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SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
14/2/10/NH/3W - MTGE DE-BOTTLENECKING
02 AUGUST 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
14/2/10/NH/3W - MTGE DE-BOTTLENECKING
SECUNDA SYNFUELS OPERATIONS: GAS
PRODUCTION
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: AUGUST 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:
14/2/10/NH/3W
Final – Compliance
Audit
EA Ref:
14/2/10/NH/3W
Date July 2019 August 2019
Prepared by Jenny Cope Jenny Cope
Signature
Checked by Ashlea Strong Ashlea Strong
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 046 046
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
Jenny Cope
Associate
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.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than
the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any
third parties directed to provide information and documents to us by the Client. We have not reviewed any other
documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
CLIENT
SHE: Environmental Compliance
Specialist
Broni van der Meer
Gas Production – Production Senior
Manager
Boysie Mokoka and Steve Namane
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
WSP August 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 MTGE De-Bottlenecking Project –
14/2/10/NH/3W .......................................................... 1
2 AUDIT SCOPE ........................................... 3
3 AUDIT METHODOLOGY ........................... 4
3.1 Audit Checklist ........................................................ 4
3.2 Site Discussion ........................................................ 4
3.3 Documentation Considered ................................... 4
3.4 Audit Compliance Assessment .............................. 6
3.5 Audit Team ............................................................... 6
3.6 Assumptions and Limitations ................................ 7
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 26
5.1 Environmental Authorisation ............................... 26
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
WSP August 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 6
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8
TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 26
FIGURES
FIGURE 1: MTGE DE-BOTTLENECKING PROJECT (UPGRADES WERE UNDERTAKEN ACROSS THE SASOL PRIMARY AREA) (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 27
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 27
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 28
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 28
APPENDICES
A ENVIRONMENTAL AUTHORISATION (14/2/10/NH/3W)
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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 Authorisation (EA) (Reference number: 14.2.10.NH.3W issued on 29 September 1998, as
amended) for the period for the period December 2014 to February 2019.
1.2 MTGE DE-BOTTLENECKING PROJECT –
14/2/10/NH/3W
The Medium Term Gas Expansion (MTGE) project was the outcome of a capacity review. The review
highlighted that there was an optimisation opportunity, to increase capacity of gas production at the Sasol
Synthetic Fuels plant. The increase in gas production was effected largely through existing infrastructure, taking
the form of a ‘de-bottlenecking’ exercise, rather than the establishment of new facilities. The expansion resulted
in gas load ability increase to enable a possible 3.2 million m3n/hour1 annual averaged pure gas load2. Upgraded
equipment included one set of additional heat exchangers in the Gas Cooling water supply system (additional
tempered water cooling), and a surge vessel system on the gas condensate handling (gas liquor) system (see
Figure 1).
1 Cubic metres of gas at “normal conditions” per hour. 2 It is noted that Sasol has not reached that enabled capacity annual average.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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Figure 1: MTGE De-bottlenecking Project (upgrades were undertaken across the Sasol Primary Area) (Source: Google Earth, 2018)
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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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). MTGE I and
II projects were completed prior to 2000.
The objective of the audit was to:
— Assess the level of compliance with the conditions of the EA;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Make recommendations in order to achieve compliance in terms of the EA;
— Ensure the commitments contained in Condition 9.03 of the Authorisation 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 to this Department within seven (7) workdays
of the date on a written request by the Department for such records.”
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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 conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site discussion (19 June 2019);
— Review of documentation relevant to the conditions of the EA (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 compliance audit (Section 4).
