secunda synfuels operations - refinery …

SECUNDA SYNFUELS OPERATIONS - REFINERY

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14.25.16 EV 10 - INSTALLATION OF SECONDARY DEPITCHER

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14.25.16 EV 10 - INSTALLATION OF SECONDARY DEPITCHER

SECUNDA SYNFUELS OPERATIONS -

REFINERY

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

Q U A L I T Y M A N A G E M E N T

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref:

14.25.16 EV 10

Final – Compliance

Audit

EA Ref:

14.25.16 EV 10

Date April 2019 June 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 040 040

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

S I G N A T U R E S

PREPARED BY

-

Ziyaad Kadwa

Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

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

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Refinery Production Senior Manager Helgard Theron

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS - REFINERY

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Installation of Secondary Depitcher, West

Refineries Plant (Authorisation Number: 14.25.16

EV 10) ........................................................................ 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 ... 14

5.1 Environmental Authorisation ............................... 14


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 14

FIGURES

FIGURE 1: SSO – SECONDARY DEPITCHER, WEST REFINERIES PLANT (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 15

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 15

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 16

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 16

APPENDICES

A ENVIRONMENTAL AUTHORISATION (14.25.16 EV 10)


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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: 14.25.16 EV 10 issued on 06 March 2000) for the period

December 2014 to February 2019.

1.2 INSTALLATION OF SECONDARY DEPITCHER, WEST

REFINERIES PLANT (AUTHORISATION NUMBER:

14.25.16 EV 10)

Sasol received an EA for the installation of a secondary depitcher at the west refineries plant, referred to as

Unit 74.

Crude Tar Acids, which is produced in both the Phenosolvan units, is depitched into a distillate known as

Depitcher Tar Acids with phenolic pitch as residue. The Depitcher Tar Acid is dispatched for further processing

and the phenolic pitch is processed in the tar distillation unit. The phenolic pitch still contains Phenol, Cresol

and Xylenol. The installation of the secondary depitcher at the existing Refinery Unit recovers the Phenol,

Cresol and Xylenol, which are high value products.

The EA was issued on 06 March 2000, and it has been confirmed that the construction phase was completed

prior to December 2014 (i.e. outside the audit period).

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


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Figure 1: SSO – Secondary Depitcher, West Refineries Plant (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

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

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

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

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


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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (13 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Ziyaad Kadwa conducted the site inspection on 13 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:

— Norman Africa (Area Manager: Production).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Environmental Authorisation: 14.25.16EV10_2000-03-06;

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.;

— App EA-Secondary Depitcher-faxed;

— IWWMP SIC 2015 Final_2018-05-15;

— AEL Sasol Synfuels 0016-2015-F02 (2017);

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— SOX Folder;


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

— Sasol SAWIS upload-2018_Jul-Sep;

— Waste register: Refining_2016-12-04;

— Induction_Mod6_EmergencyManagement;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;

— Environmental Complaints Register_2019-02-18; and,

— Various email correspondence.


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3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer and Norman Africa, to whom we express our

gratitude for their time and attention during our visit. A brief summary of the external auditors’ experience is

provided below.

— Auditor: Ziyaad Kadwa

Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal

Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the

Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it

part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural

Development for 3 years. He is currently completing his BSc Honours in Environmental Management part

time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a

number of high profile clients in various industries. He has three years of auditing experience, and has

successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,

Impala Platinum and NPC (InterCement). He has also done environmental management programme audits

for BRPM and for various infrastructure projects as part of environmental control officer duties.


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— Project Manager and Quality Assurance: Jenny Cope

Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental

Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;

undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a

range of sectors. Jenny’s recent experience includes completion and management of several pan-European

and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and

providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in

environmental consultancies and with a developer, giving context to understanding the practicalities of

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an

understanding of the Relevant Documents.

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

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

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

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

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

The findings, recommendations and conclusions given in this report are based on the author’s best scientific and

professional knowledge, as well as available information. This report is based on survey and assessment

techniques which are limited by time and budgetary constraints relevant to the type and level of investigation

undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if

and when new information may become available from on-going research or further work in this field, or

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts

no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or

in connection with the services rendered, directly or indirectly by the use of the information contained in this

document.

