SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION … · 6/27/2019 · ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

16/4/4/L/2001/15 - CA99 LOADING ZONE

27 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

16/4/4/L/2001/15 - CA99 LOADING ZONE

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

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

EA Ref:

16/4/4/L/2001/15

Draft v2 for Review –

Compliance Audit

EA Ref:

16/4/4/L/2001/15

Final – Compliance

Audit

EA Ref:

16/4/4/L/2001/15

Date April 2019 June 2019 June 2019

Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher

Signature - -

Checked by Ashlea Strong Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 028 028 028

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 Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

Solvents Production Senior Manager Alfie Naidoo

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

WSP June 2019

TABLE OF CONTENTS

1 INTRODUCTION ........................................ 1

1.1 Terms of Reference ................................................. 1

1.2 CA99 Loading Zone (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 16/4/4/L/2001/15 .............. 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 ... 25

5.1 Environmental Exemption .................................... 25

5.2 Environmental Management Plan ........................ 28


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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 ................. 17

TABLE 4: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 25

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 28

FIGURES

FIGURE 1: LOCATION OF THE CA99 LOADING ZONE ON THE SASOL SECUNDA COMPLEX (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 26

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 26

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 27

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 27

FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 28

FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 29

FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 29


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FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 30

APPENDICES

A ENVIRONMENTAL EXEMPTION (16/4/4/L/2001/15)


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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: 16/4/4/L/2001/15 issued on 7 February 2002) as well as the

associated Environmental Management Plan (dated May 2002) for the period December 2014 to February 2019.

1.2 CA99 LOADING ZONE (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(AUTHORISATION NUMBER: 16/4/4/L/2001/15

An Environmental Exemption (Reference number: 16/4/4/L/2001/15) was granted on 7 February 2002 by the

Mpumalanga Department of Agriculture, Conservation and Environment (MDACE) for the establishment of a

new loading zone for Crotonaldehyde (CA).

The CA loading rack was commissioned in 2002 to replace the old loading facility. The loading bay is located in

road L2, within the Sasol Solvents operational area (Figure 1). The CA loading bay became the main loading

point for the CA. The facility is a drive-through facility, where iso-containers enter from the east of the loading

bay and exit to the west. The facility comprises an automated loading arm and fire suppression system.

It is noted that in 2010 Sasol stopped producing CA 99%. The loading zone is now used for the adhoc loading

of Ethylol99.


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Figure 1: Location of the CA99 Loading Zone on the Sasol Secunda Complex (Source: Google Earth, 2018)


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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 and EMPr;

— 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;

— 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;

— Make recommendations in order to achieve compliance in terms of the Exemption and EMPr; and

— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically

— “Records relating to the compliance/non-compliance with the conditions of the authorisation must be

kept in good order. Such records must be made available on request by this Department.”


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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 and associated EMPr conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (12 March 2019);

— Review of documentation relevant to the conditions of the Exemption 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 Exemption and EMPr compliance audit (Section 4).

3.2 SITE INSPECTION

Bronwyn Fisher conducted the site inspection on 12 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:

— Simon Malinga (Production Foreman);

— Hans Schnetler (Process Maintenance Co-ordinator).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— 16.4.4.L.2001.15_ROD_2002-02-07;

— EMP_CA Load Zone_Aspect reg_2002-05-21;

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals Operations;

— EA_EX Handover_SCO_Solvents_CWU_EA;

— Compliance_SOX Provisions_Secunda Complax.dox;

— AEL Sasol Solvents 0017-2015-F02 (2015);

— Air Pollution license;

— SCO Atmospheric Emission Monitoring Schedule;

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— Compliance_Water_Secunda Complex.dox;

— Induction Mod3_Environment;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;

— 3.05_RESM Weekly Monitoring_2004-2019;

— 3.05_GW_Report _Prj6143_2018-06-19;

— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;


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— CWU East_2014-10-27;

— Environmental Complaints Register_2019-02-18;

— Line-up of Off-loading to COSH line (Propanol Plus and NACs);

— Line-up of Propanol Plus Off-loading to 256TK-0148;

— SOP Bottom Loading of Road Tankers Draft May 2015 (2) (002); 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 Exemption and associated

EMPr.

Where conditions are not directly specified within documentation, for instance within older EMPrs that were

compiled and submitted as Aspect Registers, auditable conditions have been defined by utilising either

mitigation measures or aspects that were defined within the EMPr. In some instances this has required the minor

re-wording of original text contained within the EMPr, in order to specify an auditable condition. WSP has used

its professional expertise and independence to ensure that such interpretation of wording is both auditable and

balanced.

