secunda synfuels operations: powerstation - steam ... · 1. the project entails the 100mw gas...

SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM

PRODUCTION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.22.3 GS 2 - POWER GENERATION FROM WASTE ENERGY

02 AUGUST 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.22.3 GS 2 - POWER GENERATION FROM WASTE ENERGY

SECUNDA SYNFUELS OPERATIONS:

POWERSTATION - STEAM PRODUCTION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: AUGUST 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

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: 17.2.22.3

GS 2

Final – Compliance

Audit

EA Ref: 17.2.22.3

GS 2

Date May 2019 August 2019

Prepared by Mpendulo Dlamini Mpendulo Dlamini

Signature

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 012 012

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

S I G N A T U R E S

PREPARED BY

Mpendulo Dlamini

Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

compliance with the conditions included in the Environmental Authorisation and associated Environmental

Management Plan.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Steam Production - Production Senior

Manager

Keith McCulloch

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Mpendulo Dlamini

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - STEAM PRODUCTION

WSP August 2019

TABLE OF CONTENTS

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

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

1.2 Power Generation from Waste energy – 17.2.22.3

GS 2 .......................................................................... 1

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

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

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

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

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

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

3.5 Audit Team ............................................................... 6

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 32

5.1 Environmental Authorisation ............................... 32

5.2 Environmental Management Plan ........................ 35


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TABLES

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

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

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 20

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 32

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 35

FIGURES

FIGURE 1: POWER GENERATION – STEAM PRODUCTION PLANT (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 7: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 33

FIGURE 8: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 33

FIGURE 9: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 34

FIGURE 10: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 34

FIGURE 11: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 36

FIGURE 12: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 36

FIGURE 13: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 37

FIGURE 14: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 37


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APPENDICES

A ENVIRONMENTAL AUTHORISATION (17.2.22.3GS 2)


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Page 1

1 INTRODUCTION

1.1 TERMS OF REFERENCE

Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP

Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit and

compile an audit report according to the requirements of the National Environmental Management Act (No. 107

of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the

Environmental Authorisation (EA) (Reference number: 17.2.22 3GS 2 issued on 20 February 2008) (as amended)

as well as the associated Environmental Management Plan (dated: May 2007) for the period December 2014 to

February 2019.

1.2 POWER GENERATION FROM WASTE ENERGY –

17.2.22.3 GS 2

An EA was granted on 20 February 2008 by the Mpumalanga Department of Environmental Affairs and Tourism,

for the construction and operation of a power generation plant that utilises waste energy.

Figure 1 provides the location of power station plant situated within Sasol Secunda Primary area.

The power station plant was completed in 2007, and commissioned in 2009. It generates electricity by using two

gas-driven turbines. The plant also provides high-pressure (HP) steam to various consumers in the Sasol Secunda

complex by means of two Heat Recovery Steam Generators (HRSGs).

Each Turbine in the plant generates approximately 105 MW (temperature-dependent), and each HRSG produces

approximately 163 t/h of steam at 41bar pressure and a temperature of 425ºC.

The gas turbine plant consists of the gas turbine auxiliaries and utilities for the process to generate electricity in

the most efficient and environmental friendly manner. Some auxiliaries and utilities are required from various

clients to enable the process; namely an air processing unit, fire protection and detection system, heating and

ventilation systems, HP Nitrogen system, air filter system, lubricant and hydraulic oil systems and lastly efficient

motors and gears.

The heat generated by the plant, drives the turbines and in the process, the shaft drives the compressor and

generator. The electricity generated is then transferred to the 132kV transformers. Waste heat (turbine exhaust

gas) is then used to generate the high-pressure system unit (HPSU) steam.

Fuel gas that drives this plant is the natural gas piped from Mozambique, as well as methane-rich gas from Unit

023 and Unit 223 from the cold separation process.

A correction to the accompanying Record of Decision (RoD) was issued on 10 April 2008 for the following:

1. The project entails the 100MW gas turbines, and not 100MV as indicated on page 2 of the Authorisation

under brief description of the activity; and

2. Clarity is provided pertaining to sewerage infrastructure as per Scoping Report Section 2.3.2 (c) under

brief description that oily water sewer network will be designed such that it can operate independently,

but at the same time can integrate with the existing Synfuels systems for water transfer. No sewerage

will be discharged to Govan Mbeki Local Municipality infrastructure. Sasol operates its own sewerage

treatment plant.

An amendment to the EA was granted on 22 September 2008. The amendment provides for the two comments,

as above.


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Page 2

Figure 1: Power generation – steam production plant (Source: Google Earth, 2018)


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Page 3

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

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

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

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

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

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

The objective of the audit was to:

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

— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr;

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

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr;

— Identify the need for any changes to the avoidance, management and mitigation measures provided for in the

EMPr;

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

— Ensure the commitments contained in Condition 7.02 of the EA are completed, more specifically:

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

in good order. Such records must be available to this Department within seven workdays from the date

of a written request from them.”


