ENVIRONMENTAL AUTHORISATION AND ......2019/06/06 · The Synthol process produces reaction water as a by-product which contains volatile fatty acids (VFAs) as the major organic pollutant,

SASOL SYNFUELS OPERATIONS: WATER AND ASH

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PROGRAMME COMPLIANCE AUDIT REPORT 17/2/2/1(E) MP-04 - WATER RECOVERY GROWTH

06 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PROGRAMME COMPLIANCE AUDIT REPORT

17/2/2/1(E) MP-04 - WATER RECOVERY GROWTH

SASOL SYNFUELS OPERATIONS: WATER

AND ASH

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 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(e)

MP-04

Final – Compliance

Audit

EA Ref: 17/2/2/1(e)

MP-04

Date April 2019 June 2019

Prepared by Tutayi Chifadza Tutayi Chifadza

Signature

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 010 010

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

REPORTS\010_SSO_WA_EA_17.2.2.1(e) MP-04\01 Draft report

S I G N A T U R E S

PREPARED BY

Tutayi Chifadza

Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

SASOL

SHE Specialist: Environment Broni van der Meer

Water and Ash Production Senior

Manager, Secunda Synfuels Operations

Rakesh Durjan

WSP

Associate Jenny Cope

Lead Auditor Ashlea Strong

Consultant Tutayi Chifadza

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PROGRAMME COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL SYNFUELS OPERATIONS: WATER AND ASH

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Water Recovery Growth Project (Authorisation

Number: 17/2/2/1(E) MP-04) .................................... 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 ... 48

5.1 Environmental Authorisation ............................... 48

5.2 Environmental Management Plan ........................ 51


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TABLES

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

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

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 19

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 48

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 51

FIGURES

FIGURE 1-1: WRG PROCESS FLOW ................ 1 FIGURE 1-2: WATER RECOVERY GROWTH

PLANT (SOURCE: GOOGLE EARTH, 2018) ............................... 3

FIGURE 5-1: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 49

FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 49

FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 50

FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 50

FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 52

FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 52

FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 53

FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 53


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APPENDICES

A ENVIRONMENTAL AUTHORISATION (17/2/2/1(E) MP-

04)


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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: 17/2/2/1(e) MP-04 issued on 16 September 2008) as well

as the associated Environmental Management Plan (dated: August 2008) for the period December 2014 to

February 2019.

1.2 WATER RECOVERY GROWTH PROJECT

(AUTHORISATION NUMBER: 17/2/2/1(E) MP-04)

The Synthol process produces reaction water as a by-product which contains volatile fatty acids (VFAs) as the

major organic pollutant, with acetic acid being the major portion. The chemical oxygen demand (COD), which is

the measure of the amount of oxygen required to oxidise the hydrocarbons to carbon dioxide and water is used to

characterise the organic content. The COD level in the reaction water ranges between approximately 12 000 and

18 000 mg/l.

The Water Recovery Growth (WRG) Plant (Unit 352) was designed to operate at a constant average daily COD

load and is able to handle short term spikes resulting from variations in COD concentration. Consequently, Unit

352 is fed at a constant COD loading and the reaction water feed rate is adjusted either according to the average

daily COD analysis or the online Total Organic Carbon (TOC) measurement.

The major processing steps include:

— Anaerobic digestion by means of Anaerobic digesters (ADs);

— AD effluent upgrading by means of activated sludge Aerobic reactors;

— Solid / liquid separation by means of a settling.

The plant is not yet running at full capacity because it only came into operation in November 2014. The design

COD feed rate is 200.4 tons per day with the Organic Loading Rate (OLR) 12kg COD/m3/day. Currently the plant

operates at an OLR of 4kg COD/m3/day and it is expected to be on full load by December 2018. The process flow

described above is shown in Figure 1-1 below.

Figure 1-1: WRG Process Flow


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The reaction water received from the Synfuels operation is treated with a Hydraulic Retention Time (HRT) of 15-

20 minutes. The treated water is routed to Water Recovery from where it can be sent back to the factory for use

as utility water or stored in the Process Water dam system until such time that it is needed. The treated water is

also utilised for cooling water makeup, urea make-up and supply to the desludging compressor at WRG. The

sludge that is generated by the process is sent to the incinerators at Water Recovery.

All stormwater runoff from areas of the WRG plant where no pollution is expected drains directly to the

environment. The water is routed via a canal to the south of the WRG site from where it drains to the

Bossiespruit.

Runoff from contaminated areas drains to a sump, from where the water is pumped back into the process

circuit of WRG.

There is a risk for the sump which collects the runoff from the potentially contaminated areas of WRG to overflow

during high rainfall events resulting in the release of the potentially contaminated water to the environment. The

sump level is monitored regularly and maintained as low as possible to prevent potential overflows. Sampling is

also undertaken to monitor the quality of the water contained within the sump. These aspects have been captured

in the Standard Operating Procedure (SOP), which has been developed for the plant.

The WRG facility location on the Synfuels facility is indicated in Figure 1-2 below.


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Figure 1-2: Water Recovery Growth Plant (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, EMPr;

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

achieve the objectives and outcomes laid out in these documents;

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

— 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 (27 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Tutayi Chifadza conducted the site inspection on 27 March 2019. The findings and observations of the site visit

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

interviewed included:

— Brendan Govender (Area Manager: Water Recovery).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— EMP_17.2.2.1(e) MP-04_Water Recovery-Amend_2013-03-15;

— Environment Impact register_ New FY19_2019-02-18;

— Environment emergency procedure_SGR-SHE000023_rev6_2015-11;

— 3.21_EA_Emergency Procedure WRG;

— Waste Management Procedure for Sasol Secunda (SGR-SHE000017);

— Environmental Complaints Register (2008-2019);

— EA_EX Handover_SSO_WA-Process Water;

— EA_EX Handover_SSO_WA-Process Water_Amend VP

— 3.19_EA_SAS-579A WRG SOP rev 0 (3) July 2018;

— AEL Sasol Synfuels 0016-2018-F03 (2018);

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - WRG 2017 Rev 1;

— Phase 1_Contaminated Land Assessment_November_2015_Final 1.0;

— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of 2_2018-08-28;

— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-20;

— EA Name Change applications_Transmittal_2017-03-29_signed;

— SGI-SHE-000014 rev 6 - Minimum requirements for ERA_Published;

— Induction_Mod4_ProcessSafetyManagement;


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— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod7_Occupational;

— SSO_BSOHSAS18001_IQNet_2018-08-24;

— Site photos; 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.

