ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL … Audit_Sa… · Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents the

SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2

ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/3 GS-172 - C3 EXPANSION PROJECT

29 MAY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/3 GS-172 - C3 EXPANSION PROJECT

SASOL CHEMICALS OPERATIONS:

POLYPROPYLENE 2

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: MAY 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

Q U A L I T Y M A N A G E M E N T

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref: 17/2/3 GS-

172

Draft v1a for Review

– Compliance Audit

EA Ref: 17/2/3 GS-

172

Draft v2 for Review –

Compliance Audit

EA Ref: 17/2/3 GS-

172

Final – Compliance

Audit

EA Ref: 17/2/3 GS-

172

Date April 2019 May 2019 May 2019 May 2019

Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Jenny Cope Jenny Cope Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534 41101534

Report number 006 006 006 006

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

S I G N A T U R E S

PREPARED BY

-

Bronwyn Fisher

Environmental Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

of their compliance with the conditions included in the Environmental Authorisation and associated

Environmental Management Plan.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Polypropylene Production Senior

Manager

Eric Munyangane

WSP

Associate Jenny Cope

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

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

WSP May 2019

TABLE OF CONTENTS

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

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

1.2 C3 Expansion Project (Authorisation Number:

17/2/3 GS-172) ............................................................................. 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 ................... 34

5.1 Environmental Authorisation .................................................. 34

5.2 Environmental Management Plan ........................................... 37


WSP May 2019

TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................................................... 7

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................................................. 18

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................................................ 34

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS ............................... 37

FIGURES

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

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................................................ 35

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................................................. 35

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..................................... 36

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................................................ 36

FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 38

FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................................................. 38

FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................................................... 39

FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........................................... 39


WSP May 2019

APPENDICES

A ENVIRONMENTAL AUTHORISATION (17/2/3 GS-172)


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Page 1

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: 17/2/3 GS- 172 issued on 13 November 2013) as well as

the associated Environmental Management Plan (dated: August 2013) for the period December 2014 to

February 2019.

1.2 C3 EXPANSION PROJECT (AUTHORISATION NUMBER:

17/2/3 GS-172)

An Environmental Authorisation (reference 17/2/3 GS-172) for the C3 expansion project was issued on 13

November 2013 by the Department of Economic Development, Environment and Tourism, Mpumalanga

Provincial Government.

The C3 expansion project was commissioned to address an estimated 105 ktpa (kilo tons per annum) additional

propylene that was being produced as a result of various optimisation projects on the upstream Sasol facilities.

An opportunity was identified for the additional propylene to be utilised as feed for the polypropylene (PP)

plants, namely PP1 and PP2.

The operating intent of the PP plants is the maximum conversion of propylene and ethylene from Sasol

operations into polypropylene pellets via a polymerization process. The products from this reaction are

homopolymers (constituting only propylene), impact copolymers (constituting propylene and high concentration

of ethylene) and random copolymers (propylene and low concentration of ethylene).

The C3 expansion project involved the upgrading and implementing of changes to the existing PP1 and PP2

process equipment to accommodate the increase in throughput. Figure 1 and Error! Reference source not

found. provide the location of the C3 Expansion Project.

Construction of the expansion project was completed between 2015 and 2016, therefore any construction related

conditions are considered relevant to the audit period.


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Page 2

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


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Page 3

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. Construction of the expansion project was

completed between 2015 and 2016, therefore any construction related conditions are considered relevant to this

audit period.

The objective of the audit was to:

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

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

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 EMPrs.


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Page 4

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 (11 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Bronwyn Fisher conducted the site inspection on 11 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:

— Brinton Walker (Technical Support Group (Polymers))

— Lucky Jiyane (Process Controller Grade 1)

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— EA_C3 Expansion_17.2.3 GS-172_ 2013_11_13;

— EMP_C3 Expansion_17.2.3 GS-172_ 2013_08;

— Sasol C3 Expansion-Final BAR plus App_red;

— Induction_Mod3_Environment;

— EA_EX Handover_SCO_Poly_Nitro_Poly;

— 3.06_EA_C3_Notification of construction_Encore_2016-04-30;

— 3.19_EA_C3_Bund Wall Philosophy_61424R-010-DW-1452-001-1

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

— Environmental Complaints Register_2019-02-18;

— SEC-042-2018-GIJ_(NOISE)_(Polymers,_Propylene_Production,_PP2);

— 3.32_EA_C3Expansion_SCO_POL_Amendment_1.3.1.16.4 G-39_2017-04-28;

— 3.26_EA_C3_Steel disposal certificates;

— PP1_PP2 Final Waste Register_2016-05-16;


— Labour_Sasol IRM Suppliers Industrial Relations Procedure;

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

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

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1- Polymers 2017 Rev 2;


WSP May 2019

Page 5

— SAS-490- Final PP1 and PP2.xlsx;

— Environmental incident procedure Process flow;

— 3.11_EA_C3Expansion_IAP_BA-AppendixC (1);

— 3.12_EA_C3Expansion_IAP_BA-AppendixC (1);

— 3.29_EA_C3Expansion_PolymersEmergManProcedure (1);

— PP2 Production Matrix -New 1;

— Decommission catalyst system for maintenance V1;

— Catalyst, Co-Catalyst and Modifier Neutralization and draining;

— C3 Expansion Project Closeout Report_2016-04-22 (1);

— C3 Expansion Project_Aspect Register (1); 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, Bronwyn Fisher, was hosted by Broni van der Meer, Brinton Walker and Lucky Jiyane to whom we

express our gratitude for their time and attention during our visit. A brief summary of the external auditors’

experience is provided below.


