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Monomer Engineering (Pty) Ltd DRAFT SCOPING REPORT PROPOSED NEW XTL DEMONSTRATION FACILITY IN OLIFANTSFONTEIN WITHIN THE EKURHULENI METROPOLITAN MUNICIPALITY, GAUTENG PROVINCE (Gaut Ref No.: 002/11 – 12/E0172) December 2011 For comment by Registered Interested and Affected Parties Due date for comment: Friday, 17 February 2012 Report compiled by: Praveshni Sewmohan (EAP) Public participation by Air quality impact assessment by Kaleo Consulting cc Airshed Planning Professionals (Pty) Ltd

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Page 1: Monomer Engineering (Pty) Ltd XTL... · 2011-12-08 · Monomer Engineering (Pty) Ltd (Monomer) ... Section 24F of the National Environmental Management Act, (Act No 36 of 1998) as

Monomer Engineering (Pty) Ltd

DRAFT SCOPING REPORT

PROPOSED NEW XTL DEMONSTRATION FACILITY INOLIFANTSFONTEIN WITHIN THE EKURHULENI

METROPOLITAN MUNICIPALITY, GAUTENG PROVINCE

(Gaut Ref No.: 002/11 – 12/E0172)

December 2011

For comment by Registered Interested and Affected Parties

Due date for comment: Friday, 17 February 2012

Report compiled by:Praveshni Sewmohan (EAP)

Public participation by Air quality impact assessment byKaleo Consulting cc Airshed Planning Professionals (Pty) Ltd

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PURPOSE OF THIS DOCUMENTMonomer Engineering (Pty) Ltd (Monomer) is the engineering and technical services arm of theMonomer Group of companies. The primary interest of the Monomer Group is the efficient,environmentally responsible beneficiation of energy resources such as natural gas, coal andbiomass for the production of transportation fuels and electrical power. The company’s XTLtechnology combines the commercial production of both electricity and transportation fuels, which isunique in the energy sector.

In order to prove its technology, Monomer wishes to install a commercial tube scale XTLdemonstration facility. The successful implementation of the pilot project will provide a proventechnology for the generation of power and transportation fuels that would not only be moreenvironmentally friendly but also more cost effective to commercial energy producers.

Before the proposed project may go ahead, a Scoping and EIA must be undertaken and theproposed project must be authorised in terms of Section 24(2) and 24D, read in conjunction withSection 24F of the National Environmental Management Act, (Act No 36 of 1998) as amended. TheScoping and EIA must be conducted by an independent consultant appointed by MonomerEngineering, and submitted to the lead authority, the Gauteng Department of Agriculture and RuralDevelopment (GDARD). The Scoping and EIA is being conducted by certified independentenvironmental assessment practitioner, Mrs Praveshni Sewmohan, and the public consultationprocess, by Kaleo Consulting, also an independent environmental consultant. This Draft ScopingReport outlines the issues of concern and suggestions for enhanced benefits/alternatives raised byinterested and affected parties and the project team. It also shows how impacts will be assessedlater in the process. An air impact specialist assessment is being undertaken by Airshed PlanningProfessionals and will be included in the EIA report later in the process.

According to EIA Regulations, interested and affected parties must be given the opportunity tocomment on the proposed project and the Scoping Report before it is submitted to GDARD. I&APshave an opportunity to comment on this Draft Scoping Report from Tuesday, 3 January 2012to Friday, 17 February 2012. The Final Scoping Report will be submitted to the GDARD togetherwill all comments received on this report for a decision on whether or not Monomer may proceedwith the proposed project or not. The Scoping Report has been prepared in compliance with the EIARegulations.

This report contains:

• A description of the proposed project• An outline of the local environment• The potential environmental issues and impacts which have been identified• The plan of study for the assessment of impacts• Public participation undertaken thus far

Should you wish to discuss this report or submit comments about this report, please contact thepublic participation office.

PUBLIC CONSULTATION OFFICEMotushi ManyakaKaleo Consulting

P O Box 73110, Lynnwood Ridge, 0040Tel: (012) 348 0000Fax: (012) 348 0006

Email: [email protected]

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Availability of this Draft Scoping Report for public comment

This report is available on the following websites for stakeholders to comment on:www.monomer.co.za and www.kaleoconsulting.co.za.

In addition, copies of the report are available at the following public places and upon request fromthe Public Participation Office:

Thank you for your participation!

The EIA team would like to express sincere appreciation to all I&APs for their time, commitment and effort toparticipate actively during the Scoping and EIA of this proposed project. All the comments will be capturedand incorporated into this Scoping Report, which will be submitted to the GDARD during February 2012 for adecision on whether or not the impact assessment may proceed.

Report compiled by:

Environmental Assessment Practitioner:

Praveshni SewmohanPO Box 665 Lonehill 2062

Email: [email protected]

Public Place Physical Address Contact person Contact number

Olifantsfontein Library Cnr. Peace & Mason Rd, Clayville 1666 Mrs Greyvenstein (011) 316 1231

Ekurhuleni Metropolitan

Municipality

238 Igqagqa Section, cnr George

Nyanga Drive and Andrew Mapheto

Drive, Tembisa, 1632

Mr Zwane (011) 999 4240

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TABLE OF CONTENTS1 INTRODUCTION .......................................................................................................................11.1 Who is conducting this EIA ........................................................................................................11.2 Who is evaluating this EIA .........................................................................................................11.3 Content of this report .................................................................................................................12 DESCRIPTION OF THE PROPOSED PROJECT......................................................................32.1 Property and location.................................................................................................................32.2 Access to the site.......................................................................................................................32.3 Infrastructure supporting the site................................................................................................32.4 Background to the XTL demonstration facility ............................................................................52.5 Process description ...................................................................................................................5

2.5.1 Gas clean up area .......................................................................................................52.5.2 Auto-thermal reforming area........................................................................................72.5.3 Carbon dioxide separation area...................................................................................72.5.4 Hydrogen separation area ...........................................................................................72.5.5 FTS .............................................................................................................................72.5.6 Light Naptha Recovery Area........................................................................................82.5.7 Power Generation Plant...............................................................................................8

2.6 Storage of Materials...................................................................................................................82.7 Process Capacity.......................................................................................................................92.8 Key raw materials and products.................................................................................................92.9 Water management ...................................................................................................................9

2.9.1 Storm water management............................................................................................92.9.2 Process water management ......................................................................................102.9.3 Process effluent treatment.........................................................................................10

2.10Emissions management...........................................................................................................102.11Waste management.................................................................................................................102.12Health and safety measures ....................................................................................................10

2.12.1 Prevention measures .............................................................................................102.12.2 Minimisation measures ..........................................................................................112.12.3 Management measures..........................................................................................11

