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_________________________________________________________________________________________ MHI Risk Assessment Spin Street Bellville South May 10

96Figure 13.2

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97Table 13.3

Typical empirical overpressure effects

Overpressure (psi)

Predicted Damage

0.5 • Minor structural damage. • Shattered windows. • Occasional damage to window frames.

1 • Partial demolition of houses. • Houses made uninhabitable.

2 • Partial collapse of walls and roofs of houses. • Corrugated asbestos shattered. • Corrugated steel or aluminium panels’ fastenings fail. • Buckling of corrugated steel or aluminium panels. • Wooden panels fastenings fail. • Wooden panels blown in.

3 • Concrete or cinder block walls (not reinforced) shattered. • Steel frame buildings distorted. • Steel framed buildings pulled away from foundations.

4 • Frameless, self-framing steel panel building demolished. • Rupture of oil storage tanks.

5 • Wooden utility poles snapped. • Severe damage to buildings.

6 • Nearly complete destruction of houses.

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98A BLEVE scenario is analysed as follows: It was previously (risk assessment report of 3 October 2008) assumed that a BLEVE occurs on a stack of 200 drums of 210 litres each, i.e. the cumulative volume in the drums is 42 000 litres (31 500 kg). It was further assumed that all the containers are simultaneously exposed to a pool fire that would cause a combined BLEVE. After implementation of the required mitigation measures, the probability of a BLEVE in the solvent storage area is reduced to a negligible level.

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9913.3 Summary of safety distances The safety distances around the Ecoservices and LA Fuels plant, related to fires and explosions, are summarized in Table 13.5.

Table 13.5

Summary of safety distances

Potential Incident

Safety

Distance m

Affected full circle

segment surface area m2

Pool fire 16 805

Vapour cloud explosion 37 4 303

BLEVE heat radiation Negligible probability

-

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100Section 14

Concentration effect of toxic releases

______________________________________________________________________ 14.1 General discussion At the Ecoservices and LA Fuels chemical plant, the following main toxic vapours (xenobiotics) caused by solvent and industrial oil fires may be released:

• Carbon dioxide. • Carbon monoxide. • Carbon particulates (soot). • Sulphur dioxide.

Petroleum fires are always characterized by heavy smoke formation. Smoke, mainly on the form of carbon particulates (soot), is caused by the incomplete oxidation of the fuel during combustion. Finely divided carbon particulates are very active as adsorption agent, aggravated by the large reactive surface area of the carbon. Toxic molecular species are adsorbed onto the surface of the particulates and are carried in this manner into the lungs of victims. Carbon smoke accounts for a large majority of human impacts from fire incidents around the world [35]. In the Piper Alpha incident in 1988, probably the worst petroleum industry offshore life-loss incident, the majority of deaths were not caused by burns, drowning or explosion impacts, but by smoke and toxic gas inhalation. Of the total number of deaths, 83% were caused by smoke and gas inhalation. Combustion gases from hydrocarbon fires mainly comprise carbon monoxide, carbon dioxide, nitrogen oxides and sulphur dioxide. In the case of polyethylene combustion, acetaldehyde and short-chain alcohols (mainly methanol) are added to the list. In the case of nylon combustion, hydrogen cyanide is another critical combustion product. Smoke from hydrocarbon fires also consists of liquid or solid particles, usually less than one micron in diameter, suspended in the combustion gases. The main dangers of smoke are the presence of narcotic gases such as carbon monoxide, carbon dioxide and the asphyxiating effects of an oxygen depleted atmosphere caused by the combustion process that severely affects human respiration. Inhalation of these gases, individually or in combination, leads to hyperventilation, which in turn leads to increased inhalation of the gases as the breathing rate increases. Narcotic gases also cause incapacitation of the human body through an attack on the central nervous system. A low level of oxygen in the brain leads to psychological disorders, which cause impaired judgment and concentration. These effects may confuse, panic or incapacitate people. Carbon monoxide poisoning causes suffocation by blocking the transport of oxygen in the blood. Incapacity usually occurs within 10 minutes at a concentration of 0,2 % carbon monoxide, if heavy activity is being performed. Carbon monoxide kills because it combines with the hemoglobin in blood, which prevents oxygen from binding with the hemoglobin, necessary to sustain life. The gas has an affinity for hemoglobin 300 times that of oxygen. The degree of poisoning depends on the exposure time and the concentration of the gas in the breathed atmosphere. At a concentration of 70 to 80 % of carbon monoxide in the blood, death is likely to follow.

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101The inhalation of hot gases into the lungs will cause tissue damage to the effect that fatal effects could be the result within 6 to 24 hours of exposure. An equally serious, yet subtler, psychological effect is the induction of panic and disorientation. When it occurs, the movement of people to achieve evacuation objectives will be seriously inhibited. In addition, the smoke will hinder fire fighting and rescue operations. The traveling of smoke and toxic gases is affected by the vertical rise of the combustion products, its horizontal spread, the rate of combustion and atmospheric air movements. Hot combustion products will generally rise upwards because they are lighter in weight than the surrounding air. The products will spread out when encountering objects such as a ceiling or structural obstacles. They will readily penetrate every available opening, such as cracks, crevices and channels. Coagulation of smoke particles occurs when molecular species gather in large groups to precipitate out of the air. This is usually a continuous process, due to the mutual attraction of particles.

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102Combustion analysis for solvents (approximated by toluene) C7H8 + 3.5O2 CO + CO2 + 5C + 4H2O

C7H8 CO CO2 C

92 g/mole 28 g/mole 44 g/mole 12 g/mole 1 mole 1 mole 1 moles 5 mole 92 g 28 g 44 g 60 g

0,092 kg 0,028 kg 0,044 kg 0,060kg 1 kg 0,3 kg 0,5 kg 0,7 kg

Estimated sulphur content of solvent or oil: 10 ppm

S8 + 8O2 8SO2

S8 SO2

256 g/mole 64 g/mole 1 mole 8 moles 256 g 512 g

0,256 kg 0,512 kg 1 kg 2 kg

0,00001 kg 0,00002 kg

1 kg of burning solvent or oil contains about 0, 00001 kg sulphur, which would yield about 0, 00002 kg of sulphur dioxide.

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103Combustion analysis for industrial oil (approximated by diesel) 2C18H38 + 51O2 2CO + 32CO2 + 2C + 38H2O

C18H38 CO CO2 C

254 g/mole 28 g/mole 44 g/mole 12 g/mole 2 moles 2 moles 32 moles 2 moles 508 g 56 g 1 408 g 24 g

0,508 kg 0,056 kg 1,408 kg 0,024 kg 1 kg 0,110 kg 2,772 kg 0,047 kg

Estimated sulphur content of industrial oil: 100 ppm

S8 + 8O2 8SO2

S8 SO2

256 g/mole 64 g/mole 1 mole 8 moles 256 g 512 g

0,256 kg 0,512 kg 1 kg 2 kg

0,0001 kg 0,0002 kg

1 kg of burning industrial oil would contain about 0,0001 kg sulphur, which would yield about 0,0002 kg of sulphur dioxide. As a worst case scenario, the size of the solvent or oil pool is 133 m2. Combustion rate of solvents or industrial oil: 0, 04 kg/m2/s Therefore, combustion rate of solvents or industrial oil in case of a leak and resultant pool fire: 5.3 kg/s

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104Table 14.1

Combustion product formation rates

Molecular Species Formation rate Kg/s

Carbon monoxide from solvent fire 1.6

Carbon monoxide from oil fire 0.6

Carbon dioxide from solvent fire 2.7

Carbon dioxide from oil fire 14.7

Carbon from solvent fire 3.7

Carbon from oil fire 0.3

Sulphur dioxide from solvent fire 0,0001

Sulphur dioxide from oil fire 0,001

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105Table 14.2

ALOHA toxic gas dispersion modelling results

1. Carbon monoxide from a solvent fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON MONOXIDE Molecular Weight: 28.01 g/mol ERPG-1: 200 ppm ERPG-2: 350 ppm ERPG-3: 500 ppm IDLH: 1200 ppm LEL: 125000 ppm UEL: 740000 ppm Ambient Boiling Point: -191.7° C Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 1.6 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 96 kilograms/min Total Amount Released: 5,760 kilograms Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behaviour. THREAT ZONE: Model Run: Gaussian Red : 119 meters --- (500 ppm = ERPG-3) Orange: 143 meters --- (350 ppm = ERPG-2) Yellow: 190 meters --- (200 ppm = ERPG-1)

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1062. Carbon monoxide from an oil fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON MONOXIDE Molecular Weight: 28.01 g/mol ERPG-1: 200 ppm ERPG-2: 350 ppm ERPG-3: 500 ppm IDLH: 1200 ppm LEL: 125000 ppm UEL: 740000 ppm Ambient Boiling Point: -191.7° C Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 0.6 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 36 kilograms/min Total Amount Released: 2,160 kilograms Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behaviour. THREAT ZONE: Model Run: Gaussian Red : 73 meters --- (500 ppm = ERPG-3) Orange: 87 meters --- (350 ppm = ERPG-2) Yellow: 116 meters --- (200 ppm = ERPG-1)

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1073. Carbon dioxide from a solvent fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON DIOXIDE Molecular Weight: 44.01 g/mol ERPG-1: 30000 ppm ERPG-2: 30000 ppm ERPG-3: 40000 ppm IDLH: 40000 ppm Normal Boiling Point: -unavail- Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% Note: Not enough chemical data to use Heavy Gas option ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 2.7 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 162 kilograms/min Total Amount Released: 9,720 kilograms THREAT ZONE: Model Run: Gaussian Red : 14 meters --- (40000 ppm = ERPG-3) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Orange: 16 meters --- (30000 ppm = ERPG-2) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 16 meters --- (30000 ppm = ERPG-1) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances.

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1084. Carbon dioxide from an oil fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON DIOXIDE Molecular Weight: 44.01 g/mol ERPG-1: 30000 ppm ERPG-2: 30000 ppm ERPG-3: 40000 ppm IDLH: 40000 ppm Normal Boiling Point: -unavail- Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% Note: Not enough chemical data to use Heavy Gas option ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 14.7 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 882 kilograms/min Total Amount Released: 52,920 kilograms THREAT ZONE: Model Run: Gaussian Red : 32 meters --- (40000 ppm = ERPG-3) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Orange: 37 meters --- (30000 ppm = ERPG-2) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 37 meters --- (30000 ppm = ERPG-1) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances.

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1095. Carbon particulates from a solvent fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON Molecular Weight: 12.00 g/mol ERPG-1: 200 ppm ERPG-2: 350 ppm ERPG-3: 500 ppm Normal Boiling Point: -unavail- Note: Not enough chemical data to use Heavy Gas option ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 3.7 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 222 kilograms/min Total Amount Released: 13,320 kilograms THREAT ZONE: Model Run: Gaussian Red : 282 meters --- (500 ppm = ERPG-3) Orange: 338 meters --- (350 ppm = ERPG-2) Yellow: 453 meters --- (200 ppm = ERPG-1)

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1106. Carbon particulates from an oil fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: CARBON Molecular Weight: 12.00 g/mol ERPG-1: 200 ppm ERPG-2: 350 ppm ERPG-3: 500 ppm Normal Boiling Point: -unavail- Note: Not enough chemical data to use Heavy Gas option ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 0.3 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 18 kilograms/min Total Amount Released: 1,080 kilograms THREAT ZONE: Model Run: Gaussian Red : 78 meters --- (500 ppm = ERPG-3) Orange: 94 meters --- (350 ppm = ERPG-2) Yellow: 125 meters --- (200 ppm = ERPG-1)

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1117. Sulphur dioxide from a solvent fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: SULFUR DIOXIDE Molecular Weight: 64.06 g/mol ERPG-1: 0.3 ppm ERPG-2: 3 ppm ERPG-3: 15 ppm IDLH: 100 ppm Carcinogenic risk - see CAMEO Ambient Boiling Point: -10.3° C Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 0.0001 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 6 grams/min Total Amount Released: 360 grams Note: This chemical may flash boil and/or result in two phase flow. THREAT ZONE: Model Run: Gaussian Red : less than 10 meters(10.9 yards) --- (15 ppm = ERPG-3) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Orange: less than 10 meters(10.9 yards) --- (3 ppm = ERPG-2) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 25 meters --- (0.3 ppm = ERPG-1) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances.

