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SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
16/4/4/L/2001/15 - CA99 LOADING ZONE
27 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
16/4/4/L/2001/15 - CA99 LOADING ZONE
SASOL CHEMICAL OPERATIONS:
SOLVENTS DIVISION
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
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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:
16/4/4/L/2001/15
Draft v2 for Review –
Compliance Audit
EA Ref:
16/4/4/L/2001/15
Final – Compliance
Audit
EA Ref:
16/4/4/L/2001/15
Date April 2019 June 2019 June 2019
Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher
Signature - -
Checked by Ashlea Strong Ashlea Strong Ashlea Strong
Signature
Authorised by Jenny Cope Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534 41101534
Report number 028 028 028
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
-
Bronwyn Fisher
Environmental Consultant
REVIEWED BY
Ashlea Strong
Principal Consultant
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf
and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding
of their compliance with the conditions included in the Environmental Authorisation 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 Specialist: Environment Broni van der Meer
Solvents Production Senior Manager Alfie Naidoo
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Bronwyn Fisher
ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 CA99 Loading Zone (SASOL CHEMICAL
OPERATIONS: SOLVENTS DIVISION)
(Authorisation Number: 16/4/4/L/2001/15 .............. 1
2 AUDIT SCOPE ........................................... 3
3 AUDIT METHODOLOGY ........................... 4
3.1 Audit Checklist ........................................................ 4
3.2 Site Inspection ......................................................... 4
3.3 Documentation Considered ................................... 4
3.4 Audit Compliance Assessment .............................. 5
3.5 Audit Team ............................................................... 6
3.6 Assumptions and Limitations ................................ 6
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 25
5.1 Environmental Exemption .................................... 25
5.2 Environmental Management Plan ........................ 28
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 17
TABLE 4: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 25
TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 28
FIGURES
FIGURE 1: LOCATION OF THE CA99 LOADING ZONE ON THE SASOL SECUNDA COMPLEX (SOURCE: GOOGLE EARTH, 2018) ............... 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 26
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 26
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 27
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 27
FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 28
FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 29
FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 29
ENVIRONMENTAL EXEMPTION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION
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FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 30
APPENDICES
A ENVIRONMENTAL EXEMPTION (16/4/4/L/2001/15)
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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 Exemption (Reference number: 16/4/4/L/2001/15 issued on 7 February 2002) as well as the
associated Environmental Management Plan (dated May 2002) for the period December 2014 to February 2019.
1.2 CA99 LOADING ZONE (SASOL CHEMICAL
OPERATIONS: SOLVENTS DIVISION)
(AUTHORISATION NUMBER: 16/4/4/L/2001/15
An Environmental Exemption (Reference number: 16/4/4/L/2001/15) was granted on 7 February 2002 by the
Mpumalanga Department of Agriculture, Conservation and Environment (MDACE) for the establishment of a
new loading zone for Crotonaldehyde (CA).
The CA loading rack was commissioned in 2002 to replace the old loading facility. The loading bay is located in
road L2, within the Sasol Solvents operational area (Figure 1). The CA loading bay became the main loading
point for the CA. The facility is a drive-through facility, where iso-containers enter from the east of the loading
bay and exit to the west. The facility comprises an automated loading arm and fire suppression system.
It is noted that in 2010 Sasol stopped producing CA 99%. The loading zone is now used for the adhoc loading
of Ethylol99.
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Figure 1: Location of the CA99 Loading Zone on the Sasol Secunda Complex (Source: Google Earth, 2018)
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2 AUDIT SCOPE The 7 April 2017 amendment to the Environmental Impact Assessment (EIA) regulations introduced the
requirement for the auditing for all EAs and EMPrs in effect on 8 December 2014 and submission of audit
reports to the Department of Environmental Affairs (DEA) by 7 December 2019 and every five years thereafter.
This audit is designed to meet the requirements of Regulation 34 of the EIA Regulations, 2014.
The audit period runs from December 2014 to February 2019, therefore any construction related conditions that
would have been relevant pre-December 2014 are considered not applicable (outside audit period).
The objective of the audit was to:
— Assess the level of compliance with the conditions of the Exemption 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;
— Make recommendations in order to achieve compliance in terms of the Exemption and EMPr; and
— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically
— “Records relating to the compliance/non-compliance with the conditions of the authorisation must be
kept in good order. Such records must be made available on request by this Department.”