2.13Motivation for the project..........................................................................................................112.13.1 Environmental considerations ................................................................................112.13.2 Economical considerations.....................................................................................11

2.14Applicable legislation, standards and guidelines ......................................................................122.14.1 National Environmental Management Act (1998) ...................................................122.14.2 Occupational Health and Safety Act, 1993 .............................................................132.14.3 National Environmental Management: Air Quality Act, 2004 ..................................13

3 CONSIDERATION OF ALTERNATIVES .................................................................................143.1 Site alternatives .......................................................................................................................143.2 Technology alternatives...........................................................................................................144 ENVIRONMENTAL CONTEXT FOR THE PROJECT ..............................................................154.1 Topography .............................................................................................................................154.2 Climatic Conditions..................................................................................................................154.3 Water Receiving Environment..................................................................................................154.4 Soils.........................................................................................................................................154.5 Socio-Economic Receiving Environment .................................................................................154.6 Cultural features ......................................................................................................................154.7 Sense of place.........................................................................................................................155 PUBLIC PARTICIPATION PROCESS UNDERTAKEN............................................................165.1 Who are the I&APs? ................................................................................................................16

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5.2 Public participation activities ....................................................................................................165.2.1 Distribution of the Draft Scoping Reports for public comment ....................................185.2.2 Submission of FSR....................................................................................................18

5.3 Decision-making ......................................................................................................................186 PLAN OF STUDY FOR EIA .....................................................................................................196.1 Methodology for Impact Assessment .......................................................................................196.2 Specialist studies.....................................................................................................................20

6.2.1 Baseline Establishment .............................................................................................206.2.2 Predicted Impact Assessment of Proposed Plants.....................................................20

6.3 Impacts identified.....................................................................................................................216.4 Public participation during impact assessment.........................................................................217 CONCLUSION.........................................................................................................................22

LIST OF FIGURESFigure 1: Location of Monomer Engineering XTL demonstration facility site in Olifantsfontein,Gauteng............................................................................................................................................4

Figure 2: Illustration of the XTL Demonstration Plant Process ..........................................................6

Figure 3: Comparison of process efficiency between commercial FT technology and the Mark 1 XTLprocess...........................................................................................................................................12

LIST OF TABLESTable 1: Compliance with Section 28(1) of Regulations R543...........................................................2

Table 2: Raw materials to be used in the plant..................................................................................9

Table 3: Products from the plant .......................................................................................................9

Table 4: Listed activities in terms of NEMA EIA Regulations 2010, as amended.............................12

Table 5: Summary of Public Participation process ..........................................................................16

Table 6: scoring of impacts .............................................................................................................19

APPENDICESAppendix A: Site plans

Appendix B: Process Flow Diagram

Appendix C: Public participation information

Appendix D: Other Information

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ABBREVIATIONS AND TERMS USED IN THIS REPORT

2010 EIA Regulations Regulations R543, R544 and R545 promulgated in terms of NEMADEIR Draft Environmental Impact Report

DSR Draft Scoping Report

EAP Environmental Assessment PractitionerEIA Environmental Impact AssessmentEMP Environmental Management Plan

GDARD Gauteng Department of Agriculture and Rural DevelopmentI&AP, IAP Interested and Affected PartykV Kilo-Volt. Measure of electricity generation or usage.

m3

Cubic meters. Measure of volume. 1 m3

= 1,000 litres

MHI Major Hazard Installation; in terms of the MHI Regulations promulgated underthe Occupational Health and Safety Act.

MW Mega Watt (measurement of electricity generation or usage)

NEMA National Environmental Management Act

NEM:AQA National Environmental Management: Air Quality Act

NEM:WA National Environmental Management: Waste Act

NWA National Water Act

OHSA Occupational Health and Safety Act

ORTIA OR Tambo International AirportPP Public participationXTL Carbon feedstock to liquid fuels process

Chemical terminologyCO Carbon monoxideCO2 Carbon dioxideCOS Carbonyl SulphideCHx Hydrocarbon (e.g. wax, diesel, naphtha or methane)CS2 Carbon DisulphideH2 HydrogenH2O WaterH2S Hydrogen SulphideN2 NitrogenO2 OxygenSO2 Sulphur DioxideMercaptans Sulphur bearing organics that have distinctive odours

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1 INTRODUCTION

As the technical services provider of the Monomer group, Monomer Engineering performs all designand developmental work for Monomer's proprietary synthetic fuels technology. In addition to itssynthetic fuels focused activities, Monomer Engineering offers general energy-associatedengineering and consulting services to the wider industry.

Compared to conventional thinking in energy solutions, the Group’s approach represents aparadigm shift. The company’s XTL technology combines the commercial production of bothelectricity and transportation fuels, which is unique in the energy sector and has the followingadvantages:

The co-generation of energy products results in very high feedstock utilisation efficiencies.

Liquid fuels and power can be produced with far lower associated GHG (greenhouse gas)emissions than traditional separate synthetic fuel and power generation processes.

Lower water usage per unit of feedstock due to the high utilisation efficiency.

1.1 Who is conducting this EIA

In terms of the 2010 EIA Regulations, Monomer Engineering has appointed Praveshni Sewmohan,an independent EAP to conduct the Scoping and EIA. Praveshni Sewmohan has no business,financial or personal interest in the proposed project and is therefore able to provide anindependent, objective assessment of the proposed project. She is a chemical engineer with over14 years of experience in leading and conducting environmental impact assessments. She iscertified as an environmental assessment practitioner by the Interim Certification Board of SouthAfrica.

Kaleo Consulting, an environmental consulting company, with extensive experience in theenvironmental and public participation field, is conducting the public participation. Airshed PlanningProfessionals, a leading consultancy on air dispersion modelling and air impact assessment, isundertaking the air impact assessment for this project.

1.2 Who is evaluating this EIA

Before the proposed project can proceed, the Scoping and EIA reports for the proposed projectmust be reviewed and based on the information provided in the reports, the GDARD will issue itsdecision regarding the proposed project. The decision will indicate whether GDARD authorises theproposed project to proceed or not, and if yes, under what conditions.

In the spirit of cooperative governance, the GDARD may consult with other governmentdepartments before making a decision. These could include Ekurhuleni Metropolitan Municipality,Department of Water Affairs, Directorate: Air Quality of the Department of Environment Affairs andTourism and the Department of Health.

Before this Draft Scoping Report is submitted to the GDARD, registered I&APs must have anopportunity to comment on the report. I&APs have an opportunity to comment on this report fromTuesday, 3 January 2012 to Friday, 17 February 2012. I&AP comments that are received by thepublic participation office will be submitted with this report to the GDARD after the public reviewcomment period has lapsed. Please see Page i for contact details.

