pre-application draft basic assessment report: …

PRE-APPLICATION DRAFT BASIC ASSESSMENT REPORT: PROPOSED SOUTHERN OIL PLANT EXPANSION, ERF 6491 & 586, MOORREESBURG

August 2021 DEA&DP Reference Number: 16/3/3/6/7/1/F5/17/2103/21 Enviroprac Reference Number: SOILL Moorreesburg

i | P a g e

Executive Summary

1) Introduction

Southern Oil (Pty) Ltd operates a canola grain processing plant on Erf 6491 in the agri-town of Moorreesburg. Southern Oil is proposing to expand the plant in order to meet a greatly increased demand for their products and services. The expansion will entail additional grain silos as well as the addition of hot pressing and chemical extraction processes at the plant, and will cover not only Erf 6491, but also adjacent Erf 586. Figure A Site locality plan

Image courtesy of Google Earth, 2021

2) Application Requirements

The Southern Oil plant is situated directly adjacent to the Moorreesburgspruit non-perennial drainage channel. The plant expansion will include the installation of three 23m3 capacity storage tanks for hexane, which is defined as a “dangerous good’ in terms of the Environmental Impact Assessment (EIA) Regulations published in Government Notice No’s 982 to 985 of 2014, as amended. The expansion therefore requires an Environmental Authorisation in terms of the National Environmental Management Act, Act No. 107 of 1998 (NEMA) for installing dangerous goods storage infrastructure of more than 30m3 capacity within 100m of a watercourse (Listing Notice 3, Activity 10 of the EIA Regulations). A Basic Assessment- type EIA process will be followed for authorisation of the proposed plant expansion in terms of Chapter 4, Part 2 of the EIA Regulations.

3) Detail, Experience and Independence Statement of the EAP Southern Oil has appointed The Environmental Practice (Pty) Ltd (Enviroprac) to undertake the application for Environmental Authorisation. Enviroprac is an independent consultancy with no financial interest in operations at the canola processing plant, other than remuneration for work performed in terms of the NEMA and the EIA Regulations; and does not have and will not have any vested interest in the outcome of this Basic Assessment application. Colleen has fourteen years’ experience in environmental management, including impact assessment. Colleen is a registered environmental assessment practitioner with the Environmental Assessment Practitioners

Association of South Africa (Reg. No. 2018/166); has an Economics Honours degree from the University of Cape Town; and is a member of good standing with the International Association of Impact Assessment, the National Association for Clean Air, and the Institute of Waste Management in Southern Africa.

4) The Purpose of the Basic Assessment Process The purpose of the Basic Assessment process is to investigate the plant expansion proposal; identify site sensitivities and potentially significant impacts associated with the expansion; investigate site, layout and technology alternatives in order to minimise these impacts; and assess the impacts of the development proposal. Specialist input into the EIA process has been obtained where required. In accordance with the requirements of the EIA Regulations, the No-Go Alternative (i.e. the option of not expanding the current canola processing plant) has also been investigated. The impact assessment process has identified what, in Enviroprac and the specialist team’s opinion, is the Best Practicable Environmental Option (BPEO) for achieving the purpose of the activity given the context of the receiving environment. BPEO is defined as “the option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term”.

5) Project description The development proposal is for the expansion of an existing cold-pressing canola oil production plant, which is situated on Consolidated Erf 6491. The expansion will entail developing structures and infrastructure to enable hot pressing and chemical extraction of canola oil. The development will cover industrial-zoned Erf 6491, as well as business zoned Erf 586, which is situated just south of Erf 6491. The development will take place in a phased manner, and will include the following (Phases 1 and 2 will take place in quick succession and are for operational purposes interlinked): Phases 1 and 2: Phase 1:

1) The existing production building will be raised in height from 7.6m to 10.6m. 2) Three 29.4m-high grain storage silos with a combined storage capacity of 6740 tons will be

installed. 3) A seed receiving pit and seed cleaners and an oil cake storage bunker will be constructed. 4) Three 100 kilolitre processed oil storage tanks will be installed. 5) The footprint of the additional structures and infrastructure, will be some 1447m2 and will be

situated on Erf 6491. 6) Key specialist- and EAP-recommended mitigation measures included in the preferred alternative:

a. Trucks should enter and exit River Street via the Piketberg Road / N7 intersection and not via the Lang Street / Main Street intersection.

b. Building materials and finishes are to be visually recessive and non-reflective or such that within 2 years have weathered to be non-reflective;.

c. The mature eucalyptus in the south-western corner of the site must remain in place and large trees must be planted along the watercourse / Royal Street.

d. The grain conveyors may not operate at night. e. Low-noise grain conveyors must be used and conveyor elements must be maintained in order

to reduce contact noise. f. Silo aeration to be installed with sound attenuators to reduce the noise on the air inlet to

aeration fans. g. Noise monitoring must be undertaken once the plant is operational to determine whether a

noise attenuation barrier is required along the western site boundary. If required, the barrier (wall) should have no gaps and have a continuous minimum surface density of 10 kg/m2. This will minimize the transmission of sound through the barrier. Note that barriers should be located as close to the source or to the receptor location to be effective.

h. A complaints register must be kept. Phase 2: The site entrance and weighbridge will shift slightly north on Erf 6491; and the following infrastructure will be installed:

1) Two additional 29.4m-high grain storage silos with a storage capacity of 7400 tons; conveyors

(“seed loop chains”) from the silos to the seed press, some 160m in length; four 20 kilolitre rainwater harvesting tanks; and three additional 100 kilolitre processed oil storage tanks.

2) The footprint of the Phase 2 infrastructure will cover some 716m2. Construction of Phases 1 and 2, in order to enable the urgent installation of grain storage facilities for accommodating the 2021 canola grain harvest, commenced in June 2021. Phase 3: Phase 3 will entail the installation of infrastructure to enable the chemical extraction of oil. For operational purposes, Phases 1 and 2 can operate independently of Phase 3:

1) One 3.5 ton per hour boiler, cooling towers of 3m in height, and a conveyor (“loop chain”) from the seed press to the extraction plant will be installed.

2) A new factory shop, a new warehouse, a new chemical extraction plant and a wastewater (wash water) treatment plant of some 24000 litres per day capacity, discharging to municipal sewer, will be constructed; and

3) Three 23m3 capacity hexane storage tanks (a dangerous good) will be installed. 4) The footprint of Phase 3 will cover approximately 1017m2 and will be situated on the very southern side

of Erf 6491, and also on southern Erf 586. 5) Key specialist-and EAP-recommended mitigation measures included:

a. The chemical extraction plant and hexane storage tanks must be situated at least 10m away

from the watercourse. b. Equipment using hexane will be located in the solvent extraction plant which will be positioned

in a bunded area connected to a sump where any spillages will be contained. c. d. The hexane storage and handling infrastructure must be designed and installed according to

the relevant SANS codes and all other applicable regulations relating to Hazchem storage and handling infrastructure.

e. With underground hexane storage tanks , it will be necessary to determine groundwater flow direction; install monitoring wells up- and down-gradient of the chemical extraction plant and tank farm; and monitor groundwater bi-annually during wet and dry season.

f. Leak detection systems in accordance with SANS standards and industry best practice must be installed.

Bulk engineering services The plant expansion will connect to the municipal bulk engineering services network. Stormwater will discharge to the municipal system; effluent and sewerage will discharge to municipal sewer; the municipality will supply the development with potable water; and the municipality will supply the development with electricity via the infrastructure upgrades that the municipality has requested the applicant to implement. Site access The trucks travelling to and from the site will utilise the Piketberg Road / N7 intersection to access River Street and will not access and leave River Street via the Lang Street / Main Street intersection. Water uses The canola oil plant expansion will not require the use of water from the adjacent Moorreesburgspruit. The expansion will also not entail the discharge of effluent into the natural environment. Rather, effluent will be discharged to the municipal system. The development site does, however, fall within the “regulated area” of the Moorreesburgspruit in terms of Section 21 (i) and (c) of the National Water Act, being situated within 100m of the river. Also, Southern Oil is investigating the feasibility of abstracting groundwater as an alternative water source to the municipal water supply. A water use authorisation in terms of the Water Act is therefore being applied for.

6) Alternatives Identified and Investigated Alternative means of fulfilling the general purpose of the application, which is the provision of additional grain storage and processing services by Southern Oil, have been identified and investigated during the Basic Assessment process. These alternatives are based on the potential impacts associated with the plant expansion. In order to avoid or minimise any adverse impacts, and to maximise any benefits associated with the expansion, site, layout and technology alternatives were investigated. These include alternatives for establishing a suitable buffer between the plant and the Moorreesburgspruit; avoiding adverse impacts on the visual landscape; minimising nuisance noise impacts on nearby residences; avoiding road safety impacts in the Moorreesburg town from Southern Oil trucks; and preventing soil and groundwater contamination from the usage of hazardous chemicals. The development proposal described in the Basic Assessment Report, includes the alternatives identified by the specialist team and by Enviroprac, as having the least adverse impacts and the most benefit for the receiving environment and surrounding community.

7) Public Participation A key component of the Basic Assessment process is public participation. This allows stakeholders to assist in identifying issues or concerns around the activity which may need further investigation or assessment. In this way, stakeholders can also contribute to the identification of alternatives for achieving the Best Practicable Environmental Option. The identification of potential stakeholders; the process whereby these stakeholders are notified of the application process; providing stakeholders with an opportunity to register as “Interested and Affected Parties” (I&APs) and to comment on all reports published during the process; the requirement for the Environmental Assessment Practitioner and the project team to address any and all issues raised by registered I&APs; and the requirement that the applicant notifies registered I&APs of the decision which the DEA&DP reaches on the application, are all strictly prescribed by the regulations contained in Chapter 6 of the EIA Regulations. This Pre-Application Draft Basic Assessment Report is the first report to be distributed for public comment. A full record of public participation will be included in subsequent versions of the Basic Assessment Report.

8) Environmental Impact Statement Summary of Key Findings of the EIA The development proposal (including the layout, design, technology and operational alternatives that were found on investigation to be the best practicable options for the minimisation of health, safety and environmental risks) was assessed against the No-Go Option, or the option of not expanding the cold-press plant. The impacts which were identified as associated with the proposed plant expansion are: Construction phase:

− Standard construction-phase impacts such as dust, noise and a short-term change in visual character of the site.

− As regards the adjacent Moorreesburgspruit: increased erosion and turbidity in the watercourse; alteration of aquatic habitat; contamination by hydrocarbons and risk of pollution from solid waste associated with construction activities.

Operational phase:

− Risk of fire and explosion and impact on employee health and safety associated with the bulk storage and handling of hexane.

− Risk of contamination of soil, groundwater and freshwater ecosystems (the adjacent Moorreesburgspruit), since hexane is toxic to aquatic biota.

− Noise impacts from an increase in the scale and intensity of activities at the plant.

− Visual intrusion of the large silos on sensitive residential receptors; obstruction of views of the town from Piketberg Way; and visual intrusion of night lighting.

− Deterioration of ambient air quality due to pollutant emission associated with operating boilers.

− Additional truck trips can add to wear and tear on roads infrastructure and adversely impact road safety.

− Benefits in terms of job opportunities, service provision to and investment in the agri-processing industry, capital investment in the Moorreesburg economy and tax revenue and salaries to the benefit of the Moorreesburg town.

It has been found that any negative impacts associated with expanding the canola oil processing plant can be avoided altogether or can be reduced to acceptable levels through appropriate mitigation. All of these negative impacts have been found to be of Medium to Low significance. The identified benefits associated with the plant expansion were found to be of High benefit due to the regional nature of the service the plant will provide. The development proposal has been assessed against the No-Go Option, which is the option of not expanding the plant. The No-Go Option has thus provided a baseline against which to assess the benefits and drawbacks of the proposed plant expansion. With the No-Go Option, the benefits identified were:

− No additional impacts on the Moorreesburgspruit.

− No risk of soil, groundwater and freshwater contamination.

− No risk of fire and explosion and no health and safety impacts associated with the bulk storage and

handling of hexane.

− No additional noise impacts.

− No visual intrusion impacting sensitive residential receptors; and no obstruction of views of the town.

− No impacts on ambient air quality.

− Traffic volumes will remain the same.

However, the No-Go Option has the significant drawback of not realising the socio-economic benefits associated with the plant expansion in terms of essential service to the agri-processing industry, jobs, capital investment, and salaries and rates and taxes to the benefit of Moorreesburg.

A summary of the findings of the impact assessment is as follows:

Table A: Summary of Construction & Decommissioning & Closure Phase Impacts Associated with the Plant Expansion

Impact Impact Significance with Mitigation (Where Mitigation is Applicable)

Plant Expansion (Including all Preferred Layout, Design, Technology & Operational

Alternatives)

Dust Medium

Noise Medium

Soil, groundwater & freshwater

contamination; littering and erosion into

the spruit

Low

Visual Medium to Low

Table B: Summary of Operational Phase Impacts Associated with the Plant Expansion1



Alternatives)

Soil and groundwater contamination;

freshwater contamination Low

Fire & explosion; health and safety risk Low

Noise (wellbeing) impacts Low

Ambient air quality impacts Low

Visual Intrusion on sensitive residential

receptors Medium-Low

Obstruction of Town Views Medium-Low

Visual Intrusion of night lighting Low

Traffic impacts (possible congestion, road

safety impacts and wear and tear on

roads)

Low

Socio-economic benefits High

Recommendations from the EAP and Recommended Conditions to be Included in the Environmental Authorisation: The canola oil plant expansion should be authorised with the inclusion of all specialist- and EAP-recommended mitigation measures. This is due to the finding that all identified impacts associated with the proposal, can be mitigated to medium or low significance. And that the medium-significance impacts identified are offset by the high socio-economic benefits associated with the expansion. The following measures should be listed as conditions of authorisation, in addition to the EMPr being approved as a condition of authorisation: Freshwater, soil and groundwater contamination; risk of fire and explosion and health and safety impacts

− The chemical extraction plant and hexane storage tanks must be situated at least 10m away from the watercourse.

− Equipment using hexane will be located in the solvent extraction plant which will be positioned in a bunded area connected to a sump where any spillages will be contained.

− Determine groundwater flow direction; install monitoring wells up- and down-gradient of the

chemical extraction plant and tank farm; and monitor groundwater bi-annually during wet and dry

season.

− The hexane storage and handling infrastructure must be designed and installed according to the relevant SANS codes and all other applicable regulations relating to Hazchem storage and handling infrastructure.

− Leak detection systems in accordance with SANS standards and industry best practice must be

installed.

1 Includes impacts that could be experienced during the operational phase due to planning and design-phase

decisions.

