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SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
1/3/1/16/1 G-21 - N-PROPANOL DE-BOTTLENECKING PROJECT
29 MAY 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
1/3/1/16/1 G-21 - N-PROPANOL DE-BOTTLENECKING PROJECT
SASOL CHEMICAL OPERATIONS:
SOLVENTS DIVISION
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: MAY 2019
WSP
BUILDING C
KNIGHTSBRIDGE, 33 SLOANE STREET
BRYANSTON, 2191
SOUTH AFRICA
T: +27 11 361 1392
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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
EA Ref: 1/3/1/16/1
G-21
Draft for Review –
Compliance Audit
EA Ref: 1/3/1/16/1
G-21
Final – Compliance
Audit
EA Ref: 1/3/1/16/1
G-21
Date April 2019 May 2019 May 2019
Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher
Signature -
Checked by Jenny Cope Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534 41101534
Report number 002 002 002
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
-
Bronwyn Fisher
Environmental Auditor
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 and associated
Environmental Management Plan.
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 Specialist: Environment Broni van der Meer
Process Maintenance Coordinator Henning van Buuren
Production Asset Management Specialist Abednego Sibanyoni
Grade 2 Process Artisan Lorenzo Peters
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Bronwyn Fisher
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP May 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 N- Propanol De-bottlenecking Project (SASOL
CHEMICAL OPERATIONS: SOLVENTS DIVISION)
(Authorisation Number: 1/3/1/16/1 G-21) ............... 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 ............................................................... 6
3.6 Assumptions and Limitations ................................ 6
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 44
5.1 Environmental Authorisation ............................... 44
5.2 Environmental Management Plan ........................ 46
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP May 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 24
TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 44
TABLE 5: SUMMARY OF EMP COMPLIANCE AUDIT FINDINGS .................................... 46
FIGURES
FIGURE 1: LOCATION OF THE DEBOTTLENECKING PROJECT (RED BLOCK) WITHIN SASOL SECUNDA PRIMARY AREA (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 44
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 45
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 45
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 46
FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 47
FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 47
FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 48
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP May 2019
FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMP CONDITIONS ............. 48
APPENDICES
A ENVIRONMENTAL AUTHORISATION (1/3/1/16/1- G-21)
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP May 2019
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 Authorisation (EA) (Reference number: 1/3/1/16/1 G-21 issued on 14 March 2016) as well as the
associated Environmental Management Plan (dated: October 2015) for the period December 2014 to February
2019.
1.2 N- PROPANOL DE-BOTTLENECKING PROJECT
(SASOL CHEMICAL OPERATIONS: SOLVENTS
DIVISION) (AUTHORISATION NUMBER: 1/3/1/16/1 G-21)
Unit 038N, Figure 1, produces N-propanol (NPA) from Propylol (mixed alcohol) feedstock, which is obtained
from an upstream alcohol recovery Unit (Unit 38N), located within the Secunda Complex. The capacity of Unit
38 was increased after the implementation of several debottlenecking projects. The current bottleneck is the
treatment of Propylol in Unit 038N.
In 2016 Sasol received an EA to implement changes to the existing Unit 038N that would optimise the recovery
of NPA of the Unit 038N; increasing NPA production from 172 to 235.4 tonnes/day. The capacity increase was
realised through increasing Propylol feed from 246.7 to 340.8m3/day (198.7 to 275.3 tonnes/day). This is an
increase of 94.1 m3/day (76.6 tonnes/day).
In Unit 038N Purification is completed by means of extractive distillation with a solvent. The solvent is then
recovered by conventional vacuum distillation and recycled to the extraction process. By-product is recovered as
fuel alcohol.
The purpose of Unit 038N is to concentrate NPA up to a purity of at least 99.9 weight percentage. The main
impurity is 2-Butanol (SBA). The SBA is removed from the NPA by means of extraction with a heavy, non-
polar solvent. The solvent used consists typically of about 48 weight percentage C12 paraffin, 48 weight
percentage C13 paraffin with the remainder being paraffins lighter and heavier than C12 and C13.
The feed to Unit 038N comes from 56TK-3838 and is a mixture of alcohols, typically about 90 weight
percentage NPA and 8.5 weight percentage SBA, with the remainder heavier alcohols. The feed stream passes
through two feed/effluent heat exchangers in which it is heated via exchanging heat with the recycling solvent.
The feed enters the NPA column (38VL-201) in the lower half of the column.
The majority of the NPA is removed as primary product in the overhead of the NPA column. Liquid from the
bottom tray of the NPA column is passed through a side reboiler (38ES-202) where heat is recovered from the
recycled solvent. The liquid/vapour mixture from the side reboiler is returned to the NPA column above a
chimney tray, from where the liquid is fed to the NPA column reboiler (38ES-201R1). The liquid from the NPA
column reboiler, consisting of NPA, SBA and the solvent, is returned to the NPA column from where it is fed to
the solvent column (38VL3-202).
The remainder of the NPA and SBA in the solvent column are taken overhead as product while the solvent in
the bottom is recycled to the NPA column for extraction. The solvent from the bottom of the solvent column
passes through the NPA column side reboiler, then exchanges heat with the fresh feed stream in 38ES-204, after
which it is cooled in an air cooler, 38EA-213, and then finally exchanges more heat with the fresh feed in 38ES-
209. The solvent is then fed to the top half of the NPA column.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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Page 2
Figure 1: Location of the Debottlenecking Project (red block) within Sasol Secunda Primary Area (Source: Google Earth, 2018)
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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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 all construction related conditions are
considered applicable (within audit period).
The objective of the audit was to:
— Assess the level of compliance with the conditions of the EA and EMPr;
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
and where applicable, the closure plans achieve the objectives and outcomes laid out in these documents;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Critically evaluate the effectiveness of the EMPr;
— Identify shortcomings in the EMPr;
— Identify the need for any changes to the avoidance, management and mitigation measures provided for in
the EMPr; and
— Make recommendations in order to achieve compliance in terms of the EA and EMPr.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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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 EA and associated EMPr conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (14 March 2019);
— Review of documentation relevant to the conditions of the EA and associated EMPr (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 EA and EMPr compliance audit (Section 4).