1.3 Content of this report

This report complies with the requirements of Section 28(1) of Regulations R543 (2010 EIARegulations). It therefore provides the following information as required by the Regulations.

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Table 1: Compliance with Section 28(1) of Regulations R543

Regulation Requirement Section in this Report

Details of the EAP who prepared this report, and the expertise of the EAP to carry outscoping procedures

Section 1.1

A description of the proposed activity Section 2

A description of any feasible and reasonable alternatives that have been identified Section 3

A description of the property on which the activity is to be undertaken Section 2.1

A description of the environment that may be affected by the activity and the mannerin which the activity may be affected by the environment

Section 4

An identification of all legislation and guidelines that have been considered in thepreparation of the scoping report

Section 2.14

A description of environmental issues and potential impacts including cumulativeimpacts that have been identified

Section 6.3

Details of the public participation process conducted in terms of Regulation 27(e),including:The steps taken to notify potentially interested and affected parties of the applicationProof that notice boards, advertisements and notices notifying potentially interestedand affected parties of the application have been displayed, placed or givenA list of all persons or organisations that were identified and registered in terms ofregulation 55 as interested and affected parties in relation to the applicationA summary of the issues raised by interested and affected parties, the date of receiptof and the response of the EAP to those issues.

Section 5

A description of the need and desirability of the proposed activity Section 2.13

A description of identified potential alternatives to the proposed activity, includingadvantages and disadvantages that the proposed activity or alternatives may have onthe environment and the community affected by the activity

Section 3

Copies of any representations, and comments received in connection with theapplication or the scoping report from interested and affected parties

Appendix C

Copies of the minutes of any meetings held by the EAP with interested and affectedparties and other role players which record the views of the participants

To be included in FinalScoping Report

Any responses by the EAP to those representations and comments and views Appendix C

A plan of study for the environmental impact assessment which sets out the proposedapproach to the environmental impact assessment of the application, which mustinclude:A description of the tasks that will be undertaken as part of the environmental impactassessment process, including any specialist reports or specialised processes, andthe manner in which such tasks will be undertakenAn indication of the stages at which the competent authority will be consultedA description of the proposed method of assessing the environmental issues andalternatives, including the option of not proceeding with the activityParticulars of the public participation process that will be conducted during theenvironmental impact assessment process

Section 6

Any specific information required by the competent authority None.

Any other matters required in terms of 24(4)(a) and (b) of the Act None.

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2 DESCRIPTION OF THE PROPOSED PROJECT

Monomer Engineering has investigated various potential sites for their XTL demonstration facility.These alternative sites are outlined in Section 3. This section is based on the preferred site inOlifantsfontein, Gauteng.

2.1 Property and location

The Olifantsfontein area lies in the northern-most area of Ekurhuleni Metropolitan Municipality,and parts of this area fall within the northern area of City of Johannesburg municipal area and thesouthern area of Tshwane Metropolitan Municipality.

The proposed site lies within a newly proclaimed township called Clayville Extension 43. The siteis zoned as an Industrial II site, which allows for industrial and commercial developments such asthe XTL demonstration facility. Other developments that exist in the area or that will be developed inthe area, conform to this zoning and are therefore either commercial or industrial activities.

The specific site to be used for this project is Erf 4383, which is shown in Figure 1. As shown inFigure 1, the site is accessed from Olifantsfontein Road (R562). Land currently earmarked fordevelopment with infrastructure such as fencing and internal roads, lie south of the site andbetween the site and the R562. Further south lies the large formal and informal northern residentialarea of Thembisa. Commercial and light industrial developments lie to the east and north of the site,and to the west there is mainly undeveloped land, with some infrastructure in place for industrial andcommercial development.

2.2 Access to the site

The site is accessed from Baksteen Road, which can be accessed from the R562 via SouthwardDrive. The R562 joins the R21 highway to the east of the site, and the N1 national highway to thewest via Midrand. Thus road access to the site allows for access to the provincial and national roadnetwork within a few kilometres of the site.

A rail link runs through Clayville parallel to the R21 to the east of the site.

2.3 Infrastructure supporting the site

Besides road and rail access, the following infrastructure is provided by the Municipality to the site.

Sasol Gas – a Sasol Gas underground bulk supply pipeline runs less than 500 metres to thesouth-east of the site. A new metered pipeline will be built from this bulk supply line to the XTLsite boundary by Sasol Gas. The EIA for this gas pipeline will be undertaken separately by theSasol Gas team.

Municipal water – potable water is supplied to each stand in the township by EkurhuleniMetropolitan Municipality. This water will be used by staff on site for domestic use, processwater and for on-site fire-fighting systems for the demonstration facility.

Sewage – sewage reticulation for each stand in the township is provided by EkurhuleniMetropolitan Municipality. Sewage from this site will only consist of domestic discharge. Noprocess water will be discharged to the Municipality sewer system. Process discharge andstorm water runoff will be captured on-site and be processed in the constructed wetland system.

Electricity. Each stand has electricity supply from Ekurhuleni Metropolitan Municipality.Electricity will be used for process equipment as well as staff use. The XTL process willgenerate electricity. However, this will be consumed on site. No electricity will be transmittedfrom the site.

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Figure 1: Location of Monomer Engineering XTL demonstration facility site in Olifantsfontein, Gauteng

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2.4 Background to the XTL demonstration facility

The XTL demonstration facility is based on the concept of using any carbon feedstock (coal, gas,biofuel, etc) which will be processed through a Fischer-Tropsch process to produce liquid fuels. Inaddition, the Monomer Mark 1 process aims to also produce electricity in the same process. Thus,the aim of the Mark 1 XTL process is to use existing carbon-based sources of energy to produceboth liquid fuels and electricity. This allows for higher efficiency usage of the energy source whencompared to current commercial technologies.

The XTL demonstration facility aims to prove that the Mark 1 XTL process is both technically soundand commercially viable. The demonstration unit will test different energy sources, commencinginitially with natural gas from Sasol Gas. It will also test various process factors such as:

catalyst type.

catalyst life-span.

catalyst activity/productivity.

the effect of inert chemicals on the process.

reactor geometry (tube size).

reactor configuration (scale of each reactor bank).

optimal syngas feed ratios (hydrogen to carbon monoxide and carbon dioxide to carbon

monoxide).

optimal reactor temperature.

optimal reactor pressure.

optimal reactor residence time.

The XTL demonstration facility represents one full scale module of the process and will prove thatthe technology can be implemented at a commercial scale.

