Managing the potential Health and Environmental Risk


Associated with the Proposed New Fuel Tank Farm, Multiproduct            

 Pipeline and Berth in Somaliland


The rapid growth that is currently taking place in many of the East African countries, including but not limited to Somaliland and the neighbouring Ethiopia has increased the demand for fuel (gasoline, diesel and jet fuel).  The demand amplified the pressure on Somaliland’s existing fuel storage facilities and associated infrastructures located in the coastal city of Berbera.  Being the only fuel tanks in Somaliland, it poses a high risk of fuel supply disruption and in the event of any incident or accident in thesefacilities or due to lack of insufficient storage capacity when the demand increases. Realizing this challenge and to meet with the goal of sustained growth and increased fuel demand, the government of Somaliland has been reported to shortly sign a concession agreement with Trafigure Pte Ltd to invest a debottlenecking project involving building of a new fuel tanks, fuel berth and associated pipelines, while also upgrading the existing infrastructures. At this stage the specifications of the agreement are not yet clear in terms of number of diesel, gasoline and jet fuel tanks, number of pipelines, number of berths and loading arms, etc.  However, albeit this may relief the pressure on fuel demand, but due to the nature of the project and its proximity to the communityand other sensitive receptors, there is the potential health and environmental risk. Thus, the need to carry out Environmental, Social and Health Impact Assessment (ESHIA) for the project is extremely important as required by not only Somaliland’sEnvironmental Law, but also international standards. The ESHIA will not only benefit the community and their environment, but it will also add a value to the project’s economic again in many ways.


The ESHIA is an international standard that allows the Front End Engineering and Design (FEED) of the project to apply the Best Available Technology (BAT) and a feasible site selection criteria. Accordingly, the design of any project should be based on BAT, whilst a scientific site appraisal should be used to determine the least sensitive location.  Furthermore, the ESHIA is also designed to offset the potential cumulative impacts that could arise not solely from theproposed project, but in combination of impacts generated by the surrounding projects including but not limited to the existing fuel farm, the port, pipelines and associated infrastructure. Failure to carryout ESHIA early in the planning stage of the project increasesthe significance of the risk both on the heath and the environment on the sounding receptors. The level of risk is determined based on many factors, including but not limited to the project’s distance to the community, marine, project’s design and retrofitted safety units.  Hence, it is important to take precaution measures during planning stage of the project and incorporate all safety measures including but not limited to retrofitting Leak Detection and Repair (LDAR) program and Emissions Recovery Systems (ERS) for Volatile Organic Compound (VOCs) and Non-Methyl-Hydrocarbons (NMHC) into the project. Moreover, as part of the ESHIA it is also vitally important to study the risk of fatality in case of Major Accident Hazards (MAHs) during the operations at the new fuel depot, tanks, berth or associated infrastructure and the consequences this may have to the nearby communities.

Furthermore, all risk reduction measures should be incorporated in the project construction including marinating a safe distance between Berbera city and project, between the project and other existing project, locating the project downwind of the city and putting in place adequate emergency response plan.

Somaliland’s Environmental Regulation (LR.79/2018)

The Somaliland’s Environmental Protection Law (Xeerka MaarayntaDeegaanka LR.79/2018) requires such projects to conduct an Environmental Impact Assessment (EIA) study to assess the health and environmental impacts from all phases, including construction, commissioning, operational and decommissioning activities of the project. The primary objective is to integrate environmental and health considerations into the decision-making process of project’s development phases. The ESHIA study is, therefore, a prerequisite to prevent, minimize and mitigate potential adverse environmental, socio-economic, and health impacts.


Like any other country in the world the Somaliland economy and human welfare benefits are dependent on availability of fuel supply. Accordingly, the implementation of such project could be considered to have a positive economic and social impacts. But, like any other project such benefits can only be seen if

1. A suitable location is selected for the project to avoid total loss in case of natural disaster or manmade disaster such as earthquake, explosion or hurricane or others. In addition, strategically speaking the current fuel storage location at Berbera is incompatible as it has so many constrains. Thus, a new location such as the coastal town of Bulahar only 65 km west of Berbera could be a viable alternative option for the project due to its close proximity to the capital (Hargeisa).  This option can also reduce traffic pressure from Berbera city by taken fuel tanks out of the city.

2. A proper ESHIA is conducted and all potential risks (e.g. spill, fire and explosions) and hazards are identified and addressedearly in the planning stage of the project.

3. The design is incorporated with a compatible material including but not limited use of LDAR, ERS and double roofstructure, one of them being a floating roof type, spill collection system, etc.

4. Tanks and infrastructure are periodically maintained in according with relevant international recommendations and standards such those of United States Environmental Protection Agency (US-EPA) or European UnionEnvironmental Protection Agency.

5. Due to the absence of fire water network in Berbera fuel tank area, minimum of two fire water storage tanks are requiredand their locations should be strategically selected. Also, due to the limitation of potable water in Berbera, the possibility of using sea water as a firewater should be assessed. The capacity of such tanks is extremely important and shall be technically determined based on the international best practice since the capacity regulates the number of hours the firefighting can last without the loss of water.

6. Nitrogen generation units is also required to generate necessary nitrogen gas that is used for blanketing fuel storage tanks.  It is vitally important to retain minimum of two nitrogen generation units so when one is in operation the other is standby.

7. In today’s world one of the most important issue for any infrastructure project is the need to incorporate appropriate adaptation measures to eliminate or minimize climate change impact.

8. An adequate emergency preparedness and response equipment that can be utilized during emergencies are maintained on site and staff are train on these equipment and procedures.

Mohammed Ibrahim Abdi