sasol secunda complex: materials management … · 5/16/2019 · 1.2 redundant materials...

SASOL SECUNDA COMPLEX: MATERIALS MANAGEMENT

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.17 EV 40 - REDUNDANT MATERIALS MANAGEMENT (ESTABLISHMENT OF A RECLAMATION YARD)

16 MAY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.17 EV 40 - REDUNDANT MATERIALS MANAGEMENT (ESTABLISHMENT OF A RECLAMATION YARD)

SASOL SECUNDA COMPLEX: MATERIALS

MANAGEMENT

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: MAY 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:

17.2.17 EV40

Draft V.2 –

Compliance Audit

EA Ref:

17.2.17 EV40

Final report –

Compliance Audit

EA Ref:

17.2.17 EV40

Date April 2019 May 2019 May 2019

Prepared by Ashlea Strong Ashlea Strong Ashlea Strong

Signature

Checked by Jenny Cope Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 019 019 019

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

Ashlea Strong

Principal 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

Materials Management Production

Senior Manager, Sasol Supply Chain

Johan Fouche

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Auditor Mpendulo Dlamini

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL SECUNDA COMPLEX: MATERIALS MANAGEMENT

WSP May 2019

TABLE OF CONTENTS

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

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

1.2 Redundant Materials Management (Authorisation

Number: 17.2.17 EV40) ............................................ 1

2 AUDIT SCOPE ........................................... 3

3 AUDIT METHODOLOGY ........................... 4

3.1 Audit Checklist ........................................................ 4

3.2 Site Inspection ......................................................... 4

3.3 Documentation Considered ................................... 4

3.4 Audit Compliance Assessment .............................. 5

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 24

5.1 Environmental Exemption .................................... 24


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 24

FIGURES

FIGURE 1: REDUNDANT MATERIAL MANAGEMENT LAYOUT (SOURCE: GOOGLE EARTH, 2016) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 25

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 25

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 26

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 26

APPENDICES

A ENVIRONMENTAL EXEMPTION (17.2.17 EV40)


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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: 17.2.17 EV40 issued on 23 March 2005) for the period

December 2014 to February 2019.

1.2 REDUNDANT MATERIALS MANAGEMENT

(AUTHORISATION NUMBER: 17.2.17 EV40)

The Redundant Materials Management (RMM) area (Reclamation Yard) of Sasol Secunda is used for the

handling of obsolete materials that are unrequired by Sasol businesses and are sold/disposed of through a service

provider. An Exemption in terms of Section 28A of the Environmental Conservation Act (No. 73 of 1989)

(ECA) with conditions set out in an attached Record of Decision (RoD) was received from the Mpumalanga

Department of Agriculture and Land Administration (MDALA) on 23 March 2005 (Reference Number: 17.2.17

EV40) (Appendix A).

The site is legally permitted to handle metals, steel, plastic drums and containers, conveyer belting, motor

vehicle tyres, instrumentation equipment, electric cables, plastics, wood, furniture, housing units and vehicles.

Directions in terms of Section 20 were also received from the Department of Water Affairs and Forestry

(DWAF) on 17 March 2005 (Reference Number: 16/2/7/C121/B/028), however these conditions do not form

part of the scope of this audit.

The site is identified by the Department of Water Affairs and Forestry (DWAF) as a temporary waste storage,

reclamation and recycling site. The site is classified by DWAF as Class G:C:B-.

Figure 1 provides an overview of the RMM (Reclamation Yard).


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Figure 1: Redundant Material Management Layout (Source: Google Earth, 2016)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

— Ensure the commitments contained in Condition 8.01 of the Exemption are completed, more specifically:

— “Records relating to the compliance or non-compliance with the conditions of this Exemption must be

kept in good order. Such records must be made available to this Department within seven (7) working

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


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

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

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

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (25 March 2019);

— Review of documentation relevant to the conditions of the Exemption (e.g. records,

permits/certificates/maintenance logs/monitoring results/previous reports etc.); and

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Environmental Consultant, Mpendulo Dlamini, conducted the site inspection on 25 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:

— Manager, Redundant Materials Management: Pieter Carter.

