SAPREF NORTH FLARE REPLACEMENT PROJECT - ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) - WSP
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SAPREF NORTH FLARE
REPLACEMENT PROJECT
ENVIRONMENTAL MANAGEMENT
PROGRAMME (EMPR)
DRAFT
SAPREF NORTH FLARE REPLACEMENT PROJECT ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) TYPE OF DOCUMENT (VERSION) DRAFT PROJECT NO.: 41102753 DATE: JANUARY 2021 WSP BLOCK A, 1 ON LANGFORD LANGFORD ROAD WESTVILLE, DURBAN, 3629 SOUTH AFRICA T: +27 31 240 8800 F: +086 606 7121 WSP.COM
QUALITY MANAGEMENT
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft
Date 13 January 2021
Prepared by Nigel Seed
Digitally signed by Seed, Nigel
(ZANS00325)
Signature DN: cn=Seed, Nigel (ZANS00325),
ou=Active,
email=Nigel.Seed@wsp.com
Date: 2021.01.16 19:36:42 +02'00'
Checked by -
Signature
Authorised by -
Signature
Project number 41102753
Report number 01
File reference -
WSP is an ISO9001:2015, ISO14001:2015 and OHSAS18001:2007 certified company
SIGNATURES
PREPARED BY
Digitally signed by Seed, Nigel
(ZANS00325)
DN: cn=Seed, Nigel (ZANS00325),
ou=Active,
email=Nigel.Seed@wsp.com
Date: 2021.01.16 19:37:02 +02'00'
Nigel Seed
Director
REVIEWED BY
N/A
This report was prepared by WSP Environmental (Pty) Ltd for the account of SHELL AND BP SOUTH AFRICA
PETROLEUM REFINERIES (SAPREF), in accordance with the professional services agreement. The disclosure
of any information contained in this report is the sole responsibility of the intended recipient. The material in it
reflects WSP’s best judgement in light of the information available to it at the time of preparation. Any use which
a third party makes of this report, or any reliance on or decisions to be made based on it, are the responsibility of
such third parties. WSP accepts no responsibility for damages, if any, suffered by any third party as a result of
decisions made or actions based on this report. This limitations statement is considered part of this report.
The original of the technology-based document sent herewith has been authenticated and will be retained by WSP
for a minimum of ten years. Since the file transmitted is now out of WSP’s control and its integrity can no longer
be ensured, no guarantee may be given to by any modifications to be made to this document.
PRODUCTION TEAM CLIENT Environmental Manger Melanie Francis Project Manager Larissa Terdu-Smolders WSP Environmental Assessment Practitioner Nigel Seed Air Quality Specialist Lisa Ramsay
TABLE OF 1 INTRODUCTION ........................................ 1
Background........................................................... 1
CONTENTS Scope of the EMPr ................................................ 1
Details of the EAP ................................................. 2
Environmental Management Programme
Structure ............................................................... 2
Applicable Documentation ................................... 4
2 LEGAL FRAMEWORK ............................... 4
3 PROJECT DESCRIPTION ......................... 5
Description of the Flare Replacement Project ..... 5
Construction Activities ......................................... 9
4 ENVIRONMENTAL MANAGEMENT
PROGRAMME GOVERNANCE ............... 11
Roles and Responsibilities................................. 11
Environmental Awareness Plan ......................... 11
Incident Management and Mitigation ................. 12
Stakeholder and Community Enquiries and
Complaints .......................................................... 13
Environmental Performance Monitoring............ 13
Document Control (Environmental File) ............ 14
EMPR Revisions ................................................. 14
5 PROPOSED MITIGATION AND
MANAGEMENT MEASURES................... 15
cultural heritage resources ................................ 15
Atmospheric EMissions ..................................... 15
Ambient Noise .................................................... 16
Hazardous Substances and Environmental
Contaminants...................................................... 17
Waste Management ............................................ 18
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)
Lighting Impacts associated with Flaring
Events ................................................................. 19
SOCIO-ECONOMICS ........................................... 20
Post Construction and Post Closure ................. 22
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)
TABLES
TABLE 1 DETAILS OF THE ENVIRONMENTAL
ASSESSMENT PRACTIONER ..... 2
TABLE 2: LEGISLATION REQUIREMENTS AS
DETAILED IN APPENDIX 4 OF
GNR 326 ...................................... 2
TABLE 3 CONSTRUCTION ACTIVITIES .... 9
TABLE 4: ROLES AND RESPONSIBILITIES......... 11
TABLE 5: TRAINING AND INDUCTION
REQUIREMENTS ....................... 12
TABLE 6: INCIDENT MANAGEMENT AND
MITIGATION .............................. 12
TABLE 7: DECOMMISSIONING PHASE ............... 22
FIGURES
FIGURE 1 ELEVATION DRAWING OF THE
PROPOSED FLARE
STRUCTURE ............................... 5
FIGURE 2 LOCATION OF THE NORTH
FLARE WITHIN THE SAPREF
REFINERY ................................... 6
FIGURE 3: DELINEATION OF RADIATION
STERILE AREA AND PROPERTY
LIMITS.......................................... 8
APPENDICES
A EAP CV
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)
1 INTRODUCTION
BACKGROUND
Shell & BP South African Petroleum Refineries (SAPREF) located at Prospecton on the south coast of the
eThekwini Municipality, is a joint venture between Shell Refining SA and BP Southern Africa. The SAPREF
Refinery located within the South Durban Basin (SDB) has been in operation for over 50 years and is the largest
crude oil refinery in sub-Saharan Africa. The refinery's products include: gasoline (petrol); paraffin; gasoil
(diesel); solvents; jet fuel; bitumen; lubricating oil; liquid petroleum gas; marine fuel oil; and chemical feed stocks.
