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SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & SULPHUR
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
17.2.4.EV7 - CONSTRUCTION OF AN OIL BLENDING FACILITY
03 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT
17.2.4.EV7 - CONSTRUCTION OF AN OIL BLENDING FACILITY
SECUNDA SYNFUELS OPERATIONS - TAR,
PHENOSOLVAN & SULPHUR
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
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KNIGHTSBRIDGE, 33 SLOANE STREET
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Q U A L I T Y M A N A G E M E N T
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft for Review –
Compliance Audit
EA Ref: 17.2.4.EV7
Final – Compliance
Audit
EA Ref: 17.2.4.EV7
Date April 2019 June 2019
Prepared by Ziyaad Kadwa Ziyaad Kadwa
Signature -
Checked by Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 1 1
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 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
Tar, Phenosolvan & Sulphur Production
Senior Manager
July Mavuso
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Ziyaad Kadwa
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & SULPHUR
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TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Oil Blending Facility (Authorisation Number:
17.2.4.EV7) ................................................................ 1
2 AUDIT SCOPE ........................................... 3
3 AUDIT METHODOLOGY ........................... 4
3.1 Audit Checklist ........................................................ 4
3.2 Site Inspection ......................................................... 4
3.3 Documentation Considered ................................... 4
3.4 Audit Compliance Assessment .............................. 5
3.5 Audit Team ............................................................... 5
3.6 Assumptions and Limitations ................................ 6
4 AUDIT FINDINGS ...................................... 7
5 SUMMARY OF THE AUDIT FINDINGS ... 15
5.1 Environmental Authorisation ............................... 15
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7
TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 15
FIGURES
FIGURE 1: SSO – OIL BLENDING FACILITY (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 16
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 16
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 17
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 17
APPENDICES
A ENVIRONMENTAL AUTHORISATION (17.2.4.EV7)
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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: 17.2.4.EV7 issued on 06 December 2002) for the period
December 2014 to February 2019.
1.2 OIL BLENDING FACILITY (AUTHORISATION NUMBER:
17.2.4.EV7)
An EA was issued to Sasol by the Mpumalanga Department of Agriculture, Conservation and Environment,
Southern Highveld Region Environmental Management; for the construction of an oil blending facility that
enables processing, blending and loading of oil products at Sasol Carbo-Tar.
The project was aimed at upgrading potential fuel oil by blending it with a higher-grade fuel oil to a final
composition of flash point, density and viscosity desired by the market.
The oil blending facility is comprised of the following installations:
— Four oil-blending tanks with agitators steam coils and attachments;
— Four oil pumps and motors;
— Storage of fuel oil products;
— Loading of fuel oil products into road tanker for transportation to the customers; and,
— Infra structural support from Sasol Carbo Tar.
Figure 1 provides an overview of the location of the facility.
The EA was issued on 06 December 2002, and it has been confirmed that the construction phase was completed
prior to December 2014 (i.e. outside the audit period).
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Figure 1: SSO – Oil Blending Facility (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 EA;
— Identify and assess any new impacts and risks that result from undertaking the activity;
— Make recommendations in order to achieve compliance in terms of the EA; and,
— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically:
— “Records relating to the compliance/non-compliance with the conditions of the authorization must be
kept in good order. Such records must be made available to this Department within seven (7) working
days from the date of the written request by the Department for such records”.
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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents
were utilised as a template during the compliance audit process. This methodology ensures that the compliance
audit was conducted in a systematic and independent manner that was documented and objectively evaluated to
determine compliance to the EA conditions.
The audit process comprised the following:
— Confirmation of the audit checklist;
— Site inspection (12 March 2019);
— Review of documentation relevant to the conditions of the EA (e.g. records, permits/certificates/maintenance
logs/monitoring results/previous reports etc.); and
— Compilation of an audit report.
3.1 AUDIT CHECKLIST
WSP compiled an audit checklist to assist with the EA compliance audit (Section 4).