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

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

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

determine compliance to the EA and associated EMPr conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (27 March 2019);

— Review of documentation relevant to the conditions of the EA and associated EMPr (e.g. records,

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Mpendulo Dlamini conducted the site inspection on 27 March 2019. The findings and observations of the site

visit are recorded and summarised in Section 4 with evidence included in Table 2 and Table 3. Key personnel

interviewed included:

— Martin Le Roux (Area Manager Production);

— Tertius Perelaar (Production Foreman, PS Gas Turbines Production); and,

— Sindi Mapodile (Process Technician II, PS Performance & Gas Turbines).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— 17.2.22.3GS2_2008-02-20;

— 17.2.22.3GS2_2008-04-10;

— 17. 17.2.22.3GS2_2008-09-22_Amended;

— 500981_Final EMPv2_2007 05 17;

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels operations;

— EA_EX Handover_SSO_PS-Steam;

— Environmental Complaints Register (Period: December 2014 – March 2019);

— 543 Observation Pond Comiddion Checklist;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;

— Copy of Environment Impact register_ New FY17;

— 500981 - Draft Scoping Report.v3_ed.2007.04.03-1;

— 201810 SSO continuous emission monitoring monthly report_5 December 2018 rev_02;

— 201901 SSO continuous emission monitoring monthly report for January 2019 rev_00;

— 201902 SSO continuous emission monitoring monthly report for February 2019 rev_00;

— IWWMP SIC 2015 Final_2018-05-15;


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Page 5

— Environment Impact register_ New FY19_2019-02-18;

— Extract from the power generation plant’s maintenance plant (provided via email);

— C.02_Plant Inspections U050;



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

— Steam Production_2016-11-07 (waste register); and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and Table 3). The checklist

included the conditions and associated requirements as specified in the EA and associated EMPr.

Where conditions are not directly specified within documentation, for instance within older EMPrs that were

compiled and submitted as Aspect Registers, auditable conditions have been defined by utilising either mitigation

measures or aspects that were defined within the EMPr. In some instances this has required the minor re-wording

of original text contained within the EMPr, in order to specify an auditable condition. WSP has used its

professional expertise and independence to ensure that such interpretation of wording is both auditable and

balanced.

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

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

associated target completion dates included.

It should be noted that some of the EA and associated EMPr conditions were apportioned according to the elements

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

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

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

development of focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

according to the requirements of the EA and associated EMPr. Non-complaint conditions are

given target completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).


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3.5 AUDIT TEAM

The Consultant, Mpendulo Dlamini, was hosted by Broni van der Meer, Martin Le Roux, Tertius Perelaar and

Sindi Mapodile; to whom we express our gratitude for their time and attention during our visit. A brief summary

of the external auditors’ experience is provided below.

— Auditor: Mpendulo Dlamini

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

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

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

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

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

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

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

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

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

(Triplo4 Sustainable Solutions).

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts no

liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

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

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

document.

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

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

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

report. If this report is used as part of a main report, the report in its entirety must be included as an appendix or

separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1.01 This Authorisation refers only to the project as specified

above and described in the Record of Decision. Separate

applications must be lodged for any other development and/

or activity at or near the proposed development, which is

covered by Section 21 and 22 of the Act and Government

Notice R 1182 of 5 September 1997.

N/A Noted. The project remains as per the authorised activities for which

the EA was granted. No additions or alterations have taken place on

or near the project’s location.

Sasol is aware of the requirement to lodge separate applications

should further works be required for the authorised activity.

None.

1.02 Authorisation is only granted in terms of Section 22(3) of the

Act and does not exempt the holder from compliance with

other relevant legislation.

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

audit.

The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

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

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

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

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

of legal compliance is commendable”.

Evidence:

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels

operations.

None.


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Page 8


1.03 No development may take place without the necessary

permits/ approvals and/ or lease agreements, where it is

relevant, from or between all relevant legislation.

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

(construction pre-2014). The plant is already in operational phase.

The condition is therefore considered not applicable.

None.

1.04 Copies of the documents mentioned in 1.3 above must be in

the possession of this Department before any construction

may commence.


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

None.

1.05 This Department may change or amend any of the conditions

in this Authorisation if, in the opinion of the Department, is

environmentally justified.

N/A

Noted.

No changes or amendments have been communicated to Sasol by

the Department since issue of the EA.

None.

1.06 A copy of this Authorisation must be available on site during

construction and all relevant staff, contractors and sub-

contractors must be familiar with the contents of this

Authorisation.

C Sasol’s environmental team have soft copies of the EAs and the

associated EMPrs, and where/when necessary, communicate any

specific details or requirements to the relevant business units.

Additionally, copies are maintained at the SHE: Environment

department and on SAP EC and SharePoint. Any specific

requirements are communicated during Safety, Health &

Environmental (SHE) induction training. Sasol provided the auditor

with the evidence that the responsible persons, Keith McCulloch

(Senior Manager of Steam Production) and Anton Booysen (legal

appointee of Power Station), were made aware of the EA (including

correction by the Department) between September and November

2016.

Evidence:

— EA_EX Handover_SSO_PS-Steam

None.

1.07 The applicant must within five (5) calendar days of receipt of

this Record of Decision (ROD):

a) Advertise the issuing of the Authorisation in the regional

and/ or local newspaper.



None.


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b) Inform all interested and affected parties registering during

the EIA process of the decision

c) The above must state at least the following:

i) That an Authorisation has been issued to the applicant to

proceed with the construction and operation of the activity;

ii) That any appeals against the issuing of the Authorisation

must be lodged with the MEC for Agriculture and Land

Administration within 30 days from the date on which the

ROD was has been issued to the applicant and at the address

stipulated in the Authorisation;

iii) Include the date on which the ROD was issued to the

applicant and the date by which appeals must reach the MEC;

iv) Indicate where copies of the Authorisation and ROD can

be viewed/ obtained.

