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SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS
INTEGRATION
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17.2.3 EV 1 - TAIL GAS TRANSFER LINE FROM SYNTHOL WEST
03 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17.2.3 EV 1 - TAIL GAS TRANSFER LINE FROM SYNTHOL WEST
SECUNDA SYNFUELS OPERATIONS:
MARKET & PROCESS INTEGRATION
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: 17.2.3 EV 1
Final – Compliance
Audit
EA Ref: 17.2.3 EV 1
Date April 2019 June 2019
Prepared by Mpendulo Dlamini Mpendulo Dlamini
Signature
Checked by Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 025 025
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
Mpendulo Dlamini
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 Exemption 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
Market and Process Integration
Production Senior Manager
Deon van Zyl
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Mpendulo Dlamini
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
WSP June 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Tail Gas Transfer Line From Synthol West
(Exemption Number: 17.2.3 EV 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 ... 14
5.1 Environmental Exemption .................................... 14
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
WSP June 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7
TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 14
FIGURES
FIGURE 1: THE TAIL GAS TRANSFER PROJECT 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 EXEMPTION (17.2.3 EV 1)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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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: 17.2.3 EV 1 issued on 02 August 2002, as amended) for the period
December 2014 to February 2019.
1.2 TAIL GAS TRANSFER LINE FROM SYNTHOL WEST
(EXEMPTION NUMBER: 17.2.3 EV 1)
An environmental exemption was granted on 02 August 2002 by the Mpumalanga Department of Environmental
Affairs and Tourism, for the construction and operation of a Tail Gas Transfer Line (TGTL). The TGTL runs from
the Synthol West to the Synthol East plant.
Figure 1 provides the location of the pipeline rack where the tail gas transfer pipeline is situated within Sasol
Secunda Primary area.
The TGTL connects the two Synthol plants in the East and West Complexes respectively. Tail gas, which is 80%
to 98% methane, refers to the gas that was not transformed to a product, which remains in the system and goes
through a separation process at the Reforming Plant. At the Reforming Plant, the tail gas is converted to carbon
monoxide and nitrogen through a splitting process, and these are used to make petrol and other Sasol products.
Prior to the implementation of this project, tail gas formerly remained at each complex, and at the end of the
process, it would be flared into the atmosphere. Furthermore, if there was maintenance occurring at either
complex, efficiency was significantly reduced as only one complex would remain active.
Following implementation of the project, flaring of the tail gas decreased as it could then be transferred between
the two complexes, to increase efficiency and the capacity to extract carbon monoxide and nitrogen (hence
generate additional products). Lastly, the project also assists to augment efficiency if one complex undergoes
maintenance.
An amendment to the exemption was granted on 12 March 2003, which removed a former condition associated
with provisioning (formerly condition 3.2). This audit has been carried out against the amended Exemption, and
hence does not include the removed condition.
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Figure 1: The tail gas transfer project area (Source: Google Earth, 2018)
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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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;
— 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 or non-compliance with the conditions of this Exemption must be
kept in good order. Such records must be made available to this Department within seven (7) working
days from the date of 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 Exemption conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (29 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
Mpendulo Dlamini conducted the site inspection on 29 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:
— Peet van Zyl - Area Manager Production
— Neeren Naidu - Production Foreman MPI
— Richard Van Den Berg - Production Foreman MPI
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— SSO DQS ISO 14001 2015;
— EA_EX Handover_SSO_MPI;
— EA_EX Handover_SSO_MPI_Amend SM;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels Operations;
— Compliance_Water_Secunda Complex.dox;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;
— Risk Assessment: SGI-SHE-000014;
— 8.02_Plant inspections U050;
— 8.02_Plant inspections U250;
— 8.02_Plant inspections U350;
— Environmental Complaints Register (Period: December 2014 – March 2019); and
— Various email correspondence
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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 Consultant, Mpendulo Dlamini, was hosted by Broni van der Meer and Peet van Zyl 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: Mpendulo Dlamini
Mpendulo has 5 years’ experience and is a multi-disciplined individual who completed his double major BSc
Environmental Science degree (Life Science and Environmental Science) at the University of KwaZulu-Natal
in 2014. He then further completed his BSc Honours Environmental Science (Spatial Epidemiology Research)
in 2015 at the same institution. Mpendulo has had exposure in the following sectors; oil and gas,
environmental consulting as well as environmental and public health. As a University Student, he has had
extensive training in biodiversity management and monitoring with a focus in plant science (undergraduate),
and with Lakes Environment air quality and modelling software as well as environmental GIS and remote
sensing in spatial modelling (Post graduate). He also has experience as an Environmental Control Officer as
well as with working on Water Use License Applications and Integrated Water and Waste Management Plans
(Triplo4 Sustainable Solutions).