SAPREF currently has two separate flares – one located at the northern side of the refinery (North Zone) and the
other at the south side (South Zone). Currently SAPREF can use the combined capacity of both flares in an
integrated manner to flare from the North and South Zones of the refinery, i.e. if the pressure generated at North
Zone exceeds the capacity of the North Flare, it could be flared in the South Flare. However, the current
situation is not ideal nor a long term solution, as these interconnecting lines will need to be isolated for unit
shutdowns whilst the flares will still be in operation. The justification for the flare replacement project is further
supported by the following:
1) The North Flare was installed in 1994 and has been operational for more than 26 years. Due to its age,
prolonged safe and reliable operation beyond 2022 is not viable even with extensive maintenance and
repairs; therefore the only option is to replace the flare with a new one.
2) SAPREF has implemented operational changes at the refinery to meet increasingly stringent fuel
sulphur specifications. In particular, the replacement of the reactor in the hydrogen desulphurisation
unit (Unit 4 / HDS4) has changed the flaring requirements of the refinery. SAPREF currently can meet
this requirement by using the combined capacity of the North and South Flares; however, to reduce
process and site risk, good practice requires that the flares should process full load without balancing.
To achieve this, the capacity of the North Flare must be increased.
3) The flare replacement project is an opportunity for SAPREF to improve the environmental
performance of the flare. The proposed replacement flare uses up-to-date technology, which will result
in lower noise emission and improved combustion of potentially harmful gasses.
The proposed flare tip will be designed without refractory1 which is according to the latest international flare tip
design standard. SAPREF has investigated various options to ensure that heat radiation levels at the refinery
boundary remain within international acceptable and safe limits, including inter alia controlling public access to
the radiation zone, the use of shields and shelters, relocation of the flare, and increasing the flare height. The
preferred option (that will be assessed in the basic assessment) involves increasing the flare height from 59.3 m
(existing flare) to at least 77 m (increase of 17.7 m).
SAPREF intends to submit an application for Environmental Authorisation (EA) to the Department of
Economic Development, Tourism, and Environmental Affairs (EDTEA) for the proposed replacement and
upgrading of the North Flare, which is an activity regulated in terms of the National Environmental
Management Act (NEMA) 2014 Environmental Impact Assessment (EIA) Regulations, as amended. The
application for the EA entails the undertaking of a Basic Assessment (BA) process, culminating in the
preparation of a BA Report and Environmental Management Plan Programme Report (EMPr) (this document).
SCOPE OF THE EMPR
The EMPr is applicable to the construction phase of the North Flare replacement as per the project description
(Section 3).
1 Refractory is a heat resistant liner material used in the flare to prevent heat and chemical damage to the structure.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 1
Once the replacement flare becomes the operational its environmental management will be incorporated into the
Standard Operating Procedures (SOP) forming part of SAPREF’s broader ISO 14000 EMS.
DETAILS OF THE EAP
WSP Environmental (Pty.) Ltd., Africa (WSP, Africa) has been appointed in the role of Independent
Environmental Assessment Practitioner (EAP) to undertake the BA processes for the proposed project as well as
to develop this EMPr. Table 1 outlines the details of the EAP and their expertise.
Table 1 Details of the Environmental Assessment Practioner
NAME OF
CONSULTANT: WSP ENVIRONMENTAL (PTY.) LTD.
Contact Person: Nigel Seed
Postal Address: Block A, 1 on Langford
Langford Road
Westville
Durban
3629 South Africa
Telephone: 031 240 8860
Fax: 031 240 8861
E-mail: Nigel.seed@wsp.com
Expertise to conduct this Nigel has 19 years’ environmental and social consulting experience. Nigel has led complex
EIA Environmental and Social Assessments (ESA) and transaction related due diligence
assessments across a range of sectors including aerospace, agro-processing, chemicals,
healthcare, infrastructure (ports, roads, waste management), manufacturing, mining and
beneficiation, oil & gas, pulp & paper power generation (thermal & renewables), and
property development.
ENVIRONMENTAL MANAGEMENT PROGRAMME
STRUCTURE
Table 2 the sections within the EMPr with the legislated requirements as per Appendix 4 of GNR 326 of 2014
as amended.
