Chevron South Africa (Pty) Ltd

FINAL BASIC ASSESSMENT REPORT FOR THE PROPOSED DECOMMISSIONING OF FUEL

TANKS LOCATED AT CRAMMIX BRICKS, BRAKENFELL

January 2015

DEA&DP REFERENCE: 16/3/1/1/A5/11/1046/14 SEC REFERENCE: 014032

PO Box 30134, Tokai, 7966 Telephone: 021 712 5060, Fax: 021 712 5061

Email: info@environmentalconsultants.co.za

1

BASIC ASSESSMENT REPORT (AUGUST 2010)

Basic Assessment Report in terms of the NEMA Environmental Impact Assessment Regulations, 2010

AUGUST 2010 Kindly note that: 1. This Basic Assessment Report is the standard report required by DEA&DP in terms of the EIA Regulations, 2010 and must be

completed for all Basic Assessment applications. 2. This report must be used in all instances for Basic Assessment applications for an environmental authorisation in terms of the

National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), as amended, and the Environmental Impact Assessment Regulations, 2010, and/or a waste management licence in terms of the National Environmental Management: Waste Act, 2008 (Act 59 of 2008) (NEM: WA), and/or an atmospheric emission licence in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEM: AQA).

3. This report is current as of 2 August 2010. It is the responsibility of the Applicant / EAP to ascertain whether subsequent

versions of the report have been published or produced by the competent authority.

4. The required information must be typed within the spaces provided in the report. The sizes of the spaces provided are not necessarily indicative of the amount of information to be provided. It is in the form of a table that will expand as each space is filled with typing.

5. Incomplete reports will be rejected. A rejected report may be amended and resubmitted. 6. The use of “not applicable” in the report must be done with circumspection. Where it is used in respect of material

information that is required by the Department for assessing the application, this may result in the rejection of the report as provided for in the regulations.

7. While the different sections of the report only provide space for provision of information related to one alternative, if more

than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for each alternative.

8. Unless protected by law all information contained in, and attached to this report, will become public information on

receipt by the competent authority. If information is not submitted with this report due to such information being protected by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for the belief that the information is protected.

9. This report must be submitted to the Department at the postal address given below or by delivery thereof to the Registry

Office of the Department. No faxed or e-mailed reports will be accepted. Please note that for waste management licence applications, this report must be submitted for the attention of the Department’s Waste Management Directorate (tel: 021-483-2756 and fax: 021-483-4425) at the same postal address as the Cape Town Office Region A.

10. Unless indicated otherwise, two electronic copies (CD/DVD) and three hard copies of this report must be submitted to the

Department.

DEPARTMENTAL DETAILS

CAPE TOWN OFFICE REGION A (Cape Winelands, City of Cape Town: Tygerberg and Oostenberg Administrations)

CAPE TOWN OFFICE REGION B (West Coast, Overberg, City of Cape Town: Helderberg, South Peninsula, Cape Town and Blaauwberg Administrations

GEORGE OFFICE (Eden and Central Karoo)

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region A2) 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: Integrated Environmental Management (Region A2) at: Tel: (021) 483-4793 Fax: (021) 483-3633

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region B) 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: Integrated Environmental Management (Region B) at: Tel: (021) 483-4094 Fax: (021) 483-4372

Department of Environmental Affairs and Development Planning Attention: Directorate: Integrated Environmental Management (Region A1) Private Bag X 6509 George, 6530 Registry Office 4th Floor, York Park Building 93 York Street George Queries should be directed to the Directorate: Integrated Environmental Management (Region A1) at: Tel: (044) 805 8600 Fax: (044) 874-2423

View the Department’s website at http://www.capegateway.gov.za/eadp for the latest version of this document.

2

DEPARTMENTAL REFERENCE NUMBER(S) File reference number (EIA): 16/3/1/1/A5/11/1046/14 File reference number (Waste): N/A File reference number (Other): N/A PROJECT TITLE The proposed decommissioning of fuel tanks located at Crammix Bricks, Brakenfell (Erf ST214). DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

Environmental Assessment Practitioner (EAP):

Adrian Sillito Kirsty Robinson

Contact person: Kirsty Robinson Postal address: PO Box 30134

Tokai Postal code: 7966 Telephone: (021) 712 5060 Cell: 076 609 9953

E-mail: info@environmentalconsultants.co.za Kirsty@environmentalconsultants.co.za Fax: (021) 712 5061

EAP Qualifications

Adrian Sillito MSc Engineering Geology Kirsty Robinson MPhil in Climate Change and Sustainable Development (2012)

EAP Registrations/Associations

Certified Environmental Assessment Practitioner Member of the International Institute Association for Impact Assessment (IAIA) Pri. Sci. Nat Associate Member of the Institute for Waste Management of Southern Africa (IWMSA)

Details of the EAP’s expertise to carry out Basic Assessment procedures Sillito Environmental Consulting (SEC) has extensive experience in environmental assessment procedures and has completed several thousand applications across South Africa since 1998. This basic assessment report is also guided by cradle to grave knowledge related to oil industry activities from EIA through to site closure. This includes baseline contamination assessments following site closure, human health risk assessments and recommendations for remedial actions, where required. Other in house experience includes environmental control officer exposure in the construction and decommissioning of service stations and fuel storage facilities.

3

EXECUTIVE SUMMARY OF THE CONTENT OF THE BASIC ASSESSMENT REPORT:

Introduction and Project Description Chevron South Africa (Pty) Ltd, hereafter known as the applicant, proposes to decommission fuel storage tanks in terms of the National Environmental Management Act, Act No. 107 of 1998, as amended (“NEMA”). The tanks are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. Since 1941, Crammix Bricks has been one of the largest and most technologically advanced producers of clay brick products in South Africa. Historically Heavy Fuel Oil on site was used to fire the kilns for the brick vitrification process. Diesel was used for re-fuelling trucks to undertake a combination of clay mining and transport, earthmoving and quarry rehabilitation and dispatch of finished goods. The Crammix Bricks site will most likely be re-zoned in the future for residential and commercial purposes. As a result of this, the Crammix Bricks factory permanently closed down in December 2013. The fuel storage tanks currently located on the site are thus no longer required and are no longer in use. The tanks to be decommissioned, which were associated with the brick manufacturing facility, will include: 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil) 1 x 23m3 aboveground fuel storage tank (Diesel) 1 x 14m3 underground fuel storage tank (Diesel) The total fuel capacity will be up to 300m3. Please note: The total fuel amount is indicated as “up to 300m3” instead of precisely 203m3 as SEC has allowed for any potential discrepancy’s in tank volume which may be discovered in the underground utilities clearance survey which will take place just prior to the tank decommissioning (this has happened in the past). As such SEC has accounted for up to 300m3 in the general fuel storage areas in the assessment of impacts of the decommissioning process as indicated in the site plans attached as Appendix B. A Baseline Environmental Conditions Assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) was conducted in May 2013. According to the results of the assessment, the Interpretive Report (dated June 2013) as well as an email from the applicant dated 26th February 2014, the site was classified as a non-contaminated site. Environmental Resources Management. “Environmental Conditions Assessment”, 2013). The Baseline Environmental Conditions Assessment of the area was updated in October 2014 to include not only the assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) but also an assessment of the area around the 1 x 23m3 above ground fuel storage tank (DGO). The applicant confirmed in an email dated 21st October 2014 that the risk profile of the site remains the same. As such, the site decommissioning is therefore not expected to involve any remediation activities (Environmental Resources Management, “Environmental Conditions Assessment, 2014). Site decommissioning is thus not expected to involve any remediation activities. A detailed methodology of the sampling procedure and storage of samples from the applicant and specialist who undertook the above mentioned site assessments has been included as part of Appendix G the Final BAR. Please Note: The applicant has confirmed in an email dated 26th September 2014 that once the tanks have been removed, a follow-up contamination assessment will be undertaken once the tanks have been removed. This will be submitted to DEA&DP Land Management, Directorate Pollution Management as well as the City of Cape. The applicant further confirms that they will comply with all commitments contained within the Final BAR and EMP and acknowledges that all legislative requirements for remediation of contamination that may be detected at the site once a further contamination assessment has been undertaken will be adhered to in order to ensure compliance with the provisions of Part 8 of the “National Norms and Standards for the remediation of contaminated land and soil quality”, of NEM: Waste Act No. 59 of 2008 (NEMWA). Please see both the original and updated Environmental Conditions Assessment Reports (dated May 2013 and October 2014 respectively), the Interpretive Report (dated June 2013) and the emails from the applicant (dated 26th February 2014 and 21st October 2014) as well as the detailed methodology of the sampling procedure attached as part of Appendix G. Legislative Context The application for Environmental Authorisation is being made to the competent authority, namely the Provincial Department of Environmental Affairs and Development Planning (DEA&DP), and is required since the proposed development includes activities which are listed in terms of the NEMA Environmental Impact Assessment (“EIA”) Regulations, 2010. In terms of the NEMA EIA Regulations (2010) the above-mentioned proposal will trigger the following activity; authorisation for which is now being applied for: Government Notice No. 544 of the EIA Regulations, Activity 27 (v) Activity 27- The decommissioning of existing facilities or infrastructure, for~

(i) Electricity generation with a threshold of more than 10MW; (ii) Electricity transmission and distribution with a threshold of more than 132kV; (iii) Nuclear reactors and storage of nuclear fuel (iv) Activities, where the facility or the land on which it is located is contaminated; (v) Storage, or storage and handling, of dangerous goods of more than 80 cubic metres;

In terms of the EIA Regulations which pertain to the decommissioning application process, a Basic Assessment process must be followed, which includes the compilation of this Basic Assessment Report (BAR).

4

Description of the Site and Surrounding Environment The 4 fuel tanks to be decommissioned are located at Crammix Bricks on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. The larger Crammix Bricks site is predominantly surrounded by residential and agricultural land uses. According to the City of Cape Town’s Biodiversity Network however, a small “CBA1B” area is located on the north-east boundary of the larger Crammix Bricks site, a small “OESA” area is located on the north-west boundary of the larger Crammix Bricks site and small a “CBA1A” and an area classified as “Protected in Perpetuity” are located on the west boundary of the larger Crammix Bricks site. In addition, according to the City of Cape Town’s Biodiversity Network, the Braken Nature Reserve (an area classified as “Protected in Perpetuity”) is located 500m from the larger Crammix Bricks site boundary as well as a small patch of land classified as “CBA 1E”.

Public Participation Process A public participation process is required in order to fulfil the requirements of a Basic Assessment process. The public participation process needs to be undertaken in accordance with the 2010 NEMA EIA Regulations. The following activities have been undertaken thus far: Initial and Draft Basic Assessment Report Notification Identified interested and affected parties as well as Organs of State were notified of the Basic Assessment process and at the same time notified of the availability of the Draft Basic Assessment (Draft BAR) report for review and comment on 23rd July 2014. The following parties were notified of the availability of the Draft BAR: DEA&DP: Land Management (Region1) DEA&DP: Pollution Management Department of Water Affairs Department of Agriculture City of Cape Town Municipality (District C) Stellenbosch Municipality Municipal Ward Councillor Ratepayer’s Associations Relevant NGO’s Landowner Landowners and occupants of properties adjacent to the site In addition to this, a newspaper advertisement was published in the Tygerburger local newspaper on 23rd July 2014; site notices were placed at the site on the 22nd July; and the Draft BAR was placed at the local Brakenfell Public Library on the 21st July 2014. The Draft BAR was also made available on the SEC website for review and comment between the 21st July 2014 and 1st September 2014. All registered stakeholders were given the opportunity to review and comment on the Draft BAR for a period of 40 days between 23rd July and 1st September 2014. Comments received and responses sent during the public comment period for the Draft BAR have been recorded in a Comments and Responses Report. In addition, all issues raised during this period have been included in the Final BAR (this report) for review by all registered stakeholders and for submission to the DEA&DP. The following activities will be undertaken from this point forward: Final Basic Assessment Report Notification: The Final BAR (this report) includes the comments, issues and concerns raised by registered stakeholders during the Draft BAR phase public participation process and is now made available for public comment for a period of 21 days. Comments received and responses sent during the public comment period for the Final BAR will be recorded in an updated Comments and Responses Report. This, along with copies of all comments received and responses sent, will be included in the Final BAR submission when it is submitted to the DEA&DP for a decision. Please refer to Appendix F for a full record of the public participation process undertaken to date. Alternatives In terms of the principles of NEMA and potential impacts identified associated with the proposed activity, alternatives in fulfilling the general objectives of the application have been identified and considered. Where alternatives have been identified as reasonable and feasible, alternatives have been comparatively assessed during the Basic Assessment Process. 1. Property and Location Alternatives Alternative property/location site alternatives were not investigated for the purposes of this application as the proposed activity will comprise the decommissioning of existing fuel tanks located at Crammix Bricks. Thus no property/location site alternatives were investigated or assessed as this would not meet the general purpose and requirements of this application.

5

2. Activity Alternatives No activity alternatives were investigated as this would not meet the general purpose of this application. The proposed activity is considered the best environmental option for the site as not only are the tanks now inactive, but leaving the ageing, unmonitored / unmaintained tanks in place increases the risk of potential tank failure and subsequent soil and groundwater contamination. 3. Design or Layout Alternatives Design or layout alternatives are not considered applicable, as the general purpose of this application is a once off activity to decommission fuel tanks located at Crammix Bricks. 4. Technology Alternatives Technology alternatives were not considered applicable as the general purpose of the application is the decommissioning of fuel tanks. As such, the nature of the proposed activity is such that the process has associated impacts. Therefore only process alternatives have been investigated for this site. 5. Operational Alternatives Operational alternatives were not considered applicable as the general purpose of the activity is a once-off decommissioning of fuel tanks at Crammix Bricks. As such, the nature of the proposed activity is such that the process has associated impacts. Therefore only process alternatives have been investigated for this site. 6. Other Alternatives: Decommissioning Process Alternatives: The decommissioning process has two key stages: purging the tanks of remnant product and degassing the tanks; and then the physical removal and disposal of the tanks and infrastructure. For both of these aspects, there are associated health, safety and environmental risks. For example, risk of explosion if the tanks are not degassed correctly; health and safety risks to employees if tests are not conducted during the process to establish whether fuel vapour and nitrogen levels are sufficiently low to allow works to proceed; risk of leaks or spills of remnant product or sludge from the fuel lines or tanks which could contaminate soil and groundwater; and fire risk associated with unmanaged hot works on or near the tanks and fuel lines.

The best practice or preferred process alternatives have been chosen for the minimisation of any such risks. 7. No-Go Alternative The No-Go Alternative was investigated as required by the principles of NEMA. The No-Go Alternative would entail not decommissioning the fuel tanks located at Crammix Bricks. As such the fuel tanks would remain in place and the portion of the site where the tanks are located would not be able to be utilised for any alternative purposes. This could result in loss of potential revenue for the landowner as a result of not being able to utilise the affected portion of the site for any other purpose. Leaving the tanks in situ could also result in an increasing environmental risk with time associated with the potential for failure of the tanks and infrastructure over time. As such, the No-Go Alternative is not considered to be a reasonable and feasible alternative for the site. Environmental Impacts Identified and Assessed A. Proposed Activity: The proposed decommissioning of fuel tanks at the Crammix Bricks site has the following associated direct impacts: Negative Direct Impacts A temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the tank decommissioning

activities. A temporary increase in fuel vapour emissions in the vicinity of the site with associated health and safety impacts. A temporary increase in noise. A temporary increase in the amount of heavy traffic on the adjacent road network due to construction vehicles accessing the site. If undertaken incorrectly, the tank decommissioning activities on site could lead to an increased risk of soil and groundwater

contamination. If inadequate training is undertaken and inadequate firefighting equipment is kept at the site, the tank decommissioning activities

could increase the risk of fire and explosion. This has the potential to impact the residential and agricultural areas surrounding the site.

Positive Direct Impacts The permanent removal of potential health, safety and environmental risks associated with ageing, unmaintained fuel storage

infrastructure situated at the site. The creation of temporary employment opportunities during the tank decommissioning activities. The landowner will be able to utilise the portion of the site where the tanks have been located for an alternative purpose, thereby

increasing the potential for enhanced personal income. The proposed decommissioning also has the potential to have the following associated cumulative impacts: Negative Cumulative Impacts A temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the tank decommissioning

activities. A temporary increase in emissions (due to tank degassing procedures). A temporary increase in noise. A temporary increase in the amount of heavy traffic due to the construction-type nature of the decommissioning activities.

Please note that these negative impacts are considered to be cumulative due to the surrounding land use (dust from the surrounding agricultural activities, emissions from traffic on the M23 and the dense road network surrounding the site, noise from traffic and the adjacent agricultural activities, traffic as a result the existing traffic flow in the area.

6

Positive Cumulative Impacts The creation of temporary employment opportunities during the tank decommissioning activities Please note that the positive impact is considered cumulative due to the surrounding land use being a source of additional employment in terms of work on the agricultural land (farm labourers and managers) as well as in the residential areas. The impact assessment undertaken found that, the potential negative environmental and social impacts arising as a result of the tank decommissioning can be mitigated to an acceptable level. Provided that the proposed mitigation measures are implemented, no factors were determined which should prevent the proposed tank decommissioning from taking place. In order to avoid/manage the potential negative direct and cumulative impacts of the tank decommissioning, an Environmental Management Plan (EMP) has been compiled. The EMP lists the various impacts that may occur during the decommissioning of the site, the proposed management and mitigation measures, the responsible person or party for ensuring that the mitigation measures are complied with and the frequency of compliance monitoring to be undertaken. The EMP should be updated regularly. Please note that the decommissioning of the 4 fuel tanks located at Crammix Bricks is the preferred alternative. B. The No-Go Alternative The No-Go Alternative means the “option of not implementing the proposed activity” i.e. not decommissioning the fuel tanks located at the site. As such the fuel tanks would remain in place permanently. Positive impacts of the No-Go Alternative: There will be no temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the

decommissioning activities not commencing. There will be no temporary increase in noise due to the construction-type nature of the decommissioning activities not commencing. There will be no temporary increase in the amount of heavy traffic at the site due to the construction-type nature of the

decommissioning activities not commencing. As the decommissioning will not occur, there will be no risk of incorrectly undertaken degassing and decommissioning. Incorrect

procedures could lead to a temporary increased environmental risk of soil and groundwater contamination which in turn could have associated human health risks (respiratory system irritation through vapour inhalation; irritation through dermal contact; etc.).

If the tank degassing and decommissioning is undertaken incorrectly, there is an associated risk of fire and explosion. With the No-Go alternative, this risk is quite minimal.