This report must not be altered or added to without the prior written consent of the author. This also refers to

electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.

Similarly, any recommendations, statements or conclusions drawn from or based on this report must make

reference to this report. If this report is used as part of a main report, the report in its entirety must be included

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1.01 This authorization refers only to the project specified above

and described in the Record of Decision. Separate

applications must be lodged for any other development

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

covered by section 21 and 22 of the Act and Government

Notice R1182 of 5 September 1997.

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

applications have been made.

None.

1.02 Authorization is only granted in terms of Section 22 of the

Act and does not exempt the holder from compliance with

other relevant legislation.

N/A Noted. The Sasol Complex operates with a dedicated

environmental and legal team, and therefore ensures that they

comply with applicable legislation.

In addition, site is operated under ISO14001:2015, which requires

the compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

1.03 No development may take place on the area of concern

without the necessary permits/approvals and/or service

agreements, where it is relevant, from or between the

following institutions and/or authorities.

1.3.1 Chief Air Pollution Control Office (CAPCO)

1.3.2 Department of Water Affairs and Forestry

C The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

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

an updated Integrated Water and Waste Management Plan

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

None.


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The above list does not limit the holder from obtaining other

relevant permits, approvals or agreements.

Evidence:

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

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

1.04 Copies of relevant documents mentioned in 1.3 above, must

be forwarded to this Department within three (3) months of

the issuing of this Authorization.

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 authorization if, in the opinion of the Department, it is

environmentally justified.

N/A No changes or amendments have been communicated to Sasol by

the Department since issue of the EA.

None.

1.06 The development must comply with all mitigatory measures

as set out in Appendix A of the application for authorization

and the Scoping document.

N/A Appendix A was provided to the auditor for review and no

mitigation measures were noted that relate to the operational

phase.

Evidence:

— App EA-Secondary Depitcher-faxed.

None.

ESTABLISHMENT OF THE ENTERPRISE

2.01 This Authorization is repealed if construction has not

commenced within two (2) years from the date of this

Authorization.

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


None.

2.02 In the case of closure of the operation this Department shall

evaluate, monitor and approve the clearing and rehabilitation

of the site.

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

according to Sasol, is estimated to occur around 2050.

None.

2.03 Construction of the plant must adhere to specifications as

described in the Scoping document. N/A This condition is considered outside of the audit period


None.


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2.04 If any change need to be made in the plan for the said

development or replacement of its structures, this

Department must be informed thirty (30) days in advance to

decide whether the change will need authorisation or not.

N/A Statement noted by Sasol.

No changes have been made within the audit period.

None.

WATER POLLUTION AND MANAGEMENT

3.01 As indicated by relevant authorities. C Surface water is managed at the site; the secondary depitcher is

within a hard surfaced and bunded area that drains to an enclosed

sump that pumps the water for reprocessing. This due to the higher

level of phenols that cannot be discharged into the oily water

system.

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

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

system that pumps the water for reprocessing.

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

time for the various Receiving Environment Surface Monitoring

(RESMs).

Ground water monitoring is conducted biannually and quarterly.

There is no groundwater monitoring specific to the secondary

depitcher, however there are 6 active boreholes located within the

Primary area which are utilised for monitoring. The auditor note a

number of exceedances in the November 2017 sampling run,

however these exceedances cannot be directly attributed to the

secondary depitcher unit.

The latest IWWMP as well as surface and ground water

monitoring results were provided to the auditor as evidence.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.

None.


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AIR POLLUTION

4.01 As indicated by relevant authorities. C Sasol has a valid Atmospheric Emission Licence (AEL) that was

issued by the Gert Sibande District Municipality. The AEL

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

It is noted that the secondary depitcher does not have stacks,

therefore no point source emissions monitoring is required. A

fugitive emissions plan provided by Sasol includes mitigation

measures as part of the monitoring plan.

According to the Environmental Team, Sasol works closely with

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

minimum legal emission requirements.

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

any emissions from the plant.

Evidence:


— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18; and,

— Fugitive Emission Monitoring Plan_2018-10-18 updated.

