secunda synfuels operations: powerstation - steam ... · 1. the project entails the 100mw gas...
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SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM
PRODUCTION
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
17.2.22.3 GS 2 - POWER GENERATION FROM WASTE ENERGY
02 AUGUST 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
17.2.22.3 GS 2 - POWER GENERATION FROM WASTE ENERGY
SECUNDA SYNFUELS OPERATIONS:
POWERSTATION - STEAM PRODUCTION
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: AUGUST 2019
WSP
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KNIGHTSBRIDGE, 33 SLOANE STREET
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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: 17.2.22.3
GS 2
Final – Compliance
Audit
EA Ref: 17.2.22.3
GS 2
Date May 2019 August 2019
Prepared by Mpendulo Dlamini Mpendulo Dlamini
Signature
Checked by Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 012 012
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
Mpendulo Dlamini
Consultant
REVIEWED BY
Jenny Cope
Associate
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf and
at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding of their
compliance with the conditions included in the Environmental Authorisation and associated Environmental
Management Plan.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than
the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any
third parties directed to provide information and documents to us by the Client. We have not reviewed any other
documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
CLIENT
SHE: Environmental Compliance
Specialist
Broni van der Meer
Steam Production - Production Senior
Manager
Keith McCulloch
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Mpendulo Dlamini
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION
WSP August 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Power Generation from Waste energy – 17.2.22.3
GS 2 .......................................................................... 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 ...................................... 7
5 SUMMARY OF THE AUDIT FINDINGS ... 32
5.1 Environmental Authorisation ............................... 32
5.2 Environmental Management Plan ........................ 35
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 20
TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 32
TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 35
FIGURES
FIGURE 1: POWER GENERATION – STEAM PRODUCTION PLANT (SOURCE: GOOGLE EARTH, 2018) ............... 2
FIGURE 7: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 33
FIGURE 8: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 33
FIGURE 9: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 34
FIGURE 10: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 34
FIGURE 11: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 36
FIGURE 12: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 36
FIGURE 13: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 37
FIGURE 14: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 37
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION
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APPENDICES
A ENVIRONMENTAL AUTHORISATION (17.2.22.3GS 2)
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1 INTRODUCTION
1.1 TERMS OF REFERENCE
Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP
Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit and
compile an audit report according to the requirements of the National Environmental Management Act (No. 107
of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the
Environmental Authorisation (EA) (Reference number: 17.2.22 3GS 2 issued on 20 February 2008) (as amended)
as well as the associated Environmental Management Plan (dated: May 2007) for the period December 2014 to
February 2019.
1.2 POWER GENERATION FROM WASTE ENERGY –
17.2.22.3 GS 2
An EA was granted on 20 February 2008 by the Mpumalanga Department of Environmental Affairs and Tourism,
for the construction and operation of a power generation plant that utilises waste energy.
Figure 1 provides the location of power station plant situated within Sasol Secunda Primary area.
The power station plant was completed in 2007, and commissioned in 2009. It generates electricity by using two
gas-driven turbines. The plant also provides high-pressure (HP) steam to various consumers in the Sasol Secunda
complex by means of two Heat Recovery Steam Generators (HRSGs).
Each Turbine in the plant generates approximately 105 MW (temperature-dependent), and each HRSG produces
approximately 163 t/h of steam at 41bar pressure and a temperature of 425ºC.
The gas turbine plant consists of the gas turbine auxiliaries and utilities for the process to generate electricity in
the most efficient and environmental friendly manner. Some auxiliaries and utilities are required from various
clients to enable the process; namely an air processing unit, fire protection and detection system, heating and
ventilation systems, HP Nitrogen system, air filter system, lubricant and hydraulic oil systems and lastly efficient
motors and gears.
The heat generated by the plant, drives the turbines and in the process, the shaft drives the compressor and
generator. The electricity generated is then transferred to the 132kV transformers. Waste heat (turbine exhaust
gas) is then used to generate the high-pressure system unit (HPSU) steam.
Fuel gas that drives this plant is the natural gas piped from Mozambique, as well as methane-rich gas from Unit
023 and Unit 223 from the cold separation process.
A correction to the accompanying Record of Decision (RoD) was issued on 10 April 2008 for the following:
1. The project entails the 100MW gas turbines, and not 100MV as indicated on page 2 of the Authorisation
under brief description of the activity; and
2. Clarity is provided pertaining to sewerage infrastructure as per Scoping Report Section 2.3.2 (c) under
brief description that oily water sewer network will be designed such that it can operate independently,
but at the same time can integrate with the existing Synfuels systems for water transfer. No sewerage
will be discharged to Govan Mbeki Local Municipality infrastructure. Sasol operates its own sewerage
treatment plant.
An amendment to the EA was granted on 22 September 2008. The amendment provides for the two comments,
as above.
