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SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17/2/5 EV 7 - UPGRADE OF THE O&S RAIL LOADING
06 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17/2/5 EV 7 - UPGRADE OF THE O&S RAIL LOADING
SASOL CHEMICAL OPERATIONS:
SOLVENTS DIVISION
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
BUILDING C
KNIGHTSBRIDGE, 33 SLOANE STREET
BRYANSTON, 2191
SOUTH AFRICA
T: +27 11 361 1392
F: +27 11 361 1381
WSP.COM
Q U A L I T Y M A N A G E M E N T
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft for Review –
Compliance Audit
EA Ref: 17/2/5 EV 7
Final – Compliance
Audit
EA Ref: 17/2/5 EV 7
Date April 2019 June 2019
Prepared by Bronwyn Fisher Bronwyn Fisher
Signature -
Checked by Ashlea Strong Ashlea Strong
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 021 021
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
-
Bronwyn Fisher
Environmental Consultant
REVIEWED BY
Ashlea Strong
Principal Consultant
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf
and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding
of their compliance with the conditions included in the Environmental Authorisation.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
CLIENT
SHE Specialist: Environment Broni van der Meer
Solvents Production Senior Manager Wikus Vermeulen
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Bronwyn Fisher
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP June 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 O&S Loading Zone (SASOL CHEMICAL
OPERATIONS: SOLVENTS DIVISION)
(Authorisation Number: 17.2.5 EV 7) ..................... 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 ... 14
5.1 Environmental Exemption .................................... 14
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP June 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7
TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 14
FIGURES
FIGURE 1: THE O&S LOADING BAY (RED BLOCK) WITHIN SASOL SECUNDA PRIMARY AREA (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 15
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 15
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 16
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 16
APPENDICES
A ENVIRONMENTAL AUTHORISATION (17.2.5 EV 7)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP June 2019
Page 1
1 INTRODUCTION
1.1 TERMS OF REFERENCE
Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP
Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit
and compile an audit report according to the requirements of the National Environmental Management Act (No.
107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the
Environmental Exemption (Reference number: 17.2.5 EV 7 issued on 26 August 2003) for the period for the
period December 2014 to February 2019.
1.2 O&S LOADING ZONE (SASOL CHEMICAL
OPERATIONS: SOLVENTS DIVISION)
(AUTHORISATION NUMBER: 17.2.5 EV 7)
An Environmental Exemption (Reference number: 17.2.5 EV 7) was granted on 26 August 2003 by the
Mpumalanga Department of Agriculture, Conservation and Environment (MDACE) for the upgrading of the by-
pass track and shunting leg at the entrance to olefins and Surfactants and the re-configuration of the rail tanker
loading racks.
The Olefins and Surfactants Rail Loading Zone (Figure 1), known as the 1-hexene rail loading facility, is used
to load pentene and hexene into the RTCs and/ or ISOs destined for Richards Bay, KwaZulu- Natal. The daily
dispatch list consisting of all order numbers, RTCs / ISOs serial numbers and scheduled dispatch generated by
the SAP R/3 business system, is forwarded via the loading / dispatch offices Management System interfacing
with the metering/billing system (PLC based) located at the loading rack. Loading of 1-hexene and 1-pentene
products can only commence after it has been confirmed that the hexene and pentene products tanks (300TK-
6001 and 300TK-6002) is on full specification.
The 1-hexene and 1-pentene loading stations, have two cable pull cars and whinhes (300ME- 8103/4). The
RTC/ISO flat bed rail car brake system is released by the operator before the car puller is moved towards the rail
car (s) until it reaches them. Thereafter, the car puller is coupled to RTC/ISO container. All the empty
RTC/ISOs containers (max 9/car puller) are pulled in to the loading bay until the first three in case of hexene
and the first two for pentene to be loaded reach the dedicated loading positions respectively.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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Figure 1: The O&S Loading Bay (Red Block) within Sasol Secunda Primary Area (Source: Google Earth, 2018)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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2 AUDIT SCOPE The 7 April 2017 amendment to the Environmental Impact Assessment (EIA) regulations introduced the
requirement for the auditing for all EAs and EMPrs in effect on 8 December 2014 and submission of audit
reports to the Department of Environmental Affairs (DEA) by 7 December 2019 and every five years thereafter.
This audit is designed to meet the requirements of Regulation 34 of the EIA Regulations, 2014.
The audit period runs from December 2014 to February 2019, therefore any construction related conditions that
would have been relevant pre-December 2014 are considered not applicable (outside audit period).
The objective of the audit was to:
— Assess the level of compliance with the conditions of the Exemption;
— Identify and assess any new impacts and risks that result from undertaking the activity; and
— Make recommendations in order to achieve compliance in terms of the Exemption; and
— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically:
— “Records relating to the compliance/non-compliance with the conditions of the authorization must be
kept in good order. Such records must be made available on request by this Department.”
