Public notification (images and photographs) are attached in Appendix A.

7.2 Comments and Responses The table below (Table 7.1) indicates all of the comments received, and the responses made to these comments indicating how they have been addressed in the EIR.



Table 7.1. Comments and Responses

Organisation and

Name of

Commenting Person

Document to which

comment refers Comment Response

BCMM: Directorate

Health and Public

Safety (Air Quality)

Mr Alan McIntyre –

Senior Environmental

Pollution Officer

Draft Atmospheric

Emissions License

(AEL) Application

1. The mailing address as well as the latitude

and longitude of the location of the facility

must be included in Part A.2 of the

application.

The mailing address and the latitude and

longitude of the facility have been included

in Part A.2.

2. The pollutants and emission limits detailed in

Part A.5 of the AELA must be aligned with all

of the controlled pollutants and emission

limits prescribed in the Listed Activities and

Emission Standards Regulations for the

various categories of activities for which

application has been made.

Amended.

3. The consumption rates in the „Raw Materials

Used‟ table in Part C of the AELA should

correspond with all the quantities listed in the

Atmospheric Impact Report or alternately

clarity should be provided on this.

Amended to correspond with the AIR.

4. A number of emission control devices and

associated pollutants are listed under Part D

of the AELA whereas the Atmospheric

Impact Report does not list any devices.

Comments are requested as to whether the

devices are not equipment associated with

production processes at the plant and not

necessarily equipment specifically designed

and placed at the plant to control air

pollutant emissions.

The emission control devices listed in Part

D of the AELA are indeed directly

associated with the production process, and

all off-gases collected by these devices are

eventually directed to the flare. As such,

the flare is the ultimate emission control

device. This has been amended in both the

AELA and the AIR to reflect the flare as the

only emission control device.

5. The AELA details one point source of

emissions under Part E of the AELA i.e. the

The results of the AIR indicated that

modelled together, all 14 point sources



flare, whereas the Atmospheric Impact

Report includes fourteen. Clarity is needed

on this.

resulted in a negligible negative impact on

the environment. As such, just the flare was

included in the AELA. This has been

amended in the AELA to reflect the same

information as presented in the AIR.

6. The requirements stipulated in the Listed

Activities Regulations applicable to the

various categories of activities for which

application has been made must be

complied with and this compliance must be

confirmed in the AELA or where necessary

in attachments to the AELA. Requirements

that are relevant include:

The provision of a Leak Detection and Repair

(LDAR) programme approved by the

licensing authority. The LDAR must be

included as an attachment to the AELA.

An LDAR programme is attached to the

amended AELA.

Specific types of storage vessels depending

on the vapour pressure of the contents of the

vessels. An indication of the vapour pressure

and the types of tanks must be included in

the AELA. The actual temperature in the tank

should be used for vapour pressure

calculations.

The detail requested has been attached to

the AELA as an appendix.

The stipulations relating to the monitoring of

emissions with specific reference to the list of

monitoring requirements applicable to the

thermal treatment of general and hazardous

waste.

This activity has been removed from the

AELA based on the fact that Clariter will not

be treating waste, but recovering sorted,

washed and pelletised plastic feedstock to

produce high-value hydrocarbon products.

Final Scoping

Report

7. With specific reference to the Final Scoping

Report in addition to the possible

environmental issues and impacts identified



in Section 9.1 of the report the following

matters should be included in the

Environmental Impact Assessment:

An indication of the likelihood of malodorous

emissions from the plant, the level of the

severity of the malodours and if significant

the impact on receptors, as well as details of

control measures.

The entire process is sealed and

pressurized. The only possible places

where odours may be generated would

be at the product filling station and at the

flare. The filling station will be fitted with

a vapour recovery unit similar to those

found at conventional fuel filling stations,

and the flare will produce predominantly

N2 gas, which is odourless.

This potential impact has been assessed

in the EIR and found to have a negligible

negative impact.

An assessment of littering of the environment

from windblown shredded plastic as well as

plastic discharged with storm water, including

details of the design of the plant and

management measures to control this.

Pelletized plastic is delivered to the

facility in sealed bags. The bags are

stored in an fully enclosed storage room

prior to being moved by forklift to the

extruder room, where the plastic is fed

into the initial stages of the process. The

extruder room is also a fully enclosed

room with no drains leading to storm

water diversion systems.

