Environmental Management Programme (EMPr) · 2016-08-01 · NEM:AQA National Environmental Air...

Annex B

Environmental Management Programme (EMPr)

Delivering sustainable solutions in a more competitive world

DRAFT Environmental Management Programme for the Vopak Efficiency (Growth 4) Project, Durban, South Africa

August 2016 Reference: 0346564 www.erm.com

ERM Reference: 0346564 DEDTEA Reference: To be confirmed Vopak Terminal Durban (Pty) Ltd DRAFT Environmental Management Programme for the Vopak Efficiency (Growth 4) Project, Durban, South Africa 1 August 2016 Prepared by: Stephanie Gopaul

This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

For and on behalf of Environmental Resources Management Approved by: Max Clark

Signed: Position: Partner Date: 1 August 2016

ENVIRONMENTAL RESOURCES MANAGEMENT VOPAK TERMINAL DURBAN (PTY) LTD

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ACRONYMS

AI Acrylonitrile AEL Air Emissions Licence amsl Metres above mean sea level API American Petroleum Institute AST Aboveground Storage Tanks BA Basic Assessment BAR Basic Assessment Report BAT Best Available Technology BBBEE Broad Based Black Economic Empowerment BID Background Information Document CPP Clean Petroleum Products CRR Comments and Responses Report CSM Conceptual Site Model CWDP Coastal Waters Discharge Permit DEDTEA Kwa-Zulu Natal Department of Economic Development, Tourism and

Environmental Affairs dBA A-weighted decibels DBAR Draft Basic Assessment Report DME Department of Minerals and Energy EA Environmental Authorisation EAP Environmental Assessment Practitioner EARES Enviro-Acoustic Research cc EIA Environmental Impact Assessment EMA eThekwini Municipal Area EMPr Environmental Management Programme EMS Environmental Management Systems EN European Standard ENIA Environmental Noise Impact Assessment ERM Environmental Resources Management EWS eThekwini Water and Sanitation Unit FRA Fire Risk Assessment GDP Gross Domestic Product GN Government Notice I&AP Interested and Affected Parties IDP Integrated Development Plan IFC International Finance Corporation K&T Kantey & Templer LPG Liquid Petroleum Gas LNAPL Light Non-Aqueous Phase Liquids m bgsl Metres below ground surface level MHI Major Hazardous Installation MIR Maximum Individual Risk MSA Municipal Systems Act mS/m Milli-siemens per meter MW Monitoring Well NCD Non-Communicable Disease NEMA National Environmental Management Act NEM:AQA National Environmental Air Quality Act NKP National Key Point NMPP New Multi Product Pipeline NSD Noise Sensitive Development NWA National Water Act OHS Occupational Health and Safety OWS Oil Water Separator PPE Personal Protective Equipment


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SANS South African National Standard SARTSM South African Road Traffic Signs Manual SDB South Durban Basin SDCEA South Durban Community Environmental Alliance SDF Spatial Development Framework SHE Safety, Health and Environment SMME Small, medium and micro enterprises SPL Sound Power Levels S-P-R Source-Pathway-Receptor SVOC Semi Volatile Organic Compounds TNPA Transnet National Ports Authority ToR Terms of Reference ULP Unleaded Petrol VOC Volatile Organic Compounds VRU Vapour Recovery Unit WML Waste Management Licence WWTP Waste Water Treatment Plant


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CONTENTS

1 INTRODUCTION 5

1.1 EMPR SCOPE AND OBJECTIVES 51.2 PROJECT APPLICANT 61.3 ENVIRONMENTAL ASSESSMENT PRACTITIONER 71.4 COMPETENT AUTHORITY 8

2 BACKGROUND INFORMATION 9

2.1 SITE SETTING 92.2 PROJECT DESCRIPTION 112.3 PROJECT PHASING 14

3 IMPLEMENTATION OF THE EMPR 17

3.1 PROJECT EMPR STAFF ORGANIZATION 173.2 METHOD STATEMENTS 213.3 TRAINING AND ENVIRONMENTAL AWARENESS 223.4 COMMUNICATION 223.5 RECORD KEEPING 223.6 CHECKING AND CORRECTIVE ACTION 23

4 ENVIRONMENTAL MANAGEMENT PROGRAMME 25

4.1 PLANNING AND DESIGN PHASE 254.2 CONSTRUCTION AND DECOMMISSIONING PHASE 314.3 OPERATIONAL PHASE 42

5 MONITORING 51

5.1 AIR QUALITY 515.2 WATER MONITORING 515.3 WASTE 52

6 ENVIRONMENTAL AWARENESS AND TRAINING 53

6.1 DUST 536.2 STOCKPILES 546.3 SPILLS/ LEAKS 546.4 STAKEHOLDER ENGAGEMENT 546.5 EATING AREAS AND CAMP CREW 556.6 HEALTH AND SAFETY 556.7 EMERGENCY SYSTEMS FOR MAJOR INCIDENT MANAGEMENT 55

7 CONTACT DETAILS AND SIGNATURES 56


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LIST OF FIGURES

Figure 2.1 Locality Map ...................................................................................................... 10 Figure 2.2 Efficiency (Growth 4) Project Site Layout ..................................................... 13 Figure 3.1 Project EMPr Staff Organogram ..................................................................... 17

LIST OF TABLES

Table 4.1 Early Works Phase: Environmental Management Programme ................. 26 Table 4.2 Construction and Decommissioning Phases: Environmental Management

Programme ........................................................................................................ 32 Table 4.3 Operational Phase: Environmental Management Programme .................. 43 Table 7.1 Relevant Contact Personnel ............................................................................. 56


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1 INTRODUCTION

The following Environmental Management Programme (EMPr) has been prepared by Environmental Resources Management Southern Africa (Pty) Ltd (ERM), for Vopak Terminal Durban (Pty) Ltd (Vopak). This EMPr has been compiled in support of the application for Environmental Authorisation (EA) for the proposed Vopak Efficiency (Growth 4) Project (the “Project”). Vopak is proposing certain expansion activities at the Farewell/King site, located at the Vopak Durban Terminal in the Island View Complex in Durban, South Africa. The aim of the proposed Project is to optimise the design of the site to reach the required storage capacity for petroleum, chemical and base oil products. The Project triggers activities listed under Government Notice (GN) R 983 of the Environmental Impact Assessment (EIA) Regulations (December, 2014) of the National Environmental Management Act (NEMA) (Act No. 107 of 1998). The investigation and assessment of the potential impact of these activities must follow the Basic Assessment (BA) process in order to acquire an EA from the competent authority, the Kwa-Zulu Natal Department of Economic Development, Tourism and Environmental Affairs (DEDTEA), prior to commencement of the Project.

1.1 EMPR SCOPE AND OBJECTIVES

The primary objective of this EMPr is to facilitate appropriate environmental management and mitigation measures during all phases of the Project to minimise potential environmental impacts that may arise. The EMPr for the Project is therefore required in order to: • assist in ensuring continuing compliance with South African

environmental legislation and Vopak’s corporate responsibility; • provide a mechanism for ensuring that measures identified in the BA are

implemented to mitigate potentially adverse environmental impacts; • provide assurance to regulators and stakeholders that their requirements

with respect to environmental and socio-economic performance will be met; and

• provide a framework for compliance auditing and inspection programs.

1.1.1 Regulatory Requirements

An EMPr for the Project is required as part of the BA process undertaken for the Project in terms of the EIA Regulations promulgated in terms of Chapter 5


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of the NEMA, as amended. The EMPr is a legally binding document on the applicant as a condition of approval of the Project by the DEDTEA, in addition to other conditions that may be stipulated in the EA, if granted. This EMPr has therefore been developed in accordance with Section 24N of the NEMA and Appendix 4 of GN R982 of the EIA Regulations (December, 2014). The EMPr is presented in draft format and is submitted to the public, registered Interested and Affected Parties (I&APs) and commenting authorities for their review and comment.

1.1.2 Vopak’s Safety, Health and Environmental Policy

The Vopak Safety, Health and Environmental Policy ensures that Vopak is committed to living and acting in accordance with the values to adhere to sound economic, environmental and social responsibilities of society and business at large. It is the responsibility of the relevant Durban Terminal Manager (or similar), assisted by the appointed Safety, Health and Environmental (SHE) Coordinator to implement the Policy. The duties of the SHE Coordinator include: • the investigation and prevention of incidents; • the provision of environmental and safety training; • the monitoring of environmental performance; • the collection of relevant statistics; and • liaison with the relevant regulating authorities. This EMPr is therefore compliant with the Vopak Safety, Health and Environmental Policy.

1.2 PROJECT APPLICANT

The proponent for the application is Vopak. Vopak is the world’s leading independent tank storage company, operating a global network of terminals located at strategic locations along major trade routes. Vopak is listed on the NYSE Euronext Amsterdam stock exchange and headquarters in Rotterdam, the Netherlands. Vopak has been operational for over 400 years and focus on sustainability, safety, efficiency and clean storage and handling of bulk liquid products. Vopak stores a wide variety of liquid bulk products classified in four groups: oil products, chemical and Liquid Petroleum Gas (LPG), biofuels and vegetable oils, and LNG. Vopak including joint ventures employs an international workforce of more than 6,000 people.


