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SECUNDA SYNFUELS OPERATIONS: WATER AND ASH
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
14.25.16 EV 11 - BLACK PRODUCTS SITE
27 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
14.25.16 EV 11 - BLACK PRODUCTS SITE
SECUNDA SYNFUELS OPERATIONS:
WATER AND ASH
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
BUILDING C
KNIGHTSBRIDGE, 33 SLOANE STREET
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SOUTH AFRICA
T: +27 11 361 1392
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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: 14.25.16 EV
11
Draft v2 for Review –
Compliance Audit
EA Ref: 14.25.16 EV
11
Final – Compliance
Audit
EA Ref: 14.25.16 EV
11
Date April 2019 June 2019 June 2019
Prepared by Tutayi Chifadza Tutayi Chifadza Tutayi Chifadza
Signature
Checked by Ashlea Strong Ashlea Strong Ashlea Strong
Signature
Authorised by Jenny Cope Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534 41101534
Report number 033 033 033
File reference W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-
REPORTS\033_SSO_WA_EA_14.25.16 EV 11\01 Draft report
S I G N A T U R E S
PREPARED BY
Tutayi Chifadza
Consultant
REVIEWED BY
Ashlea Strong
Principal Consultant
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf and
at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding of their
compliance with the conditions included in the Environmental Authorisation and associated Environmental
Management Plan.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than
the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any
third parties directed to provide information and documents to us by the Client. We have not reviewed any other
documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
SASOL
SHE: Environmental Compliance
Specialist
Broni van der Meer
Water and Ash Production Senior
Manager, Secunda Synfuels Operations
Timothy Ndlovu
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Tutayi Chifadza
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: WATER AND ASH
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TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Black Products Site (Authorisation Number:
14.25.16 EV 11)......................................................... 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 ................................ 7
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 47
5.1 Environmental Authorisation ............................... 47
5.2 Environmental Management Plan ........................ 50
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: WATER AND ASH
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 6
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 20
TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 47
TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 50
FIGURES
FIGURE 1-1: BLACK PRODUCTS SITE (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 5-1: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 48
FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 48
FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 49
FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 49
FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 51
FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 51
FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 52
FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 52
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APPENDICES
A ENVIRONMENTAL AUTHORISATION (14.25.16 EV 11)
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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 11 issued on 4 December 2000) as well as
the associated Environmental Management Plan (dated: 2002) for the period December 2014 – February 2019.
1.2 BLACK PRODUCTS SITE (AUTHORISATION NUMBER:
14.25.16 EV 11)
The Sasol Synfuels process at Secunda co-produces a spectrum of solid, liquid and gaseous wastes and by-
products. The “Black Products” portion of these waste products were disposed and contained at the “Black
Products Site”. The Black Products Site predominantly contained a mixture of tars and tar solids/sludge, oil, water,
pitch and synthol gunk.
Sasol needed to close and rehabilitate the Black Products site to make the total area available for coarse ash
stacking by 2004. In doing so, Sasol also needed to create an alternative facility for disposal, storage, treatment
or recycling of future black products. The emphasis was on recovery, recycling and treatment of black products
as Sasol recognised major synergies between rehabilitation process for the first Black Products site and a new
processing facility, handling future black products to be generated.
The Environmental Directorate of the Mpumalanga Department of Agriculture, Conservation and Environment
granted the authorisation on 4 December 2000 with reference number 14.25.16 EV 11. The Black Products site is
currently being rehabilitated, ahead of the advancing Coarse Ash Dump that will eventually cover it.
Rehabilitation at this Area entails the removal of some of the products such as pitch for reuse in manufacturing,
mixing the remaining products at a ratio of 1:5 with coarse ash and fine ash and compacting the mixture to
engineering standards. This will significantly reduce the seepage potential, implementing a similar interceptor
drain system as is used for the FADs prior to covering with coarse ash, and finally covering the area with a deep
layer of coarse ash. A Waste Management Licence (WML) was issued for this facility on 4 April 2013.
The location of the Black Products site at the Sasol Synfuels facility is indicated in Figure 1-1 below.
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Figure 1-1: Black Products Site (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 and EMPr;
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
achieve the objectives and outcomes laid out in these documents;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Critically evaluate the effectiveness of the EMPr;
— Identify shortcomings in the EMPr;
— Identify the need for any changes to the avoidance, management and mitigation measures provided for in the
EMPr;
— Make recommendations in order to achieve compliance in terms of the EA and EMPr; and
— Ensure the commitments contained in Condition 7.1 of the EA are completed, more specifically:
— “Records relating to the compliance/non-compliance with the conditions of the authorisation must be
kept in good order. Such records must be made available to this Department within seven (7) workdays
of the date of request by this Department”.
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the EA and associated EMPr conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (26 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
Tutayi Chifadza conducted the site inspection on 26 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:
— Broni van der Meer (SHE: Environmental Compliance Specialist);
— Rouxtjie Strydom (Area Manager Production);
— Sipho Mahlangu (Production Foreman); and
— Nonhlanhla Nhlapo (Senior Process Technician).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;
— SSO DQS ISO 14001 2015;
— Amended Waste Management Licence Waste Ash Site;
— Bi-Annual External Waste Management Licence Compliance Report – Waste Ash Disposal Site_September
2018;
— BP_Aspect register 26 August 2002(revised);
— 3.1_BP6 Seepage Cutoff Kickoff Minutes;
— 15-064_-_BPS_and_BP6_Capping_WORK_-_Quote_on_PMI_022_REV_3_-_2015-06-25;
— IWWMP SIC 2015 Final_2018-05-15;
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-20;
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20;
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4;
— Amended Waste Management Licence Waste Ash Site;
— Fugitive Emission Monitoring Plan_2018-10-18 updated;
— Compliance_Air_Secunda Complex;
— Environmental emergency procedure (Rev 6): SGR-SHE000023;
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— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-000031);
— External WAS Audit_2018-09-18;
— 3.3.1 Organogram_SHE Air_2018-09-17;
— 3.3.1 Organogram_SHE WWLB_2018-09-03;
— Induction_Mod1_1SHE Excellence;
— Induction_Mod4_ProcessSafetyManagement;
— Induction_Mod5_WorkPlaceSafety;
— Induction_Mod6_EmergencyManagement;
— Induction_Mod7_Occupational;
— 6.01_Waste monitoring committee_Terms of Reference_2017-10-24;
— 6.01_Establish waste monitoring committee_2017-10-24;
— Environmental Complaints Register_2019-02-18
— Compliance_Complaints_Secunda Complex;
— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01;
— Phase 1_Contaminated Land Assessment_November_2015_Final 1.0;
— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of 2_2018-08-28;
— 033_41101534_20190125_Sasol_SSO_WA_EA_14.25.16 EV 11_V1;
— J.53_EnvNoise 5439(Final) ver1_2016-08-26;
— Environmental Complaints Register_2019-02-18;
— Site photos; 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.
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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).
3.5 AUDIT TEAM
The Auditor, Tutayi Chifadza was hosted by Broni van der Meer, Rouxtjie Strydom, Sipho Mahlangu and
Nonhlanhla Nhlapo 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: Tutayi Chifadza
Tutayi Chifadza has 5 years’ experience and is an Environmental Consultant for WSP at the Johannesburg,
Bryanston office in the Environmental Services division. He holds a Bachelor of Science (Honours), Applied
Science in Environmental Technology, and Bachelor of Science, Chemistry from the University of Pretoria.
Tutayi has experience in undertaking Water Use Licence (WUL) applications, Basic Assessments and
Environmental Impact Assessments as well as technical compliance audits including for Transnet and Sasol.
He conducted Water Use Licence audits for four sections at South 32 and its reporting. He is also responsible
for conducting WUL and Waste Management Licence audits.
