FORM NO. BAR10/2019 Page 1 of 86
FORM NO. BAR10/2019
BASIC ASSESSMENT REPORT
THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) AND THE
ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS.
NOVEMBER 2019
Date: 09/07/2020
(For official use only)
Pre-application Reference Number (if applicable):
EIA Application Reference Number: 16/3/3/1/B2/32/1020/20
NEAS Reference Number:
Exemption Reference Number (if applicable):
Date BAR received by Department:
Date BAR received by Directorate:
Date BAR received by Case Officer:
GENERAL PROJECT DESCRIPTION
(This must Include an overview of the project including the Farm name/Portion/Erf number)
Proposed installation of a 70m³ LPG Vessel, Pump, 4 Profill Scales as well as storage of 9- 48kg LPG
cylinders and other gasses on Erf 5875 and Erf 5876, Samuel Walters Street, Worcester Industrial
Zone, Worcester, Western Cape.
Gasfit (Pty) Ltd is an agent of African Oxygen (Pty) Ltd (Afrox). The site is situated adjacent to
Samuel Walters Street, within the Industrial Area of Worcester. The site is owned and operated by
Gasfit management. Currently the site is storing and distributing filled LPG cylinders (of various
sizes) filled by Afrox Epping branch in Cape Town and transported to Worcester by road transport.
Site also distributes other air gases and gas products in limited quantities.
The applicant, Gasfit, has projected that in the near future the growth in LPG sales will result in
volumes that trading in filled cylinders trunked in from Cape Town will:
a) Be unable to sustain the market demand due to the number of cylinders that will have to
be in stock
b) Result in reduced efficiencies due to the large volume of cylinders that need to be
managed, especially return of empty cylinders to send to Cape Town for refilling
c) Increased risks due to the high volumes of cylinders that need to be transported between
Cape Town and Worcester on a daily basis
In order to be able to sustain future projected volumes, Gasfit intends to install a bulk storage tank
on site together with necessary filling equipment so that cylinders can be filled on site in Worcester
rather than trunk filled cylinders from Cape Town.
FORM NO. BAR10/2019 Page 2 of 86
The proposal consists of the installation of a 70m3 LPG bulk storage tank, as well as provision of an
on-site storage area for 9 to 48kg LPG cylinders. In addition to the LPG tank and pump, four
cylinder-filling scales and a new road decant point for LPG tanker off-loading will be installed. In
line with safety requirements, a fire detection and suppression system, including a deluge system
at the road tanker point, will also be installed.
The proposed mode of operation for the new facility is for bulk LPG to be brought to the site via
20-ton (40 m3) road tankers. The LPG will then be decanted into the new on-site bulk storage vessel
from the road tanker, while the road tanker is parked under the deluge (sprinkler) system at the
road decant point. There will be an overfill protection indicator to stop road tanker decanting so
as to prevent overfilling of the vessel. Empty gas cylinders will be brought to the facility on trucks,
where they will be off-loaded for refilling on site. Filling of cylinders from the proposed on-site LPG
vessel will be carried out on the cylinder-filling scales, which will be programmed to determine
residual return gas in the cylinders and calculate the exact amount of gas required for each
cylinder.
Please refer to Appendix A1 for the Locality Map and to Appendix B1 for the proposed
Development Plan.
The development aims to reduce transport costs, reduce health and safety risks and increase LPG
availability in the area, as gas are currently transported on a daily basis from the Epping (Cape
Town) branch to the Worcester branch.
IMPORTANT INFORMATION TO BE READ PRIOR TO COMPLETING THIS BASIC ASSESSMENT REPORT
1. The purpose of this template is to provide a format for the Basic Assessment report as set out in
Appendix 1 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”),
Environmental Impact Assessment (“EIA”) Regulations, 2014 (as amended) in order to ultimately
obtain Environmental Authorisation.
2. The Environmental Impact Assessment (“EIA”) Regulations is defined in terms of Chapter 5 of the
National Environmental Management Act, 19998 (Act No. 107 of 1998) (“NEMA”) hereinafter
referred to as the “NEMA EIA Regulations”.
3. The required information must be typed within the spaces provided in this Basic Assessment Report
(“BAR”). The sizes of the spaces provided are not necessarily indicative of the amount of
information to be provided.
4. All applicable sections of this BAR must be completed.
5. Unless protected by law, all information contained in, and attached to this BAR, will become public
information on receipt by the Competent Authority. If information is not submitted with this BAR
due to such information being protected by law, the applicant and/or Environmental Assessment
Practitioner (“EAP”) must declare such non-disclosure and provide the reasons for believing that
the information is protected.
6. This BAR is current as of November 2019. It is the responsibility of the Applicant/ EAP to ascertain
whether subsequent versions of the BAR have been released by the Department. Visit this
Department’s website at http://www.westerncape.gov.za/eadp to check for the latest version of
this BAR.
7. This BAR is the standard format, which must be used in all instances when preparing a BAR for Basic
Assessment applications for an environmental authorisation in terms of the NEMA EIA Regulations
when the Western Cape Government Department of Environmental Affairs and Development
Planning (“DEAandDP”) is the Competent Authority.
8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this
BAR must be submitted to the Department at the postal address given below or by delivery thereof
to the Registry Office of the Department. Reasonable access to copies of this Report must be
FORM NO. BAR10/2019 Page 3 of 86
provided to the relevant Organs of State for consultation purposes, which may, if so indicated by
the Department, include providing a printed copy to a specific Organ of State.
9. This BAR must be duly dated and originally signed by the Applicant, EAP (if applicable) and
Specialist(s) and must be submitted to the Department at the details provided below.
10. The Department’s latest Circulars pertaining to the “One Environmental Management System”
and the EIA Regulations, any subsequent Circulars, and guidelines must be taken into account
when completing this BAR.
11. Should a water use licence application be required in terms of the National Water Act, 1998 (Act
No. 36 of 1998) (“NWA”), the “One Environmental System” is applicable, specifically in terms of the
synchronisation of the consideration of the application in terms of the NEMA and the NWA. Refer
to this Department’s Circular EADP 0028/2014: One Environmental Management System.
12. Where Section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (“NHRA”) is
triggered, a copy of Heritage Western Cape’s final comment must be attached to the BAR.
13. The Screening Tool developed by the National Department of Environmental Affairs must be used
to generate a screening report. Please use the Screening Tool link
https://screening.environment.gov.za/screeningtool to generate the Screening Tool Report. The
screening tool report must be attached to this BAR.
14. Where this Department is also identified as the Licencing Authority to decide on applications under
the National Environmental Management: Air Quality Act (Act No. 29 of 2004) (‘NEM:AQA”), the
submission of the Report must also be made as follows, for-
Waste Management Licence Applications, this report must also (i.e., another hard copy and
electronic copy) be submitted for the attention of the Department’s Waste Management
Directorate (Tel: 021-483-2728/2705 and Fax: 021-483-4425) at the same postal address as the Cape
Town Office.
Atmospheric Emissions Licence Applications, this report must also be (i.e., another hard copy and
electronic copy) submitted for the attention of the Licensing Authority or this Department’s Air
Quality Management Directorate (Tel: 021 483 2888 and Fax: 021 483 4368) at the same postal
address as the Cape Town Office.
DEPARTMENTAL DETAILS
CAPE TOWN OFFICE: REGION 1 and REGION 2
(Region 1: City of Cape Town, West Coast District)
(Region 2: Cape Winelands District and Overberg District)
GEORGE OFFICE: REGION 3
(Central Karoo District and Garden Route District)
BAR must be sent to the following details:
Western Cape Government
Department of Environmental Affairs and Development
Planning
Attention: Directorate: Development Management
(Region 1 or 2)
Private Bag X 9086
Cape Town,
8000
Registry Office
1st Floor Utilitas Building
1 Dorp Street,
Cape Town
Queries should be directed to the Directorate:
Development Management (Region 1 and 2) at:
Tel: (021) 483-5829
Fax (021) 483-4372
BAR must be sent to the following details:
Western Cape Government
Department of Environmental Affairs and Development
Planning
Attention: Directorate: Development Management
(Region 3)
Private Bag X 6509
George,
6530
Registry Office
4th Floor, York Park Building
93 York Street
George
Queries should be directed to the Directorate:
Development Management (Region 3) at:
Tel: (044) 805-8600
Fax (044) 805 8650
FORM NO. BAR10/2019 Page 4 of 86
MAPS
Provide a location map (see below) as Appendix A1 to this BAR that shows the location of the proposed development
and associated structures and infrastructure on the property.
Locality Map: The scale of the locality map must be at least 1:50 000.
For linear activities or development proposals of more than 25 kilometres, 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;
• road names or numbers of all the major roads as well as the roads that provide access to
the site(s)
• a north arrow;
• a legend; and
• a linear scale.
For ocean based or aquatic activity, the coordinates must be provided within which the activity
is to be undertaken and a map at an appropriate scale clearly indicating the area within which
the activity is to be undertaken.
Where comment from the Western Cape Government: Transport and Public Works is required,
a map illustrating the properties (owned by the Western Cape Government: Transport and
Public Works) that will be affected by the proposed development must be included in the
Report.
Provide a detailed site development plan / site map (see below) as Appendix B1 to this BAR; and if applicable, all
alternative properties and locations.
Site Plan: Detailed site development plan(s) must be prepared for each alternative site or alternative
activity. The site plans must contain or conform to the following:
• The detailed site plan must preferably be at a scale of 1:500 or at an appropriate scale.
The scale must be clearly indicated on the plan, preferably together with a linear scale.
• The property boundaries and numbers of all the properties within 50m of the site must be
indicated on the site plan.
• On land where the property has not been defined, the co-ordinates of the area in which
the proposed activity or development is proposed must be provided.
• The current land use (not F) as well as the land use zoning of each of the adjoining
properties must be clearly indicated on the site plan.
• The position of each component of the proposed activity or development as well as any
other structures on the site must be indicated on the site plan.
• Services, including electricity supply cables (indicate aboveground or underground), water
supply pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads
that will form part of the proposed development must be clearly indicated on the site plan.
• Servitudes and an indication of the purpose of each servitude must be indicated on the
site plan.
• Sensitive environmental elements within 100m of the site must be included on the site plan,
including (but not limited to):
o Watercourses / Rivers / Wetlands
o Flood lines (i.e., 1:100 year, 1:50 year and 1:10 year where applicable);
o Coastal Risk Zones as delineated for the Western Cape by the Department of
Environmental Affairs and Development Planning (“DEAandDP”):
o Ridges;
o Cultural and historical features/landscapes;
o Areas with indigenous vegetation (even if degraded or infested with alien species).
• Whenever the slope of the site exceeds 1:10, a contour map of the site must be submitted.
• North arrow
A map/site plan must also be provided at an appropriate scale, which superimposes the
proposed development and its associated structures and infrastructure on the environmental
sensitivities of the preferred and alternative sites indicating any areas that should be avoided,
including buffer areas.
Site photographs Colour photographs of the site that shows the overall condition of the site and its surroundings
(taken on the site and taken from outside the site) with a description of each photograph. The
vantage points from which the photographs were taken must be indicated on the site plan, or
locality plan as applicable. If available, please also provide a recent aerial photograph.
Photographs must be attached to this BAR as Appendix C. The aerial photograph(s) should be
supplemented with additional photographs of relevant features on the site. Date of
photographs must be included. Please note that the above requirements must be duplicated
for all alternative sites.
Biodiversity
Overlay Map:
A map of the relevant biodiversity information and conditions must be provided as an overlay
map on the property/site plan. The Map must be attached to this BAR as Appendix D.
FORM NO. BAR10/2019 Page 5 of 86
Linear activities
or development
and multiple
properties
GPS co-ordinates must be provided in degrees, minutes and seconds using the Hartebeeshoek
94 WGS84 co-ordinate system.
Where numerous properties/sites are involved (linear activities) you must attach a list of the Farm
Name(s)/Portion(s)/Erf number(s) to this BAR as an Appendix.
For linear activities that are longer than 500m, please provide a map with the co-ordinates taken
every 100m along the route to this BAR as Appendix A3.
ACRONYMS
DAFF: Department of Forestry and Fisheries
DEA: Department of Environmental Affairs
DEAand DP: Department of Environmental Affairs and Development Planning
DHS: Department of Human Settlement
DoA: Department of Agriculture
DoH: Department of Health
DWS: Department of Water and Sanitation
EMPr: Environmental Management Programme
HWC: Heritage Western Cape
NFEPA: National Freshwater Ecosystem Protection Assessment
NSBA: National Spatial Biodiversity Assessment
TOR: Terms of Reference
WCBSP: Western Cape Biodiversity Spatial Plan
WCG: Western Cape Government
ATTACHMENTS
Note: The Appendices must be attached to the BAR as per the list below. Please use a (tick) or a x (cross) to
indicate whether the Appendix is attached to the BAR.
The following checklist of attachments must be completed.
APPENDIX (Tick) or
x (cross)
Appendix A:
Maps
Appendix A1: Locality Map
Appendix A2:
Coastal Risk Zones as delineated in terms of
ICMA for the Western Cape by the Department
of Environmental Affairs and Development
Planning
x
Appendix A3: Map with the GPS co-ordinates for linear
activities x
Appendix B:
Appendix B1: Site development plan(s)
Appendix B2
A map of appropriate scale, which
superimposes the proposed development and
its associated structures and infrastructure on
the environmental sensitivities of the preferred
site, indicating any areas that should be
avoided, including buffer areas;
x
Appendix C: Photographs
Appendix D:
Biodiversity overlay map
Appendix D1: CBA, ESA Map
Appendix D2: National Freshwater Ecosystem Priority Areas Map
Appendix E: Permit(s) / license(s) / exemption notice, agreements, comments from State
Department/Organs of state and service letters from the municipality.
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Appendix E1: Final comment/ROD from HWC x
Appendix E2: Copy of comment from Cape Nature x
Appendix E3: Final Comment from the DWS x
Appendix E4: Comment from the DEA: Oceans and Coast x
Appendix E5: Comment from the DAFF x
Appendix E6: Comment from WCG: Transport and Public
Works x
Appendix E7: Comment from WCG: DoA x
Appendix E8: Comment from WCG: DHS x
Appendix E9: Comment from WCG: DoH x
Appendix E10: Comment from DEA&DP: Pollution
Management x
Appendix E11: Comment from DEA&DP: Waste Management x
Appendix E12: Comment from DEA&DP: Biodiversity x
Appendix E13: Comment from DEA&DP: Air Quality x
Appendix E14: Comment from DEA&DP : Coastal Management x
Appendix E15: Comment from the local authority x
Appendix E16: Confirmation of all services (water, electricity,
sewage, solid waste management) x
Appendix E17: Comment from the District Municipality x
Appendix E18: Copy of an exemption notice x
Appendix E19 Pre-approval for the reclamation of land x
Appendix E20: Proof of agreement/TOR of the specialist studies
conducted. x
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Appendix E21:
Proof of land use rights
Zoning Map
Appendix E22: Proof of public participation agreement for
linear activities x
Appendix F:
F1: Approved Public Participation Plan and Confirmation Letter.
F2: Register of I&APs
F3: Site Notice
F4: Newspaper Advert
F5: Notification Letter to I&APs
Appendix G:
Specialist Report(s)
G1: Major Hazard Installation Risk Assessment
G2: Freshwater Specialist Statement
Appendix H: EMPr
Appendix I: I1: Screening tool report
I2: Site Verification and Compliance Statement Reports
Appendix J: The impact and risk assessment for each alternative x
Appendix K:
Need and desirability for the proposed activity or development in
terms of this Department’s guideline on Need and Desirability (March
2013)/DEA Integrated Environmental Management Guideline x
Appendix L: Additional Information: Emergency Procedures, Contingency and
Fire Plans
Appendix M: CV of Chantel Muller
FORM NO. BAR10/2019 Page 8 of 86
SECTION A: ADMINISTRATIVE DETAILS
Highlight the Departmental
Region in which the
intended application will fall
CAPE TOWN OFFICE: GEORGE OFFICE:
REGION 1
(City of Cape Town,
West Coast District
REGION 2
(Cape Winelands District
and
Overberg District)
REGION 3
(Central Karoo District and
Garden Route District)
Duplicate this section
where there is more than
one Proponent
Name of
Applicant/Proponent:
Gasfit (Pty) Ltd
Name of contact person
for Applicant/Proponent (if
other): Willem van Rooyen / Satish Bhugwathypersad
Company/ Trading
name/State
Department/Organ of
State:
Gasfit (Pty) Ltd
Company Registration
Number: 2016/376592/07
Postal address: 77 Tulbagh Road Worcester Postal code: 6850
Telephone: (023) 342 2474 / ( 011 ) 876 1285 Cell: 083 398 6368 / 082 573
1492
E-mail: [email protected]/
[email protected] Fax: ( 023 ) 342 8721
Company of EAP: Sillito Environmental Consulting
EAP name: Secondary EAP and Author of Report: Eugene Marais
Lead EAP/ Project Manager and Report Reviewer: Chantel Müller
Postal address: PO Box 30134, Tokai Postal code:7966
Telephone: (021) 712 5060 Cell: 072 677 2994
071 313 4193 E-mail: [email protected] Fax: ( )
Qualifications:
Lead EAP: Chantel Müller
M Phil in Environmental Management (2008) BA in Social Dynamics (2004)
Chantel Muller is a registered EAP with EAPSA as well as a member of the
International Association for Impact Assessment (IAIA).
Chantel is also an Accredited Professional with the Green Building Council
of South Africa.
Secondary EAP: Eugene Marais
Bachelor of Science Degree: Conservation Ecology
Master of Science Degree: Zoology
EAPASA registration no:
Duplicate this section
where there is more than
one landowner
Name of landowner:
Willem van Rooyen
Name of contact person
for landowner (if other): Willem van Rooyen
Postal address: 75 Tulbagh Street
Telephone:
E-mail:
Worcester Postal code: 6850
(023) 342 2474 Cell: 083 398 6368
[email protected] Fax: ( )
Name of Person in control
of the land:
Name of contact person
for person in control of the
land:
Same as the above (Willem van Rooyen)
FORM NO. BAR10/2019 Page 9 of 86
Postal address:
Postal code:
Telephone: ( ) Cell:
E-mail: Fax: ( )
Duplicate this section
where there is more than
one Municipal Jurisdiction
Municipality in whose area
of jurisdiction the proposed
activity will fall:
Breede Valley Local Municipality
Contact person: Pieter Hartzenberg Postal address: Private Bag X3046
Worcester Postal code: 6849 Telephone 023 348 8631 Cell: 084 622 2060
E-mail: [email protected] Fax:
EXECUTIVE SUMMARY OF THE BASIC ASSESSMENT REPORT:
Introduction
Gasfit, an agent of Afrox, is planning install a bulk LPG storage and filling facility at the existing gas
storage depot, which is situated on Erf 5875 and 5876, Samuel Walters Road, Worcester, Western
Cape. Gasfit purchased the new storage site and began trading in filled cylinders at the site mid-
2019. Currently Gasfit transports filled cylinders from Afrox Epping branch (Cape Town) on a daily
basis to Worcester. The daily transporting of LPG is already a health and safety risk to the Gasfit staff,
as well as to members of the public, due to the risks associated with road transportation.
Market projections indicate an increase in LPG demand in the near future (due to increased
loadshedding by Eskom, convenience of using gas), trading in cylinders filled in Cape Town and
transported to site daily will add unnecessary inefficiencies, operating costs and increase safety risks
due to the increased volume of cylinders that need to managed to meet the market demand. The
proposed application is to enable cylinder filling on site by installing a 70m3 LPG bulk storage tank
and cylinder filling equipment rather than to transport filled cylinders from Cape Town.
Site description
The Gasfit depot is located within the urban edge of Worcester, adjacent to Samuel Walters Street,
which is located within the Industrial Zone of Worcester. The site is surrounded by industrial type
activities, with the Hex River approximately 400m east of the site. Please refer to the figure below
and Appendix A, which shows the location of the site.
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Figure 1: Locality Map of the proposed development site (Source: Cape Farm Mapper, 2020).
Summary of Proposed Development
Please refer to the Site Layout Plan in Appendix B, and Figure 2 below.
In summary, the following is proposed:
a. 70m3 insulated LPG vessel
b. Cylinder filling pump: Corken F522
Max 300l/min
Motor 5.5kW
c. New road decant point for LPG tanker off-loading
d. Four off Profill Bizerba cylinder filling scales
e. Fire detection and suppression system (FDandS) consisting of following:
▪ Air/nitrogen supply from cylinders
▪ FDandS panel
▪ FDandS manifold
▪ 8mm SCAD tubing
▪ Deluge system at road decant point
Site Location
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The development footprint of the proposed Gasfit gas depot is approximately 882m2.
As shown in the site plan below, bulk LPG will to be brought to the site via 20-ton (40 m3) road tankers.
The LPG will then be decanted into the new on-site bulk storage vessel from the road tanker, while
the road tanker is parked under the deluge (sprinkler) system at the road decant point. There will
be an overfill protection indicator to stop road tanker decanting to prevent overfilling of the vessel.
