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SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
16.4.28.L2 - CHANGER AT THE LIQUID FERTILIZER PLANT
13 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
16.4.28.L2 - CHANGER AT THE LIQUID FERTILIZER PLANT
SECUNDA CHEMICALS OPERATIONS:
NITRO FERTILIZERS
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
BUILDING C
KNIGHTSBRIDGE, 33 SLOANE STREET
BRYANSTON, 2191
SOUTH AFRICA
T: +27 11 361 1392
F: +27 11 361 1381
WSP.COM
Q U A L I T Y M A N A G E M E N T
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft for Review –
Compliance Audit
Exemption Ref:
16.4.28.L2
Final – Compliance
Audit
Exemption Ref:
16.4.28.L2
Date April 2019 June 2019
Prepared by Ashlea Strong Ashlea Strong
Signature
Checked by Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 034 034
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
Ashlea Strong
Principal Consultant
REVIEWED BY
Jenny Cope
Associate
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf
and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding
of their compliance with the conditions included in the Environmental Authorisation.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
CLIENT
SHE: Environmental Compliance Specialist Broni van der Meer
Nitro Fertilizers Production Senior Manager,
Secunda Chemicals Operations
Tobie Visser
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Auditor Bronwyn Fisher
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
WSP June 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Changer at the Liquid Fertilizer Plant
(Authorisation Number: 16.4.28.L2) ...................... 1
2 AUDIT SCOPE ........................................... 3
3 AUDIT METHODOLOGY ........................... 4
3.1 Audit Checklist ........................................................ 4
3.2 Site Inspection ......................................................... 4
3.3 Documentation Considered ................................... 4
3.4 Audit Compliance Assessment .............................. 5
3.5 Audit Team ............................................................... 5
3.6 Assumptions and Limitations ................................ 6
4 AUDIT FINDINGS ...................................... 7
5 SUMMARY OF THE AUDIT FINDINGS ... 19
5.1 Environmental Exemption .................................... 19
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
WSP June 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7
TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 19
FIGURES
FIGURE 1: LOCATION OF THE LIQUID FERTILIZER PLANT AT SASOL SECUNDA (SOURCE: GOOGLE EARTH, 2018) ............................... 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 20
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 20
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 21
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 21
APPENDICES
A ENVIRONMENTAL EXEMPTION (16.4.28.L2)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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Page 1
1 INTRODUCTION
1.1 TERMS OF REFERENCE
Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP
Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit
and compile an audit report according to the requirements of the National Environmental Management Act (No.
107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the
Environmental Exemption (Reference number: 16.4.28.L2 issued on 28 November 2000) for the period
December 2014 to February 2019.
1.2 CHANGER AT THE LIQUID FERTILIZER PLANT
(AUTHORISATION NUMBER: 16.4.28.L2)
The Sasol Fertilizer division markets limestone ammonium nitrate (LAN), ammonium sulphate, ammonium
nitrate-based granular and liquid fertilisers and nitric acid to industrial clients, farmers, traders and fertiliser
companies.
The changer at the Liquid Fertilizer Plant is permitted in terms of Section 22 of the Environment Conservation
Act, 1989 (Act 73 of 1989) (ECA). The Exemption was received from the Mpumalanga Department of
Agriculture, Conservation and Environment (MDACE) on 28 November 2000 (Reference Number: 16.4.28.L2)
with conditions attached within the Record of Decision (RoD) (Appendix A).
It was reported and observed that the Liquid Fertilizer Plant is no longer operational, and is currently being
demolished.
Figure 1 provides an indication of the location of the Liquid Fertilizer Plant.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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Figure 1: Location of the Liquid Fertilizer Plant at Sasol Secunda (Source: Google Earth, 2018)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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2 AUDIT SCOPE The 7 April 2017 amendment to the Environmental Impact Assessment (EIA) regulations introduced the
requirement for the auditing for all EAs and EMPrs in effect on 8 December 2014 and submission of audit
reports to the Department of Environmental Affairs (DEA) by 7 December 2019 and every five years thereafter.