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, Tutayi Chifadza, was hosted by Broni van der Meer and Brendan Govender 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: Tutayi Chifadza

Tutayi Chifadza has 5 years’ experience and is an Environmental Consultant for WSP at the Johannesburg,

Bryanston office in the Environmental Services division. He holds a Bachelor of Science (Honours), Applied

Science in Environmental Technology, and Bachelor of Science, Chemistry from the University of Pretoria.

Tutayi has experience in undertaking Water Use Licence (WUL) applications, Basic Assessments and


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Page 7

Environmental Impact Assessments as well as technical compliance audits including for Transnet and Sasol.

He conducted Water Use Licence audits for four sections at South 32 and its reporting. He is also responsible

for conducting WUL And Waste Management Licence audits.

— Lead Auditor and Quality Assurance: Ashlea Strong

Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature

Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental

Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic expertise

on a diverse range of projects in the environmental management field, including environmental scoping and

impact assessment studies, environmental management plans, waste and water management, as well as the

provision of environmental management solutions and mitigation measures. She has been involved in the

management of a number of large EIAs within South Africa and has environmental auditing and training

experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed in the audit

process.

— 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

SCOPE OF AUTHORISATION

3.1 Authorisation of the activity 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. None

3.2 The activity which is authorised may only be carried out at the

property indicated above. C The EA authorised the construction of the WRG facility at

coordinates 26°32’58”S, 29°08’40”E. these were verified during the

site visit and as shown below.

Evidence:

WRG location

None


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3.3 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 site personnel that work on the WRG project undergo Safety,

Health and Environment (SHE) induction to ensure that they are

familiar with the site’s SHE aspects and requirements. All of Sasol’s

training is done through the regional SHE learning and development

academy in order to help gain compliance.

There is no requirement within the licence to audit against it

regularly both internally and externally, as such, any audits other

than the post-construction audit are from a best practice perspective.

No non-compliances were observed over the course of this audit.

None

3.4 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 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 authorisation in terms

of the regulations.

C Following Sasol’s proposal to amend the EA, the Department

granted the amendment application in order to remove Section 7.7

of the EMPr (“Flaring only to be used during emergencies and start-

up conditions”) and allow for the continuous flaring on the site

based on the motivation provided by Sasol. The amendment was

granted on 15 March 2013 and the proof was available for review.

Evidence:

— EMP_17.2.2.1(e) MP-04_Water Recovery-Amend_2013-03-

15

None

3.5 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 environmental authorisation must be

made in order 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

3.6 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. None


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APPEAL OF AUTHORISATION

3.7 The holder of the authorisation must notify every registered

interested and affected party, in writing and within seven (7)

calendar days, of receiving of the Department’s decision to

authorise the activity.



None

3.8 The notification referred to in 3.7 must:

a) Specify the date on which the authorisation was issued; N/A This condition is considered outside of the audit period


None

b) Inform the interested and affected parties of the appeal

procedure provided for in Chapter 7 of the regulations;

and



None

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

the authorisation and reasons for the decision will be

furnished on request.



None

MANAGEMENT AND MONITORING OF THE ACTIVITY

3.9 Compile a monitoring programme to ensure conformance

with the conditions contained in this Environmental

Management Plan.

C The auditor was informed that all conditions of the EMPr are loaded

on the SAP system and tasks assigned as required in order to ensure

conformance with the conditions. Reports can then be loaded from

the system as and when required.

Evidence:

— EMP_17.2.2.1(e) MP-04_Water Recovery-Amend_2013-03-

15

None


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

proposed project during both construction and operational

phases.

C The auditor was informed that the Department conducts site visits

but no feedback has been provided following the visits. The

assumption is that since there are no findings during the site walks,

and therefore there is no need for the Department to make further

contact on the site.

Evidence:

— Personnel Communication

None

COMMISSIONING AND OPERATION OF THE ACTIVITY

3.11 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 preparation.

The notice must include a date on which it is anticipated that

the activity will commence.



None

3.12 Before construction commences, the applicant must assign the

activity to a full time Environmental Control Officer who will

ensure:



None

3.12.1 Strict compliance of the activity with the conditions of the

Environmental Authorisation as well as the measures

contained in the Environmental Management Plan.



For the operational phase, compliance with the EA and EMPr is

covered under Condition 3.3.

None

3.12.2 Ensure that the contractors on site are aware of their

requirements in terms of the requirements of the

environmental authorisation and the Environmental

Management Plan (EMP).

C All site personnel that work on the WRG undergo SHE induction to

ensure that they are familiar with the site’s SHE aspects and

requirements. All of Sasol’s training is completed through the

regional SHE learning and development academy. The induction

presentation was available for review. During induction, contractors

are made aware of the EMPr requirements for the specific site.

None


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3.12.3 Monitor compliance during construction and operation of the

activity; C Sasol has an environmental team that manages the site according to

the legislative requirements and ensure EA compliance. Due to the

vast number of operations on the Synfuels facility, there is no one

officer assigned to a particular site. The Sasol environmental team

works together to ensure compliance on the WRG facility.

Furthermore, the auditor was informed that all conditions of the

EMPr are loaded on the SAP system and tasks assigned as required

in order to ensure conformance with the conditions. Reports can

then be loaded from the system as and when required since there is

no strict auditing requirement against the EA conditions.

None

3.12.4 Keep record of all environmental audits; 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.

OFI:

This current Audit must be

kept on record as required.

Target Completion:

Short Term

3.12.5 Ensure implementation of contingency plans in the event of

unforeseen circumstances. C Sasol have an environment emergency procedure (SGR-

SHE000023) that covers different scenarios on the site as well as an

environmental incident procedure process flow that indicates steps

taken when an incident occurs. Furthermore, the

WRG has its own specific emergency procedure that was available

for review.

No incidents were noted regarding the facility when the incidents

register was reviewed that needed the site personnel to implement

contingency plans. An incident procedure is available for

implementation in the event of an incident. Furthermore, the


for review.

