ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT ... · ENVIRONMENTAL AUTHORISATION AND...

SASOL SYNFUELS OPERATIONS: WATER AND ASH

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/3/8/G-1 - EMERGENCY STORAGE DAMS

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT

17/2/3/8/G-1 - EMERGENCY STORAGE DAMS

SASOL SYNFUELS OPERATIONS: WATER

AND ASH

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

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SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref: 17/2/3/8/G-1

Draft v2 for Review –

Compliance Audit

EA Ref: 17/2/3/8/G-1

Final – Compliance

Audit

EA Ref: 17/2/3/8/G-1

Date April 2019 May 2019 June 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 003 003 003

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

REPORTS\003_SSO_WA_EA_17.2.3.8G-1\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

Rakesh Durjan

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 June 2019

TABLE OF CONTENTS

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

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

1.2 Emergency Storage Dams (Authorisation

Number: 17/2/3/8/G-1) ............................................. 1

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

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

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

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

3.3 Documentation Considered ................................... 4

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

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 39

5.1 Environmental Authorisation ............................... 39

5.2 Environmental Management Plan ........................ 42


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TABLES

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

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

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 27

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 39

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 42

FIGURES

FIGURE 1-1: EMERGENCY STORAGE DAMS B AND C (SOURCE: GOOGLE EARTH, 2018) ............................... 2

FIGURE 5-1: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 40

FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 40

FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 41

FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 41

FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 43

FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 43

FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 44

FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 44


WSP June 2019

APPENDICES

A ENVIRONMENTAL AUTHORISATION (17/2/3/8/G-1)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

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

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

compile an audit report according to the requirements of the National Environmental Management Act (No. 107

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

Environmental Authorisation (EA) (Reference number: 17/2/3/8/G-1 issued on 28 September 2015) as well as the

associated Environmental Management Plan (EMPr) (dated: September 2010) for the period December 2014 to

February 2019.

1.2 EMERGENCY STORAGE DAMS (AUTHORISATION

NUMBER: 17/2/3/8/G-1)

Sasol Secunda Operations produce liquid fuels (petrol, diesel and paraffin), as well as industrial pipeline gas and

a range of chemical feedstock compounds, including the building blocks for industrial solvents and polymers,

through the gasification process of approximately 40 million tons of coal per annum. The mineral content of the

coal reports as coarse ash, which is conveyed to the coarse ash disposal site. Fine ash from the boilers for steam

and electricity generation is pumped to the Fine Ash Dams (FAD) for disposal. Wastewater generated in the Sasol

Complex is treated and upgraded to process water quality. This is then successively stored in a number of process

effluent dams and is subsequently used as process water within the Sasol Complex..

The comprehensive water balance model for the Sasol complex indicates that, for normal rainfall years (barring

major plant upset conditions), the overall complex process water balance should be in balance. Normal rainfall

conditions for this area give rainfall depths that range from 543 to 885 mm/year. This changed during the 2009 /

2010 rainfall period due to exceptionally high rainfall for this period, and the hydrological years before. The dams

within the process water circuit providing the required buffer capacity to balance these circuits over varying

rainfall periods, could not “recover” in terms of water levels, and Sasol was compelled to operate these into their

freeboard capacities to prevent spillages from the circuits/dams to the receiving surface water environment.

Due to excess water in the process and related circuits, Sasol was compelled to urgently construct two process

water emergency storage dams to protect the downstream water environment. A Section 24G Rectification

Application was prepared into the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA)

and submitted to Mpumalanga Department of Agriculture, Rural Development, Land and Environmental Affairs

(MDARLEA) before an EA (Reference number: 17/2/3/8/G-1) dated 28 September 2015 was issued. An EMPr

dated September 2010 was also submitted to support the application for the EA for construction of the dams and

provide Sasol and its contractors with guidance on how to conduct their construction, operational and

decommissioning activities in an environmentally responsible manner.

On 5 February 2016, Sasol submitted a request for an amendment of the issued EA for the emergency storage

dams for process water. The amendment focussed on three aspects within the EA, two conditions and one for

correction of the exact site coordinates. The amendment was issued on 23 March 2016 and the remainder of the

conditions stayed the same.

Both the EA and EMPr are assessed in this compliance audit report and the latest amendment conditions are

audited against. The location of the emergency storage dams are located in Figure 1-1 below.

This authorisation was issued in response to a Section 24G rectification application. Thus, all construction

activities were completed in 2010 before the issuing of the authorisation. Consequently, all construction-related

conditions are considered outside the audit period (2014-2019).


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Figure 1-1: Emergency Storage Dams B and C (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,

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.