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the Exemption 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 Exemption 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 Exemption and EMPr compliance audit (Section 4).
3.2 SITE INSPECTION
Bronwyn Fisher 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:
— Simon Malinga (Production Foreman);
— Hans Schnetler (Process Maintenance Co-ordinator).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— 16.4.4.L.2001.15_ROD_2002-02-07;
— EMP_CA Load Zone_Aspect reg_2002-05-21;
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals Operations;
— EA_EX Handover_SCO_Solvents_CWU_EA;
— Compliance_SOX Provisions_Secunda Complax.dox;
— AEL Sasol Solvents 0017-2015-F02 (2015);
— Air Pollution license;
— SCO Atmospheric Emission Monitoring Schedule;
— Fugitive Emission Monitoring Plan_2018-10-18 updated;
— Compliance_Water_Secunda Complex.dox;
— Induction Mod3_Environment;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;
— 3.05_RESM Weekly Monitoring_2004-2019;
— 3.05_GW_Report _Prj6143_2018-06-19;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
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— CWU East_2014-10-27;
— Environmental Complaints Register_2019-02-18;
— Line-up of Off-loading to COSH line (Propanol Plus and NACs);
— Line-up of Propanol Plus Off-loading to 256TK-0148;
— SOP Bottom Loading of Road Tankers Draft May 2015 (2) (002); and
— Various email correspondence.
3.4 AUDIT COMPLIANCE ASSESSMENT
WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and Table 3). The
checklist included the conditions and associated requirements as specified in the Exemption and associated
EMPr.
Where conditions are not directly specified within documentation, for instance within older EMPrs that were
compiled and submitted as Aspect Registers, auditable conditions have been defined by utilising either
mitigation measures or aspects that were defined within the EMPr. In some instances this has required the minor
re-wording of original text contained within the EMPr, in order to specify an auditable condition. WSP has used
its professional expertise and independence to ensure that such interpretation of wording is both auditable and
balanced.
Each condition was verified, either by reviewing documentation, interviewing employees and/or visually
inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with
associated target completion dates included.
It should be noted that some of the Exemption 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 Exemption 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).
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3.5 AUDIT TEAM
The auditor, Bronwyn Fisher, was hosted by Broni van der Meer and Simon Malinga to whom we express our
gratitude for their time and attention during our visit. A brief summary of the external auditors’ experience is
provided below.
— Auditor: Bronwyn Fisher
Bronwyn Fisher has 6 years of experience as an Environmental Consultant, undertaking Environmental
Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental
Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and
undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel
storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,
recycling facilities, mixed-use developments, industrial developments and renewable energy technology
projects.
— Lead Auditor and Quality Assurance: Ashlea Strong
Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature
Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental
Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic
expertise on a diverse range of projects in the environmental management field, including environmental
scoping and impact assessment studies, environmental management plans, waste and water management, as
well as the provision of environmental management solutions and mitigation measures. She has been
involved in the management of a number of large EIAs within South Africa and has environmental auditing
and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed
in the audit process.
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a
range of sectors. Jenny’s recent experience includes completion and management of several pan-European
and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and
providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in
environmental consultancies and with a developer, giving context to understanding the practicalities of
implementing recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
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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
1. GENERAL CONDITIONS
1.01 This exemption refers only to the project specified above
and described in the Record of Decision, hereafter
referred to as "the interface project" or development".
Separate application/s must be lodged for any other
development and/or activity at or near proposed
development, which is covered by Section 21 and 22 of
the Environment Conservation Act, No. 73 of 1989 Act
and Government Notice R1182 and R1183 of 5
September 1997.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
1.02 Exemption is only granted in terms of Section 28A of the
Environment Conservation Act, No. 73 of 1989 and does
not exempt the holder from compliance with any other
relevant legislation.
N/A Noted. A full legal review does not form part of the scope of this
audit.
The site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review, which specifically
states “the development of the compliance risk management
protocol (CRMP) to assist the organization to reach a higher level
of legal compliance is commendable”.
Evidence:
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals
Operations
None.
1.03 No development may take place on the area of concern
without the necessary permits/approvals and/or service N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
and/or lease agreements, where it is relevant, from or
between the following institutions:
1.3.1 Highveld Ridge Municipality (for the records)
1.3.2 DWAF
1.04 This Department may change, add or amend any of the
conditions in this exemption if, in the opinion of the
Department, it is environmentally justified.