— Lead Auditor and Quality Assurance: Ashlea Strong
Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature
Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental
Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic expertise
on a diverse range of projects in the environmental management field, including environmental scoping and
impact assessment studies, environmental management plans, waste and water management, as well as the
provision of environmental management solutions and mitigation measures. She has been involved in the
management of a number of large EIAs within South Africa and has environmental auditing and training
experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed in the audit
process.
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a range
of sectors. Jenny’s recent experience includes completion and management of several pan-European and
global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and providing
clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in environmental
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: WATER AND ASH
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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
1. GENERAL CONDITIONS
1.1 This authorisation refers only to the project specified above
and described in the Record of Decision, hereafter referred to
as "the interface project" or development". Separate
application/s must be lodged for any other development
and/or activity at or near proposed development, which is
covered by section 21 and 22 of the Environment
Conservation Act, No. 73 of 1989 Act and Government
Notice R1182 and R1183 of 5 September 1997.
N/A Noted. None
1.2 Authorisation is only granted in terms of Section 28A of the
Environment Conservation Act, No. 73 of 1989 and does not
exempt the holder from compliance with any other relevant
legislation.
N/A Noted.
A full legal review does not form part of the scope of this Audit. The
site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review.
Evidence:
— Audit report_383569_ISO 14001_2015_stage2_2018-07-27
— SSO DQS ISO 14001 2015
None
1.3 No development may take place on the area of concern
without the necessary permits/approvals and/or service and/or
lease agreements from other authorities.
C The site was approved for development when an EA was issued by
the Provincial Department on 4 December 2000 with 14.25.16 EV
11 as the reference number. A WML was issued on 4 April 2013 for
the ash handling facility with reference number 12/9/11/L1/6. Four
variations on the amended WML were further issued: which
included:
— Waste Licence Variation for height Increase of Fine Ash Dam
5 (Reference Number: 12/9/11/L1/6/V2);
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Waste Licence Variation for condition 4.7 (Reference Number:
12/9/11/L1/6/V2);
— Waste Licence Variation for condition 4.1 and 4.9 (Reference
Number: 12/9/L1/6/R1/V5);
— Waste Licence Variation for condition 1.1.2, 3.2, 4.5, 6.2.1.1,
6.2.2.2, 6.2.1.3, 6.2.2.1, 6.2.3.1, 6.2.4.1, 6.2.4.3, 6.2.4.2,
6.2.5.1 and 6.2.6.1 (Reference Number: 12/9/L1/6/V3 dated 28
March 2018).
A copy of the WML and the September 2018 compliance audit
report by SRK Consulting was available for review.
Evidence:
— Amended Waste Management Licence Waste Ash Site
— Bi-Annual External Waste Management Licence Compliance
Report – Waste Ash Disposal Site_September 2018
— 14.25.16 EV 11_Black Products Site_2000-12-04
1.4 Copies of relevant documents mentioned in 1.3 above must be
forwarded to this Department for record keeping purposes. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.5 This Department may change, add or amend any of the
conditions in this authorization if, in the opinion of the
Department, it is environmentally justified.
N/A Noted. None
1.6 An EMP must be formulated to minimise and manage
potential environmental impacts during the closure and
development of the Black products site. The EMP must
include the spill contingency plan with specific emphasis on
the extraction of wastes from the ponds, transportation of the
waste and off-loading.
C An EMP was formulated in the form of an Aspects Register during
the time of application of the EA in order to manage potential
environmental impacts during the closure and development of the
Black products site. The EMP does cover the spill contingency plan
with specific emphasis on the extraction of wastes from the ponds,
transportation of the waste and off-loading. Furthermore, The
capping project is almost done and spills will no longer be an issue
on the site.
Evidence:
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— BP_Aspect register 26 August 2002(revised)
1.7 The development must comply to all migratory measures as
set out in the scoping report. C The Scoping Report mitigatory measures were included as part of
the EMPr and have been evaluated in Table 3. No non-compliances
were noted.
None
2. ESTABLISHMENT
2.2 This Authorisation is repealed if construction has not started
within two (2) years from the date of this authorisation. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.2 Sasol must implement strategies to provide opportunities for
local labour to be involved in the closure and redevelopment
of the site.
C The construction and operational phases of the project are not
applicable and this condition focuses on decommissioning for the
required audit period. Sasol targeted reputable engineering
companies as primary contractors and has used several contractors
for the project at different stages. The main contractors also employ
subcontractors. The site rehabilitation has been divided into phases
with different contractors used at each phase. WBHO was the last
contractor used along with Jones and Wagener, however, Lynco
Projects (Pty) Ltd based out of Evander (local) have been used
before on another phase of the rehabilitation capping work done.
Minutes for kick-off meetings and the quotes submitted were
available for review.
Evidence:
— 3.1_BP6 Seepage Cutoff Kickoff Minutes
— 15-064_-_BPS_and_BP6_Capping_WORK_-
_Quote_on_PMI_022_REV_3_-_2015-06-25
None
2.3 This Department should be notified in the earliest convenient
time of any decision to discontinue operation of the said
development.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3. WATER POLLUTION
3.1 Prevention of groundwater pollution should receive the
highest priority. C The Outside Ash Disposal Area which includes the Black Product
site consists of 20 groundwater boreholes monitored quarterly, 15
groundwater boreholes monitored bi-annually, and 17 groundwater
boreholes monitored annually. Three groundwater monitoring
reports by JMA Consulting dated November 2017, May 2018 and
August 2018 by JMA Consulting were available for review. Within
these reports groundwater quality is compared to drinking water
quality standards, as presented in SANS 241:2015, or SANS
241:2006 (where 2015 parameters are unavailable). It is recognised
that such standards are considered conservative, as no potable water
abstraction points are located in the vicinity. Boreholes REGM-154
and REGM-154S were identified as reflective of ‘downstream of
Black Products’, and were reported upon for May 2017, August
2017, November 2017 and August 2018 sample runs. REGM-154S
was reported to be impacted, with contaminant concentrations
elevated above drinking water standards for electrical conductivity,
total dissolved solids, calcium, magnesium, sodium, sulphate, lead,
mercury and selenium. The groundwater reports specifically
highlight that the groundwater in REGM-154S is “deteriorating”.
However, the Black Products area is currently being rehabilitated,
and will eventually be covered by the Coarse Ash Heap. Ensuring
ongoing implementation of rehabilitation measures at the Black
Products area is action item 4.5.4 in the Sasol IWWMP 2016 – 2020.
Furthermore, Sasol received authorisation for the installation of
seepage reduction and stream flow monitoring weirs (Ref:
MP/EIA/0000524/2012) from the provincial MDEDET on 12
December 2013. The authorisation included additional cut-off
trenches around the Coarse Ash Dump and van Niekerk Dam, as
well as a pipeline at the Coarse Ash Dump. This project was
authorised during the July – December 2015 period. Construction
on Phase 1a (process water section) and Phase 1b (Dam 11) of the
project have been completed. Phase 2 (WAS section) was completed
In order to remain compliant
with this condition going
forwards, Sasol must
continue to place highest
priority on the prevention of
groundwater pollution by
investing in future-available
mitigation techniques, and
researching best available
technology.
Sasol must demonstrate a
continued focus on
groundwater pollution
prevention.
Target period:
Long term
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in October 2018. Interception drains around FAD 5, Coarse Ash
Dump and the Black Products area are visible.
The water in the ash handling areas is controlled in a closed circuit
via cement channels and is reused in the system as much as possible.
The channels are designed to prevent groundwater pollution.
The entire Outside Ash area is regarded as a “dirty area”, and
contaminated run-off is mostly contained within this area by means
of a stormwater berm and trench along the southern, south-western
and western boundary.