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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 (28 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 28 March 2019. The findings and observations of the site visit

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

interviewed included:

— Simphiwe Njikelane (Area Manager Production); and

— Aaron Matjomane (Production Foreman, W&A Production Water Recovery).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— IWWMP SIC 2015 Final_2018-05-15;

— 12776_WULApp_Final_27 Aug 2010;

— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-06-14;

— 3.2.2_EA_ 2251_Submit post construct audit Dam10BandC;

— 3.3.1 Organogram_SHE Air_2018-09-17

— 3.3.1 Organogram_SHE WWLB_2018-09-03

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

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

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

— Environmental Complaints Register (2008-2019);

— Tech Support for ESD -20100819;

— Environment emergency procedure_SGR-SHE000023_rev6_2015-11;

— Environmental incident procedure Process flow;

— Works emergency procedure_CGR-EMP-000001_Rev04_2016-02;

— Induction_Mod1_1SHE Excellence;

— Induction_Mod4_ProcessSafetyManagement;


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— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod6_EmergencyManagement;

— Induction_Mod7_Occupational;

— EA_EX Handover_SSO_WA-Process Water;

— EA_EX Handover_SSO_WA-Process Water_Amend VP;

— Compliance_Availability_Secunda Complex;

— EA Name Change applications_Transmittal_2017-03-29_signed;

— DARLEA_Sasol amendments acknowledgements_2017-04-10-1;

— DARLEA_Sasol amendments acknowledgements_2017-04-10-2;

— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage Dams_Amend_2016-03-23;

— Dams 10B & 10 C Control Survey Report 2014;

— Dams 10B & 10 C Control Survey Report 2015;

— Site photos; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2 and Table 3). The checklist

included the conditions and associated requirements as specified in the EA and associated EMPr.

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

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

associated target completion dates included. Any amended conditions will be audited against instead of the

repealed ones and will be inserted in the audit table underlined below the original condition.

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).


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3.5 AUDIT TEAM

The Auditor, Tutayi Chifadza, was hosted by Broni van der Meer, Simphiwe Njikelane and Aaron Matjomane 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.

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 License 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


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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

3.1: SCOPE OF AUTHORISATION

3.1.1 Authorisation of the activity is subject to the conditions

contained in this authorisation which are part of the

environmental authorisation and are legally binding on the

holder of the authorisation.

N/A Noted. None

3.1.2 The holder of the authorisation must ensure compliance with

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

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

employee or person rendering a service to the holder of the

authorisation.

NC All site personnel that work on the dams undergo a Safety, Health

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

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

is completed through the regional SHE learning and development

academy.

A post construction audit was conducted in March 2016 as required

by the condition 3.2.2 of this EA in order to ensure compliance with

the construction and rehabilitation activities. A 90% overall

compliance was achieved in this audit with 4 non-compliances

identified from 40 applicable conditions.

There is no requirement within the licence to audit against it

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

than the post-construction audit are undertaken from a best practice

perspective.

Non-compliances were observed over the course of this audit and

these must be rectified as per the recommendations issued.

Evidence:

— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-

06-14

— 003_41101534_20190125_Sasol_SSO_WA_EA_17.2.3.8G-

1_V1_AS_TC

Rectify all non-compliances

based on the

recommendations provided

in this report.

Target period:

Long term


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3.1.3 This authorisation refers only to the activity as specified and

described above. Any other activity listed under Section 24 of

the National Environmental Management Act (Act 107 of

1998, as amended) and which is not specified above, is not

covered by this authorisation, and must therefore comply with

the requirements of the National Environmental Management

Act and the regulations promulgated in terms of these laws.

C The EA authorises the construction of a dam and the associated

infrastructure (pipelines). The coordinates provided in the amended

EA show that the 2 dams and the related infrastructure are the only

forms of development within the stipulated development footprint.

No unauthorised activities are within the development footprint as

observed during the site visit.

Evidence:

— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-

02-05

— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage

Dams_Amend_2016-03-23

None

3.1.4 This authorisation does not negate the holder of the

authorisation`s responsibility to comply with any other

statutory requirements that may be applicable to the

undertaking of the activity.

C Sasol also required a Water Use Licence (WUL) for the operation

of the dams and as such, lodged an application for the registration

of water use in 2010. The application was then re-issued in 2015 and

a final electronic submission was completed in 2018. Sasol are still

waiting for DWS’s input. The proof of submission was available for

review.

Sasol has a site wide WUL for all their operations on the Synfuels

facility, however, this does not include the emergency dams. The

site wide Integrated Water and Waste Management Plan (IWWMP)

for the site was available for review and it included the dams

licensed in the EA indicating that they still require a WUL from

DWS.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— 12776_WULApp_Final_27 Aug 2010

None

3.2 MANAGEMENT AND MONITORING OF THE ACTIVITY

3.2.1 The Environmental Management Plan (EMP) submitted as

part of the application for environmental authorisation is NC The approved EMPr was available for review and it indicated that

monthly internal compliance inspections by the Environmental

Ensure that monthly internal

compliance inspections by


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approved and must be implemented and adhered to

throughout the life cycle of the activities.

Management Officer (EMO) and annual external audits by a

qualified and competent auditor are required during the operational

phase to ensure compliance. The EMPr mitigation measures were

only audited as part of the 2016 EA post-construction audit and not

subsequently. Daily site checks are conducted by site personnel to

ensure that no problems arise, however, no formal audits are done

against the EMPr conditions.

Evidence:

— SSO_WA_17.2.3.8.G-1_EMPr_EmergencyStorageDams_

2010-09


06-14

the EMO and annual

external audits by a qualified

and competent auditor are

undertaken against the

conditions of the EMPr as

required.

Target period:

Short term

3.2.2 The holder of the authorisation must submit a post-

construction environmental audit report to the Department.

The audit report must be compiled by an accredited

independent auditor.

C Iliso Consulting (Pty) Ltd, an accredited independent auditor, on

behalf of Sasol in March 2016, completed a post construction and

the report was submitted to the Department on 10 April 2017. The

letter of submission was also available for review.

