SECUNDA SYNFUELS OPERATIONS: TAR, PHENOSOLVAN & … · 6/21/2019 · ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA

SECUNDA SYNFUELS OPERATIONS: TAR, PHENOSOLVAN & SULPHUR

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT 17/2/1/25 MP-16 - RTO TAR VALUE CHAIN VOLATILE ORGANIC COMPOUND PROJECTS

21 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT 17/2/1/25 MP-16 - RTO TAR VALUE CHAIN VOLATILE ORGANIC COMPOUND PROJECTS

SECUNDA SYNFUELS OPERATIONS: TAR,

PHENOSOLVAN & SULPHUR

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: 17/2/1/25

MP-16

Final – Compliance

Audit

EA Ref: 17/2/1/25

MP-16

Date May 2019 June 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 009 009

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

Ashlea Strong

Principal Consultant

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

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

of their compliance with the conditions included in the Environmental Authorisation and associated

Environmental Management Plan.

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

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

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

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

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

P R O D U C T I O N T E A M

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Tar, Phenosolvan & Sulphur Production

Senior Manager

July Mavuso

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: TAR, PHENOSOLVAN & SULPHUR

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Tar Value Chain Volatile Organic Compound

Project (Authorisation Number: 17/2/1/25 MP-16) 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 .............................. 7

3.5 Audit Team ............................................................... 7

3.6 Assumptions and Limitations ................................ 8

4 AUDIT FINDINGS ...................................... 9

5 SUMMARY OF THE AUDIT FINDINGS ... 59

5.1 Environmental Authorisation ............................... 59

5.2 Environmental Management Plan ........................ 62


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 7

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 9

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 21

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 59

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 62

FIGURES

FIGURE 1: SSO _ RECOVERY THERMAL OXIDERS (SOURCE: GOOGLE EARTH, 2018) ............................... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 60

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 60

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 61

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 61

FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 63

FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 63

FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 64

FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 64


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APPENDICES

A ENVIRONMENTAL AUTHORISATION (17.2.1.25 MP-

16)


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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: 17/2/1/25 MP-16 issued on 12 March 2009) as well as

the associated Environmental Management Plan (dated: January 2009) for the period December 2014 to

February 2019.

1.2 TAR VALUE CHAIN VOLATILE ORGANIC COMPOUND

PROJECT (AUTHORISATION NUMBER: 17/2/1/25 MP-

16)

Sasol received an EA for the above-mentioned project from the Mpumalanga Department of Agriculture and

Land Administration, Directorate: Environmental Impact Management. The EA permitted the construction and

operation of seven (7) Recovery Thermal Oxidisers (RTOs), referred to in the EA as “Tar Value Chain Volatile

Organic Compound (VOC) Abatement”. The RTOs were authorised to be constructed at Units 213, 13, 96/296,

11/214, and 86.

Six RTOs were constructed to completion; the last (seventh) RTO was being completed at the time of the audit.

At the time of the audit, they were not operational as an explosion incident occurred at one of them (winter

2018) and therefore they were all shutdown pending the completion of an investigation into the cause and once

the safety of their operation can be confirmed.

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

The EA was issued on 12 March 2009, and it has been confirmed that the construction phase was not completed

prior to December 2014, therefore construction phase related conditions are relevant and have been audited.


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Figure 1: SSO _ Recovery Thermal Oxiders (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. Construction of the seventh RTO is ongoing,

therefore all construction related conditions are considered applicable (within 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 (12 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 12 March 2019. The findings and observations of the site visit

are recorded and summarised in Section 4 with evidence included in Table 2 and Table 3. Key personnel

interviewed included:

— Marlene van Der Linde (Group Technology – Environmental Specialist);

— Piet Kleynhans (Production Area Manager); and,

— Colin Jaynarain (Production Area Manager).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Environmental Authorisation: 01. TVC VOC - Environmental Authorisation 12 03 09;

— EMPr: 02. TVC VOC - EMP VOC - draft (Final for Authority Review);

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

— Sasol SAWIS upload-2018_Jul-Sep;

— Waste register: Refining_2016-12-04;

— Induction_Mod1-8;

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— M&R EA 3.9 SHE plan;

— M&R EA 3.9 Transmittal Note of SHE file Approval;

— M&R EA 3.10 Waste Management Plan;

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


— M&R EA 3.14 Photo of waste bins;

— M&R EA 3.14 Waste disposal slips;

— M&R EA 3.15.4 Photo of Hazardous storage;


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— M&R EA 3.15.6 Waste slips;

— M&R EA 3.16 Photo of Oil drums;

— M&R EA 3.17 Photo of drains;


— M&R EA 3.19 F&E plot plan;

— M&R EA 3.19 Fire checklist;

— M&R EA 3.19 Photo of fire extinguisher;

— M&R EA 3.20 Complaints register;

— M&R EA 3.20 APPA registration;

— AEL Sasol Synfuels 0016-2018-F03 (2018);

— EA 3.21 APPA AEL RE VOCA - Environmental Compliance Postponement Memo;

— M&R EA 3.1 Authorisation Letter;

— SSO_TPS_Amendment_RTO VOC Project_1.3.1.16.4 G-36_2017-04-28;

— M&R EMP 4.3.1 Plant Emergency response plan;

— M&R EMP 4.3.1 Plant Emergency response plan2;

— Labour_Sasol SA_PreferentialRecruitPractices_2018-03-15;

— Labour_Sasol IRM Suppliers Industrial Relations Procedure;

— TMS EMP 4.4.1,4.7.11,4.7.13 Personal protective equipment (PPE);

— WP EA3.13,3.14,3.15,3.17,3.19 EMP4.3.1,4.4.1,4.5.1,4.6,4.7 Photos;

— WP EMP 5.3.1 Process description;

— M&R EMP 5.2 Pressure testing procedure;

— M&R EMP 4.7.15 Smoking policy;

— M&R EMP 4.7.15 Photo of smoking area;

— M&R EMP 4.7.13 Mechanic works order;

— M&R EMP 4.7.13 Mechanic works order;

— M&R EMP 4.7.13 Photo of maintenance indicator panel on generator;

— M&R EMP 4.4 Report on occupational hygiene survey;

— M&R EMP 4.4 Photos of PPE signs;

— M&R EMP 4.6.10 Refer to Spill prevention and response plan;

— M&R EMP 4.7.9 Refueling of vehicles using diesel bowser;

— M&R EMP 4.7.9 Photo of diesel bowser and drip tray;



— M&R EMP 4.7.10 Borrow pit license;


— M&R EMP 4.7.9 Photo of diesel bowser and drip tray;

— M&R EMP 4.7.1 Dust suppression;

— M&R EMP 4.6.5 WMP with waste inventory;

— M&R EMP 4.7.3 Sasol waste management procedure;

— M&R EMP 4.7.3 Waste disposal slips;

— M&R EMP 4.6.10 Refer to Spill prevention and response plan;

— M&R EMP 4.6.11 Refer to SHE plan for waste disposal requirement;

— M&R EMP 4.6.11 Photo of waste bin for used rods;


— M&R EMP 4.6.9 Photo of sandblasting grit;



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— M&R EMP 4.6.9 Waste disposal slip;

— M&R EMP 4.6.9 Photo of sandblasting grit;

— M&R EMP 4.6.8 Photo of sanitary facilities;

— M&R EMP 4.6.3 Photo of insulation waste bin;

— M&R EMP 4.6.1 Photos of waste separation;

— M&R EMP 4.6.2 Photo of general waste bin;


— Copy of Environment Impact register_ New FY17; and,

— Environment Impact register_ New FY19_2019-02-18.