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Figure 1: Power generation – steam production plant (Source: Google Earth, 2018)
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION
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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 EAs and EMPr;
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr;
— 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 EA and EMPr;
— Ensure the commitments contained in Condition 7.02 of the EA are completed, more specifically:
— “Records relating to compliance / non-compliance with the conditions of the Authorisation must be kept
in good order. Such records must be available to this Department within seven workdays from the date
of a written request from them.”
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the EA and associated EMPr conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (27 March 2019);
— Review of documentation relevant to the conditions of the EA and associated EMPr (e.g. records,
permits/certificates/maintenance logs/monitoring results/previous reports etc.); and
— Compilation of an audit report.
3.1 AUDIT CHECKLIST
WSP compiled an audit checklist to assist with the EA and EMPr compliance audit (Section 4).
3.2 SITE INSPECTION
Mpendulo Dlamini conducted the site inspection on 27 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:
— Martin Le Roux (Area Manager Production);
— Tertius Perelaar (Production Foreman, PS Gas Turbines Production); and,
— Sindi Mapodile (Process Technician II, PS Performance & Gas Turbines).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— 17.2.22.3GS2_2008-02-20;
— 17.2.22.3GS2_2008-04-10;
— 17. 17.2.22.3GS2_2008-09-22_Amended;
— 500981_Final EMPv2_2007 05 17;
— SSO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels operations;
— EA_EX Handover_SSO_PS-Steam;
— Environmental Complaints Register (Period: December 2014 – March 2019);
— 543 Observation Pond Comiddion Checklist;
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;
— Copy of Environment Impact register_ New FY17;
— 500981 - Draft Scoping Report.v3_ed.2007.04.03-1;
— 201810 SSO continuous emission monitoring monthly report_5 December 2018 rev_02;
— 201901 SSO continuous emission monitoring monthly report for January 2019 rev_00;
— 201902 SSO continuous emission monitoring monthly report for February 2019 rev_00;
— IWWMP SIC 2015 Final_2018-05-15;
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— Environment Impact register_ New FY19_2019-02-18;
— Extract from the power generation plant’s maintenance plant (provided via email);
— C.02_Plant Inspections U050;
— C.02_Plant Inspections U250;
— C.02_Plant Inspections U350;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Steam Production_2016-11-07 (waste register); 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 EA 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 EA and associated EMPr conditions were apportioned according to the elements
requiring compliance assessment therein. Although some elements of the condition may have been compliant, if
one of the elements was determined to be non-compliant, the entire condition has been reported as such (and
counted as such during percentage compliance calculation). This apportionment further allowed for the
development of focussed recommendations and timeframes.
Table 1: Compliance Level Definition and Target Completion Dates
COMPLIANCE LEVEL DEFINITION
Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or
relevant actions were implemented.
Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented
according to the requirements of the EA and associated EMPr. Non-complaint conditions are
given target completion dates, as follows:
— Short term: 0 – 6 months.
— Medium term: 6 – 12 months.
— Long term: 12 – 18 months.
Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.
— Conditions marked as “Noted” are considered information points only.
— Where conditions are considered “not auditable” within the scope of this assessment this
is stated and explained within the condition commentary.
Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion
dates).
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3.5 AUDIT TEAM
The Consultant, Mpendulo Dlamini, was hosted by Broni van der Meer, Martin Le Roux, Tertius Perelaar and
Sindi Mapodile; to whom we express our gratitude for their time and attention during our visit. A brief summary
of the external auditors’ experience is provided below.
— Auditor: Mpendulo Dlamini
Mpendulo has 5 years’ experience and is a multi-disciplined individual who completed his double major BSc
Environmental Science degree (Life Science and Environmental Science) at the University of KwaZulu-Natal
in 2014. He then further completed his BSc Honours Environmental Science (Spatial Epidemiology Research)
in 2015 at the same institution. Mpendulo has had exposure in the following sectors; oil and gas,
environmental consulting as well as environmental and public health. As a University Student, he has had
extensive training in biodiversity management and monitoring with a focus in plant science (undergraduate),
and with Lakes Environment air quality and modelling software as well as environmental GIS and remote
sensing in spatial modelling (Post graduate). He also has experience as an Environmental Control Officer as
well as with working on Water Use License Applications and Integrated Water and Waste Management Plans
(Triplo4 Sustainable Solutions).
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a range
of sectors. Jenny’s recent experience includes completion and management of several pan-European and
global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and providing
clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in environmental
consultancies and with a developer, giving context to understanding the practicalities of implementing
recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than
the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any
third parties directed to provide information and documents to us by the Client. We have not reviewed any other
documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts no
liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or in
connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports. Similarly,
any recommendations, statements or conclusions drawn from or based on this report must make reference to this
report. If this report is used as part of a main report, the report in its entirety must be included as an appendix or
separate section to the main report.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
GENERAL CONDITIONS
1.01 This Authorisation refers only to the project as specified
above and described in the Record of Decision. Separate
applications must be lodged for any other development and/
or activity at or near the proposed development, which is
covered by Section 21 and 22 of the Act and Government
Notice R 1182 of 5 September 1997.
