ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL … · 7/22/2019 · to a fine ash dam (FAD). Four...

SASOL SYNFUELS OPERATIONS: WATER AND ASH

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

14.24 EV 2 - FINE ASH DAM 5

22 JULY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

14.24 EV 2 - FINE ASH DAM 5

SASOL SYNFUELS OPERATIONS: WATER

AND ASH

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JULY 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

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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: 14.24 EV 2

Draft v2 for Review –

Compliance Audit

EA Ref: 14.24 EV 2

Final – Compliance

Audit

EA Ref: 14.24 EV 2

Date April 2019 June 2019 July 2019

Prepared by Tutayi Chifadza Tutayi Chifadza Tutayi Chifadza

Signature

Checked by Ashlea Strong Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 036 036 036

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

REPORTS\036_SSO_WA_EA_14.24 EV 2\01 Draft report

S I G N A T U R E S

PREPARED BY

Tutayi Chifadza

Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

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

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

Management Plan.

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

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

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

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

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

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

SASOL

SHE: Environmental Compliance

Specialist

Broni van der Meer

Water and Ash Production Senior

Manager, Secunda Synfuels Operations

Timothy Ndlovu

WSP

Associate Jenny Cope

Lead Auditor Ashlea Strong

Consultant Tutayi Chifadza

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

WSP July 2019

TABLE OF CONTENTS

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

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

1.2 Fine Ash Dam 5 (Authorisation Number: 14.24

EV2) ........................................................................... 1

2 AUDIT SCOPE ........................................... 3

3 AUDIT METHODOLOGY ........................... 4

3.1 Audit Checklist ........................................................ 4

3.2 Site Inspection ......................................................... 4

3.3 Documentation Considered ................................... 5

3.4 Audit Compliance Assessment .............................. 5

3.5 Audit Team ............................................................... 6

3.6 Assumptions and Limitations ................................ 7

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

5 SUMMARY OF THE AUDIT FINDINGS ... 32

5.1 Environmental Authorisation ............................... 32

5.2 Environmental Management Plan ........................ 35


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TABLES

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

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

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

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 32

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 35

FIGURES

FIGURE 1-1: FINE ASH DAM 5 FACILITY (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 4-1: INDIGENOUS TEST TREE SPECIES TO BE USED FOR REHABILITATION AROUND FAD 5 ................................................... 11

FIGURE 4-2: STREAMS AROUND FAD 5........ 13 FIGURE 4-3: STORMWATER CHANNEL......... 14 FIGURE 4-4: DUST MONITORING

LOCATIONS ................................ 22 FIGURE 5-1: NUMBER/COUNT

CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 33

FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 33

FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 34

FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 34

FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 35

FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 36


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FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 36

FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 37

APPENDICES

A ENVIRONMENTAL AUTHORISATION (14.24 EV 2)


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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: 14.24 EV 2 issued on 15 September 2000) as well as the

associated Environmental Management Plan (dated 2000) for the period December 2014 to February 2019.

1.2 FINE ASH DAM 5 (AUTHORISATION NUMBER: 14.24

EV2)

The Sasol plant produces ash from gasification and burning of coal in the production stream. The ash from the

gasifiers and steam plants is combined and treated in the ash handling plants. The ash is transported in a water

stream from the point of origin and moves over a set of screens that separate the coarse ash particles from the

slurry. The coarse ash is deposited on the existing coarse ash heaps. The finer ash particles that pass over the

screens get concentrated in a gravity thickener where the bulk of water is removed as a clear overflow and is re-

used as a carrier for ash. The bottom fraction of the thickener is slurry of fine ash and water which is pumped out

to a fine ash dam (FAD). Four FADs were on the site with two barely operating around the year 2000. A project

to obtain authorisation for a fifth FAD was commenced. The new FAD would treat a fine ash slurry of 1 580 m3/h

by settling out the solid ash at a rate of 470 m3/h, with the water to be returned to the ash water system within the

Sasol plant. The Environmental Directorate of the Mpumalanga Department of Agriculture, Conservation and

Environment gave the authorisation for the construction of the dam on 15 September 2000 with reference number

14.24 EV 2. The dam is located on Portions 5, 8, 14 of the farm Goedehoop 290 IS and Portions 1, 2, 5, 6, 9, 10,

11 of the farm Twistdraai 285 IS, Secunda.

Fine ash is transferred via piping approximately 40 km in length from the Inside Ash facility to FAD 5. The slurry

is pumped at a rate of 320 m3/h and is pumped via seven pumping points on the paddocks on FAD 5. When the

paddock is full, pumping is moved to the next pumping point on another paddock and the ash on the first paddock

is left to settle and dry out. Water is decanted from FAD 5 into the clear ash effluent dam systems (CAE). The

location of FAD 5 is shown in Figure 1-1 below.