Evidence:


06-14

— 3.2.2_EA_ 2251_Submit post construct audit Dam10BandC

None

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

project during its operational phases C The Department conducts inspections on the dams once a year,

however, no reports have been issued to Sasol to provide feedback.

None

3.2.4 Monitoring of boreholes for ground water quality must be

done monthly and records must be kept at the offices on site.

Amended Condition (Dated 23 March 2016)

Monitoring of boreholes for ground water quality must be

done bi-annually and records must be kept at the offices on

site.

C Groundwater monitoring is conducted biannually and quarterly as

required following the EA amendment received dated March 2016

from a monthly exercise. Thirteen groundwater monitoring points

around the dams were identified. Three groundwater monitoring

reports were available for review.

Evidence:

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

20

None


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— GW_Report _Prj6143_2018-06-19

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

20

— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-

02-05

3.2.5 Any pollution incidents associated with the development in

any nearby watercourse must be reported to DWA within 24

hours.

N/A Sasol uses an incidents register to take note of any environmental

pollution occurrences that occur on site. Incidents are investigated

and reported as required. Following a review of the incident

registers for the period 2015 to 2019, there were no incidents

specifically related to the emergency dams (no spillage or leak

incidents) that needed to be reported to the DWA within 24 hours.

Evidence:

— Copy of Environment Impact register_ New FY17

— Environment Impact register_ New FY19_2019-02-18

None

3.3: SPECIFIC CONDITIONS

3.3.1 The applicant must assign the development to a full time-

based team of Environmental Officers/Scientist who will

among others:

a) Ensure strict compliance of the development with the

conditions of the Environmental Authorisation as well as

measures contained in the Environmental Management Plan;

b) Discuss and advise employees on site about the

environmental good practice:

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

the legislative requirements and ensure EA compliance. Due to the

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

officer assigned to a particular site. The Sasol environmental team

works together to ensure compliance on the emergency dams and

advises employees on the site about good environmental practice as

required.

Whilst non-compliances have been identified in the course of this

audit, this aspect is covered by Condition 3.1.2.

Evidence:



OFI:

Rectify all non-compliances

based on the

recommendations provided

in this report.

Target period:

Long term


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3.3.2 Blocking of storm water drainage system must be prevented

and storm water must be managed to prevent soil erosion C It must be noted that the dams are built at a higher topography than

the surrounding area, therefore, this prevents any potential soil

erosion towards the dams or any blockages of the stormwater drains,

as was observed during the site walk. The dams have stormwater

drains on their edges that were observed to be clean and obstruction

free. Daily site inspections are completed to ensure no such

problems occur on the site. The edges of the dams are also vegetated

(which is maintained to ensure it does not grow out of control),

which also helps in preventing any erosion and lead to blockages.

Evidence:

Vegetated edges of the dams

None

3.3.3 Runoff and storm water must be diverted around the side of

the Emergency storage dams for process water body through

cut-off drains of channels/a system of beams.

C There are cut-off drains surround the dams to divert any runoff and

stormwater around the side of the emergency storage dams as

required. This was observed during the site visit.

Evidence:

None


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Cut-off drain

3.3.4 All waste slug generated on the site must be stored, handled

and disposed of in a registered landfill site or as directed by

any other relevant authority. Under no circumstances shall

burning of waste be allowed on site.

C Sasol use the waste management procedure (SGR-SHE000017) to

manage any waste generated on the site following a waste

management hierarchy.

Waste is disposed of at registered landfill sites, however, little to no

waste is expected to be generated at the dams since they are designed

to be water-holding facilities. No waste is burned on site as required

by the EA.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09

None


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3.3.5 The soil stockpile must be shaped to reduce soil compaction

and must be managed properly to avert any wash down to

nearby watercourses.

N/A The post-construction audit indicated that all construction activities

were completed in 2010 and that no soil stockpiles were on site. The

dam walls had been shaped and vegetated to control erosion at the

time of the audit.

None

3.3.6 Alien and invader vegetation must be controlled and not

allowed to colonize the area. C Sasol cuts the vegetation once a year around the dam walls for fire

control that helps control invader and alien vegetation to an extent.

The crests of the edges are cut on a monthly basis as it is cheaper

than monthly control of the whole edge of the dam.

Evidence:

Vegetation control on crests

None


WSP June 2019

Page 15


3.3.7 Dust suppression measures must be implemented to avoid

pollution of the environment and diseases that might infect

workers

C According to the post construction audit, the construction of the

dams was completed before the issuing of the EA (c.2010). No

records are available as to the management of construction activities

are available for review regarding dust suppression, however, this

was closed out during the post-construction audit. Dams are now

operational and there are no stockpiles on the site. No dust is

generated on the footprint as the sides are vegetated and the roads

are graded and compacted to prevent any dust generation.

Evidence:

Vegetated edges of the dams

None

3.3.8 Any complaints received from employees or anyone within

the immediate vicinity must be attended to as soon as possible

and addressed to the satisfaction of all concerned

C There have been no complaints received regarding the emergency

dams since the operations commenced. The environmental

complaints register was available for review and contained

complaints for all business units dating back from 2008.