N/A Noted. The project remains as per the authorised activities for which
the EA was granted. No additions or alterations have taken place on
or near the project’s location.
Sasol is aware of the requirement to lodge separate applications
should further works be required for the authorised activity.
None.
1.02 Authorisation is only granted in terms of Section 22(3) of the
Act and does not exempt the holder from compliance with
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 specifically
states “the development of the compliance risk management
protocol (CRMP) to assist the organization to reach a higher level
of legal compliance is commendable”.
Evidence:
— SSO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels
operations.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.03 No development may take place without the necessary
permits/ approvals and/ or lease agreements, where it is
relevant, from or between all relevant legislation.
N/A This condition is considered outside of the audit period
(construction pre-2014). The plant is already in operational phase.
The condition is therefore considered not applicable.
None.
1.04 Copies of the documents mentioned in 1.3 above must be in
the possession of this Department before any construction
may commence.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
1.05 This Department may change or amend any of the conditions
in this Authorisation if, in the opinion of the Department, is
environmentally justified.
N/A
Noted.
No changes or amendments have been communicated to Sasol by
the Department since issue of the EA.
None.
1.06 A copy of this Authorisation must be available on site during
construction and all relevant staff, contractors and sub-
contractors must be familiar with the contents of this
Authorisation.
C Sasol’s environmental team have soft copies of the EAs and the
associated EMPrs, 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 Safety, Health &
Environmental (SHE) induction training. Sasol provided the auditor
with the evidence that the responsible persons, Keith McCulloch
(Senior Manager of Steam Production) and Anton Booysen (legal
appointee of Power Station), were made aware of the EA (including
correction by the Department) between September and November
2016.
Evidence:
— EA_EX Handover_SSO_PS-Steam
None.
1.07 The applicant must within five (5) calendar days of receipt of
this Record of Decision (ROD):
a) Advertise the issuing of the Authorisation in the regional
and/ or local newspaper.
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
b) Inform all interested and affected parties registering during
the EIA process of the decision
c) The above must state at least the following:
i) That an Authorisation has been issued to the applicant to
proceed with the construction and operation of the activity;
ii) That any appeals against the issuing of the Authorisation
must be lodged with the MEC for Agriculture and Land
Administration within 30 days from the date on which the
ROD was has been issued to the applicant and at the address
stipulated in the Authorisation;
iii) Include the date on which the ROD was issued to the
applicant and the date by which appeals must reach the MEC;
iv) Indicate where copies of the Authorisation and ROD can
be viewed/ obtained.
1.08 In the event that the predicted impacts exceed the significance
as predicted in the scoping report, this Authorisation may be
withdrawn after proper procedures have been followed.
N/A Noted. None.
1.09 The holder of this Authorisation must ensure compliance with
the conditions of this Record of Decision by any person acting
on his or her behalf, including but not limited to an agent, sub-
contractor, employee or any person rendering a service to the
holder of the Authorisation.
C According to the Area Manager, every person entering the Sasol site
is subject to a SHE induction process to ensure that they are familiar
with the SHE aspects and requirements of that site/plant.
Furthermore, personnel working in different plants undergo Plant
Specific Training prior to being accepted to work in the plant.
Therefore the same applies to the power generation plant, all
employees and people rendering services receive training.
None.
1.10 The holder of the Authorisation must notify the Department
in writing within 24 (twenty-four) hours if a condition of this
Authorisation is not adhered to. Any notification in terms of
this condition must be accompanied by the reasons for the
non-compliance.
C Noted. A complaints and incidents register is kept up to date for
the entire Sasol Secunda Operations. Available records go as far
back as 2008. No complaint has been recorded against the power
generation plan.
Furthermore, no non-compliances were noted during this audit.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019)
1.11 Where any of the applicant’s contact details change, including
the name of the responsible person, the physical or postal
address and/ or telephonic details, the applicant must notify
the Department as soon as the new details become known to
the applicant;
C Sasol advised the Department of a change of name from Sasol
Synfuels (Pty) Ltd to Sasol South Africa (Pty) Ltd in March 2017,
and sought to amend the EA. Sasol received confirmation from
Mpumalanga Province Department of Agriculture, Rural
development, Land & Environmental Affairs on 28 April 2017 that
the amendment to the EA had been approved.
No other changes to contact details have occurred.
Evidence:
— SSO_UTIL_Amendment_Power Waste Energy_1.3.1.16.4 G-
33_2017-04-28
None.
1.12 Any changes in the project that could have significant
environmental impacts and that differ from what was
authorized by this Department, must be submitted to this
Department for approval prior to such changes being effected.
N/A Noted. The auditor was advised that no such changes have
occurred during the audit period.
None.