Empty gas cylinders will be brought to the facility on trucks, where they will be off-loaded for refilling
on site. Filling of cylinders from the proposed on-site LPG vessel will be carried out on the cylinder-
filling scales, which will be programmed to determine residual return gas in the cylinders and
calculate the exact amount of gas required for each cylinder.
The site will be adequately serviced with stormwater management infrastructure; a connection to
the municipal sewerage system; and with municipal water and electricity supply to the small office
block proposed.
Entrance to the site is proposed from the existing site entrance gate situated on Samuel Walters
Street, which runs along the eastern boundary of Erf 5875 and 5876.
Figure 2: Site Layout Plan (full A3 Site Plan included in Appendix B of this report)
FORM NO. BAR10/2019 Page 12 of 86
Legislative Context
The proposed expansion of the existing diesel gas depot triggers the following activity, which is listed
in terms of 2014 EIA Regulations, as amended, published under the National Environmental
Management Act, Act No. 107 of 1998 (NEMA), and therefore requires an application for
Environmental Authorisation:
Activity No(s): Provide the relevant Basic Assessment Activity(ies)
as set out in Listing Notice 1
Describe the portion of the
proposed development to which
the applicable listed activity relates.
Activity 67 Phased activities for all activities-
i. listed in this Notice, which commenced
on or after the effective date of this
Notice; or
ii. similarly listed in any of the previous
NEMA notices, which commenced on or
after the effective date of such previous
NEMA Notices;
where any phase of the activity may be
below a threshold but where a
combination of the phases, including
expansions or extensions, will exceed a
specified threshold;
The proposed development
does not entail the increase
of gas storage capacity by
more than 80m3 but the total
combined capacity on site
will exceed the 80m3
threshold with the addition of
one 70m3 LPG storage tank.
As such, Activity 67 is
triggered and not Activity 51.
Planning Context
Erf 5875 and 5876 are currently zoned for industrial use in the Breede Valley Spatial Development
Framework Revision 2019-2020 (please see Appendix C) and is situated in the Worcester industrial
area. It is therefore concluded that no rezoning is required, and the proposed expansion is in line
with the intended use of the site for industrial purposes.
Major Hazard Installation Risk Assessment
An independent assessment of the Major Hazard Installation (MHI) risks was conducted at the Gasfit
storage Depot in Worcester by Nature and Business Alliance Africa (Pty) Ltd (please see Appendix
G1). In summary, the main findings of the MHI Risk Assessment are listed below.
• The Occupational Health and Safety Act (Act 85 of 1993) defines a major hazard installation
as “an installation-
▪ where more than the prescribed quantity of any substance is or may be kept,
whether permanently or temporarily; or
▪ where any substance is produced, used, handled or stored in such a form
and quantity that it has the potential to cause a major incident”.
• It was concluded in the MHI Risk Assessment that the Afrox facility and the LPG road tanker
are classified as a major hazard installation.
• The hazardous events identified by the MHI Risk Assessment that could occur at the facility
could be:
(a)An uncontrolled leak of LPG from the bulk storage tank.
(b)An uncontrolled leak of LPG from the delivery road tanker.
(c)An uncontrolled release of LPG from a cylinder at the filling platform
(d)An uncontrolled release of propane from a cylinder.
FORM NO. BAR10/2019 Page 13 of 86
(e)An uncontrolled release of acetylene from a cylinder.
(f)An uncontrolled release of ammonia from a cylinder.
(g)An uncontrolled release of Sulphur dioxide from a cylinder.
• As a result of the hazardous events, the identified potential major incidents were:
o Vapour cloud explosion
o Jet fire
o Toxic cloud
o BLEVE on bulk storage tank
o BLEVE on cylinder
o Toxic cloud
• The most critical effect that a major incident at the facility could have is a sulphur dioxide
toxic cloud or the release of LPG scenario.
• The risk profile of the facility is within the tolerable norm for public risk (1.00E-4) as well as the
norm for tolerable worker risk (1.00E-3) as recommended by the UK Health and Safety
Executive (HSE).
• Various mitigation measures have been recommended to be implemented to reduce the
risk. They have all been included in the EMPR.
The MHI Risk Assessment concluded the following:
• Residences are located 610 meters from the site and the occupants will be exposed to a
toxic sulphur dioxide gas cloud under low wind speed conditions, in case of a full release of
one cylinder.
• The level of risk posed by the facility to various populations immediately outside the site,
closest residences, vulnerable developments is highest for sulphur dioxide and LPG.
• The risks associated with the hazardous facilities on site can be tolerable provided the
recommended mitigation measures (ALARP) are implemented.
• The facility is classified as a major hazard installation, because a major incident at the site
will impact on members of the public outside the boundaries of the site.
• The LPG road tankers on site are classified as major hazard installations because a major
incident at the road tanker will impact on members of the public outside the boundary of
then site.
It was confirmed during discussions with the author of the MHI Risk Assessment, Dr Niemand, that
even if the adjacent erf is developed in the future, the health and safety risk is expected to be a
low risk because risk is a measure of the likelihood of an event and the consequence of an event.
With the proposed mitigation measures implemented, the likelihood of an event occurring is
exponentially low, resulting in the level of risk expected to be low. Dr. Niemand advised during the
discussions and in the MHI Risk Assessment that amongst other mitigation measures listed in the MHI
Assessment, key mitigation measures to reduce risk of impact to humans on the adjacent (currently
vacant) site would be the following:
• A safe separation distance of 236 meters from a BLEVE on the LPG storage tank should be
taken into consideration when planning for potential future development.
FORM NO. BAR10/2019 Page 14 of 86
Figure 3: Major Hazard Installation Risks associated with the proposed development (source: MHI, 2020).
Public Participation
A key component of the Basic Assessment process is public participation. Public participation allows
identified Interested and Affected Parties (I&AP’s) to assist in identifying issues or concerns around
the activity which may need further investigation or assessment.
The Draft Basic Assessment Report will be available for a 30 days public and Authority consultation
phase. The following means of notification of the availability of the Draft BAR will be provided:
• A newspaper advertisement will be published in the local newspaper.
• A Site Notice will be placed at the entrance to the existing site.
• A notification poster will be placed at the local café adjacent to the site.
• Additional arrangements will be made with the Adjacent Landowners and Occupiers to
ensure they receive a notification letter (See PPP Plan Appendix F1).
• An executive summary will be uploaded to SEC website as a data saving alternative.
• Electronic copies of the Draft BAR Report and EMP will be couriered to Key Commenting
Authorities
• A Notification email will be sent to all the I &APs to inform them about the availability of the
Draft BAR.
• The Draft BAR will be uploaded to SEC website.
• A reminder notification email will be sent to remind potential I&AP’s and Key Authorities to
comment.
Alternative Investigations
The NEMA EIA Regulations, 2014, as amended, require that an Applicant identify and investigate
alternative “means of meeting the general purposes and requirements of the activity” for which
authorisation is being applied for.
Site Alternatives:
FORM NO. BAR10/2019 Page 15 of 86
No site alternatives have been investigated as the proposed site for the expansion is an existing gas
depot with sufficient resources and space available for the proposed installation of a 70m3 LPG bulk
storage tank and associated infrastructure. The site is already zoned for industrial use. It is therefore
not reasonable to identify or assess site alternatives as this is an expansion activity not a new activity.
Activity/Technology Alternative:
No activity or Technology alternative exists, LPG can only be stored in carbon steel pressure vessels.
The only alternative would be to install two smaller LPG vessels, it would however increase installation
costs and increase the maintenance requirements. The installation of two smaller vessels will pose
no advantage to Afrox than rather installing one large LPG vessel.
No-Go Alternative:
The No-Go option will mean that Afrox will need to continue with their current daily operations of
transporting various gases from their Epping (Cape Town) branch to Worcester, which poses a much
greater health and safety risk than the installation of the bulk storage tank. Afrox actual gas
volumes, and predicted gas volumes show that during 2020 volume growth is expected to be ±750
tonnes, a 46% increase from 2019, with a possible 54% demand increase for 2021. The gas demand
has led to Afrox transporting gas on a daily basis from their Epping Branch (Cape Town), this
alternative is unfeasible, and increases the risk of staff or the public getting hurt due to an accident.
The preferred alternative, to install a bulk LPG storage tank is therefore needed and desired as it will
reduce the safety risks and will increase Afrox/Gasfit profits. No-Go alternative would result in the
existing facility being unable to provide for the projected future gas demand in the area and
therefore the expansion is needed to meet the demand.
Identification and Assessment of Impacts
The proposed upgrade entails the construction and operation of one 70m3 LPG bulk storage tank,
storage of 9 to 48kg gas vessels and associated infrastructure. The potentially significant impacts
identified as being associated with the depot are as follows:
Construction phase:
• Soil and Groundwater Contamination and Pollution: Fuel, oil, lubricants and other pollutants
may leak from vehicles/ machinery and contaminate the soil. Pollution and soil
contamination could also occur from chemical toilets, cement mixing directly on the soil
and stormwater runoff may flow over the site camp area and carry contaminants off-site.
• Fire, Health and Safety Risk: Exposure through breathing in vapors, swallowing hazardous
substances or skin contact may have possible health effects. There is a minor risk of a gas
cylinder release, as other gas cylinders will be stored on site during the construction phase.
• Dust and Noise Impacts: As a result of the construction phase of this development noise and
dust impacts are expected to occur in the area due to an increase in construction vehicles
and road tankers for the duration of the construction phase while materials are being
transported to the site and excavations are being made.
• Traffic, Safety and Access Impacts: As a result of the construction phase of this development
traffic impacts are expected to occur in the area due to an increase in construction vehicle
FORM NO. BAR10/2019 Page 16 of 86
and truck traffic in the area for the duration of the construction phase while materials are
being transported to the site. Road safety impacts and road condition impacts could also
occur.
• Visual Impacts: The construction phase is associated with temporary disturbance as a result
of construction (trench excavations, vehicles, machinery, fencing and signage) that may
have a negative visual impact on the public.
• Socio-economic – Creation of employment opportunities: Temporary employment
opportunities will be provided during the construction phase to those residing in the
geographical area.
Operational phase:
• Soil and Groundwater Contamination and Pollution: During the operational phase of the
proposed development soil and groundwater contamination could result due to delivery
and collection vehicles. In addition, if stormwater is not managed correctly there is the
potential for the unmanaged stormwater runoff to impact negatively on the environment,
potentially causing pollution and contamination.
• Traffic and Safety Impacts: Traffic impacts are expected to occur for the duration of the
operational phase of the activity as a result of the additional vehicles making use of the gas
depot. This could lead to safety impact or damage to road infrastructure.
• Fire, Health and Safety Impact: Exposure through breathing in vapors or skin contact may
have possible health effects. The hazardous events identified by the MHI Risk Assessment
that could occur at the facility could be an uncontrolled leak of gas at the depot from a
bulk storage tank or an uncontrolled leak of gas from the delivery road tanker. As a result of
the hazardous events, the identified potential major incidents could be the release of LPG
gas or a Sulphur dioxide gas cloud due to the full release of a gas cylinder.
• Air Quality Impact: Gas vapour emissions may cause an odour nuisance or health impacts
to adjacent residents, staff on site or to users of the gas depot.
• Socio Economic Benefit: Creation of new permanent job opportunities.
• Socio Economic Benefit: Supply of gas to the surrounding towns and communities, and
additional income opportunity for Afrox and Gasfit as they can meet the demand and job
creation.
The EAP has assessed the impacts associated with the gas depot to be as follows, after mitigation:
Table 1: Construction and operational phase impacts associated with the proposed development.
CONSTRUCTION PHASE IMPACTS and BENEFITS
IMPACT IMPACT SIGNIFICANCE AFTER
MITIGATION
Soil and Groundwater Contamination and Pollution Low (-)
Visual Impact Low (-)
Dust and Noise Impact Low (-)
FORM NO. BAR10/2019 Page 17 of 86
Fire, Health and Safety Risk Low - Medium (-)
Traffic, Safety and Access Low (-)
Socio-economic benefit – creation of 20 temporary employment opportunities Low – Medium (+)
OPERATION PHASE IMPACTS
IMPACT IMPACT SIGNIFICANCE AFTER
MITIGATION
Soil and Groundwater Contamination and Pollution Low - Medium (-)
Fire, Health and Safety Risk Low - Medium (-)
Air Quality: Gas Vapour Emissions Low (-)
Traffic and Safety Low (-)
Socio-economic benefit – creation of permanent employment opportunities Low – Medium (+)
Socio-economic benefit – gas supply to community and surrounding towns
and income opportunity for Afrox and Gasfit Medium (+)
The Basic Assessment has determined that none of these associated impacts have been found to
be of an unacceptable level; all of these impacts can either be avoided or minimised to an
acceptable level of risk, provided that the mitigation measures recommended in the EMPr are
followed.
Conclusions and Recommendations by the EAP
The most significant impact of the development proposal is the potential health and safety risk. The
MHI Risk Assessment found that a major incident such as the release of LGP or sulphur dioxide will
impact the surrounding community outside of the site boundaries. However, if the mitigation
measures recommended by the Major Hazard Installation Risk Specialist is implemented, the
likelihood of an event occurring is exponentially low, resulting in the level of risk to be low. It is also
recommended that future developments on the vacant properties adjacent to the site must have
a safe separation distance of 236 meters, in case a BLEVE on the LPG storage tank.
In terms of benefits, the depot upgrade will provide job opportunities to the community during the
construction/installation and operational phases, an income stream for the applicant as well as
additional provision of gas supply services needed in the area by the community.
Given the low-medium significance of the impacts assessed and because of the fact that the
likelihood of an incident occurring is very low, the socio-economic benefit of this project should be
realised and the EAP recommends that this site should be developed with the proposed
development.
The implementation of the design, construction and operational phase measures contained in the
EMPr in Appendix H, will maximize the benefits and avoid/ minimize any environmental risks
associated with the upgrade. It is in this case of particular importance to manage the health and
safety risk associated with the exposure to hazardous gasses and gas vapours.
There is thus adequate motivation for the Gasfit gas depot upgrade to proceed under the following
recommended conditions of approval:
• The mitigation measures listed in the EMPR must be strictly implemented.
• A fire wall of 3,6 meters will be constructed on the eastern boundary, adjacent to the LPG storage
tank.
FORM NO. BAR10/2019 Page 18 of 86
• The tanks must be installed according to the following SANS:
o All relevant electrical works must be compliant with SANS 10108
All LPG storage and filling installations must comply with SANS 10087-7
o All relevant building works must comply with SANS 10400
o SANS 10087-3 (2008) (English): The handling, storage, distribution and maintenance of
liquefied petroleum gas in domestic, commercial, and industrial installations Part 3: Liquefied
petroleum gas installations involving storage vessels of individual water capacity exceeding
500 L
The following plans and procedures must be produced prior to construction taking place (as per
design phase requirements listed in the EMPR):
o Stormwater Management Plan.
o Spill Contingency Plan.
o Fire Plan.
o Update Emergency Response Plan.
o Update Preventative Maintenance Plans.
• The installation of the Aboveground Storage Tank and associated pipework must comply with the
National Building Regulations and Standards Act No. 103 of 1977.
• The installation must comply with local authority bylaws and all procedures and equipment used
must be in accordance with the Occupational Health and Safety Act (No. 85 of 1993).
• Upon completion of the UST installation, an engineer is to inspect and verify that the tanks and
the associated infrastructure have been installed as per the design criteria described in the final
BAR and to all required SABS / SANS standards and applicable legislation.
The implementation of the design, construction and operational phase measures contained in the
EMPr in Appendix H, will maximize the benefits and minimize any environmental risks associated with
the proposal. Adherence to the EMPr should be made a condition of authorization. There is thus
adequate motivation for the gas depot expansion to proceed.
SECTION B: CONFIRMATION OF SPECIFIC PROJECT DETAILS AS INLCUDED IN THE APPLICATION FORM
1. Is the proposed development (please
tick): New Expansion X
2. Is the proposed site(s) a brownfield of greenfield site? Please explain.
Brownfield site. The site is located in the industrial area of Worcester and contains existing paved
areas and buildings.
3. For Linear activities or developments
3.1. Provide the Farm(s)/Farm Portion(s)/Erf number(s) for all routes:
3.2. Development footprint of the proposed development for all alternatives. m²
3.3.
Provide a description of the proposed development (e.g. for roads the length, width and width of the road reserve
in the case of pipelines indicate the length and diameter) for all alternatives.
3.4. Indicate how access to the proposed routes will be obtained for all alternatives.
3.5.
SG Digit
codes of
the
Farms/Farm
Portions/Erf
numbers
FORM NO. BAR10/2019 Page 19 of 86
for all
alternatives
3.6. Starting point co-ordinates for all alternatives
Latitude (S) º ‘ “
Longitude (E) º ‘ “
Middle point co-ordinates for all alternatives
Latitude (S) º ‘ “
Longitude (E) º ‘ “
End point co-ordinates for all alternatives
Latitude (S) º ‘ “
Longitude (E) º ‘ “
Note: For Linear activities or developments longer than 500m, a map indicating the co-ordinates for every 100m along the
route must be attached to this BAR as Appendix A3.
4. Other developments
4.1. Property size(s) of all proposed site(s): 4276m2
4.2. Developed footprint of the existing facility and associated infrastructure (if applicable): 3118m2
4.3. Development footprint of the proposed development and associated infrastructure size(s) for all
alternatives: 882m2
4.4. Provide a detailed description of the proposed development and its associated infrastructure (This must include
details of e.g. buildings, structures, infrastructure, storage facilities, sewage/effluent treatment and holding facilities).
Gasfit proposes to install a 70m3 LPG storage vessel at their Worcester site. The vessel will be insulated
with passive insulation in compliance with NFPA 58.
Road tanker will be offloaded under a deluge system.
There will be four off Profill Bizerba cylinder filling scales for filling of cylinders from CADAC to 48kg
cylinders.
The following new equipment to be installed:
a. 70m3 insulated LPG vessel
b. Cylinder filling pump: Corken F522
i. Max 300l/min
ii. Motor 5.5kW
c. New road decant point for LPG tanker off-loading
d. Four off Profill Bizerba cylinder filling scales
e. Fire detection and suppression system (FD&S) consisting of following:
▪ Air/nitrogen supply from cylinders
▪ FD&S panel
▪ FD&S manifold
▪ 8mm SCAD tubing
▪ Deluge system at road decant point
EQUIPMENT SPECIFIC
1. 70m3 LPG Vessel
o The vessel is filled to a level of 85%.
o The vessel to hydro-tested (to 22bar) on site once placed in its final position on site.
o The vessel will have level measurement via a Rochester centre mount gauge. There will
be overfill protection indicator to stop road tanker decanting to prevent overfilling of
the vessel.
o The trycock and overfill protection is set at a level of 92% of linear height.
2. Cylinder filling
FORM NO. BAR10/2019 Page 20 of 86
o The bypass on the pump is set at 6 bar differential pressure. This results in a rated
delivery rate of about 300 litre/min on cylinder filling.
o Pump is also interlocked to the FD&S system.
o Pump have local start/stop at pump, but only pump stop at road decant point.
o Scales are programmed to determine residual return gas in cylinders and then
calculate the exact amount of gas for that cylinder size.
3. Road tanker decant point
o A 32mm ACME filling coupling point to be provided at the decant point.
4. Fire detection and suppression system (FD&S)
o Primary air/nitrogen cylinder supplies air/nitrogen to maintain the pressure in the SCAD
tubing detection loop between 450 kPa(g) and 600 kPa(g).
o A back-up cylinder supply kicks in at 450kPa(g) in the event of supply failure from the
primary source. This is a standby facility to maintain operation.
o The detection loop will have 2 zones. One zone covers the cylinder filling dock and the
other the road tanker decant point and storage vessel.
o A break in the fire detection loop will drop the pressure in the respective loop causing all
the actuated valves around the installation to close and shutdown power. The zone
around the road tanker will also cause the deluge system to activate.
o Activation time of the system is reduced using solenoid actuated valves, which activates
to dump any residual air in the detection loop, hence aiding de-pressurisation of the loop.
They are activated once fire alarm is activated at 300kPa(g).
o The fire alarm cut off the power to the various drives and shut down the plant.
TRANSPORT OPERATIONS
o Full gas cylinders (mixed load or only LPG) is brought to site by road on cylinder trucks and
stored on site.
o Cylinder trucks are loaded on site for distribution to customers.
o Trucks will return from customers with empty cylinders. LPG cylinders will be refilled on site.
o Other empty cylinders returned by road to Afrox Epping site for refilling.
Bulk LPG will be brought to site using a 20ton (40m3) road tanker. LPG is decanted into the bulk
storage vessel from the road tanker. Road tanker parks under a sprinkler system.
4.5. Indicate how access to the proposed site(s) will be obtained for all alternatives.
Access will be obtained via the existing access gate off Samuel Walters street.
4.6.