None.

WASTE

5.01 All waste generated during construction and/or operation of

the plant shall be stored, handled and dispersed of in an

environmentally acceptable way, and as directed by this

Department or any other relevant authority.

C The site operates in accordance to Sasol’s Waste Management

Procedure. The secondary depitcher does not produce any waste

during normal operating conditions; the tanks are cleaned annually

during the shutdown period; any residual matter in the tanks is

collected for reprocessing.

Sasol makes use of a SAP Sustainability Performance

Management Module (SUPM) as a database for tracking waste

volumes that are managed on and off site.

None.


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Sasol further reports the on-site waste management data into the

South African Waste Information System (SAWIS), on a quarterly

basis. The off-site management of waste is reported into SAWIS

by the accredited Waste Management Service Providers on a

quarterly basis.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol SAWIS upload-2018_Jul-Sep; and,

— Waste register: Refining_2016-12-04.

5.02 Under no circumstances may any waste generated during the

construction and operation of the plant can be stored or

dumped in a place other than legal waste handling facilities.

C The site operates in accordance to Sasol’s Waste Management

Procedure. The secondary depitcher does not produce any waste

during normal operating conditions; the tanks are cleaned annually

during the shutdown period; any residual matter in the tanks is

collected for reprocessing.

Sasol makes use of a SAP Sustainability Performance

Management Module (SUPM) as a database for tracking waste

volumes that are managed on and off site.

Sasol further reports the on-site waste management data into the

South African Waste Information System (SAWIS), on a quarterly

basis. The off-site management of waste is reported into SAWIS

by the accredited Waste Management Service Providers on a

quarterly basis.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol SAWIS upload-2018_Jul-Sep; and,

— Waste register: Refining_2016-12-04.

None.


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RISK MANAGEMENT

6.01 All employees, contractors and sub-contractors employed or

delivering a service at the plant, should be well equipped

with emergency procedures in case of any accident.

C All visitors and contractors entering the Sasol Complex are

required to undergo an SHE induction process. All training is done

through the SHE regional learning and development academy, and

records maintained by Sasol.

Module 6 (Emergency Management) includes details regarding the

processes and procedures to be followed in the event of an

emergency.

Evidence:

— Induction_Mod6_EmergencyManagement.

None.

6.02 The applicant must ensure that all issues and concerns from

interested and affected parties are addressed. N/A This condition is considered outside of the audit period


None.

MONITORING

7.01 Written recommendations made by this Department and any

other relevant authority as part of the monitoring process

will form part of this Record of Decision and must be

adhered to.

N/A No further recommendations (other than this EA) were received by

Sasol.

None.

REPORTING

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

conditions of the authorization must be kept in good order.

Such records must be made available to this Department

within seven (7) days form the date of written request for

such records by the Department.

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.

8.02 Non-compliance with, or any deviation from the conditions

of this authorisation is regarded as an offence and, after N/A Statement noted by Sasol. None.


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reasonable provision has been made for the situation to be

remedied, will be dealt with in terms of Section 29, 30 and

31A of the Act.

8.03 Any complaints regarding the said development must be

thoroughly investigated and addressed to the satisfaction of

all parties concerned. Copies of such complaints must be

forwarded to the Department within forty-eight (48) hours of

such a complaint being made.

C All environmental complaints received from interested and

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

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

Environmental Department. Complaints are investigated and

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

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

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

complaints related to the secondary depitcher were recorded for

this audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.

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 3

below.

Table 3: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 6 1 0 5

ESTABLISHMENT OF THE ENTERPRISE 4 0 0 4

WATER POLLUTION 1 1 0 0

AIR POLLUTION 1 1 0 0

WASTE MANAGEMENT 2 2 0 0

RISK MANAGEMENT 2 1 0 1

MONITORING 1 0 0 1

REPORTING 3 1 0 2

Total Count 20 7 0 13

Total Percentage - 35% 0% 65%

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

1

2

3

4

5

6

7

Sectional Count Contribution

C

NC

N/A

7

013

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

35%

0%65%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(14.25.16 EV 10)