contaminated site assessment

Annex J

Contaminated Site Assessment

Delivering sustainable solutions in a more competitive world

ENVIRONMENTAL RESOURCES MANAGEMENT BURGAN CAPE TERMINALS

I

EXECUTIVE SUMMARY

Burgan Cape Terminals (Pty) Ltd (“Burgan Oil”) appointed Environmental Resources Management Southern Africa (Pty) Ltd (“ERM”) to conduct a contamination assessment of the site of their proposed bulk fuel storage facility to be located on the Eastern Mole, Port of Cape Town, as part of the Environmental Impact Assessment (EIA) for the proposed facility. ERM conducted a desktop study to understand the site history and identify factors which may account for present site conditions. This was followed by the excavation of 22 trial pits and the collection of soil samples for laboratory analyses. Samples were analysed for metals and petroleum hydrocarbons and the results compared against screening values proposed for commercial / industrial sites by the South African Department of Environmental Affairs (DEA). The site is located on land reclaimed between 1992 and 2000 and constructed through the back-filling of material including building rubble, tar, and concrete into the harbour. No development has been conducted on the site since reclamation, nor is there is any record of the storage or handling of metals or petroleum products on the site. Analyses for hydrocarbons including mono-aromatic hydrocarbons (MAH) and total petroleum hydrocarbons (TPH) returned results below the laboratory detection limit in most trial pits. Concentrations of hydrocarbons identified in trial pits are lower than the relevant screening values and are not considered to pose a health or liability risk to the proposed Burgan Oil operations. Metal concentrations in the soil are more variable, which is understandable given the heterogeneous nature of the materials used as backfill during the construction of the site, however these are also below the relevant screening criteria. A conceptual site model was prepared to identify sources of impact, exposure pathways and potentially sensitive receptors that could be affected by hydrocarbons. The partially consolidated nature of the backfill and the inherent permeability thereof, coupled with the location of the site (~3m above sea level in the harbour), suggest that potential hydrocarbon releases on site would migrate vertically downwards from the source until it comes into contact with the water table within the fill from where it could, depending on the construction of the Eastern Mole, migrate laterally into the harbour. An environmental impact assessment (EIA) was prepared based on the present site conditions, the conceptual site model, and the proposed bulk fuel storage project. Potential contamination of soil or groundwater from fuel or oil releases is considered moderate negative during the construction phase and high negative during the operational phase. These may be reduced to low negative for both phases through the implementation of the proposed mitigation measures. The installation of groundwater monitoring wells prior to the operational phase is recommended as an early warning system for monitoring potential impact resulting from the operations on site.


II

GLOSSARY OF TERMS

BDL Below (laboratory) detection limit CAT Cable avoidance tool CFA Cape Flats Aquifer COPC Chemicals of potential concern CSM Conceptual site model DO Dissolved oxygen DRO Diesel Range Organics DEA Department of Water Affairs DWA Department of Water Affairs EC Electrical conductivity EIA Environmental Impact Assessment ERM Environmental Resources Management Southern Africa

(Pty) Ltd GN Government Notice GPR Ground penetrating radar GRO Gasoline range organics HASP Health and safety plan K&T Kantey and Templer (Pty) Ltd. m metre MAH Mono-aromatic hydrocarbons mamsl meters above mean sea level mg/kg dm milligrams per kilogram of dry matter NGA National Groundwater Archive PSH Phase separated hydrocarbons pH -log[H] PID Photo-ionisation detector SPT Standard penetration test SSV2 Soil screening values (commercial/industrial) TLB Tractor-loader-backhoe TNPA Transnet National Ports Authority TPH Total petroleum hydrocarbons TP Trial pit USEPA United States Environmental Protection Agency VOC Volatile organic compound -ve Negative


III

CONTENTS

EXECUTIVE SUMMARY I

GLOSSARY OF TERMS II

CONTENTS III

1 INTRODUCTION 5

1.1 BACKGROUND INFORMATION 51.2 PREVIOUS WORK 51.3 SCOPE OF WORK 61.4 SITE SETTING 6

2 METHODOLOGY 9

2.1 PHASE 1 (DESKTOP) 92.2 PHASE 2 (SOIL SAMPLING BY TRIAL PITTING) 9

3 RESULTS OF ASSESSMENT 13

3.1 SUB-SURFACE CLEARANCE, TRIAL PIT EXCAVATION & FIELD OBSERVATIONS 133.2 LABORATORY RESULTS 13

4 DISCUSSION AND INTERPRETATION 16

4.1 HYDROCARBONS 164.2 METALS 164.3 CONCEPTUAL SITE MODEL 174.4 IMPACT ASSESSMENT 22

5 CONCLUSIONS 25

6 RECOMMENDED FUTURE WORK 26

6.1 OVERVIEW 266.2 ODEX DRILLING FOR SOIL AND WATER SAMPLING 266.3 INSTALLATION OF MONITORING WELLS 27

7 LIMITATIONS 29

8 REFERENCES 31


IV

LIST OF TABLES

Table 1.1 Site setting of the Burgan Oil site on the Eastern Mole, Port of Cape Town 7Table 2.1 Schedule of analyses conducted on soil samples 11Table 3.1 Summary of hydrocarbon analytical results of soil samples from trial pits 14Table 3.2 Summary of metals analytical results of soil samples from trial pits 15Table 4.1 Potential sources, transport mechanisms and sensitive receptors based on current site

conditions & project brief 20Table 4.2 Pre- and post-mitigation significance of soil or groundwater contamination impacts

from fuel or oil spill 24

LIST OF FIGURES

Figure 1.1 Location of the proposed bulk Burgan fuel storage terminal on the Eastern Mole, Port of Cape Town 8

Figure 2.1 Location of trial pits and infrastructure adjacent to Burgan fuel storage terminal on the Eastern Mole, Port of Cape Town 12

LIST OF ANNEXURES

ANNEX A HEALTH AND SAFETY PLAN ANNEX B GROUND PENETRATING RADAR SURVEY ANNEX C LABORATORY ANALYTICAL REPORTS ANNEX D PHOTOGRAPHIC LOG


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1 INTRODUCTION

1.1 BACKGROUND INFORMATION

Environmental Resources Management Southern Africa (Pty) Ltd (hereafter referred to as “ERM”) was commissioned by Burgan Cape Terminals (Pty) Ltd (hereafter referred to as “Burgan Oil”) to conduct a contaminated site assessment of their site on the Eastern Mole, Port of Cape Town. This study formed part of the Environmental Impact Assessment (EIA) for the proposed bulk fuel storage facility to be located on the Eastern Mole (“the site”). The purpose of the contamination assessment study was to provide a baseline of the site conditions against which future changes can be compared. The aim of the assessment was to determine the presence / absence of petroleum hydrocarbons including gasoline range and diesel range organics, as well as selected metals, in soil and groundwater. The Eastern Mole was reclaimed in various stages between 1992 and 2000 through the back-filling of material including building rubble, tar, concrete, bricks, and other rubble set in a loose matrix of gravel, sand and silt (K&T, 2013a). Reclamation is understood to have been achieved by end-tipping in the north-westerly and north-easterly direction from the existing Portside Road without any form of compaction. No construction has taken place on the site since it was reclaimed, hence the proposed Burgan Oil bulk fuel storage terminal would constitute the first development of this portion of the Eastern Mole. There is no record of previous hydrocarbons spills on or adjacent to the site.

