SASOL CHEMICAL OPERATIONS: SOLVENTS …...2019/06/13 · Environmental Authorisation (EA)...

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.4 GS9 CONSTRUCTION AND OPERATION OF 1-OCTENE 3 PLANT

13 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.4 GS9 CONSTRUCTION AND OPERATION OF 1-OCTENE 3 PLANT

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

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KNIGHTSBRIDGE, 33 SLOANE STREET

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref: 17.2.4 GS 9

Final – Compliance

Audit

EA Ref: 17.2.4 GS 9

Date April 2019 June 2019

Prepared by Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 016 016

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

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.

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

Solvents Production Senior Manager,

Secunda Chemicals Operations

Adriaan Lambrechts

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 1-Octene 3 Plant (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 17.2.4 GS 9) .................... 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 ............................................................... 6

3.6 Assumptions and Limitations ................................ 6

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

5 SUMMARY OF THE AUDIT FINDINGS ... 19

5.1 Environmental Authorisation ............................... 19


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TABLES

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

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

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 19

FIGURES

FIGURE 1: LOCATION OF THE 1-OCTENE 3 PLANT (RED BLOCK) (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 20

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 20

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 21

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 21

APPENDICES

A ENVIRONMENTAL AUTHORISATION (17.2.4 GS 9)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

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

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

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

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

Environmental Authorisation (EA) (Reference number: 17.2.4 GS 9 issued on 23 November 2005) for the

period for the period December 2014 to February 2019.

1.2 1-OCTENE 3 PLANT (SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION) (AUTHORISATION NUMBER:

17.2.4 GS 9)

The Octene plant process several feed streams to produce 1- Octene. The plant consists of the following

sections:

— Train 1

— Train 2

— Train 3

1-Octene 3 Plant (Figure 1) has three different heptene-containing streams, which are fed to the Plant, namely:

— Octene Train 1 pre-fractionator overheads, which is acid-free;

— Octene Train 2 pre-fractionator overheads, which contains acids; and

— Hexene Train 1 and 2 de-heptaniser column distillate, which is acid-free.

The acid-containing feed from Octene Train 2 undergoes a water wash in order to extract acids prior to feed

fractionation. The acid-free streams, however, are routed directly to the feed fractionation section. In total there

are 10 processes in the plant, namely acid removal, feed fractionation, modified-rhodium hydroformylation,

hydrogenation, alcohol fractionation, dehydration, product work-up, product polishing and a hot oil system.

The output streams from 1-Octene 3 Plant are:

— 1-octene final product;

— By-product streams to the Synfuels Refinery; and

— By-product wash water stream to Chemical Work-up

The construction and operation of the 1-Octene 3 Plant was granted authorisation on 23 November 2005

(Reference number: 17.2.4 GS 9).


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Figure 1: Location of the 1-Octene 3 Plant (red block) (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

— Ensure the commitments contained in Condition 7.1 of the EA are completed, more specifically:

— “Records relating to the compliance and non-compliance to the conditions of this authorisation must

be kept in good order. Such records must be made available to this Department within five (05)

working days from the date of a written request by the Department for such records”.


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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (14 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Bronwyn Fisher conducted the site inspection on 14 March 2019. The findings and observations of the site visit

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

included:

— Nivashnee Francois (Production Area Manager Octene 3).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Solvents_EA_17.2.4.GS.9_1_Octene_3b_2005-11-23;

— SCO DQS ISO 14001 2015;

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

— 1.3.1 APPA Registration Review;

— 1.3.1 Environmental Legal Compliance;

— 1.3.1 Hazardous Chemicals and Substances;

— 1.3.3 Environmental Report-Noise Survey;

— 1.3.3 Health Impact Assessment;

— APPA Registration Certificate;

— AEL Sasol Solvents 0017-2015-F02 (2015);

— EA_EX Handover_SCO_Solvents_SAF_OC3;

— 3.2 Ambient Air Quality Data;

— Progress report for FY19 SCO Sampling Plan_04 - rev 20190219;

— SCO Atmospheric Emission Monitoring Schedule;

— 3.3 Process Description;

— 3.4_17.2.4.GS.9_1_Octene_3b_HIA_2007-07;