2.5 Process description

Natural gas will be compressed (25 EIR) and will pass through a sulphur and heavy metal removalprocess to obtain a purified, almost sulphur free, product. The cleaned natural gas will be fed into anauto-thermal reforming unit, in conjunction with pure oxygen and steam, where it will react, atmedium pressure (25EIR) and high temperature (> 800⁰C) to produce a synthesis gas. Thesynthesis gas will be sent through a carbon dioxide (CO2) removal process to obtain a CO2 freesynthesis product. After removal of the CO2, the synthesis gas will be fed to a hydrogen (H2)separation process, where the H2 composition of the stream will be adjusted to meet the specifictest run criteria. The adjusted synthesis gas will then feed into the FTS process. Here it will react ina series of three tubular-fixed-bed Fischer-Tropsch reactors to produce liquid hydrocarbons. Un-reacted synthesis gas will be diverted to a flare or to the process power generation unit.

These various processes are described in a bit more detail below and are illustrated in Figure 2.

2.5.1 Gas clean up area

Fischer-Tropsch catalysts are extremely sensitive to poisoning from sulphur and heavy metalbearing compounds. The natural gas contains sulphur bearing compounds such as mercaptans,Carbonyl Sulphide (COS), Carbon Disulphide (CS2) and Sulphur Dioxide (SO2). The Gas Clean-Upprocess is required to reduce the contaminant levels in the synthesis gas, to less than 40 ppb.Compressed natural gas (>25EIR), in conjunction with hydrogen is saturated with steam at ambienttemperatures before being injected together with an extremely small quantity of oxygen into acatalytic adsorptive bed.

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Figure 2: Illustration of the XTL Demonstration Plant Process

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The sulphur bearing compounds are converted to Hydrogen Sulphide (H2S) within the catalyst bedbefore being adsorbed onto the surface of the catalyst.

2.5.2 Auto-thermal reforming area

The Auto-thermal reforming unit will generate synthesis gas (CO, H2 and CO2) as feedstock for theFTS process. Carbon (in the form of carbon monoxide and carbon dioxide), hydrogen and oxygenare the key elements that make up hydrocarbons, which are used as fuels. Crude oil is a liquidcarbon source; natural gas is gaseous carbon source; and coal is a solid carbon source.

Cleaned, pressurised natural gas will be fed, together with pressured oxygen and steam, at hightemperature (950⁰C) to a reforming process. Here, the hydrocarbons in the feed will be “reformed”,using a nickel based catalyst, to produce a synthesis gas. The synthesis gas contains the keyingredients to produce hydrocarbons (CO, H2 and CO2). Thus, the auto-thermal reforming areabreaks up an existing carbon source into the key ingredients that are needed to make fuels.

2.5.3 Carbon dioxide separation area

The CO2 separation unit’s function is the removal of CO2from the syngas stream for the FTS feed.Synthesis gas will be fed to the CO2 separation system. In this system a high purity CO2 stream willbe produced for the FTS process, and a CO2 lean stream may be produced which will be flared. Thesplit between these streams will depend on the specific test run criteria.

2.5.4 Hydrogen separation area

The hydrogen separation unit (ASU) performs two functions. Firstly, it will provide high purity H2 gasto the FTS reactors for cobalt catalyst activation, and secondly, it will provide the source of H2 gas tothe syngas feed stream, which will allow the molar H2:CO ratio in the feed to the FTS process to bevaried between 1.7 and 2.3 in order to test different ratios in the reactor. CO2 separation product isfed into the hydrogen separation process. Some or all of the syngas is fed into the hydrogenseparators where hydrogen is removed from the stream.

2.5.5 FTS

The purpose of the Fischer-Tropsch Synthesis (FTS) section is the development of design data forthe commercial rollout of FTS based XTL projects. To that end, determining the “performance” ofthe FTS reactors under various flow, composition, temperature and pressure conditions is required.The “performance” of the reactors relates to productivity, selectivity, thermal stability and catalyst“life-span”. Due to the inherent variability of the FTS test conditions, substantial flexibility is requiredin both upstream and downstream processes.

Synthesis gas will be fed into the FTS process at ambient conditions. The gas will be heated, in areactor preheater, to approximately 220⁰C before being fed into the top of a tubular fixed bedreactor. The synthesis gas passes over a Fischer-Tropsch catalyst where a portion of the stream isconverted to paraffinic liquid hydrocarbons. Not all the synthesis gas will be converted, and thosethat are converted will become a wide spread of hydrocarbon products. Hydrocarbons becomeliquids and vapour at different temperatures, relative to their size. Larger hydrocarbons, or heavierhydrocarbons, remain as liquids at higher temperatures. Smaller hydrocarbons, or lighterhydrocarbons, volatilise easier and thus become vapour at lower temperatures. The next step in theFTS process is therefore to separate the different hydrocarbons by using selective coolingprocesses.

The product and unconverted synthesis gas will leave the base of the reactor and will be cooled toapproximately 180⁰C. The liquid portion of the stream will be separated from the vapour in a knock-out pot, forming the process wax cut. The vapour portion will be cooled again (to approximately130⁰C) and the condensed liquid will be separated in a diesel cut knockout/decanter vessel. Finally,

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the remaining vapour material will be cooled to 40⁰C to condense the heavy naphtha and aqueousproducts which are separated in an aqueous-naphtha decanter. These heat exchangers,knockouts/decanters and the reactor will form the first FT module (Module 1).

The tail gas from Module 1 (the remaining gas after all the cooling steps in Module 1) will be sent toa second set of reactors and knockout vessels (Module 2) where the FTS process is repeated(conversion of gas into hydrocarbons using the FT catalyst and then selectively cooling the productto remove the product in different hydrocarbon fractions). The tail gas from module 2 will then,finally, pass to Module 3 where the final synthesis gas conversion and product recovery will takeplace.

The tail gas from Module 3 will be sent to the Light Naphtha Recovery process in order to recoveryas much of the light hydrocarbon material from FTS as possible.

2.5.6 Light Naphtha Recovery Area

The purpose of the Naphtha Recovery Process is to test the conditions for maximum recovery oflight hydrocarbons as a marketable product. Tail gas from the FTS process will pass through apacked bed column where it will come into contact with an organic wash stream. The light naphthawill dissolve in the wash stream, creating a lean tail gas which will be used for power generation.

The wash stream will be removed from the base of the wash column. It will combine with the dieselcut from the 3 FTS modules. The combined stream will be depressurised to 4 EIR and then fed intoa decanter where the aqueous (watery) portion of the stream will be separated from thehydrocarbon product material. The product will be heated to approximately 255⁰C and fed into anaphtha recovery distillation column. Light naphtha and LPG product will be removed from the top ofthe column and the diesel wash stream will be regenerated in the bottoms. This stream will becooled, a wash stream and clean diesel portion will be separated and the wash stream will be re-pressurised to 20EIR, before being recycled to the wash column. The diesel, light naphtha and LPGare then sent to storage as final product of the plant.

