sasol chemical operations: solvents division … · 6/13/2019 · this compliance audit report...

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14/3/L/A/SAS.EA - ETHYL ACETATE PLANT

13 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14/3/L/A/SAS.EA - ETHYL ACETATE PLANT

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref:

14/3/L/A/SAS.EA

Final – Compliance

Audit

EA Ref:

14/3/L/A/SAS.EA

Date April 2019 June 2019

Prepared by Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 041 041

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

S I G N A T U R E S

PREPARED BY

-

Bronwyn Fisher

Environmental Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

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

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

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Solvents Production Senior Manager,

Secunda Chemicals Operations

Alfie Naidoo

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Ethyl Acetate Plant (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 14/3/L/A/SAS.EA) ........... 1

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

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

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

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

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

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

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 17

5.1 Environmental Authorisation ............................... 17


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TABLES

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

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

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 17

FIGURES

FIGURE 1: LOCATION OF THE ETHYL ACETATE PLANT (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 18

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 18

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 19

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 19

APPENDICES

A ENVIRONMENTAL AUTHORISATION

(14/3/L/A/SAS.E.A)


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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: 14/3/L/A/SAS.EA issued on 14 January 2000) for the

period December 2014 to February 2019.

1.2 ETHYL ACETATE PLANT (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(AUTHORISATION NUMBER: 14/3/L/A/SAS.EA)

The Ethyl Acetate Plant was constructed in 2001 for the production of 99.8% ethyl acetate. The plant is located

within the Solvents Operation Area (Figure 1). Feed (E95) is received in tank farm TK0145 from Unit 38 (U38)

and U238, the Alcohol Processing Units. The E95 (enthanol) is converted into ethyl acetate in a vapour phase

dehydrogenation reactor prior to being sent to a polishing reactor to remove some of the impurities in the final

product. The product is then sent the tank farm for distribution. By products produced through this process are:

— E93 which is sent U73 (high purity ethanol plant); and

— Hydrogen which is sent to unit 233 (cat- poly hydro treater).

An EA (Reference number: 14/3/L/A/SAS.EA) for the construction and operation of the Ethyl Acetate Plant

was issued on 14 January 2000.


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Figure 1: Location of the Ethyl Acetate Plant (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

— Ensure the commitments contained in Condition 9.02 of the EA are completed, more specifically:

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

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

of the date of written request for such records”.


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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (12 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Bronwyn Fisher conducted the site inspection on 12 March 2019. The findings and observations of the site visit

are recorded and summarised in Section 4 with evidence included in Table 2. Key personnel interviewed

included:

— Simon Malinga (Production Foreman).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals Operations;

— EA_EX Handover_SCO_Solvents_CWU_EA;

— 3.1 RE EA Condition information;

— 3.1 RE EA Condition information1;

— 3.1 Earthing andLight Protection_2006;

— 3.1 Elec design criteria_SP-60-56_2010-05-29;

— 3.1 Smoke detection_2019-01-15;

— SCO DQS BSOHSAS 18001 2007;

— EA_Illumination Survey;

— 3.05 EA SOP;

— 3.11 EA Emergency Procedure;

— Compliance_Air_Secunda Complex;

— AEL Sasol Solvents 0017-2015-F02 (2015) ;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

— IWWMP SIC 2015 Final_2018-05-15;

— Induction_Mod3_Environment;


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— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod6_EmergencyManagement;

— Environmental Complaints Register_2019-02-18; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The auditor, Bronwyn Fisher, was hosted by Broni van der Meer and Simon Malinga to whom we express our

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

provided below.

— Auditor: Bronwyn Fisher

Bronwyn Fisher has 6 years of experience as an Environmental Consultant, undertaking Environmental

Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental

Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and

undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel

storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,


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recycling facilities, mixed-use developments, industrial developments and renewable energy technology

projects.