Any plastic pellets spilled during storage

or during delivery to the extruder will be

swept up and diverted back into the

process. This potential impact has been

assessed in the EIR, and found to have

a negligible negative impact.



8 KEY FINDINGS OF THE SPECIALIST STUDIES


k) Where applicable, a summary of the findings and recommendations of 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 assessment report;

The following discussion summarises the key findings of the specialist studies. Full reports have been attached in Appendix D of the EIR.

8.1 Air Impact Report - Airshed

8.1.1. Introduction and Scope Airshed was commissioned by EOH to undertake an Air Quality Assessment for the proposed Clariter recycling and refining facility (the Project) in East London. Clariter Recycling and Refining Centre Ltd. (Clariter) has developed a technology for converting different types of polyolefin plastics into hydrocarbon liquid materials. Clariter proposes to establish a pilot-scale Industrial Scale Plant (ISP) in the East London Industrial Development Zone (ELIDZ) as a precursor to the establishment of a Full Scale Plant (FSP) at a location not yet determined. The ELIDZ has an existing Environmental Authorization for light industry issued in 2001, which allows for the development of a light industrial zone. Additional activities specific to a particular facility must still obtain Environmental Authorisation. The facility is proposed to be constructed on erf number 60843 in ELIDZ Zone 1B. The process falls under two different Listed Activities (set out in regulations under Section 21 of the National Environmental Management Air Quality Act), namely Category 2.4: Storage and Handling of Petroleum Products and Category 6: Organic Chemicals Industry; and thus requires an Atmospheric Emissions License (AEL) to operate. As part of the AEL application, an Air Impact Report (AIR) is required. The Air Quality Impact Assessment for the Project facility forms part of the subject of this Atmospheric Impact Report (AIR). The following tasks are included:

A baseline assessment including: o The characterisation of atmospheric dispersion potential of the Project site based on

updated meteorological data.

o The characterisation of existing ambient air quality based on available ambient air quality monitoring data.

An impact assessment, including: o The estimation of emissions from proposed operations.

o Dispersion modelling to predict incremental and cumulative ambient air concentrations in order to assess compliance with National Ambient Air Quality Standards (NAAQS) and other international health risk screening criteria or guidelines; and

A comprehensive atmospheric impact report (AIR) with; o A summary of all baseline monitoring results

o Emissions inventory

o Model input parameter description

o Model results

o Discussion of model results, with specific reference to the motivation for the AEL application.



Approach and Methodology The baseline assessment includes a study of the legal requirements pertaining to air quality, a study of the physical environment of the area surrounding the project and the collection and analyses of available ambient air quality and meteorological data. Meteorological data from the SA Weather Services station East London was obtained for the period 2012-2014 and is regarded representative of the weather conditions at the Project site. In the evaluation of air emissions and ambient air quality impacts, reference was made to National Ambient Air Quality Standards (NAAQS), as well as National Minimum Emission Standards (MES) as set out in regulations under the National Environmental Management Air Quality Act (Act No. 39 of 2004) (NEMAQA). Health impacts associated with non-criteria pollutants emitted from mobile sources are assessed according to guidelines published by the relevant institutions The study assesses the air quality impact of the proposed operation on human health and environment. Emissions from the stacks are expected to comply with the Minimum Emission Standards (MES) set out in regulations under Section 21 of the National Environmental Management Air Quality Act (Subcategory 2.4 and 6). In the absence of actual values, emission values obtained from similar plant design were supplied by Clariter. Emissions from the proposed Project are expected to be similar to these designed values and have been utilized in the emissions inventory. The pollutants assessed included the following: PM10, CO, SO2, NOx, hydrogen chloride, ammonia, aromatic hydrocarbons, aliphatic hydrocarbons, hydrogen sulfide, acetylene, ethylene oxide, acetaldehyde, formaldehyde, methanol, trichloroethylene, tetrachloroethylene, methylene chloride, hydrochloric acid, sulfuric acid, acetic acid, iron, manganese, chromium, nickel and benzene. Conclusions and Recommendations The findings from this study reveal that all pollutants assessed do not exceed the respective standards, assessment criteria or guideline values, during routine and emergency operations. Long-term average ground level concentrations (GLCs) were far below the respective standards, assessment criteria or guideline values (see Figure 8.1 as an example). Also, the assessment of increased lifetime cancer risk for all carcinogens assessed resulted in qualitative description indicating “very low risk”. It should be noted that the maximum GLCs were utilized in the assessment in order to ensure a conservative approach.