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 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 Exemption 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.

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).


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3.5 AUDIT TEAM

The auditor, Bronwyn Fisher, was hosted by Broni van der Meer and Simon Malinga 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.

— 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


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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.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This exemption refers only to the project specified above

and described in the Record of Decision, hereafter

referred to as "the interface project" or development".

Separate application/s must be lodged for any other

development and/or activity at or near proposed

development, which is covered by Section 21 and 22 of

the Environment Conservation Act, No. 73 of 1989 Act

and Government Notice R1182 and R1183 of 5

September 1997.

N/A Noted. Sasol advised the auditor that they are aware of this

condition.

None.

1.02 Exemption is only granted in terms of Section 28A of the

Environment Conservation Act, No. 73 of 1989 and does

not exempt the holder from compliance with any other

relevant legislation.

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.

1.03 No development may take place on the area of concern

without the necessary permits/approvals and/or service N/A This condition is considered outside of the audit period

(construction pre-2014). It is therefore considered not applicable.

None.


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and/or lease agreements, where it is relevant, from or

between the following institutions:

1.3.1 Highveld Ridge Municipality (for the records)

1.3.2 DWAF

1.04 This Department may change, add or amend any of the

conditions in this exemption if, in the opinion of the

Department, it is environmentally justified.

N/A Noted. Sasol advised the auditor that, to their knowledge, the

Department has not added or amended any of the conditions within

this authorisation.

None.

1.05 A copy of this authorization shall be available at Sasol

Solvents Secunda, at all times and all staff, contractors,

contractors and sub-contractors shall be acquainted with

the contents of this exemption.

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. Sasol provided the auditor with

the evidence that the responsible persons, Alfie Naidoo (Senior

Manager of Chemical Workup and Ethyl Acetate) and Willem

Jacobs (legal appointee of Solvents), were made aware of the

Exemption in September / October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_CWU_EA

None.

1.06 The content of this exemption must be made known to all

interested and affected parties within 14 days from the

date of this exemption.

N/A This condition is considered outside of the audit period


None.

1.07 All mitigation measures and recommendations as laid

down in the Motivational Letter and recommendations

made by other institution are binding and must be adhered

to as part of the Environmental Management Plan.

NC Sasol has confirmed that a copy of the Motivational Letter

submitted to the MDACE is not available.

It is inherent in this condition that the measures and

recommendations as laid down in the Motivational Letter form part

of the Environmental Management Plan. The EMPr is audited in

Table 4. Full compliance with the EMPr, by default, infers

compliance with the mitigation measures and recommendations of

the Letter. However, a non-compliance with the EMPr was

observed, and given the Motivational Letter cannot be cross-

In the absence of the

Motivational Letter, it

should be ensured that all

conditions of the EMPr are

fully complied with.

Target Completion:

Medium term


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checked, it cannot be concluded that all mitigation measures and

recommendations are adhered to.

2. ESTABLISHMENT OF THE ENTERPRISE

2.1 This exemption is repealed if the development has not

taken place within 2 years from the date of this

exemption.



None.

2.2 If the decision is taken to close down the facility, sell

and/or transfer ownership of the infrastructure, this

Department must be informed of such decision at least 12

months prior the date of closure or transfer of ownership.

N/A Noted. Sasol advised that there are no plans to make this site

redundant in the foreseeable future. It is however noted that it is no

longer used for the loading of CA 99, it is still in use for the

loading of other products produced onsite.

None.

2.3 In case of closure of the site, this Department shall

evaluate, monitor and approve the clearing and

rehabilitation of the site.

N/A Noted. Sasol advised that there are no plans to make this site

redundant in the foreseeable future. Whilst the facility is no longer

used for the loading of CA 99, it is still in use for the loading of

other products produced onsite.

None.

3. CONSTRUCTION AND OPERATION

3.1 If any changes need to be made to the development or

associated infrastructure, this Department must be

informed thirty (30) days in advance to decide whether

the change will need authorization.

N/A Noted. Sasol advised the auditor that no changes have been to the

development or associated infrastructure. Whilst the facility is no

longer in use for the loading of CA 99, it is still in use for the

loading of other products produced onsite, and no significant

changes to process or infrastructure were required.

None.

3.2 Sufficient provision must be made in the annual budget

for the mitigation of the environmental impacts during the

operation and rehabilitation of this site in the event of

closure of the site.