1.2 PREVIOUS WORK

Known previous studies which have been performed at the site are summarised below.

1.2.1 Kantey & Templer Geotechnical Report (2013a)

In 2013, Kantey and Templer Consulting Engineers conducted a geotechnical study of the site of the proposed bulk fuel storage terminal (reference number 13112P). The assessment focussed on the site geology and rock/soil profile, the groundwater conditions, and the geotechnical founding conditions at the site. It involved the drilling of four cored (diamond) boreholes to between 24 and 34m depth, and the execution of standard penetration tests (SPT) to assess the competency of the material.

1.2.2 Kantey & Templer Drainage Philosophy Report (2013b)

Kantey & Templer defined the overall philosophy of the drainage system to be implemented on the various portions of the site. It detailed the portions into which the drainage stream would be segregated (e.g. oily water & storm water), estimated peak flows of these on the site, and provided details of the oil-water separators and flush basins to be constructed.


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1.3 SCOPE OF WORK

The baseline soil and groundwater contamination assessment will be achieved through a three phase approach, as follows:

• Phase 1 assessment involving a desktop study and site reconnaissance visit;

• Phase 2 intrusive assessment involving soil sampling through the excavation of trial pits; and

• Phase 3 intrusive investigation involving the installation of groundwater monitoring wells and the sampling of groundwater.

The Phase 1 assessment involved the collation of available information about the site and the proposed work (section 2.1). The Phase 2 assessment involved the excavation of trial pits for soil sampling (section 2.2). Phase 3 will involve the installation of groundwater monitoring wells and the sampling and analysis of groundwater (Chapter 6), and it is anticipated that this will be conducted prior to the construction of the facility. This report details the findings of Phases 1 & 2 of the project, and provides recommendations for Phase 3. Details of methodologies employed are provided in Chapter 2; the results of the assessment in Chapter 3; and a discussion and interpretation of the results in Chapter 4. Conclusions from this study and recommendations for future work are provided in Chapter 5 & 6 respectively.

1.4 SITE SETTING

The site of the proposed Burgan bulk fuel storage depot is located at the north-western portion of the Eastern Mole, in the Port of Cape Town (Figure 1.1). The site is divided into two portions separated by the FFS Refiners facility. The coordinates at the centre of the larger, north-western portion of the Burgan site are: 33°54’35.90”S and 18°26’17.39”E. The site is bound to the east and west by the harbour, and to the southeast industrial facilities as detailed below. Complete site settings including information on the physical conditions, as well as the surrounding land use and potential sources of contamination, are provided in Table 1.1.


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Table 1.1 Site setting of the Burgan Oil site on the Eastern Mole, Port of Cape Town

Item Description Geology The site is located on reclaimed land within the Port of Cape Town, and

consists of backfilled material to between 13 and 17m below surface (K&T, 2013a). The fill material is underlain by bedrock of the Proterozoic Tygerburg Formation, Malmesbury Group, which consists of fine- to medium-grained greywacke, shales, siltstones and quartzite which occur in beds ranging in thickness from a few centimetres to several meters. Core (diamond) drilling by K&T (2013a) indicate that these sediments have been isoclinally folded, which has formed subvertical bedding planes dipping 75 – 80° SW and fold axial traces being slightly curved. The sediments are characterised by a distinct axial plane cleavage. No faults are known to occur in the area of the Eastern Mole, although faults have been mapped in Mouille Point. At the site, sediments of the Malmesburg Group are overlain by a 7-14m thick succession of marine sediments consisting of fine- to medium-grained grey-green sand with variable quantities of shell fragments, and occasional subrounded quartz pebbles.

Hydrogeology The Malmesbury Group is generally considered to form the base of the Cape Flats Aquifer (CFA) and its upper contact is marked by a deeply weathered clay which forms an aquitard. Given the location of the site, the groundwater comprises sea water, which is generally 2.9m below ground level. The groundwater level fluctuates between 1.2 and 1.8m in sync with the tides (K&T, 2013a). During periods of high or prolonged rainfall, a temporary perched aquifer may form on the site (K&T, 2013a).

Surrounding Area

The site is bound by the ocean to the northeast and southwest (Figure 1.1). To the northwest, the site is bound by the ocean and the communication building. The FFS Refinery facility is located between the northwestern and southeastern portions of the Burgan site. The Eastern Mole access road is located to the southeast of the site.

Hydrocensus The National Groundwater Archive (NGA) data indicated no registered boreholes within 1km of the site. A hydrocensus which covered a 500 m radius around the site did not detect any additional boreholes, however the ocean is located <50m from either side of the site.

Current Operations

The Burgan site is currently vacant. A part of the smaller southeastern portion of the Burgan site is currently serving as a laydown area and housing for temporary offices for the construction crew working on the expansion of the FFS Refiners facility.

Potential sources of contamination

The FFS Refiners facility is a significant source of potential hydrocarbon contamination located adjacent to the Burgan Oil site. Products stored here include bitumen, diesel and marine slops.