None


WSP June 2019

Page 16


Evidence:

— Environmental Complaints Register (2008-2019)

3.3.9 The Emergency storage dams for process water must be

designed in such a manner that the prevent seepage of

contaminated water from entering and polluting ground water

C According to the IWWMP, the process water emergency storage

dams have dual geosynthetic liners (1.5 and 2mm HDPE) with

leakage detection to prevent the seepage of contaminated water from

entering and polluting groundwater. This was confirmed during the

site walk.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

Dam liner

None

3.3.10 The design of the Emergency storage dams for process water

must ensure adequate capacity to prevent overflowing. C Although the IWWMP indicates that there is no accurate flow

measurement in place at the inflow to the process water dames, mass

balance calculations are used to acquire estimate figures. Process

water can be pumped to the other existing dams in the system to

prevent overflows and water is also pumped back to the primary area

None


WSP June 2019

Page 17


for use as process cooling water or for washing purposes in the

plants. Furthermore, the dams have a capacity of 1 366 599m3 and

1 078 894m3 each which was deemed sufficient during the design

phase and EA application process.

The dams have level meters that are observed on a daily basis to

ensure that they do not overflow and contaminate the Trichardspruit.

In the event of high levels, the valves on the drainage channels are

opened to allow the water to gravitationally flow from one dam to

the next thus preventing any overflows.

Following a review of the emergency dams’ technical support

document, it was indicated that the dams are located well outside the

1:100 year flood line. No overflow incidents have been reported in

the audit period following the review of the incidents register.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— Tech Support for ESD -20100819


Dam level meter


WSP June 2019

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3.3.11 The construction and operation activities related to the

infrastructure must comply with the relevant provisions of

Occupational Health and Safety Act (Act No. 85 of 1993).

C All site personnel that work on the dams undergoes SHE induction

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

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

regional SHE learning and development academy. The induction

learning modules were available for review. The Health and Safety

officers are appointed for the site and their details were displayed on

the walls in the control room.

Evidence:



— Induction_Mod1_1SHE Excellence

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod6_EmergencyManagement

— Induction_Mod7_Occupational

None

3.3.12 An authorisation in terms of the National Water Act, of 1998

(Act No. 36 of 1998) obtainable from the Department of

Water Affairs must be obtained for the operation of all

activities that triggers water use licence.

C Sasol also required a Water Use Licence (WUL) for the operation

of the dams and as such, lodged an application for the registration

of water use in 2010. The application was then re-issued in 2015 and

a final electronic submission was done in 2018.

Sasol has a site wide WUL for all their operations on the Synfuels

facility, which incorporates the emergency dams. The site wide

Integrated Water and Waste Management Plan (IWWMP) for the

site was available for review and it included the dams licensed in the

EA.

Evidence:

— 12776_WULApp_Final_27 Aug 2010


None


WSP June 2019

Page 19


3.3.13 Demarcated walkways must be established to access the

facility. C Demarcated walkways have been provided around the emergency

dams as was confirmed in the post construction audit. The road is

compacted and was observed during the site walk.

Evidence:

Compacted road

None

3.3.14 An Integrated Emergency Plan must be developed and

include; 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. A works emergency procedure is

also available for any Health and Safety incidents.

Evidence:

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11

— Environmental incident procedure Process flow

— Works emergency procedure_CGR-EMP-

000001_Rev04_2016-02

None


WSP June 2019

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3.3.15 — Proper communication system between personnel and

other facilities on-site, adjacent neighbours and fire

brigade.

C The Synfuels emergency plan shows that during an incident, the

personnel in the area or unit must report to Emergency Management

at 10-4444 / 10-2444 who will then inform Environmental

Management Services standby person and Market Integrations.

All environmental incidents are recorded in the incident register,

investigated accordingly and reported if there is a need.

Evidence:

— Environmental emergency procedure (Rev 6): SGR-

SHE000023

— Environmental incident procedure process flow

None

3.3.16 — Suitable signage must be clear and interpreted in all

possible languages that can be used on site, in relation to

the danger associated with pollution control dam.

C The site has internationally acceptable pictograms used identify

danger and warn personnel of the dangers associated with the

emergency dams, which is considered acceptable to convey the

dangers. Furthermore, the PCDs are located well within security

contained areas (restricting the likelihood of tresspassers), and

English is the official language for all communication in Sasol.

Evidence:

OFI:

When the signage requires

replacement, ensure that

signage is put up in at least 3

languages, English,

Afrikaans and Zulu.

Target period:

Long term


WSP June 2019

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Dam dangers sign

3.3.17 — Code to identify the kind and severity of a release or

spillage when communicating it through to one another; C The environmental incidents are recorded in the incident register,

which has a column for indicating the magnitude or severity of the

incident. The column is also used to indicate whether the incident is

a repeat incident. The severity then determines whether the incident

is reported to the Department of Water and Sanitation.

Evidence:

— Environmental Impact Register_ FY17-19

None

3.3.18 — Actions to take in the case of various releases, spillages

and occurrence of the fire; C The environmental emergency procedure shows the actions to be

taken in response to an incident as well as preventative actions that

are tabled to prevent future occurrences. All the relevant

requirements of the emergency plan including releases and spillages

are addressed in Section 9 of the procedure as required. Section 4 of

the works emergency procedure addresses fire procedures.

Evidence:


SHE000023

None


WSP June 2019

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000001_Rev04_2016-02

3.3.19 — Responsible personnel management of different actions C The environmental emergency and the works emergency procedures

show the responsible personnel to manage different actions in an

emergency. There are various designations given to specific

personnel (standby person, shift foreman, area emergency

controller, senior officer of emergency management etc.) who are

mentioned in the management actions taken. These are displayed in

the site offices, on notice boards, as well as signage around the

dams. The emergency phone numbers are also listed accordingly.