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1128. Sulphur dioxide from an oil fire SITE DATA: Location: BELLVILLE, SOUTH AFRICA Building Air Exchanges Per Hour: 0.50 (enclosed office) CHEMICAL DATA: Chemical Name: SULFUR DIOXIDE Molecular Weight: 64.06 g/mol ERPG-1: 0.3 ppm ERPG-2: 3 ppm ERPG-3: 15 ppm IDLH: 100 ppm Carcinogenic risk - see CAMEO Ambient Boiling Point: -10.3° C Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 5.7 meters/second from S at 3 meters Ground Roughness: urban or forest Cloud Cover: 5 tenths Air Temperature: 25° C Stability Class: D No Inversion Height Relative Humidity: 50% SOURCE STRENGTH: Direct Source: 0.001 kilograms/sec Source Height: 0 Release Duration: 60 minutes Release Rate: 60 grams/min Total Amount Released: 3.60 kilograms Note: This chemical may flash boil and/or result in two phase flow. THREAT ZONE: Model Run: Gaussian Red : 11 meters --- (15 ppm = ERPG-3) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Orange: 25 meters --- (3 ppm = ERPG-2) Note: Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 80 meters --- (0.3 ppm = ERPG-1)

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113Table 14.3

Summary of safety distances for toxic gas releases during combustion

Molecular Species

Formation rate

Kg/s

Safety distance

m

Affected 1/3

circle segment surface area

m2 Carbon monoxide from solvent fire

1.6 119 14 835

Carbon monoxide from oil fire

0.6 73 5 583

Carbon dioxide from solvent fire

2.7 14 205

Carbon dioxide from oil fire 14.7 32 1 073

Carbon from solvent fire 3.7 282 83 311

Carbon from oil fire 0.3 78 6 374

Sulphur dioxide from solvent fire

0,0001 10 105

Sulphur dioxide from oil fire 0,001 11 127

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114Section 15

Potential effect of an incident on adjacent major hazard installations

______________________________________________________________________ 15.1 Identification of other facilities and installations around the chemical plant Two other facilities have been identified in close proximity of the Ecoservices and LA Fuels plant, as follows:

Facility

Distance from Ecoservices and LA Fuels plant, m

Easigas LPG depot (an existing MHI) 65

Western Cape Milling (MHI status unknown) 15

15.2 Effect on surrounding installations and facilities The identified industries and commercial enterprises will be affected mainly in the following ways by a major incident at the chemical plant: • Heat radiation exposure during a fire caused by solvents or industrial oil. • A boiling liquid expanding vapour explosion on the solvent and industrial oil containers. • A vapour cloud explosion caused by accumulation and ignition of light-fraction solvent vapour

fractions. • Release of toxic gases during combustion of solvents or industrial oil. 15.3 Easigas Easigas operates a liquefied petroleum gas (LPG) depot in Spin Street opposite the Ecoservices and LA Fuels plant, about 65 meters away. The Easigas depot could be at risk as follows: • Pool fire at Ecoservices and LA Fuels, with a safety distance of 16 meters. • Vapour cloud explosion, with a safety distance of 37 meters. 15.4 Western Cape Milling The maize mill of Western Cape Milling that is located next to Ecoservices and LA Fuels poses a risk to the chemical plant. Open-air dust fires and explosions are fairly common throughout the world [7; 17/252] with a high frequency of occurrence as shown in Table 15.1.

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115Table 15.1

Occurrence of dust cloud fires and explosions

Dust fires

Period

Number of fires

Human impacts

Injuries

Frequency (per year)

Period between

successive fires

1979-1988

159

-

36

20

18

Dust explosions

Period

Number of explosions

Human impacts

Injuries

Frequency (per year)

Days between

successive explosions

1900-1959

1 110

648

-

19

19

1958-1967

247

9

324

28

13

1962-1979

474

25

633

28

13

1979-1988

136

-

41

16

22

An alarming figure is the very short historical period between successive incidents, namely 18 days for dust fires and 13 to 22 days for dust explosions. The minimum concentration of dust in air to be able to initiate an explosion if ignited (lower flammability limit) lies between 20 and 60 gram/m3 [7]. The upper explosive limit is documented as 2 000 to 6 000 g/m3. The explosivity range is therefore very wide, which increases the risk. The explosivity of the maize dust at Western Cape Milling depends mainly on the particle size and moisture content. The smaller the particle size, the higher the explosions risk. The higher the moisture content, the higher the explosions risk. Grain storage facilities are liable to serious dust explosions. A grain dust explosion in 1977 in Louisiana killed 35 people and was classified on the same scale as that of Flixborough in 1974 (cyclohexane vapour cloud explosion with an estimated overpressure of 10 psi). The effect of maize dust cloud explosions will vary, depending on the mass of maize product dust present within the explosion limits. The overpressure effects of dust cloud explosions are remarkably high. Palmer [7; 17/261] reported a maximum explosion pressure of 109 psi for wheat flour.

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116Some approximate damage estimates for common structures based on overpressure are given in Table 15.2. [1; P163]

Table 15.2 Overpressure,

psi

Estimated Damage

0.1 Breakage of small windows under strain.

1 Partial demolition of houses. Houses made uninhabitable.

2 Corrugated asbestos shattered. Corrugated steel or aluminium panels fastenings fail, followed by buckling. Wood panels in standard housing fail and panels blown in. Partial collapse of walls and roofs of houses.

3 Concrete or cinder block walls, not reinforced, shattered. Steel frame buildings distorted and pulled away from foundations.

4 Frameless, self-framing steel panel buildings demolished. Rupture of oil storage tanks. Cladding of light industrial buildings ruptured.

5 Wooden utility poles snap. Tall hydraulic press (18 000 kg) in building slightly damaged.

6 Nearly complete destruction of houses.

7 Loaded train wagons overturned.

8 Brick panels, 8-12 inches thick, not reinforced, fail by shearing or flexure.

9 Loaded train boxcars completely demolished.

10 Probable total destruction of buildings. Heavy machine tools (3 100 kg) moved and badly damaged.

300 Limit of crater lip.

The safety distance in case of a maize dust explosion was estimated by using the TNT equivalency model [1; P160, 174, cross reference 2.20] to determine the relation between overpressure and safety distance. A mass of 10 kg TNT was used in the simulation. Results are shown in Figure 15. 1.

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117Figure 15.1

An overpressure of 1 psi would be reached within a radius of 48 meters. The Ecoservices and LA Fuels plant is located 15 meters away from Western Cape Milling. From Figure 15.1 it is concluded that overpressure caused by a maize cloud explosion could reach values of 5 to 10 psi. The effect of such overpressure on the Ecoservices and LA Fuels plant could be as follows: • Breakage of small windows under strain. • Partial demolition of houses. • Houses made uninhabitable. • Corrugated asbestos shattered. • Corrugated steel or aluminium panels fastenings fail, followed by buckling. • Wood panels in standard housing fail and panels blown in. • Partial collapse of walls and roofs of houses. • Concrete or cinder block walls, not reinforced, shattered. • Steel frame buildings distorted and pulled away from foundations. • Frameless, self-framing steel panel buildings demolished. • Rupture of oil storage tanks. • Cladding of light industrial buildings ruptured. • Wooden utility poles snap. • Tall hydraulic press (18 000 kg) in building slightly damaged. • Nearly complete destruction of houses. • Loaded train wagons overturned. • Brick panels, 8-12 inches thick, not reinforced, fail by shearing or flexure. • Loaded train boxcars completely demolished. • Probable total destruction of buildings. • Heavy machine tools (3 100 kg) moved and badly damaged.

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118Section 16

Potential effect of a major incident on other installations

______________________________________________________________________ 16.1 Identification of other installations on site The following other installations are located around the Ecoservices and LA Fuels plant:

Facility

Distance from Ecoservices and LA Fuels Plant, m

Ecoservices and LA Fuels - Inde Plastics 25 Connoisseur Mouldings (to let) 45 Dricor Furniture 75 Pinclip metal works 85 Pinclip metal works 145 Waste yard (for sale) 70 UTI warehouse 15 Storage yard 105

16.2 Effect on other installations The above installations/facilities would experience the following effects from potential major incidents at Ecoservices and LA Fuels: • Long-term heat radiation exposure from a pool fire. • Overpressure due to a vapour cloud explosion. • Exposure to toxic gas releases from combustion products.

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119Section 17

Potential effect of a major incident on members of the public and residential areas

______________________________________________________________________ 17.1 Current development around the proposed chemical plant Facilities located near the chemical plant and which are populated by humans, are listed as follows:

Facility

Distance from Ecoservices and LA Fuels Plant, m

Ecoservices and LA Fuels - Inde Plastics 25 Connoisseur Mouldings (to let) 45 Dricor Furniture 75 Pinclip metal works 85 Pinclip metal works 145 Waste yard (for sale) 70 UTI warehouse 15 Storage yard 105 Easigas 65 Western cape Milling 15

This risk assessment is based on the present development status around the proposed chemical plant site (September 2008). 17.2 Population density around the chemical plant The estimated average population density around the chemical plant varies between 794 and 2 906 persons per km2. This equates to between 0.0008 and 0.003 persons per m2 or between 333 and 1 250 m2 per person. The chemical plant site is located in an active business and industrial area of Bellville South and a population density figure of 2 906 persons per km2 is assumed for the site.

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120Figure 17.1

Population density in Bellville South area

Estimated average population density: 2 906 persons per km2 (0.003 persons per m2). 17.3 Anticipated future development

Future development plans around the chemical plant is not known at this stage. Prospective developers around the site will have to take the locality of the hazardous chemical plant into consideration.

Bellville South 2 906 persons per

square km

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121Section 18

Meteorological tendencies

______________________________________________________________________ 18.1 Lightning Lightning can be a trigger to serious plant disasters, for example when a strike hits vulnerable parts of the plant where flammable or explosive materials are stored. The incidence of lightning in the Bellville area was investigated [30] and is shown in Figure 18.1. In the Cape Peninsula thunder is heard about 12 times per year, compared with 50 to 60 times per year for Johannesburg, 11 times per year for the most of Europe and 150 times per year for central Africa. Thunderstorms are common in South Africa and typical for the northeastern summer rainfall regions. The in incidence of lightning in the Bellville area, where the Ecoservices and LA Fuels plant is located, is less than 1 strike per square kilometre (106 m2) per year. The plant surface area amounts to 31 200 m2, which implies that the incidence of lightning at the plant area is about 0.03 per year. In other words, one strike is likely to occur at the site in 33 years. It is unlikely that lightning could be the cause of a major incident at the plant. However, it is recommended that all parts of the plant be inspected to ensure that adequate vertical spikes with earth linkages are installed on vulnerable plant components, such as the distillation units for solvents, boiler, heating units for industrial oil and fixed product storage tanks.

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122Figure 18.1

Number of lightning strikes per square kilometre per year in South Africa

Ecoservices and LA Fuels Bellville site area

0 – 1 lightning strikes per km2 per year

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12318.2 Wind direction Wind roses for Cape Town International Airport [31] were used to analyse wind patterns at the Ecoservices and LA Fuels plant for the months of January, April, July and October. Data covered a period of 14 years up to 2002. The dominant wind direction data is given in Table 18.1 and the results are shown graphically in Figures 18.2 to 18.5. In summary, the dominant wind directions at the sans Fibres plant are as follows:

January (Summer): 55% direction SSE, S and SSW (1580 to 2030) April (autumn): 34% direction SSE, S and SSW (1580 to 2030) July (winter): 44% NW, NNW, N, NNE, NE (3380 to 450) October (spring): 53% SW, SSW, S, SSE, SE (1350 to 2250)

The dominant wind direction data for the Ecoservices and LA Fuels site is summarized in Figure 18.6 and Figure 18.7 for summer (January), autumn (April), winter (July) and spring (October).

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124Table 18.1

Wind directions for Cape Town International Airport

Month

Average wind

speed (m/s)

Wind speed

frequency (%)

Dominant

Wind Direction

Frequency

(%)

Cumulative wind

direction frequency

(%)

January (Summer)

6,5

84

16% calm

SE 3

67 SSE 14

S 29 SSW 13 SW 8

Calm (<0.5 m/s)

16

April (Autumn)

4,8

71

29% calm

SE 4

47 SSE 10

S 13 SSW 11 SW 7

WSW 2 Calm (<0.5

m/s) 29

July (Winter)

5,0

66

34 % calm

NW 7

41 NNW 11

N 9 NNE 8 NE 6

Calm (<0.5 m/s)

34

October (Spring)

6,5

79

21% calm

SE 6

51 SSE 12

S 19 SSW 9 SW 5

Calm (<0.5 m/s)

21

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125Figure 18.2

Wind pattern for Cape Town International Airport

Month of January

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126Figure 18.3


Month of April

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127Figure 18.4


Month of July

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128Figure 18.5

Wind pattern at Cape Town International Airport

Month of October

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129Figure 18.6

Average diurnal variation of wind direction for Cape Town International Airport during

January (summer) and July (winter) [31]

Note: Degrees indicate the direction from where the wind blows

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130Figure 18.7

Dominant wind directions at Ecoservices and LA Fuels in Bellville

Autumn

Frequency 47%

Summer

Frequency 67%

Spring

Frequency 51%

Winter Frequency 41%

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13118.3 Wind speed The average wind speed at Cape Town International Airport for the four quarters of the year is as follows: January (summer): 84% at 6,5 m/s; 16% calm conditions. April (autumn): 71% at 4,8 m/s; 29% calm conditions. July (winter): 66% at 5,0 m/s; 34% calm conditions. October (spring): 79% at 6,5 m/s; 21% calm conditions. These values are summarized in Table 18.1. The average monthly variation in wind speed is given in Figure 18.8. The variation in wind speed as a function of the hour of the day is shown in Figure 18.9. To enable modelling of toxic gas releases, an average wind speed of 5.7 m/s was estimated for the Ecoservices and LA Fuels site.