3.2 SITE INSPECTION
Bronwyn Fisher conducted the site inspection on 14 March 2019. The findings and observations of the site visit
are recorded and summarised in Section 4 with evidence included in Table 2 and Table 3. Key personnel
interviewed included:
— Lorenzo Peters (in the absence, and under the direction of Henning van Buuren).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— 15. NPA Debottlenecking - EA - 14-03-16;
— 11._NPA_Debottlenecking_-_EMPr_Final;
— 10. NPA Debottlenecking - Final BAR Report (all Appendixes);
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP Final_SRK-505119_2016-11-01;
— EA_EX Handover_SCO_Solvents_CWU_EA;
— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27;
— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to MDARDLEA
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals Operations;
— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted;
— 3.15_EA_1.3.1.16.1 G-21_NPA_Appoint SRK as ECO;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-09-23;
— 3.16_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints Register_2016-10-31 – Copy;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Incidents Register_SRK-505119_2016-09-09;
— 3.17_EA_1.3.1.16.1 G-21_Courier_ECA report to MDARDLEA_2016-10-31;
— 3.17_EA_1.3.1.16.1 G-21_NPA_ECA EMP_Final_SRK505119_2016-11-01;
— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27;
— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to MDARDLEA;
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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Page 5
— 3.21_EA_1.3.1.16.1 G-21_NPA_AEL variation app_approval commission_2016-09-13;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklis_SRK-505119_Rev01_2016-08-29;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-07-08;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-07-15;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-07-26;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-08-10;
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-08-15;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017- 2022 Rev_0;
— Environmental Complaints Register_2019-02-18;
— EA_EX Handover_SCO_Solvents_CWU_EA;
— 1_EMP_1.3.1.16.1 G-21_NPA_Communicate_EMP_contractors;
— 2.1_EMP_1.3.1.16.1 G-21_NPA_ECO_EnvToolboxTalks_2016-10-31;
— Labour_Sasol IRM Suppliers Industrial Relations Procedure;
— Induction_Mod2_Security;
— Induction_Mod5_WorkPlaceSafety;
— 3.35_EA_1.3.1.16.1 G-21_NPA_ECO_Incident Register_2016-10-31;
— SCO DQS BSOHSAS 18001 2007;
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18;
— SEC-116-2017-CM(NOISE)(Chemical_Work_Up_West,_Production,_Units_037,_038,_038N,_073); and
— Various email correspondence.
3.4 AUDIT COMPLIANCE ASSESSMENT
WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and Table 3). The
checklist included the conditions and associated requirements as specified in the EA and associated EMPr.
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 EA and associated EMPr 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 EA and associated EMPr. 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.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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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 auditor, Bronwyn Fisher, was hosted by Lorenzo Peters and Broni van der Meer 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 6 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,
recycling facilities, mixed-use developments, industrial developments and renewable energy technology
projects
— 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
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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Page 7
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 AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
SCOPE OF AUTHORISATION
3.01 Environmental Authorisation of the activities is subject to
the conditions contained in this authorisation that are part of
the Environmental Authorisation and are legally binding on
the holder of the authorisation.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
3.02 The holder of the Environmental Authorisation must ensure
compliance with the conditions by any person acting on his
or her behalf, including but not limited to, an agent, sub-
contractor, employee or person rendering a service to the
holder of the Authorisation,
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
3.03 The activities that are authorised may only be carried out at
the property indicated above. C The auditor undertook a desktop review using Google Earth to
determine the site coordinates. The auditor confirms that the
coordinates within the EA match the location of the project (refer
to Figure 1).
Evidence:
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Location of the coordinates of the plant as per the EA.
3.04 In the event of any dispute concerning the significance of a
particular impact, the opinion of the Department in respect of
its significance will prevail.
N/A Noted. Sasol has advised the auditor that no dispute has occurred
with the Department regarding the significance of an impact.
None.
3.05 A copy of this Environmental Authorisation must be made
available on site at all times and all relevant staff, contractors
and sub-contractors must be familiar with the contents of this
authorisation.
C Sasol provided the auditor with a copy of the Environmental
Control Officer (ECO) Report. The Report was compiled by SRK
as the independent ECO fort the duration of the construction
period. The ECO report provided evidence that the all contractors
involved with the construction activities were provided with a copy
of the EA and were provided with environmental awareness
training, which covered the conditions of the EA.
The auditor was advised by Sasol that copies of all authorisations
and licenses 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.
Sasol provided the auditor with the evidence that the responsible
persons, Alfie Naidoo (Senior Manager of Chemical Workup Units
and Ethyl Acetate, Solvents) and Wilem Jacobs (legal appointee of
Polymers and Nitro), were made aware of the EA in
September/October 2016.
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
— EA_EX Handover_SCO_Solvents_CWU_EA
The location of the EAs and EMPrs on the SAP EC.
3.06 Any changes to, or deviations from the project description
set out in this Environmental Authorisation must be
approved in writing, by the Department before such changes
or deviations may be effected. In assessing whether to grant
such approval or not, the Department may request such
information as it deems necessary to evaluate the
significance and impacts of such changes or deviations and it
may be necessary for the holder of the authorisation to apply
for further Environmental Authorisation in terms of the
regulations.
N/A Noted. Sasol confirmed with the auditor that no changes or
deviations have been made to the project description as set out in
the EA.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.07 These activities must commence within a period of four (4)
years from the date of issue. If commencement of the
activates do not occur within that period, the Environmental
Authorisation lapses and a new application for
Environmental Authorisation must be made in order for the
activities to be undertaken, unless the holder of this
environmental authorisation has lodged a valid application to
amend the validity period of this authorisation before this
authorisation lapses, in which case this authorisation will
remain valid. However, the activities, including site
preparations may not commence prior to the amendment
application being decided. The Department may change or
amend any of the conditions in this authorisation if, in the
opinion of the Department is environmentally justified.
C Construction activities commenced within approximately 3 months
of the issuing of the EA. This was confirmed in an email and
supporting letter from Sasol to the Department notifying them of
the commencement of construction activities. In addition, the
auditor was provided with the ECO report from the construction
period, which confirmed the commencement of construction in
June 2016.
Evidence:
— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27
— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to
MDARDLEA
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
None.
3.08 The Department may change or amend any of the conditions
in this authorisation if, in the opinion of the Department, it is
environmentally justified.
N/A Noted. Sasol has advised the auditor that no amendments have
been requested by the Department.
None.
3.09 This Environmental Authorisation does not negate the holder
of the authorisation, responsibility to comply with any other
statutory requirements that may be applicable to the
undertaking of the activities.