— M&R EMP 4.5.1 F&E Plot plan;



— M&R EMP 4.3.1 Emergency coordinator;

— M&R EMP 4.3.1 Emergency response plan;


— M&R EMP 4.3.1 Plant Emergency response plan2;

— M&R EMP 4.3.1 Training attendance;


— M&R EMP 4.2.1 Training matrix;

— M&R EMP 4.2.1 Training cost allocation;

— M&R EMP 4.1.1 Induction;

— M&R EMP 4.3.1 Training attendance;

— M&R EMP 4.1.1 Induction;

— M&R EMP 4.1.1 Appointment as principle contractor;

— IMS_Occupational Safety_2019-01-09;

— IMS_Occupational health and hygiene_2019-01-09;

— IMS_Process Safety_2019-01-09;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod7_Occupational;

— EA_EX Handover_SSO_TPS-CT-GLS-CTF;

— M&R EMP 4.1.1 BAR EMP; 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 and Table 3). The

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

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, Marlene van der Linde, Piet Kleynhans, and

Colin Jaynarain; 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: 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.


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— 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.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

SCOPE OF AUTHORISATION

3.01 Authorisation of the activity is subject to the conditions

contained in this authorisation that are part of the

environmental authorisation and are legally binding on the

holder of the authorisation.

N/A Statement noted by Sasol. None.

3.02 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

carried out 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.

3.03 The activity which is authorised may only be carried out at

the property indicated above. C It was confirmed that the activity is carried out at the property

indicated above.

None.

3.04 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 authorization 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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3.05 This activity 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.

C Construction commenced within two years from the date of issue

and was ongoing through the audit period.

Evidence:

— M&R EA 3.5 Notification of construction

None.

3.06 This authorisation does not negate the holder of the

authorisation’s responsibility to comply with any other

statutory requirements that may be applicable to the

undertaking of the activity.

N/A Noted.

The Sasol Complex operates with a dedicated environmental and

legal teams, 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.

Evidence:

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

APPEAL OF AUTHORISATION

3.07 The holder of the authorisation must notify every registered

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

calendar days, of receiving of the Department’s decision to

authorise the activity.

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

Department’s decision to authorise the activity was made in 2009).

It is therefore considered not applicable.

None.

3.08 The notification referred to in 3.7 must:

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

b) Inform the interested and affected parties of the appeal

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

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

the authorisation and reasons for the decision will be

furnished on request.

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

therefore considered not applicable.

None.


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MANAGEMENT AND MONITORING OF THE ACTIVITY

3.09 The EMP incorporated in the Basic Assessment Report must

be implemented and be strictly adhered to throughout the life

cycle of this activity.

C The EMPr was included within the Safety, Health and

Environmental (SHE) file compiled for the project specifically.

Sasol’s Environmental Specialist is responsible for overseeing

implementation, conducting inspections and reporting any issues.

No non-compliances against the EMPr were noted during this

audit.

Evidence:

— M&R EA 3.9 SHE plan; and,

— M&R EA 3.9 Transmittal Note of SHE file Approval.

None.

3.10 The waste from the units must be managed according to

Sasol’s Waste Management Plan, as stated in the Basic

Assessment Report.

C During construction, the Waste Management Plan was

implemented by the principal contractor (Murray & Roberts) and

is included in their HSE file.

At the time of the audit, the RTO facilities were not operational.

During the previous operational phase applicable to the audit

period, waste was managed in accordance with Sasol’s Waste

Management Plan.

Evidence:

— M&R EA 3.10 Waste Management Plan.

None.

3.11 The Department retains the right to monitor and or inspect

the proposed project during construction and operational

phases.

N/A According to the Environmental Specialist, the Department have

undertaken site inspections, however, none were specific to this

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

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

therefore considered not applicable.

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 All units must be paved and provided with drains to collect

storm water drainage from buildings, open and clean plant

areas. Effluent must be routed to an enclosed sump and be

piped to the correct sewage disposal system.

C All the RTOs are constructed in a similar fashion. The completed

RTO observed by the auditor during the site inspection was noted

to be within a bunded and properly managed clean and dirty

stormwater system. No signs of significant pollution were evident.

The process description details that non-process drains include

effluent from plant washing, rain water, hydrostatic pressure

testing water, low point drains and draining of the process for

maintenance purposes. Effluent generated by the above mentioned

methods in the knock-out drum and extraction fan section is

drained to the existing drainage system. Any effluent generated is

tested to confirm if it can be directed to the storm water sewer. In

the event that it is determined to be contaminated, it is disposed of

with a vacuum truck.

Evidence:


— M&R EA 3.13 Photo of drain:

None.

3.14 General waste that is generated must be disposed of at a

permitted facility. C Construction phase waste was managed by the principal

contractor; and evidence of waste receptacles and waste disposal

slips were provided to the auditor.

None.


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The RTOs are within sites that operate in accordance to Sasol’s

Waste Management Procedure.

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;


— M&R EA 3.14 Photo of waste bins; and,

— M&R EA 3.14 Waste disposal slips.

3.15 Handling of hazardous waste must strictly adhere to the following conditions:

3.15.1 Hazardous waste must be segregated and stored in

appropriate containers, and be disposed of at a permitted

waste site by a registered company/contractor.

C Limited amounts of hazardous waste was generated during the

construction phase only. The principal contractor had a waste

management plan specific to the project; provision was made for

proper hazardous waste handling, and Sasol’s Environmental

Specialist undertook regular inspections to confirm

implementation.

Proof of disposal of contaminated PPE and inorganic waste, by

Enviroserv at the Holfontein disposal site, was provided to the

auditor.


The RTOs are within sites that operate in accordance to Sasol’s

Waste Management Procedure.

None.


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Evidence:

— M&R EA 3.10 Waste Management Plan.

— M&R EA 3.15.2 Waste disposal slips;

— M&R EA 3.15.2 Registered waste company

3.15.2 Hazardous waste must be disposed at a licensed site

(Holfontein H:H disposal site) by a registered waste

management company.

C Proof of disposal of contaminated PPE and construction-phase

inorganic waste, by Enviroserv at the Holfontein disposal site, was

provided to the auditor.

Furthermore, evidence of the registration of the waste management

companies was provided.

Evidence:

— M&R EA 3.15.2 Waste disposal slips;

— M&R EA 3.15.2 Registered waste company.

None.

3.15.3 The hazardous waste must be tested and subjected to risk

assessment prior to treatment or disposal. C The registered waste contractor (Enviroserv) co-disposed of the

waste.

As the waste only comprised contaminated PPE and inorganic

waste, a risk assessment and further treatment were not required.

Evidence:


— M&R EA 3.15.3 Waste disposal slips.

None.

3.15.4 Waste chemicals, solvents and paints must be collected into

approved containers for storage or disposal. C Proof of appropriate storage of paints, solvents and chemicals,

within a lockable hazardous goods storage cage, was provided to

the auditor. No waste chemicals, solvents, or paints were discarded

during the construction phase.

No operational-phase waste is currently disposed of as the RTOs

are not operational.

Evidence:


None.


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— M&R EA 3.15.4 Photo of Hazardous storage.

3.15.5 Records of mass of hazardous waste produced and disposed

must be kept, as well as disposal certificate. C The registered waste contractor (Enviroserv) co-disposed off the

waste. Waste disposal slips were available and prove delivery and

disposal of the hazardous waste at the Holfontein disposal site.



Evidence:


None.

3.15.6 Records of all safe disposal certificates from a class H:H

disposal site must be kept by the applicant. C The registered waste contractor (Enviroserv) co-disposed off the





Evidence:


None.