1.08 In the event that the predicted impacts exceed the significance

as predicted in the scoping report, this Authorisation may be

withdrawn after proper procedures have been followed.

N/A Noted. None.

1.09 The holder of this Authorisation must ensure compliance with

the conditions of this Record of Decision by any person acting

on his or her behalf, including but not limited to an agent, sub-

contractor, employee or any person rendering a service to the

holder of the Authorisation.

C According to the Area Manager, every person entering the Sasol site

is subject to a SHE induction process to ensure that they are familiar

with the SHE aspects and requirements of that site/plant.

Furthermore, personnel working in different plants undergo Plant

Specific Training prior to being accepted to work in the plant.

Therefore the same applies to the power generation plant, all

employees and people rendering services receive training.

None.

1.10 The holder of the Authorisation must notify the Department

in writing within 24 (twenty-four) hours if a condition of this

Authorisation is not adhered to. Any notification in terms of

this condition must be accompanied by the reasons for the

non-compliance.

C Noted. A complaints and incidents register is kept up to date for

the entire Sasol Secunda Operations. Available records go as far

back as 2008. No complaint has been recorded against the power

generation plan.

Furthermore, no non-compliances were noted during this audit.

None.


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Evidence:

— Environmental Complaints Register (Period: December 2014

– March 2019)

1.11 Where any of the applicant’s contact details change, including

the name of the responsible person, the physical or postal

address and/ or telephonic details, the applicant must notify

the Department as soon as the new details become known to

the applicant;

C Sasol advised the Department of a change of name from Sasol

Synfuels (Pty) Ltd to Sasol South Africa (Pty) Ltd in March 2017,

and sought to amend the EA. Sasol received confirmation from

Mpumalanga Province Department of Agriculture, Rural

development, Land & Environmental Affairs on 28 April 2017 that

the amendment to the EA had been approved.

No other changes to contact details have occurred.

Evidence:

— SSO_UTIL_Amendment_Power Waste Energy_1.3.1.16.4 G-

33_2017-04-28

None.

1.12 Any changes in the project that could have significant

environmental impacts and that differ from what was

authorized by this Department, must be submitted to this

Department for approval prior to such changes being effected.

N/A Noted. The auditor was advised that no such changes have

occurred during the audit period.

None.

ESTABLISHMENT

2.01 This Authorisation is valid for a period of two (2) years from

the date of issue and must be renewed six (6) months in

advance of the expiry date if construction activities have not

taken place within the allocated time.



None.

2.02 Fourteen (14) days written notice must be given to this

Department before commencement of construction activities. N/A This condition is considered outside of the audit period


None.

2.03 An independent Environmental Control Officer (ECO) must

be appointed before commencement of any construction

activities to ensure that the conditions of this Record of



None.


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Decision are implemented, and also to ensure compliance

with the provisions of the Scoping Report and the

Environmental Management Plan (EMP). The name and

contact details of such an officer must be forwarded to this

Department before construction commences.

2.04 The conditions stipulated in this Record of Decision as well

as the mitigation measures and recommendations in the

Scoping Report and EMP are legally binding components of

any contract and are therefore legally enforceable.

N/A Noted. Sasol is aware that the conditions are legally binding. None.

CONSTRUCTION & OPERATION

3.01 Areas disturbed as a result of construction activities must be

rehabilitated as soon as possible to the satisfaction of this

Department.


(construction pre-2014). Furthermore, the entire site is paved and

tarred. Therefore the condition considered not applicable.

None.

3.02 Measures must be taken to prevent and manage soil erosion,

and strict erosion control measures must be implemented in

the design of storm water management.

C The entire site is paved and tarred and is not susceptible to any soil

erosion.

None.

3.03 Topsoil must be removed from all areas to be disturbed by

construction activities and be stockpiled at pre-designated

locations for use during rehabilitation and landscaping.



No exposure of soils has occurred since the construction period.

None.

3.04 The storage and handling of fuel, lubricants and other

chemicals must be in especially demarcated impervious and

bunded areas.

C The auditor observed that all chemicals and lubricants used onsite

are kept and handled in a bunded area.

Evidence:

None.


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Chemical bund

3.05 The mixing of cement must take place on an impermeable

layer such as concrete slab or in a container suitable for this. N/A This condition is considered outside of the audit period


None.

3.06 Stringent measures must be applied to suppress dust

emanating from the construction site. N/A This condition is considered outside of the audit period


Dust is not generated during the operation of the facility.

None.

3.07 Workers movements must be limited to the construction area

only and must be enforced in terms of the contracts of

appointment.



None.

3.08 Measures must be taken to ensure the safety of construction

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


None.

3.09 Appropriate notification signs must be erected warning the

public of the dangers around the construction sites. N/A This condition is considered outside of the audit period


None.

3.10 The development must be linked to Govan Mbeki Local

Municipality’s infrastructure. No other structures meant for

the disposal of sewage are permitted for this development.

C The amendment to the RoD in April 2008 renders this Condition not

applicable. No sewerage is discharged to Govan Mbeki Local

Municipality infrastructure.