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— 1.03_EX_Direction_16.2.7.C121.B.028_2005-03-17;

— 1.03_EX_DWAF Reasons_16.2.7.C121.B.028_2004-11-12;

— 1.03_2nd Hand Goods Cert;

— 1.06_EX_Minutes ROD Discussion_17.2.17_2005-04-11;

— 1.06_EX_Reclamation yard_Appl for exemption_2004-08-13;

— 3.01_Declaration of scrap example;

— IWWMP SIC 2015 Final_2018-05-15;

— 3.06_EX_Storm water management report_RMM_2016-11-24;

— Sasol Compliance Statement – Water

— 3.05_RESM Weekly Monitoring_2004-2019

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

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

— 7.01_ERA-SCSS-RMM-BvdM 2015-11-03

— 7.01_Emergency Management Plan

— 5.01_EX_Storm water management report_RMM_2016-11-24;

— Sasol Compliance Statement – Complaints;

— Environmental complaints procedure_SGR-SHE-000022_Rev04_2015-08;


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— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01;

— Environmental Complaints Register_2019-02-18;

— Onsite Checks; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the Exemption.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

Environmental Consultant, Mpendulo Dlamini, was hosted by Broni van der Meer, Pieter Carter and Johan

Erasmus to whom we express our gratitude for their time and attention during our visit. A brief summary of the

external auditors’ experience is provided below.

— Auditor: Mpendulo Dlamini

Mpendulo has 5 years’ experience and is a multi-disciplined individual who completed his double major BSc

Environmental Science degree (Life Science and Environmental Science) at the University of KwaZulu-Natal

in 2014. He then further completed his BSc Honours Environmental Science (Spatial Epidemiology Research)

in 2015 at the same institution. Mpendulo has had exposure in the following sectors; oil and gas,

environmental consulting as well as environmental and public health. As a University Student, he has had

extensive training in biodiversity management and monitoring with a focus in plant science (undergraduate),


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and with Lakes Environment air quality and modelling software as well as environmental GIS and remote

sensing in spatial modelling (Post graduate). He also has experience as an Environmental Control Officer as

well as with working on Water Use License Applications and Integrated Water and Waste Management Plans

(Triplo4 Sustainable Solutions).

— 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 Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This Exemption refers only to the project as specified above.

Separate applications must be lodged for any other

development and/or activity at or near the proposed

development, which is covered by S21 and 22 of the Act and

Government Notice R1182 of 5 September 1997.

N/A Noted None.

1.02 Exemption is only granted in terms of S 28A of the Act and

does not exempt the holder from compliance with other

relevant legislation.

N/A Noted None.

1.03 Ensure that the necessary permits, approvals, service level

agreements where it is relevant from or between the

following institutions’ are in place:-

1.3.1 Govan Mbeki Municipality

1.3.2 DWAF"

C The Auditor noted that all relevant permits, approvals and

agreements are in place for the RMM. These include:

— Second Hand Goods Permit issued by the South African Police

Service (Valid until 01 November 2022); and

— Directions in terms of the Section 20 permit issued by the

Department of Water Affairs and Forestry

The Auditor noted that the Govan Mbeki Municipality currently

holds jurisdiction for the Air Emission Licence (AEL). It is noted

that the activities undertaken at the RMM do not constitute

activities that would require an AEL and therefore no known

permits are required from the Municipality.

Evidence:

— 1.03_EX_Direction_16.2.7.C121.B.028_2005-03-17

— 1.03_EX_DWAF Reasons_16.2.7.C121.B.028_2004-11-12

— 1.03_2nd Hand Goods Cert

None.


