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ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
BASIC ASSESSMENT REPORT
NEOPAK COMBINED HEAT AND POWER
(CHP) PLANT,
ROSSLYN, GAUTENG
FEBRUARY 2017
Prepared for:Neopak (Pty) Ltd
37 Homestead Road
Sandton
2128
Prepared by:
Savannah Environmental (Pty) Ltd
First Floor, Block 2, 5 Woodlands Drive Office Park
Woodmead
Johannesburg, 2191
Tel: +27 (0)11 656 3237
Fax: +27 (0)86 684 0547
E-mail: info@savannahsa.com
www.savannahsa.com
(For official use only)
File Reference Number:
Application Number:
Date Received:
Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2010,
promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of
1998), as amended.
Kindly note that:
1. This basic assessment report is a standard report that may be required by a competent
authority in terms of the EIA Regulations, 2014 and is meant to streamline applications.
Please make sure that it is the report used by the particular competent authority for the
activity that is being applied for.
2. This report format is current as of 08 December 2014. It is the responsibility of the applicant
to ascertain whether subsequent versions of the form have been published or produced
by the competent authority.
3. The report must be typed within the spaces provided in the form. The size of the spaces
provided is not necessarily indicative of the amount of information to be provided. The
report is in the form of a table that can extend itself as each space is filled with typing.
4. Where applicable tick the boxes that are applicable in the report.
5. An incomplete report may be returned to the applicant for revision.
6. The use of “not applicable” in the report must be done with circumspection because if it is
used in respect of material information that is required by the competent authority for
assessing the application, it may result in the rejection of the application as provided for in
the regulations.
7. This report must be handed in at offices of the relevant competent authority as determined
by each authority.
8. No faxed or e-mailed reports will be accepted.
9. The signature of the EAP on the report must be an original signature.
10. The report must be compiled by an independent environmental assessment practitioner.
11. Unless protected by law, all information in the report will become public information on
receipt by the competent authority. Any interested and affected party should be
provided with the information contained in this report on request, during any stage of the
application process.
12. A competent authority may require that for specified types of activities in defined situations
only parts of this report need to be completed.
13. Should a specialist report or report on a specialised process be submitted at any stage for
any part of this application, the terms of reference for such report must also be submitted.
14. Two (2) colour hard copies and one (1) electronic copy of the report must be submitted to
the competent authority.
15. Shape files (.shp) for maps must be included on the electronic copy of the report submitted
to the competent authority.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Project Details Page i
PROJECT DETAILS
When used as a reference this report should be cited as: Savannah Environmental (2017) Basic
Assessment Report: Neopak Combined Heat and Power (CHP) Plant, Rosslyn, Gauteng.
COPYRIGHT RESERVED
This technical report has been produced for Neopak (Pty) Ltd. The intellectual property contained in this report
remains vested in Savannah Environmental (Pty) Ltd and Neopak (Pty) Ltd. No part of the report may be
reproduced in any manner without written permission from Neopak (Pty) Ltd or Savannah Environmental (Pty) Ltd.
Title : Environmental Assessment Process
Basic Assessment Report: Neopak Combined Heat and
Power (CHP) Plant, Rosslyn, Gauteng
Authors : Savannah Environmental
Lisa Opperman
Karen Jodas
Gabriele Wood
Specialist : uMoya-NILU Consulting
Applicant : Neopak (Pty) Ltd
Report Status : Basic Assessment Report for Review
Review Period : 28 February 2017 – 31 March 2017
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Table of Contents Page ii
TABLE OF CONTENTS
PAGE
PROJECT DETAILS .................................................................................................................................... i
TABLE OF CONTENTS.............................................................................................................................. ii
APPENDICES .......................................................................................................................................... iv
SUMMARY AND OVERVIEW OF THE PROJECT...................................................................................... v
1.1. NEED AND DESIRABILITY FOR THE COMBINED HEAT AND POWER (CHP) PLANT .......... ix
1.2. REQUIREMENTS FOR A BASIC ASSESSMENT PROCESS ...............................................x
1.3. DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER AND EXPERTISE TO CONDUCT
THE BASIC ASSESSMENT .................................................................................... xiv
1.4. ASSUMPTIONS AND LIMITATIONS ....................................................................... xvi
BASIC ASSESSMENT REPORT FOR REVIEW ........................................................................................ xvii
SECTION A: ACTIVITY INFORMATION................................................................................................... 1
1. PROJECT DESCRIPTION ...................................................................................... 1
a) Describe the project associated with the listed activities applied for ........................1
b) Provide a detailed description of the listed activities associated with the project as
applied for...............................................................................................................................3
2. FEASIBLE AND REASONABLE ALTERNATIVES........................................................... 3
a) Site alternatives ......................................................................................................................4
b) Technological alternatives...................................................................................................6
c) Layout alternatives ................................................................................................................7
d) Other alternatives (e.g. scheduling, demand, input, scale and design alternatives)
...................................................................................................................................................7
e) No-go alternative ..................................................................................................................8
3. PHYSICAL SIZE OF THE ACTIVITY ........................................................................... 8
4. SITE ACCESS ..................................................................................................... 9
5. LOCALITY MAP ................................................................................................. 9
6. LAYOUT/ROUTE PLAN .......................................................................................10
7. SENSITIVITY MAP...............................................................................................10
8. SITE PHOTOGRAPHS .........................................................................................14
9. FACILITY ILLUSTRATION ......................................................................................14
10. ACTIVITY MOTIVATION ......................................................................................14
11. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES .....................................20
12. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT .......................................27
a) Solid waste management................................................................................................. 27
b) Liquid effluent ...................................................................................................................... 28
c) Emissions into the atmosphere ......................................................................................... 29
d) Waste permit........................................................................................................................ 31
e) Generation of noise ........................................................................................................... 31
13. WATER USE ......................................................................................................32
14. ENERGY EFFICIENCY .........................................................................................32
SECTION B: SITE/AREA/PROPERTY DESCRIPTION...............................................................................33
1. GRADIENT OF THE SITE ......................................................................................34
2. LOCATION IN LANDSCAPE ................................................................................34
3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE.............................34
4. GROUNDCOVER..............................................................................................35
5. SURFACE WATER ..............................................................................................35
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Table of Contents Page iii
6. LAND USE CHARACTER OF SURROUNDING AREA .................................................36
7. CULTURAL/HISTORICAL FEATURES .......................................................................37
8. SOCIO-ECONOMIC CHARACTER .......................................................................37
a) Local Municipality............................................................................................................... 37
b) Socio-economic value of the activity ............................................................................ 38
9. BIODIVERSITY ...................................................................................................39
a) Indicate the applicable biodiversity planning categories of all areas on site and
indicate the reason(s) provided in the biodiversity plan for the selection of the
specific area as part of the specific category)............................................................ 39
b) Indicate and describe the habitat condition on site .................................................. 40
c) Complete the table to indicate: ..................................................................................... 40
d) Please provide a description of the vegetation type and/or aquatic ecosystem
present on site, including any important biodiversity features/information identified
on site (e.g. threatened species and special habitats).............................................. 41
SECTION C: PUBLIC PARTICIPATION...................................................................................................42
1. ADVERTISEMENT AND NOTICE............................................................................42
2. DETERMINATION OF APPROPRIATE MEASURES......................................................42
3. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ...........................................43
4. COMMENTS AND RESPONSE REPORT ..................................................................43
5. AUTHORITY PARTICIPATION................................................................................43
6. CONSULTATION WITH OTHER STAKEHOLDERS .......................................................44
SECTION D: IMPACT ASSESSMENT ......................................................................................................46
1. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION,
OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED
MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES .....46
Planning Phase.........................................................................................................46
1.1 Construction and Operation Phase ...................................................................47
1.2 Decommissioning Phase...................................................................................53
1.3 The No-Go Alternative .....................................................................................55
2. ENVIRONMENTAL IMPACT STATEMENT.................................................................55
SECTION E: RECOMMENDATION OF PRACTITIONER .........................................................................59
SECTION F: APPENDICES .....................................................................................................................61
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Appendices Page iv
APPENDICES
Appendix A: A3 Maps
Appendix A1: Locality Map
Appendix A2: Layout Map
Appendix A3: Sensitivity Map
Appendix A4: Sensitivity Map of the broader area
Appendix B: Site Photographs
Appendix C: Facility Illustration
Appendix D: Specialist(s)
Appendix D1: Atmospheric Impact Report
Appendix E: Public Participation
Appendix E1: Site Notices and Newspaper adverts
Appendix E2: Proof of Stakeholder Correspondence
Appendix E3: Authority Consultation
Appendix E4: I&AP Database
Appendix E5: Comments Received – to be included in the Final BAR
Appendix E6: Comments and Responses Report – to be included in the Final BAR
Appendix F: Impact Assessment
Appendix G: Environmental Management Programme (EMPr)
Appendix A: Layout Map
Appendix B: Grievance Mechanism for Public Complaints and Issues
Appendix C: Project Team CVs
Appendix H: EAP Declaration, Affirmation and CVs
Appendix I: Specialist Declaration
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and project overview Page v
SUMMARY AND OVERVIEW OF THE PROJECT
Neopak (Pty) Ltd propose to develop a Combined Heat and Power (CHP) gas turbine at the
existing Neopak Facility in Rosslyn, Gauteng. The project is known as the Neopak CHP Plant. The
existing Neopak paper mill facility in Rosslyn is located on a site located within Portion 3 of Erf 39,
Portion 1 of Erf 41 and Erf 40 (the affected properties)1. The development area2 proposed for
the CHP Plant is located within the existing Neopak paper mill facility (project site)3, and is the
area within which the construction and operation of the CHP Plant will take place. These
properties are considered to be a brownfields site4 which has been transformed through
industrial development (refer to Figure 1 and Table1 for more detail). A development footprint5
of approximately 675m2 has been identified within the existing Neopak facility and the
development area for the construction and operation of the CHP Plant (refer to Figure 2). The
general area is of an industrial nature, as Rosslyn is an industrialised area and includes industries
such as the BMW factory and the Nissan South Africa factory.
Table 1: Location of the Neopak CHP Plant project site, within the existing Neopak Paper Mill
Province Gauteng Province
Municipality City of Tshwane Metropolitan Municipality
Ward number(s) 98
Nearest town(s) The project site is located within Rosslyn which is an industrial area
within Pretoria. The project site is located ~23km north of the Pretoria
Central Business District.
Farm name(s) and number(s) Surveyor-General Database
» Portion 3 of Erf 39
» Portion 1 of Erf 41
» Erf 40
City of Tshwane City Planning and Development Department
» Parcel 514 Rosslyn, 6953 Hendrik van Eck Street
SG 21 Digit Code Surveyor-General Database
» T0JR02220000003900003
» T0JR02220000004100001
» T0JR02220000004000000
1The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced fromthe Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrikvan Eck Street as per the City of Tshwane City Planning and Development Department.
2 The development area is the identified location within the project site within which the CHP Plant will be sited. The
development area will include the development footprint, which will house the CHP turbine as well as the associated
linear infrastructure including gas lines and cabling. The development area is approximately 1.3ha in extent.3 The project site is defined the existing Neopak paper mill facility located in Rosslyn, Gauteng. The project site includes
three affected properties namely Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40.4 A brownfields site can be described as land previously or currently developed and used for industrial purposes or
commercial purposes. Such land is considered to be transformed, and degraded to an extent that the natural
environmental attributes are considered to be minimal.5The development footprint is the area identified within the development area to house the CHP Plant. The development
footprint is approximately 0.0675ha / 675m2 in extent.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and project overview Page vi
The Neopak Facility currently uses natural gas in a gaseous form and coal to generate steam for
use in the current paper mill operations. Neopak are now proposing the development of a CHP
Plant to pass the same gas through a gas turbine to generate both steam and electricity. This
development will be aiding and adding to the production of steam which is currently being
produced by coal and gas fired boilers on-site and also generate electricity. The purpose of the
project is, therefore, to produce both power and steam, rather than just steam which is currently
being produced by existing boilers located within the plant:
1. The steam produced by the CHP plant will be used for the operations of the paper mill
facility,
2. The electricity produced will be evacuated via an 11kV cable to an existing substation
located within the Neopak Facility.
The development will provide the opportunity for a more efficient use of the available energy,
effectively delivering a proportion of “free” conversion to electricity generation. The basic
operation of the proposed CHP Plant includes the following:
» Inlet air is filtered and ducted into multiple compression stages.
» Natural gas is fed into the combustion chamber, mixed with the compressed air and then
combusted.
» The combustion exhaust drives a series of turbine blades to provide rotational force to the
drive shaft.
» Electricity is produced through a generator connected to the drive shaft, which generates
the power component of the plant.
» Hot gases exiting the turbine at 500°C, contain a high level of energy and are ducted to a
heat recovery steam generator which generates the steam component of the plant.
» Final products of the combustion is exhausted to the atmosphere via flue.
The Neopak Facility site can be accessed via the regional road (R556) located to the north of
the project site and various secondary roads surrounding the area. The area surrounding the
project site and the site itself is of a highly industrial nature and is currently being used for the
operation of a paper mill, specifically for the production of cardboard boxes.
As the generation capacity of the CHP Plant (9.9 to 12MW) exceeds the threshold as stipulated
in Listing Notice 1 of the EIA Regulations, 2014, Savannah Environmental (Pty) Ltd has been
appointed by Neopak (Pty) Ltd in order to make an Application for Environmental Authorisation
in terms of the EIA Regulations, 2014 for the construction and operation of the CHP Plant.
The nature and extent of the plant, and the potential environmental impacts associated with
the construction, operation and decommissioning phases are explored in more detail in this
Basic Assessment Report. This report has been compiled in accordance with the requirements
of the EIA Regulations, 2014 and includes details of the activity description; the site, area and
property description; the public participation process; the impact assessment; as well as the
recommendations proposed by the Environmental Assessment Practitioner.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page vii
Figure 1: Locality map indicating the affected properties and the project site proposed for the Neopak CHP Plant
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page viii
Figure 2: Locality map indicating the development area and the development footprint of the Neopak CHP Plant in the existing Neopak Facility
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page ix
1.1. NEED AND DESIRABILITY FOR THE COMBINED HEAT AND POWER (CHP) PLANT
Globally there is increasing pressure to optimise energy usage in order to reduce
environmental impacts associated with the use of non-renewable energy resources. The
development of the CHP plant at the existing Neopak Facility will provide the opportunity to
optimise and fully utilise an available energy resource (natural gas is currently piped to the
site), as well as reduce the facility’s dependence on coal (which is combusted in the process
of raising steam for use at the current facility). Also, natural gas produces fewer emissions than
oil and coal and CHP systems capture and utilise heat that would otherwise be wasted from
the production of electricity. The CHP Plant will provide the opportunity to maximise and
optimise the use of the already available natural gas at the site.
The Combined Heat and Power (CHP) Plant proposed for the Neopak facility will not only fulfil
the role of raising steam required for use in the paper mill, but will also generate electricity for
own-use and/or export via the local electricity grid. The plant will combust natural gas to drive
a series of turbine blades and generates electricity (the power component of the plant). Hot
gases exiting the turbine at 500°C contain a high level of energy and are to be ducted to a
heat recovery steam generator which will generate the steam component of the plant. This
method of steam generation requires a considerably less amount of fuel in relation to the
conventional boilers currently installed and operating at the site.
The main objectives for the generation of electricity is to reduce the Neopak Facility’s reliance
on the municipal electricity supply, stabilise the power supply to the Neopak operations (i.e.
secure electricity supply without disruption), and strengthen the electricity capacity within an
area where significant constraints are being experienced. The installation of the CHP Plant will
provide a more efficient solution to address Neopak’s steam generation needs, while
simultaneously generating power and strengthening current supply to the site.
The following benefits are also considered to be associated with the development of the CHP
Plant:
» A lower carbon footprint will be the result of the implementation of the CHP Plant at the
Neopak facility.
» There will be a significant increase in energy efficiency as the already available natural
gas utilised will be implemented for both the operation of the existing Neopak Facility and
for the generation of electricity for the facility itself and potentially the surrounding
businesses.
