Engen's response to environmental concerns in the South Durban Basin

Thursday, 03 April 2008

Willem Oosthuizen
General Manager
Engen Refinery

Memorandum signatories included: The political ecology students of a tertiary education institution, the South Durban Community Environmental Alliance, concerned Durban residents, and GroundWork

Thank you for your memorandum which raises some very interesting issues. At the outset, however, we would suggest that many of these issues should be directed at the authorities that administer environmental legislation and not ourselves.

We can only reiterate that Engen as a concerned corporate citizen does its utmost not only to comply with all environmental legislation, but also, where possible, perform to even higher exacting environmental standards that we have set for ourselves.

We will deal with your issues point-by-point (your statements are in blue and are followed by our answer in black):

Local, provincial and national authorities improve data collection on the refinery industry, including flare monitoring of volumes and content of flare gas, extension to measure for other noxious chemicals otherwise ignored, as well as video monitoring.

This should really be directed at the authorities you mention not Engen. We believe, however, that this demand has already been addressed through the comprehensive independent atmospheric monitoring carried out in terms of the South Durban Multipoint Plan (MPP) administered by eThekwini Municipality. Their findings are mirrored by Engen's own sophisticated pollution surveillance systems (that monitor and measure all the important pollutants associated with a refinery) make the Engen Refinery one of the most closely scrutinised anywhere. These intensive levels of monitoring mean emissions from the refinery are almost always predictable.

This aerial picture from the eThekwini Air Quality Monitoring Report (apologies for the picture quality) shows the concentration of monitoring stations around Engen Refinery (blue square)

The map above show the Engen Refinery's own monitoring points which are located at strategic intervals all along the refinery's boundary.

The graph, also from the eThekwini Air Quality Monitoring Report shows the dramatic downward trend in 10-minute SO₂ exceedances

When information on emissions is provided by the refineries, this needs to be independently verified as a point of law.

Again, this should be directed at the authorities, and again we believe that this process already has these checks and balances in place as all Engen Refinery's data (which in any case is collected by a third party Ecoserve and analysed by independent laboratories) is constantly compared with that from the MPP monitoring facilities. The University is welcome to audit the custody chain for the results.

All Environmental Impact Assessments must take account of cumulative impacts and be reviewed by the authorities or any other independent party and be widely advertised to the local public.

This is another issue that can only be determined by the authorities who are responsible for promulgating the legislation. Nevertheless, it is worth stressing that all big capex undertaken by the refinery are implemented on a basis of some reduction in priority pollutants. This means that the projects contribute to a cumulative reduction (rather than increase) in priority pollutants.

A reform in the gas market, so that excess gas can easily be utilised by industries both locally and nationally.

Contrary to your suggestion our refinery does not flare excess gas. This is strictly prohibited in terms of our permit. Flaring is a safety mechanism built into the system specifically to address process disturbances that cause temporary imbalances in the system. We are obliged to report all flaring to City Health. Any excess gas that we may produce is used either to make petroleum products or to supplement other heating fuels used in the refinery.

In Alberta, if the refinery operators do not solve a flaring problem, the public can submit a written objection to the EUB (Energy and Utilities Board). The board will then consider the application for a permit and the objection. We demand similar legislation here that acknowledges residents as being crucial in terms off public participation and for bringing potential problems to the fore.

As we have already said we are obliged to report all flaring to City Health. In addition there is absolutely nothing in this democracy to prevent anyone who feels strongly about an issue from lobbying politicians or complaining to the authorities.

Enforcement of any permitting system to ensure that the industry accountable.

Again this is an issue that can only be addressed by the authorities if you believe there is a problem, but this refinery is subject to the most extensive permit that we know of for any Industry. There is a yearly review process which allows for public comment.

Skilled personnel and specialists in the refinery field to be introduced in local, provincial and national departments, as well as in community organisations.

We would welcome such a move as any programme that promotes greater understanding of how our industry functions will help dispel many of the myths and controversies that exist today (also see invitation at the end of this response).