Negative Impacts of the No-Go Alternative: There will be no permanent removal of potential health, safety and environmental risks associated with ageing, unmaintained tanks

situated at the site. There will be no creation of temporary employment opportunities during the decommissioning activities The landowner will not be able to utilise that portion of the site for any other purpose. Please note that the No-Go Alternative is not considered to be a reasonable and feasible alternative for this site and this alternative is not preferred. Please refer to Section F of this report for a detailed investigation and assessment of the above mentioned impacts.

EAP Recommendation and Mitigation Measures From the impact assessment undertaken for the site, it has been determined that the potential negative impacts associated with the proposed decommissioning of the fuel tanks can all be mitigated to an acceptable level. In addition, the positive impacts associated with the proposed activity are of greater significance than any positive impacts that may be associated with the No-Go Alternative. The EAP therefore finds it reasonable to recommend that the proposed decommissioning of the fuel tanks located at Crammix Bricks should be authorised to proceed as it is the best practible environmental option for the site. The recommended mitigation measures contained in Section F of the BAR and in the EMP for the proposed activity should be implemented and adhered to in order to avoid or minimise these potential impacts. In particular:

Soil and Groundwater Contamination

Adequate training of the tank decommissioning contractor’s staff will ensure that the impact is minimised and, should it occur, rapid, informed action is taken to contain the spillage.

A competent professional (the site assessment/ risk assessment practitioner) should be present during the tank removal process to monitor the subsurface conditions as well as provide guidance where required.

All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential soil contamination risk associated with potential spillages.

All sludge, remaining product, contaminated water etc., which is a by-product of the above, shall be collected and removed off site and disposed of at a licensed landfill site or recycled. Chain-of-custody documentation for safe disposal will be included in the site closure audit report to be submitted to the relevant authorities.

With the disposal of fuel product slops and any sludge and contaminated water, all of which is hazardous waste, the relevant waste policies and protocols (such as the Waste Classification and Management Regulations) need to be adhered to. Otherwise, the associated risk of soil and groundwater contamination if the hazardous waste is handled, transported and disposed of incorrectly, is unacceptably high.

The tanks should be thoroughly emptied prior to dismantling and should only be removed from site once they have been drained

7

and degassed. The tanks will be removed to the contractor’s site where they will either be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and environmental risk at the site.

Chevron’s health and safety protocols should be adhered to at all times. If contamination occurs because of the removal of the storage tanks and other infrastructure, or if contamination is found that was

the result of leaks during the use of the tanks, the Department of Water Affairs must be notified immediately. All rehabilitation measures contained in the emergency response plan should be adhered to at all times. If pollution of groundwater occurs, a remediation plan including a provision for groundwater monitoring for a reasonable timeframe

after the clean-up operation has taken place, must be provided to the Department of Water Affairs. The precautionary principle applies at all times. If pollution of groundwater sources occurs, every effort must be made to reduce the

contamination as far as possible. Fuel Vapour Emissions to ambient atmosphere: Air Quality: Tanks and the tank manhole area should be vented and to ensure that any vapours are below levels that pose a health and safety

risk and that oxygen levels are acceptably high. Health Effects: Workers performing the degassing must stand up wind from the operation and if required wear respirators with organic vapour

cartridges. All workers are to wear the correct personal protection. Equipment should include clean leather gloves during the degassing

operation. Gas test results must be within acceptable limits for breathing at all times. Once N2 is introduced, continuous gas testing of the work area during tank decommissioning is required to prevent asphyxiation as a

result of the N2 displacing the oxygen in the area. Should the tank shows a sign of collapse or implosion during the vacuum process, work is to be stopped immediately.

Chevron’s health and safety protocols for the degassing of the tanks can be implemented for this impact. Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and

environmental risk at the site. Steps must be taken to avoid any health nuisance relating to emissions as defined by the City of Cape Town Environmental Health

by-Law P.N. 13333 of 2003. Fire Explosion and Risk: The decommissioning and disposal of the fuel storage tanks will comply with the American Petroleum Industry’s (API) standard 1604

relating to the closure of petroleum storage tanks. Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site prior to the

degassing process. 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. The pump to be used for the emptying of the tank must be flame proof. Remaining product from the tanks should be emptied into appropriately sealable metal drums. All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential fire

risk associated with fuel vapour compression. The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and removed from

site. Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the following:

Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-fabrication off site.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk. Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk. Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process. Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health and safety

and environmental risk at the site. Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank

decommissioning activities will be carried out. Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These have been

attached as part of Appendix H. The tanks will be removed from site once they have been drained and degassed. The aboveground tanks will either be removed to

the contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Dust Adherence to the Dust Management Plan which is contained in Appendix H, and which includes the following measures: All vehicles should adhere to the local speed limit of 60km/hr on Crammix Road and 10km/hr within Crammix Bricks itself. When

travelling in areas that are particularly dusty, vehicle speed should be reduced further. All roads upon which vehicles associated with the decommissioning activities travel on should be wet down either manually or by

water bowser/ tanker as required. Areas where excavation will occur as well as areas where excavated soil and clean sand stockpiles are stored should be wet down. Quarry water bodies should be used for wetting down activities and not potable water. All excavated soil and clean sand stockpiles should be stored in neat separate piles in an area on the site with the lowest wind

exposure.

8

Erection of shade netting screens around the areas where excavation activities will occur. Covering of the excavated soils and clean sand stockpiles with netting should be considered. All Contractors and personnel associated with the decommissioning activities should wear dust masks as required. The use of goggles should also be considered. Contractors to abide by dust management protocols established for the site already. Risk of Fire and Explosion (Health and Safety Risk) All workers are to wear the correct personal protection. The decommissioning and disposal of the fuel storage tanks will comply with the American Petroleum Industry’s (API) standard 1604

relating to the closure of petroleum storage tanks. Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site prior to the

degassing process. 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. The pump to be used for the emptying of the tank must be flame proof. Remaining product from the tanks should be emptied into appropriately sealable metal drums. Tanks and the tank manhole area should be vented and to ensure that any vapours are below levels that pose a health and safety

risk and that oxygen levels are acceptably high. All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential fire

risk associated with fuel vapour compression. The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and removed from

site. Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the following:

Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-fabrication off site.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk. Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk. Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process. Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health and safety

and environmental risk at the site. Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank

decommissioning activities will be carried out. Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These have been

attached as part of Appendix H. The tanks will be removed from site once they have been drained and degassed. The aboveground tanks will either be removed to

the contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Noise The decommissioning contractor must use modern equipment, which produces the least noise. Any unavoidably noisy equipment must be identified and located in an area where it has the least likely impact. The use of noise shielding screens must be considered and the operation of such machinery restricted to when it is actually required. The use of ear protectors for workers using any machinery which emits noise in excess of 85dBA. Visual Screening of the site during the decommissioning activities. Screening of stockpiles. Traffic Warning signage (i.e. “trucks turning”) must be erected near the access point of the site on Crammix Road. A traffic marshal should be posted at the entrance of the site to assist with the safe and smooth flow of vehicles on the road whilst

heavy construction vehicles are entering and exiting the site. No construction traffic may access the site after normal working hours as defined by the local authority.

9

SECTION A: ACTIVITY INFORMATION 1. PROJECT DESCRIPTION

(a) Is the project a new development? YES NO

(b) Provide a detailed description of the development project and associated infrastructure. Chevron South Africa (Pty) Ltd, hereafter known as the applicant, proposes to decommission fuel storage tanks in terms of the National Environmental Management Act, Act No. 107 of 1998, as amended (“NEMA”). The tanks are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. Since 1941, Crammix Bricks has been one of the largest and most technologically advanced producers of clay brick products in South Africa. Historically Heavy Fuel Oil on site was used to fire the kilns for the brick vitrification process. Diesel was used for re-fuelling trucks to undertake a combination of clay mining and transport, earthmoving and quarry rehabilitation and dispatch of finished goods. The Crammix Bricks site will most likely be re-zoned in the future for residential and commercial purposes. As a result of this, the Crammix Bricks factory permanently closed down in December 2013. The fuel storage tanks currently located on the site are thus no longer required and are no longer in use. The tanks to be decommissioned, which were associated with the brick manufacturing facility, will include: 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil) 1 x 23m3 aboveground fuel storage tank (Diesel) 1 x 14m3 underground fuel storage tank (Diesel) The total fuel capacity will be up to 300m3. Please note: The total fuel amount is indicated as “up to 300m3” instead of precisely 203m3 as SEC has allowed for any potential discrepancy’s in tank volume which may be discovered in the underground utilities clearance survey which will take place just prior to the tank decommissioning (this has happened in the past). As such SEC has accounted for up to 300m3 in the general fuel storage areas in the assessment of impacts of the decommissioning process as indicated in the site plans attached as Appendix B. A Baseline Environmental Conditions Assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) was conducted in May 2013. According to the results of the assessment, the Interpretive Report (dated June 2013) as well as an email from the applicant dated 26th February 2014, the site was classified as a non-contaminated site. Environmental Resources Management. “Environmental Conditions Assessment”, 2013). The Baseline Environmental Conditions Assessment of the area was updated in October 2014 to include not only the assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) but also an assessment of the area around the 1 x 23m3 above ground fuel storage tank (DGO). The applicant confirmed in an email dated 21st October 2014 that the risk profile of the site remains the same. As such, the site decommissioning is therefore not expected to involve any remediation activities (Environmental Resources Management, “Environmental Conditions Assessment, 2014I). Site decommissioning is thus not expected to involve any remediation activities. A detailed methodology of the sampling procedure and storage of samples from the applicant and specialist who undertook the above mentioned site assessments has been included as part of Appendix G the Final BAR. Please Note: The applicant has confirmed in an email dated 26th September 2014 that once the tanks have been removed, a follow-up contamination assessment will be undertaken once the tanks have been removed. This will be submitted to DEA&DP Land Management, Directorate Pollution Management as well as the City of Cape. The applicant further confirms that they will comply with all commitments contained within the Final BAR and EMP and acknowledges that all legislative requirements for remediation of contamination that may be detected at the site once a further contamination assessment has been undertaken will be adhered to in order to ensure compliance with the provisions of Part 8 of the “National Norms and Standards for the remediation of contaminated land and soil quality”, of NEM: Waste Act No. 59 of 2008 (NEMWA). Please see both the original and updated Environmental Conditions Assessment Reports (dated May 2013 and October 2014 respectively), the Interpretive Report (dated June 2013) and the emails from the applicant (dated 26th February 2014 and 21st October 2014) as well as the detailed methodology of the sampling procedure attached as part of Appendix G.

10

(c) List all the activities assessed during the Basic Assessment process: GN No. R. 544 Activity No(s):

Describe the relevant Basic Assessment Activity (ies) in writing as per Listing Notice 1 (GN No. R. 544)

Describe the portion of the development as per the project description that relates to the applicable listed activity.

27 (v) The decommissioning of existing facilities or infrastructure, for~ (i) Electricity generation with a

threshold of more than 10MW; (ii) Electricity transmission and

distribution with a threshold of more than 132kV;

(iii) Nuclear reactors and storage of nuclear fuel

(iv) Activities, where the facility or the land on which it is located is contaminated;

(v) Storage, or storage and handling, of dangerous goods of more than 80 cubic metres;

The proposed activity will comprise the decommissioning of fuel tanks used for the storage of dangerous goods. The tanks to be decommissioned will include: 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil) 1 x 23m3 aboveground fuel storage tank (Diesel) 1 x 14m3 underground fuel storage tank (Diesel) The total fuel capacity will be up to 300m3. A Baseline Environmental Conditions Assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) was conducted in May 2013. According to the results of the assessment, the Interpretive Report (dated June 2013) as well as an email from the applicant dated 26th February 2014, the site was classified as a non-contaminated site. Environmental Resources Management. “Environmental Conditions Assessment”, 2013). The Baseline Environmental Conditions Assessment of the area was updated in October 2014 to include not only the assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) but also an assessment of the area around the 1 x 23m3 above ground fuel storage tank (DGO). The applicant confirmed in an email dated 21st October 2014 that the risk profile of the site remains the same. As such, the site decommissioning is therefore not expected to involve any remediation activities (Environmental Resources Management, “Environmental Conditions Assessment, 2014I). A detailed methodology of the sampling procedure and storage of samples from the applicant and specialist who undertook the above mentioned site assessments has been included as part of Appendix G the Final BAR. Please Note: The applicant has confirmed in an email dated 26th September 2014 that once the tanks have been removed, a follow-up contamination assessment will be undertaken once the tanks have been removed. This will be submitted to DEA&DP Land Management, Directorate Pollution Management as well as the City of Cape. Please refer to Appendix G for the Environmental Condition Assessment (2013) and the updated Environmental Conditions Assessment (2014).

GN No. R. 546 Activity No(s):

Describe the relevant Basic Assessment Activity (ies) in writing as per Listing Notice 3 (GN No. R. 546)

Describe the portion of the development as per the project description that relates to the applicable listed activity.

N/A If the application is also for activities as per Listing Notice 2 and permission was granted to subject the application to Basic Assessment, also indicate the applicable Listing Notice 2 activities: GN No. R. 545 Activity No(s):

If permission was granted in terms of Regulation 20, describe the relevant Scoping and EIA Activity (ies) in writing as per Listing Notice 2 (GN No. R. 545)

Describe the portion of the development as per the project description that relates to the applicable listed activity.

N/A

11

Waste management activities in terms of the NEM: WA (Government Gazette No. 32368): GN No. 718 - Category A Activity No(s): Describe the relevant Category A waste management activity in writing.

N/A

Please note: If any waste management activities are applicable, the Listed Waste Management Activities Additional Information Annexure must be completed and attached to this Basic Assessment Report as Appendix I. If the application is also for waste management activities as per Category B and permission was granted to subject the application to Basic Assessment, also indicate the applicable Category B activities: GN No. 718 – Category B Activity No(s): Describe the relevant Category B waste management activity in writing.

N/A

Atmospheric emission activities in terms of the NEM: AQA (Government Gazette No. 33064): GN No. 248 Activity No(s): Describe the relevant atmospheric emission activity in writing.

N/A

(d) Please provide details of all components of the proposed project and attach diagrams (e.g. architectural drawings or

perspectives, engineering drawings, process flow charts etc.). Buildings YES NO Provide brief description: The tanks are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The total size of the site is approximately 17.3ha. Buildings and infrastructure located on the site:

Crammix Bricks clay brick and paver manufacturing factory which contains the following infrastructure: o Computer controlled extruder and cutter; o Drier and Tunnel kilns; o Brick kilns cars ; o Clay brick cooling and storage area;

Offices; Clay quarry; and a Small dam on the northern border of the site boundary. Please note: Whilst the above mentioned buildings and infrastructure located at the Crammix Bricks site are no longer in use, they are not part of the scope of the decommissioning. Infrastructure located on the site to be decommissioned: 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil); 1 x 23m3 aboveground fuel storage tank (Diesel); and 1 x 14m3 underground fuel storage tank (Diesel). Infrastructure (e.g. roads, power and water supply/ storage) YES NO Provide brief description: Roads The fuel tanks to be decommissioned are located at Crammix Bricks off Crammix Road. Crammix Road connects to Kruis Street. Kruis Street in turn connects to the M23 thereafter to the South of the site. There is a dense network of roads in the area which connect either to the R300 to the West of the site as well as the R304 to the East of the site. Power and Water Supply The site is a fully serviced site with access to Municipal water and electricity supply as well as a connection to the Municipal sewer. Processing activities (e.g. manufacturing, storage, distribution) YES NO Provide brief description: Storage Historically the fuel tanks have been used on site for the storage of Heavy Fuel Oil (for the brick vitrification process) and the storage of Diesel (for the re-fuelling of trucks). The Crammix Bricks factory closed down in December 2013 and the fuel tanks are thus no longer in use or required. As such no processing, manufacturing, storage or distribution activities are currently occurring on site.

12

Storage facilities for raw materials and products (e.g. volume and substances to be stored) Provide brief description YES NO N/A Storage and treatment facilities for solid waste and effluent generated by the project Yes No Provide brief description N/A Other activities (e.g. water abstraction activities, crop planting activities) Yes No Provide brief description N/A

2. PHYSICAL SIZE OF THE ACTIVITY Size of the property: (a) Indicate the size of the property (cadastral unit) on which the activity is to be undertaken. The total extent of the site is approximately 17.3ha

Size of the facility:

(b) Indicate the size of the facility (development area) on which the activity is to be undertaken.

The fuel storage tanks and associated bunds and delivery lines and pumps cover a combined area of approximately 120m2

Size of the activity:

(c) Indicate the physical size (footprint) of the activity together with its associated infrastructure:

The fuel storage tanks and associated bunds and delivery lines and pumps cover a combined area of approximately 120m2

(d) Indicate the physical size (footprint) of the activity: The fuel storage tanks and associated bunds and delivery lines and pumps cover a combined area of approximately 120m2

(e) Indicate the physical size (footprint) of the associated infrastructure: The fuel storage tanks and associated bunds and delivery lines and pumps cover a combined area of approximately 120m2

and, for linear activities: Length of the activity: (f) Indicate the length of the activity: N/A m

3. SITE ACCESS

(a) Is there an existing access road?

The site can be accessed via Crammix Road. YES NO

(b) If no, what is the distance over which a new access road will be built? N/A (c) Describe the type of access road planned: N/A Please Note: indicate the position of the proposed access road on the site plan.

13

4. DESCRIPTION OF THE PROPERTY ON WHICH THE ACTIVITY IS TO BE UNDERTAKEN AND THE

LOCATION OF THE ACTIVITY ON THE PROPERTY (a) Provide a description of the property on which the activity is to be undertaken and the location of the activity on the

property. The tanks are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The total size of the site is approximately 17.3ha. Buildings and infrastructure located on the site: Crammix Bricks clay brick and paver manufacturing factory which contains the following infrastructure:

o Computer controlled extruder and cutter; o Drier and Tunnel kilns; o Brick kilns cars ; o Clay brick cooling and storage area;

Offices; Clay quarry; and a Small dam on the northern border of the site boundary. Please note: Whilst the above mentioned buildings and infrastructure located at the Crammix Bricks site are no longer in use, they are not part of the scope of the decommissioning. Infrastructure located on the site to be decommissioned 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil); 1 x 23m3 aboveground fuel storage tank (Diesel); and 1 x 14m3 underground fuel storage tank (Diesel).

Figure 1: Site Map indicating the location of the fuel tanks to be decommissioned at Crammix Bricks (image courtesy of Google Earth, 2014). Please also refer to Appendix B for additional site layout plans.