» The national grid will be strengthened due to the reduced supply pressure which is currently
applied by the Neopak facility.
» Positive economic growth through secured electricity supply.
» There will be an increase in cost competitiveness of the Neopak facility, enabling exports,
growth and job creation.
» The CHP Plant will also extend the life of the production line of the facility thereby assisting
in the safeguarding of local employment and economic growth within the local
communities and the country as a whole.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page x
» The introduction of innovative technology for the generation of both steam and electricity
being implemented in South Africa which provides the opportunity to move away from
conventional generation methods, including the use of coal. The associated skills transfer
and demonstration effects of the proposed technology provides a learning opportunity for
future developments of this nature.
From an overall sensitivity and planning perspective, the proposed project infrastructure is not
considered contrary to the broader strategic context of the surrounding area due to the
severely industrialised nature of the area as a whole. The plant is also considered to be in line
with broader societal needs and the public interest as it is linked to electricity generation
without the use of coal as the energy source. No exceedance of environmental limits will result
from the development of the Neopak CHP Plant, and no impacts of significance would be
associated with the project due to the location of the plant within a highly transformed area
within the Rosslyn industrial area.
1.2. REQUIREMENTS FOR A BASIC ASSESSMENT PROCESS
In terms of the Environmental Impact Assessment (EIA) Regulations published in terms of
Section 24(5) of the National Environmental Management Act (NEMA, Act No. 107 of 1998),
Neopak (Pty) Ltd requires Environmental Authorisation for the development of the CHP Plant.
In terms of Sections 24 and 24D of the National Environmental Management Act (No 107 of
1998), as read with the EIA Regulations of GN R982 – R985, a Basic Assessment process is
required to be undertaken in support of the application for authorisation for the proposed
project.
The primary Listed Activity triggered under GN R983 is Activity 2 which relates to the
development and related operation of facilities or infrastructure for the generation of
electricity from a non-renewable resource where the electricity output is more than 10MW but
less than 20MW. The CHP Plant will, through the installation of a gas turbine, generate
electricity of 9.9 to 12MW, therefore triggering the listed activity and requiring an application
for Environmental Authorisation.
In terms of Section 24(1) of NEMA, the potential impact on the environment associated with
the activity must be considered, investigated, assessed and reported on to the competent
authority that has been charged by NEMA with the responsibility of granting environmental
authorisations. As the application is related to the generation of electricity, the National
Department of Environmental Affairs (DEA) is the competent authority6, and the Gauteng
Department of Agriculture and Rural Development (GDARD) will act as the commenting
authority. This project will be registered with the DEA through submission of an Application for
Environmental Authorisation.
The nature and extent of the CHP Plant at the Neopak Facility is explored in more detail in this
Basic Assessment Report. This report has been compiled in accordance with the requirements
of the EIA Regulations of December 2014 (as per Table 2 below), and includes details of the
6 In terms of the Energy Response Plan and Government Notice 779 of 01 July 2016, the DEA is the competent authorityfor all energy related applications.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xi
activity description; the site, area and property description; the public participation process;
the impact assessment; and the recommendations of the Environmental Assessment
Practitioner (EAP).
Table 2: Legal Requirements of GN. R. 982, Appendix 1 included in the 2014 EIA Regulations
NEMA REGULATION GNR 982, SECTION 19 REQUIREMENTS FOR THE
CONTENT OF BASIC ASSESSMENT REPORTS AS PER APPENDIX 1
CROSS REFERENCE IN THIS REPORT
(refer to the following parts in the
report)
(1) A basic assessment report must contain the information that
is necessary for the competent authority to consider and
come to a decision on the application, and must include—
(a) details of—
(i) the EAP who prepared the report; and
Section 1.3
(ii) the expertise of the EAP, including a curriculum vitae; Section 1.3
Appendix H
(b) the location of the activity, including:
(i) the 21 digit Surveyor General code of each cadastral
land parcel;
Section B
(ii) where available, the physical address and farm name; Section B
(iii) where the required information in items (i) and (ii) is not
available, the coordinates of the boundary of the
property or properties;
Section A (2) (a)
(c) a plan which locates the proposed activity or activities
applied for as well as associated structures and infrastructure
at an appropriate scale;
Appendix A1 and Appendix A2
Appendix C
or, if it is—
(i) a linear activity, a description and coordinates of the
corridor in which the proposed activity or activities is to
be undertaken; or on land where the property has not
been defined, the coordinates within which the activity
is to be undertaken;
N/A – no linear activity requires
authorisation
(d) a description of the scope of the proposed activity,
including—
(i) all listed and specified activities triggered and being
applied for; and
(ii) a description of the activities to be undertaken including
associated structures and infrastructure ;
Section A (1) a and b
(e) a description of the policy and legislative context within
which the development is proposed including—
(i) an identification of all legislation, policies, plans,
guidelines, spatial tools, municipal development
planning frameworks, and instruments that are
applicable to this activity and have been considered in
the preparation of the report; and
Section A (11), Table 3.1
(ii) how the proposed activity complies with and responds
to the legislation and policy context, plans, guidelines,
tools frameworks, and instruments;
Section A(11), Table 3.1
(f) a motivation for the need and desirability for the proposed
development including the need and desirability of the
activity in the context of the preferred location;
Section 1.1
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xii
NEMA REGULATION GNR 982, SECTION 19 REQUIREMENTS FOR THE
CONTENT OF BASIC ASSESSMENT REPORTS AS PER APPENDIX 1
CROSS REFERENCE IN THIS REPORT
(refer to the following parts in the
report)
(g) a motivation for the preferred site, activity and technology
alternative;
Section 1.1
(h) a full description of the process followed to reach the
proposed preferred alternative within the site, including:
(i) details of all the alternatives considered;
(ii) details of the public participation process undertaken in
terms of regulation 41 of the Regulations, including
copies of the supporting documents and inputs;
(iii) a summary of the issues raised by interested and
affected parties, and an indication of the manner in
which the issues were incorporated, or the reasons for
not including them;
Section A(2)
Section C
Appendix E
(iv) the environmental attributes associated with the
alternatives focusing on the geographical, physical,
biological, social, economic, heritage and cultural
aspects;
Section B
Section D
(v) the impacts and risks identified for each alternative,
including the nature, significance, consequence, extent,
duration and probability of the impacts, including the
degree to which these impacts—
(aa) can be reversed;
(bb) may cause irreplaceable loss of resources; and
(cc) can be avoided, managed or mitigated;
Section D
Appendix F
(vi) the methodology used in determining and ranking the
nature, significance, consequences, extent, duration
and probability of potential environmental impacts and
risks associated with the alternatives;
Appendix F
(vii) positive and negative impacts that the proposed activity
and alternatives will have on the environment and on
the community that may be affected focusing on the
geographical, physical, biological, social, economic,
heritage and cultural aspects;
Appendix F
Section D
(viii) the possible mitigation measures that could be applied
and level of residual risk;
Appendix F
Section D
(ix) the outcome of the site selection matrix; N/A
(x) if no alternatives, including alternative locations for the
activity were investigated, the motivation for not
considering such; and
Section A (2)
(xi) a concluding statement indicating the preferred
alternatives, including preferred location of the activity;
Section D (2)
(i) a full description of the process undertaken to identify, assess
and rank the impacts the activity will impose on the preferred
location through the life of the activity, including—
(i) a description of all environmental issues and risks that
were identified during the environmental impact
assessment process; and
Appendix F
Appendix D
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xiii
NEMA REGULATION GNR 982, SECTION 19 REQUIREMENTS FOR THE
CONTENT OF BASIC ASSESSMENT REPORTS AS PER APPENDIX 1
CROSS REFERENCE IN THIS REPORT
(refer to the following parts in the
report)
(ii) an assessment of the significance of each issue and risk
and an indication of the extent to which the issue and
risk could be avoided or addressed by the adoption of
mitigation measures;
Appendix F
Appendix D
Section D
(j) an assessment of each identified potentially significant
impact and risk, including—
(i) cumulative impacts;
(ii) the nature, significance and consequences of the
impact and risk;
(iii) the extent and duration of the impact and risk;
(iv) the probability of the impact and risk occurring;
(v) the degree to which the impact and risk can be
reversed;
(vi) the degree to which the impact and risk may cause
irreplaceable loss of resources; and
(vii) the degree to which the impact and risk can be
avoided, managed or mitigated;
Appendix F
Appendix D
Section D
(k) where applicable, a summary of the findings and impact
management measures identified in any specialist report
complying with Appendix 6 to these Regulations and an
indication as to how these findings and recommendations
have been included in the final report;
Section D (2)
(l) an environmental impact statement which contains—
(i) a summary of the key findings of the environmental
impact assessment;
(ii) a map at an appropriate scale which superimposes the
proposed activity and its associated structures and
infrastructure on the environmental sensitivities of the
preferred site indicating any areas that should be
avoided, including buffers; and
(iii) a summary of the positive and negative impacts and
risks of the proposed activity and identified alternatives;
Section D (2)
Appendix F
(m) based on the assessment, and where applicable, impact
management measures from specialist reports, the recording
of the proposed impact management objectives, and the
impact management outcomes for the development for
inclusion in the EMPr;
Section D (2)
Appendix F
(n) any aspects which were conditional to the findings of the
assessment either by the EAP or specialist which are to be
included as conditions of authorisation;
Section E
(o) a description of any assumptions, uncertainties, and gaps in
knowledge which relate to the assessment and mitigation
measures proposed;
Section 1.4
(p) a reasoned opinion as to whether the proposed activity
should or should not be authorised, and if the opinion is that it
should be authorised, any conditions that should be made in
respect of that authorisation;
Section D and Section E
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xiv
NEMA REGULATION GNR 982, SECTION 19 REQUIREMENTS FOR THE
CONTENT OF BASIC ASSESSMENT REPORTS AS PER APPENDIX 1
CROSS REFERENCE IN THIS REPORT
(refer to the following parts in the
report)
(q) where the proposed activity does not include operational
aspects, the period for which the environmental authorisation
is required, the date on which the activity will be concluded,
and the post construction monitoring requirements finalised;
N/A
(r) an undertaking under oath or affirmation by the EAP in
relation to:
(i) the correctness of the information provided in the
reports;
(ii) the inclusion of comments and inputs from stakeholders
and I&APs;
(iii) the inclusion of inputs and recommendations from the
specialist reports where relevant; and
(iv) any information provided by the EAP to interested and
affected parties and any responses by the EAP to
comments or inputs made by interested and affected
parties; and
Appendix H
Appendix I
(s) where applicable, details of any financial provisions for the
rehabilitation, closure, and ongoing post decommissioning
management of negative environmental impacts;
N/A
(t) any specific information that may be required by the
competent authority; and
N/A
(u) any other matters required in terms of section 24(4)(a) and (b)
of the Act.
N/A
1.3. DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER AND EXPERTISE TO CONDUCT
THE BASIC ASSESSMENT
Neopak (Pty) Ltd has appointed Savannah Environmental (Pty) Ltd as the independent
environmental consultant to undertake the required Basic Assessment process and to identify
and assess all the potential environmental impacts associated with the proposed project,
including proposing appropriate mitigation and management measures in an Environmental
Management Programme (EMPr). As part of these environmental studies, interested and
affected parties (I&APs) have been notified and provided an opportunity to participate
through the public involvement process. Neither Savannah Environmental nor the specialist
sub-consultant on this project are subsidiaries of, or are affiliated to Neopak (Pty) Ltd. In
addition, Savannah Environmental does not have any interest in secondary developments
that may arise out of the authorisation of the proposed project.
Savannah Environmental is a specialist environmental consulting company providing holistic
environmental management services, including environmental impact assessments and
planning to ensure compliance and evaluate the risk of development and the development
and implementation of environmental management tools. Savannah Environmental benefits
from the pooled resources, diverse skills and experience in the environmental field held by its
team that has been actively involved in undertaking environmental studies for a wide variety
of projects throughout South Africa and neighbouring countries. Strong competencies have
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xv
been developed in project management of environmental processes, as well as strategic
environmental assessment and compliance advice, and the assessment of environmental
impacts, the identification of environmental management solutions and mitigation/risk
minimising measures.
The Savannah Environmental team has considerable experience in environmental impact
assessments and environmental management, and have been actively involved in
undertaking environmental studies for a wide variety of projects throughout South Africa,
including those associated with electricity generation and transmission.
The Savannah Environmental team in this project includes:
» Lisa Opperman - the principle author of this report holds a Bachelor degree with Honours
in Environmental Management and has two years of experience in the environmental
field. Her key focus is on environmental impact assessments, public participation,
environmental management plans and programmes, as well as mapping using ArcGIS for
a variety of environmental projects. She is currently involved in several EIAs for renewable
energy projects across the country.
» Karen Jodas - is a registered Professional Natural Scientist and holds a Master of Science
degree and is the registered EAP on the proposed project. She has 20 years of experience
consulting in the environmental field. Her key focus is on strategic environmental
assessment and advice; management and co-ordination of environmental projects,
which includes integration of environmental studies and environmental processes into
larger engineering-based projects and ensuring compliance to legislation and guidelines;
compliance reporting; the identification of environmental management solutions and
mitigation/risk minimising measures; and strategy and guideline development. She is
currently responsible for the project management of EIAs for several renewable energy
projects across the country.
» Gabriele Wood - the public participation consultant for this project, holds an Honours
Degree in Anthropology, obtained from the University of Johannesburg. She has 9 years of
consulting experience in public participation and social research. Her experience includes
the design and implementation of public participation programmes and stakeholder
management strategies for numerous integrated development planning and
infrastructure projects. Her work focuses on managing the public participation component
of the Environmental Impact Assessment processes undertaken by Savannah
Environmental.
In order to adequately identify and assess potential environmental impacts associated with
the proposed project, Savannah Environmental has appointed the following specialist to
conduct an Air Quality Assessment for inclusion in the Basic Assessment Report:
Specialist Report Specialist Name Company Appendix
Air Quality
Assessment
Sarisha Perumal
Mark Zunckel
uMoya-NILU Consulting D1
Curricula vitae for the Savannah Environmental project team and the specialist consultant
appointed for the Air Quality Assessment are included in Appendix H.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Summary and Project Overview Page xvi
1.4. ASSUMPTIONS AND LIMITATIONS
The following assumptions and limitations are applicable to the studies undertaken within this
Basic Assessment Process:
» All information provided by the proponent to the environmental team was correct and
valid at the time it was provided.
» It is assumed that the development site identified by the proponent represents a
technically suitable site for the establishment of the proposed CHP Plant.
» This report and its investigations are project-specific, and consequently the environmental
team did not evaluate any other alternatives in terms of location and technology.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
Basic Assessment Report for Review Page xvii
BASIC ASSESSMENT REPORT FOR REVIEW
This Basic Assessment Report has been prepared by Savannah Environmental in order to assess
the potential environmental impacts associated with the Neopak CHP Plant located in Rosslyn,
Gauteng. This process is being undertaken in support of an application for environmental
authorisation to the National Department of Environmental Affairs (DEA).
The 30-day review period for the Basic Assessment Report is from 28 February 2017 to 31 March
2017. The report is available for public review at the following locations:
» Neopak Facility Reception, Rosslyn
» www.savannahsa.com
To obtain further information, register on the project database, or submit written comment
please contact:
Gabriele Wood
Savannah Environmental
Tel: 011 656 3237
Fax: 086 684 0547
Email: gabriele@savannahsa.com
Post: PO Box 148 Sunninghill, 2157
The due date for comments on the Basic Assessment Report is
31 March 2017
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 1
SECTION A: ACTIVITY INFORMATION
Has a specialist been consulted to assist with the completion of this
section?
NO
If YES, please complete the form entitled “Details of specialist and declaration of interest”
for the specialist appointed and attach in Appendix I.
1. PROJECT DESCRIPTION
a) Describe the project associated with the listed activities applied for
Neopak (Pty) Ltd propose to develop a Combined Heat and Power (CHP) gas turbine at the
existing Neopak Facility in Rosslyn, Gauteng. The project is known as the Neopak CHP Plant.