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Projection: Geographic, Datum: WGS84Source: Chief Directorate National Geo-Spatial Information3318CD_2000_ED9_GEO.TIF 3318DC_2000_ED9_GEO.TIFInset: ESRI Data and Maps

It is unlawful for any firm or individual to reproduce copyrighted maps, graphics or drawings, in whole or in part, without permission of the copyright owner, ERM Southern Africa (Pty) Ltd ·

Legend

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National Freeway/RoutesArterial RouteMain RoadsSecondary RoadsOther RoadsTrack and Hiking TrailRailwayContours (20m)Rivers

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Great Westerford Building240 Main RoadRondebosch, 7725Cape Town, SOUTH AFRICATel: +27 21 681 5400Fax +27 21 686 073

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2 METHODOLOGY

2.1 PHASE 1 (DESKTOP)

The Phase 1 assessment consisted of a desktop study and a site reconnaissance visit. The desktop study focussed on collating available information pertaining to the site in order to compile an initial Conceptual Site Model. The objective of the desktop study was to assist in streamlining the approach taken during the Phase II Intrusive Assessment. The desktop study focussed on the aspects listed below. The findings of this phase of work are presented in Chapter 3.

2.1.1 Analysis of Historical Data

Available records pertaining to the history of the site with regards to construction and previous operational history were sourced for review. This assisted in identifying previous practices or incidents which may have occurred on the site which could have impacted on the subsurface environment, particularly activities involving the use of hydrocarbons.

2.1.2 GIS / Map-based Study

Available orthophotos, geological maps, and topographic maps were reviewed to assess the site and the surrounding environments with regards to land use, soil types and potential receptors. Furthermore, details of public and private utilities, both above and below ground were sourced and reviewed to assess their potential for impacting on the subsurface environment, or conversely, for being impacted upon by any potential subsurface contamination.

2.1.3 Site Reconnaissance Visit

A short site reconnaissance visit was conducted to source onsite information which may not be revealed by the desktop study. Visual observations with regards to soil staining and the presence of nearby potential contaminant sources and underground services were recorded and used to assist in streamlining and focusing the subsurface soil investigation.

2.2 PHASE 2 (SOIL SAMPLING BY TRIAL PITTING)

The intrusive Phase 2 assessment consisted of trial pitting and soil sampling. Twenty-two trial pits distributed across the two sites were excavated and soil samples taken and submitted to a certified laboratory for analyses. Details of the activities conducted during this phase are provided below. The findings of this phase of work are presented in Chapter 3, and a discussion and interpretation thereof is presented in Chapter 4.


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2.2.1 Health and Safety Plan including sub-surface clearance

Prior to carrying out any field work, a Health and Safety Plan (HASP) was developed in accordance with the health & safety requirements of relevant stakeholders (e.g.: Transnet) and ERM’s internal standards and policies. Among other items, the HASP included an emergency response plan, service clearance information and task specific risk assessments which addressed the potential risks associated with the tasks to be carried out. ERM and its subcontractors were expected to adhere to the ERM and Transnet H & S policies, and to attend an induction at Transnet. Clearance for underground and overhead services was conducted across the sites prior to the commencement of intrusive works. This included obtaining all available wayleaves and service diagrams from Transnet National Ports Authority (TNPA) and private utility firms including Dark Fibre Africa and Neotel. No municipal services were located on the sites. Upon receipt of the service diagrams, the sites were scanned with a cable avoidance tool (CAT) and ground penetrating radar (GPR) by TerraScan, a company specializing in the location of buried utilities and structures. Services including water, electricity & stormwater and are concentrated adjacent to the roads and plot boundaries and are considered to be live, i.e.: currently operational. An unidentified object may be present parallel to the Eastern Mole road near the eastern edge of the north-western portion of the site. It is not clear what this may be, however the absence of a strong signal characteristic of electrical utilities, water pipes and stormwater drains elsewhere on the site suggest that it is none of these. Located services were marked out on site and photographed. Locations selected for trial pits were individually scanned with the CAT and GPR. The complete GPR report is attached in Annex B.

2.2.2 Trial Pit Excavation and Soil Sampling

Twenty-two (22) trial pits were excavated to a depth of approximately 1m in a grid-like fashion across the site with a tractor-loader-backhoe (TLB) (Figure 2.1). The locations of the pits were influenced by the proposed location of fuel storage and distribution infrastructure as detailed on the site layout plan provided by Burgan, as well as by the location of underground services. The majority of trial pits (16) were excavated on the larger northwestern site where the fuel tanks will be located. This included four (4) trial pits along the southeastern boundary of the site, adjacent to the FFS Refiners facility. Six (6) trial pits were excavated on the smaller southeastern site; however the presence of temporary offices and construction activity prevented the excavation of trial pits close to the site boundary with FFS Refiners. Trial pits were photographed and representative soil samples were taken from the base of each pit. Samples were inspected visually and split into two sub samples, with one sub sample being placed in a sealed laboratory supplied


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container and the remaining sample being placed in a Ziploc™ bag to be screened with the photo ionisation detector (PID) as a first-pass to assess the potential for volatile organic compound (VOC) impact. Although PID results do not provide compound specific data, they do provide an indication of hydrocarbon impact and can be used as part of a multiple lines of evidence approach in conjunction with the other data to assess for the presence of hydrocarbons.

2.2.3 Laboratory Analyses

Soil samples were couriered under refrigerated conditions to Eurofins Analytico Laboratory in Barneveld, the Netherlands for laboratory analysis. Samples were analysed for eight metals and petroleum hydrocarbons (GRO, DRO, BTEX) as detailed in Table 2.1. Laboratory detection limits are provided in the results table (Table 3.1 and Table 3.2).

Table 2.1 Schedule of analyses conducted on soil samples

Metals Petroleum hydrocarbons Analyses package contents:

As, Cd, Cr, Cu, Pb, Hg, Ni & Zn

Dry matter (soil moisture) GRO: gasoline range organics (C6-C9) DRO: diesel range organics (C10-C36) BTEX compounds Mono Aromatic Hydrocarbons (MAH) Total Petroleum Hydrocarbons (TPH)


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3 RESULTS OF ASSESSMENT

3.1 SUB-SURFACE CLEARANCE, TRIAL PIT EXCAVATION & FIELD OBSERVATIONS

Twenty-two (22) trial pits were excavated with a TLB across the site at the locations illustrated in Figure 2.1. Pits intersected building rubble including bricks, concrete and tar, set in a matrix of sandy red-brown soil (Annex D). Other items including short metal rods and discarded cables were intersected in certain trial pits. No visual or olfactory evidence of hydrocarbons including stains or odours were noted in any of the trial pits excavated. PID readings of soil samples taken from the bottom of each trial pit recorded no detectable VOCs.

3.2 LABORATORY RESULTS

3.2.1 Screening Criteria

Results were compared against the commercial / industrial soil screening values (SSV2) listed in the National Norms and Standards for the Remediation of Contaminated Land and Soil Quality in the Republic of South Africa. These were proposed by the Department of Environmental Affairs (DEA) in Government Notice 467 of 2013 and released for public comment. Although these have not yet been promulgated, they provide a good reference against which to compare the present soil values.