— Lead Auditor and Quality Assurance: Ashlea Strong

Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature

Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental

Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic

expertise on a diverse range of projects in the environmental management field, including environmental

scoping and impact assessment studies, environmental management plans, waste and water management, as

well as the provision of environmental management solutions and mitigation measures. She has been

involved in the management of a number of large EIAs within South Africa and has environmental auditing

and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed

in the audit process.

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

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

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

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

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

document.

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

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

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

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

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1.01 This authorization refers only to the Ethyl Acetate Plant at

Sasol's Complex in Secunda, as specified above and

described in Record of Decision. Separate application/s must

be lodged for any other development and /or activity at or

near plant, which is covered by section 21 and 22 of the Act

and Government Notice R1182 and 1183 of 5 September

1997.

N/A Noted. Sasol have advised the auditor that they are aware of this

condition.

None.

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

Act, and does not exempt the holder from compliance with

any other relevant legislation.

N/A A full legal review does not form part of the scope of this Audit.

The site is operated under ISO14001:2015, which requires the

compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

protocol (CRMP) to assist the organization to reach a higher level

of legal compliance is commendable”.

Evidence:

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals

Operations.

None

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

conditions in this authorization if, in the opinion of the

Department, it is environmentally justified.

N/A Noted. Sasol advised the auditor that to their knowledge the

Department has not changed, added or amended any of the

conditions within this EA.

None.

1.04 A copy of this authorization shall be available at the Sasol

Chemical Industries (Pty) Ltd Secunda, at all times and all C Copies of all authorisations and licences are sent to, and details

communicated with, relevant business units. Copies of these

None.


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staff, contractors and sub-contractors shall be acquainted

with the contents of the authorization.

documents are also available at the SHE: Environment department

and on SAP EC and SharePoint. Sasol provided the auditor with

the evidence that the responsible persons, Alfie Naidoo (Senior

Manager of Chemical Workup Units) and Willem Jacobs (legal

appointee of Solvents), were made aware of the EA in September /

October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_CWU_EA

ESTABLISHMENT OF THE ETHYL ACETATE PLANT

2.01 If changes need to be made to the plant and/or associated

structures other than that which has been agreed upon, this

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

be able to decide whether the changes need authorization.

N/A Noted. Sasol have advised the auditor that no changes have been

made to the project description within the EA within the audit

period.

None.

2.02 The Ethyl Acetate Plant must operate according to

recognized environmental management standards. This

Department must receive a proposal towards the

environmental management system which management of

the specific plant proposes to implement in order for the

Department to approve or disapprove such a system.

C Sasol Chemical Operations are ISO 14001:2015 certified. The

auditor was provided with proof of certification. The certification

is valid from 12 October 2016 until 11 October 2019.

The submission of a proposal to the Department is deemed outside

of the audit period and therefore not applicable.

Evidence:

— SCO DQS ISO 14001 2015

None.

2.03 This Authorisation is repealed if the project is not

commenced within two (2) years from the date of

Authorization.

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

(construction pre-2014). It is therefore considered not applicable.

None.

CONSTRUCTION AND OPERATION

3.01 Standards laid down by the SABS and National Fire

Prevention Association (NFPA) regarding i) lightning C Sasol have developed Sasol specification SP-60-56 rev1_2010-05-

29 for Electrical Design Criteria and Earthing and Lightning

None.


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protection as we as ii) fire detection, protection and fighting

systems must be followed and adhered to.

Protection Guidelines DG60-06-02-001_2006-01-06. SP-60-56

makes reference to SANS 10313 (Protection against Lightning-

Physical damage to structures and life hazard). In addition Sasol

have a Earthing and Lightning Protection: General Guidelines

(DG60-06-02-001). Other codes which Sasol conform with are

NFPA code 780 standard for the installation of lightning protection

and API RP 545, Recommended Practice for Lightning Protection

of Above Ground Storage Tanks for Flammable or Combustible

Liquids.

