SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & …

SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & SULPHUR

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

16.4.28.34 EV1 - FEED PREPARATION PLANT

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

16.4.28.34 EV1 - FEED PREPARATION PLANT

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:

16.4.28.34 EV1

Draft for Review –

Compliance Audit

EA Ref:

16.4.28.34 EV1

Date April 2019 June 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 1 1

File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\

S I G N A T U R E S

PREPARED BY

-

Ziyaad Kadwa

Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

of their compliance with the conditions included in the Environmental Authorisation.

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 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 Construction and Operation of the Feed

Preparation Plant (Authorisation Number:

16.4.28.34 EV1)......................................................... 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 .............................. 4

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 15

5.1 Environmental Authorisation ............................... 15


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 EA COMPLIANCE AUDIT FINDINGS ........................ 15

FIGURES

FIGURE 1: SSO – FEED PREPARATION PLANT (SOURCE: GOOGLE EARTH, 2018) ............................... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 16

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 16

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 17

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 17

APPENDICES

A ENVIRONMENTAL AUTHORISATION (16.4.28.34 EV1)


WSP June 2019

Page 1

1 INTRODUCTION

1.1 TERMS OF REFERENCE

Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP

Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit

and compile an audit report according to the requirements of the National Environmental Management Act (No.

107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the

Environmental Authorisation (EA) (Reference number: 16.4.28.34 EV1 issued on 03 January 2002) for the

period December 2014 to February 2019.

1.2 CONSTRUCTION AND OPERATION OF THE FEED

PREPARATION PLANT (AUTHORISATION NUMBER:

16.4.28.34 EV1)

Sasol received an EA for the construction and operation of the Feed Preparation Plant (FPP) at the Carbo-Tar

Plant, to recover valuable products from the organic waste streams. The FPP treats and processes waste by

means of centrifugation and filtration, and cokes the remaining fraction. Products suitable for coking are

processed at U39 (which is outside the scope of this authorisation) and products suitable for fuel oil are stored

and sold.

The EA was issued by the Mpumalanga Department of Agriculture, Conservation and Environment, on 03

January 2002, and it has been confirmed that the construction phase was completed prior to December 2014 (i.e.

outside the audit period).

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


WSP June 2019

Page 2

Figure 1: SSO – Feed Preparation Plant (Source: Google Earth, 2018)


WSP June 2019

Page 3

2 AUDIT SCOPE The 7 April 2017 amendment to the Environmental Impact Assessment (EIA) regulations introduced the

requirement for the auditing for all EAs and EMPrs in effect on 8 December 2014 and submission of audit

reports to the Department of Environmental Affairs (DEA) by 7 December 2019 and every five years thereafter.

This audit is designed to meet the requirements of Regulation 34 of the EIA Regulations, 2014.

The audit period runs from December 2014 to February 2019, therefore any construction related conditions that

would have been relevant pre-December 2014 are considered not applicable (outside audit period).

The objective of the audit was to:

— Assess the level of compliance with the conditions of the EA;

— Identify and assess any new impacts and risks that result from undertaking the activity;

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

— Ensure the commitments contained in Condition 9.01 of the EA are completed, more specifically:

— “Records relating to the compliance/non-compliance with the conditions of the authorization must be

kept in good order. Such records must be made available on request by this Department within seven (7)

working days of the date of the written request by the Department for such records.”


WSP June 2019

Page 4

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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (12 March 2019);

— Review of documentation relevant to the conditions of the EA (e.g. records, permits/certificates/maintenance

logs/monitoring results/previous reports etc.); and

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE 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. Key personnel interviewed

included:

— Piet Kleynhans (Area Manager; TPS Production: Carbo Tar).

— Collin Jaynarain (Area Manager; Gas Liquor Separation: Unit 213).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Environmental Authorisation: 16.4.28.34EV1_2002-01-03;

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— EA_EX Handover_SSO_TPS-CT-GLS-CTF;

— IWWMP SIC 2015 Final_2018-05-15;

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

— CT_GLS and CTF_2016-11-07;

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

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

— SOX Folder;

— Environmental Complaints Register_2019-02-18; and,

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.


WSP June 2019

Page 5

Each condition was verified, either by reviewing documentation, interviewing employees and/or visually

inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with

associated target completion dates included.

It should be noted that some of the EA conditions were apportioned according to the elements requiring

compliance assessment therein. Although some elements of the condition may have been compliant, if one of

the elements was determined to be non-compliant, the entire condition has been reported as such (and counted

as such during percentage compliance calculation). This apportionment further allowed for the development of

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

according to the requirements of the EA. Non-complaint conditions are given target

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer, Piet Kleynhans, and Collin 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.