WSP May 2019

Page 6

— Auditor: Bronwyn Fisher

Bronwyn Fisher has 6 years of experience as an Environmental Consultant, undertaking Environmental

Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental

Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and

undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel

storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,

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

projects.

— 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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Page 7

4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

SCOPE OF AUTHORISATION

3.01 Authorisation of the activity is subject to the conditions

contained in this Environmental Authorisation, which form

part of the environmental authorisation and are binding on

the holder of the authorisation.

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

condition.

None.

3.02 The holder of the authorisation must ensure compliance with

the conditions by any person acting on his or her behalf,

including but not limited to, an agent, sub-contractor,

employee or any person rendering a service to the holder of

the authorisation.

C All visitors and contractors entering the Sasol Complex are

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

through the SHE regional learning and development academy, and

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

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

environmental aspects and management of the site. Sasol have

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

contract for the maintenance of the plant.

Evidence:

— Induction_Mod3_Environment

None.

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

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

Secunda. Sasol is compliant with this location description.

The auditor undertook a desktop review of the location of the C3

Stabilisation project and although the coordinates located within

the EA are slightly out it is within the general location of the

Polypropylene plant.

Evidence:

OFI:

Sasol should undertake an

EA amendment process to

amend the coordinates

within the EA to reflect the

true location of the facility.

Target completion:

Long term


WSP May 2019

Page 8


Location of the activity as stated in the EA

The location of the coordinates contained within the EA.

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

set out in this Environmental Authorisation must be

approved, in writing, by the Department before such changes

or deviations may be effected. In assessing whether to grant

such approval or not, the Department may request such

information as it deems necessary to evaluate the significance

and impacts of such changes or deviations and it may be

necessary for the holder of the Environmental Authorisation

to apply for further Environmental Authorisation in terms of

the regulations.

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

made to the project description as set out in the Environmental

Authorisation.

None.

3.05 A copy of this Environmental Authorisation must be made

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

and sub-contractors must be made familiar with the contents

of this Environmental Authorisation.

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

communicated with, relevant business units. Copies of these

documents are also available at the SHE: Environment department

and on SAP EC and SharePoint. Sasol provided the auditor with the

evidence that the responsible persons Eric Munyangane and

Francois du Toit, were made aware of the EA in September 2016.

Evidence:

— EA_EX Handover_SCO_Poly_Nitro_Poly

None.


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3.06 This activity must commence within a period of three (3)

years from the date of issue. If commencement of the activity

does not occur within that period, the Environmental

Authorisation lapses and a new application for

Environmental Authorisation must be made in order for the

activity to be undertaken.

C Construction commenced on the expansion project at the end of

April 2016. As the EA was issued on 13 November 2013 and

therefore construction commenced within 3 years of the date of

issue of the EA.

Evidence:

— 3.06_EA_C3_Notification of construction_Encore_2016-04-

30

None.

3.07 The Department may change or amend any of the conditions

in this Environmental Authorisation if, in the opinion of the

Department is environmentally justified.

N/A Noted. Sasol advised the auditor that, to their knowledge, the

Department has not changed or amended any conditions within the

EA.

None.

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

particular impact, the opinion of the Department in respect of

its significance will prevail.

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

concerning the significance of a particular impact with the

Department to date.

None.

3.09 This Environmental Authorisation does not absolve the

holder of the authorisation, responsibility to comply with any

other statutory requirements that may be applicable to the

undertaking of the activity.

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

Audit.

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

compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

protocol (CRMP) to assist the organization to reach a higher level

of legal compliance is commendable”.

Evidence:

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals

Operations.

None.

3.10 The holder of this Environmental Authorisation is

responsible for compliance with the provisions for Duty of

Care and Remediation of Environmental Damage contained

in Section 28 of the National Environmental Management

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

responsibility for compliance with the provision for Duty of Care

and Remediation of Environmental Damage.

None.


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Act, 1998 (Act 107 of 1998).

APPEAL OF AUTHORISATION

3.11 The holder of the Environmental Authorisation must notify

every registered interested and affected party, in writing and

within 12 days, of receiving notice of the Department`s

decision to authorize the activity.

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

was granted in 2013, therefore notice of the grant of the EA within

12 days would also fall outside of the audit period.

None.

3.12 The notification referred to above must-

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

b) Inform the interested and affected parties of the appeal

procedure provided for in Chapter 7 of the regulations; and

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

the authorisation and reasons for the decision will be

furnished on request."

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

was granted in 2013, therefore notice of the grant of the EA within

12 days would also fall outside of the audit period.

None.

MANAGEMENT AND MONITORING OF ACTIVITY

3.13 The Environmental Management Programme (EMPr)

incorporated in the Basic Assessment Report is hereby

approved.

N/A Noted. None.

3.14 The holder of the Environmental Authorisation must submit

a post-construction environmental audit report to the

Department within 30 (thirty) days after completion of

construction activity. The audit report must be compiled by

an independent auditor.

NC Sasol have not provided the auditor with evidence that a post-

construction audit was submitted to the Department.

A HSE Close out report was provided to the auditor, however this

does not discuss environmental aspects, and no evidence of

provision to the Department was provided.

This condition cannot be

rectified, unless such proof

of the audit can be provided.

3.15 This Department retains the right to monitor and/or inspect

the proposed project during both construction and operational

phases.

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

site regularly to monitor operational activities.

None.


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COMMISSIONING AND OPERATION OF THE ACTIVITY

3.16 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.

NC Although the contractor provided notification to the Department of

Labour, there is no evidence that the Provincial Department of

Agriculture, Rural Development, Land and Environmental Affairs

(DARDLEA) formally known as the Department of Economic

Development, Environment and Tourism, was ever notified of the

commencement of construction activities onsite.

This condition cannot be

rectified, unless such proof

of notification can be

provided.