N/A Noted. A full legal review does not form part of the scope of this
Audit.
The site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review, which specifically
states “the development of the compliance risk management
protocol (CRMP) to assist the organization to reach a higher level
of legal compliance is commendable”.
Evidence:
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals
Operations.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.10 The holder of this authorisation is responsible for
compliance with the provisions for Duty of Care and
Remediation of Environmental Damage contained in Section
28 of the National Environmental Management Act, 1998
(Act 107 of 1998).
N/A Noted. Sasol are aware of their responsibility for compliance with
the provisions of the Duty of Care and remediation of
Environmental Damage.
None.
APPEAL OF AUTHORISATION
3.12 The holder of the authorisation must notify every registered
interested and affected party, in writing and within 14 days,
of receiving notice of the Department`s decision to authorise
the activities.
C Sasol provided the auditor with proof that an advert was placed in
the Ridge Times notifying all interested and affected parties of the
Department’s decision. The advert was placed on 25 March 2016,
11 days after the EA was issued.
Evidence:
— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted
None.
3.13
The notification referred to above must:
a) Specify the date on which the authorisation was issued;
b) Inform the interested and affected parties of the appeal
procedure provided for in Chapter 2 of the regulations; and
c) Advise the interested and affected parties that a copy of
the Environmental Authorisation and reasons for the
decision will be furnished on request
C The advert placed in the Ridge Times on the 25 March 2016
specified the date on which the decision was issued, informed IAPs
on the appeal procedure, and provided details of who to contact to
request a copy of the EA.
Evidence:
— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted
None.
MANAGEMENT AND MONITORING
3.14 The Environmental Management Programme (EMPr) dated
October 2015, as incorporated in the Final Basic Assessment
Report for Environmental Authorisation is hereby approved.
N/A Noted. None.
3.15
The applicant must appoint an independent Environmental
Control Officer (ECO) that will have the responsibility of C Sasol appointed SRK Consulting (South Africa) Pty Ltd (SRK) as
the ECO for the duration of the construction phase. A copy of the
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
implementing the approved EMPr and ensuring compliance
with the conditions of this Environmental Authorisation
ECO report compiled by SRK as well as the competency of the
responsible ECO was provided to the auditor.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
— 3.15_EA_1.3.1.16.1 G-21_NPA_Appoint SRK as ECO
3.16 The ECO must maintain the following on site:
a) Strict compliance of the development to the conditions of
the Environmental Authorisation.
b) Discuss and advise contractor on site in respect of
environmental compliance before and during construction
activities.
c) Monitor compliance during construction and operation
phases of the activities.
d) Keep a site diary
e) Keep a complaints` register of all environmental
complaints regarding the proposed project and the remedies
applied to such complaints.
C The auditor was provided with the ECO report, which ensures
compliance of all construction conditions. The ECO was not
appointed to monitor compliance during the operational phase.
This is the responsibility of the Sasol SHEQ Managers. The ECO
report shows compliance with the following:
(a) Strict compliance of the development to the conditions of the
Environmental Authorisation. The ECO was onsite weekly to
monitor compliance with the conditions of the EA and the
EMPr. Contractors were advised on good environmental
practise and means to improve compliance where considered
by the ECO to be appropriate.
(b) Discuss and advise contractor on site in respect of
environmental compliance. The ECO report indicates that the
contractor was provided with environmental awareness
training and provided Toolbox talks on a regular basis
covering a variety of environmental topics.
(c) Monitor compliance during construction and operation phases
of the activities. The ECO undertook weekly site audits during
the construction phase. However, the ECO was not appointed
to monitor the construction phase.
(d) Keep a site diary. Although no evidence specifically of a site
diary was provided within the ECO report, weekly checklists
were compiled. An incidents register was maintained during
the construction phase and all non- conformances were
reported within the incidents register. Such activities are
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
generally considered consistent with the typical contents of a
site diary.
(e) Keep a complaints register of all environmental complaints
regarding the proposed project and the remedies applied to
such complaints. A complaints register was kept onsite during
the construction phase and attached to the ECO report. No
complaints had been recorded within the register, and the ECO
reported that no complaints were received during the
construction period.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-09-23
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
— 3.16_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints
Register_2016-10-31 – Copy
— 3.16_EA_1.3.1.16.1 G-21_NPA_Incidents Register_SRK-
505119_2016-09-09
3.17 The holder of the authorisation must submit a post-
construction environmental audit report to the Department
within 30 (thirty) days after completion of each authorised
activities on site.
C The auditor was provided with a copy of the final ECO audit
report, dated November 2016. The ECO report as couriered to the
department by SRK on 31 October 2016.
Evidence:
— 3.17_EA_1.3.1.16.1 G-21_Courier_ECA report to
MDARDLEA_2016-10-31;
— 3.17_EA_1.3.1.16.1 G-21_NPA_ECA
EMP_Final_SRK505119_2016-11-01.
None.
3.18 The Department retains the right to monitor and/or inspect
the proposed project during both construction and
operational phases.
N/A Noted. Sasol advised the auditor that the Department comes to site
to monitor operational activities on a regular basis
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
COMMISSIONING & OPERATION
3.19 Fourteen (14) days written notice must be given to the
Department that the activities will commence.
Commencement for the purposes of this condition includes
site preparation. The notice must include a date on which it
is anticipated that the activities will commence.
C Construction activities commenced within approximately 3 months
of the issuing of the EA. This was confirmed in an email (dated 27
May 2016) and supporting letter from Sasol to the Department
notifying them of the commencement of construction activities,
which were planned for end of June 2016 (therefore >14 days). In
addition, the auditor was provided with the ECO report from the
construction period, which confirmed the commencement of
construction in June 2016.
Evidence:
— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27
— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to
MDARDLEA
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
None.
3.20 The conditions stipulated in this Environmental
Authorisation and mitigation measures contained in the final
environmental impact report are legally binding components
of any contract and are therefore legally enforceable.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
3.21
The current N-propanol plant’s Air Emission License must
be amended, therefore no construction must take place
before the Air Emission License from the Gert Sibande
District Municipality is being amended and/or issued.
C Sasol received permission, via email on 14 September 2016, from
Nomsa Thabethe at the Gert Sibande District Municipality, that
they can commence with commissioning of the plant.