It has been evidenced to the auditor that prevention of groundwater
pollution is receiving high priority, with significant investment
made in pollution mitigation measures. Sasol is taking practical
steps in order to combat the legacy of limited containment structure
practices of the past. This condition has been marked compliance
only on the basis that such investment in pollution prevention has
been made, as deterioration in water quality has been noted.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-
20
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31
3.2 Proper drainage for storm water runoff should be put in place. C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which aims to identify the activities related to Sasol’s
operations within the context of the receiving environment (with a
focus on water resource protection), identify the risks associated
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management. The
Black Products site falls as part of the outside ash facilities.
As described above, the ash sites have cement lined stormwater
channels and trenches as well as raised walls to allow for stormwater
None
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runoff to containment facilities before discharge. Since the Black
Products site is capped, all the water that flows on the surface is
easily channelled into the existing stormwater drains that lead to the
collecting dams.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
Stormwater collection trenches
3.3 Adhere to any other water management conditions as set out
by DWAF or any other relevant authority. C The Synfuels site as a whole has a WUL. The IWWMP indicates
that “A Water Use Licence (“WUL”) was issued on 21 November
2008 (“2008 WUL”) in terms of Chapter 4 of the National Water
Act 36 of 1998 (“NWA”), and an amendment to this WUL has been
issued on 8 January 2010 (“2010 WUL Amendment”) to authorise
water uses associated with the industrial operations at the SIC.
Condition 5 in the 2008 WUL indicates that the WUL will be
reviewed every three (3) years, and a review was thus initiated
None
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during 2014. The 2010 WUL Amendment specify in condition 12.1
that an Integrated Water and Waste Management Plan (“IWWMP”)
must be submitted for approval when the WUL is being reviewed.”
The WML has recently been amended to reference the quality
requirements listed in the WUL as previously the WML listed its
own requirements.
Evidence:
— Amended Waste Management Licence Waste Ash Site
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
4. AIR POLLUTION
4.1 Air pollution should be handled as indicated by relevant
authorities. C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental Management:
Air Quality Act. Sasol works closely with the local authority and
operates units in line with the relevant AEL and minimum legal
emission requirements.
Sasol AEL and postponement applications as well as Greenhouse
Gas emission plan and Offsetting plan are stored on IMS and on the
Sharepoint.
The site does not require an AEL that is monitored by authorities,
however, air pollution measures are in place to manage air pollution
particularly related to dust. Sasol uses the Fugitive Emissions
Management Plan to manage any air quality issues related to the
Black Products site. Dust suppression is regularly conducted around
the site, especially at locations trucks are actively moving. This was
observed during the site walk. Furthermore an independent
consultant at 3 locations close to the Black Products site (dust
buckets 1 – 3) conducts dust monitoring as shown below.
Evidence:
— Fugitive Emission Monitoring Plan_2018-10-18 updated
None
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— Compliance_Air_Secunda Complex
Dust monitoring locations
4.2 An air quality monitoring programme must be initiated to
assess the potential off-site impacts of the BP site on air
quality during the closure and redevelopment of the site.
C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental Management:
Air Quality Act. Sasol works closely with the local authority and
operates units in line with the relevant AEL and minimum legal
emission requirements.
Sasol AEL and postponement applications as well as Greenhouse
Gas emission plan and Offsetting plan are stored on IMS and on the
Sharepoint.
The site does not require an AEL that is monitored by authorities,
however, air pollution measures are in place to manage air pollution
particularly related to dust. Sasol uses the Fugitive Emissions
Management Plan to manage any air quality issues related to the
Black Products site. Dust suppression is regularly conducted around
the site, especially at locations trucks are actively moving. This was
observed during the site walk. Furthermore an independent
consultant at three locations close to the Black Products site (dust
buckets 1 – 3) conducts dust monitoring as shown below.
Evidence:
None
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— Fugitive Emission Monitoring Plan_2018-10-18 updated
— Compliance_Air_Secunda Complex
Dust monitoring locations
5. RISK MANAGEMENT
5.1 All employees who will be working in the BP site should be
aware of the emergency procedures in case of any accident. C Sasol have an environment emergency procedure (SGR-
SHE000023) that covers different scenarios on the site as well as an
environmental incident procedure process flow that indicates steps
taken when an incident occurs.
The Black Products site also has its own emergency preparedness
plan (EPP) which also covered Outside Ash. Sasol reported that the
said procedure is included in Induction training. Further to this,
Sasol undertake monthly emergency scenario drills according to the
EPP for the outside ash area.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-
000031)
None
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— External WAS Audit_2018-09-18
5.2 Sasol must implement a programme to ensure compliance
with recommendations of occupational health and safety
assessment as undertaken for the closure and re-development
of the BP site.
C All site personnel that work on Black Products site undergo SHE
induction to ensure that they are familiar with the site’s SHE aspects
and requirements. All of Sasol’s training is done through the
regional SHE learning and development academy. The induction
learning modules were available for review. The Health and Safety
officers are appointed for the site and their details were displayed on
the walls in the control room.
Furthermore, Sasol have an environment emergency procedure
(SGR-SHE000023) that covers different scenarios on the site as well
as an environmental incident procedure process flow that indicates
steps taken when an incident occurs.
The Black Products site also has its own EPP which also covered
Outside Ash. Sasol reported that the said procedure is included in
Induction training. Further to this, Sasol undertake monthly
emergency scenario drills according to the EPP for the outside ash
area.
Evidence:
— 3.3.1 Organogram_SHE Air_2018-09-17
— 3.3.1 Organogram_SHE WWLB_2018-09-03
— Induction_Mod1_1SHE Excellence
— Induction_Mod4_ProcessSafetyManagement
— Induction_Mod5_WorkPlaceSafety
— Induction_Mod6_EmergencyManagement
— Induction_Mod7_Occupational
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-
000031)
— External WAS Audit_2018-09-18
None
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6. MONITORING
6.1 Sasol, in consultation with DACE (Mpumalanga) and DWAF,
must constitute a waste monitoring committee to oversee the
closure and re-development of the BP site.
C A waste monitoring committee was developed to oversee the closure
and re-development of the Black Products site as required. The
committee’s Terms of Reference were available for review as well
as a notification letter to the Department of Environmental Affairs
of the establishment of the committee and it meets twice a year.
Evidence:
— 6.01_Waste monitoring committee_Terms of Reference_2017-
10-24
— 6.01_Establish waste monitoring committee_2017-10-24
None
6.2 Sasol must finalise and implement a long-term monitoring
and management plan in consultation with DACE and
DWAF, to monitor and manage potential ground and surface
water contamination associated with the BP site.
C There is no proof that DACE and DWAF were involved in setting
up of a long term monitoring plan. The set up and their involvement
is also not applicable as it would have been done prior to 2014.
However, Sasol have a long term monitoring plan which is outlined
in the IWWMP and as required by the WUL and WML.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-
20
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
None
6.3 This Department must be granted access at any reasonable
times to the property to investigate any possible
environmental impacts that may be caused by the
rehabilitation and re-development of the BP site.
C The auditor was informed that the Department has been granted
access on a number of occasions however no reports have been
provided regarding feedback following their site visits.
None
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7. REPORTING
7.1 Records relating to the compliance/non-compliance with the
conditions of the authorisation must be kept in good order.
Such records must be made available to this Department
within seven (7) workdays of the date of request by this
Department.
N/A There is no set requirement for conducting audits against the
conditions of this licence. No previous audits over the last 5 years
were available for review and there has been no indication that the
Department requested any records.
Ensure this current audit is
kept in good order for future
reference.
Target period:
Long term
7.2 Non-compliance with, or any deviations from the conditions
as set out in the Record of Decision is regarded as an offence
and, after reasonable provision has been made for remedial
action, will be dealt with in terms of section 29, 30 and 31A
of the Act.