Figure 8.1: Simulated annual average SO2 GLCs. Note the limit is 50 µg/m3, and even at the site itself, the simulated concentration is only 1.7 µg/m3. The conclusion from the findings is that air quality impacts due to the proposed project operation will be low. The contribution of the pollutants’ impacts to the baseline is expected to be minimal, having little effect on the cumulative pollutant levels in the region. However, the findings from the study are valid provided that the operational emissions from the facility are similar to the design emissions utilized in this study. It is recommended, therefore, that an initial stack emission measurement campaign be conducted once the proposed facility is fully operational. This is to confirm that the emissions fall within the required standards. Subsequent stack monitoring campaign may be done as prescribed by the local authority.



9 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT


h) A full description of the process followed to reach the proposed development footprint within the approved site, including:

(v) The impacts and risks identified 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;

(vi) The methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks;

i) A full description of the process undertaken to identify, assess and rank the impacts the activity and associated structures and infrastructure will impose on the preferred location throughthe life of the activity, including –

(i) A description of all environmental issues and risks that were identified during the environmental impact assessment process; and

(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;

p) A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed;

In line with the above-mentioned legislative requirement, this chapter of the EIR details the approach to the EIA phase of the proposed water supply scheme with a particular focus on the methodology that was used when determining the significance of potential environmental impacts.

9.1 Assumptions and Limitations This report is based on information that is currently available and, as a result, the following limitations and assumptions are implicit–

The report is based on a project description taken from design specifications provided by the proponent.

Descriptions of the natural and social environments are based on limited fieldwork and available literature.

9.2 Possible Environmental Issues and Impacts Table 8.1 lists the environmental issues and resulting impacts that have been identified for the project development. Table 8.1: Potential impacts identified in the Scoping Phase.

Issue Potential Impact Gaseous emissions

Emission of non-condensable gasses, e.g. light hydrocarbons,

carbon dioxide, etc.

Emission of greenhouse gasses, e.g. carbon dioxide

Odorous emissions may impact on surrounding land users.

Wastewater

Release of trace hydrocarbons into the BCMM sewer system and into the sea via the Hood Point Sea Outfall



Release of acidic wastewater into the BCMM sewer system and into the sea via the Hood Point Sea Outfall

Release of wastewater containing elevated levels of nitrogenous compounds into the BCMM sewer system and into the sea via the Hood Point Sea Outfall

Storage of hazardous materials Emission of Volatile Organic Compounds fuel storage tanks

Waste Reduction in waste plastic volumes sent to landfill

Windblown plastic feedstocks as well as plastic feedstock displaced by stormwater may result in littering.

9.3 General Impact Assessment A general impact assessment was conducted based on site visits and information relating to the operation of the proposed Clariter plastic refinery facility.

9.4 Specialist Impact Assessments A series of specialist studies were conducted during the EIA and the outcomes will be summarised in this EIR. The specialists that conducted the specialist study were required to assess the foreseeable impacts of the proposed project from all possible angles and also to address the issues raised by I&APs in their report by gathering baseline information and identifying the possible impacts related to the proposed project. Mitigation measures for impacts were also provided. The specialist study undertaken for the EIA:

Air Quality Assessment and Dispersion Modelling The detailed specialist study has been attached to this report as Appendix D.

9.5 Methodology for Assessing Impacts and Alternatives

9.5.1. Introduction Identified impacts will be assessed against the following criteria: • Temporal scale • Spatial scale • Risk or likelihood • Degree of confidence or certainty • Severity or benefits • Significance The relationship of the issue to the temporal scale, spatial scale and the severity are combined to describe the overall importance rating, namely the significance.

9.5.2. Description of criteria Table 9-1: Significance Rating Table

Significance Rating Table

Temporal Scale (The duration of the impact)

Short term Less than 5 years (Many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.