− A registered professional engineer must sign off on the design and installation of the tanks and associated infrastructure.

− A 15m buffer around the chemical extraction plant must be incorporated into the site layout in accordance with National Fire Protection Association (NFPA) 36-2017 Standard for Solvent Extraction Plants.

− A Standard Operating Procedure for all activities relating to hexane storage, refilling, handling and use in processing must be compiled with the purpose of minimising associated health, safety and environmental risks.

− Staff must be trained in the SOP, with records of staff training retained for external auditing purposes.

− Bi-annual internal audits of the operation against the SOP must be conducted with records retained for external auditing purposes.

− A Preventative Maintenance Plan for the infrastructure relating to hazchem storage and handling; for

the boilers and grit arrestors; and for the grain conveyors to ensure ongoing noise reduction, must be

compiled.

− Staff must be trained in preventative maintenance, with records of staff training retained for external auditing purposes.

− Bi-annual internal audits of the operation against the Preventative Maintenance Plan must be conducted with records retained for external auditing purposes.

− A fuel and hazchem Spill Response Procedure must be compiled and attached to the Operational EMPr. The Spill Response Procedure must be submitted to the DEA&DP: Pollution & Chemicals Directorate and to the DWS for approval before filling of the hexane storage tanks and before commissioning of the chemical extraction plant.

− A fuel and Hazchem spill response kit must be in place at the chemical extraction plant.

Visual2

− Building materials and finishes are to be visually recessive and non-reflective or such that within 2

years have weathered to be non-reflective.

− A Landscape Architect be appointed to draw up a landscape plan for planting of trees, on and off the

site, that reduces the visual impact of the building from the highly sensitive receptors.

− An Operational Management Plan for Landscaping is produced by the Landscape Architects which will

prescribe maintenance requirements in order to establish and retain trees in good condition.

− That the required mitigation measures regarding Lighting and Signage are designed for and

implemented.

− The Construction Mitigation Measures are included in the EMP.

Noise3

− The grain conveyors may not operate at night.

− Low-noise grain conveyors must be used and conveyor elements must be maintained in order to reduce contact noise.

− Silo aeration to be installed with sound attenuators to reduce the noise on the air inlet to aeration fans.

− Noise monitoring must be undertaken once the plant is operational to determine whether a noise attenuation barrier is required along the western site boundary. If required, the barrier (wall) should have no gaps and have a continuous minimum surface density of 10 kg/m2. This will minimize the transmission of sound through the barrier. Note that barriers should be located as close to the source or to the receptor location to be effective.

− A complaints register must be kept.

2 Recommended inclusions in EA from Megan Anderson Landscape Architects. Full visual impact mitigation

measures are included in impact assessment and in EMP. 3 Good-practice general measures for noise reduction have not been included here, but are included in the

impact assessment and in the EMPr.

FORM NO. BAR10/2019 Page 1 of 40

FORM NO. BAR10/2019

BASIC ASSESSMENT REPORT

THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) AND

THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS.

NOVEMBER 2019

(For official use only)

Pre-application Reference Number (if applicable): 16/3/3/6/1/F5/17/2087/21

EIA Application Reference Number:

NEAS Reference Number:

Exemption Reference Number (if applicable):

Date BAR received by Department:

Date BAR received by Directorate:

Date BAR received by Case Officer:

GENERAL PROJECT DESCRIPTION

(This must Include an overview of the project including the Farm name/Portion/Erf number)

Expansion of Southern Oil Canola Oil Processing Plant, Consolidated Erf 6491 & Erf 586, River Street,

Moorreesburg


IMPORTANT INFORMATION TO BE READ PRIOR TO COMPLETING THIS BASIC ASSESSMENT

REPORT

1. The purpose of this template is to provide a format for the Basic Assessment report as set out in

Appendix 1 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”),

Environmental Impact Assessment (“EIA”) Regulations, 2014 (as amended) in order to ultimately

obtain Environmental Authorisation.

2. The Environmental Impact Assessment (“EIA”) Regulations is defined in terms of Chapter 5 of the

National Environmental Management Act, 19998 (Act No. 107 of 1998) (“NEMA”) hereinafter

referred to as the “NEMA EIA Regulations”.

3. The required information must be typed within the spaces provided in this Basic Assessment Report

(“BAR”). The sizes of the spaces provided are not necessarily indicative of the amount of

information to be provided.

4. All applicable sections of this BAR must be completed.

5. Unless protected by law, all information contained in, and attached to this BAR, will become public

information on receipt by the Competent Authority. If information is not submitted with this BAR

due to such information being protected by law, the applicant and/or Environmental Assessment

Practitioner (“EAP”) must declare such non-disclosure and provide the reasons for believing that

the information is protected.

6. This BAR is current as of November 2019. It is the responsibility of the Applicant/ EAP to ascertain

whether subsequent versions of the BAR have been released by the Department. Visit this

Department’s website at http://www.westerncape.gov.za/eadp to check for the latest version of

this BAR.

7. This BAR is the standard format, which must be used in all instances when preparing a BAR for Basic

Assessment applications for an environmental authorisation in terms of the NEMA EIA Regulations

when the Western Cape Government Department of Environmental Affairs and Development

Planning (“DEA&DP”) is the Competent Authority.

8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this

BAR must be submitted to the Department at the postal address given below or by delivery thereof

to the Registry Office of the Department. Reasonable access to copies of this Report must be

provided to the relevant Organs of State for consultation purposes, which may, if so indicated by

the Department, include providing a printed copy to a specific Organ of State.

9. This BAR must be duly dated and originally signed by the Applicant, EAP (if applicable) and

Specialist(s) and must be submitted to the Department at the details provided below.

10. The Department’s latest Circulars pertaining to the “One Environmental Management System”

and the EIA Regulations, any subsequent Circulars, and guidelines must be taken into account

when completing this BAR.

11. Should a water use licence application be required in terms of the National Water Act, 1998 (Act

No. 36 of 1998) (“NWA”), the “One Environmental System” is applicable, specifically in terms of the

synchronisation of the consideration of the application in terms of the NEMA and the NWA. Refer

to this Department’s Circular EADP 0028/2014: One Environmental Management System.

12. Where Section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (“NHRA”) is

triggered, a copy of Heritage Western Cape’s final comment must be attached to the BAR.

13. The Screening Tool developed by the National Department of Environmental Affairs must be used

to generate a screening report. Please use the Screening Tool link

https://screening.environment.gov.za/screeningtool to generate the Screening Tool Report. The

screening tool report must be attached to this BAR.

http://www.westerncape.gov.za/eadp

https://screening.environment.gov.za/screeningtool


14. Where this Department is also identified as the Licencing Authority to decide on applications under

the National Environmental Management: Air Quality Act (Act No. 29 of 2004) (‘NEM:AQA”), the

submission of the Report must also be made as follows, for-

Waste Management Licence Applications, this report must also (i.e., another hard copy and

electronic copy) be submitted for the attention of the Department’s Waste Management

Directorate (Tel: 021-483-2728/2705 and Fax: 021-483-4425) at the same postal address as the Cape

Town Office.

Atmospheric Emissions Licence Applications, this report must also be (i.e., another hard copy and

electronic copy) submitted for the attention of the Licensing Authority or this Department’s Air

Quality Management Directorate (Tel: 021 483 2888 and Fax: 021 483 4368) at the same postal

address as the Cape Town Office.

DEPARTMENTAL DETAILS

CAPE TOWN OFFICE: REGION 1 and REGION 2

(Region 1: City of Cape Town, West Coast District)

(Region 2: Cape Winelands District & Overberg District)

GEORGE OFFICE: REGION 3

(Central Karoo District & Garden Route District)

BAR must be sent to the following details:

Western Cape Government

Department of Environmental Affairs and Development

Planning

Attention: Directorate: Development Management

(Region 1 or 2)

Private Bag X 9086

Cape Town,

8000

Registry Office

1st Floor Utilitas Building

1 Dorp Street,

Cape Town

Queries should be directed to the Directorate:

Development Management (Region 1 and 2) at:

Tel: (021) 483-5829

Fax (021) 483-4372

BAR must be sent to the following details:

Western Cape Government

Department of Environmental Affairs and Development

Planning

Attention: Directorate: Development Management

(Region 3)

Private Bag X 6509

George,

6530

Registry Office

4th Floor, York Park Building

93 York Street

George

Queries should be directed to the Directorate:

Development Management (Region 3) at:

Tel: (044) 805-8600

Fax (044) 805 8650

MAPS

Provide a location map (see below) as Appendix A1 to this BAR that shows the location of the proposed development

and associated structures and infrastructure on the property.

Locality Map: The scale of the locality map must be at least 1:50 000.

For linear activities or development proposals of more than 25 kilometres, a smaller scale e.g.,

1:250 000 can be used. The scale must be indicated on the map.

The map must indicate the following:

• an accurate indication of the project site position as well as the positions of the alternative

sites, if any;

• road names or numbers of all the major roads as well as the roads that provide access to

the site(s)

• a north arrow;

• a legend; and

• a linear scale.

For ocean based or aquatic activity, the coordinates must be provided within which the activity

is to be undertaken and a map at an appropriate scale clearly indicating the area within which

the activity is to be undertaken.

Where comment from the Western Cape Government: Transport and Public Works is required,

a map illustrating the properties (owned by the Western Cape Government: Transport and

Public Works) that will be affected by the proposed development must be included in the

Report.


Provide a detailed site development plan / site map (see below) as Appendix B1 to this BAR; and if applicable, all

alternative properties and locations.

Site Plan: Detailed site development plan(s) must be prepared for each alternative site or alternative

activity. The site plans must contain or conform to the following:

• The detailed site plan must preferably be at a scale of 1:500 or at an appropriate scale.

The scale must be clearly indicated on the plan, preferably together with a linear scale.

• The property boundaries and numbers of all the properties within 50m of the site must be

indicated on the site plan.

• On land where the property has not been defined, the co-ordinates of the area in which

the proposed activity or development is proposed must be provided.

• The current land use (not zoning) as well as the land use zoning of each of the adjoining

properties must be clearly indicated on the site plan.

• The position of each component of the proposed activity or development as well as any

other structures on the site must be indicated on the site plan.

• Services, including electricity supply cables (indicate aboveground or underground), water

supply pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads

that will form part of the proposed development must be clearly indicated on the site plan.

• Servitudes and an indication of the purpose of each servitude must be indicated on the

site plan.

• Sensitive environmental elements within 100m of the site must be included on the site plan,

including (but not limited to):

o Watercourses / Rivers / Wetlands

o Flood lines (i.e., 1:100 year, 1:50 year and 1:10 year where applicable);

o Coastal Risk Zones as delineated for the Western Cape by the Department of

Environmental Affairs and Development Planning (“DEA&DP”):

o Ridges;

o Cultural and historical features/landscapes;

o Areas with indigenous vegetation (even if degraded or infested with alien species).

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

• North arrow

A map/site plan must also be provided at an appropriate scale, which superimposes the

proposed development and its associated structures and infrastructure on the environmental

sensitivities of the preferred and alternative sites indicating any areas that should be avoided,

including buffer areas.

Site photographs Colour photographs of the site that shows the overall condition of the site and its surroundings

(taken on the site and taken from outside the site) with a description of each photograph. The

vantage points from which the photographs were taken must be indicated on the site plan, or

locality plan as applicable. If available, please also provide a recent aerial photograph.

Photographs must be attached to this BAR as Appendix C. The aerial photograph(s) should be

supplemented with additional photographs of relevant features on the site. Date of

photographs must be included. Please note that the above requirements must be duplicated

for all alternative sites.

Biodiversity

Overlay Map:

A map of the relevant biodiversity information and conditions must be provided as an overlay

map on the property/site plan. The Map must be attached to this BAR as Appendix D.

Linear activities

or development

and multiple

properties

GPS co-ordinates must be provided in degrees, minutes and seconds using the Hartebeeshoek

94 WGS84 co-ordinate system.

Where numerous properties/sites are involved (linear activities) you must attach a list of the Farm

Name(s)/Portion(s)/Erf number(s) to this BAR as an Appendix.

For linear activities that are longer than 500m, please provide a map with the co-ordinates taken

every 100m along the route to this BAR as Appendix A3.

ACRONYMS

DAFF: Department of Forestry and Fisheries

DEA: Department of Environmental Affairs

DEA& DP: Department of Environmental Affairs and Development Planning

DHS: Department of Human Settlement

DoA: Department of Agriculture

DoH: Department of Health

DWS: Department of Water and Sanitation

EMPr: Environmental Management Programme

HWC: Heritage Western Cape

NFEPA: National Freshwater Ecosystem Protection Assessment

NSBA: National Spatial Biodiversity Assessment

TOR: Terms of Reference


WCBSP: Western Cape Biodiversity Spatial Plan

WCG: Western Cape Government

ATTACHMENTS

Note: The Appendices must be attached to the BAR as per the list below. Please use a (tick) or a x (cross) to

indicate whether the Appendix is attached to the BAR.

The following checklist of attachments must be completed.

APPENDIX (Tick) or

x (cross)

Appendix A:

Maps

Appendix A1: Locality Map

Appendix A2:

Coastal Risk Zones as delineated in terms of

ICMA for the Western Cape by the Department

of Environmental Affairs and Development

Planning

N/A

Appendix A3: Map with the GPS co-ordinates for linear

activities N/A

Appendix B:

Appendix B1:

Site development plan(s) (includes

environmental sensitivities of the preferred site,

indicating any areas that should be avoided,

including buffer areas)

Appendix B2 Anticipated truck routes

Appendix B3 Recommended tree planting locations from

Visual Impact Assessment

Appendix B4 Swartland Municipality’s Spatial Land Use

Proposals Map, 2019

Appendix B5 Site layout plan revisions A – D: layouts

investigated in order to obtain preferred layout

Appendix C: Site Sensitivity Verification Report, including Photographs

Appendix D: Biodiversity overlay map

Appendix E:

Permit(s) / license(s) / exemption notice, agreements, comments from State

Department/Organs of state and service letters from the municipality.