(b) Please provide a location map (see below) as Appendix A to this report which shows the location of the property and the

location of the activity on the property; as well as a site map (see below) as Appendix B to this report; and if applicable all alternative properties and locations.

14

Locality map:

The scale of the locality map must be at least 1:50 000. For linear activities 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; the prevailing wind direction (during November to April and during May to October); and GPS co-ordinates (Indicate the position of the activity using the latitude and longitude of the centre

point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection).

Site Plan:

Detailed site plan(s) must be prepared for each alternative site or alternative activity. The site plan must contain or conform to the following: The detailed site plan must be at a scale preferably at a scale of 1:500 or at an appropriate scale. The

scale must be indicated on the plan. The property boundaries and numbers of all the properties within 50m of the site must be indicated on

the site plan. The current land use (not zoning) as well as the land use zoning of each of the adjoining properties must

be indicated on the site plan. The position of each element of the application as well as any other structures on the site must be

indicated on the site plan. Services, including electricity supply cables (indicate above or underground), water supply pipelines,

boreholes, sewage pipelines, storm water infrastructure and access roads that will form part of the development must be indicated on the site plan.

Servitudes indicating the purpose of the 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 Rivers. o Flood lines (i.e. 1:10, 1:50, year and 32 meter set back line from the banks of a river/stream). o Ridges. o Cultural and historical features. o Areas with indigenous vegetation (even if it is degraded or infested with alien species).

Whenever the slope of the site exceeds 1:10, then a contour map of the site must be submitted.

(c) For a linear activity, please also provide a description of the route. N/A

Indicate the position of the activity using the latitude and longitude of the centre point of the site. The co-ordinates must be in degrees, minutes and seconds. The minutes should be given to at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection.

Latitude (S): Longitude (E):

33o 53‘ 21.09“ 18o 43‘ 25.69“

(d) or: For linear activities: N/A Latitude (S): Longitude (E): Starting point of the activity o ‘ “ o ‘ “ Middle point of the activity o ‘ “ o ‘ “ End point of the activity o ‘ “ o ‘ “ Please Note: For linear activities that are longer than 500m, please provide and addendum with co-ordinates taken every 100 meters along the route. 5. SITE PHOTOGRAPHS Colour photographs of the site and its surroundings (taken of the site and from 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 as Appendix C to this report. It 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.

15

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT Site/Area Description For linear activities (pipelines, etc.) as well as activities that cover very large sites, it may be necessary to complete copies of this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section B and indicate the area which is covered by each copy No. on the Site Plan. 1. GRADIENT OF THE SITE Indicate the general gradient of the sites (highlight the appropriate box).

Flat Flatter than 1:10 1:10 – 1:4 Steeper than 1:4 2. LOCATION IN LANDSCAPE (a) Indicate the landform(s) that best describes the site (highlight the appropriate box (is).

Ridgeline Plateau Side slope of hill/mountain

Closed valley

Open valley Plain

Undulating plain/low hills

Dune Sea-front

(b) Please provide a description of the location in the landscape.

Figure 2: Map depicting the larger Crammix Bricks site (delineated in yellow), the location of the tanks (yellow placemark) and the surrounding land uses.

16

The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. Description of the Crammix Bricks site itself: The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Description of the area surrounding the larger Crammix Bricks site: The following land uses occur in the immediate vicinity of the larger Crammix Bricks site: North Residential areas from the site boundary onwards. North-East A small patch of land classified by the City of Cape Town’s Biodiversity Network as “CBA1B” (from the site boundary for approximately 200- 300m). Agriculture areas from the boundary of the CBA1B area onwards. East An unnamed dam/reservoir (approximately 350m from the site boundary). Agricultural areas from the site boundary onwards. South-East Agricultural areas from the site boundary onwards. South Agricultural areas from the site boundary onwards. South-West Residential areas from the site boundary onwards. West A small patch of land classified by the City of Cape Town’s Biodiversity Network as “CBA1A” (from the site boundary for approximately 150m). A small patch of land classified by the City of Cape Town’s Biodiversity network as a “Protected in Perpetuity” adjacent to the CBA1A to the north also stretching for approximately 150m. Residential areas from the boundary of the CBA1A and Conservation areas onwards. North-West A small area classified by the City of Cape Town’s Biodiversity Network as an “OESA” area is located on the most north-west boundary of the site and stretches for approximately 500m. Residential areas are located both above and below the OESA area from the site boundary onwards. According to the City of Cape Town’s Biodiversity Network the Braken Nature Reserve (an area classified as “Protected in Perpetuity”) is located 500m from the site boundary along the boundary of the residential areas. In addition, according to the City of Cape Town’s Biodiversity Network, adjacent to the Braken Nature Reserve to the north there is also a small patch of land classified as “CBA 1E”. Please refer to Appendix C for photographs of the site and its surroundings and Appendix D for a Land Cover map illustrating the land use of the site and the surrounding areas as well as a Fine Scale Map indicating the biodiversity features identified on the northern portion of the site and adjacent to the larger Crammix Bricks site.

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (a) Is the site(s) located on or near any of the following (highlight the appropriate boxes)?

Shallow water table (less than 1.5m deep) YES NO UNSURE Seasonally wet soils (often close to water bodies) YES NO UNSUREUnstable rocky slopes or steep slopes with loose soil YES NO UNSUREDispersive soils (soils that dissolve in water) YES NO UNSURESoils with high clay content YES NO UNSUREAny other unstable soil or geological feature YES NO UNSUREAn area sensitive to erosion YES NO UNSUREAn area adjacent to or above an aquifer. YES NO UNSUREAn area within 100m of the source of surface water YES NO UNSURE

17

(b) If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the Department.

(Information in respect of the above will often be available at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

(c) Please indicate the type of geological formation underlying the site.

Granite Shale Sandstone Quartzite Dolomite Dolorite Other (describe)

Please provide a description. According to the baseline Environmental Conditions Assessment conducted by Environmental Resources Management in May 2013 and the updated baseline Environmental Conditions Assessment conducted by Environmental Resources Management in October 2014: Geology: According to the 1:250 000 Geological Map of Cape Town (3318), the site is underlain by sandy soils of the Springfontyn Formation which is further underlain by greywacke, phyllite and quartzitic sandstone of the Tygerberg Formation. The Springfontyn Formation is Quartenary in age and Tygerberg Formation is of the Neoproterozoic era. Hydrogeology The 1:500 000 scale hydrogeological map series (Cape Town, Sheet 3317) and the 1:3 000 000 Aquifer Classification map of South Africa compiled by the Department of Water Affairs indicates that the site is underlain predominantly by undifferentiated coastal deposits ( unconsolidated to semi-consolidated sediments including sand, calcrete, calcarenite, aeolianite, marine gravel, clay, silcrete and limestone). (Environmental Resources Management. “Environmental Conditions Assessment”, 2013) (Environmental Resources Management, “Environmental Conditions Assessment”, 2014). Please refer to Appendix G for the Environmental Condition Assessment (2013) and the updated Environmental Conditions Assessment (2014).

4. SURFACE WATER (a) Indicate the surface water present on and or adjacent to the site and alternative sites (highlight the appropriate boxes)?

Perennial River YES NO UNSURE

Non-Perennial River YES NO UNSURE

Permanent Wetland YES NO UNSURE

Seasonal Wetland YES NO UNSURE

Artificial Wetland YES NO UNSURE

Estuarine / Lagoonal wetland YES NO UNSURE

(b) Please provide a description. N/A

5. BIODIVERSITY Please note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the site and potential impact(s) of the proposed activity/ies. To assist with the identification of the biodiversity occurring on site and the ecosystem status consult http://bgis.sanbi.org or BGIShelp@sanbi.org. Information is also available on compact disc (cd) from the Biodiversity-GIS Unit, Ph. (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity information (including an indication of the habitat conditions as per (b) below) and must be provided as an overlay map to the property/site plan as Appendix D to this report.

18

(a) Highlight the applicable biodiversity planning categories of all areas on site and indicate the reason(s) provided in the

biodiversity plan for the selection of the specific area as part of the specific category).

Systematic Biodiversity Planning Category If CBA or ESA, indicate the reason(s) for its selection in biodiversity plan

Critical Biodiversity

Area (CBA)

Ecological Support

Area (ESA)

Other Natural

Area (ONA)

No Natural Area

Remaining (NNR)

The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Please refer to Appendix D: Fine Scale Biodiversity Map.

(b) Highlight and describe the habitat condition on site.

Habitat Condition

Percentage of habitat condition class (adding up

to 100%)

Description and additional Comments and Observations (Including additional insight into condition, e.g. poor land management

practises, presence of quarries, grazing/harvesting regimes etc.).

Natural Approximately

5% Please refer to description and comments below.

Near Natural (includes areas with low

to moderate level of alien invasive plants)

0% N/A

Degraded (includes areas heavily

invaded by alien plants)

0% N/A

Transformed (Includes cultivation,

dams, urban, plantation, roads, etc.)

Approximately 95%

According to the Mucina and Rutherford Vegetation Map of South Africa (2006), the site is located within the Fynbos Biome. Original natural vegetation in the area would have consisted of critically endangered Cape Flats Sand Fynbos (FFd5) with pockets of critically endangered Swartland Granite Renosterveld (FRg2) and Swartland Shale Renosterveld (FRs9). The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Please refer to Appendix D for the Original Vegetation Map, the current Land Cover Map and Fine Scale Biodiversity Map to view the site and surrounding areas in the context of the above.

(c) Complete the table to indicate:

(i) The type of vegetation, including its ecosystem status, present on the site; and (ii) Whether an aquatic ecosystem is present on site.

Terrestrial Ecosystems Aquatic Ecosystems

Ecosystem threat status as per the National

Environmental Management: Biodiversity Act (Act No. 10 of 2004)

Critical Cape Flats Sand Fynbos; Swartland Granite

Renosterveld; Swartland Shale

Renosterveld.

Wetland (including rivers, depressions, channelled

and unchanneled wetlands, flats, seeps

pans, and artificial wetlands)

Estuary Coastline Endangered

Vulnerable

Least Threatened YES NO UNSURE YES NO YES NO

19

(d) Please provide a description of the vegetation type and/or aquatic ecosystem present on site, including any important

biodiversity features/information identified on site (e.g. threatened species and special habitats) The tanks are located on Erf ST 214 at the Crammix Bricks site which located on Crammix Road, Brakenfell, Western Cape, 7561. According to the Mucina and Rutherford Vegetation Map of South Africa (2006), the site is located within the Fynbos Biome. Original natural vegetation in the area would have consisted of critically endangered Cape Flats Sand Fynbos (FFd5) with pockets of critically endangered Swartland Granite Renosterveld (FRg2) and Swartland Shale Renosterveld (FRs9). The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. There are no aquatic ecosystems present on site.

Figure 3: Map indicating the biodiversity areas located on and adjacent to the site. (image courtesy of the City of Cape Town: Biodiversity Network). Please also refer to Appendix D for the Original vegetation map as well as for the current Land Cover map to view the land cover on and around the site.

6. LAND USE OF THE SITE Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies.

Untransformed area

Low density residential

Medium density residential

High density residential Informal residential

Retail Commercial & warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting room

Military or police base/station/compound

Casino/entertainment complex

Tourism & Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or

borrow pit Dam or reservoir

Hospital/medical centre School Tertiary education facility Church Old age home

Sewage treatment plant Train station or shunting yard Railway line Major road (4 lanes or

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

20

Landfill or waste treatment site Plantation Agriculture River, stream or wetland

Nature conservation area

Mountain, koppie or ridge Museum Historical building Graveyard Archaeological site

Other land uses (describe):

Small dam on the Northern border of the site boundary.

According to the City of Cape Town’s Biodiversity Network, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site.

(a) Please provide a description. The tanks are located on Erf ST 214 at the Crammix Bricks site which is located on Crammix Road, Brakenfell, Western Cape, 7561. Buildings and infrastructure located on the site: Crammix Bricks clay brick and paver manufacturing factory which contains the following infrastructure:

o Computer controlled extruder and cutter; o Drier and Tunnel kilns; o Brick kilns cars; o Clay brick cooling and storage area;

Offices; Clay quarry; and a Small dam on the northern border of the site boundary. Please note: Whilst the above mentioned buildings and infrastructure located at the Crammix Bricks site are no longer in use, they are not part of the scope of the decommissioning. Infrastructure located on the site to be decommissioned 2 x 83m3 aboveground fuel storage tanks (Heavy Fuel Oil); 1 x 23m3 aboveground fuel storage tank (Diesel); and 1 x 14m3 underground fuel storage tank (Diesel). Please refer to Appendix A for a detailed locality map illustrating the land use of the site.

7. LAND USE CHARACTER OF SURROUNDING AREA

(a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the site.

Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies.

Untransformed area Low density residential

Medium density residential

High density residential Informal residential

Retail Commercial & warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting room

Military or police base/station/compound

Casino/entertainment complex

Tourism & Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or

borrow pit Dam or reservoir

Hospital/medical centre School Tertiary education facility Church Old age home

Sewage treatment plant Train station or shunting yard Railway line Major road (4 lanes or

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site Plantation Agriculture River, stream or wetland

Nature conservation area

Mountain, koppie or ridge Museum Historical building Graveyard Archaeological site

21

Other land uses (describe):

The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. The larger Crammix Bricks site is predominantly surrounded by residential and agricultural land uses. According to the City of Cape Town’s Biodiversity Network however, a small “CBA1B” area is located on the north-east boundary of the larger Crammix Bricks site, small “OESA” area is located on the north-west boundary of the larger Crammix Bricks site and small a “CBA1A” and an area classified as “Protected in Perpetuity” are located on the west boundary of the larger Crammix Bricks site. In addition, according to the City of Cape Town’s Biodiversity Network the Braken Nature Reserve (an area classified as “Protected in Perpetuity”) is located 500m from the larger Crammix Bricks site boundary as well as a small patch of land classified as “CBA 1E”. Please refer to Appendix A for site and locality maps as well as Appendix D for the current Land Cover map and Fine Scale Biodiversity Map to view the site and surrounding areas in the context of the above.

(b) Please provide a description, including the distance and direction to the nearest residential area and industrial area.

22

The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. Description of the Crammix Bricks site itself The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Description of the area surrounding the larger Crammix Bricks site. The following land uses occur in the immediate vicinity of the larger Crammix Bricks site: North Residential areas from the site boundary onwards. North-East A small patch of land classified by the City of Cape Town’s Biodiversity Network as “CBA1B” (from the site boundary for approximately 200- 300m). Agriculture areas from the boundary of the CBA1B area onwards. East An unnamed dam/reservoir (approximately 350m from the site boundary). Agricultural areas from the site boundary onwards. South-East Agricultural areas from the site boundary onwards. South Agricultural areas from the site boundary onwards. South-West Residential areas from the site boundary onwards. West A small patch of land classified by the City of Cape Town’s Biodiversity Network as “CBA1A” (from the site boundary for approximately 150m). A small patch of land classified by the City of Cape Town’s Biodiversity network as a “Protected in Perpetuity” adjacent to the CBA1A to the north also stretching for approximately 150m. Residential areas from the boundary of this CBA1A and Conservation areas onwards. North-West A small area classified by the City of Cape Town’s Biodiversity Network as an “OESA” area is located on the most north-west boundary of the site and stretches for approximately 500m. Residential areas are located both above and below the OESA area from the site boundary onwards. According to the City of Cape Town’s Biodiversity Network the Braken Nature Reserve (an area classified as “Protected in Perpetuity”) is located 500m from the site boundary along the boundary of the residential areas. In addition, according to the City of Cape Town’s Biodiversity Network, adjacent to the Braken Nature Reserve to the north there is also a small patch of land classified as “CBA 1E”. Please also refer to Appendix C for photographs of the site and its surroundings and Appendix D for a Land Cover map illustrating the land use of the site and the surrounding areas as well as a Fine Scale Map indicating the biodiversity features identified on the northern portion of the site and adjacent to the site.