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132Figure 18.8

Average monthly variation in wind speed at Cape Town International Airport [31]

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133Figure 18.9

Wind speed variation as a function of the hour of the day for the Ecoservices and LA Fuels

site [31]

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13418.4 Surface temperature The surface temperature (in degrees Celsius) at Cape Town International Airport varies as follows: January (summer): Minimum 15 Maximum 26 April (autumn): Minimum 12 Maximum 23 July (winter): Minimum 7 Maximum 17 October (summer): Minimum 11 Maximum 21 Refer to Figure 18.10

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135Figure 18.10

Average daily temperature fluctuations for Cape Town International Airport [33]

Based on SA Weather Services data over 31 years

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13618.5 Cloud cover The percentage cloud cover for the Bellville South area is shown on a monthly basis in Figure 18.11. The cloud cover varies as follows: January (summer): 30% April (autumn): 39% July (winter): 48% October (spring): 50% The difference between the cloud cover at 08:00 and 14:00 is less than 10% as shown in Figure 18.12.

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137Figure 18.11

Average monthly percentage cloud cover for Bellville [32]

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138Figure 18.12

Average annual percentage cloud cover for Bellville [32]

Day

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13918.6 Rainfall Rainfall in the Bellville South area varies as follows: January (summer): 14 April (autumn): 37 July (winter): 70 October (spring): 38 The rainfall pattern for the Ecoservices and LA Fuels site is shown in Figure 18.13. Typical of a winter rainfall region, the plant area experiences its heaviest rainfall during the period May to August. During this period, the transmissivity of the air will be lowest for heat radiation flux caused by fires.

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140Figure 18.13

Average monthly rainfall for Cape Town International Airport [33]

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14118.7 Atmospheric stability classification The stability conditions of the atmosphere play an important role when toxic cloud dispersion patterns are evaluated. The Pasquill atmospheric stability classification system [18; 32] was used in this risk assessment. The various stability classes are explained in Table 18.2. The dominant parameters that determine atmospheric stability are wind speed, cloud cover and time of day. A boundary layer exists in the atmosphere and consists of the first few hundred meters above the surface of the earth. This layer is affected by the retardation of airflow due to frictional drag of the surface of the earth as well as heat and moisture exchanges that take place at the surface. During the day the atmospheric boundary layer is characterized by thermal turbulence caused by heating of the earth’s surface. During the night weak vertical mixing occurs and a stable layer is common. This condition is usually associated with low wind speeds with little potential for dilution of xenobiotic molecular species. The release of atmospheric emissions will result in maximum concentrations at ground level during low wind speeds and stable atmospheric conditions (Pasquill class E to F), typically experienced during the night. The variation of wind speed as a function of the hour of the day at Cape Town International Airport, as shown in Figure 18.9, indicates that the wind speed is usually lowest between 20:00 and 08:00 (night time). Taking all the above factors into consideration, the dominant atmospheric classification for the Ecoservices and LA Fuels site is as follows: During the day During the night

January (summer): Class D Class D April (autumn): Class B-C Class E July (winter): Class C-D Class E October (spring): Class D Class D

For the purpose of mathematical modelling of the dispersion effects of toxic releases from the factory site, atmospheric classification D was considered to be the dominant condition for day and night. This also represents a worst case scenario where little dilution of xenobiotic molecular species will occur.

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142Table 18.2

Pasquill atmospheric stability classification system

Surface

wind speed in m/s

Daytime conditions

Night time conditions

Strong sunlight

Cloudiness <10%

Moderate sunlight

Cloudiness <50%

Slight sunlight

Cloudiness >50%

Cloudiness >50% **

Cloudiness <50% **

<2 A A-B B - - 2-3 A-B B C E F 3-5 B B-C C D E 5-6 C C-D D D D >6 C D D D D

A Extremely unstable conditions (calm wind, clear sky, hot daytime) B Moderately unstable conditions (clear sky, daytime) C Slightly unstable conditions (moderate wind, slightly overcast, daytime) D Neutral conditions * (high winds, cloudy, day or night) E Slightly stable conditions (moderate wind, slightly overcast, nighttime) F Moderately stable conditions (low winds, clear sky, cold, nighttime)

* Applicable to heavy overcast conditions, day or night ** Degree of cloudiness: Fraction of sky above the horizon covered by clouds

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143Section 19

Suitability of existing emergency management plan for the identified risks

______________________________________________________________________ 19.1 Evaluation of the existing emergency plan

A General Requirements

Evaluation Finding

• Various categories of emergency situations must be defined.

• Defined

• The Plan must consider all potential natural or man-made emergencies that copuld disrupt the operation of the MHI facility.

• Not considered.

• The Plan must consider all potential internal sources of emergencies that could disrupt the operation of the MHI facility.

• Not considered.

• The Plan must consider the impact of all internal and external emergencies on the operation of the MHI facility.

• Not considered.

• Response actions must be tailored to the specific MHI facility.

• Not tailored.

• The Plan must contain a list of key personnel with their responsibilities and contact information.

• Not contained.

• The Plan must contain a list of local emergency responders with their contact information.

• Not contained.

• The Plan must contain the names, titles, departments and contact numbers of individuals who can be contacted for additional information or an explanation of duties and responsibilities applicable to the Plan.

• Not contained.

• The Plan must outline how rescue operations will be performed.

• Outlined.

• The Plan must outline how medical assistance will be provided.

• Outlined.

• The Plan must state how and where personal information on employees can be obtained in an emergency.

• Not stated.

• The Plan must state how affected members of the public will be contacted, who the contact persons are and their contact numbers.

• Not stated.

• The Plan must make provision for all the factors that could lead to a major incident on the chemical plant, including:

o Restraint in the chemical plant piping system. o Mechanical damage. o Material failure. o Equipment failure. o Thermal fatigue. o Hydraulic hammer. o Wrong operating procedures. o Human error.

• No provision is made.

B Evacuation Procedure

Evaluation Finding

• The Plan must identify the conditions under which an evacuation of people would be necessary.

• Not clearly identified.

• The procedure must make provision for the evacuation of employees on site as well as affected members of the public.

• Provision is made.

• The Plan must outline a clear chain of command and designate a specific person with a standby authorized to order an evacuation or operational shutdown.

• Specific persons are not designated.

• The Plan must address the types of actions expected from different employees for the various categories of emergencies.

• Addressed, but no names are allocated.

• The Plan must identify who will stay behind to shut down critical operations during an evacuation.

• Not identified.

• The Plan must show specific evacuation routes for employees and these • Not shown.

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144must be posted at the MHI facility where they are easily accessible to all employees.

• The Plan must show specific evacuation routes for members of the public

and these must be easily accessible to the public.

• Not shown.

• The Plan must prescribe procedures for assisting people during an evacuation, people with disabilities or those who cannot speak English or read.

• Not described.

• The Plan must show one or more assembly areas where employees will gather.

• Not shown.

• The Plan must include a method of accounting for all employees.

• Not included.

• The Plan must explain how visitors will be assisted and accounted for during an evacuation.

• Not explained how they will be accounted for.

• Dominant meteorological conditions along the chemical plant route must be taken into consideration, especially wind direction and speed.

• Not taken into consideration.

C Reporting of an Emergency Condition

Evaluation Finding

• The Plan must outline the method of reporting fires and other emergencies to the local emergency services.

• Not outlined.

• The Plan must outline the method of alerting employees, including disabled employees, to evacuate from the MHI site or to take other action.

• Not outlined clearly.

D Employee Training and Drills

Evaluation Finding

• The Plan must state how and when employees will be trained with regard to the types of emergencies that may occur, their responsibilities and the actions that they must take.

• Not stated.

• The Plan must state how and when retraining of employees will take place.

• Not stated.

• The Plan must state how often drills will take place. These drills must involve all employees at the MHI site as well as affected members of the public.

• Not stated.

E Management of the News Media

Evaluation Finding

• The Plan must indicate the person whose responsibility it will be to provide information about the emergency to the news media.

• Not indicated.

• The Plan must state clear channels for the approval of media releases to journalists.

• Not stated.

19.2 Recommended emergency actions on site It is recommended that the following emergency actions be included in the emergency plan of Ecoservices and LA Fuels:

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145

POTENTIAL HAZARDS

Fire or Explosion • Materials on site must be considered flammable to highly flammable. • Ignition may occur by heat, sparks or open flames. • Vapour may form explosive mixtures with air. • Vapour may travel to a source of ignition and flash back. • Most vapours are heavier than air. It will spread along the ground and collect in low or confined areas such as sewers, tanks,

bund walls and storm water drains. • Explosion of vapours is possible indoors as well as outdoors in sewers and drains. • Liquid run-off into a sewer may create a fire hazard. • Containers may explode when heated (BLEVE). • Liquids are lighter than water. • Substances are stored and transported hot.

Health • Inhalation of hot vapours must be avoided. • Inhalation of TOXIC gases must be avoided. • Contact with materials may irritate or burn skin or eyes. • Fire may produce irritating, corrosive and toxic gases. • Vapours may cause dizziness or suffocation. • Runoff from fire control or dilution water may cause pollution of the environment.

WORKER AND PUBLIC SAFETY

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146

Protective clothing • Wear positive pressure self-contained breathing apparatus (SCBA). • Structural fire-fighters’ protective clothing will provide limited protection.

Evacuation

• Call the emergency services immediately. • If there is no fire hazard, isolate spills or leaks for at least 50 meters in all directions. • Keep unauthorized persons away. • Stay upwind. • Keep out of low-lying areas. • Ventilate closed spaces before entering. • For large spills, consider initial downwind evacuation for at least 300 meters. • If a tank is involved in a fire, isolate the area for at least 800 meters in all directions and evacuate for at least 800 meters in all

directions.

EMERGENCY RESPONSE

Fire

• The use of water spray may be inefficient. • For small fires, use dry chemical, CO2, water or regular foam. • For large fires, use water spray, fog or regular foam, but not straight streams. • Move containers from the fire area if it can be done without risk.

For tank fires:

• Fight fire from maximum distance or use unmanned hose holders or monitor nozzles. • Cool containers with flooding quantities of water until well after the fire has died. • Withdraw immediately in case of rising sound (BLEVE) from venting safety devices or a discolouration or heating of the tank. • ALWAYS stay away from tanks engulfed in a fire. • For massive fires, use unmanned hose holders or monitor nozzles. If it is impossible, withdraw from the area and let the fire

burn out.

Spill or leak • Eliminate all ignition sources. No smoking, flares, sparks, open flames or electric tools in the immediate area. • All equipment used when the product is handled must be earthed. • Do not touch or walk through spilled material. • Stop any leak if it can be done without risk. • Prevent static electricity build-up in the vicinity of the spill or leak. • Prevent entry of the product into waterways, sewers, drains or confined spaces. • A vapour suppressing foam may be used to reduce vapours. • Absorb or cover the spillage with dry earth, sand or other non-combustible material and transfer to dedicated containers. • Use clean non-sparking tools to collect absorbed material. • For large spills, construct a dyke far ahead of the liquid spill, for later disposal. • Water spray may reduce vapour, but may not prevent ignition in closed spaces.

First Aid

• Move victim to fresh air. • Call emergency medical care. • Give artificial respiration if victim is not breathing. • Administer oxygen if breathing is difficult. • Remove and isolate contaminated clothing and shoes. • In case of contact with product, immediately flush skin and eyes with running water for at least 20 minutes. • Wash skin with soap and water. • Keep victim warm and still. • In case of burns, immediately cool affected skin for as long as possible with cold water. • Do not remove clothing if it adheres to the skin. • Ensure that medical personnel are aware of the materials involved and that they take precautions to protect themselves.

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147Section 20

Environmental requirements

This risk assessment did not focus on the impacts that the chemical plant could have on the environment during its normal operations.