Appendix E1: Final comment/ROD from HWC

Appendix E2: Copy of comment from Cape Nature

N/A – fully

transformed

site

Appendix E3: Final Comment from the DWS Comment on

this BAR will be obtained from DWS x

Appendix E4: Comment from the DEA: Oceans and Coast N/A

Appendix E5: Comment from the DAFF N/A


Appendix E6:

Comment from WCG: Transport and Public

Works Comment on this BAR will be obtained

from Swartland Municipality and from WCG

Transport Department

x

Appendix E7: Comment from WCG: DoA Comment on this

BAR will be obtained from DoA x

Appendix E8: Comment from WCG: DHS N/A

Appendix E9: Comment from WCG: DoH N/A

Appendix E10:

Comment from DEA&DP: Pollution

Management Comment on this BAR will be

obtained from P&C Management

x

Appendix E11:

Comment from DEA&DP: Waste Management

Comment on this BAR will be obtained from

Waste Management

x

Appendix E12:

Comment from DEA&DP: Biodiversity


DEA&DP Biodiversity.

x

Appendix E13: Comment from DEA&DP: Air Quality N/A

Appendix E14: Comment from DEA&DP: Coastal

Management N/A

Appendix E15:

Comment from the local authority Comment

on this BAR will be obtained from Swartland

Municipality

x

Appendix E16:

Confirmation of all services (water, electricity,

sewage, solid waste management)

− See subdivision & consolidation

approval attached

− See approval with conditions for

electricity connection

− Municipality comment on the

Stormwater Management Plan will be

obtained before submission of the

Final BAR

− Confirmation of water supply and

sewerage reticulation service

capacity will be obtained before

submission of the Final BAR

Appendix E17:

Comment from the District Municipality


West Coast District Municipality

Appendix E18: Copy of an exemption notice N/A

Appendix E19 Pre-approval for the reclamation of land N/A

Appendix E20:

Proof of agreement/TOR of the specialist

studies conducted. Please see specialist

studies attached.


Appendix E21: Proof of land use rights

Appendix E22: Proof of public participation agreement for

linear activities N/A

Appendix F:

Public participation information: including a copy of the register of

I&APs, the comments and responses Report, proof of notices,

advertisements and any other public participation information as is

required.

Identified Stakeholders Table

Appendix G:

Specialist Report(s)

1) Level Four Visual Impact Assessment, Megan Anderson

Landscape Architects, August 2021

2) Freshwater Risk Assessment and Compliance Statement,

Confluent Environmental, May 2021

3) Noise Survey and Compliance Statement, Soundscape

Consulting, May 2021

4) Heritage Notice of Intent to Develop, Agency for Cultural

Resource Management, June 2021

5) Traffic Impact Statement, EFG Engineers, August 2021

Appendix H: EMPr

Appendix I: Screening tool report

Appendix J: The impact and risk assessment for each alternative

Appendix K:

Need and desirability for the proposed activity or development in

terms of this Department’s guideline on Need and Desirability (March

2013)/DEA Integrated Environmental Management Guideline


Table of Contents

A. SECTION A: ADMINISTRATIVE DETAILS ........................................................................... 9

B. Section B: CONFIRMATION OF SPECIFIC PROJECT DETAILS AS INCLUDED IN THE

APPLICATION FORM ....................................................................................................................... 10

C. SECTION C: LEGISLATION/POLICIES AND/OR GUIDELINES/PROTOCOLS ............... 13

1. Exemption applied for in terms of the NEMA and the NEMA EIA Regulations .................... 13

2. Is the following legislation applicable to the proposed activity or development. .................... 13

3. Other legislation ........................................................................................................................ 13

4. Policies ...................................................................................................................................... 13

5. Guidelines ................................................................................................................................. 14

6. Protocols ................................................................................................................................... 14

D. Section D: APPLICABLE LISTED ACTIVITIES ..................................................................... 15

E. SECTION E: PLANNING CONTEXT AND NEED AND DESIRABILITY .......................... 15

F. SECTION F: PUBLIC PARTICIPATION ................................................................................. 18

G. SECTION G: DESCRIPTION OF THE RECEIVING ENVIRONMENT ................................ 19

1. Groundwater ............................................................................................................................. 19

2. Surface water ............................................................................................................................ 20

3. Coastal Environment N/A ......................................................................................................... 20

4. Biodiversity ............................................................................................................................... 20

5. Geographical Aspects ............................................................................................................... 21

6. Heritage Resources ................................................................................................................... 21

7. Historical and Cultural Aspects ................................................................................................ 22

8. Socio/Economic Aspects .......................................................................................................... 22

H. SECTION H: ALTERNATIVES, METHODOLOGY AND ASSESSMENT OF

ALTERNATIVES................................................................................................................................ 25

1. Details of the alternatives identified and considered ................................................................ 25

2. “No-Go” areas ........................................................................................................................... 29

3. Methodology to determine the significance ratings of the potential environmental impacts and

risks associated with the alternatives. .............................................................................................. 30

4. Assessment of each impact and risk identified for each alternative ......................................... 30

I. Section I: FINDINGS, IMPACT MANAGEMENT AND MITIGATION MEASURES .......... 30

J. SECTION J: GENERAL ............................................................................................................ 33

1. Environmental Impact Statement .............................................................................................. 33

2. Recommendation of the Environmental Assessment Practitioner (“EAP”) ............................. 35

3. Water ......................................................................................................................................... 37

4. Waste......................................................................................................................................... 37

5. Energy Efficiency ..................................................................................................................... 37

K. SECTION K: DECLARATIONS ................................................................................................ 38


A. SECTION A: ADMINISTRATIVE DETAILS

Highlight the

Departmental Region in

which the intended

application will fall

CAPE TOWN OFFICE

GEORGE OFFICE

REGION 1

(City of Cape

Town,

West Coast

District)

REGION 2

(Cape

Winelands

District &

Overberg

District)

REGION 3

(Central Karoo District &

Garden Route District)

1

Duplicate this section

where there is more

than one Proponent

Name of Proponent:

Southern Oil (Pty) Ltd

Name of contact

person for Proponent

(if other): Kellie Becker, Managing Director

Company/ Trading

name/State

Department/Organ of

State:

Southern Oil

Company Registration

Number: 1995 / 006698 / 07

Postal address:

PO Box 707, Swellendam

Postal code: 6740 Telephone: ( 028 )514 3441 (ext. 1144) Cell: 082 492 6740

E-mail: [email protected]; [email protected]

Fax: ( 028 ) 514 1295

Company of EAP: The Environmental Practice 2 EAP name: Colleen McCreadie

Postal address: 23 Dartmouth Road, Muizenberg Postal code:7945

Telephone: ( 021) 788 9323 Cell: 083 695 1664

E-mail: [email protected] Fax: None Qualifications: BComm Hons Economics

EAPASA registration

no:

2018/166

3

A


where there is more

than one landowner

Name of landowner:

Consolidated Erf 6491 and Erf 586: Southern Oil (Pty) Ltd

Name of contact

person for landowner

(if other): As above

Postal address:

Telephone:

E-mail:

Postal code:

( ) Cell:

Fax: ( )

3

B


where there is more

than one landowner

Name of landowner:

Name of contact

person for landowner

(if other):

mailto:[email protected]

mailto:[email protected]


Postal address:

Telephone:

E-mail:

Postal code:

( ) Cell:

Fax: ( )

Note: The written consent form must be attached as Appendix B to this NOI form. If there is more than one cadastral, written

consent must be provided by all landowners.

The consent of the landowner or person in control of the land is not required for: a) linear activities; b) an activity directly

related to prospecting or exploration of a mineral and petroleum resource or extraction and primary processing of a mineral

resource; or c) strategic integrated projects (“SIPs”) as contemplated in the Infrastructure Development Act, 2014 (Act No.

23 of 2014).

4

Name of Person in

control of the land:

Name of contact

person for person in

control of the land:

Postal address:


Postal code:

Telephone: ( ) Cell:

E-mail: Fax: ( )

5


where there is more

than one Municipal

Jurisdiction

Municipality in whose

area of jurisdiction the

proposed activity will

fall:

Swartland Municipality

Contact person: Alwyn Burger, Town Planner Postal address: Private Bag X52, Malmesbury Postal code: 7299 Telephone: ( 082 ) 487 9400 Cell: 06 480 9870

E-mail: [email protected]

Fax: ( 022 ) 487 9440

B. Section B: CONFIRMATION OF SPECIFIC PROJECT DETAILS AS INCLUDED IN THE APPLICATION

FORM

1. Is the proposed development (please

tick): New Expansion X

2. Is the proposed site(s) a brownfield of greenfield site? Please explain.

Brownfield: Erf 4131 is already developed for Southern Oil’s cold pressing canola oil plant. And Erf 586 is developed for residential purposes.

3. For Linear activities or developments N/A

4. Other developments

4.1. Property size(s) of all proposed site(s): 10578m2

4.2. Developed footprint of the existing facility and associated infrastructure (if applicable): (buildings and

transformed yards and gardens and storage tanks, etc. covers entire site) 10578m2

4.3. Development footprint of the proposed development and associated infrastructure size(s) for all

alternatives: 10578m2

4.4. Provide a detailed description of the proposed development and its associated infrastructure (This must include

details of e.g. buildings, structures, infrastructure, storage facilities, sewage/effluent treatment and holding facilities).

The development proposal is for the expansion of an existing cold-pressing canola oil production plant, which is situated on Consolidated Erf 6491. The expansion will entail developing structures and infrastructure to enable hot pressing and chemical extraction of canola oil. The development will cover industrial-zoned Erf 6491, as well as business zoned Erf 586, which is situated just south of Erf 6491. The development will take place in a phased manner, and will include the following (Phases 1 and 2 will take place in quick succession and are for operational purposes interlinked):


Phases 1 and 2: Phase 1: 1) The existing production building will be raised in height from 7.6m to 10.6m. 2) Three 29.4m-high grain storage silos with a combined storage capacity of 6740 tons will be installed. 3) A seed receiving pit and seed cleaners and an oil cake storage bunker will be constructed. 4) Three 100 kilolitre processed oil storage tanks will be installed. 5) The footprint of the additional structures and infrastructure will be some 1447m2 and will cover the existing, developed area of Erf 4131, as well as the Portion A of northern Erf 4128, which has been subdivided from Erf 4128 and now forms part of Consolidated Erf 4131. Phase 2: The site entrance and weighbridge will shift slightly north; and the following infrastructure will be installed: 1) Two additional 29.4m-high grain storage silos with a storage capacity of 7400 tons; conveyors (“seed loop chains”) from the silos to the seed press, some 160m in length; four 20 kilolitre rainwater harvesting tanks; and three additional100 kilolitre processed oil storage tanks. 2) The footprint of the Phase 2 infrastructure will cover some 716m2. Construction of Phases 1 and 2, in order to enable the urgent installation of grain storage facilities for accommodating the 2021 canola grain harvest, commenced in June 2021. Phase 3: Phase 3 will entail the installation of infrastructure to enable the chemical extraction of oil. For operational purposes, Phases 1 and 2 can operate independently of Phase 3: 1) One 3.5 ton per hour boiler, cooling towers of 3m in height, and a conveyor (“loop chain”) from the seed press to the extraction plant will be installed. 2) A new factory shop, a new warehouse, a new chemical extraction plant and a wastewater (wash water) treatment plant of some 24000 litres per day capacity, discharging to municipal sewer, will be constructed; and 3) Three 23m3 capacity hexane storage tanks (a dangerous good) will be installed. 4) The footprint of Phase 3 will cover approximately 1017m2 and will be situated on the very southern side of Erf 4131, and also on southern Erf 586. Bulk engineering services The plant expansion will connect to the municipal bulk engineering services network. Stormwater will discharge to the municipal system; effluent will discharge to municipal sewer; the municipality will supply the development with potable water; and the municipality will supply the development with electricity via the infrastructure upgrades that the municipality has requested the applicant to implement. Please see Appendix E for confirmation of electricity supply capacity. The municipality has advised the applicant verbally that capacity to provide other services is available. Written confirmation in this regard will be included in the Final Basic Assessment Report in due course. Site access The trucks travelling to and from the site will utilise the Piketberg Road / N7 intersection and will not access and leave River Street via the Lang Street / Main Street intersection. Water uses The canola oil plant expansion will not require the use of water from the adjacent Moorreesburgspruit. The expansion will also not entail the discharge of effluent into the natural environment. Rather, effluent will be discharged to the municipal system.


The development site does, however, fall within the “regulated area” of the Moorreesburgspruit in terms of Section 21 (i) and (c) of the National Water Act, being situated within 100m of the river. Also, SOILL is investigating the feasibility of abstracting groundwater as an alternative water source to the municipal water supply. A water use authorisation in terms of the Water Act is therefore being applied for. Canola oil manufacturing process description

1) Canola seed is delivered in bulk by truck to the site.

2) The seed is loaded into the seed receiving pit, from where it is conveyed by bucket elevator to seed cleaners

and from there with bucket elevator and chain conveyors into the grain silos.

3) The seed is conveyed by chain conveyor to the preparation plant, where it is preheated before flaking to

increase surface area. The flakes are then conditioned and dried before being pressed in a mechanical screw

press.

4) The press cake is conveyed to the chemical extraction plant where the balance of the oil is chemically

extracted from the press cake. Hexane is a solvent and when fed counter-current to the press cake, extracts

the oil.

5) The hexane is evaporated off the oil and the meal and oil recovered.

6) Oil meal from the solvent extraction process, is conveyed to the meal cooler and then meal bunker for

storage. The oil meal is delivered in bulk to animal feed millers and used on site as an ingredient for the

manufacture of Extrublend, a product used in agricultural feeds.

7) The crude oil from the preparation plant and chemical extraction plant is stored on site in bulk tanks and

transported in bulk tanker trucks to other plants for further refining before sale to retail.

4.5. Indicate how access to the proposed site(s) will be obtained for all alternatives.

Access will be via River Street, via the current access point for Portion A of neighbouring Erf 4128. Potion A has been

consolidated into Erf 4131.

4.6.

SG Digit code(s) of

the proposed site(s)

for all alternatives: C 0 4 6 0 0 0 1 0 0 0 0 0 6 4 9 1 0 0 0 0

C 0 4 6 0 0 0 1 0 0 0 0 0 5 8 6 0 0 0 0 0

4.7.

Coordinates of the proposed site(s) for all alternatives:

Latitude (S) 33° 09’ 03.54”

Longitude (E) 18° 39’ 59.63”


Figure 2 Site locality map

C. SECTION C: LEGISLATION/POLICIES AND/OR GUIDELINES/PROTOCOLS

1. Exemption applied for in terms of the NEMA and the NEMA EIA Regulations

2. Is the following legislation applicable to the proposed activity or development.

The National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24

of 2008) (“ICMA”). If yes, attach a copy of the comment from the relevant competent authority as

Appendix E4 and the pre-approval for the reclamation of land as Appendix E19.

YES NO X

The National Heritage Resources Act, 1999 (Act No. 25 of 1999) (“NHRA”). If yes, attach a copy of

the comment from Heritage Western Cape as Appendix E1.

YES NO X

The National Water Act, 1998 (Act No. 36 of 1998) (“NWA”). If yes, attach a copy of the comment

from the DWS as Appendix E3.