3.15.7 All waste disposal records must be inspected to ensure good

waste disposal practices are followed.

C Sasol’s Environmental Specialist confirmed that she conducted

regular checks of disposal records during construction-phase and

the period of operation, and maintained copies of all hazardous

waste disposal records for the project.

Evidence:

— M&R EA 3.15.6 Waste slips.

None.

3.16 Used oils must be collected into drums that will be stored at

the site in a bunded area. C Three 220 litre drums of waste oils were generated during

construction and stored in closed drums in a bunded area – proof

was provided by means of a photograph taken by the

Environmental Specialist.

No used oils are currently generated.

None.


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Evidence:

— M&R EA 3.16 Photo of Oil drums;

— M&R EA 3.16 Email for procedure to remove 3x220L drums

of oil.

3.17 The plant must be operated in accordance with the relevant

provisions of Occupation Health and Safety Act (Act No. 85

of 1993).

C A comprehensive SHE Plan was compiled by Murray and Roberts

(M&R) for the construction phase of the project and provided to

the auditor for review. The Plan details and references various

legal obligations and compliance documents, and is noted to be

comprehensive.

The plant is operated in compliance with the overall Sasol Safety

and Occupational Health and Hygiene Systems. Sasol makes use

of a web based Information Management System (IMS) that

includes a comprehensive Document Management System (Easy

DMS) where all supporting documentation is available to prove

compliance with legal requirements related to process safety and

Occupational Health & Hygiene. Both IMS & Easy DMS is

structured per business unit.

Process Safety and Occupational Health & Hygiene related

information is stored on IMS.

Evidence:

— M&R EA 3.18 SHE plan.

— IMS_Occupational Safety_2019-01-09

— IMS_Occupational health and hygiene_2019-01-09

— IMS_Process Safety_2019-01-09

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod7_Occupational

None.

3.18 Before commissioning of the plants, a Risk Assessment must

be carried out to highlight all risk areas associated with the

Plant and its associated infrastructure. The outcome of the

Risk Assessment must ensure that envisaged operational

C The following operational phase Risk Assessments were provided

to the auditor that are applicable to the audit period:

— Water stand / Pressure test (dated 22 September 2015); and,

None


WSP June 2019

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failures are adequately addressed and that the site will not

represent any undue risk to the environment, employees and

the public.

— Refuelling vehicles using diesel bower (dated 15 October

2015);

Furthermore, evidence of a VOC HSE Risk Tracker (dated 2017)

was provided to the auditor.

Evidence:

— M&R EMP 5.2 Risk assessment;

— M&R EMP 4.7.9 Risk assessment; and

— M&R EMP 4.6.7 Risk tracker.

3.19 Suitable fire protection systems must be accessible on site.

Fire detection and fire fighting systems must be accessible to

the workers on site.

C The site falls within the fire management planning for the complex

as a whole. Project specific fire and emergency plans, diagrams,

and equipment were completed. Proof of fire equipment was

observed by the auditor and noted in photographs taken by the

Environmental Scientist during the construction phase.

Evidence:

— M&R EA 3.19 F&E plot plan;

— M&R EA 3.19 Fire checklist; and,

— M&R EA 3.19 Photo of fire extinguisher.

None.

3.20 Any complaints received from the employees or anyone

within the immediate vicinity of the site 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 A project specific complaints register was compiled and no

complaints by employees or anyone in the vicinity, recorded to

date.

Evidence:

— M&R EA 3.20 Complaints register.

None.

3.21 The applicant must obtain a Scheduled Process authorisation

in terms of APPA, from DEAT, prior to commencing with

activities.

C Authorisation in terms of APPA was received on 26 August 2008.

Subsequently, the RTOs have been included within the complex’s

AEL, Section 5.5.4.

A Minimum Emissions Standards postponement application has

been submitted and acknowledged by the DEA – proof was

provided to the auditor.

None.


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Evidence:

— M&R EA 3.20 APPA registration;

— AEL Sasol Synfuels 0016-2018-F03 (2018); and,

— EA 3.21 APPA AEL RE VOCA - Environmental

Compliance Postponement Memo.

SITE CLOSURE AND COMMISSIONING

3.22 A rehabilitation plan must be submitted to Department for

approval at least 6 months prior to decommissioning. N/A Requirement noted by Sasol.

According to Sasol’s Environmental Specialist, there are no plans

to decommission the RTOs; construction of the seventh RTO was

underway at the time of the site visit.

None.

3.23 Should any material of cultural or archaeological

significance be encountered during construction, all

activities must cease immediately and the SA Heritage

resources Agency must be informed.

N/A According to Sasol’s Environmental Specialist, no heritage items

were discovered. The construction activities were undertaken in

areas that were already transformed.

None.

3.24 Any complaints received from public during construction

and operational phases must be attended to as soon as

possible and addressed to the satisfaction of all concerned.

C A project specific complaints register was compiled and no

complaints recorded to date.

Evidence:


None.

GENERAL

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

where the activities will be undertaken. The authorisation C Sasol’s environmental team have soft copies of the EA and

where/when necessary, communicate any specific details or

OFI:


WSP June 2019

Page 19


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.

requirements to the relevant business units. Additionally, copies

are maintained at the SHE: Environment department and on SAP

EC and SharePoint.

Sasol provided the auditor with the evidence that the responsible

persons, Chwayita Faku (Senior Manager of CT, GLS & CTF

Production Area, Tar, Pheonosolvan & Sulphur (TPS)) and SP

Smith (legal appointee of TPS), were made aware of the EA in

September/October 2016.

The auditor is aware that the responsible person for the RTO at the

TPS plant is now July Mavuso, having taken over from Chwayita

Faku. Helgard Theron (Senior Manager Refining West) and

Willem Oosthuizen (legal appointee of Refining) are responsible

persons for RTO that is situated in the Refining area. The auditor

was advised that upon commissioning of the final RTO, the

official handover will be documented.

A copy of the EA was included within the principal contractor’s

SHE File.

Evidence:

— M&R EA 3.1 Authorisation Letter.

— EA_EX Handover_SSO_TPS-CT-GLS-CTF

It should be ensured that the

formal handover is

documented as soon as

practical, to clearly define

responsibilities.

Target completion:

Medium term

3.26 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_TPS_Amendment_RTO VOC Project_1.3.1.16.4 G-

36_2017-04-28.

None.

3.27 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

C Statement noted by Sasol.

Regular monthly monitoring and spot checks were undertaken by

Sasol’s Environmental Specialist during the construction phase.

No notifications of non-adherence were deemed necessary during

None.


WSP June 2019

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this period. Furthermore, no non-compliances were noted during

this audit.

3.28 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.


3.29 The SHEQ Manager must oversee implementation of the

conditions of the Environmental Authorisation and ensure

that there is adherence throughout the life cycle of the

project.

C Regular monthly monitoring and spot checks were undertaken by

Sasol’s Environmental Specialist during the construction phase.

The monitoring requirements are included in Sasol’s

Environmental Management System (EMS) and is overseen by

Sasol’s SHE: Environmental Compliance Specialist.

None.


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Page 21

Table 3: Audit Findings – Environmental Management Plan


4. CONSTRUCTION PHASE

4.1 Employment and Skills Development

4.1.1 Local labour and contractors must be used wherever

possible. C Sasol have implemented a preferential recruitment programme; a

minimum of 70% of general works (up to semi-skilled) must be

recruited from citizens residing within the local municipal district.

Evidence:


and,

— Labour_Sasol IRM Suppliers Industrial Relations Procedure.