Table 2: Legislation Requirements as detailed in Appendix 4 of GNR 326
Relevant Report
Appendix 4 Legislated requirements as per the NEMA GNR 326 Section
(a) details of-
(i) the EAP who prepared the EMPr; and Section 1.2
(ii) the expertise of that EAP to prepare an EMPr, including a curriculum vitae; Section 1.2 and
Appendix A
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 2(b) a detailed description of the aspects of the activity that are covered by the EMPr as Section 3
identified by the project description;
(c) a map at an appropriate scale which superimposes the proposed activity, its Section 1.2 / Figure 1
associated structures, and infrastructure on the environmental sensitivities of the
preferred site, indicating any areas that any areas that should be avoided, including
buffers;
(d) A description of the impact management outcomes, including management Section 5
statements, identifying the impacts and risks that need to be avoided, managed and
mitigated as identified through the environmental impact assessment process for all
phases of the development including-
(i) planning and design;
(ii) pre-construction activities;
(iii) construction activities;
(iv) rehabilitation of the environment after construction and where applicable post
closure; and
(v) where relevant, operation activities;
(f) a description of proposed impact management actions, identifying the manner in Section 5
which the impact management outcomes contemplated in paragraphs (d) will be
achieved, and must, where applicable, include actions to -
(i) avoid, modify, remedy, control or stop any action, activity or process which
causes pollution or environmental degradation;
(ii) comply with any prescribed environmental management standards or practices;
(iii) comply with any applicable provisions of the Act regarding closure, where
applicable; and
(iv) comply with any provisions of the Act regarding financial provisions for
rehabilitation, where applicable
(g) the method of monitoring the implementation of the impact management actions Section 4
contemplated in paragraph (f);
(h) the frequency of monitoring the implementation of the impact management actions Section 4.5 / Section 5
contemplated in paragraph (f);
(i) an indication of the persons who will be responsible for the implementation of the Section 4.1 / Section 5
impact management actions;
(j) the time periods within which the impact management actions contemplated in Section 4
paragraph (f) must be implemented;
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 3(k) the mechanism for monitoring compliance with the impact management actions Section 2.1 / Section 5
contemplated in paragraph (f);
(l) a program for reporting on compliance, taking into account the requirements as Section 2.1 / Section 4
prescribed by the Regulations
(m) an environmental awareness plan describing the manner in which- Section 4.2
(i) the applicant intends to inform his or her employees of any environmental risk
which may result from their work; and
(ii) risks must be dealt with in order to avoid pollution or the degradation of the
environment; and
(n) any specific information that may be required by the competent authority N/A
APPLICABLE DOCUMENTATION
The following documents are to be read in conjunction with the EMPr:
— BA Report for the Proposed North Flare Replacement Project.
— EA issued by the EDTEA in terms of the NEMA (still to be issued).
2 LEGAL FRAMEWORK
The national environmental legislation applicable to the proposed project includes, but is not limited, to the
following:
— The Constitution of the Republic of South Africa (No. 108 of 1996);
— National Environmental Management Act (No. 107 of 1998);
— National Environmental Management, Waste Act (No 59 of 2008);
— National Environmental Management, Air Quality Act (No 39 of 2004);
— National Environmental Management Biodiversity Act (No. 10 of 2004);
— The National Water Act, (No 36 of 1998);
— Occupational Health and Safety Act, (No 85 of 1993);
— National Heritage Resource Act (No. 25 of 1999);
— The Conservation of Agricultural Resources Act, (No 43 of 1983) (CARA); and
— Hazardous Substances Act (No. 15 of 1973).
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 43 PROJECT DESCRIPTION
DESCRIPTION OF THE FLARE REPLACEMENT
PROJECT
The North Flare system consists of a knockout drum, a seal drum, a flare stack, and a flare tip including an
ignition system and three pilot burners. The project will replace the stack and the flare tip including the ignition
system, steam injection system, and pilot burners. Each of these components of the replacement project are
described below.
The existing knockout drum and seal drum do not require replacement or upgrading and will be retained. It is
noted that mitigation against air being drawn into the stack itself will be provided by a constant purge ** of fuel
gas or MRG immediately downstream of the seal drum as part of a different project (the Flare Risk Mitigation
Project, J09).
** A small quantity of purge gas is needed to prevent air being drawn into the stack which can create a
flashback situation (explosion within the stack). The purge moves up the stack and is burned by the
burners/pilots.
An elevation drawing and 3D (isometric) render of the proposed flare structure is shown in Figure 6.
Figure 1 Elevation Drawing of the proposed Flare Structure
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 53.1.1 PROPOSED LOCATION The location of the project is shown in Figures 1 and 2. The replacement flare will be constructed 5m north from the old flare. This is to minimize downtime by allowing most of the ground-works construction of the new flare whilst the old flare is still in operation. The new flare will be lifted only when the old flare is non- operational it is not possible to work above ground-level whilst the old flare is in operation. Figure 2 Location of the North Flare within the SAPREF Refinery SAPREF NORTH FLARE REPLACEMENT PROJECT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 6
3.1.2 PROPOSED FLARE STACK
FLARE STACK CONSTRUCTION
The following three flare stack constructions are typically considered for refinery flares:
1) Free-standing flares provide ideal structural support. However, for very high units the costs increase
rapidly. In addition, the foundation required and nature of the soil must be considered.
2) Derrick-supported flares can be built as high as required since the system load is spread over the
derrick structure. This design provides for differential expansion between the stack, piping, and derrick.
Derrick-supported flares are the most expensive design for a given flare height.
3) The guy-supported flare is the simplest of all the support methods. However, a considerable amount
of land is required since the guy wires are widely spread apart. A rule of thumb for space required to
erect a guy-supported flare is a circle on the ground with a radius equal to the height of the flare stack.
The current flare is a combination of derrick and guy wire supported constructions. The derrick construction
requires maintenance which is not possible to do while the flare is in active service, therefore SAPREF has
selected a guy supported flare construction for the new flare. Another advantages of the guy supported flare is
that it minimizes the requirement for new supporting structures.
FLARE STACK HEIGHT
The flame generated by the burning of vent gas emits heat which is mostly carried upward into the atmosphere
by convection. A smaller part of the heat is converted into radiation which is emitted into to the surroundings. In
order to ensure that workers and the public are not exposed to unsafe heat radiation levels the height of the flare
stack was designed based on Shell Standard DEP 80.45.10.10-Gen which specifies radiation limits applicable to
various receptors or locations. The relevant limits applicable to the design of the project included:
1) Property Limit: 3.15kW/m2 (1000 BTU) at the SAPREF property limit fence line where there is no
access control and therefore potential for non-continuous public exposure.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 72) Sterile Area: 6.30 kW/m2 at 38 metres (2000 BTU) in the controlled area at the base of the flare where
the maximum short-term exposure to radiant heat intensity is limited to 30 seconds. The corrugated
plate interceptor (CPI) [oil water separation facility] is also required to be outside of the sterile area.