YES X NO

The National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (“NEM:AQA”). If yes, attach a copy of the comment from the relevant authorities as Appendix E13.

YES NO X

The National Environmental Management Waste Act (Act No. 59 of 2008) (“NEM:WA”) YES X NO

The National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004 (“NEMBA”). YES NO X

The National Environmental Management: Protected Areas Act, 2003 (Act No. 57 of 2003)

(“NEMPAA”).

YES NO X

The Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983). If yes, attach comment

from the relevant competent authority as Appendix E5.

YES NO X

3. Other legislation

List any other legislation that is applicable to the proposed activity or development.

The Swartland Municipality’s town planning by-law: Erf 586 needs to be rezoned from residential to industrial land use. A departure from the height restriction on Erf 6491 has been granted in order to accommodate the grain silos.

4. Policies Explain which policies were considered and how the proposed activity or development complies and responds to these

policies.

Has exemption been applied for in terms of the NEMA and the NEMA EIA Regulations. If yes, include

a copy of the exemption notice in Appendix E18. YES NO X

Site – Erf 6491 & Erf 586


Please refer to the Need and Desirability investigation attached in Appendix K.

5. Guidelines List the guidelines which have been considered relevant to the proposed activity or development and explain how they

have influenced the development proposal.

DEA 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, 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.

DEADP Guideline Document: Guideline on Alternatives, 2013

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

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

The investigation into the Need and Desirability of the facility was closely informed by this guideline.

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

This guideline was used in determining which specialists were required for this Basic Assessment process.

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

All specialist inputs were reviewed and summarized by the EAP, with the guidance of this document.

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 plant expansion.

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.

Swartland Municipality’s Municipal Planning By-Law, 2020

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

Swartland Municipality’s Spatial Development Framework, 2017

The principles governing development in the Swartland region, which are contained in the municipal SDF, were referred to in the investigation of the Need and Desirability of the plant expansion.

6. Protocols Explain how the proposed activity or development complies with the requirements of the protocols referred to in the NOI

and/or application form


The DEFF Screening Tool and the subsequent Site Sensitivity Verification exercise that was undertaken by the EAP and specialists (see Appendix C), identified that only certain of the specialist protocols are relevant to this application. Therefore, only the following specialist studies have been undertaken:

− A Freshwater Risk Assessment, which complies with the requirements of a Compliance Statement, has

been compiled.

− A Noise Survey and Compliance Statement has been compiled

− A Level 4 Visual Impact Assessment has been compiled

− A Heritage Notice of intent to Develop has been submitted to Heritage Western Cape as a screening-type

exercise. With no identified heritage impacts, no compliance statement was considered necessary.

− A Traffic Impact Statement has been compiled

D. Section D: APPLICABLE LISTED ACTIVITIES

List the applicable activities in terms of the NEMA EIA Regulations

Activity No(s): Provide the relevant Basic Assessment Activity(ies)

as set out in Listing Notice 1

Describe the portion of the proposed

development to which the applicable listed

activity relates.


as set out in Listing Notice 3



activity relates.

10 The development of dangerous goods storage infrastructure >30m3 in an urban area in the Western Cape – either on the watercourse side of a development setback, or within 100m of a watercourse if no setback has been established.

Phase 3, from which Phases 1 and 2 are operationally independent, includes the installation of three 23m3 aboveground storage tanks for the storage of hexane for chemical extraction of the canola oil. Hexane is a dangerous good.

Note:

• The listed activities specified above must reconcile with activities applied for in the application form. The onus is on the

Applicant to ensure that all applicable listed activities are included in the application. If a specific listed activity is not included

in an Environmental Authorisation, a new application for Environmental Authorisation will have to be submitted.

• Where additional listed activities have been identified, that have not been included in the application form, and amended

application form must be submitted to the competent authority.

List the applicable waste management listed activities in terms of the NEM:WA


as set out in Category A



activity relates.

None

List the applicable listed activities in terms of the NEM:AQA

Activity No(s):

Provide the relevant Listed Activity(ies)



activity relates.

None

E. SECTION E: PLANNING CONTEXT AND NEED AND DESIRABILITY

1. Provide a description of the preferred alternative.

The development proposal is for the expansion of an existing cold-pressing canola oil production plant, which is situated on Consolidated Erf 6491. The expansion will entail developing structures and infrastructure to enable hot pressing and chemical extraction of canola oil. The development will cover industrial-zoned Erf 6491, as well as business zoned Erf 586, which is situated just south of Erf 6491. The development will take place in a phased manner,


and will include the following (Phases 1 and 2 will take place in quick succession and are for operational purposes interlinked): Phases 1 and 2: Phase 1:

1) The existing production building will be raised in height from 7.6m to 10.6m. 2) Three 29.4m-high grain storage silos with a combined storage capacity of 6740 tons will be installed. 3) A seed receiving pit and seed cleaners and an oil cake storage bunker will be constructed. 4) Three 100 kilolitre processed oil storage tanks will be installed. 5) The footprint of the additional structures and infrastructure, will be some 1447m2 and will be situated

on Erf 6491. 6) Key specialist- and EAP-recommended mitigation measures included in the preferred alternative:

a. Trucks should enter and exit River Street via the Piketberg Road / N7 intersection and not via the Lang Street / Main Street intersection.

b. Building materials and finishes are to be visually recessive and non-reflective or such that within 2 years have weathered to be non-reflective;.

c. The mature eucalyptus in the south-western corner of the site must remain in place and large trees must be planted along the watercourse / Royal Street.

d. The grain conveyors may not operate at night. e. Low-noise grain conveyors must be used and conveyor elements must be maintained in order to

reduce contact noise. f. Silo aeration to be installed with sound attenuators to reduce the noise on the air inlet to aeration

fans. g. Noise monitoring must be undertaken once the plant is operational to determine whether a noise

attenuation barrier is required along the western site boundary. If required, the barrier (wall) should have no gaps and have a continuous minimum surface density of 10 kg/m2. This will minimize the transmission of sound through the barrier. Note that barriers should be located as close to the source or to the receptor location to be effective.

h. A complaints register must be kept. Phase 2: The site entrance and weighbridge will shift slightly north on Erf 6491; and the following infrastructure will be installed:

1) Two additional 29.4m-high grain storage silos with a storage capacity of 7400 tons; conveyors (“seed loop chains”) from the silos to the seed press, some 160m in length; four 20 kilolitre rainwater harvesting tanks; and three additional 100 kilolitre processed oil storage tanks.

2) The footprint of the Phase 2 infrastructure will cover some 716m2. Construction of Phases 1 and 2, in order to enable the urgent installation of grain storage facilities for accommodating the 2021 canola grain harvest, commenced in June 2021. Phase 3: Phase 3 will entail the installation of infrastructure to enable the chemical extraction of oil. For operational purposes, Phases 1 and 2 can operate independently of Phase 3:

1) One 3.5 ton per hour boiler, cooling towers of 3m in height, and a conveyor (“loop chain”) from the seed press to the extraction plant will be installed.

2) A new factory shop, a new warehouse, a new chemical extraction plant and a wastewater (wash water) treatment plant of some 24000 litres per day capacity, discharging to municipal sewer, will be constructed; and

3) Three 23m3 capacity hexane storage tanks (a dangerous good) will be installed. 4) The footprint of Phase 3 will cover approximately 1017m2 and will be situated on the very southern side of

Erf 6491, and also on southern Erf 586. 5) Key specialist-and EAP-recommended mitigation measures included:


a. The chemical extraction plant and hexane storage tanks must be situated at least 10m away from the watercourse.

b. Equipment using hexane will be located in the solvent extraction plant which will be positioned in a bunded area connected to a sump where any spillages will be contained.

c. d. The hexane storage and handling infrastructure must be designed and installed according to the

relevant SANS codes and all other applicable regulations relating to Hazchem storage and handling infrastructure.

e. With underground hexane storage tanks , it will be necessary to determine groundwater flow direction; install monitoring wells up- and down-gradient of the chemical extraction plant and tank farm; and monitor groundwater bi-annually during wet and dry season.

f. Leak detection systems in accordance with SANS standards and industry best practice must be installed.

Bulk engineering services The plant expansion will connect to the municipal bulk engineering services network. Stormwater will discharge to the municipal system; effluent and sewerage will discharge to municipal sewer; the municipality will supply the development with potable water; and the municipality will supply the development with electricity via the infrastructure upgrades that the municipality has requested the applicant to implement. Please see Appendix E for confirmation of bulk engineering services supply capacity from the municipality. Site access The trucks travelling to and from the site will utilise the Piketberg Road / N7 intersection to access River Street and will not access and leave River Street via the Lang Street / Main Street intersection. Water uses The canola oil plant expansion will not require the use of water from the adjacent Moorreesburgspruit. The expansion will also not entail the discharge of effluent into the natural environment. Rather, effluent will be discharged to the municipal system. The development site does, however, fall within the “regulated area” of the Moorreesburgspruit in terms of Section 21 (i) and (c) of the National Water Act, being situated within 100m of the river. Also, SOILL is investigating the feasibility of abstracting groundwater as an alternative water source to the municipal water supply. A water use authorisation in terms of the Water Act is therefore being applied for. 2. Explain how the proposed development is in line with the existing land use rights of the property as you have

indicated in the NOI and application form? Include the proof of the existing land use rights granted in Appendix

E21.

Consolidated Erf 6491 is zoned and used for general industry, Industrial Zone 2 in terms of the Swartland Municipality’s 2019 planning by-law. The municipality has granted a departure from the 21m height restriction applicable to Erf 6491, in order to allow for the construction of the +-29m high silos. Erf 586, across a part of which the chemical extraction plant and infrastructure will lie, is currently zoned and used for residential purposes. Whilst the house on the site will only be altered in minimal ways, the site needs to be rezoned for industrial use. The rezoning application required for the plant expansion is considered to be in line with the earmarked land use of the area in terms of the Swartland Municipality’s 2019 Spatial Development Framework, which is “mixed use”. 3. Explain how potential conflict with respect to existing approvals for the proposed site (as indicated in the NOI/and

or application form) and the proposed development have been resolved.

See E2 4. Explain how the proposed development will be in line with the following?

4.1 The Provincial Spatial Development Framework.

The development aligns with the Swartland municipal SDF and so should align with the PSDF. 4.2 The Integrated Development Plan of the local municipality.


Planscape Regional and Town Planners have advised that that the development proposal aligns with the municipal SDF and therefore should be aligned with the IDP. 4.3. The Spatial Development Framework of the local municipality.

The mixed-use demarcation of the area where the site is situated, allows for industrial development. 4.4. The Environmental Management Framework applicable to the area.

The Swartland Municipality’s 2019 Spatial Development Framework does not contain an Environmental Management Framework. But the SDF map clearly shows the area where the site is situated, to be earmarked for mixed use (urban) land use. And the development aligns with various objectives, guidelines and directives relating to environmental management, which are contained in the SDF. Please see Appendix K. 5. Explain how comments from the relevant authorities and/or specialist(s) with respect to biodiversity have influenced

the proposed development.

A freshwater risk assessment has been undertaken. This has guided the layout of the development. 6. Explain how the Western Cape Biodiversity Spatial Plan (including the guidelines in the handbook) has influenced

the proposed development.

The categorisation of the Moorreesburgspruit corridor as an Ecological Support Area in the WCBSP has been factored into the assessment of the development proposal. However, the freshwater specialist findings have been followed since these findings are based ground truthing of the biodiversity plan category. 7. Explain how the proposed development is in line with the intention/purpose of the relevant zones as defined in the

ICMA.

N/A. 8. Explain whether the screening report has changed from the one submitted together with the application form. The

screening report must be attached as Appendix I.

No, the Screening Report has not changed. 9. Explain how the proposed development will optimise vacant land available within an urban area.

The development entails the expansion of an existing canola oil processing plant, and will cover already developed / transformed land. 10. Explain how the proposed development will optimise the use of existing resources and infrastructure.

The development proposal entails the expansion of the existing canola oil processing plant and will cover already-developed land. The site is already serviced by the municipality; and the installation of a mini-substation according to the municipality’s infrastructure requirements for supplying electricity, is included in the development proposal. 11. Explain whether the necessary services are available and whether the local authority has confirmed sufficient,

spare, unallocated service capacity. (Confirmation of all services must be included in Appendix E16).

The site is serviced by the municipality and the municipality has indicated, either in writing (see attached) or verbally (written confirmation to be included in the Final BAR) that engineering services are available for the facility expansion. This applies to stormwater and effluent discharge, and to water and electricity supply. 12. In addition to the above, explain the need and desirability of the proposed activity or development in terms of this

Department’s guideline on Need and Desirability (March 2013) or the DEA’s Integrated Environmental Management

Guideline on Need and Desirability. This may be attached to this BAR as Appendix K.

See Appendix K.

F. SECTION F: PUBLIC PARTICIPATION

The Public Participation Process (“PPP”) must fulfil the requirements as outlined in the NEMA EIA Regulations and must be attached

as Appendix F. Please note that If the NEM: WA and/or the NEM: AQA is applicable to the proposed development, an

advertisement must be placed in at least two newspapers.

1. Exclusively for linear activities: Indicate what PPP was agreed to by the competent authority. Include proof of this agreement

in Appendix E22.

N/A

2. Confirm that the PPP as indicated in the application form has been complied with. All the PPP must be included in Appendix

F.

To be confirmed in the Draft BAR. Please see identified stakeholder table and Public Participation Plan contained in Appendix F.

3. Confirm which of the State Departments and Organs of State indicated in the Notice of Intent/application form were

consulted with.

To be confirmed in the Draft BAR


4. If any of the State Departments and Organs of State were not consulted, indicate which and why.

N/A

5. if any of the State Departments and Organs of State did not respond, indicate which.

N/A

6. Provide a summary of the issues raised by I&APs and an indication of the manner in which the issues were incorporated into

the development proposal.

To be provided in the Draft BAR

Note:

A register of all the I&AP’s notified, including the Organs of State, and all the registered I&APs must be included in Appendix F.

The register must be maintained and made available to any person requesting access to the register in writing. The EAP must notify I&AP’s that all information submitted by I&AP’s becomes public information.

Your attention is drawn to Regulation 40 (3) of the NEMA EIA Regulations which states that “Potential or registered interested

and affected parties, including the competent authority, may be provided with an opportunity to comment on reports and

plans contemplated in subregulation (1) prior to submission of an application but must be provided with an opportunity to

comment on such reports once an application has been submitted to the competent authority.”

All the comments received from I&APs on the pre -application BAR (if applicable and the draft BAR must be recorded,

responded to and included in the Comments and Responses Report and must be included in Appendix F.