Evidence:

— 3.1 RE EA Condition information

— 3.1 RE EA Condition information1

— 3.1 Earthing andLight Protection_2006

— 3.1 Elec design criteria_SP-60-56_2010-05-29

— 3.1 Smoke detection_2019-01-15

3.02 The Ethyl Acetate plant must be incorporated into Sasol's

existing Hearing Conservation Programme in order to

comply with the minimum requirements of Environmental

Regulations for workplaces in terms of the Occupational

Health and Safety Act, 1993 (Act 85 of 1993).

C Sasol Chemical Operations have a valid BS OHSAS 18001: 2007

certification. The auditor was provided with proof of the

certification. The certification is valid from 12 October 2016 to 11

October 2019.

Evidence:

— SCO DQS BSOHSAS 18001 2007

None.

3.03 Illumination of the plant must comply with the statutory

requirements of Environmental Regulations for Workplaces

in terms of the Occupational Health and Safety Act, 1993

(Act 85 of 1993).

NC The auditor was informed that Sasol undertake biennial

Illumination surveys at the Sasol Chemicals Operational area.

The auditor was provided with a copy of the original survey

undertaken by Daleen Locke (dated 2 February 2002). The survey

concluded that a number of areas were under illuminated. The

auditor was not provided evidence that the recommendations in

this report were actioned.

Evidence:

— EA_Illumination Survey

Ensure that illumination of

the plant meets the required

standards as outlined in this

condition.

Target Completion

Medium Term


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3.04 Care must be taken to comply with any other relevant section

of the Occupational Health and Safety Act, 1993 (Act 85 of

1993). This must be accomplished by incorporating the Ethyl

Acetate Plant into Sasol's NOSA Five (5) Star System.

C Sasol no longer use the NOSA 5 Star Safety System. Sasol are BS

OHSAS 18001: 2007 certified. The auditor was provided with

proof of the certification. The certification is valid from 12

October 2016 to 11 October 2019.

Evidence:

— SCO DQS BSOHSAS 18001 2007

None.

3.05 The design capacity of Ethyl Acetate produced at the Ethyl

Acetate plant may not be surpassed. C Sasol have advised the auditor that the plant is operated in

accordance with a Standard Operating Procedure, prohibiting

exceedance of the design capacity.

Evidence:

— 3.05 EA SOP

None.

3.06 No firewater, apart from firewater to be utilized for

firefighting/commissioning purpose, may be used during the

normal operation of the High Purity Ethanol Plant.

C During the site walk over, Sasol confirmed that no firewater, apart

from firewater to be utilized for firefighting/commissioning

purpose, is utilised during the normal operation of the High Purity

Ethanol Plant.

Evidence:

— Personal Communication

None.

3.07 No raw water/potable water may be utilized during the

normal operation of the Ethyl Acetate Plant. C During the site walk over, Sasol confirmed that no raw

water/potable water is utilized during the normal operation of the

Ethyl Acetate Plant.

Evidence:


None.

3.08 Burrow-pits utilized for the mining of dolerite must be

registered with the Department of Minerals and Energy

(DME). Operators of these burrow-pits must be in

possession of approved Environmental Management

Programmes (EMPRs), registration certificates and all

N/A Mining of dolerite is not associated with the operational activities

covered within the EA. This condition is considered not applicable.

OFI:

An amendment of the EA

could be sought to remove

this condition.


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requirements of the Minerals Act, 1991 (Act 50 of 1991),

must be adhered to.

3.09 All waste, off-spec products or spent catalysts, should be

recycled or re-routed into the process treated or disposed of

on a permitted waste disposal site according to the

classification of such waste.

C Sasol advised the auditor that all off-sec product is sent to a slop

tank and then sent back into the processing plant for reworking

until it meets the required specifications.

Evidence:


None.

3.10 Firewater and not raw water must be used for commissioning

of the Ethyl Acetate Plant. N/A This condition is considered outside of the audit period


None.

3.11 A plant specific Emergency Procedure must be developed as

part of the operation manuals of the Ethyl Acetate Plant. C Sasol have provided the auditor with the emergency response

procedure developed in August 2018 for the control room,

conference room and shutdown facility. The plan clearly identifies

the roles and responsibilities, procedures to be followed in case of

emergency scenarios such as:

— Fires on tank roofs;

— Building fires;

— Bomb threats; and

— Medical emergencies.