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148Section 21

Required organizational measures

______________________________________________________________________ The following organizational measures may be required at the Ecoservices and LA Fuels: 1. The Chief Inspector, Provincial Director and local government must be notified about the

outcome of the risk assessment in accordance with Sub regulation 3 (1) of the Major Hazard Installation Regulations R.692 of 30 July 2001. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

2. An advertisement must be published in at least one local newspaper to advertise the notification to the Chief Inspector, Provincial Director and local government in accordance with Sub regulation 3 (6) of the Major Hazard Installation Regulations. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

3. A site notices must be posted in the community around the chemical plant site to advertise the notification to the Chief Inspector, Provincial Director and local government in accordance with Sub regulation 3 (6) of the Major Hazard Installation Regulations. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

4. It is imperative that the results of the risk assessment be communicated to members of the communities around the chemical plant.

5. Ecoservices and LA Fuels must update its emergency management plan for the operation of the chemical plant.

6. Ecoservices and LA Fuels must ensure that sufficient people are employed to ensure the safe and reliable operation of the chemical plant and to have adequate human resources available to manage any emergency situation that may occur at the chemical plant.

7. Ecoservices and LA Fuels must update its emergency evacuation procedure as part of the emergency management plan, aimed at the inhabitants around the chemical plant, in collaboration with the City of Cape Town emergency services and interested and affected parties.

8. The outcome of this risk assessment must be brought to the attention of all the employees of Ecoservices and LA Fuels.

9. Ecoservices and LA Fuels needs to update the major hazard installation risk assessment for the chemical plant every 5 years, in accordance with Section 5 (1) of the Major Hazard Installation Regulations.

10. The premises of Ecoservices and LA Fuels must be cleaned up, as part of the planned mitigation measures for the site. All waste materials and products must be removed from the site and disposed of at the Vissershok hazardous waste disposal site. No unnecessary products or materials must be stored on site, to reduce the risk of fire or explosion.

11. Flammable chemical feedstock or final product may not be stored at the factory entrance, near the Spin Street gate.

12. All the feedstock and final product must be stored towards the western side of the site, furthest away from the Easigas major hazard installation opposite Spin Street.

13. All unnecessary flammable liquids must be removed from the site. 14. All the feedstock and final product must be stored in individual drums with screw caps, inside a

bunded area. The surface area of the bund must be considerably less than the original factory yard storage set-up.

15. Boiler fuel must be stored in one bunded tank instead of the previous two unbunded tanks. 16. The maximum allowable volume of flammable liquids that will be stored on site must be limited

to 50 000 litres. 17. An additional fire hydrant must be installed near the site entrance gate. 18. A fire-fighting foam supply point must be installed at the bunded area where feedstock and final

product will be stored.

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14919. The existing emergency management plan of the site must be revised and approved by Mr

Gavin Visser of the Fire Department of Bellville. 20. No plastic containers, such as Flowbins, may be used for the storage of feedstock or final

product on site. 21. The safety of workers is of paramount importance. All workers and managers on site must be

sensitised about the safety risks that exist at the factory in terms of fires, vapour cloud explosions and the release of toxic vapours. Workers and management must be trained in the safety and emergency response procedures that apply to the factory and its premises. Regular breathalyser tests must be conducted on site among all workers and management to ensure that no worker consumed alcohol before entering the site or while present on the site. If any worker or manager fails the breathalyser test, he/she must be dismissed with immediate affect.

22. The chemical factory is owned jointly by Promania 138 CC and Ecosolve CC. The two business entities must decide on a joint management meeting to appoint a specific person as responsible Chief Executive Officer who will take full responsibility, on behalf of both business entities, for the health and safety of workers on site, in accordance with Section 16 (1) of the Occupational Health and Safety Act (Act 85 of 1993).

23. A specific person must be appointed in accordance with Section 16 (2) of the Occupational Health and Safety Act to take responsibility, together with the appointed Chief Executive Officer, for the health and safety of all workers on site.

24. A solid fire wall must be constructed between the office part of the factory and the distillation process section of the plant.

25. All electrical connections on the premises of Ecoservices and LA Fuels, including temporary installations and mobile equipment, must be certified as flame-proof and spark-proof.

26. All tanks that contain flammable materials must be installed inside a closed bund wall system, capable of containing at least 110% of the contents of the tank.

27. The collapse of bund walls under thermal radiation flux must specifically be addressed. It must be possible to extinguish a fire in a bunded section within the shortest possible time, to minimise heat stress on the bund walls. The installation of foam pouring systems at all bunded areas is therefore strongly recommended.

28. All fire extinguishers on the premises must be tested at least once every six months by a certified equipment supplier.

29. All temporary containers that contain flammable liquids must be stored on a concrete slab. 30. The Chief of the Bellville Fire Department must approve all building plans for the rebuilt factory. 31. At the time of this risk assessment, no bitumen or other flammable materials are stored on the

adjacent municipal stand west of the Ecoservices and LA Fuels. Close contact must be maintained with the municipality and if they decide to start storing flammable materials on their stand the Chief of Bellville Fire Department must be notified. A revision of this risk assessment may then be required.

32. Detailed operating procedures must be developed for all operations on the premises. These include, but are not limited to, the following:

• Safe work. • The issuing of hot-work permits for any work that can be a source of ignition. • Emergency actions. • Proper ventilation to ensure that all volatile flammable vapours are kept well below the

lower explosive limit (LEL) for the particular substance. • Availability of material safety data sheets (MSDS) for all hazardous substances on site.

33. A full-time safety officer must be appointed in writing for the premises. The officer must have the authority to stop any work or action that may pose a health and safety threat to other workers on site.

34. Disciplinary action must be instituted immediately against any worker or member of management that contravenes the safety rules applicable to the premises.

35. The maintenance workshop must be located in a safe area, away from flammable liquids and vapours. The workshop must be equipped with extraction or blower fans to ensure that the

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150concentration of any explosive gases inside the workshop is always kept below the LEL. The operating capacity of the fans must be sufficient to exchange the air volume in the workshop every 5 minutes. If air is sucked into the workshop from outside, it must be ensured that the suction point is located in an area on the premises where no flammable vapours can be drawn into the workshop.

36. The management of the Ecoservices and LA Fuels must report all safety incidents, including near misses, to the Chief of the Fire Department of Bellville as well as to the Provincial Director of the Department of Labour.

37. A Health and Safety Committee must be instituted at the factory. The Committee must meet at least once per month for a review of the safety conditions and status at the premises.

38. A Maintenance Register must be instituted at the factory. The Register must contain at least the following: • List of all equipment and facilities on the premises. • Maintenance frequency. • Particulars of maintenance activities that must be performed on the listed equipment. • Responsible person.

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151Section 22

Land use around the Ecoservices and LA Fuels chemical plant site

______________________________________________________________________ 22.1 Introduction It is not the intention of this risk assessment report to express an opinion regarding the viability or feasibility of land development per se along the liquid fuel and chemical plant. Such business falls outside the scope of the risk assessment as defined in the Major Hazard Installation Regulations. However, some comments regarding land development in relation to the proximity and severity of major hazardous installations would be appropriate. The following reference sources were consulted: • The South African Development Facilitation Act (Act No 67 of 1995). • Risk Criteria for Land-use Planning in the Vicinity of Major Industrial Hazards, issued by the UK

Health and Safety Executive. 22.2 South African Development Facilitation Act [16] The purpose of the Act is as follows:

• To facilitate and speed up the implementation of reconstruction and development programmes and projects in relation to land.

• To lay down general principles governing land development throughout South Africa. • To provide for the establishment of a Development and Planning Commission for the

purpose of advising Government on policy and laws concerning land development on national and provincial level.

• To provide for the establishment in the provinces of Development Tribunals, which have the power to make decisions and resolve conflict in respect of land development projects.

• To facilitate the formulation and implementation of land development objectives by reference to which the performance of local government bodies in achieving such objectives may be measured.

• To provide for nationally uniform procedures for the subdivision and development of land for residential, small-scale farming or other needs and uses.

• To promote security of tenure while ensuring that end-user finance in the form of subsidies and loans becomes available as early as possible during the land development process.

Section 3 (1) viii states as a general principle for land development that environmentally sustainable land development practices and processes are encouraged. Section 33 (2) (n) states that, in its consideration of an application for land development, the Development Tribunal may impose any condition of establishment relating to the environment or environmental evaluations in approving a land development application. It is clear that land development in South Africa must take due cognizance of environmental requirements and constraints, biophysically and socio-economically.

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15222.3 UK Health and Safety Executive (HSE) [17] In the United Kingdom it has been recognized for some years that safety should be taken into account when making decisions about the development of land near major hazards where a major accident might extend beyond the boundaries of the site. The UK Health and Safety Executive makes a clear distinction between “individual risk” and “societal risk”. “Individual risk” is defined as the frequency at which an individual person may be expected to sustain a given level of harm from the realization of specified hazards. On the other hand, “societal risk” refers to the relationship between frequency and the number of people suffering from a given level of harm in a given population from the realization of specified hazards. In the case of the chemical plant, it would be appropriate to primarily apply the principle of societal risk, given the fact that residential development has taken place around the site and is being considered in future. However, it must be noted that societal risk is a difficult concept, as it relates to the chances of a disaster due to the location of a particular development near a major hazard installation. It is necessary to consider the size of the disaster as well as its probability. In reality there could be a range of possible sizes, each with different probabilities. For example, there might be a low chance of injuring most of the people in a particular development, or a high chance of injuring only a few of them, from the same major hazard installation. The Health and Safety Executive has given advice on about 5 000 developments near major hazard installations, requiring detailed risk assessments, over a period of 15 years. Of these, many were concluded not to be causes for concern. Of the developments, which were inadvisable, each one on its own would not have made a large addition to the overall societal risk from major hazard installations in the UK. However, taken altogether, there would perhaps have been a significant increase had the Health and Safety Executive not advised against it. In general, while it is likely that the extra societal risk due to any single development would be very small, unrestrained land developments could eventually add up to a noticeable worsening of the cumulative situation. The important point to take into consideration here is that small individual additions to societal risk will accumulate to lead to a considerable increase in the number of people at risk from major hazard installations on a regional or national scale. In the UK the Health and Safety Executive will usually advise against developments near major hazard installations in the following cases, bearing in mind that societal risk figures are not always available or reliable: • Residential developments for more than about 25 people, if the individual risk of receiving a

defined dangerous dose of a toxic substance, heat or blast overpressure exceeds 10.0E-6 per year.

• Residential developments for more than about 75 people, if the individual risk of receiving a defined dangerous dose of a toxic substance, heat or blast overpressure exceeds 1.0E-6 per year.

• Moderately sized developments where the calculated individual risk exceeds 10.0E-6 per year. • Large sized developments where the calculated individual risk exceeds 1.0E-6 per year. Another important factor that needs to be taken into consideration within the South African context is that formal development, whether it is residential or otherwise, can be controlled and managed by planning authorities. However, due to a chronic scarcity of residential land, informal settlements are a reality. It is therefore quite possible that vacant land around the chemical plant could be occupied by informal dwellers, which would be very difficult to control and manage by both Ecoservices and LA Fuels and the authorities. It must further be borne in mind that whatever decision is taken regarding future land development, will remain in force for at least 50 years.

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153Section 23

Risk criteria and the ALARP principle

______________________________________________________________________ 23.1 Introduction The risks identified in this assessment can only be interpreted meaningfully if it is compared with internationally acceptable risk criteria. The UK Health and Safety Executive (HSE) [1] is regarded as a world leader as far as occupational and public health and safety are concerned. The risk criteria applied by the HSE are therefore used as benchmarks in this report. The HSE refers to two types of risk criteria, namely individual risk and societal risk. 23.2 Individual risk criteria The HSE risk criteria framework [26] is represented by a triangle as shown in Figure 23.1. The risk increases from the bottom part of the triangle to the top. The framework suggests that there is an upper limit to individual risk, above which the risk is regarded as unacceptable, whatever the benefits. Any activity or practice that falls into this region (the dark section at the top of the triangle) would normally be ruled out (not allowed). Action needs to be taken to reduce the risk so that it can fall into one of the regions lower down in the triangle.

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154Figure 23.1

HSE framework for individual risk criteria

The zone at the bottom part of the triangle represents a broadly acceptable risk region. Activity risks that fall into this region are regarded as insignificant and adequately controlled. Further action to reduce the risk would normally not be required, unless there are obvious, reasonable practicable measures available. The levels of risk within this region are comparable to those that people regard as trivial or insignificant in their daily lives. The middle region of the triangle (between the unacceptable and broadly acceptable regions) represents a region of tolerable risk. Within this region the risks must be controlled to a level that is as low as reasonably practicable (ALARP). 23.3 Societal risk criteria The Dutch Advisory Committee on Dangerous Substances (ACDS) developed risk criteria that are applicable to societies at large. These criteria are shown in Figure 23.2. The intolerable region above the local tolerability line on the FN-curve is defined as activities that must be avoided.