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1.04 This Department may change and/or amend any of the

conditions in this exemption if, in the Department's opinion

is environmentally justified

N/A Noted. The Auditor noted that there has been no correspondence

forthcoming from the Department.

None.

1.05 A copy of this Exemption must be made available on site

during construction and all relevant staff, contractors and sub

contractors must be familiar with the contents of this

Exemption.

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

(construction pre-2014).

It is therefore considered not applicable.

None

1.06 The content of this exemption must be made known to all

registered interested and affected parties within 5 days from

the date of issue.



The exemption process was undertaken internally by Sasol. The

Auditor noted a set of minutes dated 11 March 2004 wherein Sasol

noted that a Mpumalanga Department of Agriculture, conservation

and Environment (MDACE) application would be compiled and

that Sasol would apply for exemption from the EIA process as well

as from appointing an independent consultant and public

participation. In addition, the Auditor was provided with the

covering letter to MDACE (dated 13 August 2004) which

accompanied the original application.

Therefore, due to the fact that no public participation was

undertaken, no registered interested and affected parties could be

notified of the exemption.

Evidence:

— 1.06_EX_Minutes ROD Discussion_17.2.17_2005-04-11

— 1.06_EX_Reclamation yard_Appl for exemption_2004-08-13

None.

2. ESTABLISHMENT OF ENTERPRISE

2.01 This exemption is valid for 2 years from the date of issue

and will lapse if construction activities have not taken place

within the allocated time.



Noted.


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2.02 In case of closure the site, the Dept shall evaluate, monitor

and approve the closure and rehabilitation of the site N/A The Auditor noted that there are no plans to close or decommission

the RMM site at this stage.

None.

3. CONSTRUCTION AND OPERATION

3.01 There should be a single controlled entrance to prevent

unauthorised entry. C The Auditor noted that there is a single entry point of access to the

RMM. The access point is security control. All visitors are

required to report to the security office and are issued with an

access permit.

All material delivered to the RMM must be accompanied by the

relevant documentation such as the “Declaration of Scrap and

Dispatch to RMM”. In addition, certain material is required to be

oil free and will require a decontamination certificate. Examples of

both the Declaration of Scrap and Decontamination certificates

were provided to the auditor.

Evidence:

— 3.01_Declaration of scrap example

— Photographic proof provided

Signage displayed at the access gate

None.


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Single controlled entrance to the RMM

3.02 The site must be adequately fenced. C The Auditor noted that the RMM is adequately fenced. The

perimeter is patrolled by security.

Evidence:

— Photographic evidence provided

Adequate Fencing around the site

None.


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3.03 The floors where the material will be stockpiled should be

bunded. C The Auditor noted that there are no bund walls within the RMM.

However, the materials stored on site include vehicles, engines,

electric motors, transformers, air conditioners, zink plates,

conveyor belts, plastic pallrings etc. Materials are stored on

concrete, in waste skips, on pallets (and strapped) or on sleepers.

The Auditor was advised that all items are required to be oil free

prior to acceptance. Items were an oil leak is identified are stored

on drip trays.

It was noted that no scrap is stored on site; it is taken directly to the

scrap dealer.

Evidence:

— Onsite Check – Secondary containment measures:

Storage on Pallets

None


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Vehicles stored on concrete slab

Storage on concrete slab


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Storage undercover with impermeable floor

Storage within skips

3.04 A leachate management plan for the site should be

established N/A Due to the nature of the material stored and the temporary storage

timeframes, the site is unable to produce leachate.

In addition, the Section 20 Directions from the DWS classify the

facility as a GSB- site, which would not produce leachate.

None.


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Evidence:

— 1.03_EX_Direction_16.2.7.C121.B.028_2005-03-17

3.05 The quality of surface and ground water should be

monitored. C Groundwater:

JMA Consulting is an independent contractor appointed to

complete sampling and bi-annual reporting for Sasol. The Auditor

verified that the Groundwater Quality Report compiled by JMA

Consulting. Report number: JMA/Prj6129 Rev-01; Dated:

November 2018 included groundwater monitoring of boreholes

established for the RMM. The RMM has 6 groundwater

monitoring boreholes, 4 of which are monitored biannually.