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— 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 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1. GENERAL CONDITIONS
1.01 This exemption refers only to the project specified above and
described in the Record of Decision. Other than the Tail gas
transfer line from Synthol East to Synthol West, separate
applications must be lodged for any other development and/or
activity at or near proposed development, which is covered by
Sections 21 and 22 of the Act and Government Notice R670
and R672 of 10 May 2002.
N/A Noted. The project remains as per the authorised activities for which
the Exemption was granted. No additions or alterations have taken
place on or near the project’s location.
Sasol is aware of the requirement to lodge separate applications
should further works be required for the authorised activity.
None.
1.02 Exemption is only granted in terms of Section 28A of the
Environment Conservation Act, 1989 (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 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 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 EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.03 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
No changes or amendments have been communicated to Sasol by
the Department since issue of the Exemption.
None.
1.04 A copy of this authorization shall be available at Area Leader
Environment, Sasol Secunda, at all times and all staff,
contractors, contractors and sub-contractors shall be
acquainted with the contents of this exemption.
C Sasol’s environmental team have soft copies of the Exemption 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
persons, Ronel Kotze (Senior Manager of Production Gas VC) and
Ettienne Rademeyer (legal appointee of MPI) were made aware of
the Exemption on September 2016. Deon van Zyl (Senior Manager
of Production Gas VC) and Ettienne Rademeyer (legal appointee of
MPI) were made aware of the Exemption amendment in November
2017.
Evidence:
— EA_EX Handover_SSO_MPI
— EA_EX Handover_SSO_MPI_Amend SM
None.
1.05 The content of this exemption must be made known to all
interested and affected parties within 14 days from the date of
this exemption.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2. ESTABLISHMENT OF THE ENTERPRISE
2.01 This exemption is repealed if the tail gas transfer line and
associated infrastructure has not taken place within two (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.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.02 If the decision is taken to close down the facility, sell and/or
transfer ownership of the infrastructure, this Department must
be informed of such decision at least 12 months prior the date
of closure or transfer of ownership.
N/A Noted. Sasol have advised that there are no current plans to close or
decommission the facility.
None.
2.03 In case of closure of the site, this Department shall evaluate,
monitor and approve the clearing and rehabilitation of the site. N/A The statement is noted by Sasol. None.
3. CONSTRUCTION AND OPERATION
3.01 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 have advised that no changes have been made since the
Exemption date. Furthermore, there are no plans to make changes to
the existing development.
None.
3.02 Upon completion of the associated infrastructures, all excess
construction material should be disposed of in a registered
landfill site.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
4. AIR POLLUTION
4.01 Any emissions must be permitted by relevant authority. N/A According to the Area Manager, there are no emissions from the
pipeline as it is a fully closed system.
None.
5. WATER POLLUTION
5.01 It is the responsibility of the applicant and the relevant
contractor on site to prevent any pollution of surface as well
as groundwater.
C According to the Area Manager, there is no possibility of any
surface or groundwater pollution during operation as no liquids
emanate from the pipeline.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
The consultant was notified that during maintenance, liquid traps
that remove condensate which are installed on the pipeline are
unscrewed and drip trays are used to collect small amounts of liquids
that come out. The liquid collected is then disposed of into the oily
water sewer.
Water that used to wash/scrub the pipeline during maintenance is
sent to the Synthol Plants in the East and West complexes where it
is released to the oily water sewer.
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.
Surface water monitoring is done on a weekly basis as well as real
time for the various Receiving Environmental Surface water
Monitoring points (RESMs)
Ground water monitoring is conducted biannually and quarterly.
The is no groundwater monitoring specific to the tail gas transfer
line area, however there are 6 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 tail gas
transfer line area.