Figure 3: Delineation of Radiation Sterile Area and Property Limits
In order to achieve the radiation limits at the sterile area radius and the property limit with the full design flare
gas flow height of the preferred option is to increase the height of the proposed flare to at least 77 m (17.7 m
higher than the existing flare height of 59.3m).
3.1.3 PROPOSED FLARE TIP
The current and proposed flare tip includes a gas seal that consists of baffles that prevents reverse (inward) flow
at the flare tip.
The current flare tip includes an external sparger for the injection of steam for cooling and to reduce smoke
emissions. The proposed flare tip will instead have an internal sparger which introduces steam into the
combustion zone resulting in better combustion resulting in improved smokeless flaring.
The steam flow through the sparger will be marginally increased and the control logic for steam flow will be
optimised for performance.
The current flare tip includes pilots which are ignited by a flame front generator (FFG). The FFG operates by
filling a combustion chamber and the lines connected it to the pilots with flammable mixture of methane rich
gas (MRG) / hereafter referred to as fuel gas) and instrument air. This is ignited by means a spark inside the
combustion chamber initiated at the discretion of an operator. This creates a flame front that travels to the pilots
where it ignites the fuel gas venting into the atmosphere.
The proposed flare tip includes an automated High Energy Ignition (HEI) ignition system which will be easier to
operate than the existing FFG system and will enable the flare to be operated more efficiently. A secondary FFG
ignition system will be installed as a safety measure in the event of the failure of the primary ignition system –
this is an additional safety measure to ensure that the flare is operational at all times when the refinery is
operational.
The current flare tip includes refractory which is a heat resistant liner material used in the flare to prevent heat
and chemical damage to the structure. Refractories are susceptible to various forms of mechanical damage
(cracking, spalling and erosion) which can be blasted off during an upset potentially causing damage to
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 8equipment or vehicles; therefore, the proposed flare tip will be designed without refractory which is according to
the latest international flare tip design standard and also eliminates any risks of damage to equipment/vehicles.
3.1.4 UTILITIES REQUIREMENTS
ELECTRICITY
The current and proposed flares both have a relatively low electricity requirement for lighting and for generating
sparks in the pilot ignition system. The electricity demand associated with the project is within the available
capacity of the refinery.
FUEL GAS
Fuel gas to the pilot burners will continue to be supplied at 1 barg from the existing local pressure regulators.
The fuel gas requirement of the current and proposed flares will increase slightly.
STEAM
The replacement flare will increase the steam requirement in order to ensure optimal cooling and smoke
reduction. Steam supply will be increased from c. 9.4 t/h. to c. 20t/h and will be generated within the existing
steam generation capacity of the refinery.
WATER
The current total water demand of the refinery is 8801t/day comprising reclaimed water (from the eThekwini
Southern Works water reclamation facility) and potable water from the municipal supply. The only water
requirement for the flare is linked to steam supply. Based on the steam additional requirement the increase to
current water consumption will be c. 0.02% which is considered marginal and not a significant water resource
efficiency issue.
EFFLUENT / WASTEWATER
No effluent is generated by the current or proposed flares.
CONSTRUCTION ACTIVITIES
The construction process will follow industry standard methods and techniques. Key activities associated with
the construction process are described in Table 3.
Table 3 Construction Activities
ACTIVITY DESCRIPTION
Contractor’s facilities and These will be strictly located within laydown areas inside the existing refinery premises.
materials lay-down areas Activities within these areas are likely to include:
— Temporary offices and administration facilities (e.g. containers, portable cabins).
— General materials storage and laydown areas.
— Construction of chemicals storage facilities (oil, grease, solvents etc.) and associated
infrastructure (bunds, secured / roofed areas etc.).
— Change-houses, chemical toilets and showering facilities (linked to conservancy
tanks – removal of contents by exhauster vehicle and disposal at permitted facility).
— Temporary waste storage areas; these shall be established and managed in
accordance with Environmental management Programme (EMPr) requirements.
Sourcing of construction — Where possible, equipment will be sourced locally based on the latest information on
materials and equipment South African Rand / US Dollar exchange rate. Equipment will be purchased outside
of South Africa where this makes commercial sense.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 9Pre-construction Survey — Locations for new flare base and guy wire anchor points (deadmen) will be surveyed
prior to construction to identify existing aboveground services.
— Slight changes in the location of infrastructure (micro-siting) may be required
however this will not materially change the environmental impact of the project.
Piling and Foundations — Removal of existing surfacing material (concrete, asphalt etc.) which could involve
excavation below ground level.
— Levelling and compaction using heavy machinery / earthmoving equipment – it is
noted that the topography within the refinery is flat, therefore no major cut/fill or
earth spoiling will be required.
— Potential for excavations and trenching in order to prepare foundations and laying of
below ground level equipment (cables, pipes, etc.).
— Use of a piling rig to drive piles into soil to provide foundation support at the flare
base as well as the anchor points (deadmen) for the guy wires.
— Concrete materials (aggregate, cement, steel etc.) will be sourced from existing
lawful commercial sources; there will be no direct mining, harvesting or extraction
of natural resources.
Flare Installation — Scaffolds will be erected to accommodate installation of new structures, supports,
piping and painting.
— The flare will be fully-assembled on the ground and then lifted into position with a
crane with the assistance of rigging teams.