3.2.2 Analytical Results

Complete laboratory results are provided in Annex C, while summaries for hydrocarbons and metals are presented in Table 3.1 and Table 3.2, respectively, with comparison to the adopted screening criteria.


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Table 3.1 Summary of hydrocarbon analytical results of soil samples from trial pits

Analytes Units Detection

Limit Screening Values*

TP01 TP02 TP03 TP04 TP05 TP06 TP07 TP08 TP09 TP10 TP11

MAH & Aromatics Benzene mg/kg dm 0.05 10 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL Toluene mg/kg dm 0.05 1,100 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.1 Ethylbenzene mg/kg dm 0.05 540 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL Xylenes (sum) mg/kg dm 0.01 880 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.27 BTEX (sum) mg/kg dm 0.01 2,530** BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.37 Naphtalene mg/kg dm 0.01 290 BDL BDL BDL 0.018 BDL BDL BDL BDL BDL BDL 0.035 Total Petroleum Hydrocarbons TPH (C6-C10) mg/kg dm 1.2 23,000** BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL TPH (C10-C40) mg/kg dm 38 744,400† 61 95 BDL BDL 44 BDL 61 98 66 61 95


Limit Screening

Values TP12 TP13 TP14 TP15 TP16 TP17 TP18 TP19 TP20 TP21 TP22

MAH & Aromatics Benzene mg/kg dm 0.05 10 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL Toluene mg/kg dm 0.05 1,100 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL Ethylbenzene mg/kg dm 0.05 540 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.051 Xylenes (sum) mg/kg dm 0.01 880 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.27 BTEX (sum) mg/kg dm 0.01 2,530** BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.32 Naphtalene mg/kg dm 0.01 290 BDL BDL BDL 0.031 BDL BDL BDL BDL BDL BDL BDL Total Petroleum Hydrocarbons TPH (C6-C10) mg/kg dm 1.2 23,000** BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL TPH (C10-C40) mg/kg dm 38 744,400† BDL 44 95 110 130 BDL 77 50 54 75 78

* Screening values are from the commercial / industrial soil screening values (SSV2) listed in the National Norms and Standards for the Remediation of Contaminated Land and Soil Quality in the Republic of South Africa (Government Notice 467 of 2013).


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** No value defined in SANS (GN 467 of 2013). Value provided is sum of benzene, toluene, ethylbenzene & xylenes provided. † No value defined in SANS (GN 467 of 2013). Value provided is sum of C10-C14 and C15-C36 provided. BDL = Below detection limit

Table 3.2 Summary of metals analytical results of soil samples from trial pits


Limit Screening Values*

TP01 TP02 TP03 TP04 TP05 TP06 TP07 TP08 TP09 TP10 TP11

Arsenic (As) mg/kg dm 5 150 12 12 6.6 14 10 <5.0 13 23 23 8.9 11 Cadmium (Cd) mg/kg dm 0.4 260 BDL BDL BDL BDL BDL BDL BDL BDL 4.3 BDL BDL Chromium (Cr) mg/kg dm 5 110 21 27 57 15 16 33 160 43 27 24 Copper (Cu) mg/kg dm 5 19,000 470 11 63 36 13 9.8 21 1500 39 69 44 Mercury (Hg) mg/kg dm 0.1 6.5 0.3 0.13 0.11 0.8 0.52 <0.10 0.13 0.14 0.23 0.18 0.3 Nickel (Ni) mg/kg dm 5 10,000 40 5.3 9.1 25 7.8 6 9.5 67 18 8.8 11 Lead (Pb) mg/kg dm 10 1,900 150 21 47 67 21 21 30 98 78 45 130 Zinc (Zn) mg/kg dm 5 150,000 800 37 140 120 40 34 52 320 210 110 120


Limit Screening

Values TP12 TP13 TP14 TP15 TP16 TP17 TP18 TP19 TP20 TP21 TP22

Arsenic (As) mg/kg dm 5 150 15 6.4 9.8 8.1 9.6 9.4 14 10 14 9.8 16 Cadmium (Cd) mg/kg dm 0.4 260 BDL BDL BDL BDL BDL BDL BDL BDL 0.42 BDL BDL Chromium (Cr) mg/kg dm 5 27 25 35 160 52 58 41 38 190 110 170 Copper (Cu) mg/kg dm 5 19,000 36 33 33 430 54 50 36 43 280 64 90 Mercury (Hg) mg/kg dm 0.1 6.5 0.19 0.11 <0.10 0.2 0.12 0.12 0.13 0.13 0.32 0.14 0.18 Nickel (Ni) mg/kg dm 5 10,000 8.9 13 16 58 20 25 20 17 100 45 96 Lead (Pb) mg/kg dm 10 1,900 85 38 29 65 43 38 44 60 240 56 36 Zinc (Zn) mg/kg dm 5 150,000 130 81 68 250 180 86 82 100 1700 130 160

* Screening values are from the commercial / industrial soil screening values (SSV2) listed in the National Norms and Standards for the Remediation of Contaminated Land and Soil Quality in the Republic of South Africa (Government Notice 467 of 2013).


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4 DISCUSSION AND INTERPRETATION

4.1 HYDROCARBONS

Mono-Aromatic Hydrocarbons (MAH)

Concentrations of mono-aromatic hydrocarbons (MAH) are below the laboratory detection limit, and below the relevant screening values, in all trial pits except TP04, 11, 15 and 22 (Table 3.1). Of these, only TP11 and 22 returned values above the detection limit for more than one analyte. These two trial pits are located on the inside edge of the two Burgan sites, adjacent to the FFS Refiners site (Figure 2.1), suggesting a possible relationship between the FFS Refiners facility and the MAHs in the soil. Total Petroleum Hydrocarbons (TPH)

Concentrations of total petroleum hydrocarbons (TPH) in the C6 – C10 range (i.e. the volatile TPH range) were below detection for all trial pits (Table 3.1). Concentrations of TPH in the C10 – C40 range were below the laboratory detection limit in five of the 22 trial pits sampled, and between 44 and 130 mg/kg dm in the remaining 17 trial pits (Table 3.1). The detected concentrations were all below the adopted screening values. Discussion

Given the history of the site (section 1.1) and the fact that it is constructed of a variety of back-filled material of unknown origin, some of which may have been hydrocarbon-stained, the potential for soil contamination may be expected. The current low concentrations of MAH and TPH in the soil samples from trial pits indicate levels of impact that do not pose a health or liability risk to the proposed Burgan Oil operations under the proposed land use scenario. Notwithstanding that, potential future work related to hydrocarbon screening is presented in Chapter 6.