3.17 The conditions stipulated in this Environmental

Authorisation, and the approved Environmental Management

Programme are legally binding components of any contract

and are therefore legally enforceable.

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

condition.

None.

3.18 All hazardous materials must be stored in designated, lined

and bunded areas. C During the site walkover, the auditor observed that all hazardous

materials are stored within tanks. The tanks are located within

bunded and hardsurfaced areas.

None.

3.19 The bund area must have sufficient space for containment of

spillages. C The bund walls have been designed to with the capacity to contain

110% of the volume of the largest tank. This was verified during

the site walkover and through the Bund Wall Philosophy provided

to the auditor by Sasol.

Evidence:

— 3.19_EA_C3_Bund Wall Philosophy_61424R-010-DW-1452-

001-1.

None.

3.2 Should spillages occur due to any reason, clean-up of the

spillages must be undertaken as soon as possible. C Spill kits were observed across the facility. All spills are dealt with

in accordance with the Sasol Environmental Emergency Procedure

(SGR-SHE-000023 REV6).

Evidence:

— Sasol Environmental Emergency Procedure (SGR-SHE-

000023 REV6).

None.


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Page 12


3.21 Appropriate measures must be taken to prevent and manage

soil erosion during and after construction. N/A As there was no requirement for an Environmental Control Officer

(ECO) to undertake monitoring of construction activities, there is

no evidence to indicate that this occurred during the construction

phase. However, due to the nature of the project and that it was

undertaken within the existing plant with no soil disturbance, soil

erosion is deemed unlikely.

None.

3.22 The construction camp must be established on an area that

has previously been disturbed. C As there was no requirement for an Environmental Control Officer



phase. However, Sasol have verbally advised that the construction

camp was located within the existing operational area between the

truck entrance and the management building (i.e. a disturbed area).

None.

3.23 Mixing of cement and hazardous substances must take place

on impermeable surfaces. N/A Sasol has advised the auditor that no cement mixing was

undertaken onsite. Ready mixed cement was brought in via truck.

None.

3.24 All comments and complaints received from the public

during the construction and operational phases of the activity

must be attended to as soon as possible and addressed to the

satisfaction of all concerned.

C Sasol advised the auditor that all environmental complaints

received from interested and affected parties, both internal and

external to the organisation, are recorded in a complaints register

that is available at the Environmental department. Complaints are

investigated and reported in line with the Sasol Environmental

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

requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

The auditor was provided with the complaints register and relevant

complaints procedure. No complaints had been lodged against the

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

been compiled in accordance with the procedure, which ensures

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

Evidence:

— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01;

None.


WSP May 2019

Page 13


— Environmental Complaints Register_2019-02-18.

3.25 Appropriate notification signs must be erected warning the

public of the dangers around the construction site. N/A Due to the location of the site within the existing Polypropylene

Operational area, public access is restricted.

None.

3.26 All waste generated during construction must be stored,

handled and disposed of at a registered waste disposal site. C As there was no requirement for an Environmental Control Officer



phase.

However, Sasol have advised the auditor that waste during the

construction phase would have been handled in accordance with

the Sasol Waste Management Procedure. General waste would

have been disposed of at the Sasol waste management facility,

located at Charlie 1, and metal waste would be managed through

the Sasol Redundant Materials Management (RMM). The auditor is

satisfied that this is sufficient to make this condition compliant.

None.

3.27 It is the responsibility of the holder of the Environmental

Authorisation to rectify any source of pollution from their

undertaking and to take appropriate measures to prevent any

pollution of surface as well as ground water.

C Ground water monitoring is conducted biannually and quarterly.

There is no groundwater monitoring specific to the C3 Expansion

Project, however there are six active boreholes located within the

Primary area which are utilised for monitoring. The auditor noted a

number of exceedances in the November 2017 sampling run,

however these exceedances cannot be directly attributed to the C3

Expansion Project.

None.

3.28 Dust, noise, and odour control mechanisms must be

implemented at all times to prevent health risk to the workers

and the surrounding communities.

C Due to the nature of the operations, dust emissions are not deemed

applicable.

In terms of noise, Sasol undertake regular noise surveys and have

signage indicating where noise protection must be worn. All staff

undergo annual medicals which assesses hearing.

A noise zoning survey was undertaken for PP1 and PP2 in 2017.

The report, dated 23 January 2018, it was noted that only the

maximum hearing protection (i.e. 3M Peltor OptimeTM ear muffs)

is suitable to provide adequate protection against noise levels

encountered in all areas of the PP2 plant. Sasol advised that all

None.


WSP May 2019

Page 14


employees are provided with this hearing protection.

Sasol undertake monthly stack monitoring. Odour is not anticipated

to issue at the plant as the entire system is a closed loop system.

Evidence:

— SEC-042-2018-GIJ (NOISE)_

(Polymers,_Propylene_Production,_PP2)

Signage indicating required PPE (including hearing

protection)

3.29 Suitable fire protection systems must be accessible on site

when urgently required to deal with an emergency situation.

[Equipment] such as fire detection and firefighting systems

must be accessible to workers on site.

C The site comprises a number of fire hydrants and hoses located

across the plant. In addition, all tanks are fitted with a fire deluge

system.

Evidence:

None.


WSP May 2019

Page 15


Examples of the firefighting equipment located across

the plant.

SITE CLOSURE AND DECOMMISSIONING

3.30 In case of decommissioning, a detailed Rehabilitation Plan

must be submitted to this Department for approval at least six

(6) months prior to the decommissioning phase.

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

this site redundant in the foreseeable future.

None.