Surface Water:

The Auditor was provided with evidence that stormwater is

monitored on site during the rainy season.

Sasol conduct weekly surface water sampling across the Sasol

Secunda Complex as verified by the Weekly RESM Monitoring

Spreadsheet.

Sasol monitor the Bossiespruit, Brandspruit Kleinspruit, Klipspruit

and Trichardspruit,

Evidence:



— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-

20

— Groundwater – Boreholes:

None.


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Monitoring boreholes established at the RMM

— Surface Water – RESM Points:

Location of the RESM monitoring points monitored on a

continuous basis

3.06 Storm water drainage should be established to manage

runoff from the site. C The stormwater plan for the RMM is outlined in the Sasol

IWWMP (dated 18 September 2015) and states the following:

“Wastewater from the washing bay, and stormwater run-off arising

at the washing bay is routed from the Redundant Materials Yard

and exit the site towards the north. For the remainder of the area,

None


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stormwater runoff follows the topography. Two (2) small

stormwater collection pits were excavated, one to the north and

one to the east of the Redundant Materials Yard, to serve as a

collection point to obtain samples that will give an indication of

the stormwater quality. Seepage from the Quarry Dam (part of the

Brandspruit Mine of Sasol Mining) impacts on the RMM area,

which give rise to elevated sulphate concentrations observed in

samples taken from the northern stormwater collection pit.

To provide additional storage space for Green Coke, a storage pad

was constructed with concrete walls, which slopes towards the

north-east. The pad is divided into two (2) sections, with the

higher portion used to store the Green Coke, and the lower portion

used to collect run-off from the stored Green Coke. Any runoff

that collects in the lower portion is analysed, and if the quality is

deemed acceptable, it is discharged to the Bossie Spruit via a

sediment trap.”

Additional recommendations regarding the management and

monitoring of the seepage from Quarry Dam were made on 24

November 2016. The Auditor has been informed that these

recommendations have been implemented.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— 3.06_EX_Storm water management report_RMM_2016-11-

24

— On-site Check:


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Stormwater Drains

3.07 If any changes need to be made to the infrastructure this dept

must be informed 30 days in advance to be able to decide

whether the changes need authorisation.

N/A The Auditor was informed that no changes have been made to the

RMM since establishment.

None.


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4. AIR POLLUTION

4.01 Air pollution should be handled as indicated by the relevant

authorities. N/A The nature of the material stored will not result in any air

emissions. It is noted that the activities undertaken at the RMM do

not constitute activities that would require an AEL

Sasol makes use of an integrated approach to air quality

management as governed by National Environmental

Management: Air Quality Act. Sasol works closely with the local

authority and operates units in line with the relevant AEL and

minimum legal emission requirements.

Evidence:

— Fugitive Emission Monitoring Plan_2018-10-18 updated

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 surface as

well as ground water.

C The Auditor has noted that the IWWMP 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:

— Concrete floors are utilised where required;

— A Works Instruction for the Disposal of recyclable and other

redundant materials, assets and equipment (Document

Number: SCSS-MM-000008) has been compiled for the

facility, which requires:

— Material to be oil free prior to acceptance at the RMM;

None


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— Loads to be inspected visually prior to acceptance, in the

event that material is not suitable or adequately cleaned,

material is sent back.

— A decontamination certificate to accompany items where

required.

— Drip trays are utilised where required;

Surface and Ground Water monitoring is in place as described

under Condition 3.5 above. Overall water quality mostly falls

within the SANS 241 water quality standard.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— 3.01_Declaration of scrap example



— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-

20

— Onsite Check:

Vehicles stored on concrete slab


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Storage on concrete slab

Storage within skips

6. WASTE MANAGEMENT

6.01 All waste generated during the construction and/or operation

of the site shall be stored, handled and disposed of in an C The Auditor notes that the construction period for the development

of the township is outside of the Audit Period.