Evidence:

— Environment Impact register_ New FY19_2019-02-18

None


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— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11

— 3.21_EA_Emergency Procedure WRG

3.13 The construction area must be clearly demarcated on the site

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


None

3.14 Waste must be separated into different categories and be

placed in separate waste containers before disposal. C All waste on the site is managed according to the waste management

procedure (SGR-SHE000017) for the waste generated on the site

following a waste management hierarchy. Waste is disposed of at

registered landfill sites.

Waste was observed to be appropriately stored during the site walk.

Evidence:

— Waste Management Procedure for Sasol Secunda (SGR-

SHE000017)

None

3.15 All petroleum products must be kept in properly bunded areas.

The fuels must be stored at a designated storage facility

outside the construction site.



None

3.16 Rocks and other materials from the excavation process must

be disposed of in a manner that does not impact negatively on

aesthetic of the environment.



None

3.17 Adequate measures must be put in place to control surface

water flows across and around all construction sites. N/A This condition is considered outside of the audit period


None

3.18 The applicant must ensure that storm water leaving the

footprint of the proposed development is not contaminated by

any substance, whether liquid, solid, etc.

C The site is completely concreted, with stormwater channels that lead

to the out-sump. This water is then channelled back to the system to

be reworked. Furthermore, all the tanks with reagents used in the

process are bunded and contained to help prevent any flow of

contaminated stormwater to the surrounding environment. The

sumps which collect contaminated water are monitored for both the

None


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quality and level so as to prevent an overflow into the surrounding

environment.

Sasol monitors both surface and groundwater to ensure there is no

contamination. Surface water and the borehole monitoring points

are indicated in the IWWMP. Two of the monitoring boreholes

adjacent to this site (REGM-128 and REGM-129) with groundwater

considered to be within quality requirements, with no actions

required and no exceedances observed.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-

20

Concreted surface and bunded tanks

3.19 The flaring system to be utilised must ensure that there is no

flaring visible or audible to the surrounding communities. C Sasol uses enclosed or ground based flares rather than elevated

flares. The flares used reduce noise, luminosity and heat radiation.

Furthermore, the system used provides wind protection and

effective emission monitoring.

None


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The complaints register was reviewed and there were no complaints

regarding the flaring system related to this EA.

Evidence:

— Environmental Complaints Register (2008-2019)

3.20 The necessary air permit must be obtained prior to

commencement of this activity. C The sludge produced in the process is sent to the two incinerators on

the site. This was as confirmed in the SOP. The use of the site

biosludge incinerators is licensed in the AEL (under subcategory 8.1

- thermal treatment of general and hazardous waste), which was

provided for review.

Evidence:

— 3.19_EA_SAS-579A WRG SOP rev 0 (3) July 2018

— AEL Sasol Synfuels 0016-2018-F03 (2018)

None

3.21 An Emergency/ Contingency Plan must be developed before

commissioning of the activity. Such a plan must among others

address safety, fire hazards, etc.

C Sasol have an environment emergency procedure (SGR-





for review.

Evidence:

— Environmental emergency procedure (Rev 6): SGR-

SHE000023


None

3.22 The Applicant must implement appropriate measures to

reduce or prevent contamination of ground and surface water

as a result of spills of potentially dangerous substances.

C The site is completely concreted, with stormwater channels that lead






quality and level so as to prevent an overflow into the surrounding

environment.

None


WSP June 2019

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Evidence:

— IWWMP SIC 2015 Final_2018-05-15


20

3.23 The applicant must comply with Major Hazard Installation

Regulation (regulation 5(5) of the Occupation Health and

Safety Act (Act No. 85 of 1993).



None

3.24 All vehicles, equipment and machinery must be maintained in

good condition such that they do not leak oil and any other

petroleum products onto the soil.

C The site is mainly unmanned and operated from the control room.

Consequently, there is little to no traffic movement on the site for

the most part as the process is mainly automated. The site is

concreted and there were no signs of leaks observed during the site

walk therefore, indicating little to no risk of soil contamination.

Evidence:

None


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Impermeable surface

3.25 All waste (general and hazardous) generated during

construction of the plant must be disposed of at an appropriate

licensed waste disposal sites.



None

3.26 Any complaints received from the public during construction

and operational phases of the activity must be attended to as

soon as possible and addressed to the satisfaction of all

concerned.

C The complaints register was reviewed and there were no complaints

regarding the flaring system related to this EA. Sasol provides

feedback on all complaints as observed in the complaints register.

Evidence:


None


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GENERAL

3.27 A copy of this 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 and must be available for inspection by

any employee or agent of the holder of the authorisation who

works or undertakes work at the property.

C Sasol keeps all authorisations and permits at the SHE department on

the SAP system and on SharePoint and are available upon request.

All environmental aspects are shared to site personnel during

induction. Sasol provided the auditor with the evidence that the

responsible persons, Rakesh Durjan (Senior Manager of Process

Water Area) and Simon Baloyi (legal appointee of Water & Ash),

were made aware of the EA on in September / October 2016.

Evidence:

— EA_EX Handover_SSO_WA-Process Water;

— EA_EX Handover_SSO_WA-Process Water_Amend VP

None

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

the name of the responsible person, the physical or postal

address and / or telephonic details; the applicant must notify

the Department as soon as the new details become known to

the applicant.

C A name change application was lodged on 29 March 2017 from

Sasol Synfuels (Pty) ltd to Sasol South Africa (Pty) Limited. This

was captured in the amended EA issued in March 2016.

Evidence:

— EA Name Change applications_Transmittal_2017-03-

29_signed

None

3.29 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

C No non-compliances were observed over the course of this audit. None

3.30 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. None


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Table 3: Audit Findings – Environmental Management Plan


4 CONSTRUCTION PHASE

4.1 EMPLOYMENT, AWARENESS AND SKILLS DEVELOPMENT

Appointment of contractor, temporary labour

4.1.1 Local labour and contractors must be used wherever possible. N/A This condition is considered outside of the audit period


None

4.1.2 Basic skills development and capacity building must be

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


None

4.1.3 Sasol must ensure that this EMP forms part of any contractual

agreements with a Contractor(s) and sub-contractors for the

execution of the proposed project.