GENERAL

3.31 A copy of this Environmental Authorisation must be kept at

the property where the activity will be undertaken. The

Environmental Authorisation must be produced to any

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

communicated with, relevant business units. Copies of these

documents are also available at the SHE: Environment department

None.


WSP May 2019

Page 16


authorized official of the Department who requests to see it

and must be made available for inspection by any employee

or agent of the holder of the Environmental Authorisation

who works or undertakes to work at the property.

and on SAP EC and SharePoint. Sasol Provided the auditor with

the evidence that the responsible persons Eric Munyangane and

Francois du Toit, were made aware of the EA in September 2016.

Evidence:

— EA_EX Handover_SCO_Poly_Nitro_Poly

3.32 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 Sasol provided the Department with notification of the change of

ownership from Sasol Synfuels (Pty) Ltd to Sasol South Africa

(Pty) Ltd. The Department issued the Amendment to the

Authorisation (reference number: 1/3/1/16/4 G- 39).

Evidence:

— 3.32_EA_C3Expansion_SCO_POL_Amendment_1.3.1.16.4

G-39_2017-04-28

None.

3.33 The holder of the authorisation must notify the Department,

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

the Environmental Authorisation are not adhered to. Any

notification in terms of this condition must be accompanied

by reasons for the non-compliance.

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

has been informed of the non-compliances noted associated with

this EA.

For historical non-

compliances, this condition

is considered non-

rectifiable. Going forwards,

Sasol should ensure that all

non-conformances are

reported within 24 hours.

Target completion:

Medium term

3.34 Non-compliance with a condition of this Environmental

Authorisation results in criminal prosecution or other actions

provided for in the National Environmental Management

Act, 1998 and the regulations.

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

condition.

None.

3.35 National government, provincial government, local

authorities or committees appointed in terms of the

conditions of this Environmental Authorisation or any other

public authority shall not be held responsible for any

damages or losses suffered by the applicant or his successor

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

condition.

None.


WSP May 2019

Page 17


in title in any instance where construction or operation

subsequent to construction be temporarily or permanently

stopped for reasons of non-compliance by the applicant with

the conditions of Environmental Authorisation as set out in

this document or any other subsequent document emanating

from these conditions of Environmental Authorisation.


WSP May 2019

Page 18

Table 3: Audit Findings – Environmental Management Plan


CONSTRUCTION PHASE

1.01 Appointment of a contractor:

— EMPr must be included as part of any contractual

documentation.

NC The auditor was provided with a copy of Works Information for

Installation of C3 Administration Building Electrical and HVAC

Systems, which forms a contractual document. However, whilst the

following is stated, no specific reference to the EMPr is made: “The

Contractor complies with all the legal requirements of the Act as

well as any site specific standards, procedures and Safety, Health

and Environmental (SH&E) management rules while working on

the site”.

Additionally, a Closeout report was provided, however this is

principally a H&S document, and does not evidence contractor

appointment documents make reference to the EMPr.

Consequently, the auditor has not been provided with evidence that

the EMPr is included in contractor appointment documentation.

Evidence:

— EMP1.01_C3 Exp_SOW Installation Contract

— C3 Expansion Project Closeout Report_2016-04-22 (1)

This condition relates only

to construction phase and

consequently cannot be

rectified unless such

evidence is available.

1.02 Environmental Awareness and Safety Training:

— Contractor is expected to have safety tool box talks in

accordance with the risks and trends associated with

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

— The principal contractor will develop a specific

emergency procedure and implement an emergency plan

based on the Sasol Business Unit’s (SBU) guidelines for

that site.

C A HSE Project Closeout Report for the period 05 January 2015 –

22 April 2016, indicates that 46 Toolbox Talks were compiled by

Technip (lead contractor) and issued to Contractors.

The Project Closeout Report also indicates that each contract

submitted a 27 point HSE file to Technip for review, and to Sasol

for final approval. Baseline risk assessments, in addition to issue

based/task specific risk assessments were completed by the Lead

Contractor.

Evidence:


None.

1.03 Personal Protective Equipment (PPE): C The construction activities were undertaken within the existing

Polypropylene plant operational area. Site access is prohibited

None.


WSP May 2019

Page 19


— No person is allowed to enter the site without the SBU

approved required PPE.

— All contractors shall be trained on the correct use of

PPE. All contractors are required to keep an updated

register of all PPE issued.

— A contractor shall ensure action is taken against an

employee who continuously fails to comply.

— PPE minimum requirement notice boards shall be

placed at all entrances.

without the correct PPE, and evidence of PPE signage was

observed for the wider site.

As there was no requirement for an Environmental Control Officer


no evidence to indicate that all contractors kept an updated register

of all PPE issued. However, adherence with PPE requirements are

strictly controlled at Sasol, and contractors are not permitted to

work onsite without abiding by the Sasol policies and procedures.

Furthermore, a copy of the HSE Project Closeout Report was

provided, which includes photographic images of the construction

site. Evidence of adherence with PPE requirements was

demonstrated.

Evidence:


1.04 Dust Control:

— There should be strict speed limits on site roads to

prevent liberation of dust in to the atmosphere.

— Dust must be suppressed on the construction site during

the transportation of material during dry periods by the

regular application of water.

— To avoid the generation of unnecessary dust, material

drop height should be reduced and material storage piles

should be protected from wind erosion. This can take

the form of wind breaks, water sprays or vegetation of

piles.

C The construction activities were undertaken within the existing

Polypropylene plant operational area. Speed limits within the Sasol

Secunda complex are strictly monitored and implemented onsite.

Due to the location of the construction activities and the nature of

the project, Sasol advised the auditor that no soil was disturbed

during the construction phase, consequently limiting dust

generation potential.

None.

1.05 Noise:

— Vehicles and equipment must be maintained in good

working order.