The existing Neopak paper mill facility in Rosslyn is located on a site located within Portion 3
of Erf 39, Portion 1 of Erf 41 and Erf 40 (the affected properties)7. The development area8
proposed for the CHP Plant is located within the existing Neopak paper mill facility (project
site)9, and is the area within which the construction and operation of the CHP Plant will take
place. These properties are considered to be a brownfields site10 which has been
transformed through industrial development. A development footprint11 of approximately
675m2 has been identified within the existing Neopak facility and the development area for
the construction and operation of the CHP Plant. The general area is of an industrial nature,
as Rosslyn is an industrialised area and includes industries such as the BMW factory and the
Nissan South Africa factory.
The Neopak Facility currently uses natural gas in a gaseous form and coal to generate steam
for use in the current paper mill operations. Neopak are now proposing the development of
a CHP Plant to pass the same gas through a gas turbine to generate both steam and
electricity. This development will be aiding and adding to the production of steam which is
currently being produced by coal and gas fired boilers on-site and also generate electricity.
The purpose of the project is, therefore, to produce both power and steam, rather than just
steam which is currently being produced by existing boilers located within the plant:
1. The steam produced by the CHP plant will be used for the operations of the paper
mill facility,
7 The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced from
the Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrik
van Eck Street as per the City of Tshwane City Planning and Development Department.
8 The development area is the identified location within the project site within which the CHP Plant will be sited. The
development area will include the development footprint, which will house the CHP turbine as well as the associated
linear infrastructure including gas lines and cabling. The development area is approximately 1.3ha in extent.
9 The project site is defined the existing Neopak paper mill facility located in Rosslyn, Gauteng. The project site includes
three affected properties namely Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40.10 A brownfields site can be described as land previously or currently developed and used for industrial purposes or
commercial purposes. Such land is considered to be transformed, and degraded to an extent that the natural
environmental attributes are considered to be minimal.11The development footprint is the area identified within the development area to house the CHP Plant. The
development footprint is approximately 0.0675ha / 675m2 in extent.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 2
2. The electricity produced will be evacuated via an 11kV cable to an existing
substation located within the Neopak Facility.
The development will provide the opportunity for a more efficient use of the available
energy, effectively delivering a proportion of “free” conversion to electricity generation. The
basic operation of the proposed CHP Plant includes the following:
» Inlet air is filtered and ducted into multiple compression stages.
» Natural gas is fed into the combustion chamber, mixed with the compressed air and then
combusted.
» The combustion exhaust drives a series of turbine blades to provide rotational force to
the drive shaft.
» Electricity is produced through a generator connected to the drive shaft, which
generates the power component of the plant.
» Hot gases exiting the turbine at 500°C, contain a high level of energy and are ducted to
a heat recovery steam generator which generates the steam component of the plant.
» Final products of the combustion is exhausted to the atmosphere via flue.
The site can be accessed via the regional road (R556) located to the north of the project site
and various secondary roads surrounding the area. The area surrounding the project site
and the site itself is of a highly industrial nature and is currently being used for the operation
of a paper mill, specifically for the production of cardboard boxes.
The requirement for the basic assessment is based on the electricity generation capacity of
the CHP Plant which is 9.9 to 12MW.
The following construction, operation and decommissioning activities will be associated with
the CHP Plant:
Construction Phase
The construction phase will be 6 months. The construction phase will include the
transportation of the required equipment and building material to the Neopak Facility. No
excavation of any natural habitats or vegetation will be required for the construction phase
due to the already transformed nature of the site within an industrial area. The installation of
the CHP Plant will include the connection of the CHP Plant to the existing gas lines which
service the site, the installation of the CHP Plant in the existing Neopak Facility and the
laydown of the 11kV cable (within an already transformed area) for the evacuation of the
generated electricity to the existing substation located within the Neopak Facility boundary
and approximately 140m west of the proposed CHP Plant.
Up to 75 employment opportunities will be created during the construction phase of the CHP
Plant.
Operation Phase
The operation phase will be ~20 years in duration. The operation phase will include the
generation of steam and electricity through the use of natural gas (which is already available
on the site and already used for the Neopak Facility operating processes). The CHP Plant will
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 3
require maintenance as and when required, which will be determined through the
performance of the plant.
The nature of the impact of the development of the CHP Plant on ambient air quality during
the operation phase is largely dependent on emissions from the operation phase of the CHP
Plant associated with the combustion of natural gas in a gaseous form. Natural gas produces
fewer emissions than oil and coal and CHP systems capture and utilise heat that would
otherwise be wasted from the production of electricity. While there will be an increase in
concentrations of both CO and NOx, the impacts on ambient air quality are minimal relative
to the NAAQS. The release of the expected emissions, including carbon monoxide, nitrogen
dioxide, sulphur dioxide and particulate matter, will not reach any set limit as per the National
Ambient Air Quality Standards (NAAQS) and is therefore considered to be compliant with
the standards.
The operation phase is not anticipated to create additional full time employment
opportunities as the Neopak Facility already employs a significant number of staff who have
the required skill for the operation of the CHP Plant.
Decommissioning
The CHP Plant will be decommissioned once it has reached its economic viability (~20 years)
or the technology will be updated to continue the operation of the CHP Plant. If the CHP
Plant is decommissioned then the un-instalment of the CHP Plant will be the main activity.
Employment opportunities might be available during the decommissioning phase
depending on the requirements at the time.
All services required for the construction, operation and decommissioning phases are readily
available and will be provided by the existing Neopak Facility.
b) Provide a detailed description of the listed activities associated with the project as
applied for
The proposed development requires Environmental Authorisation in terms of Sections 24 and
24D of the National Environmental Management Act (No 107 of 1998), as read with the EIA
Regulations of 2014, GN R983, and therefore a Basic Assessment (BA) process will be required
for the project.
2. FEASIBLE AND REASONABLE ALTERNATIVES
“alternatives”, in relation to a proposed activity, means different means of meeting the general
purpose and requirements of the activity, which may include alternatives to—
Listed activity as described in GN R 983, 984 and 985 Description of project activity that triggers listed
activity
GN R 983 Item 2(1):
The development and related operation of facilities
or infrastructure for the generation of electricity from
a non-renewable resource where the electricity
output is more than 10 megawatts but less than 20
megawatts
The development and operation of a Combined
Heat and Power (CHP) gas turbine to generate
both steam and electricity to be evacuated into
the existing Neopak Substation located within
the boundaries of the Neopak Facility. The
generating capacity will be 9.9 to 12MW.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 4
(a) the property on which or location where it is proposed to undertake the activity;
(b) the type of activity to be undertaken;
(c) the design or layout of the activity;
(d) the technology to be used in the activity;
(e) the operational aspects of the activity; and
(f) the option of not implementing the activity.
Describe alternatives that are considered in this application as required by Regulation 22(2)
(h) of GN R.982. Alternatives should include a consideration of all possible means by which the
purpose and need of the proposed activity could be accomplished in the specific instance
taking account of the interest of the applicant in the activity. The no-go alternative must in all
cases be included in the assessment phase as the baseline against which the impacts of the
other alternatives are assessed.
The determination of whether a site and/or activity (including different processes, etc.) is
appropriate, needs to be informed by the specific circumstances of the activity and its
environment. After receipt of this report the competent authority may also request the
applicant to assess additional alternatives that could possibly accomplish the purpose and
need of the proposed activity if it is clear that realistic alternatives have not been considered
to a reasonable extent.
The identification of alternatives should be in line with the Integrated Environmental Assessment
Guideline Series 11, published by the DEA in 2004. Should the alternatives include different
locations and lay-outs, the co-ordinates of the different alternatives must be provided. The
co-ordinates should be in degrees, minutes and seconds. The projection that must be used in
all cases is the WGS84 spheroid in a national or local projection.
a) Site alternatives
A site alternative refers to the identification of more than one potential site which may be
suitable for the establishment of a proposed facility. However, the requirement of the CHP
Plant forms part of the needs for the development at the Neopak Facility and will be specific
to the operations of the Facility. Also, the location of the CHP Plant within the Neopak Facility
is limited by space requirements and the location of the existing gas lines. Therefore, the site
proposed for the development of the CHP Plant and the location of the CHP Plant within the
Neopak Facility is considered as preferred with no other feasible site alternative available.
Alternative 1: preferred site alternative
Description Lat (DDMMSS) Long (DDMMSS)
CHP Plant development area 25°37’38.05”S
25°37’40.01”S
25°37’41.64”S
25°37’40.74”S
28°04’50.25”E
28°04’57.55”E
28°04’50.95”E
28°04’49.00”E
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 5
Figure 3: Layout map indicating the location of the CHP Plant to be developed within the Neopak Facility in Rosslyn, Gauteng
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 6
In the case of linear activities:
Alternative: Latitude (S): Longitude (E):
• Starting point of the activity
• Middle/Additional point of the activity
• End point of the activity
For route alternatives that are longer than 500m, please provide an addendum with co-
ordinates taken every 250 meters along the route for each alternative alignment.
The 11kV cable for the connection between the CHP Plant and the existing substation will be
less than 140m.
b) Technological alternatives
The Neopak Facility currently uses natural gas and coal to generate steam for use in the current
paper mill operations. The development of a CHP Plant to pass the same gas through a gas
turbine (Combined Heat and Power Gas Turbine) to generate both steam and electricity (9.9
to 12MW) is a technology alternative to the current installed plant. The CHP is considered an
alternative technology as it would aid and add to the production of steam at the paper mill
as well as generate electricity. The purpose of the technology alternative is, therefore, to
produce both power and steam, rather than just steam which is currently being produced by
existing boilers located within the plant.
No other technology alternatives are being considered.
PREFERRED TECHNOLOGY ALTERNATIVE
Alternative 1 (preferred alternative) – Combined Heat and Power gas turbine
A combined heat and power (CHP) turbine integrates the production of usable heat and power
(electricity) in a single and highly efficient process. CHP generates electricity while also
capturing usable heat that is produced in this process. This contrasts with conventional ways of
generating electricity where vast amounts of heat is simply wasted (Association for
Decentralised Energy, 2017).
Through the use of heat (which would have been a wasted resource with a conventional
turbine), CHP Plants can reach efficiency ratings of up to 90%. In comparison to the efficiency
of gas power stations which have an efficiency of between 49% and 52%, CHP technology is
considered to be the most viable technology. And for this application at the Neopak Facility,
the CHP solution will co-generate electricity and steam, both of which are required and used
at the paper mill.
Figure 4 below provides a process diagram of the CHP plant proposed at the Neopak site.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 7
Figure 4: CHP process
c) Layout alternatives
Only one layout is being considered for the development of the CHP Plant due to the following
reasons:
1. The Neopak Facility has existing infrastructure which needs to be considered in the position
and layout for the CHP Plant, which includes the points of connection of the existing gas
pipeline and grid connection.
2. The Neopak Facility has limited available space to accommodate the 675m2 development
footprint of the CHP Plant and therefore the location for the development is restricted to a
single location within the transformed industrial site.
Therefore no alternative layouts are being considered for the development of the CHP Plant.
Alternative 1 (preferred alternative)
The preferred layout for the CHP Plant is considered as the most appropriate and feasible
layout for the development. This layout takes into consideration the existing infrastructure
of the Neopak Facility and the best possible location of the CHP Plant within the Neopak
Facility. The preferred layout is included as Figure 3, and Appendix A2 and Appendix C.
d) Other alternatives (e.g. scheduling, demand, input, scale and design alternatives)
The design of the CHP Plant is based on widely proven and accepted industry standards and
does not affect the significance of environmental impacts (for example emissions to air). For
this CHP Plant located at the Neopak facility, the development footprint is located within a
highly transformed area characterised by industrial development and existing infrastructure.
No other alternatives are being considered for the development of the CHP Plant.
Fuel(natural gas available
at the NeopakFacility)
CombinedHeat and
Power(CHP Plant)
Power(evacuated to the
exsiting substation foroperational use at
the Neopak Facility)
Steam(evacuted to theNeopak Facility
through pipelines forthe operational use
at the Neopak Facility
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 8
e) No-go alternative
The no-go (or do nothing) alternative will result in the continuation of the use of the current
boilers at the Neopak Facility to raise steam, which operate on both gas and coal. A portion
of the energy input into the current boilers is wasted, and not used as an energy source to
generate electricity. The best practicable environmental solution is to introduce a technology
to the plant which can utilise heat that would otherwise be wasted.
As the current boilers are only able to raise steam, this no-go alternative is undesirable as the
Neopak Facility will still be reliant on coal as an energy resource. An in addition, electrical
energy potential from the boilers will still be wasted and no benefit arising from this energy. The
no-go alternative for the development of the CHP Plant is not considered as the desirable or
feasible alternative due to the following reasons:
a. The existing Neopak facility has natural gas in gaseous form readily available for use. A
new source of gas is, therefore, not required.
b. The development of the CHP Plant will ensure the efficient use of the natural gas through
the generation of both steam and electricity which are considered as essential
requirements for the operation of the paper mill.
c. The development of the CHP Plant ensures that all more of the energy released through
the combustion of natural gas in gaseous form is utilised for the operating process and that
a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising the
use of the energy resource.
d. The generated electricity will be evacuated to the existing substation located within the
Neopak facility boundaries via an 11kV cable. The electricity will be utilised for the
operation of the paper mill which in turn eliminates the dependence of the Neopak facility
on the national grid as well as strengthen the grid supply due to a reduced supply pressure
on the grid.
The opportunities presented by the development will be lost if the no-go alternative is applied,
and is therefore not considered desirable for the project. The negative impacts of the no-go
alternative are considered to outweigh the positive impacts of this alternative.
3. PHYSICAL SIZE OF THE ACTIVITY
a) Indicate the physical size of the preferred activity/technology as well as alternative
activities/technologies (footprints):
Alternative: Size of the activity:
Alternative A1 – Preferred (CHP Plant development area) ~1.3ha
Alternative A2
Alternative A3
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SECTION A: ACTIVITY INFORMATION Page 9
b) Indicate the size of the alternative sites or servitudes (within which the above
footprints will occur):
Alternative: Size of the site/servitude:
Alternative A1
Alternative A2
Alternative A3
4. SITE ACCESS
Does ready access to the site exist? YES
If NO, what is the distance over which a new access road will be built m
Describe the type of access road planned:
Access to the site is readily available via the use of secondary roads located within the Rosslyn
industrial area, the Neopak Facility main access (514 Hendrick van Eck Street, Rosslyn) and
facility internal roads. The main access route to the site will be the regional road (R566) which
is located approximately 330m to the north.
Appendix A1 indicates the position of the access road to the site which is the R566.