None

4.1.4 Sasol and the Contractor must comply with the relevant

provisions of the EMP, environmental authorisation, by-laws,

applicable environmental legislation and associated

regulations promulgated in terms of these laws.



None

4.1.5 Construction staff must be adequately educated by the Sasol

Technology EIA Specialist or the Project Manager as to the

provisions included in the EMP and general environmentally

friendly practice.



None


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4.2 SITE ESTABLISHMENT AND MANAGEMENT (CONSTRUCTION CAMP)

Site Establishment

4.2.1 The site selected for the construction camp should ensure

potential environmental impacts are kept to a minimum. N/A This condition is considered outside of the audit period


None

4.2.2 The construction area must be clearly demarcated on a site

plan, and all other areas must be considered no-go areas for

the construction personnel.



None

4.2.3 Only designated areas may be used for the storage of

construction material, topsoil, machinery, equipment and

establishment of site offices.



None

4.2.4 The following activities must be prohibited at site camp(s),

and by the construction staff in general: N/A This condition is considered outside of the audit period


None

4.2.4.1 The irresponsible use of welding equipment, oxy-acetylene

torches and other naked flames which could result in fires or

constitute a hazard.



None

4.2.4.2 Burning of any type of waste material. N/A This condition is considered outside of the audit period


None

4.2.4.3 The use of rivers, streams, dams or any watercourses/surface

water for washing or recreational purposes. N/A This condition is considered outside of the audit period


None

4.2.4.4 Entering areas outside of the demarcated construction area

without relevant permissions. N/A This condition is considered outside of the audit period


None


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Personal Protective Equipment (PPE)

4.2.5 No person is allowed to enter the site without Sasol Business

Unit (SBU) approved (SANS approved) PPE. N/A This condition is considered outside of the audit period


None

4.2.6 Strict non-compliance measures must be administered to any

employees not complying with the use of PPE. N/A This condition is considered outside of the audit period


None

4.2.7 The contractor must ensure that the company logo is displayed

and company personnel re easily identifiable. N/A This condition is considered outside of the audit period


None

4.2.8 PPE minimum requirement notice boards shall be placed at

the entrance to the construction site. N/A This condition is considered outside of the audit period


None

Generation and indiscriminate disposal of domestic waste

4.2.9 All construction waste will be placed in provided waste bins. N/A This condition is considered outside of the audit period


None

4.2.10 Waste will be separated into different types and placed into

separate waste containers. N/A This condition is considered outside of the audit period


None

4.2.11 The Contractor should ensure that sewerage waste is routed

accordingly and does not drain into the nearby stormwater

system.



None

Spillage of petroleum products

4.2.12 All diesel generators will be equipped with drip trays. N/A This condition is considered outside of the audit period


None


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4.2.13 All petroleum products will be kept in a properly bunded area. N/A This condition is considered outside of the audit period


None

4.2.14 Refuelling of machinery/vehicles will take place in a properly

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


None

4.2.15 Contaminated soil will be properly removed and sent to the

Waste Recycling Facility (WRF). N/A This condition is considered outside of the audit period


None

Sanitation

4.2.16 Use of any ablution facility other than those provided is

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


None

4.2.17 Contractor will be responsible for providing and maintaining

own toilet facilities. N/A This condition is considered outside of the audit period


None

4.3 SITE CLEARING

Erosion

4.3.1 Areas susceptible to erosion should be protected by installing

the necessary temporary and/or permanent drainage works as

soon as possible and by taking other measures necessary to

prevent surface water from being concentrated in streams and

from scouring slopes, banks or other areas.



None

4.3.2 Any runnels or erosion channels developed during the

construction period shall be backfilled and compacted, and the

areas restored to an acceptable condition.



None


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4.3.3 Blocking of stormwater drainage systems must be prevented

and stormwater must be managed to prevent soil erosion. N/A This condition is considered outside of the audit period


None

Existing Earth Dams (two)

4.3.7 Concrete slabs will be demolished and disposed off at a

regular disposal site approved by Sasol. N/A This condition is considered outside of the audit period


None

4.3.8 After demolition of the slabs, mass excavations (~3m) and

backfilling (ash/dolerite) shall take place over the entire plot

space to provide a terraced plot. It might be possible that some

piling of heavy equipment may occur.



None

4.4 PLANT CONSTRUCTION

Calibration of monitoring equipment

4.4.1 Calibration of equipment will be done as required. N/A This condition is considered outside of the audit period


None

Domestic waste

4.4.2 All construction waste to be disposed off in waste bins

provided. Waste will be separated into different types and

placed in separated waste containers.



None

Grinding






None


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Insulation material






None

Mixing of concrete


provided and disposed off according to the Sasol Waste

Management Procedure (Document still in draft format -

SGR-GEN-000002).



None

Other waste






None

Packaging material






None

Painting

4.4.8 Potential spillages:

— All paints will be kept in a well bunded area.

— Soil contaminated by paint will be removed and sent to

the WRF.



None


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4.4.9 Paint cans left on site:

— All construction waste to be disposed off in waste bins

provided.



None

Storage of cement/grease, oils, paints and chemicals

4.4.10 All products that have a potential of contaminating the soil

will be kept in a well protected/bunded area. N/A This condition is considered outside of the audit period


None

Welding






None

4.5 SITE PREPARATION ACTIVITIES

Removal of contaminated rainwater from foundations

4.5.1 All contaminated water will be disposed off into the correct

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


None

Use of electricity/diesel generators - Noise

4.5.2 All generators will comply to the noise limit of 85dB.



None


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Use of electricity/diesel generators - smoke

4.5.3 Electricity generators used by the Contractor should be in

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


None

Use of electricity/diesel generators - leaks

4.5.4 Electricity generators used by the contractor should be in good

working condition and not leak oil. N/A This condition is considered outside of the audit period


None

4.5.5 All generators will be furnished with drip trays. N/A This condition is considered outside of the audit period


None

4.5.6 In the instance of spillages, clean-up measures should be

executed in order to contain the pollution and remediation

should be carried out.