— Construction staff working in area where the 8-hour

ambient noise levels exceed 85 dBA must have the

appropriate PPE e.g. ear protection equipment.

— Where possible, stationary noisy equipment (e.g.

C As there was no requirement for an Environmental Control Officer


no evidence to indicate that vehicles and equipment were

maintained in good working order during the construction phase.

However, maintenance schedules for vehicles and equipment are

routinely utilised to ensure good condition is maintained.

All personnel (including contractors) entering the Polypropylene

plant operational area are required to wear ear protection. Due to

None.


WSP May 2019

Page 20


compressors, generators etc) should be encapsulated in

acoustic covers, screens or sheds. Portable acoustic

shields should be used in the case where noisy

equipment is not stationary (e.g. drills, angle grinders,

chipping hammers).

the location of the construction activities within the Sasol Secunda

Complex, all construction staff will have been required to wear

hearing protection.

1.06 Storage and handling hazardous substances:

— The contractor must comply with all national, regional

and local legislation with regard to the storage,

transportation, use and disposal chemical, harmful and

hazardous substances and materials.

— The contractor will be responsible for the training and

education of all personnel on site on handling the

material, its proper use, and disposal as well as spill

response.

— Ascertain that the workers understand the content of the

hazardous products and the information on the MSDSs.

— MSDSs of chemicals must always be available.

— Clear signage must be placed at all storage areas

containing hazardous substances / materials.

— Any hazardous waste from the clean-up must be

disposed of at a hazardous waste site. In the event of a

spillage occurring, clean up must be done immediately

to prevent widespread pollution.

— Ensure that functioning spill kits are available onsite to

clean-up spills and leaks.

— Lubricants, chemicals and other hazardous substances

must be stored in a designated area that is well

ventilated, with an impervious surface, bunded, covered

and able to contain 110% of the total volume of

materials stored at any given time.

— Refuelling of machinery must be done using a drip tray

and vehicle refuelling must only be done at the

designated area.

— Ensure that only designated areas are used for the

storage and handling of construction materials and fuels.


(ECO) to undertake monitoring of construction activities, verifying

these construction phase conditions retrospectively is challenging.

Sasol provided the auditor with a selection of MSDS for the

chemicals being stored onsite during the site walkover. Signage

relevant to the storage of hazardous materials was observed during

the site walkover.

Access to the area is strictly controlled, and firefighting equipment

was observed.

The HSE Project Closeout Report states that 46 Toolbox talks were

compiled by Technip and issued to contractors, 54 audits on

contractors were completed by Technip, and 48 site management

walks (Sasol) were completed.

The final Basic Assessment Report for the Expansion Project

indicates that all hazardous substances must be stored on an

impervious surface in a designated bunded area, able to contain

110% of the total volume of materials stored at any given time; and

the integrity of the impervious surface and bunded area must be

inspected regularly and any maintenance work conducted must be

recorded in a maintenance report. The BAR further states that

employees and contractors must be trained on the correct handling

of spillages and precautionary measures that need to be

implemented to minimise potential spillages; and employees should

be provided with absorbent spill kits and disposal containers to

handle spillages.

Evidence:


— Sasol C3 Expansion-Final BAR plus App_red

None.


WSP May 2019

Page 21


— Equipment and vehicles should be regularly inspected in

order to detect leaks as early as possible.

— All diesel generators will be equipped with drip trays

and the contractor should ensure that the generators are

in good working condition.

— Access must be strictly controlled and only authorised

persons may enter.

— Fire fighting equipment must be present at all storage

facilities.

Example of safety signage onsite.

1.07 Waste management:

— General waste disposal bins will be made available for

employees to use throughout construction phase and

littering should not be allowed.

— Waste will be temporarily stored onsite (less than 90

days) before being disposed of at an appropriately.

— General waste e.g. packaging material and spent

welding rods will be disposed of at an approved facility.

— Records of all waste being taken offsite must be kept as

evidence.

— Burning waste will not be permitted.

— Hazardous materials will be generated if there are

spillages during construction and maintenance periods.

This waste should be cleaned up using absorbent


(ECO) to undertake monitoring of construction activities, verifying

these construction phase conditions retrospectively is challenging.

Sasol have advised the auditor that all general waste was disposed

of at Sasol’s Waste Management Facility at Charlie 1. Metal waste

was managed through the Sasol Redundant Materials Management

(RMM). Sasol have provided proof that steel was collected from

the Sasol RMM during the construction period.

Waste management is completed via implementation of a Waste

Management procedure that addresses the approach to manage

waste in line with the internationally accepted waste hierarchy,

whereby disposal to land is considered the last management option

to undertake once avoidance, re-use, recycling, recovery and

treatment options have been considered / eliminated. The

procedure further details waste disposal and management through

None.


WSP May 2019

Page 22


material provided in spill kits onsite.

— Absorbent materials used to clean up spillages should be

disposed of in a separate hazardous waste bin.

— Hazardous waste generated e.g. mixed concrete, paint

cans and brushes, contaminated soil must be disposed of

at a licensed hazardous waste disposal site. Records of

waste disposed of must be kept.

— The storage area for hazardous waste material must be

concreted, bunded, covered, labelled and well

ventilated.

— Provide employees with appropriate PPE for handling

hazardous materials.

— All hazardous waste will be disposed of in a registered

hazardous waste disposal facility.

— The construction staff handling chemicals of hazardous

materials must be trained in the use of the substances

and the environmental, health and safety consequences

of incidents.

— The contractor must design, test/exercise appropriate

emergency preparedness programmes (plans, schedules,

procedures and methods) for addressing environmental

accidents, incidents, and events such as spills of fuel,

lubricants; fires etc.

characterization and classification that is detailed in site specific

waste registers.