None.


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Page 13


Correction dated 10 April 2008: Clarity is provided

pertaining to sewerage infrastructure as per Scoping Report

Section 2.3.2 (c) under brief description that oily water sewer

network will be designed such that it can operate

independently, but at the same time can integrate with the

existing Synfuels systems for water transfer. No sewerage will

be discharged to Govan Mbeki Local Municipality

infrastructure. Sasol operates its own sewerage treatment

plant

3.11 Any complaints received from the public during the

construction and operational phases of the activity must be

attended to as soon as possible and addressed to the

satisfaction of all concerned.

C A complaint register is kept up to date for the entire Sasol Secunda

Operations. Available records go as far back as 2008. There were no

complaints applicable to this development during the audit period.

Evidence:


– March 2019)

None.

3.12 Good Environmental Management Practice must be carried

out as an integral part of implementation of the plant. C The auditor was satisfied with the environmental management

practices onsite; such as the availability of waste receptacles,

hazardous materials bunding, general housekeeping, the presence of

fire firefighting equipment, and proper signage. Paper recycling

initiatives were implemented in the office areas.

Waste receptacles onsite


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Safety signage onsite

Fire-fighting equipment


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Paper recycling initiative

3.13 A Risk Assessment Study must be conducted before the

commencement of construction activities. N/A This condition is considered outside of the audit period


None.

3.14 The proposed Oily Water and Storm Water Sewer must be

registered with the Department of Water Affairs and Forestry.

Correction dated 10 April 2018: Clarity is provided

pertaining to sewerage infrastructure as per Scoping Report

Section 2.3.2 (c) under brief description that oily water sewer

network will be designed such that it can operate

independently, but at the same time can integrate with the

existing Synfuels systems for water transfer. No sewerage will

be discharged to Govan Mbeki Local Municipality

infrastructure. Sasol operates its own sewerage treatment

plant.

N/A The oily water separator does not discharge to municipal sewerage,

and hence does not require registration with the DWAF. Clarity was

provided in the amendment to the RoD dated April 2018.

No sewerage is discharged to the Govan Mbeki Local Municipality

infrastructure (see Condition 3.10).

None.


WSP August 2019

Page 16


WATER AND AIR POLLUTION

4.01 It is the responsibility of the applicant and the relevant

contractor to prevent any pollution of surface as well as

ground water.

C The entire site is paved and tarred and hazardous materials are stored

and handled within bunded areas, to prevent pollution.

The IWWMP aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

Surface water monitoring is conducted weekly, in addition to real

time for various RESMs.

Groundwater monitoring is conducted biannually and quarterly.

There is no groundwater monitoring specific to the power

generation plant, however there are six active boreholes located

within the Primary area which are utilised for monitoring. The

auditor note a number of exceedances in the November 2017

sampling run, however these exceedances cannot be directly

attributed to power generation plant.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.

None.

4.02 Any further conditions as set out by any relevant Authority

(e.g. Department of Water Affairs & Forestry) must be

adhered to.

N/A Noted. Sasol has advised it is not aware of any further conditions. None.

WASTE

5.01 All waste generated on site must be stored, handled, and

disposed of at a registered landfill site or as directed by any

other relevant authority.

C Adequate waste receptacles have been provided throughout the site.

Waste is collected by Sasol’s waste service providers for disposal.

Records of waste disposal are kept on Sasol’s document

management system.

None.


WSP August 2019

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5.02 Building rubble must be disposed of at a site specifically

earmarked for that purpose. N/A This condition is considered outside of the audit period


None.

5.03 No oil spills, concrete or other construction material must be

allowed to remain on site after the construction phase. N/A This condition is considered outside of the audit period


None.

5.04 Waste generated during the operation of the site must be

classified and disposed of in an appropriate manner as

prescribed in the Minimum Requirements for waste disposal

as prescribed by the Department of Water Affairs and

Forestry.

C Adequate waste receptacles have been provided throughout the site.

Waste is collected by Sasol’s waste service providers for disposal.

Records of waste disposal are kept on Sasol’s document

management system.

Liquid waste in the stormwater collection pond is tested and sent to

the API. Should the results exceed the required contamination

levels, the auditor was notified that the water would not be sent to

the API, but would be vacuumed and disposed of at a licenced

landfill.

None.

MONITORING

6.01 This Department retains the right to inspect or monitor the

proposed project during both construction and operational

phases to ensure that it complies with legislation and the

conditions stipulated in this Record of Decision.

N/A Noted. None.

6.02 Environmental compliance will further be monitored through

complaints received from the public. N/A Noted. Information on the Sasol complaints process is detailed

under the findings for Condition 3.11.

None.

6.03 Monitoring of the emissions must be monitored on a monthly

basis to ensure that emissions stay within the prescribed

limits.

C The monthly SSO continuous emissions monitoring reports for the

periods November 2018, January 2019, and February 2019 were

provided to the auditor as a sample.

For the steam generation emissions, results were within limits

prescribed by the Atmospheric Emissions Licence (AEL).

Evidence:

None.


WSP August 2019

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— 201810 SSO continuous emission monitoring monthly

report_5 December 2018 rev_02;

— 201901 SSO continuous emission monitoring monthly report

for January 2019 rev_00; and

— 201902 SSO continuous emission monitoring monthly report

for February 2019 rev_00.