3.2 SITE DISCUSSION
Jenny Cope conducted a site-specific interview on 19 June 2019. The findings and observations of the site visit
are recorded and summarised in Section 4 with evidence included in Table 2. Key personnel interviewed
included:
— Ed Koper (TBC)
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— SSO_GP_14.2.10.NH.3W_MTGE_1998-09-29;
— 14.2.10.NH.3W_V1_1998-09-29;
— SSO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels Operations;
— EA_EX Handover_SSO_GP-CP;
— 2.01_EA_MTGE_Poof of commencement_1998-11-04;
— 2.02_EA_MTGE_Poof of commence_1998-04-22;
— 2.02_EA_MTGE_Poof of commencement_1998-04-22;
— 4.02 16.04.2019;
— 4.03 Ambient Air Quality Report;
— 4.03 Passive sampler results;
— Fugitive Emission Monitoring Plan_2018-10-18 updated;
— 201904 SSO continuous emission monitoring quaterly report_January to March 2019 rev_final;
— SSO Phenosolvan FY19_Q2;
— SSO Phenosolvan FY19_Q3;
— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-05;
— 4.07_EA_MTGE_Charlie1Odour_1998-10-29;
— 4.07_EA_MTGE_Charlie1Odour_1998-11-04;
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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— 4.07_EA_MTGE_Charlie1Odour_1999-01-11;
— AEL Sasol Synfuels 0016-2018-F03 (2018)
— 4.08 Secunda Annual Dust Report 2018;
— 201810 SSO continuous emission monitoring monthly report_5 December 2018 rev_02;
— 201901 SSO continuous emission monitoring monthly report for January 2019 rev_00;
— 201902 SSO continuous emission monitoring monthly report for February 2019 rev_00;
— 4.08 Secunda Monthly Dust Report Feb 2019;
— 4.08 Secunda Monthly Dust Report Jan-19;
— 4.08 Secunda Monthly Dust Report Mar 2019;
— WUL SIC SSA_200322144_2008-11-21;
— WUL SIC SSA amendment_200322144_2010-01-08;
— 5.02_EA_MTGE_Design Philosophy_1999-02-11;
— 5.04_EA_MTGE_Design Philosophy_1999-02-11;
— 5.9 Mitigation Measures;
— 5.9 Mitigation Measures 2;
— Environmental Complaints Register (Period: December 2014 – March 2019);
— Copy of Environment Impact register_ New FY17;
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;
— Environment Impact register_ New FY19_2019-02-18;
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Gasification_2016-11-28;
— EA_14.25.16 EV 11;
— Risk Assessment: SGI-SHE-000014;
— Induction_Mod4_ProcessSafetyManagement;
— Induction_Mod5_WorkPlaceSafety;
— Induction_Mod7_Occupational;
— 5157_Sasol Secunda emissions and dust fallout reports_201905_rev00;
— 201904 SSO continuous emission monitoring monthly report for April 2019 rev_00;
— Annual emission report for Sasol Synfuels 0016-2015-F02_FY18;
— Emission Report for SSO_8 May 2018;
— FY18 Annual emission report for Sasol Oil 0019-2015-F02 final;
— FY18 Annual emission report for SCO_Solvents_0017_2015_F02_final;
— Phenosolvan VOC Sampling Report _FY18_Q2_Resampling_V01;
— VOC Sampling report for Phenosolvan_FY18_Q1_V01;
— AEL 0016-2019-F03 Secunda Synfuels Operations – certificate;
— AEL 0016-2019-F03 Secunda Synfuels Operations - license issued 23 April 2019;
— EIA Final;
— FY19 201903 Dustfall monitoring monthly report_5 May 2019;
— Groundwater monitor WISH Database_Survey New_201900523;
— RESMS Weekly Monitoring_2008-2019;
— RN_1901592_SAS GESI Secunda Monthly Dust Report Mar-19;
— RN_1901557_SAS GESI Secunda Monthly Dust Report Feb-19;
— SSO Stack Sampling Schedule 2019_2020;
— Raw water intake figures for May 2019;
— Raw & Rand water;
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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— 5152_Sasol Secunda quarterly emissions and dust fallout reports_201904_rev00;
— 201904 SSO continuous emission monitoring quaterly report_January to March 2019 rev_final;
— FY19 201902 Dustfall monitoring monthly report_5 April 2019;
— SSO Water Recovery FY19_Q2 PM and others;
— SSO Water Recovery FY19_Q2 TOC;
— SSO Water Recovery FY19_Q3 PM and others;
— SSO Water Recovery FY19_Q3 TOC;
— 20190604 Summary of coal contract FY18-19 - May included – West;
— 20190604 Summary of coal contract FY18-19 - May included – East; and
— Various email correspondence.
3.4 AUDIT COMPLIANCE ASSESSMENT
WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2). The checklist included
the conditions and associated requirements as specified in the EA.
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 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. Non-complaint conditions are given target
completion dates, as follows:
— Short term: 0 – 6 months.
— Medium term: 6 – 12 months.
— Long term: 12 – 18 months.
Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.
— Conditions marked as “Noted” are considered information points only.
— Where conditions are considered “not auditable” within the scope of this assessment this
is stated and explained within the condition commentary.
Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion
dates).
3.5 AUDIT TEAM
A brief summary of the external auditors’ experience is provided below.
— Auditor and Project Manager: Jenny Cope
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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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.
— 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.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or
in connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.
Similarly, any recommendations, statements or conclusions drawn from or based on this report must make
reference to this report. If this report is used as part of a main report, the report in its entirety must be included
as an appendix or separate section to the main report.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
GENERAL CONDITIONS
1.01 This Authorisation refers only to the project specified above
and described in the Record of Decision. Separate
applications must be lodged for any other development and/
or activity which is covered by Sections 21&22 of the Act
and Government Notice R 1182 of 5 September 1997.