3.2 SITE INSPECTION
Ziyaad Kadwa conducted the site inspection on 12 March 2019. The findings and observations of the site visit
are recorded and summarised in Section 4 with evidence included in Table 2. Key personnel interviewed
included:
— Piet Kleynhans (Area Manager; TPS Production: Carbo Tar).
— Collin Jaynarain (Area Manager; Gas Liquor Separation: Unit 213).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— Environmental Authorisation: 17.2.4EV7_2002-12-06;
— SSO DQS ISO 14001 2015;
— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;
— EA_EX Handover_SSO_TPS-CT-GLS-CTF;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Sasol SAWIS upload-2018_Jul-Sep;
— Waste register: Final- TPS Production Phenosolvan-2016-12-02;
— IWWMP SIC 2015 Final_2018-05-15;
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.pdf;
— Compliance_Risk_Secunda Complex;
— AEL Sasol Synfuels 0016-2018-F03 (2018);
— Environmental Complaints Register_2019-02-18;
— Fugitive Emission Monitoring Plan_2018-10-18 updated; 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 Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer, Piet Kleynhans, and Collin Jaynarain, 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.
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— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a
range of sectors. Jenny’s recent experience includes completion and management of several pan-European
and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and
providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in
environmental consultancies and with a developer, giving context to understanding the practicalities of
implementing recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or
in connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.
Similarly, any recommendations, statements or conclusions drawn from or based on this report must make
reference to this report. If this report is used as part of a main report, the report in its entirety must be included
as an appendix or separate section to the main report.
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1. GENERAL CONDITIONS
1.01 This authorisation refers only to the project specified above
and described in the Record of Decision. Other than the
above-specified project and the associated infrastructure,
separate application/s must be lodged for any other
development and/or activity at or near proposed
development, which is covered by section 21 and 22 of the
Environment Conservation Act, No. 73 of 1989 Act and
Government Notice R1182 and R1183 of 5 September 1997.
N/A Noted. The activity remains as specified and no further alterations
or applications have been made.
None.
1.02 Authorization is only granted in terms of Section 22 (3) of
the Environmental Conservation Act, 1989 (Act 73 of 1989)
and does not exempt the holder from compliance with any
other relevant authorities.
N/A Noted. The Sasol Complex operates with a dedicated
environmental and legal team, and therefore ensures that they
comply with applicable legislation.
In addition, site is operated under ISO14001:2015, which requires
the compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review, which confirms
conformance with requirements to determine compliance
obligations, and how these apply to the organisation.
Evidence:
— SSO DQS ISO 14001 2015; and,
— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.
None.
1.03 No development may take place on the area of concern
without the necessary permits/approvals and/or service
and/or lease agreements, where it is relevant, from or
between the following institutions:
C The Sasol Complex operates with a dedicated environmental and
legal teams, and therefore ensures that they comply with applicable
legislation.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1.3.1 DWAF
1.3.2 CAPCO
1.3.3 Goven Mbeki Municipality
Sasol is in possession of an AEL (issued per business unit) and has
an updated Integrated Water and Waste Management Plan
(IWWMP) (updated 2018) that applies to the whole complex.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15; and,
— AEL Sasol Synfuels 0016-2018-F03 (2018).
1.04 This Department may change, add or amend any of the
conditions in this authorization if, in the opinion of the
Department, it is environmentally justified.
N/A No changes or amendments have been communicated to Sasol by
the Department since issue of the EA.
None.
1.05 A copy of this authorization shall be available at Sasol
Carbo Tar Secunda at all times and all staff, contractors,
contractors and sub-contractors shall be acquainted or made
to be acquainted with the content of this authorization.
C Sasol’s environmental team have soft copies of the EA and
where/when necessary, communicate any specific details or
requirements to the relevant business units.
Additionally, copies are maintained at the SHE: Environment
department and on SAP EC and SharePoint. Any specific
requirements are communicated during SHE induction training.
Sasol provided the auditor with the evidence that the responsible
person, Joretha Klaassee, has been made aware of the EA on 19
September 2016.
