SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION … · 2019-11-12 · wsp environmental (pty) ltd....

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

1/3/1/16/1 G-21 - N-PROPANOL DE-BOTTLENECKING PROJECT

29 MAY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

1/3/1/16/1 G-21 - N-PROPANOL DE-BOTTLENECKING PROJECT

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: MAY 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: 1/3/1/16/1

G-21

Draft for Review –

Compliance Audit

EA Ref: 1/3/1/16/1

G-21

Final – Compliance

Audit

EA Ref: 1/3/1/16/1

G-21

Date April 2019 May 2019 May 2019

Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Jenny Cope Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 002 002 002

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 Auditor

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 Specialist: Environment Broni van der Meer

Process Maintenance Coordinator Henning van Buuren

Production Asset Management Specialist Abednego Sibanyoni

Grade 2 Process Artisan Lorenzo Peters

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

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

WSP May 2019

TABLE OF CONTENTS

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

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

1.2 N- Propanol De-bottlenecking Project (SASOL

CHEMICAL OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 1/3/1/16/1 G-21) ............... 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 ...................................... 8

5 SUMMARY OF THE AUDIT FINDINGS ... 44

5.1 Environmental Authorisation ............................... 44

5.2 Environmental Management Plan ........................ 46


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 24

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 44

TABLE 5: SUMMARY OF EMP COMPLIANCE AUDIT FINDINGS .................................... 46

FIGURES

FIGURE 1: LOCATION OF THE DEBOTTLENECKING PROJECT (RED BLOCK) WITHIN SASOL SECUNDA PRIMARY AREA (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 44

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 45

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 45

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 46

FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 47

FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 47

FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 48


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FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMP CONDITIONS ............. 48

APPENDICES

A ENVIRONMENTAL AUTHORISATION (1/3/1/16/1- G-21)


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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: 1/3/1/16/1 G-21 issued on 14 March 2016) as well as the

associated Environmental Management Plan (dated: October 2015) for the period December 2014 to February

2019.

1.2 N- PROPANOL DE-BOTTLENECKING PROJECT

(SASOL CHEMICAL OPERATIONS: SOLVENTS

DIVISION) (AUTHORISATION NUMBER: 1/3/1/16/1 G-21)

Unit 038N, Figure 1, produces N-propanol (NPA) from Propylol (mixed alcohol) feedstock, which is obtained

from an upstream alcohol recovery Unit (Unit 38N), located within the Secunda Complex. The capacity of Unit

38 was increased after the implementation of several debottlenecking projects. The current bottleneck is the

treatment of Propylol in Unit 038N.

In 2016 Sasol received an EA to implement changes to the existing Unit 038N that would optimise the recovery

of NPA of the Unit 038N; increasing NPA production from 172 to 235.4 tonnes/day. The capacity increase was

realised through increasing Propylol feed from 246.7 to 340.8m3/day (198.7 to 275.3 tonnes/day). This is an

increase of 94.1 m3/day (76.6 tonnes/day).

In Unit 038N Purification is completed by means of extractive distillation with a solvent. The solvent is then

recovered by conventional vacuum distillation and recycled to the extraction process. By-product is recovered as

fuel alcohol.

The purpose of Unit 038N is to concentrate NPA up to a purity of at least 99.9 weight percentage. The main

impurity is 2-Butanol (SBA). The SBA is removed from the NPA by means of extraction with a heavy, non-

polar solvent. The solvent used consists typically of about 48 weight percentage C12 paraffin, 48 weight

percentage C13 paraffin with the remainder being paraffins lighter and heavier than C12 and C13.

The feed to Unit 038N comes from 56TK-3838 and is a mixture of alcohols, typically about 90 weight

percentage NPA and 8.5 weight percentage SBA, with the remainder heavier alcohols. The feed stream passes

through two feed/effluent heat exchangers in which it is heated via exchanging heat with the recycling solvent.

The feed enters the NPA column (38VL-201) in the lower half of the column.

The majority of the NPA is removed as primary product in the overhead of the NPA column. Liquid from the

bottom tray of the NPA column is passed through a side reboiler (38ES-202) where heat is recovered from the

recycled solvent. The liquid/vapour mixture from the side reboiler is returned to the NPA column above a

chimney tray, from where the liquid is fed to the NPA column reboiler (38ES-201R1). The liquid from the NPA

column reboiler, consisting of NPA, SBA and the solvent, is returned to the NPA column from where it is fed to

the solvent column (38VL3-202).

The remainder of the NPA and SBA in the solvent column are taken overhead as product while the solvent in

the bottom is recycled to the NPA column for extraction. The solvent from the bottom of the solvent column

passes through the NPA column side reboiler, then exchanges heat with the fresh feed stream in 38ES-204, after

which it is cooled in an air cooler, 38EA-213, and then finally exchanges more heat with the fresh feed in 38ES-

209. The solvent is then fed to the top half of the NPA column.


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Figure 1: Location of the Debottlenecking Project (red block) within Sasol Secunda Primary Area (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 all construction related conditions are

considered applicable (within audit period).

The objective of the audit was to:

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

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

and where applicable, the closure plans achieve the objectives and outcomes laid out in these documents;

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

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr;

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

the EMPr; and

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


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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 (14 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

Bronwyn Fisher conducted the site inspection on 14 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:

— Lorenzo Peters (in the absence, and under the direction of Henning van Buuren).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— 15. NPA Debottlenecking - EA - 14-03-16;

— 11._NPA_Debottlenecking_-_EMPr_Final;

— 10. NPA Debottlenecking - Final BAR Report (all Appendixes);

— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP Final_SRK-505119_2016-11-01;

— EA_EX Handover_SCO_Solvents_CWU_EA;

— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27;

— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to MDARDLEA

— SCO DQS ISO 14001 2015;

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

— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted;

— 3.15_EA_1.3.1.16.1 G-21_NPA_Appoint SRK as ECO;

— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-505119_Rev01_2016-09-23;

— 3.16_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints Register_2016-10-31 – Copy;

— 3.16_EA_1.3.1.16.1 G-21_NPA_Incidents Register_SRK-505119_2016-09-09;

