Legacy Environmental Management Consulting (Pty) Ltd (Legacy EMC) has been appointed by WorleyParsons Group t/a Advisian on behalf of its client, Oiltanking MOGS Saldanha (RF) (Pty) Ltd (OTMS), as the independent consultants to undertake the External Environmental Compliance Audit (audit) as required in terms of the conditions of the environmental authorisation (EA) issued by the relevant Competent Authority, namely the Western Cape Department of Environmental Affairs and Development Planning (DEADP) Directorate: Development Management (Region 1).
Introduction and Background
The EA and EA Amendment was issued in respect to the proposed OTMS HDPE Seawater Pipeline Route, Saldanha, Western Cape.
OTMS received an EA for the construction of a crude oil blending and storage terminal on Portion 5 of Farm Os Fontein No. 194, Saldanha Bay, Wester Cape on 6 February 2014 (EA Ref.: E12/2/4/2- F4/16- 3035/11). This EA includes a sub-surface crude oil pipeline from the OTMS Crude Oil Terminal to the Strategic Fuel Fund (SFF) Crude Oil Terminal pipeline servitude. Construction of the OTMS Crude Oil Terminal is currently underway.
OTMS was further granted an EA for the construction of a HDPE Seawater Pipeline and associated infrastructure from the OTMS Crude Oil Blending and Storage Terminal (OTMS Terminal) to the Seawater Pipeline Intake Pump Station located at the disuse Oyster Pond east of the Port of Saldanha, for the purposes of hydrostatic testing of the OTMS Terminal tanks. Thereafter the seawater pipeline will serve as a backup fire management system to the OTMS Terminal as well as the SFF Terminal. The pipeline will not exceed 8 km and will have an internal diameter of 400 mm. Environmental Authorisation for this pipeline was issued by the Department of Environmental Affairs and Development Planning (DEADP) on 31 August 2017 (DEADP Ref No.: 16/3/3/2/F4/17/3064/16).
Since the EA for the HDPE Seawater Pipeline and associated infrastructure was issued, ArcelorMittal South Africa (AMSA) received an EA for the construction of a brine discharge pipeline and a gas pipeline from Saldanha Steel to the bay, providing an alternative servitude. OTMS, with the support of AMSA, applied for an amendment of the EA for the HDPE Seawater Pipeline to reroute the pipeline to the AMSA servitude, and this EA was granted on 26 September 2018 (DEADP Ref. No.: 16/3/3/5/F4/17/3019/18).
External Audit Process
As per Condition 20 of the EA dated 31 August 2017 and subsequent amendment dated 26 September 2018, independent environmental audits must be undertaken to determine compliance with the conditions of the EA and the approved Environmental Management Programme (EMPr), in accordance with Appendix 7 of the National Environmental Management Act (Act No. 107 of 1998) (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014 (as amended). In addition, the Environmental Audit Reports must be submitted to the CA for consideration.
Legacy EMC’s Scope of Work entails compliance of the Environmental Audit Report, however the submission to the CA and notification to Interested and Affected Parties (IAPs) of the availability of the Environmental Audit Report has not been included in Legacy’s Scope of Work.
The conditions of the EA and the EMPr have been tabulated and are used throughout the audit to assess the compliance of the project in terms of the conditions.
The approved Pre-Construction, Construction and Operational EMPr for the OTMS HDPE Seawater Pipeline Route, Saldanha (August 2018) provides management guidelines for the construction methodology and construction works of the project, to ensure environmental impacts are monitored and minimised where possible. The EMPr sets out the proposed project, Environmental Objectives to reach the Goals, Targets and Management Actions.
The EMPr incorporates the recommendations of the Environmental Impact Reporting Process and its appended specialist and technical reports, in respect of the various mitigating measures to be implemented during the construction and operational phases. The EMPr covers pre-construction, construction and post-construction (operational) phases for the project.
This Environmental Compliance Audit Report assessed the current conditions on site against the mitigation measures and management actions included in the EMPr, as well as the application and adherence to the Conditions of Authorisation of the EA and amended EA (dated 31 August 2017 and 26 September 2018, respectively).
Recommendations and Conclusion
There is no need to amend the approved EMPr, following the compliance audit conducted within the first three months of commencement of the construction phase. The next audit report will be conducted after completion of the development phase.
Legacy EMC is of the professional opinion that minor updates to the EMPr are necessary to address and mitigate any negative environmental and socio-environmental impacts that might arise during the current construction phase of the HDPE Seawater Pipeline, and that these amendments are needed for the EMPr to meet all the environmental objectives. No significant issues were noted during the compliance audit inspection, and the minor issues can be easily addressed.
Partial Compliances noted during the audit inspection included the presence of alien invasive species on the topsoil stockpiles, topsoils not shaded, trimming and shaping of servitude required, and excavations without demarcation / barricades.
The entire report is available below.OTMS Sewater Pipeline External Audit Report_Nov 2018