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the Exemption conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (14 March 2019);
— Review of documentation relevant to the conditions of the Exemption (e.g. records,
permits/certificates/maintenance logs/monitoring results/previous reports etc.); and
— Compilation of an audit report.
3.1 AUDIT CHECKLIST
WSP compiled an audit checklist to assist with the Exemption compliance audit (Section 4).
3.2 SITE INSPECTION
Bronwyn Fisher conducted the site inspection on 14 March 2019. The findings and observations of the site visit
are recorded and summarised in Section 4 with evidence included in Table 2. Key personnel interviewed
included:
— Lawrence Ratombo (Area Manager Production);
— Lazarus Moropa (Area Manager Octene); and
— Petunia Zondi (Production Asset Management Specialist, SOL Hex,Oct 1&2 & Rail Production).
It should be noted that due to the fact that the site is a National Key Point, and that an intrinsically safe camera
was not available, no photographs were able to be taken during the site walk through.
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— 17.2.5EV7_ROD_2003-09-26;
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals Operations;
— EA_EX Handover_SCO_Solvents_Hex_OC1_2_Rail;
— AEL Sasol Solvents 0017-2015-F02 (2015);
— Air Pollution license;
— Top Risk Rail FY19 – Phineas.
— Hexene Pentene operating Manual;
— Compliance_Water_Secunda Complex.dox;
— Induction Mod3_Environment;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;
— 3.05_GW_Report _Prj6143_2018-06-19;
— 3.06_RMM SW management_2016-11-24;
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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— 3.05_RESM Weekly Monitoring_2004-2019;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09
— Hexene_SAS490_2017-06-15;
— Environmental Complaints Register_2019-02-18; and
— Various email correspondence.
3.4 AUDIT COMPLIANCE ASSESSMENT
WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2). The checklist included
the conditions and associated requirements as specified in the Exemption.
Each condition was verified, either by reviewing documentation, interviewing employees and/or visually
inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with
associated target completion dates included.
It should be noted that some of the Exemption conditions were apportioned according to the elements requiring
compliance assessment therein. Although some elements of the condition may have been compliant, if one of
the elements was determined to be non-compliant, the entire condition has been reported as such (and counted
as such during percentage compliance calculation). This apportionment further allowed for the development of
focussed recommendations and timeframes.
Table 1: Compliance Level Definition and Target Completion Dates
COMPLIANCE LEVEL DEFINITION
Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or
relevant actions were implemented.
Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented
according to the requirements of the Exemption. Non-complaint conditions are given target
completion dates, as follows:
— Short term: 0 – 6 months.
— Medium term: 6 – 12 months.
— Long term: 12 – 18 months.
Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.
— Conditions marked as “Noted” are considered information points only.
— Where conditions are considered “not auditable” within the scope of this assessment this
is stated and explained within the condition commentary.
Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion
dates).
3.5 AUDIT TEAM
The auditor, Bronwyn Fisher, was hosted by Broni van der Meer, Lawrence Ratombo, Lazarus Moropa and
Petunia Zondi to whom we express our gratitude for their time and attention during our visit. A brief summary
of the external auditors’ experience is provided below.
— Auditor: Bronwyn Fisher
Bronwyn Fisher has 6 years of experience as an Environmental Consultant, undertaking Environmental
Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental
Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and
undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel
storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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recycling facilities, mixed-use developments, industrial developments and renewable energy technology
projects.
— Lead Auditor and Quality Assurance: Ashlea Strong
Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature
Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental
Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic
expertise on a diverse range of projects in the environmental management field, including environmental
scoping and impact assessment studies, environmental management plans, waste and water management, as
well as the provision of environmental management solutions and mitigation measures. She has been
involved in the management of a number of large EIAs within South Africa and has environmental auditing
and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed
in the audit process.
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a
range of sectors. Jenny’s recent experience includes completion and management of several pan-European
and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and
providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in
environmental consultancies and with a developer, giving context to understanding the practicalities of
implementing recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or
in connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.
Similarly, any recommendations, statements or conclusions drawn from or based on this report must make
reference to this report. If this report is used as part of a main report, the report in its entirety must be included
as an appendix or separate section to the main report.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1. GENERAL CONDITIONS
1.01 This exemption refers only to the project specified above and
described in the Record of Decision. Separate application/s
must be lodged for any other development and/or activity at
or near proposed development, which is covered by section
21 and 22 of the Environment Conservation Act, No. 73 of
1989 Act and Government Notice R1182 and R1183 of 5
September 1997.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
1.02 Exemption is only granted in terms of Section 28A of the
Environment Conservation Act, No. 73 of 1989 and does not
exempt the holder from compliance with any other relevant
legislation.