N/A Noted. Sasol advised the auditor that, to their knowledge, the
Department has not added or amended any of the conditions within
this authorisation.
None.
1.05 A copy of this authorization shall be available at Sasol
Solvents Secunda, at all times and all staff, contractors,
contractors and sub-contractors shall be acquainted with
the contents of this exemption.
C Copies of all authorizations and licences are sent to, and details
communicated with, relevant business units. Copies of these
documents are also available at the SHE: Environment department
and on SAP EC and SharePoint. Sasol provided the auditor with
the evidence that the responsible persons, Alfie Naidoo (Senior
Manager of Chemical Workup and Ethyl Acetate) and Willem
Jacobs (legal appointee of Solvents), were made aware of the
Exemption in September / October 2016.
Evidence:
— EA_EX Handover_SCO_Solvents_CWU_EA
None.
1.06 The content of this exemption must be made known to all
interested and affected parties within 14 days from the
date of this exemption.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.07 All mitigation measures and recommendations as laid
down in the Motivational Letter and recommendations
made by other institution are binding and must be adhered
to as part of the Environmental Management Plan.
NC Sasol has confirmed that a copy of the Motivational Letter
submitted to the MDACE is not available.
It is inherent in this condition that the measures and
recommendations as laid down in the Motivational Letter form part
of the Environmental Management Plan. The EMPr is audited in
Table 4. Full compliance with the EMPr, by default, infers
compliance with the mitigation measures and recommendations of
the Letter. However, a non-compliance with the EMPr was
observed, and given the Motivational Letter cannot be cross-
In the absence of the
Motivational Letter, it
should be ensured that all
conditions of the EMPr are
fully complied with.
Target Completion:
Medium term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
checked, it cannot be concluded that all mitigation measures and
recommendations are adhered to.
2. ESTABLISHMENT OF THE ENTERPRISE
2.1 This exemption is repealed if the development has not
taken place within 2 years from the date of this
exemption.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2.2 If the decision is taken to close down the facility, sell
and/or transfer ownership of the infrastructure, this
Department must be informed of such decision at least 12
months prior the date of closure or transfer of ownership.
N/A Noted. Sasol advised that there are no plans to make this site
redundant in the foreseeable future. It is however noted that it is no
longer used for the loading of CA 99, it is still in use for the
loading of other products produced onsite.
None.
2.3 In case of closure of the site, this Department shall
evaluate, monitor and approve the clearing and
rehabilitation of the site.
N/A Noted. Sasol advised that there are no plans to make this site
redundant in the foreseeable future. Whilst the facility is no longer
used for the loading of CA 99, it is still in use for the loading of
other products produced onsite.
None.
3. CONSTRUCTION AND OPERATION
3.1 If any changes need to be made to the development or
associated infrastructure, this Department must be
informed thirty (30) days in advance to decide whether
the change will need authorization.
N/A Noted. Sasol advised the auditor that no changes have been to the
development or associated infrastructure. Whilst the facility is no
longer in use for the loading of CA 99, it is still in use for the
loading of other products produced onsite, and no significant
changes to process or infrastructure were required.
None.
3.2 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 site.
C The auditor was advised that due to being listed on the New York
Stock Exchange, Sasol adheres 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. The environmental and asset
retirement obligations for both SSO and SCO is therefore a
liability provision for closure purposes and not for any activities
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
regarded as operational costs. 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:
— Compliance_SOX Provisions_Secunda Complax.dox
3.3 Upon completion of the associated infrastructures, all
excess construction material should be disposed of in a
registered landfill site.
N/A Noted. This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
4. AIR POLLUTION
4.01 Air pollution should be handled as indicated by relevant
authorities. Any emissions must be permitted by CAPCO. C Sasol had a registered certificate (APPA) for the Alpha Olefins
Plant (certificate number: 1308/5) issued on 11 March 2002. This
was then converted to an Atmospheric Emissions Licence (AEL),
with the promulgation of the National Environmental
Management: Air Quality Act (Act No. 39 of 20014) which
required the conversion from APPA to an AEL.