C The auditor was advised that due to being listed on the New York

Stock Exchange, Sasol adheres to the Sarbanes Oxley (SOX)

legislation in the US which requires transparent financial

disclosure, including its environmental liabilities, to be included in

the company financial statements. The environmental and asset

retirement obligations for both SSO and SCO is therefore a

liability provision for closure purposes and not for any activities

None.


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regarded as operational costs. Provision is made for the removal of

surface infrastructure, in line with the future land use, as well as

for the remediation of areas that would remain a liability post-

closure in terms of potential future contamination.

Evidence:

— Compliance_SOX Provisions_Secunda Complax.dox

3.3 Upon completion of the associated infrastructures, all

excess construction material should be disposed of in a

registered landfill site.

N/A Noted. This condition is considered outside of the audit period


None.

4. AIR POLLUTION

4.01 Air pollution should be handled as indicated by relevant

authorities. Any emissions must be permitted by CAPCO. C Sasol had a registered certificate (APPA) for the Alpha Olefins

Plant (certificate number: 1308/5) issued on 11 March 2002. This

was then converted to an Atmospheric Emissions Licence (AEL),

with the promulgation of the National Environmental

Management: Air Quality Act (Act No. 39 of 20014) which

required the conversion from APPA to an AEL.

The Gert Sibande District Municipality issued an Atmospheric

Emissions Licence for the Sasol Solvents Operations (Reference:

11/19/1 Govern Mbeki Sasol South Africa (Pty) Ltd

0017/2015/F02) in March 2015. The AEL covers all Solvent

Operations at the Sasol Secunda Complex.

Evidence:

— Air Pollution license;

— AEL Sasol Solvents 0017-2015-F02 (2015).

None.


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5. WATER POLLUTION

5.01 It is the responsibility of the applicant and the relevant

contractor on site to prevent air pollution and any

pollution of the surface as well as groundwater.

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 auditor noted the following precautions that have been put in

place to prevent surface and ground water pollution:

— The entire loading zone is and hardsurfaced;

— The loading zone has a dedicated OWS to ensure any spillage

and stormwater is drained to the API dam;

— Sasol have developed a number of procedures for managing

the loading and offloading activities at this loading zone;

— Surface and groundwater monitoring is completed in

accordance with the IWWMP.

In addition, all staff, contractors and visitors are provided with

induction training, which includes prevention of pollution of the

environment.

Evidence:

— Compliance_Water_Secunda Complex.dox;

— Induction Mod3_Environment;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;

— Line-up of Off-loading to COSH line (Propanol Plus and

NACs);

— Line-up of Propanol Plus Off-loading to 256TK-0148;

None.


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— Loading Bay Production Training Document (LMqadi);

— Propanol Plus Loading Line-Up;

— SOP Bottom Loading of Road Tankers Draft May 2015 (2)

(002).

5.02 In case of non-compliance with section 19 of the National

Water Act, 1998 (Act 36 of 1998), the applicant will be

responsible to remedy the effects of pollution.

N/A Noted. Sasol advised the auditor that, to their knowledge, the

loading operations have not resulted in pollution of the

surrounding environment. The auditor reviewed the incidents

register and confirmed that no incidents of spillage during the audit

period were recorded. It is noted that in February 2019 the Sasol

Emergency Management responded to a product spill on road 2 L

leading up in road 29, where a decanted oil spilled onto the road.

Emergency management traced the spill to Averda’s yard.

Responders determined that the possible cause was due to a valve

that was leaking, while the individual was driving the chemical

truck. Although it is in close proximity to the loading zone, the

spill was not as a result of the loading zone activities.

Evidence:

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18.

None.

6. WASTE

6.01 All waste generated during the construction and/or

operation of the development shall be stored, handled and

disposed of in an environmentally acceptable way.

C The auditor was advised that waste management is carried out via

implementation of a Waste Management procedure (SGR-SHE-

000017 REV10) that addresses the approach to manage waste in

line with the internationally accepted waste hierarchy, whereby

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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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 little to no waste

is produced at the loading zone.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09

— CWU East_2014-10-27

7. RISK ASSESSMENT

7.01 Fire extinguishing equipments should be available at the

site at all times.

C During the site walk over the auditor noted that there was a fire

suppression system installed at the loading zone.

Evidence:

The red pipes at the loading zone indicate the deluge system

None.


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8. MONITORING

8.01 Records of monitoring must be made available for

inspection of any relevant authorities inspecting the

development.