— 3.17_EA_1.3.1.16.1 G-21_Courier_ECA report to MDARDLEA_2016-10-31;

— 3.17_EA_1.3.1.16.1 G-21_NPA_ECA EMP_Final_SRK505119_2016-11-01;

— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27;

— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to MDARDLEA;


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— 3.21_EA_1.3.1.16.1 G-21_NPA_AEL variation app_approval commission_2016-09-13;

— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklis_SRK-505119_Rev01_2016-08-29;






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

— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017- 2022 Rev_0;

— Environmental Complaints Register_2019-02-18;

— EA_EX Handover_SCO_Solvents_CWU_EA;

— 1_EMP_1.3.1.16.1 G-21_NPA_Communicate_EMP_contractors;

— 2.1_EMP_1.3.1.16.1 G-21_NPA_ECO_EnvToolboxTalks_2016-10-31;

— Labour_Sasol IRM Suppliers Industrial Relations Procedure;

— Induction_Mod2_Security;

— Induction_Mod5_WorkPlaceSafety;

— 3.35_EA_1.3.1.16.1 G-21_NPA_ECO_Incident Register_2016-10-31;

— SCO DQS BSOHSAS 18001 2007;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

— SEC-116-2017-CM(NOISE)(Chemical_Work_Up_West,_Production,_Units_037,_038,_038N,_073); 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.

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.


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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 Lorenzo Peters and Broni van der Meer 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: 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,

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

projects

— 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


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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

SCOPE OF AUTHORISATION

3.01 Environmental Authorisation of the activities is subject to

the conditions contained in this authorisation that are part of

the Environmental Authorisation and are legally binding on

the holder of the authorisation.

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

condition.

None.

3.02 The holder of the Environmental Authorisation must ensure

compliance with the conditions by any person acting on his

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

contractor, employee or person rendering a service to the

holder of the Authorisation,


condition.

None.

3.03 The activities that are authorised may only be carried out at

the property indicated above. C The auditor undertook a desktop review using Google Earth to

determine the site coordinates. The auditor confirms that the

coordinates within the EA match the location of the project (refer

to Figure 1).

Evidence:

None.


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Location of the coordinates of the plant as per the EA.

3.04 In the event of any dispute concerning the significance of a

particular impact, the opinion of the Department in respect of

its significance will prevail.

N/A Noted. Sasol has advised the auditor that no dispute has occurred

with the Department regarding the significance of an impact.

None.

3.05 A copy of this Environmental Authorisation must be made

available on site at all times and all relevant staff, contractors

and sub-contractors must be familiar with the contents of this

authorisation.

C Sasol provided the auditor with a copy of the Environmental

Control Officer (ECO) Report. The Report was compiled by SRK

as the independent ECO fort the duration of the construction

period. The ECO report provided evidence that the all contractors

involved with the construction activities were provided with a copy

of the EA and were provided with environmental awareness

training, which covered the conditions of the EA.

The auditor was advised by Sasol that copies of all authorisations

and licenses are sent to, and details communicated with, relevant

business units. Copies of these 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 Ethyl Acetate, Solvents) and Wilem Jacobs (legal appointee of

Polymers and Nitro), were made aware of the EA in

September/October 2016.

None.


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Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_EnvComplianceAudit EMP

Final_SRK-505119_2016-11-01

— EA_EX Handover_SCO_Solvents_CWU_EA

The location of the EAs and EMPrs on the SAP EC.

3.06 Any changes to, or deviations from the project description

set out in this Environmental Authorisation must be

approved in writing, by the Department before such changes

or deviations may be effected. In assessing whether to grant

such approval or not, the Department may request such

information as it deems necessary to evaluate the

significance and impacts of such changes or deviations and it

may be necessary for the holder of the authorisation to apply

for further Environmental Authorisation in terms of the

regulations.

N/A Noted. Sasol confirmed with the auditor that no changes or

deviations have been made to the project description as set out in

the EA.

None.


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3.07 These activities must commence within a period of four (4)

years from the date of issue. If commencement of the

activates do not occur within that period, the Environmental

Authorisation lapses and a new application for

Environmental Authorisation must be made in order for the

activities to be undertaken, unless the holder of this

environmental authorisation has lodged a valid application to

amend the validity period of this authorisation before this

authorisation lapses, in which case this authorisation will

remain valid. However, the activities, including site

preparations may not commence prior to the amendment

application being decided. The Department may change or

amend any of the conditions in this authorisation if, in the

opinion of the Department is environmentally justified.

C Construction activities commenced within approximately 3 months

of the issuing of the EA. This was confirmed in an email and

supporting letter from Sasol to the Department notifying them of

the commencement of construction activities. In addition, the

auditor was provided with the ECO report from the construction

period, which confirmed the commencement of construction in

June 2016.

Evidence:

— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27

— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to

MDARDLEA


Final_SRK-505119_2016-11-01

None.

3.08 The Department may change or amend any of the conditions

in this authorisation if, in the opinion of the Department, it is

environmentally justified.

N/A Noted. Sasol has advised the auditor that no amendments have

been requested by the Department.

None.

3.09 This Environmental Authorisation does not negate the holder

of the authorisation, responsibility to comply with any other

statutory requirements that may be applicable to the

undertaking of the activities.

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

Audit.

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

compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, 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.


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3.10 The holder of this authorisation is responsible for

compliance with the provisions for Duty of Care and

Remediation of Environmental Damage contained in Section

28 of the National Environmental Management Act, 1998

(Act 107 of 1998).

N/A Noted. Sasol are aware of their responsibility for compliance with

the provisions of the Duty of Care and remediation of

Environmental Damage.

None.

APPEAL OF AUTHORISATION

3.12 The holder of the authorisation must notify every registered

interested and affected party, in writing and within 14 days,

of receiving notice of the Department`s decision to authorise

the activities.

C Sasol provided the auditor with proof that an advert was placed in

the Ridge Times notifying all interested and affected parties of the

Department’s decision. The advert was placed on 25 March 2016,

11 days after the EA was issued.