N/A Noted. The project remains as per the authorised activities for
which the EA was granted.
Whilst a number of subsequent improvements to the associated
plant have been made, each of these was accompanied by separate
environmental authorisation applications. Sasol is aware of the
requirement to lodge separate applications should further works be
required for the authorised activity.
None.
1.02 Authorisation is only granted in terms of Section 22 of the
Environment Conservation Act, 1989 (Act 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 Sasol Complex operates with a dedicated environmental and
legal team, and therefore works to ensure that they comply with
applicable legislation.
In addition, 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:
— SSO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels
Operations.
None.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.03 This Department may change and / or amend any of the
conditions in this exemption if, in the opinion of the
Department, it is environmentally justified or if cleaner
technology has been developed.
N/A Noted. Sasol has advised that no changes or amendments have
been communicated to Sasol by the Department since issue of the
EA.
None.
1.04 A copy of this authorisation shall be available at the plant at
all times and all staff, contractors and sub-contractors shall
be acquainted with the contents of this Authorisation and the
Environmental Management Plan of SSF.
C Sasol’s environmental team have soft copies of the authorisation
and where/when necessary, communicate any specific details or
requirements to the relevant business units.
Additionally, copies are maintained at the SHE: Environment
department and on SAP EC and SharePoint. Any specific
requirements are communicated during SHE induction training.
None.
ESTABLISHMENT OF THE ENTERPRISE
2.01 This authorisation is repealed if the project has not
commenced within two (2) years from the date of this
authorisation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2.02 Fourteen (14) days written notice must be given to this
Department before commencement with construction
activities.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
CONSTRUCTION AND OPERATION
3.01 The MTGE project will commence as has been agreed
between the Department and SSF, subject to the conditions
set by this Department.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.02 If any changes need to be made to the Plant and/or
associated structures other than that which has been agreed
upon, this Department must be informed thirty (30) days in
N/A Noted. The project remains as per the authorised activities for
which the EA was granted.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
advance, to be able to decide whether the changes need
authorisation.
Whilst a number of subsequent improvements to the associated
plant have been made, each of these was accompanied by separate
environmental authorisation applications.
3.03 For the purpose of taking effluent samples and measuring the
flow, the necessary facilities shall be provided in wastewater
outlets. The details shall be agreed with the Department of
Water Affairs & Forestry.
N/A The auditor was advised that there is no net wastewater outflow
from the MTGE project-associated equipment. No wastewater is
released to the environment, as both the ash water and gas liquor
effluents are internal circulated and re-used.
None.
3.04 Increased production of coal for the MTGE project is only to
occur at the Twistdraai East and West shafts. NC 90% of the feedstock to the gas production facility is coal (the
remaining 10% is natural gas from Mozambique). The plant
utilises a blended coal product, supplied by six coal suppliers (five
Sasol-suppliers and one external supplier).
The Twistdraai shafts are no longer utilised, as the product in the
vicinity of these shafts has been extracted, and replacement shafts
have been sunk to access the coal seams in a commercial, practical
and safe manner. These shafts have themselves have been subject
to environmental assessment and authorisation.
There has been no further increase in coal requirements since the
EA was granted.
However, the condition specifically states that “increased
production of coal for the MTGE project is only to occur at the
Twistdraai East and West shafts”, and an amendment should have
been sought at the time that the Twistdraai shafts were identified
for replacement.
This non-compliance is associated with the specific inclusion of
the reference to “shafts” within the condition wording.
An amendment to the
condition should be sought
in order to remove reference
to specific coal shafts, and
reflect the multiple sources
of supply coal.
Target Completion:
Long term
AIR POLLUTION
4.01 Whenever dust or airborne particles from the Plant are
identified as a problem by either this Department or any
other interested or affected party, the necessary steps must be
C The auditor was verbally advised that there are no airborne
particles or dust related issues at the Gas Production Plant. Ash
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
taken by SSF to remedy the matter to the satisfaction of all
relevant authorities. Any such events must be recorded in the
occurrence or complaints register which must be available
for inspection by this Department.
from the gasifiers is handled as a wet material and does not
generate dust.
Where there is the potential for airborne particles or dust
generation the emission is passed through a scrubber. The steam
plant utilises pulverised fuel, and electrostatic precipitators are
employed to control particulate matter.
A complaint register for internal and external complaints is kept up
to date for the entire Sasol Secunda Operations. Available records
go as far back as 2008. No complaints related to dust or airborne
particles at the Gas Production plant were identified.
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019);
— EIA Final.
4.02 Sulphur emissions to the atmosphere may not increase.
Hydrogen sulphide emissions may not exceed the present
limit of 11.5 Sth (tonnes of sulphur per hour), monthly
average. This is a temporary concession granted to SSF
Sasol subject to a continued programme to reduce the
emissions of sulphur to the atmosphere.