None.

4.1.2 Basic skills development and capacity building must be

incorporated. C The principal contractor provided a training matrix and cost

allocation to prove that training was provided to labour.

Evidence:

— M&R EMP 4.2.1 Training matrix; and,

— M&R EMP 4.2.1 Training cost allocation.

None.

4.1.3 Sasol must ensure that this EMP forms part of any

contractual agreements with a Contractor(s) and sub-

contractors for the execution of the proposed project.

C The principal contractor’s appointment letter made provision for

the compliance to SHE Regulations, and a copy of the EMPr

provided with it to the contractor.

Evidence:

— M&R EMP 4.1.1 Appointment as principle contractor; and,

— M&R EMP 4.1.1 BAR EMP.

None.

4.1.4 Sasol and the Contractor must comply with the relevant

provisions of the EMP, environmental authorisation, by-

laws, applicable environmental legislation and associated

regulations promulgated in terms of these laws.

C The principal contractor’s appointment letter made provision for

the compliance to SHE Regulations, and a copy of the EMPr

provided with it to the contractor.

None.


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Page 22


Evidence:

— M&R EMP 4.1.1 Appointment as principle contractor; and,

— M&R EMP 4.1.1 BAR EMP.

4.1.5 Construction staff must be adequately educated by the Sasol

Technology EIA Specialist or the Project Manager as to the

provisions included in the EMP and general environmentally

friendly practice.

C An induction was provided by Sasol prior to construction

beginning and signed registers maintained as evidence.

Evidence:

— M&R EMP 4.1.1 Induction.

None.

4.2 Safety Orientation, Induction and Training

4.2.1 The contractor shall ensure that all its employees are

adequately orientated, inducted and trained to perform the

tasks. The training costs and requirements shall be reflected

in the project tender document.

C An induction was provided by Sasol prior to construction

beginning and signed registers maintained as evidence.

The principal contractor provided a training matrix and cost

allocation to prove that training was provided to the labour force.

Evidence:


— M&R EMP 4.2.1 Training cost allocation; and,

— M&R EMP 4.1.1 Induction.

None.

4.2.2 All contractor employees entering the Sasol site shall

comply with the safety regulations. Before a contractor

employee shall be granted access the SASOL site, SH&ERQ

induction shall be done.

C An induction and emergency procedure training was provided by

Sasol prior to construction beginning and signed registers

maintained as evidence.

The principal contractor provided a training matrix and cost

allocation to prove that training was provided to the labour force.

Evidence:


— M&R EMP 4.2.1 Training cost allocation;

— M&R EMP 4.1.1 Induction; and,

None.


WSP June 2019

Page 23


— M&R EMP 4.3.1 Training attendance.

4.3 Emergency Preparedness

4.3.1 The principal contractor will develop (based on credible

scenarios) a specific emergency procedure focusing on Sasol

Business Units (SBU’s) and implement an emergency plan

based on the business units guidelines for that site in

collaboration with contractor’s SH&E officer and the agent’s

representative on site. The principal contractor shall ensure

that the emergency procedure is approved in writing by the

SBU and Emergency Management Department.

C Area and Site-Specific Emergency Procedures are compiled by

Sasol; this is in addition to a project specific Emergency Response

Plan compiled by the construction contractor. Training for

emergency procedures was also undertaken and a signed register

retained as proof.

Evidence:

— EA3.19, EMP4.3.1,EMP5.3.1 - Unit 213 Process safety file;




— M&R EMP 4.3.1 Plant Emergency response plan2; and,


None.

4.3.2 Flammable liquids store facilities must comply with

legislation and be approved by the Sasol’s emergency

officer.

C Proof of appropriate storage of paints, solvents and chemicals,


the auditor.

Evidence:

— M&R EA 3.15.4 Photo of Hazardous storage:

None.


WSP June 2019

Page 24


4.3.3 All employees and emergency coordinators must be trained

in the emergency procedure and routine trial emergencies

implemented. Emergency telephone and ambulance numbers

must be available at all telephones and displayed on site.

C Area and Site Specific Emergency Procedures are compiled by

Sasol; this is in addition to a project specific Emergency Response

Plan compiled by the construction contractor. Training for

emergency procedures was also undertaken and a signed register

retained as proof. Emergency numbers were noted in the

Emergency Response Plan which was displayed onsite; it is

unknown if it is was available at all telephones.

Evidence:




— M&R EMP 4.3.1 Plant Emergency response plan2; and,


None.


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Page 25


4.4 Personal Protective Equipment

4.4.1 No person is allowed to enter the site without the SBU

approved (SANS approved) required PPE. C A project specific PPE Management Procedure was compiled,

detailing PPE requirements to enter the site. Signage was also

placed indicating the PPE required to enter the construction area.

Evidence:

— M&R EMP 4.4 PPE management procedure; and,

— M&R EMP 4.4 Photos of PPE signs:

None.

4.4.2 The contractor must ensure that the company logo is

displayed and company personnel can be easily identified. C The auditor was provided with photographic evidence that

Contractor’s PPE displayed the company logo.

Evidence:

None.


WSP June 2019

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— TMS EMP 4.4.1,4.7.11,4.7.13 Personal protective equipment

(PPE); and,

— WP EA3.13,3.14,3.15,3.17,3.19 EMP4.3.1,4.4.1,4.5.1,4.6,4.7

Photos:

4.4.3 Ear protection shall be worn in any designated noise zone

and where noise generating equipment and tools are being

used. The contractor shall conduct a survey on decibel levels

and implement protection accordingly.

C Ashreq Environmental and Occupational Hygiene Consultants

undertook an Occupational Hygiene Survey which included noise

assessments. Recommendations were provided in the report for

implementation by the contractor.

Noise zones were demarcated by means of signage; proof was

provided to the auditor in the form of photographs of the relevant

signage. PPE was noted to be correctly worn by employees during

the site walkover. PPE was noted to be correctly worn by

employees during the site walkover.

None.


WSP June 2019

Page 27


Evidence:

— M&R EMP 4.4 Report on occupational hygiene survey; and,

— M&R EMP 4.4 Photos of PPE signs:

4.5 Site Establishment

4.5.1 The construction area must be clearly demarcated on a site

plan, and all other areas must be considered no-go areas for

the construction personnel.

C The construction area was clearly demarcated on the Fire and

Emergency Plot Plan compiled for the project prior to site

establishment. According to the Environmental Specialist,

construction staff were restricted access to other areas.

None.


WSP June 2019

Page 28


Evidence:

— M&R EMP 4.5.1 F&E Plot plan.

4.5.2 Only designated areas may be used for the storage of

construction material, topsoil, machinery and equipment. C Storage and laydown areas were clearly demarcated on the Fire

and Emergency Plot Plan compiled for the project prior to site

establishment.

Copies of certification from Sasol permitting the use of the site by

Murray & Roberts contractors for temporary site establishment and

laydown were provided to the auditor.

Evidence:

— M&R EMP 4.5.1 F&E Plot plan;

— M&R EMP 4.5.1 Temporary site laydown area

None.

4.5.3 The following activities must be prohibited at the

construction area, and by the construction staff in general:

— Burning of any type of waste material.

— The use of rivers, streams, dams or any

watercourses/surface water for washing or recreational

purposes.

— Entering areas outside of the demarcated construction

area without relevant permissions.

C The principal contractor implemented a project specific SHE Plan

that includes these prohibitions. In addition, there are no

watercourses within proximity of the construction area.

Evidence:

— M&R EA 3.9 SHE plan.

None.