5. LOCALITY MAP
An A3 locality map must be attached to the back of this document, as Appendix A. The scale
of the locality map must be relevant to the size of the development at least1:50000. For linear
activities of more than 25 km, a smaller scale e.g. 1:250 000 can be used. The scale must be
indicated on the map. The map must indicate the following:
• an accurate indication of the project site position as well as the positions of the alternative
sites, if any;
• indication of all the alternatives identified;
• closest town(s);
• road access from all major roads in the area;
• road names or numbers of all major roads as well as the roads that provide access to the
site(s);
• all roads within a 1km radius of the site or alternative sites; and
• a north arrow;
• a legend; and
• locality GPS co-ordinates (Indicate the position of the activity using the latitude and
longitude of the centre point of the site for each alternative site. The co-ordinates should
be in degrees and decimal minutes. The minutes should have at least three decimals to
ensure adequate accuracy. The projection that must be used in all cases is the WGS84
spheroid in a national or local projection)
An A3 Locality map has been included within Appendix A1
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SECTION A: ACTIVITY INFORMATION Page 10
6. LAYOUT/ROUTE PLAN
A detailed site or route plan(s) must be prepared for each alternative site or alternative
activity. It must be attached as Appendix A to this document. The site or route plans must
indicate the following:
6.1 the scale of the plan which must be at least a scale of 1:500;
6.2 the property boundaries and numbers of all the properties within 50 metres of the site;
6.3 the current land use as well as the land use zoning of each of the properties adjoining
the site or sites;
6.4 the exact position of each element of the application as well as any other structures on
the site;
6.5 the position of services, including electricity supply cables (indicate above or
underground), water supply pipelines, boreholes, street lights, sewage pipelines, storm
water infrastructure and telecommunication infrastructure;
6.6 all trees and shrubs taller than 1.8 metres;
6.7 walls and fencing including details of the height and construction material;
6.8 servitudes indicating the purpose of the servitude;
6.9 sensitive environmental elements within 100 metres of the site or sites including (but not
limited thereto):
rivers;
the 1:100 year flood line (where available or where it is required by DWA);
ridges;
cultural and historical features;
areas with indigenous vegetation (even if it is degraded or invested with alien
species);
6.10 for gentle slopes the 1 metre contour intervals must be indicated on the plan and
whenever the slope of the site exceeds 1:10, the 500mm contours must be indicated on
the plan; and
6.11 the positions from where photographs of the site were taken
A Layout Map has been included in Appendix A2
7. SENSITIVITY MAP
The layout/route plan as indicated above must be overlain with a sensitivity map that indicates
all the sensitive areas associated with the site, including, but not limited to:
• watercourses;
• the 1:100 year flood line (where available or where it is required by DWS);
• ridges;
• cultural and historical features;
• areas with indigenous vegetation (even if it is degraded or infested with alien species); and
• critical biodiversity areas.
The sensitivity map must also cover areas within 100m of the site and must be attached in
Appendix A.
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SECTION A: ACTIVITY INFORMATION Page 11
An A3 sensitivity map of the site has been included within Appendix A3 and Figure 5 below.
This sensitivity map illustrates that no sensitive features are located within the site or directly
adjacent to the CHP Plant or the Neopak Facility due to the current transformed conditions
of the Rosslyn industrial area. An A3 sensitivity map of the site and the broader area has
been included within Appendix A4 and Figure 6 below. This sensitivity map illustrates
sensitive environmental features located well outside of the boundaries of the site and the
Neopak Facility and include:
» The Marikana Thornveld located to the south of the site which is classified as Vulnerable.
» Ecological Support Areas located north, west and east of the site as per the Gauteng
Conservation Plan (Gauteng CPlan).
» An area considered as irreplaceable located north east of the site.
» A Protected Area (known as the De Onderstepoort Private Nature Reserve) located
north east of the site.
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SECTION A: ACTIVITY INFORMATION Page 12
Figure 5: Map illustrating the sensitivity of the CHP Plant site overlain with the CHP Layout
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 13
Figure 6: Map illustrating the sensitivity of the broader area surrounding the site, and that the sensitive environments are located well outside
of the Rosslyn industrial area
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SECTION A: ACTIVITY INFORMATION Page 14
8. SITE PHOTOGRAPHS
Colour photographs from the centre of the site must be taken in at least the eight major
compass directions with a description of each photograph. Photographs must be attached
under Appendix B to this report. It must be supplemented with additional photographs of
relevant features on the site, if applicable.
Site photographs are attached within Appendix B.
9. FACILITY ILLUSTRATION
A detailed illustration of the activity must be provided at a scale of at least 1:200 as Appendix
C for activities that include structures. The illustrations must be to scale and must represent a
realistic image of the planned activity. The illustration must give a representative view of the
activity
A facility illustration is included within Appendix C.
10. ACTIVITY MOTIVATION
a) Need and desirability of the activity
Motivate and explain the need and desirability of the activity (including demand for the
activity):
1. Is the activity permitted in terms of the property’s existing land
use rights?YES
Please
explain
The affected properties are currently zoned for industrial use. The proposed activity will be
located within the existing Neopak facility and the steam and power generated from the CHP
Plant will be utilised for the operation of the Neopak Facility. The proposed activity is therefore
permitted and appropriate in terms of the property’s land use rights
2. Will the activity be in line with the following?
(a) Provincial Spatial Development Framework (PSDF) YESPlease
explain
The activity is to be undertaken within the existing and fully operational Neopak facility in
Rosslyn which in terms of the Gauteng Spatial Development Framework (GSDF) is part of the
“Provincial Economic Core” which is anchored by Rosslyn to the north (Tshwane) and is linked
to the OR Tambo International Airport to the east (Ekurhuleni) via the N1/R21 and the Central
Business District of Johannesburg to the south via the N1/M1 highway. This emerging Gauteng
Urban Region and its strategic prominence is a very strong force that will shape Tshwane’s
future not only spatially, but also economically and institutionally over the next decade.
Therefore, the activity is in line with the Provincial Spatial Development Framework.
(b) Urban edge / Edge of Built environment for the area YESPlease
explain
The CHP Plant is proposed to be developed within the existing and fully operational Neopak
Facility in Rosslyn, Gauteng. The City of Tshwane Metropolitan Spatial Development
Framework locates the Neopak Facility inside the boundary of an area to be used for higher
density urban development therefore the activity is located within the edge of built
environment for the area.
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(c) Integrated Development Plan (IDP) and Spatial
Development Framework (SDF) of the Local Municipality
(e.g. would the approval of this application compromise
the integrity of the existing approved and credible
municipal IDP and SDF?).
YESPlease
explain
The City of Tshwane Spatial Development Framework (2012) locates the existing Neopak
Facility in the north western quadrant of the City of Tshwane Metropolitan Municipality within
Region 1 of the 7 regions. This Region is known for its specialised nature of industrial areas
including the area within which the CHP Plant is proposed to be developed, therefore the
approval of this application would be in-line with and would not compromise the integrity of
the existing approved and credible municipal SDF.
In its strive towards energy security, the City of Tshwane Integrated Development Plan
(2016/17) acknowledges that the City of Tshwane is, through its long-term development plan
- Vision 2055, encouraging optimal energy management solutions, including those that
incorporate alternative energy, to be used in order to improve the resilience and resource
efficiency of the City. It has been stated amongst the Strategic Actions of the first Decade of
Change – by 2020, that focus should be on, amongst others, optimal energy management
solutions, including those that incorporate alternative energy, to be used. The CHP Plant is
aimed at using natural gas as an alternative energy source and to maximise and optimise the
use of the energy resource. Therefore, the development of the CHP Plant falls within the
municipality’s long term development plan and the approval of this application would
support the integrity of the Municipal IDP.
(d) Approved Structure Plan of the Municipality YESPlease
explain
The CHP Plant is to be developed within the existing and fully operational Neopak Facility
located within the Rosslyn Industrial Area. The structure plan of the City of Tshwane
Metropolitan Municipality fully accommodates the Rosslyn Industrial Area, therefore it can be
concluded that the CHP Plant development is in line with the structure plan. The Plant would
be considered to be additional to the existing infrastructure within the existing Neopak Facility.
(e) An Environmental Management Framework (EMF)
adopted by the Department (e.g. Would the approval of
this application compromise the integrity of the existing
environmental management priorities for the area and if
so, can it be justified in terms of sustainability
considerations?)
YESPlease
explain
The CHP Plant falls within the existing Neopak Facility which in terms of the Gauteng
Environmental Management Framework is located within a developed area that is zoned for
industry therefore the approval of this application would not compromise the integrity of the
of environmental management priorities for the area and will add to development in this
regard.
(f) Any other Plans (e.g. Guide Plan) YESPlease
explain
Tshwane Vision 2055:
The vision translates into six broad Outcomes that represent the areas that are key for the City
of Tshwane’s broad development logic over the next four decades. Outcome 1 is the City of
Tshwane’s commitment to implement the principles and interventions of a ‘smart
environment. The characteristics of a smart environment include the attractiveness of the
City’s natural environment, pollution reduction, protecting the environment and sustainable
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resource management. The goal in achieving Outcome1 is to use the City’s natural resources
effectively to reduce the City’s impact on the environment. The proposed activity
encourages Objective 1 of the Vision through maximising and optimising the use of a natural
non-renewable energy resource.
3. Is the land use (associated with the activity being applied for)
considered within the timeframe intended by the existing
approved SDF agreed to by the relevant environmental
authority (i.e. is the proposed development in line with the
projects and programmes identified as priorities within the
credible IDP)?
YESPlease
explain
The City of Tshwane Spatial Development Framework (2012) locates the existing Neopak
Facility in the north western quadrant of the City of Tshwane Metropolitan Municipality within
Region 1 of the 7 regions. This Region is known for its specialised nature of industrial areas
including the area within which the CHP Plant is proposed to be developed, therefore the
land-use is considered to be agreed to by the relevant environmental authority.
4. Does the community/area need the activity and the
associated land use concerned (is it a societal priority)? (This
refers to the strategic as well as local level (e.g. development
is a national priority, but within a specific local context it could
be inappropriate.)
YESPlease
explain
The Rosslyn area is already an industrial area. The CHP Plant is consistent with the activities
which are already present in the industrial area. The main purpose of the CHP Plant is to
enable the Neopak Facility to maximise its current natural gas usage. The Combined Heat
and Power Gas Turbine will generate both steam and electricity (9.9-12MW). This
development will be aiding and adding to the production of steam which is currently being
produced by coal and gas fired boilers on-site and also generate electricity. This is beneficial
to the area as the municipal grid will be strengthened in this area as a result of the power
generated at the site.
5. Are the necessary services with adequate capacity currently
available (at the time of application), or must additional
capacity be created to cater for the development?
(Confirmation by the relevant Municipality in this regard must
be attached to the final Basic Assessment Report as Appendix
I.)
YESPlease
explain
All the services needed for the CHP Plant have been developed for the existing Neopak
Facility and is readily available to utilise. The requirement of the CHP Plant will not require
additional capacity to the existing services due to the nature of the development. This
includes the natural gas pipeline which already exists at the site.
6. Is this development provided for in the infrastructure planning
of the municipality, and if not what will the implication be on
the infrastructure planning of the municipality (priority and
placement of services and opportunity costs)? (Comment by
the relevant Municipality in this regard must be attached to
the final Basic Assessment Report as Appendix I.)
NOPlease
explain
The CHP Plant will not have any implications for the Municipality infrastructure planning. Water
and other services is already available to be utilised as part of the existing Neopak Facility.
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7. Is this project part of a national programme to address an
issue of national concern or importance?YES
Please
explain
The introduction of natural gas into South Africa's mainstream energy supply is an important
step in the fulfilment of one of the major objectives of the White Paper on Energy Policy.
Natural gas burns cleaner than other fossil fuels, producing less carbon dioxide than both coal
and oil. Its use will therefore positively impact South Africa’s carbon emissions and is
considered as a manner of addressing issues of national concern even if the inputs therein are
only limited.
8. Do location factors favour this land use (associated with the
activity applied for) at this place? (This relates to the
contextualisation of the proposed land use on this site within
its broader context.)
YESPlease
explain
The location of the CHP Plant falls within the existing Neopak Facility (as the end-user) which
is located within a developed area that is zoned for industry (i.e. Rosslyn Industrial Area). The
site has been transformed and, therefore the location is highly suitable for the development
with negligible impact on the environment. The location of the proposed activity is therefore
considered to be the most feasible option taking technical issues and environmental aspects
into consideration.
9. Is the development the best practicable environmental option
for this land/site?YES
Please
explain
The Neopak Facility is an existing paper mill and processing plant which has been operational
over an extended period of time. The location of the CHP Plant falls within the existing Neopak
Facility (as the end-user) which is located within a developed area that is zoned for industry
(i.e. Rosslyn Industrial Area). The site has been transformed and, therefore the location is highly
suitable for the development with negligible impact on the environment. The CHP Plant would
be infill development within the Neopak industrial site. The location of the CHP Plant within
the Neopak Facility is therefore considered to be the best practicable environmental option
for this land/site.
10. Will the benefits of the proposed land use/development
outweigh the negative impacts of it?YES
Please
explain
The development of the CHP Plant will have a negligible environmental impact that can be
mitigated. The project is proposed within the existing Neopak Facility located within the
Rosslyn Industrial Area which has been transformed by various industrial developments. The
CHP Plant will facilitate the optimum usage of the natural gas supply to the site, with the CHP
Plant producing both electricity and steam for use the Neopak facility. The CHP Plant will
result in an overall reduction in carbon emissions, which will have positive impact at a local,
regional and national level and be in line with various national and provincial policies. No
significant negative impacts associated with the project have been identified, and the
project benefits are considered to outweigh any negative impacts (none of which are
considered fatal flaws or of a high significance).
11. Will the proposed land use/development set a precedent
for similar activities in the area (local municipality)?NO
Please
explain
There are numerous other industries operational in the existing Rosslyn industrial area and this
authorisation will not set a precedent for industrial developments. The CHP Plant may,
however, set a positive precedent to other industries which are able to also utilise similar
technology.
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12. Will any person’s rights be negatively affected by the
proposed activity/ies?NO
Please
explain
The private landowner has initiated the project. The location of the CHP Plant within the
Neopak Facility (which is utilised for industrial development) eliminates the potential for
negative impact on other person’s rights.
13. Will the proposed activity/ies compromise the “urban
edge” as defined by the local municipality?NO
Please
explain
The CHP Plant is proposed within the existing Neopak Facility which already falls within the built
and industrial environment – the Rosslyn Industrial area. Therefore the project will not
compromise the urban edge.
14. Will the proposed activity/ies contribute to any of the 17
Strategic Integrated Projects (SIPS)?NO
Please
explain
The main purpose of the CHP Plant is to enable the Neopak Facility to optimise their power
and steam needs at the facility. This project will not specifically contribute to the 17 SIPs.
15. What will the benefits be to society in general and to the local
communities?
Please
explain
The construction phase of the CHP Plant will create short term employment opportunities
during the construction phase, which will enable employees to be skilled in the new
technology, and which will be beneficial for similar future developments. The CHP Plant will
facilitate the optimum usage of the natural gas supply to the site, with the CHP Plant
producing both electricity and steam for use the Neopak facility. The CHP Plant will result in
an overall reduction in carbon emissions, which will have positive impact at a local, regional
and national level. The project will therefore have a positive impact in terms of cleaner energy
utilisation and a positive impact on the surrounding communities.
16. Any other need and desirability considerations related to the proposed
activity?
Please
explain
The development of the CHP plant at the existing Neopak Facility will provide the opportunity
to optimise and fully utilise an available energy resource (natural gas is currently piped to the
site), as well as reduce the facility’s dependence on coal (which is combusted in the process
of raising steam for use at the current facility). Also, natural gas produces fewer emissions than
oil and coal and CHP systems capture and utilise heat that would otherwise be wasted from
the production of electricity. The CHP Plant will provide the opportunity to maximise and
optimise the use of the already available natural gas at the site.
The Combined Heat and Power (CHP) Plant proposed for the Neopak facility will not only fulfil
the role of raising steam required for use in the paper mill, but will also generate electricity for
own-use and/or export via the local electricity grid. The plant will combust natural gas to drive
a series of turbine blades and generates electricity (the power component of the plant). Hot
gases exiting the turbine at 500°C contain a high level of energy and are to be ducted to a
heat recovery steam generator which will generate the steam component of the plant. This
method of steam generation requires a lower amount of fuel in relation to the conventional
boilers currently installed and operating at the site.
The main objectives for the generation of electricity is to reduce the Neopak Facility’s reliance
on the municipal electricity supply, stabilise the power supply to the Neopak operations (i.e.
secure electricity supply without disruption), and strengthen the electricity capacity within an
area where significant constraints are being experienced. The installation of the CHP Plant
will provide a more efficient solution to address Neopak’s steam generation needs, while
simultaneously generating power and strengthening current supply to the site.
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17. How does the project fit into the National Development Plan for 2030?Please
explain
By 2030 South Africa aims to reduce carbon emissions, promote economic development and
increase the GDP. To achieve this, the Provinces have aimed to improve Infrastructure and
Basic Services; Socio-economic Development; Institutional Transformation; Good
Governance and Public Participation; Financial viability and Management. The proposed
activity will assist in reducing the carbon footprint, as it will be utilising a cleaner energy source
than coal or oil.