2.5.7 Power Generation Plant

The process power generation section serves to demonstrate the capacity to generate electricityfrom FTS tail gas, under various conditions of inert (N2 and CO2) dilution. Un-reacted FTS synthesisgas will be sent through light naphtha recovery where light naphtha hydrocarbons are stripped fromthe stream. The unrecovered hydrocarbons and un-reacted CO and H2 will be sent to powergeneration where they will be combusted to produce electricity.

Both a supplementary natural gas and reformer product feed will be available as feeds to the powergeneration process. When additional CO2 is required for FTS, the combustion product will be cooledto knock out water and then compressed and recycled to the CO2 separation system for use in theprocess, thus minimising CO2 emissions from the plant.

2.6 Storage of Materials

Specially designed storage vessels will be provided for CO2, O2, N2, and H2. These vessels undergopressure testing to ensure they will not rupture. Regular inspections will be carried out throughoutthe life of the project to ensure these vessels can continue to operation safely. The gases will besupplied by commercial suppliers such as Air Products, Air Liquide and AFROX. These gases willbe used when needed for different test runs. The storage vessels will have the following capacities:

CO2 vessel: 34 tons. O2 vessel: 38 tons N2 (nitrogen): 40 tons H2: (to be confirmed in EIA report)

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2.7 Process Capacity

Under “normal” operating conditions, the overall process capacity of the XTL demonstration facilitywill be between 3 barrels per day (bpd) and 6 bpd (360kg/d to 720kg/d), of liquid hydrocarbons.

2.8 Key raw materials and products

The key raw materials from the plant are shown in Table 2 and the key products are shown in Table3.

Table 2: Raw materials to be used in the plant

Raw material Usagetonnes/month

Storage details Supplier

Water 180 None-supplied by pipeline MunicipalityNatural Gas 84 None-supplied by pipeline Sasol GasN2 213.6 Cryogenic Pressure vessel Air Products/Air LiquideO2 133.632 Cryogenic Pressure vessel Air Products/Air Liquide

CO2 162.7 Cryogenic Pressure vessel Air Products/Air LiquideNickel catalyst 0.03 t/year In vessel storage and change out

load in sealed inerted drums.Huaxi Chemical Company

Zinc oxide activatedcarbon catalyst

10 m3 / annum In vessel storage and change outload in sealed inerted drums.

Albemarle

Adsorbent for PSA units 1.67 t/annum In vessel storage and change outload in sealed inerted drums.

Huaxi Chemical Company

Table 3: Products from the plant

Product Production capacitytonnes/month

Storage details Potential Customers

Diesel 1.69 Local tank storage and weeklyshipping to customers or wastetreatment

Natref, local users

Electricity 120kW None None (for demo plantonly).

Kerosene 1.70 Local tank storage and weeklyshipping to customers or wastetreatment

Natref

Heavy naphtha 1.08 Local tank storage and weeklyshipping to customers or wastetreatment

Natref

Light Naphtha 0.55 Local tank storage and weeklyshipping to customers or wastetreatment

Natref

FT Wax 8.32 Local drum storage and monthlyshipping to customer

Natref, local market

2.9 Water management

2.9.1 Storm water management

Tanks and process areas will either be under roof or bunded to minimise any storm watercontamination and to ensure any storm water that comes into contact with process chemicals, iskept on site. Storm water captured in bunded areas will be re-used in the plant, treated through theconstructed wetland or removed from site for disposal at Holfontein.

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2.9.2 Process water management

Municipal water will be treated in a demineralisation plant to remove most of the salts before it issent to a boiler for the production of process steam. Steam used in the process will become part ofthe product. For equipment that uses steam for heating purposes, the condensed steam will berecovered and re-used for steam production.

The process will produce an effluent stream, which is mainly water, but is likely to contain some ofthe hydrocarbons produced in the plant. As a result, a constructed wetland unit is proposed to beused to treat the water.

2.9.3 Process effluent treatment

The FT process in particular will produce reaction water with a high oxygenate content; ketones,aldehydes, carboxylic acids and alcohols. The reaction water from these processes cannot beemitted to the environment and must be treated to remove potentially hazardous species. Thepreference, in selecting the water treatment technology, is to treat the water effluent biologically in aconstructed wetland. Should this prove not to be a viable alternative, chemical treatment processeswill be considered. The organics in the water will be broken down in the wetland system and thetreated water will return to the process for re-use. No discharges are therefore envisaged from thesite.

2.10 Emissions management

For the safe operation of the plant, it will be necessary to operate the flare continuously toaccommodate off specification products or shut down circumstances. The flares will operate atindustrial standard and no downstream filters or scrubbers are envisaged.

2.11 Waste management

Solid wastes from the site are expected to be spent catalysts, packaging for chemicals, usedspares, workshop waste, and office waste. As far as possible, packaging and spent catalysts will bereturned to suppliers for recycling, regeneration and re-use. All other solid wastes will be separatedat source to allow for recycling, resale and re-use. Hazardous wastes that cannot be recycled or re-used safely will be disposed of to Holfontein. Wastes that do not classify as hazardous wastes willbe disposed of to the municipality.

2.12 Health and safety measures

Health and safety measures will adhere to the requirements of the Occupational Health and SafetyAct, as well as to guidelines and standards promulgated by the chemical industry. With the startupof the operation, it is the intention of Monomer to become a signatory of the Responsible Careinitiative, with the implicit responsibilities that arise there-from.

Health and safety measures will be implemented in terms of risk preventative measures, riskminimisation measures and management measures.

2.12.1 Prevention measures

The site will be a registered Major Hazard Installation (MHI). As a result regular risk assessmentreviews will be carried out by an approved inspection authority to ensure emergency preparednessmeasures meet the requirements of the site’s approved Emergency Preparedness and ResponseAction Plan, and to ensure this action plan remains relevant and current for the operations.

The site will maintain strict maintenance schedules for all pressure vessels, pumps and piping.

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2.12.2 Minimisation measures

The facility is designed with intrinsic safety systems that will minimise any release of process orproduct chemicals to the environment, which include the following:

Gas sensor alarms for the early detection of any leaks or emissions. This will trigger automaticmitigation measures in the control system of the plant. The plant is design in the event of amajor failure to shut off the natural gas supply to the facility and purge all of the process gas withnitrogen to the controlled flare system. This dual action of purging the process contents to safeflare and cutting off the natural gas source will minimise the release of toxic components to theenvironment.