This audit is designed to meet the requirements of Regulation 34 of the EIA Regulations, 2014.
The audit period runs from December 2014 to February 2019, therefore any construction related conditions that
would have been relevant pre-December 2014 are considered not applicable (outside audit period).
The objective of the audit was to:
— Assess the level of compliance with the conditions of the Exemption;
— Identify and assess any new impacts and risks that result from undertaking the activity; and
— Make recommendations in order to achieve compliance in terms of the Exemption;
— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically:
— “Records relating to compliance/ non-compliance with the conditions of this authorization must be
kept in good order. Such records must be made available to the Department within seven (7) days from
the date of written Record of Decision.”
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the Exemption conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (15 March 2019);
— Review of documentation relevant to the conditions of the Exemption (e.g. records,
permits/certificates/maintenance logs/monitoring results/previous reports etc.); and
— Compilation of an audit report.
3.1 AUDIT CHECKLIST
WSP compiled an audit checklist to assist with the Exemption compliance audit (Section 4).
3.2 SITE INSPECTION
Environmental Consultant, Bronwyn Fisher, conducted the site inspection on 15 March 2019. The findings and
observations of the site visit are recorded and summarised in Section 4 with evidence included in Table 2. Key
personnel interviewed included:
— Tobie van der Vyver - Production Senior Manager Nitro Fertilizers;
— Pieter Stadler - Mechanical Senior Manager – Nitro;
— Ilze Swanepoel - SCO Senior Manager Environment; and
— Albert Wolfaardt - SHE Occupational Safety Manager Nitro.
It should be noted that no photographs were able to be taken during the site walk through due to the fact that the
Liquid Fertilizer Plant site was a construction site at the time of the audit and the auditor was unable to enter the
site due to the health and safety risks associated.
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— Sasol Compliance Statement – Water;
— 3.05_RESM Weekly Monitoring_2004-2019;
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20;
— Groundwater – Borehole map;
— Surface Water – Biannual monitoring points;
— Surface Water – RESM Points;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Compliance_Emergency Management_Secunda Complex;
— Environment emergency procedure_SGR-SHE000023_rev6_2015-11;
— Works emergency procedure_CGR-EMP-000001_Rev04_2016-02;
— EA_EX Handover_SCO_Poly_Nitro_Fert;
— Sasol Compliance Statement – Complaints;
— Environmental complaints procedure_SGR-SHE-000022_Rev04_2015-08;
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— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01;
— Environmental Complaints Register_2019-02-18;
— AEL Sasol Nitro 0020-2015-F02 (2016); and
— Various email correspondence.
3.4 AUDIT COMPLIANCE ASSESSMENT
WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2). The checklist included
the conditions and associated requirements as specified in the Exemption.
Each condition was verified, either by reviewing documentation, interviewing employees and/or visually
inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with
associated target completion dates included.
It should be noted that some of the Exemption conditions were apportioned according to the elements requiring
compliance assessment therein. Although some elements of the condition may have been compliant, if one of
the elements was determined to be non-compliant, the entire condition has been reported as such (and counted
as such during percentage compliance calculation). This apportionment further allowed for the development of
focussed recommendations and timeframes.
Table 1: Compliance Level Definition and Target Completion Dates
COMPLIANCE LEVEL DEFINITION
Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or
relevant actions were implemented.
Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented
according to the requirements of the Exemption. Non-complaint conditions are given target
completion dates, as follows:
— Short term: 0 – 6 months.
— Medium term: 6 – 12 months.
— Long term: 12 – 18 months.
Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.
— Conditions marked as “Noted” are considered information points only.
— Where conditions are considered “not auditable” within the scope of this assessment this
is stated and explained within the condition commentary.
Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion
dates).