Long term Between 20 and 40 years (From a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Spatial Scale (The area in which any impact will have an affect)

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area.

Study area The proposed site and its immediate environs

Municipal Impacts affect BCMM, or any towns within the boundary of the Metro.

Regional Impacts affect the wider district municipality or the province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Likelihood (The confidence with which one has predicted the significance of an impact)

Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.

Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring.

Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 9-2 Impact Severity Rating

Impact severity (The severity of negative impacts, or how beneficial positive impacts would be on a particular affected system or affected party)

Very severe Very beneficial

An irreversible and permanent change to the affected system(s) or party(ies) which cannot be mitigated. For example the permanent loss of land.

A permanent and very substantial benefit to the affected system(s) or party(ies), with no real alternative to achieving this benefit. For example the vast improvement of sewage effluent quality.

Severe Beneficial

Long term impacts on the affected system(s) or party(ies) that could be mitigated. However, this mitigation would be difficult, expensive or time consuming, or some combination of these. For example, the clearing of forest vegetation.

A long term impact and substantial benefit to the affected system(s) or party(ies). Alternative ways of achieving this benefit would be difficult, expensive or time consuming, or some combination of these. For example an increase in the local economy.

Moderately severe Moderately beneficial

Medium to long term impacts on the affected system(s) or party (ies), which could be mitigated. For example constructing a sewage treatment facility where there was vegetation with a low conservation value.

A medium to long term impact of real benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are equally difficult, expensive and time consuming (or some combination of these), as achieving them in this way. For example a „slight‟ improvement in sewage effluent quality.



Slight Slightly beneficial

Medium or short term impacts on the affected system(s) or party(ies). Mitigation is very easy, cheap, less time consuming or not necessary. For example a temporary fluctuation in the water table due to water abstraction.

A short to medium term impact and negligible benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are easier, cheaper and quicker, or some combination of these.

No effect Don‟t know/Can‟t know

The system(s) or party(ies) is not affected by the proposed development.

In certain cases it may not be possible to determine the severity of an impact.

Table 9-3 Overall Significance Rating

Overall Significance (The combination of all the above criteria as an overall significance)

VERY HIGH NEGATIVE VERY BENEFICIAL

These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance.

HIGH NEGATIVE BENEFICIAL

These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH.

MODERATE NEGATIVE SOME BENEFITS

These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant.

LOW NEGATIVE FEW BENEFITS

These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away.

NO SIGNIFICANCE

There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context.

DON‟T KNOW

In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people‟s psychological perspective of the environment.



10 IMPACT ASSESSMENT


h) A full description of the process followed to reach the proposed development footprint within the approved site, including: (vii) Positive and negative impacts that the proposed activity and alternatives will have on

the environment and on the community that may be affected focussing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

(viii) The possible mitigation measures that could be applied and level of residual risk; 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 mitigated;

The impact assessment identified and assessed impacts across four phases of development: • Planning & Design Phase • Construction Phase • Operational Phase • Decommissioning Phase Table 10.1 lists the major issues identified, expands on the potential impacts associated with the issue and also indicates during which phase of the development the impact will be exerted. Table 10.1: Identification of issues and impacts and the relevant phases in which the impacts will be felt.

Issue Impact Applicable Phase Dust Management Unloading of 500kg bags of pelletized

plastic into the automatic feeders may result in the release of dust particles into the atmosphere, creating a potentially hazardous environment for workers, and potential nuisance dust for surrounding land users.

Planning and Design √

Construction

Operation √

Decommissioning

Fugitive plastic waste There is potential for windblown plastic accidentally discarded by the facility to be transported into storm water infrastructure, etc.


Construction

Operation √

Decommissioning

Generation of odours It is possible that the facility may release malodorous emissions that could negatively impact on the surrounding land users.


Construction

Operation √

Decommissioning

General Waste Management

At a capacity of 9 tons every three days, there is the potential for disposal of 180 0.5 ton empty feed bags per month. Improper management of this general


Construction

Operation √



waste could lead to nuisance pollution of the surrounding areas, or worse.

Decommissioning

Recycling of Plastic Specific plastic types will be diverted from landfill to provide feedstock for the facility. This will impact the landfill positively in that non-biodegradable waste inflow will decrease, and more space will be available for other waste types.