ESTABLISHMENT
2.01 This Authorisation is valid for a period of two (2) years from
the date of issue and must be renewed six (6) months in
advance of the expiry date if construction activities have not
taken place within the allocated time.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2.02 Fourteen (14) days written notice must be given to this
Department before commencement of construction activities. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2.03 An independent Environmental Control Officer (ECO) must
be appointed before commencement of any construction
activities to ensure that the conditions of this Record of
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
Decision are implemented, and also to ensure compliance
with the provisions of the Scoping Report and the
Environmental Management Plan (EMP). The name and
contact details of such an officer must be forwarded to this
Department before construction commences.
2.04 The conditions stipulated in this Record of Decision as well
as the mitigation measures and recommendations in the
Scoping Report and EMP are legally binding components of
any contract and are therefore legally enforceable.
N/A Noted. Sasol is aware that the conditions are legally binding. None.
CONSTRUCTION & OPERATION
3.01 Areas disturbed as a result of construction activities must be
rehabilitated as soon as possible to the satisfaction of this
Department.
N/A This condition is considered outside of the audit period
(construction pre-2014). Furthermore, the entire site is paved and
tarred. Therefore the condition considered not applicable.
None.
3.02 Measures must be taken to prevent and manage soil erosion,
and strict erosion control measures must be implemented in
the design of storm water management.
C The entire site is paved and tarred and is not susceptible to any soil
erosion.
None.
3.03 Topsoil must be removed from all areas to be disturbed by
construction activities and be stockpiled at pre-designated
locations for use during rehabilitation and landscaping.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
No exposure of soils has occurred since the construction period.
None.
3.04 The storage and handling of fuel, lubricants and other
chemicals must be in especially demarcated impervious and
bunded areas.
C The auditor observed that all chemicals and lubricants used onsite
are kept and handled in a bunded area.
Evidence:
None.
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Chemical bund
3.05 The mixing of cement must take place on an impermeable
layer such as concrete slab or in a container suitable for this. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.06 Stringent measures must be applied to suppress dust
emanating from the construction site. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
Dust is not generated during the operation of the facility.
None.
3.07 Workers movements must be limited to the construction area
only and must be enforced in terms of the contracts of
appointment.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.08 Measures must be taken to ensure the safety of construction
personnel. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.09 Appropriate notification signs must be erected warning the
public of the dangers around the construction sites. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.10 The development must be linked to Govan Mbeki Local
Municipality’s infrastructure. No other structures meant for
the disposal of sewage are permitted for this development.
C The amendment to the RoD in April 2008 renders this Condition not
applicable. No sewerage is discharged to Govan Mbeki Local
Municipality infrastructure.
None.
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Correction dated 10 April 2008: Clarity is provided
pertaining to sewerage infrastructure as per Scoping Report
Section 2.3.2 (c) under brief description that oily water sewer
network will be designed such that it can operate
independently, but at the same time can integrate with the
existing Synfuels systems for water transfer. No sewerage will
be discharged to Govan Mbeki Local Municipality
infrastructure. Sasol operates its own sewerage treatment
plant
3.11 Any complaints received from the public during the
construction and operational phases of the activity must be
attended to as soon as possible and addressed to the
satisfaction of all concerned.
C A complaint register is kept up to date for the entire Sasol Secunda
Operations. Available records go as far back as 2008. There were no
complaints applicable to this development during the audit period.
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019)
None.
3.12 Good Environmental Management Practice must be carried
out as an integral part of implementation of the plant. C The auditor was satisfied with the environmental management
practices onsite; such as the availability of waste receptacles,
hazardous materials bunding, general housekeeping, the presence of
fire firefighting equipment, and proper signage. Paper recycling
initiatives were implemented in the office areas.
Waste receptacles onsite
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Safety signage onsite
Fire-fighting equipment
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Paper recycling initiative
3.13 A Risk Assessment Study must be conducted before the
commencement of construction activities. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
3.14 The proposed Oily Water and Storm Water Sewer must be
registered with the Department of Water Affairs and Forestry.
Correction dated 10 April 2018: Clarity is provided
pertaining to sewerage infrastructure as per Scoping Report
Section 2.3.2 (c) under brief description that oily water sewer
network will be designed such that it can operate
independently, but at the same time can integrate with the
existing Synfuels systems for water transfer. No sewerage will
be discharged to Govan Mbeki Local Municipality
infrastructure. Sasol operates its own sewerage treatment
plant.
N/A The oily water separator does not discharge to municipal sewerage,
and hence does not require registration with the DWAF. Clarity was
provided in the amendment to the RoD dated April 2018.
No sewerage is discharged to the Govan Mbeki Local Municipality
infrastructure (see Condition 3.10).
None.
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WATER AND AIR POLLUTION
4.01 It is the responsibility of the applicant and the relevant
contractor to prevent any pollution of surface as well as
ground water.
C The entire site is paved and tarred and hazardous materials are stored
and handled within bunded areas, to prevent pollution.
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.
Surface water monitoring is conducted weekly, in addition to real
time for various RESMs.
Groundwater monitoring is conducted biannually and quarterly.
There is no groundwater monitoring specific to the power
generation plant, however there are six 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 power generation plant.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15;
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.