3.5 AUDIT TEAM
The Environmental Consultant, Bronwyn Fisher, was hosted by Broni van der Meer; Tobie van der Vyver;
Pieter Stadler; Ilze Swanepoel and Albert Wolfaardt to whom we express our gratitude for their time and
attention during our visit. A brief summary of the external auditors’ experience is provided below.
— Auditor: Bronwyn Fisher
Bronwyn Fisher has 5 years of experience as an Environmental Consultant, undertaking Environmental
Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental
Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and
undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel
storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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recycling facilities, mixed-use developments, industrial developments and renewable energy technology
projects.
— Lead Auditor and Quality Assurance: Ashlea Strong
Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature
Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental
Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic
expertise on a diverse range of projects in the environmental management field, including environmental
scoping and impact assessment studies, environmental management plans, waste and water management, as
well as the provision of environmental management solutions and mitigation measures. She has been
involved in the management of a number of large EIAs within South Africa and has environmental auditing
and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed
in the audit process.
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a
range of sectors. Jenny’s recent experience includes completion and management of several pan-European
and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and
providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in
environmental consultancies and with a developer, giving context to understanding the practicalities of
implementing recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or
in connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.
Similarly, any recommendations, statements or conclusions drawn from or based on this report must make
reference to this report. If this report is used as part of a main report, the report in its entirety must be included
as an appendix or separate section to the main report.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
GENERAL CONDITIONS
1.01 This authorization refers only to the project specified and
described in the Record of Decision. Other than the area
indicated for in the map any changes in the Fedmis Delmas
Fertilizer Plant, separate application(s) must be lodged with
the Department for any development and/or activity on or
near the relevant property which is covered by Section 21 &
22 of the Act and Government Notices R1182 & R1183 of 5
September 1997.
N/A Noted. None.
1.02 Authorization is granted in terms of Section 22(3) of the
Environment Conservation Act 1989 (Act No. 73 of 1989)
and does not exempt the holder from compliance with any
other relevant legislation.
N/A Noted. None.
1.03 No development will take place in the area of concern
without the necessary permits/approvals and/or service
agreements from other relevant Authorities.
N/A This condition is considered outside of the audit period
(construction pre-2014).
It is therefore considered not applicable.
None.
1.04 Copies of documents mentioned under 1.3 above must be in
possession of this Department before any construction
commences.
N/A This condition is considered outside of the audit period
(construction pre-2014).
It is therefore considered not applicable.
None.
1.05 This Department may change add or amend any of the
conditions mentioned in this authorization if in the opinion
of the Department it is environmentally justified.
N/A Noted. Sasol has advised that no amendments have been received
in association with this Exemption.
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.06 A copy of this authorization shall be available at the site
office at all times and staff members and contractors shall be
conversant with its contents.
C Copies of all authorizations and licences are sent to, and details
communicated with, relevant business units. Copies of these
documents are also available at the SHE: Environment department
and on SAP EC and SharePoint.
Evidence:
— EA_EX Handover_SCO_Poly_Nitro_Fert
None.
1.07 The proposed mitigation measures, as set out in the
information provided in the application shall strictly be
adhered to.
NC The mitigation measures, as set out in the information provided in
the application were not available for review. Therefore, this
condition cannot be verified.
None.
1.08 The record of Public participation shall be sent to this
Department for record keeping purpose. N/A This condition is considered outside of the audit period
(construction pre-2014).
It is therefore considered not applicable.
None.
ESTABLISHMENT OF THE DEVELOPMENT
2.01 This authorization is repealed if development has not started
within three (3) years from the date of issue. N/A This condition is considered outside of the audit period
(construction pre-2014).
It is therefore considered not applicable.
None.
2.02 If decision is taken to discontinue the operation, sell or
transfer ownership or infra-structure on the site in any way,
this Department must be informed of such decision within
twelve (12) months prior to the date of implementing such a
decision.
NC During the site walkover the auditor was informed that the plant
has been decommissioned.
The auditor was informed that the Department was not informed of
the decision to discontinue the operation within 12 months prior to
the implementation of the decision.