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Figure 1-1: Fine Ash Dam 5 Facility (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

and where applicable, the closure plans 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;

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

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

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

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

from the date of written request for such records by the 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 EA and associated EMPr conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (26 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Tutayi Chifadza conducted the site inspection on 26 March 2019. The findings and observations of the site visit

are recorded and summarised in Section 4 with evidence included in Table 2 and


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Table 3. Key personnel interviewed included:

— Rouxtjie Strydom (Area Manager Production);

— Sipho Mahlangu (Production Foreman); and

— Nonhlanhla Nhlapo (Senior Process Technician).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— SSO DQS ISO 14001 2015;

— Amended Waste Management Licence ¬ Waste Ash Site;

— Bi-Annual External Waste Management Licence Compliance Report – Waste Ash Disposal Site_September

2018;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4;

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

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20;

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— Compliance_Air_Secunda Complex;

— Environmental emergency procedure (Rev 6): SGR-SHE000023;

— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-000031);

— External WAS Audit_2018-09-18;

— Environmental Complaints Register (2008-2019);

— Compliance_Complaints_Secunda Complex

— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01

— Site photos; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and


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Table 3). The checklist included the conditions and associated requirements as specified in the EA and associated

EMPr.

Where conditions are not directly specified within documentation, for instance within older EMPs that were

compiled and submitted as Aspect Registers, auditable conditions have been defined by utilising either mitigation

measures or aspects that were defined within the EMPr. In some instances this has required the minor re-wording

of original text contained within the EMPr, in order to specify an auditable condition. WSP has used its

professional expertise and independence to ensure that such interpretation of wording is both auditable and

balanced.

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

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

associated target completion dates included.

It should be noted that some of the EA and associated EMPr conditions were apportioned according to the elements

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

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

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

development of focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

to the requirements of the EA and associated EMPr. Non-complaint conditions are given target

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Auditor, Tutayi Chifadza, was hosted by Broni van der Meer, Rouxtjie Strydom, Sipho Mahlangu and

Nonhlanhla Nhlapo to whom we express our gratitude for their time and attention during our visit. A brief

summary of the external auditors’ experience is provided below.

— Auditor: Tutayi Chifadza

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

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

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

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

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


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

for conducting WUL and Waste Management Licence audits.

— Lead Auditor and Quality Assurance: Ashlea Strong

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

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

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

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

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

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

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

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

process.

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts no

liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

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

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

document.

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

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

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

report. If this report is used as part of a main report, the report in its entirety must be included as an appendix or

separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.1 This Authorisation 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 plant, which is covered by Section 21 and 22 of the

Environment Conservation Act, No. 73 of 1989 Act and

Government Notice R1182 and 1183 of 5 September 1997.

N/A Noted. None

1.2 Authorisation is only granted in terms of Section 22 of the Act

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.

Evidence:

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27

— SSO DQS ISO 14001 2015

None

1.3 No development may take place on the area of concern

without the necessary permits/approvals and/or service and/or

lease agreements from other relevant authorities.

C The site was approved for development when an EA was issued by

the Provincial Department on 15 September 2000 with 14.24 EV 2

as the reference number. A waste management licence (WML) was

issued on 4 April 2013 for the ash handling facility with reference

number 12/9/11/L1/6. Four variations on the amended WML were

further issued, which included:

SSO_WA_14.24EV2_FAD5_2000-09-15;

Waste Licence Variation for height Increase of Fine Ash Dam

5 (Reference Number: 12/9/11/L1/6/V2);

None


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Waste Licence Variation for condition 4.7 (Reference Number:

12/9/11/L1/6/V2);

Waste Licence Variation for condition 4.1 and 4.9 (Reference

Number: 12/9/L1/6/R1/V5);

Waste Licence Variation for condition 1.1.2, 3.2, 4.5, 6.2.1.1,

6.2.2.2, 6.2.1.3, 6.2.2.1, 6.2.3.1, 6.2.4.1, 6.2.4.3, 6.2.4.2,

6.2.5.1 and 6.2.6.1 (Reference Number: 12/9/L1/6/V3 dated 28

March 2018).

A copy of the WML and the September 2018 compliance audit

report by SRK Consulting was available for review.

Evidence:

— Amended Waste Management Licence Waste Ash Site

— Bi-Annual External Waste Management Licence Compliance

Report – Waste Ash Disposal Site_September 2018

1.4 Copies of relevant documents mentioned in 1.3 above, must

be forwarded to this Department within three (3) months of

this issuing of this Authorisation.

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

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

None

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

conditions in this authorisation if, in the opinion of the

Department, it is environmentally justified.

N/A Noted. None

1.6 The development must comply with all mitigatory measures

as set out in the permit application documents submitted to the

Department.

C The EMP is part of the documentation that was submitted during the

permit application process and has been audited as part of this scope.