— Piping run-ups (all above ground) to the flare will fabricated on site and installed.
Decommissioning of — Removal of the flare structure and associated piping, instrumentation, and electrical
equipment equipment.
— Specific methods of demolition are still to be defined by the contractor; typically this will
involve manual dismantling and the use trucks and cranes, generators, cutting and
welding equipment, compressors etc.
Working Hours — Due to the heavy industrial nature of the refinery, it is not envisaged that daytime
working hours would need to be adhered to; the exception would be in the case of
excessively noisy activities which would be limited to normal daytime working hours if
practical.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 104 ENVIRONMENTAL MANAGEMENT
PROGRAMME GOVERNANCE
ROLES AND RESPONSIBILITIES
Table 7 provides a high level outline of the various roles and responsibilities of SAPREF’s representatives and
the Contractor(s).
Table 4: Roles and Responsibilities
Designation Roles and Responsibility
SAPREF — Prepare EMP amendments / updates if required.
Environmental — Authorise environmental method statements.
Manager — Environmental awareness training.
— Stakeholder engagement.
— Maintain environmental incidents and stakeholder complaints register.
— Environmental incident management.
— Effect designated Management and Mitigation Actions detailed in the EMPr.
Independent — Undertake compliance audits against the EMPr and conditions of the EA.
Environmental — Provide support and advice to the project team, contractor and all subcontractors in the
Control Officer implementation of environmental management procedures and corrective actions.
(ECO) — Assess the efficacy of the EMPr and identify possible areas of improvement or amendment
required within the EMPr.
— Facilitate the amendment of the EMPr in conjunction with the Environmental Manager (as
required).
— Prepare audit reports (and submit reports to the relevant authority as required).
Contractors, Staff — Prepare Method Statements as per the EMPr
and Service — Regular on-site auditing to assess performance against the requirements of this EMPr.
Providers — Completion of the appropriate training requirements as specified in the training program.
— Implementation and maintenance of environmental management controls as set out in the
project’s environmental management documentation.
ENVIRONMENTAL AWARENESS PLAN
SAPREF has the responsibility to ensure that all persons involved in the project are aware of, and are familiar
with, the environmental requirements for the project. All project personnel, including contractors and sub-
contractors are required to receive training of a type and level of detail that is appropriate for the environmental
aspects of their work. As a minimum, all personnel are required to complete the training requirements stipulated
in Table 8.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 11Table 5: Training and Induction Requirements
Awareness Initiative Purpose Frequency
Site Induction The purpose of the induction is to ensure that, as a minimum, — Construction Phase: prior to
all on-site personnel understand the EMPr in terms of: commencement of work by
— Key issues relating to the project. staff and / or contractors.
— Relevant conditions of the EA. — Operational Phase: N/A
— Location and protection of environmentally sensitive
areas.
— Waste management and minimisation.
— Minimising potential impacts to air, noise and water
quality.
— Erosion and sediment control.
— Surface and groundwater contamination.
— Spill control measures.
— Environmental Emergency Plan.
— Incident reporting procedures.
— Best pollution prevention practices.
— Roles and responsibility relating to environmental
management.
Toolbox Talks Toolbox talks are intended to deliver specific training in an — Construction Phase: As
aspect of work or control including: required.
— Personal Protective Equipment (PPE) requirements.
— Waste handling procedures.
— Ad hoc training and awareness as required to promote
compliance with the EMPr.
Attendance records must be completed after each training session for the above and retained on site within the
Environmental File.
INCIDENT MANAGEMENT AND MITIGATION
Table 9 itemises the requirements for incident management and mitigation:
Table 6: Incident Management and Mitigation
Aspect Requirement
Reporting of Any environmental incident should be reported immediately to the SAPREF Environmental
Environmental Manager.
Incidents
— Immediate correspondence should be taken with the relevant staff members to determine
mitigation and close-out requirements.
— All significant incidents are to be reported to the relevant Authority as per the legal
requirements.
Contents of Environmental incident reporting and recording should include the following information:
Environmental
— Time, date and nature of the incident.
incident records
— Response and investigation undertaken.
— Actions taken and by whom.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 12Continual — Corrective and preventative action requests should be forwarded to the responsible person so
Improvement that corrective action can be taken. Open non-conformances should only be closed on
verification by the Project Manager that the corrective action has been implemented effectively
in order to meet the EMPr requirements.
— The cause of all incidents should be investigated to determine root cause and to ensure that
corrective action is able to be implemented to ensure that there is no repeat of the incident.
— A summary and review of incidents recorded during the maintenance activities should be
included within a report by the SAPREF Environmental Manager.
— If required following an incident, a review of the efficacy of the EMPr should be undertaken by
the SAPREF Environmental Manager in order to identify possible areas of improvement or
updating or amendment required within the EMPr.
STAKEHOLDER AND COMMUNITY ENQUIRIES AND
COMPLAINTS
Enquiries or complaints should be able to be received from adjacent land-users and / or the community (i.e.
stakeholders) through the following channels:
— Contact: Melanie Francis (Environmental Manager)
— Telephone number: +27 31 480 1911 (SAPREF Main Contact Number) or 0800 330 090
Community enquiries or complaints that are environmental in nature must be brought to the attention of the
SAPREF Environmental Manager who should ensure corrective action and close-out. As a minimum the following
information should be recorded:
— Time, date and nature of enquiry or complaint.
— The means by which the enquiry or complaints was made.
— Personal details of the person / party lodging the enquiry or complaint (subject to privacy considerations).
