ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL … Audit_Sa… · 29-05-2019 · SHE: Environmental Compliance Specialist Broni van der Meer Gas Circuit Production Senior Manager

SECUNDA SYNFUELS OPERATIONS: GAS CIRCUIT

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/2/1(I) MP-1 - C2 RECOVERY FROM NATURAL GAS

29 MAY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/2/1(I) MP-1 - C2 RECOVERY FROM NATURAL GAS

SECUNDA SYNFUELS OPERATIONS: GAS

CIRCUIT

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: MAY 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

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:

17/2/2/1(i) MP-1

Draft v2 for Review –

Compliance Audit

EA Ref:

17/2/2/1(i) MP-1

Final – Compliance

Audit

EA Ref:

17/2/2/1(i) MP-1

Date April 2019 May 2019 May 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 013 013 013

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

-

Ziyaad Kadwa

Consultant

REVIEWED BY

Jenny Cope

Associate

This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf

and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding

of their compliance with the conditions included in the Environmental Authorisation 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: Environmental Compliance

Specialist

Broni van der Meer

Gas Circuit Production Senior Manager Peter de Cruz

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS CIRCUIT

WSP May 2019

TABLE OF CONTENTS

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

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

1.2 C2 Recovery from Natural Gas (Authorisation

Number: 17/2/2/1(i) MP-1) ....................................... 1

2 AUDIT SCOPE ........................................... 3

3 AUDIT METHODOLOGY ........................... 4

3.1 Audit Checklist ........................................................ 4

3.2 Site Inspection ......................................................... 4

3.3 Documentation Considered ................................... 4

3.4 Audit Compliance Assessment .............................. 5

3.5 Audit Team ............................................................... 5

3.6 Assumptions and Limitations ................................ 6

4 AUDIT FINDINGS ...................................... 7

5 SUMMARY OF THE AUDIT FINDINGS ... 20

5.1 Environmental Authorisation ............................... 20

5.2 Environmental Management Plan ........................ 23


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 14

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 20

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 23

FIGURES

FIGURE 1: SSO – C2 RECOVERY FROM NATURAL GAS (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 21

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 21

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 22

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 22

FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 23

FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 24

FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 24

FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 25


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APPENDICES

A ENVIRONMENTAL AUTHORISATION (17/2/2/1(I) MP-1)


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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: 17/2/2/1(i) MP-1 issued on 19 November 2007) as well

as the associated Environmental Management Plan (EMPr) (undated) for the period December 2014 to February

2019.

1.2 C2 RECOVERY FROM NATURAL GAS

(AUTHORISATION NUMBER: 17/2/2/1(I) MP-1)

Sasol received an EA for the recovery of C2 from natural gas by means of modifying the pre-existing cold

separation unit. The project was only commissioned in 2014 (although it was constructed the year prior), and

entailed the installation of the following infrastructure/equipment:

— Air cooled heat exchanger;

— Three driers;

— Shell and tube heat exchanger;

— Two filters;

— Feed and effluent heat exchanger;

— Three separator drums; and,

— Two knock-out drums

Figure 1 provides an overview of the location of the facility.

The EA was issued on 19 November 2007, and it has been confirmed that the construction phase was completed

prior to December 2014 (i.e. outside the audit period).


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Figure 1: SSO – C2 Recovery from Natural Gas (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 EA 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; and,

— Make recommendations in order to achieve compliance in terms of the EA and EMPr.


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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents

were utilised as a template during the compliance audit process. This methodology ensures that the compliance

audit was conducted in a systematic and independent manner that was documented and objectively evaluated to

determine compliance to the EA and associated EMPr conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (13 March 2019);

— Review of documentation relevant to the conditions of the EA and associated EMPr (e.g. records,

permits/certificates/maintenance logs/monitoring results/previous reports etc.); and

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

WSP compiled an audit checklist to assist with the EA and EMPr compliance audit (Section 4).