SG Digit code(s) of
the proposed site(s)
for all alternatives: C 0 8 5 0 0 0 4 0 0 0 0 5 8 7 5 0 0 0 0 0
C 0 8 5 0 0 0 4 0 0 0 0 5 8 7 6 0 0 0 0 0
4.7.
Coordinates of the proposed site(s) for all alternatives:
Latitude (S) 33° 38′ 43.38″
Longitude (E) 19° 28′ 31.82″
FORM NO. BAR10/2019 Page 21 of 86
SECTION C: LEGISLATION/POLICIES AND/OR GUIDELINES/PROTOCOLS
1. Exemption applied for in terms of the NEMA and the NEMA EIA Regulations
2. Is the following legislation applicable to the proposed activity or development.
The National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24
of 2008) (“ICMA”). If yes, attach a copy of the comment from the relevant competent authority as
Appendix E4 and the pre-approval for the reclamation of land as Appendix E19.
YES NO
The National Heritage Resources Act, 1999 (Act No. 25 of 1999) (“NHRA”). If yes, attach a copy of
the comment from Heritage Western Cape as Appendix E1.
YES NO
The National Water Act, 1998 (Act No. 36 of 1998) (“NWA”). If yes, attach a copy of the comment
from the DWS as Appendix E3.
YES NO
The National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (“NEM:AQA”). If yes, attach a copy of the comment from the relevant authorities as Appendix E13.
YES NO
The National Environmental Management Waste Act (Act No. 59 of 2008) (“NEM:WA”) YES NO
The National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004 (“NEMBA”). YES NO
The National Environmental Management: Protected Areas Act, 2003 (Act No. 57 of 2003)
(“NEMPAA”).
YES NO
The Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983). If yes, attach comment
from the relevant competent authority as Appendix E5.
YES NO
3. Other legislation
List any other legislation that is applicable to the proposed activity or development.
Spatial Planning Land Use Management Act 16 of 2013
Mineral and Petroleum Resources Act 49 of 2008
National Energy Regulator Act 40 of 2004
The national Environmental Management Act, Act 107 of 1998, as amended.
o The expansion of the gas storage depot will take place according to the conditions set out in
the NEMA, whereby environmental authorization is required for the expansion of facilities for the
storage and handling of a dangerous good, where such activity is a phased development
where any phase of the activity may be below a threshold but where a combination of the
phases, including expansions or extensions, will exceed a specified threshold.
Occupational Health and Safety Act 85 of 1993
o The Occupational Health and Safety Act (Act 85 of 1993) defines a major hazard installation as
“an installation-
a. where more than the prescribed quantity of any substance is or may be kept,
whether permanently or temporarily; or
b. where any substance is produced, used, handled or stored in such a form and
quantity that it has the potential to cause a major incident”.
The proposed expansion could potentially impact on people outside of the boundary of the site
and is therefore defined as a major hazard installation.
Major Hazardous Installation Regulations issued in Terms of Occupational Health and Safety.
Nature and Business Alliance Africa (Pty) Ltd conducted an MHI Risk Assessment in line with the MHI
Regulations. The site has been registered by Nature and Business Alliance Africa (Pty) Ltd with the
municipality as an MHI installation.
Has exemption been applied for in terms of the NEMA and the NEMA EIA Regulations. If yes, include
a copy of the exemption notice in Appendix E18. YES NO
FORM NO. BAR10/2019 Page 22 of 86
Disaster Management Act, 57 of 2002
This Act defines “disaster” and “disaster management”. Chapter 5 outlines the requirements for
Municipal disaster management. When a disastrous event occurs or is threatening to occur in the
area of a municipality, the disaster management centre of the municipality concerned must
determine whether the event should be regarded as a disaster in terms of this Act, and if so, must
immediately-
a. initiate efforts to assess the magnitude and severity or potential magnitude and
b. inform the National Centre and the relevant provincial disaster management centre of the
disaster and its initial assessment of the magnitude and severity or potential magnitude and
severity of the disaster;
c. alert disaster management role-players in the municipal area that may be of assistance.
d. initiate the implementation of any contingency plans and emergency procedures;
Breede valley Municipality Fire Safety By-law
This by law outlines various requirements for a fire-safe environment on site and has been taken into
account in the design of the site, the EMPR Requirements and the MHI Assessment.
Fire Brigade Services Act,99 of 1987
This Act provide for the establishment, maintenance, employment, co-ordination and
standardization of fire brigade services; and for matters connected therewith and provides for the
establishment of the Chief Fire Officer in the municipality.
4. Policies
Explain which policies were considered and how the proposed activity or development complies and responds to these
policies.
Western Cape Spatial Development Framework (PSDF), 2009
The principles governing development in the Western Cape, which are contained in the PSDF,
were referred to in the investigation of the Need and Desirability of the expansion of the gas
storage depot.
Integrated Development Plan and Spatial Development Framework of the Breede Valley
Municipality 2019-2020
The policy was used to assess whether the proposed development aligns the IDP and SDF of the
Breede Valley Municipality.
DEA Integrated Environmental Management Guidelines Series, Guideline 5: Assessment of
Alternatives and Impacts in support of the Environmental Impact Assessment Regulations.
These guidelines were used to guide the EAP in decision making and assessment regarding
development alternatives and the associated impacts.
Western Cape Noise Regulations (2013)
The proposed development will comply with these Regulations, gas storage and delivery are not
a noise producing activity.
5. Guidelines
List the guidelines which have been considered relevant to the proposed activity or development and explain how they
have influenced the development proposal.
DEA&DP EIA Guideline Information Document
on Need and Desirability, March 2013
These guidelines were used to guide the EAP
to ensure all the requirements with regards to
FORM NO. BAR10/2019 Page 23 of 86
DEA&DP EIA Guideline Information Document
on Alternatives, March 2013
the consideration of alternatives, public
participation and procedures to assess the
need and desirability were assessed and
inquired. These guidelines were considered
during the BAR and preparation of this report.
DEA&DP EIA Guideline Information Document
on Public Participation, March 2013
DEA&DP EIA Guideline Information Document
on Environmental Management Plans, July
2005
DEA&DP Guideline for Determining the Scope
of Specialist Involvement, June 2005
6. Protocols
Explain how the proposed activity or development complies with the requirements of the protocols referred to in the NOI
and/or application form
The following screening protocols were identified from the screening report:
1. Agricultural Theme
2. Terrestrial Biodiversity Theme
3. Aquatic Biodiversity Theme
4. Noise Impacts
The site is complete transformed and located within an industrial area, the only protocol where
specialist input was provided, was for the aquatic features located more than 300m east of the
site. Please see Appendix I2, the site sensitivity verification report, which summarises the
applicability of the protocols, and the sensitivity verification.
The sensitivities that were identified in the screening tool were as follows:
Theme Very High
Sensitivity
High Sensitivity Medium
Sensitivity
Low Sensitivity
Agricultural Theme X
Animal Species
Theme
X
Aquatic Biodiversity
Theme
X
Archaeological and
Cultural Heritage
Theme
X
Civil Aviation Theme X
Plant Species Theme X
Defence Theme X
Terrestrial Biodiversity
Theme
X
The table above indicates the potential sensitivity ratings from the screening report (Appendix I).
Site verification was carried out to confirm the sensitivity of the plant species and animal species,
as required by the report.
Site Verification
A site visit was carried out to verify whether the sensitivities as recorded in the Screening Report
(Appendix I) are correct. The purpose of the site visit was to determine whether the on-site
condition/characteristics are in line with the findings from the screening report.
As required by the Screening Tool’s General Requirements for undertaking an initial site
verification where no specific assessment protocol has been identified (GNR 648, 10 May 2019).
As per the regulation, the first step in the site verification process is the analysis of satellite imagery.
The following image of the site was taken on 28 January 2020, the Google Earth imagery shows
that the site is completely transformed and located within an area surrounded by other industrial
businesses.
FORM NO. BAR10/2019 Page 24 of 86
Figure 4: Locality Map of proposed development site (Source: Google Earth Pro, 2020).
In terms of the animal sensitivity, none of the species listed in the Screening Tool Report was
recorded on site. The site is completely transformed with no natural vegetation or significant
biodiversity features. The site is already established and operational, therefore no impacts are
expected to terrestrial biodiversity.
The site is located within the Worcester Industrial area; therefore, no significant noise impacts are
expected. Ground truthing was done by a freshwater specialist, as there are several watercourses
adjacent to the development site, to determine potential freshwater impacts resulting from the
proposed development.
SECTION D: APPLICABLE LISTED ACTIVITIES
List the applicable activities in terms of the NEMA EIA Regulations
Activity No(s): Provide the relevant Basic Assessment Activity(ies)
as set out in Listing Notice 1
Describe the portion of the proposed
development to which the applicable listed
activity relates.
Activity 67 Phased activities for all activities-
i. listed in this Notice, which commenced
on or after the effective date of this
Notice; or
ii. similarly listed in any of the previous
NEMA notices, which commenced on or
after the effective date of such previous
NEMA Notices;
where any phase of the activity may be
below a threshold but where a
combination of the phases, including
expansions or extensions, will exceed a
specified threshold;
The proposed development does not
entail the increase of gas storage
capacity by more than 80m3 but the
total combined capacity on site will
exceed the 80m3 threshold with the
addition of one 70m3 LPG storage tank.
As such, Activity 67 is triggered and not
Activity 51.
Activity No(s): Provide the relevant Basic Assessment Activity(ies)
as set out in Listing Notice 3
Describe the portion of the proposed
development to which the applicable listed
activity relates.
N/A
FORM NO. BAR10/2019 Page 25 of 86
Note:
• The listed activities specified above must reconcile with activities applied for in the application form. The onus is on the
Applicant to ensure that all applicable listed activities are included in the application. If a specific listed activity is not included
in an Environmental Authorisation, a new application for Environmental Authorisation will have to be submitted.
• Where additional listed activities have been identified, that have not been included in the application form, and amended
application form must be submitted to the competent authority.
List the applicable waste management listed activities in terms of the NEM:WA
Activity No(s): Provide the relevant Basic Assessment Activity(ies)
as set out in Category A
Describe the portion of the proposed
development to which the applicable listed
activity relates.
N/A
List the applicable listed activities in terms of the NEM:AQA
Activity No(s):
Provide the relevant Listed Activity(ies)
Describe the portion of the proposed
development to which the applicable listed
activity relates.
N/A
SECTION E: PLANNING CONTEXT AND NEED AND DESIRABILITY
1. Provide a description of the preferred alternative.
The development proposal is for the installation of one 70m3 LPG storage tank, associated
infrastructure, and the storage of 9-48kg LPG cylinders. The 70m3 cylinder will be installed in an
existing and operational gas storage depot, therefore no layout or site alternatives have been
investigated.
The preferred development proposal comprises of the installation of a 70m3 LPG storage tank and
its associated infrastructure on Erf 5875 and 5876, which is located within the Worcester Industrial
Area, and zoned as Industrial Zone 1.
There are no sensitive natural or cultural areas in close proximately to the site, the site is not within a
Critical biodiversity Area and is situated approximately 400m from the Hex River and its associated
wetlands, additionally the freshwater specialist concluded that the proposed development will
have no impacts on the adjacent watercourses (Appendix G2). The existing infrastructure at the site
makes the proposed location the most financially feasible alternative for Gasfit as the site is owned
by Gasfit. It is therefore not reasonable or feasible to consider site alternatives.
Therefore, only Erf 5875 and 5876, Samuel Walters Street, Worcester, is the only site assessed in the
EIA Process.
2. Explain how the proposed development is in line with the existing land use rights of the property as you
have indicated in the NOI and application form? Include the proof of the existing land use rights
granted in Appendix E21.
The proposed development entails the installation of a 70m3 LPG storage tank and its associated
infrastructure on Erf 5875 and 5876, located within the Worcester Industrial Area, and zoned as
Industrial Zone 1. The proposed development is an expansion to an already existing and operating
gas storage depot.
3. Explain how potential conflict with respect to existing approvals for the proposed site (as indicated in
the NOI/and or application form) and the proposed development have been resolved.
There are no existing approval conflicts associated with the proposed development.
4. Explain how the proposed development will be in line with the following?
4.1 The Provincial Spatial Development Framework.
Job opportunities as well as additional services will be provided in the community.
FORM NO. BAR10/2019 Page 26 of 86
4.2 The Integrated Development Plan of the local municipality.
The site is within the Worcester urban edge, aligns with the existing land use rights and is zoned for
industrial use in the Breede Valley Spatial Development Framework (Appendix M).
4.3. The Spatial Development Framework of the local municipality.
The site is within the Worcester urban edge, aligns with the existing land use rights and is zoned for
industrial use in the Breede Valley Spatial Development Framework (Appendix M).
4.4. The Environmental Management Framework applicable to the area.
No EMP has been developed for the Worcester area. The site is located within the industrial area of
Worcester, consisting of built up, concrete and paved, surfaces. The site does not fall within any
Critical Biodiversity Areas. The site does however contain patches of Ecological Support Areas,
which would have been mapped prior to the development of the site.
5. Explain how comments from the relevant authorities and/or specialist(s) with respect to biodiversity
have influenced the proposed development.
A pre-application meeting was held with DEAandDP on 12 March 2020, where it was confirmed that
no biodiversity studies will be required, except for the on-site verification of the watercourses by a
Freshwater Specialist. The site is an existing and operating facility, therefore the installation of the
70m3 LPG storage tank, and its associated infrastructure will have minimal biodiversity impacts, and
does not require any other biodiversity specialist input.
6. Explain how the Western Cape Biodiversity Spatial Plan (including the guidelines in the handbook) has
influenced the proposed development.
The WCBSP notes that there are five basic steps to follow when using the BSP Map to determine the
biodiversity context of a proposed lands, and to identify possible impacts to terrestrial and that may
require additional investigation.
Step 1: Desktop Mapping and Information Gathering
Prior to the site visit various biodiversity resources were consulted, by analysing the BSP Map, the
associated land use guidelines and the underlying GPS layers. Information regarding vegetation
types, conservation status, aquatic features etc were included in the preliminary assessment.
Step 2: Verify Desktop Results
A site visit was carried out to verify/ground-truth the results from the desktop analysis. The ESA
mapping indicated that patches of Ecological Support Areas were present within the site, the site
has however been completely transformed and consist of hard paved and concrete surfaces.
Therefore, no further or other impacts to biodiversity are expected at the proposed development
site, due to the current condition of the site.
No further investigation is therefore required with regards to opportunities to conserve biodiversity,
as the site is already completely transformed.
7. Explain how the proposed development is in line with the intention/purpose of the relevant zones as
defined in the ICMA.
N/A 8. Explain whether the screening report has changed from the one submitted together with the
application form. The screening report must be attached as Appendix I.
The screening report has not been submitted previously, the same screening report will be submitted
with the Application form and Draft BAR (attached as Appendix I).
FORM NO. BAR10/2019 Page 27 of 86
9. Explain how the proposed development will optimise vacant land available within an urban area.
The proposed development is consistent with the land uses of the area. The additional storage
capacity will utilise the land use as gas demand is increasing significantly in the Worcester area,
therefore, the installation of additional infrastructure to store gas will benefit the surrounding
community. The increase in trade will also increase regional profit, and specifically the local
economy, compared to no development of the land parcel. The proposed development will
increase land utilisation within the urban area, as Afrox will install the bulk LPG storage tank within
the existing Gasfit depot rather than obtaining a new undeveloped erf.
10. Explain how the proposed development will optimise the use of existing resources and infrastructure.
The site is established and operational, the additional LPG storage capacity will result in increased
gas usage, and in return reduce electricity demand. The additional storage of gas will increase gas
utilisation as gas will be readily available to the community. The increase in gas usage and availably
will contribute to the local economy, as Gasfit has experienced a rapid demand growth from 2017
and predict that demand will increase significantly to 2021. Therefore, by installing additional LPG
storage space, Gasfit will be able to meet LPG demands, and contribute to the local economy/
financial resources in a safer and more feasible manner.
11. Explain whether the necessary services are available and whether the local authority has confirmed
sufficient, spare, unallocated service capacity. (Confirmation of all services must be included in
Appendix E16).
No new or other services are required, as the site is located within the Worcester industrial zone, and
already serviced by the Breede River local municipality.
12. In addition to the above, explain the need and desirability of the proposed activity or development in
terms of this Department’s guideline on Need and Desirability (March 2013) or the DEA’s Integrated
Environmental Management Guideline on Need and Desirability. This may be attached to this BAR as
Appendix K.
The Need and Desirability Guideline of 2013 1 explains that the need and desirability is determined
by considering the broader community’s needs and interests as reflected in a credible IDP, SDF and
EMF for the area, and as determined by the EIA. It is further also highlighted that society in general
should improve the efficiency and responsibility with which we use resources, and improve on the
level of integration of social, economic, ecological and governance systems. The need and
desirability therefore need to illustrate how a development integrates the socio-economic,
ecological and political aspect in a beneficial manner.
The proposed development will entail an expansion of infrastructure (installation of a 70m3 LPG Bulk
storage tank. The site is therefore already established and operational. The site is aligns with the
current land use rights of the area as it is located within the Industrial Zone of Worcester. The site is
zoned as Industrial Zone 1, and therefore does not conflict with the SDF of IDP.
The site is located within the urban edge of Worcester, and primarily consist of hard paved and
concrete surfaces. The site does not fall within any conservation or biodiversity zones. The locality of
the site and the possible impacts to the surrounding communities were assessed in the MHI Risk
Assessment. The assessment suggested that if a major hazardous spill should occur, communities
surrounding the development site would be affected by a toxic gas cloud, the extent of the impact
will be determined by the weather conditions. It is however highly unlikely that a major hazardous
event would occur, furthermore, several mitigation measures will be implemented to reduce the risk
of a major hazardous event occurring.
Therefore, impacts to the surrounding community’s health and wellbeing may be affected by the
proposed development, if a major hazardous event would occur. It is expected that the site will
have limited visual/ aesthetic impacts, noise pollution, fumes and dust, under normal operational
procedures. Mitigation measures described in the BAR and EMPr will be applied to decrease these
impacts to a level where people’s health and wellbeing will not be impacted upon.
FORM NO. BAR10/2019 Page 28 of 86
The development is needed and desired because negative impacts associated with the No-Go
alternative include lack of temporary and permanent job opportunities, the additional profit
opportunity cost lost for Afrox and Gasfit, and the opportunity cost lost to supply gas to the
surrounding towns.
The No-Go option will mean that Afrox will need to continue with their current daily operations of
transporting various gases from their Epping (Cape Town) branch to Worcester, which poses a much
greater health and safety risk than the installation of the bulk storage tank. Afrox actual gas
volumes, and predicted gas volumes show that during 2020 volume growth is expected to be ±750
tonnes, a 46% increase from 2019, with a possible 54% demand increase for 2021. The gas demand
has led to Afrox transporting gas on a daily basis from their Epping Branch (Cape Town), this
alternative is unfeasible, and increases the risk of staff or the public getting hurt due to an accident.
The preferred alternative, to install a bulk LPG storage tank is therefore needed and desired as it will
reduce the safety risks and will increase Afrox and Gasfit profits. No-Go alternative would result in
the existing facility being unable to provide for the projected future gas demand in the area and
therefore the expansion is needed to meet the demand.
SECTION F: PUBLIC PARTICIPATION
The Public Participation Process (“PPP”) must fulfil the requirements as outlined in the NEMA EIA Regulations and must be attached
as Appendix F. Please note that If the NEM: WA and/or the NEM: AQA is applicable to the proposed development, an
advertisement must be placed in at least two newspapers.
1. Exclusively for linear activities: Indicate what PPP was agreed to by the competent authority. Include proof of this agreement
in Appendix E22.
No linear activity is proposed.
2. Confirm that the PPP as indicated in the application form has been complied with. All the PPP must be included in Appendix
F.
The PPP has not commenced yet but will be in accordance with Chapter 6 of the 2014 NEMA EIA
Regulations, as amended. The new Directions issued by DEFF was incorporated into the approved
PPP Plan (Appendix F1). All PPP proof will be attached as Appendix F in the Final BAR.
3. Confirm which of the State Departments and Organs of State indicated in the Notice of Intent/application form were
consulted with.
The following Departments, in addition to DEAD, will be invited to comment on the Draft BAR:
Breede Gouritz Catchment Management Agency Mr. Jan Van Staden
Elkerine Rossouw
Department of Transport and Public Works Grace Swanepoel
DEA and DP: Waste Directorate Thorstern Aab
DEA and DP: Pollution and Chemicals Directorate
Zayed Brown
Gunther Frantz
Cape Nature Phillipa Huntly
DEA and DP: Air Quality Directorate
Joy Leaner
DEA and DP: Development Management Directorate
Region 2
Kobus Munro
FORM NO. BAR10/2019 Page 29 of 86
Cape Winelands District Municipality
Office of the Municipal Manager
Mr H Prins
Cape Winelands District Municipality
Technical Services
F Van Eck
Breede Valley Municipality Ward 8 Councillor MT Williams
Breede Valley Municipality: Technical Services Jaco Steyn
Breede Valley: Environmental Management
4. If any of the State Departments and Organs of State were not consulted, indicate which and why.
Heritage Western Cape will not be consulted with, since the installation of the gas storage tank is
within an existing operational site, and will not affect any items of cultural heritage significance
based on the thresholds specified in terms of Section 38 of the National Heritage Resources Act
(Act 25 of 1999).