Construction

Operation √

Decommissioning

Production of valuable products

The beneficiation of plastic waste to produce valuable products will potentially drive a renewed interest in recycling plastic, as waste plastic providers will be paid for their stock, and as the market for the valuable products increase, the need for feedstock will increase. This will have a knock-on effect of decreasing the volumes of specific plastics sent to landfill.


Construction

Operation √

Decommissioning

Waste Water Quality The quality of the process wastewater streams is influenced by the efficiency of the plastic beneficiation process. Process failures and emergency conditions may result in decreased wastewater quality. This could result in negative impacts on the ELIDZ sewerage infrastructure, and further, on the BCMM sewerage infrastructure, and at worst, on the marine environment to which the Hood Point Sea outfall discharges.


Construction

Operation √

Decommissioning

Below is a summary of the impact assessment in terms of number of impacts identified for each phase. The significance of each impact, both pre-and post-mitigation are also included in the summary for each specialist assessment. The full impacts tables can be located in Appendix C.

10.1 Summary of findings and comparative assessment of impacts A detailed impact assessment of all the identified impacts is provided in Appendix C. A breakdown of the assessments, presented in Table 10.1 – 10.2 below, provide insight into the key issues of all phases of the proposed development.

10.1.1. DEVELOPMENT IMPACT ASSESSMENT Table 10-1 Impact Assessment for impacts identified by the General Impact Assessment

PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH VERY HIGH


Planning & Design 1 4(+2) 1 0 6 (+2) 0 0

Operation 3 2(+2) 1 0 6 (+2) 0 0

TOTAL 4 6(+4) 2 0 12 (+4) 0 0



10.1.2. NO-GO IMPACT ASSESSMENT Table 10-2. Impacts associated with the No-go alternative

PRE-MITIGATION POST-MITIGATION



TOTAL (+2) 1 (+2) 1



11 ENVIRONMENTAL IMPACT STATEMENT


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;

n) The final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified through the assessment;

In line with the above-mentioned legislative requirement, this Chapter of the Draft EIR provides a summary of the findings of the EIA and a comparative assessment of the positive and negative implications of the proposed project and identified alternatives. This Chapter further identifies the Preferred Alternative in response to all proposed impact management measures, avoidance, and mitigation measures.

11.1 Summary of the key findings of the EIA The EIA process identified a total of 12 potential negative and 4 potential positive impacts across the planning and design and operation phase of the development. The impacts were divided evenly between the phases. Two HIGH negative impacts were identified (pre-mitigation), both of which related to impacts on the quality of the air as a result of the emission of pollutants such as SOx, HCL, H2S and VOC from the facility. The potential for air quality degradation was investigated by Airshed (Appendix D), who conducted a modelling exercise to determine the likelihood of deterioration in air quality as a result of emissions from the Clariter facility. The model incorporated information regarding local climate and topography, as well as estimated emission concentrations for the facility. The results of the exercise indicated that the pollutants assessed do not exceed the respective standards, assessment criteria or guideline values, during routine and emergency operations. Long-term average ground level concentrations (GLCs) were far below the respective standards, assessment criteria or guideline values. Also, the assessment of increased lifetime cancer risk for all carcinogens assessed resulted in qualitative description indicating “very low risk”. Further to this, the conclusion of the AIR stated that air quality impacts will be LOW, with the proviso that once operational, a stack emission measurement campaign is undertaken to confirm the findings based on the predicted emissions. All other impacts could be easily mitigated to LOW impact.

11.2 Consideration of Alternatives

Based on Table 6.1, the following alternatives were assessed during the scoping phase: Property or location alternatives

Erf 60834 located within ELIDZ Zone 1B (Preferred Alternative)

A second location within the ELIDZ was briefly contemplated, but the topography was considered unsuitable.



Type of activity

Light Industry: Refining of recovered plastic from waste sources (Preferred Alternative)

No alternative – the site is within the ELIDZ, which is zoned for Light Industry, no other types of activities are typically located here, e.g. residential, agriculture, etc.