4.6 Plant Construction

4.6.1 Generation and indiscriminate disposal of domestic waste:

4.6.1.1 All construction waste will be placed in provided waste bins. C Sasol’s Environmental Specialist undertook audits during the

construction phase and photos of waste separation and proper

storage was provided as evidence to the auditor.

Evidence:

— M&R EMP 4.6.1 Photos of waste separation.

None.


WSP June 2019

Page 29


4.6.1.2 Waste will be separated into different types and placed into

separate waste containers. C Sasol’s Environmental Specialist undertook audits during the



Evidence:

— M&R EMP 4.6.2 Photo of general waste bin;

— M&R EMP 4.6.1 Photos of waste separation:

None.

4.6.1.3 The Contractor should ensure that sewerage waste is routed

accordingly and does not drain into the nearby stormwater

system.

C Toilet and ablution facilities connected to the site’s sewerage

system was provided to workers for the construction phase.

Evidence:

— M&R EMP 4.6.8 Photo of sanitary facilities:

None.


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Page 30


4.6.2 Grinding:

4.6.2.1 All construction waste must be disposed of in an

environmentally responsible manner. No waste can be left

littering the construction site, storage site or construction

camp area.

C A project specific Waste Management Plan was compiled by the

contractor and implemented during construction. Spot checks and

audits were done by Sasol’s Environmental Specialist during the

construction phase. Waste disposal slips were also retained by

Sasol as evidence.

Evidence:

— M&R EA 3.15.3 Waste disposal slips; and,

— M&R EMP 4.6.5 WMP with waste inventory.

4.6.2.2 All construction waste to be disposed of in waste bins

provided. Waste will be separated into different types and

placed in separated waste containers.

C A project specific Waste Management Plan was compiled by the

contractor and implemented during construction. The plan makes

provision for waste separation and photos proving adequate

separation were taken by Sasol’s Environmental Specialist and

provided as proof.

None.


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Page 31


Evidence:


— M&R EA 3.15.3 Waste disposal slips; and,


4.6.3 Insulation Material:

4.6.3.1 All construction waste must be disposed of in an

environmentally responsible manner. C Sasol’s Environmental Specialist undertook audits during the



The registered waste contractor (Enviroserv) co-disposed off the



Evidence:



None.




C Sasol’s Environmental Specialist undertook audits during the


storage of insulation waste was provided as evidence to the

auditor.

Evidence:

— M&R EMP 4.6.3 Photo of insulation waste bin.

None.

4.6.4 Mixing of Concrete:


provided and disposed of according to the Sasol Waste

Management Procedure (Document still in draft format -

SGR-GEN-000002).



storage was provided as evidence to the auditor. This was noted to

be in accordance with Sasol’s Waste Management Procedure.

None.


WSP June 2019

Page 32


The registered waste contractor (Enviroserv) co-disposed off the



Evidence:



000017_Rev10_2017-09;


4.6.5 Other Waste:







Evidence:


None.

4.6.6 Packaging Material:







Evidence:


None.

4.6.7 Painting:

4.6.7.1 Potential spillages:

— All paints will be kept in a well bunded area.

C Proof of appropriate storage of paints, solvents and chemicals,


the auditor.

None.


WSP June 2019

Page 33


— Soil contaminated by paint will be removed and sent to

the WRF.

Paint cans left on site:

— All construction waste to be disposed of in waste bins

provided.

A project specific Waste Management Plan was compiled by the

contractor and implemented during construction. Sasol’s

Environmental Specialist undertook audits during the construction

phase and photos of waste separation and proper storage was

provided as evidence to the auditor.

The contractor spill prevention and response plan was provided to

the auditor.

Evidence:

— M&R EA 3.13 Spill prevention and response plan


— M&R EMP 4.6.1 Photos of waste separation; and,

— M&R EMP 4.6.5 WMP with waste inventory.

4.6.8 Potable water and toilet facilities on site (temporary):

4.6.8.1 Sewerage discharges may not enter storm water also certain

basic sanitary conditions must apply and sanitary facilities

must be provided on site.

C Toilet and ablution facilities connected to the site’s sewerage

system was provided to workers for the construction phase.

Evidence:

— M&R EMP 4.6.8 Photo of sanitary facilities.

None.

4.6.9 Sand/shot blasting:

4.6.9.1 Determine if medium is contaminated and dispose of

correctly. C Provision was made in the WMP for the safe disposal of the

sandblasting grit. Waste disposal slips proving safe disposal were

retained by Sasol.

Evidence:


— M&R EMP 4.6.9 Waste disposal slip; and,

— M&R EMP 4.6.9 Photo of sandblasting grit:

None.


WSP June 2019

Page 34


4.6.9.2 The production of dust will be minimised and controlled as

much as possible especially in the residential areas. C The grit was contained and collected within a bulk bag. No

complaints or incidents related to dust from the sandblasting

process was recorded.

Evidence:

— M&R EMP 4.6.9 Photo of sandblasting grit; and,


None.


WSP June 2019

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4.6.10 Storage of cement/grease, oils, paints and chemicals:

4.6.10.1 All products that have a potential of contaminating the soil

will be kept in a well-protected/bunded area. C Proof of appropriate storage of paints, solvents and chemicals,


the auditor. Sasol’s Environmental Specialist noted that drip trays

were used to contain any leaks form machinery during the

construction phase.

Evidence:

— M&R EA 3.15.4 Photo of Hazardous storage; and,

— M&R EMP 4.6.10 Photo of diesel bowser and drip tray:

None.


WSP June 2019

Page 36


4.6.10.2 Clean up contaminated soil where spillages occur. C No incidences of major contamination to soil have been recorded

for the audit period. If any minor spills occurred, they would have

been cleaned according to the Spill Prevention and Response Plan

compiled for the project. No spillage incidents were recorded for

this audit period.

Evidence:

— Environment Impact register_ New FY19_2019-02-18;

— Copy of Environment Impact register_ New FY17;

— M&R EA 3.13 Spill prevention and response plan.

None.

4.6.11 Welding:




C Used welding rods were stored in a specific waste bin.

Evidence:

— M&R EMP 4.6.11 Photo of waste bin for used rods:

None.


WSP June 2019

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4.6.11.2 Contractor to remove waste in appropriate manner – to be

stipulated in contract document. C The project specific SHE Plan (part of the contract documentation

pack) for the project included provision for the safe disposal of

waste.

Evidence:

— M&R EMP 4.6.11 Refer to SHE plan for waste disposal

requirement.

None.

4.7 Site Preparation Activities

4.7.1 Backfill with dolerite/ash for foundation purposes. N/A Construction phase for the RTOs does not involve excavation, as

such backfilling is not considered applicable.

None.

4.7.2 The production of dust will be minimised and controlled as

much as possible. C Dust suppression by water spraying was noted by Sasol’s


Evidence:

— M&R EMP 4.7.1 Dust suppression.

None.

4.7.1 Removal of contaminated rainwater from foundations

4.7.1.1 Prevent discharge of contaminated water flowing into

streams or rivers. C Any contaminated material generated during the construction

phase was managed in accordance to the WMP and Waste

Procedure, and safely disposed with proof of safe disposal retained

by Sasol.

Evidence:

— M&R EMP 4.7.3 Sasol waste management procedure; and,

— M&R EMP 4.7.3 Waste disposal slips.

None.


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Page 38


4.7.2 Removing redundant/contaminated equipment and not disposing correctly

4.7.2.1 Contaminated equipment must be identified and disposed of

correctly. C Any contaminated material (including equipment) generated

during the construction phase was managed in accordance to the

WMP and Waste Procedure, and safely disposed with proof of safe

disposal retained by Sasol.