No non-compliances were observed during this audit.

None


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2. ESTABLISHMENT OF THE ENTERPRISE

2.1 This Authorisation is repealed if construction has not been

started within two (2) years from the date of this

Authorisation.



None

2.2 Where possible, the development should proceed from one

side of the site to the other, rather than affecting to entire site

simultaneously.

C Sasol do develop from one side of the site to the other, rather than

affecting to entire site simultaneously as required.

The auditor was informed that there are seven pumping points to

each paddock in FAD 5 and after each paddock is filled, it is left to

dry and pumping is shifted onto the next paddock in a circular

manner until a full revolution is completed and back to the first

paddock so as to grow the site evenly. This was confirmed during

the site walk.

None

2.3 Topsoil and subsoil removed during the site preparation and

construction should be stored separately. Topsoil that cannot

be used for onsite revegetation should be used at alternative

sites.



None

2.4 Where possible the sides and surrounds of the dam should be

revegetated with indigenous plant species that perform an

adequate stabilising function. Where this is not possible, non-

invasive exotic species should be used.

C The sides and surrounds of the dam are currently naturally

revegetated with both indigenous and exotic species. The exotic

species are managed at least once a year by a contractor. Sasol have

been planting several species around the coarse ash dam facility over

the last few years to test which ones grow best as part of a study

conducted by a local university. The best species will then be

prioritised for revegetation around all ash dams when rehabilitation

is done.

The auditor observed revegetation during the site walkover.

Evidence:

None




Figure 4-1: Indigenous test tree species to be used

for rehabilitation around FAD 5

3. WATER POLLUTION AND MANGEMENT

3.1 Prevention of groundwater pollution should receive the

highest priority. C There are 21 groundwater monitoring boreholes for

FAD 5 & 6. Three groundwater monitoring reports by JMA

Consulting dated November 2017, May 2018 and August 2018 by

JMA Consulting were available for review. Multiple boreholes were

identified as reflective of ‘downstream of Fine Ash Dam 5’, and

were reported upon for May 2017, August 2017, November 2017

and August 2018 sample runs. Based on the analytical results, the

water contained in FAD 5 is potentially negatively impacting on the

groundwater resource.

The water in the ash handling areas is controlled in a closed circuit

via cement channels and is reused in the system as much as possible.

The channels are designed to prevent groundwater pollution.

In order to remain compliant

with this condition going

forwards, Sasol must

continue to place highest

priority on the prevention of

groundwater pollution by

investing in future-available

mitigation techniques, and

researching best available

technology.

Target period:

Long term




Interception drains around FAD 5, Coarse Ash Dump and the Black

Products area are visible.

The entire Outside Ash area is regarded as a “dirty area”, and

contaminated run-off is mostly contained within this area by means

of a stormwater berm and trench along the southern, south-western

and western boundary.

It has been evidenced to the auditor that prevention of groundwater

pollution is receiving high priority, with significant investment

made in pollution mitigation measures. Sasol is taking practical

steps in order to combat the legacy of limited containment structure

practices of the past. This condition has been marked compliance

only on the basis that such investment in pollution prevention has

been made, as deterioration in water quality has been noted.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-

20

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

20

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31

3.2 Deep seepage interception drains into intact sedimentary rock

should be excavated and constructed to the east and west of

the fine ash dam to prevent contaminated seepage from

reaching the drainage features to the east and west of the fine

ash dam and its return water dams.

C Sasol completed Phase 1 of the Seepage study undertaken to reduce

seepage. Recommendations made during the Phase 1 study are being

implemented as part of Phase 2 and interception drains have been

installed around FAD 5. An EA for the installation of seepage

reduction and stream flow monitoring weirs (Ref:

MP/EIA/0000524/2012) was issued in December 2013. The

interception drains were observed during the site walk.

None

3.3 No development, including roads, waste disposal and

construction should be placed within 100m of drainage lines,

and in particular the Groot Bossiespruit tributary.

C No development of roads and waste disposal is within 100m of

drainage lines. The map showing streams in the IWWMP was

reviewed and showed that the closest channel was the Brand Spruit

and it was at least 100m from the closest point of development

None




around FAD 5. The Groot-Bossie Spruit was more distant, as

indicated in the image below.

Evidence:

Figure 4-2: Streams Around FAD 5

3.4 Proper drainage for storm water run-off should be put in place. 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.

The dam has channels around it, and the water is guided to its return

water dam (RWD). Water from FAD 5’s RWD is pumped to the

channels which drain to Evaporation Dam 2 Interception drains have

been installed around FAD 5.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4

None




Figure 4-3: Stormwater channel

3.5 Adhere to any other water management conditions as set out

by DWAF or any other relevant authority. C The Synfuels site as a whole has a WUL. The IWWMP indicates

that “A Water Use Licence (“WUL”) was issued on 21 November

2008 (“2008 WUL”) in terms of Chapter 4 of the National Water

Act 36 of 1998 (“NWA”), and an amendment to this WUL has been

issued on 8 January 2010 (“2010 WUL Amendment”) to authorise

water uses associated with the industrial operations at the SIC.