Evidence:


SHE000023


000001_Rev04_2016-02

Emergency telephone numbers

None


WSP June 2019

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3.3.20 In the event of an accidental spillage, clean-up of the spillages

must be undertaken within 48 hours. C The clean-up of spillages is completed immediately after the

Environmental Management Services standby person is informed of

the incident. The procedure also indicates that any reportable

incidents to DWS are completed within 24 hours after they have

occurred, with an action plan presented as part of the reporting.

Furthermore, there have been no spillage events on the dams which

required clean-up and this was confirmed following a review of the

incidents register.

Evidence:


SHE000023

— Environmental Impact Register_ FY17-19

None

4: SITE CLOSURE

4.1 Should the activity ever cease or become redundant, the

applicant shall undertake the required actions as prescribed by

legislation at the time and comply with all relevant legal

requirements administered by any relevant and competent

authority at that time.

N/A Noted. The Emergency Dams are currently operational and this will

only be considered when closure is carried out.

None

4.2 A Rehabilitation Plan must be submitted to this Department

for approval at least six (6) months prior to the

decommissioning of the facility.

N/A Noted. The Emergency Dams are not being considered for closure

at this stage.

None

5: GENERAL

5.1 A copy of this authorisation must be kept at the property

where the activity will be undertaken. The authorisation must

be produced to any authorized official of the Department who

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

communicated with, relevant business units. Copies of these

documents are also available at the SHE: Environment department

None


WSP June 2019

Page 24


requests to see it and must be made available for inspection

by any employee or agent of the holder of the authorisation

who works or undertakes work at the property.

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

evidence that the responsible person, Rakesh Durjan (Senior

Manager of Process Water Area), was made aware of the EA on 27

September 2016.

All environmental aspects are shared to site personnel during

induction.

Evidence:

— EA_EX Handover_SSO_WA-Process Water

— EA_EX Handover_SSO_WA-Process Water_Amend VP

— Compliance_Availability_Secunda Complex

5.2 The holder/applicant of this authorisation is responsible for

compliance with the duty of care remediation as contained in

Section 28 of the National Environmental Management Act,

1998 (Act No.107 of 1998).

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

for compliance with the provision for Duty of Care and Remediation

of Environmental Damage as contained in Section 28 of the

National Environmental Management Act, 1998 (Act No.107 of

1998).

None

5.3 Any changes to or deviations from the project description set

out in this authorisation must be approved in writing by the

Department before such changes of deviations may be

effected. In assessing whether to grant such approval or not,

the Department may request such information as it deems

necessary to evaluate the significance and impacts of such

changes or deviations

N/A Noted. The EA authorises the construction of two dams and related

infrastructure. No deviations to the authorised EA were observed.

None

5.4 Where any of the applicant`s contact details change, including

the name of the responsible person, the physical or postal

address and/or telephonic details, the applicant must notify the

Department as soon as the new details become known to the

applicant.

C A name change application was lodged in February 16 from Sasol

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

captured in the amended EA issued in March 2016.

The name change was communicated to the Mpumalanga

Department of Agriculture, Rural Development, Land and

Environmental Affairs on 27 March 2017 and was received on 29

March 2017.

Evidence:

None


WSP June 2019

Page 25


— EA Name Change applications_Transmittal_2017-03-

29_signed

— DARLEA_Sasol amendments acknowledgements_2017-04-

10-1

— DARLEA_Sasol amendments acknowledgements_2017-04-

10-2

— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage

Dams_Amend_2016-03-23

5.5 The holder of the authorisation must notify the Department,

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

this Environmental Authorisation are not adhered to. Any

notification must be accompanied by reasons for the non-

compliance.

NC Although non-compliances have been observed during this audit, no

evidence of reporting of these non-compliances to the department

was available for review period outside of the post construction

audit that was conducted in March 2016 and submitted in April

2017.

Ensure any non-compliances

submitted to the

Department. Furthermore,

consider an amendment to

have the requirement of

notification within 24 hours

unless it is a major pollution

event.

Target period:

Long term

5.6 Non-compliance with a condition of this authorisation may

result in criminal prosecution or other actions provided for in

the National Environmental Management Act, 1998 and the

regulations.

N/A Noted. None

5.7 National government, provincial government, local

authorities or committees appointed in terms of the conditions

of this authorisation or any other public authority shall not be

held responsible for any damages or losses suffered by the

applicant or his successor in title in any instance where

construction or operation subsequent to construction be

temporarily or permanently stopped for reasons of non-

compliance by the applicant with the conditions of

authorisation as set out in this document or any other

N/A Noted None


WSP June 2019

Page 26


subsequent document emanating from these conditions of

authorisation

6: APPEAL OF AUTHORISATION

6.1 The holder of the authorisation must notify every registered

interested and affected party, in writing and within twelve (12)

days of the date of this decision, of the outcome of the

application.

NC The post construction audit confirmed that the registered interested

and affected parties (I&APs) were notified in writing, however, this

was not within the 12 days of the date of decision as required.

Notification was made on 10 November 2015 but the EA was issued

on 29 September 2015. This was closed out in this audit report, as

notifications cannot be redone.

Evidence:


06-14

Not rectifiable.