None

Use of construction vehicles/machinery – Borrow pits

4.5.7 Only licenced borrow pits may be used. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Spent engine oil

4.5.8 In a case of spillages, contaminated soil will be removed and

disposed off properly. N/A This condition is considered outside of the audit period


None

4.5.9 Clean-up measures must be in place when spillages occur. N/A This condition is considered outside of the audit period


None


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Use of construction vehicles/machinery – Fuel storage and refuelling leading to spillages

4.5.10 All fuels will be stored at a designated storage facility outside

the construction site and no refuelling will be allowed on site

unless done on a properly bunded area or using a drip tray.



None

Use of construction vehicles/machinery – Dust

4.5.11 Dust must be suppressed on access roads and construction

sites during dry periods by the regular application of water.

Water used for this purpose must be used in quantities that

will not result in the generation of run-off.



None

4.5.12 Dust dispersion from construction activities, unsurfaced

roads, spoil dumps and other construction locations will be

limited and suppressed to the maximum extent practical.



None

4.5.13 Spoil dumps will be positioned such that they are not

vulnerable to wind erosion. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Noise

4.5.14 All construction vehicles will comply to the noise limit of

85dB. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Excavated material not used for backfill left on site

4.5.15 Rock and other material from the excavation process will be

disposed of in a way that does not have a negative impact on

the aesthetics of the environment and that blends in with the

rehabilitation process.



None


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4.5.16 Any redundant excavated material will be disposed off at

Charlie 1 general waste site. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Contaminated excavated material not used for backfill left on site

4.5.17 Contaminated excavated material will be disposed of at the

WRF for treatment. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Building rubble left on site

4.5.18 Rock and other material from the excavation process will be

disposed of in a way that does not have a negative impact on

the aesthetics of the environment and that blends in with the

rehabilitation process.



None

4.5.19 Any redundant excavated material will be disposed off at

Charlie 1 general waste site. N/A This condition is considered outside of the audit period


None

Use of construction vehicles/machinery – Contaminated building rubble left on site

4.5.20 Contaminated building rubble will be disposed of at the WRF

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


None

Removing redundant/contaminated equipment and not disposed of correctly

4.5.21 Redundant equipment will be sent to the reclamation yard. N/A This condition is considered outside of the audit period


None

4.5.22 Contaminated equipment will be cleaned prior to being sent

to the reclamation yard. N/A This condition is considered outside of the audit period


None


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Backfill with dolerite/ash for foundation

4.5.23 Dolerite will be sourced from licenced sellers. N/A This condition is considered outside of the audit period


None

Backfill with dolerite/ash for foundation purposes & Ash heaps resulting in dust

4.5.24 Dust suppressing measures will be established. N/A This condition is considered outside of the audit period


None

4.6 HYDROLOGY

Stormwater management

4.6.1 Adequate measures will be put into place to control surface

water flows across and around all construction sites. N/A This condition is considered outside of the audit period


None

4.6.2 Ensure that no pollution enters surface water or has the

potential to pollute groundwater by ensuring that there is

containment of spillages and that there is an emergency plan

in place to deal with accidental spillage.



None

4.6.3 Ensure that no stormwater is discharged to the working areas

and further ensuring that the stormwater leaving the footprint

of the proposed development areas is not contaminated by any

substance, whether that substance is solid, liquid, vapour or

any combination thereof.



None

4.6.4 The quantity of uncontaminated stormwater entering cleared

areas will be minimised by appropriate site design and by

installation of control structures and drains which direct such



None


WSP June 2019

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flows away from cleared areas and slopes to stable (vegetated)

areas.

4.7 TRASNPORTATION OF EQUIPMENT BY ROAD/RAILWAYS/PIPELINES

Overloading capacity of existing infrastructure

4.7.1 Drivers will comply with Sasol Internal as well as the South

African Traffic rules. N/A This condition is considered outside of the audit period


None

Spillages

4.7.2 A Transport Risk Assessment will be conducted and

recommendations will be implemented. N/A This condition is considered outside of the audit period


None

5 PRE-COMMISSIONING PHASE

5.1 CLEANING OF EQUIPMENT

Chemicals used for cleaning/pickling/passivation

5.1.1 Ensure that the chemicals are disposed of at a permitted site. N/A This condition is considered outside of the audit period


None

5.1.2 Proper disposal methods should be used. Chemicals will be

disposed off by the responsible Contractor/s.



None


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Water used for cleaning of steam/condensate system

5.1.3 Water will be routed through to the proper sewer system. N/A This condition is considered outside of the audit period


None

Water used for cleaning/flushing of plant equipment



None

5.2 LOADING OF SLUDGE INTO THE REACTORS

Spillage of the sludge while loading

5.2.1 Loading must take placed on the paved area. N/A This condition is considered outside of the audit period


None

5.2.2 Contaminated soil will be sent to the WRF. N/A This condition is considered outside of the audit period


None

5.3 STORAGE OF CHEMICALS FOR CLEANING/PICKLING/PASSIVATION

Spillage of hazardous substance when storing

5.3.1 The Contractor will be responsible for safe storage of

chemicals and will compile and keep all the emergency

response plans and MSDSs.



None


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5.4 TESTING OF EQUIPMENT: HYDRAULIC TESTING

Management of used water



None

5.5 TRANSPORTATION OF CHEMICALS OF CLEANING/PICKLING/PASSIVATION

Spillage of hazardous substance when transporting

5.5.1 Contractor will be responsible for safe transportation of

chemicals and will compile and keep all the emergency

response plans and MSDSs.



None

5.6 WET RUN (CIRCULATION): WATER USED FOR CIRCULATION




None

6 START-UP AND SHUTDOWN PHASE

6.1 DRAINING OF VESSELS DURING SHUT DOWNS

Incorrect disposal of effluents

6.1.1 Drain to the correct sewers/sumps. C All WRG operations follow the issued SOP, which all responsible

personnel and contractors have access to. The effluent is drained to

None


WSP June 2019

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the correct sewers/sumps according to Section 5.6 (specifically step

1 of 5.6.1 of the SOP) when vessels are shut down. The SOP was

reviewed and indicated that the lines are flushed and drained to the

sewer and then the relevant sump as required.

Evidence:


6.2 FILLING UP OF VESSELS

Displacement of air/nitrogen etc.