The National Development Plan contains a plan aimed at eliminating poverty and reducing
inequality by 2030. The NDP identifies 9 key challenges and associated remedial plans.
Managing the transition towards a low carbon national economy is identified as one of the 9
key national challenges. Therefore the development of the CHP Plant will enable the Neopak
Facility to reduce its reliance on coal which will assist with achieving a low carbon economy
(even if the inputs are limited).
18. Please describe how the general objectives of Integrated Environmental Management
as set out in section 23 of NEMA have been taken into account.
The general objectives of Integrated Environmental Management have been taken into
account for this Basic Assessment report by means of identifying, predicting and evaluating
the actual and potential impacts on the biophysical environment.
The risks, consequences, alternatives as well as options for mitigation of activities have also
been considered with a view to minimise negative impacts, maximise benefits, and promote
compliance with the principles of environmental management.
19. Please describe how the principles of environmental management as set out in section
2 of NEMA have been taken into account.
Section 2 of NEMA states that environmental management must place people and their
needs at the forefront, and serve their physical, psychological, developmental, cultural and
social interests equitably. These principles of NEMA include the following:
» Development must be sustainable;
» Pollution must be avoided or minimised and remedied;
» Waste must be avoided or minimised, reused or recycled;
» Negative impacts must be minimised; and
» Responsibility for the environmental health and safety consequences of a policy, project,
product or service exists throughout its life cycle.
The principles of NEMA have been considered in this assessment through compliance with
the requirements of the relevant legislation in undertaking the assessment of potential
impacts, as well as through the implementation of the principle of sustainable development
where appropriate mitigation measures have been recommended for impacts which cannot
be avoided. In addition, the successful implementation and appropriate management of
this proposed project will aid in achieving the principle of minimisation of pollution and
environmental degradation, mainly due to the proposed location of the development. The
project also decreases the release of CO2 to air.
This process has been undertaken in a transparent manner and all effort has been made to
involve interested and affected parties, stakeholders and relevant Organs of State such that
an informed decision regarding the project can be made by the Competent Authority.
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11. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES
List all legislation, policies and/or guidelines of any sphere of government that are applicable
to the application as contemplated in the EIA regulations, if applicable (refer to Table 3 below.
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Table 3: Applicable Legislation, Policies and/or Guidelines to the development of the CHP Plant
Legislation Applicable Requirements Relevant Authority Compliance requirements
National Legislation
National
Environmental
Management
Act (Act No.
107 of 1998)
The EIA Regulations have been promulgated
in terms of Chapter 5 of the Act. Listed
activities which may not commence without
an environmental authorisation are identified
within these Regulations.
In terms of S24(1) of NEMA, the potential
impact on the environment associated with
these listed activities must be assessed and
reported on to the competent authority
charged by NEMA with granting of the
relevant environmental authorisation.
In terms of GNR 983 and 985 of June 2010 a
Basic Assessment Process is required to be
undertaken for the proposed project.
» National Department of
Environmental Affairs (DEA)
– competent authority
» Gauteng Department of
Agriculture and Rural
Development (GDARD) –
commenting authority
The listed activity triggered by the proposed CHP Plant have
been identified and assessed in the EIA process being
undertaken (i.e. Basic Assessment).
This Basic Assessment Report will be submitted to the
competent and commenting authority in support of the
application for authorisation.
National
Environmental
Management
Act (Act No.
107 of 1998)
In terms of the Duty of Care provision in S28(1)
the project proponent must ensure that
reasonable measures are taken throughout
the life cycle of this project to ensure that any
pollution or degradation of the environment
associated with a project is avoided, stopped
or minimised.
» National Department of
Environmental Affairs (DEA)
– competent authority
While no permitting or licensing requirements arise directly,
the holistic consideration of the potential impacts of the
proposed project has found application in the EIA process.
The implementation of mitigation measures are included as
part of the EMPr (Appendix G) and will continue to apply
throughout the life cycle of the Project.
National
Environmental
Management:
Waste Act,
2008 (Act No.
59 of 2008)
The Minister may by notice in the Gazette
publish a list of waste management activities
that have, or are likely to have, a detrimental
effect on the environment.
The Minister may amend the list by –
» Adding other waste management
activities to the list.
» National Department of
Environmental Affairs (DEA)
» Gauteng Department of
Agriculture and Rural
Development (GDARD)
As no waste disposal site is to be associated with the
proposed CHP Plant, therefore no permit is required in this
regard.
Waste handling, storage and disposal during construction
and operation is required to be undertaken in accordance
with the requirements of the Act, as detailed in the EMPr
(refer to Appendix G).
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Legislation Applicable Requirements Relevant Authority Compliance requirements
» Removing waste management activities
from the list.
» Making other changes to the particulars
on the list.
In terms of the Regulations published in terms
of this Act (GN 921), A Basic Assessment or
Environmental Impact Assessment is required
to be undertaken for identified listed activities
(Category A and B) while Category C
Activities (such as storage of waste) must be
undertaken in accordance with the
necessary norms and standards.
Any person who stores waste must at least
take steps, unless otherwise provided by this
Act, to ensure that:
» The containers in which any waste is
stored, are intact and not corroded or in
any other way rendered unlit for the safe
storage of waste.
» Adequate measures are taken to prevent
accidental spillage or leaking.
» The waste cannot be blown away.
» Nuisances such as odour, visual impacts
and breeding of vectors do not arise; and
» Pollution of the environment and harm to
health are prevented.
National
Environmental
Management:
Air Quality Act
S18, S19, and S20 of the Act allow certain
areas to be declared and managed as
“priority areas.”
» National Department of
Environmental Affairs (DEA)
– competent authority
» City of Tshwane
Metropolitan Municipality
The CHP Plant is considered to be a Small Boiler with a heat
input of less than 50MW per unit. Therefore, an Atmospheric
Emission License (AEL) will not be required (declared in terms
of Section 24 of the National Environmental Management:
Air Quality Act. An Atmospheric Impact report has been
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Legislation Applicable Requirements Relevant Authority Compliance requirements
(Act No. 39 of
2004)
GN R 893 of 22 November 2013 – the raising of
steam for power generation using solid, liquid
or gaseous fuels is a listed activity.
GN R831 of 2013 - Boilers using solid, liquid or
gaseous fuels with a design capacity of more
than 10MW but less than 50MW heat input per
unit are classifie as Small Boilers.
Declaration of controlled emitters (Part 3 of
Act) and controlled fuels (Part 4 of Act) with
relevant emission standards.
» GN R 827 – National Dust Control
Regulations prescribes general measures
for the control of dust in all areas
undertaken as part of the Basic Assessment report and is
includes as Appendix D1.
Dust Control Regulations describe the measures for control
and monitoring of dust, including penalties. These
regulations might be applicable during the construction
phase of the project. Dust management have also been
accounted for in the EMPr (see Appendix G).
Air Quality
Amendment
Act (Act No. 20
of 2014)
The National Environmental Management: Air
Quality Amendment Act, 2014 amends
certain provisions under the National
Environmental Management: Air Quality Act,
2004, so as to provide for further alignment
with the provisions of the National
Environmental Management Act, 1998 (Act
No. 107 of 1998); to close regulatory gaps
within the atmospheric emission licensing
system and to delete certain obsolete
provisions.
» National Department of
Environmental Affairs (DEA)
– competent authority
» City of Tshwane
Metropolitan Municipality
No gaps are considered to be associated with the
development of the CHP Plant due to the exclusion for the
need of an Atmospheric Emissions License based on the
classification of the CHP Plant as a Small Boiler.
National
Ambient Air
Quality
Standards
(NAAQS)
The standards provides limits for six
contaminants that are believed to be most
harmful to humans and the environment.
Contaminants are carbon monoxide, Lead,
nitrogen dioxide, Lead, particulate matter,
ozone, and sulphur dioxide
» National Department of
Environmental Affairs (DEA)
– competent authority
» City of Tshwane
Metropolitan Municipality
The CHP Plant will emit carbon monoxide, nitrogen dioxide,
sulphur dioxide and particulate matter (PM10). However, as
per the results of the Atmospheric Impact Report (refer to
Appendix D1) none of the emissions associated with the
development will reach the set limits of the NAAQS.
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Legislation Applicable Requirements Relevant Authority Compliance requirements
Hazardous
Substances
Act (Act No. 15
of 1973)
This Act regulates the control of substances
that may cause injury, or ill health, or death
due to their toxic, corrosive, irritant, strongly
sensitising, or inflammable nature or the
generation of pressure thereby in certain
instances and for the control of certain
electronic products. To provide for the rating
of such substances or products in relation to
the degree of danger; to provide for the
prohibition and control of the importation,
manufacture, sale, use, operation,
modification, disposal or dumping of such
substances and products.
» Group I and II: Any substance or mixture
of a substance that might by reason of its
toxic, corrosive etc., nature or because it
generates pressure through
decomposition, heat or other means,
cause extreme risk of injury etc., can be
declared to be Group I or Group II
hazardous substance;
» Group IV: any electronic product;
» Group V: any radioactive material.
The use, conveyance, or storage of any
hazardous substance (such as distillate fuel) is
prohibited without an appropriate license
being in force.
» Department of Health It is necessary to identify and list all the Group I, II, III, and IV
hazardous substances that may be on the site and in what
operational context they are used, stored or handled. If
applicable, a license could be required to be obtained from
the Department of Health.
Take note that during construction, an estimated amount of
3000m3 solid construction waste will be produced over a one
month period, for the expected 6 month construction
period.
Compliance must take note that all construction waste must
be safely stored in containers and be removed from site on
an ad hoc basis by the appointed construction contractor,
as and when deemed necessary. The construction waste
will be disposed of at an appropriately licenced Municipal
landfill site.
National Road
Traffic Act (Act
No 93 of 1996)
The technical recommendations for highways
(TRH 11): “Draft Guidelines for Granting of
Exemption Permits for the Conveyance of
Abnormal Loads and for other Events on
Public Roads” outline the rules and conditions
which apply to the transport of abnormal
» Provincial Department of
Transport (provincial roads)
» South African National
Roads Agency Limited
(national roads)
An abnormal load/vehicle permit may be required to
transport the various components to site for construction.
These include route clearances and permits could be
required for vehicles carrying abnormally heavy or
abnormally dimensioned loads.
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Legislation Applicable Requirements Relevant Authority Compliance requirements
loads and vehicles on public roads and the
detailed procedures to be followed in
applying for exemption permits are described
and discussed.
Legal axle load limits and the restrictions
imposed on abnormally heavy loads are
discussed in relation to the damaging effect
on road pavements, bridges and culverts.
» The general conditions, limitations and
escort requirements for abnormally
dimensioned loads and vehicles are also
discussed and reference is made to
speed restrictions, power/mass ratio, mass
distribution and general operating
conditions for abnormal loads and
vehicles. Provision is also made for the
granting of permits for all other
exemptions from the requirements of the
National Road Traffic Act and the
relevant Regulations.
Depending on the trailer configuration and height when
loaded, some of the components may not meet specified
dimensional limitations (height and width) and would need
to apply for the relevant permit/ clearance.
Provincial Legislation
Gauteng
Provincial
Environmental
Management
Framework
The Gauteng Provincial Environmental
Management Framework is a legal instrument
in terms of the Environmental Management
Framework Regulations, 2010.
The purpose of the regulations is to assist
environmental impact management
including EIA processes, spatial planning and
sustainable development.
» Gauteng Department of
Agriculture and Rural
Development (GDARD)
The development of the CHP Plant will aid in the promotion
of sustainable development within an area where there are
low environmental concerns (i.e. highly transformed
industrialised area) and high development demand.
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Legislation Applicable Requirements Relevant Authority Compliance requirements
The objective of the framework is to promote
efficient urban development (including
associated service infrastructure) in defined
selected areas with lower environmental
concerns and high development demand.
Service
Delivery
Charter and
Standards for
the Gauteng
Department of
Agriculture,
Conservation
and
Environment
The following strategic objectives must be
implemented:
» The facilitation of sustainable
development in Gauteng by ensuring
sustainable land uses (including
infrastructure development) and land use
patterns.
» To contribute to sustainable development
and quality of life by promoting a safe
and healthy living environment.
» Gauteng Department of
Agriculture and Rural
Development (GDARD)
The development of the CHP Plant will contribute to
sustainable development in terms of energy efficient
infrastructure. The development of the CHP Plant will reduce
the need for coal based electricity generation.
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12. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT
a) Solid waste management
Will the activity produce solid construction
waste during the construction/initiation
phase?
YES
If YES, what estimated quantity will be
produced per month?
The construction phase will create
approximately 3000m3 of spoil material (solid
waste) to be excavated over a period of
one month. Additional 1000m3 of general
waste will be generated during the 4 month
and will consist mainly of packaging
material and construction-related waste.
How will the construction solid waste be disposed of (describe)?
The construction waste generated by the construction of the CHP Plant will be disposed of
at acceptable and licensed facilities, in line with current industrial waste disposal practises
being practised by the Neopak Facility.
Where will the construction solid waste be disposed of (describe)?
The construction solid waste will be disposed of at acceptable and licensed facilities which
forms part of the current industrial waste disposal practises being practised by the Neopak
Facility.
Will the activity produce solid waste during its operational phase? NO
If YES, what estimated quantity will be produced per month? N/A – the amount will
be negligible and will
only result from plant
maintenance and
parts replacement.
How will the solid waste be disposed of (describe)?
Any solid waste resulting from the operation of the CHP Plant will be disposed of at
acceptable and licensed facilities, in line with current industrial waste disposal practises
being practised by the Neopak Facility.
If the solid waste will be disposed of into a municipal waste stream, indicate which registered
landfill site will be used.
The solid waste resulting from the operation of the CHP Plant will be disposed of at
acceptable and licensed facilities which forms part of the current industrial waste disposal
practises being practised by the Neopak Facility.
Where will the solid waste be disposed of if it does not feed into a municipal waste stream
(describe)?
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SECTION A: ACTIVITY INFORMATION Page 28
If the solid waste (construction or operational phases) will not be disposed of in a registered
landfill site or be taken up in a municipal waste stream, then the applicant should consult
with the competent authority to determine whether it is necessary to change to an
application for scoping and EIA.
Can any part of the solid waste be classified as hazardous in terms of the
NEM:WA?NO
If YES, inform the competent authority and request a change to an application for scoping
and EIA. An application for a waste permit in terms of the NEM:WA must also be submitted
with this application.
Is the activity that is being applied for a solid waste handling or treatment
facility?NO
If YES, then the applicant should consult with the competent authority to determine whether
it is necessary to change to an application for scoping and EIA. An application for a waste
permit in terms of the NEM:WA must also be submitted with this application.
The machinery associated with the CHP Plant will require oil change every c.35000 hours of
operation. This is considered to be the only waste generated at the site. The oil will be disposed
of at a licensed oil disposal facility to be chosen at the time. Both oil processing (FFS Refiners
(Pty) Ltd 1 Neutron Road, Chloorkop - (011) 976 219) and landfill options will be considered
(Valhalla Landfill Site Stefanus Schoeman Road, Valhalla. Tel: 012 374 2612).
b) Liquid effluent
Will the activity produce effluent, other than normal sewage, that will be
disposed of in a municipal sewage system?NO
If YES, what estimated quantity will be produced per month? m3
Will the activity produce any effluent that will be treated and/or disposed of
on site?
NO
If YES, the applicant should consult with the competent authority to determine whether it is
necessary to change to an application for scoping and EIA.
Will the activity produce effluent that will be treated and/or disposed of at
another facility?NO
If YES, provide the particulars of the facility:
Facility
name:
Contact
person:
Postal
address:
Postal code:
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 29
Telephone: Cell:
E-mail: Fax:
Describe the measures that will be taken to ensure the optimal reuse or recycling of waste
water, if any:
Water use at the plant will be limited to process water. A wastewater treatment plant is also
proposed to be developed for the Neopak Facility to facilitate the reuse and recycling of
process water at the site. The application for Environmental Authorisation for the water
treatment plant has been submitted to the Gauteng Department of Agriculture and Rural
Development.
c) Emissions into the atmosphere
Will the activity release emissions into the atmosphere other than
exhaust emissions and dust associated with construction phase
activities?