Condition 5 in the 2008 WUL indicates that the WUL will be

reviewed every three (3) years, and a review was thus initiated

during 2014. The 2010 WUL Amendment specify in condition 12.1

that an Integrated Water and Waste Management Plan (“IWWMP”)

must be submitted for approval when the WUL is being reviewed.”

The site is licensed under the National Environmental Management

Waste Act (NEM:WA) for its operations and the Synfuels facility

has a site-wide WUL. Sasol amended the WML for the site so that

the variables for surface and groundwater monitoring would match

None




those in the WUL to ensure that water management is conducted as

required by the Department of Water and Sanitation.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

4. AIR POLLUTION

4.1 During the construction phase the generation of dust from

earth works activities should be controlled by regular spraying

of haul routes and working areas.



None

4.2 It is recommended that a dust monitoring plan be developed

using, as a basis, simulation patterns shown in the report

submitted to this Department. The monitoring should include

both air concentrations and depositions for a preferred period

of one year or more.

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.

Sasol AEL and postponement applications as well as Greenhouse

Gas emission plan and Offsetting plan are stored on IMS and on the

Sharepoint.

The site does not require and AEL that is monitored by authorities,

however, air pollution measures are in place to manage air pollution

particularly related to dust. Sasol uses the Fugitive Emissions

Management Plan to manage any air quality issues related to the

Synfuels facility including FAD 5. Dust suppression is regularly

conducted on the site, especially at locations trucks are actively

moving.

Evidence:

— Fugitive Emission Monitoring Plan_2018-10-18 updated

— Compliance_Air_Secunda Complex

None




4.3 A dust management plan should also be developed as part of

environmental management programme and should remain

operative throughout the life of the dam.

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.

Sasol AEL and postponement applications as well as Greenhouse

Gas emission plan and Offsetting plan are stored on IMS and on the

Sharepoint.

The site does not require and AEL that is monitored by authorities,

however, air pollution measures are in place to manage air pollution



Synfuels facility including FAD 5. Sasol Secunda Operations has a

well established and an ongoing dust fallout monitoring program.

Dust suppression is regularly conducted on the site, especially at

locations trucks are actively moving.

Evidence:



None

4.4 The investigation on air pollution, in the area found that the

presence of a water layer on Black Products Ponds Nos. BP7,

BP 8 and BP 13, significantly reduced the emissions of

volatile organic compounds. Due to the significant benzene

levels in the area, it is also recommended that this pollutant be

monitored for verification purposes.

C Sasol uses the Fugitive Emissions Management Plan to manage any

air quality issues related to the Synfuels facility including FAD 5.

The benzene monitoring is conducted as part of the volatile organic

compounds (VOC) monitoring around the site. VOC emissions

measured at the monitoring sites reflect the contribution of all the

sources within the Synfuels operations.

Evidence:


None




5. RISK MANAGEMENT

5.1 All employees who will be working in the new fine ash dam

should be aware of emergency procedures in case of any

accident.

C Sasol have an environment emergency procedure (SGR-

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

environmental incident procedure process flow that indicates steps

taken when an incident occurs.

Sasol reported that the said procedure is included in Induction

training. Further to this, Sasol undertake monthly emergency

scenario drills according to the EPP.

Evidence:

— Environmental emergency procedure (Rev 6): SGR-

SHE000023

— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-

000031)

— External WAS Audit_2018-09-18

None

6. MONITORING

6.1 Any possible form of groundwater pollution and to ensure

maintenance of the acceptable ground and/or surface water

quality.

N/A This condition is considered not auditable. Further comment is made

on groundwater quality against Condition 3.1 of the EA and 3.14 of

the EMPr.

None

6.2 This Department must be granted access to the property at any

reasonable times to investigate any possible environmental

impacts that may be caused by the operation of the said new

fine ash dam.

C The auditor was informed that the Department has been granted

access on a number of occasions, however, no reports have been sent

to provide feedback following their site visits.

None

7. REPORTING

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

conditions of the authorisation must be kept in good order.

Such records must be made available to this Department

N/A There is no set requirement for conducting audits against the

conditions of this licence. No previous audits over the last 5 years

Ensure this current audit is

kept in good order so that it




within seven (7) workdays of the date of request by this

Department.

were available for review and there has been no indication that the

Department requested any records.

is readily available on

request in the future.

Target period:

Long term

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

as set out in the Record of Decision is regarded as an offence

and, after reasonable provision has been made for remedial

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

of the Act.