None.
4.02 Any further conditions as set out by any relevant Authority
(e.g. Department of Water Affairs & Forestry) must be
adhered to.
N/A Noted. Sasol has advised it is not aware of any further conditions. None.
WASTE
5.01 All waste generated on site must be stored, handled, and
disposed of at a registered landfill site or as directed by any
other relevant authority.
C Adequate waste receptacles have been provided throughout the site.
Waste is collected by Sasol’s waste service providers for disposal.
Records of waste disposal are kept on Sasol’s document
management system.
None.
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5.02 Building rubble must be disposed of at a site specifically
earmarked for that purpose. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
5.03 No oil spills, concrete or other construction material must be
allowed to remain on site after the construction phase. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
5.04 Waste generated during the operation of the site must be
classified and disposed of in an appropriate manner as
prescribed in the Minimum Requirements for waste disposal
as prescribed by the Department of Water Affairs and
Forestry.
C Adequate waste receptacles have been provided throughout the site.
Waste is collected by Sasol’s waste service providers for disposal.
Records of waste disposal are kept on Sasol’s document
management system.
Liquid waste in the stormwater collection pond is tested and sent to
the API. Should the results exceed the required contamination
levels, the auditor was notified that the water would not be sent to
the API, but would be vacuumed and disposed of at a licenced
landfill.
None.
MONITORING
6.01 This Department retains the right to inspect or monitor the
proposed project during both construction and operational
phases to ensure that it complies with legislation and the
conditions stipulated in this Record of Decision.
N/A Noted. None.
6.02 Environmental compliance will further be monitored through
complaints received from the public. N/A Noted. Information on the Sasol complaints process is detailed
under the findings for Condition 3.11.
None.
6.03 Monitoring of the emissions must be monitored on a monthly
basis to ensure that emissions stay within the prescribed
limits.
C The monthly SSO continuous emissions monitoring reports for the
periods November 2018, January 2019, and February 2019 were
provided to the auditor as a sample.
For the steam generation emissions, results were within limits
prescribed by the Atmospheric Emissions Licence (AEL).
Evidence:
None.
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— 201810 SSO continuous emission monitoring monthly
report_5 December 2018 rev_02;
— 201901 SSO continuous emission monitoring monthly report
for January 2019 rev_00; and
— 201902 SSO continuous emission monitoring monthly report
for February 2019 rev_00.
REPORTING
7.01 The applicant must notify this Department within 24 hours in
the event of non-compliance with any of the conditions of
this Authorisation.
C No non-compliances have been identified during this audit. None.
7.02 Records relating to compliance / non-compliance with the
conditions of the Authorisation must be kept in good order.
Such records must be available to this Department within
seven workdays from the date of a written request from them.
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.
7.03 Non-compliance with any deviation from the conditions of
this Authorisation 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 31 of the Act.
N/A Noted. None.
7.04 Any complaints regarding the development must be brought
to the attention of this Department within 24 hours after
receiving the complaint. A complaints’ register must be kept
up to date for inspection by the Department.
C A complaint register is kept up to date for the entire Sasol Secunda
Operations. Available records go as far back as 2008. There were no
complaints applicable to this development during the operational
period.
Evidence:
— Environmental Complaints Register (Period: December 2014
– March 2019)
None.
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7.05 The applicant must ensure that all related Legislation;
National, Provincial and Local must be complied with as
stipulated within the Scoping Report.
N/A Noted.
The Draft Scoping Report dated April 2007 was provided to the
auditor. Administrative, legal and policy requirements are listed in
Section 1.3 of that Scoping Report, as follows:
— The Constitution of the Republic of South Africa (Act No.
108 of 1996);
— The Environment Conservation Act: ECA, 1989 (Act No. 73
of 1989), and the EA Regulations, promulgated in terms of
the Act;
— The National Environmental Management Act: NEMA, 1989
(Act No. 107 of 1998),
— The National Water Act, 1989 (Act No. 36 of 1998); and
— The Atmospheric Pollution Prevention Act, 1965 (Act No. 45
of 1965).
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 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:
— 500981 - Draft Scoping Report.v3_ed.2007.04.03-1;
— SSO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels
operations.
None.
