SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2 …...May 22, 2019 · PP1 and PP2 were constructed in...

SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17/2/2/1(J) GS-01 - C3 STABILISATION PROJECT

22 MAY 2019 CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17/2/2/1(J) GS-01 - C3 STABILISATION PROJECT

SASOL CHEMICALS OPERATIONS:

POLYPROPYLENE 2

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:

17/2/2/1(j) GS-01

Draft v2 for Review –

Compliance Audit

EA Ref:

17/2/2/1(j) GS-01

Final – Compliance

Audit

EA Ref:

17/2/2/1(j) GS-01

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 007 007 007

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

S I G N A T U R E S

PREPARED BY

-

Bronwyn Fisher

Environmental Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

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

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Polypropylene Production Senior

Manager

Eric Munyangane

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2

WSP May 2019

TABLE OF CONTENTS

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

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

1.2 C3 Stabilisation Project (Authorisation Number:

17/2/2/1(j) GS- 01) .................................................... 1

2 AUDIT SCOPE ........................................... 4

3 AUDIT METHODOLOGY ........................... 5

3.1 Audit Checklist ........................................................ 5

3.2 Site Inspection ......................................................... 5

3.3 Documentation Considered ................................... 5

3.4 Audit Compliance Assessment .............................. 6

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

3.6 Assumptions and Limitations ................................ 7

4 AUDIT FINDINGS ...................................... 8

5 SUMMARY OF THE AUDIT FINDINGS ... 21

5.1 Environmental Authorisation ............................... 21


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 6

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

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 21

FIGURES

FIGURE 1: THE LOCATION OF THE C3 STABILISATION PROJECT (RED BLOCK) (SOURCE: GOOGLE EARTH, 2018) ............................... 2

FIGURE 2: PP1 AND PP2 HIGH-LEVEL PROCESS OVERVIEW ................. 3

FIGURE 4: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 22

FIGURE 5: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 22

FIGURE 6: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 23

FIGURE 7: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 23

APPENDICES

A ENVIRONMENTAL AUTHORISATION (17/2/2/1 (J) GS-

01)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

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

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

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

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

Environmental Authorisation (EA) (Reference number: 14/2/2/1(j) GS- 01 issued on 11 March 2011) for the

period December 2014 to February 2019.

1.2 C3 STABILISATION PROJECT (AUTHORISATION

NUMBER: 17/2/2/1(J) GS- 01)

The C3 Stabilisation project involved the construction and subsequent operation of a propylene feed stabilisation

facility. The project involved the installation of five (5) large pressure vessels, measuring approximately 60 metres

in length and six metres in diameter. The aim of the C3 stabilisation plant is to keep inventory for the Polypropylene

1 (PP1) and Polypropylene 2 (PP2) in case of any failures within the PP1 and PP2 Units. Figure 1 provides an

overview of the location of the facility.

The EA was issued on 11 March 2011, and it has been confirmed that the construction phase was completed prior

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

PP1 and PP2 were constructed in 1989 and 2008 respectively. Figure 2 provides a brief overview of the processes

occurring at the PP1 and PP2 units from material feed to product distribution.


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Figure 1: The location of the C3 Stabilisation Project (red block) (Source: Google Earth, 2018)


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Figure 2: PP1 and PP2 high-level process overview


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

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

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

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

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

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

The objective of the audit was to:

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

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

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


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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (11 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Bronwyn Fisher conducted the site inspection on 11 March 2019. The findings and observations of the site visit

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

included:

— Brinton Walker (Technical Support Group (Polymers))

— Lucky Jiyane (Process Controller Grade 1)

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— EA_C3 Stabilisation_17.2.2.1(j) GS-01_2011-03-11

— Induction_Mod3_Environment;

— SCO DQS ISO 14001 2015;

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

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1- Polymers 2017 Rev 2;

— Sasol Environmental Emergency Procedure (SGR-SHE-000023 REV6);

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

— AEL Sasol Polymers 0021-2015-F02 (2015);

— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18;

— EA_EX Handover_SCO_Poly_Nitro_Poly;

— SCO_POL_Amendment_C3 Stabilization Project_1.3.1.16.4 G-38_2017-04-28; and,

— Various email correspondence.