23

8. SOCIO-ECONOMIC ASPECTS Describe the existing social and economic characteristics of the community in order to provide baseline information. Please note: Socio-economic data has been taken from the following source: City of Cape Town 2011 Census, Suburb: Brakenfell (July 2011) http://www.capetown.gov.za/en/stats/2011CensusSuburbs/2011_Census_CT_Suburb_Brackenfell_Profile.pdf

Figure 4: Map depicting the range of the census July, 2011 (Image courtesy of the City of Cape Town Strategic Development Information and GIS Department, July 2013). Available from: http://www.capetown.gov.za/en/stats/2011CensusSuburbs/2011_Census_CT_Suburb_Brackenfell_Profile.pdf

24

Demographic Profile Racial Profile

Brakenfell Population Male Female Total Num % Num % Num %

Black African 2 255 4.2 2 567 4.8 4 822 9.1 Coloured 6 645 12.5 7 155 13.5 13 800 25.9 Asian 192 0.4 173 0.3 365 0.7 White 16 187 30.4 17 308 32.5 33 495 63 Other 375 0.7 329 0.6 704 1.3 Total 25 654 48.2 27 532 51.8 53 186 100

Age Profile

Brakenfell Age

Black African Coloured Asian White Other Total Num % Num % Num % Num % Num % Num %

0 to 4 499 10.4 1 084 7.9 21 5.8 2 170 6.5 81 11.5 3 855 7.2 5 to 14 565 11.7 1 905 13.8 38 10.5 3 620 10.8 87 12.4 6 215 11.7 15 to 24 753 15.6 2 326 16.9 68 18.7 3 960 11.8 99 14.1 7 206 13.6 25 to 64 2 796 58 7 912 57.3 229 63.1 20

410 60.9 401 57.1 31

748 59.7

65 years + 208 4.3 573 4.2 7 1.9 3 333 10.0 34 4.8 4 155 7.8 Total 4 821 100 13

800 100 363 100 33

493 100 702 100 53

179 100

Education Profile

Brakenfell Adult Education

Black African Coloured Asian White Other Total Num % Num % Num % Num % Num % Num %

No Schooling 18 0.5 51 0.5 0 0.0 48 0.2 9 1.8 126 0.3 Some primary

42 1.2 306 3.2 3 1.1 165 0.6 18 3.7 534 1.3

Completed primary

27 0.8 210 2.2 3 1.1 93 0.4 3 0.6 336 0.8

Some secondary

354 10.5 2 679 27.7 27 9.9 4 233 16.4 72 14.6 7 365 18.6

Grade 12 1 113 33.0 3 630 37.6 117 42.9 11 760

45.6 219 44.5 16 839

42.5

Higher 1 782 52.8 2 733 28.3 123 45.1 9 318 36.1 168 32.1 14 124

35.7

Other 39 1.2 57 0.6 0 0.0 192 0.7 3 0.6 291 0.7 Total 3 375 100 9 666 100 273 100 25

809 100 492 100 36

615 100

25

Economic Profile Employment Rates

Brakenfell Labour Force Indicators

Black African Coloured Asian White Other Total

Population aged 15 to 64

3 549 10 236 300 24 372 495 38 952

Labour Force 2 772 7 449 222 19 248 357 30 048 Employed 2 526 6 720 204 18 468 315 28 233 Unemployed 246 729 18 780 42 1 815 Unemployment rate

8.87% 9.79% 8.11% 4.05% 11.76% 6.04%

Monthly Household Income

Brakenfell Monthly Household Income

Black African Coloured Asian White Other Total Num % Num % Num % Num % Num % Num %

No Income 183 10.9 282 7.5 18 15.8 1 068 8.6 24 14.5 1 575 8.7 R1- 1600 72 4.3 156 4.2 3 2.6 351 2.8 9 5.5 591 3.3 R1601- 3200 66 3.9 180 4.8 0 0.0 351 2.8 12 7.3 609 3.4 R3201- 6400 120 7.2 252 6.7 6 5.3 942 7.6 15 9.1 1 335 7.4 R6401- 12800 234 14.0 633 16.9 15 13.2 2 076 16.7 33 20.0 2 991 16.5 R12801- 25600 489 29.2 1 119 29.9 36 31.6 3 333 26.8 27 16.5 5 004 27.6 R25601- 51200 363 21.6 843 22.5 24 21.1 3 123 25.2 30 18.2 4 383 24.3 R51201- 102400

111 6.6 213 5.7 9 7.0 936 7.5 6 3.6 1 275 7.0

R102401 and more

39 2.3 63 1.7 3 2.6 237 1.9 9 5.5 351 1.9

Unspecified 0 0 0 0 0 0 0 0 0 0 0 0 Total 1 677 100 3 741 100 114 100 12

417 100 165 100 100

Dwelling Profile Dwelling Type

Type of Dwelling

Black African Coloured Asian White Other Total Num % Num % Num % Num % Num % Num %

Formal Dwelling

1 644 98.4 3 709 99 106 98.1 12 334

99.3 157 98.1 17 950

99.1

Informal Dwelling/ Shack in Backyard

5 0.3 12 0.3 0 0 11 0.1 1 0.6 29 0.2

Informal Dwelling/Shack NOT in Backyard

5 0.3 9 0.2 0 0 26 0.2 1 0.6 41 0.2

Other 16 1.0 15 0.4 2 1.9 52 0.4 1 0.6 86 0.5 Total 1 670 100 3 745 100 100 12

423 100 160 100 18

106 100

Tenure Status

Tenure Status Black African Coloured Asian White Other Total Num % Num % Num % Num % Num % Num %

Owned and Paid Off

167 10.0 862 23.0 16 14.7 2 626 21.1 23 14.3 3 694 20.4

Owned and Not Paid Off

427 25.6 1 922 51.3 48 44.0 5 656 45.5 55 34.2 8 108 44.8

Rented 1 043 62.4 879 23.5 44 40.4 3 924 31.6 79 49.1 5 969 33.0 Occupied Rent-Free

25 1.5 62 1.7 1 0.9 122 1.0 2 1.2 212 1.2

Other 9 0.5 20 0.5 0 0.9 94 0.8 2 1.2 125 0.7 Total 1 671 100 3 745 100 109 100 12

422 100 161 100 18

108 100

26

9. HISTORICAL AND CULTURAL ASPECTS (a) Please be advised that if section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999), is applicable to your

proposed development, then you are requested to furnish this Department with written comment from Heritage Western Cape as part of your public participation process. Section 38 of the Act states as follows: “38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as-

(a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length;

(b) the construction of a bridge or similar structure exceeding 50m in length; I any development or other activity which will change the character of a site- (i) exceeding 5 000 m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources

authority; (d) the re-zoning of a site exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources

authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.”

(b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section 3(2)

(i)(vi) and (vii), of the National Heritage Resources Act, 1999 (Act No. 25 of 1999), must also be investigated, assessed and evaluated. Section 3(2) states as follows: “3(2) Without limiting the generality of subsection (1), the national estate may include—

(a) places, buildings, structures and equipment of cultural significance; (b) places to which oral traditions are attached or which are associated with living heritage; I historical settlements and townscapes; (d) landscapes and natural features of cultural significance; (e) geological sites of scientific or cultural importance; (f) archaeological and paleontological sites; (g) graves and burial grounds, including— (i) ancestral graves; (ii) royal graves and graves of traditional leaders; (iii) graves of victims of conflict; (iv) graves of individuals designated by the Minister by notice in the Gazette; (v) historical graves and cemeteries; and (vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983); (h) sites of significance relating to the history of slavery in South Africa; (i) movable objects, including— (i) objects recovered from the soil or waters of South Africa, including archaeological and paleontological objects and material, meteorites and rare geological specimens; (ii) objects to which oral traditions are attached or which are associated with living heritage; (iii) ethnographic art and objects; (iv) military objects; (v) objects of decorative or fine art; (vi) objects of scientific or technological interest; and (vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996).”

Is section 38 of the National Heritage Resources Act, 1999, applicable to the development? YES NO

UNCERTAIN

If YES, explain:

Will the development impact on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999?

YES NO

UNCERTAIN

If YES, explain:

Will any building or structure older than 60 years be affected in any way? YES NO UNCERTAIN

If YES, explain:

Please Note: If uncertain, the Department may request that specialist input be provided.

27

10. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

(a) Please list all legislation, policies and/or guidelines that have been considered in the preparation of this Basic Assessment

Report.

LEGISLATION ADMINISTERING AUTHORITY

TYPE Permit/ license/

authorisation/comment / relevant consideration (e.g. rezoning or

consent use, building plan approval)

DATE (if already obtained):

National Environmental Management Act, No 107 of 1998 (NEMA)

DEA&DP Environmental Authorisation Pending

Regulations 543, 544 and 546 in terms of Chapter 5 of the NEMA 1998 (as amended)

DEA&DP Environmental Authorisation Pending

National Environmental Management Waste Act, No 59 of 2008 (NEMWA)

DEA None Needed N/A

POLICY/ GUIDELINES ADMINISTERING AUTHORITY

Guideline Document, EIA Regulations, Implementation of Sections 21, 22 and 26 of the Environment Conservation Act. DEA

DEA Integrated Environmental Management Guideline Series, Guideline 3: General Guide to the Environmental Impact Assessment Regulations, 2006,

DEA

DEA Integrated Environmental Management Guideline Series, Guideline 4: Public Participation in support of the Environmental Impact Assessment Regulations, 2006,

DEA

DEA Integrated Environmental Management Guideline Series, Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, 2006

DEA

DEA Companion to the NEMA EIA Regulations of 2010 DEA DEA Integrated Environmental Management Guideline Series, Guideline 5: Companion to the Environmental Impact Assessment Regulations, 2012

DEA

DEA&DP Guideline Document: Guideline on Alternatives, March 2013 DEA&DP DEA&DP Guideline Document: Guideline on Public Participation, March 2013 DEA&DP

DEA&DP Guideline Document: Guideline on Need and Desirability, March 2013 DEA&DP

DEA&DP Guideline for determining the scope of specialist involvement in the EIA process, June 2005 DEA&DP

DEA&DP Guideline for the review of specialist input in the EIA process, June 2005 DEA&DP

The Provincial Urban Edge Guideline, December 2005 DEA&DP The Western Cape Provincial Spatial Development Framework (PSDF), November (2009) DEA&DP

(b) Please describe how the legislation, policies and/or guidelines were taken into account in the preparation of this Basic

Assessment Report. LEGISLATION / POLICY / GUIDELINE DESCRIBE HOW THE LEGISLATION / POLICY / GUIDELINE WERE TAKEN INTO ACCOUNT

(e.g. Describe the extent to which it was adhered to, or deviated from, etc.). The National Environmental Management Act, Act 107 of 1998, as amended.

The National Environmental Management Principles contained in Chapter 1 of the Act are the principles against which the need and desirability of the development has been investigated.

DEA Integrated Environmental Management Guideline Series, Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, 2006

This guideline was consulted during the impact assessment phase of the Basic Assessment and guided the impact assessment criteria and methodology used.

DEA&DP Guideline Document: Guideline on Public Participation, March 2013

The public participation requirements contained in Chapter 6 of the NEMA EIA Regulations were interpreted in conjunction with the recommendations contained in this guideline.

28

DEADP Guideline Document: Guideline on Alternatives, March 2013

The investigation and / or assessment of alternatives, including the No-Go Option, were guided by this guideline.

DEA&DP Guideline Document: Guideline on Need and Desirability, March 2013

The investigation into the Need and Desirability of the development was guided by this guideline.

The Provincial Urban Edge Guideline, December 2005

The investigation into the appropriateness of the development given the receiving environment was guided by this document.

The Western Cape Provincial 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 development.

DEA (2010) Companion to the EIA Regulations 2010, Integrated Environmental Management Guideline Series 5, Department of Environmental Affairs

The NEMA EIA Regulations relevant to this application were interpreted with the assistance of this guideline documents.

Please note: Copies of any permit(s) or licences received from any other organ of state must be attached this report as Appendix E.

29

SECTION C: PUBLIC PARTICIPATION

The public participation process must fulfil the requirements outlined in NEMA, the EIA Regulations, and if applicable the NEM:

WA and/or the NEM: AQA. This Department’s Guideline on Public Participation (August 2010) and Guideline on Exemption

Applications (August 2010), both of which are available on the Department’s website (http://www.capegateway.gov.za/eadp),

must also be taken into account.

Please highlight the appropriate box to indicate whether the specific requirement was undertaken or whether there was a

deviation that was agreed to by the Department.

1. Were all potential interested and affected parties notified of the application by –

(a) fixing a notice board at a place conspicuous to the public at the boundary or on the fence of -

(i) the site where the activity to which the application relates is to be undertaken; and YES DEVIATED

(ii) any alternative site mentioned in the application; N/A Alternative property/location sites were not investigated for the purposes of this application as the proposed activity will comprise the decommissioning of 4 fuel tanks located at Crammix Bricks located on Erf ST 214, Crammix Road, Brakenfell, Western Cape, 7561. Thus no property/location site alternatives were investigated as this would not meet the general purpose and requirements of this application.

YES DEVIATED

(b) giving written notice to – (i) the owner or person in control of that land if the applicant is not the owner or person in control of the land;

YES N/A

(ii) the occupiers of the site where the activity is to be undertaken and to any alternative site where the activity is to be undertaken;

YES DEVIATED

(iii) owners and occupiers of land adjacent to the site where the activity is to be undertaken and to any alternative site where the activity is to be undertaken;

YES DEVIATED

(iv) the municipal councillor of the ward in which the site and alternative site is situated and any organisation of ratepayers that represent the community in the area;

YES DEVIATED

(v) the municipality which has jurisdiction in the area; YES DEVIATED

(vi) any organ of state having jurisdiction in respect of any aspect of the activity; and YES DEVIATED

(vii) any other party as required by the competent authority; YES DEVIATED

I placing an advertisement in -

(i) one* local newspaper; and YES DEVIATED

(ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

YE S DEVIATED N/A

(d) placing an advertisement in at least one* provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken.

YE S DEVIATED N/A

* Please note: In terms of the NEM: WA and NEM: AQA a notice must be placed in at least two newspapers circulating in the

area in which the activity applied for is to be carried out.

2. Provide a list of all the state departments that were consulted:

Department of Environmental Affairs and Development Planning: Land Management (Region 1) Bernadette Osborne Registry Office 1st Floor Utilitas Building 1 Dorp Street Cape Town Private Bag X9086 Cape Town 8000 Tel: 021 483 4793 Fax: 021 483 3633 Email: Bernadette.Osborne@westerncape.gov.za

30

Department of Environmental Affairs: Pollution Management Catherine Bill Registry Office 1st Floor Utilitas Building 1 Dorp Street Cape Town 8000 Tel: 021 483 2760 Fax: 021 483 3254 Email: cbill@pgwc.gov.za

Department of Water Affairs Derril Daniels 52 Voortrekker Road Bellville 7532 Private Bag X16 Sanlamhof 7532 Tel: 021 941 6000 Fax: 021 941 6107 Email: danielsd@dwaf.gov.za

Department of Agriculture Joyene Isaacs Department of Agriculture: Western Cape Private Bag X1 Elsenburg 7607 Tel: 021 808 5005 Fax: 021 808 5000 Email: Info@elsenburg.com

City of Cape Town Municipality: Environmental Resource Management Branch (District C) Pat Titmuss PO Box 5 Milnerton 7535 Tel: 021 444 0597 Fax: 021 444 0605 Cell: 083 701 4318 Email: Pat.Titmus@capetown.gov.za

Stellenbosch Municipality Schalk Van De Merwe Stellenbosch Municipality Plein Street Stellenbosch 7600 PO Box 17 Stellenbosch 7600 Tel: 021 808 8679 Fax: 021 886 6899 Email: schalk.vandemerwe@stellenbosch.gov.za

31

3. Please provide an overall summary of the Public Participation Process that was followed. (The detailed outcomes of this process must be included in a comments and response report to be attached to the final Basic Assessment Report (see note below) as Appendix F).

Public Participation Process A public participation process is required in order to fulfil the requirements of a Basic Assessment process. The public participation process needs to be undertaken in accordance with the 2010 NEMA EIA Regulations. The following activities have been undertaken thus far: Initial and Draft Basic Assessment Report Notification Identified interested and affected parties as well as Organs of State were notified of the Basic Assessment process and at the same time notified of the availability of the Draft Basic Assessment (Draft BAR) report for review and comment on 23rd July 2014. The following parties were notified of the availability of the Draft BAR: DEA&DP: Land Management (Region1) DEA&DP: Pollution Management Department of Water Affairs Department of Agriculture City of Cape Town Municipality (District C) Stellenbosch Municipality Municipal Ward Councillor Ratepayer’s Associations Relevant NGO’s Landowner Landowners and occupants of properties adjacent to the site In addition to this, a newspaper advertisement was published in the Tygerburger local newspaper on 23rd July 2014; site notices were placed at the site on the 22nd July; and the Draft BAR was placed at the local Brakenfell Public Library on the 21st July 2014. The Draft BAR was also made available on the SEC website for review and comment between the 21st July 2014 and 1st September 2014. All registered stakeholders were given the opportunity to review and comment on the Draft BAR for a period of 40 days between 23rd July and 1st September 2014. Comments received and responses sent during the public comment period for the Draft BAR have been recorded in a Comments and Responses Report. In addition, all issues raised during this period have been included in the Final BAR (this report) for review by all registered stakeholders and for submission to the DEA&DP. The following activities will be undertaken from this point forward: Final Basic Assessment Report Notification: The Final BAR (this report) includes the comments, issues and concerns raised by registered stakeholders during the Draft BAR phase public participation process and is now made available for public comment for a period of 21 days. Comments received and responses sent during the public comment period for the Final BAR will be recorded in an updated Comments and Responses Report. This, along with copies of all comments received and responses sent, will be included in the Final BAR submission when it is submitted to the DEA&DP for a decision. Please refer to Appendix F for a full record of the public participation process undertaken to date.

Spatial Planning: Kraaifontein Gerrit Fourie Parow Civic Centre Cnr. Talent Str & Voortrekker Rd Parow Tel: 021 444 8874 Cell: 074 580 3550 Email: Gerrit.Fourie2@capetown.gov.za

Heritage Western Cape Andrew Hall (Executive Officer) Protea Assurance Building Green Market Square Cape Town 8000 Tel: 021 483 9543 Fax: 021 483 9842 Email: hwc@pgwc.gov.za

32

Please note: Should any of the responses be “No” and no deviation or exemption from that requirement was requested and agreed to /granted by the Department, the Basic Assessment Report will be rejected. A list of all the potential interested and affected parties, including the organs of State, notified and a list of all the register of interested and affected parties must be submitted with the final Basic Assessment Report. The list of registered interested and affected parties must be opened, maintained and made available to any person requesting access to the register in writing.

The draft Basic Assessment Report must be submitted to the Department before it is made available to interested and affected parties, including the relevant organs of State and State departments which have jurisdiction with regard to any aspect of the activity, for a 40-day commenting period. With regard to State departments, the 40-day period commences the day after the date on which the Department as the competent/licensing authority requests such State department in writing to submit comment. The applicant/EAP is therefore required to inform this Department in writing when the draft Basic Assessment Report will be made available to the relevant State departments for comment. Upon receipt of the Draft Basic Assessment Report and this confirmation, this Department will in accordance with Section 24O (2) and (3) of the NEMA request the relevant State departments to comment on the draft report within 40 days.

All comments of interested and affected parties on the draft Basic Assessment Report must be recorded, responded to and included in the Comments and Responses Report included as Appendix F to the final Basic Assessment Report. If necessary, any amendments in response to comments received must be effected in the Basic Assessment Report itself. The Comments and Responses Report must also include a description of the public participation process followed.

The final Basic Assessment Report must be made available to registered interested and affected parties for comment before submitting it to the Department for consideration. Unless otherwise indicated by the Department, a final Basic Assessment Report must be made available to the registered interested and affected parties for comment for a minimum of 21-days. Comments on the final Basic Assessment Report does not have to be responded to, but the comments must be attached to the final Basic Assessment Report.

The minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants must also be submitted as part of the public participation information to be attached to the final Basic Assessment Report as Appendix F.

Proof of all the notices given as indicated, as well as of notice to the interested and affected parties of the availability of the draft Basic Assessment Report and final Basic Assessment Report must be submitted as part of the public participation information to be attached to the final Basic Assessment Report as Appendix F.

33

SECTION D: NEED AND DESIRABILITY Please Note: Before completing this section, first consult this Department’s Guideline on Need and Desirability (August 2010) available on the Department’s website (http://www.capegateway.gov.za/eadp).

1. Is the activity permitted in terms of the property’s existing land use rights? YES NO Please explain Historically, Heavy Fuel Oil on site was used to fire the kilns for the brick vitrification process. Diesel was used for re-fuelling trucks to undertake a combination of clay mining and transport, earthmoving and quarry rehabilitation and dispatch of finished goods. The Spatial Planner for the District at the City of Cape Town, Mr Gerrit Fourie, confirmed in an email dated 17th June 2014 that the site is currently zoned Agricultural in terms of the new City of Cape Town zoning scheme which came into effect in March 2013. Whilst the land use does not conform to the new zoning scheme, the use is only considered a non-conforming use in that it did conform to the previous old zoning scheme. As such, the land use is legal in terms of the previous legislation. Mr Gerrit Fourie, confirmed in a telecom dated 30th September 2014 that the site will most likely be re-zoned for residential and commercial purposes. As a result of the site being scheduled for rezoning in the future, the factory permanently closed down in December 2013 and the property is to be sold. The activity applied for is the decommissioning of the fuel tanks. The City of Cape Town: Spatial Planning has confirmed in an email dated 17th June 2014 that it does not object to the decommissioning of the fuel tanks.