All information obtained during the PPP (the minutes of any meetings held by the EAP with I&APs and other role players wherein

the views of the participants are recorded) and must be included in Appendix F.

Please note that proof of the PPP conducted must be included in Appendix F. In terms of the required “proof” the following is

required:

• a site map showing where the site notice was displayed, dated photographs showing the notice displayed on site and

a copy of the text displayed on the notice;

• in terms of the written notices given, a copy of the written notice sent, as well as:

o if registered mail was sent, a list of the registered mail sent (showing the registered mail number, the name of the

person the mail was sent to, the address of the person and the date the registered mail was sent);

o if normal mail was sent, a list of the mail sent (showing the name of the person the mail was sent to, the address

of the person, the date the mail was sent, and the signature of the post office worker or the post office stamp

indicating that the letter was sent);

o if a facsimile was sent, a copy of the facsimile Report;

o if an electronic mail was sent, a copy of the electronic mail sent; and

o if a “mail drop” was done, a signed register of “mail drops” received (showing the name of the person the notice

was handed to, the address of the person, the date, and the signature of the person); and

• a copy of the newspaper advertisement (“newspaper clipping”) that was placed, indicating the name of the

newspaper and date of publication (of such quality that the wording in the advertisement is legible).

G. SECTION G: DESCRIPTION OF THE RECEIVING ENVIRONMENT

Please refer to the Site Sensitivity Verification Report contained in Appendix C for a full description of the site and surrounds and

any natural or cultural sensitivities identified, including photos of the site and surrounds.

All specialist studies must be attached as Appendix G.

1. Groundwater1

1.1. Was a specialist study conducted? YES NO X

1.2. Provide the name and or company who conducted the specialist study.

SOILL is investigating the feasibility of abstracting groundwater to provide an alternative to municipal water supply. Umvoto Africa geohydrologists will conduct the assessment.

1.3. Indicate above which aquifer your proposed development will be located and explain how this has influenced

your proposed development.

See 1.4

1 https://gis.elsenburg.com/apps/cfm/#, accessed 10th June 2021

https://gis.elsenburg.com/apps/cfm/


1.4. Indicate the depth of groundwater and explain how the depth of groundwater and type of aquifer (if present) has

influenced your proposed development.

The site is underlain by a Minor aquifer (classified as Fractured) of Medium-High susceptibility and Moderate vulnerability. According to the resource database, depth to groundwater is +-10.66m. Drilling on site confirmed ground water at 2.54m during construction phase. Subsurface structures for the development will include the following:

− Hexane storage tanks

− Foundations for 5 x silos

− Grain intake pits, chutes and foundations for 2 x grain elevator and supports

− Oil cake bunker

− Foundations for chemical extraction plant

Readymix concrete will be used to pour the foundations and stabilise the surface structures referred to above. For the hexane tanks, they will be mild steel tanks with an exterior fibreglass coating. Chemical resistant and anti-corrosive coatings will be applied on the tank interiors. The tanks will comply with the relevant SANS codes and regulations for the design and installation of Hazchem storage tanks. Impact on the aquifer is therefore considered to be acceptable, provided that the design and installation and operation of the hexane storage tanks and associated infrastructure meets the relevant SANS codes, and the Standard Operating Procedures and Preventative Maintenance Plans which should be incorporated into the Operational Phase Environmental Management Programme. In support of the water use authorisation application for inter alia groundwater abstraction, a groundwater assessment will be undertaken by Umvoto Africa geohydrologists. Any findings and recommendations from this study which might be relevant for protection of the aquifer, will be included in the Basic Assessment Report and EMPr submission to the DEA&DP for their decision.

2. Surface water

2.1. Was a specialist study conducted? YES X NO

2.2. Provide the name and/or company who conducted the specialist study.

Confluent Environmental (Dr James Dabrowski)

2.3. Explain how the presence of watercourse(s) and/or wetlands on the property(ies) has influenced your proposed

development.

Confluent Environmental has recommended a 10m setback from the river for the hexane storage tanks and for the chemical extraction plant. This has been included in the development layout. Confluent and Enviroprac have recommended construction phase measures for avoiding contamination and silting of the river. These were communicated to Southern Oil prior to their commencement of works associated with Phases 1 and 3 of the expansion, which do not require Environmental Authorisation. Please see email attached in Appendix L. These measures are included in the EMP to govern Phase 3, which is the subject of this application.

3. Coastal Environment N/A

3.1. Was a specialist study conducted? YES NO


3.3. Explain how the relevant considerations of Section 63 of the ICMA were taken into account and explain how this

influenced your proposed development.

3.4. Explain how estuary management plans (if applicable) has influenced the proposed development.

3.5. Explain how the modelled coastal risk zones, the coastal protection zone, littoral active zone and estuarine functional

zones, have influenced the proposed development.

4. Biodiversity

4.1. Were specialist studies conducted? YES X NO

4.2. Provide the name and/or company who conducted the specialist studies.


Confluent Environmental (Dr James Dabrowski)

4.3. Explain which systematic conservation planning and other biodiversity informants such as vegetation maps, NFEPA,

NSBA etc. have been used and how has this influenced your proposed development.

Terrestrial biodiversity: the Western Cape Biodiversity Spatial Plan. The site is situated within an Ecological Support Area associated with the Moorreesburgspruit. Specialist recommendations have been followed. Aquatic biodiversity: please refer to the Freshwater Risk Assessment attached in Appendix G. According to the specialist, the development is acceptable (Low risk) with the implementation of recommended mitigation measures (such as locating the chemical extraction plant and hexane storage tanks beyond 10m from the spruit).

4.4. Explain how the objectives and management guidelines of the Biodiversity Spatial Plan have been used and how has

this influenced your proposed development.

Terrestrial Biodiversity: according to the specialist, there is no riparian zone along the river reach running through the town Moorreesburg. And the site itself is full transformed with no indigenous vegetation remaining. The development thus aligns with the objectives and management guidelines of the WCBS Plan as regards terrestrial vegetation. Aquatic Biodiversity: According to the specialist, the Moorreesburgspruit is degraded and its Present Ecological State is “Largely Modified. It’s Ecological Importance and Sensitivity is Low. And all activities during the lifecycle of the development have been rated as Low Risk to the river. Therefore, whilst the site partly falls into an Ecological Support Area associated with the Moorreesburgspruit, the development thus does not contravene the objectives and management guidelines of the WCBS Plan.

4.5. Explain what impact the proposed development will have on the site specific features and/or function of the

Biodiversity Spatial Plan category and how has this influenced the proposed development.

The site partly falls into an Ecological Support Area associated with the Moorreesburgspruit. But no indigenous vegetation remains on the fully-transformed site. And the freshwater specialist has found the adjacent Moorreesburgspruit to be of Largely Modified Present Ecological State and of Low Ecological Importance and Sensitivity, with the development posing Low Risk to the river.

4.6. If your proposed development is located in a protected area, explain how the proposed development is in line with

the protected area management plan.

N/A

4.7. Explain how the presence of fauna on and adjacent to the proposed development has influenced your proposed

development.

The site is fully transformed and situated within an urban area. Also, the freshwater specialist has found the spruit to be devoid of riparian a riparian zone where the spruit runs through the town. Therefore, the development proposal has not been influenced by considerations of protecting fauna.

5. Geographical Aspects

Explain whether any geographical aspects will be affected and how has this influenced the proposed activity or development.

According to the DEFF’s Environmental Potential Atlas (ENPAT), the geology of the area is Greywacke and phyllite of the Moorreesburg Formation, Malmesbury Group; with surficial cover formed in situ on Malmesbury rocks. The slope of the property is flat. The soils have strong texture contrasts; have a marked clay accumulation, are strongly structured and a reddish colour, with about 15 – 35% clay2. The development therefore does not impact on geological aspects (erosion; development on steep slopes; etc.)

6. Heritage Resources

6.1. Was a specialist study conducted? YES X NO


Dr Jonathan Kaplan, Agency for Cultural Resource Management

6.3. Explain how areas that contain sensitive heritage resources have influenced the proposed development.

2 https://gis.elsenburg.com/apps/cfm/#, accessed 10th June 2021

https://gis.elsenburg.com/apps/cfm/


No sensitive heritage resources were identified on or in close proximity to the site. The ACRM found the development to have no heritage impacts. A Heritage Notice of Intent to Develop was compiled and submitted to Heritage Western Cape as a precautionary measure, since the DEFF Screening Tool found the site to be of Very High Sensitivity from a heritage perspective (due to a Grade 2 heritage site, the Carnegie Building, being situated some 350m south-west of the site).

7. Historical and Cultural Aspects Explain whether there are any culturally or historically significant elements as defined in Section 2 of the NHRA that will be

affected and how has this influenced the proposed development.

The Agency for Cultural Resource Management has screened the site and compiled a Heritage Notice of Intent to Develop. The ACRM found that the site is not situated in the historic core of the town and that there are no cultural or heritage resources at or in close proximity to the site. The closest building of heritage significance is a Grade 2 heritage site: the Carnegie Building, now the Moorreesburg Tourism Centre, is situated some 360m south-west of the site. There will be no impact on palaeontological resources. And the house on Erf 586 dates back to the 1930’s and so a permit for the minor alterations planned for the structure may be needed.

8. Socio/Economic Aspects

8.1. Describe the existing social and economic characteristics of the community in the vicinity of the proposed site.

The site is surrounded by residences to the west and south, and by commercial and industrial development (although low-density and in some cases, derelict and disused) to the north and east. The area is mixed-use and characterised by agri-industry (tractor sales and repairs; fuel depot) and by low density residences.

8.2. Explain the socio-economic value/contribution of the proposed development.

Southern Oil is a major buyer and processor of canola seed in South Africa, for the purposes of producing canola oil for the local and export markets. In 2020, even with the negative impact of COVID on all sectors of the economy, Southern Oil processed around 100 000 tons of canola seed, produced about 90 million litres of oil and their turnover was some R2 billion. Southern Oil have indicated that crop growers are shifting away from other crops and towards canola. This is due to growth in yields obtained from canola and increased prices that improve the profitability for producers. The COVID- related lockdown and closure of alcohol sales are limiting market potential for barley. Canola works well in rotation with barley and/or wheat, promoting more sustainable agriculture. In 2021, there is thus a higher than ever demand for Southern Oil to purchase canola crops. If they are unable to meet this demand, the impact on the local economy will be negative, with canola growers potentially sitting with product that is not marketable and that might go wasted. Specialist structures for storage of the seed directly after harvest is needed, and lack of infrastructure at South Arica’s ports makes exporting the grain very difficult. In addition to this, Southern Oil have indicated that the plant expansion represents an additional 32 direct jobs at the plant as well as tax revenue. The additional production opportunity will also create numerous job along the supply chain, while the products produced replace imports, all benefitting the local economy.

8.3. Explain what social initiatives will be implemented by applicant to address the needs of the community and to uplift

the area.

According to Southern Oil, the Canola Development Trust owns 15% of the shares of Southern Oil through the Canola Development Company. The beneficiaries of this trust are permanent employees of farmers producing canola. The mandate of the trust is to support development of the families of farm workers with the primary focus on education. The trust is currently busy with intervention in literacy at rural schools in the region and already showing some good results

8.4. Explain whether the proposed development will impact on people’s health and well-being (e.g. in terms of noise,

odours, visual character and sense of place etc) and how has this influenced the proposed development.

Visual impacts The development is situated in a mixed-use area of Moorreesburg, outside of the industrial area and outside of the historic core of the town. The area surrounding the site comprises some low density residential development, as well as some low-intensity industrial and commercial development.


The town of Moorreesburg is considered to be an agri-hub with a strong rural character. Industry in the town is predominantly agri-industry. Therefore, grain silos and storage and processing and transportation are commonplace in the town. Having said that, the site is situated very close to residences and although already developed, does not include grain silos which are of considerable height and could be considered as visually intrusive. The visual character of the surrounds is thus a key factor in whether structures such as grain silos present an acceptable visual impact. A Visual Impact Assessment has been undertaken by Megan Anderson Landscape Architects. Please see Appendix G. According to MALA: “The potential visual impacts would occur predominantly during the construction and operation phase of the development. The nature of the visual impacts will be the visual effect the activity would have on the receiving environment… The visual impacts will be the result of the partially developed site being extended, the heights and footprints of existing buildings increasing and new development (silo’s and buildings) occurring. This will result in a change in visual character of the site as well as obstructing views of the town from Jakaranda Street as one enters Moorreesburg from the N7 (Page 35)”. Visibility of construction activity from adjacent, highly sensitive receptors resulting in a change in visual townscape will be a negative impact during the construction phase. During the operational phase, MALA has identified the following impacts on the visual character and identified receptors in the area:

− Visual Intrusion of large silo structures on a few adjacent residential erven along Royal Street to south west

and west.

− Obstruction of views of the town centre from Piketberg Way town entrance road in the north east.

− Visual intrusion of night lighting.

The impacts were determined to be Medium negative before mitigation; and Medium to Low after mitigation. Recommended mitigation measures include:

− Building materials and finishes are to be visually recessive and non-reflective or such that within 2 years have

weathered to be non-reflective.

− Employ a Landscape Architect to draw a Landscape Master Plan, suitable for the industrial scale of the

building, that will include screening of large structures by large trees along Royal Street and Moorreesburg

Spruit.

− Maintain trees for minimum of 5 years.

− Minimise external lighting and ensure the lights are covered on top to direct light downwards, are low spill

luminaires, are on low posts where possible and if possible are bollard height.

− Appoint Landscape Architect to provide input into minimising lighting and designing screening of lighting from

sensitive receptors.

Please see the VIA report in Appendix G and the impact assessment in Appendix J for more detail. Noise impacts Owing to concerns raised by a neighbour to the south of the site during the planning application for consolidating Erf 6419, the noise generated by an expanded operation on the site was identified as a possible impact, especially given the relative proximity of residential receptors.