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3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The auditor, Bronwyn Fisher, was hosted by Broni van der Meer, Brinton Walker and Lucky Jiyane 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 (EIA’s) and Basic Assessments. She has experience in developing Environmental

Management Programmes (EMPr’s), 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


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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

SCOPE OF AUTHORISATION

3.01 Authorisation of the activity is subject to the conditions

contained in this authorisation, which form part of the

Environmental Authorisation and are 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 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.

C All visitors and contractors entering the Sasol Complex are

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

through the SHE regional learning and development academy, and

records maintained by Sasol. The auditor was provided with a copy

of the induction training, specifically Module 3, which covers the

environmental aspects and management of the site. Sasol have

advised the auditor that the Conditions of the EA form part of any

contract for the maintenance of the plant.

Evidence:

— Induction_Mod3_Environment

None.

3.03 The activity which is authorised may only be carried out at

the property indicated above. C The description of the location of the project is within Sasol

Secunda. Sasol is compliant with this location description.

The auditor undertook a desktop review of the location description

in Section 2 of the EA using Google Earth Pro, and it was noted

that the coordinates for the facility do not match the location of the

coordinates provided within the EA. The coordinates within the

EA do not fall within the Sasol Secunda Complex, but are

approximately 50 km north of the site. WSP notes that the co-

ordinates referenced within the EA for the buffer tank are correct,

and recognises that the co-ordinates for the facility are likely a

OFI:

Sasol should undertake an

EA amendment process to

amend the coordinates

within the EA to reflect the

true location of the facility.

Target completion:

Long term


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typographic error on behalf of the Department, and it is

recommended that the coordinates are updated.

Evidence:

Location of the activity as stated in the EA

The location of the coordinates contained within the EA.

3.04 Any changes to, or deviations from, the project description

set out in this 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 for the holder of the authorisation to apply for

further authorisation in terms of the regulations.

C In 2013 Sasol received an EA (Reference number: 17/2/3 GS- 172)

for the C3 Expansion Project. The expansion project constitutes a

change in the project description as it was an expansion to

accommodate the additional propylene being produced as a result

upstream process modifications. Due to the nature of the

expansion activities, a full Basic Assessment Process was followed

in order to obtain a new EA. Sasol therefore followed the

appropriate processes, satisfying this condition.

This EA is however not being assessed as part of this audit report

but rather as a separate project.

None.


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Evidence:

— EA_C3 Expansion_17.2.3 GS-172_ 2013_11_13

3.05 This activity must commence within a period of two (2)

years from the date of issue. If commencement of the

activity does not occur within that period, the authorisation

lapses and a new application for the activity to be

undertaken.

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

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

None.

3.06 The holder of this authorisation is responsible for

compliance with the provision 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 advised the auditor that they are aware of their

responsibility for compliance with the provision for Duty of Care

and Remediation of Environmental Damage.

None.

3.07 This 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 activity.

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.

APPEAL OF AUTHORISATION

3.08 The holder of the authorisation must notify every registered

interested and affected party, in writing and within seven N/A This condition is considered outside of the audit period


None.


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(12) calendar days, of receiving notice of the Department's

decision to authorise the activity.

3.09 The notification referred to above must-

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

b) Inform the interested and affected party of the appeal

procedure provided for in Chapter 7 of the regulations; and

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

authorisation and reasons for the decision will be furnished

on request.



None.

MANAGEMENT AND MONITORING OF ACTIVITY

3.10 The holder of the authorisation must submit a post-

construction compliance report to the Department within 90

days of completion of construction. The environmental

report must be compiled by an Environmental Control

Officer, and must indicate the date of the audit, the name of

the auditor and the outcome of the audit in terms of

compliance with the conditions of this authorisation.



None.

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

the proposed project during both construction and

operational phases.

N/A Noted. Sasol has advised the auditor that the Department has not

monitored or inspected the project during the operational phase.

None.

COMMISSIONING AND OPERATION OF THE ACTIVITY

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

Department that the activity will commence.

Commencement for the purposes of this condition includes

site clearing and preparation. The notice must include a date

on which it is anticipated that the activity will commence.



None.


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3.13 Effective erosion and dust control measures must be

implemented. C During the site walkover, the auditor observed that the entire site is

hardsurfaced and stormwater effectively managed onsite, therefore

erosion is not deemed to be an issue onsite.