C Two sources of sulphur emissions are identified; the boiler plant
and from the gasification process.
There is commercial benefit to the recovery of elemental sulphur,
hence recovery from H2S is carried out.
Sasol provided the auditor with the Sulphur Recovery Report dated
16 April 2019.
Sasol’s current AEL permit requirements set a limit of 10.50
tonnes of sulphur per hour, and the 30 day average sulphur plant
emissions have not exceeded this limit for the data period provided
(May 2018 – April 2019).
The reduction of the limit from 11.5 to 10.5 tonnes of sulphur per
hour demonstrates that Sasol is committed to reduce the emissions
of sulphur to the atmosphere.
Evidence:
— 4.02 16.04.2019;
— EIA Final.
OFI:
Sasol should seek an
amendment to the EA to
recognise that sulphur
emission levels are reflected
in the current AEL.
Target Completion:
Long term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
4.03 SSF Sasol must institute a programme to investigate
emissions of VOCs (stack and fugitive) to the atmosphere as
well as the control of these emissions. SSF Sasol must
provide the Department of Environmental Affairs and
Tourism (Directorate Air Pollution Control) and the
Department of Environmental Affairs and Tourism
(Mpumalanga) with regular reports (every 3 months)
regarding the progress of these investigations.
NC Sasol has provided the auditor with an Ambient Air Quality
Monitoring Report (October 2016 – March 2017), in addition to
Passive Sampler Results for the period January 2017 – November
2018).
The Ambient Air Quality Monitoring Report includes stack
emissions, and fugitive monitoring is further described in Sasol’s
Fugitive Emission Monitoring Plan.
Evidence of the submission to Gert Sibande District Municipality
of quarterly Dust Fallout Monitoring and Continuous Emissions
Monitoring Reports was provided to the auditor. These reports do
not cover VOC emissions.
VOC emissions for the Phenosolvan plants are reported within the
“Quarterly Continuous Emission Monitoring Report”
(documentation reviewed for April 2019), and Emission Testing
Reports (documentation viewed for December 2018 and February
2019 sample runs). No evidence of VOC sampling for equipment
other than the Phenosolvan plants was viewed, however the auditor
was advised that at the time of the audit Phenosolvan was the only
measuring point.
However, no evidence of submission to the departments listed in
this condition was provided to the auditor, although some evidence
of submission to Gert Sibande District Municipality was provided
(as required by Sasol’s current AEL). It is acknowledged that
submission to these authorities is likely considered superseded by
the AEL requirements.
Evidence:
— 4.03 Ambient Air Quality Report;
— 4.03 Passive sampler results;
— Fugitive Emission Monitoring Plan_2018-10-18 updated;
— 5157_Sasol Secunda emissions and dust fallout
reports_201905_rev00;
— EIA Final;
It is recommended that
Sasol seek an amendment to
bring this condition in line
with Sasol’s current AEL
reporting requirements.
Target Completion:
Long term
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— 201904 SSO continuous emission monitoring quaterly
report_January to March 2019 rev_final;
— SSO Phenosolvan FY19_Q2;
— SSO Phenosolvan FY19_Q3;
— Annual emission report for Sasol Synfuels 0016-2015-
F02_FY18;
— Emission Report for SSO_8 May 2018;
— FY18 Annual emission report for Sasol Oil 0019-2015-F02
final;
— FY18 Annual emission report for
SCO_Solvents_0017_2015_F02_final;
— Phenosolvan VOC Sampling Report
_FY18_Q2_Resampling_V01;
— VOC Sampling report for Phenosolvan_FY18_Q1_V01.
4.04 SSF Sasol must investigate the factors contributing to the
forming of secondary visible pollution. Where possible, the
necessary preventative steps must be taken. SSF Sasol must
provide the Department of Environmental Affairs and
Tourism (Directorate Air Pollution Control) and the
Department of Environmental Affairs and Tourism
(Mpumalanga) with regular reports (every 3 months)
regarding the progress of these investigations.
NC The auditor was provided with an Air Quality and Dust Monitoring
Program Report for the Waste Ash Disposal Site (dated July 2010).
Dustfall reporting from 2018 and 2019 was also provided.
Evidence of the submission to Gert Sibande District Municipality
of quarterly Dust Fallout Monitoring and Continuous Emissions
Monitoring Reports was provided to the auditor.
However, no evidence of submission to MDEAT or the Directorate
Air Pollution Control was provided to the auditor. It is
acknowledged that submission to these authorities is likely
considered superseded by the AEL requirements.