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The proponent for this application is:

Vopak Terminal Durban (Pty) Ltd Contact Person: Ms Carla Manion (SHEQ Manager) Postal Address: P.O. Box 1522

Durban 4000

Physical Address: 105 Taiwan Road Bluff, Island View 4052

Tel: +27 (0) 31 466 9200 Fax: +27 (0) 31 466 9273 Email: [email protected]

1.3 ENVIRONMENTAL ASSESSMENT PRACTITIONER

Environmental Resources Management Southern Africa (Pty) Ltd (ERM) has been appointed by Vopak to undertake the function of independent Environmental Assessment Practitioner (EAP) to undertake the BA process for the proposed Project. ERM is a global environmental consulting organisation employing over 4,000 people with 140 offices in 40 countries worldwide. Founded in 1971, ERM has built an organisation based on the supply of a full range of environmental and social policy, scientific, technical, and regulatory expertise. ERM’s primary focus is to provide quality work and service to our clients in these areas. ERM has been involved in numerous projects in Africa over the past 30 years and in 2003 established a permanent presence in Southern Africa to meet the growing needs of our clients. The Southern African ERM offices are based in Cape Town, Johannesburg, Durban, Maputo and Nairobi. ERM Southern Africa has a staff complement of 160 comprising dedicated environmental professionals offering expert skills in EIA and Environmental Management Planning / Programming (EMP), Environmental Management Systems (EMS) and auditing, risk assessment, corporate social responsibility and socio-economic impact assessment, climate change services, specialist groundwater services as well as contaminated site management. More specifically, the Project team selected for this Project possesses all the relevant expertise and experience to undertake this BA.


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The EAP for the applicant is:

Environmental Resources Management Southern Africa (Pty) Ltd Contact Person: Mrs Stephanie Gopaul (Project Manager) Postal Address: Postnet Suite 59

Private Bag X21 Westville 3630

Physical Address: 17 The Boulevard, Westway Office Park, Westville, Durban

Tel: +27(0) 31 265 0033 Fax: +27 (0) 31 265 0150 Email: [email protected] Please find detailed Curriculum Vitae of the EAP attached as Annex A.

1.4 COMPETENT AUTHORITY

The Competent Authority in terms of the EIA Regulations (December, 2014) is the Kwa-Zulu Natal Department of Economic Development, Tourism and Environmental Affairs (DEDTEA). The contact details for the assigned case officer for the DEDTEA are as follows:

KwaZulu-Natal Department of Economic Development, Tourism and Environmental Affairs Contact Person: Mrs Yugeshni Govender Physical Address: 17th Floor, Commercial City Building

Dr AB Xuma Street, Durban 4001

Tel: +27(0) 31 3667319 Fax: +27 (0) 31 302 2866 Email: [email protected]


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2 BACKGROUND INFORMATION

2.1 SITE SETTING

Vopak operates from four sites at three locations within the Cutler Complex of Island View; namely Farewell/King (physically at one location), Blend and Fynn (1) sites – together forming the Vopak Durban Terminal (Figure 2.1). The proposed Project is planned for the Farewell /King site. The Cutler Complex is an area of national importance (a National Key Point (NKP)) designated for the bulk storage of petroleum and chemical products. The Vopak Durban Terminal is accessible from the external road network via Bayhead Road. The Cutler Complex is located in the South Durban Basin, which covers approximately 60 km2 and includes a mix of industrial and commercial land use together with residential communities. North of the site is the Port of Durban and to the south are the suburbs of Fynnlands and The Bluff. The site falls within the jurisdiction of the eThekwini Municipal Area (EMA).

2.1.1 Farewell / King Site

The two plots of land pertinent to this BAR are located within the Cutler Complex and are known as the Farewell / King Sites (combined due to their close proximity to one another). This (combination due to their close proximity to each other) is the largest of the three sites and occupies an approximate area of 62 000 m2 Bunds 1 and 2 will be subject to expansion and these two bunds currently have a combined capacity of 32 000m3. The GPS coordinates for the centre point of the site are 29°53’38”S and 31°01’12”E and the Surveyor General code is as follows: N 0 F U 0 0 2 7 0 0 0 0 0 0 8 9 0 0 0 0 0

(1)The Blend and Fynn sites are not the subject of this application.

Figure 2.1 Locality Map


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2.2 PROJECT DESCRIPTION

The Vopak Efficiency (Growth 4) Project will include the expansion of the Farewell/King Sites to increase the storage capacity of petroleum products (diesel and ULP), base oils and chemicals. This will involve: • Demolition of 38 Aboveground Storage Tanks (ASTs) with a total storage

capacity of 32 000 m3 and associated infrastructure including: o drumming shed; o two gantries; o three pump stations; o hose exchanges located in bund 2A and bund 1A; and o separator.

• Building of six new tanks with a storage capacity of 20 000 m3 each (total

storage capacity of 120 000 m3) for the storage of clean petroleum products (worst case assessed as diesel and ULP), including associated infrastructure (i.e. pipelines to and from berths, between tanks, and between terminals).

• Building of six new tanks with a storage capacity of 5 000 m3 each for Clean Petroleum Products (CPP), chemicals (caustic and Monoethylene Glycol (MEG)) and base oils (total storage capacity of 30 000 m3), including associated infrastructure (i.e. pipelines to and from berths, between tanks, and between terminals).

• Installation of associated infrastructure including:

o A new pump bay and associated infrastructure including pumps, pipelines and manifolds connecting to and between Vopak terminals and the NMPP.

• Upgrade of: o Fuel 2 substation or new substation; o Overall Operation and Automation philosophy in line with Fuel 2

and Fuel 3; o Possible options to connect to site rail sidings; o Building facilities (ablution and offices) on Farewell Site; o The existing waste water treatment plant.

All pipelines will be constructed above ground and along existing racks. No pipelines will be abandoned (decommissioned). The new ULP storage tanks will be fitted with internal floating roofs. The benefits of using internal floating roofs includes minimisation of vapours produced being emitted (which further prevents product loss due to evaporation) and fire risks (as roofs reduce the explosive limit of the product in the tank). The proposed site layout is provided in Figure 2.2Figure 2.1.


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2.2.1 Associated Infrastructure

Firefighting Infrastructure

The existing firefighting infrastructure at the Farewell/King site will be

upgraded to accommodate the product and volume changes described above. Firefighting requirements will be established for all new installations i.e. pump bays, tanks/tank bunds as well as for the optimised road loading facilities. All firefighting requirements will be determined in accordance with SANS 10089-1: 2008, NFPA 11 and NFPA 15 and Vopak standards, There will be a two point activation system, remote activation at control room/remote wall and manual activation as required. Foam injection facilities will be included. Water Treatment Plant

There is a current Waste Water Treatment Plant (WWTP) at the Farewell/King Site with a capacity of 50 000 m3. This comprises of an oil water separator (OWS) and treatment unit. The discharge permit issued in accordance with the eThekwini Municipality Sewage Disposal By-Laws states that the total monthly discharge volume may not exceed 1 000 k . The water treatment philosophy at the site is as follows: • Only storm water and water from containment pits in working areas is

allowed into the OWS, where it is then treated in the WWTP and stored in effluent tanks for sampling prior to release to the sewer.

• Rain water in the bunds is sampled and verified as only water and

released directly out of site to canal. • In the event of a spillage within the bund, product contained in the bund

would be firstly recovered into alternative tanks, and residual sludge would be pumped into slop tubes or tanks for disposal.

Vopak propose to relocate the WWTP (oil/water separator and treatment unit) within the Farewell/King Site as per the final site layout drawing.

Figure 2.2 Efficiency (Growth 4) Project Site Layout


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2.2.2 Storm and waste water

A sump pit with pump (centrifugal pump next to sump) shall be installed for each tank pit. The water in the tank pit must be tested to check the quality, pending which water can be pumped directly into the bund drainage system that discharges into the canal. If polluted, the contents must be treated in the relocated oily water separator. For this, a hose connection point should be present in the discharge of the pump. Water/spills from operational areas (pump, manifold, hose pit) should be connected to the drainage system that discharges in the new oily water separator.

2.3 PROJECT PHASING

2.3.1 Planning and Design Phase

In terms of the engineering planning and design, the tank design specifications that will be considered include: • South African National Standard (SANS) 10089-1:2003: ‘Storage and

Distribution of Petroleum Products in Aboveground Bulk Installation’;

• American Petroleum Institute (API) 19.1: ‘Manual of Petroleum Measurement Standards Chapter 19 - Evaporative Loss Measurement Section 1 - Evaporative Loss from Fixed-Roof Tanks’ ;

• API 650: ‘Welded Steel Tanks for Oil Storage’; • API 620: ‘Design and Construction of Large, Welded, Low Pressure

Storage Tanks; • API 2000: ‘Venting Atmospheric and Low Pressure Storage Tanks: Non-

refrigerated and Refrigerated’; and • European Standard (EN) 14015: Specification for the Design and

Manufacture of Site Built, Vertical, Cylindrical, Flat- Bottomed, Above Ground, Welded, Steel Tanks for the Storage of Liquids at Ambient Temperature and Above.

Early Works

Early works are not subject to this authorisation process but a description of the activities involved are included for completeness. Tanks to be demolished will be isolated and gas-tested if required. During tank demolishing, the relevant international standards will be followed: • API 2015: Safe Entry and Cleaning of Petroleum Storage Tanks; and


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• Vopak’s Decommissioning and Tank Cleaning Standards and procedures.