Evidence:

— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted

None.

3.13

The notification referred to above must:

a) Specify the date on which the authorisation was issued;

b) Inform the interested and affected parties of the appeal

procedure provided for in Chapter 2 of the regulations; and

c) Advise the interested and affected parties that a copy of

the Environmental Authorisation and reasons for the

decision will be furnished on request

C The advert placed in the Ridge Times on the 25 March 2016

specified the date on which the decision was issued, informed IAPs

on the appeal procedure, and provided details of who to contact to

request a copy of the EA.

Evidence:

— 3.13_EA_1.3.1.16.1 G-21_NPA_Proof of notices posted

None.

MANAGEMENT AND MONITORING

3.14 The Environmental Management Programme (EMPr) dated

October 2015, as incorporated in the Final Basic Assessment

Report for Environmental Authorisation is hereby approved.

N/A Noted. None.

3.15

The applicant must appoint an independent Environmental

Control Officer (ECO) that will have the responsibility of C Sasol appointed SRK Consulting (South Africa) Pty Ltd (SRK) as

the ECO for the duration of the construction phase. A copy of the

None.


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implementing the approved EMPr and ensuring compliance

with the conditions of this Environmental Authorisation

ECO report compiled by SRK as well as the competency of the

responsible ECO was provided to the auditor.

Evidence:


Final_SRK-505119_2016-11-01

— 3.15_EA_1.3.1.16.1 G-21_NPA_Appoint SRK as ECO

3.16 The ECO must maintain the following on site:

a) Strict compliance of the development to the conditions of

the Environmental Authorisation.

b) Discuss and advise contractor on site in respect of

environmental compliance before and during construction

activities.

c) Monitor compliance during construction and operation

phases of the activities.

d) Keep a site diary

e) Keep a complaints` register of all environmental

complaints regarding the proposed project and the remedies

applied to such complaints.

C The auditor was provided with the ECO report, which ensures

compliance of all construction conditions. The ECO was not

appointed to monitor compliance during the operational phase.

This is the responsibility of the Sasol SHEQ Managers. The ECO

report shows compliance with the following:

(a) Strict compliance of the development to the conditions of the

Environmental Authorisation. The ECO was onsite weekly to

monitor compliance with the conditions of the EA and the

EMPr. Contractors were advised on good environmental

practise and means to improve compliance where considered

by the ECO to be appropriate.

(b) Discuss and advise contractor on site in respect of

environmental compliance. The ECO report indicates that the

contractor was provided with environmental awareness

training and provided Toolbox talks on a regular basis

covering a variety of environmental topics.

(c) Monitor compliance during construction and operation phases

of the activities. The ECO undertook weekly site audits during

the construction phase. However, the ECO was not appointed

to monitor the construction phase.

(d) Keep a site diary. Although no evidence specifically of a site

diary was provided within the ECO report, weekly checklists

were compiled. An incidents register was maintained during

the construction phase and all non- conformances were

reported within the incidents register. Such activities are

None.


WSP May 2019

Page 14


generally considered consistent with the typical contents of a

site diary.

(e) Keep a complaints register of all environmental complaints

regarding the proposed project and the remedies applied to

such complaints. A complaints register was kept onsite during

the construction phase and attached to the ECO report. No

complaints had been recorded within the register, and the ECO

reported that no complaints were received during the

construction period.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklist_SRK-

505119_Rev01_2016-09-23


Final_SRK-505119_2016-11-01

— 3.16_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints

Register_2016-10-31 – Copy

— 3.16_EA_1.3.1.16.1 G-21_NPA_Incidents Register_SRK-

505119_2016-09-09

3.17 The holder of the authorisation must submit a post-

construction environmental audit report to the Department

within 30 (thirty) days after completion of each authorised

activities on site.

C The auditor was provided with a copy of the final ECO audit

report, dated November 2016. The ECO report as couriered to the

department by SRK on 31 October 2016.

Evidence:

— 3.17_EA_1.3.1.16.1 G-21_Courier_ECA report to

MDARDLEA_2016-10-31;

— 3.17_EA_1.3.1.16.1 G-21_NPA_ECA

EMP_Final_SRK505119_2016-11-01.

None.

3.18 The Department retains the right to monitor and/or inspect

the proposed project during both construction and

operational phases.

N/A Noted. Sasol advised the auditor that the Department comes to site

to monitor operational activities on a regular basis

None.


WSP May 2019

Page 15


COMMISSIONING & OPERATION

3.19 Fourteen (14) days written notice must be given to the

Department that the activities will commence.

Commencement for the purposes of this condition includes

site preparation. The notice must include a date on which it

is anticipated that the activities will commence.

C Construction activities commenced within approximately 3 months

of the issuing of the EA. This was confirmed in an email (dated 27

May 2016) and supporting letter from Sasol to the Department

notifying them of the commencement of construction activities,

which were planned for end of June 2016 (therefore >14 days). In

addition, the auditor was provided with the ECO report from the

construction period, which confirmed the commencement of

construction in June 2016.

Evidence:

— 3.07_EA_1.3.1.16.1 G-21_NPA_FW NoteConst_2016-05-27

— 3.07_EA_1.3.1.16.1 G-21_NPA_Notice of Construction to

MDARDLEA


Final_SRK-505119_2016-11-01

None.

3.20 The conditions stipulated in this Environmental

Authorisation and mitigation measures contained in the final

environmental impact report are legally binding components

of any contract and are therefore legally enforceable.


condition.

None.

3.21

The current N-propanol plant’s Air Emission License must

be amended, therefore no construction must take place

before the Air Emission License from the Gert Sibande

District Municipality is being amended and/or issued.

C Sasol received permission, via email on 14 September 2016, from

Nomsa Thabethe at the Gert Sibande District Municipality, that

they can commence with commissioning of the plant.

It is the auditor’s understanding that an application for an

amendment to the Sasol Solvents’ AEL (which was issued in

March 2015) had been lodged prior to the commissioning of the

plant. Whilst the amended AEL has not yet been received, the

Department did acknowledge the application at the time and gave

permission to continue the operations.