2. Will the activity be in line with the following? (a) Provincial Spatial Development Framework (PSDF) YES NO Please explain The proposed activity entails the decommissioning of fuel tanks on a long-developed site which is situated within the urban edge. As such the principles of the PSDF would not be contravened in any way. (b) Urban edge / Edge of Built environment for the area YES NO Please explain The site is located within the urban edge. (c) Integrated Development Plan and Spatial Development Framework of the

Local Municipality (e.g. would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF?).

YES NO Please explain

The proposed activity is not in conflict with the local IDP and SDP of the Local Municipality as the proposed activity entails the decommissioning of fuel tanks located on a long-developed site. (d) Approved Structure Plan of the Municipality YES NO Please explain The activity applied for is for the decommissioning of the fuel tanks at Crammix Bricks. The City of Cape Town: Spatial Planning has confirmed in an email dated 17th June 2014 that it does not object to the decommissioning of the fuel tanks. In light of this, the proposed activity cannot be considered contrary to the spatial planning imperatives contained in any structure plans which pertain to the area. (e) An Environmental Management Framework (EMF) adopted by the Department (e.g. Would the approval of this application compromise the integrity of the existing environmental management priorities for the area and if so, can it be justified in terms of sustainability considerations?)

YES NO Please explain

The proposed activity is not in conflict with the City’s EMF adopted by the Department as the proposed activity entails the decommissioning of fuel tanks located on a long-developed site. (f) Any other Plans (e.g. Guide Plan) YES NO Please explain The proposed activity entails the decommissioning of fuel tanks located on a long-developed site. At this stage, no further developments are proposed to take place and no other plans apply.

3. Is the land use (associated with the activity being applied for) considered within the timeframe intended by the existing approved Spatial Development Framework (SDF) agreed to by the relevant environmental authority (i.e. is the proposed development in line with the projects and programmes identified as priorities within the credible IDP)?

YES NO Please explain

Not applicable as the decommissioning of the fuel tanks located at Crammix Bricks is a once off activity only.

4. Should development, or if applicable, expansion of the town/area concerned in terms of this land use (associated with the activity being applied for) occur here at this point in time?

YES NO Please explain

Not applicable as the proposed activity is for the once-off decommissioning of the fuel tanks located at Crammix Bricks.

34

5. Does the community/area need the activity and the associated land use concerned (is it a societal priority)? (This refers to the strategic as well as local level (e.g. development is a national priority, but within a specific local context it could be inappropriate.)

YES NO Please explain

The community does not specifically need the proposed activity to go ahead. Should the proposed activity not go ahead however, it could result in both an increasing environmental risk with time associated with the potential tank failure. There is also a potential loss of revenue for the landowner as a result of not being able to utilise that portion of the site for any other purpose. As such, it can be suggested that the interests of the community are served with the decommissioning of the fuel tanks.

6. Are the necessary services with adequate capacity currently available (at the time of application), or must additional capacity be created to cater for the development? (Confirmation by the relevant Municipality in this regard must be attached to the final Basic Assessment Report as Appendix E.)

YES NO Please explain

No additional services are required for the proposed activity. All services required for the proposed decommissioning activities are currently in place.

7. Is this development provided for in the infrastructure planning of the municipality, and if not what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)? (Comment by the relevant Municipality in this regard must be attached to the final Basic Assessment Report as Appendix E.)

YES NO Please explain

Not applicable as the proposed activity is for the once-off decommissioning of fuel tanks at Crammix Bricks. All infrastructure required for the proposed decommissioning activities are currently in place.

8. Is this project part of a national programme to address an issue of national concern or importance? YES NO Please explain

The tank decommissioning is for one site only and as such is not linked to any part of a national programme to address an issue of national concern or importance.

9. Do location factors favour this land use (associated with the activity applied for) at this place? (This relates to the contextualisation of the proposed land use on this site within its broader context.)

YES NO Please explain

N/A The proposed activity is for the decommissioning of fuel tanks at Crammix Bricks.

10. How will the activity or the land use associated with the activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

YES NO Please explain

Sensitive Natural Areas The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. According to the Mucina and Rutherford Vegetation Map of South Africa (2006), the site is located within the Fynbos Biome. Original natural vegetation in the area would have consisted of critically endangered Cape Flats Sand Fynbos (FFd5) with pockets of critically endangered Swartland Granite Renosterveld (FRg2) and Swartland Shale Renosterveld (FRs9). The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). On the north-west portion of the site however, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the City of Cape Town’s Biodiversity Network as “CBA1A”. These remnants however, shouldn’t be affected by the proposed decommissioning activities as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Cultural areas: There are no sensitive cultural or historical aspects directly on the site which can or will be impacted by the proposed activity as the site is not on any land of any cultural significance.

11. How will the development impact on people’s health and wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc.)? YES NO Please explain

There will be a temporary increase in noise, dust, fuel vapour emissions and vibration in the immediate vicinity of the site due to the construction-type nature of the tank decommissioning activities. Due to the distance of the residential and agricultural areas in relation to the site however, these impacts, are anticipated to be low.

35

(17) Please describe how the general objectives of Integrated Environmental Management as set out in section 23 of NEMA have been taken into account: The general objectives of Integrated Environmental Management as set out in section 23 of NEMA: The manner in which these objectives have been taken into account is as follows: Compliance with and integration of the principles of environmental management is addressed in the following section

(Section 18 below). All the actual and potential impacts on the environment, socio-economic conditions and cultural heritage, the risks and

consequences and alternatives and options for mitigation of activities, with a view to minimizing negative impacts, maximizing benefits have been identified, predicted and evaluated (see Section F of this report).

Public participation has been adequate and an appropriate opportunity has been afforded for public participation in decisions that may affect the environment. The local community and Organs of State having jurisdiction over the proposed activity have been given an opportunity to participate (see Appendix F for details).

12. Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs? YES NO Please explain

The proposed activity will not result in any unacceptable opportunity costs. Should the proposed activity not occur however, it would result in both an increasing environmental risk with time associated with the potential tank failure as well as loss of potential revenue for the landowner or future landowner as a result of not being able to utilise that portion of the site for any other purpose.

13. What will the cumulative impacts (positive and negative) of the proposed land use associated with the activity applied for, be? YES NO Please explain

The proposed decommissioning of the fuel storage tanks located at Crammix Bricks has the potential to have the following cumulative impacts: Negative Cumulative Impacts A temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the tank

decommissioning activities. A temporary increase in emissions (due to tank degassing procedures). A temporary increase in noise. A temporary increase in the amount of heavy traffic due to the construction-type nature of the decommissioning

activities.

Please note that these negative impacts are considered to be cumulative due to the surrounding land use (dust from the surrounding agricultural activities, emissions from traffic on the M23 and the dense road network surrounding the site, noise from traffic and the adjacent agricultural activities, traffic as a result the existing traffic flow in the area. Positive Cumulative Impacts The creation of temporary employment opportunities during the tank decommissioning activities. Please note that the positive impact is considered cumulative due to the surrounding land use being a source of additional employment in terms of work on the agricultural land (farm labourers and managers) as well as in the residential areas. Please refer to Section F of this report for a detailed investigation and assessment of the above mentioned impacts.

14. Is the development the best practicable environmental option for this land/site? YES NO Please explain

Should the proposed activity not occur, it would result in both an increasing environmental risk with time associated with the potential tank failure as well as loss of potential revenue for the landowner as a result of not being able to utilise that portion of the site for any other purpose. It has been determined that the potential negative impacts associated with the proposed activity can all be mitigated to an acceptable level. In addition, the positive impacts of the proposed tank decommissioning are of higher significance than any benefits associated with the No-Go Alternative. As such, the proposed activity can be considered the best practible environmental option for the site.

15. What will the benefits be to society in general and to the local communities? Please explain The proposed activity does not have any direct benefits to society in general or the local community (in terms of long term employment or new service provision, for example). It is however in the interests of the community that the fuel tanks are decommissioned as when they are no longer in use they will not be monitored or maintained. As such should the fuel tanks be decommissioned, it would result in a decrease in environmental risk with time associated with the potential tank failure as a result of leaving the tanks in place.

16. Any other need and desirability considerations related to the proposed activity? Please explain There are no additional need and desirability considerations related to the proposed activity.

36

(18) Please describe how the principles of environmental management as set out in section 2 of NEMA have been taken into account: The investigation of the tank decommissioning and its associated impacts has considered the benefits of the decommissioning for the receiving social, economic and biophysical environment; as well as the harms that may result to the environment as a result of the decommissioning. The impacts of the tank decommissioning on the receiving environment have been considered without favouring any particular aspect of the receiving environment over another aspect; nor favouring any particular community comprising those affected by the proposed decommissioning. All interested and affected parties identified as possibly impacted (or benefited) by the development have been given the opportunity to participate in the Basic Assessment process through the public participation activities undertaken in accordance with Chapter 6 of the NEMA EIA Regulations contained in GN No. R543 of 2010. The identification of any possible negative environmental impacts associated with the site decommissioning has led to the recommendation of a suite of mitigation measures to either avoid any such impacts altogether; or to ensure that such impacts remain at an acceptable level without adversely impacting the environment as people’s common heritage. Lastly, the suite of mitigation measures recommended for implementation during the decommissioning of the tanks, are considered by the EAP to represent the best practicable environmental option for land use at the site.

37

SECTION E: ALTERNATIVES Please Note: Before completing this section, first consult this Department’s Guideline on Alternatives (August 2010) available on the Department’s website (http://www.capegateway.gov.za/eadp). “Alternatives”, in relation to a proposed activity, means different means of meeting the general purposes and requirements of the activity, which may include alternatives to –

(a) the property on which, or location where, it is proposed to undertake the activity; (b) the type of activity to be undertaken; I the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity.

The NEMA prescribes that the procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment must, inter alia, with respect to every application for environmental authorisation –

ensure that the general objectives of integrated environmental management laid down in NEMA and the National Environmental Management Principles set out in NEMA are taken into account; and

include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment and assessment of the significance of those potential consequences or impacts, including the option of not implementing the activity.

The general objective of integrated environmental management is, inter alia, to “identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance with the principles of environmental management” set out in NEMA. 1. In the sections below, please provide a description of any identified and considered alternatives and alternatives that

were found to be feasible and reasonable. Please note: Detailed written proof the investigation of alternatives must be provided and motivation if no reasonable or feasible alternatives exist.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: Alternative property/location site alternatives were not investigated for the purposes of this application as the proposed activity will comprise the decommissioning of fuel tanks located at Crammix Bricks located on Erf ST 214, Crammix Road, Brakenfell, Western Cape, 7561. Thus no property/location site alternatives were investigated or assessed as this would not meet the general purpose and requirements of this application. (b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: No activity alternatives were investigated as this would not meet the general purpose of this application. The proposed activity is considered the best environmental option for the site as not only are the tanks now inactive, but leaving the ageing, unmonitored / unmaintained tanks in place increases the risk of potential tank failure and subsequent soil and groundwater contamination. (c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts, or detailed motivation if no reasonable or feasible alternatives exist: Design or layout alternatives are not considered applicable, as the general purpose of this application is a once off activity to decommission 4 fuel tanks located at Crammix Bricks located on Erf ST 214, Crammix Road, Brakenfell, Western Cape, 7561. As such, design and layout alternatives are not considered applicable for this application and were not investigated or assessed. (d) Technology alternatives (e.g. to reduce resource demand and resource use efficiency) to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

38

Technology alternatives were not considered applicable as the general purpose of the application is a once off decommissioning of 4 fuel tanks located at Crammix Bricks located on Erf ST 214, Crammix Road, Brakenfell, Western Cape, 7561. As such, the nature of the proposed activity is such that the process has associated impacts. Therefore only process alternatives have been investigated for this site. (e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: Operational alternatives were not considered applicable as the general purpose of the activity is a once-off decommissioning of 4 fuel storage tanks at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. As such, the nature of the proposed activity is such that the process has associated impacts. Therefore only process alternatives have been investigated for this site. (f) the option of not implementing the activity (the No-Go Option): The No-Go option was investigated as required by the principles of NEMA. The No- Go Alternative means “the option of not implementing the activity”, i.e. not decommissioning the 4 fuel tanks located at Crammix Bricks. As such the 4 fuel tanks would remain in place and the portion of the site where the tanks are located would not be able to be utilised for any alternative purposes. Positive impacts of the No-Go Option: There will be no temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of

the decommissioning activities not commencing. There will be no temporary increase in noise with the potential to disrupt concentration from the site due to the

construction-type nature of the decommissioning activities not commencing. There will be no temporary increase in the amount of heavy traffic at the site due to the construction-type nature of the

decommissioning activities due to the construction-type nature of the decommissioning activities not commencing. As the decommissioning will not occur, there will be no risk of incorrectly undertaken degassing and decommissioning.

Incorrect procedures could lead to an increased environmental risk of soil and groundwater contamination which in turn could have associated human health risks (respiratory system irritation through vapour inhalation; irritation through dermal contact; etc.).

If the tank degassing and decommissioning is undertaken incorrectly, there is an associated risk of fire and explosion. With the No-Go alternative, this risk is quite minimal.

Negative Impacts of the No-Go Option: There will be no permanent removal of potential health, safety and environmental risks associated with ageing,

unmaintained tanks situated at the site. There will be no creation of temporary employment opportunities during the decommissioning activities The landowner will not be able to utilise that portion of the site for any other purpose. The No-Go Alternative is not considered to be a reasonable and feasible alternative for this site and this alternative is not preferred by the EAP. (g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: The nature of tank degassing and decommissioning activities is such that the process (or operational procedures to be undertaken during the degassing and decommissioning) has associated impacts. Process alternatives (or “operational” alternatives for the site decommissioning) were therefore identified and assessed as follows: Process alternatives The proposed activity will comprise the once-off decommissioning of 4 fuel storage tanks and associated infrastructure at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The decommissioning process needs to take place in a specific manner in order to minimise the associated health and safety and environmental risks associated with works on fuel storage and handling infrastructure. The decommissioning process has been informed by oil industry investigation and experience over a number of years, which has yielded the following best-practice or “preferred” decommissioning protocol: Preferred / best practice process alternatives for tank decommissioning: The two main aspects of the tank decommissioning process entail (1) making the tank safe for decommissioning, which includes tank purging and degassing; and (2) the physical removal of the tanks: 1) Tank Purging and Degassing The tank purging and degassing process will follow the method statement contained in Appendix H. This includes aspects such as: Draining the fuel lines. Venting the tanks and testing the tank manhole area to ensure that any vapours are below levels that pose a health and

safety risk (toxic via inhalation, or explosive) and that oxygen levels are acceptably high.

39

Emptying any remaining product from the tanks into appropriately sealable metal drums. The tanks are degassed by a method of introducing nitrogen into the tanks under vacuum conditions. Continuous gas

testing of the work area is required to prevent asphyxiation as a result of the N2 displacing the oxygen in the area. Should the tank shows signs of collapse or implosion during the vacuum process, work is to be stopped immediately. Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site

prior to the degassing process; workers performing the degassing must wear appropriate PPE and stand up wind from the operation and if required wear respirators with organic vapour cartridges; and that the pump to be used for the emptying of the tank must be flame proof.

2) Tank Decommissioning and Disposal The decommissioning and disposal of the aboveground fuel storage tank will comply with the American Petroleum

Industry’s (API) standard 1604 relating to the closure of aboveground petroleum storage tanks. The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and

removed from site. All sludge, remaining product, contaminated water etc., which is a by-product of the above, shall be collected and removed off site and disposed of at a licensed landfill site or recycled. Chain-of-custody documentation for safe disposal will be included in the site closure audit report to be submitted to the relevant authorities.

Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the following: Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-

fabrication off site. The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to

minimise fire risk. Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process

Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and environmental risk at the site.

The tanks will be removed from site once they have been drained and degassed. The aboveground tanks will either be removed to the contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

With the disposal of fuel product slops and any sludge and contaminated water, all of which is hazardous waste, the relevant waste policies and protocols (such as the Waste Classification and Management Regulations) need to be adhered to. Otherwise, the associated risk of soil and groundwater contamination if the hazardous waste is handled, transported and disposed of incorrectly, is unacceptably high.

Discarded process alternatives Various different procedures and standards for the degassing, decommissioning and disposal of fuel storage infrastructure were considered and tested over time by the oil industry internationally. The standards that will be adhered to and which are the preferred alternative for this application, as detailed above, minimise health, safety and environmental risks associated with the infrastructure decommissioning process. Some of the process alternatives which have been investigated and discarded by the oil industry as they are not best-practice, are as follows: Given the relatively high-risk environment of a fuel storage site, it has been shown that working without appropriate fire

screening (such as blanketing with firefighting foam) carries an unacceptably high risk of a major incident occurring. Not dipping the tanks to record if any residual product remains results in an unacceptably high fire risk and risk for tank

explosion once the decommissioning commences. Not testing the vapour limits prior to work commencing on the tanks exposes workers to risk of adverse health impacts due

to potentially high concentrations of fuel vapours (excessive inhalation of fuel vapours has been linked to dizziness, headache and vomiting); as well as the risk of explosion if vapour concentrations are not sufficiently low.

Removing the fuel lines whilst they still contain product has a high associated fire risk and risk of spillage and possible associated soil and groundwater contamination. Fuel vapour emissions would also be uncontrollable and unnecessarily high, with attendant health and safety risks for decommissioning contractors.

The sparking associated with angle grinding or similar to cut the tanks and infrastructure during removal, has an extremely high attendant fire risk and risk of explosion and so is not safe or feasible.

If contractors are not properly trained, the risk of fire, explosion, spillage and associated human and environmental health impacts would be unacceptably high.

The preferred process alternatives for the decommissioning have been included in the EMP contained in Appendix H, which includes Chevron’s tank purging and degassing method statement. Please Note: In order to avoid/manage the potential negative impacts of the tanks’ decommissioning, an Environmental Management Plan (EMP) has been compiled. The EMP lists the various impacts that may occur during the decommissioning of the tanks, the proposed management and mitigation measures, the responsible person or party for ensuring that the mitigation measures are complied with and the frequency of compliance monitoring to be undertaken. The EMP should be updated regularly. Please note the decommissioning of the 4 fuel tanks is the preferred alternative. Please refer to Appendix H for the full EMP.