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Table 3: Audit Findings – Environmental Management Plan
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
CATEGORY A - PLANNING PHASE
A.01 Appointment and Duties of SES N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.02 Appointment and Duties of SH&E OFFICER N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.03 EMP N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.04 Environmental incidents N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.05 Erosion sedimentation and flooding N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.06 Crime, Safety and security N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.07 Storm water Management N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.08 Occupational Health and Hygiene Issues N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.09 SH&E Orientation, Induction and Training 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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A.10 Safety Induction N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.11 Social upliftment and crime N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.12 Waste disposal N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.13 Accidental Spillage N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.14 Refuelling N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.15 Road Infrastructure N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
A.16 Sewage N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
CATEGORY B - CONSTRUCTION PHASE
B.01 General N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.02 Management of topsoil N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.03 Machinery, tools and equipment 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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B.04 Noise N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.05 Waste Management N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.06 Personal Protective Equipment (PPE) N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.07 Transport and Vehicles N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.08 Construction crew site N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.09 Effects of the construction site N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.10 Effects of the construction crew site N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.11 Effects of the construction site N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.12 Erosion, sedimentation and flooding N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.13 Groundwater Contamination 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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B.14 Geology N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.15 Heritage resources N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.16 Destruction of vegetation N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.17 Impact on fauna N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.18 Crime, safety and security N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.19 Noise and atmospheric pollution N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.20 Visual impact N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.21 Waste N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.22 Adequacy of waste disposal facilities N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
B.23 Excavated areas 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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B.24 Inspection and Auditing N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
CATEGORY C - OPERATIONAL PHASE
C.01 General
A Management Body should be established to ensure that the
EMP is implemented and sound environmental management
occurs in the operational phase.
C According to the Area Manager, the Senior Manager is responsible
for leading the unit with regards to ensuring that the EMPr is
implemented. The unit’s production team is also in constant liaison
with Sasol’s environmental department which oversees the
implementation of all licences and EMPrs.
None.
C.02 Site Management
A maintenance plan for the development must be developed
with regard to maintaining buildings and perimeter fencing
etc. in order to ensure that they do not deteriorate and
become aesthetically unpleasant.
C An extract from the generation plant’s maintenance plan was
provided to the auditor for verification.
Evidence:
— Extract from the power generation plant’s maintenance plant
(provided via email).
None.
C.03 Safety Risks
Only authorized persons are allowed to enter the bulk storage
tank area. C The Area Manager notified the auditor that no unauthorised persons
enter the bulk tank storage area; only the unit’s production team is
allowed. If a delivery has to be made, the service provider must
furnish a delivery slip prior to being permitted to enter. All service
providers have to be accompanied by a production team when
offloading a delivery.
None.
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Electronic equipment that could create static must be
restricted to the main office building (Cell phones, Cameras
etc.).
C Signage that prohibits electronic equipment onsite is displayed.
Lockers are provided at the site office, in which on-site staff must
place all their gadgets prior to accessing the site.
None.
C.04 Groundwater Quality
Any damages to the sewage system must be reported and
repaired immediately. C The Area Manager, advised that he was not aware of any sewage
system damages having occurred to drainage system, although no
underground surveys of the sewage system has been completed. The
auditor was notified that in 2017 a suction pump had a
malfunctioned. This was inspected and replaced before any damage
could occur.
Site staff are responsible for reporting any observations regarding
malfunctions or damages, to identify areas for repair.
OFI:
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
The sewage system must be inspected for leakages on a
regular basis and any leakages must be attended to
immediately.
NC The aboveground sections of sewerage system are inspected by the
shift foreman every shift.
No underground surveys of the sewage system has been
completed.
Evidence:
— C.02_Plant Inspections U050;
— C.02_Plant Inspections U250; and,
— C.02_Plant Inspections U350.
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
Storm water gullies, drains and channels must be regularly
inspected for evidence of pollution and contamination (as
part of the Safety Representatives monthly inspection)
C As far as can be expected from a monthly inspection (i.e.
aboveground sections only) the storm water gullies, drains and
channels are inspected, as these are checked by the shift foreman
every shift.
OFI:
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
No underground surveys of the sewage system has been
completed, however this is considered beyond the assumed remit
of this Condition, given that inspection is required monthly.
Evidence:
— C.02_Plant Inspections U050;
— C.02_Plant Inspections U250; and,
— C.02_Plant Inspections U350.
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
C.05 Site Storm Water and Sewer System management
Storm water and sewer drains must be mapped on the site plan
and personnel made aware of their function. C The oily water and stormwater lines onsite have different colours.
The oily water line is marked with brown, and the clean stormwater
is marked with green.
All personnel onsite are aware of stormwater and sewer functions as
they are undergo plant specific inductions prior to working onsite.
None.
The storm water system, especially the discharge points, must
be inspected, and damaged areas must be repaired if required. C The aboveground sections of sewerage system are inspected by the
shift foreman every shift.
No underground surveys of the sewage system has been
completed, however this is discussed under Condition C.04.
OFI:
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
Any spills of product must be reported and investigated and
appropriate remedial action taken. Action may include clean
up by the site or making use of the specialized services of a
contractor (in the case of a major spill)
C All environmental incidents are recorded in an incident register that
is available at the Environmental department. All incidents are
investigated and reported in line with the procedure and as per legal
requirements. The auditor has checked the incident register for the
None.
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audit period, and no spill incidents associated with the power
generation plant have been noted.
Evidence:
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18.
Any damages to the sewage or storm water system must be
reported and repaired as soon as possible. C The Area Manager, advised that he was not aware of any stormwater
or sewage system damages having occurred to drainage system,
although no underground surveys have been completed. The auditor
was notified that in 2017 a suction pump on the sewer system had a
malfunctioned. This was inspected and replaced before any damage
could occur.