— 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


WSP June 2019

Page 6

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.


WSP June 2019

Page 7

4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This authorization refers only to the project specified above

and described in the Record of Decision. Separate

applications must be lodged for any other development

and/or activity at or near proposed development, which is

covered by Sections 21 and 22 of the Act and Government

Notice R1182 and R1183 of 5 September 1997.

N/A Noted. The activity remains as specified and no further alterations

or applications have been made.

None.

1.02 Authorization is only granted in terms of Section 22 (3) of

the Environmental Conservation Act, 1989 (Act 73 of 1989)

and does not exempt the holder from compliance with any

other relevant legislation.

N/A Noted. A full legal review does not form part of the scope of this

audit.

The Sasol Complex operates with a dedicated environmental and

legal 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. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

1.03 No development may take place on the site of concern

without the necessary permits/approvals and/or service

and/or lease agreements, where it is relevant, from or

between the following institutions:

C The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

None.


WSP June 2019

Page 8


1.3.1 CAPCO

1.3.2 DWAF

1.3.3 Highveld East Municipality (for record purpose)

Sasol is in possession of an AEL (issued per business unit) and has

an updated Integrated Water and Waste Management Plan

(IWWMP) (updated 2018) that applies to the whole complex.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15; and,

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

1.04 This Department may change, add or amend any of the

conditions in this authorization if, in the opinion of the

Department, it is environmentally justified.

N/A Statement noted by Sasol. No changes or amendments have been

communicated to Sasol by the Department since issue of the EA.

None.

1.05 A copy of this authorization shall be available at the

premises of the Feed Preparation Plant at all times and all

staff, contractors, contractors and sub-contractors shall be

acquainted or made to be acquainted with the content of this

authorization.

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

where/when necessary, communicate any specific details or

requirements to the relevant business units.

Additionally, copies are maintained at the SHE: Environment

department and on SAP EC and SharePoint. Any specific

requirements are communicated during SHE induction training.

Sasol provided the auditor with the evidence that the responsible

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

Production Area, was made aware of the EA on 25 September

2016.

Evidence:

— EA_EX Handover_SSO_TPS-CT-GLS-CTF.

None.

1.06 The contents of this authorization should be made known to

all interested and affected parties. 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 authorization is repealed if the construction has not

taken place within two (2) years from the date of this

authorization.

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

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

None.


WSP June 2019

Page 9


2.02 In the event of decommissioning or closure of the FPP, sell

or transfer ownership of the infrastructure on the site in any

way, this Department must be informed of such a decision at

least 12 months prior to the date of closure or transfer of

ownership.

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

according to Sasol, is estimated to occur around 2050.

None.

2.03 In case of closure of the FPP, this Department shall evaluate,

monitor and approve the decommissioning and rehabilitation

of the site.

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


None.

3 CONSTRUCTION & OPERATION

3.01 If any changes need to be made to the FPP and/or associated

infrastructure, this Department must be informed thirty (30)

days in advance, to be able to decide whether the changes

need authorization.

N/A The activity remains as specified and no further alterations or

applications have been made.

None.

3.02 Sufficient provision must be made in the annual budget for

the mitigation of the environmental impacts during the

operation and rehabilitation of this site in the event of

closure of the FPP.

C Statement noted by Sasol. Closure is not yet planned for and


Due to being listed on the New York Stock Exchange, Sasol is

required to adhere to the Sarbanes Oxley (SOX) legislation in the

US which requires transparent financial disclosure, including its

environmental liabilities, to be included in the company financial

statements. Provision is made for the removal of surface

infrastructure, in line with the future land use, as well as for the

remediation of areas that would remain a liability post-closure in

terms of potential future contamination.

Evidence:

— SOX Folder.

None.


WSP June 2019

Page 10


4. AIR POLLUTION

4.01 Air pollution should be handled as indicated by the relevant

authorities. Any emissions must be permitted by CAPCO. C Sasol has a valid Atmospheric Emission Licence (AEL) that was

issued by the Gert Sibande District Municipality. The AEL

(reference: 0016/2014/F01) is valid to 31 March 2020.

According to the Environmental Team, Sasol works closely with

the local authority and operates units in line with the AEL and

minimum legal emission requirements.

The incidents registers for 2015- 2017 and 2017- 2019 do indicate

any emission exceedances from the plant.

Evidence:

— Compliance_Air_Secunda Complex

— Copy of Environment Impact register_ New FY17

— Environment Impact register_ New FY19_2019-02-18

— AEL Sasol Solvents 0017-2015-F02 (2015)

None.