None.


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environmentally acceptable way and as directed by this

Department or any other relevant authority.

All waste generated as a result of the RMM operations is managed

as outlined in Sasol’s Waste Management Procedure (SGR-SHE-

000017).

The Auditor viewed the Waste Management procedure that is in

place, and this provides an 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 characterisation and

classification that is detailed in site specific waste registers.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09

7. RISK ASSESSMENT

7.01 Risk assessment should be handled as indicated by relevant

authorities. C The Auditor was informed that no directions have been forth

coming from the authorities in this regard.

Sasol advised the Auditor that it has a Governance SHE Risk and

Assurance department that assesses environmental risks and drives

implementation by business.

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.

A Procedure was viewed by the Auditor that defines the

requirements, responsibilities, and the process to be followed in the

management, execution, and control of environmental risk

assessments.

The Auditor noted the following risk assessments to be specific to

the RMM:

None.


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— Environmental Risk Assessment – Redundant Materials

Management (03 November 2015);

— Emergency Plan for the RMM

Evidence:

— 7.01_ERA-SCSS-RMM-BvdM 2015-11-03

— 7.01_Emergency Management Plan

8. REPORTING

8.01 Records relating to compliance / non-compliance with the

conditions of this Authorization must be kept in good order.

Such records must be made available to this Department

within 7 work days from the date of a written request for

them.

N/A Prior to the introduction of the 7 April 2014 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required. However, this Audit

represents the second audit for this Exemption. WSP undertook an

initial audit of the facility in 2016.

The Auditor was advised that all records relating to compliance are

stored on the Sasol Sharepoint.

Evidence:

— 5.01_EX_Storm water management report_RMM_2016-11-

24

8.02 Non-compliance with or any deviations from the conditions

of this Authorization is regarded as an offence and after

reasonable provision has been made for remedial action, will

be dealt with in terms of S 29,30 and 31A of the Act

N/A Noted. Sasol has confirmed to the Auditor that no communications

have been received from the Authorities regarding non-

compliances.

None.

8.03 Any complaints regarding the development must be brought

to the attention of this Department 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 available and the

Environmental department. Complaints are investigated and

reported in line with the procedure and as per legal requirements.

None.


WSP May 2019

Page 23


Environmental complaints contact details are communicated to

internal and external stakeholders.

A procedure relating to complaints from stakeholders (SGR-SHE-

000022) has been implemented at the Sasol Secunda Complex.

The complaints and/or incidents register verified by the auditors

confirmed that no complaints have been logged regarding the

RMM during the audit period.

Evidence:

— Sasol Compliance Statement – Complaints

— Environmental complaints procedure_SGR-SHE-

000022_Rev04_2015-08


000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18

8.04 A complaints register must be kept up to date for inspection

by members of this Department C The complaints and/or incidents register verified by the auditors

confirmed that no complaints have been logged regarding the

RMM during the audit period.

Evidence:

— Sasol Compliance Statement – Complaints


000022_Rev04_2015-08


000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITIONS 6 1 0 5

ESTABLISHMENT OF ENTERPRISE 2 0 0 2

CONSTRUCTION AND OPERATION 7 5 0 2

AIR POLLUTION 1 0 0 1

WATER POLLUTION 1 1 0 0

WASTE MANAGEMENT 1 1 0 0

RISK ASSESSMENT 1 1 0 0

REPORTING 4 2 0 2

Total Count 23 11 0 12

Total Percentage 48% 0% 52%

Percentage Compliance with Applicable Conditions 100%

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.


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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

11

0

12

Total Compliance

C

NC

N/A


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Page 26

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

48%

0%

52%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION (17.2.17

EV40)