6.2.1 The biogas will be routed to the flare. C All WRG operations follow the issued SOP, which all responsible

personnel and contractors have access to. The biogas is drained to

flare according to Section 5.6 (specifically step 5 of 5.6.17 of the

SOP) when vessels are shut down. The SOP was reviewed and

indicated that the biogas is routed to the flare as required.

Evidence:


None

6.3 FLARING

Flare

6.3.1 Flaring systems shall be designed such that there is no flaring

visible or audible to the surrounding communities and general

public, except for provable process or plant emergencies.

C Sasol uses enclosed or ground based flares rather than elevated

flares. The flares used reduce noise, luminosity and heat radiation.

Furthermore, the system used provides wind protection and

effective emission monitoring.

The complaints register was reviewed and there were no complaints

regarding the flaring system related to this EA.

Evidence:


None


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6.3.2 Ensure that Best Available Techniques (BAT) technical flare

design criteria are applied. N/A This condition is considered outside of the audit period


None

6.3.3 Eliminate / reduce / minimise the need to continuously

“destroy” flare gases through optimal: technology selection;

plant design and flare gas recovery.



None

6.4 FLUSHING, DRAINING AND DISPOSAL OF OILS

Oils not disposed of correctly

6.4.1 Oil will be removed by the contractor. C The driver collects all the oil collected in the sumps from the Waste

Recycling Facility (WRF) adjacent to the WRG plant who also

collects used oil from all other Sasol Secunda facilities including the

mining operations. All the oil is taken to the WRF before contractors

for recycling collect it.

None

6.5 PROCESSING OF FEED: OFF-SPEC MATERIAL

Management of off-spec material: Incorrect disposal of non-recyclable material

6.5.1 The off-spec reaction water will go to the current system.

C All WRG operations follow the issued SOP, which all responsible

personnel and contractors have access to. Off-spec water on the site

is taken to the current system to be treated so that it can then be re-

used as process water again.

Evidence:


None


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7 OPERATION AND MAINTENANCE PHASE

7.1 ADDITIONAL PERMANENT EMPLOYMENT

Employment and skills development

7.1.1 Local labour and contractors must be used wherever possible. C Sasol uses trained personnel and contractors for operation and

maintenance. All site personnel that work on the WRG undergo

SHE induction to ensure that they are familiar with the site’s SHE

aspects and requirements. All of Sasol’s training is carried out

through the regional SHE learning and development academy. The

induction presentation and the SOP for the site were available for

review.

Evidence:

— Induction Modules


None

7.1.2 Basic skills development and capacity building must be

incorporated. C All site personnel that work on the WRG undergo SHE induction to

ensure that they are familiar with the site’s SHE aspects and

requirements. All of Sasol’s training is done through the regional

SHE learning and development academy. The induction

presentation and the SOP for the site were available for review.

Evidence:



— SA Regional Procedure - Generic SHE Training.docx Rev.01

July 2018

None

7.1.3 Employees will be trained as required. C All site personnel that work on the WRP undergoes Safety, Health

and Environment (SHE) induction to ensure that they are familiar

with the site’s SHE aspects and requirements. All of Sasol’s training

is done through the regional SHE learning and development

None


WSP June 2019

Page 36


academy. Site personnel are trained on the WRG SOP on how the

site operates. The induction presentation and the SOP for the site

were available for review.

Evidence:



— SA Regional Procedure - Generic SHE Training.docx Rev.01

July 2018

7.2 CLEANING OF EQUIPMENT

Chemicals used for cleaning/pickling/passivation, etc.

7.2.1 Water will be routed to the correct sewer system according to

the Synfuels Water Management Procedure. C According to the IWWMP and the SOP, all water that falls within

contaminated areas including bunds is channelled in the dirty

stormwater system and taken away to the effluent collection sumps.

Any spillages in the chemical bunded and off-loading area first need

to be neutralised before being released to the effluent sump. If lime

is spilled, it can be diluted with plant water before being routed to

the oily water system. The acid sump level must also be monitored

to prevent any potential spillages and is pumped out completely

when required.

Evidence:


— SIC IWWMP Appendix 1 - WRG 2017 Rev 1

None

Water used for cleaning of steam/condensate system





None


WSP June 2019

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The sump is operated as empty as possible at all times to prevent

any overflow to the clean stormwater sewer.

Evidence:



Water used for cleaning/flushing of plant equipment





The sump is operated as empty as possible at all times to prevent

any overflow to the clean stormwater sewer.

Evidence:



None

7.3 COOLING TOWER DRIFT

Liquid fall out

7.3.1 Drift eliminators will be installed to minimise liquid fall out. C During the site walk over, it was confirmed that drift eliminators

were installed to minimise liquid fall out as required.

Evidence:

— Personnel Communication

None


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7.4 EMERGENCY AND RISK

Safety risks and emergency plan

7.4.1 Process Hazard Analysis and HAZOPs and training of

personnel will be conducted. C Sasol conducts risk assessments on the processes conducted on the

site based on risk assessment procedure (SGI-SHE-000014).

Several scenarios are covered during risk assessments to ensure safe

operation of the site.

All site personnel that work on the WRP undergoes SHE induction

to ensure that they are familiar with the site’s SHE aspects and

requirements. All of Sasol’s training is done through the regional

SHE learning and development academy. The induction

presentation was available for review.

Sasol have an environment emergency procedure (SGR-





for review

Evidence:

— SGI-SHE-000014 rev 6 - Minimum requirements for

ERA_Published

— IMS_Occupational Safety_2019-01-09

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod7_Occupational

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11


None


WSP June 2019

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7.4.2 Emergency plan must be in place before the commissioning

of the plant. C Sasol have an environment emergency procedure (SGR-



taken when an incident occurs. Furthermore, WRG has its own

specific emergency procedure that was available for review.

Evidence:

— Environmental emergency procedure (Rev 6): SGR-

SHE000023


None

7.4.3 Safety features that are intrinsic (built-in) rather than extrinsic

(added-on) to the basic design - this philosophy and the use of

high-integrity equipment and piping, provide the first lines of

defence against the dramatic and often catastrophic effects of

an overpressure and subsequent rupture, explosion or fire.

C The auditor was informed that the site equipment came with intrinsic

safety features to help prevent potential incidents. Furthermore,

additional safety features are installed around the facility to assist.