2.3.2 Construction Phase

Site preparation

Cutting and felling of tanks will be undertaken by specialists in accordance with legislated safe practices to ensure that neighbouring tanks are not affected and that all employees are safe during the process. Tank Building

Vopak uses the Repeatable Formula Manual which provides over 90 minimum standards wherever large expansions are being undertaken (such as the proposed Project). These standards incorporate the best available technology and construction techniques and the cumulative lessons learnt by Vopak globally. These standards cover Safety, Health and Environment (SHE), technical and operational practices. The proposed tanks at the Farewell/King site will be atmospheric, vertical tanks with internal floating roofs (for the ULP tanks) and would be able to store either diesel or petrol. All tanks will be 32.4 m in height with tank diameter of 28 and 14 m for the 20 000m3 and 5 000 m3 tanks respectively. Overfill protection of the tanks would be consistent with the other tanks on site. The 20 000 m3 tanks would have a single secondary containment for all six tanks of a bunded area of 7560 m2. The bund will have internal walls between the tanks to catch minor spills. The minor bund of each tank will be approximately 1260 m2. The outer wall would have to be approximately 3 m in height to retain 110% of the largest tank. Further, the proposed new tanks will be built as per API 650, SANS 10089-1:2003 and Vopak’s Design Manual, and will have a number of safety characteristics. These are listed below: • Full Automation System which allows tanks and its accessories to be

controlled and monitored from the central control room. This includes line ups, interlocks, activation and deactivations of emergency systems at the push of the button;

• High level alarm warnings will be automatically sounded when the

volume of a tank that is being filled reaches a certain capacity; • Independent Overfill Protection which will enable the tank to safely

close the valves if reaction from operators was slow after the warning alarms were activated;


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• Remotely activated emergency stop valves to enable the operators to operate valves from a distance in an emergency, significantly reducing the risk of being harmed; and

• Vapour return systems which will lower the emissions from tank

breathing and during truck loading.

2.3.3 Operation Phase

The operational activities at the Farewell / King Site will not change with proposed Project. The site is designed to receive, store and dispatch a variety of commodity bulk liquid chemicals. Receipts and dispatches are very flexible in type i.e. material can be delivered to site by ship, rail or road and pumped to the desired tanks. Likewise, the products stored in the tanks can either be decanted into 200 litre drums or dispatched in bulk via ships, rail or road. The connecting of the various tanks and pumps are achieved by hose exchanges where non-permanent pipe spools or hoses are manually connected in order to line up the tanks prior to pumping. These hose exchange areas are located in bunded areas to catch any spillage. The rail and road loading are performed at dedicated unloading or loading gantries. Some unloading or loading gantries are equipped with vapour return lines (mostly where toxic components are loaded). The loading of the rail and road cars is controlled manually, while the loading of acrylonitrile (ACN) is done via a dedicated batching system that would close the supply vales when a high level is detected in the rail tankers. Gas detection and emergency stops are also present at the gantry that will shut down the supply pumps under emergency conditions. Bulk chemicals can be decanted into drums at the drum loading facilities as needed. Thereafter, the drums are temporarily stored in a drum area (with containment) and then are dispatched as soon as possible.

2.3.4 Terminal Automation

The process control and safety of the new equipment will be connected to the existing process control and safety interlock system on the Vopak Terminal Durban. The process of receiving and transferring products will be semi-automatic with line out valves being motorized with the control system, automatic tank gauging and tank overfill protection will be automated via the control system.


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3 IMPLEMENTATION OF THE EMPR

Vopak is committed to providing resources and establishing the systems and components essential to the implementation and control of the EMPr. These include appropriate human resources and specialized skills, training programs, communication procedures, documentation control and a procedure for the management of change.

3.1 PROJECT EMPR STAFF ORGANIZATION

The Project will have dedicated personnel competent on the basis of appropriate education, training, and experience that will manage and oversee the Environmental, Health and Safety (EHS) aspects over the Project lifecycle. Vopak will however retain the primary responsibility for meeting environmental commitments throughout the Project life span. The key environmental management roles during the construction, operation and decommissioning phases of the Project include, but are not limited to: the Project Developer (Vopak), the Project Manager (PM), Contractors, the Environmental Management Officer (EMO), the Safety Manger and representatives of the Project authorities (CME- EDTEA). The EMPr implementation organogram (Figure 3.1) illustrates the Project staff required, as well as the linkages between staff, the project developer and Project authorities.

Figure 3.1 Project EMPr Staff Organogram


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During construction, Vopak will delegate responsibility of the EMPr implementation to construction contractors. In the same way, Vopak may engage contractors for certain operational aspects and would delegate the same responsibility. Vopak will manage and monitor the Contractor’s implementation of the EMPr through contractual mechanisms and regular direct oversight. Vopak will have a supervisory PM on the site and an EMO will also be appointed to monitor compliance with the EMPr and other conditions of approval (i.e. Environmental Authorisation (EA), Air Emissions Licence (AEL) etc). Furthermore, the Project authorities including DEDTEA and the eThekwini Municipality will also be involved in the oversight of the Project and EMPr implementation, primarily through the compliance monitoring activities.

3.1.1 Key Staff Obligations and Responsibilities

Project Developer

For the purpose of this EMPr, the Project Developer refers to Vopak, who is thus ultimately responsible for compliance with all conditions of approval of Project development or any aspect thereof by any Project authority. Vopak undertakes to manage all activities associated with the Vopak Efficiency (Growth 4) Project in a manner that minimises adverse effects on the environment and the public, maximises socio-economic benefits for the area and protects the health and safety of employees, contractors, visitors and the general public. To this end, Vopak will: • ensure that all relevant approvals and permits have been obtained prior to

the start of the construction and decommissioning phases; • ensure that the EMPr forms an integral part of the contract documents

entered into with all contractors;

• educate personnel, contractors and visitors with regard to the safety, health and environmental (SHE) requirements applicable in general to the Project site, prior to accessing the site;

• appoint a suitably qualified or experienced Environmental Management

Officer (EMO) prior to the start of construction activities on the Site for: o undertaking monthly internal EMPr compliance audits to ensure

that all conditions of the approval are being complied with; and for on-going compliance monitoring during the operational phase.

• appoint a competent Project Manager to oversee all aspects of the expansion activities of the Project;


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• monitor, evaluate and report performance in safety, health and environmental protection to the relevant management level within Vopak.

Project Manager

The Project Manager (PM) refers to the person who is responsible for overseeing all aspects of the construction and decommissioning phases activities. Key obligations and responsibilities of the PM include, but are not limited to: • ensure that the planning / design requirements as set out in this EMPr and

any other conditions stipulated by relevant Project authorities are implemented prior to expansion activities;

• assist the EMO in ensuring that the conditions of the EMPr are adhered to

and promptly issue instructions requested by the EMO to the Contractors(s);

• assist the EMO in making decisions and finding solutions to

environmental problems that may arise during the Project lifecycle; • review and approve construction method statements with input from the

EMO; • order the removal of person(s) and/or equipment not complying with the

specifications (as required by the EMO or otherwise); and • provide input into the EMO’s on-going internal review of the EMPr. Contractor(s)

Contractor(s) will be appointed by Vopak for the expansion activities of the Project. This entity refers to any company or individual appointed by Vopak to undertake any aspects of the Project. The Contractor(s) will: • enter into a contractual commitment with Vopak to adhere to the

requirements of this EMPr;

• familiarise themselves with the requirements of this EMPr and educate all sub-contractors’, employees, suppliers, agents etc. accordingly;

• prepare method statements describing how techniques, practices and

methods will be employed that ensure the fulfilment of these requirements;

• undertake additional mitigation, management and / or remedial measures

following the receipt of a written instruction from Vopak to do so;


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• take all reasonable and practical measures to prevent the occurrence of accidents that may compromise the integrity of the environment and/or the health and safety of all persons on site, of all persons on neighbouring land and of the general public;

• cooperate in EMPr compliance audits by the EMO, external auditors

and/or relevant government bodies and provide the necessary information to this effect; and

• report to Vopak or its representative all incidents including but not limited

to environmental damage, injuries and/or loss of or damage to Vopak’s physical assets or corporate image;

• In the event of an incident as described above occurring, present a detailed

plan to: o restore the environmental conditions, in so far as it is possible to do

so, to a state similar to that existing before the incident; o address any injuries caused in a manner satisfactory to the injured

party or parties and Vopak; and o prevent the future occurrence of similar incidents.

Environmental Management Officer (EMO)

The EMO will: • undertake at least weekly inspections (with frequency determined by the

nature of the on-site activities as may be appropriate) to monitor compliance of all parties with the requirements of the EMPr;

• provide the appropriate level of management within Vopak with monthly

reports on environmental compliance and performance;

• advise/recommend on actions or issues impacting on the environment to the PM, who shall issue any required site instructions to the Contractor(s);

• develop an environmental awareness and training programme describing the manner in which:

o the applicant intends to inform its employees and contractors of

any foreseeable environmental risks which may result from their work; and

o risks must be dealt with in order to avoid pollution or degradation of the environment identified during the BA process and which emerge during the project.

• review and approve construction method statements together with the PM

for those activities that are identified as having a significant environmental risk.;


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• assist the Contractor(s) in finding environmentally responsible solutions to problems that may arise;

• recommend to the PM the removal of person(s) and/or equipment not

complying with the EMPr; • undertake photographic monitoring during the decommissioning and

construction activities (berth areas and common areas will not be photographed due to National Key Point requirements);

• keep records of all activities/ incidents concerning the environment; • take immediate action on the site to stop works where significant and

irreparable damage is being inflicted on the environment, and inform the PM immediately of the occurrence and action taken; and

• undertake regular internal review of the EMPr and make

recommendations regarding its updating to the PM and Vopak.