Evidence:
— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-
05;
— 5157_Sasol Secunda emissions and dust fallout
reports_201905_rev00;
— FY19 201903 Dustfall monitoring monthly report_5 May
2019;
The condition should be
amended to bring the
monitoring reporting
requirements into line with
the requirements of the
current AEL.
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— RN_1901592_SAS GESI Secunda Monthly Dust Report Mar-
19;
— 4.08 Secunda Annual Dust Report 2018.
4.05 The emission limits and operating conditions as stated in the
provisional registration certificates issued in terms of the
Atmospheric Pollution Act, 1965 (Section 9) for this project
must be adhered to.
C The facility is covered under the current AEL, and documentation
viewed by the auditor indicates that Sasol is operating the facility
within the AEL permitted emission levels.
The auditor notes that the Atmospheric Pollution Act, 1965
(Section 9) has been repealed, and Sasol operates according to the
National Environmental Management: Air. Quality Act
(NEMAQA), 2004 (Act No. 39 of 2004).
Evidence:
— AEL Sasol Synfuels 0016-2018-F03 (2018);
— EIA Final;
— 4.02 16.04.2019;
— 201810 SSO continuous emission monitoring monthly
report_5 December 2018 rev_02;
— 201901 SSO continuous emission monitoring monthly report
for January 2019 rev_00;
— 201902 SSO continuous emission monitoring monthly report
for February 2019 rev_00.
OFI:
Sasol should seek an
amendment to update this
Condition, to remove
reference to superseded
legislation.
Target Completion:
Long term.
4.06 Revised permits must be obtained for the incinerators in
view of the increased throughput anticipated before the
operation of the expanded plant may commence.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
Furthermore, the facility is covered under the current AEL.
Evidence:
— AEL Sasol Synfuels 0016-2018-F03 (2018).
None.
4.07 The odour problem experienced at the Charlie 1 domestic
waste disposal site must be addressed, and mitigation N/A The odour problems at Charlie 1 domestic waste disposal site
originated from former disposal of organic material at the site two
years prior to the commencement of the MTGE project. The
practice was abandoned and no further problems have been
OFI:
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measures implemented within a time frame as specified by
this Department and other relevant authorities.
experienced. This occurred outside of the audit period, and
compliance is considered no longer applicable.
Sasol’s provided evidence to the auditor that the authorities had
been advised of the situation.
Evidence:
— EIA Final;
— 2.01_EA_MTGE_Poof of commencement_1998-11-04;
— 4.07_EA_MTGE_Charlie1Odour_1998-10-29;
— 4.07_EA_MTGE_Charlie1Odour_1998-11-04;
— 4.07_EA_MTGE_Charlie1Odour_1999-01-11.
Sasol should seek an
amendment to remove this
condition.
Target Completion:
Long term
4.08 Increased dust generation potential, as result of the increased
height of the ash dumps and fine coal dams, must be
quantified and appropriate mitigation measures implemented
within a time frame as specified by this Department.
C The auditor was verbally advised that coarse ash is discarded to the
coarse ash stack in a wet condition, which mitigates against dust
generation. Once the maximum permitted height is reached for the
stack, the stack is stabilised with vegetation and topsoil further
stabilising the stack. Sasol is currently not increasing the coarse
ash stack, rather increasing width.
Waste fly ash is also generated wet, and sets hard upon drying,
therefore dust generation is limited.
All fine coal is utilised within the Sasol site (boilers at Steam
Plant), and in the event that the fine coal is not required for use in
the plant it is pumped into water dams (slurry ponds) and kept
underwater and is therefore not at risk of generating dust. Fine coal
is recovered as required, and there is water-spraying in the fine
coal recovery areas to suppress dust (in the event that this is
required).
The EIA states that fly ash emissions (released from the main tall
stacks) will not increase for MTGE (no increased load on the
boilers).
The surface moisture on the coal from the mines means that there
is no dust / fine coal particles into the air. In dry conditions, the
None.
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coal supply stockpiles are coated in water from hydrants to
mitigate against dust generation.
The auditor was provided with dust monitoring reporting, which
evidences that dust generation is quantified and appropriate
mitigation measures implemented.
Evidence:
— EIA Final;
— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-
05;
— 4.08 Secunda Annual Dust Report 2018;
— 4.08 Secunda Monthly Dust Report Feb 2019;
— 4.08 Secunda Monthly Dust Report Jan-19;
— 4.08 Secunda Monthly Dust Report Mar 2019.
WATER POLLUTION
5.01 Water used for the cleaning of the dams and tanks before,
during or after the production season, must be treated
according to the specifications of the Department of Water
Affairs & Forestry (DWAF), or any other relevant authority,
before it is released into the environment. A copy of this
specifications must be forwarded to this Department before
31 October 1998.
C The gas production plant is considered a zero discharge facility.