3.2 SITE INSPECTION

Ziyaad Kadwa conducted the site inspection on 13 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:

— Pieter Venter (Day-shift Foreman).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Environmental Authorisation: SSO_GC_17.2.2.1(i) MP-1_C2 Recovery_2007-11-19;

— EMPr: 00. EIA documentation C2+ Recovery - EMP;

— Induction_Mod1-8;

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— Copy of Environment Impact register_ New FY17;

— IWWMP SIC 2015 Final_2018-05-15;

— Environmental Complaints Register_2019-02-18;

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

— Sasol SAWIS upload-2018_Jul-Sep;

— Waste register: Gas Processing_2016-12-08;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.pdf;

— SOX Folder;

— SSO_GC_Amendment_C2 Recovery from Natural Gas_1.3.1.16.4 G-32_2017-04-28;

— 4.01_EMP_Maintenance Strategy_SGR-MOR-000004;

— 5.01_EMP_InspectionTaskSheet_X23M038;


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— Works emergency procedure_CGR-EMP-000001_Rev04_2016-02;

— Induction_Mod6_EmergencyManagement; and,

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and Table 3). The

checklist included the conditions and associated requirements as specified in the EA and associated EMPr.

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 EA and associated EMPr conditions were apportioned according to the

elements requiring compliance assessment therein. Although some elements of the condition may have been

compliant, if one of the elements was determined to be non-compliant, the entire condition has been reported as

such (and counted as such during percentage compliance calculation). This apportionment further allowed for

the development of focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or

relevant actions were implemented.

Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented

according to the requirements of the EA and associated EMPr. Non-complaint conditions are

given target completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.

— Conditions marked as “Noted” are considered information points only.

— Where conditions are considered “not auditable” within the scope of this assessment this

is stated and explained within the condition commentary.

Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion

dates).

3.5 AUDIT TEAM

The Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer and Pieter Venter, 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.


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— Auditor: Ziyaad Kadwa

Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal

Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the

Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it

part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural

Development for 3 years. He is currently completing his BSc Honours in Environmental Management part

time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a

number of high profile clients in various industries. He has three years of auditing experience, and has

successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,

Impala Platinum and NPC (InterCement). He has also done environmental management programme audits

for BRPM and for various infrastructure projects as part of environmental control officer duties.

— Project Manager and Quality Assurance: Jenny Cope

Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental

Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;

undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a

range of sectors. Jenny’s recent experience includes completion and management of several pan-European

and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and

providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in

environmental consultancies and with a developer, giving context to understanding the practicalities of

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an

understanding of the Relevant Documents.

Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other

than the Client for the contents of, or any omissions from, this Report.

To prepare this Report, we have reviewed only the documents and information provided to us by the Client or

any third parties directed to provide information and documents to us by the Client. We have not reviewed any

other documents in relation to this Report and except where otherwise indicated in the Report.

The findings, recommendations and conclusions given in this report are based on the author’s best scientific and

professional knowledge, as well as available information. This report is based on survey and assessment

techniques which are limited by time and budgetary constraints relevant to the type and level of investigation

undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if

and when new information may become available from on-going research or further work in this field, or

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts

no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or

in connection with the services rendered, directly or indirectly by the use of the information contained in this

document.

This report must not be altered or added to without the prior written consent of the author. This also refers to

electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.

Similarly, any recommendations, statements or conclusions drawn from or based on this report must make

reference to this report. If this report is used as part of a main report, the report in its entirety must be included

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

SCOPE OF AUTHORISATION

3.1 Authorisation of the activities is subject to the conditions

contained in this authorisation, which form part of the

environmental authorisation and are binding on the holder of

the authorisation.

N/A Statement noted by Sasol. None.

3.2 The holder of the authorisation must ensure compliance with

the conditions by any person acting on his or her behalf,

including but not limited to, an agent, sub-contractor,

employee or person rendering a service to the holder of the

authorisation.

C All visitors and contractors entering the Sasol Complex are

required to undergo an SHE induction process. All training is done

through the SHE regional learning and development academy, and

records maintained by Sasol.