— Induction_Mod3_Environment;

— Induction_Mod4_ProcessSafetyManagement;


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— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod6_EmergencyManagement;

— Octene III_SAS490_2017-06-15;

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

— 3.8 Bundwall Procedure;

— 3.8 Operational Procedures;

— 3.9 Requirements for site location;

— SA Regional Procedure - Generic SHE Training.docx Rev.01 July 2018;

— Labour_SasolSupplierLocalRecruitment_2018-08;

— Labour_Sasol IRM Suppliers Industrial Relations Procedure;

— Air Quality Management;


— IWWMP SIC 2015 Final_2018-05-15;

— 5.1 Water Management;

— Environmental Complaints Register_2019-02-18; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).


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3.5 AUDIT TEAM

The Auditor, Bronwyn Fisher, was hosted by Broni van der Meer and Nivashnee Francois to whom we express

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

is provided below.

— Auditor: Bronwyn Fisher

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

Impact Assessments (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


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in connection with the services rendered, directly or indirectly by the use of the information contained in this

document.

This report must not be altered or added to without the prior written consent of the author. This also refers to

electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.

Similarly, any recommendations, statements or conclusions drawn from or based on this report must make

reference to this report. If this report is used as part of a main report, the report in its entirety must be included

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This authorisation refers only to the project specified above

and described in Record of Decision. Separate applications

must be lodged for any other development and /or activity at

or near the proposed development, which is covered by

Section 21 and 22 of the Act and Government Notice R1182

of 5 September 1997.

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

condition, and no subsequent development that would require

separate authorisation has commenced.

None.

1.02 Authorisation is only granted in terms of Section 22(3) of the

Environment Conservation Act, No. 73 of 1989 and does not

exempt the holder from compliance with any other relevant

legislation.

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.

1.03 Ensure that the necessary permits/approvals and/or service

and/or lease agreements, where it is relevant, from or

between the following institutions are in place:

1.3.1 CAPCO

1.3.2 DWAF

C Sasol provided the auditor with the proof of the APPA permit as

well as the AAPA permit review and the exiting AEL. In addition,

Sasol have engaged with the Department of Water and Sanitation

(DWS), formally known as DWAF, and have a Sasol Secunda

Integrated Water and Waste Management Plan (IWWMP) which

has been issued to DWS. A Health Impact Assessment was also

None.


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1.3.3 Provincial Department of Health

1.3.4 Department of Labour

undertaken for the 1-Octeme Train 3 and submitted to the

Department of Health as part of the EIA process.

Evidence:

— 1.3.1 APPA Registration Review;

— 1.3.1 Environmental Legal Compliance;

— 1.3.1 Hazardous Chemicals and Substances;

— 1.3.3 Environmental Report-Noise Survey;

— 1.3.3 Health Impact Assessment;

— APPA Registration Certificate;

— AEL Sasol Solvents 0017-2015-F02 (2015).

1.04 This Department may change and/or amend any of the

conditions in this authorisation if, in the opinion of the

Department, it is environmentally justified.

N/A Noted. Sasol have confirmed that, to their knowledge, no

conditions within the EA have been changed or amended.

None.

1.05 A copy of this authorisation must be available at the

premises of the applicant at all times and all staff,

contractors and sub-contractors shall be acquainted with the

contents of the authorisation.

C Copies of all authorizations and licences 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, Francois du Plessis

(Senior Manager of SAFOL & Octene 3 Production) and Willem

Jacobs (legal appointee of Solvents), were made aware of the EA

on in September / October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_SAF_OC3

None.

1.06 The contents of this authorisation must be known to all

interested and affected parties within five (5) days from the

date of authorisation.

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

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

None.

1.07 The applicant must advertise this ROD in a local newspaper

within five (05) days after the issue of this authorisation. N/A This condition is considered outside of the audit period


None.


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2. ESTABLISHMENT OF THE ENTERPRISE

2.01 This authorisation is repealed if the proposed 1-Octene Plant

has not been constructed within two (2) years from the date

of the authorisation.



None.

2.02 In case of closure of the site, this Department will evaluate

and monitor and approve the closure and rehabilitation plan

of the site.