In addition to the obligations and/or responsibilities described above, the EMO has the authority to recommend to DEDTEA that works be stopped if in his/her opinion serious harm to, or impact on the environment is likely to occur or has occurred and such actual or potential harm or impact is in contravention of the EMPr, and which is or may be caused by expansion activities. The EMO will be responsible for the compilation of a final compliance audit report for the Project, completed when all expansion activities related to the Project have terminated and the site has been cleared of all construction related debris, materials or equipment not forming part of the permanent works. The final compliance audit report will be submitted to the DEDTEA in order to achieve “environmental closure” for the decommissioning and construction phase of the Project.

3.2 CONTRACTOR METHOD STATEMENTS

Method statements will be required for specific activities that are identified to pose a significant risk to the environment and/or which require site specific detail beyond that contained in the EMPr or when requested by the PM. A Method Statement is a “live document” in that changes can be implemented by the Contractor(s) and the EMO, as circumstances unfold. A Method Statement describes the scope of the intended work in a step-by-step description, in order for the EMO and the PM to understand the Contractor’s intentions. This will enable them to assist in devising any mitigation measures, which would minimize environmental impact during these tasks.


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Method Statements must be developed based on the risk assessments of the contractors’ activities.

3.3 TRAINING AND ENVIRONMENTAL AWARENESS

Vopak will develop an environmental awareness and training programme describing the manner in which:

• the applicant intends to inform its employees and contractors of any foreseeable environmental risks which may result from their work; and

risks must be dealt with in order to avoid pollution or degradation of the environment identified during the BA process and which emerge during the project.

3.4 COMMUNICATION

Channels of communication must be established between Vopak, the Contractor(s) and external stakeholders. Vopak (EMO) shall establish and maintain procedures for: • internal communication between the various levels and functions of the

Project staff organisation; and

• receiving, documenting and responding to relevant communication from external interested parties.

A complaints procedure must be established and maintained to record any complaints or comments received from the public during the construction, decommissioning and operational phases. The complaints procedure should be underpinned by the following principles and commitments: • disseminate key information to directly impacted stakeholders; • seek to resolve all grievances timeously; and • maintain full written records of each grievance case and the associated

process of resolution and outcome. The responsibility for resolution of grievances will lie with Vopak and its Contractor(s) where applicable.

3.5 RECORD KEEPING

Vopak will control HSE documentation, including Project licenses, approvals, this EMPr; associated procedures; checklists, forms and reports, through a formal procedure. The document control procedure will describe the processes that the Project will employ for official communication of both hardcopy and electronic documents and the requirement for electronic filing, document tracking and version control numbers.


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Vopak (the EMO) is responsible for maintaining a master list of applicable Project HSE documents and for communicating this list to the appropriate parties. The Contractor(s) will be required to develop a system for maintaining and controlling its own E documentation. All Project records and documentation will be kept on site for those site activities which require such documentation to be kept on site. Relevant documentation will be backed up on Project Place (Vopak’s project management database)(. A records register will be maintained indicating document formats (hard or soft copy) and will be archived for the life of the Project.

3.6 CHECKING AND CORRECTIVE ACTION

Checking includes inspections and monitoring as well as audit activities to confirm proper implementation of the EMPr as well as effectiveness of its mitigations. Corrective actions include response to incidents, non-compliances, and non-conformances. Actions also include those intended to improve performance and prevent future non-conformances.

3.6.1 Inspection

Site inspections will be conducted weekly on an ad hoc basis (internally) and formally once every month in an effort to monitor compliance and implement conditions stipulated in this EMP.

3.6.2 Monitoring

Monitoring activities shall include the recording of information to track compliance with the EMP The main objectives of the monitoring program will be to: • comply with regulatory requirements (i.e. emissions as stipulated);

• monitor changes in existing physical, biological and social characteristics

of the environment, compared to the baseline; • determine the effectiveness of the control and mitigation / enhancement

measures and provide a basis for recommending additional or alternative measures;

• verify that all project management plans are appropriate and relevant to

their respective project activities and phases; and • provide accountability and a sense of ownership through the Project

lifecycle.


24

The DEDTEA requires monitoring activities as part of an EMPr. The monitoring plan has therefore been incorporated into the list of EMP commitments in Section 4.

3.6.3 Auditing

Vopak will conduct regular audits to monitor compliance with the Project EMPr. The Contractors’ performances towards meeting these requirements will also be assessed. Audits will be undertaken as follows during the Project: • Internal audit: The Vopak EMO will audit activities of the Contractors and

Vopak’s performance on a monthly basis and undertake weekly inspections. A formal monthly report will be submitted to the ECO. The EMO shall use this EMPr as a basis to develop a checklist for monthly auditing.

• External audit: a suitably qualified independent third party

(Environmental Control Officer) will audit the Contractors and Vopak on a 3-monthly basis against the requirements of the EA and EMPr during the expansion activities .

Both the internal and external audits will include, at a minimum, the following: • completeness of applicable HSE documentation, including planning

documents and inspection records;

• conformance with monitoring requirements; • efficacy of activities to address any non-conformance with monitoring

requirements; and • training activities and record keeping.

3.6.4 Corrective Action

Vopak shall establish and maintain procedures for defining responsibility and authority for handling and investigating non-conformances, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive action. Any corrective or preventive action taken shall be appropriate to the magnitude of problems and correspond with the environmental impact encountered.


25

4 ENVIRONMENTAL MANAGEMENT PROGRAMME

This section covers the environmental specifications and recommendations required during the following phases of the Project: • Planning and Design Phase - Table 4.1; • Expansion- Table 4.2; and • Operational Phase - Table 4.3. The EMPr outlines the following: • affected receptor;

• potential impact to the receptor;

• project activities resulting in the potential impact;

• proposed mitigation / management and monitoring measures;

• parameters for monitoring;

• timing/frequency for implementation of mitigation / management and

monitoring measures; and

• responsibility for implementation.

4.1 PLANNING AND DESIGN PHASE

Impact mitigations and management measures identified for this Phase are included in Table 4.1below and must be incorporated into the overall Project design.

Table 4.1 Planning and Design Phase: Environmental Management Programme

Number Issue/ Receptor

Potential Impact Project Activities EMPr Mitigation / Management / Monitoring Measures

Parameters for Monitoring

Timing/Frequency Responsibility

4.1.1 General and Management

Regulatory non-compliance resulting in a fine

Commencing with the Project with no adherence to regulatory requirements

Notify all registered I&APs and key stakeholders of the opportunity to appeal the Environmental Authorisation, if granted.

I&AP notification letter

Within 14 days of receiving the EA in accordance with EIA Regulations (December, 2014)

Vopak Independent Environmental Assessment Practitioner

4.1.2 Notify DEDTEA prior to commencing with construction phase activities.

Proof of communication

Within the number of days stipulated by the EA

Vopak EMO

4.1.3 The EMPr must form part of the contractor’s tender documentation for all contractors working on the project and must be endorsed contractually. Signed commitment from any Contractors to compliance with EMPr.

Signed EMPr on site

Prior to construction

Vopak

4.1.4 Air Quality Potential emissions to the atmosphere

Generation of dust and other air pollutants as a result of expansion and operational Project activities

Develop a fugitive dust emissions management plan which shall include: • dust suppression of all on-site

dusty roads to minimize entrained dust emissions;

• regular sweeping of on-site roads to minimize silt loading.

Fugitive dust emissions management plan

Prior to construction and decommissioning phase activities

EMO

4.1.5 All new tanks are to be designed with the best available technology (BAT) in order to minimise the emission of hydrocarbons to the atmosphere.

Final Design Planning and Design Phase

Vopak EMO

4.1.6 Noise Potential increase in noise emissions

Some construction and decommissioning activities are likely to have an acoustical nature.

Gantries should be designed so that tanker trucks do not need to reverse on the facility (minimising reverse alarms). If unavoidable, then proper mitigation must be in place.


Vopak PM

4.1.7 Traffic Potential increase Movement of Develop a traffic accommodation Traffic Prior to expansion Vopak EMO





in traffic volumes in the local network during decommissioning, construction and operational activities and traffic delays due to transportation of abnormal loads.

vehicles and machinery

plan outlining measures to enhance the efficient transportation of components and materials to site while minimising congestion and disruption which might affect general traffic

Accommodation Plan

activities

4.1.8 Socio- Economic

Community involvement and benefits

Construction and operational Project activities

Establish a grievance procedure to allow community members to raise concerns and issues relating to the Project.

Grievance procedure

Planning and Design Phase

Vopak EMO

4.1.9 CSI Fund Align Corporate Social Initiatives (CSI) programmes with the existing/or planned municipal community development projects where possible.

Project CSI priorities


Vopak SHEQ Manager

4.1.10 Creation of Employment Opportunities

Proposed Project is anticipated to create 800 construction-related employment opportunities during decommissioning and construction activities

Vopak must maximize the use of local labour and stipulate the percentage local employment to be created as a condition in contractor contracts.

Recruitment policy


Vopak EMO and contractors

4.1.11 All contractors will be required to recruit in terms of Vopak’s Employment Equity Plan, where practically possible.

Recruitment policy


Vopak Contractor(s)

4.1.12 Vopak should ensure that recruitment policies take into consideration the recruitment of women and historically disadvantaged individuals.