Evidence:
— EA_EX Handover_SSO_TPS-CT-GLS-CTF.
None.
1.06 The contents of this authorization should be made known to
all interested and affected parties within 5 days of the issuing
of the authorization.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
2. ESTABLISHMENT OF THE ENTERPRISE
2.01 This authorization is repealed if the proposed oil blending
facility and associated infrastructure has not taken place
within two (2) years from the date of this authorization.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3. CONSTRUCTION & OPERATION
3.01 If any changes need to be made to the development and/or
associated infrastructure, this Department must be informed
thirty (30) days in advance to decide whether the changes
need authorization.
N/A The activity remains as specified and no further alterations or
applications have been made.
None.
3.02 Upon completion of the construction of oil blending facility,
all excess construction material should be disposed of in a
registered landfill site.
N/A This condition is considered outside of the audit period
(construction pre-2014). It is therefore considered not applicable.
None.
4. AIR POLLUTION
4.01 Air pollution should be handled as indicated by relevant
authorities. C Sasol has a valid Atmospheric Emission Licence (AEL) that was
issued by the Gert Sibande District Municipality. The AEL
(reference: 0016/2014/F01) is valid to 31 March 2020.
It is noted that the oil blending facility does not have stacks,
therefore no point source emissions monitoring is required. A
fugitive emissions plan provided by Sasol identifies storage tanks
as a potential source of fugitive emissions, and mitigation
measures form part of the monitoring plan.
According to the Environmental Team, Sasol works closely with
the local authority and operates units in line with the AEL and
minimum legal emission requirements.
Evidence:
— AEL Sasol Synfuels 0016-2015-F02 (2017);
— Fugitive Emission Monitoring Plan_2018-10-18 updated.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
5. WATER POLLUTION
5.01 It is the responsibility of the applicant and the relevant
contractor on site to prevent any pollution of the surface as
well as groundwater.
C Surface water is managed at the site; the operational areas are
within hard surfaced and bunded areas that drain to an enclosed
system that pumps the water for treatment. This was verified by
the auditor during the site walkover.
Sump – Part of the water Management System
Surface water monitoring is done on a weekly basis as well as real
time for the various Receiving Environment Surface Monitoring
(RESMs).
Ground water monitoring is conducted biannually and quarterly.
The is no groundwater monitoring specific to the oil blending
facility, however there are 6 active boreholes located within the
Primary area which are utilised for monitoring. The auditor note a
number of exceedances in the November 2017 sampling run,
however these exceedances cannot be directly attributed to the oil
blending facility.
The latest IWWMP as well as surface and ground water
monitoring results were provided to the auditor as evidence. The
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
nearest surface water quality monitoring locations (RESM-6 and
RESM-7) showed results within limits.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15; and,
— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-
31.pdf.
5.02 In case of non-compliance with Section 19 of the National
Water Act, 1998 (Act 36 of 1998), the applicant will be held
responsible to remedy the effects of pollution.
N/A Statement noted by Sasol. None.
6. WASTE
6.01 All waste generated during the construction and/or operation
of the oil blending facility shall be stored, handled and
disposed of in a registered landfill site.
C The site operates in accordance to Sasol’s Waste Management
Procedure. The operation does not produce any waste during
normal operating conditions.
Sasol makes use of a SAP Sustainability Performance
Management Module (SUPM) as a database for tracking waste
volumes that are managed on and off site.
Sasol further reports the on-site waste management data into the
South African Waste Information System (SAWIS), on a quarterly
basis. The off-site management of waste is reported into SAWIS
by the accredited Waste Management Service Providers on a
quarterly basis.
The waste register for TPS was viewed which indicates all waste
from the wider facility is disposed of to approved waste facilities.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Sasol SAWIS upload-2018_Jul-Sep; and,
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Waste register: Final- TPS Production Phenosolvan-2016-12-
02.
7. RISK ASSESSMENT
7.01 Risk assessment should be handled as indicated by the
relevant authorities. C Sasol has a Governance SHE Risk and Assurance department that
assesses environmental risks and drives implementation per
business unit.