Upper limit of tolerable risk for workers: 1.0E-3/year

Upper limit of tolerable risk for public: 1.0E-4/year

Broadly acceptable risk: 1.0E-6/year

High risk

Low risk

Unacceptable region

Tolerable region where ALARP principle applies

Broadly acceptable region

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155Below the negligible line lies a region where risks are negligible and no further action is required to reduce the risk level. The middle region, above the negligible line and below the local tolerability line, is a region of possibly unjustifiable risk. The ALARP principle is applicable in this region. 23.4 The ALARP principle The ALARP (as low as reasonably practicable) principle arises from the fact that it would theoretically be possible to spend an infinite amount of resources such as time, effort and money in an attempt to reduce a particular risk to a level of zero. It will be a never-ending process. The objective of risk management is to reduce the risks associated with a particular activity to such a level that nothing else can be done further without serious cost or other disadvantages. These disadvantages may be of such a magnitude that it is not wothwhile to pursue the activity anymore. It means that all reasonably practicable mitigation measures have been taken to reduce the level of the residual risk. The risk is then low enough so that any attempt to reduce it further would be more costly than the costs that may be incurred due to the risk per se. The residual risk is then called tolerable risk, as shown in Figure 23.2.

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156Figure 23.2

Dutch criteria for societal risk

1.0E-06

1.0E-05

1.0E-04

1.0E-03

1.0E-02

1.0E-01

1.0E+00

1 10 100 1000 10000

Number of fatalities, N

Freq

uenc

y of

N o

r mor

e fa

talit

ies

per y

ear

Negligible line

Local tolerability line

Local scrutiny line

Possibly unjustifiable risk region

ALARP region of tolerable risk

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157 Section 24

Conclusions

______________________________________________________________________ 1. The following potential major incidents are anticipated at the Ecoservices and LA Fuels plant:

• Heat radiation due to a pool fire. • Heat radiation due to a flash fire. • A vapour cloud explosion caused by the light-fraction components of solvents. • A boiling liquid expanding vapour explosion of the containers in which solvents are stored. • Release of toxic combustion gases during a fire, including carbon monoxide, carbon

dioxide, carbon particulates (soot) and sulphur dioxide. 2. The safety risks associated with the Ecoservices and LA Fuels plant are summarised as

follows:

Table 24.1

Potential Major

Incident

Frequency Incidents per

year

Minimum Safety Radius

m

Surface Area of Effective Circle

Segment m2

Potential Number of Human Impacts

N * Heat radiation due to pool fire

3.88 E+1 16 805 23

Heat radiation due to flash fire

3.88 E+1 3 29 1

Vapour cloud explosion

9.7 E0 37 4 303 7

Release of CO from solvent fire

3.88 E+1 119 14 835 23

Release of CO from oil fire

3.88 E+1 73 5 583 9

Release of CO2

from solvent fire 3.88 E+1 14 205 1

Release of CO2

from oil fire 3.88 E+1 32 1 073 2

Release of carbon particulates from solvent fire

3.88 E+1 282 83 311 125

Release of carbon particulates from oil fire

3.88 E+1 78 6 374 10

Release of SO2 from solvent fire

3.88 E+1 10 105 1

Release of SO2 from oil fire

3.88 E+1 11 127 1

*Based on a human impact rate of 50% 3. The Ecoservices and LA Fuels plant was destroyed by a major fire in November 2009. The

exact cause of the fire is unknown to the risk assessor. In addition, at least one near miss occurred on the premises during the past year.

4. The societal risk profile for the plant (Figure 24.1) shows that the estimated risk lies above the tolerable level for the public, mainly because the anticipated frequency of a major incident exceeds the norm of 1.0 E-4.

5. The individual risk transect for the plant (Figure 24.2) shows that the estimated risk lies above the tolerable level for workers, mainly because the anticipated frequency of a major incident exceeds the norm of 1.0 E-3.

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1586. The maize mill of Western Cape Milling that is located next to Ecoservices and LA Fuels

poses a risk to the chemical plant. Open-air dust fires and explosions are fairly common throughout the world with a high frequency of occurrence. An alarming figure is the very short historical period between successive incidents, namely 18 days for dust fires and 13 to 22 days for dust explosions. Grain storage facilities are liable to serious dust explosions. A grain dust explosion in 1977 in Louisiana killed 35 people and was classified on the same scale as that of Flixborough in 1974 (cyclohexane vapour cloud explosion with an estimated overpressure of 10 psi). The effect of maize dust cloud explosions will vary, depending on the mass of maize product dust present within the explosion limits. The overpressure effects of dust cloud explosions are remarkably high with maximum explosion pressures of 109 psi for wheat flour been recorded. In the case of Western Cape Milling an overpressure of 1 psi could be reached within a radius of 48 meters. The Ecoservices and LA Fuels plant is located 15 meters away from Western Cape Milling and the Ecoservices and LA Fuels plant could be exposed to an overpressure of 5 to 10 psi. The effect of such overpressure on the Ecoservices and LA Fuels plant could be as follows: • Breakage of small windows under strain. • Partial demolition of houses. • Houses made uninhabitable. • Corrugated asbestos shattered. • Corrugated steel or aluminium panels fastenings fail, followed by buckling. • Wood panels in standard housing fail and panels blown in. • Partial collapse of walls and roofs of houses. • Concrete or cinder block walls, not reinforced, shattered. • Steel frame buildings distorted and pulled away from foundations. • Frameless, self-framing steel panel buildings demolished. • Rupture of oil storage tanks. • Cladding of light industrial buildings ruptured. • Wooden utility poles snap. • Tall hydraulic press (18 000 kg) in building slightly damaged. • Nearly complete destruction of houses. • Loaded train wagons overturned. • Brick panels, 8-12 inches thick, not reinforced, fail by shearing or flexure. • Loaded train boxcars completely demolished. • Probable total destruction of buildings. • Heavy machine tools (3 100 kg) moved and badly damaged.

7. Easigas operates a liquefied petroleum gas (LPG) depot in Spin Street opposite the

Ecoservices and LA Fuels plant, about 65 meters away. The Easigas depot could be at risk as follows: • Pool fire at Ecoservices and LA Fuels, with a safety distance of 16 meters. • Vapour cloud explosion, with a safety distance of 37 meters.

However, based on the proposed mitigation measures, the above risks to which Easigas would be exposed reduced substantially, to the extent that the risk contour around Ecoservices and LA Fuels excludes Easigas.

8. Ecoservices and LA Fuels must confirm that the boiler on their premises has been registered at

the Provincial Director of the Department of Labour in accordance with the Pressure Equipment Regulations R.734 of 15 July 2009.

9. A major hazard installation risk assessment was conducted for the Ecoservices and LA Fuels factory on 3 October 2008 (Report MHI-17/9/2008-1-Organic) and revised on 1 June 2009 (Report MHI-17/9/2008-2-Organic), for the plant that was destroyed by a major fire.

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159 10. In order to be classified as a major hazard installation (MHI), a facility must satisfy at least one

of the following two criteria:

The highest frequency of a potential major incident exceeds the norm of 1.0E-4, although the potential number of human impacts do not exceed the norm of 10 000. For this risk assessment, the estimated frequencies of potential major incidents at the Ecoservices and LA Fuels plant have been increased by an exponent of 2 as a result of the major fire in November 2009. Based on this risk assessment, it is concluded that the planned new chemical plant of Ecoservices and LA Fuels constitutes a major hazard installation and should be classified as such under the Major Hazard Installation Regulations R.692 of 30 July 2001. If any part of a facility is classified as a major hazard installation, the entire facility is classified as such.

11. The risk assessor reserves the right to inspect the facility on a date agreed with the owners, to verify that the planned mitigation measures have indeed been implemented correctly.

12. The purpose of any major hazard installation risk assessment under current South African legislation is not to authorize or reject any development proposal. The purpose is to identify and analyze possible risk scenarios, so that the expected risks could be managed appropriately in the interest of the safety of the general public and workers on the premises. In the case of the Ecoservices and LA Fuels chemical plant in Bellville South, this risk assessment highlights the fact that the chemical plant is a major hazard installation with specific expected incidents. The onus is now on Ecoservices and LA Fuels to operate the chemical plant system in such a way that the risks are minimized to the lowest acceptable level.

The following organizational measures may be required at the Ecoservices and LA Fuels plant in Bellville-South: 1. The Chief Inspector, Provincial Director and local government must be notified about the

outcome of the risk assessment in accordance with Sub regulation 3 (1) of the Major Hazard Installation Regulations R.692 of 30 July 2001. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

2. An advertisement must be published in at least one local newspaper to advertise the notification to the Chief Inspector, Provincial Director and local government in accordance with Sub regulation 3 (6) of the Major Hazard Installation Regulations. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

The highest frequency of a major incident must be higher than 1.0E-4 / year

F > 0, 0001 / yr

UK Health and Safety Executive

The maximum number of human impacts that could be caused by the major incident must be higher than 10 000

N > 10 000

Dutch Advisory Committee on Dangerous Substances

OR

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1603. A site notices must be posted in the community around the chemical plant site to advertise

the notification to the Chief Inspector, Provincial Director and local government in accordance with Sub regulation 3 (6) of the Major Hazard Installation Regulations. It must specifically be mentioned that the factory was destroyed by a fire in November 2009 and will now be rebuilt.

4. It is imperative that the results of the risk assessment be communicated to members of the communities around the chemical plant.

5. Ecoservices and LA Fuels must update its emergency management plan for the operation of the chemical plant.

6. Ecoservices and LA Fuels must ensure that sufficient people are employed to ensure the safe and reliable operation of the chemical plant and to have adequate human resources available to manage any emergency situation that may occur at the chemical plant.

7. Ecoservices and LA Fuels must update its emergency evacuation procedure as part of the emergency management plan, aimed at the inhabitants around the chemical plant, in collaboration with the City of Cape Town emergency services and interested and affected parties.

8. The outcome of this risk assessment must be brought to the attention of all the employees of Ecoservices and LA Fuels.

9. Ecoservices and LA Fuels needs to update the major hazard installation risk assessment for the chemical plant every 5 years, in accordance with Section 5 (1) of the Major Hazard Installation Regulations.

10. The premises of Ecoservices and LA Fuels must be cleaned up, as part of the planned mitigation measures for the site. All waste materials and products must be removed from the site and disposed of at the Vissershok hazardous waste disposal site. No unnecessary products or materials must be stored on site, to reduce the risk of fire or explosion.

11. Flammable chemical feedstock or final product may not be stored at the factory entrance, near the Spin Street gate.

12. All the feedstock and final product must be stored towards the western side of the site, furthest away from the Easigas major hazard installation opposite Spin Street.

13. All unnecessary flammable liquids must be removed from the site. 14. All the feedstock and final product must be stored in individual drums with screw caps, inside a

bunded area. The surface area of the bund must be considerably less than the original factory yard storage set-up.

15. Boiler fuel must be stored in one bunded tank instead of the previous two unbunded tanks. 16. The maximum allowable volume of flammable liquids that will be stored on site must be limited

to 50 000 litres. 17. An additional fire hydrant must be installed near the site entrance gate. 18. A fire-fighting foam supply point must be installed at the bunded area where feedstock and final

product will be stored. 19. The existing emergency management plan of the site must be revised and approved by Mr

Gavin Visser of the Fire Department of Bellville. 20. No plastic containers, such as Flowbins, may be used for the storage of feedstock or final

product on site. 21. The safety of workers is of paramount importance. All workers and managers on site must be

sensitised about the safety risks that exist at the factory in terms of fires, vapour cloud explosions and the release of toxic vapours. Workers and management must be trained in the safety and emergency response procedures that apply to the factory and its premises. Regular breathalyser tests must be conducted on site among all workers and management to ensure that no worker consumed alcohol before entering the site or while present on the site. If any worker or manager fails the breathalyser test, he/she must be dismissed with immediate affect.

22. The chemical factory is owned jointly by Promania 138 CC and Ecosolve CC. The two business entities must decide on a joint management meeting to appoint a specific person as responsible Chief Executive Officer who will take full responsibility, on behalf of both business

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161entities, for the health and safety of workers on site, in accordance with Section 16 (1) of the Occupational Health and Safety Act (Act 85 of 1993).

23. A specific person must be appointed in accordance with Section 16 (2) of the Occupational Health and Safety Act to take responsibility, together with the appointed Chief Executive Officer, for the health and safety of all workers on site.

24. A solid fire wall must be constructed between the office part of the factory and the distillation process section of the plant.