Features used on the facility include level controls linked to pumps,

pressure sensors, trip systems and alarms monitored in the control

room. All these are used to prevent site incidents.

Evidence:


None

7.4.4 Reduction of the probability of occurrence of an event by

considering the integrity of equipment and safe guards in

place to prevent failure of equipment should be addressed

during Basic Engineering.

C The auditor was informed that the site equipment came with intrinsic

safety features to help minimise the probability of occurrence of an

event. Furthermore, additional safe guards are installed around the

facility to prevent failure of equipment. Features used on the facility

include level controls linked to pumps, pressure sensors, trip

systems and alarms monitored in the control room. All these are

used to prevent site incidents.

Evidence:


None

7.4.5 New storage tanks will be designed with floating roofs and the

deck fittings and rim seals will be in accordance with

international standards to minimise evaporative losses.



No new tanks have been added since construction was completed.

None


WSP June 2019

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7.4.6 Storage and liquid impoundment areas for fuels, raw material

and in-process materials, solvents, wastes and products shall

be designed with secondary containment measures and hard

surfaces, suitable subsurface lining and leak detection

systems, pressure relief valves and high level alarms to

prevent spills and contamination of soil, groundwater and

surface water.

C All storage tanks are within concreted bunds that contain any

potential leaks. This was observed during the site walk and indicated

in the photo taken and referenced in Table 2. Furthermore, all the

tanks as well as the process are monitored in the control room to see

if there are any leaks, pressure build-up as well as potential changes

to levels within the tanks. The contained spillages are channelled

towards the sumps and are to be reworked back to the system.

The site is completely concreted, with stormwater channels that lead






quality and level so to prevent an overflow into the surrounding

environment.







Soil pollution monitoring is conducted as part of contaminated land

management. Phase 1 (December 2015) and Phase 2 (August) land

monitoring reports have been conducted for the Synfuels site as a

whole by Geo Pollution Technologies. Recommendations from each

report are marked down for implementation as required.

Contaminated land is managed within legal requirements and

incident registers are maintained in order to monitor any

contamination events.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


20

None


WSP June 2019

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— Phase 1_Contaminated Land

Assessment_November_2015_Final 1.0

— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of

2_2018-08-28

7.4.7 The safety, health and environmental objectives of the plant

layout are to minimise the potential for injuries, overall

property and environmental damage, and related business

interruption. Measures should be taken during the site layout

to minimise the incident size and impact.



None

7.4.8 Where possible new process units, storage tanks, control

building, occupied buildings and other facilities shall be

separated to minimise the effect of fires, explosions, radiant

heat, spills, etc., in one area onto adjacent areas (domino

effect).

N/A No new process units installed since the plant was commissioned in

2013.

None

7.4.9 Occupational health practices and operating procedures

currently conducted will be maintained and continually

improved in keeping with the current approach. Requirements

of the OHS Act (85 of 1993) and its Regulations, Sasol SH&E

Minimum Requirements, the requirements of the International

Risk Control Africa (IRCA) Occupational Health auditing

system, principles of the OHSAS 18000 standard, World

Health Organisation (WHO) guidelines and practices

currently embedded in the Synfuels Occupational Health

system will apply to the proposed project.

C Sasol maintain and continually improve their operational

occupational health and safety practices as required in terms of the

OHS Act (85 of 1993) and its Regulations. All health and safety

documentation is kept on the IMS system and the appointed safety

officers are displayed in the control room as was confirmed during

the site walk. All the relevant documentation was indexed on the

IMS system.

All site personnel that work on the WRG project undergo Safety,

Health and Environment (SHE) induction to ensure that they are

familiar with the site’s SHE aspects and requirements. All of Sasol’s

training is done through the regional SHE learning and development

academy. The induction modules for process safety management,

workplace safety and occupational health and safety were all

available for review.

The Synfuels facility is an ISO 18000 certified facility and the

relevant certificate was available for review which was issued on 24

August 2018 and will expire on 11 March 2021.

None


WSP June 2019

Page 42


Evidence:

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod7_Occupational

— SSO_BSOHSAS18001_IQNet_2018-08-24

7.5 FEED TO PLANT: TRANSPORTATION

Incidents during transportation

7.5.1 The feed to the plant will be by pipeline. A Transport Risk

Assessment will be conducted and is applicable during start-

up.

C According to Section 5.7 of the WRG SOP, inspections are carried

out according to the pre-commissioning checklist. The sequence

involved is:

— Clearance for operation certificate

— Permits signed off

— MOC completed

— Alarms and trip systems checked

— Emergency and safety equipment checks

— Lock out system enforced

This is also monitored in the control room. after all checks are done

and there are no issues, the feed can be started.

Evidence:


None


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7.6 FIRE WATER: ROUTING OF FIRE WATER

Water used to extinguish a fire not routed/disposed of correctly

7.6.1 Existing WRF fire system will be used. C The auditor was informed that the WRF fire system is used for any

potential fires that may arise on the WRG site. This is stipulated in

the WRG SOP.

Evidence:


None

7.7 FLARE

Emissions to the atmosphere

7.7.1 Flare only to be used during emergencies and start-up

conditions. C The flare is used as required. During the site walk, the flare system

was not in use and the auditor was informed that it is only used as

and when required.

Evidence:

— Personnel communication

None

7.8 INCINERATOR

Emissions to the atmosphere

7.8.1 Make use of existing incinerators. C The sludge produced in the process is sent to the two incinerators on


biosludge incinerators is licensed in the AEL (under subcategory 8.1

- thermal treatment of general and hazardous waste), which was

provided for review.

Evidence:

None


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7.9 MAINTENANCE REPLACE OLD EQUIPMENT

Removing redundant/contaminated equipment and not disposed of correctly

7.9.1 Redundant equipment will be sent to the Reclamation yard. N/A Noted. No equipment has been made redundant since

commissioning was completed.

None

7.10 NITROGEN BLANKETING IN TANKS

Continuous venting of VOCs saturated in Nitrogen to the atmosphere

7.10.1 Nitrogen will be routed to the biogas system and then to the

flare. C Any venting of nitrogen is routed according to the condition, and is

confirmed in the SOP (which was available for review).