Site staff are responsible for reporting any observations regarding
malfunctions or damages, to identify areas for repair.
OFI:
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
Oil leaks or spills from workshops/equipment must be
absorbed with spill absorbent material. Waste oil must be
recycled through specialist contractors
C Spills are addressed with absorbent material if they occur. Waste is
managed through implementation of a Waste Management
procedure 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
(provided for review).
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Steam Production_2016-11-07 (waste register)
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
The sewage system must be inspected for leakages or
blockages regularly (as part of the site Safety Representative’s
inspection).
C As far as can be expected from a routine inspection (i.e.
aboveground sections only) the storm water gullies, drains and
channels are inspected, as these are checked by the shift foreman
every shift.
No CCTV surveys of the below ground network have been
completed, however this is considered beyond the assumed remit
of this Condition, given that inspection is required as part of the
site Safety Representative’s inspection.
Evidence:
— C.02_Plant Inspections U050;
— C.02_Plant Inspections U250; and,
— C.02_Plant Inspections U350.
OFI:
Sasol must conduct
underground inspection of
the sewage system to
identify damage which
could lead to leakage and
therefore potential
contamination.
Target Completion:
Medium term.
C.06 Flooding
Litter blocking storm water channels must be removed. C Litter is removed as part of the maintenance strategy, and the site
was observed to be litter free.
None.
C.07 Visual and aesthetics
Public open space areas must be maintained. This includes
watering plants, pruning trees, cutting grass, collecting litter,
etc.
C The entire site has tar and concrete paving all around. In terms of
litter, the site was observed to be litter free.
None.
Disposal of all domestic waste must be undertaken by the
local council. C Waste is managed through implementation of a Waste Management
procedure 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
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
classification that is detailed in site specific waste registers
(provided for review).
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Steam Production_2016-11-07 (waste register).
Landscape areas are to be maintained and weeded frequently. N/A The entire site has tar and concrete paving all around. No landscaped
areas fall within the site.
None.
C.08 Waste Management
All waste generated during the operational phase must be
disposed off in a manner that is in accordance with Sasol’s
Waste Management Procedure (see Appendix 3).
C All waste generated onsite is handled according to Sasol’s Waste
Management Procedure. Adequate measures to handle and store
waste are implemented.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09.
None.
Litter accumulating in or near the water bodies must be
controlled. This could be done by initiating clean-up
campaigns.
C Litter is removed as part of the maintenance strategy, and the site
was observed to be litter free.
None.
External dustbins should be cleaned at least once a week in a
maintenance plan for the development as per local authority
/contractor.
C Waste contractors collect waste twice a week, or as and when
required should volumes be large. However, large volumes are only
experienced during maintenance work.
None.
Efforts should be made to recycle wastes – income derived
can be used in motivational programmes for staff. C According to the Area Manager, at the moment, the only waste
currently being recycled onsite is paper waste which is collected by
either Mondi or Sappi.
OFI:
Further recycling
opportunities should be
explored.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Disposal of all domestic waste must be undertaken by the
local council or an independent approved company (approved
by the council).
C Disposal of domestic waste is undertaken Sasol’s internal waste
service contractor, Enviroserv, which is a registered and licenced
service provider.
None.
Waste disposal records for hazardous waste must be filed and
available for inspection. N/A According to the SHE Environmental Compliance Specialist,
hazardous waste from site was last disposed of more than 5 years
ago. Therefore, it falls outside of the audit period.
None.
The development should be kept clean through the removal of
litter on a daily basis as per local authority guide. This should
be included in a maintenance plan for the development.
C The site was observed to be in a clean and tidy condition. Daily
removal of litter is not necessary, as the operation does not produce
considerable amounts of litter.
None.
C.09 Accident and Incident Reporting
Before establishment of a first aid facility on site the
Contractor shall negotiate and agree with the Sasol site
medical facility and Agent on minimum standards and the in
order clarify the type of treatment. The Sasol medical officials
may at any time audit such facilities. The Sasol Injury
classifications shall be used as a guide-line.
N/A There is no first aid facility onsite. However, Sasol has a fully
trained and equipped emergency response as well as medical team
always on standby for emergencies and accidents.
None.
The following accidents and incidents mentioned below shall
be reported immediately to the Agent’s Representative. Only
injuries which are classified as project related shall be
accepted and recorded for statistical purposes.
— Any occupational injuries and illnesses on site (Fatal
Cases, Lost Work Day Cases, Restricted Work Cases,
Medical Treatment Cases, First-aid Cases)
— All visits from Department of Labour, any condition
that may endanger the adjacent and surrounding plants
and any condition that may endanger the construction
activities must be reported to the Agent’s
representative.
C Sasol makes use of a web based Information Management System
(IMS) that includes a comprehensive Document Management
System (Easy DMS) where all supporting documentation is
available to prove compliance with legal requirements related to
process safety and Occupational Health & Hygiene.