Functional spare units will be installed for safety and system critical circuits All major process flow controls will have isolation and bypass systems in place for use in the

case of equipment failure. Full bunding of major process items will be installed with drainage to an oily sump for collection

and off-site processing. The oily sump system will be operated and contained independently ofthe storm water system.

2.12.3 Management measures

The site will be a registered MHI. The site will have an Emergency Response Plan that details howspills, leaks and discharges that could result in an unacceptable risk should be dealt with both on-site and off-site. The site will make use of monitors and alarms that would activate the site’semergency procedures should there be a release of a dangerous good on site. Regular site drillswill be held to ensure all personnel are familiar with the site’s emergency response measures.

2.13 Motivation for the project

2.13.1 Environmental considerations

This XTL demonstration facility will ensure the following environmental advantages over current XTLtechnologies in operation:

Higher degree of use of the carbon feedstock in producing a useable, saleable fuel. Narrower range of hydrocarbon products, thus limiting waste or unusable product, and

elimination of the traditional black products associated with XTL processes. Capture and re-use of carbon dioxide produced in the power generation plant, to produce fuel. The combination of power generation and fuel production produces an overall improved process

efficiency which reduces the requirements of feedstock for unit of output power and fuel. This isclearly demonstrated in Figure 3.

2.13.2 Economical considerations

The Mark I XTL process has the following advantages over current XTL installations in operation:

Modular process, allowing for very small to very large plants to be developed. The modular process allows for easy deployment to customers.

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Figure 3: Comparison of process efficiency between commercial FT technology and the Mark1 XTL process

Installation costs are low and therefore this technology can be applied to developing countries,without requiring external aid funding.

Different range of feed materials can be used, allowing for the technology to be applied in termsof available local carbon feedstock.

The plant modules can be installed in sequential fashion, leading to staggered investment andreturns– this means that the facility can start repayment of the debt from the first day of operationwhile the second and latter modules are in construction.

2.14 Applicable legislation, standards and guidelines

An assessment of the legal requirements that may apply to this project was undertaken by CameronCross Inc and the summary of their findings is provided in Appendix D. In summary, the followingkey requirements must be complied with.

2.14.1 National Environmental Management Act (1998)

The National Environmental Management Act, 107 of 1998 (NEMA) specifies that where an activityrequires permission by law and may significantly affect the environment, it is necessary for anapplicant to undertake an EIA, which meets the minimum requirements of section 24(7) of NEMA.The EIA must be presented to all organs of state that are required to grant (or refuse) thepermission that is required by law to undertake the proposed activity. The minimum requirements ofsection 24(7) of NEMA are regulated in terms of Regulations 543, 544 and 545 of 2010. The listedactivities provided in the EIA application form are given in Table 4.

Table 4: Listed activities in terms of NEMA EIA Regulations 2010, as amended.

Listing Notice Activity No. Activity descriptionListing Notice 1 Activity 1(a)* The construction of facilities or infrastructure for the generation

of electricity where:i. the electricity output is more than 10 megawatts but lessthan 20 megawatts; orii. the output is 10 megawatts or less but the total extent ofthe facility covers an area in excess of 1 hectare

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Listing Notice Activity No. Activity descriptionListing Notice 1 Activity 13 The construction of facilities or infrastructure for the storage, or

for the storage and handling, of a dangerous good, where suchstorage occurs in containers with a combined capacity of 80 butnot exceeding 500 cubic meters

Listing Notice 2 Activity 3* The construction of facilities or infrastructure for the storage, orstorage and handling of a dangerous good, where such storageoccurs in containers with a combined capacity of more than 500cubic meters

Listing Notice 2 Activity 4 The construction of facilities or infrastructure for the refining,extraction or processing of gas, oil or petroleum products withan installed capacity of 50 cubic meters or more per day,excluding facilities for the refining, extraction or processing ofgas from landfill sites

* It has been confirmed that these activities are not applicable to this project.

2.14.2 Occupational Health and Safety Act, 1993

Hazardous chemical substances: employees on the site may carry out work which exposes themto the intake of hazardous chemical substances. The regulations under the Occupational Health andSafety Act of 1993 require that an employer shall ensure that employees are adequately trained andinformed of the potential source of exposure, the risks of exposure, protection measures, personalprotective equipment, maintenance of safety equipment, air sampling and medical surveillance, safeworking procedures and emergency actions. This information should also be provided to the driversof vehicles carrying the hazardous chemical substances.

Employers shall control the amount of exposure of employees to hazardous chemical substances byattempting to use a substitute for the compound or limiting the use of and the number of employeesexposed. Labelling, packaging, transportation and storage of hazardous chemical substances mustalso be carried out in accordance with codes of practice published by the South African Bureau ofStandards (SABS codes 072, 0228, and 0229).

Major Hazard Installation Regulations: these operations will classify as a Major HazardInstallation. This means that the chief inspector of the Department of Labour, provincial director andrelevant local government must be informed in writing of the major hazard installation. Furthermore,a risk assessment must be carried out to ensure that the risks can be appropriately managed, andan Emergency Preparedness and Response Plan must be submitted to the local government forapproval.

2.14.3 National Environmental Management: Air Quality Act, 2004

Refining of gas is a Listed Activity under the National Environmental Management (NEM): AirQuality Act of 2004 (AQA) and therefore require an atmospheric emissions licence. However, testand experimental facilities are excluded. Therefore, an atmospheric emissions license is notrequired for this project.

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3 CONSIDERATION OF ALTERNATIVES

3.1 Site alternatives

The site consideration required access to the existing Sasol Gas supply network. This feed decisionwas specifically taken to reduce the environmental impact of the operation of the facility. Sites closeto the Sasol Gas bulk supply network were therefore sought and this limited the options for potentialsites. Three potential sites were identified by Monomer Engineering; however two sites were notsuitable for the following reasons:

South Germiston: the available site was within 100 metres of an informal settlement, and giventhe nature of the operation, it was felt that this close proximity was not desirable from a safetyperspective. The site also lacked proper road access for the transportation of equipment to thesite.

Midrand: this site was situated on agriculturally zoned land, and lacked the water and powersupply infrastructure necessary to support the demonstration plant.

Three potential sites adjacent to each other in Olifantsfontein were identified, and were preferredsince these were already zoned for industrial development. Water, electricity and the Sasol Gasbulk pipeline runs in close proximity to the sites. In addition the sites are surrounded by otherindustrial stands and development, and the closest residential development is a few hundred metresaway. Monomer Engineering initiated the process of securing these potential sites, and it was foundout that two sites were being bought by Rham Equipment, leaving one site for this project. Thepreferred site is in the process of being bought by Monomer Engineering.

3.2 Technology alternatives

Given the intention of the facility to pilot and demonstrate a new technology there were noalternatives that might be considered for the technology.