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

redundant in the foreseeable future.

None.

3. CONSTRUCTION AND OPERATION

3.01 Any emissions levels of the pollutants (NOx, SO2,

H2S,VOC, PM2.5 and PM10) must be approved by CAPCO

before construction and operation commences.



None.

3.02 Monitoring of ambient air quality and characterisation of

pollutant concentrations for the entire Sasol Complex must

be carried out in order to assess the cumulative pollutant

concentrations and its impact on the receptor areas (Sasol

Complex, Secunda, eMbalenhle, etc.)

C Sasol makes use of an integrated approach to air quality

management as governed by National Environmental

Management: Air Quality Act. Sasol works closely with the local

authority and operates units in line with the relevant AEL and

minimum legal emission requirements.

The auditor was informed that continuous ambient air quality

measurements are done at two monitoring station (Secunda Club

and Langverwacht) which are close to the Secunda and

eMbalenhle residential areas respectively. Ambient air quality is

also managed within the Secunda Complex.

All monitoring data is stored on the Sasol IMS and on the

Sharepoint.

Evidence:

— 3.2 Ambient Air Quality Data

— Progress report for FY19 SCO Sampling Plan_04 - rev

20190219

None.


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— SCO Atmospheric Emission Monitoring Schedule

3.03 The dispersion potential of the pollutants must be measured

and characterised in various receptor areas (Sasol Complex,

Secunda, eMbalenhle, etc.

C Sasol makes use of an integrated approach to air quality

management as governed by National Environmental

Management: Air Quality Act. Sasol works closely with the local

authority and operates units in line with the relevant AEL and

minimum legal emission requirements.

The auditor was informed that the dispersion potential was

calculated as 5km and was included in the AEL application.

Evidence:

— 3.3 Process Description

None.

3.04 The adverse human effects that may be caused by the

proposed development including emissions of pollutants

must be documented and be made available to this

Department when needed.

C Sasol provided the auditor with the Health Impact Assessment,

dated July 2017. The impact assessment deals only with the 1-

Octene Train 3.

Evidence:

— 3.4_17.2.4.GS.9_1_Octene_3b_HIA_2007-07

None.

3.05 Workers must be made aware of the harmful effects of

emissions and must be trained on the dangers and safety

measures that must be taken should such a situation arise.

C Every person entering the Sasol site is subject to a SHE induction

process to ensure that all persons are familiar with the Safety,

Health & Environmental aspects and requirements of that

site/plant.

In addition, there is specific induction training for entry into the

Sasol Solvents Operational areas. No unaccompanied person or

unauthorised person will be allowed access to the solvents area

without undertaking solvents induction training. Sasol advised the

auditor that the training includes risks associated with working in

the solvents area, operational and emergency procedures.

Evidence:

— Induction_Mod3_Environment;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

None.


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— Induction_Mod6_EmergencyManagement.

3.06 All waste material must be placed in suitable containers and

disposed of in a suitable site C The auditor was advised that waste management is completed via

implementation of a Waste Management procedure (SGR-SHE-

000017 REV10) 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.

Waste Registers were made available to the auditor. A sample of

the registers specifically related to the facility operations were

checked during the audit. All hazardous waste streams are disposed

of at Holfontein Hazardous Landfill Site, with the exception of

certain spent catalysts which are collected by external service

providers (such as Golden Pond) and are processed to recover

metals from the spent catalyst.

Evidence:

— Octene III_SAS490_2017-06-15;

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09.

None.

3.07 A suitable ablution facility for workers must be provided

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


None.

3.08 Bunded areas and a fast drainage system must be put in place

to recover feed, chemicals, solvents, products, and by-

products during loading and off-loading

C The auditor noted that the plant, including the loading and off-

loading zone is sufficiently bunded with a fast draining system to

ensure that any spilled substances is cleared quickly. Sasol have

developed a bundwall procedure for the 1-Octene 3 Plant, which

has been reviewed by the auditor.

The 1-Octene 3 Plant is situated inside the Sasol Primary area,

which is served with an Oily Water Sewer (“OWS”) and a Clean

None.