YES
If YES, is it controlled by any legislation of any sphere of government? YES – it is
controlled
by the
NEM: Air
Quality
Act
If YES, the applicant must consult with the competent authority to determine whether it is
necessary to change to an application for scoping and EIA.
The raising of steam for power generation using solid, liquid or gaseous fuels is a Listed Activity
with a design capacity equal to or greater than 50 MW heat input per unit in terms of
Government Notice 893 of 22 November 2013 (Government Gazette No. 37054). Boilers
using solid, liquid or gaseous fuels with a design capacity of more than 10MW but less than
50MW heat input per unit are, however, classified as Small Boilers. The small boilers are
considered as Controlled Emitters (DEA, 2013: Government Gazette 38973, No. 831 1
November 2013).
The Government Notice which defines the emission standards for boilers and the reporting
requirements talks to “per unit” and so the interpretation is that if the unit remains below 50
MW thermal, that the need for an Air Emissions License (AEL) is not required.
In order assess the impact of the emissions to air, an Atmospheric Impact Report has been
undertaken (refer to Appendix D1) as part of this Basic Assessment Process.
The Neopak plant is currently consuming natural gas to generate steam. The project
proposes the passing of the same gas through a gas turbine to generate power and steam.
The five existing boilers at the Neopak facility operate by combusting a combination of
natural gas in gaseous form and coal. The current thermal input is circa a million gigajoules
per year. There is no gas stored on site as gas is currently supplied via pipeline.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 30
Gas turbines, also called “combustion turbines”, are used in a broad scope of applications
including electric power generation. A gas turbine is an internal combustion engine that
operates with rotary rather than reciprocating motion.
The primary pollutants from gas turbine engines are nitrogen oxides (NOx), carbon monoxide
(CO), and to a lesser extent, volatile organic compounds (VOC). Particulate matter (PM) is
also a primary pollutant for gas turbines using liquid fuels. Nitrogen oxide formation is strongly
dependent on the high temperatures developed in the combustor. Carbon monoxide,
VOC, hazardous air pollutants (HAP), and PM are primarily the result of incomplete
combustion. Trace to low amounts of HAP and sulphur dioxide (SO2) are emitted from gas
turbines. Emissions of sulphur compounds, mainly SO2, are directly related to the sulphur
content of the fuel.
In South Africa ambient air quality is regulated in terms of the National Environmental
Management: Air Quality Act (No. 39 0f 2004) (NEM: AQA), the Air Quality Amendment Act
(Act No. 20 of 2014) and supporting regulations. Relevant to this assessment is the National
Ambient Air Quality Standards (NAAQS) and the dust fallout regulations.
The NAAQS for criteria pollutants consists of a limit value and a permitted frequency of
exceedance. The limit value is the fixed concentration level aimed at reducing the harmful
effects of a pollutant. The permitted frequency of exceedance represents the tolerated
exceedance of the limit value annually and accounts for high concentrations as a result of
process upsets and meteorological variation. Compliance with the ambient standard
implies that the frequency of exceedance does not exceed the permitted tolerance.
The following section provides the findings for two operation scenarios at the Neopak
Facility. Firstly a baseline scenario assesses the existing boilers 3, 4 and 5 running on natural
gas in gaseous form; and secondly, the future scenario considering the operation of boilers
3, 4 and 5 together with the CHP turbine running on natural gas (i.e. a cumulative
assessment, assuming that the existing boilers are still used during operation, even if only from
time to time).
» Carbon monoxide: The ambient 1-hour CO concentrations resulting from emissions from
the baseline scenario are low. The predicted CO concentrations are also well below
the 1-hour NAAQS of 30 mg/m3 (30 000 μg/m3) for the estimated future emission. The
maximum concentration of 44 μg/m3 is predicted to occur during the baseline
approximately 100m from the source. Similarly, the predicted 8-hour CO
concentrations for the future scenario are similar to the current operations. They are
well below the 8-hour NAAQS standard of 10 mg/m3 (10 000 μg/m3) for the estimated
future emission. The maximum concentration of 30.8 μg/m3 is predicted to occur
approximately 100m from the source.
» Nitrogen dioxide: The predicted 1-hour NO2 concentrations for the future scenario are
higher than the baseline scenario. They are however below the 1-hour NAAQS of 200
μg/m3. The maximum concentration of 135.5 μg/m3 is predicted to occur
approximately 1 200 m from the source. The predicted annual NO2 concentrations are
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION A: ACTIVITY INFORMATION Page 31
also well below the annual NAAQS of 40 μg/m3 for the estimated future emission. The
maximum concentration of 10.8 μg/m3 is predicted to occur approximately 1 400m
from the source.
» Sulphur dioxide: SO2 is emitted from Boilers 4 and 5 only. The predicted ambient
concentrations for the baseline are therefore the same for the future scenario. The
predicted 1-hour, 24-hour and annual average S02 concentrations are very low and
are below the respective NAAQS. The maximum concentration is predicted to occur
at the source in each averaging period and decrease consistently with increasing
distance from the source.
» Particulate matter (PM10): Similar to SO2, particulates are emitted from Boilers 4 and 5.
The predicted ambient concentrations for the baseline are therefore the same for the
future scenario. The predicted 24-hour PM10 concentrations are below the NAAQS of
75 μg/m3 for the estimated future emission. The maximum concentration of 0.22 μg/m3
is predicted to occur at the source and concentrations decrease consistently with
increasing distance from the source. The predicted PM10 concentrations are also well
below the 1 year NAAQS standard of 40 μg/m3. The maximum concentration of
0.02 μg/m3 is predicted to occur at the source and concentrations decrease
consistently with increasing distance from the source.
Refer to Section D, Appendix D1 and Appendix F for an assessment of the impacts relating
to emissions. Appendix G provides mitigation measures to be adhered regarding the
atmospheric impacts.
If NO, describe the emissions in terms of type and concentration:
d) Waste permit
Will any aspect of the activity produce waste that will require a waste permit
in terms of the NEM:WA?NO
If YES, please submit evidence that an application for a waste permit has been submitted to
the competent authority
e) Generation of noise
Will the activity generate noise? NO
If YES, is it controlled by any legislation of any sphere of government?
If YES, the applicant should consult with the competent authority to determine whether it is
necessary to change to an application for scoping and EIA.
If NO, describe the noise in terms of type and level:
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SECTION A: ACTIVITY INFORMATION Page 32
Noise impacts of acceptable levels will be generated. The CHP plant is ISO compliant with
regards to noise (ISO 10494: 1993 Gas turbines and gas turbines sets-measurements of
emitted air). It is expected that any new noise would meet these same levels in a free field
with no background noise.
13. WATER USE
Please indicate the source(s) of water that will be used for the activity by ticking the
appropriate box(es):
Municipal Water boardGroundwater River, stream,
dam or lakeOther
The activity
will not use
water
If water is to be extracted from groundwater, river, stream, dam, lake or
any other natural feature, please indicate the volume that will be
extracted per month:
Notapplicable
Does the activity require a water use authorisation (general authorisation
or water use license) from the Department of Water Affairs?YES NO
If YES, please provide proof that the application has been submitted to the Department of
Water Affairs.
Process water is to be sourced from the Municipal supply feeding the industrial area (supplied
by City of Tshwane (Rand Water)), as well as from the planned water treatment plant for the
recycling and re-use of process water currently being utilised as part of the operations of the
Neopak facility. The water requirements for operation of the CHP plant are small volumes used
for cleaning during maintenance, and they do not materially change Neopak’s current water
use levels. It is predicted that the cleaning of the CHP Plant will be required twice a year which
will require ~0.3m3.
14. ENERGY EFFICIENCY
Describe the design measures, if any that have been taken to ensure that the activity is energy
efficient:
The development of the CHP Plant is considered to be a process which will maximise the
use of natural gas through the generation of both steam and electricity for the operational
use at the existing Neopak Facility.
Describe how alternative energy sources have been taken into account or been built into the
design of the activity, if any:
Not applicable. The project in its very nature is aimed at providing alternative electricity to
the Neopak Facility for their operations.
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 33
SECTION B: SITE/AREA/PROPERTY DESCRIPTION
Important notes:
1. For linear activities (pipelines, etc.) as well as activities that cover very large sites, it may
be necessary to complete this section for each part of the site that has a significantly
different environment. In such cases please complete copies of Section B and indicate
the area, which is covered by each copy No. on the Site Plan.
Section B Copy No. (e.g. A): A
2. Paragraphs 1 - 6 below must be completed for each alternative.
3. Has a specialist been consulted to assist with the completion of this
section? NO
If YES, please complete the form entitled “Details of specialist and declaration of interest” for
each specialist thus appointed and attach it in Appendix I. All specialist reports must be
contained in Appendix D.
Property
description/
physical
address:
Province Gauteng Province
District Municipality City of Tshwane Metropolitan Municipality
Local Municipality -
Ward number(s) Ward 98
Nearest town(s) The project site is located within Rosslyn which is a suburb of
Pretoria. The project site is located ~23km north of the Pretoria
Central Business District.
Farm name(s) and number(s) Surveyor-General Database
» Portion 3 of Erf 39
» Portion 1 of Erf 41
» Erf 40
City of Tshwane City Planning and Development12 Department
» Parcel 514 Rosslyn, 6953 Hendrik van Eck Street
SG 21 Digit Code Surveyor-General Database
» T0JR02220000003900003
» T0JR02220000004100001
» T0JR02220000004000000
The affected properties house the existing Neopak Facility and it is within these
properties and the Neopak Facility that the CHP Plant will be developed.
12 The affected properties of the Neopak Facility (i.e. Portion 3 of Erf 39, Portion 1 of Erf 41 and Erf 40) was sourced from
the Surveyor-General Database. However, the affected properties are also known as Parcel 514 Rosslyn, 6953 Hendrikvan Eck Street as per the City of Tshwane City Planning and Development Department.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 34
Where a large number of properties are involved (e.g. linear activities), please
attach a full list to this application including the same information as indicated
above.
1. GRADIENT OF THE SITE
Indicate the general gradient of the site.
The Preferred Site (total development area of ~1.3ha)
Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper
than 1:5
2. LOCATION IN LANDSCAPE
Indicate the landform(s) that best describes the site:
2.1 RIDGELINE
2.2 PLATEAU
2.3 SIDE SLOPE OF HILL/MOUNTAIN
2.4 CLOSED VALLEY
2.5 OPEN VALLEY
2.6 PLAIN
2.7 UNDULATING PLAIN / LOW HILLS
2.8 DUNE
2.9 SEAFRONT
3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE
Is the site(s) located on any of the following?
Shallow water table (less than 1.5m deep) NO
Dolomite, sinkhole or doline areas NO
Current land-
use zoning as
per local
municipality
IDP/records:
Industrial use
In instances where there is more than one current land-use zoning, please
attach a list of current land use zonings that also indicate which portions
each use pertains to, to this application.
Is a change of land-use or a consent use application required? NO
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 35
Seasonally wet soils (often close to water
bodies)
NO
Unstable rocky slopes or steep slopes with
loose soil
NO
Dispersive soils (soils that dissolve in water) NO
Soils with high clay content (clay fraction
more than 40%)
NO
Any other unstable soil or geological
feature
NO
An area sensitive to erosion NO
If you are unsure about any of the above or if you are concerned that any of the above
aspects may be an issue of concern in the application, an appropriate specialist should be
appointed to assist in the completion of this section. Information in respect of the above will
often be available as part of the project information or at the planning sections of local
authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by the
Council for Geo Science may also be consulted.
4. GROUNDCOVER
Indicate the types of groundcover present on the site. The location of all identified rare or
endangered species or other elements should be accurately indicated on the site plan(s).
Natural veld -
good conditionE*
Natural veld with
scattered aliensE*
Natural veld with
heavy alien
infestationE
Veld dominated
by alien speciesEGardens
Sport field Cultivated land Paved surfaceBuilding or other
structureBare soil
If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to
assist in the completion of this section if the environmental assessment practitioner doesn’t
have the necessary expertise.
5. SURFACE WATER
Indicate the surface water present on and or adjacent to the site and alternative sites?
Perennial River NO
Non-Perennial River NO
Permanent Wetland NO
Seasonal Wetland NO
Artificial Wetland NO
If any of the boxes marked YES or UNSURE is ticked, please provide a description of the relevant
watercourse
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 36
6. LAND USE CHARACTER OF SURROUNDING AREA
Indicate land uses and/or prominent features that currently occur within a 500m radius of the
site and give description of how this influences the application or may be impacted upon by
the application:
Natural area Reservoir Polo fields
Low density residential Hospital/medical centre Filling station H
Medium density residential SchoolLandfill or waste treatment
site
High density residential Tertiary education facility Plantation
Informal residentialA Church Agriculture
Retail commercial &
warehousingOld age home River, stream or wetland
Light industrial Sewage treatment plantA Nature conservation area
Medium industrial AN Train station or shunting yard N Mountain, koppie or ridge
Heavy industrial AN Railway line N Museum
Power station Major road (4 lanes or more) N Historical building
Office/consulting room Airport N Protected Area
Military or police
base/station/compoundHarbour Graveyard
Spoil heap or slimes damA Sport facilities Archaeological site
Quarry, sand or borrow pit Golf course Livestock Grazing
If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by
the proposed activity?
The existing railway line infrastructure located within the area will not impacted upon as a
result of the development of the CHP Plant. The CHP Plant will be located within the Neopak
Facility boundaries and will not have an effect on the railway lines located within the area.
If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by
the proposed activity? Specify and explain:
The CHP Plant will be located within the Rosslyn industrial area and the project itself is
considered to be of an industrial nature. Therefore, no impact is expected to occur on the
CHP Plant from the industrial area and vice versa.
If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by
the proposed activity? Specify and explain:
N/A
Does the proposed site fall within any of the following:
Critical Biodiversity Area (as per provincial conservation plan)? NO
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 37
Core area of a protected area? NO
Buffer area of a protected area? NO
Planned expansion area of an existing protected area? NO
Existing offset area associated with a previous Environmental
Authorisation?
NO
Buffer area of the SKA? NO
If the answer to any of these questions was YES, a map indicating the affected area must be
included in Appendix A.
7. CULTURAL/HISTORICAL FEATURES
Are there any signs of culturally or historically significant elements, as
defined in section 2 of the National Heritage Resources Act, 1999, (Act No.
25 of 1999), including Archaeological or paleontological sites, on or close
(within 20m) to the site? If YES, explain:
NO
The site is located within a brownfields site which has been transformed to the extent that
no natural environmental attributes remain. The chance of a heritage find within the site will
be negligible due to historic transformation of the site.
If uncertain, conduct a specialist investigation by a recognised specialist in the field
(archaeology or palaeontology) to establish whether there is such a feature(s) present on or
close to the site. Briefly explain the findings of the specialist.
Will any building or structure older than 60 years be affected in any way? NO
Is it necessary to apply for a permit in terms of the National Heritage
Resources Act, 1999 (Act 25 of 1999)?NO
If YES, please provide proof that this permit application has been submitted to SAHRA or the
relevant provincial authority.
A permit application will be submitted if necessary, after the final siting of the infrastructure
and walk through surveys.
8. SOCIO-ECONOMIC CHARACTER
a) Local Municipality
Please provide details on the socio-economic character of the local municipality in which the
proposed site(s) are situated.
Level of unemployment:
According to the 2011 Census data, 345 356 people are unemployed within the City of
Tshwane Local Municipality and 1 079 273 people are employed. The unemployment rate
was identified to be 24.2%.
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 38
Economic profile of local municipality:
The City of Tshwane Metropolitan Municipality economy is highly service-based with
community services and government, financial services and manufacturing as the most
significant sectors. The City has a well-established manufacturing sector with the
automotive industry being a key player in this sector. The City boasts the highest
concentration of automotive Original Equipment Manufacturers (OEMs) in the country.