Evidence:

— 3.11 EA Emergency Procedure

None.

3.12 Commissioning of the site may not take place before receipt

of, and approval of the final design criteria for the Polishing

Reactor and Ethyl Acetate column reflux system.



None.

3.13 Commissioning of the site may not commence without this

Department receiving and approving the considerations

given in determining the final site location with regard to a

potential explosive buffer zone.



None.


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3.14 Sasol must conduct a quantitative risk assessment as soon as

more detailed process information becomes available. N/A This condition is considered outside of the audit period


None.

3.15 Emission limits and operating conditions issued in terms of

the Atmospheric Pollution Prevention Act, 1965 (Act 45 of

1965), must be adhered to.

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 Solvents Chemical Operations have an Atmospheric

Emissions Licence (AEL) issued on 31 March 2015 (reference

number: 0017/2015/F02). Sasol undertake atmospheric emission

monitoring in accordance with the conditions of the requirements

of the AEL. The incidents registers for 2015- 2017 and 2017- 2019

do indicate any emission exceedances from the plant.

Evidence:

— Compliance_Air_Secunda Complex

— AEL Sasol Solvents 0017-2015-F02 (2015)

— Copy of Environment Impact register_ New FY17

— Environment Impact register_ New FY19_2019-02-18

None.

3.16 Detailed plans for the water removal unit must be forwarded

to this Department and the DWAF before the construction of

the plant may commence.



None.

3.17 Sasol must develop the contingency plans regarding storm

water quality and quantity. These plans must be approved by

the DWAF. Proof of approval must forwarded to this

Department.

C Sasol have developed an Integrated Water and Waste Management

Plan (IWWMP) which was submitted to the Department of Water

and Sanitation (DWA), formally known as DWAF. Sasol have

however Sasol have not provided evidence that the approval of the

IWWMP was submitted to the Provincial Department of

Agriculture, Rural Development, Land and Environmental Affairs

(DARDLEA), formally known as the Department of Agriculture,

Conservation and Environment.

None.


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The submission of the plans to the DWAF, and subsequent

approval, is considered outside of this audit period.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

AIR POLLUTION

4.01 Emission limits and operating conditions as stated in the

provisional registration certificates issued in terms of the

Atmospheric Pollution Prevention Act, 1965 (Act 45 of

1965), must be adhered to.

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 Solvents Chemical Operations have an Atmospheric

Emissions Licence (AEL) issued on 31 March 2015 (reference

number: 0017/2015/F02). Sasol undertake atmospheric emission

monitoring in accordance with the conditions of the requirements

of the AEL. The incidents registers for 2015- 2017 and 2017- 2019

do indicate any emission exceedances from the plant.

Evidence:

— Compliance_Air_Secunda Complex

— Copy of Environment Impact register_ New FY17

— Environment Impact register_ New FY19_2019-02-18

— AEL Sasol Solvents 0017-2015-F02 (2015)

None.

RISK MANAGEMENT

5.01 All employees, contractors and sub-contractors employed by,

or delivering a service to Sasol with regard to the Ethyl

Acetate Plant must be acquainted with the characteristics and

dangers associated with such a plant. They must also be

familiarised with emergency procedures associated with the

C Every person entering the Sasol site is subject to a SHE induction

process to ensure that all persons are familiar with the Safety,

Health & Environmental aspects and requirements of that

site/plant.

In addition, there is specific induction training for entry into the

Sasol Solvents Operational areas. No person unaccompanied

None.


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Ethyl Acetate Plant and any other integrated structures that is

relevant to this project.

unauthorised person will be allowed access to the solvents area

without undertaking solvents induction training. Sasol have

advised the auditor that the training includes risks associated with

working in the solvents area, operational and emergency

procedures.

