SECUNDA SYNFUELS OPERATIONS: REFINERY ENVIRONMENTAL ...

SECUNDA SYNFUELS OPERATIONS: REFINERY

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

16.4.28.L 3 - SKELETAL ISOMERIZATION PLANT

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

16.4.28.L 3 - SKELETAL ISOMERIZATION PLANT

SECUNDA SYNFUELS OPERATIONS:

REFINERY

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref: 16.4.28.L3

Final – Compliance

Audit

EA Ref: 16.4.28.L3

Date April 2019 June 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 032 032

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

S I G N A T U R E S

PREPARED BY

-

Ziyaad Kadwa

Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

of their compliance with the conditions included in the Environmental Authorisation.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Refinery Production Senior Manager Helgard Theron

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: REFINERY

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Skeletal Isomerisation Plant (Exemption Number:

16.4.28.L3) ................................................................ 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 ... 16

5.1 Environmental Exemption .................................... 16


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 16

FIGURES

FIGURE 1: SSO – SKELETAL ISOMERISATION PLANT (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 17

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 17

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 18

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 18

APPENDICES

A ENVIRONMENTAL EXEMPTION (16.4.28.L3)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

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

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

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

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

Exemption (Reference number: 16.4.28.L3 issued on 04 April 2001) for the period December 2014 to February

2019.

1.2 SKELETAL ISOMERISATION PLANT (EXEMPTION

NUMBER: 16.4.28.L3)

Sasol received an Exemption for the development of the skeletal isomerisation plant, referred to as unit 90. The

objective of the establishment of the plant was to increase the production of 93 octane unleaded petrol by 30%

(at the time of issue of the Exemption).

The Exemption was issued on 04 April 2001, and it has been confirmed that the construction phase was

completed prior to December 2014 (i.e. outside the audit period).


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Figure 1: SSO – Skeletal Isomerisation Plant (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

— 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 Exemption; and,

— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically:

— “Records relating to the compliance/non-compliance with the conditions of the authorization must be

kept in good order. Such records should be made available to this Department within seven (7) days

from the date of the written request for such records from this Department”.


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

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

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

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (13 March 2019);

— Review of documentation relevant to the conditions of the Exemption (e.g. records,

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Ziyaad Kadwa conducted the site inspection on 13 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:

— Barries Barnard (Production Foreman).

It should be noted that due to the sensitive nature of the Skeletal Isomerisation Plant, limited photographs were

taken by the Production Foreman and supplied to WSP.

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Exemption: 16.4.28_L3_2001-04-04;

— SSO DQS ISO 14001 2015;

— EA_EX Handover_SSO_REF-West

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— SOX Folder;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.pdf;

— 1.7,1.8, 6.2 Scoping Report_28-02-2001;

— Environmental Complaints Register_2019-02-18;

— IWWMP SIC 2015 Final_2018-05-15;

— Induction_Mod6_EmergencyManagement;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

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

— Refining_2016-12-04;

— SCC_2016-07-27;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;


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

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the Exemption.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer and Barries Barnard, to whom we express

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

is provided below.

— Auditor: Ziyaad Kadwa

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

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

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

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

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

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

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

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


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

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

— Project Manager and Quality Assurance: Jenny Cope

Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental

Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;

undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a

range of sectors. Jenny’s recent experience includes completion and management of several pan-European

and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and

providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in

environmental consultancies and with a developer, giving context to understanding the practicalities of

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an

understanding of the Relevant Documents.

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

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

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

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

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

The findings, recommendations and conclusions given in this report are based on the author’s best scientific and

professional knowledge, as well as available information. This report is based on survey and assessment

techniques which are limited by time and budgetary constraints relevant to the type and level of investigation

undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if

and when new information may become available from on-going research or further work in this field, or

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts

no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or

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

document.

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

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

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

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

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This authorization refers only to the project specified and

described in the Record of Decision. Separate applications

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

or near proposed development, which is covered by section

21 and 22 of the Act and Government Notices R1182 and

R1183 of 5 September 1997.

N/A Noted. The activity remains as specified and no further alterations

or applications have been made.

None.

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

the Environment Conservation Act and does not exempt the

holder from compliance with any other relevant authorities.

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

audit.

The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

In addition, site is operated under ISO14001:2015, which requires

the compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

1.03 No development may take place in the area of concern

without the necessary permits/approvals and/or service

agreements from other relevant authorities.

C The Sasol Complex operates with a dedicated environmental and

legal team, and therefore ensures that they comply with applicable

legislation.

None.


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Sasol is in possession of an AEL (issued per business unit) and has

an updated Integrated Water and Waste Management Plan

(IWWMP) (updated 2018) that applies to the whole complex.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15; and,

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

1.04 Copies of documents mentioned under 1.3 above, must be in

possession of this Department before any construction may

commence.