Recruitment policy


Vopak Contractor(s)

4.1.13 Training and skills development

Training of Project workforce

Ensure that the appointed Contractor(s) and suppliers have access to Health, Safety, Environmental and Quality training as required by the Project.

Training programmes


Vopak





4.1.14 Procurement of goods and services

Goods and services required to support Project activities (i.e. construction materials and plant equipment)

Vopak must establish linkages with local small, medium and micro enterprises (SMME) development organisations where possible to determine which areas of SMME expertise are in existence, and which can be used during the construction and decommissioning phase activities.

Procurement policy


Vopak Contractor(s)

4.1.15 The use of SMMEs should be made a condition of tenders to contractors, in line with Vopak’s commitment to Broad Based Black Economic Empowerment (BBBEE).

Local supplier agreements


Vopak Contractor(s)

4.1.16 Health and Safety

Health and Safety impacts related to encountering impacted soil and groundwater

LNAPL and dissolved-phase contamination may be mobilised during trench excavations and dewatering.

An excavation plan must be developed prior to performing excavations in potentially contaminated areas.

Excavation Plan Prior to construction and decommissioning phase activities

Vopak EMO

4.1.17 Appropriate approvals need to be sought prior to discharge of potentially impacted groundwater to the sewer and/or stormwater system.

Record of communication


Vopak EMO

4.1.18 Unplanned Events

Risk of fires and explosions

Catastrophic failure of tanks and / or tank overfills resulting in bund fires; flash fires and / or vapour cloud explosions.

Compliance with all statutory requirements i.e. pressure vessel designs and applicable SANS codes.


Vopak PM

4.1.19 Incorporation of applicable guidelines or equivalent international recognised codes of good design and practice into the designs e.g. IEC 61508 and IEC 61511 (Safety Instrument Systems) standards or equivalent to ensure that adequate protective instrumentation is included in the design and would remain valid for the full life cycle of the tank farm.


Vopak PM

4.1.20 Complete a recognised process Proof of Process Planning and Vopak PM





hazard analysis (such as a HAZOP study, FMEA, etc.) on the proposed facility to ensure design and operational hazards have been identified and adequate mitigation put in place.

Hazard Analysis

Design Phase

4.1.21 All engineering designs must be signed by a professional engineer registered in South Africa in accordance with the Professional Engineers Act, who takes responsibility for suitable designs.

Final Design signed off by a professional engineer


Vopak EMO

4.1.22 Compile an emergency preparedness and response document for on-site .

Emergency Preparedness and Response Document

Planning and Design Phase - prior to initiating the MHI risk assessment

Vopak EMO

4.1.23 An MHI risk assessment must be completed in accordance to the MHI regulations and must cover the entire facility.

MHI risk assessment


Vopak EMO

4.1.24 Develop a detailed hazardous material spill response plan for the Vopak Efficiency (Growth 4) Project which is to be implemented from the construction phase.

Hazardous Material Spill Response Plan


Vopak EMO

4.1.25 Waste Possible contamination of ground water, surface water and soil.

Incorrect storage, transfer (loading and unloading) and handling of products and waste items including wastewater during decommissioning, construction and operational

Notify the municipal Waste Services to ensure waste material is disposed in an appropriate manner at a licence landfill site with the capacity to receive such wastes.

Communication with municipality


Vopak Contractor(s)

4.1.26 Secondary containment procedures to be included in design that avoid accidental or intentional releases of contaminated containment fluids.


Vopak EMO





4.1.27 activities Storm water channels and collection ponds with subsequent treatment with OWS to be included in design.


Vopak

4.1.28 Meters (“sight glasses”) to determine water content in tank, as well as vortex eliminators / barriers to minimize product release during draw off to be included in tank design.


Vopak


31

4.2 CONSTRUCTION AND DECOMMISSIONING PHASE

Activities associated with the construction (expansion activities) and decommissioning (final decommissioning of tanks and associated infrastructure) phases are similar and similar mitigation and management measures apply to both: Construction Phase

• Demolition of 38 ASTs with a total storage capacity of 32 000 m3 and

associated infrastructure.

• Building of six ASTs with a storage capacity of 20 000 m3 each (total storage capacity of 120 000 m3), six ASTs with a storage capacity of 5 000 m3 each (total storage capacity of 30 000 m3) and associated infrastructure.

• Decommissioning Phase

• Demolition of six ASTs with a storage capacity of 20 000 m3 each (total storage capacity of 120 000 m3), six ASTs with a storage capacity of 5 000 m3 each (total storage capacity of 30 000 m3) and associated infrastructure at the end of the Project life (not anticipated in the short or foreseeable long term at this stage).

In order to ensure compliance with environmental legislation requirements and Vopak’s environmental policy, the mitigation / management / monitoring measures of Table 4.2 are applicable to the construction and decommissioning phase activities of the Project.

Table 4.2 Construction and Decommissioning Phases: Environmental Management Programme

Number Issue / Receptor

Potential Impact Project Activities

EMPr Mitigation / Management / Monitoring Measure


Timing / Frequency

Responsibility

4.2.1 Legal Regulatory non-compliance resulting in a fine

Commencing with the Project with no adherence to regulatory requirements.

Ensure that the approved EMPr and Environmental Authorisation Licence are kept on site and are available throughout construction and decommissioning activities.

Approved EMPr Environmental Authorisation

Prior to construction and decommissioning activities

Vopak EMO

4.2.2 Air Quality

Impact on ambient air quality from dust and other vehicular emissions.

Construction and decommissioning phase activities have the potential to generate dust from: • movement of

construction vehicles;

• vehicle exhausts; • earth moving

activities; • back-fill

operations; • decommissioning

of old tanks; and • construction of

new tanks.

Use dust minimizing techniques at working areas to keep dust from being generated.

Visual verification

During construction and decommissioning activities

Contractor(s)

4.2.3 Ensure regular maintenance and repair of construction vehicles and machinery to keep vehicle emissions under control.

Vehicle and equipment maintenance log

Periodically during construction and decommissioning activities

Contractor(s)

4.2.4 Enforce speed limits of 15kph on unhardened roads and surfaces.

Visual verification


Contractor(s)

4.2.5 Loads on vehicles carrying dusty construction materials should be covered;

Visual verification


Contractor(s)

4.2.6 Limit access to construction site to construction vehicles only.

Visual verification


Contractor(s)

4.2.7 Noise Potential increase in noise emissions

Construction and decommissioning phase activities that are likely to have an acoustical nature include: • Cutting of steel

tanks with welders;

Ensure that equipment is well maintained and fitted with the correct and appropriate noise abatement measures. Acoustical mufflers (or silencers) should be considered on equipment exhausts.

Equipment maintenance log

Periodically during construction and decommissioning activities

Contractor(s)

4.2.8 Communicate and consult with surrounding neighbours and local communities regarding the

Proof of consultation

Prior to and during construction and

Project Contractor(s) and Vopak





Timing / Frequency

Responsibility

• Generators to supply onsite power;

• Mobile cranes for the dismantling and implementation of tankers;

• Grit blasting; • Riveting of steel

tankers and structures; and

• movement of construction vehicles.

construction work schedules. decommissioning activities

EMO

4.2.9 On-site work during construction and decommissioning should be limited to week days (Monday to Friday) for noisy construction activities. Non-noisy activities (which do not affect the communities surrounding the Island View Complex) to take place 7 days a week.

Construction schedule


Project Contractor(s)

4.2.10 Construction work producing excessive noise (i.e. above stipulated noise standards) shall be limited to daytime (07h00 to 17h00) as far as possible, while non-noisy construction work can take place at any hour.

Construction schedule



4.2.11 Should blasting be necessary, this should take place during the day only.

Visual verification

Prior to any blasting activities

Project Contractor(s) Vopak

4.2.12 Noisy equipment such as generators and air compressors, and noisy processes such as grit blasting should be located as far away from the noise sensitive residential areas as possible.

Visual verification



4.2.13 Construction staff working in areas where the 8-hour ambient noise is equal to or exceeds 85 dBA must be provided with ear protection equipment and erect sign-posting at these high noise areas.

Visual verification



4.2.14 Should complaints be received regarding the construction and decommissioning phase noise, a monitoring plan must be established and implemented within 3 months of receipt of the

Monitoring to be conducted by trained individuals.


Vopak EMO





Timing / Frequency

Responsibility

complaint. 4.2.15 Soil and

Water Potential contamination of soils, surface water and groundwater resources

Tank washings and inert solid waste (building rubble and construction materials), will be generated.

Wastes will be carefully handled and stored and suitably qualified waste contractors will remove and dispose of the waste, where appropriate. A closed drainage system including sump and control valves must be implemented to ensure that the tank contents are contained.

Waste disposal documentation



4.2.16 Potential leaks/ spills The floor of the bunds must be fully concreted to minimise the potential for soil and groundwater contamination.

Visual verification or contractor interview

During construction


4.2.17 Traffic Potential increase in traffic volumes in the local network during decommissioning and construction activities and traffic delays due to transportation of abnormal loads.

Movement of construction vehicles and machinery

Provide temporary traffic accommodation and respective road signage (e.g. road signage, road markings, barricades, and warning devices) in accordance with the South African Road Traffic Signs Manual (SARTSM) Volume 2 Chapter 13.