The Gert Sibande District Municipality issued an Atmospheric
Emissions Licence for the Sasol Solvents Operations (Reference:
11/19/1 Govern Mbeki Sasol South Africa (Pty) Ltd
0017/2015/F02) in March 2015. The AEL covers all Solvent
Operations at the Sasol Secunda Complex.
Evidence:
— Air Pollution license;
— AEL Sasol Solvents 0017-2015-F02 (2015).
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
5. WATER POLLUTION
5.01 It is the responsibility of the applicant and the relevant
contractor on site to prevent air pollution and any
pollution of the surface as well as groundwater.
C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which aims to identify the activities related to Sasol’s
operations within the context of the receiving environment (with a
focus on water resource protection), identify the risks associated
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management.
The auditor noted the following precautions that have been put in
place to prevent surface and ground water pollution:
— The entire loading zone is and hardsurfaced;
— The loading zone has a dedicated OWS to ensure any spillage
and stormwater is drained to the API dam;
— Sasol have developed a number of procedures for managing
the loading and offloading activities at this loading zone;
— Surface and groundwater monitoring is completed in
accordance with the IWWMP.
In addition, all staff, contractors and visitors are provided with
induction training, which includes prevention of pollution of the
environment.
Evidence:
— Compliance_Water_Secunda Complex.dox;
— Induction Mod3_Environment;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;
— Line-up of Off-loading to COSH line (Propanol Plus and
NACs);
— Line-up of Propanol Plus Off-loading to 256TK-0148;
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Loading Bay Production Training Document (LMqadi);
— Propanol Plus Loading Line-Up;
— SOP Bottom Loading of Road Tankers Draft May 2015 (2)
(002).
5.02 In case of non-compliance with section 19 of the National
Water Act, 1998 (Act 36 of 1998), the applicant will be
responsible to remedy the effects of pollution.
N/A Noted. Sasol advised the auditor that, to their knowledge, the
loading operations have not resulted in pollution of the
surrounding environment. The auditor reviewed the incidents
register and confirmed that no incidents of spillage during the audit
period were recorded. It is noted that in February 2019 the Sasol
Emergency Management responded to a product spill on road 2 L
leading up in road 29, where a decanted oil spilled onto the road.
Emergency management traced the spill to Averda’s yard.
Responders determined that the possible cause was due to a valve
that was leaking, while the individual was driving the chemical
truck. Although it is in close proximity to the loading zone, the
spill was not as a result of the loading zone activities.
Evidence:
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18.
None.
6. WASTE
6.01 All waste generated during the construction and/or
operation of the development shall be stored, handled and
disposed of in an environmentally acceptable way.
C The auditor was advised that waste management is carried out via
implementation of a Waste Management procedure (SGR-SHE-
000017 REV10) that addresses the approach to manage waste in
line with the internationally accepted waste hierarchy, whereby
disposal to land is considered the last management option to
undertake once avoidance, re-use, recycling, recovery and
treatment options have been considered / eliminated. The
procedure further details waste disposal and management through
characterization and classification that is detailed in site-specific
waste registers.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Waste Registers were made available to the auditor. A sample of
the registers specifically related to the Solvent operations were
checked during the audit. It is however noted that little to no waste
is produced at the loading zone.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09
— CWU East_2014-10-27
7. RISK ASSESSMENT
7.01 Fire extinguishing equipments should be available at the
site at all times.
C During the site walk over the auditor noted that there was a fire
suppression system installed at the loading zone.
Evidence:
The red pipes at the loading zone indicate the deluge system
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
8. MONITORING
8.01 Records of monitoring must be made available for
inspection of any relevant authorities inspecting the
development.
C Sasol advised the auditor that monitoring associated with the Tank
is limited to surface water and groundwater monitoring; as well as
fugitive air emission monitoring (specifically VOC) through the
use of leak detection monitoring.
Surface water monitoring is conducted on a weekly basis as well as
real time for the various Receiving Environmental Surface water
Monitoring points (RESMs).
Groundwater monitoring is conducted biannually and quarterly for
the various Receiving Environmental Groundwater Monitoring
points (REGMs).
The November 2017 Water Quality Monitoring Report compiled
JMA Consulting, dated November 2017, was provided to the
auditor to review. The report confirmed the number of sampling
points and the frequency in which they are sampled.
VOC leaking from the process equipment is conducted by a third
party in line with USEPA Method 21. A minimum of 100 000
points are sampled per year. Leak detection monitoring on tanks is
carried out once every three years (in line with USEPA Method
21), or after leaking equipment is repaired.