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

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

None.

1.05 This Department may change, add or amend any of the

conditions mentioned in this authorization if, in the opinion

of the Department, it is environmentally justified.

N/A No changes or amendments have been communicated to Sasol by

the Department since issue of the Exemption.

None.

1.06 A copy of this authorization shall be available at the site

office at all times, and the staff and contractors shall be

conversant with its content.

C Sasol’s environmental team have soft copies of the EA and

where/when necessary, communicate any specific details or

requirements to the relevant business units.

Additionally, copies are maintained at the SHE: Environment

department and on SAP EC and SharePoint. Any specific

requirements are communicated during SHE induction training.

Sasol provided the auditor with the evidence that the responsible

persons, Helgard Theron (Senior Manager of Refining West

Production Area) and Willem Oosthuizen (legal appointee of

Refining), were made aware of the Exemption in October 2016.

Evidence:

— EA_EX Handover_SSO_REF-West

None.

1.07 The proposed mitigation measures, as set out in the Scoping

Report shall be strictly adhered to. C Sasol provided the auditor with a full copy of the Scoping Report,

dated 12 March 2001. The mitigation measures include:

— Update IWWMP to include new development;

None.


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— Investigate existing flare capacity to handle additional

emissions from skeletal isomerisation plant, and revise

atmospheric emissions certificate;

— Include the skeletal isomerisation plant in existing SSF

operating and safety procedure;

— Investigate risks associated with handling, storage and

distribution of chemicals as part of HAZOP study (pre-

construction);

— Awareness training regarding Sasol’s recruitment policy.

Based on the auditor’s review of the IWMMP, risk documentation,

recruitment documentation, and the AEL supporting

documentation that is in place, the auditor is satisfied that these

mitigation measures have been implemented.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

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

ERA_Published;

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

— Labour_Sasol SA_PreferentialRecruitPractices_2018-03-15

1.08 The content of the authorization must be made known to all

registered Interested and Affected Parties within 14 days of

the date of this document.



None.

2. ESTABLISHMENT OF THE DEVELOPMENT

2.01 This authorization is repealed if the construction has not

started within 3 years from the date of issue. N/A This condition is considered outside of the audit period


None.

2.02 If a decision is taken to discontinue the operation, sell or

transfer ownership of the infrastructure on the site in any N/A Statement noted by Sasol. Closure is not yet planned for and

according to Sasol, is estimated to occur around 2050.

None.


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way, this Department must be informed within twelve (12)

months prior to the date of implementing such a decision.

2.03 In the event of 2.2 above, this Department shall be notified

about rehabilitation plans. N/A Statement noted by Sasol. None.

3. CONSTRUCTION AND OPERATION

3.01 This development will take place according to the conditions

and requirements by the Department of Agriculture,

Conservation and Environment.



None.

3.02 If any change need to be made to the plan for the said

development or replacement of any of its structures, this

Department must be informed within thirty (30) days in

advance, to decide whether such changes will need

authorization or not.

N/A The activity remains as specified and no further alterations or

applications have been made.

None.

4. WATER POLLUTION

4.01 It is the responsibility of SSF and the contractor on site to

ensure that there is no surface as well as ground water

pollution.

C Surface water is managed at the site; the tanks and loading areas

are within hard surfaced and bunded areas that drain to an enclosed

system that pumps the water for reprocessing.

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

time for the various Receiving Environment Surface Monitoring

points (RESMs).

Ground water monitoring is conducted biannually and quarterly.

There is no groundwater monitoring specific to the Skeletal

Isomerisation unit, however there are 6 active boreholes located

within the Primary area which are utilised for monitoring. The

auditor note a number of exceedances in the November 2017

sampling run, however these exceedances cannot be directly

attributed to the Skeletal Isomerisation unit.

None.


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The latest IWWMP as well as surface and ground water

monitoring results were provided to the auditor as evidence. The

nearest surface water quality monitoring locations (RESM-6 and

RESM-7) showed results within limits.

No environmental incidents associated with the site have been

noted for the audit period.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15; and,

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-

31.pdf;


— Environment Impact register_ New FY19_2019-02-18

4.02 In case of non-compliance with regulations, the burden of

proof remains with SSF and/or with the relevant authority. N/A Statement noted by Sasol. None.

5. WASTE MANAGEMENT

5.01 All waste which will be generated during construction phase

of the Skeletal Isomerization unit and associated activities

will be disposed of in a registered landfill and to the

satisfaction of this Department and/or relevant authority.



None.

5.02 Any hazardous waste that may result from the construction

and/or operation of the said unit shall be disposed of in an

environmentally acceptable manner as directed by this

Department and/or other relevant authority.

C The construction related requirement of this condition is

considered outside of the audit period (construction pre-2014). It is

therefore considered not applicable.