It is the auditor’s understanding that an application for an
amendment to the Sasol Solvents’ AEL (which was issued in
March 2015) had been lodged prior to the commissioning of the
plant. Whilst the amended AEL has not yet been received, the
Department did acknowledge the application at the time and gave
permission to continue the operations.
Evidence:
OFI:
Sasol should follow up with
the Gert Sibande District
Municipality with regards to
the Amended AEL.
Completion Target:
Medium term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— 3.21_EA_1.3.1.16.1 G-21_NPA_AEL variation app_approval
commission_2016-09-13
3.22 Measures must be undertaken to ensure the prevention or
minimization of erosion during construction. Such measures
must take into account the period in which construction takes
place.
C Sasol appointed an ECO to undertake monitoring of compliance
against the EMPr and EA. The weekly checklists undertaken by
the ECO showed no erosion issues or incidents were noted during
the construction phase. This is largely attributed to the location of
the construction activities within the existing Sasol Complex and
the existence of a stormwater management system.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklis_SRK-
505119_Rev01_2016-08-29
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-07-08
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-07-15
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-07-26
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-08-10
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-08-15
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-09-02
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-09-05
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-09-16
— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-
505119_Rev01_2016-09-23
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
3.23 Any complaints received from the employees or anyone
within the immediate vicinity of the site during the
construction and operational phases of the activity must be
attended to as soon as possible and addressed to the
satisfaction of all involved.
C During the construction phase a complaints register was
maintained onsite and provided to the auditor with the Final ECO
Report. No complaints were received.
Sasol has advised the auditor that 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.
The auditor has reviewed the complaints register maintained by
Sasol. No complaints have been received in relation to the
operating of the Debottlenecking Plant for the audit period.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
— 3.23_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints
Register_2016-10-31
— Environmental Complaints Register_2019-02-18
None.
3.24
Dust suppression measures must be implemented during all
phases of the project. N/A The auditor was provided with the ECO Report and all ECO
weekly checklists. The ECO Report noted that the activities
conducted during the construction phase did not require dust
suppression. Although the ECO Report does not provide a reason it
is assumed that it was due to the minimal soil disturbance
undertaken as part of the construction activities,
In addition, the operational activities at the 038N unit do not
generate dust and therefore dust suppression is not necessary. This
was confirmed by the auditor during the site walk over.
Evidence:
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP
Final_SRK-505119_2016-11-01
Entire plant is hard surfaced.
3.25 All hazardous materials must be stored in designated, lined
and bounded areas. C The auditor observed that hazardous substances being stored onsite
are done so in tanks. The tanks are located within bunded areas.
Evidence:
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Storage tanks associated with U38N, located within bunded tank farms.
3.26 The handling and storage of any hazardous waste must
comply with the relevant statutory requirements. C The auditor was advised that waste management is managed
through implementation of a Waste Management procedure (SGR-
SHE-000017 REV10), which provides the approach of managing
waste in line with the internationally accepted waste hierarchy.
According to this hierarchy, disposal to land is considered the last
management option to undertake once avoidance, re-use, recycling,
recovery and treatment options have been considered / eliminated.
The procedure further details waste disposal and management
through characterization and classification that is detailed in site-
specific waste registers.
Waste Registers were made available to the auditor. A sample of
the registers specifically related to the Solvent operations were
checked during the audit. It is however noted that, during normal
operations, no waste is produced – as by-products are either
recovered or sent back into the wider Sasol Secunda system.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Sasol Secunda Industrial Complex, Mpumalanga IWMP
2017- 2022 Rev_0.
3.27 All general waste generated on site must be disposed of at a
registered landfill site or as directed by relevant authority. C The auditor viewed the Waste Management procedure that is in
place, and this provides an approach to manage waste in line with
the internationally accepted waste hierarchy, waste classification
and characterisation (see above).
General waste is disposed of at the Sasol waste management
facility, located at Charlie 1.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09
None.
3.28 It is the responsibility of the holder of the authorisation to
rectify any source of pollution and to take appropriate
measures to prevent any pollution of surface and ground
water.
C The auditor has noted that 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 noted the following precautions that have been put in
place to prevent surface and ground water pollution:
— The entire plant is bunded and hardsurfaced;
— There plant has both a Chenicals Conservation Sewer (CCS)
to drain all spilled feed or product back to eh feed tank,
— There is an Oily Water Sewer (OWS) for all stormwater
falling within the plant;
— Surface and groundwater monitoring is done in accordance
with the IWWMP.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— SIC IWWMP Action Plan Update_FY18_20180123;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
3.29 Appropriate ablution facilities must be provided for the
construction team. C The ECO report provided by Sasol confirmed that permanent
ablution facilities, located within the operational areas, were made
available to the contractor for the duration of the construction
activities.
Evidence:
— 3.26_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
3.30
Spillages must be cleaned up as soon as it is practically
possible to prevent soil and water pollution. C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which 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 plant has been designed in such a way that should any spill
occur, it will drain into the Chemical System where the spilled
material is drained back into the feed tank for reprocessing. No
evidence of spillages were observed during the site inspection.
Evidence:
— SIC IWWMP Action Plan Update_FY18_20180123;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
None,
3.31
Ponding of water must be prevented on site in order to avoid
pollution of ground water. C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which 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
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management.
All stormwater falling onto the site drains into the OWS and then
sent to the API dams. No evidence of pooling of water was
observed during the site inspection.
Evidence:
— SIC IWWMP Action Plan Update_FY18_20180123;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
3.32
Storm water management plan and mitigation measures
regarding erosion control should be developed and adhered
to.
C As above, Sasol have an Integrated Waste and Water Management
Plan (IWWMP), which covers erosion prevention in general.
Stormwater erosion at the plant is not anticipated as the entire plant
is hardsurfaced, and stormwater drainage ties into the site wide
stormwater management system.
Evidence:
— SIC IWWMP Action Plan Update_FY18_20180123
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
None.
GENERAL
3.33
A copy of this Environmental Authorisation must be kept at
the property where the activities will be undertaken. The
authorisation must be produced to any authorised official of
the Department who requests to see it must be made
available for inspection by any employee or agent of the
holder of the authorisation who works or undertakes work at
the property.
C Copies of all authorisations and licenses 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. Sasol provided the auditor with
the evidence that the responsible persons, Alfie Naidoo (Senior
Manager of Chemical Workup Units and Ethyl Acetate, Solvents)
and Wilem Jacobs (legal appointee of Polymers and Nitro), were
made aware of the EA in September/October 2016.