25. All electrical connections on the premises of Ecoservices and LA Fuels, including temporary installations and mobile equipment, must be certified as flame-proof and spark-proof.

26. All tanks that contain flammable materials must be installed inside a closed bund wall system, capable of containing at least 110% of the contents of the tank.

27. The collapse of bund walls under thermal radiation flux must specifically be addressed. It must be possible to extinguish a fire in a bunded section within the shortest possible time, to minimise heat stress on the bund walls. The installation of foam pouring systems at all bunded areas is therefore strongly recommended.

28. All fire extinguishers on the premises must be tested at least once every six months by a certified equipment supplier.

29. All temporary containers that contain flammable liquids must be stored on a concrete slab. 30. The Chief of the Bellville Fire Department must approve all building plans for the rebuilt factory. 31. At the time of this risk assessment, no bitumen or other flammable materials are stored on the

adjacent municipal stand west of the Ecoservices and LA Fuels. Close contact must be maintained with the municipality and if they decide to start storing flammable materials on their stand the Chief of Bellville Fire Department must be notified. A revision of this risk assessment may then be required.

32. Detailed operating procedures must be developed for all operations on the premises. These include, but are not limited to, the following:

• Safe work. • The issuing of hot-work permits for any work that can be a source of ignition. • Emergency actions. • Proper ventilation to ensure that all volatile flammable vapours are kept well below the

lower explosive limit (LEL) for the particular substance. • Availability of material safety data sheets (MSDS) for all hazardous substances on site.

33. A full-time safety officer must be appointed in writing for the premises. The officer must have the authority to stop any work or action that may pose a health and safety threat to other workers on site.

34. Disciplinary action must be instituted immediately against any worker or member of management that contravenes the safety rules applicable to the premises.

35. The maintenance workshop must be located in a safe area, away from flammable liquids and vapours. The workshop must be equipped with extraction or blower fans to ensure that the concentration of any explosive gases inside the workshop is always kept below the LEL. The operating capacity of the fans must be sufficient to exchange the air volume in the workshop every 5 minutes. If air is sucked into the workshop from outside, it must be ensured that the suction point is located in an area on the premises where no flammable vapours can be drawn into the workshop.

36. The management of the Ecoservices and LA Fuels must report all safety incidents, including near misses, to the Chief of the Fire Department of Bellville as well as to the Provincial Director of the Department of Labour.

37. A Health and Safety Committee must be instituted at the factory. The Committee must meet at least once per month for a review of the safety conditions and status at the premises.

38. A Maintenance Register must be instituted at the factory. The Register must contain at least the following: • List of all equipment and facilities on the premises. • Maintenance frequency.

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162• Particulars of maintenance activities that must be performed on the listed equipment. • Responsible person.

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163Figure 24.1

Societal risk profile for the Ecoservices and LA Fuels plant

Current risk assessment May 2010

Profile for previous risk assessment, June 2009, for comparison

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164Figure 24.2

Individual risk transect

Current risk assessment May 2010

Profile for previous risk assessment, June 2009, for comparison

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165Section 25

References

______________________________________________________________________ [1] American Institute of Chemical Engineers. Center for Chemical Process Safety. Guidelines for Chemical Process Quantitative Risk Analysis. Second Edition. 2000. [2] US Environmental Protection Agency (EPA). US federal Emergency Management Agency (FEMA). US Department of Transportation. Automated Resource for Chemical Hazard Incident Evaluation used in conjunction with the Handbook of Chemical Hazard Analysis Procedures, Volume 1 and 2. 1987. [3] US Environmental Protection Agency. US National Oceanic and Atmospheric Administration. US Chemical Emergency Preparedness and Prevention Office. US Hazardous Materials Response Division. Computer-aided Management of Emergency Operations used in conjunction with the Areal Locations of Hazardous Atmospheres (ALOHA) User Manual Volume 1 and 2. March 2004. [4] US Arizona Emergency Response Commission. Cameo Companion Procedure for the Management of Hazardous Situations. October 2004. [5] MHI risk assessment for Airports Company of South Africa for a new Jet A-1 fuel and depot at O R Tambo Airport in Kempton Park, Ekurhuleni. [6] Sam Mannan. Lee’s Loss Prevention in the Process Industries. Hazard Identification, Assessment and Control. Volume 1. Third Edition. 2005. [7] Sam Mannan. Lee’s Loss Prevention in the Process Industries. Hazard Identification, Assessment and Control. Volume 2. Third Edition. 2004. [8] Sam Mannan. Lee’s Loss Prevention in the Process Industries. Hazard Identification, Assessment and Control. Volume 3. Third Edition. 2004. [9] Robert H Perry and Cecil H Chilton. Chemical Engineer’s Handbook. Fifth Edition. 1973. [10] A C Valsamakis, R W Vivian and G S du Toit. Risk Management. Second Edition. 1999. [11] J D Andrews and T R Moss. Reliability and Risk Assessment. Second Edition. 2002. [12] Dennis P Nolan. Handbook of Fire and Explosion Protection Engineering Principles for Oil, Gas, Chemical and related Facilities. Noyes Publications. 1996. [13] CRC Press. Handbook of Chemistry and Physics. 61st Edition. 1980. [14] RSA Occupational Health and Safety Act (Act No 85 of 1993). [15] RSA Major Hazard Installation Regulations R.692 of 30 July 2001. [16] RSA Development Facilitation Act (Act No 67 of 1995).

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166[17] UK Health and Safety Executive. Risk Criteria for Land-use Planning in the Vicinity of Major Industrial Hazards. 1989. [18] Milton R Beychok. Fundamentals of Stack Gas Dispersion. Third Edition. 1995. [19] RSA Weather Service. A C Kruger. Climate of South Africa: Surface Winds. Publication No WS-43. 2002. [20] RSA Weather Bureau. Climate of South Africa. Climate Statistics up to 1984. Publication WB-40. [21] RSA Weather Bureau. Climate of South Africa Part 8. General Survey. Publication WB-28. [22] RSA National Nuclear Regulator. A Guideline Document for the Release of Contaminated Sites from Regulatory Control. July 2002. [23] RSA Environment Conservation Act (Act No 73 of 1989). [24] RSA National Environmental Management Second Amendment Act (Act No 8 of 2004). [25] Internet web site for Ecoservices and LA Fuels. [26] UK Health and Safety Executive. Lines of Defence / Layers of Protection Analysis in the COMAH (Control of Major Accident Hazards regulations of 1999) Context. 1999. [27] Digital Globe, National Geographic and Google Earth Plus. Global satellite image mapping. 2005. [28] The Concise Oxford Dictionary. 1983. [29[ UK Health and Safety Executive. Reducing Risks, Protecting People. 2001. [30] D van Zyl. South African Weather and Atmospheric Phenomena. Briza Publications. 2003. [31] South African Weather Service. Climate of South Africa – Surface Winds. Publication WS43. 2002. [32] Weather Bureau of South Africa. Climate of South Africa Part 8 WB28. 1994. [33] Weather Bureau of South Africa. Climate of South Africa WB40. 1988. [34] Statistics South Africa. Data sets for the Ekurhuleni census survey in 2001. [35] Dennis P Nolan. Handbook of Fire and Explosion Protection Engineering Principles for Oil, Gas, Chemical and Related Facilities. Noyes Publications. 1996. [36] A Garrett, W T Lippincott, F Verhoek. Chemistry – A study of Matter. Ohio State University. 1972. [37] E W McAllister (Editor). Pipeline Rules of Thumb Handbook. Gulf Professional Publishing, Fifth Edition. 2002.

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167[38] VGI Consulting Incorporated. Civil and Structural Consulting Engineers and Project Managers. [39] US Department of Transportation, Chemical plant and Hazardous Materials Safety Administration. Hazardous liquid chemical plant incident statistics 1988-2006. [40] European Gas Pipeline Incident Data Group (EGIG), 6th Report: 1970-2004. December 2005.

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168Section 26

Statements and Declarations

1. Statement of competence Alfonso Niemand is the author of this report. In terms of the ISO/IEC-17020 standards he has been appointed as Technical Manager of Nature & Business Alliance Africa (Pty) Ltd. Alfonso holds the following qualifications: • Baccalaureus Scientiae (BSc), University of South Africa. • Masters Degree in Business Leadership (MBL), University of South Africa. • Certificate course in the Integration of Safety, Health, Environmental, Risk and Quality

Management Systems, University of Potchefstroom, South Africa. • Certificate course in Environmental Management, University of Pretoria, South Africa. • Certificate courses as Safety and Health Representative, Occupational Health and Safety

Services and Advantage ACT. • Certificate course in Health and Safety Incident Investigation, Advantage ACT. Alfonso Niemand holds the following memberships: • International Association for Impact Assessment (IAIA). • South African Right of Way Association (SARWA). • South African Association for Professional Managers (SAAPM, registration 9/2/99) • South African Council for Natural Scientific Professions (SACNASP, registration 200026/04). • American Institute of Chemical Engineers (AIChE). Alfonso Niemand has 28 years experience in the petrochemical and construction industries in South Africa. He worked with the Environmental Protection Agency of the United States in 1981 for the environmental, safety and health mapping of an oil-from-coal plant in South Africa. He works in close collaboration with the European Gas Chemical plant Incident Data Group (EGIG), Nederlandse Gasunie, the Health and Safety Executive (HSE) of the United Kingdom and the USA Department of Transportation Office of Chemical plant Safety.

2. Quality manual and accreditation Nature & Business Alliance Africa (Pty) Ltd conducts its risk assessments in accordance with a quality manual that complies with the requirements of the ISO/IEC-17020 Standards for Various Bodies Performing Inspections. Nature & Business Alliance Africa (Pty) Ltd is accredited by the South African National Accreditation System (SANAS) as a Type A Major Hazard Risk Installation Inspection Body (accreditation number MHI-004).

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1693. Registration as Approved Inspection Authority (AIA)

Nature & Business Alliance Africa (Pty) Ltd is registered by the Department of Labour as an Approved Inspection Authority (AIA) for toxic, flammable and explosive substances (registration number MHI-002). 4. Statement of indemnity This risk assessment specifically pertains to the chemical plant of Ecoservices and LA Fuels in 1 Spin Street, Bellville South. Modifications or alterations made to the site, equipment, facilities or operating procedures and parameters after completion of this risk assessment are not covered by the assessment outcomes and are explicitly excluded. Nature & Business Alliance Africa (Pty) Ltd will not be liable for damage to any assets, injury to any persons or the death of any person as a direct result of the activities of Ecoservices and LA Fuels (the client) or the client’s subcontractors, before, during and after the requested risk assessment has been conducted. The risk assessment conducted by Nature & Business Alliance Africa (Pty) Ltd and the related findings are based on the circumstances, external factors and conditions that prevailed at the time when the study was conducted. The risk assessment, related reports and all recommendations must not be interpreted as automatic safeguards against an incident that could lead to damage, injury or death and Nature & Business Alliance Africa (Pty) Ltd does not accept liability for such damage, injury or death. 5. Copyright Nature & Business Alliance Africa (Pty) Ltd retain copyright of this report. No part of the report may be copied or reproduced in any format without written approval from the author. If any part of the report is to be used for other work by another party, clear reference must be made to Nature & Business Alliance Africa (Pty) Ltd as the owner and copyright holder of the report. 6. Condition of non-influence It is declared that Nature & Business Alliance Africa (Pty) Ltd did not allow any form of external influencing of this assessment results, conclusions and recommendations, including undue time constraints imposed on the author, bribery, incentives offered to personnel and alterations made to this report. The submission of any draft report to the client does not grant the client the opportunity or the right to alter the findings, conclusions or recommendations in its favour in any way, without sound substantiation. 7. Declaration of independence Nature & Business Alliance Africa (Pty) Ltd and Alfonso Niemand (the author) in particular, declare that the organization and its personnel are not related to Ecoservices and LA Fuels or to its employees or contractors for this assignment. It is declared that the risk assessment report and the findings are unbiased and was not influenced by any commercial, financial or other pressures imposed on the organization or the author. 8. Confidentiality All information disclosed to us by Ecoservices and LA Fuels or its contractors, are treated as confidential. The information contained in this study report will also be treated as confidential and

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170will not be disclosed by the author to any third party without the authorization of Ecoservices and LA Fuels. 9. Validity period This report is valid for a period of 5 years only, in accordance with the Major Hazard Installation Regulations, Section 5 (1).