Evidence:

— M&R EMP 4.7.3 Sasol waste management procedure; and,

— M&R EMP 4.7.3 Waste disposal slips.

None.

4.7.3 Use of construction vehicles/ machinery: Building rubble left on site

4.7.3.1 Rock and other material from the excavation process will be

disposed of in a way that does not have a negative impact on

the aesthetic of the environment and that blends in with the

rehabilitation process of the trench.

N/A No specific excavation material was noted to be generated during

the construction phase.

None.

4.7.3.2 Any redundant excavated material will be disposed of at

Charlie 1 general waste site. N/A No specific excavation material was noted to be generated during

the construction phase.

None.

4.7.4 Use of construction vehicles/ machinery: Contaminated excavated material not used for backfill left on site

4.7.4.1 Determine if excavated material is contaminated and dispose

of correctly N/A The auditor was informed that no specific excavation material was

generated during the construction phase.

None.

4.7.4.2 Determine if building rubble is contaminated and disposed

of correctly.

N/A The auditor was informed that no specific building rubble was


None.


WSP June 2019

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4.7.5 Use of construction vehicles/ machinery: Dust

4.7.5.1 Dust must be suppressed on access roads and construction

sites during dry periods by the regular application of water. C Dust suppression by water spraying was noted by Sasol’s


Evidence:


None.

4.7.5.2 The production of dust will be minimised and controlled as

much as possible especially in the residential areas. C Dust suppression by water spraying was noted by Sasol’s

Environmental Specialist. No residential areas are in proximity to

the construction areas.

Evidence:


None.

4.7.6 Use of construction vehicles/machinery – Excavated material not used for backfill left on site

4.7.6.1 Rock and other material from the excavation process will be

disposed of in a way that does not have a negative impact on

the aesthetics of the environment and that blends in with the

rehabilitation process.

N/A The auditor was informed that no specific excavation material was


None.

4.7.6.2 Any redundant excavated material will be disposed of at

Charlie 1 general waste site. N/A The auditor was informed that no specific excavation material was


None.

4.7.7 Use of construction vehicles/machinery – Fuel storage and refuelling leading to spillages

4.7.7.1 Meet the requirements of storage facilities for design and

maintenance as explained in applicable local bylaws. N/A A diesel bowser was only used for refuelling during the

construction phase. No other fuel storage facilities were required.

Evidence:

— M&R EA 3.13 Spill prevention and response plan;

— M&R EMP 4.7.9 Photo of diesel bowser and drip tray:

None.


WSP June 2019

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4.7.7.2 Proper control measures must be in place on the storage site

of the fuel and lubricants. C A procedure for refuelling using the bowser was compiled for the

project and included in the SHE File. Proof of the usage of drip-

trays was captured by Sasol’s Environmental Specialist.

Evidence:

— M&R EA 3.13 Spill prevention and response plan;

None.

4.7.7.3 Prevent spillage of fuel during refuelling. C None.

4.7.7.4 Drip trays must be used for refuelling and oil changes. C None.


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4.7.7.5 The refuelling of machinery should be done in such a way as

to prevent any spillage on site or in the storage area. C


and,

— M&R EMP 4.7.9 Photo of diesel bowser and drip tray.

None.

4.7.8 Use of construction vehicles/machinery – Borrow pits

4.7.8.1 Only licensed borrow pits may be used. C Proof of obtaining material from a licensed borrow pit was

retained and provided to the auditor.

Evidence:

— M&R EMP 4.7.10 Borrow pit license.

None.

4.7.9 Use of construction vehicles/machinery –Noise

4.7.9.1 All attempts will be made to keep noise levels to a minimum

(obtain allowable noise levels form OHS Act).

C Noise generated during the construction phase were limited to

general construction type noise and noise generated by

machinery/equipment used.

Ashreq Environmental and Occupational Hygiene Consultants






signage.

Evidence:


— M&R EMP 4.4 Photos of PPE signs.

None.


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4.7.10 Use of construction vehicles/machinery – Spent engine oil

4.7.10.1 Drip trays must be used for refuelling and oil changes. C A procedure for refuelling using the bowser was compiled for the

project and included in the SHE File. Proof of the usage of drip-

trays was captured by Sasol’s Environmental Specialist.

Evidence:


and,

— M&R EMP 4.7.9 Photo of diesel bowser and drip tray.

None.

4.7.10.2 In a case of spillages, contaminated soil will be removed and

disposed of properly.

Clean-up measures must be in place when spillages occur.

C No incidences of major contamination to soil were recorded for the

construction phase. If any minor spills occurred, they would have

been cleaned according to the Spill Prevention and Response Plan

compiled for the project.

Evidence:

— M&R EA 3.13 Spill prevention and response plan.

None.

4.7.11 Use of electricity/diesel generators – Noise

4.7.11.1 All attempts will be made to keep noise levels to a minimum

(not exceed 85 dB).

C Noise generated during the construction phase were limited to

general construction type noise and noise generated by

machinery/equipment used.

Ashreq Environmental and Occupational Hygiene Consultants






signage.

Evidence:

None.

4.7.11.2 No equipment causing excessive noise (above normal

standards for specified equipment) should be allowed on site. C None.

4.7.11.3 Hearing protection should be used where required (above 85

dB). C None.


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— M&R EMP 4.4 Photos of PPE signs.

4.7.12 Use of electricity/diesel generators – Smoke

4.7.12.1 Electricity generators used by the Contractor should be in

good working condition. C Generators were maintained on an as required basis and an

indicator noted on the generator to confirm it was working

properly.

Evidence:

— M&R EMP 4.7.13 Mechanic works order; and,

— M&R EMP 4.7.13 Photo of maintenance indicator panel on

generator:

None.


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4.7.12.2 No equipment causing excessive smoke (above normal

standards for specified equipment) should be allowed on site. C Equipment was regularly serviced and if they were noted to be

malfunctioning, then a technician was called out to provide

maintenance/repairs.

Evidence:

— M&R EMP 4.7.13 Mechanic works order.

None.


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4.7.13 Smoking during construction phase

4.7.13.1 Use designated smoking areas. C A Smoking Policy document was implemented for the construction

phase; a dedicated smoking area was demarcated and was the only

area within which smoking was allowed.

Evidence:

— M&R EMP 4.7.15 Smoking policy; and,

— M&R EMP 4.7.15 Photo of smoking area:

None.


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5. PRE-COMMISSIONING PHASE

5.1 Leak Test of Tank and Pipeline:

5.1.1 Determine if water is contaminated and disposed of to the

right system. C According to the Environmental Specialist, the water used during

testing was discarded to the oily water (dirty water) system for

treatment. Water is tested prior to disposal, to establish if the water

is suitable for disposal to the API.

None.

5.2 Testing of Equipment: Hydraulic Testing (Management of Water)

5.2.1 Disposal of water should be disposed to the right systems. C The process description details that non-process drains include









Evidence:

— EMP 5.2.1 Hydrotesting in shop TEST_PACK_56

(hydrotesting in shop);

— WP EMP 5.3.1 Process description.

None.

5.2.2 Ensure that interface documentation is in place. C A detailed pressure testing procedure was compiled and included

specific measures and steps to follow during testing.

Evidence:

— M&R EMP 5.2 Pressure testing procedure.

None.


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5.3 Venting of Equipment (Odour, fire, risk, noise, emissions to atmosphere)

5.3.1 Quantify venting and route to Thermal Oxidiser. C Venting and the route to the Thermal Oxidiser are included in the

Process Descriptions document compiled by Worley Parsons for

the project.