N/A Noted. None

7.3 Any complaint regarding the said development must be

thoroughly investigated and addressed to the satisfaction of all

parties concerned. Copies of such complaints must be

forwarded to this Department within forty-eight (48) hours of

such a complaint.

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 available and the Environmental

department. Complaints are investigated and reported in line with

the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders

There have been no complaints received regarding the ash handling

facility since the operations commenced. The environmental

complaints register was available for review and contained

complaints for all business units dating back from 2008.

Evidence:

— Environmental Complaints Register_2019-02-18


— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01

None



Table 3: Audit Findings – Environmental Management Plan


1. CONSTRUCTION AND PRE-COMMISSIONING

1.1 ROD Condition: During the construction phase the generation

of dust from earth works activities should be controlled by

regular spraying of haul routes and working areas.



None

1.2 Strategy for employment to be completed of using local

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


None

1.3 Legal permit requirements to be investigated and expressed in

terms of a schedule for permit application as well as the

possible economic impact if such a permit is not obtained.



None

1.4 ROD Conditions to be implemented by SSF Environment and

Project Manager / Engineer. N/A This condition is considered outside of the audit period


None

2. COMMISSIONING AND START-UP

2.1 Transport of chemicals: The possible storage, loading and

handling of chemicals for cleaning of pipelines should be the

responsibility of the contractor. The disposal of such

chemicals must be coordinated with the contractor (contract)

and SSF Environment.



None

2.2 Welding. HS / occupational hygiene requirements to be

obtained and observed (contractor). N/A This condition is considered outside of the audit period


None

2.3 To be co-ordinate with SSF Environment. Confirm

availability of a suitable site for storage of topsoil and other N/A This condition is considered outside of the audit period


None




excavated material. Re-usable excavated material to be used

on site.

2.4 Contractor to responsibly dispose of building rubble and

construction waste at a suitable waste facility. Requirements

to be included in the contractors contract.



None

2.5 Confirm availability. Confirm disposal route to return water

dam. (applicable to firewater, water used for hydro-testing and

water used for flushing)



None

2.6 Local construction workers to be used where possible. A

strategy for the use of local people is to be completed. Number

of required additional personnel to be confirmed.



None

2.7 Dolerite to be mined / obtained from a licensed site only. If

this is also the responsibility of the contractor, he should be

informed in his contract.



None

2.8 H&S aspects and environmental requirements to be

communicated to construction personnel. To be included in

contract. No surface water contamination resulting from the

use of concrete may be allowed.



None

2.9 Confirm availability of electricity supply. N/A This condition is considered outside of the audit period


None

2.10 HS / occupational hygiene requirements regarding noise

pollution to be obtained and observed. N/A This condition is considered outside of the audit period


None

2.11 Impact on operations regarding optimum use of resources to

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


None




3. OPERATING, MAINTENANCE AND SHUTDOWN

3.1 Disposal / routing of spent chemicals for

cleaning/pickling/passivation and desicants, solvents and

catalysts.

Discarding of spent catalyst. Current disposal route to be

confirmed. Possible impacts on water and soil to be mitigated.

N/A FAD 5 is only used for fine ash disposal and not for disposal of spent

catalyst.

None

3.2 Stormwater management (routing of on-spec/contaminated

stormwater).

ROD condition: Proper drainage for storm water runoff

should be put in.

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.

The dam has channels around it and the water is guided to its return

water dam (RWD). Water from FAD 5’s RWD is pumped to the

channels which drain to Evaporation Dam 2 Interception drains have

been installed around FAD 5 as shown in Figure 4-3.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4

None

3.3 Dust emissions to be investigated.

ROD conditions: Although the predictions on Air Pollution

indicate relatively low particulate air impact, it is

recommended that dust control measures must nevertheless be

implemented. This will typically include cleaning the paved

road surface to the Black Product Waste Pond, water spray on

unpaved roads and a water spray programme on fine and

coarse ash dams during dry winter periods, especially August

and September.




locations trucks are actively moving.

Dust suppression is regularly conducted on the site via spraying of

water on the road surfaces along the dam, especially at locations

trucks are actively moving. Management of this activity is governed

by the Fugitive Emissions Management Plan for the Synfuels

facility.

Evidence:

None






3.4 ROD Condition: It is recommended that a dust monitoring

plan be developed using as a basis simulation patterns shown

in the report submitted to this Department. The monitoring

should include both air concentrations and depositions for a

preferred period of one year or more.




locations trucks are actively moving. Furthermore dust monitoring

is conducted at 3 locations around FAD 5 (dust buckets 1 – 3) as

shown below.

Evidence:



Figure 4-4: Dust monitoring locations

None

3.5 ROD Condition: A dust management plan should also be

developed as part of the environmental management

programme and should remain operative throughout the life

of the dam.