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4 ENVIRONMENTAL CONTEXT FOR THE PROJECT

This section outlines the receiving environment within which the site exists and within which theproposed project will take place, if it is authorised.

4.1 Topography

The site slopes mainly to the west, north-west and has a gentle gradient.

4.2 Climatic Conditions

The annual mean temperature for ORTIA is 15.9°C. The average daily maximum temperaturesrange from 25.3°C in January to 16.0°C in June, with daily minimum values ranging from 14.3°C inJanuary to 4°C in June and July. The Mean Annual Precipitation (MAP) for this area is between 600mm and 700 mm.

4.3 Water Receiving Environment

The site drains to the north-west towards an un-named river, which eventually flows into theHennops River. The Hennops River flows into the Centurion Lake, which drains into the CrocodileRiver. The Crocodile River feeds into Hartebeestpoort Dam. Sensitivities in the Hennops River arerelated mainly to siltation arising from the significant development in the headwaters of thecatchment. The Crocodile River and Hartebeestpoort Dam has low assimilative capacity forpollutants associated with industrial and domestic effluents.

4.4 Soils

The site has been identified as having dolomite deposits. A full geotechnical assessment isunderway and the result will be made available in the Draft EIR. The geotechnical study will includea dolomite stability assessment.

4.5 Socio-Economic Receiving Environment

The main economic sectors in Gauteng are wholesale and retail trade, finance, insurance and realestate and business services and community, social and personal services. Gauteng Province has atotal population of 8.84 million (2001 Population Census) with only 33% of this population beingeconomically active and 19% officially unemployed (excluding students, homemakers andpensioners).

4.6 Cultural features

There are no cultural features of significance in or within a 100m of the site.

4.7 Sense of place

The area is dominated by commercial and industrial developments around it. The vacant standsaround the site are zoned for industrial development and are likely to result in furtherindustrialisation of the area.

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5 PUBLIC PARTICIPATION PROCESS UNDERTAKEN

Public participation, an essential and regulatory requirement for an environmental authorisationprocess, has been conducted in accordance with the EIA Regulations GN R543 under the NationalEnvironment Management Act 1998 (Act no. 107 1998) (NEMA). The Scoping and EIA process,including the public participation process, is summarised below.

The public participation process for the proposed project has been designed to provide sufficientand accessible information to I&APs in an objective manner to assist them to:

• During the Scoping phaseo Raise issues of concern;o Make suggestions for enhanced project benefits and reasonable alternatives; ando Contribute relevant local knowledge and information to the environmental assessment.

• During the EIA Assessment processo Verify that their issues have been accurately recorded;o Comment on the findings of the specialist assessments; ando Raise additional issues and suggestions.

• During the Decision-making phaseo Understand the appeals process after the lead authority has made a decision on

whether the project may proceed.

5.1 Who are the I&APs?

Interested and Affected Parties (I&APs) include representatives from all sectors of society, includingrelevant government departments at all levels (national, local and provincial), spokespeople of keyorganisations, non-governmental organizations (NGOs), and community leaders in the area.

A stakeholder database was proactively compiled for this project, resulting in about 25 individualsand organisations being informed.

5.2 Public participation activities

Table 5 provides details of the public participation activities conducted thus far. Where activitieshave already been completed, appendices of supporting material are indicated.

Table 5: Summary of Public Participation process

Activity Details Reference in BA Report

ANNOUNCEMENT PHASE

Identification of stakeholders. Update an existing stakeholderdatabase which includesinterested and affected partiesfrom various sectors of societyincluding directly affectedlandowners in and around theproject area.

Appendix CFull Stakeholder Database.

Appendix CRegistered I&APs Database.

Obtained comments fromstakeholders.

Comments, issues of concern andsuggestions received fromstakeholders are captured in theComment and Response Report.Comments were obtained bymeans of telephonic consultationand written submissions

Appendix CComment and Response Report.

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Activity Details Reference in BA Report

Distribution of projectannouncement letter, invitation toregister as Interested andAffected Parties (I&APs), andBackground InformationDocument (BID).

BID and announcementdocumentation emailed andposted to the completestakeholder database, comprising28 stakeholders, duringSeptember 2011.

Appendix CBID, announcement letter,registration and comment sheet.

Newspaper advertisements toannounce the project.

Two advertisements (English)published in The Citizen on 28October 2011 and The Tembisanon 4 November 2011.

Appendix CCopies of publishedadvertisements.

Displaying site notices in andaround the project area.

4 sites notices (English) wereplaced at various locations in theproject area.

Appendix CSite notice locations and photos.

Written comments. Written comments received hasbeen captured to the CRR.

Appendix CWritten comments received fromstakeholders.

PUBLIC REVIEW OF THE DRAFT SCOPING REPORTAnnouncement of availability ofDraft Scoping Report

Letter emailed and posted toregistered I&APs on 8 December2011.

Appendix CLetter to registered I&APs

Public review of DSR Distribution of DSR to publicplaces and IAPs that requested acopy.

Appendix CWritten comments received.(to be included in Final ScopingReport on submission).Written comments received.

PUBLIC REVIEW OF THE DRAFT EIA REPORTAnnouncement of availability ofDraft EIA Report

Letter to be emailed and posted toregistered I&APs.

Appendix C

(to be included in Draft EIR).Public review of Draft EIA Report Open House to discuss content of

Draft EIA ReportDistribution of DEIR to publicplaces and IAPs that request acopy.

Appendix CRecord of Open House(to be included in Draft EIR onsubmission).

Written comments to be added toreport.

Appendix CWritten comments received.(to be included in Final EIR onsubmission).

DECISION-MAKING PHASESubmission of final EIA report Letter to be sent to registered

I&APs to indicate submission.Appendix CLetter to registered I&APs.(to be included in Final EIR onsubmission).

Notification of authority decision Letter to be emailed and posted toregistered I&APs to indicateauthority decision and appealprocess.Advertisement in The Tembisanand The Citizen

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5.2.1 Distribution of the Draft Scoping Reports for public comment

The DSR is available for public review and comment from Tuesday, 3 January 2012 to Friday, 17February 2012. These reports are available for comment by way of the following:

• At public places within the project area (see page ii);• Emailing or posting copies or CDs to key stakeholders and other I&APs who have requested a

copy; and• Placing the reports on the two websites (www.kaleoconsulting.co.za and

www.monomer.co.za).

5.2.2 Submission of FSR

Comment received during the public review period will be added to the FSR Comments andResponse Report. The FSR will then be made available on the websites to stakeholders anddistributed to the authorities for decision making.

5.3 Decision-making

I&APs will be informed of the authority’s decision about the proposed project by letter.