Furthermore, the City’s economy is characterised by a favourable and rapidly growing
trade performance with exports
Level of education:
Approximately 4.2% of people aged 20 years or more have received no education.
Approximately 34% of people aged 20 years of older have a matric certificate.
Approximately 23.4% of people age 20 years or older have a higher education.
b) Socio-economic value of the activity
What is the expected capital value of the activity
on completion?
The expected capital value will be between R 200
million and R 230 million.
What is the expected yearly income that will be
generated by or as a result of the activity?
The value of the energy savings is dependent on
electricity, coal and gas prices, as well as any
export of power to either the grid or neighbouring
industrial facilities.
Will the activity contribute to service infrastructure? YES. The activity will
strengthen the power
grid, reduce grid load
(i.e. reduced power
required from the
municipal supply)
Is the activity a public amenity? NO
How many new employment opportunities will be
created in the development phase of the activity?
During the construction phase, up to 75
employment opportunities may be created across
civil, mechanical and electrical aspects. The jobs
are created during the design & engineering,
transport, construction and commissioning phases.
These functions are being commissioned through
service providers who will be managing the
employment process. Some jobs will be temporary
and/or part time depending the specific activity or
service required.
What is the expected value of the employment
opportunities during the development phase?
The expected value of employment opportunities
will be between R 20 million and R 50 million.
What percentage of this will accrue to previously
disadvantaged individuals?
The percentage that accrues to previously
disadvantaged individuals will vary according to
the category of work and final procurement plans.
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How many permanent new employment
opportunities will be created during the operational
phase of the activity?
The operation phase is not anticipated to create
additional full time employment opportunities. The
Neopak Facility already employs a significant
number of staff. Job security is expected to improve
with increasing efficiency of operations. The
operators on site will also be increasing their skills in
learning to operate new technology associated
with the CHP Plant. The capability to operate gas
turbine power plants is a transferable skill that is
expected to become increasingly in demand as
South Africa increases use of natural gas for
electricity, as mandated for in the Integrated
Resource Plan.
What is the expected current value of the
employment opportunities during the first 10 years?
Not applicable, as the operation phase is not
anticipated to create additional full time
employment opportunities.
What percentage of this will accrue to previously
disadvantaged individuals?
Not applicable, as the operation phase is not
anticipated to create additional full time
employment opportunities
9. BIODIVERSITY
Please note: The Department may request specialist input/studies depending on the nature of
the biodiversity occurring on the site and potential impact(s) of the proposed activity/ies. To
assist with the identification of the biodiversity occurring on site and the ecosystem status
consult http://bgis.sanbi.org or BGIShelp@sanbi.org. Information is also available on compact
disc (cd) from the Biodiversity-GIS Unit, Ph (021) 799 8698. This information may be updated
from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is
used. A map of the relevant biodiversity information (including an indication of the habitat
conditions as per (b) below) and must be provided as an overlay map to the property/site
plan.
a) Indicate the applicable biodiversity planning categories of all areas on site and
indicate the reason(s) provided in the biodiversity plan for the selection of the
specific area as part of the specific category)
Systematic Biodiversity Planning Category
If CBA or ESA, indicate the
reason(s) for its selection in
biodiversity plan
Critical
Biodiversity
Area (CBA)
Ecological
Support Area
(ESA)
Other Natural
Area (ONA)
No Natural
Area
Remaining
(NNR)
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b) Indicate and describe the habitat condition on site
Habitat Condition
Percentage of
habitat
condition class
(adding up to
100%)
Description and additional comments and observations
(including additional insight into condition, e.g. poor land
management practises, presence of quarries, grazing,
harvesting regimes etc.).
Natural 0%
No natural areas are located within the site due to the
industrial nature of the Neopak Facility and the surrounding
areas.
Near Natural
(includes areas with
low to moderate level
of alien invasive
plants)
0% No near-natural areas are located within the site due to the
industrial nature of the Neopak Facility and the surrounding
areas.
Degraded
(includes areas
heavily invaded by
alien plants)
0% No degraded areas are located within the site due to the
industrial nature of the Neopak Facility and the surrounding
areas.
Transformed
(includes cultivation,
dams, urban,
plantation, roads,
etc.)
100% The site and location of the CHP Plant has been completely
transformed and no natural features are present within the
site. The broader area and the site is characterised by
industrial development and infrastructure including
factories, warehousing, roads and electrical infrastructure.
c) Complete the table to indicate:
(i) the type of vegetation, including its ecosystem status, present on the site; and
(ii) whether an aquatic ecosystem is present on site.
Terrestrial Ecosystems Aquatic Ecosystems
Ecosystem threat status
as per the National
Environmental
Management:
Biodiversity Act (Act No.
10 of 2004)
Critical Wetland (including
rivers, depressions,
channelled and
unchanneled
wetlands, flats, seeps
pans, and artificial
wetlands)
Estuary CoastlineEndangered
Vulnerable
YES NO YES NO YES NOLeast
Threatened
No terrestrial or aquatic ecosystems occur within the site or the adjacent areas due to the
industrial nature of the area, the Neopak Facility and the operations thereof and the location
of the proposed CHP Plant within Neopak Facility.
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION Page 41
d) Please provide a description of the vegetation type and/or aquatic ecosystem
present on site, including any important biodiversity features/information identified
on site (e.g. threatened species and special habitats)
Broad-Scale Vegetation
The original vegetation located within the project site was the Marikana Thornveld
vegetation type. This vegetation type has been classified as a vulnerable ecosystem.
However, due to the transformation of the Rosslyn area, which has been subject to heavy
industrial and infrastructure development over an extended period of time the vegetation
type is no longer present within the site, with the nearest portion of the vegetation located
over 650m to the south. Therefore, the impact of the CHP Plant on the vulnerable vegetation
will be negligible to none.
Site Sensitivity
No specialised natural habitat remains within the Neopak Facility boundaries due to the
built/transformed nature of the area including warehousing, processing infrastructure and
large paved surfaces. The location proposed for the CHP Pant within the Neopak Facility is
transformed and will be located between existing infrastructure associated with the Neopak
Facility. Refer to Appendix B for photos of the site.
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SECTION C: PUBLIC PARTICIPATION Page 42
SECTION C: PUBLIC PARTICIPATION
1. ADVERTISEMENT AND NOTICE
Publication name Pretoria News
Date published 03 March 2017
Site notice position Latitude Longitude
25°37'45.40"S 28° 4'52.78"E
Date placed 16 February 2017
Include proof of the placement of the relevant advertisements and notices (refer to Appendix
E1).
2. DETERMINATION OF APPROPRIATE MEASURES
Provide details of the measures taken to include all potential I&APs as required by Regulation
54(2)(e) and 54(7) of GN R.982.
» A2 Site notices were placed on the existing Neopak Facility main gate.
» An advert was placed in one local newspaper to notify the public about the EIA process
and availability of the Basic Assessment Report for a 30-day review period.
» No Stakeholder and I&AP issues and comments have been raised at this time. Comments
received and responses will be included in the Comments and Responses Report in the
Final Basic Assessment Process.
Key stakeholders (other than organs of state) identified in terms of Regulation 40(2)(c) and (d)
of GN R.982 (refer to Appendix E4 for the I&AP Database).
Title, Name and Surname Affiliation/ key stakeholder status Contact details (tel number or
e-mail address)
Mr. Dave Adam BMW SA (Pty) Ltd – Adjacent
Landowner
CEZ Investments cc:
Managing Director
Adjacent Landowner
Mr. Kenneth Collins Imbali Props (Pty) Ltd – Adjacent
Landowner
Mr. Mark Balladon KAP Automotive – Adjacent
Landowner
Mr. Jens Dieter Schutte MA Automotive Tool and Die (Pty)
Ltd – Adjacent Landowner
Mr. Abdul Khalik Patel Moneda Investments – Adjacent
Landowner
Mr. Paul le Roux Neopak (Pty) Ltd – Impacted
Landowner
Mr. Francois Greeff Nissan South Africa (Pty) Ltd –
Adjacent Landowner
Mr. Johan Koegelenberg Sentech Ltd – Interested and
Affected Party
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION C: PUBLIC PARTICIPATION Page 43
Tshwane North TVET
College: Head of Property
and Facilities Management
Adjacent Landowner
Include proof that the key stakeholders received written notification of the proposed activities
as Appendix E2. This proof may include any of the following:
• e-mail delivery reports;
• registered mail receipts;
• courier waybills;
• signed acknowledgements of receipt; and/or
• or any other proof as agreed upon by the competent authority.
Proof of written notification to key stakeholders have been included in Appendix E2.
3. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES
No comments have been received on the project to date. A focus group meeting will be held
during the review period with all adjacent landowners to provide a background to the project
and provide the opportunity for them to raise any issues of concern. All comments received
during the review period of the Basic Assessment report, as well as responses provided will be
captured and recorded within the Comments and Response Report attached as Appendix E6
in this Basic Assessment Report.
4. COMMENTS AND RESPONSE REPORT
The practitioner must record all comments received from I&APs and respond to each
comment before the Draft BAR is submitted. The comments and responses must be captured
in a comments and response report as prescribed in the EIA regulations and be attached to
the Final BAR as Appendix E6.
A comments and responses report including all comments received from I&APs and responses
to the comments received during the 30-day review period of the Basic Assessment Report will
be attached to the Final Basic Assessment Report for consideration by the DEA as Appendix
E6.
5. AUTHORITY PARTICIPATION
Authorities and organs of state identified as key stakeholders - refer to the I&AP database
contained in Appendix E4.
Authority/Organ of State Contact person (Title,
Name and Surname)
Tel No Fax No e-mail Postal
address
City of Tshwane Metropolitan
Municipality
Ward Councillor
(Ward 98): Marnette
Sutherland
City of Tshwane Metropolitan
Municipality
Air Quality Officer:
Livhuwani Siphuma
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION C: PUBLIC PARTICIPATION Page 44
Authority/Organ of State Contact person (Title,
Name and Surname)
Tel No Fax No e-mail Postal
address
City of Tshwane Metropolitan
Municipality
Acting City Manager:
Lindiwe Kwele
Department of Energy Program and
Projects: Wolsey Otto
Barnard
Department of Mineral
Resources
Regional Manager:
Mmadikeledi Malebe
Department of Water and
Sanitation
Acting Provincial
Head: Penutia
Ramunenyiwa
Eskom Holdings SOC Ltd Senior Environmental
Advisor: John
Geeringh
Gauteng Department of
Agriculture and Rural
Development
Chief Director: Loyiso
Mkwana
National Energy Regulatory
of South Africa (NERSA)
Senior Engineer:
Tamai Hore
Provincial Heritage Resources
Authority Gauteng (PHRAG)
Maphata Ramphele
South African Civil Aviation
Authority
Obstacle Specialist:
Lizell Stroh
Telkom SA Limited Leonard Shaw
Transnet Limited National Capacity
Planning and
Strategy: Futhi
Mathebula
Include proof that the Authorities and Organs of State received written notification of the
proposed activities as Appendix E3.
Proof of written notification to Authorities and Organs of State regarding the project is included
as Appendix E3.
In the case of renewable energy projects, Eskom and the SKA Project Office must be included
in the list of Organs of State.
6. CONSULTATION WITH OTHER STAKEHOLDERS
Note that, for any activities (linear or other) where deviation from the public participation
requirements may be appropriate, the person conducting the public participation process
may deviate from the requirements of that sub-regulation to the extent and in the manner as
may be agreed to by the competent authority.
Proof of any such agreement must be provided, where applicable. Application for any
deviation from the regulations relating to the public participation process must be submitted
prior to the commencement of the public participation process.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION C: PUBLIC PARTICIPATION Page 45
A list of registered I&APs has been included as Appendix E4.
Copies of any correspondence and minutes of any meetings held is to be included in
Appendix E2 and Appendix E3.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 46
SECTION D: IMPACT ASSESSMENT
The assessment of impacts must adhere to the minimum requirements in the EIA Regulations,
2014, and should take applicable official guidelines into account. The issues raised by
interested and affected parties should also be addressed in the assessment of impacts.
1. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION,
OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED
MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES
Provide a summary and anticipated significance of the potential direct, indirect and
cumulative impacts that are likely to occur as a result of the planning and design phase,
construction phase, operation phase, decommissioning and closure phase, including
impacts relating to the choice of site/activity/technology alternatives as well as the
mitigation measures that may eliminate or reduce the potential impacts listed. This impact
assessment must be applied to all the identified alternatives to the activities identified in
Section A (2) of this report.
The construction and decommissioning phases will have similar impacts in terms of
disturbance, as well as associated mitigation measures. It is however unlikely that this CHP
Plant will be completely decommissioned and closed (depending on the operation of the
existing Neopak Facility). Appropriate mitigation measures, which may eliminate, reduce or
manage any potential impacts of the construction, operation, and decommissioning phases
of the CHP Plant are included in the EMPr for the project, which is attached as Appendix G.
Planning Phase
Activities associated with the design and pre-construction phase pertains mostly to feasibility
assessments undertaken at a desktop level. However, due to the nature of the site proposed
for the development it is not expected that any feasibility assessments would be required.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 47
1.1 Construction and Operation Phase
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
Construction Impacts
Nuisance impacts
including dust and noise
during the construction
phase of the CHP Plant.
Direct impacts:
Limited dust and noise will be generated
by the construction activities for the
installation of the CHP Plant. There will not
be a significant impact to surrounding
areas due to the industrialised nature of
the area and the installation of the CHP
plant within the existing Neopak facility.
The impact can be considered as
negligible.
Low Dust impacts must be mitigated through the
implementation of appropriate dust suppression,
as required.
Indirect impacts:
Increased levels of noise, pollution,
disturbance within the broader area.
However, the impact will be limited due to
existing industrial elements and
disturbance already taking place within
the area.
Low
Cumulative impacts:
The cumulative impact will be low due to
the limited nature and extent of the
development within an already
industrialised area
Low
The generation of
construction waste
Direct impacts:
Limited waste will be generated during the
construction phase. All waste generated
Low All construction waste is disposed of at a licensed
facility and the disposal is supported with a waste
manifest.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 48
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
during the construction phase is required
to be disposed of in an appropriate
manner.
Indirect impacts:
None
-
Cumulative impacts:
None
-
Impact on traffic
resulting from
transportation of the
equipment required for
the construction of the
facility to the site
Direct impacts:
Equipment and project components will
be transported to site during the six-month
construction period. The site for the CHP
Plant is located within the Rosslyn industrial
area which is has an adequate road
network to provide for the movement of
light and heavy vehicles in the area, and
can readily accommodate abnormal
loads.
Low All vehicles must be road-worthy and all drivers
must have a valid license.
If abnormal loads will be transported to site the
relevant permits or clearances must be in place.
Transporting of goods through the use of abnormal
loads need to take please during off-peak hours.
Indirect impacts:
Disturbance on the road networks not
located within the surrounding areas of the
site
Low
Cumulative impacts:
Cumulative impacts will be minimal due to
the short construction period (6-months)
for the CHP Plant
Low
Employment
opportunities during the
construction phase
Direct impacts:
The construction phase will create up to 75
employment opportunities. Skills transfer
Low The allocation of employment opportunities
should be undertaken on a fair basis.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 49
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
will occur as the employees will be trained
in the construction of power generation
technology utilising gas.
Indirect impacts:
Skills transfer will occur as the employees
will be trained in the construction of gas
technology.
Low
Cumulative impacts:
None
-
PM10 emissions from
construction activities
Direct impacts:
The construction will include activities will
lead to the emission of particulate matter
(PM10) which may impact any affected
parties. Emissions of air pollutants will be
very low and the associated ambient
concentrations will also be very low and
limited to the site.
Low Cover loads on vehicles carrying dusty
construction materials and limit access to
construction site to construction vehicles only.
Indirect impacts:
Exposure to PM10 concentrations
exceeding the NAAQS
Low
Cumulative impacts:
Particulate matter emissions from
construction will increase the ambient
concentrations, but it is unlikely that the
cumulative effect will result in
exceedances of the NAAQS.