Evidence:

OFI:

Sasol should follow up with

the Gert Sibande District

Municipality with regards to

the Amended AEL.

Completion Target:

Medium term


WSP May 2019

Page 16


— 3.21_EA_1.3.1.16.1 G-21_NPA_AEL variation app_approval

commission_2016-09-13

3.22 Measures must be undertaken to ensure the prevention or

minimization of erosion during construction. Such measures

must take into account the period in which construction takes

place.

C Sasol appointed an ECO to undertake monitoring of compliance

against the EMPr and EA. The weekly checklists undertaken by

the ECO showed no erosion issues or incidents were noted during

the construction phase. This is largely attributed to the location of

the construction activities within the existing Sasol Complex and

the existence of a stormwater management system.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_Audit Checklis_SRK-

505119_Rev01_2016-08-29


505119_Rev01_2016-07-08


505119_Rev01_2016-07-15


505119_Rev01_2016-07-26


505119_Rev01_2016-08-10


505119_Rev01_2016-08-15


505119_Rev01_2016-09-02


505119_Rev01_2016-09-05


505119_Rev01_2016-09-16


505119_Rev01_2016-09-23

None.


WSP May 2019

Page 17



Final_SRK-505119_2016-11-01

3.23 Any complaints received from the employees or anyone

within the immediate vicinity of the site during the

construction and operational phases of the activity must be

attended to as soon as possible and addressed to the

satisfaction of all involved.

C During the construction phase a complaints register was

maintained onsite and provided to the auditor with the Final ECO

Report. No complaints were received.

Sasol has advised the auditor that all environmental complaints

received from interested and affected parties, both internal and

external to the organisation, are recorded in a complaints register

that is available at the Environmental department. Complaints are

investigated and reported in line with the procedure and as per

legal requirements.

The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the Debottlenecking Plant for the audit period.

Evidence:


Final_SRK-505119_2016-11-01

— 3.23_EA_1.3.1.16.1 G-21_NPA_ECO_Complaints

Register_2016-10-31

— Environmental Complaints Register_2019-02-18

None.

3.24

Dust suppression measures must be implemented during all

phases of the project. N/A The auditor was provided with the ECO Report and all ECO

weekly checklists. The ECO Report noted that the activities

conducted during the construction phase did not require dust

suppression. Although the ECO Report does not provide a reason it

is assumed that it was due to the minimal soil disturbance

undertaken as part of the construction activities,

In addition, the operational activities at the 038N unit do not

generate dust and therefore dust suppression is not necessary. This

was confirmed by the auditor during the site walk over.

Evidence:

None.


WSP May 2019

Page 18



Final_SRK-505119_2016-11-01

Entire plant is hard surfaced.

3.25 All hazardous materials must be stored in designated, lined

and bounded areas. C The auditor observed that hazardous substances being stored onsite

are done so in tanks. The tanks are located within bunded areas.

Evidence:

None.


WSP May 2019

Page 19


Storage tanks associated with U38N, located within bunded tank farms.

3.26 The handling and storage of any hazardous waste must

comply with the relevant statutory requirements. C The auditor was advised that waste management is managed

through implementation of a Waste Management procedure (SGR-

SHE-000017 REV10), which provides the approach of managing

waste in line with the internationally accepted waste hierarchy.

According to this hierarchy, 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.

Waste Registers were made available to the auditor. A sample of

the registers specifically related to the Solvent operations were

checked during the audit. It is however noted that, during normal

operations, no waste is produced – as by-products are either

recovered or sent back into the wider Sasol Secunda system.

None.


WSP May 2019

Page 20


Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol Secunda Industrial Complex, Mpumalanga IWMP

2017- 2022 Rev_0.

3.27 All general waste generated on site must be disposed of at a

registered landfill site or as directed by relevant authority. C The auditor viewed the Waste Management procedure that is in

place, and this provides an approach to manage waste in line with

the internationally accepted waste hierarchy, waste classification

and characterisation (see above).

General waste is disposed of at the Sasol waste management

facility, located at Charlie 1.

Evidence:


000017_Rev10_2017-09

None.

3.28 It is the responsibility of the holder of the authorisation to

rectify any source of pollution and to take appropriate

measures to prevent any pollution of surface and ground

water.

C The auditor has noted that 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.

The Auditor noted the following precautions that have been put in

place to prevent surface and ground water pollution:

— The entire plant is bunded and hardsurfaced;

— There plant has both a Chenicals Conservation Sewer (CCS)

to drain all spilled feed or product back to eh feed tank,

— There is an Oily Water Sewer (OWS) for all stormwater

falling within the plant;

— Surface and groundwater monitoring is done in accordance

with the IWWMP.

None.


WSP May 2019

Page 21


Evidence:

— SIC IWWMP Action Plan Update_FY18_20180123;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.

3.29 Appropriate ablution facilities must be provided for the

construction team. C The ECO report provided by Sasol confirmed that permanent

ablution facilities, located within the operational areas, were made

available to the contractor for the duration of the construction

activities.

Evidence:

— 3.26_EA_1.3.1.16.1 G-21_NPA_Envir Compliance Audit

EMP Final_505119_2016-11-01.

None.

3.30

Spillages must be cleaned up as soon as it is practically

possible to prevent soil and water pollution. C Sasol have an Integrated Waste and Water Management Plan

(IWWMP) which aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

The plant has been designed in such a way that should any spill

occur, it will drain into the Chemical System where the spilled

material is drained back into the feed tank for reprocessing. No

evidence of spillages were observed during the site inspection.

Evidence:



None,

3.31

Ponding of water must be prevented on site in order to avoid

pollution of ground water. C Sasol have an Integrated Waste and Water Management Plan

(IWWMP) which aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

None.


WSP May 2019

Page 22


with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

All stormwater falling onto the site drains into the OWS and then

sent to the API dams. No evidence of pooling of water was

observed during the site inspection.

Evidence:



3.32

Storm water management plan and mitigation measures

regarding erosion control should be developed and adhered

to.

C As above, Sasol have an Integrated Waste and Water Management

Plan (IWWMP), which covers erosion prevention in general.