5. if any of the State Departments and Organs of State did not respond, indicate which.
All the comments received during the 30-day PPP on the Draft BAR will be summarised and
attached to the Final BAR for Review. A commends and Response Report will be attached to the
Draft BAR as Appendix F.
6. Provide a summary of the issues raised by IandAPs and an indication of the manner in which the issues were incorporated into
the development proposal.
No PPP has been carried out to date. All the comments received during the comment period on
the Draft BAR will be summarised and attached to the Final BAR for review. A Comments and
Response Report will be attached to the Final BAR as Appendix F.
Note:
A register of all the IandAP’s notified, including the Organs of State, and all the registered IandAPs must be included in Appendix
F. The register must be maintained and made available to any person requesting access to the register in writing. The EAP must notify IandAP’s that all information submitted by IandAP’s becomes public information.
Your attention is drawn to Regulation 40 (3) of the NEMA EIA Regulations which states that “Potential or registered interested
and affected parties, including the competent authority, may be provided with an opportunity to comment on reports and
plans contemplated in subregulation (1) prior to submission of an application but must be provided with an opportunity to
comment on such reports once an application has been submitted to the competent authority.”
All the comments received from IandAPs on the pre -application BAR (if applicable and the draft BAR must be recorded,
responded to and included in the Comments and Responses Report and must be included in Appendix F.
FORM NO. BAR10/2019 Page 30 of 86
All information obtained during the PPP (the minutes of any meetings held by the EAP with IandAPs and other role players
wherein the views of the participants are recorded) and must be included in Appendix F.
Please note that proof of the PPP conducted must be included in Appendix F. In terms of the required “proof” the following is
required:
• a site map showing where the site notice was displayed, dated photographs showing the notice displayed on site and
a copy of the text displayed on the notice;
• in terms of the written notices given, a copy of the written notice sent, as well as:
o if registered mail was sent, a list of the registered mail sent (showing the registered mail number, the name of the
person the mail was sent to, the address of the person and the date the registered mail was sent);
o if normal mail was sent, a list of the mail sent (showing the name of the person the mail was sent to, the address
of the person, the date the mail was sent, and the signature of the post office worker or the post office stamp
indicating that the letter was sent);
o if a facsimile was sent, a copy of the facsimile Report;
o if an electronic mail was sent, a copy of the electronic mail sent; and
o if a “mail drop” was done, a signed register of “mail drops” received (showing the name of the person the notice
was handed to, the address of the person, the date, and the signature of the person); and
• a copy of the newspaper advertisement (“newspaper clipping”) that was placed, indicating the name of the
newspaper and date of publication (of such quality that the wording in the advertisement is legible).
SECTION G: DESCRIPTION OF THE RECEIVING ENVIRONMENT
All specialist studies must be attached as Appendix G.
1. Groundwater
1.1. Was a specialist study conducted? YES NO
1.2. Provide the name and or company who conducted the specialist study.
No specialist study was conducted.
1.3. Indicate above which aquifer your proposed development will be located and explain how this has influenced your
proposed development.
FORM NO. BAR10/2019 Page 31 of 86
The following information was sourced from Cape Farm Mapper:
• Aquifer Classification
• Minor
• Aquifer Type and Yield
• Intergranular 0.5-2.0 l/s
• Aquifer Susceptibility
• Medium-high
• Aquifer Vulnerability
• Moderate
• Depth to Groundwater
• 13.27 mbgl
• Groundwater Quality
• 150-370 mS/m
The proposed development is for the installation of a 70m3 above ground LPG storage tank, which
will be installed in an existing and operating gas storage facility. The entire facility consists of hard
concrete and paved surfaces, the storage tank will be located above ground, therefore, no impacts
is expected on the underlying ground water. The storage of gas is associated with air/atmospheric
impacts and not groundwater impacts.
Title Hydrological
Map
Project Title
Project
Number 019097
Legend:
Surface Lithology:
Alluvium (clay,
sand, fravel and
boulders)
Principal
Groundwater
Occurrence (0.5-2.0)
1.4. Indicate the depth of groundwater and explain how the depth of groundwater and type of aquifer (if present) has
influenced your proposed development.
N
Proposed Development
Site
FORM NO. BAR10/2019 Page 32 of 86
The proposed development is located above an intergranular aquifer. The depth of the groundwater
is 13.27 mbgl. The proposed development does not pose any direct impacts to the groundwater
below the site, as there is no below ground storage of gas proposed. Furthermore, the storage of LPG
is associated with atmospheric impacts and not with groundwater contamination impacts. Only
minor impacts to groundwater may occur as a result of hazardous (oils, fuels or lubricants) spills
associated with the delivery and collection vehicles, the entire site is however paved and will have
an on-site clean-up kit for small hazardous spills. Several mitigation measures are listed in the BAR and
EMPr to reduce the risk of groundwater contamination.
2. Surface water
2.1. Was a specialist study conducted? YES NO
2.2. Provide the name and/or company who conducted the specialist study.
Dean Ollis from Inland Waters Consultancy
2.3. Explain how the presence of watercourse(s) and/or wetlands on the property(ies) has influenced your proposed
development.
FORM NO. BAR10/2019 Page 33 of 86
Due to the presence of the Hex River within 500 m of the site and the possible occurrence of wetlands
associated with the river, the need for specialist input from a freshwater ecologist was identified. The
specialist study consisted of a site scan so as to identify and delineate any wetlands (and other
freshwater ecosystems) located within 500 m of the proposed development footprint, and to
determine whether there is any risk of potential impacts on nearby freshwater ecosystems as a result
of the proposed installation.
Identification of wetlands and other watercourses within 500 m of the site
Desktop-based mapping was carried out for the study area, NBA-2018
project indicated a portion of the the Hex River but no wetlands within the 500 m buffer area around
the site. The NFEPA project and the WCBSP, on the other hand, both indicated that there are wetland
features (mostly associated with the Hex River) within the 500 m buffer area around the site.
Figure 5: Watercourses within a 500m buffer of the proposed development site (Source: Freshwater Letter).
Through the interpretation of aerial imagery by Inland Waters Consultancy, a refined desktop based
map of potential wetland areas within 500 m of the site was produced to guide the fieldwork. During
the fieldwork completed by Inland Waters Consultancy, it was confirmed that the main current-day
channel of the Hex River is located approximately 400 m to the south-east of the site. The relevant
reach of the river is located in the Upper Foothill Zone, near the transition to the Lower Foothill Zone
9, and the channel form is anastomising 10. The main characteristics of rivers in the Upper Foothill Zone
are a moderately steep channel (gradient 0.005 to 0.02), with the substratum typically dominated by
cobbles and a narrow floodplain of sand, gravel or cobble often present. Two secondary flood
channels associated with the Hex River, both of which also flow through culverts/bridges under the
R60 road to the south of the site, were also confirmed to be present within 500 m of the site.
According to the results of the NBA-2018 assessment for river ecosystems, the type of river ecosystem
represented by the relevant section of the Hex River (i.e. a perennial/seasonal Upper Foothill river in
FORM NO. BAR10/2019 Page 34 of 86
the Western Folded Mountains Ecoregion) was assigned an Ecosystem Threat Status of "Least
Threatened". The NFEPA project identified the wetland area associated with the relevant section of
the Hex River as a Freshwater Ecosystems Priority Area (FEPA). As shown on the map in Figure 6, the
WCBSP, which was undertaken at a finer spatial scale than NFEPA or NBA-2018 (regional vs. national),
rated the relevant section of the Hex River and its associated wetlands as an Aquatic Critical
Biodiversity Area (CBA).
Based on fieldwork observations made by Inland Waters Consultancy during our site visit, it was
concluded that some sections of the secondary channels associated with the Hex River do have
wetland characteristics. In particular, in certain areas, saturated soils were encountered and/or low
chroma soils with feint mottles (indicating seasonal or intermittent saturation) as well as impermeable
(rock or clay-dominated) underlying layers within 50 cm of the ground surface. Most of these areas
consisted of bare ground with no vegetation and, in many cases there was a crusted surface layers
or clods of clayey loam, indicating the presence of standing water that had evaporated by the time
of the site visit.
Outside of the wetland areas associated with the Hex River and/or its secondary channels, no
wetlands or other watercourses were found to be present within 500 m of the site for the proposed
LPG installation. Furthermore, the wetlands and other watercourses confirmed to be present in the
study area are all located more than 200 m from the site.
Although wetlands or other watercourses (as described above) were confirmed to be present within
500 m of the site for the proposed LPG installation, the operation of the new installation will not pose
any risks to these watercourses that are not already present from the current activities in the industrial
area within which the site is located (as explained previously).
In conclusion, this specialist study has verified that, for the proposed LPG gas installation at the existing
Gasfit facility in the Worcester Industrial Zone, no Water Use Authorisation should be required for any
Section 21(c) and (i) "water use" activities in terms of the NWA, and no watercourse-related "listed
activities" will be triggered in terms of the NEMA EIA Regulations. This is because, despite the
identification of wetlands and other watercourses by us within 500 m of the site, none of these
watercourses could be in any way altered by the newly proposed development activities.
3. Coastal Environment
3.1. Was a specialist study conducted? YES NO
3.2. Provide the name and/or company who conducted the specialist study.
N/A
3.3. Explain how the relevant considerations of Section 63 of the ICMA were taken into account and explain how this
influenced your proposed development.
N/A
3.4. Explain how estuary management plans (if applicable) has influenced the proposed development.
N/A
3.5. Explain how the modelled coastal risk zones, the coastal protection zone, littoral active zone and estuarine functional
zones, have influenced the proposed development.
4. Biodiversity
4.1. Were specialist studies conducted? YES NO
4.2. Provide the name and/or company who conducted the specialist studies.
N/A
4.3. Explain which systematic conservation planning and other biodiversity informants such as vegetation maps, NFEPA,
NSBA etc. have been used and how has this influenced your proposed development.
FORM NO. BAR10/2019 Page 35 of 86
Prior to the drafting of the Draft BAR the datasets available on Cape Farm Mapper and Datasets
available on SANBI’s online mapping tools were used to demine the site sensitivity. Components such
as the conservation status, vegetation, water resources and topography were assessed. Accordingly,
it was determined during a site visit that there are no areas on the site that will be negatively impacted
by the proposed development, as the site is completely transformed and developed.
Approximately 400 m east of the site is the Hex River and its associated wetlands, which is classified
as a NFEPA. The freshwater specialist however concluded that the proposed development will have
no impacts on the river or the wetlands due to their distance from the proposed development, and
the current condition of the watercourses.
4.4. Explain how the objectives and management guidelines of the Biodiversity Spatial Plan have been used and how has
this influenced your proposed development.
As per the Western Cape Biodiversity Spatial Plan (WCBSP) the management guideline determines
the ecological state or condition in which a parcel of land or freshwater feature should be
maintained. The management objectives are determined for a range of variety of land uses i.e.
Protected Areas, Critical Biodiversity Areas as well as Ecological Support Areas. From the image
below, there are several Ecological Support Areas located within the development site, the site has
however been completely transformed and consist of concrete surfaces. The site is therefore not
identified as a priority area, as no biodiversity targets can be identified/ achieved for the proposed
development site, as the site is already developed and operational.
:
Figure 6: Environmental sensitivity map (Soure: Cape Farm Mapper, 2020).
4.5. Explain what impact the proposed development will have on the site specific features and/or function of the
Biodiversity Spatial Plan category and how has this influenced the proposed development.
FORM NO. BAR10/2019 Page 36 of 86
The WCBSP states that these sites should maintain functional, near natural state, with some habitat
loss as acceptable, provided that the underlying biodiversity objectives and ecological functioning
are not compromised.
No biodiversity targets can be identified for the proposed development site, as the site is already
existing and operational.
4.6. If your proposed development is located in a protected area, explain how the proposed development is in line with
the protected area management plan.
N/A
4.7. Explain how the presence of fauna on and adjacent to the proposed development has influenced your proposed
development.
The proposed development site is located within the Industrial Zone of Worcester, with other buildings
and developments to the north, east and west of the site. The southern wall of the site borders a
servitude road with some natural areas, the fauna of the adjacent area is however unknown. No
fauna was noted on site during the site visit.
5. Geographical Aspects
Explain whether any geographical aspects will be affected and how has this influenced the proposed activity or development.
No geographical aspects will be affected by the proposed development. The development proposal
entails the installation of a 70m3 LPG storage tank and its associated infrastructure, within the industrial
area of Worcester, on a site which is already established and operational as a gas depot.
6. Heritage Resources
6.1. Was a specialist study conducted? YES NO
6.2. Provide the name and/or company who conducted the specialist study.
N/A
6.3. Explain how areas that contain sensitive heritage resources have influenced the proposed development.
A Basic Assessment EIA Process is required in terms of NEMA because Activity 67 of the EIA
Regulations is triggered. None of the categories set out in Section 38(1) of the NHRA are
triggered. The development proposal is for the installation of a 70m3 LPG Tank as well as the
storage of 9-48kg gas cylinders on site. The facility is already established as a gas storage
facility within an industrial area. No heritage approval or comment is required as section 38 is
not triggered.
7. Historical and Cultural Aspects
Explain whether there are any culturally or historically significant elements as defined in Section 2 of the NHRA that will be
affected and how has this influenced the proposed development.
No cultural and heritage aspects will be impacted upon.
8. Socio/Economic Aspects
8.1. Describe the existing social and economic characteristics of the community in the vicinity of the proposed site.
FORM NO. BAR10/2019 Page 37 of 86
The proposed development site is located within Ward 8 of Worcester. The Socio-economic
information of the ward was obtained from the Breede Valley Municipality website. The socio-
economic characteristics of the ward is summarised in the table below:
Socio-economic Factor
Population size 8911
Number of households 2328
Predominant race group Coloured (54%)
Predominant language group IsiXhosa (82%)
Individuals younger than 18 years 33%
Formal housing 67%
Informal housing 14%
Access to water 99%
No ablution facilities 1.1%
Refuse removal services 98%
Households with electricity 96%
Households with municipal water 64%
Households with flush toilets 98%
Individuals with no income 19%
Individuals employed 28%
Individuals not economically active 34%
Individuals unemployed 25%
Percentage of population who completed grade 9 and higher 71%
Percentage of population who completed matric 38%
Population with no education 4%
Development Phase
Socio-economic Impacts- Job Opportunities
Operational Phase- Job Opportunities
8.2. Explain the socio-economic value/contribution of the proposed development.
LPG is a green energy source and can be used for cooking and heating. It can be used in times of
load shedding to make/heat food and to generate heat against the cold weather. It can also be
used as an alternative energy source to replace electricity. Therefore, having a positive effect on the
current supply strain on electricity in South Africa.
LPG is also a price-controlled product by the DOE. Therefore, price protects the consumer who
cannot afford or does not have access to electricity or other expensive energy sources.
Installing the bulk tank will have a potential cost saving due to the transport of gas in a bulk tank
versus transporting thousands of cylinders with gas inside (therefore mainly transporting steel). The
potential cost saving will allow for at least another five permanent positions, from historically
disadvantaged backgrounds, at Gasfit. This will be cylinder filler positions. In addition, the bulk tank
cost savings could potentially reduce the selling price of LPGas and subsequently benefit the
consumer positively.
The additional volume achieved with bulk storage will assist the continuous supply of LPGas and
therefore allow all consumers to have guaranteed access to energy. This additional capacity will also
assist with the five-kilogram Safety gas cylinder offer to the informal markets. This safety gas initiative
can benefit the consumer since the five-kilogram Safety cylinder can be obtained with a small
refundable deposit. The cylinder will also be maintained by Afrox to allow the consumer safe usage
of the product.
Installing the bulk tank will generate improvements in the lives of individuals and society at large.
8.3. Explain what social initiatives will be implemented by applicant to address the needs of the community and to uplift
the area.
FORM NO. BAR10/2019 Page 38 of 86
The applicant will potentially employ five individuals from historically disadvantaged backgrounds,
employees will also be trained when working at the gas storage depot.
Training will be given on safe handling of cylinders, safe filling of cylinders, forklift drivers’ licence will
be obtained after the necessary training was done, truck tail lift operation and Firefighting training.
First aid training will also be given for selected individuals.
The new staff will receive all PPE for free and in addition receive two sets of trousers and golf shirts,
one pair of safety shoes, jacket, and rain suite in order to work safe and comfortable.
The proposed bulk filling site is positioned relatively close to the Zwelethemba versus any other gas
supplier. This will allow for reasonable access to fill cylinders without having to use transport.
The applicant will employ individuals from historically disadvantaged backgrounds, employees will
also be trained when working at the gas storage depot.
8.4. Explain whether the proposed development will impact on people’s health and well-being (e.g. in terms of noise,
odours, visual character and sense of place etc) and how has this influenced the proposed development.
With regards to the health and well-being of community surrounding the development, no significant
negative impacts are expected. The expected impacts in terms of noise, odours, visual character
and sense of place are briefly explained:
Noise: It is anticipated that the development will not cause a significant increase in noise in the area,
as the development is situated within the industrial area of Worcester.
Odours: Since the development entails the installation of a gas storage tank, there is a possibility that
the neighbouring industrial area could be impacted by the presence of some gas fumes. This will most
likely occur when the storage tank and smaller cylinders are filled-up.
Visual Character and sense of place: The development proposal will have no visual impacts as the
site is located within the industrial zone of Worcester. The tank will be installed within an existing and
operational facility.
The development proposal will ultimately have a positive impact as Afrox currently has to transport
gas daily from their depot in Epping (Cape Town) to Worcester, in order to fulfil gas demands. Many
households use gas as their primary energy source for cooking and heaters, therefore, the additional
storage of LPG gas will increase availability and accessibility of LPG gas to the community.
SECTION H: ALTERNATIVES, METHODOLOGY AND ASSESSMENT OF ALTERNATIVES
1. Details of the alternatives identified and considered
1.1. Property and site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise
positive impacts.
Provide a description of the preferred property and site site alternative.
The preferred property is Erf 5875 and Erf 5876, the site is currently being used as a gas storage depot.
The development proposal is therefore to install a 70m3 bulk LPG storage tank within the existing and
operational Gasfit facility. The site is located within the Industrial zone of Worcester.
Provide a description of any other property and site alternatives investigated.
No alternative sites have been investigated. The proposed site is within an existing operational gas
storage and filling depot and is zoned for industrial use in the Breede Valley Spatial Development
Framework Revision 2019-2020. There are no sensitive natural or cultural areas in close proximately to
the site, the site is not within a Critical biodiversity Area, is situated approximately 400m away from
watercourses and existing infrastructure at the site makes the proposed location the most financially
feasible alternative for Gasfit.
FORM NO. BAR10/2019 Page 39 of 86
Therefore Erf 5875 and 5876, Samuel Walters Street, Worcester, is the only site assessed in the EIA Process.
Provide a motivation for the preferred property and site alternative including the outcome of the site selectin matrix.
Gasfit already owns the property and propose to expand their existing facility. It is therefore not
reasonable or feasible to consider site alternatives.
Provide a full description of the process followed to reach the preferred alternative within the site.
See paragraphs above. Provide a detailed motivation if no property and site alternatives were considered.
No property alternatives were considered as the proposed development only entails the installation of
infrastructure to an existing and operational facility, already owned by Gasfit.
List the positive and negative impacts that the property and site alternatives will have on the environment.
Negative Impacts:
• Noise impacts during the construction and operational phase.
• Odour impacts during operational phase.
• Health and safety impacts during the operational phase.
Positive impact:
• No new land has to be cleared for the development, as the development proposal only entails
the installation of infrastructure in an existing operational site.
• LPG will be more readily available to the community.
• Job creation during construction and operational phases.
• Money into municipal coffers that can be invested into other projects.
1.2. Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive
impacts.
Provide a description of the preferred activity alternative.
Activity alternatives are not appropriate for further investigation within this application. The need that
this development addresses is that of additional LPG storage infrastructure, no other activity would
meet this need.
The only alternative would be to install two smaller LPG vessels.
Provide a description of any other activity alternatives investigated.
N/A Provide a motivation for the preferred activity alternative.
N/A Provide a detailed motivation if no activity alternatives exist.
Activity alternatives are not appropriate for further investigation within this application. The need that
this development addresses is that of additional LPG storage infrastructure, no other activity would
meet this need.
The only alternative would be for Afrox to install two smaller LPG storage vessels, this will however not
be feasible to Gasfit, as two tanks will increase installation and maintenance costs. This will increase
operational costs and ultimately erode cost saving to the consumer.
List the positive and negative impacts that the activity alternatives will have on the environment.
N/A 1.3. Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise
positive impacts
Provide a description of the preferred design or layout alternative.