During normal operation, solid catalyst is produced that is captured

within enclosed skips. This waste is not discarded but is recovered.

A small amount of contaminated materials and general waste is

generated at the Skeletal Isomerization unit and handled according

to Sasol’s Waste Management Procedure.

None.


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Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Refining_2016-12-04; and,

— SCC_2016-07-27

Waste Management Procedure_SGR-SHE-000017_Rev10_2017-

09.

6. RISK ASSESSMENT

6.01 All employees who will be working in the construction and

operation of the Skeletal Isomerization unit will be well

equipped with the company's emergency procedures for any

accident that may be experienced on site.

C Construction was completed prior to this audit period.

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.

Module 6 (Emergency Management) includes details regarding the

processes and procedures to be followed in the event of an

emergency.

Evidence:

— Induction_Mod6_EmergencyManagement.

None.

6.02 SSF must ensure that all issues and concerns that have been

raised by the I&APs are addressed as stated in the Scoping

Report.



None.

7. AIR POLLUTION

7.01 According to specification by the relevant Authority. C Gaseous emissions are routed to the pre-existing flare (authorised

outside of this Exemption).

Sasol is in possession of an AEL (issued per business unit) and has

an updated Integrated Water and Waste Management Plan

None.


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(IWWMP) (updated 2018) that applies to the whole complex. The

monitoring systems and campaigns run were shown to the auditor

and noted to be aligned with the requirements of the AEL and

IWWMP.

The incidents registers for 2015- 2017 and 2017- 2019 do indicate

any emission exceedances from the plant.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;


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

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

8. MONITORING

8.01 It is the responsibility of the operator of the development to

install monitoring systems that will detect any form of

surface as well as ground water pollution, and other negative

environmental impacts.

C Surface water is managed at the site; the tanks and loading areas

are within hard surfaced and bunded areas that drain to an enclosed

system that pumps the water for reprocessing.

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

time for the various Receiving Environment Surface Monitoring

(RESMs).

Ground water monitoring is conducted biannually and quarterly.

The is no groundwater monitoring specific to the Skeletal

Isomerization unit, however there are 6 active boreholes located

within the Primary area which are utilised for monitoring. The

auditor note a number of exceedances in the November 2017

sampling run, however these exceedances cannot be directly

attributed to Skeletal Isomerization unit .

The latest IWWMP as well as surface and ground water

monitoring results were provided to the auditor as evidence.

The incidents registers for 2015- 2017 and 2017- 2019 do indicate

any significant groundwater or surface water incidents from the

plant.

None.


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Evidence:

— IWWMP SIC 2015 Final_2018-05-15;


— Environment Impact register_ New FY19_2019-02-18;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31

8.02 The Department must be granted access to the property

during any reasonable time to investigate any possible

environmental impacts that may be caused by the operation

of this development.

N/A No such requests have been received by Sasol from the

Department (specific to this Exemption) for this audit period.

None.

9. REPORTING

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

conditions of the authorization must be kept in good order.

Such records should be made available to this Department

within seven (7) days from the date of the written request for

such records from this Department.

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.

1.01 Non-compliance with or deviation from the conditions of

this authorization as set out in the Record of Decision will be

regarded as an offence, and after reasonable provision has

been made for remedial action, will be dealt with in terms of

section 29, 30 and 31A of the Act.

N/A Statement noted by Sasol. None.

9.03 Any complaint regarding the said development should be

thoroughly investigated and addressed to the satisfaction of

all parties concerned. Copies of such a complaint must be

forwarded to this Department within 24 hours.

C All environmental complaints received from interested and

affected parties, both internal and external to the organisation, are

recorded in a complaints register that is maintained by Sasol’s

Environmental Department. Complaints are investigated and

reported in line with the procedure (SGR-SHE-000022)) and as per

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

None.


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The complaints register (FY 2014-2019) was checked and no

complaints related to the Skeletal isomerisation Plant were

recorded for this audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITIONS 8 3 0 5

ESTABLISHMENT OF THE DEVELOPMENT 3 0 0 3

CONSTRUCTION AND OPERATION 2 0 0 2

WATER POLLUTION 2 1 0 1

WASTE MANAGEMENT 2 1 0 1

RISK ASSESSMENT 2 1 0 1

AIR POLLUTION 1 1 0 0

MONITORING 2 1 0 1

REPORTING 3 2 0 1

Total Count 25 10 0 15

Total Percentage - 40% 0% 60%

Percentage Compliance with Applicable Conditions 100%


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Figure 2 illustrates the number/count contribution of the findings of the Exemption per section while Figure 3

presents the total proportion of compliance for the facility.

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

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

0123456789

Sectional Count Contribution

C

NC

N/A

10

0

15

Total Compliance

C

NC

N/A


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

the total percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

40%

0%

60%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION

(16.4.28.L3)

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