Stormwater erosion at the plant is not anticipated as the entire plant

is hardsurfaced, and stormwater drainage ties into the site wide

stormwater management system.

Evidence:

— SIC IWWMP Action Plan Update_FY18_20180123

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2

None.

GENERAL

3.33

A copy of this Environmental Authorisation must be kept at

the property where the activities will be undertaken. The

authorisation must be produced to any authorised official of

the Department who requests to see it must be made

available for inspection by any employee or agent of the

holder of the authorisation who works or undertakes work at

the property.

C Copies of all authorisations and licenses are sent to, and details

communicated with, relevant business units. Copies of these

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 Ethyl Acetate, Solvents)

and Wilem Jacobs (legal appointee of Polymers and Nitro), were

made aware of the EA in September/October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_CWU_EA

None.


WSP May 2019

Page 23


3.34

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.

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

to the details included in the EA.

None.

3.35

The holder of the Environmental Authorisation must notify

the Department, in writing and within 24 (twenty-four)

hours, if conditions of this Environmental Authorisation are

not adhered to. Any notification in terms of this condition

must be accompanied by reasons for the non-compliance.

C Non non-conformances with the EA have been noted during this

audit.

None.

3.36

Non-compliance with a condition of this authorisation may

result in criminal prosecution or other actions provided for in

the National Environmental Management Act, 1998 and the

regulations.


condition.

None.

3.37

National government, provincial government, local

authorities or committees appointed in terms of the

conditions of this Environmental Authorisation or any other

public authority shall not be held responsible for any

damages or losses suffered by the applicant or his successor

in title in any instance where construction or operation

subsequent to construction be temporarily or permanently

stopped for reasons of non-compliance by the applicant with

the conditions of authorisation as set out in this document or

any other subsequent document emanating from these

conditions of authorisation.


condition.

None.


WSP May 2019

Page 24

Table 3: Audit Findings – Environmental Management Plan


1 This EMPr must form part of the contractual agreements

with the specific contractors. C Sasol provided the auditor with evidence that the contractor

responsible for the construction activities was made aware of the

EMPr Additionally, evidence that the EMPr was included as part

of the contract documentation was also provided.

Evidence:

— 1_EMP_1.3.1.16.1 G-

21_NPA_Communicate_EMP_contractors

None.

This condition is considered

non-rectifiable given

construction is completed.


WSP May 2019

Page 25


Contractors’ declaration of acceptance of the EMP

2.1 The contractor is expected to have safety “tool box” talks in

accordance with the risks and trends associated with the

project. Proof of these talks shall be kept on site.

C Sasol provided proof of the Toolbox talks (including the

attendance registers) undertaken during the construction phase by

the contractor, Topfix. The toolbox talks topics included:

— Material Handling;

— General awareness;

— Safety Moment: Hazardous waste;

— Safety Moment: Eating areas;

— Spill Control;

— Save Water;

— Water Pollution;

— Situational awareness - Emergency Assembly &

Environmental (wetlands); and

— Flash Notification.

Evidence:

— 2.1_EMP_1.3.1.16.1 G-

21_NPA_ECO_EnvToolboxTalks_2016-10-31

None.


WSP May 2019

Page 26


2.2 The contractor will develop specific emergency procedure

and plan. C Sasol advised the auditor that each contractor was provided with a

copy of the Sasol site specific Emergency Response Plan. This was

confirmed within the Final ECO Report, dated November 2016.

All contractors working on Sasol sites are required to align entirely

with the Sasol emergency procedure in order to ensure a unified

response in the event of an emergency. All service providers

inductions therefore include training in, and are expected to follow

the Sasol emergency management procedures.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA

Envir Audit EMP Final

None.

3 Labour (skilled and unskilled) and contractors employed for

the proposed improvements to Unit 038N should be sourced

locally where feasible.

C Sasol has advised the auditor that they have implemented a

Supplier Industrial Relations Procedure (SIRP) that aims to

provide the greatest degree of uniformity, consistency and to

standardisation of procedures and practices pertaining to security /

site access and Industrial Relations matters to all Suppliers, their

Agents, Sub-contractors and Labour brokers/TES. Suppliers and

contractors are required to ensure that the SIRP, its procedures and

practices are communicated, understood, observed and followed

by them and all their constituents at all times. Non-compliance

with the procedure may result in the termination of the commercial

agreement between the parties. The policy makes reference

preferential recruitment practices, where preference must be given

to local people residing within the local municipality.

Evidence:

— Labour_Sasol IRM Suppliers Industrial Relations Procedure

None.

4 No alcohol /drugs are permitted on site. C Sasol prohibit drugs and alcohol onsite. Random spot checks and

random alcohol testing are carried out on persons entering the

Sasol Secunda Complex, as well as the entrance to the Sasol

Solvents operational areas. Module 2 of the Sasol Induction

None.


WSP May 2019

Page 27


includes instruction that drugs and alcohol as items are not

permitted on site.

Evidence:

— Induction_Mod2_Security.

Induction Training Module 2 shows drugs and alcohol as prohibited items

5 No firearms allowed on site, unless used by security

personnel. C Sasol prohibit firearms or weapons onsite. Module 2 of the Sasol

Induction includes weapons and firearms as items not permitted on

site. Vehicles are randomly checked at the entrance to the Sasol

site, as well as at the entrance to the Sasol Solvents operational

area.

Evidence:

— Induction_Mod2_Security.

None.

6.1 Correct Personal Protective Equipment (PPE) must be worn

at all times by the personnel on site. Personnel must be

trained on the use of PPE.

C Any person entering the operational areas within the Sasol

Secunda Complex must have the correct PPE as indicated on the

signage at the various plants. Any person not wearing the correct

PPE is prohibited from accessing the plant. PPE requirements are

provided in Induction Module 5. During the site inspection the

auditor observed that all personnel were wearing the PPE indicated

None.


WSP May 2019

Page 28


on the signage located around the site (i.e. hard hat, boots, overalls,

Hearing protection and googles).

Evidence:

— Induction_Mod5_WorkPlaceSafety.