Type of technology

Clariter proprietary process for refining recovered plastic waste to produce high-value products. (Preferred Alternative)

The alternative here would be to purchase the rights to a competitor‟s proprietary process, which is not considered a reasonable or feasible alternative.

Design or Layout

The layout indicated in Figure 3.1 is the Preferred Alternative, and has undergone significant iterations during the design process in order to ensure the optimum layout to address all potential issues (environmental, logistical, etc.) relating to construction and operation of the facility.

Operational aspects

The facility will operate 24 hours per day, 7 days per week. This will limit unnecessary use of additional electrical/thermal energy for start-up procedures and shut down procedures. This is the Preferred Alternative

The No-Go

The No-Go is NOT the preferred alternative. There is no reason, based on the current information and design parameters, that provides sufficient reasons for why this development should not go ahead in the suggested location.



12 EAP OPINION AND RECOMMENDATIONS


m) Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation;

o) 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;

q) 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;

r) Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post-construction monitoring requirements finalised;

s) 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 or affected parties;

12.1 Recommendations of the EAP It is the opinion of EOH CES that the proposed development should be approved provided that appropriate mitigation measures are implemented and that the Environmental Management Programme (EMPr) is implemented, maintained and adapted to incorporate relevant legislation, standard requirements and audit reporting, throughout the life of the development. The mitigation measures for all impacts identified in the EIA are provided in the detailed assessment in Appendix C and have been incorporated into the EMPr. The EMPr must be implemented by the relevant parties during all phases of development of the project, i.e. Planning & Design and Operational phases. The existing and approved ELIDZ construction EMPr will be used during the construction of the facility. Inclusions, additions and adaptations of the EMPr, as well as all final plan drawings and maps must be submitted to DEDEAT (Amathole Region) for final approval.

12.2 Opinion of the EAP It is the opinion of the EAP that based on:

the information provided by Clariter and their technical/design team;

the conclusions drawn by the Air Quality specialist in the specialist assessment; and

the outcome of the Environmental Impact Assessment undertaken by the EAP;

that no fatal flaws exist that would result in the refusal of an Environmental Authorisation for the proposed Clariter plastics refinery facility. It is also the opinion of the EAP that sufficient information is provided in this document for the competent authority (DEDEAT) to make a decision as to whether or not Environmental Authorisation should be granted to Clariter.



12.3 Environmental Authorisation validity It is recommended that the Environmental Authorisation be issued with a validity period of not more than 5 years.

12.4 EAP Declaration I, Cherie-Lynn Mack , declare that:

I act as the independent environmental practitioner in this application;

I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting environmental impact assessments, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

I will take into account, to the extent possible, the matters listed in regulation 8 of the Regulations when preparing the application and any report relating to the application;

I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;

I will ensure that information containing all relevant facts in respect of the application is distributed or made available to interested and affected parties and the public and that participation by interested and affected parties is facilitated in such a manner that all interested and affected parties will be provided with a reasonable opportunity to participate and to provide comments on documents that are produced to support the application;

I will ensure that the comments of all interested and affected parties are considered and recorded in reports that are submitted to the competent authority in respect of the application, provided that comments that are made by interested and affected parties in respect of a final report that will be submitted to the competent authority may be attached to the report without further amendment to the report;

I will keep a register of all interested and affected parties that participated in a public participation process;

I will provide the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not;

To my knowledge, all the particulars furnished by me in this form are true and correct;

I will perform all other obligations as expected from an environmental assessment practitioner in terms of the Regulations; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

Signed Date



13 OTHER


t) Where applicable, details of any financial provisions for the rehabilitation, closure, and on-going post decommissioning management of negative impacts;

N/A


u) An indication of any deviation from the approved scoping report, including the plan of study, including –

(i) Any deviation from the methodology used in determining the significance of potential environmental impacts and risks; and

(ii) A motivation for the deviation; No deviations from the approved plan of study (Date) were made.


v) Any specific information that may be required by the competent authority; and

An Air Impact Assessment Report and Dispersion Modelling have been undertaken by a specialist company – Airshed. The report is attached in Appendix D.


w) Any other matters required in terms of section 24(4)(a) and (b) of the Act.

An Air Impact Assessment Report and Dispersion Modelling have been undertaken by a specialist company – Airshed. The report is attached in Appendix D.

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