The MPP Monitoring Stations are improved to function at all times, especially when flaring incidents are occurring, and to measure a larger number of chemicals emitted by the refineries.

We believe this demand is currently in the process of being addressed by the MPP administrators who are adding additional monitoring functionality to the system.

A reduction in the need for flaring through more efficient operating procedures and Best Available Technology (BAT) at the refineries, with flare gas recovery systems being of a sufficient size to handle most upsets.

This refinery has no on-going flare source. Scavengers are aimed at extended periods of flaring not short duration issues such as seen at this refinery. The refinery flares conform to BAT.

In order to reduce flaring incidents and accidents, that the refineries and power suppliers look at alternative power sources and back-up systems for when there are power failures that cause the supply to the refineries to be interrupted.

eThekwini Electricity and Engen have invested heavily in dual redundancy for electrical supply systems and dip protection systems. Back-up generation will generally have lower energy efficiency than large Eskom boilers so the greenhouse gas effect and the additional emissions associated with generation facilities will have to be considered in the EIA.

That both Sapref and Engen calculate the carbon emitted not by assuming high combustion efficiency but rather, by measuring actual combustion efficiency.

Flare combustion efficiency predictions are available for the flare systems we use. Efficiency reduction is mostly experienced at very high flare rates which are very uncommon. The best way to understand effects at ground level is by using monitors such as the MPP monitoring stations.

Furthermore, we demand that the actual efficiency in the destruction of hydrogen sulphide within a flaring system is measured.

Our plant design means that there is seldom any flaring of gas with high levels of H₂S. A flare gas sampling system is used to take samples during flare events. This provides Engen and the authorities with sufficient information to predict any impact. If SDCEA knows of a simple and accurate way to measure on-line H₂S combustion efficiency we would be delighted if they would tell us about it.

Engen and Sapref provides an interval for their maintenance cycle to the public.

Every piece of refinery equipment has a unique maintenance strategy that includes on-line checks, routine maintenance and off-line Inspection.

It is simply not possible to put a single number on all components but what can be done is to list the codes and standards that we use to determine intervals for the range of maintenance activities.

Engen and Sapref introduce vapour recovery systems (where though - Engen has made some modification to recapture benzene. We need to be clear about this.)

Engen has two vapour recovery systems in place and are running a stringent LDAR programme. Monitoring over several years indicates that the site meets WHO and EU standards for priority VOC's at all it's boundaries

Engen makes clear their position on the addition of auxiliary fuels added to flares as the statement that they do not do this is in contradiction with their project in progress to develop the use of Methane.

The Methane is to run the flare pilots that have to be on line continually as this ensures combustion when there is a flaring event.

Engen adopts a better attitude in dealing with its public and correctly trains its public liaison officers to properly handle and understand the opinion of people on the street.

Engen has a monthly Community Liaison forum to discuss a wide range of issues. On a quarterly basis one of these is devoted to environmental performance and related issues. SDCEA are once again invited to attend these.

Engen should publicly and in a transparent way illustrate profits and exact community investments for civil analysis, comment and application.

Refinery profit and loss data is freely available to all staff but, in common with almost all un-listed companies, it is not our policy to release this into the public domain.

Thank you again for your interest in the Engen Refinery. We hope our answers have both satisfied your curiosity and given you a better understanding of the high levels of environmental compliance exercised by the Engen Refinery.

I would also like to reiterate the deal agreed to during discussions with SDCEA at the Refinery Gate. I will attend a public meeting to debate the environmental issues if SDCEA agrees to attend Engen CLF meetings on a regular basis.

In conclusion, I would like to extend a very sincere invitation to you to select two political ecology students from the group who were on Tuesday's picket line to come and work in the Engen Refinery's Environmental Department during the university vacation so they can get a firsthand perspective of just how seriously we take our environmental responsibilities.

Willem Oosthuizen
General Manager
Engen Refinery