Dangers and safety measures are included within induction training

material.

Evidence:

— Induction_Mod1-8.

None.

3.3 The activities which are authorized may only be carried out

at the property indicated above. C The activity remains as specified and no further alterations or

changes have been made.

None.

3.4 Any changes to, or deviations from, the project description

set out in this authorisation must be approved, in writing, by

the Department before such changes or deviations may be

effected. In assessing whether to grant such approval or not,

the Department may request such information as it deems

necessary to evaluate the significance and impacts of such

changes or deviations and it may be necessary for the holder

of the authorisation to apply for further authorisation in

terms of the regulations.

C The activity remains as specified and no further alterations or

applications have been made.

None.


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3.5 These activities must commence within a period of two (2)

years from the date of issue. If commencement of the

activity does not occur within that period, the authorisation

lapses and a new application for environmental authorisation

must be made in order for the activity to be undertaken.

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

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

None.

3.6 This authorisation does not negate the holder of the

authorisation of the responsibility to comply with any other

statutory requirements that may be applicable to the

undertaking of the activities.

N/A Noted. The Sasol Complex operates with a dedicated

environmental and legal team, and therefore ensures that they

comply with applicable legislation.

In addition, 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 confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

APPEAL OF AUTHORISATION

3.7 The holder of the authorisation must notify every registered

interested and affected party, in writing and within seven (7)

calendar days, of receiving notice of the Department’s

decision to authorise the activities.



None.

3.8 The notification referred to in 3.7 must –

a) Specify the date on which the authorisation was issued;

b) Inform the interested and affected party of the appeal

procedure provided for in Chapter 7 of the regulations; and,



None.


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c) Advise the interested and affected party that a copy of the

authorisation and reasons for the decision will be furnished

on request.

MANAGEMENT AND MONITORING OF THE ACTIVITY

3.9 The Environmental Management plan (“EMP”) submitted as

part of the application for environmental authorisation must

be implemented and adhered to during the commissioning,

operation and decommissioning of the activity.

C Construction was completed prior to this audit period.

The EMPr has not been audited against between the completion of

construction and operation up to 2019.

One internal audit against the EMPr was done in 2019 and the

EMPr has been included within this audit. This audit constitutes a

further review of compliance to the EMPr. No non-compliances

were observed for the audit period.

Sasol is considered compliant due to the operation of the plant

being within the environmental policies and procedures that are in

effect.

None.

3.10 The holder of the authorisation must submit a post-

construction environmental audit report after a year of

commencement of the project to the Department. The audit

report must be compiled by an accredited independent

auditor.



None.

3.11 The Department retains the right to monitor and/or inspect

the proposed project during both construction and

operational phases

N/A According to Sasol, no such requests to inspect have been made

since issue of the EA.

None.

COMMISSIONING AND OPERATION OF THE ACTIVITY

3.12 Fourteen (14) days written notice must be given to the

Department that the activity will commence.

Commencement for the purposes of this condition includes



None.


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site preparation. The notice must include a date on which it

is anticipated that the activity will commence.

3.13 Approval from CAPCO with regards to the amendment of

the existing air permit must be obtained before any

construction activities commence.



None.

3.14 Workers must be made aware of the harmful effects of the

project and must be trained on the dangerous and safety

measures that must be taken.

C All visitors and contractors entering the Sasol Complex are

required to undergo an SHE induction process. All training is done

through the SHE regional learning and development academy, and

records maintained by Sasol.

Dangers and safety measures are included within induction training

material.

Evidence:

— Induction_Mod1-8.

None.

3.15 Measures must be taken to prevent and manage soil

contamination during and after construction. C Construction was completed prior to this audit period.

The auditor inspected the plant area during the site walkover and

noted that the plant is built on a hard surfaced area and is bunded.

There are no exposed surfaces that can be directly contaminated by

the plant.

None.

3.16 It is the responsibility of the holder of the authorisation to

rectify any source of pollution from their undertaking. C The authorisation was limited to the installation of the

infrastructure listed in Section 1.2 (as per the EA); although the

infrastructure is linked to the greater process, there are no air

pollutants or point sources that were created as a result of the

installation.