— Actions taken to investigate and close-out the complaint as well as complainant feedback.
All complaints received will be investigated and a response (even if pending further investigation) will be given
to the complainant within 7 days.
Any actions that cannot be managed immediately should be assigned to the appropriate personnel and will become
an outstanding action. The action remains outstanding until it is closed off by the Project Manager.
ENVIRONMENTAL PERFORMANCE MONITORING
The scope of environmental monitoring activities in this EMPr is limited to construction phase activities.
Environmental monitoring during the operational phase will be covered by the broader environmental
management system processes at SAPREF which include
4.5.1 INTERNAL MONITORING
During construction the SAPREF Environmental Manager is required to monitor the performance of the contractor
against the conditions of the EA and the EMPr. The frequency and scope of the internal monitoring is at the
discretion of the SAPREF Environmental Manager unless otherwise stated in the EA conditions.
4.5.2 EXTERNAL MONITORING (INDEPENDENT)
During construction external environmental audits of the EMPr must be undertaken by an independent
environmental consultant (Environmental Control Officer – ECO). The EA will determine the frequency of
external audits, however audits at a frequency of once a month are recommended.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 13In order to facilitate communication between the ECO, Project Manager / Environmental Manager and Contractor,
it is important that a suitable chain of command is structured that will ensure that the ECO’s recommendations
have the full backing of the SAPREF project team before being conveyed to the Contractor.
DOCUMENT CONTROL (ENVIRONMENTAL FILE)
During construction the Environmental Manager is responsible for ensuring that up to date documentation is kept
on-site; this should include, as a minimum, the following:
— Up to date copy of the EMPr;
— Approved Contractor Method Statements;
— Copies of other Contractor environmental information such as waste Safe Disposal Certificates
— Environmental Monitoring and inspection reports (internal and external);
— Environmental Incident Reports;
— Records of stakeholder and community complaints and follow-up actions taken; and
— Induction and training records.
— Material Safety Data Sheet (MSDS) and Safety Data Sheets (SDS)
EMPR REVISIONS
It is proposed that in the construction phase, revisions may only be made by the independent ECO. In the case of
amendments that materially change the project impacts, the amendments are to be submitted to the EDTEA for
approval.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 145 PROPOSED MITIGATION AND
MANAGEMENT MEASURES
CULTURAL HERITAGE RESOURCES
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objective:
— Protection of cultural heritage resources
BA Ref 6.2.1 a) Potential for a) If a heritage object is found, work in that area Contractor Construction
chance finds of cultural (the immediate area affecting the find) must
heritage resources be stopped immediately. A heritage find may
include archaeological materials, fossils, and
The project is being human remains. Should the contractor be
undertaken on an existing unsure of the any of the above aspects, the
industrial site. Previous SAPEF Environmental Manager should be
investigations have indicated contacted immediately.
that there are no cultural
heritage features present.
Whilst no impacts are b) In the event that items of potential heritage or SAPREF
anticipated, it is nevertheless archaeological importance are discovered, Environmental
possible that a resource may activities should be halted, AMAFA should Manager
be encountered during be notified immediately:
excavation activities, and - Contact details for Amafa aKwaZulu Natali
therefore a chance find are as follows:
management actions are
required. 195 Langalibalele Street Pietermaritzburg,
3201
Tel 033-3946543
c) The response of AMAFA must be followed, Dependent on
which may include a systematic and outcome of
professional investigation / removal of such engagement.
material.
SAPREF
Environmental
Manager to
remain informed.
ATMOSPHERIC EMISSIONS
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objective:
— To minimise potential fugitive emissions release associated with construction activities, materials transport etc.
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Project No. 41102753 January 2021
SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 15BA Ref 6.2.2 a) The a) Limit vehicle speeds on un-surfaced areas. Contractor Construction
construction phase of the
project will result in localised b) Avoid dust-generating activities (i.e. grading
dust emissions which could and moving of soil) during windy periods.
result in a nuisance factor to c) Cover and/or maintain appropriate freeboard
sensitive receptors if on trucks hauling any loose material that
unabated. could produce dust when travelling.
d) Re-vegetate or hard surface disturbed areas as
soon as possible to prevent excessive dust
from occurring.
e) Dampen exposed soil to suppress dust if
required. This will be undertaken by using
lignosulphonate and/or water where possible.
BA Ref 6.2.3 a) The AIR Worst case emergency scenario
shows that the potential for
short-term SO2 exceedances at a) Ensure project design mitigates risks to as low SAPREF Planning and
sensitive receptors during as reasonably practicable (ALARP). Design
flaring incidents at SAPREF.
b) Existing process safety management systems SAPREF Operation
However, these occur when to be continued in order to reduce the risk
combining a conservative
unplanned unit downtime and unit trips which
emission scenario with worst
lead to unplanned flaring events.
case meteorological
conditions which is very Planned refinery shutdown
improbable. It is more likely
than not that a planned c) Reduce the frequency of planned flaring
shutdown will occur during events by changing major shutdowns to a 4-
meteorological conditions that year cycle post 2022.
promote effective dispersion
and do not result in ambient
exceedances at sensitive
receptors.
Importantly, the proposed
increased height of the North
Flare decreases the likelihood
of exceedances at sensitive
receptors, due to increased
dispersion of emissions before
reaching ground level.
AMBIENT NOISE
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objective:
— To minimise environmental noise levels at the property fenceline and at potential off-site receptors.
BA Ref 6.2.4 a) Changes a) Maintain existing noise monitoring SAPREF Operation
in off-site ambient noise programme / obtain confirmatory Environmental
levels due to flare sound monitoring data regarding reduction in Manager
power levels (SPL) ambient noise levels during flaring events.