N/A Noted. None
7.3 Any complaint regarding the said rehabilitation and re-
development of the BP site must be thoroughly investigated
and addressed to the satisfaction of all parties concerned.
Copies of such complaint must be forwarded to this
Department within 48 hours.
C All environmental complaints received from interested and affected
parties, both internal and external to the organisation, are recorded
in a complaints register that is available and the Environmental
department. Complaints are investigated and reported in line with
the procedure and as per legal requirements.
Environmental complaints contact details are communicated to
internal and external stakeholders
There have been no complaints received regarding the Black
Products site since the operations commenced. The environmental
complaints register was available for review and contained
complaints for all business units dating back from 2008.
Evidence:
— Environmental Complaints Register_2019-02-18
— Compliance_Complaints_Secunda Complex
— Environmental complaints procedure_SGR-SHE-
000022_Rev05_2019-01
None
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Table 3: Audit Findings – Environmental Management Plan
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1. CONSTRUCTION AND PRE-COMMISSIONING
1.1 Transport of feed to plant:
List of documents: Conceptual package, Basic engineering
package, Detail design package, Commissioning plan,
Operations manual, EPCM contract, Contractor procedure
Interface doc's Permits/ROD Plan of execution.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.2 Disposal of used potable water:
Potable water use: HS occupational hygiene requirements to
be obtained and observed. Water to be available for
construction personnel. Documents relating to this aspect to
referenced to project or safety files.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.3 Labour and employment required:
Strategy for employment to be completed. Local people to be
used as labourers. This aspect should be discussed with the
contractor and included in contract or RFQ documents.
Reference to be supplied. Procedure / strategy towards skills
development to be completed. Strategy document to be kept
on file and reference included in closeout documentation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.4 Permit requirements for TLC / CAPCO / DWAF / Transport /
Excavations etc:
Legal permit requirements to be investigated and expressed in
terms of a schedule for permit application. Application
documents to be kept on the Safety or project file and
references to be included in the closeout documentation. All
relevant emergency plans to be completed
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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1.5 Steam usage / electricity required / firewater for firefighting.
Confirm availability. Reference to document in project file. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.6 Firewater tie-in points for firefighting/Water use for
hydrotesting / water use for flushing. Confirm availability.
Reference to document in project file.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.7 Foreign Investment:
The possibilities for foreign investment should be
investigated. Document references required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.8 ROD Conditions as received on 27 February 2001 should be
implemented and the required accountabilities allocated to all
relevant departments / personnel involved e.g. SSF
Environment.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.9 New Technology:
The use of new technology should be investigated. Document
references required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.10 Construction / Clean-up kick-off meeting:
All environmental aspects and ROD to be discussed at this
kick-off meeting.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
1.11 Sandblasting, Welding, Spray Painting:
HS / occupational hygiene requirements to be obtained and
observed (contractor). Document references required.
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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1.12 Project environmental closeout inspections to be held on time
at the site / safety file. Project manager and process engineer
to assist in the provision of reference documents and site visit.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2. COMMISSIONING AND START-UP
2.1 Disposal / routing of spent chemicals for cleaning / pickling /
passivation and desiccants, solvents, catalysts:
Disposal route of chemicals to be confirmed. Suitable site /
system to be identified.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.2 Disposal/routing of off-spec by-products and products:
Disposal route of off-spec material to be confirmed. Suitable
site / system to be identified. Documentation to be kept on file
and reference to document and file to be included in closeout
documents.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.3 Disposal of construction wastes. To include wastes from spray
painting, welding, grinding, cutting of pipes, storage of
cement/grease, oils and paints and during the mixing of
concrete:
HS / occupational hygiene requirements to be obtained and
observed (contractor). Spray painting & welding. Ref to
documents in project or safety file required. H&S aspects and
environmental requirements to be communicated to the
contractor responsible for construction.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.4 Routing/disposal/ re-use/storage of excavated materials /
soils:
To be co-ordinate with SSF Environment. Confirm
availability of a suitable site for storage of topsoil and other
excavated material to be re-used on site, otherwise disposed.
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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To be included in works instruction documents of contractors
and discussed at construction / commissioning kick-off
meeting. Reference will be the works instruction documents.
2.5 Scoping Report (SR): Contaminated soil and additional soil
contamination: The ultimate closure and redevelopment of the
BPS will however decrease the potential for additional soil
contamination.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.6 Disposal / re-use of building rubble and other construction
waste:
Contractor to responsibly dispose of building rubble and
construction waste at a suitable waste facility. Requirements
to be included in the contractors contract / works instruction.
Reference to be included in closeout documentation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.7 Handling / storage / disposal of redundant piping and
equipment:
Disposal route to be confirmed. Document addressing this
issue to be referenced to project or safety file.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.8 Disposal of water used for hydro-testing:
Confirm availability and disposal route if applicable. If this
activity is the responsibility of contractor, this issue should be
included in the contract / works instruction documentation and
referenced in the closeout document.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.9 Disposal of water used for flushing:
Confirm availability and disposal route. Interface documents
to be kept on project file. Reference to be included in closeout
documentation.
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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2.10 Routing/disposal of process effluent:
Disposal route to be confirmed. Acceptable site / equipment
to be indicated. Reference to documentation in safety or
project file required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.11 Labour and employment required:
Number of required additional personnel to be confirmed.
Local construction workers to be used where possible. A
strategy for the use of local people is to be completed.
Procedure / strategy towards skills development to be
completed. Strategy document to be kept on file and reference
included in closeout documentation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.12 Pressure on infrastructure / roads and services due to
increased workforce.
To be coordinated with the traffic department in terms of
schedule. Communication to be recorded and documents to be
kept on file if required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.13 Dolorite mining:
Dolorite to mined / obtained from a licensed site only. If this
is also the responsibility of the contractor, he should be
informed in his contract / works instruction documentation as
well as at the relevant kick off meetings.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.14 Permit requirements for TLC / CAPCO / DWAF / Transport /
Excavations etc:
Legal permit requirements to be investigated and expressed in
terms of a schedule for permit application. Application
documents to be kept on the Safety or project file and
references to be included in the closeout documentation.
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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2.15 Foreign Investment: The possibilities for foreign investment
should be investigated. Document references required. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.16 ROD Conditions as received on 27 February 2001 should be
implemented and the required accountabilities allocated to all
relevant departments / personnel involved e.g. SSF
Environment.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
2.17 Project Environmental Closeout inspections to be held on time
at the site / safety file. Project manager and process engineer
to assist in the provision of reference documents and site visit.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
3. OPERATING, MAINTENANCE AND SHUTDOWN
3.1 Transport of chemicals for cleaning / pickling / passivation
and desiccants solvents, catalysts:
Requirements to be obtained from SSF traffic officials.
Emergency procedure for loss of containment to be updated.
Procedure to be referenced in Project file or safety file.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.2 Disposal / routing of off-spec by-products and products:
Obtain and observe Risk and HS requirements. These
requirements to be kept on project file / safety file and
reference to be included in closeout documentation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.3 Handling and disposal of contaminated equipment:
SR: Contaminated soil: - As a result of disposal of waste at
the BPS has a potential to contribute to groundwater
contamination, additional soil contamination could occur
during the closure and redevelopment of the BPS.
Mitigation:-baseline monitoring mentioned - the ultimate
closure will however decrease the potential for additional soil
C Groundwater monitoring is conducted on a monthly basis and a
sample groundwater monitoring reports by JMA Consulting were
available for review.
Soil pollution monitoring is done as part of contaminated land
management. Phase 1 (December 2015) and Phase 2 (August) land
monitoring reports have been conducted for the Synfuels site as a
whole by Geo Pollution Technologies. Recommendations from each
None
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contamination. In the event of waste product spills during the
closure of the BPS would occur in the vicinity of the BP dams.