General waste disposal bins across the Sasol site were observed by

the auditor, and no notable volume of litter was observed during the

site walkover.

Evidence:

— 3.26_EA_C3_Steel disposal certificates;

— PP1_PP2 Final Waste Register_2016-05-16.


1.08 Employment:

— All labour (skilled and unskilled) and contractors should

be sourced locally where possible recruitment.

— Recruitment at the construction site will not be allowed.

C Sasol has advised the auditor that they have implement a Supplier

Industrial Relations Procedure (SIRP) that aims to provide the

greatest degree of uniformity, consistency and to standardisation of

procedures and practices pertaining to security / site access and

Industrial Relations matters to all Suppliers, their Agents, Sub-

contractors and Labour brokers/TES. Suppliers are required to

ensure that the SIRP, its procedures and practices are

communicated, understood, observed and followed by them and all

their constituents at all times. Non-compliance with the procedure

may result in the termination of the commercial agreement between

the parties.

Evidence:

None.


WSP May 2019

Page 23


— Labour_Sasol IRM Suppliers Industrial Relations Procedure

1.09 Traffic:

— Routes for the passage of vehicles and machinery must

be agreed by the project team to ensure minimal

disruption to daily plant activities.

C Sasol have confirmed that contractors involved with construction

had specific laydown areas and used entrances into the facility as

directed by Sasol. This formed part of the induction process. No

specific route plan is available as the interruption to normal plant

activities was minimal.

None.

PRE COMMISSIONING

2.01 Storage and handling hazardous substances:

— An inventory of all chemicals onsite must be kept.

MSDSs must always be available.

— Access to the store must be controlled and flammable

and inflammable materials should be kept separately.

— Ascertain that the workers understand the content of the

products and the information on the MSDSs.

— All chemicals will be kept in a properly bunded area

with access control.

— Emergency plan and procedures must be put in place.

— Ensure that used chemicals are disposed of at a

permitted hazardous waste disposal site.

C Sasol provided the auditor with a selection of MSDS for the

chemicals being stored onsite during the site walkover. The entire

site is access controlled, and the chemicals being stored are located

within tanks. The tanks are bunded and located on hardsurfacing.

All chemical waste produced at the C3 expansion plant is sent

elsewhere on the site for processing or recovery.

The final Basic Assessment Report (BAR) for the Expansion

Project indicates that all hazardous substances must be stored on an

impervious surface in a designated bunded area, able to contain

110% of the total volume of materials stored at any given time; and

the integrity of the impervious surface and bunded area must be

inspected regularly and any maintenance work conducted must be

recorded in a maintenance report. The BAR further states that

employees and contractors must be trained on the correct handling

of spillages and precautionary measures that need to be

implemented to minimise potential spillages; and employees should

be provided with absorbent spill kits and disposal containers to

handle spillages.

Emergency plans and procedures are in place.

Evidence:


— Sasol C3 Expansion-Final BAR plus App_red

— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017-

OFI:

The Sasol Polymers Area

Emergency Procedure dates

from 2012, i.e. prior to the

completion of the C3

Expansion Project and

should be updated to ensure

suitability.


WSP May 2019

Page 24


2022 Rev_0;

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol Environmental Emergency Procedure (SGR-SHE-

000023 REV6);

— 3.29_EA_C3Expansion_PolymersEmergManProcedure (1).

2.02 Waste water (effluent handling):

— Contaminated water should be directed into the correct

disposal system and none should go into the stormwater

management system.

— Waste water must not be allowed to come into direct

contact with exposed soils or run across the plant site.

— Vehicles and machinery may not be washed onsite. All

waste water must be collected and disposed of in a

correct and environmentally suitable manner.

C Sasol have an IWWMP, which aims to identify the activities

related to Sasol’s operations within the context of the receiving

environment (with a focus on water resource protection), identify

the risks associated with these operations, and subsequently

manage these risks by means of an action plan committed to by

Sasol management.

The IWWMP has a detailed description of stormwater management

within the Polymers Plants. The auditor was able to confirm that

the description of the management of contaminated run-off is

implemented onsite. According to the IWWMP “At the Polymers

site there is a prominent segregation of clean and contaminated

storm water runoff. Operational areas where there is the potential

for spillages of chemicals or oil are bunded, and runoff from these

areas drains into the Polymers API dam. The water from the

Polymers API dam is transferred to the Synfuels API East system.

The storm water runoff from the remaining areas drains in a

northerly direction primarily to the Check basin or the Pellet

Separator basin. Any fire water utilised onsite will also report to

the Check Basin.”

Stormwater Management is managed as site-wide within the

Secunda complex, rather than being plant specific.

All operational areas of the Polymers Plant area is hardsurfaced,

restricting the likelihood of wastewater coming into direct contact

with exposed soils.

No vehicle washing occurs in the Polymers Plant.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

None.


WSP May 2019

Page 25


— SIC IWWMP Appendix 1- Polymers 2017 Rev 2

An example of a Stormwater drain on the Polypropylene site.

The pellet separator.


WSP May 2019

Page 26


The Check Basin and Polymers API dam.

2.03 Venting of equipment:

— Venting of equipment must be minimized to prevent the

risk of fire, air and noise pollution.

— Venting activities should comply with Sasol standards

and should be conducted by properly trained personnel.

C Sasol advised the auditor that venting is carried out at the plant, but

that it is minimised as required. It was confirmed that all venting is

completed in accordance with the Sasol Venting Standard.

None.

OPERATIONS AND MAINTENANCE

3.01 Cleaning of equipment:

— Chemical will be disposed of correctly at a permitted

site.

— Contamination water should be routed to the correct

drainage system according to the water management

procedure.

