While there is a drive from indus- tries to become more eco- friendly, many small companies are not aware of the current environmental regulations under the National Environ- mental Management Act, No 107 of 1998, which require an environmental-impact assessment (EIA) to be undertaken before the installation of a storage tank aboveground or underground, reports Responsible Packaging Management Association of South Africa president Liz Anderson.
“Ignorance of the law is not an excuse, but, unfortunately, there are those who do not have sufficient information to be compliant with the law,” she explains.
The new EIA regulations will replace existing regulations in August and were promulgated because of interpretation problems with the old rules and also to accommodate the changing legal regime relating to mining and the environment.
The existing 2009 activities listings under notice 1 R166 of the Act include regulation 1r, which states that authorisation is required for storage of dangerous goods with a combined capacity of more than 100 m³ in industrial areas and more than 50 m³ in other areas. This regulation has been replaced with R544, activity 13 for construction, activity 27 for decommissioning and activity 42 for expansion. There is no differentiation between aboveground and underground storage.
The regulations require an applicant to put an environmental management plan (EMP) in place and to monitor compliance against this. Similarly, decommissioning at the end of a storage tank’s life requires an EIA and an EMP to be undertaken to monitor safe decommissioning and removal to prevent pollution.
Anderson says that any company that deals with chemicals or petrochemicals has to factor in the potential pollution risk to the environment and the related financial risk.
“Companies wish to avoid expensive spills at all costs. Normally, before installing a tank of 5 000 ℓ and upwards, an EIA has to be passed by the provincial authority, which, today, includes a public participation process,” she adds.
The cost and time required for an EIA could be challenging for companies but, when considering the costly risk that is avoided, these challenges become worthwhile, says Anderson.
Companies will benefit from compliance with environmental regulations in that it protects the environment and ensures the safety of individuals through the prevention of spills and leakages that create pollution, as well as reduces financial risk, which includes the payment of fines and the cost incurred when cleaning up a spill.
Anderson says that about 30 years ago, underground tanks, such as those used at petrol stations, were buried without any precautions being taken. However, in the past ten years, regulations and standards came into effect to prevent environmental damage caused by leak- ing underground tanks. The regulations require that underground tanks be placed in a contained hole that has been sealed with cement or bricks and that the space around the tank be filled with an inert material to prevent chemicals from seeping into the earth.
She explains that, currently, there are not many chemicals that are stored below ground. Most chemicals are stored in aboveground tanks, as it is a better practice and problems are more easily dealt with, because leaks are more visible. However, fuel tanks are still not kept above ground, as it is more convenient to store these tanks underground in residential areas.
Further, she explains that, aboveground tanks must have a bund, a surrounding wall that can contain at least one-third of the tank’s contents if there is a leak or spill. As part of routine maintenance, com- panies should undertake engineering inspections of tank valves, flanges and pumps to ensure that there are no leaks.
The South African National Standards pertaining to the installation of a storage tank include Sans 310, which requires that an aboveground storage tank be of sufficient structural strength, based on sound engineering practices, to withstand normal operations and use; Sans 1668, for fibre-reinforced plastic tanks for the underground storage of petroleum products; Sans 10089-1, which deals with the storage and distribution of petroleum products in aboveground bulk installations; and Sans 1535, for glass- reinforced polyester-coated steel tanks, for the underground storage of hydro- carbons and oxygenated solvents, which are intended to be buried horizontally.
Further, a tank, as well as seals, pipes and fittings, is required to be chemi- cally compatible with the hazardous substance being stored in it, protected from, or resistant to, all forms of internal and external wear, vibration, shock and corrosion; have a stable foundation or support structure suitable for all operating conditions; be protected from fire, heat, vacuum and pressure, which might cause tank failure; and be sized to suit process and storage requirements.