FORM NO. BAR10/2019 Page 40 of 86
The proposed development site is an existing and operational site, therefore limited space is available
to install the additional LPG bulk storage tank. The storage tank could therefore only be installed at the
current position (see figure x) to ensure compliance with SANS-10087 safety distances, as well as
allowing easy access via Samuel Walters Street.
Figure 7: Proposed development layout at the Gasfit Depot, Worcester.
Provide a description of any other design or layout alternatives investigated.
No other design or layout alternatives were considered, as no other feasible design alternative exist. Provide a motivation for the preferred design or layout alternative.
The current design and layout alternative are the only feasible option available for the positioning of
the storage tank to be in compliance with SANS-10087 safety distances. The proposed layout
alternative allows for the site to be easily accessible to delivery and collection vehicles, as the site is
located next to Samuel Walters Street.
Provide a detailed motivation if no design or layout alternatives exist.
The current design and layout alternative are the only feasible option available for the positioning of
the storage tank to be in compliance with SANS-10087 safety distances. The proposed layout
alternative allows for the site to be easily accessible to delivery and collection vehicles, as the site is
located next to Samuel Walters Street.
List the positive and negative impacts that the design alternatives will have on the environment.
FORM NO. BAR10/2019 Page 41 of 86
No design or layout alternatives were considered for the proposed development.
The positive impacts associated with the preferred alternative includes:
• Space optimization by Gasfit, therefore not clearing additional land
• Gas will be more readily available
• Potential gas spills/ transport accidents will be avoided, as the additional storage will reduce
the need for the transportation of gas from Epping.
• No additional roads are required as the site is easily accessible to collection and delivery
vehicles via the existing Samuel Walters Road.
Negative Impacts:
• Possibility for air quality/odour impacts
• Possible traffic impacts, as the site is accessed via an existing road.
1.4. Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to avoid negative
impacts, mitigate unavoidable negative impacts and maximise positive impacts.
Provide a description of the preferred technology alternative:
No technology alternatives were considered, the only option for bulk LPG storage is in a pressure vessel.
Provide a description of any other technology alternatives investigated.
N/A Provide a motivation for the preferred technology alternative.
There are no alternatives for bulk gas storage, therefore the only development proposal option is the
installation of an LPG pressure vessel.
Provide a detailed motivation if no alternatives exist.
There are no alternatives for bulk gas storage, therefore the only development proposal option is the
installation of an LPG pressure vessel.
List the positive and negative impacts that the technology alternatives will have on the environment.
No technology alternatives were considered for this application.
The positive impacts associated with the storage of LPG in a pressure vessel is as follows:
o The bulk storage of LPG is extensively used worldwide, the storage process, operational
procedures and health and safety risks/protocols are well known and understood in the
industry, therefore decreasing the health and safety risks when storing LPG.
Negative Impacts:
o The proposed development is for the storage of LPG, which is a flammable substance, with
several health and safety risks to the surrounding community.
1.5. Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive
impacts.
Provide a description of the preferred operational alternative.
The following operational procedures will be followed by Gasfit during the day-to-day running of the
LPG depot. These procedures will maximise the benefits and minimise the impacts/risks associated with
the LPG depot. Therefore, alternative operational procedures were not investigated:
FORM NO. BAR10/2019 Page 42 of 86
a) Sustainable management of waste to keep the site neat and tidy and to minimise complaints from
Interested and Affected Parties (IandAP’s) will be implemented on site.
b) Effective storm water management techniques will be implemented in order to minimise loss of
topsoil, avoid flooding and to minimise pollution of soil and the adjacent watercourses.
c) A routine inspection for tank integrity shall be implemented.
d) Noise levels will be kept at acceptable limits determined by the relevant local law.
e) Delivery vehicles will drive at a speed of 40km/h or lower on Samuel Walters Street to minimise dust
creation and reduce the risks of incidents and complaints by IandAP’s.
f) An emergency plan, fire plan and spill contingency plan shall be implemented.
g) Traffic management will be implemented to ensure backlog of traffic does not develop at access
points through a scheduling system.
h) All buildings will be maintained at the engineering’s specifications.
i) All pipes/ taps will be inspected for any burst, leakage of blockage regularly.
Provide a description of any other operational alternatives investigated.
N/A Provide a motivation for the preferred operational alternative.
Not applicable, no other operational alternatives were considered. Provide a detailed motivation if no alternatives exist.
No operational alternatives were considered, as there is no other operation alternative that can be
investigated at this moment in time.
List the positive and negative impacts that the operational alternatives will have on the environment.
Positive Impacts:
• Creation of employment opportunities which will lead to improving employees financial
standing.
• Provision of gas to the surrounding towns, increasing supply in the area.
• Improvement of services offered in the area, which may lead to improvement of residents’
community by adding certain services such as gas availability that was previously not available.
Negative Impacts:
• Increased traffic volume
• Potential increase in odours
• Possible health and safety risk in case of an emergency.
1.6. The option of not implementing the activity (the ‘No-Go’ Option).
Provide an explanation as to why the ‘No-Go’ Option is not preferred.
The No-Go alternative entails that the 70m3 LPG storage tank will not be installed at the Gasfit facility,
and that the site will continue to operate the depot in its current form. Afrox will continue to fill their gas
cylinders at the Epping branch (Cape Town) and transport them on a daily basis to the Worcester
storage site. The current operation of the site is therefore less efficient and will continue to present a
health and safety risk due to the daily transport of filled gas cylinders.
FORM NO. BAR10/2019 Page 43 of 86
The potential job opportunities will not materialise if the No-Go option is implemented. The NO-GO
alternative would result in the existing facility being unable to provide for the projected future gas
demand in the area.
1.7. Provide and explanation as to whether any other alternatives to avoid negative impacts, mitigate unavoidable
negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist.
No other alternatives were considered, as explained above. 1.8. Provide a concluding statement indicating the preferred alternatives, including the preferred location of the activity.
The proposed development is to install one 70m3 LPG bulk storage tank on the eastern boundary of
the site. The proposed site layout is preferred as it is feasible and reasonable, it takes into account the
very flat gradient, that is ideal for the proposed storage requirements, the existing site layout and
operations, access routes and stormwater management. Entrance and exit will be from the existing
site entrance gate situated on Samuel Walters Street, which runs along the eastern boundary of the
site. This option will allow constraint free movement of delivery and upload vehicles through the site.
The proposed site is within an existing gas depot that is transformed and is zoned for industrial use in
the Breede Valley Spatial Development Framework Revision 2019-2020. There are no sensitive natural
or cultural areas in close proximately to the site, the site is not within a Critical biodiversity Area, is
situated far (approximately 400m) from rivers and wetlands and existing infrastructure at the site makes
the proposed location the most financially feasible alternative for Gasfit as they own the site already
and propose to expand their existing facility.
It is therefore not reasonable or feasible for Gasfit to consider site alternatives when an existing industrial
zoned site has the required space for additional storage.
2. “No-Go” areas
Explain what “no-go” area(s) have been identified during identification of the alternatives and provide the co-ordinates of the
“no-go” area(s).
No No-Go areas are located within the proposed development site. Several wetlands are located
approximately 400 m to the east of the site. The likelihood of these systems being impacted by the
proposed development is low, these sites will however still be listed as No-Go areas.
Methodology to determine the significance ratings of the potential environmental impacts and risks
associated with the alternatives.
Describe the methodology to be used in determining and ranking the nature, significance, consequences, extent, duration of
the potential environmental impacts and risks associated with the proposed activity or development and alternatives, the
degree to which the impact or risk can be reversed and the degree to which the impact and risk may cause irreplaceable loss
of resources.
The Basic Assessment was undertaken in accordance with the principles of Integrated Environmental
Management as detailed in Section 23 of NEMA and in the NEMA EIA Regulations.
The impact assessment is aimed at determining the likely significance of any impacts (positive or
negative) associated with the development. The significance of the impacts is determined by
investigating certain key aspects, or parameters, of the potential impact, which are determined by
the nature of the activity, as well as the nature of the receiving environment. Aspects investigated
include the extent, duration and timing, and magnitude of the impact.
Table 2: Methodology in determining the extent, duration, probability, significance, reversibility and cumulative
impact of an environmental impact (to be read with impact tables below).
Determination of Extent (Scale):
FORM NO. BAR10/2019 Page 44 of 86
Site Specific The impact is limited to the development site (development footprint) or
part thereof.
Local The impacted area includes the whole or a measurable portion of the site,
but could affect the area surrounding the development, including the
neighbouring properties and wider municipal area.
Regional The impact would affect the broader region (e.g. neighbouring towns)
beyond the boundaries of the adjacent properties.
National The impact would affect the whole country (if applicable).
Determination of Duration:
Temporary The impact will be limited to part of the construction phase or less than one
month.
Short term The impact will continue for the duration of the construction phase, or less
than one year.
Medium term The impact will continue for part the operational phase
Long term
The impact will continue for the entire operational lifetime of the
development, but will be mitigated by direct human action or by natural
processes thereafter.
Permanent This is the only class of impact that will be non-transitory. Such impacts are
regarded to be irreversible, irrespective of what mitigation is applied.
Determination of Probability:
Improbable The possibility of the impact occurring is very low, due either to the
circumstances, design or experience.
Probable There is a possibility that the impact will occur to the extent that provisions
must therefore be made.
Highly
probable
It is most likely that the impacts will occur at some stage of the
development. Plans must be drawn up to mitigate the activity before the
activity commences.
Definite The impact will take place regardless of any prevention plans.
Determination of Significance (without mitigation):
No
significance
The impact is not substantial and does not require any mitigation action.
Low The impact is of little importance, but may require limited mitigation.
Medium
The impact is of sufficient importance and is therefore considered to have
a negative impact. Mitigation is required to reduce the negative impacts
to acceptable levels.
Medium-High The impact is of high importance and is therefore considered to have a
negative impact. Mitigation is required to manage the negative impacts to
acceptable levels.
High
The impact is of great importance. Failure to mitigate, with the objective of
reducing the impact to acceptable levels, could render the entire
development option or entire project proposal unacceptable. Mitigation is
therefore essential.
Very High The impact is critical. Mitigation measures cannot reduce the impact to
acceptable levels. As such the impact renders the proposal unacceptable.
FORM NO. BAR10/2019 Page 45 of 86
Determination of Significance (with mitigation):
No
significance
The impact will be mitigated to the point where it is regarded to be
insubstantial.
Low The impact will be mitigated to the point where it is of limited importance.
Low - Medium The impact will be mitigated to a point where it may occur but will have a
limited / low effect / impact to people and / or the environment. Taken
within the overall context of the project this impact can be mitigated to a
significance rating that is acceptable given the overall benefit.
Medium
Notwithstanding the successful implementation of the mitigation measures,
the impact will remain of significance. However, taken within the overall
context of the project, such a persistent impact does not constitute a fatal
flaw.
High
Mitigation of the impact is not possible on a cost-effective basis. The impact
continues to be of great importance, and, taken within the overall context
of the project, is considered to be a fatal flaw in the project proposal.
Determination of Reversibility:
Completely
Reversible
The impact is reversible with implementation of minor mitigation measures
Partly Reversible
The impact is partly reversible but more intense mitigation measures
Barely Reversible
The impact is unlikely to be reversed even with intense mitigation measures
Irreversible
The impact is irreversible and no mitigation measures exist
Determination of Degree to which an Impact can be Mitigated:
Can be mitigated
The impact can be completely mitigated
Can be partly
mitigated
The impact can be partly mitigated
Can be barely
mitigated It is possible to mitigate the impact only slightly
Not able to mitigate
It is not possible to mitigate the impacts
Determination of Loss of Resources:
No loss of resource
The impact will not result in the loss of any resources
Marginal loss of
resource
The impact will result in marginal loss of resources
Significant loss of
resources
The impact will result in significant loss of resources
Complete loss of
resources
The impact will result in a complete loss of all resources
Determination of Cumulative Impact:
FORM NO. BAR10/2019 Page 46 of 86
Negligible
The impact would result in negligible to no cumulative effects
Low
The impact would result in insignificant cumulative effects
Medium
The impact would result in minor cumulative effects
High
The impact would result in significant cumulative effects
Other factors which are also considered in the assessment of impacts include whether the
impact is direct, indirect or cumulative. A direct impact can be explained as being a direct
result of activities associated with the development, such as damage of on-site infrastructure
due to a fire.
An indirect impact would be a downstream, secondary or “knock-on” impact resulting from
an impact directly associated with the development (such as the contamination of
freshwater resources downstream of the municipal stormwater system in the event of a
contamination incident).
A cumulative impact would be an impact which already occurs in the receiving environment
associated with other activities taking place in proximity to the development, such as noise,
vibration and dust due to industrial activities in the area.
Other factors considered include whether the impact is reversible; and whether the impact
could cause an irreplaceable loss of resources.
The impact assessment methodology used has been closely guided by the DEAT EIA
Guideline Document 5, on the assessment of impacts and alternatives (DEAT 2006); as well as
reference to the description of the criteria used for the assessment of impacts as contained
in the DEAandDP Specialist Guidelines Series (2005).
3. Assessment of each impact and risk identified for each alternative
Note: The following table serves as a guide for summarising each alternative. The table should be repeated for each
alternative to ensure a comparative assessment. The EAP may decide to include this section as Appendix J to this BAR.
Planning Design and Construction Phase Assessment of Significance of Alternative A: Proposed Site
Layout
Soil and Groundwater Contamination and Pollution
Potential impact and risk:
Soil and Groundwater Contamination and Pollution:
Fuel, oil, lubricants and other pollutants may leak from
vehicles/ machinery and contaminate the soil.
Pollution and soil contamination could also occur from
cement mixing directly on the soil and stormwater
runoff may flow over the area and carry contaminants
off-site.
Nature of impact: Negative
Extent and duration of impact: Site Specific; temporary
FORM NO. BAR10/2019 Page 47 of 86
Consequence of impact or risk: Contamination and pollution of the soil/ groundwater.
Probability of occurrence: Improbable Degree to which the impact may cause irreplaceable
loss of resources: No loss of resource
Degree to which the impact can be reversed: Completely reversable
Indirect impacts:
Soil and Groundwater contamination could result in
human health impacts, if humans are exposed to the
contaminated soil and groundwater through dermal
contact.
Cumulative impact prior to mitigation: Low Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low
Degree to which the impact can be avoided: Can be avoided Degree to which the impact can be managed: Can be managed Degree to which the impact can be mitigated: Can be mitigated
Proposed mitigation:
1. A Spill Contingency Plan must be produced. This
should be a stand-alone operational procedure). It
should be compiled prior to the construction phase
of the extension to the gas depot and included as
an Annexure to the EMP.
2. The appointed Environmental Control Officer (ECO)
must undertake at least one site inspection
fortnightly, for the duration of the construction
phase, and to produce a short ECO report
monitoring the compliance of the property
developer with the conditions of the approved
EMP.
3. During the construction phase of the LPG storage
tank and associated infrastructure, an experienced
contractor will be appointed and it will be ensured
that the correct protocols will be followed that
relate to the handling of materials, thereby
minimising the likelihood of such an incident
occurring.
4. Adequate training of construction personnel will
ensure that incidents resulting in product spills are
minimised and that the correct actions are taken in
the event of an incident.
5. In the event of such an emergency condition, a
suitably trained clean-up contractor will be
appointed to clean up the spill. Hazardous waste
may be generated where absorbent materials are
used to mop up a product spill. This will be suitably
contained and handled by a specialist contractor
using the correct personal protective equipment
and hazardous waste temporary storage
receptacles.
6. Disposal of such waste at a suitable hazardous
landfill site with chain-of-custody documentation
provided by the contractor as proof of end
recipient.
7. The ECO will supervise any remediation procedures
in order to ensure that the correct material is
treated.
FORM NO. BAR10/2019 Page 48 of 86
8. If the location of the existing gas lines are not
known, a Ground Probing Radar (GPR) survey is
required to take place prior to construction to map
out the existing gas lines on site. The objective is to
avoid accidental damage of service and gas lines
which may cause impacts to the receiving
environment.
In addition, the following general management
measures will be implemented to avoid contamination
of soil and groundwater:
Waste Management:
1. Hazardous waste bins must be kept on an
impermeable bunded surface capable of holding
at least 110% of the volume of the bins.
2. Skips/ bins must be provided with secure lids or
covering that will prevent scavenging and
windblown waste or dust.
3. Waste bins/skips must be regularly emptied and
must not be allowed to overflow.
4. Construction workers must be instructed not to litter
and to place all waste in the appropriate waste
bins provided on site.
5. All waste, hazardous as well as general, which result
from the proposed activities must be disposed of
appropriately at a licensed Waste Disposal Facility
(WDF).
Pollution Management – hydrocarbons (oil, fuel etc.)
1. Vehicles and machinery must be in good working
order and must be regularly inspected for leaks.
2. If a vehicle or machinery is leaking pollutants it
must, as soon as possible, be taken to an
appropriate location for repair.
3. Repairs to vehicles/ machinery may take place on
site, within a designated maintenance area at the
site camp. Drip trays, tarpaulin or other
impermeable layer must be laid down prior to
undertaking repairs.
4. Refuelling of vehicles/ machinery may only take
place at the site camp or vehicle maintenance
yard. Where refuelling must occur, drip trays should
be utilised to catch potential spills/ drips.
5. Drip trays must be utilised during decanting of
hazardous substances and when refilling chemical/
fuel storage tanks.
6. Drip trays must be placed under generators (if used
on site) water pumps and any other machinery on
site that utilises fuel/ lubricant, or where there is risk
of leakage/spillage.
FORM NO. BAR10/2019 Page 49 of 86
7. Soil contaminated by hazardous substances must
be excavated and disposed of as hazardous
waste.
Cement Batching:
1. Cement batching must take place on an
impermeable surface large enough to retain any
slurry or cement water run-off. If necessary, plastic/
bidim lined detention ponds (or similar) should be
constructed to catch the run-off from batching
areas. Once the water content of the cement
water/ slurry has evaporated the dried cement
should be scraped out of the detention pond and
disposed of at an appropriate disposal facility
authorised to deal with such waste
2. Cement batching should take place on already
transformed areas within the footprint of the facility.
3. Unused cement bags must be stored in such a way
that they will be protected from rain. Empty
cement bags must not be left lying on the ground
and must be disposed of in the appropriate waste
bin.
4. Washing of excess cement/concrete into the
ground is not allowed. All excess concrete/ cement
must be removed from site and disposed of at an
appropriate location.
Residual impacts: None Cumulative impact post mitigation: Negligible Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low (-)
Dust and Noise Impacts
Potential impact and risk:
Dust and Noise Impacts: As a result of the construction
phase of this development noise and dust impacts are
expected to occur in the area due to an increase in
construction vehicles and road tankers for the duration
of the construction phase while materials are being
transported to the site.
Nature of impact: Negative
Extent and duration of impact: Site Specific; temporary
Consequence of impact or risk: Nuisance to surrounding residents
Probability of occurrence: Improbable Degree to which the impact may cause irreplaceable
loss of resources: No loss of recourses
Degree to which the impact can be reversed: Completely reversable
Indirect impacts: Nuisance to surrounding residents
Cumulative impact prior to mitigation: Negligible Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low
Degree to which the impact can be avoided: Can be avoided Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be mitigated
FORM NO. BAR10/2019 Page 50 of 86
Proposed mitigation:
Dust Mitigation
1. A Dust Management Plan for Gasfit is attached as
Appendix M
2. Dust suppression measures such as the wetting
down of sand heaps as well as exposed areas
around the site should be implemented especially
on windy days.
3. If dust issues occur, dust can be suppressed on
access roads and the construction site during dry
periods by the regular application of non-potable
water or a biodegradable soil stabilisation agent.
Under no circumstances should potable water be
used for dust suppression. Potable water should not
be used for anything besides drinking.
4. All vehicles transporting sand need to have
tarpaulins covering their loads which will assist in
any windblown sand occurring off the trucks.
5. Dust levels specified in the National Dust Control
Regulations (GN 827 of November 2013) may not
be exceeded.
6. A Complaints Register must be available at the site
office for inspection by the ECO of dust complaints
that may have been received.
7. The appointed Environmental Control Officer (ECO)
must undertake regular site inspections for the
duration of the construction phase, and to produce
regular ECO monitoring audit reports, auditing on
the compliance of the Contractor with the
conditions of the Environmental Authorisation and
the approved EMP.
Noise Mitigation
1. A noise complaints register will be opened.
2. Excavations and earth-moving activities should be
restricted to normal construction working hours
(7:30 – 17:30) as far as possible.
3. Vehicles and equipment should be kept in good
working condition. If deemed necessary,
machinery and equipment should be fitted with
mufflers/ exhaust silencers. No unnecessary
disturbances should be allowed to emanate from
the construction site.
4. Noise levels must comply with the relevant health
and safety regulations and SANS codes and should
be monitored by the Health and Safety Officer as
necessary and appropriate.
5. The appointed Environmental Control Officer (ECO)
must undertake regular site inspections for the
duration of the construction phase, and to produce
FORM NO. BAR10/2019 Page 51 of 86
regular ECO monitoring audit reports, auditing on
the compliance of the property developer with the
conditions of the Environmental Authorisation and
the approved EMP.