— Cleaning of equipment should be done in a designated

bunded area to prevent eventual soil and water

pollution.

C The auditor was advised that chemical wastewater from the

cleaning of equipment is discharged into the oily water sump,

where it goes to the Polymers API dam.

Chemical disposal is carried out in accordance with Sasol’s Waste

Management procedure that addresses the approach to manage

waste in line with the internationally accepted waste hierarchy,

whereby disposal to land is considered the last management option

to undertake once avoidance, re-use, recycling, recovery and

treatment options have been considered / eliminated. The

procedure further details waste disposal and management through

None.


WSP May 2019

Page 27


— The chemicals used for cleaning must be disposed of

correctly. MSDS of the chemicals should always be

available.

characterization and classification that is detailed in site specific

waste registers.

Evidence:



3.02 Water/effluent handling (routing of fire water, management

of contaminated and uncontaminated storm water):

— Correct disposal of effluent must be ensured.

— Any spill should be cleaned up immediately and

disposed off at a designated site.

— Ensure uncontaminated and contaminated storm water

are channelled into the correct system.

C Sasol have an IWWMP, which aims to identify the activities

related to Sasol’s operations within the context of the receiving

environment (with a focus on water resource protection), identify

the risks associated with these operations, and subsequently

manage these risks by means of an action plan committed to by

Sasol management.

The IWWMP has a detailed description of stormwater management

within the Polymers Plants. The auditor was able to confirm that

the description of the management of contaminated run-off is

implemented onsite. According to the IWWMP “At the Polymers

site there is a prominent segregation of clean and contaminated

storm water runoff. Operational areas where there is the potential

for spillages of chemicals or oil are bunded, and runoff from these

areas drains into the Polymers API dam. The water from the

Polymers API dam is transferred to the Synfuels API East system.

The storm water runoff from the remaining areas drains in a

northerly direction primarily to the Check basin or the Pellet

Separator basin. Any fire water utilised onsite will also report to

the Check Basin.”

Stormwater Management is managed as site-wide within the

Secunda complex, rather than being plant specific.

According to the Sasol IWWMP, any fire water utilised onsite will

report to the Check Basin. This was confirmed with Sasol by the

auditor during the site walkover.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1- Polymers 2017 Rev 2.

None.


WSP May 2019

Page 28


3.03 Waste management - i.e. hazardous and general wastes

generated during operational and maintenance activities e.g.

servicing of old equipment:

— Equipment that has the potential for spillages or

leakages shall be equipped with drip-trays.

— Care should be taken to ensure that spillages of oils and

effluent are limited during maintenance. In the event of

a spill/leak, the source of the spill or leak must be

identified and stopped.

— The oil/effluent must be cleaned immediately and any

contaminated soil must be removed and disposed of

through a recognised waste disposal method.

— Hazardous waste must be stored in a covered well

labelled, ventilated area which is also bunded.

— Hazardous and general waste must be disposed of at a

licensed hazardous waste disposal facility.

— Evidence of correct disposal of waste must be retained.

— Uncontaminated equipment can be taken to a recycling

facility, e.g. metal.

C The site generates very little hazardous waste. No spent catalyst is

generated in the manufacturing process, as the catalyst is

incorporated into the final product. Any expired additives are

stored on site in skips and removed to the Holfontein Hazardous

landfill site. Off-spec product is sent back to the feed tank and

reworked to meet the quality specification. Waste storage practices

observed by the auditor were noted to be adequate.

Sasol advised the auditor that waste management is handled

through implementation of a Waste Management Procedure that

addresses the approach to manage waste in line with the

internationally accepted waste hierarchy, whereby disposal to land

is considered the last management option to undertake once

avoidance, re-use, recycling, recovery and treatment options have

been considered / eliminated. The procedure further details waste

disposal and management through characterisation and

classification that is detailed in site specific waste registers.

General waste produced at the plant is disposed of at the Sasol

Waste Management Facility, located at Charlie 1. Scrap metals and

redundant materials are sent to the Sasol Redundant Materials

Management.

Evidence:

— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017-

2022 Rev_0;


000017_Rev10_2017-09;

— SAS-490- Final PP1 and PP2.xlsx;



None.

3.04 Health and Safety:

— All personnel must be well trained to work in the PP

plants.

— Strict access rules should be applied to personnel

entering the PP plant.

C Site access is strictly controlled at the entrance to the Polymers

Unit. All unauthorised personnel must report to security and sign

in. Access to site without the correct PPE is prohibited across the

Sasol site. PPE requirements are indicated at the entrance to

operational areas. Sasol have a site wide spill procedure which was

provided to the auditor.

None.


WSP May 2019

Page 29


— All operators should wear appropriate PPE.

— Procedures must be put in place for clean up and

incidents to be reported.

— Appropriate signage (e.g. no smoking) should be clearly

displayed in the PP plant.

— The PP plants should be regularly maintained as

required to ensure that all the fittings and equipment are

in good working condition.

During routine shut down (annual) any maintenance and/ or

cleaning that is required is carried out.

Evidence:

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11

— Response Env Emergency Incidents_SGR-SHE-000023(under

review)_2018-10-08

Example of safety signage onsite.

3.05 Storage, loading and off-loading of catalysts:

— Procedures to be in place to prevent spillages / clean-up.

Procedures to be followed and incidents to be reported.

C Sasol provided the auditor with the procedures for the following,

which includes spillage and clean-up:

— Environmental Emergencies;

— IWWMP;

— Catalyst, co-catalyst and modifier neutralization; and,

— Decommission catalyst system for maintenance.