An incident comprising ‘black smoke flaring’ occurred on 15

February 2017 and was caused by the compressors which tripped

at the Cold Separation East and although attributed to the C2

Recovery Unit (Unit 223), it was not caused by any of the

infrastructure installed as part of this EA.

None.


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The plant is operating within a hard surfaced and bunded area, and

any stormwater is managed by the oily water system.

One condensate pipe discharges steam to a clean stormwater drain.

Bunding and Hard Surfacing Around the System

Evidence:

— Copy of Environment Impact register_ New FY17; and,

— IWWMP SIC 2015 Final_2018-05-15.

3.17 Any complaints received from the public during construction

and operational phases of the activity must be attended to as

soon as possible and addressed to the satisfaction of all

concerned.

C All environmental complaints received from interested and

affected parties, both internal and external to the organisation, are

recorded in a complaints register that is maintained by Sasol’s

Environmental Department. Complaints are investigated and

reported in line with the procedure (SGR-SHE-000022)) and as per

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

None.


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The complaints register (FY 2014-2019) was checked and no

complaints related to the C2 recovery plant were recorded for this

audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.

3.18 All waste generated on the site must be stored, handled, and

disposed of in a registered landfill site or as directed by any

other relevant authority.

C The site operates in accordance to Sasol’s Waste Management

Procedure. The C2 recovery plant does not produce any waste

during normal operating conditions; the tanks are cleaned and de-

sludged annually during the shutdown period. Spent catalyst

produced is collected and disposed as hazardous waste via a

specialised waste management contractor.

Sasol makes use of a SAP Sustainability Performance

Management Module (SUPM) as a database for tracking waste

volumes that are managed on and off site.

Sasol further reports the on-site waste management data into the

South African Waste Information System (SAWIS), on a quarterly

basis. The off-site management of waste is reported into SAWIS

by the accredited Waste Management Service Providers on a

quarterly basis.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol SAWIS upload-2018_Jul-Sep; and,

— Waste register: Gas Processing_2016-12-08.

None.

SITE CLOSURE AND DECOMMISSIONING

3.18 A rehabilitation plan must be submitted to this Department

for approval at least six (6) months prior to the

decommissioning phase.

N/A Statement noted by Sasol. Closure is not yet planned for and

according to Sasol, is estimated to occur around 2050.

None.


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GENERAL

3.19 A copy of this authorisation must be kept at the property

where the activities will be undertaken. The authorisation

must be produced to any authorized official of the

Department who requests to see it and must be available for

inspection by any employee or agent of the holder of the

authorisation who works or undertakes work at the property.

C Sasol’s environmental team have soft copies of the EA 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.

Sasol provided the auditor with the evidence that the responsible

person, Joretha Klaassee, has been made aware of the EA on 06

September 2016.

Evidence:

— EA_EX Handover_SSO_GC-GP.

None.

3.20 Where any of the applicant’s contact details change,

including the name of the responsible person, the physical or

postal address and / or telephonic details; the applicant must

notify the Department as soon as the new details become

known to the applicant.

C Sasol notified the Department of a name change that occurred; an

amendment confirmation letter was received (dated 28 April

2017).

Evidence:

— SSO_GC_Amendment_C2 Recovery from Natural

Gas_1.3.1.16.4 G-32_2017-04-28.

None.

3.21 The holder of the authorisation must notify the Department,

in writing and within 24 (twenty-four) hours, if conditions of

this authorisation are not adhered to. Any notification in

terms of this condition must be accompanied by reasons for

the non-compliance.

N/A According to Sasol, no non-compliances or notifications were

submitted to the Department for this audit period.

None.

3.22 Non-compliance with a condition of this authorisation may

result in criminal prosecution or other actions provided for in

the National Environmental Management Act, 1998 and the

regulations.

N/A Statement noted by Sasol. None.