All accidents and incidents are recorded within the onsite register.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— All reportable incidents as required by legislations.
(Flying or falling objects, machinery out of control,
failure of safety or alarm systems, dangerous substance
spilled or uncontrolled release of substance under
pressure).
— Any occupational diseases
— Any damage caused to the property or environment.
If a Contractor is making use of his own Medical facility he
shall ensure that all injuries are reported to the Sasol medical
station for confirmation of classification of all injuries
treated outside these facilities.
N/A Noted. Contractors typically utilise the Sasol medical facilities. None.
Reporting of all incidents is encouraged to determine trends
and identifying root causes and by rectification prevent
major incidents. The Contractor will be required to have in
place a system for identifying these trends and implementing
preventative actions.
N/A Noted. All accidents and incidents are recorded within the onsite
register. Contractors typically utilise the Sasol medical facilities.
None.
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL AUTHORISATION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 4
below.
Table 4: Summary of EA Compliance Audit Findings
SECTION OF THE EA NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 12 4 0 8
ESTABLISHMENT OF THE DEVELOPMENT 4 0 0 4
CONSTRUCTION & OPERATION 14 5 0 9
WATER AND AIR POLLUTION 2 1 0 1
WASTE 4 2 0 2
MONITORING 3 1 0 2
REPORTING 5 2 0 3
Total Count 44 15 0 29
Total Percentage 34% 0% 66%
Percentage Compliance with Applicable Conditions 100%
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Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents
the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the EA conditions per Section
Figure 3: Overall count findings on compliance to the EA conditions
0
2
4
6
8
10
12
14
16
Sectional Count Contribution
C
NC
N/A
15
029
Total Compliance
C
NC
N/A
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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
34%
0%66%
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.
It is to be that noted that the conditions of the planning and construction phase have been excluded from the audit
as the audit period is from December 2014 to February 2019, and this development was already in operational
phase during that time.
Table 5: Summary of EMPr Compliance Audit Findings
SECTION OF THE EMPR NO. COMMITMENTS C NC N/A
PLANNING PHASE 16 0 0 16
CONSTRUCTION PHASE 24 0 0 24
OPERATIONAL PHASE:
GENERAL 1 1 0 0
SITE MANAGEMENT 1 1 0 0
SAFETY RISKS 2 2 0 0
GROUNDWATER QUALITY 3 2 1 0
SITE STORM WATER AND
SEWER SYSTEM MANAGEMENT
6 6 0 0
FLOODING 1 1 0 0
VISUAL AND AESTHETICS 3 2 0 1
WASTE MANAGEMENT 7 6 0 1
ACCIDENT AND INCIDENT REPORTING 4 1 0 3
Total Count 68 22 1 45
Total Percentage 22% 1% 66%
Percentage Compliance with Applicable Conditions 96%
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Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7
presents the total proportion of compliance for the facility.
Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section
Figure 7: Overall count findings on compliance to the EMPr conditions
0
5
10
15
20
25
30
Sectional Count Contribution
C
NC
N/A
22
145
Total Compliance
C
NC
N/A
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Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the
total percentage compliance for the facility.
Figure 8: Percentage contribution of findings made to the EMPr conditions per Section
Figure 9: Overall percentage findings on compliance to the EMPr conditions
5.2.1 EFFECTIVENESS OF THE EMPR
Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy
and effectiveness of the EMPr as part of the audit scope, as follows:
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
achieve the objectives and outcomes laid out in these documents;
— Identify and assess any new impacts and risks that result from undertaking the activity;
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
32%
1%66%
Total Percentage Compliance
C
NC
N/A
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— 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 more than 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 EA, relevant WUL and
AEL; and through Sasol’s choice to comply with the ISO 14001 Environmental Management international
standard.
The EIA Regulations 2014 (as amended) requires that the EA and EMPr is audited only at least every five years,
and Sasol has systems in place which are considered to be more robust for monitoring compliance and
implementing changes than through the EMPr audits; including the annual audit of each business unit to
meeting ISO 14001 standards.
New impacts and risks are continually identified and assessed by Sasol by its Governance SHE Risk and
Assurance department; which assesses environmental risks and drives improvement implementation. The SHE
Environment department facilitates Environmental Risk Assessments per business entity to ensure that gaps are
addressed through implementation of mitigation measures via the Integrated Management System. Sasol further
addresses all Key Undesirable Events (KUEs) from a group perspective. Risk documentation is hosted on
Sasol’s Information Management System.
In conclusion, WSP considers that for the duration that Sasol continues to operate each business unit under ISO
14001 standards and meet licence compliance (EA, WUL, AEL), this is effective as mitigation against any gaps
in the EMPr and as a means to regularly identify new impacts and risks. In the event that Sasol elects to no
longer comply with ISO standards, an alternative system must be implemented. Such an alternative may involve
updates to the EMPr and regular (annual) audits against these updates.
APPENDIX
A ENVIRONMENTAL AUTHORISATION (17.2.22.3GS 2)