OFI:

The Sasol Polymers Area

Emergency Procedure dates

from 2012, i.e. prior to the

completion of the C3

Expansion Project and

should be updated to ensure


WSP May 2019

Page 30


Evidence:

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11


— Catalyst, Co-Catalyst and Modifier Neutralization and

draining;

— Environmental incident procedure Process flow

— SIC IWWMP Appendix 1 - Polymers 2017 Rev 2

suitability.

3.06 Noise production:

— Personal working in the PP plants must have the

appropriate PPE since ambient noise levels usually

exceed 85 dBA.

C The auditor observed onsite that all personnel entering the PP

operational areas must have hearing protection. Signage has been

erected across the operational areas indicating the use of hearing

protection. Any person not wearing the correct PPE is prohibited

from entering the PP plant.

None.


WSP May 2019

Page 31


Safety signage indicating the use of hearing protection.

3.07 Effluent handling as a results of cleaning vessels and

draining of vessels during shutdowns:

— Correct disposal of effluent must be ensured.

— All workers should be trained on the correct cleaning

procedures and draining methods.

— All workers should wear appropriate PPE.

— Equipment must be designed and managed properly in

accordance with Sasol standards and specifications.

— Appropriate measures should be taken to avoid

spillages.

C According to the IWWMP chemicals used for the cleaning of

equipment is discharged into the oily water sump, where it goes to

the Polymers API dam. The auditor confirmed this during the site

walkover.

The auditor observed onsite that all personnel entering the PP

operational areas must have hearing protection. Signage has been

erected across the operational areas indicating the use of hearing

protection. Any person not wearing the correct PPE is prohibited

from entering the PP plant.

The final Basic Assessment Report (BAR) for the Expansion

Project indicates that employees and contractors must be trained on

the correct handling of spillages and precautionary measures that

None.


WSP May 2019

Page 32


need to be implemented to minimise potential spillages; and

employees should be provided with absorbent spill kits and

disposal containers to handle spillages.

The auditor was also provided with the PP2 training matrix; and

SOPs for decommissioning the catalyst system for maintenance,

and catalyst, co-catalyst and modifier neutralization. These

documents evidence the presence of procedural control over

training and awareness.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;


— PP2 Production Matrix -New 1;


— Catalyst, Co-Catalyst and Modifier Neutralization and

draining; and,

— Sasol C3 Expansion-Final BAR plus App_red.

3.08 Management of catalysts during shutdowns:

— Ensure that disposal procedure are in place and that

disposal take place at permitted sites.

C Any expired additives are stored on site in skips and removed to the

Holfontein Hazardous landfill site. The auditor was provided with

the Waste Register for the expired additives. The auditor is

satisfied that the Holfontein Hazardous Waste Landfill site is

appropriately licenced to accept and dispose of this hazardous

waste type.

Evidence:



000017_Rev10_2017-09;

— SAS-490- Final PP1 and PP2.xlsx.

None.

DECOMMISSIONING PHASE

4.01 Waste generation during the decommissioning phase will

have a negative impact on the environment, if not controlled N/A Noted. Sasol has advised the auditor that they are aware of this

condition however, there are no plans in the foreseeable future to

None.


WSP May 2019

Page 33


adequately waste includes general waste or hazardous waste. decommission the plant.

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


decommission the plant.

None.

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



None.

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



None.

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



None.

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



None.

4.07 Contamination of surface and groundwater due to spillage

leakage, incorrect storage and handling of chemicals, oil,

lubricants, cement, fuels and other hazardous materials.

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



None.


WSP May 2019

Page 34

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

below.

Table 4: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 10 4 0 6

APPEAL OF AUTHORISATION 2 0 0 2

MANAGEMENT AND MONITORING OF ACTIVITY 3 0 1 2

COMMISSIONING AND OPERATING OF THE ACTIVITY 14 9 1 4

SITE CLOSURE AND DECOMMISSIONING 1 0 0 1

GENERAL 5 2 1 2

Total Count 35 15 3 17

Total Percentage 43% 9% 49%

Percentage Compliance with Applicable Conditions 83%


WSP May 2019

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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

2

4

6

8

10

12

14

16

Sectional Count Contribution

C

NC

N/A

15

3

17

Total Compliance

C

NC

N/A


WSP May 2019

Page 36

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

43%

9%

49%

Total Percentage Compliance

C

NC

N/A


WSP May 2019

Page 37

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 9 8 1 0

PRE COMMISSIONING 3 3 0 0

OPERATIONS AND MAINTENANCE 8 8 0 0

DECOMMISSIONING PHASE 7 0 0 7

Total Count 27 19 1 7

Total Percentage 70% 4% 26%

Percentage Compliance with Applicable Conditions 95%


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Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7

presents the total proportion of compliance for the facility.

Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section

Figure 7: Overall count findings on compliance to the EMPr conditions

0123456789

10

Construction Phase Pre Commissioning Operations andMaintenance

DecommissioningPhase

Sectional Count Contribution

C

NC

N/A

19

1

7

Total Compliance

C

NC

N/A


WSP May 2019

Page 39

Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the

total percentage compliance for the facility.

Figure 8: Percentage contribution of findings made to the EMPr conditions per Section

Figure 9: Overall percentage findings on compliance to the EMPr conditions

5.2.1 EFFECTIVENESS OF THE EMPR

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

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

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

achieve the objectives and outcomes laid out in these documents;

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

— Critically evaluate the effectiveness of the EMPr;

0102030405060708090

100

Construction Phase Pre Commissioning Operations andMaintenance

DecommissioningPhase

Sectional Percentage Contribution

C

NC

N/A

70%

4%

26%

Total Percentage Compliance

C

NC

N/A


WSP May 2019

Page 40

— 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 half of the listed measures will be no longer

applicable going forwards, as these mostly related to the construction-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

(17/2/3 GS-172)