C Sasol advised the auditor that monitoring associated with the Tank

is limited to surface water and groundwater monitoring; as well as

fugitive air emission monitoring (specifically VOC) through the

use of leak detection monitoring.

Surface water monitoring is conducted on a weekly basis as well as

real time for the various Receiving Environmental Surface water

Monitoring points (RESMs).

Groundwater monitoring is conducted biannually and quarterly for

the various Receiving Environmental Groundwater Monitoring

points (REGMs).

The November 2017 Water Quality Monitoring Report compiled

JMA Consulting, dated November 2017, was provided to the

auditor to review. The report confirmed the number of sampling

points and the frequency in which they are sampled.

VOC leaking from the process equipment is conducted by a third

party in line with USEPA Method 21. A minimum of 100 000

points are sampled per year. Leak detection monitoring on tanks is

carried out once every three years (in line with USEPA Method

21), or after leaking equipment is repaired.

Evidence:

— 3.05_GW_Report _Prj6143_2018-06-19;

— 3.05_RESM Weekly Monitoring_2004-2019;

— SCO Atmospheric Emission Monitoring Schedule;

— Fugitive Emission Monitoring Plan_2018-10-18 updated.

This condition cannot be

rectified.


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9. REPORTING

9.01 Records relating to the compliance/non-compliance with

the conditions of the authorisation must be kept in good

order. Such records must be made available on request by

this Department.

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 with, or any deviations from the

conditions as set out in the Record of Decision, is

regarded as an offence and, after reasonable provision has

been made for remedial action, will be dealt with in terms

of section 29, 30 and 31A of the Act.

N/A Noted. Sasol have advised the auditor that they are aware of this

condition.

None.

9.03 Any complaint regarding the said development must be

brought to the attention of this office within 24 hours after

receiving the complaint.

C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the loading zone for the audit period.

Evidence:

— Environmental Complaints Register_2019-02-18

None.

9.04 A complaint register must be kept up to date for

inspection by members of this Department. C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the loading zone for the audit period.

Sasol have advised that should a copy of the complaints register be

requested by the relevant Department, it will be made available.

Evidence:

— Environmental Complaints Register_2019-02-18

None.


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Table 3: Audit Findings – Environmental Management Plan


1. CONSTRUCTION AND PRE-COMMISSIONING

1.1 Transportation of feed to plant (Pipeline) N/A This condition is considered outside of the audit period


None.

1.2 Disposal of Construction wastes. To include any wastes from

spray painting, welding, grinding, cutting of pipes, storage of

cement/ grease, oils and paints and during mixing of

concrete. (responsibility of contractor. Will be included in

contract)



None.

1.3 Disposal of packaging material. (responsibility of

Contractor) N/A This condition is considered outside of the audit period


None.

1.4 Routing/ disposal/ re-use/ storage of excavated materials/

soils. (Dolerite will be used. Take samples of the soil and

dispose of it accordingly)



None.

1.5 Disposal/ re-use of building rubble and other wastes.

(Responsibility of Contractor) N/A This condition is considered outside of the audit period


None.

1.6 Handling and disposal of contaminated equipment.

(Existing piping will be disposed according to correct

procedure.)



None.

1.7 Handling/Storage/disposal of redundant piping and

equipment (clean according to correct procedure) N/A This condition is considered outside of the audit period


None.

1.8 Disposal of domestic waste (Responsibility of Contractor) N/A This condition is considered outside of the audit period


None.


WSP June 2019

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1.9 Spillage of fuel and oil during the use of electricity

generators. (Responsibility of Contractor) N/A This condition is considered outside of the audit period


None.

1.10 Disposal/ routing of water used for circulation (wet run).

(Test deluge) N/A This condition is considered outside of the audit period


None.

1.11 Emissions from electricity generators. (Responsibility of



None.

1.12 Labour and employment required. (Responsibility of



None.

1.13 Dolorite mining permit required. (Permit needed) N/A This condition is considered outside of the audit period


None.

1.14 Permit required for TLC/CAPCO/Transport/ Excavations

etc. (Excavations permit required) N/A This condition is considered outside of the audit period


None.

1.15 Emergency response plan for major loss of contaminant in

the plant (with consideration of air, groundwater, soil and

surface water).



None.

1.16 Emergency response for clean-up measures. N/A This condition is considered outside of the audit period


None.

1.17 Pressure on infrastructure/ roads and services due to

increased workforce. Turning circle to be moved. Talk to

traffic department.