Evidence:
— EA_EX Handover_SCO_Solvents_CWU_EA
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.34
Where any of the applicant`s contact details change,
including the name of the responsible person, the physical or
postal address and/or telephonic details; the applicant must
notify the Department as soon as the new details become
known to the applicant.
N/A Noted. Sasol advised the auditor that no changes have been made
to the details included in the EA.
None.
3.35
The holder of the Environmental Authorisation must notify
the Department, in writing and within 24 (twenty-four)
hours, if conditions of this Environmental Authorisation are
not adhered to. Any notification in terms of this condition
must be accompanied by reasons for the non-compliance.
C Non non-conformances with the EA have been noted during this
audit.
None.
3.36
Non-compliance with a condition of this authorisation may
result in criminal prosecution or other actions provided for in
the National Environmental Management Act, 1998 and the
regulations.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
3.37
National government, provincial government, local
authorities or committees appointed in terms of the
conditions of this Environmental Authorisation or any other
public authority shall not be held responsible for any
damages or losses suffered by the applicant or his successor
in title in any instance where construction or operation
subsequent to construction be temporarily or permanently
stopped for reasons of non-compliance by the applicant with
the conditions of authorisation as set out in this document or
any other subsequent document emanating from these
conditions of authorisation.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
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Table 3: Audit Findings – Environmental Management Plan
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1 This EMPr must form part of the contractual agreements
with the specific contractors. C Sasol provided the auditor with evidence that the contractor
responsible for the construction activities was made aware of the
EMPr Additionally, evidence that the EMPr was included as part
of the contract documentation was also provided.
Evidence:
— 1_EMP_1.3.1.16.1 G-
21_NPA_Communicate_EMP_contractors
None.
This condition is considered
non-rectifiable given
construction is completed.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Contractors’ declaration of acceptance of the EMP
2.1 The contractor is expected to have safety “tool box” talks in
accordance with the risks and trends associated with the
project. Proof of these talks shall be kept on site.
C Sasol provided proof of the Toolbox talks (including the
attendance registers) undertaken during the construction phase by
the contractor, Topfix. The toolbox talks topics included:
— Material Handling;
— General awareness;
— Safety Moment: Hazardous waste;
— Safety Moment: Eating areas;
— Spill Control;
— Save Water;
— Water Pollution;
— Situational awareness - Emergency Assembly &
Environmental (wetlands); and
— Flash Notification.
Evidence:
— 2.1_EMP_1.3.1.16.1 G-
21_NPA_ECO_EnvToolboxTalks_2016-10-31
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.2 The contractor will develop specific emergency procedure
and plan. C Sasol advised the auditor that each contractor was provided with a
copy of the Sasol site specific Emergency Response Plan. This was
confirmed within the Final ECO Report, dated November 2016.
All contractors working on Sasol sites are required to align entirely
with the Sasol emergency procedure in order to ensure a unified
response in the event of an emergency. All service providers
inductions therefore include training in, and are expected to follow
the Sasol emergency management procedures.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
3 Labour (skilled and unskilled) and contractors employed for
the proposed improvements to Unit 038N should be sourced
locally where feasible.
C Sasol has advised the auditor that they have implemented a
Supplier Industrial Relations Procedure (SIRP) that aims to
provide the greatest degree of uniformity, consistency and to
standardisation of procedures and practices pertaining to security /
site access and Industrial Relations matters to all Suppliers, their
Agents, Sub-contractors and Labour brokers/TES. Suppliers and
contractors are required to ensure that the SIRP, its procedures and
practices are communicated, understood, observed and followed
by them and all their constituents at all times. Non-compliance
with the procedure may result in the termination of the commercial
agreement between the parties. The policy makes reference
preferential recruitment practices, where preference must be given
to local people residing within the local municipality.
Evidence:
— Labour_Sasol IRM Suppliers Industrial Relations Procedure
None.
4 No alcohol /drugs are permitted on site. C Sasol prohibit drugs and alcohol onsite. Random spot checks and
random alcohol testing are carried out on persons entering the
Sasol Secunda Complex, as well as the entrance to the Sasol
Solvents operational areas. Module 2 of the Sasol Induction
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
includes instruction that drugs and alcohol as items are not
permitted on site.
Evidence:
— Induction_Mod2_Security.
Induction Training Module 2 shows drugs and alcohol as prohibited items
5 No firearms allowed on site, unless used by security
personnel. C Sasol prohibit firearms or weapons onsite. Module 2 of the Sasol
Induction includes weapons and firearms as items not permitted on
site. Vehicles are randomly checked at the entrance to the Sasol
site, as well as at the entrance to the Sasol Solvents operational
area.
Evidence:
— Induction_Mod2_Security.
None.
6.1 Correct Personal Protective Equipment (PPE) must be worn
at all times by the personnel on site. Personnel must be
trained on the use of PPE.
C Any person entering the operational areas within the Sasol
Secunda Complex must have the correct PPE as indicated on the
signage at the various plants. Any person not wearing the correct
PPE is prohibited from accessing the plant. PPE requirements are
provided in Induction Module 5. During the site inspection the
auditor observed that all personnel were wearing the PPE indicated
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
on the signage located around the site (i.e. hard hat, boots, overalls,
Hearing protection and googles).
Evidence:
— Induction_Mod5_WorkPlaceSafety.
6.2 A register will be kept on what PPE has been issued and
when. Contractors are to take disciplinary action against
employees who fail to adhere to the PPE requirements.
C According to the Final ECO Report, correct PPE was made
available to all contractors onsite. Each contractor appointed a
Safety Officer who monitors the use of PPR on site.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
7 Smoking can only take place in designated smoking areas. C As part of the Sasol Secunda Operations, smoking is only
permitted in designated areas. The ECO report noted that ‘No
Smoking’ signs had been erected around the site and no
contraventions were observed.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
8 Each contractor will employ their own Safety Officer to
monitor the safety conditions during the construction phase.
Sasol Safety Officer will oversee the contractor.
C Sasol advised that each contractor appointed a Safety Officer for
the duration of the construction phase. This is confirmed in the
Final ECO report.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
9 Any safety or environmental incidents must be reported to
the Safety Officer who then needs to communicate to the
Environmental Standby (082 902 1989).
C During the construction phase an incidents register was maintained
onsite. The incident register was provided to the auditor. The
incidents recorded were minor and did not require the
environmental standby team.