(operation)
b) Reduce the frequency of planned flaring
Screening sound level events by changing major shutdowns to a 4-
propagation calculations year cycle post 2022.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 16based on an SPL of 85dB(A) c) Reduced the frequency of unplanned events
at 1m indicate that the by operational monitoring and maintenance
proposed flare will have a of equipment to ensure reliability and reduce
unit upsets.
negligible have a negligible
contribution to cumulative
contributions at the refinery
boundary.
This will be an improvement
to the current situation where
flaring at SAPREF is a
significant contributor to off-
site noise levels.
HAZARDOUS SUBSTANCES AND ENVIRONMENTAL
CONTAMINANTS
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objectives:
— To manage any potentially contaminated seepage and stormwater from the site.
— To prevent occupational health and safety incidents.
— To ensure that soil and water resources are adequately protected.
BA Ref 6.2.5 a) Soil and General Management Contractor Construction
groundwater a) Provide and utilise drip trays for immobile
Contamination due to vehicles and machinery that will be
accidental spillage of operated on site.
small quantities b) Acquire spill kits to clean up any
hazardous substances hydrocarbon or chemical spills during
Construction activities closure to prevent seepage.
have the potential to c) Storage of hazardous materials if any,
generate stormwater should be undertaken within impermeable
contaminated with bunded, ventilated and covered storage
sediment, and oil and areas, capable of containing 110% of total
grease from machinery. volume.
Unless these pollutants are Spill and Incident Management
contained, there is
potential for localised d) Spill and response equipment must be
contamination of the soil. accessible on-site.
e) Suitable spill containment must be
provided for transfer points outside of
bunded areas.
f) Spillages / leaks are to be contained
immediately; deploy oil containment
berms if the spill migrates to other areas.
g) Cover the spill with absorbent material.
h) Remediation of the spill areas will be
undertaken to the satisfaction of the
Environmental Manager.
SAPREF NORTH FLARE REPLACEMENT PROJECT WSP
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 17i) Dispose of the clean-up material in line
with MSDS requirements of spilled
material.
j) Staff handling hazardous substances /
materials must be aware of the potential
impacts and follow appropriate safety
measures. Appropriate PPE must be made
available.
BA Ref 6.2.5 b) Soil and a) All excavated material must be considered Contractor Construction
Groundwater as ‘potentially hazardous waste’ whether
intended for backfilling/reuse on site or SAPREF
contamination associated
with the handling of spoiling off-site. Confirmatory sampling Environmental
potential latent must be undertaken and the results Manager to advise
analysed to obtain representative and oversee
subsurface
contamination determination of the presence of
contamination.
There is potential for the
identification of latent b) In the event that material is contaminated
(historical) subsurface it must be treated as hazardous waste and
contamination during classified in accordance with GN. R635
construction related (National Norms and Standards for the
excavations; however these Assessment of Waste for Landfill
will be very limited in Disposal). Specifically, the re-use and
nature. If not handled disposal of contaminated material on-site
correctly, it would have the is not permitted.
potential to cause
c) The above mitigation does not release
occupational health and
safety risks as well as SAPREF from compliance with the current
environmental impacts on legislation concerning the assessment and
soil, groundwater and remediation of contaminated land under
surface water. the National Environmental Management
Waste Act (2008).
WASTE MANAGEMENT
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objectives:
— To ensure waste generation is minimised (i.e. avoided, reduced, re-used and recycled) and / or disposed of responsibly.
— To ensure no direct or indirect environmental impacts as a result of waste management, handling or disposal.
— To ensure the safety of personnel involved in the handling of hazardous waste types.
BA Ref 6.2.6 a) Soil and a) Hazardous waste (including used oils and Contractor Construction
groundwater contamination material containing oils, solvents, empty
associated with waste chemical containers etc.) should be
generation and handling undertaken within impermeable bunded and
(construction) ventilated storage areas, capable of
containing 110% of total volume. All storage
The construction process is containers are to be labelled, sealed and
anticipated to generate stored in accordance with Material Safety
additional general and Data Sheet (MSDS) or Safety Data Sheet
hazardous waste streams. (SDS) requirements.
There is potential for b) Waste should be stored within waste skips
minor/localised within a designated area with consideration to
surface/groundwater and soil stormwater management.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 18contamination due to c) MSDS or SDS for all hazardous wastes must
inadequate waste handling. be available on site during construction and
operational phases.
d) Train and inform all onsite personnel
regarding general waste minimisation,
management and disposal. Ensure that no
waste is stored for more than 90 days onsite.
e) Prohibit littering and burning of waste onsite.
f) The contractor is required to implement
systems at the construction site for the
segregation of recyclable materials in order to
divert waste from landfill. As a minimum the
following waste streams are to be recycled:
- Metal (ferrous and non-ferrous)
- Paper and cardboard
- Used oil
- Non-contaminated recyclable plastic
g) Waste is only allowed to be removed from
site by a licensed waste service provider.
h) Safe disposal certificates for all waste
removed from site are to be obtained and
retained on file.
LIGHTING IMPACTS ASSOCIATED WITH FLARING
EVENTS
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objectives:
— To validate the absence of light pollution impacts during flaring events.