C Air pollution measures are in place to manage air pollution



Synfuels facility including FAD 5. Dust suppression is regularly

conducted on the site, especially at locations trucks are actively

None




moving. Furthermore dust monitoring is conducted at 3 locations

around FAD 5 (dust buckets 1 – 3) as shown in Figure 4-4 above.

Evidence:



3.6 ROD Condition: The investigation on Air Pollution in the area

found that the presence of a water layer on Black Product

Ponds No5 BP 7, BP 8 and BP13, significantly reduced the

emissions of volatile organic compounds. Due to the

significant benzene levels in the area it is also recommended

that this pollutant be monitored for verification purposes.



The benzene monitoring is conducted as part of the volatile organic

compounds (VOC) monitoring around the site. VOC emissions

measured at the monitoring sites reflect the contribution of all the

sources within the Synfuels operations.

Evidence:


None

3.7 All relevant emergency plans to be completed / updated and

communicated with SSF Environment. Issues to be included

are surface water, soil, ground water, air, economy and

impacts on humans.








Evidence:


SHE000023


000031)


None

3.8 ROD Conditions (key factor for the decision): In the report

on: Predicted Air Pollution from current and projected ash

disposal site" it is specifically recommended that the

N/A Noted. FAD 5 is still operational and there is no set date for

decommissioning of the site.

None




development of the new Fine Ash dam no 5 proceed as

planned, but that strict adherence to the rehabilitation

programme be followed.

3.9 ROD condition (key factor for the decision): It is

recommended in the study on biodiversity assessment of the

proposed Fine ash Dam that the Fine Ash dam drainage

system, include the return water pond should be isolated from

surface and ground water by impermeable barrier, the

drainage system should be adequate to operate under worst

case storm.

C Channels that collect water and drain it towards the RWD are

present as required surround FAD 5. The RWD is isolated from

surface and ground water by an impermeable clay barrier. The four

dams around the ash facilities are designed to contain water

generated on the site as they cascade into each other as well as the

holding dams so as to prevent overflows.

The following “as-built drawings”: indicate the facility’s ability to

cater to the 1:100 year flood event:

— FAD 5 General Arrangement (Jones and Wagner Ref: 7338-01,

02;

— SK03, Sasol drawing Ref: 4560.M8-03-A0-0501 and 0502);

— BP Dam “as-built drawing” (Jones and Wagner No. 9253-00-

027, March 2005, inclusive of Figures A and B cross sections);

and

— Sasol FAD 5 Penstock Design Rev 01a.

The Sasol Secunda FAD 4 & 5 Monthly Monitoring Report for June

2018 noted the FAD 4 and 5 operated with a freeboard of 1.137m

and 1.653 respectively during July 2018. It was noted that the actual

freeboard at both FAD 4 and 5 was within the minimum required

freeboard (as per this condition) for July 2018.

The penstock at FAD 5 was upgraded to ensure effluent arising

therefrom is adequately contained in the drain/trench leading into

the RWD and/or secondary containment reticulation system.

Evidence:


02

— SK03, Sasol drawing Ref: 4560.M8-03-A0-0501 and 0502)

None





027, March 2005, inclusive of Figures A and B cross sections)


3.10 ROD Conditions (key factor for the decision): Contaminated

run-off from the sides of the ash dam will be contained in run-

off paddocks adjacent to the toe of the dam. These paddocks

are sized to retain the run-off from a 1 in 100-year storm of 24

hour.

C The penstock at FAD 5 was upgraded to ensure effluent arising from

there is adequately contained in the drain/trench leading into the

RWD and/or secondary containment reticulation system.

Evidence:


02

— SK03, Sasol drawing Ref: 4560.M8-03-A0-0501 and 0502)


027, March 2005, inclusive of Figures A and B cross sections)


None

3.11 ROD condition (key factor for the decision): A cut-off canal

will be constructed along the upstream boundary of the dam

to intercept all run-off and to divert it to the natural drainage

features to the west and east. Two cut-off trenches will be

excavated within the dam area.






MP/EIA/0000524/2012) was issued in December 2013. FAD 5 has

the cut-off canal along the upstream boundary as required in order

to intercept all run-off and to divert it to the natural drainage features

to the west and east. This water is then captured in the RWD and

thus is prevented from flowing into the surrounding environment.

The interception drains were observed during the site walk.

None

3.12 ROD condition: Adhere to any other water management

conditions as set out by DWAF or any other relevant

authority.

C The Synfuels site as a whole has a WUL. The IWWMP indicates

that “A Water Use Licence (“WUL”) was issued on 21 November

2008 (“2008 WUL”) in terms of Chapter 4 of the National Water

Act 36 of 1998 (“NWA”), and an amendment to this WUL has been

issued on 8 January 2010 (“2010 WUL Amendment”) to authorise

water uses associated with the industrial operations at the SIC.