It is recommended that
Sasol inform the
Department that the Plant
has been decommissioned.
Target Completion:
Short Term
2.03 In the event of 2.2 above, this Department shall be notified
about the rehabilitation plans. N/A During the site walkover the auditor was informed that the plant
has been decommissioned. . It is noted that a new plant is being
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
built on the site and therefore there are no current plans to
rehabilitate the site.
CONSTRUCTION AND OPERATION
3.01 This development will take place according to conditions
and requirements by the Department of Agriculture,
Conservation & Environment.
N/A Noted. This condition is considered outside of the audit period
(construction pre-2014).
None.
3.02 If any change(s) need to be made in the plan of the said
development or replacement of any of its structures, this
Department must be informed thirty (30) days in advance to
decide whether such change(s) will need authorization or
not.
N/A During the site walk over, the auditor was informed that the Plant
has been decommissioned.
It was also noted that Sasol are in the process of building a new
facility within the footprint of the previous plant, however it is
noted that the new facility is not related to changer at Liquid
Fertilizer Plant. Sasol informed the Auditor that no authorisations
were required for the new facility.
None.
WATER POLLUTION
4.01 It is the responsibility of Fedmis Delmas Fertilizer and the
Contractor on site to prevent any surface as well as ground
water pollution.
NC The IWWMP aims to identify the activities related to Sasol’s
operations within the context of the receiving environment (with a
focus on water resource protection), identify the risks associated
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management.
The Auditor verified that the Liquid Fertiliser Plant is included in
the IWWMP.
Groundwater:
Ground water monitoring is conducted biannually and quarterly.
JMA Consulting is an independent contractor appointed to
complete sampling and bi-annual reporting for Sasol. The auditor
verified that the Groundwater Quality Report compiled by JMA
Consulting. Report number: JMA/Prj6129 Rev-01; Dated:
It is recommended that a
remediation action plan is
compiled and executed to
rectify the elevated water
quality variables in both the
surface and ground water at
the site.
Target Completion:
Medium Term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
November 2018 included groundwater monitoring of boreholes
established for the Liquid Fertiliser Plant.
The Auditor noted that 19 out of 36 boreholes are monitored
biannually at the Liquid Fertiliser Plant. The water quality analysis
of the borehole samples highlight elevated EC, TDS, Ca, Mg, Na,
SO4, NO3, Mn, NH4, NO2 and E.Coli showing that the
groundwater in this area is polluted.
Surface Water:
Surface water monitoring is done on a weekly basis as well as real
time for the various RESMs. Sasol monitor the Bossiespruit,
Brandspruit, Kleinspruit, Klipspruit and Trichardspruit,
Surface water is also monitored biannually at two sumps at the
Liquid Fertilizer Plant. The water quality analysis of these two
points highlights elevated concentrations for Ca, Mg, Na, K, Cl,
SO4, NO3, Mn, NH4 and B, showing that these surface water points
are polluted.
Evidence:
— Sasol Compliance Statement – Water
— 3.05_RESM Weekly Monitoring_2004-2019
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
— Groundwater – Boreholes:
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Monitoring boreholes established at the Liquid Fertiliser Plant
— Surface Water – Biannual monitoring points
Biannual Surface Water monitoring points at the Liquid Fertiliser Plant
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Surface Water – RESM Points:
Location of the RESM monitoring points monitored on a continuous basis
4.02 In case of non-compliance with regulations, the burden of
proof rests with Fedmis Delmas Fertilizer and/or relevant
contractor.
N/A Noted None
WASTE MANAGEMENT
5.01 All waste generated during the proposed changes in the said
plant or any other related activities will be handled and
disposed of in the registered landfill site and must be to the
satisfaction of this Department and/or any relevant authority.
N/A It is noted that the plant has not been operational since the first half
of 2015 therefore this condition is considered Not Applicable
None.