6.2.8 a) Light pollution a) Maintain existing complaints register as a SAPREF Operation
associated with increase grievance mechanism for identifying any Environmental
light emissions from the future light pollution issues. Manager
flare flame
b) Reduce the frequency of planned flaring
The potential for increase light events by changing major shutdowns to a 4-
emissions from the flare as a year cycle post 2022.
source of impacts has been
evaluated as low. In addition, c) Reduced the frequency of unplanned events
The suburban community and by operational monitoring and maintenance
of equipment to ensure reliability and reduce
industrial areas surrounding
the refinery are intrinsically unit upsets.
bright environments due to
existing artificial light sources
(street lights, mast lighting,
industrial lighting etc.) and are
therefore unlikely be sensitive
to changes in light levels
(albeit that significant changes
are not expected in the case of
the current project).
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 19The absence of community
complaints associated with
light pollution from the
refinery during the 2015 –
2020 (September) indicating
that this is not an existing
impact that could be
exacerbated by the project.
SOCIO-ECONOMICS
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objectives:
— Promote employment and training opportunities at a local level.
— Promote indirect benefits to local businesses.
BA Ref 5.2.13 a) Indirect Despite the positive character of the impact, the SAPREF Project Prior to appointment
employment opportunities following must be adopted by SAPREF: Manager with of Contractors
within contracting firms support from
in the construction phase a) Tender processes must include the SAPREF Human
prioritisation of local businesses Resources
The project will create contractors and labour throughout the
limited indirect
construction phase, where feasible.
employment opportunities
within contracting firms in b) All contractors will be obliged to use local
the construction phase. labour where possible.
These may lead to
improvement in the
financial income and
potential for improved
living standards of
employed individuals and
households.
5.7.1 TRAFFIC AND TRANSPORTATION
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objectives:
— To prevent congestion from occurring particularly during peak times; and safety risks to pedestrians.
— To prevent public access to construction sites and storage areas.
— To ensure safety for all onsite personnel.
BA Ref 5.1.1 Transportation a) All contractor drivers are required to hold Contractor Construction
Impacts valid licenses and be able to demonstrate
technical training for respective class of
Increased vehicular traffic
during construction is likely to vehicle. Validation of contractor
be associated only with the documentation and qualifications prior to
delivery of equipment and appointment.
removal of waste materials for
off-site disposal. The
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 20quantities of materials for the b) Equipment and materials to be transported to
project are relatively small; the refinery during off peak periods, where
loads will be intermittent, and practicable.
therefore no significant
increase road traffic is c) Ensure compliance with applicable road
anticipated. regulations and any permit issued in terms of
the National Road Traffic Regulations (2000).
There is no traffic or
transportation associated with d) The movement of vehicles into and out of the
the operational phase of the site must be managed to ensure the impact on
flare. public areas is minimised, such as ensuring
Notwithstanding the above, that abnormal loads are moved outside of peak
management actions are traffic hours, and reasonable measures are
proposed. taken to ensure that public and staff safety is
managed adequately.
5.7.2 CULTURAL HERITAGE
POTENTIAL ISSUES / RESPONSIBLE
IMPACTS MANAGEMENT ACTIONS PERSON TIMEFRAME
Objective:
— Ensure the identification and protection of any heritage or archaeological resources.
Excavations may result in a a) Ensure that employees and contractors are Project Manager Construction
possible disturbance and aware of requirements for heritage resource & Contractor
discovery of unknown protection and communicate any findings
heritage resources. immediately.
b) In the event that items of potential heritage or
archaeological importance are discovered,
activities should be halted, AMAFA should
be notified immediately:
- Contact details for Amafa aKwaZulu Natali
are as follows:
195 Langalibalele Street Pietermaritzburg,
3201
Tel 033-3946543
c) Any potential “chance finds” of heritage
objects must be logged in the site incident
register.
d) Should the contractor be unsure of the any of
the above aspects, the ECO should be
contacted immediately.
e) SAPREF must implement procedures as part SAPREF Project
of the EMS to ensure vehicles making use of Manger
the external road network are roadworthy and
that drivers hold a valid drivers licenced for
respective class of vehicle.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 21POST CONSTRUCTION AND POST CLOSURE
This EMPr relates to the proposed North Flare Replacement Project. Given the indeterminate, and likely long
term timeframe expected before the decommissioning phase, it is recommended that the requirements for the
decommissioning mitigation measures be developed by SAPREF as a separate / future initiative. It is noted that
the decommissioning of the Refinery in the future would likely require extensive environmental approval
procedures, which would include the requirement for an EMPr.
Notwithstanding the above, Table 9 outlines generic aspects and impacts have been proposed and are not
considered exhaustive. The onus remains with SAPREF (or appropriate responsible party to be confirmed with
the EDTEA) to prepare a revised decommissioning EMPr to be submitted prior to decommissioning.
Table 7: Decommissioning Phase
ASPECTPECT POTENTIAL ISSUES AND IMPACTS
Air Quality — Decommissioning phase activities may potentially generate dust from a number of
sources.
Noise — Noise can be generated from a variety of decommissioning sources, which could result
in the increase of the ambient noise levels at the fence-line.
Solid Waste — Waste generation from the decommissioning activities (e.g. concrete, scrap metal,
removed pipelines, waste building material, residual hydrocarbon / chemical material /
containers) may result in localised soil and / or stormwater contamination.
— Presence of potentially contaminated land and infrastructure requiring classification
and development of disposal requirements.
Traffic — Increased traffic due to removal of material from the site with associated impacts
Generation including inter alia additional traffic congestion, and safety impacts to port users.
Hazardous — Accidental spills resulting from removal / decommissioning of infrastructure may cause
Substances potential impacts to human and / or environmental health.
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SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 22APPENDIX A EAP CV
APPENDIX
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