Soundscape Consulting undertook a noise survey to identify possible noise sources associated with the expanded plant, and whether the noise generated by the plant would likely cause a nuisance to nearby residents. Please see Appendix G. The survey entailed taking noise measurements at key on-site and off-site locations, particularly where noise might be generated by current activities and also where noise might be experienced by residential receptors. A noise survey was also undertaken at Southern Oil’s Swellendam plant. The Swellendam operation includes certain activities which the expanded Moorreesburg operation will include, but the Swellendam plant operates on a much larger scale. From the baseline noise survey undertaken at Moorreesurg, it was determined that the area is of low sensitivity from an environmental noise perspective. Existing noise sources in the area besides the current cold-pressing canola oil plant include traffic, industry and community noise sources. Scaling down the noise levels measured at the Swellendam plant to factor in the smaller scale of the Moorreesburg expansion, it was found that the predicted change in noise levels associated with the expansion may be experienced as “disturbing” by residents to the west and south of operations. It was predicted that “little response with sporadic complaints”, according to the SANS 10103:2008 standard relating to noise levels and noise disturbance, is likely to result from this additional noise, provided mitigation is implemented. Mitigation Measures to Control Noise Impacts According to Soundscape Consulting, essential management measures to be included in the EMPr are: a) Silo conveyors: a. The use of lower noise conveyors at delivery silos as planned. b. Maintenance of conveyor elements to reduce contact noise. c. Limiting the operation of silo conveyors to day-time hours. b) Silo aeration to be installed with sound attenuators to reduce the noise on the air inlet to aeration fans as planned. c) Noise monitoring. d) Keep a complaint register. Also, according to Soundscape, measures to address general construction, light industrial, and traffic noise are considered good practice and should also be adopted as part of the facility’s EMPr. Such measures have been included in the EMPr. And finally, Soundscape has indicated that, based on the outcome of operational-phase noise monitoring, the installation of additional acoustic barriers (2 to 3 m high) may be required for additional mitigation of ground level noise sources. Installing acoustic barriers without gaps and with a continuous minimum surface density of 10 kg/m2 will minimize the transmission of sound through the barrier. Note that barriers should be located as close to the source or to the receptor location to be effective. This has also been included in the EMPr. Please see the Noise Survey report in Appendix G and the impact assessment in Appendix J for more detail. Transport and traffic impacts A Traffic Impact Statement was undertaken in August 2021 in order to determine baseline traffic volumes on the road network surrounding the site; and to identify any impacts from the additional truck trips associated with the plant expansion. Investigation of baseline traffic conditions determined weekday traffic volumes at the main intersections to Moorreesburg from the N7 to be low. It was also found that peak truck trips occur between 10:00 and 11:00 and do not coincide with commuter AM and PM peaks. The throughput volume of raw material and output associated with the plant expansion, as well as additional employees, was analysed by EFG Engineers. It was determined that during harvest time (the peak season in the year), the maximum hourly number of trips is expected to be 5 truck trips IN and 5 truck trips OUT; and 10 staff vehicle trips IN during the AM peak and 10 staff vehicle trips OUT during the PM peak.


EFG found that the peak hour trip generation rates associated with the plant expansion will be well below the maximum that could be generated based on the industrial development rights of the property. EFG analysed the geometrical aspects of the surrounding road network in relation to the types of trucks expected with the plant expansion. For road safety purposes, they propose that all the large articulated Soill trucks approach and exit the site via River Street and Piketberg Road to/from the N7 rather than along River Road and Piketberg Road to/from Lang Street EFG also found that about 85% of truck loads will be coming to / going from the site in a north, south and easterly direction, and about 15% will be coming from / going to the west. I.e. only about 15% of trucks would need to reassign to follow the Piketberg Road / N7 intersection.

Figure 3 Proposed truck routes to/from Erf 6419 EFG further found that the number of parking bays provided for in the plant expansion proposal, is adequate. In conclusion, EFG’ findings support the plant expansion with the recommended access route via the Piketberg Road / N7 intersection. This recommendation has been included in the development proposal. Please see the Traffic impact Statement in Appendix G and the impact assessment in Appendix J for more detail.

H. SECTION H: ALTERNATIVES, METHODOLOGY AND ASSESSMENT OF ALTERNATIVES

1. Details of the alternatives identified and considered

1.1. Property and site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts.

Provide a description of the preferred property and site alternative.

Erf 6491 and Erf 586, River Street, Moorreesburg. Please see the Site Sensitivity Verification Report in Appendix C, as well as Section G, for more detail on the site. There are no aspects of the site and surrounds which suggest that the plant expansion should not proceed on Erf 6491 and Erf


586, provided that mitigation is implemented. Specialist recommended and best practice mitigation measures have been included in the development proposal and in the EMPr. Provide a description of any other property and site alternatives investigated.

Erf 15711, Wellington, which was purchased by Southern Oil for the purposes of developing a full-scale (cold- and hot-press, chemical extraction and refining) canola oil plant. According to a Basic Assessment Report compiled by Ecosense in 2020, Erf 15711 was ideal from the perspective of being central to suppliers and to distribution networks. Ecosense describes the site as follows: “The proposed site is a brownfield site. It was previously used as evaporation dams for effluent from the old tannery located next to Hermon Road to the west of the site. The evaporation ponds have been covered by fill and lie above the surrounding land. The site is otherwise undeveloped with highly disturbed vegetation”. However, during the Basic Assessment application process to approve Erf 15711 for development, it was found that the site is contaminated due to its past land use, being tannery effluent storage. It was determined that the contamination should be remediated before any development can take place. The remediation process will take some 2 years. Further to this, Southern Oil have advised that per agreement with the developers of Erf 15711, bulk engineering services were going to be supplied by these developers whilst they developed other industrial sites to the west of Erf 15711. These developments were put on hold as a result of COVID leaving the site without services in time for the required canola factory development. Owing to the urgent need for a facility that can meet the demand for additional canola grain processing locally, the site was excluded for the purposes of meeting Southern Oil’s current needs. Provide a motivation for the preferred property and site alternative including the outcome of the site selection matrix.

There are no environmental sensitivities identified on or nearby Erf 6491 and Erf 586 which should prevent the plant expansion from proceeding. The site is already owned and operated by Southern Oil, and therefore meets their urgent need to provide additional canola grain processing facilities to the market. Provide a full description of the process followed to reach the preferred alternative within the site.

N/A: the entire Erf 6491 and Erf 586 will be utilised for the purposes of the expanded processing plant. Provide a detailed motivation if no property and site alternatives were considered.

It should be noted that Southern Oil approached the Swartland Municipality about the possibility of developing the plant in Malmesbury. According to Southern Oil, feedback from the municipality was that a suitable site with existing bulk engineering services in place would not be available to meet Southern Oil’s urgent development timeline. List the positive and negative impacts that the property and site alternatives will have on the environment.

The only reasonable and feasible site alternative is Erf 6491 and Erf 586. Impacts identified with expanding the canola oil processing facility on this site include:

− Noise impacts – low

− Visual impacts – medium to low

− Freshwater impacts – low

− Heritage impacts – none

− Socio-economic benefits – high

− Terrestrial biodiversity – none

− Traffic impacts –low

− Soil and groundwater and freshwater contamination – low

− Fire and explosion and health and safety – low

− Ambient air quality impacts - low

1.2. Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts.

Provide a description of the preferred activity alternative.

The establishment of a canola grain processing facility in order to meet increased market demand. See Section E1 of this report. Provide a description of any other activity alternatives investigated.

N/A


Provide a motivation for the preferred activity alternative.

Southern Oil is a major buyer and processor of canola seed in South Africa, for the purposes of producing canola oil for the local and export markets. In 2020, even with the negative impact of COVID on all sectors of the economy, Southern Oil processed around 100 000 tons of canola seed, produced about 90 million litres of oil and their turnover was some R2 billion. Southern Oil have indicated that crop growers are shifting away from other crops and towards canola. This is due to growth in yields obtained from canola and increased prices that improved the profitability for producers. The COVID related lockdown and closure of alcohol sales are limiting market potential for barley. Canola works well in rotation with barley and/or wheat, promoting more sustainable agriculture. In 2021, there is thus a higher than ever demand for Southern Oil to purchase canola crops. If they are unable to meet this demand, the impact on the local economy will be negative, with canola growers potentially sitting with product that is not marketable and that might go wasted. Specialist structures for storage of the seed directly after harvest is needed, and lack of infrastructure at South African ports makes exporting the canola very difficult. In addition to this, the plant expansion represents an additional 32 direct jobs at the plant as well as tax revenue. According to Southern Oil, the additional production opportunity will also create numerous job along the supply chain, while the products produced replace imports, all benefitting the local economy. Provide a detailed motivation if no activity alternatives exist.

No activity alternatives are appropriate for meeting the goal of the development, being the establishment of a canola grain processing facility to meet market demand. List the positive and negative impacts that the activity alternatives will have on the environment.

Socio-economic benefits – high 1.3. Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts

Provide a description of the preferred design or layout alternative.

The development proposal as shown in the site layout plan in Appendix B, is the preferred development layout. Please note: this is not a detailed design drawing but shows the design and layout principles on which the plant will be expanded. Approval of the site layout plan should therefore factor in that changes within the specialist-recommended and best-practice parameters may need to occur during detailed design. Provide a description of any other design or layout alternatives investigated.

Please refer to the site layout diagrams contained in Appendix B5, which show the various iterations of the development layout that were considered before the preferred layout was chosen. Building lines; truck turning circles and access to the site; location of safety barriers; and the requirement to locate certain infrastructure away from the watercourse, were all factors that were considered in these layout iterations. Provide a motivation for the preferred design or layout alternative.

The development layout shown in the site plan in Appendix B is preferred due to the restricted space available on Erf 6491 and Erf 586, which is the only suitable site alternative as described already (to illustrate, Erf 15711, Wellington, could accommodate a development footprint of some 29000m2. Erf 6491 and Erf 586 combined cover an area of some 10500m2). The layout accounts for truck turning circles, the need for significant grain storage facilities, and the optimal layout of the silos and conveyors, seed pits and other infrastructure to optimise operational efficiencies and reduce worker health and safety risks. The preferred development layout includes a setback of 10m between the Moorreesburgspruit and the chemical extraction plant and hexane storage tanks, due to the hazardous nature of the hexane. The preferred development layout includes a buffer of 15m around the chemical extraction plant as required by National Fire Protection Association (NFPA) 36-2017 Standard for Solvent Extraction Plants, in order to minimise health and safety risks and risk of damage to property from possible hexane fire or explosion. Also, underground tanks for the hexane are included in the preferred development design and layout due to the explosive and flammable nature of hexane. Southern Oil’s consultation with Major Hazard Installation specialists and the fire department have found that underground storage tanks are preferred in order to minimise the impacts of any fire or explosion that could occur at the bulk storage tanks.


The development design / layout includes the retention of the mature eucalyptus trees in the south-western corner of Erf 6491 for visual screening purposes. Provide a detailed motivation if no design or layout alternatives exist.

See above. List the positive and negative impacts that the design alternatives will have on the environment.

− Visual impacts – medium to low

− Freshwater impacts - low

− Health and safety, fire and explosion – low

1.4. Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to avoid negative

impacts, mitigate unavoidable negative impacts and maximise positive impacts.

Provide a description of the preferred technology alternative:

− Lower noise conveyors (e.g. drag link conveyors, running on HDPE wear strips, which will eliminate the steel-on-

steel contact), are included in the development proposal. The noise specialist identified that conventional noise

barriers are only effective for ground-level noise sources and will not be effective for at-height noises

associated with the silos and conveyors. Lower noise conveyors are therefore a must for noise control

purposes.

− Building materials and finishes are visually recessive and non-reflective (within 24 months).

− The development proposal includes hexane (hazardous good) storage and piping infrastructure that complies

with the relevant SANS codes for the minimisation of leaks and associated environmental, health and safety

risks.

− Grit arrestors will be installed at the boiler that supplies heat to the facility, in order to minimise pollutant

emissions to atmosphere and associated adverse impacts on air quality.

Provide a description of any other technology alternatives investigated.

From the description of the technology alternatives included in the development proposal, it can be seen that other alternatives are not reasonable or feasible if negative impacts and risks are to be minimised. Provide a motivation for the preferred technology alternative.

The technology alternatives included in the development proposal are aimed at minimising nuisance and wellbeing, health and safety impacts associated with the plant expansion. Provide a detailed motivation if no alternatives exist.

The technology alternatives included in the development proposal are best practice and/ or specialist recommended for the purposes of minimising health, safety, environmental, nuisance and wellbeing impacts associated with the plant expansion. It is therefore not necessary (or “reasonable and feasible”) to explore other technology alternatives. List the positive and negative impacts that the technology alternatives will have on the environment.

− Noise impacts (nuisance and wellbeing) – low

− Visual impacts (wellbeing) – medium and low

− Health and safety, fire and explosion – low

− Soil and groundwater and freshwater contamination – low

− Ambient air quality - low

1.5. Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts.

Provide a description of the preferred operational alternative.

Operating the canola oil plant can have, in particular, noise impacts on nearby residential receptors. As such, the development proposal includes the following essential and good-practice operational alternatives:

− The silo conveyers will only operate during daytime hours (essential).

Good practice:

− Avoid unnecessary revving of engines and switch off equipment/vehicles/trucks when not required.

− Managing the impact of reverse warning signals:


▪ Remove the need for reversing by using drive through pathways.

▪ Use alternative means of carrying out the work that do not require the use of reversing vehicles.

▪ Install audio-visual devices in vehicles such as broadband alarms, flashing lights, proximity detection systems,

and reversing cameras.

− Maintain internal road surfaces and avoid steep road gradients.

− Enforce speed limits.

− Avoid excessive use of exhaust brakes.

The development alternative also includes trucks accessing River Street from the Piketberg Road / N7 intersection and no via the Lang Street / main Street intersection for road safety purposes. Provide a description of any other operational alternatives investigated.

No other impacts were identified that required the investigation of additional operational alternatives for the purposes of impact minimisation. Provide a motivation for the preferred operational alternative.

Noise impacts could be significant if the specialist-recommended essential and good-practice operational measures for noise control are not included in the development proposal Provide a detailed motivation if no alternatives exist.

It is not deemed necessary to investigate further operational alternatives besides those recommended by the specialists for avoiding adverse impacts. List the positive and negative impacts that the operational alternatives will have on the environment.

− Noise impacts (nuisance and wellbeing) – low

− Traffic impacts (safety and wellbeing) - low

1.6. The option of not implementing the activity (the ‘No-Go’ Option).

Provide an explanation as to why the ‘No-Go’ Option is not preferred.

According to market research undertaken by Southern Oil, the No-Go Option (not expanding the seed storage capacity and oil processing plant) will have adverse impacts on the local economy Canola growers will potentially sit with product that is not marketable and that might go wasted. Specialist structures for storage of the seed directly after harvest are needed, and lack of infrastructure at South African ports makes exporting the canola very difficult. According to Southern Oil, lack of sufficient local grain processing facilities could also adversely impact the agricultural supply chain Farmers could be forced to produce wheat only, thereby applying mono culture practices. This has been proven to be less profitable and sustainable, because resistance to pesticides and herbicides starts to develop. 1.7. Provide and explanation as to whether any other alternatives to avoid negative impacts, mitigate unavoidable

negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist.

None 1.8. Provide a concluding statement indicating the preferred alternatives, including the preferred location of the activity.