4.2 METALS

Concentrations of individual metals vary considerably, by up to a factor of 100, between trial pits. For example, concentrations of chromium range from 15 mg/kg dm in TP05 to 190 mg/kg dm in TP20; concentrations of copper from 9.8 mg/kg dm in TP06 to 1500 mg/kg dm in TP08; and concentrations of zinc from 34 mg/kg dm in TP06 to 1,700 mg/kg dm in TP20 (Table 3.2). This variability is most likely due to the nature of the site, being reclaimed land constructed by end-tipping of a variety of material including concrete, tar, rock, bricks, timber, and metal, all set in a variable matrix of gravel, sand, silt and clay (K&T, 2013a). Given the artificial “man-made” nature of the site, no patterns or inferences can be deduced from the spatial distribution of metals.


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All metal concentrations in the soil are significantly below SSV2 screening values for commercial / industrial sites, indicating no significant health risk. The metals concentrations provide a baseline against which to compare future values in order to assess the potential impacts of the proposed fuel storage facility on the site.

4.3 CONCEPTUAL SITE MODEL

4.3.1 Overview

Using the available information on the present conditions and the planned future development of the Burgan Oil site, a conceptual site model (CSM) was developed to assess known/potential future contaminant sources. Often the subsurface environment is too complex to be described comprehensively, and hence a CSM provides a simplified representation of the natural environment within a set of reasonable boundaries and assumptions. The CSM is based on available information and should be constantly updated as new information becomes available. Specifically, the CSM identifies a source of impact and chemical release mechanism, an environmental transport medium or pathway, a potential exposure point and exposure route, and a potentially exposed population or receptor. The CSM is used to inform and drive site investigations, to assess the qualitative risks related to the site and to assist with remedial strategies (if required). A potential risk scenario is only present when a complete linkage exists between a source, pathway and receptor. If no complete linkage is present no risk would exist. If a complete linkage is present, the identified receptor may be exposed to the compounds of potential concern (COPC) detected at the site through the identified pathway.

4.3.2 Sources, Pathways and Receptors

The current conditions and the information which is presently available regarding the proposed development of the Burgan Oil site was used to develop the CSM. The relevant technical information is presented below and summarised in Table 4.1. A discussion of this is provided in section 4.3.3. Sources of Impact

The Burgan Oil site on the Eastern mole is vacant, and there are currently no known sources of impact on the site. Potential future sources of impact will include fuel storage and distribution infrastructure including tanks, pipelines, filler points etc. The adjacent FFS Refiners facility is a present potential source of impact. Exposure Pathways

Potential exposure pathways at the site that may be applicable should the site become impacted include the following:


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• Direct contact (incidental ingestion and dermal contact) with hydrocarbons by on-site workers;

• Inhalation of hydrocarbon vapours; and • Vertical migration of contaminants through substrate into sea, and

laterally from there. As-built drawings of the Eastern Mole provided by TNPA show that steel sheet piling is located on either side of Portside Road (located on the southwest boundary of the site, adjacent to Duncan Dock) and that this can be considered largely impermeable (TNPA, pers. comm.). The northwestern end of the Eastern Mole (adjacent to the Telkom building) is constructed of concrete tetrahedrons, while the northeastern edge (on the Ben Schoeman Dock) is constructed of backfilled material into which a fine but permeable screen has been set (TNPA, pers. comm.). Lateral migration of contaminants which reach the sea water below the Burgan Oil site could therefore potentially migrate northwest and northeast into the Ben Schoeman Dock and Table Bay. Potentially Sensitive Receptors

Potentially sensitive receptors that may be affected by hydrocarbon impacts at the site include the following:

• On-site workers; and • Marine ecosystems in the harbour.

4.3.3 Discussion

Concomitant with the storage and handling of hydrocarbons products on the Burgan Oil site is the risk of equipment failure or human error leading to the release of petroleum hydrocarbons and the contamination of the environment. The potential sources, exposure pathways and sensitive receptors are outlined above. Two features of the Burgan Oil Eastern Mole site distinguish it from conventional terrestrial sites and have important implications for the CSM:

• The site is underlain by a variety of partially-consolidated back-filled material which has a range of physical properties (composition, density etc.) and which has no preferred fabric or fluid pathway (e.g.: bedding plane, fracture set etc.); and

• Sea level is located at ~3m below surface and represents the receptor, or destination, as hydrocarbons, being less dense than water, will float on the surface and distribute laterally rather than vertically at this point.

This suggests that any hydrocarbon spills released from the site will not migrate laterally but rather vertically downwards through the back-fill (excluding influence of bunds, concrete pads and other design features that may form part of the facility). Given the partially consolidated nature of the fill, this migration will be rapid relative to conventional terrestrial sites. Upon


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reaching groundwater (sea water), hydrocarbons will float on the water surface and/or partially dissolve into it. Migration paths velocity and limits will be a function of many factors (e.g.: tides), but site conditions are conducive to rapid migration. This may result in rapid movement of the hydrocarbon spill beyond the limits of the site boundary where it may adversely affect marine life and pose a safety risk in the adjacent Ben Schoeman Dock and potentially into Table Bay beyond. Proximal to the site, the hydrocarbons may stain back-fill situated beneath sea level over a vertical distance of approximately 1.8m (the spring tidal range: K&T, 2013a).


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Table 4.1 Potential sources, transport mechanisms and sensitive receptors based on current site conditions & project brief

Scenario Sensitive Receptors

Distance Source-

Receptor

Potential Exposure

Media

Potential Exposure Pathways description

Potential Exposure Pathway?

Rationale for Assessment

On-site

- Industrial/ commercial

workers during construction /

operation

0m

Soil / Fill

- Inhalation of volatiles in indoor and ambient air from

soil; and - Direct contact with soil (accidental ingestion and

dermal contact).

Yes

Industrial workers stationed on site during the operational phase of the project may be exposed to hydrocarbon vapour or come into direct contact with soils, concrete, tar and other materials which may have been impacted by hydrocarbons spills. It is assumed that occupational H&S procedures will address these issues and make provision for the handling and disposal of material impacted by hydrocarbons.

Groundwater (sea water)

- Inhalation of volatiles in ambient air from groundwater

volatilisation; and - Direct contact with

groundwater (accidental ingestion and dermal contact).