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— 3.35_EA_1.3.1.16.1 G-21_NPA_ECO_Incident
Register_2016-10-31
10 No unauthorised ignition sources will be permitted on site
and debris/waste shall not be burnt under any circumstances. C Due to the nature of the site no unauthorised ignition sources are
prohibited onsite.
None.
11 Erect suitable warning and information signage near any
hazardous storage facility. Handling of hazardous chemicals
must only be done by trained personnel.
C During the construction phase Sasol advised the auditor that no
hazardous substances were stored onsite. This was confirmed
within the ECO Report.
The auditor noted that suitable signage has been erected across the
site. The signage indicates the PPE that must be worn as well as an
indication of the dangers associated with the facility.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
Signage at the entrance to the plant.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
12 All provisions of the Occupational Health and Safety Act
(Act No 85 of 1993) and Sasol Internal Standards must be
fully complied with.
C The ECO report noted that a safety officer for the project, who
monitored all safety requirements had been appointed. The safety
officer was responsible for adherence to the Occupational Health
and Safety Act (Act No. 85 of 1993) and Sasol Internal Standards.
Sasol Chemical Operations have a valid BS OHSAS 18001: 2007
certification. The auditor was provided with proof of the
certification. The certification is valid from 12 October 2016 to 11
October 2019.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
— SCO DQS BSOHSAS 18001 2007
None.
13 In the event of an emergency, the Contractor shall contact
the Sasol emergency services. Telephone numbers of Sasol
emergency services must be posted conspicuously at the site.
C The auditor observed that there are numerous information boards
across the site which contain the contact details for the Emergency
Response Team. The ECO report noted this during the
Construction Phase.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
The emergency contact details on signage at the entrance to the debottlenecking plant.
14 Safety Data Sheets (SDSs) must be readily available on site
for hazardous substances. C The ECO report for the construction phase noted that all SDSs
were kept within the Environmental File.
Hazardous chemicals stored onsite during the operational phase are
stored within Storage Tanks. The SDS are therefore kept on file
within the control room. The auditor was shown the location of all
SDS associated with the plant.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
15 Workers should at all times be made aware of the health
risks associated with any hazardous substances/dangerous
goods used, through talk topics and awareness campaigns.
C The ECO Report noted that the contractor undertook Toolbox
Talks during the construction period.
Sasol advised the auditor that all employees undertake Sasol
Induction training, which they must refresh annually, as well as
Induction Training specific to the Sasol Solvents Operational area.
This training covers the health risks associated with hazardous
substances.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
16 In the event of an emergency relating to hazardous
substances, procedures detailed in the SDS shall be
implemented.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
17 Where waterborne sewerage is not available, an area must be
designated for the erection of portable chemical toilets. An
accredited company must then provide temporary chemical
toilets. Such toilets must be available for all construction
staff.
C Sasol advised the auditor that the contractors were provided with
access to ablution facilities connected to the sewerage. The ECO
report indicated that waterborne sewage was made available during
the construction period.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
18 Under no circumstances may open areas or the surrounding
vegetation be used as toilet facilities. C The ECO report noted that during the construction phase no
incidents were recorded. Sasol advised the auditor that public
urination is prohibited onsite and is a fineable offence. The auditor
reviewed the incidents register and no incidents of public urination
or similar have been recorded.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final;
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18.
19 Toilets, permanent or portable/temporary, shall be
maintained in a hygienic state and serviced regularly.
Portable toilets, should they be required, should be serviced
by a reputable contractor and the contents shall be removed
to a licensed disposal facility.
C The ECO Report noted that during the construction phase the
toilets were kept in a suitable condition.
Sasol advised the auditor that the toilets, which are permanent and
located in various locations across the site are connected to the
sewer system and are cleaned on a regular basis.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
20 Contractors’ waste management procedures will be approved
as part of the safety file. C Sasol advised the auditor that each contractor was provided with a
copy of the Sasol Waste Management Procedure. This was
confirmed within the ECO Report.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
21 Existing storm water management structures servicing the
Unit 038N will be inspected regularly to ensure they are in
proper working order.
C During the construction phase the ECO undertook weekly
monitoring of the stormwater management structures on and
around the construction site.
Sasol advised the auditor that stormwater management structures
are inspected on a regular basis by the plant managers.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
22 Sufficient bins/skips are to be provided for the safe and
environmentally responsible disposal of waste. C The ECO Report noted that during the construction phase, the
contractor was provided with waste receptacles. The receptacles
were labelled according to the designated waste type.
Waste produced as a result of the operational activities is managed
in accordance with Sasol’s Waste Management procedure. The
auditor viewed the Waste Management procedure that is in place,
and this provides an approach to manage waste in line with the
internationally accepted waste hierarchy. The procedure further
details waste disposal and management through characterisation
and classification that is detailed in site specific waste registers. It
is however noted that, during normal operations, no waste is
produced as by-products are either recovered or sent back into the
system.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Sasol Secunda Industrial Complex, Mpumalanga IWMP
2017- 2022 Rev_0.
None.
23 Littering on site is forbidden and the site must be cleared of
litter at the end of each working day. C The ECO Report noted that during the construction phase small
quantities of litter were observed on site during the weekly audits.
The site was cleaned on a daily basis after each shift. At the end of
construction no litter was noted onsite.
During the site walkover, the auditor did not observe any litter
onsite.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
24 Where possible, materials used or generated by construction
activities must be recycled. C The ECO Report noted that all redundant recyclable materials
generated as a result of the construction activities was collected
and recycled by Sasol.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
25 Waste will not be stored for a period exceeding 90 days or
volumes exceeding 100 cubic meters. C During the construction phase the ECO report noted that waste was
removed at frequent intervals. No waste was stored for more than
90 day. Whilst volumes were not provided. It is assumed however,
that the construction activities did not produce more than 100m3
due to the scale of the construction activities.
During normal operations, no waste is produced as everything is
either recovered or sent back into the system. All general office
type waste is collected regularly and taken to the Waste
Management Facility at Charlie 1 for disposal.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09.
None.
26 Waste generated on the proposed site should be collected by
authorised waste contractors and frequently disposed of at a
licensed landfill site as the last resort. Recycling/reuse of
waste should be enforced where feasible.