Low
Operation Phase
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 50
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
Maximisation and
optimisation of natural
gas as an energy
resource
Direct impacts:
The CHP Plant will utilise natural gas (readily
available at the Neopak Facility) for the
generation of both steam and electricity.
Both the steam and electricity will be
utilised for the processes of the Neopak
Facility. This will reduce the dependence
of coal as an energy source for Neopak.
Low Maintenance on the CHP Plant should be carried
out regularly to ensure the efficient operation of
the plant and the efficient use of the natural gas
as an energy resource.
Indirect impacts:
None
-
Cumulative impacts:
Better use of natural gas in a gaseous form
as an energy resource without the loss of
energy through the combustion of the
natural gas
Low
Natural Gas Combustion
associated with the CHP
Turbine and the release
of CO
Direct impacts:
The nature of the impact on ambient air
quality is largely dependent on emissions
from the operation phase of the CHP Plant
associated with the combustion of natural
gas. Natural gas produces fewer emissions
than oil and coal and CHP systems
capture and utilise heat that would
otherwise be wasted from the production
of electricity. While there will be an
increase in concentrations of both CO and
NOx, the impacts on ambient air quality
are minimal relative to the NAAQS.
Low The CHP Plant should operate under optimal
conditions and carry out regular maintenance.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 51
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
Indirect impacts:
Exposure to CO concentrations exceeding
the NAAQS
Low
Cumulative impacts:
There are limited sources of CO in the
vicinity of the site, the potential for
cumulative impact is therefore low.
Low
Natural gas Combustion
associated with the CHP
Turbine and the release
of NOx
Direct impacts:
The nature of the impact on ambient air
quality is largely dependent on emissions
from the operational phase of the CHP
System associated with the combustion of
natural gas. Natural gas produces fewer
emissions than oil and coal and CHP
systems capture and utilise heat that
would otherwise be wasted from the
production of electricity. While there will
be an increase in concentrations of both
CO and NOx, the impacts on ambient air
quality are minimal relative to the NAAQS.
Low The CHP Plant should operate under optimal
conditions and carry out regular maintenance.
Indirect impacts:
Exposure to NOx concentrations
exceeding the NAAQS
Low
Cumulative impacts:
There are limited sources of NOX in the
vicinity of the site, the potential for
cumulative impact is therefore low.
Low
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 52
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
PM10 emissions from
natural gas boilers
Direct impacts:
Particulate matter (PM10) is emitted by the
existing boilers using natural gas. Emissions
are very low and the associated ambient
concentrations will also be very low and
limited to the site.
Low The CHP Plant should operate under optimal
conditions and carry out regular maintenance.
Indirect impacts:
Exposure to PM10 concentrations
exceeding the NAAQS
Low
Cumulative impacts:
There are exceedances of PM10 in Rosslyn,
but predicted concentrations from
Neopak are very low, the potential for
cumulative impact is therefore low.
Low
SO2 emissions from
natural gas boilers
Direct impacts:
SO2 is emitted by the existing boilers using
natural gas. Emissions are very low and the
associated ambient concentrations will
also be very low and limited to the site.
Low The CHP Plant should operate under optimal
conditions and carry out regular maintenance.
Indirect impacts:
Exposure to SO2 concentrations exceeding
the NAAQS
Low
Cumulative impacts:
The limited sources of SO2 in the vicinity of
Nepoak and the predicted concentrations
from Neopak are very low, the potential for
cumulative impact is therefore low.
Low
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 53
Activity Impact summary Significance
(with mitigation)
Proposed mitigation/enhancement
Maintenance of the
CHP Plant during the
operation phase
Direct impacts:
Maintenance will include the replacement
of oils utilised by the CHP Plant and the
replacement of parts. These project
components will be required to be
disposed of in a responsible manner and at
licensed waste disposal facilities.
Low Oils replaced at the plant must be disposed of in
an appropriate manner or recycled for re-use.
All parts replaced at the CHP Plant are required to
be disposed of at an appropriate disposal site or
recycled.
Indirect impacts:
None
-
Cumulative impacts:
None
-
1.2 Decommissioning Phase
Impacts associated with the decommissioning of the proposed infrastructure will be similar to those described and assessed for the construction
phase.
Decommissioning Phase
PM10 emissions from
closure activities
Direct impacts:
The decommissioning will include cutting
and general demolition. Emissions of
particulates will be very low and the
associated ambient concentrations will
also be very low and limited to the site.
Low Cover loads on vehicles carrying dusty
construction materials and limit access to site to
construction vehicles only.
Indirect impacts:
Exposure to PM10 decommissioning
exceeding the NAAQS
Low
Cumulative impacts: Low
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 54
PM10 emissions from decommissioning will
increase the ambient concentrations, but
it is unlikely that the cumulative effect will
result in exceedances of the NAAQS.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 55
1.3 The No-Go Alternative
The no-go (or do nothing) alternative will result in the continuation of the use of the current
boilers at the Neopak Facility to raise steam, which operate on both gas and coal. A portion
of the energy input into the by the current boilers is wasted, and not used as an energy
source to generate electricity. The best practicable environmental solution is to introduce
a technology to the plant which can utilise heat that would otherwise be wasted.
As the current boilers are only able to raise steam, this no-go alternative is undesirable as the
Neopak Facility will still be reliant on coal as an energy resource, with no reduction in the
use thereof. An in addition, heat energy from the boilers will still be wasted and no benefit
arising from this energy. The no-go alternative for the development of the CHP Plant is not
considered as the desirable or feasible alternative due to the following reasons:
a. The existing Neopak facility has natural gas in gaseous form readily available for use. A
new source of gas is, therefore, not required.
b. The development of the CHP Plant will ensure the efficient use of the natural gas through
the generation of both steam and electricity which are considered as essential
requirements for the operation of the paper mill.
c. The development of the CHP Plant ensures that all more of the energy released through
the combustion of natural gas in gaseous form is utilised for the operating process and
that a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising
the use of the energy resource.
d. The generated electricity will reduce the dependence of the Neopak facility on the
national grid as well as strengthen the grid supply due to a reduced supply pressure on
the grid.
The opportunities presented by the development will be lost if the no-go alternative is
applied, and is therefore not considered desirable for the project. The negative impacts of
the no-go alternative are considered to outweigh the positive impacts of this alternative.
The ‘No-Go’ alterative is an undesirable option for the project as it will result in a lost
opportunity for sufficient energy utilisation at the existing Neopak facility. The ‘No-Go’
alternative is, therefore, not a preferred alternative.
A complete impact assessment in terms of Regulation 22(2)(i) of GN R.982 is included as
Appendix F.
2. ENVIRONMENTAL IMPACT STATEMENT
Taking the assessment of potential impacts into account, please provide an environmental
impact statement that summarises the impact that the proposed activity and its alternatives
may have on the environment after the management and mitigation of impacts have been
taken into account, with specific reference to types of impact, duration of impacts, likelihood
of potential impacts actually occurring and the significance of impacts.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 56
The overall significance rating of the impacts of the proposed development of the proposed
CHP Plant during the construction and operation phase is low significance (both with or
without the implementation of mitigation). The low significance of the impact is primarily due
to the location and nature of the site and the surrounding area which is characterised by
industrial developments and existing infrastructure. There are no natural features located
within the site or the existing Neopak Facility as the site has been completely transformed for
the operation of the Neopak paper mill. It is predicted through the air quality assessment that
the operations of the CHP Plant will generate low emissions, low ambient concentrations, and
low ambient air quality impacts, resulting in an impact of low significance (both with or without
the implementation of mitigation). Emissions to air from the operation of the CHP Plant will be
local in extent and long-term. The magnitude of the impact will be minor and is probable to
occur. The overall significance is therefore low (and remains low with the implementation of
the recommended mitigation measures).
Cumulative impacts associated with the development of the CHP Plant are considered to be
of a very low significance. The site is located within an industrial area, and in an area
dominated by industrial facilities. The existing Neopak Facility is an industrial development (i.e.
paper mill) and the location of the CHP Plant within the paper mill is characterised by paved
surfaces, buildings and heavy infrastructure. The development of the CHP Plant will not lead
to a whole-scale change of the area due to the current state of the Rosslyn Industrial Area and
the Neopak Facility. The development will also not significantly add to the current impacts of
the paper mill. Therefore, the development of the CHP is considered appropriate within the
proposed location without any significant cumulative impacts.
The impacts expected during the construction phase will be of a short duration (~6 months)
and of a local extent. The magnitude of the impacts will range from small to minor. The
impacts expected during the operation phase will be of a long duration (~20 years) and of a
local extent. The magnitude of the impacts will be minor.
Conclusion:
Overall the impact of the CHP Plant will be of low to negligible significance due to the already
heavily transformed nature of the site through the development of the existing Neopak Paper
Mill Facility. No natural features or habitats will be destructed during the life cycle of the facility.
Impacts associated with the construction phase (~6 months) will be negligible due to the
transformed nature of the site and the presence of the existing Neopak facility infrastructure.
The impacts associated with the operation phase (~20 years) will be the most prominent as
disturbance will take place within the paved (sealed)/transformed area, however only limited
due to the nature of the surrounding industrial area and the nature of the operational CHP
Plant. The impacts of the construction phase and operation phase have been assessed as
being of a low significance, both before and after the implementation of the recommended
mitigation measures.
With the implementation of appropriate mitigation measures the development of the CHP
Plant is considered to be appropriate, with negligible impacts on all activities and without any
fatal flaws.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 57
If the recommended mitigation measures mentioned in Section E of the form below and those
contained in the attached EMPr (Appendix G) are applied, the significance of the impacts will
be low with no lasting significant negative environmental impacts arising from the
development of the CHP Plant (construction phase and/or the operation phase).
The project has significant benefits, and is considered the best practicable environmental
solution as this technology can utilise heat to generate electricity that would otherwise be
wasted. The long-term benefits include:
a. The existing Neopak facility has natural gas in gaseous form readily available for use. A
new source of gas is, therefore, not required.
b. The development of the CHP Plant will ensure the efficient use of the natural gas through
the generation of both steam and electricity which are considered as essential
requirements for the operation of the paper mill.
c. The development of the CHP Plant ensures that all more of the energy released through
the combustion of natural gas in gaseous form is utilised for the operating process and that
a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising the
use of the energy resource.
d. The generated electricity will reduce the dependence of the Neopak facility on the power
grid as well as strengthen the grid supply due to a reduced supply pressure on the grid.
This section provides a summary of the environmental assessment and conclusions drawn for
the Neopak CHP Plant which will be developed for the generation of both steam and
electricity through the use natural gas already available at the Neopak Facility. In doing
so, it draws on the information gathered as part of the Basic Assessment process and the
knowledge gained by the environmental consultant during the course of the process, and
presents an informed opinion of the environmental impacts associated with the proposed
project. The following conclusions can be drawn from the Basic Assessment:
The development of the CHP Plant at the Neopak Facility in Rosslyn will result in positive
impacts and minor negative impacts.
The positive impacts relate to the optimisation of the use of a non-renewable energy
resource (i.e. natural gas) through the application of a CHP gas turbine. The use of this CHP
plant will ensure that the steam produced as part of the Neopak Facility operations is
produced in a more efficient manner than the current boilers. Also, the use of natural gas
produces fewer emissions than oil and coal and CHP systems capture and utilise heat that
would otherwise be wasted from the production of electricity. The fact that the
development will take place within an area which has been subjected to heavy industrial
development and whole-scale transformation is also considered to be a positive impact as
the construction and operation of the CHP Plant will not impact on any natural habitats and
features.
Therefore the development is considered to be a sustainable use of a site which has been
transformed to a point where no ecosystem functioning exists. Limited positive social
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION D: IMPACT ASSESSMENT Page 58
impacts are expected within the construction phase which includes up to 75 employment
opportunities and skills transfer in the construction phase of the gas turbine.
Impacts during the construction phase will primarily be minor nuisance impacts limited to
the site and the industrial area. These impacts are local in extent, short-term are of low to
negligible significance. Operation impacts will mainly relate to emissions to air, and all
impacts related to emissions have been assessed as being of low significance.
No-go alternative (compulsory)
The ‘Do nothing’ alterative is the option of not constructing the Neopak CHP Facility. This
option will result in no impacts occurring, including positive impacts which is mainly the
opportunity of sufficient energy generation of a non-renewable energy resource. The no-
go alternative for the development of the CHP Plant is not considered as the desirable or
feasible alternative due to the following reasons:
a. The existing Neopak facility has natural gas in gaseous form readily available for use. A
new source of gas is, therefore, not required.
b. The development of the CHP Plant will ensure the efficient use of the natural gas through
the generation of both steam and electricity which are considered as essential
requirements for the operation of the paper mill.
c. The development of the CHP Plant ensures that all more of the energy released through
the combustion of natural gas in gaseous form is utilised for the operating process and
that a much smaller percentage (from c.30% to c.10% losses) of energy is lost, optimising
the use of the energy resource.
d. The generated electricity will reduce the dependence of the Neopak facility on the
national grid as well as strengthen the grid supply due to a reduced supply pressure on
the grid.
The ‘No-Go’ alterative is an undesirable option for the project as it will result in a lost
opportunity for sufficient energy utilisation at the existing Neopak facility. The ‘No-Go’
alternative is, therefore, not a preferred alternative.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION E: RECOMMENDATION OF PRACTITIONER Page 59
SECTION E: RECOMMENDATION OF PRACTITIONER
Is the information contained in this report and the documentation
attached hereto sufficient to make a decision in respect of the activity
applied for (in the view of the environmental assessment practitioner)?
YES
If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA
process before a decision can be made (list the aspects that require further assessment).
If “YES”, please list any recommended conditions, including mitigation measures that should
be considered for inclusion in any authorisation that may be granted by the competent
authority in respect of the application.
It is the recommendation of the environmental consultant that the development of the CHP
Plant be authorised, constructed and operated due to the positive impacts associated with
the development, as well as the negligible negative impacts arising for the implementation
of the project.
The construction and operation of the CHP Plant should be implemented according to the
specifications of the EMPr to ensure mitigation and management of potential impacts
associated with construction and operation activities. The activities should be monitored
against the approved EMPr, the Environmental Authorisation (once issued) and all other
relevant environmental legislation. Relevant conditions to be adhered to include:
» An Environmental Control Officer (ECO) should monitor compliance during construction.
» Stormwater runoff must be managed to control pollution and/or erosion within and
outside of the Neopak Facility boundaries.
» Register the plant with the Air Emissions Licensing Authority and/or the Local Municipality
and comply with relevant reporting requirements.
» All hazardous materials should be stored in the appropriate manner to prevent
contamination. Any accidental spills that occur at the site should be cleaned up in the
appropriate manner as related to the nature of the spill.
NEOPAK CHP PLANT, ROSSLYN, GAUTENGBasic Assessment Report February 2017
SECTION F: APPENDICES Page 61
SECTION F: APPENDICES
The following appendices must be attached:
Appendix A: A3 Maps
Appendix A1: Locality Map
Appendix A2: Layout Map
Appendix A3: Sensitivity Map
Appendix A4: Sensitivity Map of the broader area
Appendix B: Site Photographs
Appendix C: Facility Illustration
Appendix D: Specialist(s)
Appendix D1: Atmospheric Impact Report
Appendix E: Public Participation
Appendix E1: Site Notices and Newspaper adverts
Appendix E2: Proof of Stakeholder Correspondence
Appendix E3: Authority Consultation
Appendix E4: I&AP Database
Appendix E5: Comments Received – to be included in the Final BAR
Appendix E6: Comments and Responses Report – to be included in the Final BAR
Appendix F: Impact Assessment
Appendix G: Environmental Management Programme (EMPr)
Appendix A: Layout Map
Appendix B: Grievance Mechanism for Public Complaints and Issues
Appendix C: Project Team CVs
Appendix H: EAP Declaration, Affirmation and CVs
Appendix I: Specialist Declaration
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