Condition 5 in the 2008 WUL indicates that the WUL will be

None




reviewed every three (3) years, and a review was thus initiated

during 2014. The 2010 WUL Amendment specify in condition 12.1

that an Integrated Water and Waste Management Plan (“IWWMP”)

must be submitted for approval when the WUL is being reviewed.”

The site is licensed under the National Environmental Management

Waste Act (NEM:WA) for its operations and the Synfuels facility

has a site-wide WUL. Sasol amended the WML for the site so that

the variables for surface and groundwater monitoring would match

those in the WUL to ensure that water management is conducted as

required by the Department of Water and Sanitation.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

3.13 ROD Condition: All employees who will be working in the

new fine ash dam should be aware of emergency procedures

in case of any accident.








Evidence:


SHE000023


000031)


None

3.14 Monitoring of any possible form of groundwater pollution and

to ensure maintenance of the acceptable groundwater. N/A There are 21 groundwater monitoring boreholes for

FAD 5 & 6 (note that only FAD 5 is relevant for this audit, however

the facilities are interlinked). Three groundwater monitoring reports

by JMA Consulting dated November 2017, May 2018 and August

2018 by JMA Consulting were available for review. Multiple

boreholes were identified as reflective of ‘downstream of Fine Ash

Sasol must continue to place

highest priority on the

prevention of groundwater

pollution by monitoring, and

by investing in future-

available mitigation




Dam 5’, and were reported upon for May 2017, August 2017,

November 2017 and August 2018 sample runs. Based on the

analytical results, the water contained in FAD 5 is potentially

negatively impacting on the groundwater resource.

It has been evidenced to the auditor that monitoring of groundwater

is routinely undertaken, therefore Sasol is compliance with this

section of the condition.

However, the remainder of this condition is considered not

auditable, as “acceptable” standards of groundwater quality cannot

be defined. The Sasol facility is an industrial site, which is not

situated within the catchment of any potable abstractions, and no

standardised or site-specific quality benchmarks have been set for

this circumstance. Given the long-running nature of the facility,

existing background levels of determinants were not established,

and cannot be extrapolated.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


20


20


techniques, and researching

best available technology.

It is further recommended

that Sasol seek to engage

with the authorities to

establish alternative more

auditable wording for this

condition.

Target completion

Long term

3.15 This Department must be granted access at any reasonable

times to the property to investigate any possible

environmental impacts that may be caused by the operation of

the said new fine ash dam.

C The auditor was informed that the Department has been granted

access on a number of occasions, however, no reports have been sent

to provide feedback following their site visits.

None

3.16 ROD Condition: Records relating to the compliance or non-

compliance with the conditions of the authorisation must be

kept in good order. Such records must be made available to

this Department within seven working days from the date of

written request for such records by the Department.

N/A There is no set requirement for conducting audits against the

conditions of this licence. No previous audits over the last 5 years

were available for review and there has been no indication that the

Department requested any records.

Ensure this current audit is

kept in good order so that it

is readily available on

request in the future.

Target Completion




Long term

3.17 Non-Compliance with, or any deviation from the conditions

of this authorisation is regarded as an offence, and after

reasonable provision has been made for the situation to be

remedied, will be dealt with in terms of Section 29, 30 and

31A of the Act.

N/A Noted. None

3.18 Any complaint regarding the said development must be

thoroughly investigated and addressed to the satisfaction of all

parties concerned. Copies of such complaints must be

forwarded to the Dept. within 28 hours of such a complaint.

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 available and the Environmental

department. Complaints are investigated and reported in line with

the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders

There have been no complaints received regarding the ash handling

facility since the operations commenced. The environmental

complaints register was available for review and contained

complaints for all business units dating back from 2008.

Evidence:

— Environmental Complaints Register_2019-02-18


— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01

None

3.19 This Authorisation is repealed if construction has not been

started within two (2) years from the date of this

Authorisation.



None

3.20 Where possible, the development should proceed from one

side of the site to the other, rather than affecting to entire site

simultaneously.

C Sasol do develop from one side of the site to the other, rather than

affecting to entire site simultaneously as required.

None




The auditor was informed that there are seven pumping points to

each paddock in FAD 5 and after each paddock is filled, it is left to

dry and pumping is directed onto the next paddock in a circular

manner until a full revolution is completed and back to the first

paddock so as to grow the site evenly. This was confirmed during

the site walk.

3.21 Topsoil and subsoil removed during site preparation and

construction should be stored separately. Topsoil that cannot

be used for onsite revegetation should be used at alternative

sites



None

3.22 Where possible the sides and surrounds of the dam should be

revegetated with indigenous plant species that perform an

adequate stabilising function should be used at alternative

sites. Where this is not possible, non-invasive species should

be used.