Significance of the existing soil contamination associated
with the BPS is considered to be low.
report are marked down for implementation as required.
Contaminated land is managed within legal requirements and
incident registers are maintained in order to monitor any
contamination events.
Evidence:
— Phase 1_Contaminated Land
Assessment_November_2015_Final 1.0
— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of
2_2018-08-28
— IWWMP SIC 2015 Final_2018-05-15
3.4 Solid waste generated during the regeneration of spent-
catalyst:
Current disposal route to be confirmed. Possible impacts on
water and soil to be mitigated. Documentation on possible
mitigation to be kept on file and reference to be included in
closeout documentation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.5 Stormwater management (routing of on- spec/contaminated
stormwater):
SR: Stormwater from area adjacent to the BPS is diverted
away from the site. All rainfall falling within the site is
contained within the site and either percolates into the ground
or evaporates. Once the closure and redevelopment of the BPS
is complete and higher coarse ash stacking is occurring,
stormwater within the area, which may be contaminated,
could flow off-site. Appropriate stormwater management will
be established for the closure and redevelopment of the BPS,
although it will have low significance.
C Sasol have an Integrated Waste and Water Management Plan
(IWWMP) which aims to identify the activities related to Sasol’s
operations within the context of the receiving environment (with a
focus on water resource protection), identify the risks associated
with these operations, and subsequently manage these risks by
means of an action plan committed to by Sasol management. The
Black Products site falls as part of the outside ash facilities.
As described above, the ash sites have cement lined stormwater
channels and trenches as well as raised walls to allow for stormwater
runoff to containment facilities before discharge. Since the Black
Products site is capped, all the water that flows on the surface is
easily channelled into the existing stormwater drains that lead to the
collecting dams as shown below.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
None
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— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
Stormwater collection trenches
3.6 Routing/disposal of process effluent:
The disposal route is to be confirmed. Acceptable site /
equipment to be indicated. Reference to documentation in
safety or project file required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.7 Measuring of effluent and method:
Method of measurement to be confirmed. To be reviewed
during a possible HAZOP meeting (only if applicable).
Reference to Documents required.
N/A All the potential seepage generated is collected and channelled
towards the effluent collection dams around the Outside Ash area.
None
3.8 Other emissions: C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental Management:
Air Quality Act. Sasol works closely with the local authority and
None
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Dust emissions to be investigated. SR: Impact on air quality:
Gaseous emissions are the primary emissions to the
atmosphere from the BPS, VOC's, SVOC's, PAH's and
phenols. Increase in ambient temperatures to greater than
25°C result in noticeable increases in ambient concentrations
of organic smelling vapours. Particulate emissions are also
significant in the immediate vicinity, especially during windy
conditions.
During closure an increase in emissions from the site will
occur. Level of contamination in the ambient air is generally
below levels of concern regarding OHS exposure limits.
Sampling during management study suggests gaseous
emissions from the BPS are sufficiently diluted by the
receiving environment. The total particulate load emitted from
the entire waste complex is relatively low. Capping of the BPS
will eliminate the potential for gaseous and particulate
emissions from the area particularly once coarse ash stacking
commences. However, this activity will result in an increase
in particulate emissions from the Sasol industrial complex.
Present situation low significance. Potential impact of the
BPS on air quality during closure medium significance. High
coarse ash stacking on the BPS medium significance.
operates units in line with the relevant AEL and minimum legal
emission requirements.
Sasol AEL and postponement applications as well as Greenhouse
Gas emission plan and Offsetting plan are stored on IMS and on the
Sharepoint.
It must be noted that the Black Products site has been capped off and
completely rehabilitated, eliminating the potential for gaseous and
particulate emissions from the area.
The site does not require an AEL that is monitored by authorities,
however, air pollution measures are in place to manage air pollution
particularly related to dust, especially once coarse ash stacking
commences. Sasol uses the Fugitive Emissions Management Plan to
manage any air quality issues related to the Black Products site. Dust
suppression is regularly conducted around the site, especially at
locations trucks are actively moving. This was observed during the
site walk. Furthermore dust monitoring is conducted at 3 locations
close to the Black Products site (dust buckets 1 – 3) as shown below.
Evidence:
— Fugitive Emission Monitoring Plan_2018-10-18 updated
— Compliance_Air_Secunda Complex
Dust monitoring locations
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3.9 Labour and employment required:
Confirm usage of existing personnel if no additional
temporary people will be used. This confirmation could be an
email document to be kept on the project or safety file.
Procedure / strategy towards skills development to be
completed. Strategy document to be kept on file and reference
included in closeout documentation.
C Sasol subcontracted the work conducted on the Black Products site
to make use of specialised engineering contractors. These
organisations bring in their own personnel who are sufficiently
trained to conduct the work, however, all contractors undergo Sasol
induction before they commence work.
All Sasol personnel that work on Black Products site undergo SHE
induction to ensure that they are familiar with the site’s SHE aspects
and requirements. All of Sasol’s training is done through the
regional SHE learning and development academy. The induction
learning modules were available for review. The Health and Safety
officers are appointed for the site and their details were displayed on
the walls in the control room.
None
3.10 Labour and employment required:
SR: There is potential for employment opportunities during
the closure and redevelopment of the BPS. Limited
employment are envisaged as OHSA indicated that the use of
manual labour must be limited due to high risks associate with
the work required. Low significance.
C Sasol targeted reputable engineering companies as primary
contractors and has used several contractors for the project at
different stages. The main contractors also employ subcontractors..
These organisations bring in their own personnel who are
sufficiently trained to conduct the work, however, all contractors
undergo Sasol induction before they commence work and hence
limit manual labour. Manual labour is sourced locally, especially if
the contractor is local.
Evidence:
— 3.1_BP6 Seepage Cutoff Kickoff Minutes
— 15-064_-_BPS_and_BP6_Capping_WORK_-
_Quote_on_PMI_022_REV_3_-_2015-06-25
None
3.11 Area influenced by visual impact:
SR: Limited or no impact has been identified. Although the
BP dams is elevated above ground level, they are bordered on
all sides by fine and coarse ash dams which are on average 30
- 40 m higher than the dams and the width of the coarse ash
dams varying between 300 and 1100m. The BP dams is not
directly visible from any of the adjacent residential and/or
commercial areas including the closest formal residential area,
C As noted in the SR, there is negligible significance with regards to
visual impact related to the site. There have been no complaints
received regarding Black Products site, including visual complaints,
since the operations commenced. The environmental complaints
register was available for review and contained complaints for all
business units dating back from 2008.
Evidence:
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Embalenhle (4 km east). Therefore no potential visual impact
is envisaged during the closure and redevelopment of the site,
which has negligible significance.
— Environmental Complaints Register_2019-02-18
3.12 Does an emergency plan for major loss of containment in the
plant (with consideration of air, groundwater, soil and surface
water) exist?
All relevant emergency plans to be completed / updated and
communicated with SSF Environment, Anton Noordman and
contractors. Issues to be included are surface water, soil,
ground water, air economy and impacts on humans. Records
of this communication to be kept on file and reference to be
included in closeout documents.
C Sasol have an environment emergency procedure (SGR-
SHE000023) that covers different scenarios on the site as well as an
environmental incident procedure process flow that indicates steps
taken when an incident occurs.
The Black Products site also has its own EPP which also covered
Outside Ash. Sasol reported that the said procedure is included in
Induction training. Further to this, Sasol undertake monthly
emergency scenario drills according to the EPP for the outside ash
area.
These procedures are communicated to the contractors during
induction.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-
000031)
— External WAS Audit_2018-09-18
None
3.13 Foreign Investment:
The possibilities for foreign investment should be
investigated. Document references required.