6.2 The notification referred to above, must –

(a) Specify the date on which the authorisation was issued. C The date of the authorisation was issued was indicated in the

notification.

None

(b) Inform the interested and affected party of the appeal

procedure provided for in Chapter 7 of the Regulations. C The I&APs were notified of the appeal procedure provided in

Chapter 7 of the Regulations.

None

(c) Advise the interested and affected party to the manner in

which the decision can be accessed.

NC Interested and affected parties were not advised as to the manner in

which the decision could be accessed.

Not rectifiable.

(d) Be published in the newspaper contemplated in Regulation

54(2)(c) and which newspaper was used for the placing of

advertisement as part of the public participation process.

C An advertisement was placed in “The Ridge Times” as part of the

public participation process.

None


WSP June 2019

Page 27

Table 3: Audit Findings – Environmental Management Plan


CONSTRUCTION PHASE

Terrestrial Ecology Maintain existing ecological function

beyond the boundaries of the construction

site:

— The footprint to be cleared and the area

to be covered by the embankments will

be clearly demarcated. Identified

sensitive areas (e. g. wetlands) will be

avoided as far as possible. Vegetation

will be cleared before the grass owls

start nesting in early spring.

— Laydown of construction materials and

parking of vehicles will take place

within the footprint to be cleared.

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

pre-2014). It is therefore considered not applicable. This authorisation

was issued in response to a Section 24G rectification application.

Thus, all construction activities were completed in 2010 before the

issuing of the authorisation.

None

Limit the impact to the area of the dam basins

only:

— The area to be excavated will be clearly

demarcated prior to the commencement

of excavation and the excavation

progress will be monitored to ensure its

confinement within the demarcated

area.

— If burrowing animals with young are

encountered, they will be captured and

relocated.






None

To maintain control of weeds and invasive

aliens:

— Disturbed areas will be re-vegetated

with locally indigenous grasses




None


WSP June 2019

Page 28


(Themeda triandra, Hyparrhennia hirta

and Eragrostis species) and monitored

until the vegetation becomes self-

sustaining.

— The progress of the re vegetation

programme will be monitored quarterly

and corrective action taken as

necessary, with input from a specialist

as may be required.



Surface Water To prevent pollution of soil and dirty runoff

to Trichardspruit:

— Water quality in the Trichardspruit

downstream of the project site will be

checked with regard to TDS,

hydrocarbons and silt prior to

construction, monthly during

construction and again after completion

of construction.

— Maintenance and refuelling to be done

at contractors’ camp, not within

footprint of new dams.

— Spill kits must be available at site.

— Drip trays will be placed under vehicles

when parked.

— All spillages incidents will be recorded.

— Contaminated soil will be removed

immediately and disposed at an

appropriate facility.






None

To prevent transport of silt into the

Trichardspruit:

— A trench will be dug down-gradient of

the dam basin and along the footprint of

each dam wall before clearing of






None


WSP June 2019

Page 29


vegetation. Construction of dam walls

will take place immediately as material

is removed from the dam basin

— The silt content of runoff to the

Trichardspruit will be monitored after

each significant rainfall event during

the construction period.

Groundwater To prevent pollution of soil and

groundwater:

— Ensure proper construction of liner

systems in accordance with design

specifications by diligent supervision

and weekly inspections Groundwater

quality in monitoring boreholes up- and

down-gradient of the site will be

checked and recorded prior to and after

completion of construction

— Maintenance and refuelling to be done

at contractors’ camp, not within

footprint of new dams

— Spill kits must be available at site

— Drip trays will be placed under vehicles

when parked

— All spillages incidents will be recorded

— Contaminated soil will be removed

immediately and disposed at an

appropriate facility.






None

Air Quality No visible dust at construction sites:

— Install dust buckets up – and down-

wind of the site

— Apply wet suppression, especially on

dry, windy days






None


WSP June 2019

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— Ensure proper maintenance of vehicles,

especially diesel engines

— Enforce low speed limits on unpaved

areas

No increase in PM10 or PM2.5 at monitoring

points:

— Record weekly measurements of PM10

and monthly mass of dust collected in

fallout buckets.






None

No increase in dust fall at monitoring points. N/A This condition is considered outside of the audit period (construction





None

Noise Non-exceedance of nuisance noise levels at

sensitive receptors. See Table 5-5:

— Noise abatement equipment on

machinery will be properly maintained.






None

Protection of personnel from health impacts

associated with high noise levels:

— In general, operations must meet the

noise standard requirements of the

Occupational Health and Safety Act

(Act No 85 of 1993).

— Construction staff working in areas

where the 8-hour average ambient noise

levels exceed 75dBA must wear

hearing protection equipment.






None


WSP June 2019

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— Personnel must wear hearing protection

in vicinity of machinery with dBA

levels of 85 dBA or more at 5 metres.

Socio-economic Maximise benefit for local contractors:

— Give preference to local contractors

wherever practicable.






None

Cultural and heritage

resources

Identification and preservation of cultural

and heritage resources:

— Train supervisory personnel to

recognise human remains and artefacts

of potential cultural and heritage value

that may be unearthed during

construction

— In the event of such artefacts or human

remains being found, work in the

immediate vicinity thereof will be

halted and a specialist will do an

inspection.