6.2 A register will be kept on what PPE has been issued and

when. Contractors are to take disciplinary action against

employees who fail to adhere to the PPE requirements.

C According to the Final ECO Report, correct PPE was made

available to all contractors onsite. Each contractor appointed a

Safety Officer who monitors the use of PPR on site.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

7 Smoking can only take place in designated smoking areas. C As part of the Sasol Secunda Operations, smoking is only

permitted in designated areas. The ECO report noted that ‘No

Smoking’ signs had been erected around the site and no

contraventions were observed.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

8 Each contractor will employ their own Safety Officer to

monitor the safety conditions during the construction phase.

Sasol Safety Officer will oversee the contractor.

C Sasol advised that each contractor appointed a Safety Officer for

the duration of the construction phase. This is confirmed in the

Final ECO report.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

9 Any safety or environmental incidents must be reported to

the Safety Officer who then needs to communicate to the

Environmental Standby (082 902 1989).

C During the construction phase an incidents register was maintained

onsite. The incident register was provided to the auditor. The

incidents recorded were minor and did not require the

environmental standby team.

None.


WSP May 2019

Page 29


Evidence:

— 3.35_EA_1.3.1.16.1 G-21_NPA_ECO_Incident

Register_2016-10-31

10 No unauthorised ignition sources will be permitted on site

and debris/waste shall not be burnt under any circumstances. C Due to the nature of the site no unauthorised ignition sources are

prohibited onsite.

None.

11 Erect suitable warning and information signage near any

hazardous storage facility. Handling of hazardous chemicals

must only be done by trained personnel.

C During the construction phase Sasol advised the auditor that no

hazardous substances were stored onsite. This was confirmed

within the ECO Report.

The auditor noted that suitable signage has been erected across the

site. The signage indicates the PPE that must be worn as well as an

indication of the dangers associated with the facility.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


Signage at the entrance to the plant.

None.


WSP May 2019

Page 30


12 All provisions of the Occupational Health and Safety Act

(Act No 85 of 1993) and Sasol Internal Standards must be

fully complied with.

C The ECO report noted that a safety officer for the project, who

monitored all safety requirements had been appointed. The safety

officer was responsible for adherence to the Occupational Health

and Safety Act (Act No. 85 of 1993) and Sasol Internal Standards.

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:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


— SCO DQS BSOHSAS 18001 2007

None.

13 In the event of an emergency, the Contractor shall contact

the Sasol emergency services. Telephone numbers of Sasol

emergency services must be posted conspicuously at the site.

C The auditor observed that there are numerous information boards

across the site which contain the contact details for the Emergency

Response Team. The ECO report noted this during the

Construction Phase.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 31


The emergency contact details on signage at the entrance to the debottlenecking plant.

14 Safety Data Sheets (SDSs) must be readily available on site

for hazardous substances. C The ECO report for the construction phase noted that all SDSs

were kept within the Environmental File.

Hazardous chemicals stored onsite during the operational phase are

stored within Storage Tanks. The SDS are therefore kept on file

within the control room. The auditor was shown the location of all

SDS associated with the plant.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 32


15 Workers should at all times be made aware of the health

risks associated with any hazardous substances/dangerous

goods used, through talk topics and awareness campaigns.

C The ECO Report noted that the contractor undertook Toolbox

Talks during the construction period.

Sasol advised the auditor that all employees undertake Sasol

Induction training, which they must refresh annually, as well as

Induction Training specific to the Sasol Solvents Operational area.

This training covers the health risks associated with hazardous

substances.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

16 In the event of an emergency relating to hazardous

substances, procedures detailed in the SDS shall be

implemented.


condition.

None.

17 Where waterborne sewerage is not available, an area must be

designated for the erection of portable chemical toilets. An

accredited company must then provide temporary chemical

toilets. Such toilets must be available for all construction

staff.

C Sasol advised the auditor that the contractors were provided with

access to ablution facilities connected to the sewerage. The ECO

report indicated that waterborne sewage was made available during

the construction period.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

18 Under no circumstances may open areas or the surrounding

vegetation be used as toilet facilities. C The ECO report noted that during the construction phase no

incidents were recorded. Sasol advised the auditor that public

urination is prohibited onsite and is a fineable offence. The auditor

reviewed the incidents register and no incidents of public urination

or similar have been recorded.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA

Envir Audit EMP Final;

None.


WSP May 2019

Page 33



— Environment Impact register_ New FY19_2019-02-18.

19 Toilets, permanent or portable/temporary, shall be

maintained in a hygienic state and serviced regularly.

Portable toilets, should they be required, should be serviced

by a reputable contractor and the contents shall be removed

to a licensed disposal facility.

C The ECO Report noted that during the construction phase the

toilets were kept in a suitable condition.

Sasol advised the auditor that the toilets, which are permanent and

located in various locations across the site are connected to the

sewer system and are cleaned on a regular basis.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA

Envir Audit EMP Final.

None.

20 Contractors’ waste management procedures will be approved

as part of the safety file. C Sasol advised the auditor that each contractor was provided with a

copy of the Sasol Waste Management Procedure. This was

confirmed within the ECO Report.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

21 Existing storm water management structures servicing the

Unit 038N will be inspected regularly to ensure they are in

proper working order.

C During the construction phase the ECO undertook weekly

monitoring of the stormwater management structures on and

around the construction site.

Sasol advised the auditor that stormwater management structures

are inspected on a regular basis by the plant managers.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 34


22 Sufficient bins/skips are to be provided for the safe and

environmentally responsible disposal of waste. C The ECO Report noted that during the construction phase, the

contractor was provided with waste receptacles. The receptacles

were labelled according to the designated waste type.

Waste produced as a result of the operational activities is managed

in accordance with Sasol’s Waste Management procedure. The

auditor viewed the Waste Management procedure that is in place,

and this provides an approach to manage waste in line with the

internationally accepted waste hierarchy. The procedure further

details waste disposal and management through characterisation

and classification that is detailed in site specific waste registers. It

is however noted that, during normal operations, no waste is

produced as by-products are either recovered or sent back into the

system.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA



000017_Rev10_2017-09;


2017- 2022 Rev_0.