None.


WSP June 2019

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2. OPERATING MAINTENANCE AND SHUTDOWN

2.1 Transportation of feed to the plant (pipeline). C Sasol provided the auditor with the following operating procedures

for the loading zone:

— Line-up of off-loading to COSH line (Propanol Plus and

NACs)

— Line-up of Propanol Plus Off-loading to 256TK-0148

— SOP Bottom Loading of Road Tankers

Sasol advised the auditor that these procedures are provided to all

individuals who operate the loading zone through task specific

training and task observations.

Evidence:

— Line-up of off-loading to COSH line (Propanol Plus and

NACs)

— Line-up of Propanol Plus off-loading to 256TK-0148

— SOP Bottom Loading of Road Tankers Draft May 2015 (2)

(002)

None.

2.2 Disposal/ routing of off- spec by-products and products

(when isocontainer is contaminated). N/A No off-spec product reaches the loading zone and therefore

condition is not applicable.

OFI:

Sasol should revise the

aspect register and remove

conditions that are not

deemed applicable at any

stage during the life of the

plant (including

decommissioning).

Target Completion:

Medium term


WSP June 2019

Page 20


2.3 Handling and disposal of contaminated equipment. N/A It is noted that contaminated equipment will only be disposed of

when the plant becomes redundant. Sasol advised the auditor that

there are no plans to decommission the loading zone for the

foreseeable future.

When required all equipment that is removed from site will be sent

to the Redundant Materials Management (RMM). The auditor was

advised that the equipment would be washed prior to being sent to

the RMM.

None.

2.4 Stormwater management (routing of on- spec/ contaminated

storm water). Stormwater will be kept in sump and

incinerated. Calculate water to be incinerated.

C During the site walkover Sasol advised the auditor that the

drainage of all the stormwater 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. The effluent and contaminated

run-off collected in the OWS reports to the API dams and is

eventually treated at the Water Recovery Plant.

Evidence:

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2

Oily Water Sump located within the loading zone.

OFI:

The wording of the aspect

register with regards to the

incineration of water is

unclear. It is recommended

that the Aspect Register is

reviewed to provide clarity

with regards to stormwater

management.

Target Completion:

Medium Term


WSP June 2019

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2.5 Disposal/ routing of water used for circulation (wet run).

Test monthly. NC During the site walkover, Sasol advised the auditor that all water

used for the monthly wet run is disposed of in the OWS. No

evidence of monthly testing was available.

Evidence:


Ensure water is tested

monthly in line with the

condition, or the Aspect

Register is amended.

Target Completion:

Medium Term

2.6 Disposal of used potable water. Eyewash and safety showers

facilities. Water goes to sump. C The loading zone does not have a site-specific eyewash or safety

showers area. This is located within the Chemical Work Up

operational area. Used potable water drains to the OWS.

None.

2.7 Disposal/ routing of firewater. Go to sump. C Sasol advised the auditor that firewater used at the loading zone

drains to the OWS.

Evidence:


None.

2.8 Disposal of water used for hydro testing. Go to sump and

then incinerator. N/A Sasol advised the auditor that hydro testing is not undertaken as

part of the operational activities at the loading zone. This condition

is therefore considered not applicable.






plant.

Target Completion:

Medium term

2.9 Disposal of water used for flushing. Goes to sump. Same

water that is used for hydro testing. C Sasol advised that water used to flush the loading system goes to

the OWS.

Evidence:


None.


WSP June 2019

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2.10 Venting of emissions. Closed system. Goes into venting

system. C The auditor noted that the loading bay has a vent arm installed for

vacuum and over pressure protection during offloading and

loading respectively.

The auditor was provided with the U238 Off-loading Bay

Relocation Project Training Document and Procedures (Dated20

August 2018), this document states that when product is loaded

into the road tanker the vapours displaced will be vented through

the 4”vent arm to the atmosphere via 237ME-239 to protect the

tanker from over pressure.

Evidence:

— Loading Bay Production Training Document (LMqadi)

None.

2.11 Incinerator emissions. Verify impact on incinerators

emissions from closed sump content. N/A The loading zone does not comprise an incinerator. This condition

is therefore not applicable.






plant.

Target Completion:

Medium term

2.12 Fugitive emissions. Dry breaks. Therefore no emissions. N/A Sasol advised the auditor that no fugitive emissions are associated

with the loading activities.






plant.