40

(h) Please provide a summary of the alternatives investigated and the outcomes of such investigation: Please note: If no feasible and reasonable alternatives exist, the description and proof of the investigation of alternatives, together with motivation of why no feasible or reasonable alternatives exist, must be provided. In terms of the principles of NEMA and potential impacts identified associated with the proposed activity, alternatives in fulfilling the general objectives of the application have been identified and considered. Where alternatives have been identified as reasonable and feasible, alternatives have been comparatively assessed during the Basic Assessment Process. 1. Property and Location Alternatives Alternative property/location site alternatives were not investigated for the purposes of this application as the proposed activity will comprise the decommissioning of existing fuel tanks located at Crammix Bricks. Thus no property/location site alternatives were investigated or assessed as this would not meet the general purpose and requirements of this application. 2. Activity Alternatives The proposed activity is considered the best environmental option for the site as not only are the tanks now inactive, but leaving the ageing, unmonitored / unmaintained tanks in place increases the risk of potential tank failure and subsequent soil and groundwater contamination. As such, no activity alternatives were investigated as this would not meet the general purpose of this application. 3. Design or Layout Alternatives Design or layout alternatives are not considered applicable, as the general purpose of this application is a once off activity to decommission fuel tanks located at Crammix Bricks. 4. Technology Alternatives Technology alternatives were not considered applicable as the general purpose of the application is the decommissioning of fuel tanks. As such, the nature of the proposed activity is such that the process has associated impacts. Therefore only process alternatives have been investigated for this site. 5. Operational Alternatives Operational alternatives were not considered applicable as the general purpose of the activity is a once-off decommissioning of fuel tanks at Crammix Bricks. 6. Other Alternatives: Decommissioning Process Alternatives: The decommissioning process has two key stages: purging the tanks of remnant product and degassing the tanks; and then the physical removal and disposal of the tanks and infrastructure. For both of these aspects, there are associated health, safety and environmental risks. For example, risk of explosion if the tanks are not degassed correctly; health and safety risks to employees if tests are not conducted during the process to establish whether fuel vapour and nitrogen levels are sufficiently low to allow works to proceed; risk of leaks or spills of remnant product or sludge from the fuel lines or tanks which could contaminate soil and groundwater; and fire risk associated with unmanaged hot works on or near the tanks and fuel lines.

The best practice or preferred process alternatives have been chosen for the minimisation of any such risks. 7. No-Go Alternative The No-Go Alternative was investigated as required by the principles of NEMA. The No-Go Alternative would entail not decommissioning the fuel tanks located at Crammix Bricks. As such the fuel tanks would remain in place and the portion of the site where the tanks are located would not be able to be utilised for any alternative purposes. This could result in loss of potential revenue for the landowner as a result of not being able to utilise the affected portion of the site for any other purpose. Leaving the tanks in situ could also result in an increasing environmental risk with time associated with the potential for failure of the tanks and infrastructure over time. As such, the No-Go Alternative is not considered to be a reasonable and feasible alternative for the site.

41

SECTION F: IMPACT ASSESSMENT, MANAGEMENT, MITIGATION AND MONITORING MEASURES Please note: The information in this section must be duplicated for all the feasible and reasonable alternatives (where relevant). 1. PLEASE DESCRIBE THE MANNER IN WHICH THE DEVELOPMENT WILL IMPACT ON THE FOLLOWING

ASPECTS: (a) Geographical and physical aspects: Potential geographical and geophysical impacts associated with the tank decommissioning include the following: Groundwater and Soil Contamination: In terms of the site decommissioning, the soil and groundwater could be impacted if best practice decommissioning procedures (e.g. inadequate training of decommissioning staff with subsequent spillages and leaks) are not carried out correctly. Such contamination could result in detrimental effects to soil and freshwater ecosystems. Once the recommended measures prescribed in Section F6 of this report and the attached EMP are implemented however, the probability of such contamination occurring is very low. (b) Biological aspects: Will the development have an impact on critical biodiversity areas (CBAs) or ecological support areas (CSAs)? YES NO If yes, please describe: The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the as “CBA1A”. These above mentioned vegetated areas on the north-west portion of the site, should not be affected by the proposed decommissioning activities however, as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. Will the development have on terrestrial vegetation, or aquatic ecosystems (wetlands, estuaries or the coastline)? YES NO

If yes, please describe: The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the as “CBA1A”. These above mentioned vegetated areas on the north-west portion of the site, should not be affected by the proposed decommissioning activities however, as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. There are no aquatic ecosystems on the site. As such the proposed tank decommissioning will have no impact on terrestrial vegetation or aquatic ecosystems on site. Will the development have an impact on any populations of threatened plant or animal species, and/or on any habitat that may contain a unique signature of plant or animal species? YES NO

If yes, please describe:

42

The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the as “CBA1A”. These above mentioned vegetated areas on the north-west portion of the site, should not be affected by the proposed decommissioning activities however, as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. There are no aquatic ecosystems on the site. As such the proposed tank decommissioning will have no impact on populations of threatened plant or animal species or habitats that contain a unique signature of plant or animal species that may be located on site. Please describe the manner in which any other biological aspects will be impacted: The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the as “CBA1A”. These above mentioned vegetated areas on the north-west portion of the site, should not be affected by the proposed decommissioning activities however, as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. In addition, as there is no natural terrestrial or aquatic ecosystem on the portion of the site where the tanks are located, and no populations of threatened plant or animal species or habitats that contain a unique signature of plant or animal species located on the portion of the site where the tanks are located, no biological aspects will be impacted by the proposed tank decommissioning. (c) Socio-Economic aspects:

What is the expected capital value of the activity on completion? Unknown at this point

What is the expected yearly income or contribution to the economy that will be generated by or as a result of the activity?

N/A This is a once off decommissioning

Will the activity contribute to service infrastructure? YES NO How many new employment opportunities will be created in the construction phase of the activity? The decommissioning teams will be appointed by Chevron. This will be an established, experienced contractor with the necessary qualifications, expertise and track record. This is to ensure that there is a minimum opportunity for a health, safety or, an environmental incident during the tanks decommissioning process. As such, the decommissioning process will not create any employment opportunities for the local population but will provide temporary work for a contracting pump and tank company.

What is the expected value of the employment opportunities during the construction phase? Unknown at this stage

What percentage of this will accrue to previously disadvantaged individuals? Unknown at this stage

How will this be ensured and monitored (please explain): Unknown at this stage How many permanent new employment opportunities will be created during the operational phase of the activity? Not Applicable: The proposed activity comprises only a short term decommissioning phase.

N/A

What is the expected current value of the employment opportunities during the first 10 years? Not Applicable: The proposed activity comprises only a short term decommissioning phase.

N/A

What percentage of this will accrue to previously disadvantaged individuals? Not Applicable: The proposed activity comprises only a short term decommissioning phase.

N/A

43

How will this be ensured and monitored (please explain): Not Applicable: The proposed activity comprises only a short term decommissioning phase. Any other information related to the manner in which the socio-economic aspects will be impacted: With fuel storage and handling facilities, there is always some risk of fire and / or explosion. This is due to flammable and explosive fuel vapour emissions, as well as the liquid fuel product being flammable. There are also health impacts associated with inhalation of fuel vapours. These impacts are discussed under Section F (2) (b) below. Strict health and safety protocols therefore need to be in place during the infrastructure decommissioning in order to avoid any such impacts. There will be no impact to other socio-economic aspects due to the small scale of the tank decommissioning. (d) Cultural and historic aspects: There are no sensitive cultural or historical aspects directly on the site which can or will be impacted by the proposed activity as the site is not on any land of any cultural significance. 2. WASTE AND EMISSIONS (a) Waste (including effluent) management Will the activity produce waste (including rubble) during the construction phase? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type? Unknown M3

The decommissioning of the fuel storage tanks will generate general construction waste (i.e. building rubble, steel), which will be removed by a waste contractor and be disposed of at a licensed landfill site.

The quantity is unknown but expected to be minimal due to the small scale of the activity. Any hazardous waste such as sludge from the fuel tanks will be disposed of to a licensed landfill site

(Visseshok) with chain-of-custody documentation retained as proof of safe disposal.

Will the activity produce waste during its operational phase? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type? Not applicable. The proposed activity is for the once off decommissioning of fuel tanks at Crammix Bricks. As such there will be no operational phase.

M3

Where and how will the waste be treated / disposed of (describe)? If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type per phase of the development? Not applicable. The proposed activity is for the once off decommissioning of 4 fuel tanks at Crammix Bricks. As such there will be no operational phase. Has the municipality or relevant authority confirmed that sufficient capacity exist for treating / disposing of the waste to be generated by this activity (ies)? If yes, provide written confirmation from Municipality or relevant authority. Once it has been determined whether off-site disposal of material is required, it will be ascertained whether the quantity is sufficient to warrant consulting with the Municipality on this regard.

YES NO

Will the activity produce waste that will be treated and/or disposed of at another facility other than into a municipal waste stream? YES NO

If yes, has this facility confirmed that sufficient capacity exist for treating / disposing of the waste to be generated by this activity (ies)? Provide written confirmation from the facility and provide the following particulars of the facility: N/A

YES NO

Does the facility have an operating license? (If yes, please attach a copy of the license.) N/A

YES NO

Facility name: Contact person: Postal address: Postal code:

44

Telephone: Cell: E-mail: Fax: Describe the measures that will be taken to reduce, reuse or recycle waste: Once the 4 fuel storage tanks are removed from the site, the tanks can be cut up, recycled (sent to the smelter) for recasting into other products. (b) Emissions into the atmosphere Will the activity produce emissions that will be disposed of into the atmosphere? YES NO If yes, does it require approval in terms of relevant legislation? YES NO Describe the emissions in terms of type and concentration and how it will be treated/mitigated: Dust emissions When the tanks are decommissioned, there will be associated dust impacts associated with the construction-type activities that will take place: heavy vehicles traversing sandy areas of the site; excavation of the tanks; backfill material stockpiling; etc. The scale of the tank decommissioning is small, and the duration of the decommissioning phase given the small scale of the installation will be very short (anticipated one to two weeks). Additionally, there are standard, proven construction industry methods that can be implemented during the tank decommissioning, which will minimise dust impacts. These include covering materials stockpiles with shade netting; imposing very low speed limits at the construction site; ceasing work during high wind conditions; wetting down sandy surfaces and stockpiles; etc. It is therefore anticipated that dust impacts associated with the tank decommissioning will be minor if managed adequately. Fuel vapour emissions Fuel vapour emissions will be released during the decommissioning process. This will occur when the tanks and lines are emptied and cut, with fuel product and vapours being exposed; and then to a greater degree when the lines and tanks are degassed: the fuel vapours are “purged” from the lines and tanks (through the nitrogen degassing process described in Chevron’s degassing method statement contained in Appendix H). In a case such as the Crammix bricks facility, fuel vapour emissions have predominantly health and safety impacts for workers exposed to the vapours: components of these vapours negatively impact the respiratory system and so are hazardous to human health. These vapours are also explosive. The number of tanks and associated infrastructure being decommissioned ta the Crammix site is small and so the health and safety impacts relating to fuel vapour emissions are anticipated to be quite minor. Vapours can also have cumulative air quality impacts, but this would be more in the context of a large depot-type fuel storage and handling installation, and additionally where such bulk installations are mostly situated in industrial areas with other sources of air quality impacts (fuel burning appliance emissions, fugitive emissions from chemicals, chimney stack emissions from production processes with associated emissions, etc.). This is not the case with the small-scale Crammix fuel storage and handling installation. Cumulative air quality impacts associated with the tank decommissioning are therefore anticipated to be negligible. 3. WATER USE Please indicate the source(s) of water for the activity by ticking the appropriate box (es)

Municipal Less than 1m3 of water will be used during the removal of the tanks for

water spraying purposes as a safety

feature to minimise the risk of fire.

Water board Groundwater River, Stream,

Dam or Lake Other The activity will not use water

If water is to be extracted from a groundwater source, river, stream, dam, lake or any other natural feature, please indicate the volume that will be extracted per month: N/A m3

Please provide proof of assurance of water supply (e.g. Letter of confirmation from municipality / water user associations, yield of borehole) Does the activity require a water use permit / license from DWAF? YES NO If yes, please submit the necessary application to Department of Water Affairs and attach proof thereof to this application. N/A Describe the measures that will be taken to reduce water demand, and measures to reuse or recycle water: N/A

45

4. POWER SUPPLY Please indicate the source of power supply e.g. Municipality / Eskom / Renewable energy source Power is to be supplied by the City of Cape Town Municipality. If power supply is not available, where will power be sourced from? N/A 5. ENERGY EFFICIENCY

Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

Energy efficiency measures are not applicable to this activity.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

Alternative energy sources are not applicable to this activity.

46

6. DESCRIPTION AND ASSESSMENT OF THE SIGNIFICANCE OF IMPACTS PRIOR TO AND AFTER

MITIGATION

Please note: While sections are provided for impacts on certain aspects of the environment and certain impacts, The sections should also be copied and completed for all other impacts.

(a) Impacts that may result from the planning, design and construction phase (briefly describe and compare the potential

impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the planning, design and construction phase.

Please note: Section F6 (a) is not applicable as the proposed tank decommissioning has a decommissioning phase only. (b) Impacts that may result from the operational phase (briefly describe and compare the potential impacts (as appropriate),

significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the operational phase.

Please note: Section F6 (b) is not applicable as the proposed tank decommissioning has a decommissioning phase only. (c) Impacts that may result from the decommissioning and closure phase (briefly describe and compare the potential impacts

(as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the decommissioning and closure phase.

Potential impacts on the geographical and physical aspects: Physical Environment

Soil and Groundwater Contamination

Nature of impact:

The impact is associated with incorrect decommissioning procedures being carried out. Possible reasons for contamination include spills or leaks of fuel product as a result of incorrect procedures being followed, or lack of staff training. Contamination of the groundwater or soils could lead to detrimental effects to soil and freshwater ecosystems. Additionally, inhalation of vapours from contaminated soil, or ingestion of contaminated groundwater pose a risk to human health.

Extent and duration of impact: The extent is local in the immediate vicinity of the site and the impact will be over a short term duration for as long as the tank decommissioning continues.

Probability of occurrence: If the proposed mitigation measures are implemented, the probability of occurrence is considered unlikely.

Degree to which the impact can be reversed: The impact is reversible with appropriate remediation measures. Mitigation measures can also be implemented to reduce the risk of contamination.

Degree to which the impact may cause irreplaceable loss of resources:

It is unlikely that a spill or leak (of the remnant fuel in the tanks) could cause irreplaceable loss of resources due to the small scale of the activity.

Cumulative impact prior to mitigation: The impact is not considered to be cumulative as the surrounding residential and agricultural areas do not represent significant sources of potential contamination.

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) Medium Low.

Degree to which the impact can be mitigated: Management and mitigation measures can easily be implemented to reduce the risk of contamination. Additionally, should the impact occur, remediation measures can be readily implemented.

Proposed mitigation:

The following recommendations have been made to prevent any possible contamination during the tank decommissioning activities: Adequate training of the tank decommissioning contractor’s

staff will ensure that the impact is minimised and, should it occur, rapid, informed action is taken to contain the spillage.

A competent professional (the site assessment/ risk assessment practitioner) should be present during the tank removal process to monitor the subsurface conditions as well as provide guidance where required.

All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential soil contamination risk associated with potential spillages.

All sludge, remaining product, contaminated water etc., which is a by-product of the above, shall be collected and removed off site and disposed of at a licensed landfill site or recycled. Chain-of-custody documentation for safe disposal will be included in the site closure audit report to be submitted to the

47

relevant authorities. With the disposal of fuel product slops and any sludge and

contaminated water, all of which is hazardous waste, the relevant waste policies and protocols (such as the Waste Classification and Management Regulations) need to be adhered to. Otherwise, the associated risk of soil and groundwater contamination if the hazardous waste is handled, transported and disposed of incorrectly, is unacceptably high.

The tanks should be thoroughly emptied prior to dismantling and should only be removed from site once they have been drained and degassed. The tanks will be removed to the contractor’s site where they will either be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and environmental risk at the site.

Chevron’s health and safety protocols should be adhered to at all times.

If contamination occurs because of the removal of the storage tanks and other infrastructure, or if contamination is found that was the result of leaks during the use of the tanks, the Department of Water Affairs must be notified immediately.

All rehabilitation measures contained in the emergency response plan should be adhered to at all times.

If pollution of groundwater occurs, a remediation plan including a provision for groundwater monitoring for a reasonable timeframe after the clean-up operation has taken place, must be provided to the Department of Water Affairs.

The precautionary principle applies at all times. If pollution of groundwater sources occurs, every effort must be made to reduce the contamination as far as possible.

Cumulative impact post mitigation: The impact is not considered to be cumulative as the surrounding residential and agricultural areas are not considered to represent significant sources of contamination.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Low.

Potential impacts on the geographical and physical aspects: Air Quality

Potential Dust

Nature of impact:

The tank decommissioning will entail the dismantling of the fuel storage tanks. This will involve the following dust generating activities: Heavy vehicles and equipment moving to and from the site. Dust dispersal during the removal of the storage tanks

(particularly from excavation activities associated with the tank that is currently underground).

Dust dispersal as a result of excavated soil and clean sand (for backfill) stockpiles.

Extent and duration of impact: The impact will be in the local vicinity of the site, as dust is windblown. The duration of this impact will be short-term, for the duration of the tank decommissioning.

Probability of occurrence: The impact is likely to occur, especially on windy days. Degree to which the impact can be reversed: The impact itself cannot be reversed but can be mitigated. Degree to which the impact may cause irreplaceable loss of resources: Dust impacts will not cause any irreplaceable loss of resources.

Cumulative impact prior to mitigation: The impacts can be considered cumulative as the site where the tanks are located is adjacent to agricultural land, the activities on which are a source of additional dust.

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) Medium

Degree to which the impact can be mitigated: The impact can be mitigated with the appropriate dust suppression and avoidance measures.

Proposed mitigation:

Proposed mitigation measures, which have been included in the Dust Management Plan contained in Appendix H, include: All vehicles should adhere to the local speed limit of 60km/hr on

Crammix Road and 10km/hr within Crammix Bricks itself. When travelling in areas that are particularly dusty, vehicle speed should be reduced further.

All internal roads on the site used by construction vehicles should be wet down as required.