None.

23 Littering on site is forbidden and the site must be cleared of

litter at the end of each working day. C The ECO Report noted that during the construction phase small

quantities of litter were observed on site during the weekly audits.

The site was cleaned on a daily basis after each shift. At the end of

construction no litter was noted onsite.

During the site walkover, the auditor did not observe any litter

onsite.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 35


24 Where possible, materials used or generated by construction

activities must be recycled. C The ECO Report noted that all redundant recyclable materials

generated as a result of the construction activities was collected

and recycled by Sasol.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

25 Waste will not be stored for a period exceeding 90 days or

volumes exceeding 100 cubic meters. C During the construction phase the ECO report noted that waste was

removed at frequent intervals. No waste was stored for more than

90 day. Whilst volumes were not provided. It is assumed however,

that the construction activities did not produce more than 100m3

due to the scale of the construction activities.

During normal operations, no waste is produced as everything is

either recovered or sent back into the system. All general office

type waste is collected regularly and taken to the Waste

Management Facility at Charlie 1 for disposal.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA



000017_Rev10_2017-09.

None.

26 Waste generated on the proposed site should be collected by

authorised waste contractors and frequently disposed of at a

licensed landfill site as the last resort. Recycling/reuse of

waste should be enforced where feasible.

C The auditor was advised that waste management is carried out via

implementation of a Waste Management procedure (SGR-SHE-

000017 REV10), which addresses the approach to manage waste in

line with the internationally accepted waste hierarchy. According

to the hierarchy 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.

None.


WSP May 2019

Page 36


Waste Registers were made available to the auditor. A sample of

the registers specifically related to the Solvent operations were

checked during the audit. It is however noted that during normal

operations, no waste is produced as by-products are either

recovered or sent back into the system.

Evidence:


000017_Rev10_2017-09;


2017- 2022 Rev_0.

27 An inventory of all chemicals on site must be kept together

with the respective SDS. C The ECO report for the construction phase noted that all SDSs

were kept within the Environmental File.


stored within Storage Tanks. The SDS are therefore kept on file

within the control room. The auditor was shown the location of all

SDS associated with the plant. Sasol maintain a full inventory of

all chemicals stored onsite as these chemicals form part of their

processing activities.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

28 Cleaning of equipment/vehicles should be done in a

designated area to prevent soil and water pollution. C The ECO Report noted that the no vehicle or equipment was

cleaned onsite during the construction phase of the project.

Equipment and vehicles were removed from site after each shift.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 37


29 Storage areas containing hazardous substances/materials are

to be clearly demarcated and labelled. C The ECO report noted that during the construction phase no

hazardous substances were stored onsite.


stored within Storage Tanks. The auditor observed that the tank

farm was clearly demarcated and signage erected regarding PPE

requirements and safety warnings.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.

30 Functional spill kits and/or drip trays are to be made

available at areas where potential spillages of substances can

take place Machinery will be kept maintained in line with

manufacturers specifications to minimise the risk of

hydrocarbon spillages.

C The ECO report noted during the construction phase a spill kit was

kept onsite by the contractor.

Spill kits were observed across the site, however, the site is

hardsurfaced and bunded. Any spilled material or product drains to

Chemical Sewer where it is sent back to the material feed tanks

and is reprocessed.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA



None.

31 Remediation of spillages must be conducted as far as

practically reasonable given the operational constraints of

the Unit 308N.

C The ECO Report noted that during the construction phase a

hydrocarbon spill was identified and remediated immediately. The

contaminated Soil was sent to Sasol for remediation.

As the site is hardsurfaced and bunded, any spilled material or

product drains to Chemical Sewer where it is sent back to the

material feed tanks and is reprocessed.

Evidence:

— 3.16_EA_1.3.1.16.1 G-21_NPA_505119 2016 11 01_NPA


None.


WSP May 2019

Page 38



32 No wastewater or waste will be disposed of into the

surrounding environment at any time. Water collected in

bunded areas must be collected in containers and disposed of

in accordance with Sasol’s wastewater management

Standards.

C The ECO Report noted that during the construction phase, all

water was managed through the existing stormwater management

system.

The drainage of all the storm water run-off from Solvents is routed

to the API Oily Water System (OWS) as part of the formal runoff

drainage within the Primary Area. This includes clean storm water

from the Chemical Work Up area.

Evidence:


None.

33 An incident reporting system will be implemented in order

to ensure incidents, where spillage occurred, are closed out

and appropriate measures are taken to prevent further

incidents.

C Sasol advised the auditor that 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.

Incident next steps are managed on SAP PS1 (transaction code

QM02) and progress is reported in the monthly performance

reports which is sent to all senior managers.

Evidence:

— Environmental incident procedure Process flow;

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11;


None.

34 When mortar is used on site, the following guidelines apply:

— Carefully control all on-site operations that involve the

use of mortar and concrete;

— Limit mortar mixing to single sites where possible;

C The ECO report noted that no cement mixing was done onsite.

Cement required for construction was transported to site already

mixed.

No cement is required for normal operational activities.

Evidence:

None.


WSP May 2019

Page 39


— Use plastic trays or liners when mixing mortar and

concrete: Do not mix mortar and concrete directly on

the ground;

— Dispose of in the approved manner.


EMP Final_505119_2016-11-01.

35 Where there is contaminated soil, the Environmental

Standby and Emergency Services must be notified, who will

advise on treatment, clean-up and disposal.

C The ECO report noted that only small hydrocarbon spills occurred

during the construction phase. These were remediated to the

approval of the ECO.

Evidence:


EMP Final_505119_2016-11-01;



None.

36 Should there be a specific storage area for fuel, oil and other

hydrocarbon/hazardous materials. This area will be access

controlled and SDSs will be available.

C The ECO Report noted that no storage was required during the

construction phase.

The auditor noted that the entire solvents operation is monitored by

security and access is controlled through access booms and

security checks. All visitors have to report to security where they

are either accompanied around site by an authorised individual or

undergo induction training specifically for the solvents operational

area.