In addition, all staff, contractors and visitors are provided with
induction training, which includes pollution of the environment.
Evidence:
— Compliance_Water_Secunda Complex.dox
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
5.02 In case of non-compliance with Section 19 of the National
Water Act, 1998 (Act 36 of 1998), the applicant will be
responsible to remedy the effects of pollution.
N/A The statement is noted by Sasol. None.
6. WASTE
6.01 All waste generated during the construction and/or operation
of the tail gas transfer line shall be stored, handled and
disposed of in an environmentally acceptable way.
C No solid waste is generated from the operation of the pipeline.
Liquid waste generated scheduled maintenance activities is
collected in drip trays or sent to the Synthol Plants for it to be
disposed of in the oily water sewer.
None.
7. RISK ASSESSMENT
7.01 Risk study, safety measures and emergency plans must be in
place at each Synthol plant. C According to the Production Foremen, Risk Based Inspection are
undertaken on a weekly basis. The reports are uploaded onto the
IMS system every Friday for the midweek inspection and on
Mondays for the weekend inspections. 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.
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 Synthol
plants. Refresher trainings are held every three years from the initial
induction for each personnel.
Evidence:
— Risk Assessment: SGI-SHE-000014
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— 8.02_Plant inspections U050
— 8.02_Plant inspections U250
— 8.02_Plant inspections U350
7.02 Fire extinguishing equipment should be available at the site
at all times. C The pipeline passes a lot of plant units along Sasol’s internal road
network along with other pipelines. The pipeline therefore depends
on fire-fighting equipment of the plant units that it passes. The
auditor observed the fire-fighting equipment along the route within
the units. Pictures could not be taken as prior permission to enter
the units was not obtained.
According to the Area Manager, the pipeline is mainly dependant
on the Unit 350 fire-fighting equipment as well as fire monitors, fire-
fighting powder as well as hydrants in between the units.
None.
8. MONITORING
8.01 Monitoring should be done as indicated by the relevant
authorities. N/A According to the Environmental Specialist, besides the Exemption
Authorisation, there were no further recommendations received
from the Department.
None.
8.02 Weekly monitoring and inspection of leaks along the
pipeline route must be carried out. C According to the Production Foremen, Risk Based Inspection are
undertaken on a weekly basis. The reports are uploaded onto the
IMS system every Friday for the midweek inspection and on
Mondays for the weekend inspections.
Evidence:
— 8.02_Plant inspections U050
— 8.02_Plant inspections U250
— 8.02_Plant inspections U350
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
9. REPORTING
9.01 Records relating to the compliance/non-compliance with the
conditions of the exemption must be kept in good order. Such
records must be made available on to this Department within
seven (7) working days of the written request by the
Department for such records.
N/A This audit represents the first required audit for this Exemption.
Prior to the introduction of the 7 April 2017 amendment to the
Environmental Impact Assessment (EIA) regulations, no audit
against this Exemption was required.
None.
9.02 Non-compliance with, or any deviations from the conditions
as set out in the Record of Decision is regarded as an offence
and, after reasonable provision has been made for remedial
action, will be dealt with in terms of Section 29, 30 and 31A
of the Act.
N/A Noted. 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 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.
9.04 A complaint register must be kept up to date for inspection by
members of this Department. C A complaint register is kept up to date for the entire Sasol Secunda
Operations. Available records go as far back as 2008.
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019)
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 3 0 0 3
CONSTRUCTION AND OPERATION 2 0 0 2
AIR POLLUTION 1 0 0 1
WATER POLLUTION 2 1 0 1
WASTE 1 1 0 0
RISK ASSESSMENT 2 2 0 0
MONITORING 2 1 0 1
REPORTING 4 2 0 2
Total Count 22 8 0 14
Total Percentage 100% 36% 0% 64%
Percentage Compliance with Applicable Conditions 100%
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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
Exemption
Sectional Count Contribution
C
NC
N/A
8
0
14
Total Compliance
C
NC
N/A
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION
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
36%
0%
64%
Total Percentage Compliance
C NC
N/A
APPENDIX
A ENVIRONMENTAL EXEMPTION (17.2.3
EV 1)