Areas where excavation will occur as well as areas where excavated soil and clean sand stockpiles are stored should be wet down.

Quarry water bodies should be used for wetting down activities and not potable water.

48

All excavated soil and clean sand stockpiles should be stored in neat separate piles in an area on the site with the lowest wind exposure.

Erection of shade netting screens around the areas where excavation activities will occur.

Covering of the excavated soils and clean sand stockpiles with netting should be considered.

All Contractors and personnel associated with the decommissioning activities should wear dust masks as required.

The use of goggles should also be considered. Contractors to abide by dust management protocols established

for the site already. All relevant aspects of the City of Cape Town Environmental

Health by-Law P.N. 13333 of 2003 must be compiled with at all times.

All relevant aspects of the City of Cape Town Air Quality Management by-Law P.G. 6772 of 2010 must be complied with at all times.

Cumulative impact post mitigation: The cumulative impacts of dust associated with the tank decommissioning activities once all recommended mitigation measures are implemented are considered to be very minor.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Low.

Potential impacts on the geographical and physical aspects: Air Quality

Fuel Vapour Emissions to ambient atmosphere

Nature of impact:

When the fuel is removed from the tanks and the tanks are degassed a marginal amount of fuel vapour emissions are expected to be released into the ambient atmosphere. The effects of these emissions are outlined below: 1. Air Quality These emissions can be considered to have a negligible impact on air quality due to the relatively small scale and duration of the activity. 2. Health effects Inhalation of fuel vapours may affect workers in close vicinity to the tanks during the decommissioning operations. 3. Fire and explosion risk Due to the flammable nature of fuel vapours, the risk of fire and explosion could result in injury or loss of life, damage to property and infrastructure, as well as air quality impacts from the fire or explosion (smoke).

Extent and duration of impact:

The extent of fuel vapour emissions is local in the immediate vicinity of the site where the decommissioning activities will take place. It is anticipated that the duration of fuel vapour emissions will be of a short term duration, lasting as long as the tank decommissioning, but that the effects of this impact may be long term.

Probability of occurrence: Definite.

Degree to which the impact can be reversed: The impact cannot be reversed but with adequate mitigation measures in place, the effects of this impact are expected to be minor.

Degree to which the impact may cause irreplaceable loss of resources: The impact will not cause irreplaceable loss of resources.

Cumulative impact prior to mitigation: The impact is considered cumulative as the site where the tanks are located is adjacent to the heavily trafficked M23 to the South of the site are an additional source of fuel vapour emissions.

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) Medium – High.

Degree to which the impact can be mitigated:

The impact cannot be mitigated but precautionary measures to prevent the potential effects from occurring can be implemented to reduce the risk to human health, infrastructure and the environment during the degassing process.

Proposed mitigation:

Air Quality: Tanks and the tank manhole area should be vented to ensure

that any vapours are below levels that pose a health and safety risk and that oxygen levels are acceptably high.

Health Effects:

49

Workers performing the degassing must stand up wind from the operation and if required wear respirators with organic vapour cartridges.

All workers are to wear the correct personal protection. Equipment should include clean leather gloves during the degassing operation.

Gas test results must be within acceptable limits for breathing at all times.

Once N2 is introduced, continuous gas testing of the work area during tank decommissioning is required to prevent asphyxiation as a result of the N2 displacing the oxygen in the area. Should the tank shows signs of collapse or implosion during the vacuum process, work is to be stopped immediately.

Chevron’s health and safety protocols for the degassing of the tanks can be implemented for this impact.

Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and environmental risk at the site.

Steps must be taken to avoid any health nuisance relating to emissions as defined by the City of Cape Town Environmental Health by-Law P.N. 13333 of 2003.

Fire Explosion and Risk: The decommissioning and disposal of the fuel storage tanks will

comply with the American Petroleum Industry’s (API) standard 1604 relating to the closure of petroleum storage tanks.

Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site prior to the degassing process.

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.

The pump to be used for the emptying of the tank must be flame proof.

Remaining product from the tanks should be emptied into appropriately sealable metal drums.

Tanks and the tank manhole area should be vented to ensure that any vapours are below levels that pose a health and safety risk and that oxygen levels are acceptably high.

All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential fire risk associated with fuel vapour compression.

The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and removed from site.

Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the following: Minimisation of hot work by using alternative methods and

equipment such as air driven tools, cold cutting and pre-fabrication off site;

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk;

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water; and

A fire attendant will be on stand-by during the decommissioning process.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk.

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water.

A fire attendant will be on stand-by during the decommissioning process.

Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health and safety and environmental risk at the site.

Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank decommissioning activities will be carried out.

Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These have been attached as Appendix H.

50

The tanks will be removed from site once they have been drained and degassed. The tanks will either be removed to the contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Cumulative impact post mitigation: The cumulative impact associated with the anticipated fuel vapour emissions, given the small scale of the activity, is considered to be very low.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Low.

Potential impacts: Socio-economic aspects Risk of Fire or Explosion (Health and safety Risk)

Nature of impact:

Should the degassing and decommissioning activities be undertaken incorrectly, there is a risk of fire or explosion as a result of the presence of the fuel itself as well as the fuel vapours and associated fuel vapour emissions. Fire and explosion could result in injury or loss of life, damage to property and infrastructure, as well as air quality impacts from the fire or explosion (smoke).

Extent and duration of impact: The extent would be local in the immediate vicinity of the site and short term as rapid fire fighting responses are anticipated.

Probability of occurrence: It is unlikely that a fire will occur should the appropriate health and safety protocols be adhered to.

Degree to which the impact can be reversed: Should the impact occur, the impacts cannot be reversed. The impact can however, be effectively avoided should correct safety procedures be adhered to.

Degree to which the impact may cause irreplaceable loss of resources:

In the event or a major fire or explosion, loss of life, livelihoods and damage to the Crammix Bricks site could occur. Should this happen, it would constitute a loss of irreplaceable resources and loss of revenue for the landowner.

Cumulative impact prior to mitigation: The impact cannot be considered cumulative as the activities surrounding the site do not constitute a fire hazard.

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) High.

Degree to which the impact can be mitigated: Should a fire occur, it cannot be mitigated. The impact can be avoided however, should the correct safety procedures be adhered to.

Proposed mitigation:

Proposed mitigation measures include: All workers are to wear the correct personal protection. The decommissioning and disposal of the fuel storage tanks will

comply with the American Petroleum Industry’s (API) standard 1604 relating to the closure of petroleum storage tanks.

Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site prior to the degassing process.

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.

The pump to be used for the emptying of the tank must be flame proof.

Remaining product from the tanks should be emptied into appropriately sealable metal drums.

Tanks and the tank manhole area should be vented to ensure that any vapours are below levels that pose a health and safety risk and that oxygen levels are acceptably high.

All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential fire risk associated with fuel vapour compression.

The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and removed from site.

Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the following: Minimisation of hot work by using alternative methods and

equipment such as air driven tools, cold cutting and pre-fabrication off site;

The use of appropriate shielding and screening such as

51

blanketing with firefighting foam and water screens to minimise fire risk;

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water; and

A fire attendant will be on stand-by during the decommissioning process.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk.

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water.

A fire attendant will be on stand-by during the decommissioning process.

Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health and safety and environmental risk at the site.

Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank decommissioning activities will be carried out.

Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These have been attached as Appendix H.

The tanks will be removed from site once they have been drained and degassed. The aboveground tanks will either be removed to the contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Cumulative impact post mitigation:

Decommissioning of the fuel storage tanks, once all health and safety protocols are followed, will contribute minimally to the risk of fire and explosion in the surrounding areas and as such the activity will not contribute to a cumulative impact.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Low.

Potential impacts on the socio-economic aspects: Income and Employment (Benefits)

Nature of impact:

The tank decommissioning team will be appointed by Chevron. This will be a team of established, experienced contractors with the necessary qualifications, expertise and track record. This is to ensure that there is minimum opportunity for health, safety or environmental incident to occur during the decommissioning process. The tank decommissioning process will not create any employment opportunities for the local population but instead will provide temporary work for a contracting company.

Extent and duration of impact:

The employment benefits will be short term in nature, for the duration of the tank decommissioning only (approximately 2-3 weeks). The impact will be highly localised, benefitting a single, approved decommissioning contractor only.

Probability of occurrence: The impact is definite should the decommissioning be authorised. Degree to which the impact can be reversed: N/A This is a benefit. Degree to which the impact may cause irreplaceable loss of resources:

The impact will be a benefit and as such no irreplaceable loss of resources will occur.

Cumulative impact prior to mitigation: The benefit is considered to be cumulative as the agricultural activities to the west and south of the site are an additional source of employment.

Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) Low (positive).

Degree to which the impact can be mitigated: N/A this impact is a benefit. Proposed mitigation: N/A this impact is a benefit. Cumulative impact post mitigation: N/A Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) N/A

Potential impacts on the cultural-historical aspects: Sensitive Cultural/ Historical Features

Nature of impact: As described in Section B9 of this report, there will be no cultural-historical impacts due to the fact that the site is not located near any sites of cultural or historical significance. In addition, the surrounding

52

area has been entirely transformed by urban development and cultivation. As such, the following section is not considered applicable.

Extent and duration of impact: N/AProbability of occurrence: N/ADegree to which the impact can be reversed: N/ADegree to which the impact may cause irreplaceable loss of resources:

N/A

Cumulative impact prior to mitigation: N/ASignificance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

N/A

Degree to which the impact can be mitigated: N/AProposed mitigation: N/ACumulative impact post mitigation: N/ASignificance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

N/A

Potential impact biological aspects: Vegetation

Nature of impact:

The 4 fuel tanks to be decommissioned are located at Crammix Bricks located on Erf ST214, Crammix Road, Brakenfell, Western Cape. The Crammix Bricks site itself has been almost entirely transformed as a result of the historical activities at the site (brick manufacturing and mining). According to the City of Cape Town’s Biodiversity Network however, on the north-west portion of the site, relatively good patches of fynbos vegetation remain on and abutting the larger Crammix site and are listed on the as “CBA1A”. These above mentioned vegetated areas on the north-west portion of the site, should not be affected by the proposed decommissioning activities however, as the activities will be undertaken in the already disturbed/mined area, on the southern section of the site. As such the proposed tank decommissioning will have no impact on populations of threatened plant or animal species or habitats that contain a unique signature of plant or animal species that may be located on site. As such, this section is not considered applicable.

Extent and duration of impact: N/AProbability of occurrence: N/ADegree to which the impact can be reversed: N/ADegree to which the impact may cause irreplaceable loss of resources:

N/A

Cumulative impact prior to mitigation: N/ASignificance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High)

N/A

Degree to which the impact can be mitigated: N/AProposed mitigation: N/ACumulative impact post mitigation: N/ASignificance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High)

N/A

Potential noise impacts: Noise

Nature of impact:

Decommissioning activities at the site would entail the use of heavy machinery and equipment to dismantle the fuel storage infrastructure. The activities will emit noise which will be a nuisance impact for the surrounding residential areas.

Extent and duration of impact: The extent is local in the immediate vicinity of the site with the noise impacts lasting as long as the tank decommissioning.

Probability of occurrence: The impact will definitely occur.

Degree to which the impact can be reversed:

The impact is not reversible however mitigation measures can be implemented to ensure that noise levels remain acceptable both for the neighbouring properties and residents as well as the contractors and site workers working on site.

Degree to which the impact may cause irreplaceable loss of resources:

Without appropriate mitigation in the areas on site determined to emit noise levels above 85dBA, hearing of workers can be damaged possibly on a permanent basis. This would represent the loss of an irreplaceable resource for the people concerned.

Cumulative impact prior to mitigation: This impact is considered cumulative as the Crammix Bricks site, where the tanks are located, lies adjacent to the heavily trafficked M23 to the South of the site. Adjacent roads within the nearby

53

residential to the direction are also a source of noise. Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) Medium.

Degree to which the impact can be mitigated: The impact can be mitigated by using appropriate noise reduction and management measures.

Proposed mitigation:

Proposed mitigation measures include: The decommissioning contractor must use modern equipment,

which produces the least noise. Any unavoidably noisy equipment must be identified and

located in an area where it has the least likely impact. The use of noise shielding screens must be considered and the

operation of such machinery restricted to when it is actually required.

The use of ear protectors for workers using any machinery which emits noise in excess of 85dBA.

Working hours on site will be confined between 08h00 and 17h00 on weekdays only and no work will be undertaken on weekends. No noise generating activities are to occur outside of these working hours.

Steps must be taken to avoid any noise nuisance as defined by the City of Cape Town Environmental Health by-Law P.N. 13333 of 2003.

All relevant aspects of the Western Cape Noise Control Regulations, P.N 200 of 2013 as promulgated under the Environmental Conservation Act, 1989 must be compiled with at all times.

Cumulative impact post mitigation:

The tank decommissioning activities on site will not contribute excessively to the environmental noise levels already experienced in the area. In addition, noise form the tank decommissioning will be mitigated as far as possible, as outlined above.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Low.

Potential visual impacts: Visual

Nature of impact:

This section is not considered applicable as the site has already been highly degraded due to the activities on site pertaining to the manufacturing of the clay bricks. As such, the visual impact of the construction-type vehicles and machinery required on site for the decommissioning is negligible.

Extent and duration of impact: N/A Probability of occurrence: N/A Degree to which the impact can be reversed: N/A Degree to which the impact may cause irreplaceable loss of resources: N/A

Cumulative impact prior to mitigation: N/A Significance rating of impact prior to mitigation (Low, Medium, Medium-High, High, or Very-High) N/A

Degree to which the impact can be mitigated: N/A Proposed mitigation: N/A Cumulative impact post mitigation: N/A Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) N/A

(d) Any other impacts:

Potential impacts on the socio-economic aspects: Traffic

Nature of impact:

During the decommissioning process, heavy construction-type vehicles will be moving to and from site. As such, there will be a temporary increase in the amount of heavy traffic at the site during the tank decommissioning, with the possibility of congestion of traffic safety impacts on adjacent roads.

Extent and duration of impact: The impact will be felt on Crammix Road and Kruis Road only.

Probability of occurrence: Should the decommissioning be authorised, the impact will definitely occur.

Degree to which the impact can be reversed: The impact will cease as soon as the decommissioning activities have ceased.

Degree to which the impact may cause irreplaceable loss of resources:

No irreplaceable loss of resources will occur as a result of the increase in traffic in the area.

Cumulative impact prior to mitigation: The impact is considered cumulative as Kruis Road as well as the M23 which Kruis Road connects too are heavily trafficked.

Significance rating of impact prior to mitigation The traffic associated with the site decommissioning will be on a very

54

(Low, Medium, Medium-High, High, or Very-High) small scale and the impact will be Very Low.

Degree to which the impact can be mitigated: The impact can be easily mitigated.

Proposed mitigation:

Proposed mitigation measures include: Warning signage (i.e. “trucks turning”) must be erected near the

access point of the site on Crammix Road. A traffic marshal should be posted at the entrance of the site to

assist with the safe and smooth flow of vehicles on the road whilst heavy construction vehicles are entering and exiting the site.

Cumulative impact post mitigation: The impact on traffic on Crammix Road, Kruis Road and the M23, once all mitigation measures are implemented, will be negligible.

Significance rating of impact after mitigation (Low, Medium, Medium-High, High, or Very-High) Negligible.

7. SPECIALIST INPUTS/STUDIES AND RECOMMENDATIONS

Please note: Specialist inputs/studies must be attached to this report as Appendix G. Also take into account the Department’s Guidelines on the Involvement of Specialists in EIA Processes available on the Department’s website (http://www.capegateway.gov.za/eadp).

Specialist inputs/studies and recommendations: A Baseline Environmental Conditions Assessment of the area around the 2 x 83m3 aboveground storage tanks (HFO) and the 1 x 14m3 underground fuel storage (DGO) was conducted in May 2013 whilst the site was still operational. According to the results of the ECA and the follow-on Interpretive Report (dated June 2013), as well as an email from the applicant dated 26th February 2014, the site was classified as a non-contaminated site. (Environmental Resources Management. “Environmental Conditions Assessment”, 2013). The Baseline Environmental Conditions Assessment of the area was updated in October 2014 to include an assessment of the area around the 1 x 23m3 above ground fuel storage tank (DGO), which area had not previously been assessed. Based on the updated assessment, the applicant confirmed in an email dated 21st October 2014 that the risk profile of the site remains the same. Site decommissioning is thus not expected to involve any remediation activities. Suitable mitigation and management measures have been developed in order to minimise the health, safety and environmental risk associated with the decommissioning of the fuel tanks. These are based on oil industry best practice and have been included in the Environmental Management Programme. Please refer to Appendix H for the Environmental Management Programme.

55

8. IMPACT SUMMARY Please provide a summary of all the above impacts: Proposed Activity: The proposed decommissioning of fuel tanks at the old Crammix Bricks site has the following associated direct impacts: Negative Direct Impacts A temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the tank

decommissioning activities. A temporary increase in fuel vapour emissions with associated health and safety impacts. A temporary increase in noise. A temporary increase in the amount of heavy traffic on the adjacent road network due to construction vehicles

accessing the site. If undertaken incorrectly, the tank decommissioning activities on site could lead to an increased risk of soil and

groundwater contamination. If inadequate training is undertaken and inadequate firefighting equipment is kept at the site, the tank decommissioning

activities could increase the risk of fire and explosion. This has the potential to impact the residential and agricultural areas surrounding the site.

Positive Direct Impacts The permanent removal of potential health, safety and environmental risks associated with ageing, unmaintained fuel

storage infrastructure situated at the site. The creation of temporary employment opportunities during the tank decommissioning activities The landowner will be able to utilise the portion of the site where the tanks have been located for an alternative purpose,

thereby increasing the potential for enhanced personal income.

The proposed decommissioning also has the potential to have the following associated cumulative impacts: Negative Cumulative Impacts A temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of the tank

decommissioning activities. A temporary increase in emissions (due to tank degassing procedures). A temporary increase in noise. A temporary increase in the amount of heavy traffic due to the construction-type nature of the decommissioning

activities.