5.02 Any hazardous waste that may result in the process shall be
disposed of in the environmentally acceptable way and is
directed by this Department and any other relevant authority.
N/A It is noted that the plant has not been operational since the first half
of 2015 therefore this condition is considered Not Applicable
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
RISK ASSESSMENT
6.01 All employees who will be working in the construction and
operation of the said development shall be well equipped
with the emergency procedures in case of an accident.
C When an environmental emergency occurs the area / unit must
report it to Emergency Management at Tel: 10- 4444 / 10 2444
who will inform the Environmental Management Services standby
person and Market and Market Integration.
The environmental emergency is addressed in accordance with the
following procedures:
— Sasol Secunda Work Emergency Procedure (Reference
Number: CGR-EMP-000001); and
— Response to environment related emergencies and a guideline
to other incidents (Reference Number: SGR-SHE-000023)
Operation specific Emergency Management Plans can be found on
Sasol’s IMS.
In addition, Sasol advised the auditor that it has a Governance SHE
Risk and Assurance department that assesses environmental risks
and drives implementation by business.
The SHE Environment department facilitates Environmental Risk
Assessments per business entity to ensure that gaps are addressed
through implementation of mitigation measures via the Integrated
Management System. Sasol further addresses all Key Undesirable
Events (KUEs) from a group perspective.
A Procedure was viewed by the auditor that defines the
requirements, responsibilities, and the process to be followed in the
management, execution, and control of environmental risk
assessments.
Evidence:
— Compliance_Emergency Management_Secunda Complex
— Environment emergency procedure_SGR-
SHE000023_rev6_2015-11
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Works emergency procedure_CGR-EMP-
000001_Rev04_2016-02
6.02 The owner of the property must ensure that all issues and
concerns of the affected parties are addressed as stated in the
information provided in the application.
C All environmental complaints received from interested and
affected parties, both internal and external to the organisation, are
recorded in a complaints register that is available at the
Environmental department. Complaints are investigated and
reported in line with the procedure and as per legal requirements.
Environmental complaints contact details are communicated to
internal and external stakeholders.
A procedure relating to complaints from stakeholders (SGR-SHE-
000022) has been implemented at the Sasol Secunda Complex. The
complaints and/or incidents register verified by the auditors
confirmed that no complaints have been logged regarding the
Liquid Fertiliser Plant during the audit period.
Evidence:
— Sasol Compliance Statement – Complaints
— Environmental complaints procedure_SGR-SHE-
000022_Rev04_2015-08
— Environmental complaints procedure_SGR-SHE-
000022_Rev05_2019-01
— Environmental Complaints Register_2019-02-18
None.
AIR POLLUTION
7.1 As directed by relevant authority. C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental
Management: Air Quality Act. Sasol works closely with the local
authority and operates units in line with the relevant AEL and
minimum legal emission requirements.
Evidence:
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— AEL Sasol Nitro 0020-2015-F02 (2016)
MONITORING
8.01 Monitoring systems must be installed by the operator of the
plant to detect any form of ground and or surface water
pollution and to ensure the maintenance of the acceptable
ground and/or surface water quality.
C Groundwater:
Ground water monitoring is conducted biannually and quarterly.
JMA Consulting is an independent contractor appointed to
complete sampling and bi-annual reporting for Sasol. The Auditor
verified that the Groundwater Quality Report compiled by JMA
Consulting. Report number: JMA/Prj6129 Rev-01; Dated:
November 2018 included groundwater monitoring of boreholes
established for the Liquid Fertiliser Plant.
The Auditor noted that 19 out of 36 boreholes are monitored
biannually at the Liquid Fertiliser Plant.
Surface Water:
Surface water monitoring is done on a weekly basis as well as real
time for the various RESMs. Sasol monitor the Bossiespruit,
Brandspruit, Kleinspruit, Klipspruit and Trichardspruit,
Surface water is also monitored biannually at two sumps at the
Liquid Fertilizer Plant.