Target Completion:

Medium term


WSP June 2019

Page 23


2.13 Gas pressure testing of equipment. Iso-containers being

pressure tested with low pressure nitrogen. C Sasol advised the auditor that low pressure nitrogen is used to

pressure test the iso-containers.

None.

2.14 Emissions from effluent from loading/ off- loading/ disposal

of feed/ chemicals etc. This is to be a closed system, with the

exception of PSV to atmosphere.

N/A Sasol advised the auditor that effluent is not loaded or offloaded at

the loading zone. This condition is therefore not applicable.






plant.

Target Completion:

Medium term

2.15 Venting of purge gas (N2 etc) to vent system. C The auditor noted that the loading bay has a vent arm installed for

vacuum and over pressure protection during offloading and

loading respectively. It is understood purge gas would also route

via the vent arm.

The auditor was provide with the U238 Off-loading Bay

Relocation Project Training Document and Procedures (Dated20

August 2018), this document states that when product is loaded

into the road tanker the vapours displaced will be vented through

the 4”vent arm to the atmosphere via 237ME-239 to protect the

tanker from over pressure.

Evidence:

— Loading Bay Production Training Document (LMqadi)

— Propanol Plus Loading Checklist (7 Sep 2018)

None.

2.16 Measuring of emissions and method. N/A Sasol advised the auditor that emissions are not monitored at the

loading zone as it is not required due to the nature of the activities

being undertaken. This condition is therefore not applicable.






plant.


WSP June 2019

Page 24


Target Completion:

Medium term

2.17 Loading at night. N/A It is understood that no loading or off-loading is undertaken at

night.

None

2.18 Handling/ Storage/ disposal of redundant piping and

equipment. N/A Sasol advised the auditor that there are no plans to decommission

the loading zone for the foreseeable future.

None.


WSP June 2019

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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

4 below.

Table 4: Summary of Exemption Compliance Audit Findings

SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A

GENERAL CONDITIONS 7 1 1 5

ESTABLISHMENT OF ENTERPRISE 3 0 0 3

CONSTRUCTION AND OPERATION 3 1 0 2

AIR POLLUTION 1 1 0 0

WATER POLLUTION 2 1 0 1

WASTE 1 1 0 0

RISK ASSESSMENT 1 1 0 0

MONITORING 1 1 0 0

REPORTING 4 2 0 2

Total Count 23 9 1 13

Total Percentage 39% 4% 57%

Percentage Compliance with Applicable Conditions 90%


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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

0

1

2

3

4

5

6

7

8

Sectional Count Contribution

C

NC

N/A

9

1

13

Total Compliance

C

NC

N/A


WSP June 2019

Page 27

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

39%

4%

57%

Total Percentage Compliance

C

NC

N/A


WSP June 2019

Page 28

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 EMPr conditions are as listed in Table 5

below.

Table 5: Summary of EMPr Compliance Audit Findings

SECTION OF THE EMPR NO. COMMITMENTS C NC N/A

CONSTRUCTION AND PRE-COMMISSIONING 17 0 0 17

OPERATING MAINTENANCE AND SHUTDOWN 18 8 1 9

Total Count 35 8 1 26

Total Percentage 23% 3% 74%

Percentage Compliance with Applicable Conditions 89%

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

0

2

4

6

8

10

12

14

16

18

20

Construction and Pre- Commissioning Operating Maintenance and Shutdown

Sectional Count Contribution

C

NC

N/A


WSP June 2019

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Figure 7: Overall count findings on compliance to the EMPr conditions

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

8

1

26

Total Compliance

C

NC

N/A

0

10

20

30

40

50

60

70

80

90

100

Construction and Pre- Commissioning Operating Maintenance and Shutdown

Sectional Percentage Contribution

C

NC

N/A


WSP June 2019

Page 30

Figure 9: Overall percentage findings on compliance to the EMPr 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;

— 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 approximately half of the listed measures are no longer

applicable, as these mostly related to the planning and construction phases only. The original EMPr document

was designed pre-operation principally to govern these construction phase impacts, and has been superseded

during the operational phase by Sasol Business Unit-specific risk assessments; compliance with the Exemption,

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 Exemption 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.

23%

3%

74%

Total Percentage Compliance

C

NC

N/A


WSP June 2019

Page 31

In conclusion, WSP considers that for the duration that Sasol continues to operate each business unit under ISO

14001 standards and meet licence compliance (Exemption, 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.

APPENDIX

A ENVIRONMENTAL EXEMPTION

(16/4/4/L/2001/15)