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Table 3: Audit Findings – Environmental Management Plan


APPOINTMENT CONTRACTOR, LABOURERS, ETC.

1.01 Employment & Skills development:

Local labourers will be used during construction.

Labourers will acquire basic skills such as painting during

construction.

N/A No contractors operated on the C2 plant for this audit period.

This condition is considered outside of the audit period


None.

SITE PREPARATION

2.01 Oil and noise from electricity generators and other diesel

machinery:

Ear protection shall be worn at all times on site and

machinery which leaks oils shall be removed from site and

replaced.



None.

CONSTRUCTION

3.01 Spent grinder wheels, welding rods and insulation material

(non-asbestos) not disposed of correctly:

These will have a dedicated waste bin which will be emptied

at the registered Charlie 1 general waste disposal site.



None.

3.02 Spent oils:

These are collected in suitable receptacles and removed from

site by the contractor.



None.

3.03 Construction equipment: N/A This condition is considered outside of the audit period


None.


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Drip trays to be provided for all generators. Equipment with

excessive smoke, noise and leaking oil are not allowed on

site.

3.04 Refuelling:

Efficient funnels and nozzles to be used and drip trays. Any

spills will be cleaned immediately.



None.

3.05 Spent grease:

If it is in the ratio of 1 of grease: 12 of general waste, it can

go to Charlie 1 general waste disposal site.



None.

3.06 Paint containers:

Collected in a special bin and disposed of at Holfontein

hazardous waste disposal site.



None.

3.07 Insulation material not disposed of correctly/packing

material:

Waste bins must be separated and disposed at the recognised

sites.



None.

3.08 Water from temporary portable toilet facilities:

Regular site inspections by Construction Health & Safety

group.



None.

3.09 Spent cement:

Uncontaminated cement shall be disposed of at the Charlie 1

general waste disposal site. Should the cement be

contaminated then it will taken to Holfontein hazardous

waste disposal site.



None.


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3.10 Overloading capacity of existing infrastructure:

Contractor will comply to National and Sasol road traffic

regulations.



None.

COMMISSIONING OF EQUIPMENT

4.01 Spent water used in hydro testing:

Used water will be drained to the oily water sewer where it

will treated at bioworks.



None.

4.02 Chemicals used for cleaning, not disposed of correctly:

All chemicals used for cleaning will be disposed by the

contractor at a permitted site.



None.

4.03 Incorrect disposal of redundant equipment (contaminated or

non-contaminated):

Contaminated equipment to be separated and disposed as per

existing procedures.



None.

OPERATIONS

5.01 Leaks from new product lines:

All new lines shall form part of the plant’s maintenance

strategy involving daily inspections, reporting and

maintenance.

C All new lines installed were included within the plant’s

maintenance strategy. In addition, statutory inspection task sheets

are completed on each piece of equipment.

Evidence:

— 4.01_EMP_Maintenance Strategy_SGR-MOR-000004; and,

— 5.01_EMP_InspectionTaskSheet_X23M038.

None.


WSP May 2019

Page 17


5.02 Safety Risks/Emergency Plan:

Update existing emergency plans and training modules

C All the aspects related to the C2 plant are covered within the site’s

emergency plan. Emergency management is also included as a

module within the induction training.

Evidence:

— Works emergency procedure_CGR-EMP-

000001_Rev04_2016-02; and,

— Induction_Mod6_EmergencyManagement.

None.

5.03 Fire water system:

The existing fire water system will be updated to

accommodate the new equipment.

C The site is included in the fire management system at Sasol.

During the site walkover, serviced fire hydrants, fire extinguishers

and fire lines were noted.

There are also a number of alarm and detection systems throughout

the site.

Fire Water System

None.


WSP May 2019

Page 18


SHUTDOWN & MAINTENANCE

6.01 Draining of lines:

Contaminated water to be separated and disposed into the

oily water sewer.

C The plant is located within a hard surfaced and bunded area with a

drain connected to the oily water system which drains to the API

Dams for treatment.

Bunding and Hard Surfacing around the System

None.