All stormwater within Sasol is collected onsite and, if deemed
contaminated, is sent to the API oily water sewer and recovery
system.
Water is not utilised for cleaning of the dams. During the tank
cleaning process settlement product is removed as solid waste, and
tanks are only steam-cleaned in the event that the tanks require re-
coating. In such instances the wastewater is contained and removed
from site as liquid waste.
The requirement to forward a copy of the treatment process /
equipment specification prior to 31 October 1998 is considered
outside of the audit period.
Evidence:
— 5.02_EA_MTGE_Design Philosophy_1999-02-11;
— IWWMP SIC 2015 Final_2018-05-15;
None.
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— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2.
5.02 No untreated water may be released into the environment,
and if untreated water cannot be stored or properly treated
onsite, it must be disposed of on a registered waste site for
hazardous waste. The treatment of cleaning water should be
included in the EMP.
C Noted. The SSF factories are considered zero discharge facilities.
All stormwater within Sasol is collected onsite and, if deemed
contaminated, is sent to the API oily water sewer and recovery
system.
Evidence:
— 5.02_EA_MTGE_Design Philosophy_1999-02-11;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2.
None.
5.03 All storm water that originates on the property must be
collected and treated to specifications set by DWAF or any
other relevant authority, before it is released to the
environment. Where relevant the necessary permits must be
obtained from the relevant authority and copies thereof
forwarded to this Department within 30 days of obtaining the
said permits.
C All stormwater within Sasol is collected onsite and, if deemed
contaminated, is sent to the API oily water sewer and recovery
system. The oily water is skimmed and analysed. Upon acceptable
water quality parameters being achieved the treated water is
released to the environment.
The entire Sasol complex is operated under one Water Use Licence
(WUL).
Evidence:
— 5.02_EA_MTGE_Design Philosophy_1999-02-11;
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2;
— WUL SIC SSA_200322144_2008-11-21; and,
— WUL SIC SSA amendment_200322144_2010-01-08.
None.
5.04 Splash pads must make provision for the containment of
storm water. No untreated water may be released or allowed
to be released to the environment, and if untreated water
cannot be stored or properly treated onsite, it must be
disposed of on a registered waste site for hazardous waste.
The treatment of runoff water should be included in the
EMP.
C There are no splash pads at the gas production plant. All
stormwater within Sasol Synfuels Operations is collected onsite
and, if deemed contaminated, is sent to the API oily water sewer
and recovery system. The oily water is skimmed and analysed.
Upon acceptable water quality parameters being achieved the
treated water is released to the environment
Evidence:
OFI:
It is recommended that an
amendment is sought to
remove reference to splash
pads.
Target Completion:
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2 Long term
5.05 The water balance and the water quality at the various
compliance points may not be impacted on by the MTGE
project.
C The water balance of the Gas Production plant is included in the
Business Unit’s IWWMP. Ground water monitoring is conducted
biannually (every six months) and quarterly. In terms of water
quality, there are no monitoring boreholes in immediate proximity
to the gasification plants both on the East and West complexes.
However, there are six active boreholes located within the Primary
area which are utilised for monitoring. The auditor note a number
of exceedances in the November 2017 sampling run, however
these exceedances cannot be directly attributed to the gasification
plants.
Furthermore, water that is used in the gasification process is
recycled and reused in the process. The SSF factories are
considered zero discharge facilities.
Evidence:
— 5.02_EA_MTGE_Design Philosophy_1999-02-11;
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2;
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.
None.
5.06 The impact of the surface mine water system must be
resolved before the commissioning of the MTGE project can
commence at the end of 1999.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
5.07 The integrated water management plan must be presented to
the Department of Water Affairs and Forestry and the
Department of Environmental Affairs and Tourism
(Mpumalanga) by December 1998. This integrated
management plan must adequately address the issue of
excess mine water. Mitigation measures to be implemented
must also be proposed and submitted to the relevant
authorities for comments and approval.
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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5.08 The integrated water management plan must be approved by
the Department of Water Affairs and Forestry and the
Department of Environmental Affairs and Tourism
(Mpumalanga) before the commission of the MTGE project
can commence.
N/A This condition is considered outside of the audit period
(construction pre-2014). The plant is already in operational phase.
It is therefore considered not applicable.
None.
5.09 Mitigation measures are to be implemented to address
surface water, groundwater and soil contamination at the
black products site.
N/A Noted. The Black Products site is closed off and was completely
rehabilitated.
Sasol have a long term monitoring plan which is outlined in the
IWWMP and as required by the WUL and WML.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-
11-20
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
None.
WASTE
6.01 All waste from the Plant shall be stored, handled and
disposed of in an environmentally acceptable way, and as
directed by this Department or any other relevant authority.