Residual impacts: None
Cumulative impact post mitigation: Negligible Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low (-)
Fire, Health and Safety Risk:
Potential impact and risk:
Fire, Health and Safety Risk: Exposure through
breathing vapours or skin contact may have possible
health effects. There is a minor risk of a gas pool fire and
toxic combustion gases if an incident occurs at the
existing facility while construction takes place for the
upgrade.
Nature of impact: Negative
Extent and duration of impact: Local; temporary
Consequence of impact or risk: Damage to the property and may cause injuries to
people in and around the site.
Probability of occurrence: Improbable Degree to which the impact may cause irreplaceable
loss of resources: Marginal loss of resource
Degree to which the impact can be reversed: Barely reversable
Indirect impacts: A localised fire may cause nuisance impacts such as
smoke to surrounding residents.
Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Medium
Degree to which the impact can be avoided: Can be avoided
Degree to which the impact can be managed: Can be managed Degree to which the impact can be mitigated: Can be mitigated
Proposed mitigation:
1. The mitigation measures listed under the
operational phase to avoid fire, health and safety
risks are also applicable to be implemented during
the construction phase seeming as there are
existing tanks/ gas cylinders on the site.
2. A Fire Plan schematic (layout plan) and supporting
narrative must be compiled that shows the location
of the fire extinguishers, hydrants, ingress, exits,
assembly points etc.
3. The Emergency Plan has to be compiled / updated
with the input and cooperation of both the
employer and the local government in response
the risks identified in the MHI.
4. The installation of Aboveground Storage Tank and
associated pipework must be implemented in
accordance with the relevant South African
National Standards (SANS), specifically (not
exclusive to) the following standards:
5. Bulk LPG Installation and associated pipework with
equipment certificate a certificate of compliance
must be issued by the registered LPG installer.
FORM NO. BAR10/2019 Page 52 of 86
6. All relevant safety distances for bulk LPG
installations must be in accordance with SANS
10087
7. No vehicles shall be closer than 5m from the LPG
installation (SANS 1142)
8. All safety signage must be in accordance with
SANS 1186
9. SANS 10087-3 (2008) (English): The handling,
storage, distribution and maintenance of liquefied
petroleum gas in domestic, commercial, and
industrial installations Part 3: Liquefied petroleum
gas installations involving storage vessels of
individual water capacity exceeding 500 L
10. The installation of the Aboveground Storage Tank
and associated pipework must comply with the
National Building Regulations and Standards Act
No. 103 of 1977;
11. The installation must comply with local authority
bylaws and all procedures and equipment used
must be in accordance with the Occupational
Health and Safety Act (No. 85 of 1993);
12. Upon completion of the LPG storage tank
installation, an engineer is to inspect and verify that
the tanks and the associated infrastructure have
been installed as per the design criteria described
in the final BAR and to all required SABS / SANS
standards and applicable legislation.
13. Adequate training in emergency response
situations of the contractor and personnel
undertaking the construction activities will be
carried out. All workers on site will be informed of
the emergency procedure to follow in the event of
accidental fires.
14. No open fires will be allowed on the construction
site during any phase of the project. No smoking will
be allowed on the construction site.
15. Minimisation of hot work by using alternative
methods and equipment such as air driven tools,
cold cutting and pre-fabrication off site.
16. The use of appropriate shielding and screening
such as blanketing with firefighting foam and water
screens to minimise fire risk.
17. Minimisation through spark quenching by wetting
down and/or using construction power tools such
as jack hammers under sprayed water.
18. All people working on site are responsible for their
own safety on site. Contractors and Principal
Agent/s shall at all times comply with the relevant
statutory requirements including the Occupational
Health and Safety Act, Act 85 of 1993.
FORM NO. BAR10/2019 Page 53 of 86
19. A comprehensive site specific first aid kit must be
available on site at all times.
20. At least one person trained in safety and first aid
and familiar with the first aid equipment on site must
be present on the site at all times.
21. Emergency procedures will be established prior to
the start of construction works on site.
22. Awareness training of personnel at the site and for
road tanker drivers delivering gas to site will be
conducted.
Residual impacts: None
Cumulative impact post mitigation: Low Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low to Medium (-)
Traffic, Safety and Access Impacts:
Potential impact and risk:
Traffic, Safety and Access Impacts: As a result of the
construction phase of this development traffic impacts
are expected to occur in the area due to an increase
in construction vehicle and truck traffic in the area for
the duration of the construction phase while materials
are being transported to the site. Road safety impacts
and road condition impacts could also occur.
Nature of impact: Negative
Extent and duration of impact: Local; short term
Consequence of impact or risk: Safety risks may occur and damages to road
infrastructure
Probability of occurrence: Probable Degree to which the impact may cause irreplaceable
loss of resources: No loss of resource
Degree to which the impact can be reversed: Partly reversable
Indirect impacts:
Safety risks may occur and damages to road
infrastructure. Nuisance impacts to surrounding
businesses due to increased traffic.
Cumulative impact prior to mitigation: Low Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low
Degree to which the impact can be avoided: Can be partly avoided
Degree to which the impact can be managed: Can be managed Degree to which the impact can be mitigated: Can be partly mitigated
Proposed mitigation:
1. The contractor must provide a traffic marshal for
situations where heavy construction traffic may
impede normal traffic flows on any roads adjacent
to the site.
2. All drivers and machinery operators must exercise
due caution when entering/ exiting the site.
3. Construction vehicles must adhere to the load
carrying capacity of road surfaces and adhere to
all other prescriptive regulations regarding the use
of public roads by construction vehicles.
4. The Contractor must ensure that any large or
abnormal loads (including hazardous materials)
that must be transported to/ from the site are
routed appropriately, and that appropriate safety
FORM NO. BAR10/2019 Page 54 of 86
precautions are taken during transport to prevent
road accidents.
5. All vehicles will be legally compliant
6. All drivers will be competent and in possession of an
appropriate valid driver’s license.
7. All vehicles travelling on site will adhere to the
specified speed limits.
8. The movement of all vehicles will be controlled such
that they remain on designated routes.
9. No member of the workforce will be permitted to
drive a vehicle under the influence of alcohol or
narcotic substances.
10. Warning signage (i.e. “trucks turning”) must be
erected near the access point to the site.
11. A traffic marshal should be posted at the entrance
to the site to assist with the safe and smooth flow of
vehicles on the road whilst heavy construction
traffic is entering and exiting the site.
12. No construction traffic may access the site after
normal working hours as defined by the local
authority.
Residual impacts: None Cumulative impact post mitigation: Negligible Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-High) Low (-)
Visual Impacts:
Potential impact and risk:
Visual Impacts: The construction phase is associated
with temporary disturbance as a result of construction
(trench excavations, vehicles, machinery and signage)
that may have a negative visual impact to the area.
Nature of impact: Negative
Extent and duration of impact: Site specific; temporary
Consequence of impact or risk: Visual impacts to sensitive receptors
Probability of occurrence: Probable
Degree to which the impact may cause
irreplaceable loss of resources: No loss of resource
Degree to which the impact can be reversed: Partly reversible
Indirect impacts: None
Cumulative impact prior to mitigation: Negligible
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low to Medium (-)
Degree to which the impact can be avoided: Can be partly avoided
Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be partly mitigated
Proposed mitigation:
1. Consult with the ECO when determining the
appropriate site for the site camp.
2. The site camp must be kept neat and tidy and free
of litter at all times.
3. Waste must be managed according to the EMPr.
FORM NO. BAR10/2019 Page 55 of 86
Socio-economic – Creation of business and employment opportunities
Potential impact and risk:
Socio-economic – Creation of business and
employment opportunities: Temporary employment
opportunities will be provided during the construction
phase.
Nature of impact: Positive
Extent and duration of impact: Local Extent; Short term duration
Consequence of impact or risk: This positive impact will result in job creation and
income opportunity
Probability of occurrence: Definite
Degree to which the impact may cause
irreplaceable loss of resources: N/A – this is a positive impact
Degree to which the impact can be reversed: N/A – this is a positive impact
Indirect impacts: N/A – this is a positive impact
Cumulative impact prior to mitigation: N/A – this is a positive impact
4. Good housekeeping practices on site must be
maintained to ensure the site is kept neat and tidy.
5. The site camp, storage facilities, stockpiles, waste
bins, and any other temporary structures on site
should be located in such a way that they will
present as little visual impact to surrounding
residents and road users as possible.
6. Work on site must be well-planned and well-
managed so that work proceeds quickly and
efficiently, thus minimizing the disturbance time.
7. The site camp will require visual screening via shade
cloth or other suitable material.
8. Special attention should be given to the screening
of highly reflective material.
9. Use of lighting (if required) should take into account
surrounding land users and should present little or
no nuisance. Downward facing, spill-off type
lighting is recommended.
10. Construction vehicles must enter and leave the site
during working hours.
11. The appointed Environmental Control Officer (ECO)
must undertake at least one site inspection
fortnightly for the duration of the construction
phase, and to produce a short ECO report
monitoring the compliance of the property
developer with the conditions of the approved
EMP.
Residual impacts: None
Cumulative impact post mitigation: Negligible
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low (-)
FORM NO. BAR10/2019 Page 56 of 86
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low to Medium
Degree to which the impact can be avoided: N/A – this is a positive impact
Degree to which the impact can be managed: N/A – this is a positive impact
Degree to which the impact can be mitigated: N/A – this is a positive impact
Proposed enhancement:
Preference should be given to historically
disadvantaged individuals from the local, surrounding
community, when appointing employees for
construction work.
Residual impacts: None
Cumulative impact post mitigation: N/A – this is a positive impact
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low – Medium (+)
Operational Phase Assessment of Significance of Alternative A: Proposed Site Layout
*Note: The only operational phase impacts associated with Alternative B: The NO-GO Alternative is the
socio-economic impact associated with no permanent job opportunities being provided to the local
community (Low – Medium significance), the opportunity cost lost to provide the community in the
area with gas (Medium negative significance) and the loss of income potential for Afrox and Gasfit
(Medium negative significance). No positive impacts are expected as a result of the no-go alternative.
Contamination and Pollution of the Soil and / or Groundwater
Potential impact and risk:
Soil and Groundwater Contamination and Pollution:
During the operational phase of the proposed
development soil and groundwater contamination
could result due to delivery/collection vehicles entering
and existing the depot. In addition, if stormwater is not
managed correctly there is the potential for the
unmanaged stormwater runoff to impact negatively on
the environment, potentially causing pollution and
contamination.
Nature of impact: Negative
Extent and duration of impact: Local; medium term duration
Consequence of impact or risk: Soil and / or ground water impacts could cause health
impacts to those exposed to the soil or groundwater.
Probability of occurrence: Improbable
Degree to which the impact may cause
irreplaceable loss of resources: No loss of resource
Degree to which the impact can be reversed: Can be barely reversed
Indirect impacts: Community health impacts
Cumulative impact prior to mitigation: Low
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low
Degree to which the impact can be avoided: Can be avoided
Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be mitigated
FORM NO. BAR10/2019 Page 57 of 86
Proposed mitigation:
The following precautionary measures will be followed
on site:
1. Gas collection/delivery records must be kept on site
(incoming and outgoing deliveries) as to account
for fuel leaks and spills.
2. Drip trays will be available for any vehicles that may
be potentially leaking.
3. Emergency spill kits will be kept on site.
4. The storage tanks will be regularly inspected for any
leaks.
5. The installation of Aboveground Storage Tanks and
associated pipework must be implemented in
accordance with the relevant South African
National Standards (SANS), specifically (not
exclusive to) the following standards:
SANS 10087-3 (2008) (English): The handling,
storage, distribution and maintenance of
liquefied petroleum gas in domestic,
commercial, and industrial installations Part 3
Liquefied petroleum gas installations involving
storage vessels of individual water capacity
exceeding 500 L
6. The installation of the Aboveground Storage Tanks
and associated pipework must comply with the
National Building Regulations and Standards Act
No. 103 of 1977.
7. The installation must comply with local authority
bylaws and all procedures and equipment used
must be in accordance with the Occupational
Health and Safety Act (No. 85 of 1993);
8. Upon completion of the LPG storage tank
installation, an engineer is to inspect and verify that
the tanks and the associated infrastructure have
been installed as per the design criteria described
in the final BAR and to all required SABS / SANS
standards and applicable legislation.
9. An Emergency Response Plan and Spill
Contingency Plan must be produced (or any
existing plans updated) prior to the operation of the
upgrade and included as an Annexure to the EMP.
10. If an “incident1” takes place on site, the owner of
the facility must within 14 days of the incident,
report to the Director General, provincial head of
department and municipality such information as is
available to enable an initial evaluation of the
incident, including (refer to footnote below for
definition of “incident”):
a) The nature of the incident;
1 In terms of section 30(1)(a) of NEMA, an “incident” means an unexpected, sudden and uncontrolled release of a hazardous
substance (such a diesel/fuel), including from a major emission, fire or explosion, that causes, has caused or may cause
significant harm to the environment, human life or property.
FORM NO. BAR10/2019 Page 58 of 86
b) The substances involved and an estimation of the
quantity released and their possible acute effect
on persons and the environment and data needed
to assess these effects;
c) Initial measures taken to minimise impacts;
d) Causes of the incident, whether direct or indirect ,
including equipment, technology, system or
management failure; and
measures taken and to be taken to avoid a
recurrence of such incident.
Residual impacts: Groundwater contamination
Cumulative impact post mitigation: Low
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low (-)
Fire, Health and Safety Risk
Potential impact and risk:
Fire, Health and Safety Impact: Exposure through
breathing vapours or skin contact may have possible
health effects. The hazardous events identified by the
MHI Risk Assessment that could occur at the facility
could be an uncontrolled leak of gas at the depot from
a bulk storage tank or an uncontrolled leak of gas from
the delivery road tanker. As a result of the hazardous
events, the identified potential major incidents could
be the release of LPG gas or a Sulphur dioxide gas
cloud due to the full release of a gas cylinder.
Nature of impact: Negative
Extent and duration of impact: Local; Medium term
Consequence of impact or risk:
Damage to property and equipment, illness, injuries or
death to people on site or on the adjacent currently
vacant erf.
Probability of occurrence: Improbable
Degree to which the impact may cause
irreplaceable loss of resources: If loss of life occurs this will be irreplaceable.
Degree to which the impact can be reversed: Partly reversible
Indirect impacts: A localised fire may cause nuisance impacts such as
smoke to surrounding residents.
Cumulative impact prior to mitigation: Negligible
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
High
Degree to which the impact can be avoided: Can be avoided
Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be mitigated
Proposed mitigation:
1. No flammable materials, such as wooden pallets,
must be stored near the bulk gas tank or near the
area where the road tanker parks for gas deliveries.
2. The emergency management plan must be
updated at least once per year.
FORM NO. BAR10/2019 Page 59 of 86
3. A 3,6 meters high fire wall will be constructed along
the eastern boundary of the site.
4. Operating procedures must be updated for the
facility, to include preventative measures against
the uncontrolled release of the following: following
potential major incidents:
a. LPG
b. Acetylene
c. Propane
d. Ammonia
e. Sulphur dioxide
5. All possible ignition sources near areas where gas is
stored and handled at the facility must be
eliminated. Guidelines for the control of ignition
sources are as follows:
a. Use only electrical equipment that is
certified to be flameproof and spark proof.
b. Control static electricity.
c. Ensure that vulnerable equipment is
properly bonded to ground.
d. Prohibit smoking, open flames and sparks.
e. Prevent mechanical sparks and friction.
f. Use separator devices to remove foreign
materials capable of igniting from process
materials.
g. Separate heated surfaces from dust.
h. Separate heating systems from dust.
i. Select and use industrial trucks properly.
j. Use cartridge activated tools properly.
k. Implement an equipment preventative
maintenance programme.
6. The outcome of the risk assessment must be brought
to the attention of all the employees at the facility.
7. The gas storage tank and all pipelines and fittings
must be protected against corrosion, to prevent
gas leaks.
8. The Maintenance Plan must be updated for all the
equipment used on the facility. The Plan must
contain at least the following:
a. List of all equipment and facilities on the
facility.
b. Maintenance frequency.
c. Particulars of maintenance activities that
must be performed on the listed equipment.
d. Responsible person.
9. All hazardous equipment and facilities on the
facility must be inspected on a weekly basis by
means of an Inspection Register. The Register must
contain at least the following:
a. List of all equipment and facilities on the
facility.
FORM NO. BAR10/2019 Page 60 of 86
b. Equipment items that must be inspected.
c. Facilities that must be inspected.
d. Areas that must be inspected.
e. Inspection findings.
f. Responsible person who carried out the
inspection.
10. Detailed operating procedures must be updated
at least annually for all sections of the depot, in
collaboration with the equipment suppliers. All
authorised operators must be trained in the
application of the procedure. Special attention
must be given to the offloading of diesel via road
tankers on the premises.
11. Material safety data sheets (MSDS) for the following
hazardous materials must be available on site at all
times:
a. Gases stored on site.
12. All operating personnel at the facility must be made
aware and kept aware of the dangers involving the
various gasses stored on site.
13. Access to the facility must be controlled 24 hours
per day. The safety guard on duty must comply with
the following requirements:
a. The guard must be trained in the potential
major incidents that could occur at the site
as well as the emergency procedure that
must be followed.
b. The guard must be linked via safety
management system or cellular phone with
a responsible standby person of the
operating company.
c. The guard must be able to contact the local
Fire Department immediately.
14. The Emergency Evacuation Procedure aimed at
workers must be updated at least once per year in
collaboration with the emergency services of
Worcester.
15. The Emergency Response Plan and Emergency
Evacuation Procedure must be tested at least once
every 12 months by means of mock emergencies.
The Fire Department of Worcester must preferably
participate in such tests.
16. Customer parking bays must be located in an area
where public vehicles will not cause obstruction of
emergency vehicles.
17. Adequate space must be provided for the road
tankers to enter, exit and park safely for delivery of
gas to the bulk storage tank.
18. The bulk storage tank must be adequately earthed
against lightning.
FORM NO. BAR10/2019 Page 61 of 86
19. An LPG detection alarm system must be installed at
the cylinder platform and tested regularly in
consultation with the equipment installer.
20. The LPG road tanker must never reverse or
maneuver on site.
21. All workers and tank drivers will be informed of the
emergency procedure to follow in the event of
accidental fires.
22. Effective measures must be implemented to
prevent overfilling of the storage tank and the
resultant spillage of gas.
23. A pneumatically-actuated deluge system must be
installed at the LPG storage tank, the road tanker
offloading bay and at the LPG cylinder platform.
The system must be tested weekly to confirm its
reliable operation.
24. A windsock must be installed on site.
25. No open fires will be allowed on the site.
26. A dedicated smoking area will be designated; no
smoking is to take place outside of the dedicated
smoking area.
27. Firefighting facilities will be to Oil Industry standards,
which will include hand-held fire extinguishers and
a hose reel. These facilities must be approved by
the local fire department.
28. All people working on site are responsible for their
own safety on site. Contractors and Principal
Agent/s shall at all times comply with the relevant
statutory requirements including the Occupational
Health and Safety Act, Act 85 of 1993.
29. A comprehensive site specific first aid kit must be
available on site at all times.
30. At least one person trained in safety and first aid
and familiar with the first aid equipment on site must
be present on the site at all times.
Residual impacts: None
Cumulative impact post mitigation: Low
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low – Medium (-)
Air Quality Impact
Potential impact and risk:
Air Quality Impact: Gas vapour emissions may cause
an odour nuisance or health impacts to adjacent
residents, staff on site or to users of the gas depot.
Nature of impact: Negative
Extent and duration of impact: Site specific; Medium term (the gas vapour fumes will
be present for the lifespan of the depot)
Consequence of impact or risk:
Odour nuisance to the adjacent residents and
inhalation of gas fumes could cause health impacts to
those exposed to the fumes.
FORM NO. BAR10/2019 Page 62 of 86
Probability of occurrence: Probable
Degree to which the impact may cause
irreplaceable loss of resources: No loss of resource
Degree to which the impact can be reversed: Completely reversible
Indirect impacts:
Odour nuisance to the adjacent resident’s and health
impacts due to inhalation to those exposed to the
fumes.
Cumulative impact prior to mitigation: Low – Medium
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Medium
Degree to which the impact can be avoided: Not avoidable
Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be partly mitigated
Proposed mitigation:
1. Awareness training of personnel at the site and for
road tanker drivers delivering gas to site will be
conducted.
2. Contractors and Principal Agent/s shall at all times
comply with the relevant statutory requirements
including the Occupational Health and Safety Act,
Act 85 of 1993.
3. The development of site specific protocols with
regard to delivery and use of products and use of
the relevant SANS procedures.
4. The careful location and elevation of the vent pipes
to allow for the maximum dispersion of vapour.
Residual impacts: Health impacts
Cumulative impact post mitigation: Low
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low (-)
Traffic and Safety Impacts:
Potential impact and risk:
Traffic and Safety Impacts: Traffic impacts are
expected to occur for the duration of the operational
phase of the activity as a result of the additional
vehicles making use of the gas depot. This could lead
to safety impact or damage to road infrastructure.