C Sasol have investigated the possibilities of foreign investment to
fund the rehabilitation process as required. The Remediation
Programme Progress report was available for review and it focused
on cost estimations for the project. Section 7 of the document
indicated the split of how much foreign investment would be utilised
on the project.
Evidence:
— J.54_ConsBPRemediationProgReport Rev A 00-00667-P5-9_
None
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3.14 ROD Conditions as received on 27 February 2001 should be
implemented and the required accountabilities allocated to all
relevant departments / personnel involved e.g. SSF
Environment.
C The ROD conditions are being implemented as required, and no
non-compliances have been noted for the ROD conditions over the
course of this audit.
Evidence:
— 033_41101534_20190125_Sasol_SSO_WA_EA_14.25.16
EV 11_V1
None
3.15 Satellite Industries:
Investigate possible satellite industry development.
Document references required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.16 Minimise Current Production Losses:
Value improvement practices to be identified and completed.
Document references required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.17 Optimum Utilisation of Resources:
Impact on operations to be investigated. Document references
required.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.18 ROD Condition: This Authorisation refers to the project
specified above and described in the ROD. Separate
applications must be lodged for any other development and/or
activity at or near the proposed development, which is covered
by Section 21 & 22 of the Act and Government Notice R1182
of 5 September 1997.
N/A Noted. None
3.19 ROD Condition: Authorisation 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.
A full legal review does not form part of the scope of this Audit. The
site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review.
None
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Evidence:
— Audit report_383569_ISO 14001_2015_stage2_2018-07-27
— SSO DQS ISO 14001 2015
3.20 ROD Condition: Copies of the relevant documents mentioned
in 1.3 above, must be forwarded to this Department within 3
months of the issuing of this Authorisation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
3.21 ROD Condition: No development may take place on the area
of concern without the necessary permits/approvals and /or
service agreement from other relevant authorities.
C The site was approved for development when an EA was issued by
the Provincial Department on 4 December 2000 with 14.25.16 EV
11 as the reference number. A WML was issued on 4 April 2013 for
the ash handling facility with reference number 12/9/11/L1/6. Four
variations on the amended WML were further issued: which
included:
— Waste Licence Variation for height Increase of Fine Ash Dam
5 (Reference Number: 12/9/11/L1/6/V2);
— Waste Licence Variation for condition 4.7 (Reference Number:
12/9/11/L1/6/V2);
— Waste Licence Variation for condition 4.1 and 4.9 (Reference
Number: 12/9/L1/6/R1/V5);
— Waste Licence Variation for condition 1.1.2, 3.2, 4.5, 6.2.1.1,
6.2.2.2, 6.2.1.3, 6.2.2.1, 6.2.3.1, 6.2.4.1, 6.2.4.3, 6.2.4.2,
6.2.5.1 and 6.2.6.1 (Reference Number: 12/9/L1/6/V3 dated 28
March 2018).
A copy of the WML and the September 2018 compliance audit
report by SRK Consulting was available for review.
Evidence:
— Amended Waste Management Licence Waste Ash Site
— Bi-Annual External Waste Management Licence Compliance
Report – Waste Ash Disposal Site_September 2018
— 14.25.16 EV 11_Black Products Site_2000-12-04
None
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3.22 ROD Condition: An Environmental Management Plan must
be formulated to minimise and manage potential
environmental impacts during the closure and redevelopment
of the Black Products site. The EMP must include a spill
contingency plan with specific emphasis on the extraction of
wastes from the ponds, transportation of the waste and off-
loading.
C An EMPr was formulated in the form of an Aspects Register during
the time of application of the EA in order to manage potential
environmental impacts during the closure and development of the
Black products site. The EMPr does cover the spill contingency plan
with specific emphasis on the extraction of wastes from the ponds,
transportation of the waste and off-loading. Furthermore, The
capping project is almost done and spills will no longer be an issue
on the site.
Evidence:
— BP_Aspect register 26 August 2002(revised)
None
3.23 ROD Condition: This Department may change or amend any
of the conditions in this authorisation if in the opinion of the
Department it is environmentally justified.
N/A Noted. None
3.24 ROD Condition: The development must comply to all
mitigatory measures as set out in the scoping report. C The Scoping Report mitigatory measures were included as part of
the EMPr and have been evaluated in Table 3. No non-compliances
were noted.
None
3.25 ROD Condition: This Authorisation is repealed if the
rehabilitation and redevelopment of the Black Products site
has not commenced within 2 years from the date of this
Authorisation.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None
3.26 ROD Condition: This Department should be notified in the
earliest convenient time of any decision to discontinue the
operation of the said development.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been completely
rehabilitated.
None
3.27 ROD Condition: Sasol must implement strategies to provide
opportunities for local labour to be involved in the closure and
redevelopment of the site.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
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3.28 ROD Condition: Proper drainage for storm water runoff
should be put in place. C Sasol have an IWWMP which aims to identify the activities related
to Sasol’s operations within the context of the receiving
environment (with a focus on water resource protection), identify
the risks associated with these operations, and subsequently manage
these risks by means of an action plan committed to by Sasol
management. The Black Products site falls as part of the outside ash
facilities.
As described above, the ash sites have cement lined stormwater
channels and trenches as well as raised walls to allow for stormwater
runoff to containment facilities before discharge. Since the Black
Products site is capped, all the water that flows on the surface is
easily channelled into the existing stormwater drains that lead to the
collecting dams as shown below.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
None
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Stormwater collection trenches
3.29 ROD Condition: Prevention of groundwater pollution should
receive the highest priority. C The Outside Ash Disposal Area which includes the Black Product
site consists of 20 groundwater boreholes monitored quarterly, 15
groundwater boreholes monitored bi-annually, and 17 groundwater
boreholes monitored annually. Three groundwater monitoring
reports by JMA Consulting dated November 2017, May 2018 and
August 2018 by JMA Consulting were available for review. Within
these reports groundwater quality is compared to drinking water
quality standards, as presented in SANS 241:2015, or SANS
241:2006 (where 2015 parameters are unavailable). It is recognised
that such standards are considered conservative, as no potable water
abstraction points are located in the vicinity. Boreholes REGM-154
and REGM-154S were identified as reflective of ‘downstream of
Black Products’, and were reported upon for May 2017, August
2017, November 2017 and August 2018 sample runs. REGM-154S
was reported to be impacted, with contaminant concentrations
elevated above drinking water standards for electrical conductivity,
total dissolved solids, calcium, magnesium, sodium, sulphate, lead,
In order to remain compliant
with this condition going
forwards, Sasol must
continue to place highest
priority on the prevention of
groundwater pollution by
investing in future-available
mitigation techniques, and
researching best available
technology.
Sasol must demonstrate a
continued focus on
groundwater pollution
prevention.
Target period:
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mercury and selenium. The groundwater reports specifically
highlight that the groundwater in REGM-154S is “deteriorating”.
However, the Black Products area is currently being rehabilitated,
and will eventually be covered by the Coarse Ash Heap. Ensuring
ongoing implementation of rehabilitation measures at the Black
Products area is action item 4.5.4 in the Sasol IWWMP 2016 – 2020.
Furthermore, Sasol received authorisation for the installation of
seepage reduction and stream flow monitoring weirs (Ref:
MP/EIA/0000524/2012) from the provincial MDEDET on 12
December 2013. The authorisation included additional cut-off
trenches around the Coarse Ash Dump and van Niekerk Dam, as
well as a pipeline at the Coarse Ash Dump. This project was
authorised during the July – December 2015 period. Construction
on Phase 1a (process water section) and Phase 1b (Dam 11) of the
project have been completed. Phase 2 (WAS section) was completed
in October 2018. Interception drains around FAD 5, Coarse Ash
Dump and the Black Products area are visible.
The water in the ash handling areas is controlled in a closed circuit
via cement channels and is reused in the system as much as possible.