C The waste register for the gasification plant was viewed, and waste
appear appropriately classified and disposal methods listed are
acceptable.
Waste management is carried out via implementation of a Waste
Management procedure 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.
Evidence:
None.
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— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Gasification_2016-11-28.
6.02 Ash from the incinerators may only be disposed of on an
authorised site. C Fine ash from the incinerators is sent to the ash plant, where it is
reused, or to the fine ash dams (a licensed facility). Coarse ash is
sent to the Outside Ash facility, which is also an authorised site.
Evidence:
— EIA Final
None.
6.03 In order to compensate for the ongoing production of
catalyst waste products and to provide alternative waste
storage, recycling and stabilizing facilities by the year 2004,
details regarding the project must be provided to the
Department of Water Affairs and Forestry and the
Department of Environmental Affairs and Tourism
(Mpumalanga) through the submission of ongoing progress
reports every (three) 3 months.
N/A A document on the classification of spent catalyst, dated August
1998 was provided to the auditor, in addition to a minimisation
study dated September 1997.
However, compliance with this condition is considered outside of
the audit period, as it is stated that alternative waste storage,
recycling and stabilizing facilities are required by 2004 (i.e.
outside of the audit period).
Evidence:
— 6.03_EA_MTGE_Waste Minimization Study;
— 6.7 Waste stream Audit;
— 6.3 MTGE EA Conditions_Spent Cat treatement
None.
6.04 The MTGE project must slot into the waste minimisation
strategy of the Sasol Secunda Complex. C A waste minimisation study for the MTGE project was completed
in 1997; this document included the waste registers applicable to
the project at the time of commencement. Furthermore, Sasol has a
Waste Management Procedure as well the latest waste registers
applicable to all the business units in its Integrated Management
System.
The MTGE EIA was provided to the auditor, which also references
waste minimisation procedures, and states that MTGE will have no
negative effect on the waste minimisation initiatives that are
currently being implemented.
None.
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Evidence:
— 5.9 Mitigation Measures;
— 5.9 Mitigation Measures 2;
— 6.03_EA_MTGE_Waste Minimization Study;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Gasification_2016-11-28.
6.05 The MTGE project must also form part of the
comprehensive integrated Sasol Secunda Waste Emissions
Management Programme.
C Waste management across the Sasol complex (including at the
gasification plants) is carried out via implementation of a Waste
Management procedure 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.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Gasification_2016-11-28.
None.
6.06 The issue of the spent catalyst must be resolved and
approved by the authorities before the MTGE project is
commissioned at the end of 1999.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
Regardless, a document on the classification of spent catalyst,
dated August 1998 was provided to the auditor, in addition to a
minimisation study dated September 1997.
Evidence:
— 6.6 MTGE EA Conditions_Spent Cat treatement;
— 6.7 Waste stream Audit.
None.
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6.07 Any lateral expansions of existing solid waste facilities will
require authorisation in terms of the Environment
Conservation Act, 1989 (Act 73 of 1989).
N/A Noted. There have not been any expansions or additions since the
receipt of the RoD (i.e. within the audit period) that have not been
separately authorised.
Evidence:
— 6.7 Waste stream Audit.
None.
6.08 The Black Products Waste Disposal site is to be closed by
2004 and rehabilitated. The rehabilitation plan for the
disposal site must be authorised by the Departments of
Water Affairs and Forestry and Environmental Affairs and
Tourism at least 60 days before planned closure of the site.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
The Black Products site is closed off and was completely
rehabilitated.
None.
6.09 Alternative waste storage, recycling and stabilization
facilities are to be identified and authorised by the
Departments of Water Affairs & Forestry and Environmental
Affairs & Tourism before the year 2004.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
RISK MANAGEMENT
7.01 All employees, contractors and sub-contractors employed by,
or delivering a service to SSF, shall be acquainted with the
characteristics and dangers associated with the processes
used by SSF. They shall also be familiar with these
processes as well as the emergency plans associated with it,
and shall receive instructions and procedures necessary to
prevent emergency situations.
C A work instruction for Minimum requirements for environmental
risk assessments for all Sasol Synfuels and Sasol Chemical
Operations is also available on Sasol’s web-based system, and its
latest review date is 01 February 2017.
Every person entering the Sasol site is subject to a SHE induction
process to ensure that all persons are familiar with the Safety,
Health & Environmental aspects and requirements of that
site/plant.
Safety and emergency information for Sasol is also available on its
web-based system and every staff member has access to it. At each
plant, personnel undergo induction that includes all the health and
safety aspects as well as the emergency procedures of the
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
gasification plants. Refresher trainings are held every three years
from the initial induction for each personnel.