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171Accreditation Certificate

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172

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173Certificate of Appointment by Department of Labour

Environmental Compliance Audit of LA Fuels Processing Facility

Environmental Compliance Audit of L A Fuels Processing facility

ROSE Foundation April 2011

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks

Date April 2011

Prepared by K Sims

Signature

Checked by Rhys Giljam

Signature

Authorised by S. Doel

Signature

Project number 22619

File reference

Reg. No: 1995/08790/07

Contents

1 Introduction 4

2 General Background 7

2.1 Site Description and History 7

2.2 Site History 7

3 Summary of Permits and Authorisations 9

3.1 Legal Compliance 10

4 Audit Findings 14

4.1 Water and Effluent Management 14

4.2 Solid Waste Management 14

4.3 Air Quality Management 15

4.4 Hazardous Materials Management 15

4.5 General Environmental Practice 15

4.6 Extended Producer Responsibility 16

5 Assessment of Potential Impacts to Environment 17

5.1 Air Quality 17

5.2 Surface Water Quality 17

5.3 Groundwater 17

5.4 Ground Contamination 17

5.5 Oil Samples 18

6 Summary of Key Issues Identified 19

6.1 Preliminary Audit Findings 19

7 Summary and Recommendations 21

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1 Introduction

The Rose Foundation is a non-profit Section 21 company dedicated to managing the collection and recycling of used lubricating oil in South Africa. The Rose Foundation has contracts with a number of independent used oil reprocessing companies to supply them with used oil and accordingly, the Rose Foundation undertakes independent environmental audits to assess the oil reprocessing sites in terms of their physical state and the process operations.

WSP Environmental (Pty) Ltd (hereafter WSP) was appointed by the Rose Foundation to undertake an Environmental Audit of L A Fuels (Pty) Ltd (hereafter L A Fuels) in Cape Town. The site location and contact details for the site are as follows:

CONTACT DETAILS:

L A Fuels

1 Spin Street

Belville South

Cape Town

Tel: 082 576 4230

Contact: Len Heydenrych

The site audits were undertaken on 4th April 2011 by Mr Sean Doel and Miss Kirsten Sims of WSP.

1.1 BACKGROUND AND SCOPE OF WORKS

L A Fuels are a used oil processing facility, and have recently resumed operations following a fire on site in November 2009. The fire resulted in the need for an almost total re-build of the site. Operations resumed on the 26th November 2010. Ecosolve T/a L A Fuels trades in conjunction with Promania T/a Ecoservices who specialise in solvent recovery.

L A Fuels now wish to be recognised by the ROSE foundation as an oil processor.

This audit represents the first annual environmental compliance audit of the L A Fuels facility, which has been undertaken by WSP on behalf of the Rose Foundation. The primary objective of the audit was to identify and assess key environmental issues pertaining to L A Fuels operations and facilities. The assessment takes into consideration environmental risk and liability to L A Fuels as well as potential reputational risk to the Rose Foundation within the used oil industry with respect to the collection and recycling of used oil by L A Fuels.

The scope of the audit included assessment of the following key elements: Site operational control measures – assessment of key operational control

measures including (where applicable) water and effluent management, solid waste management, and hazardous materials management including transport and storage of used oils, spill and emergency response, and fire protection.

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Legal and regulatory compliance – assessment of legal and regulatory compliance in terms of site permit requirements and adherence to safety measures.

Impacts to environment – assessment of potential impacts to air quality, ground

and/or surface water or groundwater quality; assessment of the risk of any impact to surrounding land-users as well as from surrounding land-users on the property.

General Environmental Practice – assessment of the standard of general

environmental good practice including implementation and maintenance of environmental management systems.

1.2 REPORT STRUCTURE

This report outlines the findings of the Environmental Compliance Audit undertaken on 4th April 2011. A brief overview of the site operations is provided in Section 2. A legal review is presented in Section 3, following which the audit findings are presented in Sections 4, 5 and 6 under the following headings: Water and Effluent Management Solid Waste Management Air Quality Management Hazardous Materials Management Legal and regulatory compliance General Environmental Practice Assessment of Potential Impacts to Environment Summary of key issues identified

1.3 CLASSIFICATION OF AUDIT FINDINGS

Issues that have been identified in this audit have been classified as either regulatory issues, or those which address good health, safety and environment management practices. Each finding is further categorized as either Category I, II or III and a time-frame in terms of corrective action is indicated as per the classification system outlined below.

Significance

The significance of the audit findings are classified as either;

Regulatory (R): a finding resulting from potential variance with governmental laws, ordinances, or regulations

Good Management Practice (GMP): a finding resulting from a variance with company policies or good management practices.

Category

CATEGORY I - An incident/issue which has or potentially has high health, safety or environment impairment on the public, employees, environment, the Company and its reputation.

CATEGORY II - An incident/issue which has or potentially has moderate health, safety or environment impairment on the public, employees, environment, the Company and its reputation.

CATEGORY III - Procedural matter with no HSE impact or incident/issue with low potential for impairment on people or the environment.

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Timeframe

For each recommendation a priority is assigned as follows which indicates the timeframe within which action should commence:

Immediate (within 3 months)

Short term (3-12 months)

Medium term (1-3 years)

Long term (3 or more years)

This enables the facility to assess the period in which a response is required.

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2 General Background

2.1 SITE DESCRIPTION AND HISTORY

The site is located within the Sacks Circle Industrial Area of South Belville, Cape Town and is approximately 4,047 m2 in extent. The area is characterised by medium-industrial businesses. The site is bordered to the north by Inde Plastics, a plastic manufacturer and Western Cape Milling on the southern side of the property. The Cape Peninsula University of Technology (CPUT) Sports fields lie approximately 500m west of the site. A sewage treatment plant lies approximately 200m to the south of the site and a railway line lies approximately 600m south- east of the site.

The site coordinates are: 33°55’46.25’’S; 18°39’14.55’’E

The site has a slight gradient of <0.5° sloping towards the east of the site, and is situated at approximately 60m above sea level. L A Fuels recycle spent lubricating oils for use as heating fuel. The recycling process includes a series of physical separation and evaporation steps that remove free water and particulates from the oil.

The site infrastructure consists of the following;

Buildings – the site has one main office building used for administration

purposes and a small area for servicing of equipment. The main office building also houses a small laboratory space.

Storage Tanks – ten above ground storage tanks with a total capacity of

223.5m3 of product (including 25m3 of flammable product and 198.5m3 of non-flammable product). All storage tanks are fully bunded.

Bunded Storage Area – for the storage of oils and solvents in flow bins and

barrels. Effluent Handling - the facility has two oil/water separators on site. All

stormwater from bunded areas on site is drained to sewer. The buildings on site (which include an administration building and factory) cover an area of approximately 600m2. The remainder of the site comprised of storage area and access roads.

The site processes approximately 50-60m3 of oil per month. This capacity is expected to increase in the future but will not exceed 200m3. L A Fuels contracts a small number of oil collectors to collect the waste oils delivered to site. The oil is collected in flow bins loaded onto the back of small trucks and delivered to the site. Collected oils are received by trucks carrying 1000 litres to 9000 litres of oil at one time. The trucks are connected to the tanks via pipe. The oil undergoes filtration to remove any solids before being pumped to a centralised collection storage tank. Processing includes heating and centrifugal action to remove water and particulates prior to being pumped to final storage.

2.2 SITE HISTORY

The site history of the L A Fuels site is complex. The first business operating from this site was a chemical company, named Comar Chemicals, which had permission from the local authority to conduct its business, which included handling and storage of bulk flammable liquids. This business vacated the premises and the initial industrial waste solvent recycling was done, to start with, by Fuel Firing Systems (FFS), when the company commissioned the current industrial waste solvent recycling plant, at 1 Spin Street, by mid-2001. In 2004, FFS decided to exit from waste solvent recycling, and

8 20382

offered to sell the business and equipment to Ecoservices (solvent processors). LA Fuels began operating at the site in 2007 as Ecosolv CC t/a LA Fuels.

The site was in operation with both L A Fuels and Ecoservices operating on the site until November 2009. During this time, the operations involved the storage of approximately 46 000L at any one time of used industrial mineral oils in above ground storage tanks.

In November 2009 the site was devastated by a fire. Following the fire, the entire site was rebuilt and resumed operations as an oil and solvent processing facility in November 2010.

The site operations were not authorised in terms of the National Environmental Management Act (NEMA) prior to the fire. A Section 24 (g) rectification application was submitted, but subsequently withdrawn in October 2009 by one of the previous tenants at the site. In November 2009, L A Fuels and Ecoservices proceeded to engage with DEADP and an EAP (SEC Consulting) to carry out said rectification.

The new site, although almost completely rebuilt following the fire also does not have an ROD from the relevant authority in terms of the National Environmental Management Act No 107 of 1998. A Section 24 (g) application was finally submitted to DEADP on the 7 April 2011.

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3 Summary of Permits and Authorisations

Authorisations have been granted for the following:

Flammable Substance Certificate – Application submitted to City of Cape Town (Approved 17th February 2011)

Applications have been submitted for the following:

Section 24 (g) Rectification – Application submitted to DEADP (submitted 7 April 2011) Reference number: E/18/2/3/2/2.

Certificate of approval in terms of Section 13 of the City of Cape Town Air Quality Management by-law, 2010 - Application submitted to City of Cape Town (18th November 2010)

Effluent Discharge Permit – Application submitted to City of Cape Town (23rd November 2010)

Major Hazard Installation – A full report was submitted to the Provincial Director of Labour in the Western Cape, and received by Me. Mashuvho Makhado of the Directors Office on the 4th of October 2010. No approval as yet.

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3.1 LEGAL COMPLIANCE

3.1.1 National Environmental Management Act (107 of 1998)

L A Fuels did not have Environmental Authorisation prior to the site re-build.

Listed activities relevant to the site according to the old NEMA regulations (effective up to 2 August 2010) requiring basic assessment authorisation (Government Notice No. R386 activities) and Scoping & EIA authorisation (Government Notice No. R387 activities) include:

Government Notice. 386

1 (p) The construction of facilities or infrastructure, including associated structures or infrastructure, for – the temporary storage of hazardous waste; and

(7) The above ground storage of a dangerous good, including petrol, diesel, liquid petroleum gas or paraffin, in containers with a combined capacity of more than 30 cubic metres but less than 1 000 cubic metres at any one location or site.

Government Notice 387

1 (g) The construction of facilities or infrastructure, including associated structures or infrastructure, for – the use, recycling, handling, treatment, storage or final disposal of hazardous waste;

Following site re-build and subsequent resuming of site operations, L A Fuels do not have an Environmental Authorisation in terms of the National Environmental Management Act (Act No 107 of 1998) (as amended 2 August 2010) and Government Notice (GN) 544 and GN 545.

Listing Notice 1 (Government Notice 544) Requiring a Basic Assessment (13) The construction of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic meters.

Listing Notice 2 (Government Notice 545) Requiring an Environmental Impact Assessment (4) The construction of facilities or infrastructure for the refining, extraction or processing of gas, oil or petroleum products with an installed capacity greater than 50 cubic meters or more, excluding facilities for the refining, extraction or processing of landfill gas.

(5) The construction of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice no 544 of 2010 or included in the list of waste management activities published in terms of Section 19 of the NEM:WA (59 of 2008) in which case that act will apply.

WSP Comment

L A Fuels has been operating at the facility since 2007, and therefore requires an authorisation under all of the above legislation. No such authorisation was available at the time of the audit. A Section 24 (g) Rectification application has been submitted to DEADP. An EIA process should have been followed when the site was re-built in 2009/2010. It is anticipated that DEADP will require a similar process to be followed for rectification purposes. Progress against this requirement must be demonstrable at the time of the next audit.

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L A Fuels comment

An application for a Section 24(g) Rectification was submitted in early April 2011. The application was completed by Sillito Environmental Consulting (SEC). Evidence of the application has been seen by WSP. Awaited reference number has since been received, and an authorisation process will follow.

3.1.2 Waste Management License

The site commenced operations in around 2000 and therefore under Section 20 of the Environmental Conservation Act (ECA) would have required a permit. Section 20 of ECA states,

(1) No person may establish, provide or operate a disposal site without a permit issued by the Minister... ‘

Where a disposal site is defined as

‘a site used for the accumulation of waste with the purpose of disposing or treatment of such waste.’

In March 2009 the National Environmental Management Waste Act (NEM:WA) came into effect repealing Section 20 of ECA. General Notice (GN) 718 was issued under NEM:WA the defines activities to be regulated.

The following activities outlined in GN718, relate to the activities at the L A Fuels site:

Category ‘A’ Activities (requiring a Basic Assessment)

(2) The storage including the temporary storage of hazardous waste at a facility that has the capacity to store in excess of 35m3 of hazardous waste at any one time, excluding the storage of waste in a lagoon.

Category ‘B’ Activities (requiring an Environmental Impact Assessment)

(2) The re-use and recycling of hazardous waste.

(3) the recovery of hazardous waste including the refining, utilisation or compressing of waste at a facility with a capacity to process more than 500 kg of hazardous waste per day excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises or unless the minister has approved the re-use guidelines for the specific waste stream.