Visual verification

During construction and decommissioning

H&S officer and the Project Contractor(s)

4.2.18 Implement strict traffic controls prior to and during the construction and decommissioning phase activities of the proposed Project. Including: • Training of all drivers

(contractor and Project employee’s);

• Enforcement of speed limits for all vehicles;

• Maintenance of road degradation resulting from proposed Project use.

Training records Visual verification

Training to be undertaken weekly, during construction and decommissioning activities. Monthly audits of speed limits. Continuous maintenance of road degradation as required and when possible.

Contractor(s) EMO

4.2.19 The movement of ‘abnormal loads’ Delivery During Project





Timing / Frequency

Responsibility

must be undertaken during off-peak periods to minimise disruption to other road users.

schedule

decommissioning and construction activities

Contractor(s)

4.2.20 Should complaints be received related to traffic issues, traffic monitoring must be implemented. Traffic monitoring data should be analysed and reviewed at regular intervals and compared with the operating standards so that any necessary corrective actions can be taken.

Monitoring to be conducted by trained individuals.

Traffic monitoring frequency should be sufficient to provide representative data for road usage

Vopak EMO

4.2.22 Socio-economic

Creation of Employment Opportunities

Proposed Project is anticipated to create 800 construction-related employment opportunities during decommissioning and construction activities.

All recruitment will be undertaken through formal channels, and no recruitment will take place at the entrance to the site.

Visual verification

Prior to and during construction and decommissioning activities

Vopak Contractor(s)

4.2.23 Procurement of local goods and services

Proposed Project may increase spending in the local economy during construction.

Contractors to use local suppliers where appropriate/ possible and cost effective in line with Vopak’s procurement policy and procedure.

Procurement policy

Prior to and during construction and decommissioning activities

Vopak Contractor(s)


Training of Project workforce.

Vopak will ensure that workers are trained through a training service provider and on the job training by the contractor / EMO.

Training records Weekly updates during construction and decommissioning activities

Contractor(s) EMO

4.2.25 Community involvement and benefits

Construction and operational Project activities.

Maintain a grievance procedure to allow community members to raise concerns and issues relating to the Project.

Grievance procedure


Vopak Contractor(s)

4.2.26 Health and Safety

Health and safety impacts related to encountering impacted soil and groundwater

LNAPL and dissolved-phase contamination may be mobilised during trench excavations

Appropriate OH&S procedures and protocols (which should include Personal Protective Equipment (PPE), breathable air quality monitoring and explosive

Visual verification


Contractor(s)





Timing / Frequency

Responsibility

and dewatering. atmosphere monitoring) must be used.

4.2.27 Should dewatering activities be undertaken, it should be ensured that this does not result in the mobilisation of LNAPL and dissolved-phase contamination.

Visual verification



4.2.28 A hazardous materials spill management plan must be developed and available on site to contractors and site staff.

Visual verification of documents


Vopak EMO

4.2.29 Environmental awareness and emergency preparedness training must be provided to contractors and site personnel prior to the construction and decommissioning phase commencing.

Visual verification of documents



4.2.30 Occupational health risks associated with the decommissioning and construction activities

Construction and decommissioning activities such as working at heights, working within a confined space, increased movement of heavy vehicles to and from site etc.

Visibility of the pedestrian pathways should be increased by applying reflective road marking.

Visual verification



4.2.31 All access to site must be strictly controlled.

Visual verification


Contractor(s) and EMO

4.2.32 Contract workers will be inducted to the Project through a programme that includes sensitivity to the local social environment. Health risks will be highlighted in a standard Health and Safety programme that includes a focus on HIV/Aids awareness training.

Training records Weekly updates during construction and decommissioning activities


4.2.33 Unplanned events

Accidental spills to soil and groundwater resources

Storage and handling of hazardous materials

Hazardous material storage facilities (e.g. fuel stores) shall be designed and built to Vopak Standards or local design criteria

Visual verification


Contractor(s), Vopak PM and EMO





Timing / Frequency

Responsibility

(whichever is deemed the most stringent of the two).

4.2.34 Store all hazardous materials on hardstanding with an impermeable surface which should also be bunded.

Visual verification



4.2.35 Refuel equipment and vehicles in designated areas on hard standing ground.

Visual verification



4.2.36 Drip trays shall be used during construction and decommissioning activities when refuelling and servicing vehicles or equipment, where it is not on a hardstanding.

Visual verification



4.2.37 All spills shall be immediately contained and cleaned up and contaminated areas shall be remediated and post remediation verification carried out in accordance with the hazardous material spill response plan.

Visual verification Incident report



4.2.38 Fires and Explosions

Catastrophic failure of tanks and / or tank overfills resulting in bund fires; flash fires and / or vapour cloud explosions.

Vopak firefighting standard and secondary containment standard for design requirements must be adhered to.

Visual verification

During construction and prior to operational phase commencing


4.2.39 Each tank to have fire detection installed

Visual verification



4.2.40 Each tank to have top foam pourers which will be supplied by foam on wheels and manually activated.

Visual verification

During construction and prior to operational






Timing / Frequency

Responsibility

phase commencing

4.2.41 Each tank to have shell and roof cooling rings which can be activated remotely and supplied via the CFI system.

Visual verification


Contractor(s) and Vopak PM/ EMO

4.2.42 Bund foam pourers connected into CFI system and having option to inject foam from the foam injection canons.

Visual verification



4.2.43 Foam injection manifold must be accessible from the main road for emergency vehicle to connect on.

Visual verification



4.2.44 Manifolds/Pump bays to have fire detection system. Manifolds/Pump bays to have sprinkler system which can be activated remotely.

Design documentation



4.2.45 Manifolds/pump bays should have portable foam monitors.




4.2.46 Road loading facilities should have sprinkler systems.








Timing / Frequency

Responsibility

4.2.47 Waste Incorrect disposal/ storage of wastes could result in leaching and the contamination of soil and groundwater resources.

Incorrect disposal/ storage of wastes including: • hazardous and

non-hazardous solid waste;

• sewage and grey water; and

• hazardous liquid wastes such as used oils and spent chemicals.

Mixing of hazardous and general wastes within waste containers must be avoided.

Visual verification

During decommissioning and construction activities


4.2.48 Waste storage areas must be established that separate general and hazardous wastes, with signage to indicate the designated areas.

Visual verification



4.2.49 Waste storage area must contain sufficient containment for unforeseen spillages. In line with accepted international good practice the containment areas should be constructed to allow for the greater of 110% of the largest container, or 25% of the combined capacity of all containers to be placed within the store. The design of the secondary containment should include a waterproof base, bund walls, trenches or humps.

Visual Inspection. Containment areas to allow for the greater of 110% of the largest container, or 25% of the combined capacity of all containers to be placed within the store



4.2.50 All waste must be removed from site within a reasonable timeframe to reduce the risk from hazardous waste, prevent odours, and prevent potential health conditions and environmental impacts arising from the accumulation of waste.

Visual verification

Waste must not be stored for longer than 30 days at the site.


4.2.51 All staff and contractors on site must be trained in the site’s waste management plan to understand the different types of wastes that are generated, the associated risks and the designated waste container and area into which the waste may be placed.

Training records Weekly, during construction and decommissioning activities






Timing / Frequency

Responsibility

4.2.51 Hazardous wastes that are not compatible must be adequately separated in a manner that will prevent them coming into contact with each other - i.e. wastes that may pose a health and safety hazards if they react with each other (e.g. acids and bases).

Visual verification



4.2.52 Sufficient waste containers e.g. skips, bins or drums should be placed on site for different types of waste.

Visual verification



4.2.53 Hazardous waste containers should be kept closed or covered when not in use to prevent potential spillages and stormwater ingress.

Visual verification



4.2.54 Waste containers must be labelled to indicate the contents of the waste.

Visual verification



4.2.55 Only waste management companies (the transporter) that have been approved by the relevant authority may be used for the transport of waste.

Waste disposal contractor licence



4.2.56 All loading of waste should be supervised to ensure that waste containers are safely and securely loaded in a manner that will not result in spillages during transit. Hazardous waste must be transported in sealed or closed containers.

Visual verification



4.2.57 Hazardous waste, or general waste treated with hazardous materials may not be given or sold to staff, contractors or the public e.g. empty chemical containers (even if

Visual verification







Timing / Frequency

Responsibility

washed) and treated wooden pallets.

4.2.58 Certificates of Safe Disposal and/or final copies of Waste Manifest Documents (WMD) indicating acceptance at the waste facility should be obtained for all hazardous waste after the waste has reached its intended destination.

Record keeping – Safe Disposal Certificates and WMDs.

During and after decommissioning and construction activities. Records of hazardous waste disposal must kept on file (or archived) for a period of 5 years.


4.2.58 Inspections of the waste storage areas and waste containers must be conducted, to assess the separation, integrity of the containers and storage areas, correct labelling and signage.

Monthly audit reports

Monthly internal audits

Vopak EMO

4.2.59 The Site shall monitor the quantities of waste generated, in tonnes, of the following: • general waste disposed, • hazardous waste disposed,

and • recycled wastes.

Records of quantities of waste disposed


Contractor(s) EMO


42

4.3 OPERATIONAL PHASE

There will be minimal changes to operational phase activities as compared to existing operations on site (i.e. no drumming and the reduction of chemicals stored). The Site is designed to receive, store and dispatch a variety of commodity bulk liquid chemicals. Mitigation / management / monitoring measures (refer to Table 4.3 below) are described to provide a mechanism for ensuring that Vopak mitigate potentially adverse impacts during operations.