Evidence:

Hardstanding across the site

None.

3.14 All excavation works must be carried out in accordance with

the requirements of the Occupational Health and Safety Act

(Act No. 85 of 1993).



None.

3.15 All sensitive areas within the boundaries of the site must be

protected. N/A There are no sensitive areas within the boundaries of the site. The

auditor notes that the site was transformed outside of the audit

period.

None.

3.16 Safety signage must be erected for the control of dangerous

equipment. C Safety signage was observed by the auditor to be erected at the

entrance to the facility. In addition, safety signage was erected

across the facility indicating the dangers, and highlighting the

relevant PPE required to be worn in that area.

Evidence:

None.


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Examples of the signage that has been erected around

the Polypropylene site.

3.17 Ablution facilities must be provided for the duration of the

construction and operation of the project. C Construction period:

Provision of ablution facilities during the construction phase is

considered not applicable, as this falls outside of the audit period

(pre-2014).

Operational period:

The facility has a permanent ablution facilities located within the

operational Control Building and other administration buildings

surrounding the site. No portable facilities are utilised at the site.

None.


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3.18 Storm water must be effectively controlled to avoid any

associated environmental damage. C 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 IWWMP has a detailed description of stormwater

management within the Polymers Plants. The auditor was able to

confirm that the description of the management of contaminated

run-off is implemented onsite. Stormwater Management is

managed as site-wide within the Secunda complex, rather than

being plant specific.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— SIC IWWMP Appendix 1- Polymers 2017 Rev 2

An example of a Stormwater drain on the Polypropylene

site.

None.


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The pellet separator.

The Check Basin and Polymers API dam.

3.19 The pollution of the adjacent areas due to improper storage

of construction material or any hazardous substances must be

prevented at all costs.

C All hazardous substances being stored onsite were observed to be

stored in tanks. The tanks are within bunded, hardsurfaced areas,

with dedicated sumps to collect any spills or releases of hazardous

substances.

None.


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3.20 Spillage kit must always be made available for clean-up of

spills and leaks. C Spill kits were observed across the facility. All spills are dealt with

in accordance with the Sasol Environmental Emergency Procedure

(SGR-SHE-000023 REV6).

Evidence:

— Sasol Environmental Emergency Procedure (SGR-SHE-

000023 REV6)

None.

3.21 All petroleum products must be kept in properly bounded

areas. N/A The C3 stabilisation plant does not require the storage of petroleum

products.

None.

3.22 All waste generated on site must be segregated, stored and

disposed of at a registered landfill site or as may be directed

by any other relevant authority. The handling, storage and

subsequent disposal of waste must strictly adhere to all the

relevant environmental precepts.

C Sasol advised the auditor that waste management is handled

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. It is

noted that very little waste is produced at the C3 Stabilisation

project. The majority of waste that is generated is by- products

which are sent downstream, or to the Sasol Refinery for

processing. The waste storage areas are well maintained on

hardsurfacing, signage and are lockable.

Evidence:

— Sasol Secunda Industrial Complex, Mpumalanga IWMP

2017- 2022 Rev_0

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09

None.

3.23 Used oil must be collected into drums and stored in a

bounded area. N/A Sasol confirmed with the auditor that no used oil is collected or

stored as part of the C3 Stabilisation Plant.

None.


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3.24 Public access to the site must be restricted. C The C3 Stabilisation Facility is located within the Sasol Secunda

Complex, specifically within the Polymers Unit. Access to the

Secunda is gained through two security check points, which is a

security controlled access point. All visitors to the site have to

report to Charlie 1 prior to accessing the site. Access to the

Polymers unit is controlled by security. Authorised personnel have

to use tags to open the booms and all visitors have to sign in with

security.

None.

3.25 The relevant atmospheric emission license must be obtained

prior to commencement of the project. C This condition, so far as it related to pre-commencement, is

considered outside of the audit period (construction pre-2014).

Sasol received an AEL (Reference number: Polymers

0021/2015/F02, dated March 2015 and valid for five years) for the

Sasol Polymers Plant, which includes the C3 Stabilisation project.

Evidence:

— AEL Sasol Polymers 0021-2015-F02 (2015)

None.

3.26 A sump must be installed around the buffer tank and

propylene storage tanks to contain any spillage that may

occur.