WSP Comment

L A fuels is not in possession of a Waste Management Licence and the site is therefore operating illegally at present. An EIA process will be required to obtain the Waste Licence and should be done concurrently with the Environmental Authorisation process required in the 24(g) rectification process or authorisation process followed. Progress against this requirement must be demonstrable by the time of the next audit.

L A Fuels Comment

LA Fuels are awaiting comment from DEADP regarding the procedure to be followed regarding the application for rectification in terms of Section 24(g).

3.1.3 Air Emissions License

A boiler is present on-site and represents the only point source of air emissions. The boiler is powered by illuminating paraffin and low sulphur industrial heating fuel and has a capacity of 0.002MW. An application for a Certificate of Approval in terms of Section 13 of the City of Cape Town Air Quality Management By-law 2010 has been submitted to the City of Cape Town.

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An Air Emissions Licence under the NEM:AQA will not be required as long as the boiler on site has a capacity of less than 50MW, the oils stored on site do not exceed 500 tons capacity and the monthly throughput of processed oils does not exceed 5000 tons.

WSP Comment

Progress against this point is expected by the time of the next audit.

L A Fuels Comment

L A fuels is awaiting approval for the application submitted to the City of Cape Town for approval of said fuel burning appliance on the 18th November 2010.

3.1.4 Occupational Health and Safety

OCSA completed an Occupational Health medical Service Surveillance for period of 2008 and 2009 for the site. However no further OHS audit reports were available.

The Occupational Health and Safety Act of 2003 states that Hazardous Chemical Substances, Noise and Illumination surveys are required.

WSP Comment

The surveys are required on minimum of a biannual basis. They have yet to be undertaken and therefore this should be made a priority.

L A Fuels Comment

N/A

3.1.5 Compliance to Bylaws

Industrial Effluent

Section 5 of the of the City of Cape Town Municipality Waste Water Bylaws states:

No person may, except with the written consent of the Council, and subject to such conditions it may impose:—

(a) discharge or permit the discharge of industrial effluent directly or indirectly into any wastewater system;

(b) increase, or permit to be increased, the quantity or vary, or permit to be varied, the nature, content or composition of any industrial effluent in contravention of the conditions imposed by the council, or

(c) contravene, or permit to be contravened, any other condition imposed by the council when consent was granted to discharge industrial effluent.

WSP Comment

The facility has submitted an application to the City of Cape Town to dispose of the industrial effluent to sewer. Progress is required against this point by the time of the next audit.

L A Fuels Comment

An application for an Industrial Effluent Permit was submitted to the City of Cape Town on the 23rd November 2010 and awaits further comment.

Fire Safety

Section 38(1) of the City of Cape Town Bylaw Relating to Fire Safety states that the site requires a flammable substance certificate.

WSP Comment

The above legislation indicates that the site requires a flammable substances certificate.

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L A Fuels Comment

L A fuels submitted an application for flammable substance certificate for storage of 50,000L., the application was approved on 17th February 2011.

Major Hazard Installation

The facility has been assessed for its status as an MHI facility in accordance to Section (3)6 of the Major Hazard Installation Regulations R.692 of 30 July 2001.

The full report was submitted to Provincial Director of Labour in the Western Cape on the 4th of October 2010 and approval is awaited.

WSP Comment

Progress is required against this point by the time of the next audit.

L A Fuels Comment

The full report was submitted to the Provincial Director of Labour in the Western Cape, and received by Me. Mashuvho Makhado of the Directors Office on the 4th of October 2010.

Simultaneously a registered parcel with the Post Office Waybill number PA358 346 445 ZA was despatched to The Chief Inspector of Labour in Pretoria on the same day.

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4 Audit Findings

4.1 WATER AND EFFLUENT MANAGEMENT

4.1.1 Water Supply

All water usage on the property is from municipal supply and there are no boreholes on site. There is no process related water usage, and therefore water usage is primarily for domestic consumption, ablutions and cleaning of the plant and equipment. 4.1.2 Waste Water

No waste water is generated from the oil processing, since excess water is removed from the oil through evaporation and released to the atmosphere. The major effluent producing process originates as cooling tower drainage (250 litres water removed once every four weeks) and blow down from the boiler (20-30 litres of water removed once per day). The effluent is fed into the on-site oil-water separator before passing into the municipal sewer. All rain water build up from bunded areas is checked for pH and inspected for oil contamination before being released to the sump if contaminated with oil. When the water is clean it is released to the general storm water area of the specific bund. The water is reportedly pH monitored at the separator sump on a daily basis before discharge, and boiler/ cooling tower water is reportedly monitored on a weekly basis. 4.1.3 Stormwater

The property consists of a mixture of hardstanding and gravel. All tanks and storage containers are situated on bunded hardstanding. L A Fuels has a designated offloading area on a bunded hardstanding, within which all oils are received. All uncontained stormwater drains off-site through stormwater drains. All bunded/contained areas drain to the separator sump at the south-east corner of the site. The water passing through the oil-water separator is then disposed of to the municipal sewer. It is recommended that during offloading of incoming oils, all run-off from the offloading area is handled as effluent along with the boiler blow down and is diverted to a separate sump for effluent treatment or storage for disposal. An application to discharge industrial effluent has been submitted to the City of Cape Town, at present cooling tower drainage and blow down from the boiler is discharged to municipal sewer without the appropriate permit from the municipality. It is anticipated that once a permit is granted it will contain stipulations for effluent discharge standards. At this stage, on-site monitoring and subsequent treatment may be necessary to fall within stipulated discharge limits. Alternatively, the effluent could be collected and periodically delivered to an appropriate treatment facility. Safe disposal certificates to indicate correct disposal would be required. 4.2 SOLID WASTE MANAGEMENT

Hazardous wastes include sludges are produced during the oil processing (from the centrifuge process) and build-up in the oil-water separator. L A Fuels reports that there has not been a need to dispose of this waste thus far, and volumes of sludge have been manageable to the point that it can still be stored in 44 gallon drums on site. L A Fuels have been provided with quotes by ‘Interwaste’ for safe disposal. However at the time of

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the audit, volumes of waste had not been sufficient to warrant collection. L A Fuels were considering ways which the oil may be used as a boiler fuel source. L A Fuels report that there is very little hazardous solid waste produced on site. Oily rags are reportedly washed in solvents and re-used. Oily rags and other miscellaneous contaminated materials are placed in 44 gallon drums prior to disposal. A closed container is recommended for such hazardous wastes which should be removed by a registered waste carrier for safe disposal at a licenced Waste Disposal Site at appropriate timeframes. A general waste skip was available on site for non-hazardous, which is removed by ‘bin-it’ on a 2-3 month timeframe. 4.3 AIR QUALITY MANAGEMENT

4.3.1 Point Source Emissions

A boiler is present on-site and represents the only point source of air emissions. The boiler is powered by illuminating paraffin and low sulphur industrial heating fuel. 4.3.2 Fugitive emissions

There were a number of open trays of oils/ sludge’s on site that present a potential source of fugitive emissions. It is recommended that these trays have at least partially covering lids to prevent harmful levels of volatile organic compounds (VOC’s). 4.4 HAZARDOUS MATERIALS MANAGEMENT

4.4.1 Transport and Handling

Collection of used oils is subcontracted by L A Fuels to a number of small owner-drivers. A vehicle was delivering at the time of audit, and although it was not inspected, it was noted that the vehicle was not using a drip tray. It is recommended that L A Fuels request that collectors make use of safety equipment such as drip trays, PPE and have spill equipment available at all times when delivering to site. The drum offloading area represents the area of highest importance as significant spillage occurs in this area is an unavoidable consequence of the nature of the operation. The tanker off-loading area is currently situated on a designated area on hardstanding with appropriate bunding. 4.4.2 Storage

All storage tanks are located within fully bunded areas. The condition of the tanks, bunding and hardstanding infrastructure on site is very good, since the site was almost completely re-built following the fire. 4.4.3 Spill Management, Fire Fighting and Emergency Response

The site does have an Emergency Management Action Plan for fire, spills, explosions and hazardous chemical incidents. The site is well equipped with fire extinguishers- and staff have reportedly been trained in fire safety. Spill management equipment on site includes a spill kit, as well as an additional 5m3 of sand and 10 m3 of sawdust available on site at all times. 4.5 GENERAL ENVIRONMENTAL PRACTICE

The site does not have an operational EMS yet, as such no incident records were available. L A Fuels does wish to obtain ISO 14001 accreditation in the future. General housekeeping on site is good and there appears to be a strong commitment towards becoming compliant with the relevant and required legislation.

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4.6 EXTENDED PRODUCER RESPONSIBILITY

Extended producer responsibility is defined in the NEM: Waste Act (Act 59 of 2008) as: Measures that extend a person's financial or physical responsibility for a product to the post-consumer stage of the product, and includes— (a) Waste minimisation programmes; (b) Financial arrangements for any fund that has been established to promote the reduction re-use. Recycling and recovery of waste; (c) Awareness programmes to inform the public of the impacts of waste emanating from the product on health and the environment: and d) Any other measures to reduce the potential impact of the product on health and the environment; In terms of the requirements of the Section 18 of the NEM: Waste Act (Act 59 of 2008), “The Minister after consultation with the Minister of Trade and Industry may....identify a product or class of products in respect of which extended producer responsibility applies.” However invoking mandatory EPR as per Section 18 of the Waste Act is an interventionist measure which will be applied when industry self-regulation through an industry waste management plan or other measures have failed. The operation at L A fuels is very recent. There was no discussion regarding company policy or assurance that for downstream users. The following suggestions may be of use to L A Fuels for the future;

Before a product is delivered to site, a technical advisor from L A Fuels should check the installation (product storage tank) and ensure that it is within a bunded area and is acceptable to store product in.

Maintain records and supporting documentation to confirm that the above steps are undertaken.

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5 Assessment of Potential Impacts to Environment

5.1 AIR QUALITY

There are emissions associated with the burning of industrial heating fuel at the boiler. No monitoring has been carried out therefore the ambient air quality impacts cannot be assessed at this time. However no strong smells were encountered during the audit. As stated, there were a number of open bins containing oils and sludges. These open trays are sources of fugitive emissions for volatile organic compounds (VOCs). The main concern would be health impacts to employees through inhalation of the volatile compounds. It is suggested that these trays are at least partially covered to limit the venting of VOCs to the atmosphere. 5.2 SURFACE WATER QUALITY

Potential impacts to surface water include run-off from the offloading areas, and other areas which may become contaminated by spills and leaks that are not captured by the formal capture system. It is recommended that monitoring of stormwater quality should be considered as there is no available data by which to assess the effectiveness of the current water management plan in terms of separating clean and contaminated run-off from the plant. Water from the loading/offloading areas should be captured and treated as effluent along with boiler blow down water. 5.3 GROUNDWATER

Potential soil and groundwater contamination was possible through accidental spills during fuel dispensing, road tanker refuelling or line/tank failure. The storage tanks were located in bund areas of sufficient capacity as per oil industry standards. As stated previously, there were therefore measures in place to contain any spillage and prevent contamination of soils by product into the surrounding soil and groundwater in the event of an incident A baseline soil and water contamination exercise was carried out by Sillito Environmental Consulting on the 9 July 2010. The assessment was required after a fire destroyed the main factory building at the site in November 2009. The local planning authority were concerned that the fire and resulting loss of containment of certain storage containers may have led to contamination of the sub-soils and groundwater, the latter possibly requiring the removal of such material. Should such a scenario occur, the planning authority were concerned that some of the building may need to be removed and were thus reluctant to give planning approval until this had been assessed. The results of the study concluded that sub-soil or groundwater remediation would not be necessary at the site as a result of the fire and assuming that all receptor pathways have been blocked through a proper bunding containment system, there should be limited further exposure in these areas. 5.4 GROUND CONTAMINATION

Previous soil investigations confirmed hydrocarbon odour in the soils underlying the site, although not at levels warranting remediation. Unless all areas where potential contamination exists are placed under hardstanding and high levels of housekeeping (i.e. spill clean-up) in this area are maintained, it can be expected that subsurface soil contamination will eventually result. It is advised that the costs of upgrading

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hardstanding in all areas, and maintaining their integrity will be substantially less than the cost and liability associated with remediation of the property at a future time. All oil storage areas are bunded according to industry standards and under hardstanding. The structures appeared to be in good condition, and therefore the risk of contamination from tank leakage/failure is considered to be low. 5.5 OIL SAMPLES

Representative incoming and outgoing oil samples were taken from the site for inclusion on the SA Waste Registry. The results of the analytic testing carried out by M & L Laboratory Services are provided in Appendix A.

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