The channels are designed to prevent groundwater pollution.
The entire Outside Ash area is regarded as a “dirty area”, and
contaminated run-off is mostly contained within this area by means
of a stormwater berm and trench along the southern, south-western
and western boundary.
It has been evidenced to the auditor that prevention of groundwater
pollution is receiving high priority, with significant investment
made in pollution mitigation measures. Sasol is taking practical
steps in order to combat the legacy of limited containment structure
practices of the past. This condition has been marked compliance
only on the basis that such investment in pollution prevention has
been made, as deterioration in water quality has been noted.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
Long term
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— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-
20
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31
3.30 ROD Condition: Air pollution should be handled as indicated
by relevant authorities. C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental Management:
Air Quality Act. Sasol works closely with the local authority and
operates units in line with the relevant AEL and minimum legal
emission requirements.
Sasol AEL and postponement applications as well as Greenhouse
Gas emission plan and Offsetting plan are stored on IMS and on the
Sharepoint.
The site does not require an AEL that is monitored by authorities,
however, air pollution measures are in place to manage air pollution
particularly related to dust. Sasol uses the Fugitive Emissions
Management Plan to manage any air quality issues related to the
Black Products site. Dust suppression is regularly conducted around
the site, especially at locations trucks are actively moving. This was
observed during the site walk. Furthermore dust monitoring is
conducted at 3 locations close to the Black Products site (dust
buckets 1 – 3) as shown below.
Evidence:
— Fugitive Emission Monitoring Plan_2018-10-18 updated
— Compliance_Air_Secunda Complex
None
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Dust monitoring locations
3.31 ROD Condition: Adhere to any other water management
conditions set out by DWAF or any other relevant authority. C The Synfuels site as a whole has a WUL. The IWWMP indicates
that “A Water Use Licence (“WUL”) was issued on 21 November
2008 (“2008 WUL”) in terms of Chapter 4 of the National Water
Act 36 of 1998 (“NWA”), and an amendment to this WUL has been
issued on 8 January 2010 (“2010 WUL Amendment”) to authorise
water uses associated with the industrial operations at the SIC.
Condition 5 in the 2008 WUL indicates that the WUL will be
reviewed every three (3) years, and a review was thus initiated
during 2014. The 2010 WUL Amendment specify in condition 12.1
that an Integrated Water and Waste Management Plan (“IWWMP”)
must be submitted for approval when the WUL is being reviewed.”
The WML has recently been amended to reference the quality
requirements listed in the WUL as previously the WML listed its
own requirements.
Evidence:
— Amended Waste Management Licence Waste Ash Site
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
None
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3.32 ROD Condition: All employees who will be working in the
Black Products site should be aware of emergency procedures
in case of any accidents.
C Sasol have an environment emergency procedure (SGR-
SHE000023) that covers different scenarios on the site as well as an
environmental incident procedure process flow that indicates steps
taken when an incident occurs.
The Black Products site also has its own EPP which also covered
Outside Ash. Sasol reported that the said procedure is included in
Induction training. Further to this, Sasol undertake monthly
emergency scenario drills according to the EPP for the outside ash
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-
000031)
— External WAS Audit_2018-09-18
None
3.33 ROD Condition: An air quality monitoring programme must
be initiated to assess the potential off-site impacts of the Black
Products site on air quality during the closure and
redevelopment of the site.
C Sasol makes use of an integrated approach to air quality
management as governed by National Environmental Management:
Air Quality Act. Sasol works closely with the local authority and
operates units in line with the relevant AEL and minimum legal
emission requirements.
Sasol AEL and postponement applications as well as Greenhouse
Gas emission plan and Offsetting plan are stored on IMS and on the
Sharepoint.
The site does not require an AEL that is monitored by authorities,
however, air pollution measures are in place to manage air pollution
particularly related to dust. Sasol uses the Fugitive Emissions
Management Plan to manage any air quality issues related to the
Black Products site. Dust suppression is regularly conducted around
the site, especially at locations trucks are actively moving. This was
observed during the site walk. Furthermore an independent
consultant at 3 locations close to the Black Products site (dust
buckets 1 – 3) conducts dust monitoring as shown below.
Evidence:
None
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— Fugitive Emission Monitoring Plan_2018-10-18 updated
— Compliance_Air_Secunda Complex
Dust monitoring locations
3.34 ROD Condition: Sasol in consultation with DACE -MP and
DWAF, must constitute a waste monitoring committee to
oversee the closure and redevelopment of the Black Products
site.
C A waste monitoring committee was developed to oversee the closure
and re-development of the Black Products site as required. The
committee’s Terms of Reference were available for review as well
as a notification letter to the Department of Environmental Affairs
of the establishment of the committee and it meets twice a year.
Evidence:
— 6.01_Waste monitoring committee_Terms of Reference_2017-
10-24
— 6.01_Establish waste monitoring committee_2017-10-24
None
3.35 ROD Condition: Sasol must implement a programme to
ensure compliance with the recommendation of the
occupational health and safety assessment as undertaken for
the closure and redevelopment of the Black Products site.
C All site personnel that work on Black Products site undergo SHE
induction to ensure that they are familiar with the site’s SHE aspects
and requirements. All of Sasol’s training is done through the
regional SHE learning and development academy. The induction
learning modules were available for review. The Health and Safety
officers are appointed for the site and their details were displayed on
the walls in the control room.
None
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Furthermore, Sasol have an environment emergency procedure
(SGR-SHE000023) that covers different scenarios on the site as well
as an environmental incident procedure process flow that indicates
steps taken when an incident occurs.
The Black Products site also has its own EPP which also covered
Outside Ash. Sasol reported that the said procedure is included in
Induction training. Further to this, Sasol undertake monthly
emergency scenario drills according to the EPP for the outside ash
area.
Evidence:
— 3.3.1 Organogram_SHE Air_2018-09-17
— 3.3.1 Organogram_SHE WWLB_2018-09-03
— Induction_Mod1_1SHE Excellence
— Induction_Mod4_ProcessSafetyManagement
— Induction_Mod5_WorkPlaceSafety
— Induction_Mod6_EmergencyManagement
— Induction_Mod7_Occupational
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-
000031)
— External WAS Audit_2018-09-18
3.36 ROD Condition: This department must be granted access at
any reasonable times to the property to investigate any
possible environmental impacts that may be caused by the
rehabilitation and redevelopment of the Black Products site.
C The auditor was informed that the Department has been granted
access on a number of occasions however no reports have been
provided regarding feedback following their site visits.
None
3.37 ROD Condition: Sasol must finalise and implement a long-
term monitoring and management plan in consultation with
DACE and DWAF, to monitor and manage potential ground
C There was no proof of a long-term monitoring and management plan
that was agreed up with DACE and DWAF to monitor and manage
potential ground and surface water contamination associated with
the BP site. However, Sasol have a ground and surface water
None
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and surface water contamination associated with the black
Products site.
monitoring programme as indicated in the IWWMP and as within
the licensed WUL.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-
20
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
3.38 ROD Condition: Non-compliance with or any deviation from
the conditions of this authorisation is regarded as an offence,
and after 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.
N/A Noted. None
3.39 ROD Condition: Records relating to the compliance or non-
compliance with the conditions of the authorisation must be
kept in good order. Such records must be made available to
this Department within seven working days from the date of
written request for such records by the Department.
N/A There is no set requirement for conducting audits against the
conditions of this licence. No previous audits over the last 5 years
were available for review and there has been no indication that the
Department requested any records.
Ensure this current audit is
kept in good order so that it
is readily available on
request in the future.
Target period:
Long term
3.40 ROD Condition: Any complaint regarding the said
rehabilitation and redevelopment of the Black Products site
must be thoroughly investigated and addressed to the
satisfaction of all parties concerned. Copies of such
complaints must be forwarded to this Department within 48
hours of such a complaint being lodged.