None

Dangerous activities

To maintain safe work practices in a safe

environment and to minimise personnel

injuries and damage to assets:

— Toolbox talks/staff briefing sessions

— Site workers’ training programme

— Training in the use and handling of

equipment






None


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OPERATIONAL PHASE

Dam Stability To detect signs of instability early enough to

enable the dams to be emptied before any

collapse occurs:

— The vertical positions of the

benchmarks and the monitoring points

will be surveyed before water flows into

the dams, and again weekly until the

design water level is reached. The water

levels will also be surveyed. Thereafter,

the survey will be done monthly until

initial settling has ceased, where after

the survey will be repeated quarterly.

The instruments and methodology used

will determine the vertical positions of

the benchmark beacons and the

monitoring points with an accuracy of <

10mm and will provide early warning

of any signs of instability.

— The data will be monitored for signs of

settling that could herald the onset of

unstable conditions. If such conditions

are detected, the dams will not be

viewed as long-term features, but will

be emptied and closed as soon as

possible.

— If further analysis of the risk parameters

shows a low risk of instability over the

long term and Sasol Synfuels decides to

keep the dams in operation, the survey

intervals may be increased to once per

annum, or the surveys may cease

altogether, depending on the outcome

of the risk analysis.

C This authorisation was issued in response to a Section 24G

rectification application. Thus, all construction activities were

completed in 2010 before the issuing of the authorisation. Therefore,

the first two parts of this authorisation are not applicable.

Nako Lategan Bouwer Consulting Engineers (Nako LBE) conducts

annual dam surveys on behalf of Sasol. The operation and

maintenance manuals of the emergency dams states that both must be

monitored on a yearly basis for any movement from possible roof

instability of the old mined-out areas under the dams. In November

2011, a base survey for vertical movement was conducted at Dam 10B

and during November 2011 at Dam 10C. The base survey for

horizontal movement was only done during October 2012 at both

dams. These surveys were used going forward as a basis to monitor

possible movement of the dam walls. These identified low risk of

instability and surveys have been done on an annual basis.

A sample of the reports were available for review and they indicated

that the measured vertical movements are completely within the norm

and acceptable range as this is expected due to settling over time.

Evidence:

— Dams 10B & 10 C Control Survey Report 2014

— Dams 10B & 10 C Control Survey Report 2015

None


WSP June 2019

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Terrestrial Ecology Control of invasive aliens, weeds and exotics

in vicinity of project:

— A programme to eradicate weeds, alien

invasive and exotic plant species will be

instituted and maintained.

— Progress will be monitored quarterly

until the indigenous species have been

restored to good condition, thereafter

annually.

C The auditor was informed that Sasol cuts the vegetation once a year

around the dam walls for fire control as well as removing alien

invasive species, weeds and exotics at the same time. The crests of the

edges of the sides of the road adjacent to the dams are cut on a monthly

basis, as it is cheaper than monthly control of the whole area around

the dam.

Evidence:

Cut road edges

None

Surface water To prevent the existing process water dams

from overflowing and contaminating the

Trichardspruit:

— The emergency dams must be built

before the commencement of the

2010/2011 rain season

C Although the IWWMP indicates that there is no accurate flow

measurement in place at the inflow to the process water dames, mass

balance calculations are used to acquire estimate figures. Process

water can be pumped to the other existing dams in the system to

prevent overflows and water is also pumped back to the primary area

for use as process cooling water or for washing purposes in the plants.

Furthermore, the dams have a capacity of 1 366 599m3 and

None


WSP June 2019

Page 34


1 078 894m3 each which was deemed sufficient during the design

phase and EA application process.

The dams have level meters that are observed on a daily basis to ensure

that they do not overflow and contaminate the Trichardspruit. In the

event of high levels, the valves on the drainage channels are opened to

allow the water to gravitationally flow from one dam to the next thus

preventing any overflows.

Following a review of the emergency dams’ technical support

document, it was indicated that the dams are located well outside the

1:100 year flood line. No overflow incidents have been reported in the

audit period following the review of the incidents register.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15



Dam level meter

To prevent deterioration of water quality and

habitat in the Trichardspruit due to seepage C According to the IWWMP, the process water emergency storage dams

have dual geosynthetic liners (1.5 and 2mm HDPE) with leakage

None


WSP June 2019

Page 35


of contaminated process water from the

emergency dams:

— The emergency dams must be lined as

per the description provided in Section

2.4.

— Water quality and aquatic health in the

Trichardspruit will be monitored at the

sampling points shown in Figure 5-3 on

a quarterly basis (February, May,

August, November), Samples will be

analysed for TDS, silt load, COD, F,

NH3, B, As, Cd and Se

detection to prevent the seepage of contaminated water from entering

and polluting groundwater. This was confirmed during the site walk.

The dams are equipped with a leak detection system and any leaks are

collected and passed back into the surrounding dams. There were

minimal to no leaks observed during the site walk.