Evidence:
— Risk Assessment: SGI-SHE-000014;
— Induction_Mod4_ProcessSafetyManagement;
— Induction_Mod5_WorkPlaceSafety;
— Induction_Mod7_Occupational.
MONITORING
8.01 After operation of the Plant has commenced, monitoring
results as per the approved monitoring plan, must be
recorded in the monitoring register.
C A Department-approved consolidated monitoring register and
monitoring plan for gas production were not provided to the
auditor.
However, the auditor was provided with a stack sampling schedule
(2019-2020), and evidence of both groundwater and surface water
monitoring. Monitoring is completed in line with the AEL and
WUL.
Monitoring requirements and results are logged into a central
Environmental Information System, and the auditor was provided
with screenshot evidence of this record.
Evidence:
— SSO Stack Sampling Schedule 2019_2020;
— RESMS Weekly Monitoring_2008-2019;
— Groundwater monitor WISH Database_Survey
New_201900523.
OFI:
An amendment should be
sought to bring the
monitoring recording and
reporting requirements into
line with the current AEL
and WUL requirements.
Target Completion:
Long term
8.02 Monitoring for water pollution must be carried out according
to the existing monitoring programme. C An IWWMP for the Gas Production business unit exists, and
groundwater monitoring takes place annually.
Monitoring is completed as stipulated in the requirements of the
Sasol Complex-wide WUL.
None.
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Evidence:
— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2;
— WUL SIC SSA_200322144_2008-11-21; and,
— WUL SIC SSA amendment_200322144_2010-01-08.
REPORTING
9.01 SSF shall keep regular records of use of raw materials,
auxiliary materials water and all other materials potentially
hazardous to the environment, and of the generation and
disposal of wastewater and waste. These records shall be
audited by this Department as well as any other relevant
authority, and shall be available for inspection at all times.
C Sasol keeps records of the volumes of raw materials used and
waste disposed of, principally for commercial purposes. The main
inputs are coal and water. The auditor was provided with evidence
of the water usage records and coal usage records.
Sasol makes use of a web based Information Management System
(IMS) that includes a comprehensive Document Management
System (Easy DMS) where all supporting documentation for all its
authorisations and other legal obligations are kept and are available
to prove compliance with legal requirements. These shall be made
available to the department upon request.
Evidence:
— Raw & Rand water
— 20190604 Summary of coal contract FY18-19 - May included
– East
— 20190604 Summary of coal contract FY18-19 - May included
- West
None.
9.02 The company must notify this authority within 24 hours in
the event of non-compliance with any of the conditions of
the authorisation and/ or in the case of any event which
results in emissions or discharges of pollutants.
NC Non-compliances have been noted during this audit relating to air
quality reporting requirements and coal supply source, and it is
understood that the department has not been notified as such.
Going forwards, Sasol
should notify the
department of any non-
compliances with this EA in
a timely manner, in
accordance with this
condition.
Target Completion:
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Medium term
9.03 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 to this Department
within seven (7) workdays of the date on a written request by
the Department for such records.
N/A This audit represents the first required audit for this EA. Prior to
the introduction of the 7 April 2017 amendment to the
Environmental Impact Assessment (EIA) regulations, no audit
against this EA was required.
None.
9.04 Non-compliance with, or any deviation from the conditions
as set out in the Exemption 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. None.
9.05 Any complaints regarding the said development must be
brought to the attention of the Department within 24 hours
after receiving the complaint. A complaints register must be
kept for inspection by members of this Department.
C
The complaints register from 2008 to date was available for review
and there have been no complaints lodged with regards to the
operation of the pipeline for the 2014-2018 audit period.
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019).
None.
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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 3
below.
Table 3: Summary of EA Compliance Audit Findings
SECTION OF THE EA NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 4 1 0 3
ESTABLISHMENT OF THE ENTERPRISE 2 0 0 2
CONSTRUCTION AND OPERATION 4 0 1 3
AIR POLLUTION 8 4 2 2
WATER POLLUTION 9 5 0 4
WASTE 9 4 0 5
RISK MANAGEMENT 1 1 0 0
MONITORING 2 2 0 0
REPORTING 5 2 1 2
Total Count 44 19 4 21
Total Percentage 43% 9% 48%
Percentage Compliance with Applicable Conditions 83%
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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
Figure 3: Overall count findings on compliance to the EA conditions
0123456789
10
Sectional Count Contribution
C
NC
N/A
19
4
21
Total Compliance
C
NC
N/A
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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
Figure 5: Overall percentage findings on compliance to the EA conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
43%
9%
48%
Total Percentage Compliance
C
NC
N/A
APPENDIX
A ENVIRONMENTAL AUTHORISATION
(14/2/10/NH/3W)