SASOL ENERGY SECUNDA TANKFARM ENVIRONMENTAL … · SASOL ENERGY SECUNDA TANKFARM WSP April 2019...

SASOL ENERGY SECUNDA TANKFARM

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.4.GS10 - INSTALLATION OF CONTINGENCY FLARES

03 APRIL 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.4.GS10 - INSTALLATION OF CONTINGENCY FLARES

SASOL ENERGY SECUNDA TANKFARM

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: APRIL 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

Exemption Ref:

17.2.4.GS10

Final – Compliance

Audit

Exemption Ref:

17.2.4.GS10

Date March 2019 April 2019

Prepared by Ziyaad Kadwa and

Bronwyn Fisher

Ziyaad Kadwa

Signature

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 018 018

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

Ziyaad Kadwa

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 Exemption.

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

Tank Farm Production Senior Manager Khutso Mohaleamalla

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

Consultant Bronwyn Fisher

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL ENERGY SECUNDA TANKFARM

WSP April 2019

TABLE OF CONTENTS

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

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

1.2 Installation of Temporary Contingency Flares for

Project Turbo (SCC) in the Primary Area

(Exemption Number: 17.2.4.GS10) ........................ 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 .............................. 4

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 11

5.1 Environmental Exemption .................................... 11


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 8

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 11

FIGURES

FIGURE 1: SEST – CONTINGENCY FLARE (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 11

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 12

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 12

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ............................ ..13

APPENDICES

A ENVIRONMENTAL EXEMPTION (17.2.4.GS10)


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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

Exemption (Reference number: 17.2.4.GS10 issued on 24 June 2005) for the period December 2014 to February

2019.

1.2 INSTALLATION OF TEMPORARY CONTINGENCY

FLARES FOR PROJECT TURBO (SCC) IN THE

PRIMARY AREA (EXEMPTION NUMBER: 17.2.4.GS10)

An application for exemption from requiring a full Environmental Impact Assessment was submitted by Sasol to

the Mpumalanga Department of Agriculture and Land Administration (MDALA) on 07 April 2005; for the

installation of temporary contingency flares for Project Turbo (SCC) in the primary area.

The exemption was granted by the MDALA on 24 June 2005, and included eight (8) commitments which Sasol

are required to comply with.

Figure 1 provides the location of the flare within Sasol Secunda Primary area.


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Figure 1: SEST – Contingency Flare (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

— 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 Exemption.


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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 Exemption 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 Exemption (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 Exemption 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:

— Fanie van der Westhuizen (Process Engineer II).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— AEL Sasol Oil 0019-2015-F02 (2015);

— Environment Impact register_ New FY19_2019-02-18;

— Environmental Complaints Register_2019-02-18;

— 3_EX_APPA2003Cert A1972.27_Valid2005-02-04_2003-08-05;

— 3_EX_APPA2005Cert A1972.27_Valid 2006-11-30_2005-09-19;

— 6_EX_SCCContingencyFlare_APPA app_REF1019_2005-08-11;

— 7_EX_Scope_Current Flare Site;

— 7_EX_Scope_Flare Ground Plan;

— 17.2.4.GS10_2005-04-07;

— 17.2.4.GS10_2005-06-24; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the Exemption.

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.


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It should be noted that some of the Exemption 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 Exemption. 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 Consultant, Bronwyn Fisher, was hosted by Broni van der Meer and Fanie van der Westhuizen, 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: Ziyaad Kadwa

Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal

Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the

Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it

part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural

Development for 3 years. He is currently completing his BSc Honours in Environmental Management part

time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a

number of high profile clients in various industries. He has three years of auditing experience, and has

successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,

Impala Platinum and NPC (InterCement). He has also done environmental management programme audits

for BRPM and for various infrastructure projects as part of environmental control officer duties.

— 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


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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.


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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 Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1 The flaring of material will happen inside the Secunda

primary area, Ptns of the farmsGoedehoop 290 IS,

Twistdraai 285 IS andMiddelbult 284 IS, highveld ridge

District.

C The location of the activity has not been changed or altered, and is

occurring on the property as described. The location was verified

during the site visit.

None.

2 Flaring might not happen at all, however it is an option that

must be available when needed. N/A Statement noted by Sasol. None.

3 The flare could be temporarily utilised for a year. C After the initial year, the flare was included in an extension of the

APPA permit. The flare was then included in a NEMAQA

application and was included as part of the license issued for Sasol

Oil (0019/2015/F02).

Evidence:

— AEL Sasol Oil 0019-2015-F02 (2015).

None.

4 Other options were considered i.e. The two existing flares on

the Western side of the factory (Pit flare with capacity of

10m3/h and Sea Dragon Flare with capacity of 20m3/h)

which made the option of utilizing the Eastern site to be a

more viable option as it is big enough to cater for the 40m3/h

of SCC material that could be flared.

N/A Statement noted by Sasol. None.

5 There should not be any explosion issues. C No explosion issues have been reported since the commissioning

of the flare. An environmental impact register is maintained by

Sasol’s Environmental Department. All incidents are investigated

None.


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and reported in line with the procedure (SGR-SHE-000023) and as

per legal requirements.

The environmental impact register was checked for the 2017, 2018

and 2019 periods, and no incidents related to this specific flare

were recorded for this audit period.

Environmental Risk Assessments are completed every five years

throughout the complex, in order to identify and mitigate any

potential explosion risk.

Evidence:

— Environment Impact register_ New FY19_2019-02-18; and,

— Risk Assessments (SGI-SHE-000014).

6 Flares will be totally smokeless. C As per the documentation submitted with the original APPA

application, a Schlumberger flare is installed which achieves

smokeless flaring with crude oil.

In addition, no complaints have been logged on the complaints

register for the audit period regarding smoke from this flare.

Evidence:

— 8_EX_SCCContingencyFlare_APPA app_REF1019_2005-

08-11; and,

— Environmental Complaints Register_2019-02-18.

None.

7 An internal Scoping Exercise has been undertaken which

has identified and addressed all issues of soil and water

pollution that the project might have.

N/A Statement noted by Sasol. None.

8 You are further required to lodge an application with

CAPCO for a Flaring Permit. C An application to CAPCO was made on 16 August 2005.

Evidence:

— Application for the Registration of a Temporary Contingency

Flare for Project Turbo (SCC) Plant in Terms of the

None.


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Atmospheric Pollution Prevention Act (Act 45 of 1965)

(August 2005).


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITIONS 8 5 0 3

Total Count 8 5 0 3

Total Percentage 63% 0% 38%

Percentage Compliance with Applicable Conditions 100%

Figure 2 illustrates the number/count contribution of the findings of the Exemption Compliance Audit per

section while Figure 3 presents the total proportion of compliance for the facility.

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


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

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

the total percentage compliance for the facility.

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


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

APPENDIX

A ENVIRONMENTAL EXEMPTION

(17.2.4.GS10)

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