Nature of impact: Negative
Extent and duration of impact: Local extent; Long term duration
Consequence of impact or risk:
Nuisances to road users may occur. Infrastructure
damages to the road network may occur and there
may be safety risks associated with high traffic events.
Probability of occurrence: Probable
Degree to which the impact may cause
irreplaceable loss of resources: No loss of resource
Degree to which the impact can be reversed: Partly reversible
Indirect impacts:
Nuisances to road users may occur. Infrastructure
damages to the road network may occur and there
may be safety risks associated with high traffic events.
Cumulative impact prior to mitigation: Medium
FORM NO. BAR10/2019 Page 63 of 86
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Medium
Degree to which the impact can be avoided: Not avoidable
Degree to which the impact can be managed: Can be managed
Degree to which the impact can be mitigated: Can be mitigated
Proposed mitigation:
1. Damages to the road network should be monitored
and repaired as they occur.
2. All vehicles will be legally compliant.
3. All drivers will be competent and in possession of an
appropriate valid driver’s license.
4. All vehicles travelling on site will adhere to the
specified speed limits.
5. The movement of all vehicles will be controlled such
that they remain on designated routes.
6. No member of the workforce will be permitted to
drive a vehicle under the influence of alcohol or
narcotic substances.
7. Warning signage (i.e. “trucks turning”) must be
erected near the access point to the site.
Residual impacts:
Even after the above mitigation measures have been
implemented, when (worst case scenario) there is a
breakdown of a road tanker or a customer’s vehicle, or
an unanticipated que, temporary traffic impacts may
occur to the flow of existing traffic in the area.
Cumulative impact post mitigation: Low
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low (-)
Socio-economic – Creation of business and employment opportunities
Potential impact and risk:
Socio-economic – Creation of business and
employment opportunities: Permanent employment
opportunities are proposed to be created.
Nature of impact: Positive
Extent and duration of impact: Local Extent; Long term
Consequence of impact or risk: This positive impact will result in job creation and
income opportunity
Probability of occurrence: Definite
Degree to which the impact may cause
irreplaceable loss of resources: N/A – this is a positive impact
Degree to which the impact can be reversed: N/A – this is a positive impact
Indirect impacts: N/A – this is a positive impact
Cumulative impact prior to mitigation: N/A – this is a positive impact
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low to Medium (+)
Degree to which the impact can be avoided: N/A – this is a positive impact
Degree to which the impact can be managed: N/A – this is a positive impact
Degree to which the impact can be mitigated: N/A – this is a positive impact
FORM NO. BAR10/2019 Page 64 of 86
Proposed enhancement:
Preference should be given to historically
disadvantaged individuals from the local, surrounding
community, when appointing employees for operation
phase.
Residual impacts: None
Cumulative impact post mitigation: N/A – this is a positive impact
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low – Medium (+)
Socio-economic- Gas Supply to Local Community
Potential impact and risk:
Socio-economic – Gas Supply to the Local Community:
Gas will be readily available, with less gas shortages, as
well as an income opportunity for Afrox and Gasfit.
Nature of impact: Positive
Extent and duration of impact: Local Extent; Long term
Consequence of impact or risk: This positive impact will result in job creation and
income opportunity
Probability of occurrence: Definite
Degree to which the impact may cause
irreplaceable loss of resources: N/A – this is a positive impact
Degree to which the impact can be reversed: N/A – this is a positive impact
Indirect impacts: N/A – this is a positive impact
Cumulative impact prior to mitigation: N/A – this is a positive impact
Significance rating of impact prior to mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low to Medium (+)
Degree to which the impact can be avoided: N/A – this is a positive impact
Degree to which the impact can be managed: N/A – this is a positive impact
Degree to which the impact can be mitigated: N/A – this is a positive impact
Residual impacts: None
Cumulative impact post mitigation: N/A – this is a positive impact
Significance rating of impact after mitigation
(e.g. Low, Medium, Medium-High, High, or Very-
High)
Low – Medium (+)
SECTION I: FINDINGS, IMPACT MANAGEMENT AND MITIGATION MEASURES
1. Provide a summary of the findings and impact management measures identified by all Specialist and an indication of
how these findings and recommendations have influenced the proposed development.
An independent assessment of the Major Hazard Installation (MHI) risks was conducted at the Gasfit
gas storage Depot in Worcester by Nature and Business Alliance Africa (Pty) Ltd (please see Appendix
G1). In summary, the main findings of the MHI Risk Assessment are listed below.
• The Occupational Health and Safety Act (Act 85 of 1993) defines a major hazard installation as
“an installation-
▪ where more than the prescribed quantity of any substance is or may be kept,
whether permanently or temporarily; or
▪ where any substance is produced, used, handled or stored in such a form and
quantity that it has the potential to cause a major incident”.
FORM NO. BAR10/2019 Page 65 of 86
• It was concluded in the MHI Risk Assessment that the Gasfit facility and the LPG road tanker are
classified as a major hazard installation.
• The hazardous events identified by the MHI Risk Assessment that could occur at the facility could
be:
(a)An uncontrolled leak of LPG from the bulk storage tank.
(b)An uncontrolled leak of LPG from the delivery road tanker.
(c)An uncontrolled release of LPG from a cylinder at the filling platform
(d)An uncontrolled release of propane from a cylinder.
(e)An uncontrolled release of acetylene from a cylinder.
(f)An uncontrolled release of ammonia from a cylinder.
(g)An uncontrolled release of Sulphur dioxide from a cylinder.
• As a result of the hazardous events, the identified potential major incidents were:
o Vapour cloud explosion
o Jet fire
o Toxic cloud
o BLEVE on bulk storage tank
o BLEVE on cylinder
o Toxic cloud
• The most critical effect that a major incident at the facility could have is a sulphur dioxide toxic
cloud or the release of LPG scenario.
• The risk profile of the facility is within the tolerable norm for public risk (1.00E-4) as well as the norm
for tolerable worker risk (1.00E-3) as recommended by the UK Health and Safety Executive (HSE).
• Various mitigation measures have been recommended to be implemented to reduce the risk.
They have all been included in the EMPR.
The MHI Risk Assessment concluded the following:
• Residences are located 610 meters from the site and the occupants will be exposed to a toxic
sulphur dioxide gas cloud under low wind speed conditions, in case of a full release of one
cylinder.
• The level of risk posed by the facility to various populations immediately outside the site, closest
residences, vulnerable developments is highest for sulphur dioxide and LPG.
• The risks associated with the hazardous facilities on site can be tolerable provided the
recommended mitigation measures (ALARP) are implemented.
• The facility is classified as a major hazard installation, because a major incident at the site will
impact on members of the public outside the boundaries of the site.
• The LPG road tankers on site are classified as major hazard installations because a major
incident at the road tanker will impact on members of the public outside the boundary of then
site.
It was confirmed during discussions with the author of the MHI Risk Assessment, Dr Niemand, that even
if the adjacent erf is developed in the future, the health and safety risk is expected to be a low risk
because risk is a measure of the likelihood of an event and the consequence of an event. With the
proposed mitigation measures implemented, the likelihood of an event occurring is exponentially low,
resulting in the level of risk expected to be low. Dr. Niemand advised during the discussions and in the
MHI Risk Assessment that amongst other mitigation measures listed in the MHI Assessment, key
mitigation measures to reduce risk of impact to humans on the adjacent (currently vacant) site would
be the following:
• A safe separation distance of 236 meters from a BLEVE on the LPG storage tank should be
taken into consideration when planning for potential future development.
FORM NO. BAR10/2019 Page 66 of 86
Figure 8: Major Hazard Installation Risks associated with the proposed development.
2. List the impact management measures that were identified by all Specialist that will be included in the EMPr
The Following Impact Management Measures were recommended by the Major Hazardous Risk
Installation Specialist:
1. The emergency management plan must be updated when personnel changes or contact
details change.
2. Operating procedures for the site must be kept up to date to include preventative measures
against the uncontrolled release of the following hazardous substances:
o LPG
o Acetylene
o Propane
o Ammonia
o Sulphur dioxide
3. The outcome of the risk assessment must be brought to the attention of all the employees at
the facility.
4. The Maintenance Plan must be kept up to date for all the hazardous equipment used on the
facility. The Plan must contain at least the following:
o List of all equipment and the facilities at Gasfit
o Maintenance frequency
o Particulars of maintenance activities that must be performed on the listed equipment
o Responsible person
5. hazardous equipment and facilities on the facility must be inspected on a daily basis by means
of an Inspection Register. The Register must contain at least the following:
o List of all equipment and facilities on the facility
o Equipment items that must be inspected
o Facilities that must be inspected
o Areas that must be inspected
o Inspection findings
o Responsible person who carried out the inspection
FORM NO. BAR10/2019 Page 67 of 86
6. All authorised operators must be trained in the application of the operating procedures
applicable to them.
7. All operating personnel at the facility must be made aware and kept aware of the dangers
involving LPG, propane, acetylene, ammonia and sulphur dioxide.
8. The facility must remain under safety and security access control for 24 hours per day. The
safety guard on duty must comply with the following requirements:
o The guard must be trained in the potential major incidents that could occur at the site
as well as the emergency procedure that must be followed.
o The guard must be linked via SMS or cellular phone with a responsible standby person
at the site.
o The guard must be able to contact the local Fire Department immediately.
9. The Emergency Evacuation Procedure aimed at workers and visitors must be updated in
collaboration with the emergency services Worcester Municipality.
10. The Emergency Management Plan and Emergency Evacuation Procedure must be tested at
least once every 12 months by means of mock emergencies. The emergency services of
Worcester must be invited to participate in these tests.
11. Customer and staff parking bays must be located in an area where public vehicles will not
cause obstruction to emergency vehicles.
12. An LPG detection and alarm system must be installed at the cylinder platform and tested
regularly in consultation with the equipment installer.
13. The LPG road tanker must never reverse or maneuver on site.
14. A pneumatically actuated deluge system must be installed at the LPG storage tank, the road
tanker offloading bay and at the LPG cylinder platform. The system must be tested at least
weekly to confirm its reliable operation.
15. A windsock must be installed on site.
16. Surrounding neighbours must be informed about the presence of LPG, ammonia and sulphur
dioxide on site.
17. Prior to construction work for the installation of the LPG tank and cylinder platform, the local
office of the Department of Employment and Labour must be notified in writing, in accordance
with the Construction Regulations of the Department of Employment and Labour.
3. List the specialist investigations and the impact management measures that will not be implemented and provide an
explanation as to why these measures will not be implemented.
All impact management measures recommended by the specialists will be implemented. 4. Explain how the proposed development will impact the surrounding communities.
The proposed development will create new job opportunities to individuals from previously
disadvantaged backgrounds. Additional services will be available to the surrounding communities
such as the availability of gas products, improving the communities’ access to such services.
The proposed development could potentially have a negative effect on the surrounding communities
in the case of an emergency event. The MHI Report stated that communities located 610 meters from
the site will be exposed to toxic sulphur dioxide gas, if a full cylinder is released.
5. Explain how the risk of climate change may influence the proposed activity or development and how has the potential
impacts of climate change been considered and addressed.
When considering climate change in an EIA or BA context, two specific terms are appropriate, i.e.
climate change “adaptation” and “mitigation”. Climate change “adaptation” refers to the
implementation of measures to reduce the impacts of climate change on a specific project, thereby
addressing a project’s vulnerability to climate change by implementing measures to increase project
resilience. Climate change “mitigation” refers to the implementation of measures to reduce the
impact of a proposed project on climate change, thereby reducing a project’s greenhouse gas (GHG)
emissions.
FORM NO. BAR10/2019 Page 68 of 86
The information below aims to identify potential adaptation responses to the effects of climate change
as it relates to the proposed development, and to identity potential measures to minimise the effects
of the proposed project on climate change through climate change mitigation (by reducing GHG
emissions).
The complexity associated with climate change prediction highlights the need for adaptive and
flexible responses to climate variability. The incorporation of climate change mitigation and
adaptation into projects through the EIA and BA processes is therefore eminent.
Climate change adaptation:
Climate change projections for the Western Cape include higher mean annual temperatures, higher
maximum temperatures, more hot days and more heat waves, higher minimum temperatures, fewer
cold days and frost days, intensification of rainfall events, and increased mean sea level and
associated storm surges (DEAandDP, 2014)1.
In order to increase a project’s ability to adapt to the impacts of climate change, it is important to
identify its vulnerability or sensitivity to the potential effects of climate change. The parameters to which
this project could be vulnerable or sensitive to, together with more information on the potential
impacts, are as follows:
Increased temperatures may cause increase in fire risks or major hazardous events occurring:
The increased temperatures associated with climate change will lead to increased fire risk. Inadequate
fire risk management may result in an increased major hazardous risk occurring. The significance of this
potential impact associated will be medium without mitigation and low with mitigation.
Climate Change mitigation:
Measures should be implemented to ensure resource efficiency and renewable energy supply in order
for the proposed development to limit its greenhouse gas emissions and thereby reducing its impact
on climate change:
• Renewable energy installations such as solar should be considered for implementation as part
of the proposed development, as well as LED lighting an lightbulbs and similar fittings in the
buildings on site.
• During the operational phase the proposed development will encourage gas usage as energy
source for cooking and heating as compared to conventional coal powered electricity.
Therefore, promoting energy efficiency and a greener alternative to the surrounding
communities.
6. Explain whether there are any conflicting recommendations between the specialists. If so, explain how these have been
addressed and resolved.
N/A 7. Explain how the findings and recommendations of the different specialist studies have been integrated to inform the
most appropriate mitigation measures that should be implemented to manage the potential impacts of the proposed
activity or development.
Freshwater assessment:
The findings of the freshwater specialist concluded that the proposed development would have no
impact on the surrounding watercourses, as the development proposal will not alter the characteristics
of the wetlands. Furthermore, the identified watercourses are all located significantly away from the
development site.
Major Hazard Installation:
The recommendations made by the Hazardous Risk Specialist was used to ensure that the
development proposal is accordance with the safety requirements for the installation of the bulk LPG
FORM NO. BAR10/2019 Page 69 of 86
storage tank. Mitigation measures were provided to the EAP and was included in the BAR to ensure
that health and safety risks are minimised, during the operational phase.
8. Explain how the mitigation hierarchy has been applied to arrive at the best practicable environmental option.
According to the Environmental Impact Assessment and Management strategy for South Africa, 2014
Impact Mitigation Hierarchy is a tool used throughout a project lifecycle to limit negative impacts on
the environment.
1. Avoid and Prevent
The development proposal is for the installation of an LPG storage tank within an existing facility. The
facility is located within an industrial zone, with several developments surrounding the site. It is therefore
not possible to avoid or prevent the development, as the site and area is already established.
2. Minimise
The proposed development entails the installation of an LPG in an existing and operational site;
therefore, layout alternatives, scale and technology options are limited. The preferred layout
alternative was deemed to have the lowest impacts, due to the layout, safety and traffic
considerations. The development will keep environmental impacts to a minimum by complying to
various industry standards as well as regulation from the department of energy as well as the National
Energy Regulator of South Africa, among others.
3. Rehabilitate
The proposed development will not cause an irreplaceable loss of resource, as the development
proposal entails the installation of an LPG storage tank within an existing gas storage depot. The site is
located within the Worcester industrial zone and completely transformed; therefore, no rehabilitation
is expected. Should the gas depot be decommissioned, all relevant legal procedures will need to be
complied with at that moment in time.
SECTION J: GENERAL
1. Environmental Impact Statement
1.1. Provide a summary of the key findings of the EIA.
FORM NO. BAR10/2019 Page 70 of 86
Investigation and assessment of Erf 5875 and 5876 found that the proposed site is an ideal location to
construct an gas depot site, as there are no biodiversity impacts associated with the upgrade, there is
no vegetation on the site and the closest watercourse is approximately 400 m south east of the site. In
addition, no cultural or heritage impacts are expected to occur. The site is completely transformed,
within an urban built up area already zoned for industry (Worcester industrial area).
The most significant impact of the development proposal is the potential health and safety risk. The MHI
Risk Assessment found that a major incident such as the release of LGP or sulphur dioxide will impact
the surrounding community outside of the site boundaries. However, if the mitigation measures
recommended by the Major Hazard Installation Risk Specialist is implemented, the likelihood of an event
occurring is exponentially low, resulting in the level of risk to be low. It is also recommended that future
developments on the vacant properties adjacent to the site must have a safe separation distance of
236 meters, in case a BLEVE on the LPG storage tank.
In terms of benefits, the depot upgrade will provide job opportunities to the community during the
construction/installation and operational phases, an income stream for the applicant as well as
additional provision of gas supply services needed in the area by the community.
Given the low-medium significance of the impacts assessed and because of the fact that the likelihood
of an incident occurring is very low, the socio-economic benefit of this project should be realised and
the EAP recommends that this site should be developed with the proposed development.
The implementation of the design, construction and operational phase measures contained in the EMPr
in Appendix H, will maximize the benefits and avoid/ minimize any environmental risks associated with
the upgrade. It is in this case of particular importance to manage the health and safety risk associated
with the exposure to hazardous gasses and gas vapours.
There is thus adequate motivation for the Gasfit gas depot upgrade to proceed under the following
recommended conditions of approval:
• The mitigation measures listed in the EMPR must be strictly implemented;
• A fire wall of 3,6 meters will be constructed on the eastern boundary, adjacent to the LPG storage
tank;
• The tanks must be installed according to the following SANS:
o All relevant electrical works must be compliant with SANS 10108
All LPG storage and filling installations must comply with SANS 10087-7
o All relevant building works must comply with SANS 10400
o SANS 10087-3 (2008) (English): The handling, storage, distribution and maintenance of liquefied
petroleum gas in domestic, commercial, and industrial installations Part 3: Liquefied petroleum
gas installations involving storage vessels of individual water capacity exceeding 500 L
The following plans and procedures must be produced prior to construction taking place (as per design
phase requirements listed in the EMPR):
o Stormwater Management Plan;
o Spill Contingency Plan;
o Fire Plan;
o Update Emergency Response Plan;
o Update Preventative Maintenance Plans.
• The installation of the Aboveground Storage Tank and associated pipework must comply with the
National Building Regulations and Standards Act No. 103 of 1977;
FORM NO. BAR10/2019 Page 71 of 86
• The installation must comply with local authority bylaws and all procedures and equipment used must
be in accordance with the Occupational Health and Safety Act (No. 85 of 1993);
• Upon completion of the UST installation, an engineer is to inspect and verify that the tanks and the
associated infrastructure have been installed as per the design criteria described in the final BAR and
to all required SABS / SANS standards and applicable legislation.
The implementation of the design, construction and operational phase measures contained in the EMPr
in Appendix H, will maximize the benefits and minimize any environmental risks associated with the
proposal. Adherence to the EMPr should be made a condition of authorization. There is thus adequate
motivation for the gas depot expansion to proceed.
1.2. Provide a map that that superimposes the preferred activity and its associated structures and infrastructure on the
environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers. (Attach
map to this BAR as Appendix B2)
FORM NO. BAR10/2019 Page 72 of 86
Figure 9: Environmental sensitive areas at the proposed development site.
FORM NO. BAR10/2019 Page 73 of 86
Figure 10: Proposed development layout at the existing Gasfit gas depot facility, Worcester
Several Ecological Support Areas are located within the proposed development site, as shown in the
Cape Farm Mapper Map (Figure 9). The data source layer is dated 2018, and therefore does not
indicate the current condition of the site, as the site was established mid-2019 and has been operational
as a gas storage depot since 2019. 1.3. Provide a summary of the positive and negative impacts and risks that the proposed activity or development and
alternatives will have on the environment and community.
Positive Impacts:
• Utilisation of space by Gasfit who already owns the property.
• The proposed development is in line with the SDF of Worcester
• Job creation during the construction and operational phase, allowing employees to earn an
income and better their socio-economic standing.
• The establishment of an LPG bulk storage facility will contribute to the services offered in the
area and allow residents to have LPG readily available.
• The development proposal will reduce the safety risk to Afrox who currently has to transport gas
on a daily basis from Epping (Cape Town) to Worcester.
Negative Impacts:
FORM NO. BAR10/2019 Page 74 of 86
• Potential increase in noise levels, especially during the construction phase- the noise of the
construction vehicles may desorb residents and surrounding business owners. This will however
only be for a short period of time, as the proposed development only involves the installation of
a bulk LPG tank and the associated infrastructure.
• Increase in the level op traffic as the site is a storage depot, several trucks will collect and drop
off gas cylinders.
• The possibility of loss of lives exist, during an emergency event, as the facility will store and handle
dangerous goods.
Risks
• The major risks identified includes the storage of LPG in a bulk storage tank, as well as the LPG
road tanker, as any major incident will impact members of the public outside the boundaries if
the site.
• Several watercourses are located approximately 400 m south east of the site, therefore any
hazardous spills that are transported through the stormwater system may have indirect impacts
on the watercourses. An emergency response plan will be implemented and required in the
EMP for hazardous spills.