6.02 Used catalyst not disposed correctly:

The molecular sieves will be subjected to a thorough

regeneration before being discharged from the vessel. The

molecular sieves will be doused or soaked with excess water

before being sent to landfill.

C Spent catalyst is collected and disposed as hazardous waste via a

specialised waste management contractor.

Sasol makes use of a SAP Sustainability Performance

Management Module (SUPM) as a database for tracking waste

volumes that are managed on and off site.

Sasol further reports the on-site waste management data into the

South African Waste Information System (SAWIS), on a quarterly

basis. The off-site management of waste is reported into SAWIS

by the accredited Waste Management Service Providers on a

quarterly basis.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

None.


WSP May 2019

Page 19


— Sasol SAWIS upload-2018_Jul-Sep; and,

— Waste register: Gas Processing_2016-12-08.


WSP May 2019

Page 20

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

The audit findings have been summarised into the following categories: compliance, non-compliance and not

applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 4

below.

Table 4: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 6 3 0 3

APPEAL OF AUTHORISATION 2 0 0 2

MANAGEMENT AND MONITORING 3 1 0 2

COMMISSIONING AND OPERATION 7 5 0 2

SITE CLOSURE AND DECOMMISSIONING 1 0 0 1

GENERAL 4 2 0 2

Total Count 23 11 0 12

Total Percentage - 48% 0% 52%

Percentage Compliance with Applicable Conditions 100%


WSP May 2019

Page 21

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

0

1

2

3

4

5

6

7

8

Sectional Count Contribution

C

NC

N/A

11

0

12

Total Compliance

C

NC

N/A


WSP May 2019

Page 22

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

48%

0%

52%

Total Percentage Compliance

C

NC

N/A


WSP May 2019

Page 23

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

APPOINTMENT CONTRACTOR, LABOURERS, ETC. 1 0 0 1

SITE PREPARATION 1 0 0 1

CONSTRUCTION 10 0 0 10

COMMISSIONING OF EQUIPMENT 3 0 0 3

OPERATIONS 3 3 0 0

SHUTDOWN & MAINTENANCE 2 2 0 0

Total Count 20 5 0 15

Total Percentage - 25% 0% 75%

Percentage Compliance with Applicable Conditions 100%

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

Sectional Count Contribution

C

NC

N/A


WSP May 2019

Page 24

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

5

0

15

Total Compliance

C

NC

N/A

0102030405060708090

100

AppointmentContractor,

Labourers, etc.

SitePreparation

Construction Commissioningof Equipment

Operation Shutdown &Maintenance

Sectional Percentage Contribution

C

NC

N/A


WSP May 2019

Page 25

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 the majority of the listed measures are now no longer applicable,

as these mostly related to the construction-phase 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 EA, relevant WUL and AEL; and through

Sasol’s choice to comply with the ISO 14001 Environmental Management international standard.

The EIA Regulations 2014 (as amended) requires that the EA and EMPr is audited only at least every five years,

and Sasol has systems in place which are considered to be more robust for monitoring compliance and

implementing changes than through the EMPr audits; including the annual audit of each business unit to

meeting ISO 14001 standards.

New impacts and risks are continually identified and assessed by Sasol by its Governance SHE Risk and

Assurance department; which assesses environmental risks and drives improvement implementation. The SHE

Environment department facilitates Environmental Risk Assessments per business entity to ensure that gaps are

addressed through implementation of mitigation measures via the Integrated Management System. Sasol further

addresses all Key Undesirable Events (KUEs) from a group perspective. Risk documentation is hosted on

Sasol’s Information Management System.

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

14001 standards and meet licence compliance (EA, WUL, AEL), this is effective as mitigation against any gaps

in the EMPr and as a means to regularly identify new impacts and risks. In the event that Sasol elects to no

longer comply with ISO standards, an alternative system must be implemented. Such an alternative may involve

updates to the EMPr and regular (annual) audits against these updates.

25%

0%

75%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17/2/2/1(I) MP-1)