Table 4.3 Operational Phase: Environmental Management Programme


Potential Impact

Project Activities / Environmental Aspects



Timing / Frequency

Responsibility

4.3.1 Air Quality Potential increase in ambient concentrations of dust and construction vehicle and construction equipment exhaust emissions such as SO2, NO2, PM10, CO and benzene.

Storage and handling of petroleum products, base oils and chemicals Tank cleaning and degassing

Apply Best Available technologies (BAT) for storage tanks that depends on the vapour pressure of the product.

Design specifications

Prior to operations

Vopak PM

4.3.2 Fixed-roof designs that are vented to atmosphere must be implemented for products with a vapour pressure less than 14 kPa, i.e. diesel.


Prior to operations

Vopak PM

4.3.3 Conduct ambient air quality monitoring in accordance with existing AEL requirements.

National Ambient Air Quality Standards (NAAQS) Emission Limits

During operations

Vopak Appointed Air Quality Specialist

4.3.4 For products with a vapour pressure of more than 14 kPa, i.e. ULP; external floating-roof tank with primary rim seal and secondary rim seal for tank with a diameter greater than 20m, or a fixed-roof tank with internal floating deck fitted with a primary seal, or a fixed-roof tank with vapour recovery system must be implemented.


Internal inspection every 10 years

Vopak PM/ EMO

4.3.5 The development and implementation of servicing programs for the Growth 4 tanks


Within the first year of construction

Vopak PM

4.3.6 Stocking of critical components to ensure the availability of spares in the event of mechanical faults.

Visual inspection Within the first year of construction

Vopak PM

4.3.7 Noise Potential Operational Clearly demarcate and label high Visual During operation Vopak EMO


Potential Impact




Timing / Frequency

Responsibility

increase in noise emissions during day and night-time operational periods

noise sources include: • Pumps; • Trucks; and • Gantries.

noise areas (i.e. the compressor room, generator room and use of power tools).

verification

4.3.8 Hearing protection should be worn by all Vopak personnel in high noise areas.

Visual verification

During operation Vopak EMO

4.3.9 Maintain machines and plant equipment.

Maintenance log Periodically, during operation

Vopak PM

4.3.10 Soils and Water

Potential contamination of soils, surface water and groundwater resources

Potential leaks and spills associated with operations and maintenance of tanks and associated infrastructure.

The construction of all infrastructure necessary for the collection of the first flush (including drains) must be connected to a separator.

Prior

4.3.11 Traffic Increased traffic flow on the local network during operation; and traffic delays due to transportation of ‘abnormal loads’.

Movement of delivery and collection vehicles.

The movement of ‘abnormal loads’ will be undertaken during off-peak periods where possible to minimise disruption to other road users.

Delivery schedule

During operation Vopak PM and contractor

4.3.12 Should a complaint be received from neighbouring communities regarding traffic or if excessive traffic congestion occurs due to the Growth 4 Project, then Vopak should develop a traffic management plan outlining measures to enhance the efficient transportation of components and materials to site while minimising congestion and disruption.

Traffic Management Plan or complaints register

As required during operation

Vopak EMO

4.3.13 Socio- Economic

Potential nuisance to the community

Air and noise emissions as well as traffic resulting from the operation of the Terminal.

Implement the grievance procedure to allow community members to raise concerns and issues relating to the operation of the Vopak Durban Terminal.

Grievances logged



Potential Impact




Timing / Frequency

Responsibility

4.3.14 Creation of employment opportunities

Additional Project workforce for operations

Ensure recruitment of Project workforce is undertaken in line with the Vopak recruitment policy. In particular, preference must be given to local residents, suppliers and consideration given to gender equality.

Percentage targets for recruitment policy are met

Prior to operation Vopak PM


Provision of training

Ensure that all appointed Project Contractor/s and suppliers have access to Health, Safety, Environmental and Quality training and skills development activities as required for applicable job descriptions.

Training records and training material

Prior to and during operation

Vopak EMO/ SHEQ officer

4.3.16 Occupational Health and Safety

Occupational health and safety risks associated with dermal contact or inhalation of hazardous chemicals

Operational activities including fuel loading, unloading and storage

Exposure should be prevented through the implementation of Vopak’s Occupational Health and Safety management program. Procedures shall be in place to address potential issues related to the Vopak Efficiency (Growth 4) Project.

Visual verification of document and training records

During operation Vopak SHEQ manager/ officer

4.3.17 All access to site must be strictly controlled.

Visual verification

During operation Vopak PM/ site manager

4.3.18 Confined space entry (e.g. storage tanks, secondary containment areas and stormwater / wastewater management infrastructure) must be in accordance with Vopak minimum best practise requirements.

Visual verification and document verification



4.3.19 Unplanned events

Risk of fires and explosions

Catastrophic failure of tanks and / or tank overfills resulting in bund

Even though Vopak has a comprehensive Emergency Plan that covers all possible emergencies, prior to operation of the proposed project, this plan must be updated.

Updated Emergency Plan

Prior to operation Vopak EMO


Potential Impact




Timing / Frequency

Responsibility

4.3.20 fires; flash fires and / or vapour cloud explosions.

Employees and contractors shall be made aware of any changes to the site emergency plans resulting from the Project and will be trained on all emergency requirements.

Training record Staff awareness


4.3.21 Notify neighbours and authorities of the hazardous installations associated with the Project.

Proof of notification


4.3.22 Accidental spills to soil and groundwater resources

Storage and handling of hazardous materials

Store all hazardous materials on hardstanding with an impermeable surface which should also be bunded.

Visual verification


4.3.23 Refuel equipment and vehicles in designated areas on hard standing ground.

Visual verification


4.3.24 All spills shall be immediately contained and cleaned up and contaminated areas shall be remediated and post remediation verification carried out in accordance with the hazardous material spill response plan.

Visual verification Incident report

During operation Vopak EMO and contractor(s)

4.3.25 Periodically check containment areas for leaks.

Visual verification

During operation, on a monthly basis

Vopak EMO/ PM/ SHEQ

4.3.26 Waste Possible contamination of ground water, surface water, soil and corrosion of underground piping systems from wastewater.

Wastewater consists mainly of tank bottom draining and contaminated storm water runoff, including water from tank leaks and spills that collects in secondary containment

OWS must be included in the Vopak Durban Terminal’s maintenance schedule.

Maintenance Schedule and Log


4.3.27 Oil collected in OWS must be removed off site by a reputable waste management contractor and disposal/recycle certificates must be supplied to Vopak by the waste management contractor.

OWS Waste Disposal Certificates

During operation, at regular intervals

Vopak EMO

4.3.28 Regular maintenance to locate and repair/replace tank roof, seals, or

Maintenance Log During operation Vopak EMO


Potential Impact




Timing / Frequency

Responsibility

areas. Other possible sources of wastewater include oil contaminated water from washing tanker trucks and railcars, and wastewater from vapour recovery processes.

other sources of water infiltration.

4.3.29 Potential for spills or leaks impacting soil, surface water and groundwater resources

Incorrect storage and transfer (loading and unloading) of products and waste items including: • hazardous

and non-hazardous solid waste;

• sewage and grey water; and

• hazardous liquid wastes such as used oils and spent chemicals.

Tank sludge and spill clean-up materials must be managed as waste at a facility licensed to handle this type of material in an environmentally sound manner.

Waste Disposal Certificates


4.3.30 Small quantities of oil contaminated soils should be managed at a waste at a facility licensed to handle this type of material.

Waste Disposal Certificates


4.3.31 Mixing of hazardous and general wastes within waste containers must be avoided.

Visual verification


4.3.32 Waste storage area must contain sufficient containment for unforeseen spillages. The design of the secondary containment should include a waterproof base such as impermeable lining, and bund walls, trenches or humps.

Visual Inspection. Containment areas to allow for the greater of 110% of the largest container, or 25% of the combined capacity of all containers to be placed within the store

During operation Vopak PM/ EMO

4.3.32 All waste must be removed from Visual Waste must not Contractor and


Potential Impact




Timing / Frequency

Responsibility

site within a reasonable timeframe to reduce the risk from hazardous waste, prevent odours, and prevent potential health conditions and environmental impacts arising from the accumulation of waste.

verification and waste disposal certificates

be stored for longer than 30 days at the site.

Vopak EMO

4.3.33 All Vopak site personnel must be trained in the site’s waste management plan to understand the different types of wastes that are generated, the associated risks and the designated waste container and area into which the waste may be placed.

Training records Regularly during operation

Vopak EMO

4.3.34 Hazardous wastes that are not compatible must be adequately separated in a manner that will prevent them coming into contact with each other - i.e. wastes that may pose a health and safety hazards if they react with each other (e.g. acids and bases).

Visual verification


4.3.35 Sufficient waste containers e.g. skips, bins or drums should be placed on site for different types of waste.

Visual verification


4.3.36 Hazardous waste containers should be kept closed or covered when not in use to prevent potential spillages and stormwater ingress.

Visual verification


4.3.37 Waste containers must be labelled to indicate the contents of the waste.

Visual verification


4.3.38 Only waste management companies (the transporter) that have been approved by the relevant authority may be used for the transport of waste.

Waste disposal contractor licence



Potential Impact




Timing / Frequency

Responsibility

4.3.39 All loading of waste should be supervised to ensure that waste containers are safely and securely loaded in a manner that will not result in spillages during transit. Hazardous waste must be transported in sealed or closed containers.