Evidence:
— 3.05_GW_Report _Prj6143_2018-06-19;
— 3.05_RESM Weekly Monitoring_2004-2019;
— SCO Atmospheric Emission Monitoring Schedule;
— Fugitive Emission Monitoring Plan_2018-10-18 updated.
This condition cannot be
rectified.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
9. REPORTING
9.01 Records relating to the compliance/non-compliance with
the conditions of the authorisation must be kept in good
order. Such records must be made available on request by
this Department.
N/A This audit represents the first required audit for this Exemption.
Prior to the introduction of the 7 April 2017 amendment to the
Environmental Impact Assessment (EIA) regulations, no audit
against this Exemption was required.
None.
9.02 Non-compliance with, or any deviations from the
conditions as set out in the Record of Decision, is
regarded as an offence and, after reasonable provision has
been made for remedial action, will be dealt with in terms
of section 29, 30 and 31A of the Act.
N/A Noted. Sasol have advised the auditor that they are aware of this
condition.
None.
9.03 Any complaint regarding the said development must be
brought to the attention of this office within 24 hours after
receiving the complaint.
C The auditor has reviewed the complaints register maintained by
Sasol. No complaints have been received in relation to the
operating of the loading zone for the audit period.
Evidence:
— Environmental Complaints Register_2019-02-18
None.
9.04 A complaint register must be kept up to date for
inspection by members of this Department. C The auditor has reviewed the complaints register maintained by
Sasol. No complaints have been received in relation to the
operating of the loading zone for the audit period.
Sasol have advised that should a copy of the complaints register be
requested by the relevant Department, it will be made available.
Evidence:
— Environmental Complaints Register_2019-02-18
None.
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Table 3: Audit Findings – Environmental Management Plan
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1. CONSTRUCTION AND PRE-COMMISSIONING
1.1 Transportation of feed to plant (Pipeline) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.2 Disposal of Construction wastes. To include any wastes from
spray painting, welding, grinding, cutting of pipes, storage of
cement/ grease, oils and paints and during mixing of
concrete. (responsibility of contractor. Will be included in
contract)
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.3 Disposal of packaging material. (responsibility of
Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.4 Routing/ disposal/ re-use/ storage of excavated materials/
soils. (Dolerite will be used. Take samples of the soil and
dispose of it accordingly)
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.5 Disposal/ re-use of building rubble and other wastes.
(Responsibility of Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.6 Handling and disposal of contaminated equipment.
(Existing piping will be disposed according to correct
procedure.)
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.7 Handling/Storage/disposal of redundant piping and
equipment (clean according to correct procedure) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.8 Disposal of domestic waste (Responsibility of Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.9 Spillage of fuel and oil during the use of electricity
generators. (Responsibility of Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.10 Disposal/ routing of water used for circulation (wet run).
(Test deluge) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.11 Emissions from electricity generators. (Responsibility of
Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.12 Labour and employment required. (Responsibility of
Contractor) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.13 Dolorite mining permit required. (Permit needed) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.14 Permit required for TLC/CAPCO/Transport/ Excavations
etc. (Excavations permit required) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.15 Emergency response plan for major loss of contaminant in
the plant (with consideration of air, groundwater, soil and
surface water).
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.16 Emergency response for clean-up measures. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.17 Pressure on infrastructure/ roads and services due to
increased workforce. Turning circle to be moved. Talk to
traffic department.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2. OPERATING MAINTENANCE AND SHUTDOWN
2.1 Transportation of feed to the plant (pipeline). C Sasol provided the auditor with the following operating procedures
for the loading zone:
— Line-up of off-loading to COSH line (Propanol Plus and
NACs)
— Line-up of Propanol Plus Off-loading to 256TK-0148
— SOP Bottom Loading of Road Tankers
Sasol advised the auditor that these procedures are provided to all
individuals who operate the loading zone through task specific
training and task observations.
Evidence:
— Line-up of off-loading to COSH line (Propanol Plus and
NACs)
— Line-up of Propanol Plus off-loading to 256TK-0148
— SOP Bottom Loading of Road Tankers Draft May 2015 (2)
(002)
None.
2.2 Disposal/ routing of off- spec by-products and products
(when isocontainer is contaminated). N/A No off-spec product reaches the loading zone and therefore
condition is not applicable.