REPORTING

7.01 The applicant must notify this Department within 24 hours in

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

this Authorisation.

C No non-compliances have been identified during this audit. None.

7.02 Records relating to compliance / non-compliance with the

conditions of the Authorisation must be kept in good order.

Such records must be available to this Department within

seven workdays from the date of a written request from them.

N/A This audit represents the first required audit for this EA. Prior to the

introduction of the 7 April 2017 amendment to the Environmental

Impact Assessment (EIA) regulations, no audit against this EA was

required.

None.

7.03 Non-compliance with any deviation from the conditions of

this Authorisation is regarded as an offence, and after

reasonable provision has been made for remedial action, will

be dealt with in terms of Sections 29,30, and 31 of the Act.

N/A Noted. None.

7.04 Any complaints regarding the development must be brought

to the attention of this Department within 24 hours after

receiving the complaint. A complaints’ register must be kept

up to date for inspection by the Department.

C A complaint register is kept up to date for the entire Sasol Secunda

Operations. Available records go as far back as 2008. There were no

complaints applicable to this development during the operational

period.

Evidence:


– March 2019)

None.


WSP August 2019

Page 19


7.05 The applicant must ensure that all related Legislation;

National, Provincial and Local must be complied with as

stipulated within the Scoping Report.

N/A Noted.

The Draft Scoping Report dated April 2007 was provided to the

auditor. Administrative, legal and policy requirements are listed in

Section 1.3 of that Scoping Report, as follows:

— The Constitution of the Republic of South Africa (Act No.

108 of 1996);

— The Environment Conservation Act: ECA, 1989 (Act No. 73

of 1989), and the EA Regulations, promulgated in terms of

the Act;

— The National Environmental Management Act: NEMA, 1989

(Act No. 107 of 1998),

— The National Water Act, 1989 (Act No. 36 of 1998); and

— The Atmospheric Pollution Prevention Act, 1965 (Act No. 45

of 1965).

A full legal review does not form part of the scope of this audit.

The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

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

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

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

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

of legal compliance is commendable”.

Evidence:

— 500981 - Draft Scoping Report.v3_ed.2007.04.03-1;

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels

operations.

None.


WSP August 2019

Page 20

Table 3: Audit Findings – Environmental Management Plan


CATEGORY A - PLANNING PHASE

A.01 Appointment and Duties of SES N/A This condition is considered outside of the audit period


None.

A.02 Appointment and Duties of SH&E OFFICER N/A This condition is considered outside of the audit period


None.

A.03 EMP N/A This condition is considered outside of the audit period


None.

A.04 Environmental incidents N/A This condition is considered outside of the audit period


None.

A.05 Erosion sedimentation and flooding N/A This condition is considered outside of the audit period


None.

A.06 Crime, Safety and security N/A This condition is considered outside of the audit period


None.

A.07 Storm water Management N/A This condition is considered outside of the audit period


None.

A.08 Occupational Health and Hygiene Issues N/A This condition is considered outside of the audit period


None.

A.09 SH&E Orientation, Induction and Training N/A This condition is considered outside of the audit period


None.


WSP August 2019

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A.10 Safety Induction N/A This condition is considered outside of the audit period


None.

A.11 Social upliftment and crime N/A This condition is considered outside of the audit period


None.

A.12 Waste disposal N/A This condition is considered outside of the audit period


None.

A.13 Accidental Spillage N/A This condition is considered outside of the audit period


None.

A.14 Refuelling N/A This condition is considered outside of the audit period


None.

A.15 Road Infrastructure N/A This condition is considered outside of the audit period


None.

A.16 Sewage N/A This condition is considered outside of the audit period


None.

CATEGORY B - CONSTRUCTION PHASE

B.01 General N/A This condition is considered outside of the audit period


None.

B.02 Management of topsoil N/A This condition is considered outside of the audit period


None.

B.03 Machinery, tools and equipment N/A This condition is considered outside of the audit period


None.


WSP August 2019

Page 22


B.04 Noise N/A This condition is considered outside of the audit period


None.

B.05 Waste Management N/A This condition is considered outside of the audit period


None.

B.06 Personal Protective Equipment (PPE) N/A This condition is considered outside of the audit period


None.

B.07 Transport and Vehicles N/A This condition is considered outside of the audit period


None.

B.08 Construction crew site N/A This condition is considered outside of the audit period


None.

B.09 Effects of the construction site N/A This condition is considered outside of the audit period


None.

B.10 Effects of the construction crew site N/A This condition is considered outside of the audit period


None.

B.11 Effects of the construction site N/A This condition is considered outside of the audit period


None.

B.12 Erosion, sedimentation and flooding N/A This condition is considered outside of the audit period


None.

B.13 Groundwater Contamination N/A This condition is considered outside of the audit period


None.


WSP August 2019

Page 23


B.14 Geology N/A This condition is considered outside of the audit period


None.

B.15 Heritage resources N/A This condition is considered outside of the audit period


None.

B.16 Destruction of vegetation N/A This condition is considered outside of the audit period


None.

B.17 Impact on fauna N/A This condition is considered outside of the audit period


None.

B.18 Crime, safety and security N/A This condition is considered outside of the audit period


None.

B.19 Noise and atmospheric pollution N/A This condition is considered outside of the audit period


None.