The EAP has assessed the impacts associated with the gas depot to be as follows, after mitigation:
Table 3: Summary Tables of Construction and Operation Phase Impact Significance, After Mitigation
CONSTRUCTION PHASE IMPACTS and BENEFITS
IMPACT IMPACT SIGNIFICANCE AFTER
MITIGATION
Soil and Groundwater Contamination and Pollution Low (-)
Visual Impact Low (-)
Dust and Noise Impact Low (-)
Fire, Health and Safety Risk Low - Medium (-)
Traffic, Safety and Access Low (-)
Socio-economic benefit – creation of 20 temporary employment opportunities Low – Medium (+)
OPERATION PHASE IMPACTS
IMPACT IMPACT SIGNIFICANCE AFTER
MITIGATION
Soil and Groundwater Contamination and Pollution Low - Medium (-)
Fire, Health and Safety Risk Low - Medium (-)
Air Quality: Gas Vapour Emissions Low (-)
Traffic and Safety Low (-)
Socio-economic benefit – creation of 4 permanent employment opportunities Low – Medium (+)
Socio-economic benefit – gas supply to community and surrounding towns
and income opportunity for Afrox and Gasfit. Medium (+)
2. Recommendation of the Environmental Assessment Practitioner (“EAP”)
2.1. Provide Impact management outcomes (based on the assessment and where applicable, specialist assessments) for the
proposed activity or development for inclusion in the EMPr
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The impact management, mitigation and monitoring measures (to avoid or reduce impacts) have
been listed in the impact tables above under “proposed mitigation” and they have also been
duplicated in the attached EMPr.
The impact management objectives, as listed in the EMPr, for each phase of the development
proposal, are as follows:
The following impact management objectives and outcomes have been identified for inclusion in the
EMPR:
Planning and Design Phase:
OBJECTIVE OUTCOMES
Appoint an Environmental Control
Officer.
The requirements of the EMPr are implemented and
monitored during all phases of the development,
which will promote sound environmental
management on site.
Undertake a GPR Survey to Detect
Existing Service Lines to be Avoided
To avoid accidental damage of service lines and gas
lines which may cause impacts to the receiving
environment. Damaged water pipes may cause
erosion, soil compaction and flooding, and damaged
sewage pipes may cause pollution and soil
contamination.
Compile / Update the Hazardous Gases
Emergency Procedures Plan.
In the event of a hazardous gas leak the procedure
and response plan is clear and understood by all,
which results in the incident having a low
environmental, health and / or safety impact.F
Compile a Fire Plan for the Gas Depot In the event of a fire at the facility the procedure and
response plan are clear and understood by all, which
results in a low health and / or safety impact.
Update the Existing Emergency Response
and Evacuation Plan
➢ To compile and Emergency Response and
Evacuation Plan that takes into account the
“on-site” and “off-site” aspects in response to
a disaster event.
➢ Ensure co-ordinated organizational and
institutional arrangements. This is to prevent or
reduce any of the hazards from occurring
and to prepare and respond if a hazard
cannot be avoided.
➢ Guide the tactical and operational co-
ordination mechanism between all the
relevant stakeholders, both pro-actively and
reactively.
➢ Provide for the safety and evacuation or
sheltering of the workers as well as that of the
public.
➢ The outcome of the plan should prompt
emergency response and relief that will:
a) Save lives,
b) Reduce further risk exposure,
c) A reduce suffering,
FORM NO. BAR10/2019 Page 76 of 86
d) Protect property,
e) Protect the environment,
f) Reduce economic and social losses, and
g) Provide for the safety and health of all
responders;
Update Preventative Maintenance Plans Prevent leaks, prevent health and safety risk and
maintain good house-keeping
Demarcation of Working Areas and NO-
GO Areas
Construction activities will be restricted to within the
designated areas and NO-GO areas will be protected
from disturbance.
Establishment of Site Camp and
Associated Site Facilities
Before the start of the construction phase a site camp
must be established with all the required ablutions,
waste management infrastructure and firefighting
equipment where the vehicles and equipment can
be stored.
Undertake Pre-Construction ECO Visit An ECO undertakes the first inspection prior to
construction commencing to monitor the applicants
compliance to the pre-construction mitigation
measures listed above and the EA.
Construction Phase
OBJECTIVE OUTCOMES
Avoid Contamination and Pollution of the
Soil and Groundwater
To avoid the contamination of soil and groundwater
by inappropriate waste management practises, fuel
and oil spills, chemical toilet spills and inappropriate
cement mixing.
Limit Noise and Dust Impacts The surrounding environment, land users, residents
and passers-by do not experience significant
nuisance impacts related to dust, noise and vibration.
Limit Traffic Impacts to Existing Road Users,
Pedestrians and Road Infrastructure
During the construction phase of the development
while materials are being delivered to the site,
damages to road infrastructure does not occur and
the safety to pedestrians is not at unacceptable risk.
Reduce the Visual Impact of the
Construction Phase Activities
Sensitive receptors are not significantly impacted
upon by construction activities taking place.
Avoid Fire, Health and Safety Risk Gas delivery, storing and dispensing activities are
undertaken responsibly and in in line with the National
Standards so that risk of explosion or exposure to
hazardous vapours and liquids are avoided.
Enhance Business and Employment
Opportunities
The development provides a benefit to the local
community in terms of job provision.
Post Construction Rehabilitation Phase
OBJECTIVE OUTCOMES
Rehabilitate disturbed areas and ensure
environmentally sensitive closure of the
construction site.
The site is neat and tidy, and all exposed
surfaces are suitably covered/ stabilized.
There is no construction-related waste or
pollution remaining on site
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Operation Phase
OBJECTIVE OUTCOMES
Avoid Soil and Groundwater Contamination No soil or groundwater contamination
occurs.
Avoid Air Quality Impact Gas vapour emissions do not cause an odour
nuisance or health impacts to adjacent
properties or to users of the gas depot.
Avoid Health and Safety Impacts
The gas depot is operated in a safe and
responsible manner in line with the legislative
requirements for the operation of a gas
depot.
Limit Traffic and Safety Impacts from
Occurring
To ensure that any damages to the road
network are maintained.
To avoid traffic accidents or delays as a
result of heavy traffic.
Enhance Business and Employment
Opportunities
The development provides a benefit to the
local community in terms of job provision.
2.2. Provide a description of any aspects that were conditional to the findings of the assessment either by the EAP or specialist
that must be included as conditions of the authorisation.
Recommended conditions of approval:
• The mitigation measures listed in the EMPR must be strictly implemented;
• A 3,6 m high wall should be constructed along the eastern boundary of the site;
• The tanks must be installed according to the following SANS:
o All relevant electrical works must be compliant with SANS 10108
o All LPG storage and filling installations must comply with SANS 10087-7
o All relevant building works must comply with SANS 10400
o SANS 10087-3 (2008) (English): The handling, storage, distribution and maintenance of
liquefied petroleum gas in domestic, commercial, and industrial installations Part 3:
Liquefied petroleum gas installations involving storage vessels of individual water
capacity exceeding 500 L
• The following plans and procedures must be produced prior to construction taking place (as
per design phase requirements listed in the EMPR):
o Stormwater Management Plan;
o Spill Contingency Plan;
o Fire Plan;
o Update Emergency Response Plan;
o Update Preventative Maintenance Plans.
• The installation of the Aboveground Storage Tanks and associated pipework must comply
with the National Building Regulations and Standards Act No. 103 of 1977;
• The installation must comply with local authority bylaws and all procedures and equipment
used must be in accordance with the Occupational Health and Safety Act (No. 85 of 1993);
Upon completion of the UST installation, an engineer is to inspect and verify that the tanks and the
associated infrastructure have been installed as per the design criteria described in the final BAR and
to all required SABS / SANS standards and applicable legislation.
2.3. Provide a reasoned opinion as to whether the proposed activity or development should or should not be authorised, and
if the opinion is that it should be authorised, any conditions that should be included in the authorisation.
FORM NO. BAR10/2019 Page 78 of 86
Investigation and assessment of Erf 5875 and 5876 found that the proposed site is an ideal location to
utilised for additional gas storage and supply services as there are no biodiversity impacts associated
with the upgrade, there is no vegetation on the site and no water resources in close proximity to the
site (closest watercourses is approximately 400m south east of the site). In addition, no cultural or
heritage impacts are expected to occur. The site is completely transformed, within an urban built up
area already zoned for industry (Worcester industrial area).
The most significant impact of the development proposal is the potential health and safety risk. The
MHI Risk Assessment found that a major incident such as the release of LGP or sulphur dioxide will
impact the surrounding community outside of the site boundaries. However, if the mitigation measures
recommended by the Major Hazard Installation Risk Specialist is implemented, the likelihood of an
event occurring is exponentially low, resulting in the level of risk to be low. It is also recommended that
future developments on the vacant properties adjacent to the site must have a safe separation
distance of 236 meters, in case a BLEVE on the LPG storage tank.
It was confirmed during discussions with the author of the MHI Risk Assessment, Dr Niemand, that even
if the adjacent erf is developed in the future, the health and safety risk is expected to be a low risk
because risk is a measure of the likelihood of an event and the consequence of an event. With the
proposed mitigation measures implemented, the likelihood of an event occurring is exponentially low,
resulting in the level of risk expected to be low.
In terms of benefits, the depot upgrade will provide job opportunities to the community during the
construction and operation phases, an income stream for the applicant as well as additional provision
of gas supply services needed in the area by the surrounding towns and communities.
Given the low-medium significance of the impacts assessed and because of the fact that the likelihood
of an incident occurring is very low, the socio-economic benefit of this project should be realised and
the EAP recommends that this site should be developed with the proposed development.
The implementation of the design, construction and operational phase measures contained in the
EMPr in Appendix H, will maximize the benefits and avoid/ minimize any environmental risks associated
with the upgrade. It is in this case of particular importance to manage the health and safety risk
associated with the storage of the various gasses especially the storage of LPG in the proposed bulk
storage tank, to avioda potential exposure to a gas release and gas vapours.
The implementation of the design, construction and operational phase measures contained in the
EMPr in Appendix H, will maximize the benefits and minimize any environmental risks associated with
the proposal. Adherence to the EMPr should be made a condition of authorization.
There is thus adequate motivation for the gas depot expansion to proceed.
2.4. Provide a description of any assumptions, uncertainties and gaps in knowledge that relate to the assessment and
mitigation measures proposed.
Assumptions
• It is assumed that all the information provided in this report and on which the report is
based is correct and valid.
• The exact impacts discussed in this report may vary once the project commences due to
real life events. The impacts identified and the mitigatory measures proposed are
predicted to occur with the information as per this report.
• It is assumed that the proposed mitigation measures as listed in this report and the EMPr
(Appendix H) will be implemented and adhered to.
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• The assessment of impacts and recommendation of mitigation measures was informed
by the site-specific ecological concerns arising from the field survey and based on the
assessor’s working knowledge and experience with similar development projects. The
degree of confidence is considered good. There is no underlying assumptions and
uncertainties or gaps in knowledge for this project.
Uncertainties:
No pre-application public consultation was carried out, therefore the comments that will be
received from the public and authorities are unknown.
Gaps in Knowledge:
There are no gaps in knowledge for the proposed project.
2.5. The period for which the EA is required, the date the activity will be concluded and when the post construction monitoring
requirements should be finalised.
i. the period within which commencement must
occur; 5 years
ii. the period for which the environmental
authorisation is granted and the date on
which the development proposal will have
been concluded, where the environmental
authorisation does not include operational
aspects;
N/A – The EA does include operational aspects
iii. the period for which the portion of the
environmental authorisation that deals with
non-operational aspects is granted; and
5 years
iv. the period for which the portion of the
environmental authorisation that deals with
operational aspects is granted.
N/A – the operation phase is permanent.
3. Water
Since the Western Cape is a water scarce area explain what measures will be implemented to avoid the use of potable water
during the development and operational phase and what measures will be implemented to reduce your water demand, save
water and measures to reuse or recycle water.
The proposed development is not associated with excessive water use. During the installation/
construction phase, non-potable water will be used for construction activities. Water used to clean
concrete batching equipment will be stored and reused in the concrete batching process.
Gasfit proposes to install JoJo tanks to capture and use rainwater on site.
4. Waste
Explain what measures have been taken to reduce, reuse or recycle waste.
Refuse waste generated on site is removed by the Breede Valley Municipality on a weekly basis. All the
broken gas cylinders are sent back to Afrox, where they either recycle of repair the gas cylinders.
5. Energy Efficiency
8.1. Explain what design measures have been taken to ensure that the development proposal will be energy efficient.
The proposed installation entails the bulk storage of LPG, the increase in storage capacity will increase
LPG availability in the area, therefore reducing electricity usage by households and businesses in the
area.
Liquid Petroleum Gas has a smaller carbon footprint, and is more energy efficient than coal, which is
primarily used in South Africa as energy source. Therefore, the development will increase energy
efficiency in the Worcester area.
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The site building is fitted with fluorescent lights, which reduces energy usage.
FORM NO. BAR10/2019 Page 81 of 86
SECTION K: DECLARATIONS
DECLARATION OF THE APPLICANT
Note: Duplicate this section where there is more than one Applicant.
I Willem Johannes Jacobus van Rooyen ID number 6801235033086 in my personal capacity or duly
authorised thereto hereby declare/affirm that all the information submitted or to be submitted as part
of this application form is true and correct, and that:
• I am fully aware of my responsibilities in terms of the National Environmental Management Act, 1998
(Act No. 107 of 1998) (“NEMA”), the Environmental Impact Assessment (“EIA”) Regulations, and any
relevant Specific Environmental Management Act and that failure to comply with these
requirements may constitute an offence in terms of relevant environmental legislation;
• I am aware of my general duty of care in terms of Section 28 of the NEMA;
• I am aware that it is an offence in terms of Section 24F of the NEMA should I commence with a
listed activity prior to obtaining an Environmental Authorisation;
• I appointed the Environmental Assessment Practitioner (“EAP”) (if not exempted from this
requirement) which:
o meets all the requirements in terms of Regulation 13 of the NEMA EIA Regulations; or
o meets all the requirements other than the requirement to be independent in terms of Regulation
13 of the NEMA EIA Regulations, but a review EAP has been appointed who does meet all the
requirements of Regulation 13 of the NEMA EIA Regulations;
• I will provide the EAP and any specialist, where applicable, and the Competent Authority with
access to all information at my disposal that is relevant to the application;
• I will be responsible for the costs incurred in complying with the NEMA EIA Regulations and other
environmental legislation including but not limited to –
o costs incurred for the appointment of the EAP or any legitimately person contracted by the
EAP;
o costs in respect of any fee prescribed by the Minister or MEC in respect of the NEMA EIA
Regulations;
o Legitimate costs in respect of specialist(s) reviews; and
o the provision of security to ensure compliance with applicable management and mitigation
measures;
• I am responsible for complying with conditions that may be attached to any decision(s) issued by
the Competent Authority, hereby indemnify, the government of the Republic, the Competent
Authority and all its officers, agents and employees, from any liability arising out of the content of
any report, any procedure or any action for which I or the EAP is responsible in terms of the NEMA
EIA Regulations and any Specific Environmental Management Act.
Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney
must be attached.
09/07/2020
Signature of the Applicant: Date:
Gasfit (PTY) Ltd
Name of company (if applicable):
FORM NO. BAR10/2019 Page 82 of 86
DECLARATION OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (“EAP”)
I Eugene Marais EAPASA Registration number N/A as the appointed EAP hereby declare/affirm the
correctness of the:
• Information provided in this BAR and any other documents/reports submitted in support of this BAR;
• The inclusion of comments and inputs from stakeholders and IandAPs;
• The inclusion of inputs and recommendations from the specialist reports where relevant; and
• 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 that:
• In terms of the general requirement to be independent:
o other than fair remuneration for work performed in terms of this application, have no business,
financial, personal or other interest in the activity or application and that there are no
circumstances that may compromise my objectivity; or
o am not independent, but another EAP that meets the general requirements set out in
Regulation 13 of NEMA EIA Regulations has been appointed to review my work (Note: a
declaration by the review EAP must be submitted);
• In terms of the remainder of the general requirements for an EAP, am fully aware of and meet all
of the requirements and that failure to comply with any the requirements may result in
disqualification;
• I have disclosed, to the Applicant, the specialist (if any), the Competent Authority and registered
interested and affected parties, all material information that have or may have the potential to
influence the decision of the Competent Authority or the objectivity of any report, plan or
document prepared or to be prepared as part of this application;
• I have ensured that information containing all relevant facts in respect of the application was
distributed or was made available to registered interested and affected parties and that
participation will be facilitated in such a manner that all interested and affected parties were
provided with a reasonable opportunity to participate and to provide comments;
• I have ensured that the comments of all interested and affected parties were considered,
recorded, responded to and submitted to the Competent Authority in respect of this application;
• I have ensured the inclusion of inputs and recommendations from the specialist reports in respect
of the application, where relevant;
• I have kept a register of all interested and affected parties that participated in the public
participation process; and
• I am aware that a false declaration is an offence in terms of Regulation 48 of the NEMA EIA
Regulations;
09/07/2020
Signature of the EAP: Date:
Sillito Environmental Consulting
Name of company (if applicable):
FORM NO. BAR10/2019 Page 83 of 86
DECLARATION OF THE REVIEW EAP
I Chantel Muller EAPASA Registration number N/A as the appointed Review EAP hereby declare/affirm
that:
• I have reviewed all the work produced by the EAP;
• I have reviewed the correctness of the information provided as part of this Report;
• I meet all of the general requirements of EAPs as set out in Regulation 13 of the NEMA EIA
Regulations;
• I have disclosed to the applicant, the EAP, the specialist (if any), the review specialist (if any), the
Department and IandAPs, all material information that has or may have the potential to influence
the decision of the Department or the objectivity of any Report, plan or document prepared as
part of the application; and
• I am aware that a false declaration is an offence in terms of Regulation 48 of the NEMA EIA
Regulations.
Signature of the EAP: Date:
Sillito Environmental Consulting
Name of company (if applicable):
FORM NO. BAR10/2019 Page 84 of 86
DECLARATION OF THE SPECIALIST
Note: Duplicate this section where there is more than one specialist.
I Dr Alfonso Niemand as the appointed Specialist hereby declare/affirm the correctness of the
information provided or to be provided as part of the application, and that:
• In terms of the general requirement to be independent:
o other than fair remuneration for work performed in terms of this application, have no business,
financial, personal or other interest in the development proposal or application and that there
are no circumstances that may compromise my objectivity; or
o am not independent, but another specialist (the “Review Specialist”) that meets the general
requirements set out in Regulation 13 of the NEMA EIA Regulations has been appointed to
review my work (Note: a declaration by the review specialist must be submitted);
• In terms of the remainder of the general requirements for a specialist, have throughout this EIA
process met all of the requirements;
• I have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and
IandAPs all material information that has or may have the potential to influence the decision of
the Department or the objectivity of any Report, plan or document prepared or to be prepared
as part of the application; and
• I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations.
09/07/2020
Signature of the EAP: Date:
Nature & Business Alliance Africa (Pty) Ltd
Name of company (if applicable):
FORM NO. BAR10/2019 Page 85 of 86
DECLARATION OF THE SPECIALIST
Note: Duplicate this section where there is more than one specialist.
I Dean Ollis as the appointed Specialist hereby declare/affirm the correctness of the information
provided or to be provided as part of the application, and that:
• In terms of the general requirement to be independent:
o other than fair remuneration for work performed in terms of this application, have no business,
financial, personal or other interest in the development proposal or application and that there
are no circumstances that may compromise my objectivity; or
o am not independent, but another specialist (the “Review Specialist”) that meets the general
requirements set out in Regulation 13 of the NEMA EIA Regulations has been appointed to
review my work (Note: a declaration by the review specialist must be submitted);
• In terms of the remainder of the general requirements for a specialist, have throughout this EIA
process met all of the requirements;
• I have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and
IandAPs all material information that has or may have the potential to influence the decision of
the Department or the objectivity of any Report, plan or document prepared or to be prepared
as part of the application; and
• I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations.
09/07/2020
Signature of the EAP: Date:
Inlands Waters Consultancy
Name of company (if applicable):
FORM NO. BAR10/2019 Page 86 of 86
DECLARATION OF THE REVIEW SPECIALIST
I ………………………………………………………., as the appointed Review Specialist hereby
declare/affirm that:
• I have reviewed all the work produced by the Specialist(s):
• I have reviewed the correctness of the specialist information provided as part of this Report;
• I meet all of the general requirements of specialists as set out in Regulation 13 of the NEMA EIA
Regulations;
• I have disclosed to the applicant, the EAP, the review EAP (if applicable), the Specialist(s), the
Department and IandAPs, all material information that has or may have the potential to influence
the decision of the Department or the objectivity of any Report, plan or document prepared as
part of the application; and
• I am aware that a false declaration is an offence in terms of Regulation 48 of the NEMA EIA
Regulations.
Signature of the EAP: Date:
Name of company (if applicable):