OFI:
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant (including
decommissioning).
Target Completion:
Medium term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.3 Handling and disposal of contaminated equipment. N/A It is noted that contaminated equipment will only be disposed of
when the plant becomes redundant. Sasol advised the auditor that
there are no plans to decommission the loading zone for the
foreseeable future.
When required all equipment that is removed from site will be sent
to the Redundant Materials Management (RMM). The auditor was
advised that the equipment would be washed prior to being sent to
the RMM.
None.
2.4 Stormwater management (routing of on- spec/ contaminated
storm water). Stormwater will be kept in sump and
incinerated. Calculate water to be incinerated.
C During the site walkover Sasol advised the auditor that the
drainage of all the stormwater run-off from Solvents is routed to
the API Oily Water System (OWS) as part of the formal runoff
drainage within the Primary Area. This includes clean storm water
from the Chemical Work Up area. The effluent and contaminated
run-off collected in the OWS reports to the API dams and is
eventually treated at the Water Recovery Plant.
Evidence:
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
Oily Water Sump located within the loading zone.
OFI:
The wording of the aspect
register with regards to the
incineration of water is
unclear. It is recommended
that the Aspect Register is
reviewed to provide clarity
with regards to stormwater
management.
Target Completion:
Medium Term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.5 Disposal/ routing of water used for circulation (wet run).
Test monthly. NC During the site walkover, Sasol advised the auditor that all water
used for the monthly wet run is disposed of in the OWS. No
evidence of monthly testing was available.
Evidence:
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
Ensure water is tested
monthly in line with the
condition, or the Aspect
Register is amended.
Target Completion:
Medium Term
2.6 Disposal of used potable water. Eyewash and safety showers
facilities. Water goes to sump. C The loading zone does not have a site-specific eyewash or safety
showers area. This is located within the Chemical Work Up
operational area. Used potable water drains to the OWS.
None.
2.7 Disposal/ routing of firewater. Go to sump. C Sasol advised the auditor that firewater used at the loading zone
drains to the OWS.
Evidence:
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
None.
2.8 Disposal of water used for hydro testing. Go to sump and
then incinerator. N/A Sasol advised the auditor that hydro testing is not undertaken as
part of the operational activities at the loading zone. This condition
is therefore considered not applicable.
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant.
Target Completion:
Medium term
2.9 Disposal of water used for flushing. Goes to sump. Same
water that is used for hydro testing. C Sasol advised that water used to flush the loading system goes to
the OWS.
Evidence:
— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.10 Venting of emissions. Closed system. Goes into venting
system. C The auditor noted that the loading bay has a vent arm installed for
vacuum and over pressure protection during offloading and
loading respectively.
The auditor was provided with the U238 Off-loading Bay
Relocation Project Training Document and Procedures (Dated20
August 2018), this document states that when product is loaded
into the road tanker the vapours displaced will be vented through
the 4”vent arm to the atmosphere via 237ME-239 to protect the
tanker from over pressure.
Evidence:
— Loading Bay Production Training Document (LMqadi)
None.
2.11 Incinerator emissions. Verify impact on incinerators
emissions from closed sump content. N/A The loading zone does not comprise an incinerator. This condition
is therefore not applicable.
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant.
Target Completion:
Medium term
2.12 Fugitive emissions. Dry breaks. Therefore no emissions. N/A Sasol advised the auditor that no fugitive emissions are associated
with the loading activities.
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant.
Target Completion:
Medium term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
2.13 Gas pressure testing of equipment. Iso-containers being
pressure tested with low pressure nitrogen. C Sasol advised the auditor that low pressure nitrogen is used to
pressure test the iso-containers.
None.
2.14 Emissions from effluent from loading/ off- loading/ disposal
of feed/ chemicals etc. This is to be a closed system, with the
exception of PSV to atmosphere.
N/A Sasol advised the auditor that effluent is not loaded or offloaded at
the loading zone. This condition is therefore not applicable.
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant.
Target Completion:
Medium term
2.15 Venting of purge gas (N2 etc) to vent system. C The auditor noted that the loading bay has a vent arm installed for
vacuum and over pressure protection during offloading and
loading respectively. It is understood purge gas would also route
via the vent arm.