B.20 Visual impact N/A This condition is considered outside of the audit period


None.

B.21 Waste N/A This condition is considered outside of the audit period


None.

B.22 Adequacy of waste disposal facilities N/A This condition is considered outside of the audit period


None.

B.23 Excavated areas N/A This condition is considered outside of the audit period


None.


WSP August 2019

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B.24 Inspection and Auditing N/A This condition is considered outside of the audit period


None.

CATEGORY C - OPERATIONAL PHASE

C.01 General

A Management Body should be established to ensure that the

EMP is implemented and sound environmental management

occurs in the operational phase.

C According to the Area Manager, the Senior Manager is responsible

for leading the unit with regards to ensuring that the EMPr is

implemented. The unit’s production team is also in constant liaison

with Sasol’s environmental department which oversees the

implementation of all licences and EMPrs.

None.

C.02 Site Management

A maintenance plan for the development must be developed

with regard to maintaining buildings and perimeter fencing

etc. in order to ensure that they do not deteriorate and

become aesthetically unpleasant.

C An extract from the generation plant’s maintenance plan was

provided to the auditor for verification.

Evidence:

— Extract from the power generation plant’s maintenance plant

(provided via email).

None.

C.03 Safety Risks

Only authorized persons are allowed to enter the bulk storage

tank area. C The Area Manager notified the auditor that no unauthorised persons

enter the bulk tank storage area; only the unit’s production team is

allowed. If a delivery has to be made, the service provider must

furnish a delivery slip prior to being permitted to enter. All service

providers have to be accompanied by a production team when

offloading a delivery.

None.


WSP August 2019

Page 25


Electronic equipment that could create static must be

restricted to the main office building (Cell phones, Cameras

etc.).

C Signage that prohibits electronic equipment onsite is displayed.

Lockers are provided at the site office, in which on-site staff must

place all their gadgets prior to accessing the site.

None.

C.04 Groundwater Quality

Any damages to the sewage system must be reported and

repaired immediately. C The Area Manager, advised that he was not aware of any sewage

system damages having occurred to drainage system, although no

underground surveys of the sewage system has been completed. The

auditor was notified that in 2017 a suction pump had a

malfunctioned. This was inspected and replaced before any damage

could occur.

Site staff are responsible for reporting any observations regarding

malfunctions or damages, to identify areas for repair.

OFI:

Sasol must conduct

underground inspection of

the sewage system to

identify damage which

could lead to leakage and

therefore potential

contamination.

Target Completion:

Medium term.

The sewage system must be inspected for leakages on a

regular basis and any leakages must be attended to

immediately.

NC The aboveground sections of sewerage system are inspected by the

shift foreman every shift.

No underground surveys of the sewage system has been

completed.

Evidence:


— C.02_Plant Inspections U250; and,

— C.02_Plant Inspections U350.

Sasol must conduct





therefore potential

contamination.

Target Completion:

Medium term.

Storm water gullies, drains and channels must be regularly

inspected for evidence of pollution and contamination (as

part of the Safety Representatives monthly inspection)

C As far as can be expected from a monthly inspection (i.e.

aboveground sections only) the storm water gullies, drains and

channels are inspected, as these are checked by the shift foreman

every shift.

OFI:

Sasol must conduct





WSP August 2019

Page 26



completed, however this is considered beyond the assumed remit

of this Condition, given that inspection is required monthly.

Evidence:





therefore potential

contamination.

Target Completion:

Medium term.

C.05 Site Storm Water and Sewer System management

Storm water and sewer drains must be mapped on the site plan

and personnel made aware of their function. C The oily water and stormwater lines onsite have different colours.

The oily water line is marked with brown, and the clean stormwater

is marked with green.

All personnel onsite are aware of stormwater and sewer functions as

they are undergo plant specific inductions prior to working onsite.

None.

The storm water system, especially the discharge points, must

be inspected, and damaged areas must be repaired if required. C The aboveground sections of sewerage system are inspected by the

shift foreman every shift.


completed, however this is discussed under Condition C.04.

OFI:

Sasol must conduct





therefore potential

contamination.

Target Completion:

Medium term.

Any spills of product must be reported and investigated and

appropriate remedial action taken. Action may include clean

up by the site or making use of the specialized services of a

contractor (in the case of a major spill)

C All environmental incidents are recorded in an incident register that

is available at the Environmental department. All incidents are

investigated and reported in line with the procedure and as per legal

requirements. The auditor has checked the incident register for the

None.


WSP August 2019

Page 27


audit period, and no spill incidents associated with the power

generation plant have been noted.

Evidence:

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18.

Any damages to the sewage or storm water system must be

reported and repaired as soon as possible. C The Area Manager, advised that he was not aware of any stormwater

or sewage system damages having occurred to drainage system,

although no underground surveys have been completed. The auditor

was notified that in 2017 a suction pump on the sewer system had a

malfunctioned. This was inspected and replaced before any damage

could occur.

Site staff are responsible for reporting any observations regarding

malfunctions or damages, to identify areas for repair.

OFI:

Sasol must conduct





therefore potential

contamination.

Target Completion:

Medium term.