Water quality and aquatic health in the Trichardspruit is monitored at

the required sampling points in Figure 5-3 of the EMPr and more

samples are taken along the route as well. The Trichardspruit is

monitored off RESM 2 (for seepage from process water dams 8, 9 and

the main body of process water dams), RESM 4 (for eastern portion of

dam 9 and game and cattle farming as well as historical irrigation

area), RESM 5 (for runoff from Secunda and Sasol general landfill

site) and RESM 26 (for sewage works). RESM 4 and 26 are monitored

on a weekly basis while RESM 2 and 5 are monitored weekly and

continuously. It must be noted that these monitoring locations measure

the impact of the contributions of the facilities in the area and not

specifically to the emergency storage dams alone. Since there have

been no incidents regarding overflows and seepages with regards to

the emergency dams, it can be assumed that they have not contributed

to any potential deterioration in water quality in the Trichardspruit.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15



WSP June 2019

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Leak detection collection sump

Groundwater To prevent deterioration of groundwater

quality due to seepage of contaminated

process water from the emergency dams:

— The emergency dams must be lined as

per the description provided in section

2.4

— The groundwater status must be

monitored by six-monthly sampling and

analysis of up-gradient and down-

gradient boreholes for TDS, COD, F,

NH3, B, As, Cd and Se

C According to the IWWMP, the process water emergency storage dams

have dual geosynthetic liners (1.5 and 2mm HDPE) with leakage

detection to prevent the seepage of contaminated water from entering

and polluting groundwater. This was confirmed during the site walk.

The dams are equipped with a leak detection system and any leaks are

collected and passed back into the surrounding dams. There were

minimal to no leaks observed during the site walk as shown the leak

detection collection sump image above.

Groundwater monitoring is conducted biannually and quarterly as

required following the EA amendment received dated March 2016

from a monthly exercise. Thirteen groundwater monitoring points

around the dams were identified. Three groundwater monitoring

reports were available for review.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

None


WSP June 2019

Page 37


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

— GW_Report _Prj6143_2018-06-19

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

— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-02-

05

CLOSURE PHASE

Terrestrial Ecology Prevent invasive aliens, weeds and exotics

from establishing and spreading into the

surrounding veld.

N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Surface Water To prevent pollution of soil and dirty runoff

to Trichardspruit. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Prevent transport of silt into Trichardspruit

by storm water runoff. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Groundwater To prevent pollution of soil and

groundwater. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Air Quality No visible dust at project site. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

No increase in PM10 or PM2.5 at monitoring

points


closure.

None

No increase in dust fall at monitoring points. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None


WSP June 2019

Page 38


Noise Non-exceedance of nuisance noise levels at

sensitive receptors. See Table 5-5 N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Protection of personnel from health impacts

associated with high noise levels. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None

Land use and land

capability

To rehabilitate the decommissioned dams to

a self-sustaining state after removal of the

ash layer and liners to.


closure.

None

Socio-economic Maximise benefit for local contractors. N/A The Emergency Dams are currently operational and not yet marked for

closure.

None


WSP June 2019

Page 39

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

Table 4: Summary of EA Compliance Audit Findings

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

SCOPE OF AUTHORISATION 4 2 1 1

MANAGEMENT AND MONITORING OF THE ACTIVITY 5 3 1 1

SPECIFIC CONDITIONS 20 19 0 1

SITE CLOSURE 2 0 0 2

GENERAL 7 2 1 4

APPEAL OF AUTHORISATION 5 3 2 0

Total Count 43 29 5 9

Total Percentage 67% 12% 21%

Percentage Compliance with Applicable Conditions 85%


WSP June 2019

Page 40

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

presents the total proportion of compliance for the facility.

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

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

0

5

10

15

20

25

Scope ofAuthorisation

Managementand

Monitoring ofthe Activity

SpecificConditions

Site Closure General Appeal ofAuthorisation

Sectional Count Contribution

C

NC

N/A

29

5

9

Total Compliance

C

NC

N/A


WSP June 2019

Page 41

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

total percentage compliance for the facility.

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

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

0102030405060708090

100

Scope ofAuthorisation

Managementand Monitoringof the Activity

SpecificConditions

Site Closure General Appeal ofAuthorisation

Sectional Percentage Contribution

C

NC

N/A

67%

12%

21%

Total Percentage Compliance

C

NC

N/A


WSP June 2019

Page 42

5.2 ENVIRONMENTAL MANAGEMENT PLAN

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

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

below.

Table 5: Summary of EMPr Compliance Audit Findings

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

CONSTRUCTION PHASE 14 0 0 14

OPERATIONAL PHASE 5 5 0 0

CLOSURE PHASE 11 0 0 11

Total Count 30 5 0 25

Total Percentage 17% 0% 83%

Percentage Compliance with Applicable Conditions 100%


WSP June 2019

Page 43

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

presents the total proportion of compliance for the facility.

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

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

0

2

4

6

8

10

12

14

16

Construction Phase Operational Phase Closure Phase

Sectional Count Contribution

C

NC

N/A

5

0

25

Total Compliance

C

NC

N/A


WSP June 2019

Page 44

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

total percentage compliance for the facility.

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

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

0102030405060708090

100

Construction Phase Operational Phase Closure Phase

Sectional Percentage Contribution

C

NC

N/A

17%

0%

83%

Total Percentage Compliance

C NC

N/A


WSP June 2019

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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 half of the listed measures are now no longer

applicable, as these related to the construction-phase only. The original EMPr document was designed pre-

operation principally to govern these construction phase impacts, and has been superseded during the operational

phase by Sasol Business Unit-specific risk assessments; compliance with the EA, relevant WUL and AEL; and

through Sasol’s choice to comply with the ISO 14001 Environmental Management international standard.

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

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

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

ISO 14001 standards.

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

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

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

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

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

Information Management System.

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

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

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

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

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

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17/2/3/8/G-1)

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