Yes

Direct contact with groundwater (sea water) and the potential vapour migration from impacted water to outdoor air is not considered to be a potential risk when compared with the daily contact/vapours which will originate from the site operations, and it is assumed that occupational H&S procedures will address these issues. It is presently understood that no sea water will be used on the site and hence ingestion thereof has not been considered further. Should Burgan plan to use sea water on site, e.g.: for fire suppression, and decide to source this proximal to the site, the potential implications of extracting hydrocarbon contaminated sea water should be considered.

Off-site

- Industrial/ commercial

workers <50m Soil

-Inhalation of volatiles in indoor and ambient air from

soil; and - Direct contact with soil (accidental ingestion and

dermal contact).

Yes

Industrial workers stationed on or visitors to adjacent sites including the FFS Refiners facility and Transnet communications building will not come into physical contact with soil on the Burgan Oil site. There is the potential that a sufficiently large spill of hydrocarbons would generate outdoor vapours which could be smelt on adjacent sites. It is assumed that occupational H&S procedures will address these issues and make provision for the handling and disposal of material impacted by hydrocarbons.


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Scenario Sensitive Receptors

Distance Source-

Receptor

Potential Exposure

Media

Potential Exposure Pathways description

Potential Exposure Pathway?

Rationale for Assessment

Groundwater (sea water)

- Inhalation of volatiles in indoor and ambient air from

groundwater (sea water) volatilisation;

Yes

It is possible that hydrocarbon spills at the Burgan Oil site will reach the sea water and disperse. Should currents or other factors conspire to retard dispersion and instead concentrate hydrocarbons in the fill below nearby buildings, this could pose a significant safety risk.

- Direct contact with groundwater (accidental

ingestion and dermal contact). Yes

It is possible that sea water is used on nearby sites for fire suppression, hence the potential implications of extracting hydrocarbon contaminated sea water should be considered.

- Atlantic Ocean 15-20m Groundwater

(sea water) Direct contact with ecosystem Yes

Should hydrocarbons leak from site, the heterogeneous nature and consequent porosity of the fill is likely to facilitate hydrocarbons reaching the sea where is will adversely affect marine life, and may distribute quickly.


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4.4 IMPACT ASSESSMENT

This section focusses on the potential contamination of soil which may result from the storage and handling of petroleum hydrocarbons on the Burgan Oil Eastern Mole site. It discusses potential impacts that may occur during the construction and operational phases of the project, then proposes mitigation measures for each phase and discusses residual impacts that may remain. The current conditions on the Burgan Oil site, as summarised in Chapter 3 and 4 above, represent the baseline conditions against future contamination impacts will be assessed.

4.4.1 Construction Phase

Baseline soil conditions are presented in section 3.3 and discussed in sections 4.2 & 4.3. The construction of the facility may result in the following impacts relevant to the contamination of soil and water resources:

• Leaking of fuels or lubricants from construction machinery into the soil or groundwater (sea water);

• Runoff of rainwater from hydrocarbon-stained machinery leaching into soil or groundwater;

• Spills of bitumen, sealants and other substances used in the construction of the facility.

Box 4.1 Construction impact: soil or groundwater contamination from fuel or oil spill

4.4.2 Operational Phase

The baseline for the operational phase of the project will be the site conditions as at the end of the construction phase. Additional sampling and analysis of soil and groundwater may therefore be warranted at this stage of the project. The operation of the facility may result in the following impacts relevant to the contamination of soil and water resources:

Nature: Construction activities could result in a direct negative impact on existing soil and groundwater conditions on the site. Impact Magnitude: Low negative • Extent: The extent of the impact to the soil will likely be confined to the project area, unless

operations (e.g.: loading, refuelling etc.) involving hydrocarbons or other potential contaminants are conducted outside of the project area.

• Duration: The duration of the impact would be long-term. • Intensity: The intensity is likely to be medium. Likelihood: The likelihood of this impact occurring is possible. IMPACT SIGNIFICANCE (PRE-MITIGATION): MODERATE (-VE) Degree of Confidence: The degree of confidence is high.


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• Spills or leaks ranging from minor to major of hydrocarbons may occur due numerous reasons, including:

o Tank failure, o Pipeline leak, o Decoupling of filler points, o Faulty valves, o Vehicles or equipment colliding with fuel equipment, o Failure of emergency shut-off equipment;

• Runoff into the sea of rainfall which has come into contact with hydrocarbons on site;

Box 4.2 Operational impact: soil or groundwater contamination from fuel or oil spill

4.4.3 Mitigation

Construction Phase The following mitigation measures to avoid contamination of the soil and water resources are recommended for the construction phase of the project:

• All fuel storage equipment (e.g.: tanks) should meet appropriate internationally-recognised standards for structural design and integrity, e.g.: American Petroleum Institute (API) standards 650, 652, 653, & 2610.

• All fuel storage equipment should be fitted with leak detection technology.

• Install shutdown valves, e.g.: automatic pressure-activated values, to shut down or isolate ruptured tanks, pipes etc.

• Impermeable bunds with a capacity of 110% of the tank(s) which they enclose should be constructed.

• Ensure that staff are adequately trained in spill prevention, containment and response.

• Design and install an appropriate stormwater catchment system to prevent hydrocarbon-contaminated water from leaving site.

Nature: Operations could lead to a fuel or oil spill resulting in a direct negative impact to the soil on the site, and groundwater (sea water) both on and off the site. Impact Magnitude: High negative • Extent: The extent of the impact on the soil is site-specific, however the extent on the

groundwater could be local (i.e.: across Duncan and Ben Schoeman Docks and potentially into Table Bay), in the case of a sufficiently large fuel spill.

• Duration: The duration of the effect of soil and/or groundwater contamination would be long-term as the remediation of the oil spill may take months to years to effect, and may have limited success leaving lasting (residual) impacts.

• Intensity: The intensity of sol or groundwater contamination would be high. Likelihood: It is unlikely that a spill of petroleum hydrocarbons will occur. IMPACT SIGNIFICANCE (PRE-MITIGATION): HIGH (-VE) Degree of Confidence: The degree of confidence is high.


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Operational Phase The following mitigation measures to avoid contamination of the soil and water resources are recommended for the operational phase of the project:

• Regular and precise wet stock inventories should be conducted to timeously identify discrepancies and potential leaks.

• A spill response plan should be prepared to quickly react to and contain as far as possible and spills emanating from fuel infrastructure on site. This should be risk-based and include all necessary equipment, appropriate training prerequisites for staff, critical checks etc.