C The auditor was advised that waste management is carried out via
implementation of a Waste Management procedure (SGR-SHE-
000017 REV10), which addresses the approach to manage waste in
line with the internationally accepted waste hierarchy. According
to the hierarchy disposal to land is considered the last management
option to undertake once avoidance, re-use, recycling, recovery
and treatment options have been considered / eliminated. The
procedure further details waste disposal and management through
characterization and classification that is detailed in site specific
waste registers.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Waste Registers were made available to the auditor. A sample of
the registers specifically related to the Solvent operations were
checked during the audit. It is however noted that during normal
operations, no waste is produced as by-products are either
recovered or sent back into the system.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Sasol Secunda Industrial Complex, Mpumalanga IWMP
2017- 2022 Rev_0.
27 An inventory of all chemicals on site must be kept together
with the respective SDS. C The ECO report for the construction phase noted that all SDSs
were kept within the Environmental File.
Hazardous chemicals stored onsite during the operational phase are
stored within Storage Tanks. The SDS are therefore kept on file
within the control room. The auditor was shown the location of all
SDS associated with the plant. Sasol maintain a full inventory of
all chemicals stored onsite as these chemicals form part of their
processing activities.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final
None.
28 Cleaning of equipment/vehicles should be done in a
designated area to prevent soil and water pollution. C The ECO Report noted that the no vehicle or equipment was
cleaned onsite during the construction phase of the project.
Equipment and vehicles were removed from site after each shift.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
29 Storage areas containing hazardous substances/materials are
to be clearly demarcated and labelled. C The ECO report noted that during the construction phase no
hazardous substances were stored onsite.
Hazardous chemicals stored onsite during the operational phase are
stored within Storage Tanks. The auditor observed that the tank
farm was clearly demarcated and signage erected regarding PPE
requirements and safety warnings.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final.
None.
30 Functional spill kits and/or drip trays are to be made
available at areas where potential spillages of substances can
take place Machinery will be kept maintained in line with
manufacturers specifications to minimise the risk of
hydrocarbon spillages.
C The ECO report noted during the construction phase a spill kit was
kept onsite by the contractor.
Spill kits were observed across the site, however, the site is
hardsurfaced and bunded. Any spilled material or product drains to
Chemical Sewer where it is sent back to the material feed tanks
and is reprocessed.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
None.
31 Remediation of spillages must be conducted as far as
practically reasonable given the operational constraints of
the Unit 308N.
C The ECO Report noted that during the construction phase a
hydrocarbon spill was identified and remediated immediately. The
contaminated Soil was sent to Sasol for remediation.
As the site is hardsurfaced and bunded, any spilled material or
product drains to Chemical Sewer where it is sent back to the
material feed tanks and is reprocessed.
Evidence:
— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA
Envir Audit EMP Final;
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
32 No wastewater or waste will be disposed of into the
surrounding environment at any time. Water collected in
bunded areas must be collected in containers and disposed of
in accordance with Sasol’s wastewater management
Standards.
C The ECO Report noted that during the construction phase, all
water was managed through the existing stormwater management
system.
The drainage of all the storm water run-off from Solvents is routed
to the API Oily Water System (OWS) as part of the formal runoff
drainage within the Primary Area. This includes clean storm water
from the Chemical Work Up area.
Evidence:
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
None.
33 An incident reporting system will be implemented in order
to ensure incidents, where spillage occurred, are closed out
and appropriate measures are taken to prevent further
incidents.
C Sasol advised the auditor that all environmental incidents are
recorded in an incident register that is available at the
Environmental department. All incidents are investigated and
reported in line with the procedure and as per legal requirements.
Incident next steps are managed on SAP PS1 (transaction code
QM02) and progress is reported in the monthly performance
reports which is sent to all senior managers.
Evidence:
— Environmental incident procedure Process flow;
— Environment emergency procedure_SGR-
SHE000023_rev6_2015-11;
— Environment Impact register_ New FY19_2019-02-18.
None.
34 When mortar is used on site, the following guidelines apply:
— Carefully control all on-site operations that involve the
use of mortar and concrete;
— Limit mortar mixing to single sites where possible;
C The ECO report noted that no cement mixing was done onsite.
Cement required for construction was transported to site already
mixed.
No cement is required for normal operational activities.
Evidence:
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Use plastic trays or liners when mixing mortar and
concrete: Do not mix mortar and concrete directly on
the ground;
— Dispose of in the approved manner.
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
35 Where there is contaminated soil, the Environmental
Standby and Emergency Services must be notified, who will
advise on treatment, clean-up and disposal.
C The ECO report noted that only small hydrocarbon spills occurred
during the construction phase. These were remediated to the
approval of the ECO.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01;
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18.
None.
36 Should there be a specific storage area for fuel, oil and other
hydrocarbon/hazardous materials. This area will be access
controlled and SDSs will be available.
C The ECO Report noted that no storage was required during the
construction phase.
The auditor noted that the entire solvents operation is monitored by
security and access is controlled through access booms and
security checks. All visitors have to report to security where they
are either accompanied around site by an authorised individual or
undergo induction training specifically for the solvents operational
area.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
37 Speed limits applicable to the SSIC should be enforced on
the access road to the construction site. C The ECO Report noted that during the construction phase speed
limits were adhered to in accordance with the Sasol Safety
Standards.
Evidence:
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
38 Vehicles and machinery should be maintained regularly to
ensure that emissions are minimized. C The ECO Report noted that during the construction phase no
excessive emissions were observed during the construction phase.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
39 Should extensive dust be generated during construction,
localised dust suppression will be implemented. C The ECO report noted that during the construction phase no
excessive dust emissions were observed.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
40 Use of potentially polluting and hazardous substances on site
should be strictly controlled. C The ECO report noted that during the construction phase, minimal
hazardous substances were utilised. The gases used for welding
were stored in designated cage within the operational area.
Potentially polluting and hazardous substances are stored within
tanks in the tank farm prior to being used or once they have met
the required product specification. These substances are essential
to produce the array of products produced by Sasol.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
The tank farm at the plant.
41 Where there is contaminated soil, the Environmental
Standby and Emergency Services must be notified, who will
advise on treatment, clean-up and disposal.
C The ECO report noted that only small hydrocarbon spills occurred
during the construction phase. These were remediated to the
approval of the ECO.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01;
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18.
None.
42 Spill response procedures must be clearly defined and well
known by all construction staff. C The ECO Report noted that the contractors using chemicals and
hydrocarbons had a spill procedure in place. No chemicals were
stored onsite during the construction phase.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
43 Demolish and remove all infrastructure not required post
closure. N/A Noted. Sasol advised the auditor that there are no plans to
decommission this plant in the foreseeable future.