5. WATER POLLUTION

5.01 It is the responsibility of the applicant and the relevant

contractor on the site to prevent any pollution of the surface

as well as groundwater.

C Surface water is managed at the site; the tanks and loading areas

are within hard surfaced and bunded areas that drain to an enclosed

system that pumps the water for reprocessing.

Surface water monitoring is done on a weekly basis as well as real

time for the various Receiving Environment Surface Monitoring

(RESMs).

Ground water monitoring is conducted biannually and quarterly.

The is no groundwater monitoring specific to the FPP, 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 FPP.

None.


WSP June 2019

Page 11


The latest IWWMP as well as surface and ground water

monitoring results were provided to the auditor as evidence. The

nearest surface water quality monitoring locations (RESM-6 and

RESM-7) showed results within limits.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15; and,

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-

31.pdf.

5.02 In case of non-compliance with Section 19 of the National

Water Act, 1998 (Act 36 of 1998), the applicant will be held

responsible to remedy the effects of pollution.

N/A Statement noted by Sasol. None.

6. WASTE MANAGEMENT

6.1 All waste generated during the construction and/or operation

of the FPP shall be store, handled and disposed of in an

environmentally acceptable way.

C This construction related requirement of this condition is

considered outside of the audit period (construction pre-2014). It is

therefore considered not applicable.

During normal operation, a sludge is produced that is captured

within enclosed skips. This sludge is not discarded but is

recovered.

A small amount of contaminated materials and general waste is

generated at the FPP and handled according to Sasol’s Waste

Management Procedure.

Evidence:

— CT_GLS and CTF_2016-11-07; and,

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09.


WSP June 2019

Page 12


7. RISK ASSESSMENT

7.01 Risk assessment should be handled as indicated by the

relevant authorities. C Sasol has a Governance SHE Risk and Assurance department that

assesses environmental risks and drives implementation per

business unit.

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.

All risk documentation is saved on the Sasol IMS; a folder

containing the risk assessments undertaken for TPS was shown to

the auditor in a screenshot of the IMS system folders.

None.

7.02 Fire extinguishing should be available at the site at all times. C Fire extinguishing equipment was inspected during the site

walkover and noted to be within service dates.

Fire Extinguisher at the Feed Preparation Plant – Within

Service Dates

None.


WSP June 2019

Page 13


8. MONITORING

8.01 Monitoring should be done as indicated by the relevant

authorities.

C According to Sasol’s Environmental Compliance Specialist, the

monitoring completed is as per the requirements in the AEL and

IWWMP.

Monitoring of surface and groundwater, and emissions monitoring

measures, are in place and was observed by the auditor during the

site inspection.

None.

9. REPORTING

9.01 Records relating to the compliance/non-compliance with the

conditions of the authorization must be kept in good order.

Such records must be made available on request by this

Department within seven (7) working days of the date of the

written request by the Department for such records.

N/A This audit represents the first required audit for this EA. Prior to

the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this EA was required.

None.

9.02 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 Sections 29,

30 and 31A of the Act.

N/A Statement noted by Sasol. 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 All environmental complaints received from interested and

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

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

Environmental Department. Complaints are investigated and

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

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

None.


WSP June 2019

Page 14


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

complaints related to the Feed Preparation Plant were recorded for

this audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.

9.04 A complaint register must be kept up to date for inspection

by members of this Department. C All environmental complaints received from interested and

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

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

Environmental Department. Complaints are investigated and

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

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

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

complaints related to the Feed Preparation Plant were recorded for

this audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.

None.


WSP June 2019

Page 15

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 3

below.

Table 3: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 6 2 0 4

ESTABLISHMENT OF THE ENTERPRISE 3 0 0 3

CONSTRUCTION & OPERATION 2 1 0 1

AIR POLLUTION 1 1 0 0

WATER POLLUTION 2 1 0 1

WASTE MANAGEMENT 1 1 0 0

RISK ASSESSMENT 2 2 0 0

MONITORING 1 1 0 0

REPORTING 4 2 0 2

Total Count 22 11 0 11

Total Percentage - 50% 0% 50%

Percentage Compliance with Applicable Conditions 100%


WSP June 2019

Page 16

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

the total proportion of compliance for the facility.

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

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

0

1

2

3

4

5

6

7

Sectional Count Contribution

C

NC

N/A

11

0

11

Total Compliance

C

NC

N/A


WSP June 2019

Page 17

Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total

percentage compliance for the facility.

Figure 4: Percentage contribution of findings made to the EA conditions per Section

Figure 5: Overall percentage findings on compliance to the EA conditions

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

50%

0%

50%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(16.4.28.34 EV1)