NC Sasol have confirmed that no sump has been installed around the

buffer tank as they state that “the design did not require it”. This is

however deemed non-complaint as it is a requirement of the EA.

It is recommended that Sasol undertake an amendment process to

motivate for the removal of this condition.

Sasol should undertake an

EA Amendment Process to

have this condition

removed.

Target completion:

Long term

3.27 Any complaints received from the public during the

construction and operation phases of the activity must be

attended to as soon as possible and addressed to the

satisfaction of all concerned.

C Sasol 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 and the Environmental department. Complaints

are investigated and reported in line with the Sasol Environmental

Complaints Procedure (SGR-SHE-000022 REV5) and as per legal

requirements.

None.


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Environmental complaints contact details are communicated to

internal and external stakeholders.

The auditor was provided with the complaints register and relevant

complaints procedure. No complaints had been lodged against the

C3 Stabilisation project. It is noted that the complaints register has

been compiled in accordance with the procedure, which ensures

that feedback is provided and proof of the feedback being issued.

Evidence:

— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18

SITE CLOSURE AND DECOMMISSIONING

3.28 Should the use of the facilities installed as part of this

authorisation ever cease or become redundant, the applicant

must undertake the required actions as prescribed by

legislation at the time and comply with all relevant legal

requirements administered by any relevant and competent

authority at that time.

N/A Noted. Sasol advised that there are no plans to make this site

redundant in the foreseeable future.

None.

GENERAL

3.29 A copy of this authorisation must be kept at the property

where the activity will be undertaken. The authorisation

must be produced to any authorised official of the

Department who requests to see it and 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 authorizations 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, Eric Munyangane

(Senior Manager of Polypropylene Production, Polymers and

Nitro) and Francois du Toit (legal appointee of Polymers and

Nitro), was made aware of the EA in September 2016.

Evidence:

None.


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— EA_EX Handover_SCO_Poly_Nitro_Poly

3.30 Where any of the applicant's 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 On the 28 April 2017 the Department issued an amendment to the

EA pertaining to the change in the Company’s name from Sasol

Synfuels (Pty) Ltd to Sasol South Africa (Pty) Ltd.

Evidence:

— SCO_POL_Amendment_C3 Stabilization Project_1.3.1.16.4

G-38_2017-04-28

None.

3.31 The holder of the authorisation must notify the Department,

in writing and within 24 (twenty-four) hours, if conditions of

this authorisation are not adhered to. Any notification in

terms of this condition must be accompanied by reasons for

the non-compliance.

NC No evidence has been provided to the auditor that the Department

has been informed of the non-compliance (Condition 3.26) noted

associated with this EA.

Going forwards, Sasol

should ensure that all non-

conformances are reported

within 24 hours.

Target completion:

Medium term

3.32 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.

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

Condition.

None.

3.33 National government, provincial government, local

authorities or committees appointed in terms of the

conditions of this 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.

N/A Noted. None.


WSP May 2019

Page 21

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

below.

Table 3: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 7 3 0 4

APPEAL OF AUTHORISATION 2 0 0 2

MANAGEMENT AND MONITORING OF ACTIVITY 2 0 0 2

COMMISSIONING AND OPERATION OF THE ACTIVITY 16 10 1 5

SITE CLOSURE AND DECOMMISSIONING 1 0 0 1

GENERAL 5 2 1 2

Total Count 33 15 2 16

Total Percentage 45% 6% 48%

Percentage Compliance with Applicable Conditions 88%


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Page 22

Figure 3 illustrates the number/count contribution of the findings of the EA per section while Figure 4 presents

the total proportion of compliance for the facility.

Figure 3: Number/Count contribution of findings made to the EA conditions per Section

Figure 4: Overall count findings on compliance to the EA conditions

02468

1012141618

Sectional Count Contribution

C

NC

N/A

15

2

16

Total Compliance

C

NC

N/A


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Page 23

Figure 5 illustrates the percentage contribution of the findings of the EA conditions. Figure 6 presents the total

percentage compliance for the facility.

Figure 5: Percentage contribution of findings made to the EA conditions per Section

Figure 6: Overall percentage findings on compliance to the EA conditions

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

45%

6%

48%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17/2/2/1 (J) GS-01)

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