Evidence:


None

7.11 PRODUCTION OF PRODUCT/BY-PRODUCT

Off-spec product and/or by-product not disposed of/routed correctly

7.11.1 Off-spec product will be circulated within the system. C All off-spec product is circulated within the system, as was

confirmed in the SOP.

Evidence:


None


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7.12 RELIEVE VALVES BIOGAS SYSTEM

Emissions to atmosphere

7.12.1 Routed to flare.

C Any venting of emissions to the atmosphere are routed according to

the condition which is confirmed in the SOP, which was available

for review.

Evidence:


None

7.13 STORMWATER MANAGEMENT: CONTAMINATED STORMWATER

Contaminated stormwater not disposed of/routed correctly

7.13.1 Stormwater contaminated by foam will go to the stormwater

dams. C According to the IWWMP and the WRG SOP, runoff from

contaminated areas drains to a sump, from where the water is

pumped back into the process circuit of WRG after passing through

the stormwater dams as required before that water is then treated and

sent back as process water.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


None

7.14 STORMWATER MANAGEMENT: UNCONTAMINATED STORMWATER

Uncontaminated stormwater not disposed of/routed correctly

7.14.1 Uncontaminated stormwater will be routed to the existing

stormwater system. C According to the IWWMP and the SOP, all stormwater runoff from

areas of the WRG plant where no pollution is expected drains

None


WSP June 2019

Page 46


directly to the environment. The water is routed via a canal to the

south of the WRG site from where it drains to the Bossiespruit.

Evidence:



7.15 TESTING OF EQUIPMENT: HYDRAULIC TESING



the Synfuels Water Management Procedure. C As indicated before and according to the IWWMP, water is

channelled into the stormwater system that surrounds the site and is

taken to the same stormwater system as contaminated water. This

leads to stormwater dams as required before that water is then

treated and sent back as process water.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


None

7.16 WASTE GENERATED IN THE PROCESS: SLUDGE

Sludge not disposed of correctly

7.16.1 Sludge will be incinerated. C The sludge produced in the process is sent to the two incinerators on


biosludge incinerators is licensed in the AEL under subcategory 8.1

(thermal treatment of general and hazardous waste) that was

provided for review as required.

Evidence:


None


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7.17 WASTE GENERATED IN THE PROCESS: SOLID WASTE

Solid waste generated in the process not disposed of correctly

7.17.1 The slurry resulting from the project will be sent to

incinerators. C The auditor was informed that the slurry produced is sent to the

biosludge incinerators as required. This was confirmed following a

review of the SOP.

Evidence:


None


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

Table 4: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 6 3 0 3

APPEAL OF AUTHORISATION 4 0 0 4

MANAGEMENT AND MONITORING OF THE ACTIVITY 2 2 0 0

COMMISSIONING AND OPERATION OF THE ACTIVITY 21 11 0 10

GENERAL 4 8 0 1

Total Count 37 19 0 18

Total Percentage 51% 0% 49%

Percentage Compliance with Applicable Conditions 100%


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Figure 5-1 illustrates the number/count contribution of the findings of the EA per section while Figure 5-2

presents the total proportion of compliance for the facility.

Figure 5-1: Number/Count contribution of findings made to the EA conditions per Section

Figure 5-2: Overall count findings on compliance to the EA conditions

0

5

10

15

20

25

Scope ofAuthorisation

Appeal ofAuthorisation

Management andMonitoring of the

Activity

Commissioningand Operation of

the Activity

General

Sectional Count Contribution

C

NC

N/A

19

0

18

Total Compliance

C

NC

N/A


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Page 50

Figure 5-3 illustrates the percentage contribution of the findings of the EA conditions. Figure 5-4 presents the

total percentage compliance for the facility.

Figure 5-3: Percentage contribution of findings made to the EA conditions per Section

Figure 5-4: Overall percentage findings on compliance to the EA conditions

0102030405060708090

100

Scope ofAuthorisation

Management andMonitoring of the

Activity

Commissioningand Operation of

the Activity

General

Sectional Percentage Contribution

C

NC

N/A

51%

0%

49%

Total Percentage Compliance

C

NC

N/A


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5.2 ENVIRONMENTAL MANAGEMENT PLAN

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

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

below.

Table 5: Summary of EMPr Compliance Audit Findings

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

CONSTRUCTION PHASE 72 0 0 72

PRE-COMMISSIONING PHASE 10 0 0 10

START-UP AND SHUTDOWN PHASE 7 5 0 2

OPERATION AND MAINTENANCE PHASE 29 25 0 4

Total Count 118 30 0 88

Total Percentage 25% 0% 75%

Percentage Compliance with Applicable Conditions 100%


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Figure 5-5 illustrates the number/count contribution of the findings of the EMPr per section while Figure 5-6

presents the total proportion of compliance for the facility.

Figure 5-5: Number/Count contribution of findings made to the EMPr conditions per Section

Figure 5-6: Overall count findings on compliance to the EMPr conditions

0

10

20

30

40

50

60

70

80

Construction Phase Pre-CommissioningPhase

Start-Up andShutdown Phase

Operation andMaintenance Phase

Sectional Count Contribution

C

NC

N/A

30

0

88

Total Compliance

C

NC

N/A


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Figure 5-7 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 5-8 presents the

total percentage compliance for the facility.

Figure 5-7: Percentage contribution of findings made to the EMPr conditions per Section

Figure 5-8: Overall percentage findings on compliance to the EMPr conditions

0102030405060708090

100

Construction Phase Pre-CommissioningPhase

Start-Up and ShutdownPhase

Operation andMaintenance Phase

Sectional Percentage Contribution

C

NC

N/A

25%

0%

75%

Total Percentage Compliance

C NC

N/A


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Page 54

5.2.1 EFFECTIVENESS OF THE EMPR

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

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

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

achieve the objectives and outcomes laid out in these documents;

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

— 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 approximately 70% of the listed measures are no longer applicable,

as these mostly related to the construction phase and pre-commissioning phase only. The original EMPr document

was designed pre-operation principally to govern these construction phase impacts, and has been superseded

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

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

international standard.

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

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

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

ISO 14001 standards.

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

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

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

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

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

Information Management System.

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

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

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

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

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

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17/2/2/1(e) MP-04)