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6 PLAN OF STUDY FOR EIA

This plan of study outlines the work to be undertaken in the impact assessment phase of the project.

6.1 Methodology for Impact Assessment

Potential impacts will be scored according to Table 6.

Table 6: scoring of impacts

SEVERITY OCCURENCE

Magnitude (severity)of impact

Duration of

Impact

Extent of impact Probability ofoccurrence

Magnitude Duration Scale Probability

10 Very high/ don’tknow

5 Permanent 5 International 5 Definite/don’t know

8 High 4 Long-term (impactceases after closure ofactivity)

4 National 4 Highly probable

6 Moderate 3 Medium-term (5 to 15years)

3 Regional 3 Medium probability

4 Low 2 Short-term (0 to 5years)

2 Local 2 Low probability

2 Minor 1 Transient 1 Site only 1 Improbable

1 None

After ranking these factors for each impact, the significance of the two aspects, occurrence andseverity, was assessed using the following formula:

SP (significance points) = (magnitude + duration + scale) x probability

The maximum value is 100 significance points (SP). The environmental effects were then rated onthe following basis:

SP >70 Indicates highenvironmental significance

Where it would influence the decision regardless of anypossible mitigation. An impact that could influence thedecision about whether or not to proceed with the project.

SP 40 - 70 Indicates moderateenvironmental significance

Where it could have an influence on the decision unless it ismitigated. An impact or benefit which is sufficiently importantto require management. Of moderate significance - couldinfluence the decisions about the project if left unmanaged

SP <40 Indicates lowenvironmental significance

Where it will not have an influence on the decision. Impactswith little real effect and which should not have an influenceon or require modification of the project design or alternativemitigation

+ Positive impact An impact that is likely to result in positive consequences /effects.

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6.2 Specialist studies

Airshed Planning Professionals will conduct the air impact assessment as follows.

Establish Baseline conditions Prepare an emissions inventory of proposed project; Predict ground level concentrations of most significant pollutants; Assess predicted criteria pollutant concentrations against local (for compliance) and

international standards (for comparison). Assess predicted pollutant concentrations of non-criteria pollutants against health risk

guidelines. Typically using the World Health organisation and the US Environmental ProtectionAgency.

Assess the significance of the impacts identified; and Identify practicable mitigation measures to reduce negative impacts and indicate how these can

be implemented in the construction and management of the proposed project.

The following enabling tasks are proposed to complete the impact assessment:

Establishment of Baseline Conditions, includingo Legislative context;o Analysis of existing meteorological data; ando Analysis of available air quality monitoring data.

Predicted Impact, includingo Emission inventory of proposed operational emissions, including upset conditions e.g.

flaringo Atmospheric dispersion modelling of significant pollutants;o Impact analysis of proposed operations (compliance and preliminary health risk); ando Identification and implementation of practicable mitigation measures to reduce negative

impacts

These are briefly described below.

6.2.1 Baseline Establishment

At the outset of the Baseline Chapter, it is important to summarise and discuss the ambient airstandards and targets as prescribed by the National Environmental Management: Air Quality Act,2004 (Act No. 39 of 2004). It is also important to put this into context of international criteria used byinstitutions such as the World Health Organisation, US Environmental Protection Agency, WorldBank, etc.

The baseline requires the use of all available air quality information to provide a benchmark for anypredicted changes. This includes local meteorological data, ambient air quality monitoring data andemission data from most significant sources. The baseline characterisation will include thecharacterisation of the atmospheric dispersion potential of the area by analysing meteorologicaldata nearest to site.

6.2.2 Predicted Impact Assessment of Proposed Plants

All sources of emissions will be identified and emissions from these sources quantified. Theemission rates would be quantified using emission factor application and/or engineeringcalculations. The emission inventory would attempt to accommodate normal and upset operationalconditions.

Once equipped with the air emissions, these would be simulated using a suitable, internationallyrecognised atmospheric dispersion model. For this project, it is recommended that the simulations

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be performed using one of the US Environmental Protection Agency’s regulatory dispersion modelsor the UK’s ADMS-4 model. The US EPA’s workhorse of models, the AERMET/AERMOD suite, iscurrently being investigated to become the regulatory model of choice by the DEA. The advantageof the UK’s ADMS-4 model is that no upper air data are required, as opposed to the AERMETmodel. The final selection would be based on data availability and complexity of the modellingdomain.

Regulations pertaining to atmospheric emissions typically include ambient air quality guidelines andstandards and emission limits. Reference will be made to ambient air quality standards included inthe National Environmental Management: Air Quality Act, in addition to other air quality guidelines,standards and goals issued by various countries and organisations, e.g. USA, UK, EuropeanCommunity, World Health Organisation and the World Bank.

The predicted air pollution levels for the proposed developments would be super-imposed onavailable baseline data to provide cumulative impacts. Both incremental and cumulative predictionswould be compared to standards, for criteria pollutants, and to internationally accepted guidelinesfor non-criteria pollutants. Carcinogenic and non-carcinogenic pollutants would be treateddifferently in the health risks assessment due to the considerable differences in the nature of thedose-response relationship of each.

6.3 Impacts identified

The key impacts identified by the project team and the EIA team are as follows:

Emissions from the demonstration plant – will any of these have an effect on neighbouring sitesand the closest residential areas? The air impact assessment will address this question.

Unsafe conditions – what is the chance of an accident or fire taking place on site? If so, how nigan accident could occur, and to what extent would it result in damage off site? The MHI riskassessment will address this question.

6.4 Public participation during impact assessment

Public participation during the impact assessment phase will comprise mainly the review of the DraftEIA report and communication of the authority’s decision. The public review of the Draft EIA reportwill follow the same approach as done for the Draft Scoping Report. An Open House event will beheld during the public review period for the Draft EIA report.

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7 CONCLUSION

This Draft Scoping Report represents the project information and the EIA process to date. It will beupdated with IAP comments and submitted to the GDARD for approval at the end of the publicreview period.

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APPENDIX A: SITE PLANS

A1: LOCALITY PLAN

A2: SITE PRELIMINARY LAYOUT

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APPENDIX B: PROCESS FLOW DIAGRAM

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APPENDIX C: PUBLIC PARTICIPATION INFORMATION

1 – Proof of site notice

2 – Written notices issued to those persons detailed in 1(b) to 1(f) above

3 – Proof of newspaper advertisements

4 – Communications to and from persons detailed in Point 2 and 3 above

5 – Comments and Responses Report

6 – Copy of the register of I&APs

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APPENDIX D: OTHER INFORMATION

1: List of state departments to whom this report was submitted

2: Summary of Legal Requirements Assessment from Cameron Cross