C All environmental complaints received from interested and affected
parties, both internal and external to the organisation, are recorded
in a complaints register that is available and the Environmental
department. Complaints are investigated and reported in line with
the procedure and as per legal requirements.
Environmental complaints contact details are communicated to
internal and external stakeholders
There have been no complaints received regarding the Black
Products site since the operations commenced. The environmental
None
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complaints register was available for review and contained
complaints for all business units dating back from 2008.
Evidence:
— Environmental Complaints Register_2019-02-18
— Compliance_Complaints_Secunda Complex
— Environmental complaints procedure_SGR-SHE-
000022_Rev05_2019-01
3.41 Presentation BP/BE Kick-off: Scope of work: Refer to scope
of work in the database. N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable as
the Black Products site is closed off and has been rehabilitated.
None
3.42 SR: Groundwater contamination: No known formal users of
groundwater within 5km radius of the BPS. Analysis of the
groundwater showed limited contamination by organics and
inorganics. Short-term management is to monitor
groundwater with respect to contaminants from the BPS if
contamination is found to represent a problem. Medium to
long-term management is to install cut-off and interception
trenches for leachate generated at BPS. Abstraction of
groundwater may also be implemented to prevent the
migration of groundwater away from the BPS should it be
required. Impact of groundwater is considered to be of
medium significance.
C Short-term management requirement:
The Outside Ash Disposal Area which includes the Black Product
site consists of 20 groundwater boreholes monitored quarterly, 15
groundwater boreholes monitored bi-annually, and 17 groundwater
boreholes monitored annually. Three groundwater monitoring
reports by JMA Consulting dated November 2017, May 2018 and
August 2018 by JMA Consulting were available for review.
Medium to long-term management requirement:
Sasol installed interception drains around the Outside Ash area
which includes the Black Products site. The interception drains are
constructed to effectively intercept and drain any potential surface
and sub-surface seepage generated from the treatment and disposal
area. The drains were observed during the site visit.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— Bi-Annual External Waste Management Licence Compliance
Report – Waste Ash Disposal Site_September 2018
None
3.43 SR: Surface water contamination: Potential for waste products
to enter nearby surface water bodies as a result of failure of C The Black Products site is closed off and has been completely
rehabilitated. Any surface water that flows on the side is treated as
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
one of the side slopes of the ponds. The option of closure
involves extraction of the liquid phase of the material within
the ponds. The solid/sludge material remaining will be
covered with coarse ash, which will negate the potential for
waste within the ponds to flow off-site in the event of slope
failure. Low significance.
stormwater that will either evaporate or flow over the sides of the
capped site.
Sasol have an IWWMP which aims to identify the activities related
to Sasol’s operations within the context of the receiving
environment (with a focus on water resource protection), identify
the risks associated with these operations, and subsequently manage
these risks by means of an action plan committed to by Sasol
management. The Black Products site falls as part of the outside ash
facilities.
As described above, the ash sites have cement lined stormwater
channels and trenches as well as raised walls to allow for stormwater
runoff to containment facilities before discharge. Since the Black
Products site is capped, all the water that flows on the surface is
easily channelled into the existing stormwater drains shown below
that lead to the collecting dams.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4
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Stormwater collection trenches
3.44 SR: Noise Potential noise during closure relate primarily to
the use of vehicles and heavy machinery at the site. Noise
generated by such equipment could impact on personnel
within the Sasol industrial complex itself, the neighbouring
residential and commercial areas. Closure will not be an
ongoing activity and will be completed in a limited time.
Closest areas occupied by personnel are at least 2.5 km away.
Low significance.
C Noise surveys are conducted to ensure that Sasol Secunda facilities
do not affect the neighbouring communities. Safetech conducts the
surveys for all Secunda operations and noise measurements are
taken at 5 locations (Sasol entry points, Charlie 15) as shown in the
figure below. These measurements are representative of all of
Sasol’s Secunda operations including the Black Products site. A
sample noise survey report dated 26 August 2016 was available for
review and it indicated none of the points exceeded the SANS limits
for industrial areas for both daytime and nighttime monitoring.
There have been no complaints received regarding the Black
Products site since the operations commenced. The environmental
complaints register was available for dating back from 2008.
Evidence:
— J.53_EnvNoise 5439(Final) ver1_2016-08-26
None
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— Environmental Complaints Register_2019-02-18
Noise monitoring points
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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 7 3 0 4
ESTABLISHMENT 3 1 0 2
WATER POLLUTION 3 3 0 0
AIR POLLUTION 2 2 0 0
RISK MANAGEMENT 2 2 0 0
MONITORING 3 3 0 0
REPORTING 3 1 0 2
Total Count 23 15 0 8
Total Percentage 65% 0% 35%
Percentage Compliance with Applicable Conditions 100%
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Figure 5-1 illustrates the number/count contribution of the findings of the EA per section while Figure 5-2
presents the total proportion of compliance for the facility.
Figure 5-1: Number/Count contribution of findings made to the EA conditions per Section
Figure 5-2: Overall count findings on compliance to the EA conditions
0
1
2
3
4
5
6
7
8
Sectional Count Contribution
C
NC
N/A
150
8
Total Compliance
C
NC
N/A
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Figure 5-3 illustrates the percentage contribution of the findings of the EA conditions. Figure 5-4 presents the
total percentage compliance for the facility.
Figure 5-3: Percentage contribution of findings made to the EA conditions per Section
Figure 5-4: Overall percentage findings on compliance to the EA conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
65%0%
35%
Total Percentage Compliance
C
NC
N/A
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5.2 ENVIRONMENTAL MANAGEMENT PLAN
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the EMPr conditions are as listed in Table 5
below.
Table 5: Summary of EMPr Compliance Audit Findings
SECTION OF THE EMPR NO. COMMITMENTS C NC NA
CONSTRUCTION AND PRE-COMMISSIONING 12 0 0 12
COMMISSIONING AND START-UP 17 0 0 17
OPERATING, MAINTENANCE AND SHUTDOWN 44 26 0 18
Total Count 73 26 0 47
Total Percentage 36% 0% 64%
Percentage Compliance with Applicable Conditions 100%
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Figure 5-5 illustrates the number/count contribution of the findings of the EMPr per section while Figure 5-6
presents the total proportion of compliance for the facility.
Figure 5-5: Number/Count contribution of findings made to the EMPr conditions per Section
Figure 5-6: Overall count findings on compliance to the EMPr conditions
05
101520253035404550
Construction and Pre-Commissioning
Commissioning and Start-Up Operating, Maintenance andShutdown
Sectional Count Contribution
C
NC
N/A
26
0
47
Total Compliance
C
NC
N/A
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Figure 5-7 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 5-8 presents the
total percentage compliance for the facility.
Figure 5-7: Percentage contribution of findings made to the EMPr conditions per Section
Figure 5-8: Overall percentage findings on compliance to the EMPr conditions
0102030405060708090
100
Construction and Pre-Commissioning
Commissioning and Start-Up Operating, Maintenance andShutdown
Sectional Percentage Contribution
C
NC
N/A
36%
0%
64%
Total Percentage Compliance
C
NC
N/A
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5.2.1 EFFECTIVENESS OF THE EMPR
Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy
and effectiveness of the EMPr as part of the audit scope, as follows:
— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,
achieve the objectives and outcomes laid out in these documents;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Critically evaluate the effectiveness of the EMPr;
— Identify shortcomings in the EMPr; and
— Identify the need for any changes to the avoidance, management and mitigation measures provided for in
the EMPr.
The EMPr compliance audit has identified that approximately 40% of the listed measures are no longer applicable,
as these mostly related to the construction and pre-commissioning, and commissioning and start-up 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
(14.25.16 EV 11)