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.
All risk documentation is saved on the Sasol IMS; a folder
containing the risk assessments undertaken for TPS was shown to
the auditor in a screenshot of the IMS system folders.
Evidence:
— Compliance_Risk_Secunda Complex.
None.
7.02 Fire extinguishing equipment should be available at the oil
blending facility at all times. C Fire extinguishing equipment was inspected during the site
walkover and noted to be within service dates.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Firefighting Equipment at the Oil Blending Facility
8. MONITORING
8.01 Monitoring should be done as indicated by the relevant
authorities. C The Sasol Complex operates with a dedicated environmental and
legal teams, and therefore ensures that they comply with applicable
legislation.
Sasol is in possession of an AEL (issued per business unit) and has
an updated Integrated Water and Waste Management Plan
(IWWMP) (updated 2018) that applies to the whole complex. The
monitoring systems and campaigns run were shown to the auditor
and noted to be aligned with the requirements of the AEL and
IWWMP.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15; and,
— AEL Sasol Synfuels 0016-2018-F03 (2018).
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
9. REPORTING
9.01 Records relating to the compliance/non-compliance with the
conditions of the authorization must be kept in good order.
Such records must be made available to this Department
within seven (7) working days from the date of the written
request by the Department for such records.
N/A This audit represents the first required audit for this EA. Prior to
the introduction of the 7 April 2017 amendment to the
Environmental Impact Assessment (EIA) regulations, no audit
against this EA was required.
None.
9.02 Non-compliance with, or any deviations from the conditions
as set out in the Authorisation, is regarded as an offence and,
after reasonable provision has been made for remedial
action, will be dealt with in terms of section 29, 30 and 31A
of the Act.
N/A Statement noted by Sasol. None.
9.03 Any complaint regarding the said development must be
brought to the attention of this office within 24 hours after
receiving the complaint.
N/A The complaints register was checked and no complaints related
specifically to the oil blending facility were recorded for this audit
period.
Evidence:
— Environmental Complaints Register_2019-02-18.
None.
9.04 A complaints register must be kept up to date for inspection
by members of this Department. C All environmental complaints received from interested and
affected parties, both internal and external to the organisation, are
recorded in a complaints register that is maintained by Sasol’s
Environmental Department. Complaints are investigated and
reported in line with the procedure (SGR-SHE-000022)) and as per
legal requirements. Environmental complaints contact details are
communicated to internal and external stakeholders.
The complaints register (FY 2014-2019) was checked and no
complaints related to the oil blending facility were recorded for
this audit period.
Evidence:
— Environmental Complaints Register_2019-02-18.
None.
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL AUTHORISATION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the EA conditions are as listed in Table 3
below.
Table 3: Summary of EA Compliance Audit Findings
SECTION OF THE EA NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 6 2 0 4
ESTABLISHMENT OF THE ENTERPRISE 1 0 0 1
CONSTRUCTION & OPERATION 2 0 0 2
AIR POLLUTION 1 1 0 0
WATER POLLUTION 2 1 0 1
WASTE MANAGEMENT 1 1 0 0
RISK MANAGEMENT 2 2 0 0
MONITORING 1 1 0 0
REPORTING 4 1 0 3
Total Count 20 9 0 11
Total Percentage - 45% 0% 55%
Percentage Compliance with Applicable Conditions 100%
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & SULPHUR
WSP June 2019
Page 16
Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents
the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the EA conditions per Section
Figure 3: Overall count findings on compliance to the EA conditions
0
1
2
3
4
5
6
7
Sectional Count Contribution
C
NC
N/A
9
0
11
Total Compliance
C
NC
N/A
ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS - TAR, PHENOSOLVAN & SULPHUR
WSP June 2019
Page 17
Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total
percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the EA conditions per Section
Figure 5: Overall percentage findings on compliance to the EA conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
45%
0%
55%
Total Percentage Compliance
C
NC
N/A
APPENDIX
A ENVIRONMENTAL AUTHORISATION
(17.2.4.EV7)