Oil leaks or spills from workshops/equipment must be

absorbed with spill absorbent material. Waste oil must be

recycled through specialist contractors

C Spills are addressed with absorbent material if they occur. Waste is

managed through implementation of a Waste Management

procedure that addresses the approach to manage waste in line with

the internationally accepted waste hierarchy, whereby disposal to

land is considered the last management option to undertake once

avoidance, re-use, recycling, recovery and treatment options have

been considered / eliminated. The procedure further details waste

disposal and management through characterization and

classification that is detailed in site specific waste registers

(provided for review).

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Steam Production_2016-11-07 (waste register)

None.


WSP August 2019

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The sewage system must be inspected for leakages or

blockages regularly (as part of the site Safety Representative’s

inspection).

C As far as can be expected from a routine inspection (i.e.

aboveground sections only) the storm water gullies, drains and

channels are inspected, as these are checked by the shift foreman

every shift.

No CCTV surveys of the below ground network have been

completed, however this is considered beyond the assumed remit

of this Condition, given that inspection is required as part of the

site Safety Representative’s inspection.

Evidence:




OFI:

Sasol must conduct





therefore potential

contamination.

Target Completion:

Medium term.

C.06 Flooding

Litter blocking storm water channels must be removed. C Litter is removed as part of the maintenance strategy, and the site

was observed to be litter free.

None.

C.07 Visual and aesthetics

Public open space areas must be maintained. This includes

watering plants, pruning trees, cutting grass, collecting litter,

etc.

C The entire site has tar and concrete paving all around. In terms of

litter, the site was observed to be litter free.

None.

Disposal of all domestic waste must be undertaken by the

local council. C Waste is managed through implementation of a Waste Management

procedure that addresses the approach to manage waste in line with

the internationally accepted waste hierarchy, whereby disposal to

land is considered the last management option to undertake once

avoidance, re-use, recycling, recovery and treatment options have

been considered / eliminated. The procedure further details waste

disposal and management through characterization and

None.


WSP August 2019

Page 29


classification that is detailed in site specific waste registers

(provided for review).

Evidence:


000017_Rev10_2017-09;

— Steam Production_2016-11-07 (waste register).

Landscape areas are to be maintained and weeded frequently. N/A The entire site has tar and concrete paving all around. No landscaped

areas fall within the site.

None.

C.08 Waste Management

All waste generated during the operational phase must be

disposed off in a manner that is in accordance with Sasol’s

Waste Management Procedure (see Appendix 3).

C All waste generated onsite is handled according to Sasol’s Waste

Management Procedure. Adequate measures to handle and store

waste are implemented.

Evidence:


000017_Rev10_2017-09.

None.

Litter accumulating in or near the water bodies must be

controlled. This could be done by initiating clean-up

campaigns.

C Litter is removed as part of the maintenance strategy, and the site

was observed to be litter free.

None.

External dustbins should be cleaned at least once a week in a

maintenance plan for the development as per local authority

/contractor.

C Waste contractors collect waste twice a week, or as and when

required should volumes be large. However, large volumes are only

experienced during maintenance work.

None.

Efforts should be made to recycle wastes – income derived

can be used in motivational programmes for staff. C According to the Area Manager, at the moment, the only waste

currently being recycled onsite is paper waste which is collected by

either Mondi or Sappi.

OFI:

Further recycling

opportunities should be

explored.


WSP August 2019

Page 30


Disposal of all domestic waste must be undertaken by the

local council or an independent approved company (approved

by the council).

C Disposal of domestic waste is undertaken Sasol’s internal waste

service contractor, Enviroserv, which is a registered and licenced

service provider.

None.

Waste disposal records for hazardous waste must be filed and

available for inspection. N/A According to the SHE Environmental Compliance Specialist,

hazardous waste from site was last disposed of more than 5 years

ago. Therefore, it falls outside of the audit period.

None.

The development should be kept clean through the removal of

litter on a daily basis as per local authority guide. This should

be included in a maintenance plan for the development.

C The site was observed to be in a clean and tidy condition. Daily

removal of litter is not necessary, as the operation does not produce

considerable amounts of litter.

None.

C.09 Accident and Incident Reporting

Before establishment of a first aid facility on site the

Contractor shall negotiate and agree with the Sasol site

medical facility and Agent on minimum standards and the in

order clarify the type of treatment. The Sasol medical officials

may at any time audit such facilities. The Sasol Injury

classifications shall be used as a guide-line.

N/A There is no first aid facility onsite. However, Sasol has a fully

trained and equipped emergency response as well as medical team

always on standby for emergencies and accidents.

None.

The following accidents and incidents mentioned below shall

be reported immediately to the Agent’s Representative. Only

injuries which are classified as project related shall be

accepted and recorded for statistical purposes.

— Any occupational injuries and illnesses on site (Fatal

Cases, Lost Work Day Cases, Restricted Work Cases,

Medical Treatment Cases, First-aid Cases)

— All visits from Department of Labour, any condition

that may endanger the adjacent and surrounding plants

and any condition that may endanger the construction

activities must be reported to the Agent’s

representative.

C Sasol makes use of a web based Information Management System

(IMS) that includes a comprehensive Document Management

System (Easy DMS) where all supporting documentation is

available to prove compliance with legal requirements related to

process safety and Occupational Health & Hygiene.

All accidents and incidents are recorded within the onsite register.

None.


WSP August 2019

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— All reportable incidents as required by legislations.