Evidence:

— Induction_Mod3_Environment

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod6_EmergencyManagement

INSPECTION AND MONITORING

6.01 The Ethyl Acetate Plant and its associated infrastructure

should be regularly checked to prevent incidents from

occurring. Inspection time frames must be reviewed at pre-

determined time-intervals.

C During the site walkover Sasol advised the auditor that the Ethyl

Acetate Plant and its associated infrastructure is regularly

inspected to prevent incidents from occurring.

Evidence:


None.

DECOMMISSIONING

7.01 Decommissioning of the new Ethyl Acetate Plant may not

commence without the Department receiving, and approving

the formal rehabilitation plan for the plant six (6) months in

advance of the proposed decommissioning date.

N/A Noted. Sasol have advised the auditor that there are no plans to

decommission the plant in the foreseeable future. This condition is

therefore deemed not applicable.

None.

ENVIRONMENTAL AUDITING

8.01 External environmental audit: Six (6) months after

commissioning of the plant, this Department must be

supplied with the external audit report. The report must



None.


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cover all environmental as well as operational aspects

associated with the plant.

8.02 Internal Environmental auditing: Sasol must conduct internal

environmental audits on a yearly basis. The results of these

internal audits must be forwarded to this Department for

monitoring purposes.

NC Sasol have not undertaken internal auditing of the EA on an annual

basis.

Sasol should undertake

annual internal audits going

forward.

Target Completion

Short term

REPORTING

9.01 The Department must be notified within 24 hours in the

event of non-compliance with any of the conditions of this

Authorization.

NC Sasol have not advised the Department regarding the non-

compliances identified in this audit.

Going forward Sasol must

notify the Department of

any non-compliances

against the conditions of

this EA.

Target Completion

Short Term

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

conditions of the authorization must be kept in good order.

Such records must be made available to this Department

within seven (7) workdays of the date of written request for

such records.

N/A This audit represents the first required audit for this Exemption.

Prior to the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

9.03 Non-compliance with, or any deviations from the conditions

as set out in the authorization and Environmental Scoping

Report, is regarded as an offence and, after reasonable

provision has been made for remedial action, will be dealt

with in terms of Section 29, 30 and 31A of the Act.

N/A Noted. Sasol has advised the auditor that they are aware of this

condition.

None.


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9.04 Any complaint regarding the said activity must be brought to

the attention of the Department within 24 hours after

receiving the complaint. A complaints register must be kept.

This register must contain up to date information by

members of this Department within seven (7) days, after

requesting such information.

C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the Ethyl Acetate Plant for the audit period. Sasol

have advised that should a copy of the complaints register be

requested by the relevant Department, it will be made available.

Evidence:

— Environmental Complaints Register_2019-02-18

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 3

below.

Table 3: Summary of EA Compliance Audit Findings

SECTION OF THE EA

NO.

COMMITMENTS C NC N/A

GENERAL CONDITIONS 4 1 0 3

ESTABLISHMENT OF THE ETHYL ACETATE

PLANT

3 1 0 2

CONSTRUCTION AND OPERATION 17 10 1 6

AIR POLLUTION 1 1 0 0

RISK MANAGEMENT 1 1 0 0

INSPECTIONS AND MONITORING 1 1 0 0

DECOMMISSIONING 1 0 0 1

ENVIRONMENTAL AUDITING 2 0 1 1

REPORTING 4 1 2 1

Total Count 34 16 4 14

Total Percentage 47% 12% 41%

Percentage Compliance with Applicable Conditions 80%


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Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents

the total proportion of compliance for the facility.

Figure 2: Number/Count contribution of findings made to the EA conditions per Section

Figure 3: Overall count findings on compliance to the EA conditions

02468

1012141618

Sectional Count Contribution

C

NC

N/A

16

4

14

Total Compliance

C

NC

N/A


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Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total

percentage compliance for the facility.

Figure 4: Percentage contribution of findings made to the EA conditions per Section

Figure 5: Overall percentage findings on compliance to the EA conditions

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

47%

12%

41%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(14/3/L/A/SAS.E.A)