Evidence:
— Sasol Compliance Statement – Water
— 3.05_RESM Weekly Monitoring_2004-2019
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
— Groundwater – Boreholes:
OFI:
It is recommended that a
remediation action plan is
compiled and executed to
rectify the elevated water
quality variables in both the
surface and ground water at
the site.
Target Completion:
Medium Term
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Monitoring boreholes established at the Liquid Fertiliser Plant
— Surface Water – Biannual monitoring points
Biannual Surface Water monitoring points at the Liquid Fertiliser Plant
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Surface Water – RESM Points:
Location of the RESM monitoring points monitored on a continuous basis
8.02 The Department must be granted access to the property at
any reasonable time to investigate any possible
environmental impacts that may be caused by the operation
of the facility.
N/A Noted. None
REPORTING
9.01 Records relating to compliance/ non-compliance with the
conditions of this authorization must be kept in good order.
Such records must be made available to the Department
within seven (7) days from the date of written Record of
Decision.
N/A This Audit represents the first required audit for this Exemption.
Prior to the introduction of the 7 April 2017 amendment to the
Environmental Impact Assessment (EIA) regulations, no audit
against this Exemption was required.
None.
9.02 Non-compliance or any deviation from the conditions of this
authorization will be regarded as an offence, and after
reasonable provision has been made for remedial action,
shall be dealt with in terms of Section 29, 30 & 31A of the
Act.
N/A Noted. Sasol has confirmed to the auditor that no communications
have been received from the Authorities regarding non-
compliances.
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
9.03 Any complaint regarding to the said development must be
thoroughly investigated and addressed to the satisfaction of
all parties concerned. Copies of such a complaint must be
forwarded to this Department within forty eight (48) hours.
C All environmental complaints received from interested and
affected parties, both internal and external to the organisation, are
recorded in a complaints register that is available and the
Environmental department. Complaints are investigated and
reported in line with the procedure and as per legal requirements.
Environmental complaints contact details are communicated to
internal and external stakeholders.
A procedure relating to complaints from stakeholders (SGR-SHE-
000022) has been implemented at the Sasol Secunda Complex. The
complaints and/or incidents register verified by the auditors
confirmed that no complaints have been logged regarding the
Liquid Fertiliser Plant during the audit period.
Evidence:
— Sasol Compliance Statement – Complaints
— Environmental complaints procedure_SGR-SHE-
000022_Rev04_2015-08
— Environmental complaints procedure_SGR-SHE-
000022_Rev05_2019-01
— Environmental Complaints Register_2019-02-18
None.
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL EXEMPTION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the Exemption conditions are as listed in Table
3 below.
Table 3: Summary of Exemption Compliance Audit Findings
SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 8 1 1 6
ESTABLISHMENT OF THE DEVELOPMENT 3 0 1 2
CONSTRUCTION AND OPERATION 2 0 0 2
WATER POLLUTION 2 0 1 1
WASTE MANAGEMENT 2 0 0 2
RISK ASSESSMENT 2 2 0 0
AIR POLLUTION 1 1 0 0
MONITORING 2 1 0 1
REPORTING 3 1 0 2
Total Count 25 6 3 16
Total Percentage 24% 12% 64%
Percentage Compliance with Applicable Conditions 67%
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS
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Figure 2 illustrates the number/count contribution of the findings of the Exemption per section while Figure 3
presents the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the Exemption conditions per Section
Figure 3: Overall count findings on compliance to the Exemption conditions
0123456789
Sectional Count Contribution
C
NC
N/A
6
316
Total Compliance
C
NC
N/A
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Figure 4 illustrates the percentage contribution of the findings of the Exemption conditions. Figure 5 presents
the total percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the Exemption conditions per Section
Figure 5: Overall percentage findings on compliance to the Exemption conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
24%
12%64%
Total Percentage Compliance
C
NC
N/A
APPENDIX
A ENVIRONMENTAL EXEMPTION
(16.4.28.L2)
Recommended