N/A Noted. A full legal review does not form part of the scope of this
Audit.
The site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review, which specifically
states “the development of the compliance risk management
protocol (CRMP) to assist the organization to reach a higher level
of legal compliance is commendable”.
Evidence:
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals
Operations
None.
1.03 No development may take place on the area of concern
without the necessary permits/approvals and/or service
and/or lease agreements, where it is relevant, from or
between the following institutions:
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.3.1 Govan Mbeki Municipality
1.3.2 DWAF
1.3.3 Spoornet
1.04 This Department may change, add or amend any of the
conditions in this authorization if, in the opinion of the
Department, it is environmentally justified.
N/A Noted. Sasol advised the auditor that, to their knowledge, the
Department has not added or amended any of the conditions within
this authorisation.
None.
1.05 A copy of this authorization shall be available at the
applicant office at all times and all staff, contractors and sub-
contractors shall be acquainted with the contents of this
exemption.
C Copies of all authorizations and licenses are sent to, and details
communicated with, relevant business units. Copies of these
documents are also available at the SHE: Environment department
and on SAP EC and SharePoint. Sasol provided the auditor with
the evidence that the responsible persons, Wikus Vermeulen
(Senior Manager of Hexene, Octene 1 & 2 and Railing Production)
and Willem Jacobs (legal appointee of Solvents), were made aware
of the Exemption in September / October 2016.
Evidence:
— EA_EX Handover_SCO_Solvents_Hex_OC1_2_Rail.
None.
2. ESTABLISHMENT
2.01 This exemption is repealed if the development has not taken
place within 2 years from the date of this exemption. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2.02 In case of closure of the site, this Department shall evaluate,
monitor and approve the clearing and rehabilitation of the
site.
N/A Noted. Sasol advised that there are no plans to make this site
redundant in the foreseeable future.
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3. CONSTRUCTION AND OPERATION
3.01 An Environmental Management Plan must be compiled and
submitted for approval. NC Sasol have advised the auditor that no EMPr has been developed
for the rail loading facility.
Sasol should develop an
EMPr for the operating of
the rail loading zone.
Target Completion
Medium term
3.02 Material for constructing the railway foundations must be
obtained from a commercial source. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.03 Where vegetation cover has been removed, control measures
must be used to prevent soil pollution. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.04 If any changes need to be made to the development or
associated infrastructure, this Department must be informed
thirty (30) days in advance to decide whether the change will
need authorization.
N/A Noted. Sasol advised the auditor that no changes have been made
to the development or associated infrastructure.
None.
4. AIR POLLUTION
4.01 Air pollution should be handled as indicated by relevant
authorities.
C Sasol have a registered certificate (APPA) for the Alpha Olefins
Plant (certificate number: 1308/5) issued on 11th March 2002. This
was then converted to an Atmospheric Emissions Licence (AEL),
with the promulgation of the National Environmental
Management: Air Quality Act (Act No. 39 of 20014) which
required the conversion from APPA to an AEL.
The Gert Sibande District Municipality issued an Atmospheric
Emissions Licence for the Sasol Solvents Operations (Reference:
11/19/1 Govern Mbeki Sasol South Africa (Pty) Ltd
0017/2015/F02) in March 2015. The AEL covers all Solvent
Operations at the Sasol Secunda Complex.
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— AEL Sasol Solvents 0017-2015-F02 (2015);
— Air Pollution license.
5. WATER POLLUTION
5.01 Any water pollution of surface as well as ground water
should be prevented at all cost.
C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which aims to identify the activities related to Sasol’s
operations within the context of the receiving environment (with a
focus on water resource protection), identify the risks associated
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management.
The auditor noted the following precautions that have been put in
place to prevent surface and ground water pollution:
— The entire loading zone is bunded and hardsurfaced;
— Each tanker loading bay is provided with a drain to the oily
water sewer via a slop pit kept under water level. The slop pit
is situated 40 m west of the slap south of the rail lines;
— Surface and groundwater monitoring is carried out in
accordance with the IWWMP.
Surface water monitoring is conducted on a weekly basis as well as
real Surface water monitoring is conducted on a weekly basis as
well as real time for the various Receiving Environmental Surface
water Monitorings (RESMs).
Ground water monitoring is conducted biannually and quarterly for
the various Receiving Environmental Groundwater Monitorings
(REGMs).
The November 2017 Water Quality Monitoring Report compiled
JMA Consulting, dated November 2017, was provided to the
auditor to review. The report confirmed the number of sampling
points and the frequency in which they are sampled. In addition, all
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
staff, contractors and visitors are provided with induction training,
which includes pollution of the environment.