• Infrastructure and equipment using or storing hydrocarbons should be routinely maintained and regularly inspected in order to minimise the chance of hydrocarbon spills.

• Warning signs and appropriate barricading should be placed around vulnerable fuel-carrying infrastructure.

4.4.4 Residual

Should the recommended mitigation measures listed above be implemented, the residual impact significance from the construction and operational phases will be reduced to from moderate (-ve) and high (-ve) to low (-ve) and low (-ve) respectively (Table 4.2).

Table 4.2 Pre- and post-mitigation significance of soil or groundwater contamination impacts from fuel or oil spill

Phase Significance (Pre-mitigation) Residual Significance (Post-

mitigation) Construction MODERATE (-VE) LOW (-VE) Operational HIGH (-VE) LOW (-VE)


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5 CONCLUSIONS

The following conclusions can be drawn from the contamination assessment study on the Burgan Oil site on the Eastern Mole, Port of Cape Town: Baseline Conditions

• By virtue of the nature of the site, being reclaimed land constructed through the end-tipping of a variety of materials, the results of laboratory analyses conducted on soil samples from trial pits are variable and heterogeneous.

• To ERM’s knowledge, the land was reclaimed between 1992 and 2000 and has never been developed; hence the results of these analyses provide a reliable indication of the baseline conditions of the site.

• Concentrations of MAH in soil are below laboratory detection limits for all but two trial pits (TP11 & 22). In these pits, the concentrations are below the SSV2 (commercial/industrial) screening values.

• Concentrations of TPH in the C6 – C10 range are below laboratory detection limits for all trial pits, while concentrations of TPH in the C10 – C40 range vary from below the laboratory detection limit (in 5 of the 22 pits) to concentrations that are below the SSV2 (commercial/industrial) screening values in the remaining pits.

• Metal concentrations in soil vary by a factor of up to 100, with the greatest variability evident in chromium, copper and zinc. Given the nature of the site, such variability is to be expected and no spatial patterns can be drawn from the results. All metals are present in concentrations well below the relevant screening values.

Conceptual Site Model & Impact Assessment

• The location of the site in the harbour ~3m above sea level on partially consolidated backfill material which is inherently permeable, suggest that any hydrocarbon spill from site will migrate vertically down from the source until it comes into contact with groundwater (sea water), and then migrate laterally from there. Migration paths velocity and limits are a function of many factors, but site conditions are conducive to rapid groundwater flow.

• The potential impacts of soil and groundwater contamination as a result of the construction of a bulk fuel storage terminal on the Burgan Oil site are moderate negative, however these can be reduced to low negative through the implementation of the proposed mitigation measures.

• The potential impacts of soil and groundwater contamination as a result of the construction of a bulk fuel storage terminal on the Burgan Oil site high negative, however these can be reduced to low negative through the implementation of the proposed mitigation measures.


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6 RECOMMENDED FUTURE WORK

6.1 OVERVIEW

Based on the findings of the present study and our understanding of the Burgan Oil’s objectives for the project, it is recommended that additional soil sampling be conducted and water samples be taken from surface to water below by means of drilling. This should be conducted prior to construction to form part of the baseline for the site. Following the construction of the facilities, monitoring wells should be installed to allow regular sampling of the sea water below site.

6.2 ODEX DRILLING FOR SOIL AND WATER SAMPLING

6.2.1 Overview

In order to complete a more comprehensive contamination baseline for the site of the proposed Burgan Oil facilities, it is recommended that drilling be conducted in order to obtain samples of the fill material down to water level as well as to obtain water samples from below the site. It is proposed that six holes be drilled on the larger northwestern portion of the site, and three or four on the smaller southeastern portion.

6.2.2 Drilling and Sampling Specifications

Given the partially consolidated and highly variable nature of the backfill material which includes concrete, bricks and sand, boreholes are likely to collapse during drilling and retard sampling. It is therefore recommended that percussion drilling using the Odex method should be used. The Odex drill method involves the insertion of temporary metal casing as the drill bit advances, thereby keeping the borehole open. Once the required borehole depth is reached, the drill stem is retracted through the casing allowing water at the base of the hole to be sampled. After sampling, the casing is retracted and the borehole filled up or allowed to collapse. During drilling, individual soil samples should be taken from each meter to obtain a vertical profile through the site. A water sample should be taken from the base of each borehole once it has reached the required depth. Given that sea level is ~3m below, it is recommended that boreholes be advanced to 4m.

6.2.3 Laboratory Analyses

Soil and water samples should be submitted to Eurofins Analytico (Barneveld) for the same analyses conducted on the samples taken during this phase of work, viz. metals and hydrocarbons. The latter includes analyses for mono aromatic hydrocarbons (BTEXN), total petroleum hydrocarbons (TPH), and TPH volatiles.


27

6.3 INSTALLATION OF MONITORING WELLS

6.3.1 Overview

A network of simple groundwater monitoring wells should be installed across the site including the tank farm and dispending areas after construction of the facility. These wells should be located where they can be used to determine the potential for contaminants to migrate onto or off of the site, i.e.: by installing these close to the site boundaries, and where they can facilitate in the identification of potential releases of product from tanks or piping, i.e.: by installing these adjacent to the tanks/piping. Wells adjacent to tanks should be located outside of but as close as possible to bund walls. The installation of wells prior to construction is not advised given the propensity for wells to be destroyed by heavy construction equipment.

6.3.2 Monitoring well installation

Based on information currently available, including the present layout designs, the following is recommended:

• Install between 9 and 12 groundwater monitoring wells across the sites to a depth of 4m below ground level by means of rotary air percussion drilling.

• Wells should be equipped with 63mm PVC casing, screened across the water table with a sufficient screened interval above and below the water level to allow for tidal variation.

• The well annulus should be filled with filter pack material to above the screened interval and then back grouted to near the surface level.

• A bentonite seal should be placed within 0.2m of the surface, followed by concrete slurry.

• Wells should be equipped with a hot dip galvanised steel stand pipe with a welded table D flange, gasket and blank flange for sealing within bund areas

• Wells should be developed to remove fine sediments from the casing and to develop the filter pack. Waste water generated during purging will be removed from the site and disposed of in an environmentally responsible manner. Should the oil water separator be constructed by the time well development take place, the waste water could be discharged through the separator.