Evidence:


— EA3.19, EMP4.3.1,EMP5.3.1 - Unit 213 Process safety file.

None.

6.2.4 Determine volumes of existing sumps. C The volumes of existing sumps were included in the Process

Descriptions document compiled by Worley Parsons for the

project.

Evidence:


None.

6.2.5 Sumps must be designed and managed properly – chemical

conservation sewer; use hard piping. C Sumps are included in the Process Descriptions document

compiled by Worley Parsons for the project, and were considered

appropriately designed.

Evidence:


None.

6. START-UP AND SHUTDOWN PHASE

6.1 Cleaning of Vessels (Incorrect disposal/ management of material)

6.1.1 Tar condensate formation in lines - All waste must be

disposed to the correct system. C Construction phase waste was managed by the principal

contractor; and evidence of waste receptacles and waste disposal

slips were provided to the auditor.

Nnoe.


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The RTO facilities are currently not operational. Furthermore, the

RTOs are within sites that operate in accordance to Sasol’s Waste

Management Procedure.








quarterly basis.

Evidence:


000017_Rev10_2017-09;


— M&R EA 3.14 Photo of waste bins; and,

— M&R EA 3.14 Waste disposal slips.

6.1.2 Sumps must be designed and managed properly (chemical

conservation sewer). C Sumps are included in the Process Descriptions document



Evidence:


None.

6.1.3 Prevent spillages. C The RTO facilities are currently not operational. No incidences of

major contamination to soil were recorded on the incident register.

If any minor spills occur, are attended to according to the Spill

Prevention and Response Plan compiled for the project.

Proof of appropriate storage of paints, solvents and chemicals,

within a lockable hazardous goods storage cage, was viewed by

the auditor.

None.


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Evidence:



— M&R EMP 4.6.10 Refer to Spill prevention and response

plan.

6.1.4 Prevent incorrect disposal of organic and inorganic waste. C The RTO facilities are currently not operational. Furthermore, the

RTOs are within sites that operate in accordance to Sasol’s Waste

Management Procedure.








quarterly basis.

Evidence:


000017_Rev10_2017-09;

— Sasol SAWIS upload-2018_Jul-Sep.

None.

6.2 Draining of Vessels during Shut Downs

6.2.1 Sumps must be designed and managed properly – Determine

volume of sump; use hard piping. C The volumes of existing sumps were included in the Process


project.

Evidence:


None.

6.2.2 Prevent spillages. C The RTO facilities are currently not operational. No incidences of

major contamination to soil were recorded on the incident register.

None.


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If any minor spills were to occur, these are attended to according

to the Spill Prevention and Response Plan compiled for the project.

Evidence:



— M&R EMP 4.6.10 Refer to Spill prevention and response

plan.

6.2.3 Prevent incorrect disposal of effluent. C The process description details that non-process drains include









Evidence:


None.

6.2.4 Determine volumes of existing sumps. C The volumes of existing sumps were included in the Process


project.

Evidence:


None.

6.2.5 Sumps must be designed and managed properly – chemical

conservation sewer; use hard piping. C Sumps are included in the Process Descriptions document



Evidence:


None.


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6.3 Filling up of Vessels (Displacement of air/ nitrogen, etc)

6.3.1 Identify, evaluate and mitigate if possible. C Mitigation, venting and the route to the Thermal Oxidiser are

included in the Process Descriptions document compiled by

Worley Parsons for the project.

Evidence:


None.

6.3.2 Route to Thermal Oxidiser. C

6.4 Purging of Vessels during Shut Downs (Releasing of VOCs etc into the atmosphere)

6.4.1 Identify, evaluate and mitigate if possible. C Shutdown is covered in the Process Descriptions document

compiled by Worley Parsons for the project. Four scenarios are

available when stopping the RTO, all of which start with stopping

the flow of VOC gas. In the event that any gas must be released,

this is directed via the stack for emission control.

Evidence:


None.

6.4 Replacement of Equipment (Incorrect reclaiming/ disposal of redundant equipment)

6.4.1 Prevent the contaminated equipment from being incorrectly

disposed. C Any contaminated material (including equipment) generated is

managed in accordance to the WMP and Waste Procedure, and

safely disposed with proof of safe disposal retained by Sasol.

Redundant equipment is sent to a reclamation yard within Sasol,

which is authorised under separate environmental exemption (Ref:

17.2.17 EV40).

None.


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6.5 Stack Design (Stack emissions to atmosphere)

6.5.1 Identify, evaluate, quantify and minimise. C Mitigation, venting and stack emission information is included in

the Process Descriptions document compiled by Worley Parsons

for the project.

Evidence:


None.

6.5.2 Not to exceed permit conditions and ground level

concentrations. C The RTO facilities are currently not operational.

The RTOs were authorised to be constructed at Units 213, 13,

96/296, 11/214, and 86. Consequently the following units were

Gas Liquor Separation (Tar plant), Coal Tar Filtration, Tar

distillation, and Feed Preparation Plant. Atmospheric emissions

from these facilities are controlled under the facility’s AEL.

Evidence:

— AEL Sasol Synfuels 0016-2018-F03 (2018).

None.

6.5.3 Modelling will be done (in Basic Engineering) to determine

exposures on ground downtime – then further risk

assessments to determine PPE requirements.

N/A The Basic Engineering process would have occurred prior to this

audit period and is therefore deemed not applicable.

None.

6.6 Venting of Vessels under Positive Pressure during Shut Downs (Venting to atmosphere to de-pressurise)

6.6.1 Identify, evaluate and eliminate if necessary. C Shutdown is covered in the Process Descriptions document

compiled by Worley Parsons for the project. Four scenarios are

available when stopping the RTO, all of which start with stopping

the flow of VOC gas. In the event that any gas must be released,

this is directed via the stack for emission control.

Evidence:


None.


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6.6.2 Venting from release valve – emergency venting not routed

to Thermal Oxidiser. C Venting and the route to the Thermal Oxidiser are included in the

Process Descriptions document compiled by Worley Parsons for

the project.

Evidence:


None.

7. OPERATION AND MAINTENANCE

7.1 Additional Permanent Employment

7.1.1 Local labour and contractors must be used wherever

possible. C Sasol have implemented a preferential recruitment programme; a



Evidence:


and,


None.

7.1.2 Basic skills development and capacity building must be

incorporated. C Sasol have a detailed procedure which includes provision for

ongoing skills development and capacity building.

Evidence:

— SA Regional Procedure - Generic SHE Training.docx Rev.01

July 2018.

None.

7.1.3 Employees will be subject to the necessary basic skills

training. C Sasol have a detailed procedure which includes provision for

ongoing skills development and capacity building.

Evidence:

— SA Regional Procedure - Generic SHE Training.docx Rev.01

July 2018.

None.


WSP June 2019

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7.1.4 All reasonable attempts will be made to appoint people from

the local communities as temporary labourers for non-

specialised tasks.

C Sasol have implemented a preferential recruitment programme; a



Evidence:


and,


None.

7.2 Emergency and Risk (Emergency plan and safety risks)

7.2.1 Emergency plan must be in place before the commissioning

of the abatement units.

C Area and Site-Specific Emergency Procedures are compiled by

Sasol.

Evidence:

— M&R EMP 4.3.1 Plant Emergency response plan; and,

— M&R EMP 4.3.1 Plant Emergency response plan2.

None.

7.2.2 Reduction of the probability of occurrence of an event by

considering the integrity of equipment and safe guards in

place to prevent failure of equipment should be addressed

during Basic Engineering.