None.
44 Should there be reason or suspect reason the soils are
contaminated following decommissioning activities, the soils
will be assessed by a competent person and remediated
within a reasonable timeframe.
N/A Noted. Sasol advised the auditor that there are no plans to
decommission this plant in the foreseeable future.
None.
45 The footprint area of the decommissioning activities must be
landscaped to represent the surrounding environment as
determined by the relative timing of Unit 038N
decommissioning to the overall SSIC decommissioning.
Landscaping must be done so that pooling of water does not
occur.
N/A Noted. Sasol advised the auditor that there are no plans to
decommission this plant in the foreseeable future.
None.
46 Signs of erosion must be inspected on a frequent basis
following decommissioning activities. Remedial measures
will be instated should erosion occur.
N/A Noted. Sasol advised the auditor that there are no plans to
decommission this plant in the foreseeable future.
None.
47 Appropriate PPE will be worn by employees and contractors. C The ECO Report noted that during the construction phase all
contractors wore PPE. This was inspected by the contractors
Safety Officer.
Sasol advised the auditor that any individual entering the
operational areas must have the correct PPE or access is
prohibited. The auditor observed all personal wearing the correct
PPE. The importance of PPE is included within the site induction
Training.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01;
— Induction_Mod5_WorkPlaceSafety.
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
48 If noise levels exceed 85 dBA, acoustic mitigation measures
must be installed. C The ECO Report noted that during the construction phase the
construction activities did not escalate the noise levels.
Sasol appointed an external service provider to undertake a Noise
Survey, report dated 31 July 2017. The noise survey included
U38N. The report concluded that within the operational area 71%
of the normalised 8 hour noise rating levels in the areas measured
were equal to or above the statutory noise rating limit of 85dbA.
The plant (U38N) is a designated noise zone. The report notes that
the current practice of issuing hearing protective devices (HPDs)
currently issued to employees is deemed adequate protection in
most zones.
Evidence:
— 3.27_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit
EMP Final_505119_2016-11-01;
— SEC-116-2017-
CM(NOISE)(Chemical_Work_Up_West,_Production,_Units_
037,_038,_038N,_073).
Signage at the plant indicating the use of hearing protection.
None.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL AUTHORISATION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 4
below.
Table 4: Summary of EA Compliance Audit Findings
SECTION OF THE EA NO. COMMITMENTS C NC N/A
SCOPE OF AUTHORISATION 10 3 0 7
APPEAL OF AUTHORISATION 2 2 0 0
MANAGEMENT AND MONITORING 5 3 0 2
COMMISSIONING AND OPERATING 14 12 0 2
GENERAL 5 2 0 3
Total Count 36 22 0 14
Total Percentage 61% 0% 39%
Percentage Compliance with Applicable Conditions 100%
Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents
the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the EA conditions per Section
02468
10121416
Scope ofAuthorisation
Appeal ofAuthorisation
Management andMonitoring
Commissioningand Operating
General
Sectional Count Contribution
C
NC
N/A
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Figure 3: Overall count findings on compliance to the EA conditions
Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total
percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the EA conditions per Section
22
0
14
Total Compliance
C
NC
N/A
0102030405060708090
100
Scope ofAuthorisation
Appeal ofAuthorisation
Management andMonitoring
Commissioningand Operating
General
Sectional Percentage Contribution
C
NC
N/A
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Figure 5: Overall percentage findings on compliance to the EA conditions
5.2 ENVIRONMENTAL MANAGEMENT PLAN
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the EMP conditions are as listed in Table 5
below.
Table 5: Summary of EMP Compliance Audit Findings
SECTION OF THE EMP NO. COMMITMENTS C NC N/A
GENERAL 50 45 0 5
Total Count 50 45 0 5
Total Percentage 100% 0% 10%
Percentage Compliance with Applicable Conditions 100%
61%
0%
39%
Total Percentage Compliance
C
NC
N/A
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Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7
presents the total proportion of compliance for the facility.
Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section
Figure 7: Overall count findings on compliance to the EMPr conditions
42434445464748495051
General
Sectional Count Contribution
C
NC
N/A
45
05
Total Compliance
C
NC
N/A
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Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the
total percentage compliance for the facility.
Figure 8: Percentage contribution of findings made to the EMPr conditions per Section
Figure 9: Overall percentage findings on compliance to the EMP conditions
5.2.1 EFFECTIVENESS OF THE EMPR
Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy
and effectiveness of the EMPr as part of the audit scope, as follows:
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
achieve the objectives and outcomes laid out in these documents;
84
86
88
90
92
94
96
98
100
General
Sectional Percentage Contribution
C
NC
N/A
90%
0%10%
Total Percentage Compliance
C
NC
N/A
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— Identify and assess any new impacts and risks that result from undertaking the activity;
— Critically evaluate the effectiveness of the EMPr;
— Identify shortcomings in the EMPr; and
— Identify the need for any changes to the avoidance, management and mitigation measures provided for in
the EMPr.
The EMPr compliance audit has identified that the majority of the EMPr conditions remain applicable, and the
EMPr is considered effective.
The original EMPr document was designed pre-operation principally to also govern construction phase impacts,
and has been somewhat superseded during the operational phase by Sasol Business Unit-specific risk
assessments; compliance with the EA, relevant WUL and AEL; and through Sasol’s choice to comply with the
ISO 14001 Environmental Management international standard.
The EIA Regulations 2014 (as amended) requires that the EA and EMPr is audited only at least every five years,
and Sasol has systems in place which are considered to be more robust for monitoring compliance and
implementing changes than through the EMPr audits; including the annual audit of each business unit to
meeting ISO 14001 standards.
New impacts and risks are continually identified and assessed by Sasol by its Governance SHE Risk and
Assurance department; which assesses environmental risks and drives improvement implementation. 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. Risk documentation is hosted on
Sasol’s Information Management System.
In conclusion, WSP considers that for the duration that Sasol continues to operate each business unit under ISO
14001 standards and meet licence compliance (EA, WUL, AEL), this is effective as mitigation against any gaps
in the EMPr and as a means to regularly identify new impacts and risks. In the event that Sasol elects to no
longer comply with ISO standards, an alternative system must be implemented. Such an alternative may involve
updates to the EMPr and regular (annual) audits against these updates.