Evidence:
— Hexene Pentene operating Manual;
— 3.05_GW_Report _Prj6143_2018-06-19;
— 3.06_RMM SW management_2016-11-24;
— 3.05_RESM Weekly Monitoring_2004-2019
— Compliance_Water_Secunda Complex.dox;
— Induction Mod3_Environment;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
6. WASTE
6.01 All waste generated shall be stored, handled and disposed off
in a licensed landfill site. C The auditor was advised that waste management is completed via
implementation of a Waste Management procedure (SGR-SHE-
000017 REV10) that addresses the approach to manage waste in
line with the internationally accepted waste hierarchy, whereby
disposal to land is considered the last management option to
undertake once avoidance, re-use, recycling, recovery and
treatment options have been considered / eliminated. The
procedure further details waste disposal and management through
characterization and classification that is detailed in site specific
waste registers.
Waste Registers were made available to the auditor. A sample of
the registers specifically related to the Solvent operations were
checked during the audit. It is however noted that little to no waste
is produced at the loading zone.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Hexene_SAS490_2017-06-15.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
7. RISK MANAGEMENT
7.01 Risk associated with transportation of products/by-products
must be identified, quantified and mitigation measures put in
place.
C The auditor was presented with part of a document which
evidenced that Sasol had acknowledged a ‘key undesirable event
during product transportation, storage or handling’ as a top risk.
The document for FY19 presents causes, consequences,
mitigations (preventative and corrective) and a risk assessment
taking into account probability and impact.
Evidence:
— Top Risk Rail FY19 – Phineas.
None.
8. MONITORING
8.01 Monitoring should be done as indicated by relevant
authorities.
C Due to the nature of the facility (rail loading), there is no
Atmospheric Emissions Monitoring required at the loading zone.
Surface water monitoring is done on a weekly basis as well as real
time for the various Receiving Environmental Surface water
Monitorings (RESMs)
Groundwater monitoring is conducted biannually and quarterly.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.
None.
8.02 This Department will monitor compliance with this
authorization. N/A Noted. Sasol advised the auditor that the Department routinely
attends site to inspect the rail loading facility.
None.
9. REPORTING
9.01 Records relating to the compliance/non-compliance with the
conditions of the authorization must be kept in good order. N/A This audit represents the first required audit for this Exemption.
Prior to the introduction of the 7 April 2017 amendment to the
None.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Such records must be made available on request by this
Department.
Environmental Impact Assessment (EIA) regulations, no audit
against this Exemption was required.
9.02 Non-compliance with, or any deviations from the conditions
as set out in the Record of Decision is regarded as an
offence and, after reasonable provision has been made for
remedial action, will be dealt with in terms of section 29, 30
and 31A of the Act.
N/A Noted. Sasol have advised the auditor that they are aware of this
condition.
None.
9.03 Any complaint regarding the said development must be
brought to the attention of this office within 24 hours after
receiving the complaint.
C The auditor has reviewed the complaints register maintained by
Sasol. No complaints have been received in relation to the
operating of the loading zone for the audit period.
Evidence:
— Environmental Complaints Register_2019-02-18
None.
9.04 A complaint register must be kept up to date for inspection
by members of this Department. C The auditor has reviewed the complaints register maintained by
Sasol. No complaints have been received in relation to the
operating of the loading zone for the audit period.
Evidence:
— Environmental Complaints Register_2019-02-18
None.
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL EXEMPTION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the Exemption conditions are as listed in Table
3 below.
Table 3: Summary of Exemption Compliance Audit Findings
SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 5 1 0 4
ESTABLISHMENT 2 0 0 2
CONSTRUCTION AND OPERATION 4 0 1 3
AIR POLLUTION 1 1 0 0
WATER POLLUTION 1 1 0 0
WASTE POLLUTION 1 1 0 0
RISK MANAGEMENT 1 1 0 0
MONITORING 2 1 0 1
REPORTING 4 2 0 2
Total Count 21 8 1 12
Total Percentage 38% 5% 57%
Percentage Compliance with Applicable Conditions 89%
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP June 2019
Page 15
Figure 2 illustrates the number/count contribution of the findings of the Exemption per section while Figure 3
presents the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the Exemption conditions per Section
Figure 3: Overall count findings on compliance to the Exemption conditions
0
1
2
3
4
5
6
Sectional Count Contribution
C
NC
N/A
8
1
12
Total Compliance
C
NC
N/A
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
WSP June 2019
Page 16
Figure 4 illustrates the percentage contribution of the findings of the Exemption conditions. Figure 5 presents
the total percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the Exemption conditions per Section
Figure 5: Overall percentage findings on compliance to the Exemption conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
38%
5%
57%
Total Percentage Compliance
C
NC
N/A
APPENDIX
A ENVIRONMENTAL AUTHORISATION
(17.2.5 EV 7)