The development proposal as described in Section E1 and shown in the site development plan in Appendix B, is for the expansion of the current cold-pressing canola oil plant on Erf 6491, for the purposes of hot-pressing and chemical extraction of much larger quantities of canola grain. The development proposal, site and layout have been informed by market demand for canola grain processing facilities; by the suitability of Erf 6491 and Erf 586 to accommodate the plant expansion; by the lack of sensitive environmental aspects that could be adversely impacted by the plant expansion; and by specialist-recommendations and industry best-practice for minimising disturbance and wellbeing, health and safety and environmental impacts associated with the plant expansion. The development proposal is therefore the preferred alternative for this application.

2. “No-Go” areas Explain what “no-go” area(s) have been identified during identification of the alternatives and provide the co-ordinates of the

“no-go” area(s).

The area immediately west of the western boundary of Erf 6491 and Erf 586, which area abuts the Moorreesburgspruit, is a No Go Area.

Corner Latitude Longitude


North-west 33° 09’ 01.66” 18° 39’ 56.99”

North-east 33° 09’ 01.67” 18° 39’ 57.44”

South-east 33° 09’ 05.29” 18° 39’ 58.65”

South-west 33° 09’ 05.28” 18° 39’ 58.22”

3. Methodology to determine the significance ratings of the potential environmental impacts and

risks associated with the alternatives. Describe the methodology to be used in determining and ranking the nature, significance, consequences, extent, duration of

the potential environmental impacts and risks associated with the proposed activity or development and alternatives, the

degree to which the impact or risk can be reversed and the degree to which the impact and risk may cause irreplaceable loss

of resources.

See Appendix J

4. Assessment of each impact and risk identified for each alternative Note: The following table serves as a guide for summarising each alternative. The table should be repeated for each

alternative to ensure a comparative assessment. The EAP may decide to include this section as Appendix J to this BAR.

Please see Appendix J. The impact assessment entails assessing the development proposal, including all specialist-

recommended and best-practice mitigation measures (i.e. the preferred alternative) against the No-Go Option.

I. Section I: FINDINGS, IMPACT MANAGEMENT AND MITIGATION MEASURES

1. Provide a summary of the findings and impact management measures identified by all Specialist and an indication of

how these findings and recommendations have influenced the proposed development.

Visual According to the visual specialist, Megan Anderson Landscape Architects (see the Visual Impact Assessment in Appendix G): “The potential visual impacts would occur predominantly during the construction and operation phase of the development. The nature of the visual impacts will be the visual effect the activity would have on the receiving environment… The visual impacts will be the result of the partially developed site being extended, the heights and footprints of existing buildings increasing and new development (silo’s and buildings) occurring. This will result in a change in visual character of the site as well as obstructing views of the town from Jakaranda Street as on enters Moorreesburg from the N7” (Page 35). Visibility of construction activity from adjacent, highly sensitive receptors resulting in a change in visual townscape will be a negative impact during the construction phase. During the operational phase, MALA has identified the following impacts on the visual character and identified receptors in the area:

− Visual Intrusion of large silo structures on a few adjacent residential erven along Royal Street to south west and

west.

− Obstruction of views of the town centre from Piketberg Way town entrance road in the north east.

− Visual intrusion of night lighting.

The impacts were determined to be Medium negative before mitigation; and Medium, Medium to Low and Low after mitigation.


Please see the VIA report in Appendix G and the impact assessment in Appendix J for more detail. Noise impacts The noise specialist, Soundscape Consulting, undertook a baseline noise survey at and around the site. It was determined that the area is of low sensitivity from an environmental noise perspective. Existing noise sources in the area besides the current cold-pressing canola oil plant include traffic, industry and community noise sources. With the proposed plant expansion, it was found that the predicted change in noise levels associated with the expansion may be experienced as “disturbing” by residents to the west and south of operations. It was predicted that “little response with sporadic complaints”, according to the SANS 10103:2008 standard relating to noise levels and noise disturbance, is likely to result from this additional noise, provided mitigation is implemented. Please see the Noise Survey report in Appendix G and the impact assessment in Appendix J for more detail. Freshwater Terrestrial Biodiversity: according to the freshwater specialist, Confluent Environmental, there is no riparian zone along the river reach running through the town Moorreesburg. And the site itself is full transformed with no indigenous vegetation remaining. The development thus aligns with the objectives and management guidelines of the WCBS Plan as regards terrestrial vegetation. Aquatic Biodiversity: According to the specialist, the Moorreesburgspruit is degraded and its Present Ecological State is “Largely Modified. It’s Ecological Importance and Sensitivity is Low. And all activities during the lifecycle of the development have been rated as Low Risk to the river. Therefore, whilst the site partly falls into an Ecological Support Area associated with the Moorreesburgspruit, the development thus does not contravene the objectives and management guidelines of the WCBS Plan. Please see the Freshwater Risk Assessment in Appendix G and the impact assessment in Appendix J for more detail. Heritage The Agency for Cultural Resource Management has screened the site and compiled a Heritage Notice of Intent to Develop. The ACRM found that the site is not situated in the historic core of the town and that there are no cultural or heritage resources at or in close proximity to the site. The closest building of heritage significance is a Grade 2 heritage site: the Carnegie Building, now the Moorreesburg Tourism Centre, is situated some 360m south-west of the site. There will be no impact on palaeontological resources. And the house on Erf 586 dates back to the 1930’s and so a permit for the minor alterations planned for the structure may be needed. Please see the Heritage Notice of Intent to Develop attached in Appendix G for more detail. Traffic EFG Engineers compiled a Traffic Impact Statement in order to determine baseline traffic volumes on the road network surrounding the site; and to identify any impacts from the additional truck trips associated with the plant expansion. The throughput volume of raw material and output associated with the plant expansion, as well as additional employees, was analysed by EFG Engineers. It was determined that peak hour trip generation rates associated with the plant expansion will be well below the maximum that could be generated based on the industrial development rights of the property. EFG analysed the geometrical aspects of the surrounding road network in relation to the types of trucks expected with the plant expansion. For road safety purposes, they propose that all the large articulated Soill trucks approach and exit the site via River Street and Piketberg Road to/from the N7 rather than along River Road and Piketberg Road to/from Lang Street


EFG also found that about 85% of truck loads will be coming to / going from the site in a north, south and easterly direction, and about 15% will be coming from / going to the west. I.e. only about 15% of trucks would need to reassign to follow the Piketberg Road / N7 intersection. Please see the Traffic Impact Statement in Appendix G and the impact assessment in Appendix J for more detail. The above specialist findings have informed the choice of Erf 6491 and Erf 586 as the preferred development site; and have informed the layout, design, technology and operational alternatives which have been included in the development proposal. Please see Section J (1.1) for specialist-recommended mitigation measures. 2. List the impact management measures that were identified by all Specialist [and the EAP, based on industry best practice]

that will be included in the EMPr

See Section J (2.3) 3. List the specialist investigations and the impact management measures that will not be implemented and provide an

explanation as to why these measures will not be implemented.

None. 4. Explain how the proposed development will impact the surrounding communities.

The following impacts identified, described and assessed in this report, will be experienced by the surrounding communities:

− Health and safety

− Nuisance and wellbeing

− Traffic (possible congestion, road safety, road wear and tear)

− Socio-economic benefits 5. Explain how the risk of climate change may influence the proposed activity or development and how has the potential

impacts of climate change been considered and addressed.

− The development site is not sensitive to sea level rise, being situated in an inland town.

− The development is part of an essential food supply chain. Whilst grain production may be adversely impacted by climate change in the future, the need exists for the foreseeable future to supply the market with canola oil.

− The canola oil production process is not water intensive, especially with the inclusion of the washwater treatment plant. Therefore, if municipal water supply is adversely impacted in the future by climate change, this will not impact severely on the plant.

− Southern Oil is keen to utilise alternative forms of energy as the need arises, e.g. biofuels in the boilers and solar panels on the facility roof. As and when required, Southern Oil will undertake a cost-benefit analysis of alternative fuel and energy supplies and weigh up cost, efficiency and reliability of supply to determine whether to shift to alternatives. This flexibility will ensure that the Southern Oil plant can continue operating within the framework of regulation and practical restrictions brought about by climate change.

6. Explain whether there are any conflicting recommendations between the specialists. If so, explain how these have been

addressed and resolved.

None 7. Explain how the findings and recommendations of the different specialist studies have been integrated to inform the

most appropriate mitigation measures that should be implemented to manage the potential impacts of the proposed

activity or development.

All specialist-recommended mitigation measures have been included in the development proposal (technology, design and layout) and in the EMPr. Specialist findings have also determined that there are no constraints to expanding the oil processing plant on Erf 6491, in the manner described in the development proposal. 8. Explain how the mitigation hierarchy has been applied to arrive at the best practicable environmental option.

The fully-developed development site, situated in a mixed-use urban area, avoids sensitive natural areas, sensitive heritage areas, and areas that are not appropriate for agri-industrial development in terms of land use precedent and land use planning. Visual (wellbeing) impacts are minimised by the specialist-recommended design and technology measures included in the development proposal.


Risk of fire and explosion and other health and safety impacts, as well as risk of soil and groundwater contamination, are minimised by the inclusion of industry best practice and mandatory design measures for the hexane storage and handling infrastructure in the development proposal. Noise (wellbeing) impacts are minimised through the inclusion in the development proposal of technology and operational measures for noise control. Adverse impacts on the Moorreesburgspruit are minimised by the layout of the development proposal, which includes setting back the chemical extraction plant and storage tanks 10m from the spruit. Rectification and offsetting are not required for this application.

J. SECTION J: GENERAL

1. Environmental Impact Statement

1.1. Provide a summary of the key findings of the EIA.

Summary of Key Findings of the EIA The development proposal (including the layout, design, technology and operational alternatives that were found on investigation to be the best practicable options for the minimisation of health, safety and environmental risks) was assessed against the No-Go Option, or the option of not expanding the cold-press plant. The impacts which were identified as associated with the proposed plant expansion are: Construction phase:

− Standard construction-phase impacts such as dust, noise and a short-term change in visual character of the site.

− As regards the adjacent Moorreesburgspruit: increased erosion and turbidity in the watercourse; alteration of aquatic habitat; contamination by hydrocarbons and risk of pollution from solid waste associated with construction activities.

Operational phase:

− Risk of fire and explosion and impact on employee health and safety associated with the bulk storage and handling of hexane.

− Risk of contamination of soil, groundwater and freshwater ecosystems (the adjacent Moorreesburgspruit), since hexane is toxic to aquatic biota.

− Noise impacts from an increase in the scale and intensity of activities at the plant.

− Visual intrusion of the large silos on sensitive residential receptors; obstruction of views of the town from Piketberg Way; and visual intrusion of night lighting.

− Deterioration of ambient air quality due to pollutant emission associated with operating boilers.

− Additional truck trips can add to wear and tear on roads infrastructure and adversely impact road safety.

− Benefits in terms of job opportunities, service provision to and investment in the agri-processing industry, capital investment in the Moorreesburg economy and tax revenue and salaries to the benefit of the Moorreesburg town.

A summary of the findings of the impact assessment is contained in Table A and Table B. Detail on the impact assessment methodology used and the full impact assessment are included in Appendix J. It has been found that any negative impacts associated with expanding the canola oil processing plant can be avoided altogether or can be reduced to acceptable levels through appropriate mitigation. All of these negative impacts have been found to be of Medium to Low significance.


The identified benefits associated with the plant expansion were found to be of High benefit due to the regional nature of the service the plant will provide. The development proposal has been assessed against the No-Go Option, which is the option of not expanding the plant. The No-Go Option has thus provided a baseline against which to assess the benefits and drawbacks of the proposed plant expansion. With the No-Go Option, the benefits identified were:

− No additional impacts on the Moorreesburgspruit.

− No risk of soil, groundwater and freshwater contamination.

− No risk of fire and explosion and no health and safety impacts associated with the bulk storage and handling of

hexane.

− No additional noise impacts.

− No visual intrusion impacting sensitive residential receptors; and no obstruction of views of the town.

− No impacts on ambient air quality.

− Traffic volumes will remain the same.

However, the No-Go Option has the significant drawback of not realising the socio-economic benefits associated with the plant expansion in terms of essential service to the agri-processing industry, jobs, capital investment, and salaries and rates and taxes to the benefit of Moorreesburg.

1.2. Provide a map that that superimposes the preferred activity and its associated structures and infrastructure on the

environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers. (Attach

map to this BAR as Appendix B2)

See Appendix B. 1.3. Provide a summary of the positive and negative impacts and risks that the proposed activity or development and

alternatives will have on the environment and community.

Table A: Summary of Construction & Decommissioning & Closure Phase Impacts Associated with the Plant Expansion



Alternatives)

Dust Medium

Noise Medium

Soil, groundwater & freshwater

contamination; littering and erosion into

the spruit

Low

Visual Medium to Low

Table B: Summary of Operational Phase Impacts Associated with the Plant Expansion3



Alternatives)

Soil and groundwater contamination;

freshwater contamination Low

Fire & explosion; health and safety risk Low

Noise (wellbeing) impacts Low

Ambient air quality impacts Low

3 Includes impacts that could be experienced during the operational phase due to planning and design-phase decisions.


Visual Intrusion on sensitive residential

receptors Medium-Low

Obstruction of Town Views Medium-Low

Visual Intrusion of night lighting Low

Traffic impacts (possible congestion, road

safety impacts and wear and tear on

roads)

Low

Socio-economic benefits High

2. Recommendation of the Environmental Assessment Practitioner (“EAP”)

2.1. Provide Impact management outcomes (based on the assessment and where applicable, specialist assessments) for

the proposed activity or development for inclusion in the EMPr

− Reduce the visibility of construction activities from adjacent, sensitive receptors.

− Minimise the obstruction of views of the town centre from Piketberg Way.

− Minimise the visual intrusion of night lighting.

− Minimise the visual intrusion of large silo structures on adjacent residential erven along Royal Street.

− Minimise noise impacts on residential receptors to the west and south of the site.

− Avoid and minimise impacts on the adjacent Moorreesburgspruit that could occur due to: increased erosion and turbidity in the watercourse; alteration of aquatic habitat; contamination of the watercourse by hydrocarbons; and pollution of the watercourse with solid waste (during the construction phase); and due to contamination by hazchems which are toxic to aquatic biota (during the operational phase).

− Avoid and minimise soil and groundwater contamination associated with Hazchem storage and handling.

− Avoid health and safety impacts and damage to property associated with risk of fire and explosion from Hazchem storage and handling.

− Minimise adverse impacts on ambient air quality.

− Minimise adverse impacts on road safety.