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Stormwater Sewer (“CSS”), which comprises a set of open drains,

canals and pipelines to collect process effluents generated in the

different manufacturing processes, and to collect contaminated

surface run-off.

Evidence:


— 3.8 Operational Procedures;

— IWWMP SIC 2015 Final_2018-05-15;

An example of bunding at the loading/ off loading zone

at the Octene Storage Tank farm.


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An example of the OWS within the Octene plant.

3.09 Fire-fighting equipment must be installed according to

relevant legislation on the proposed site. C The auditor observed a number of fire hoses and extinguishers

located around the plant. In addition, Sasol have installed a fire

deluge system across the complex.

Evidence:

— 3.9 Requirements for site location

None.


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An example of a fire extinguisher within the Octene

plant.

3.10 Local labour and local materials, where possible must be

used. C Sasol advised the auditor that it has implemented 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. The procedure covers the preference for local

labour.

Evidence:

None.


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

July 2018;

— Labour_SasolSupplierLocalRecruitment_2018-08;

— Labour_Sasol IRM Suppliers Industrial Relations Procedure.

3.11 If any changes need to be made to the site and/or associated

infrastructure, this Department must be informed thirty (30)

days in advance, to be able to decide whether the changes

need authorisation.

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

development or associated infrastructure.

None.

4. AIR POLLUTION

4.1 The necessary air permits must be obtained and forwarded to

this department before the plant is put in operation. N/A — This condition is considered outside of the audit period

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

applicable.

None.

5. WATER POLLUTION

5.1 Any pollution of the surface as well as groundwater must be

prevented at all cost. C Sasol have an Integrated Waste and Water Management Plan

(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.

In addition, the plant was designed and operated in accordance

with the 1-Octene 3 Plant bundwall procedure.

Surface water monitoring is done on a weekly basis as well as real

time for the various Receiving Environmental Surface water

Monitoring points (RESMs).

Ground water monitoring is conducted biannually and quarterly.

The is no groundwater monitoring specific to the 1-Octene 3 Plant,

however there are 6 active boreholes located within the Primary

area which are utilised for monitoring. The auditor note a number

of exceedances in the November 2017 sampling run, however

None.


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these exceedances cannot be directly attributed to 1-Octene 3

Plant.

In addition, all staff, contractors and visitors are provided with

induction training, which includes pollution of the environment.

Evidence:


— IWWMP SIC 2015 Final_2018-05-15;

— 5.1 Water Management.

6. MONITORING

6.01 The Department of Health, DWAF, Department of Labour

and the CAPCO will further monitor compliance to this

authorisation.

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

condition.

None.

7. REPORTING

7.01 Records relating to the compliance/non-compliance with the

conditions of the authorization must be kept in good order.

Such records must be made available to this Department

within five (5) working days of the date on a written request

by the Department for such records.

N/A This audit represents the first required audit for this Exemption.

Prior to the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

7.02 Non-compliance with, or any deviations from the conditions

as set out in the authorisation, is regarded as an offence and,

after reasonable provision has been made for remedial

action, will be dealt with in terms of Sections 29, 30 and 31A

of the Act.

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

condition.

None.

7.03 Any complaints regarding the said development must be

brought to the attention of the Department within 24 hours

after receiving the complaint.

C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the 1-Octene 3 Plant for the audit period.

None.


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Evidence:

— Environmental Complaints Register_2019-02-18

7.04 A complaints register must be kept up to date for inspection

by members of this Department. C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the 1-Octene 3 Plant for the audit period.

Evidence:

— Environmental Complaints Register_2019-02-18

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

below.

Table 3: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 7 2 0 5

ESTABLISHMENT OF THE ENTERPRISE 2 0 0 2

CONSTRUCTION AND OPERATION 11 8 0 3

AIR POLLUTION 1 0 0 1

WATER POLLUTION 1 1 0 0

MONITORING 1 0 0 1

REPORTING 4 2 0 2

Total Count 27 13 0 14

Total Percentage 48% 0% 52%

Percentage Compliance with Applicable Conditions 100%


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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

Sectional Count Contribution

C

NC

N/A

13

0

14

Total Compliance

C

NC

N/A


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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

48%

0%

52%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17.2.4 GS 9)

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