N/A Statement noted by Sasol.

The Basic Engineering process would have occurred prior to this

audit period and is therefore deemed not applicable.

None.

7.2.3 Prevent environmental contamination. C The Sasol Complex operates with a dedicated environmental team

and have detailed procedures and monitoring measures in place to

prevent contamination and detect if any contamination sources

occur. No environmental contamination incidents were recorded

for this audit period.

Evidence:


— Environment Impact register_ New FY19_2019-02-18.

None.


WSP June 2019

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7.2.4 Occupational health practices and operating procedures

currently conducted will be maintained and continually

improved in keeping with the current approach.

Requirements of the OHS Act (85 of 1993) and its

Regulations, Sasol SH&E Minimum Requirements, the

requirements of the International Risk Control Africa

(IRCA) Occupational Health auditing system, principles of

the OHSAS 18000 standard, World Health Organisation

(WHO) guidelines and practices currently embedded in the

Synfuels Occupational Health system will apply to the

proposed project.


7.3 Fire Water – Routing (Water used to extinguish a fire not routed/ disposed of)

7.3.1 Ensure correct disposal of fire water. C Fire water would be routed within the hard surfaced area to the

oily water system and would therefore be contained.

None.

7.4 Maintenance – Replace Old Equipment (Removing redundant/ contaminated equipment and not disposed of correctly)

7.4.1 Prevent the contaminated equipment from being incorrectly

disposed. C Any contaminated material (including equipment) generated is

managed in accordance to the WMP and Waste Procedure, and

safely disposed with proof of safe disposal retained by Sasol.

Redundant equipment is sent to a reclamation yard within Sasol,

which is authorised under separate environmental exemption (Ref:

17.2.17 EV40).

None.

7.5 Stormwater Management: Contaminated Stormwater (Contaminated stormwater not disposed of/routed correctly)

7.5.1 Ensure proper disposal of storm water. C Surface water is managed at the site; the area is within a hard

surfaced and bunded area that drains to an enclosed system that

pumps the water for treatment. This was verified by the auditor

during the site walkover.

None.


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7.6 Stormwater Management: Uncontaminated Stormwater (Uncontaminated stormwater not disposed of/routed correctly)

7.6.1 Uncontaminated stormwater will be routed to the existing

stormwater system.

C Any stormwater falling outside the bunded area drains to a sump

and thereafter to the clean water system. This was verified during

the site walkover.

None.

7.7 Testing of Equipment: Hydraulic Testing (Management of used water)

7.7.1 Water will be routed to the correct sewer system according

to the Synfuels Water Management Procedure. C The process description details that non-process drains include









Evidence:


None.

7.7.2 Prevent incorrect disposal of effluents. C None.

7.8 Other

7.8.1 Determine if there is enough crane access for construction. C Sufficient crane access was provided, and the construction was

completed without crane-related concerns. No incidents relating to

crane access were noted on the incident registers.

Evidence:



— Environment Impact register_ New FY19_2019-02-18

None.


WSP June 2019

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7.8.2 Process safety when combining existing and new collection

ducting - most concentrated streams will be in smallest

pipes.

C A sample of process safety documentation was provided, which

cover the ducting.

Evidence:


— EA 3.19, EMP4.6.7&4.7.14

Unit_014_&_214_process_safety_file_-_Rev_A_-_2013-02-

27;

— EA 3.19, EMP4.6.7&4.7.14 Unit_086_process_safety_file_-

_Rev_A_-_2013-02-14;

— EA 3.19, EMP4.6.7&4.7.14 Unit_213_Process_safety_file_-

_2012-09-12;

— EA 3.19, EMP4.6.7&4.7.14_Unit_013_Process_safety_file_-

_2012-09-12.

None.

7.8.3 Provide adequate steam out lines and flanged lines for

cleaning. C A sample of process safety documentation was provided, which

coves venting.

Evidence:


— EA 3.19, EMP4.6.7&4.7.14

Unit_014_&_214_process_safety_file_-_Rev_A_-_2013-02-

27;

— EA 3.19, EMP4.6.7&4.7.14 Unit_086_process_safety_file_-

_Rev_A_-_2013-02-14;

— EA 3.19, EMP4.6.7&4.7.14 Unit_213_Process_safety_file_-

_2012-09-12;

— EA 3.19, EMP4.6.7&4.7.14_Unit_013_Process_safety_file_-

_2012-09-12.

None.

7.8.4 Design sumps to contain all water effluent, which will then

be routed to API (oily sewer) dams. C The process description details that non-process drains include




None.


WSP June 2019

Page 58







Evidence:


8. DECOMMISSIONING PHASE

8.1 Upon site closure and decommissioning of the authorised

activity, apply in terms of Government Notice R. 386 of

2006 (23) for the relevant Environmental Authorisation.

N/A There is currently no proposal for imminent decommissioning of

this facility. This condition is therefore not applicable.

None.

8.2 All structures, foundations and concrete and tarred areas are

demolished, removed and waste material recycled or

disposed of at an appropriately licensed waste disposal site.



None.

8.3 All access/service roads not required are closed and fully

rehabilitated. N/A There is currently no proposal for imminent decommissioning of


None.

8.4 All disturbed areas are compacted, sloped and contoured to

ensure drainage and runoff and to minimise the risk of

erosion.



None.

8.5 All rehabilitated areas are monitored for erosion. N/A There is currently no proposal for imminent decommissioning of


None.

8.6 Ensure a long term monitoring system is in place to ensure

total rehabilitation of the site after decommissioning. N/A There is currently no proposal for imminent decommissioning of


None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

below.

Table 4: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 6 4 0 2

APPEAL OF AUTHORISATION 2 0 0 2

MANAGEMENT AND MONITORING OF ACTIVITY 3 2 0 1

COMMISSIONING AND OPERATION OF THE ACTIVITY 16 15 0 1

SITE CLOSURE AND COMMISSIONING 3 1 0 2

GENERAL 5 4 0 1

Total Count 35 26 0 9

Total Percentage - 74% 0% 26%

Percentage Compliance with Applicable Conditions 100%


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Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents

the total proportion of compliance for the facility.

Figure 2: Number/Count contribution of findings made to the EA conditions per Section

Figure 3: Overall count findings on compliance to the EA conditions

02468

1012141618

Sectional Count Contribution

C

NC

N/A

26

0

9

Total Compliance

C

NC

N/A


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Page 61

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

Scope ofAuthorisation

Appeal ofAuthorisation

Managementand Monitoring

of Activity

Commissioningand Operationof the Activity

Site Closureand

Commissioning

General

Sectional Percentage Contribution

C

NC

N/A

74%

0%

26%

Total Percentage Compliance

C

NC

N/A


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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 EMP 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

4. CONSTRUCTION PHASE 61 53 0 8

5. PRE-COMMISSIONING PHASE 6 6 0 0

6. START-UP AND SHUT DOWN PHASE 18 17 0 1

7. OPERATION AND MAINTENANCE 18 16 0 2

8. DECOMMISSIONING PHASE 6 0 0 6

Total Count 109 92 0 17

Total Percentage - 84% 0% 16%

Percentage Compliance with Applicable Conditions 100%


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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

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

0

10

20

30

40

50

60

70

Sectional Count Contribution

C

NC

N/A

92

0

17

Total Compliance

C

NC

N/A


WSP June 2019

Page 64

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

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;

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

84%

0%

16%

Total Percentage Compliance

C

NC

N/A


WSP June 2019

Page 65

— 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 approximately half of the listed measures are now no longer

applicable going forwards, as these 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.

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17.2.1.25 MP-16)