2.2. Provide a description of any aspects that were conditional to the findings of the assessment either by the EAP or

specialist that must be included as conditions of the authorisation.

None 2.3. Provide a reasoned opinion as to whether the proposed activity or development should or should not be authorised,

and if the opinion is that it should be authorised, any conditions that should be included in the authorisation.

The canola oil plant expansion should be authorised with the inclusion of all specialist- and EAP-recommended mitigation measures. This is due to the finding that all identified impacts associated with the proposal, can be mitigated to medium or low significance. And that the medium-significance impacts identified are offset by the high socio-economic benefits associated with the expansion. The following measures should be listed as conditions of authorisation, in addition to the EMPr being approved as a condition of authorisation: Freshwater, soil and groundwater contamination; risk of fire and explosion and health and safety impacts

− The chemical extraction plant and hexane storage tanks must be situated at least 10m away from the watercourse.

− Equipment using hexane will be located in the solvent extraction plant which will be positioned in a bunded area connected to a sump where any spillages will be contained.

− Determine groundwater flow direction; install monitoring wells up- and down-gradient of the chemical

extraction plant and tank farm; and monitor groundwater bi-annually during wet and dry season.

− The hexane storage and handling infrastructure must be designed and installed according to the relevant SANS codes and all other applicable regulations relating to Hazchem storage and handling infrastructure.

− Leak detection systems in accordance with SANS standards and industry best practice must be installed.


− A registered professional engineer must sign off on the design and installation of the tanks and associated infrastructure.

− A 15m buffer around the chemical extraction plant must be incorporated into the site layout in accordance with National Fire Protection Association (NFPA) 36-2017 Standard for Solvent Extraction Plants.

− A Standard Operating Procedure for all activities relating to hexane storage, refilling, handling and use in processing must be compiled with the purpose of minimising associated health, safety and environmental risks.

− Staff must be trained in the SOP, with records of staff training retained for external auditing purposes.

− Bi-annual internal audits of the operation against the SOP must be conducted with records retained for external auditing purposes.

− A Preventative Maintenance Plan for the infrastructure relating to hazchem storage and handling; for the

boilers and grit arrestors; and for the grain conveyors to ensure ongoing noise reduction, must be compiled.

− Staff must be trained in preventative maintenance, with records of staff training retained for external auditing purposes.

− Bi-annual internal audits of the operation against the Preventative Maintenance Plan must be conducted with records retained for external auditing purposes.

− A fuel and hazchem Spill Response Procedure must be compiled and attached to the Operational EMPr. The Spill Response Procedure must be submitted to the DEA&DP: Pollution & Chemicals Directorate and to the DWS for approval before filling of the hexane storage tanks and before commissioning of the chemical extraction plant.

− A fuel and Hazchem spill response kit must be in place at the chemical extraction plant.

Visual4

− Building materials and finishes are to be visually recessive and non-reflective or such that within 2 years have

weathered to be non-reflective.

− A Landscape Architect be appointed to draw up a landscape plan for planting of trees, on and off the site, that

reduces the visual impact of the building from the highly sensitive receptors.

− An Operational Management Plan for Landscaping is produced by the Landscape Architects which will prescribe

maintenance requirements in order to establish and retain trees in good condition.

− That the required mitigation measures regarding Lighting and Signage are designed for and implemented.

− The Construction Mitigation Measures are included in the EMP.

Noise5

− The grain conveyors may not operate at night.

− Low-noise grain conveyors must be used and conveyor elements must be maintained in order to reduce contact noise.

− Silo aeration to be installed with sound attenuators to reduce the noise on the air inlet to aeration fans.

− Noise monitoring must be undertaken once the plant is operational to determine whether a noise attenuation barrier is required along the western site boundary. If required, the barrier (wall) should have no gaps and have a continuous minimum surface density of 10 kg/m2. This will minimize the transmission of sound through the barrier. Note that barriers should be located as close to the source or to the receptor location to be effective.

− A complaints register must be kept.

2.4. Provide a description of any assumptions, uncertainties and gaps in knowledge that relate to the assessment and

mitigation measures proposed.

− The 1:100 year floodline for the stretch of the Moorreesburgspruit in the area of the site has not been determined. Based on the condition and characteristics of the spruit, however, the freshwater specialist is confident to assess the risks of the proposal to the spruit in the absence of a determined floodline.

− The particular SANS codes applicable to the design and installation of the hexane storage tanks and pipework and associated leak detection are not known at this stage. It is assumed that the tank supplier,

4 Recommended inclusions in EA from Megan Anderson Landscape Architects. Full visual impact mitigation measures

are included in impact assessment and in EMP. 5 Good-practice general measures for noise reduction have not been included here, but are included in the impact

assessment and in the EMPr.


in conjunction with Southern Oil, will ensure that the applicable SANS codes and any other regulatory requirements relating to design and installation of Hazchem storage infrastructure are adhered to.

− It is assumed that Southern Oil will compile the necessary Standard Operating Procedures for all processes relating to the storage, refilling and use of hexane, for attachment to the Operational EMPr.

− It is assumed that Southern Oil will compile the necessary Preventative Maintenance Plan for the infrastructure relating to hazchem storage and handling; for the boilers and grit arrestors; and for the grain conveyors to ensure ongoing noise reduction.

− Impacts of possible tank failure on soil and groundwater have been described and assessed based on EAP experience and research and a specialist has not been consulted. It is considered adequate to have a geohydrologist determine groundwater flow direction and monitor groundwater quality closer to the commissioning of the plant. However, it is expected that the DWS will indicate whether they require a geohydrological study at this time in order to inform the planning of the plant expansion.

2.5. The period for which the EA is required, the date the activity will be concluded and when the post construction monitoring

requirements should be finalised.

− The canola oil plant expansion is a long-term operation and so the EA should be valid for the lifetime of the plant

− Construction should take about 12 months from date of authorisation.

− Post-construction monitoring should be finalised within 14 months of authorisation

− The operation of the plant is considered to be low risk provided the recommendation for bi-annual groundwater monitoring and reporting is followed; and provided that preventative maintenance of key infrastructure (such as the hexane tanks and pipelines and associated infrastructure) is undertaken. Auditing the operational phase on a biennial basis should therefore be adequate.

3. Water Since the Western Cape is a water scarce area explain what measures will be implemented to avoid the use of potable water

during the development and operational phase and what measures will be implemented to reduce your water demand, save

water and measures to reuse or recycle water.

The development proposal includes an on-site washwater treatment plant so that the washwater can be re-used several times before being discharged to municipal sewer. There will be final discharge to sewer of a portion of the water consumed.

4. Waste

Explain what measures have been taken to reduce, reuse or recycle waste.

The canola oil manufacturing process is essentially a waste-free process. All outputs and byproducts from grain processing are usable.

5. Energy Efficiency

8.1. Explain what design measures have been taken to ensure that the development proposal will be energy efficient.

According to Southern Oil, European processing principles that rely greatly on the recovery of process energy are applied. High efficiency motors are used as far as possible and frequency controllers are used together with a high level of plant automation to ensure that equipment runs at optimal efficiency.


K. SECTION K: DECLARATIONS

DECLARATION OF THE APPLICANT

Please see end of document

I, Kellie Becker, ID number ……………………………in my personal capacity or duly authorised thereto

hereby declare/affirm that all the information submitted or to be submitted as part of this application

form is true and correct, and that:

• I am fully aware of my responsibilities in terms of the National Environmental Management Act, 1998

(Act No. 107 of 1998) (“NEMA”), the Environmental Impact Assessment (“EIA”) Regulations, and any

relevant Specific Environmental Management Act and that failure to comply with these

requirements may constitute an offence in terms of relevant environmental legislation;

• I am aware of my general duty of care in terms of Section 28 of the NEMA;

• I am aware that it is an offence in terms of Section 24F of the NEMA should I commence with a

listed activity prior to obtaining an Environmental Authorisation;

• I appointed the Environmental Assessment Practitioner (“EAP”) (if not exempted from this

requirement) which:

o meets all the requirements in terms of Regulation 13 of the NEMA EIA Regulations; or

o meets all the requirements other than the requirement to be independent in terms of Regulation

13 of the NEMA EIA Regulations, but a review EAP has been appointed who does meet all the

requirements of Regulation 13 of the NEMA EIA Regulations;

• I will provide the EAP and any specialist, where applicable, and the Competent Authority with

access to all information at my disposal that is relevant to the application;

• I will be responsible for the costs incurred in complying with the NEMA EIA Regulations and other

environmental legislation including but not limited to –

o costs incurred for the appointment of the EAP or any legitimately person contracted by the

EAP;

o costs in respect of any fee prescribed by the Minister or MEC in respect of the NEMA EIA

Regulations;

o Legitimate costs in respect of specialist(s) reviews; and

o the provision of security to ensure compliance with applicable management and mitigation

measures;

• I am responsible for complying with conditions that may be attached to any decision(s) issued by

the Competent Authority, hereby indemnify, the government of the Republic, the Competent

Authority and all its officers, agents and employees, from any liability arising out of the content of

any report, any procedure or any action for which I or the EAP is responsible in terms of the NEMA

EIA Regulations and any Specific Environmental Management Act.

Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney

must be attached.

Signature of the Applicant: Date:


Name of company (if applicable):


DECLARATION OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (“EAP”)

I , Colleen McCreadie, EAPASA Registration number 2018/166 as the appointed EAP hereby

declare/affirm the correctness of the:

• Information provided in this BAR and any other documents/reports submitted in support of this BAR;

• The inclusion of comments and inputs from stakeholders and I&APs;

• The inclusion of inputs and recommendations from the specialist reports where relevant; and

• Any information provided by the EAP to interested and affected parties and any responses by the

EAP to comments or inputs made by interested and affected parties, and that:

• In terms of the general requirement to be independent:

o other than fair remuneration for work performed in terms of this application, have no business,

financial, personal or other interest in the activity or application and that there are no

circumstances that may compromise my objectivity; or

o am not independent, but another EAP that meets the general requirements set out in

Regulation 13 of NEMA EIA Regulations has been appointed to review my work (Note: a

declaration by the review EAP must be submitted);

• In terms of the remainder of the general requirements for an EAP, am fully aware of and meet all

of the requirements and that failure to comply with any the requirements may result in

disqualification;

• I have disclosed, to the Applicant, the specialist (if any), the Competent Authority and registered

interested and affected parties, all material information that have or may have the potential to

influence the decision of the Competent Authority or the objectivity of any report, plan or

document prepared or to be prepared as part of this application;

• I have ensured that information containing all relevant facts in respect of the application was

distributed or was made available to registered interested and affected parties and that

participation will be facilitated in such a manner that all interested and affected parties were

provided with a reasonable opportunity to participate and to provide comments;

• I have ensured that the comments of all interested and affected parties were considered,

recorded, responded to and submitted to the Competent Authority in respect of this application;

• I have ensured the inclusion of inputs and recommendations from the specialist reports in respect

of the application, where relevant;

• I have kept a register of all interested and affected parties that participated in the public

participation process; and

• I am aware that a false declaration is an offence in terms of Regulation 48 of the NEMA EIA

Regulations;

19/08/2021

Signature of the EAP: Date:

The Environmental Practice (Pty) Ltd



DECLARATION OF THE SPECIALIST

Please also see specialist declarations contained in the noise and visual specialist studies.

DECLARATION OF THE SPECIALIST

Note: Duplicate this section where there is more than one specialist.

I James Michael Dabrowski, as the appointed Specialist for conducting a freshwater assessment for

the proposed expansion of the Southern Oil canola processing plant on Erf 6491 and Erf 586,

Moorreesburg, hereby declare/affirm the correctness of the information provided or to be provided

as part of the application, and that:

• In terms of the general requirement to be independent:

o other than fair remuneration for work performed in terms of this application, have no business,

financial, personal or other interest in the development proposal or application and that there

are no circumstances that may compromise my objectivity; or

o am not independent, but another specialist (the “Review Specialist”) that meets the general

requirements set out in Regulation 13 of the NEMA EIA Regulations has been appointed to

review my work (Note: a declaration by the review specialist must be submitted);

• In terms of the remainder of the general requirements for a specialist, have throughout this EIA

process met all of the requirements;

• I have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and

I&APs all material information that has or may have the potential to influence the decision of the

Department or the objectivity of any Report, plan or document prepared or to be prepared as

part of the application; and

• I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations.

06 July 2021

Signature of the EAP: Date:

Confluent Environmental


DECLARATION OF THE SPECIALIST Note: Duplicate this section where there is more than one specialist. I ……………………………………, as the appointed Specialist for compiling a Traffic Impact Statement the proposed expansion of the Southern Oil canola processing plant on Erf 6491 and Erf 586, Moorreesburg hereby declare/affirm the correctness of the information provided or to be provided as part of the application, and that: In terms of the general requirement to be independent:

o other than fair remuneration for work performed in terms of this application, have no business, financial, personal or other interest in the development proposal or application and that there are no circumstances that may compromise my objectivity; or

o am not independent, but another specialist (the “Review Specialist”) that meets the general requirements set out in Regulation 13 of the NEMA EIA Regulations has been appointed to review my work (Note: a declaration by the review specialist must be submitted);

In terms of the remainder of the general requirements for a specialist, have throughout this EIA process met all of the requirements;

I have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and I&APs all material information that has or may have the potential to influence the decision of the Department or the objectivity of any Report, plan or document prepared or to be prepared as part of the application; and

I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations.

19/08/2021 Signature of the Specialist: Date: EFG Engineers (Pty) Ltd Name of company (if applicable):

Andri de Bruin

DECLARATION OF THE SPECIALIST Note: Duplicate this section where there is more than one specialist. I ……………………………………, as the appointed Specialist for compiling a Traffic Impact Statement the proposed expansion of the Southern Oil canola processing plant on Erf 6491 and Erf 586, Moorreesburg hereby declare/affirm the correctness of the information provided or to be provided as part of the application, and that: In terms of the general requirement to be independent:

o other than fair remuneration for work performed in terms of this application, have no business, financial, personal or other interest in the development proposal or application and that there are no circumstances that may compromise my objectivity; or

o am not independent, but another specialist (the “Review Specialist”) that meets the general requirements set out in Regulation 13 of the NEMA EIA Regulations has been appointed to review my work (Note: a declaration by the review specialist must be submitted);

In terms of the remainder of the general requirements for a specialist, have throughout this EIA process met all of the requirements;

I have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and I&APs all material information that has or may have the potential to influence the decision of the Department or the objectivity of any Report, plan or document prepared or to be prepared as part of the application; and

I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations.

19/08/2021 Signature of the Specialist: Date: EFG Engineers (Pty) Ltd Name of company (if applicable):

David Faure

pre-application draft basic assessment report: …

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