The auditor was provide with the U238 Off-loading Bay
Relocation Project Training Document and Procedures (Dated20
August 2018), this document states that when product is loaded
into the road tanker the vapours displaced will be vented through
the 4”vent arm to the atmosphere via 237ME-239 to protect the
tanker from over pressure.
Evidence:
— Loading Bay Production Training Document (LMqadi)
— Propanol Plus Loading Checklist (7 Sep 2018)
None.
2.16 Measuring of emissions and method. N/A Sasol advised the auditor that emissions are not monitored at the
loading zone as it is not required due to the nature of the activities
being undertaken. This condition is therefore not applicable.
Sasol should revise the
aspect register and remove
conditions that are not
deemed applicable at any
stage during the life of the
plant.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Target Completion:
Medium term
2.17 Loading at night. N/A It is understood that no loading or off-loading is undertaken at
night.
None
2.18 Handling/ Storage/ disposal of redundant piping and
equipment. N/A Sasol advised the auditor that there are no plans to decommission
the loading zone for the foreseeable future.
None.
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL EXEMPTION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the Exemption conditions are as listed in Table
4 below.
Table 4: Summary of Exemption Compliance Audit Findings
SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 7 1 1 5
ESTABLISHMENT OF ENTERPRISE 3 0 0 3
CONSTRUCTION AND OPERATION 3 1 0 2
AIR POLLUTION 1 1 0 0
WATER POLLUTION 2 1 0 1
WASTE 1 1 0 0
RISK ASSESSMENT 1 1 0 0
MONITORING 1 1 0 0
REPORTING 4 2 0 2
Total Count 23 9 1 13
Total Percentage 39% 4% 57%
Percentage Compliance with Applicable Conditions 90%
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Figure 2 illustrates the number/count contribution of the findings of the Exemption per section while Figure 3
presents the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the Exemption conditions per Section
Figure 3: Overall count findings on compliance to the Exemption conditions
0
1
2
3
4
5
6
7
8
Sectional Count Contribution
C
NC
N/A
9
1
13
Total Compliance
C
NC
N/A
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Figure 4 illustrates the percentage contribution of the findings of the Exemption conditions. Figure 5 presents
the total percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the Exemption conditions per Section
Figure 5: Overall percentage findings on compliance to the Exemption conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
39%
4%
57%
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 EMPr conditions are as listed in Table 5
below.
Table 5: Summary of EMPr Compliance Audit Findings
SECTION OF THE EMPR NO. COMMITMENTS C NC N/A
CONSTRUCTION AND PRE-COMMISSIONING 17 0 0 17
OPERATING MAINTENANCE AND SHUTDOWN 18 8 1 9
Total Count 35 8 1 26
Total Percentage 23% 3% 74%
Percentage Compliance with Applicable Conditions 89%
Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7
presents the total proportion of compliance for the facility.
Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section
0
2
4
6
8
10
12
14
16
18
20
Construction and Pre- Commissioning Operating Maintenance and Shutdown
Sectional Count Contribution
C
NC
N/A
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Figure 7: Overall count findings on compliance to the EMPr conditions
Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the
total percentage compliance for the facility.
Figure 8: Percentage contribution of findings made to the EMPr conditions per Section
8
1
26
Total Compliance
C
NC
N/A
0
10
20
30
40
50
60
70
80
90
100
Construction and Pre- Commissioning Operating Maintenance and Shutdown
Sectional Percentage Contribution
C
NC
N/A
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Figure 9: Overall percentage findings on compliance to the EMPr conditions
5.2.1 EFFECTIVENESS OF THE EMPR
Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy
and effectiveness of the EMPr as part of the audit scope, as follows:
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
achieve the objectives and outcomes laid out in these documents;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Critically evaluate the effectiveness of the EMPr;
— Identify shortcomings in the EMPr; and
— Identify the need for any changes to the avoidance, management and mitigation measures provided for in
the EMPr.
The EMPr compliance audit has identified that approximately half of the listed measures are no longer
applicable, as these mostly related to the planning and construction phases 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 Exemption,
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 Exemption 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.
23%
3%
74%
Total Percentage Compliance
C
NC
N/A
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In conclusion, WSP considers that for the duration that Sasol continues to operate each business unit under ISO
14001 standards and meet licence compliance (Exemption, 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 EXEMPTION
(16/4/4/L/2001/15)