Visual verification

During operation Contractor(s) and Vopak EMO

4.3.40 Hazardous waste, or general waste treated with hazardous materials may not be given or sold to staff, contractors or the public e.g. empty chemical containers (even if washed) and treated wooden pallets.

Visual verification


4.3.41 Certificates of Safe Disposal and/or final copies of Waste Manifest Documents (WMD) indicating acceptance at the waste facility should be obtained for all hazardous waste after the waste has reached its intended destination.

Record keeping – Safe Disposal Certificates and WMDs

During operation. Records of hazardous waste disposal must kept on file (or archived) for a period of 5 years.

Contractor(s) and Vopak EMO

4.3.42 Inspections of the waste storage areas and waste containers must be conducted, to assess the separation, integrity of the containers and storage areas, correct labelling and signage.

Monthly audit reports

Monthly internal audits

Contractor(s) and Vopak EMO

4.3.43 The Waste inventory, including information to assist with the safe management of waste on site must be updated regularly.

Waste inventory At lease every five years

Vopak EMO

4.3.44 Wastes must be classified to ensure the correct handling and disposal/recycling of the waste.

Waste classification manifest

As often as waste stream changes

Vopak EMO

Vopak shall monitor the quantities Records of During operation Vopak EMO


Potential Impact




Timing / Frequency

Responsibility

of waste generated, in tonnes, of the following: • general waste disposed, • hazardous waste disposed, and • recycled wastes.

quantities of waste disposed


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5 MONITORING

5.1 AIR QUALITY

Although the predicted air quality impacts are low, it is important that the facility is maintained to ensure performance continually meets the design specifications. It is recommended that Vopak’s current ambient air quality monitoring program is expanded to include BTEX monitoring on the fenceline of the facility. In addition, it is recommended that that the current Leak Detection and Repair program is revised to include the new tanks.

5.1.1 Environmental Management System

An Environmental Management System consists of an emissions inventory, monitoring system and reporting. Requirements for environmental management will be dictated by the conditions in the Atmospheric Emission License (AEL) and these are likely to include:

i. Annual emission inventory update;

ii. Annual LDAR and reporting;

iii. Fenceline monitoring of BTEX;

iv. Annual reporting of emissions to the National Atmospheric Emission Inventory System (NAEIS) (Government Gazette 38633, Notice No. R 283 of 2 April 2015); and

v. Registration on the South African Atmospheric Emission and Licensing Portal (SAAELIP) and annual reporting to the Licensing Officer in terms of the AEL.

5.2 WATER MONITORING

A specific plan to address the current contamination present in the groundwater will be developed and will align with the Vopak remediation strategy where applicable. Currently, Vopak undertakes annual groundwater monitoring of all its sites. Where groundwater monitoring wells are removed as part of the construction phase activities, these will be reinstated as required.


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5.3 WASTE

5.3.1 Waste Management Principles

During the project Vopak will evaluate measures to: a. avoid the generation of waste and where such generation cannot be

avoided, to minimise the toxicity and amounts of waste that are generated; b. reduce, re-use, recycle and recover waste; c. where waste must be disposed of, ensure that the waste is treated and

disposed in an environmentally sound manner; d. manage the waste in such a manner that it does not endanger health or the

environment or cause a nuisance through noise, odour or visual impacts; and

e. prevent the waste from being used for an unauthorised purpose.

The Site shall monitor the quantities of waste generated, in tonnes, of the following will be maintained:

• general waste disposed; • hazardous waste disposed; and • recycled wastes .

An appointed environmental management officer shall conduct regular inspections of the Project site and activities related to the various phases pertinent to the expansion in order to identify any concerns an address these accordingly.


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6 ENVIRONMENTAL AWARENESS AND TRAINING

In addition to health & safety inductions, all subcontractors and workers must be inducted on the site specific EA and EMPr requirements applicable. Toolbox talks must include an environmental component and records of training, including an attendance register, must also be kept on site. The contractor is required to provide and maintain a method statement for “solid waste management” including (but not limited to) the following: • Details on littering; • Good site housekeeping; • All rubble must be periodically removed; • Do not bury waste on site; • Waste separation; • Hazardous waste; • General waste; • Reusable construction material; • Recyclable waste; • Demarcate an area for waste storage;

Sufficient closed containers to be provided; • Dispose of hazardous waste material at a licenced disposal site; • Safe disposal certificates to be provided to Vopak and the ECO. The Contractor must provide method statements for the “handling and storage of oils and chemicals “which must include (but not limited to) the following: • Dangerous and toxic materials must be clearly labelled; • Store chemicals that react with each other separately; • Chemicals must be stored in appropriate containers; • Storage of hazardous chemicals requires secondary containment; • Drip trays must be placed under all vehicles. Contractors must provide and maintain a method statement for “cement and concrete batching” which must include (but not limited to) the following: • Wear appropriate PPE during cement mixing; • Store cement bags in a demarcated hazardous area; • Visible remains of concrete (solid or from washings) must be physically

removed and disposed as waste to a registered landfill site; • Dedicate an area for cement mixing which must be on a hard surface (not

soil); • Demarcate area with a berm (soil or other item).

6.1 DUST

The contractor must provide and maintain a method statement for “dust control” which must include (but not limited to) the following: • Details of the source of water to be utilized must be included;


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• Appropriate PPE including dust masks must be used when necessary; • Employ dust mitigation measures e.g. wetting soil surface before

conducting dust generating activities; • Dust suppression must not involve chemicals.

6.2 STOCKPILES

The following general recommendations apply to stockpiled material and it is the duty of the contractor to enforce these: • Stockpiled material must be placed on easily accessible areas without any

environmental damage; • Stockpiles to be stabilised if signs of erosion are visible; • Topsoil stockpiles must be monitored for invasive vegetation and

demarcated as no-go areas.

6.3 SPILLS/ LEAKS

The following general recommendations apply to spill and leaks, and it is the duty of the contractor to enforce these: • Appropriate spill kits must be available on site; • A spills register must be maintained on site. This must include details of

the corrective action taken; • Leaks / spills > 10 and/or that cause water pollution must be reported

immediately to the Project Manager, Vopak and ECO; • Leaks and/or spills must be appropriately cleaned up, and disposed

correctly; • Appropriate spill kits must be available on site; • A spills register must be maintained on site. This must include details of

the corrective action taken; • Leaks / spills > 10 and/or that cause water pollution must be reported

immediately to the Project Manager, Vopak and ECO; • Leaks and/or spills must be appropriately cleaned up, and disposed

correctly. The procedure for responding to a spill/leak of manageable volume, involves mobilising to stop it at the source of the spill/leak. Containment is the next step in the process and if there is a fire risk or a need to control vapours, then foam will be used to blanket the spill. Absorbents and neutralizers may also be used and when the situation is stabilised and confirmed as safe, then the spilled product is pumped into a mobile slop drum/ tank stored on site until removed by a contractor. Were foam, neutralizers or absorbents are used to respond to a spill the waste is treated and disposed of with records of all spills being kept.

6.4 STAKEHOLDER ENGAGEMENT

Complaints received by surrounding landowners and any I&APs must be addressed via a Complaints and Incidents Register.


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6.5 EATING AREAS AND CAMP CREW

The contractor must provide and maintain a method statement for “Crew Camps and Construction Laydown Areas “which must stipulate designated eating areas and the provision of adequate closed refuse bins.

6.6 HEALTH AND SAFETY

The following general recommendations apply to health and safety and it is the duty of the contractor to enforce these: • The construction site must be fenced off to prohibit unauthorised access

and site access must be strictly controlled; • All employees, contractors and subcontractors must wear appropriate

PPE; • The site and crew must be managed in accordance with applicable and

relevant Occupational Health and Safety Act; • Emergency procedures in place prior to commencing work and to include

but not be limited to: fire, spills, accidents to employees, use of hazardous substances and materials;

• Appropriate health and safety signage must be displayed on site.

6.7 EMERGENCY SYSTEMS FOR MAJOR INCIDENT MANAGEMENT

In the event of a major incident or spill, the spilled product must be contained in the concrete bunds surrounding the tanks to prevent the lateral spread of product to other areas of the site. The sites will have sealed concrete flooring in all its bunds and this together with the bunding around the containers eliminates potential groundwater and surface water contamination from spills. If a major incident in the form of a tank fire or a loss of containment were to occur, the Emergency Response Procedure would be activated and firefighting and/or inter-bund drainage may be required depending on the nature of the incident. In both cases significant amounts of waste would be produced (product mixed with firewater). Suitable licensed liquid waste removal contractors would remove the waste from the site and undertake the necessary treatment offsite.


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7 CONTACT DETAILS AND SIGNATURES

The contact details of relevant personnel must be provided in the table below (Table 7.1) prior to the commencement of the Project. The signatures of the Vopak PM, SHEQ manager, Contractor(s) and EMO will signify that the mitigation, management and monitoring measures of this EMPr will be adhered as stipulated in this EMPr.

Table 7.1 Relevant Contact Personnel

Name Contact Person Contact Numbers Vopak Project Manager (PM) (for construction and decommissioning phases)

Vopak SHEQ Manager (for all phases)

Environmental Management Officer (EMO)

Contractor

Contractor

Contractor


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SIGNATURES Vopak Project Manager (PM) Signature Date

Vopak SHEQ Manager Signature Date

EMO Signature Date

Contractor Signature Date

Contractor Signature Date

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