Evidence:


EMP Final_505119_2016-11-01.

None.

37 Speed limits applicable to the SSIC should be enforced on

the access road to the construction site. C The ECO Report noted that during the construction phase speed

limits were adhered to in accordance with the Sasol Safety

Standards.

Evidence:

None.


WSP May 2019

Page 40



EMP Final_505119_2016-11-01.

38 Vehicles and machinery should be maintained regularly to

ensure that emissions are minimized. C The ECO Report noted that during the construction phase no

excessive emissions were observed during the construction phase.

Evidence:


EMP Final_505119_2016-11-01.

None.

39 Should extensive dust be generated during construction,

localised dust suppression will be implemented. C The ECO report noted that during the construction phase no

excessive dust emissions were observed.

Evidence:


EMP Final_505119_2016-11-01.

None.

40 Use of potentially polluting and hazardous substances on site

should be strictly controlled. C The ECO report noted that during the construction phase, minimal

hazardous substances were utilised. The gases used for welding

were stored in designated cage within the operational area.

Potentially polluting and hazardous substances are stored within

tanks in the tank farm prior to being used or once they have met

the required product specification. These substances are essential

to produce the array of products produced by Sasol.

Evidence:


EMP Final_505119_2016-11-01.

None.


WSP May 2019

Page 41


The tank farm at the plant.

41 Where there is contaminated soil, the Environmental

Standby and Emergency Services must be notified, who will

advise on treatment, clean-up and disposal.

C The ECO report noted that only small hydrocarbon spills occurred

during the construction phase. These were remediated to the

approval of the ECO.

Evidence:


EMP Final_505119_2016-11-01;



None.

42 Spill response procedures must be clearly defined and well

known by all construction staff. C The ECO Report noted that the contractors using chemicals and

hydrocarbons had a spill procedure in place. No chemicals were

stored onsite during the construction phase.

Evidence:


EMP Final_505119_2016-11-01.

None.


WSP May 2019

Page 42


43 Demolish and remove all infrastructure not required post

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

decommission this plant in the foreseeable future.

None.

44 Should there be reason or suspect reason the soils are

contaminated following decommissioning activities, the soils

will be assessed by a competent person and remediated

within a reasonable timeframe.

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


None.

45 The footprint area of the decommissioning activities must be

landscaped to represent the surrounding environment as

determined by the relative timing of Unit 038N

decommissioning to the overall SSIC decommissioning.

Landscaping must be done so that pooling of water does not

occur.



None.

46 Signs of erosion must be inspected on a frequent basis

following decommissioning activities. Remedial measures

will be instated should erosion occur.



None.

47 Appropriate PPE will be worn by employees and contractors. C The ECO Report noted that during the construction phase all

contractors wore PPE. This was inspected by the contractors

Safety Officer.

Sasol advised the auditor that any individual entering the

operational areas must have the correct PPE or access is

prohibited. The auditor observed all personal wearing the correct

PPE. The importance of PPE is included within the site induction

Training.

Evidence:


EMP Final_505119_2016-11-01;

— Induction_Mod5_WorkPlaceSafety.

None.


WSP May 2019

Page 43


48 If noise levels exceed 85 dBA, acoustic mitigation measures

must be installed. C The ECO Report noted that during the construction phase the

construction activities did not escalate the noise levels.

Sasol appointed an external service provider to undertake a Noise

Survey, report dated 31 July 2017. The noise survey included

U38N. The report concluded that within the operational area 71%

of the normalised 8 hour noise rating levels in the areas measured

were equal to or above the statutory noise rating limit of 85dbA.

The plant (U38N) is a designated noise zone. The report notes that

the current practice of issuing hearing protective devices (HPDs)

currently issued to employees is deemed adequate protection in

most zones.

Evidence:


EMP Final_505119_2016-11-01;

— SEC-116-2017-

CM(NOISE)(Chemical_Work_Up_West,_Production,_Units_

037,_038,_038N,_073).

Signage at the plant indicating the use of hearing protection.

None.


WSP May 2019

Page 44

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

SCOPE OF AUTHORISATION 10 3 0 7

APPEAL OF AUTHORISATION 2 2 0 0

MANAGEMENT AND MONITORING 5 3 0 2

COMMISSIONING AND OPERATING 14 12 0 2

GENERAL 5 2 0 3

Total Count 36 22 0 14

Total Percentage 61% 0% 39%

Percentage Compliance with Applicable Conditions 100%

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

02468

10121416

Scope ofAuthorisation

Appeal ofAuthorisation

Management andMonitoring

Commissioningand Operating

General

Sectional Count Contribution

C

NC

N/A


WSP May 2019

Page 45

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

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

22

0

14

Total Compliance

C

NC

N/A

0102030405060708090

100

Scope ofAuthorisation

Appeal ofAuthorisation

Management andMonitoring

Commissioningand Operating

General

Sectional Percentage Contribution

C

NC

N/A


WSP May 2019

Page 46

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

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 EMP conditions are as listed in Table 5

below.

Table 5: Summary of EMP Compliance Audit Findings

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

GENERAL 50 45 0 5

Total Count 50 45 0 5

Total Percentage 100% 0% 10%

Percentage Compliance with Applicable Conditions 100%

61%

0%

39%

Total Percentage Compliance

C

NC

N/A


WSP May 2019

Page 47

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

42434445464748495051

General

Sectional Count Contribution

C

NC

N/A

45

05

Total Compliance

C

NC

N/A


WSP May 2019

Page 48

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 EMP 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;

84

86

88

90

92

94

96

98

100

General

Sectional Percentage Contribution

C

NC

N/A

90%

0%10%

Total Percentage Compliance

C

NC

N/A


WSP May 2019

Page 49

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

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr; and

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

the EMPr.

The EMPr compliance audit has identified that the majority of the EMPr conditions remain applicable, and the

EMPr is considered effective.

The original EMPr document was designed pre-operation principally to also govern construction phase impacts,

and has been somewhat 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

(1/3/1/16/1- G-21)

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION … · 2019-11-12 · wsp environmental (pty) ltd....

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