C The sides and surrounds of the dam are currently naturally

revegetated with both indigenous and exotic species. The exotic

species are managed at least once a year by a contractor. Sasol have

been planting several species around the coarse ash dam facility over

the last few years to test which ones grow best as part of a study

conducted by a local university. The best species will then be

prioritised for revegetation around all ash dams when rehabilitation

is done.

The auditor observed revegetation during the site walkover and

illustrated in Figure 4-1.

None

3.23 Prevention of groundwater pollution should receive the

highest priority. C There are 21 groundwater monitoring boreholes for

FAD 5 & 6. Three groundwater monitoring reports by JMA

Consulting dated November 2017, May 2018 and August 2018 by

JMA Consulting were available for review. Multiple boreholes were

identified as reflective of ‘downstream of Fine Ash Dam 5’, and

were reported upon for May 2017, August 2017, November 2017

and August 2018 sample runs. Based on the analytical results, the

water contained in FAD 5 is potentially negatively impacting on the

groundwater resource.

The water in the ash handling areas is controlled in a closed circuit

via cement channels and is reused in the system as much as possible.

The channels are designed to prevent groundwater pollution.

In order to remain compliant

with this condition going

forwards, Sasol must

continue to place highest

priority on the prevention of

groundwater pollution by

investing in future-available

mitigation techniques, and

researching best available

technology.

Target period:




Interception drains around FAD 5, Coarse Ash Dump and the Black

Products area are visible.

The entire Outside Ash area is regarded as a “dirty area”, and

contaminated run-off is mostly contained within this area by means

of a stormwater berm and trench along the southern, south-western

and western boundary.

It has been evidenced to the auditor that prevention of groundwater

pollution is receiving high priority, with significant investment

made in pollution mitigation measures. Sasol is taking practical

steps in order to combat the legacy of limited containment structure

practices of the past. This condition has been marked compliance

only on the basis that such investment in pollution prevention has

been made, as deterioration in water quality has been noted.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


20


20


Long term

3.24 Deep seepage interception drains into intact sedimentary rock

should be excavated and constructed to the east and west of

the fine ash dam to prevent contaminated seepage from

reaching the drainage features to the east and west of the fine

ash dam and its return water dam.






MP/EIA/0000524/2012) was issued in December 2013. The

interception drains were observed during the site walk.

None

3.25 No development including roads, waste disposal and

construction should be placed within 100m of drainage lines,

and in particular the Groot.

C No development of roads and waste disposal is within 100m of

drainage lines. The map showing streams in the IWWMP was

reviewed and showed that the closest channel was the Brand Spruit

and it was at least 100m from the closest point of development

None




around FAD 5. The Groot-Bossie Spruit was more distant as

indicated in Figure 4-2.



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

GENERAL CONDITIONS 6 2 0 4

ESTABLISHMENT OF THE ENTERPRISE 4 2 0 2

WATER POLLUTION 5 5 0 0

AIR POLLUTION 4 3 0 1

RISK MANAGEMENT 1 1 0 0

MONITORING 2 1 0 1

REPORTING 3 1 0 2

Total Count 25 15 0 10

Total Percentage 60% 0% 40%

Percentage Compliance with Applicable Conditions 100%



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

presents the total proportion of compliance for the facility.

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

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

0

1

2

3

4

5

6

7

Sectional Count Contribution

C

NC

N/A

15

0

10

Total Compliance

C

NC

N/A



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

total percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

60%

0%

40%

Total Percentage Compliance

C

NC

N/A



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 AND PRE-COMMISSIONING 4 0 0 4

COMMISSIONING AND START-UP 11 0 0 11

OPERATING, MAINTENANCE AND SHUTDOWN 25 18 0 7

Total Count 40 18 0 22

Total Percentage 45% 0% 55%

Percentage Compliance with Applicable Conditions 100%

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

presents the total proportion of compliance for the facility.

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

0

5

10

15

20

25

30

Construction and Pre-Commissioning

Commissioning and Start-Up Operating, Maintenance andShutdown

Sectional Count Contribution

C

NC

N/A



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

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

total percentage compliance for the facility.

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

18

0

22

Total Compliance

C

NC

N/A

0102030405060708090

100

Construction and Pre-Commissioning

Commissioning and Start-Up Operating, Maintenance andShutdown

Sectional Percentage Contribution

C

NC

N/A



Figure 5-8: 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;

— 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 40% of the listed measures are no longer applicable,

as these mostly related to the construction and pre-commissioning, and commissioning and start-up phases 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

45%

0%

55%

Total Percentage Compliance

C

NC

N/A



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

(14.24 EV 2)

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL … · 7/22/2019 · to a fine ash dam (FAD). Four...

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Transcript of ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL … · 7/22/2019 · to a fine ash dam (FAD). Four...