6.3.3 Monitoring well sampling

Monitoring wells should be sampled after a rest period of seven days following drilling, to allow the well to equilibrate with ambient conditions within the aquifer. During sampling, the depth to groundwater and the thickness of Phase Separated Hydrocarbons (PSH), where present, should be measured using an interface meter.


28

The monitoring wells not containing PSH should be purged (purge water recovered from monitoring wells should be collected and disposed of via the onsite separator, or removed off site and disposed of in an environmentally responsible manner) and well-head parameters (pH, electrical conductivity (EC), dissolved oxygen (DO), Eh and temperature) should be monitored with a YSI flow-through cell until they stabilise. Groundwater samples should be recovered, directly into laboratory supplied bottles, using a peristaltic pump in accordance with in-house protocols based on United States Environmental Protection Agency (USEPA) methods. Groundwater samples should be taken from each monitoring well and submitted to Analytico Milieu Laboratories in the Netherlands for the following analyses:

• Total Petroleum Hydrocarbons (TPH) with carbon banding and aliphatic/aromatic splits (TPHCWG);

• Benzene, Toluene, Ethyl benzene and Xylenes (BTEX); • Basic Heavy Metal Suite Analysis

Quality Assurance/Quality Control Samples should be collected following strict procedures to avoid cross-contamination. The samples should be collected into laboratory-supplied sample bottles and be adequately sealed and packed on ice to maintain a temperature of approximately 4 - 5 °C. Samples should be shipped with the appropriate Chain-of-Custody documentation to the laboratory for analysis on a standard 5 working day turnaround from receipt of the samples. During sampling and decontamination activities, disposable nitrile gloves should be worn to minimise transfer of contaminants. Any disposable equipment, such as gloves and bailers, should be dedicated to each sampling location and disposed of after use. For QA/QC purposes the following quality samples should be included:

• 3 x Trip blank for BTEX (1 sample per container – assume 3 containers);

• 1 x Blind duplicate for all analyses – (10% sample duplicates); On completion of the field works, the factual Phase I and II report will be updated to include the completed Phase III works. The additional sections of the report will include a discussion on the analytical results of the collected water samples and provide an updated site conceptual model which will provide an overview of the subsurface conditions and baseline of soil and groundwater quality prior to operation of the facility.


29

7 LIMITATIONS

This report was prepared in accordance with the scope of work outlined in our Proposal and in a manner consistent with the level of skill and care stated in our contract. This report was developed within the confines of the existing available data, our scope of work, the budget, schedule and other constraints. ERM makes no warranty concerning the suitability of the site for any purpose or the permissibility of any use, development or re-development of the site. More generally, ERM make no warranties, expressed or implied, as to merchantability or fitness for a particular purpose. Except as otherwise specifically stated in this report, ERM’s assessment was limited strictly to identifying specified environmental conditions associated with the subject site and does not evaluate structural conditions of any buildings or utilities on the subject site. Lack of identification in the report of any hazardous or toxic materials on the subject site is not, and should not be interpreted as, a guarantee that such materials do not exist in, on, under or within the vicinity of the site. This report is based upon the application of scientific principles and professional judgment to specified facts, with resultant subjective interpretations. Professional judgments expressed herein are based on the facts available at the time that the investigations were undertaken. The information provided in this report is not to be construed as legal advice. This assessment is based on site inspection conducted by ERM personnel, sampling and analyses described in the report, and information provided by our client and its affiliates and other people with knowledge of the site conditions. While a reasonable level of checking of the accuracy of data has been conducted, ERM assumes no responsibility or liability for errors in data obtained from such sources, regulatory agencies or any other external sources, nor from occurrences outside the scope of this project. ERM prepared this report for the sole and exclusive benefit and use of our client. Except as otherwise expressly agreed by ERM, delivery of a copy of this report provided to a third party by ERM or our client shall be for informational purposes only, without the right to rely and ERM disclaims all liability to such third party to the extent permitted by law. Any delivery to or use of this report by a third party is deemed to constitute acceptance of this limitation. ERM is not engaged in environmental assessment and reporting for the purpose of advertising, sales promotion or endorsement of any the Client’s interests, including raising investment capital, recommending investment decisions or other publicity purposes. Accordingly, the Client also agrees that none of its advertising, sales promotion or other publicity matter containing


30

information obtained from this audit and report will mention or imply the name of ERM. The client agrees that it will not quote, attribute or refer to ERM, our services or this report (or any part thereof) in any prospectus, offering circular or similar document without ERM’s prior written consent. To the extent that ERM does consent to any such use, quotation, attribution or reference, we reserve the right to review and comment on the form and content thereof.


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8 REFERENCES

Kantey & Templer (2013a). Report on geotechnical investigations for proposed new fuel storage terminal at Eastern Mole, Cape Town Harbour. Referfence no.: 13112P. October 2013.

Kantey & Templer (2013b). Cape Town Terminal, Eastern Mole, Cape Town Harbour: Drainage Philosophy. Referfence no.: 13112P. November 2013.

TNPA (pers. comm.). Transnet National Ports Authority. March 2014.

Chromatogram TPH/ Mineral Oil

Sample ID.: 7965747 Certificate no.: 2014013107Sample description.: TP01

v

Minutes

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 2.6

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C1

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C1

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35

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40

C4

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Chromatogram TPH/Mineral OilSample id.: 7965753

Certificate no.: 2014013107

Sample description.: TP07

C10

_In

tern

e_st

and

aard

C12

C16

C21

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_In

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Figure D1 Selected site photographs

1

Dean Alborough

From: Ken KingSent: 03 July 2014 09:41 PMTo: Dean AlboroughSubject: Addendum to baseline contamination assessment for Burgan Oil

Dear Dean, The baseline contamination assessment conducted on the two portions of the Burgan Oil site determined that hydrocarbons were not present in notable concentrations in the substrate. Without having the opportunity to sample the substrate along the length of the proposed 10" pipeline to run 900m between Berth 2 and the import/export manifold, based on the findings of the study conducted it is assumed that the baseline conditions in the areas investigated are representative of those along the proposed pipeline route. Therefore it is assumed that hydrocarbons are not present beneath the route of the proposed pipeline in concentrations which exceed those measured on the two portions of the Burgan Oil site. Based on the above assumption, the potential impacts and associated mitigation measures described for the proposed tank farm (including ancillary infrastructure) are also relevant to the proposed pipeline. There is therefore no change to the baseline contamination assessment previously conducted for this project. Sincerely, Ken King

ERM’s Cape Town Office

ERM’s Johannesburg Office

ERM’s Durban Office

contaminated site assessment

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