(Flying or falling objects, machinery out of control,

failure of safety or alarm systems, dangerous substance

spilled or uncontrolled release of substance under

pressure).

— Any occupational diseases

— Any damage caused to the property or environment.

If a Contractor is making use of his own Medical facility he

shall ensure that all injuries are reported to the Sasol medical

station for confirmation of classification of all injuries

treated outside these facilities.

N/A Noted. Contractors typically utilise the Sasol medical facilities. None.

Reporting of all incidents is encouraged to determine trends

and identifying root causes and by rectification prevent

major incidents. The Contractor will be required to have in

place a system for identifying these trends and implementing

preventative actions.

N/A Noted. All accidents and incidents are recorded within the onsite

register. Contractors typically utilise the Sasol medical facilities.

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 4

below.

Table 4: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 12 4 0 8

ESTABLISHMENT OF THE DEVELOPMENT 4 0 0 4

CONSTRUCTION & OPERATION 14 5 0 9

WATER AND AIR POLLUTION 2 1 0 1

WASTE 4 2 0 2

MONITORING 3 1 0 2

REPORTING 5 2 0 3

Total Count 44 15 0 29

Total Percentage 34% 0% 66%

Percentage Compliance with Applicable Conditions 100%


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Page 33

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

the total proportion of compliance for the facility.

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

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

0

2

4

6

8

10

12

14

16

Sectional Count Contribution

C

NC

N/A

15

029

Total Compliance

C

NC

N/A


WSP August 2019

Page 34

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

percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

34%

0%66%

Total Percentage Compliance

C

NC

N/A


WSP August 2019

Page 35

5.2 ENVIRONMENTAL MANAGEMENT PLAN

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

applicable. The overall audit findings concerning compliance to the EMPr conditions are as listed in Table 5

below.

It is to be that noted that the conditions of the planning and construction phase have been excluded from the audit

as the audit period is from December 2014 to February 2019, and this development was already in operational

phase during that time.

Table 5: Summary of EMPr Compliance Audit Findings

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

PLANNING PHASE 16 0 0 16

CONSTRUCTION PHASE 24 0 0 24

OPERATIONAL PHASE:

GENERAL 1 1 0 0

SITE MANAGEMENT 1 1 0 0

SAFETY RISKS 2 2 0 0

GROUNDWATER QUALITY 3 2 1 0

SITE STORM WATER AND

SEWER SYSTEM MANAGEMENT

6 6 0 0

FLOODING 1 1 0 0

VISUAL AND AESTHETICS 3 2 0 1

WASTE MANAGEMENT 7 6 0 1

ACCIDENT AND INCIDENT REPORTING 4 1 0 3

Total Count 68 22 1 45

Total Percentage 22% 1% 66%

Percentage Compliance with Applicable Conditions 96%


WSP August 2019

Page 36

Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7

presents the total proportion of compliance for the facility.

Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section

Figure 7: Overall count findings on compliance to the EMPr conditions

0

5

10

15

20

25

30

Sectional Count Contribution

C

NC

N/A

22

145

Total Compliance

C

NC

N/A


WSP August 2019

Page 37

Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the

total percentage compliance for the facility.

Figure 8: Percentage contribution of findings made to the EMPr conditions per Section

Figure 9: Overall percentage findings on compliance to the EMPr conditions

5.2.1 EFFECTIVENESS OF THE EMPR

Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy

and effectiveness of the EMPr as part of the audit scope, as follows:

— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,

achieve the objectives and outcomes laid out in these documents;

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

32%

1%66%

Total Percentage Compliance

C

NC

N/A


WSP August 2019

Page 38

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr; and

— Identify the need for any changes to the avoidance, management and mitigation measures provided for in

the EMPr.

The EMPr compliance audit has identified that more than half of the listed measures are no longer applicable, as

these mostly related to the planning and construction phases only. The original EMPr document was designed

pre-operation principally to govern these construction phase impacts, and has been superseded during the

operational phase by Sasol Business Unit-specific risk assessments; compliance with the EA, relevant WUL and

AEL; and through Sasol’s choice to comply with the ISO 14001 Environmental Management international

standard.

The EIA Regulations 2014 (as amended) requires that the EA and EMPr is audited only at least every five years,

and Sasol has systems in place which are considered to be more robust for monitoring compliance and

implementing changes than through the EMPr audits; including the annual audit of each business unit to

meeting ISO 14001 standards.

New impacts and risks are continually identified and assessed by Sasol by its Governance SHE Risk and

Assurance department; which assesses environmental risks and drives improvement implementation. The SHE

Environment department facilitates Environmental Risk Assessments per business entity to ensure that gaps are

addressed through implementation of mitigation measures via the Integrated Management System. Sasol further

addresses all Key Undesirable Events (KUEs) from a group perspective. Risk documentation is hosted on

Sasol’s Information Management System.

In conclusion, WSP considers that for the duration that Sasol continues to operate each business unit under ISO

14001 standards and meet licence compliance (EA, WUL, AEL), this is effective as mitigation against any gaps

in the EMPr and as a means to regularly identify new impacts and risks. In the event that Sasol elects to no

longer comply with ISO standards, an alternative system must be implemented. Such an alternative may involve

updates to the EMPr and regular (annual) audits against these updates.

APPENDIX

A ENVIRONMENTAL AUTHORISATION (17.2.22.3GS 2)