Please note: The negative impacts are considered to be cumulative due to the surrounding land use (dust from the surrounding agricultural activities, emissions from traffic on the M23 and the dense road network surrounding the site, noise from traffic and the adjacent agricultural activities, traffic as a result the existing traffic flow in the area. Positive Cumulative Impacts The creation of temporary employment opportunities during the tank decommissioning activities Please note: The positive impact is considered cumulative due to the surrounding land use being a source of additional employment in terms of work on the agricultural land (farm labourers and managers) as well as in the residential areas. The impact assessment undertaken found that, the potential negative environmental and social direct and cumulative impacts arising as a result of the tank decommissioning can be mitigated to an acceptable level. Provided that the proposed mitigation measures are implemented, no factors were determined which should prevent the proposed tank decommissioning from taking place. In order to avoid/manage the potential negative direct and cumulative impacts of the tank decommissioning, an Environmental Management Plan (EMP) has been compiled. The EMP lists the various impacts that may occur during the decommissioning of the site, the proposed management and mitigation measures, the responsible person or party for ensuring that the mitigation measures are complied with and the frequency of compliance monitoring to be undertaken. The EMP should be updated regularly. Please note that the decommissioning of the 4 fuel tanks located at Crammix Bricks is the preferred alternative by the EAP. The No-Go Alternative The No-Go Alternative means the “option of not implementing the proposed activity” i.e. not decommissioning the fuel tanks located at the site. As such the fuel tanks would remain in place and the portion of the site where the tanks are located would not be able to be utilised for any alternative purposes. Positive impacts of the No-Go Alternative: There will be no temporary increase in dust and vibrations in the vicinity of the site due to the construction-type nature of

the decommissioning activities not commencing. There will be no temporary increase in noise due to the construction-type nature of the decommissioning activities not

commencing. There will be no temporary increase in the amount of heavy traffic at the site due to the construction-type nature of the

decommissioning activities not commencing. As the decommissioning will not occur, there will be no risk of incorrectly undertaken degassing and decommissioning.

Incorrect procedures could lead to an increased environmental risk of soil and groundwater contamination which in turn

56

could have associated human health risks (respiratory system irritation through vapour inhalation; irritation through dermal contact; etc.).

If the tank degassing and decommissioning is undertaken incorrectly, there is an associated risk of fire and explosion. With the No-Go alternative, this risk is quite minimal.

Negative Impacts of the No-Go Alternative: There will be no permanent removal of potential health, safety and environmental risks associated with ageing,

unmaintained tanks situated at the site. There will be no creation of temporary employment opportunities during the decommissioning activities. The landowner will not be able to utilise that portion of the site for any other purpose. Please note that the No-Go Alternative is not considered to be a reasonable and feasible alternative for this site and this alternative is not preferred. Please refer to Section F of this report for a detailed investigation and assessment of the above mentioned impacts. The recommended mitigation measures contained in Section F of the BAR and in the EMP for the proposed activity should be implemented and adhered to in order to avoid or minimise these potential impacts. This assessment and the mitigation measures proposed are based on the Environmental Assessment Practitioner (EAP)’s professional judgement.

9. OTHER MANAGEMENT, MITIGATION AND MONITORING MEASURES (a) Over and above the mitigation measures described in Section 6 above, please indicate any additional management,

mitigation and monitoring measures. There are no additional mitigation measures other than those included in Section 6 of this report and the Final EMP. (b) Describe the ability of the applicant to implement the management, mitigation and monitoring measures. The measures will be undertaken as part of project planning and execution by Chevron SA (Pty) Ltd.

Please note: A draft ENVIRONMENTAL MANAGEMENT PROGRAMME must be attached this report as Appendix H.

57

SECTION G: ASSESSMENT METHODOLOGIES AND CRITERIA, GAPS IN KNOWLEDGE, UNDERLAYING ASSUMPTIONS AND UNCERTAINTIES (a) Please describe adequacy of the assessment methods used. The assessment of the impacts associated with the facility was guided by the DEA’s 2006 Integrated Environmental Management Guideline Series, Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations. The DEA&DP EIAGuideline and Information Document Series published in March 2013 also informed the approach taken during this Basic Assessment process, which has been an integrated environmental management approach in alignment with Section 23 of the NEMA and with the National Environmental Management Principles contained in Chapter 1 of the NEMA. The assessment has also been guided by professional knowledge and experience, as well as specialist input. The assessment methodology utilized is therefore considered to be entirely adequate for the purposes of assessing the environmental impacts associated with the tanks’ decommissioning and to ascertain whether the decommissioning is in fact necessary and desirable given its impacts on the receiving environment. (b) Please describe the assessment criteria used. This 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 (2010). The standard National Department of Environmental Affairs assessment criteria were used by the EAP. As such, all potential impacts have been assessed in terms of their significance based on the following criteria:

Intensity (or magnitude) Duration Extent Probability Confidence

Practicable mitigation measures (where warranted) have been identified to minimize the potential impacts associated with the decommissioning. The significance of any potential impact before and after mitigation is also provided to give an indication of the efficacy of the proposed mitigation measure/s. (c) Please describe the gaps in knowledge. The following uncertainties and gaps in knowledge were identified in the assessment undertaken: That the tank decommissioning will be carried out according to the oil companies’ normal operating standards. That management will act in a responsible manner and take action when incidents occur to determine the cause and/or

rectify the cause of the problem. That the available data, including Topocadastral maps, geological maps and DWA national ground water database

information, are reasonably accurate. That all information extracted from previous site assessment studies is correct. (d) Please describe the underlying assumptions. That the tank decommissioning will be carried out according to the oil companies’ normal operating standards. That management will act in a responsible manner and take action when incidents occur to determine the cause and/or

rectify the cause of the problem. That the available data, including Topocadastral maps, geological maps and DWA national ground water database

information, are reasonably accurate. That all information extracted from previous site assessment studies is correct. (e) Please describe the uncertainties. There are no uncertainties which have arisen from investigations undertaken by the EAP.

58

SECTION H: RECOMMENDATION OF THE EAP

In my view (EAP), the information contained in this application form and the documentation attached hereto is sufficient to make a decision in respect of the activity applied for. YES NO

If “NO”, list the aspects that should be further assessed through additional specialist input/assessment or whether this application must be subjected to a Scoping & EIR process before a decision can be made:

N/A If “YES”, please indicate below whether in your opinion the activity should or should not be authorised: Activity should be authorised: YES NO Please provide reasons for your opinion The potential negative environmental and social impacts arising as a result of the decommissioning of the tanks can be mitigated to an acceptable level and, provided that the proposed mitigation measures are implemented, no factors were determined which should prevent the proposed tank decommissioning from taking place. As such, the EAP has not identified any reasons why the proposed tank decommissioning cannot proceed provided that the mitigation measures contained in the EMP are implemented. If you are of the opinion that the activity should be authorised, then please provide any conditions, including mitigation measures that should in your view be considered for inclusion in an authorisation. The EAP has not identified any reasons why the proposed tank decommissioning cannot proceed. The mitigation measures contained in the Environmental Management Programme attached to this document however must be implemented. In particular:

Soil and Groundwater Contamination

Adequate training of the tank decommissioning contractor’s staff will ensure that the impact is minimised and, should it occur, rapid, informed action is taken to contain the spillage.

A competent professional (the site assessment/ risk assessment practitioner) should be present during the tank removal process to monitor the subsurface conditions as well as provide guidance where required.

All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the potential soil contamination risk associated with potential spillages.

All sludge, remaining product, contaminated water etc., which is a by-product of the above, shall be collected and removed off site and disposed of at a licensed landfill site or recycled. Chain-of-custody documentation for safe disposal will be included in the site closure audit report to be submitted to the relevant authorities.

With the disposal of fuel product slops and any sludge and contaminated water, all of which is hazardous waste, the relevant waste policies and protocols (such as the Waste Classification and Management Regulations) need to be adhered to. Otherwise, the associated risk of soil and groundwater contamination if the hazardous waste is handled, transported and disposed of incorrectly, is unacceptably high.

The tanks should be thoroughly emptied prior to dismantling and should only be removed from site once they have been drained and degassed. The tanks will be removed to the contractor’s site where they will either be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer.

Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and environmental risk at the site.

Chevron’s health and safety protocols should be adhered to at all times. If contamination occurs because of the removal of the storage tanks and other infrastructure, or if contamination is found

that was the result of leaks during the use of the tanks, the Department of Water Affairs must be notified immediately. All rehabilitation measures contained in the emergency response plan should be adhered to at all times. If pollution of groundwater occurs, a remediation plan including a provision for groundwater monitoring for a reasonable

timeframe after the clean-up operation has taken place, must be provided to the Department of Water Affairs. The precautionary principle applies at all times. If pollution of groundwater sources occurs, every effort must be made to

reduce the contamination as far as possible.

Fuel Vapour Emissions to ambient atmosphere: Air Quality: Tanks and the tank manhole area should be vented to ensure that any vapours are below levels that pose a health and

safety risk and that oxygen levels are acceptably high. Health Effects: Workers performing the degassing must stand up wind from the operation and if required wear respirators with organic

vapour cartridges. All workers are to wear the correct personal protection. Equipment should include clean leather gloves during the

degassing operation. Gas test results must be within acceptable limits for breathing at all times. Once N2 is introduced, continuous gas testing of the work area during tank decommissioning is required to prevent

asphyxiation as a result of the N2 displacing the oxygen in the area. Should the tank shows signs of collapse or implosion during the vacuum process, work is to be stopped immediately.

Chevron’s health and safety protocols for the degassing of the tanks can be implemented for this impact. Trained, permit holding contractors will be used during the decommissioning process to minimise health and safety and

environmental risk at the site. Steps must be taken to avoid any health nuisance relating to emissions as defined by the City of Cape Town

59

Environmental Health by-Law P.N. 13333 of 2003. Fire Explosion and Risk: The decommissioning and disposal of the fuel storage tanks will comply with the American Petroleum Industry’s (API)

standard 1604 relating to the closure of petroleum storage tanks. Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site

prior to the degassing process. 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. The pump to be used for the emptying of the tank must be flame proof. Remaining product from the tanks should be emptied into appropriately sealable metal drums. All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the

potential fire risk associated with fuel vapour compression. The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and

removed from site. Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the

following: Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-

fabrication off site; The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to

minimise fire risk; Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water;

and A fire attendant will be on stand-by during the decommissioning process.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk.

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process. Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health

and safety and environmental risk at the site. Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank

decommissioning activities will be carried out. Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These

have been attached as Appendix H. The tanks will be removed from site once they have been drained and degassed. The tanks will either be removed to the

contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Dust Adherence to the Dust Management Plan which is contained in Appendix H, and which includes the following measures: All vehicles should adhere to the local speed limit of 60km/hr on Crammix Road and 10km/hr within Crammix Bricks itself.

When travelling in areas that are particularly dusty, vehicle speed should be reduced further. All roads upon which vehicles associated with the decommissioning activities travel on should be wet down either

manually or by water bowser/ tanker as required. Areas where excavation will occur as well as areas where excavated soil and clean sand stockpiles are stored should be

wet down. Quarry water bodies should be used for wetting down activities and not potable water. All excavated soil and clean sand stockpiles should be stored in neat separate piles in an area on the site with the lowest

wind exposure. Erection of shade netting screens around the areas where excavation activities will occur. Covering of the excavated soils and clean sand stockpiles with netting should be considered. All Contractors and personnel associated with the decommissioning activities should wear dust masks as required. The use of goggles should also be considered. Contractors to abide by dust management protocols established for the site already. Risk of Fire and Explosion (Health and Safety Risk) All workers are to wear the correct personal protection. The decommissioning and disposal of the fuel storage tanks will comply with the American Petroleum Industry’s (API)

standard 1604 relating to the closure of petroleum storage tanks. Controls and precautionary measures include that all firefighting equipment and a fire watch must be available on site

prior to the degassing process. 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. The pump to be used for the emptying of the tank must be flame proof. Remaining product from the tanks should be emptied into appropriately sealable metal drums. Tanks and the tank manhole area should be vented to ensure that any vapours are below levels that pose a health and

safety risk and that oxygen levels are acceptably high. All fuel lines will be drained of product and flushed before being disconnected from tanks and degassed to minimise the

potential fire risk associated with fuel vapour compression. The fuel lines will be cold cut (i.e. a manually operated blade will be used as opposed to power tools), vented and

removed from site. Controls and precautionary measures for any hot work in hazardous areas will be implemented which includes the

following: Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-

60

fabrication off site; The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to

minimise fire risk; Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water;

and A fire attendant will be on stand-by during the decommissioning process.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk.

Spark quenching by wetting down and/or using construction power tools such as jack hammers under running water. A fire attendant will be on stand-by during the decommissioning process. Trained, permit holding contractors will be used during the degassing and decommissioning process to minimise health

and safety and environmental risk at the site. Adequate training in emergency response situations of the contractor and construction personnel undertaking the tank

decommissioning activities will be carried out. Chevrons method statements for the degassing and decommissioning process must be adhered to at all times. These

have been attached as Appendix H. The tanks will be removed from site once they have been drained and degassed. The tanks will either be removed to the

contractor’s site where they will both be cleaned and prepared for re-use, or will be cold cut and disposed of to a scrap metal dealer. Once the tanks have been cleaned and degassed, there is no longer any environmental, health or safety risk associated with the infrastructure and safe disposal certificates are not necessary.

Noise The decommissioning contractor must use modern equipment, which produces the least noise. Any unavoidably noisy equipment must be identified and located in an area where it has the least likely impact. The use of noise shielding screens must be considered and the operation of such machinery restricted to when it is

actually required. The use of ear protectors for workers using any machinery which emits noise in excess of 85dBA. Visual Screening of the site during the decommissioning activities. Screening of stockpiles. Traffic Warning signage (i.e. “trucks turning”) must be erected near the access point of the site on Crammix Road. A traffic marshal should be posted at the entrance of the site to assist with the safe and smooth flow of vehicles on the

road whilst heavy construction vehicles are entering and exiting the site. No construction traffic may access the site after normal working hours as defined by the local authority.

Duration and Validity: Environmental authorisations are usually granted for a period of three years from the date of issue. Should a longer period be required, the applicant/EAP is requested to provide a detailed motivation on what the period of validity should be. N/A

61

SECTION I: APPENDICES The following appendices must be attached to this report:

Appendix Tick the box if Appendix is attached

Appendix A:

Locality maps Site Map Site Locality Map Topographic Map

Yes

Appendix B: Site plan(s) Yes

Appendix C: Photographs Yes

Appendix D:

Biodiversity overlay maps National original vegetation map (SANBI) National threatened ecosystem map (SANBI) National biome map (SANBI) National Land Cover map (SANBI) City of Cape Town Biodiversity Network Fine Scale Plan

Yes

Appendix E: Permit(s) / license(s) from any other organ of state including service letters from the municipality None

Appendix F:

Public participation information: Landowner Notification Initial Stakeholder Table Registered Stakeholder Table Copies of Cover Letters sent to Organs of State Copies of the Notification Letters, Site Notices and Advert Proof of Deliveries of Notification Letters & Hand Deliveries and delivery of

the Draft BAR to Organs of State and the Library Proof of placement of Site Notice and Advert Copies of Comments and Responses received and sent during the Draft

BAR public participation period. Comments and Responses Report. Summary of Public Participation undertaken to date.

Yes

Appendix G:

Specialist Report(s) Environmental Conditions Factual Report (May 2013) Interpretive Report (June 2014) Environmental Conditions Factual Report (October 2014) Email from the applicant dated 26th February 2014 Environmental Resources Management Sampling Methodology

(December 1996) Environmental Resources Management Summary of the Sampling

Methodology (September 2014)

Yes

Appendix H : Environmental Management Programme & Dust Management Plan Yes

Appendix I: Additional information related to listed waste management activities (if applicable) None

Appendix J: Any Other (if applicable) (describe) Chevron Method statements for the decommissioning degassing process Yes

62

DECLARATIONS

THE APPLICANT

I Thembelilhle Precious Mashinini, in my personal capacity or duly authorised (please circle the

applicable option) by Chevron South Africa thereto hereby declare that I:

regard the information contained in this report to be true and correct, and

am fully aware of my responsibilities in terms of the National Environmental Management Act of 1998 (“NEMA”) (Act No. 107 of 1998), the Environmental Impact Assessment Regulations (“EIA Regulations”) in terms of NEMA (Government Notice No. R. 543 refers), and the relevant specific environmental management Act, and that failure to comply with these requirements may constitute an offence in terms of the environmental legislation;

appointed the environmental assessment practitioner as indicated above, which meet all the requirements in terms of regulation 17 of GN No. R. 543, to act as the independent environmental assessment practitioner for this application;

have provided the environmental assessment practitioner and the competent authority with access to all information at my disposal that is relevant to the application;

will be responsible for the costs incurred in complying with the environmental legislation including but not limited to –

o costs incurred in connection with the appointment of the environmental assessment practitioner or any person contracted by the environmental assessment practitioner;

o costs incurred in respect of the undertaking of any process required in terms of the regulations; o costs in respect of any fee prescribed by the Minister or MEC in respect of the regulations; o costs in respect of specialist reviews, if the competent authority decides to recover costs; and o the provision of security to ensure compliance with the applicable management and

mitigation measures;

am responsible for complying with the conditions that might be attached to any decision(s) issued by the competent authority;

have the ability to implement the applicable management, mitigation and monitoring measures;

hereby indemnify, the government of the Republic, the competent authority and all its officers, agents and employees, from any liability arising out of, inter alia, the content of any report, any procedure or any action for which the applicant or environmental assessment practitioner is responsible; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543.

Please Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney must be attached.

Signature of the applicant: Chevron South Africa (Pty) Ltd Name of company: Date:

63

THE INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

I ……………………………………, as the appointed independent environmental practitioner (“EAP”)

hereby declare that I:

act/ed as the independent EAP in this application;

regard the information contained in this report to be true and correct, and

do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

have and will not have no vested interest in the proposed activity proceeding;

have disclosed, to the applicant and competent authority, any 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 required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2010 (specifically in terms of regulation 17 of GN No. R. 543) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the application was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments;

have ensured that the comments of all interested and affected parties were considered, recorded and submitted to the competent authority in respect of the application;

have kept a register of all interested and affected parties that participated in the public participation process;

have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543.

Note: The terms of reference must be attached. Signature of the environmental assessment practitioner: Sillito Environmental Consulting Name of company: Date:

64

THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A SPECIALIST PROCESS

I ……………………………………, as the appointed independent specialist hereby declare that I:

act/ed as the independent specialist in this application;

regard the information contained in this report as it relates to my specialist input/study to be true and correct, and

do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

have and will not have no vested interest in the proposed activity proceeding;

have disclosed, to the applicant, EAP and competent authority, any 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 required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act;

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2010 (specifically in terms of regulation 17 of GN No. R. 543) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study;

have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application;

have ensured that the names of all interested and affected parties that participated in terms of the specialist input/study were recorded in the register of interested and affected parties who participated in the public participation process;

have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and

am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543.

Note: The terms of reference must be attached. Signature of the specialist: Name of company: Date: