SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION … · 9.03 Non-compliance with, or any deviations...

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

HIGH PURITY ETHANOL PLANT [14/3/L/A/SAS.HPE]

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

HIGH PURITY ETHANOL PLANT [14/3/L/A/SAS.HPE]

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

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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:

14/3/L/A/SAS.HPE

Draft v1a for Review

– Compliance Audit

EA Ref:

14/3/L/A/SAS.HPE

Draft v2 for Review –

Compliance Audit

EA Ref:

14/3/L/A/SAS.HPE

Final – Compliance

Audit

EA Ref:

14/3/L/A/SAS.HPE

Date April 2019 April 2019 May 2019 June 2019

Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Jenny Cope Jenny Cope Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534 41101534

Report number 037 037 037 037

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

S I G N A T U R E S

PREPARED BY

-

Bronwyn Fisher

Environmental Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

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

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

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

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

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

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

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

CLIENT

SHE Specialist: Environment Broni van der Meer

Solvents Production Senior Manager Alfie Naidoo

WSP

Associate Jenny Cope

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

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

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 High Purity Ethanol Plant (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 14/3/L/A/SAS.HPE) ............................ 1

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

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

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

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

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

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

3.5 Audit Team .................................................................................. 5

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

4 AUDIT FINDINGS ...................................................... 7

5 SUMMARY OF THE AUDIT FINDINGS ................... 15

5.1 Environmental Authorisation .................................................. 15


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TABLES

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

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

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................................................ 15

FIGURES

FIGURE 1: LOCATION OF THE HIGH PURITY ETHANOL PLANT (SOURCE: GOOGLE EARTH, 2018) ............................................... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................................................ 16

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................................................. 16

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..................................... 17

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................................................ 17

APPENDICES

A ENVIRONMENTAL AUTHORISATION

(14/3/L/A/SAS.HPE)


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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: 14/3/L/A/SAS.HPE issued on 19 July 2000) for the

period December 2014 to February 2019.

1.2 HIGH PURITY ETHANOL PLANT (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(AUTHORISATION NUMBER: 14/3/L/A/SAS.HPE)

In July 2000, the Department of Agriculture, Conservation and Environment (DACE) issued an Environmental

Authorisation (EA) (14/3/L/A/SAS.HPE) for the construction and operation of the High Purity Ethanol (HPE)

Plant.

The plant was commissioned in order to increase the quality of Ethanol 95 to 99.99% purity. The HPE plant has

the capacity to treat 85 000 t/pa through a combination of distillation and extractive distillation units.

The HPE plant receives Ethyl 93 and Ethyl 95 from the Solvents West Alcohol Recovery Unit. The feed is fed

through a ‘lights column’ where light components such as water, methanol and ethers are removed. The lights

free ethanol then goes through the High Purity Ethanol purification column. The pure ethanol found at the top of

the column is sent to the product tank and the product at the bottom of the tank is fed to the solvent recovery

column. The alcohol stream produced from the recovery process is recycled to the alcohol recovery unit, where

alcohol is removed and then the alcohol free product is recycled back to the High Purity Ethanol Plant.


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Figure 1: Location of the high purity ethanol plant (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

— Ensure the commitments contained in Condition 8.01 of the Exemption are completed, more specifically:

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

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

of the date of written request for such records”.


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

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

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

determine compliance to the EA conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (14 March 2018);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

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

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

included:

— Lorenzo Peters (Grade 2 Process Artisan).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— EA- 14.3.L.A.SAS.HPE

— SCO DQS ISO 14001 2015;

— SCO DQS ISO 9001 2015;

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

— EA_EX Handover_SCO_Solvents_CWU_EA;

— SCO DQS ISO 14001 2015;

— 3.1 RE EA Condition information;

— 3.1 RE EA Condition information1;

— 3.1 Earthing andLight Protection_2006;

— 3.1 Elec design criteria_SP-60-56_2010-05-29;

— SCO DQS BSOHSAS 18001 2007;

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

— CWUW SAS-490_2017-06-15;

— Air Pollution license;

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

— Induction_Mod3_Environment;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod6_EmergencyManagement;

— 6.1 U73 HPE plant inspections;


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— 6.1 073 Rotating maint inspection sheet;

— 6.1 073 Stat maintenance inspection task list;

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18;

— Environmental Complaints Register_2019-02-18; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the EA.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

to the requirements of the EA. Non-complaint conditions are given target completion dates, as

follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The auditor, Bronwyn Fisher was hosted by Broni van der Meer and Lorenzo Peters to whom we express our

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

provided below.

— Auditor: Bronwyn Fisher

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

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

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

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

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

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


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projects.

— 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

GENERAL CONDITIONS

1.01 This authorisation only refers to the High Purity Ethanol

Plant at Secunda, as specified above and described in 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 Act and Government

Notice R 1182 and 1183 of 5 September 1997.

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

condition.

None.

1.02 Authorisation is only granted in terms of Section 22 of the

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

exempt the holder from compliance with any other relevant

legislation.

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

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

compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

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

of legal compliance is commendable”.

Evidence:

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals

Operations.

None.

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

conditions in this authorization if, in the opinion of the

Department, it is environmentally justified.

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

Department has not changed, added or amended any of the

conditions within this EA.

None.

1.04 A copy of this authorization shall be available at the Sasol

Chemical Industries (Pty) Ltd Secunda, at all times and all

staff, contractors and sub-contractors shall be acquainted

with the contents of the authorization.

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

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

None.


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evidence that the responsible persons, Alfie Naidoo (Senior

Manager of Chemical Workup Units) and Wilem Jacobs (legal

appointee of Solvents, Sasol Secunda Chemical Operations), were

made aware of the EA in September/October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_CWU_EA.

ESTABLISHMENT OF THE HIGH PURITY ETHANOL PLANT

2.01 If any changes need to be made to the plant and/or associated

structures other than that which has been agreed upon, this

Department must be informed thirty (30) days in advance, to

be able to decide whether the changes need authorization.

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

made to the project description within the EA within the audit

period.

None.

2.02 The High Purity Ethanol must operate according to

recognised environmental standards after the precise standard

to be followed is accepted by this Department. In addition to

this, the requirements set by Sasol's Quality Management

Standards (QMS 918) will be adhered to.

C Sasol Secunda is an ISO Certified Facility and therefore operate in

accordance with the ISO standards. The auditor was provided with

the ISO 14001: 2015 certificate issued on 12 October 2016 and is

valid until 11 October 2019.

In addition, Sasol operates the facility in accordance with their

internal QMS standards, and is also an ISO 9001: 2015 certified

company.

Evidence:

— SCO DQS ISO 14001 2015

— SCO DQS ISO 9001 2015

None.

CONSTRUCTION AND OPERATION

3.01 Standards laid down by the SABS and National Fire

Prevention Association (NFPA) regarding i) lightning

protection as well as ii) fire detection, protection and fighting

systems must be followed and adhered to.

C Sasol have developed Sasol specification SP-60-56 rev1_2010-05-

29 for Electrical design criteria and Earthing and Lightning

Protection guidelines DG60-06-02-001_2006-01-06. SP-60-56

makes reference to SANS 10313 (Protection against Lightning-

Physical damage to structures and life hazard). In addition Sasol

have a Earthing and Lightning Protection: General Guidelines

None.


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(DG60-06-02-001).

Other codes which Sasol conform with are NFPA code 780

standard for the installation of lightning protection and API RP

545, Recommended Practice for Lightning Protection of Above

Ground Storage Tanks for Flammable or Combustible Liquids.

A general Electrical Design Criteria documentation provides for

information regarding the prevention of electrical fires.

Evidence:

— 3.1 RE EA Condition information

— 3.1 RE EA Condition information

— 3.1 Earthing andLight Protection_2006

— 3.1 Elec design criteria_SP-60-56_2010-05-29

3.02 The High Purity Ethanol plant must be incorporated into

Sasol's existing Hearing Conservation Programme in order to

comply with the minimum requirements of Environmental

Regulations for workplaces in terms of the Occupational

Health and Safety Act, 1993 (Act 85 of 1993).

C Sasol Chemical Operations have a valid BS OHSAS 18001: 2007

certification. The auditor was provided with proof of the

certification. The certification is valid from 12 October 2016 to 11

October 2019.

In addition the auditor was provided with a Noise survey and

impact assessment for hearing conservation purposes report for

SCO – Solvents Operations (Chemical Work-up West Production)

dated 31 July 2017 (Units 36, 37, 38, 38N and 73). The HPE Plant

is Unit No. 73.

Evidence:

— SCO DQS BSOHSAS 18001 2007

— SEC-116-2017-

CM(NOISE)(Chemical_Work_Up_West,_Production,_Units_

037,_038,_038N,_073)

None.

3.03 Illumination of the plant must comply with the statutory

requirements of Environmental Regulations for workplaces

in terms of the Occupational Health and Safety Act, 1993

(Act 85 of 1993).

NC Sasol has advised that no illumination certificate is available. The

occupational hygiene team has engaged with service providers to

conduct illumination survey for the whole Solvents area.

None.


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3.04 Care must be taken to comply with any other relevant section

of the Occupational Health and Safety Act, 1993 (Act 85 of

1993). This must be accomplished by incorporating the High

Purity Ethanol Plant into Sasol's NOSA Five (5) Star System.

C Sasol no longer use the NOSA 5 Star Safety System. Sasol are BS

OHSAS 18001: 2007 certified. The auditor was provided with

proof of the certification. The certification is valid from 12 October

2016 to 11 October 2019.

Evidence:

— SCO DQS BSOHSAS 18001 2007

None.

3.05 The High Purity Ethanol Plant's design capacity of 85 000

t/pa may not be exceeded. C Sasol confirmed with the auditor that the design capacity of 85 000

t/pa is not exceeded.

The auditor was advised that the AEL provides more a maximum

capacity of 340 tonnes per day (equivalent of 124 100 t/pa). Whilst

this is permission under the AEL, the capacity of 85 00 t/pa must

not be exceeded or else Sasol will be in contravention of this EA.

Evidence:

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

OFI: In the event that Sasol

wishes to operate above

85 000 t/pa (as permitted

under the AEL), an

amendment to this EA must

be sought.

3.06 No water, apart from firewater to be utilized for

firefighting/commissioning purpose, may be used during the

normal operation of the High Purity Ethanol Plant.

C Sasol confirmed with the auditor that no water is utilised for the

processing activities, but rather water is removed from feed to form

the product.

None.

3.07 No raw water/potable water may be utilized during the

normal operation of the High Purity Ethanol Plant. C Sasol confirmed with the auditor that no raw /potable water is used

during operations. Rather water is removed from the feed to form

the product.

None.

3.08 Stripped gas liquor to be obtained from the Acid Recovery

Units Cooling Water Systems should be used as a cooling

medium.

C Sasol advised the auditor during the audit that U73 cooling

medium is obtained from the Acid Recovery cooling towers

(71CT401A/B/C) which utilizes SGL (stripped gas liquor) as

cooling medium in all the heat exchangers utilizing cooling

water. The cooling towers were designed to utilize fans to ensure

dissipation of the heat from the water returning from the plant.

This was reported to be part of the standard design, and is not a

deviation from the authorisation.

None.


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3.09 All effluents or off-spec products should be recycled or re-

routed into the process or disposed of an a class H:H waste

disposal site. This Department must be notified of any such

products being disposed of at any hazardous waste site in

Mpumalanga or any other province, in order to legalise

transportation and dumping of such waste.

C Sasol have a Waste Management Procedure, (SGR-SHE-000017)

which is implemented across the Sasol complex. Waste Registers

were provided to the auditor for the audit period.

It must be noted that any off-spec product is sent back to the feed

tank for reworking. All by-products are either sent to the solvent

recovery plant or the alcohol recovery plant.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— CWUW SAS-490_2017-06-15.

None.

3.10 Fire water and not raw water must be used for

commissioning of the HPE Plant. N/A This condition is considered outside of the audit period

(construction pre-2014).

It is therefore considered not applicable.

None.

3.11 The contractual agreement regarding transport of product

should include guidelines on the official truck stops and

routes.

NC Sasol makes use of a risk-based approach for all product's lifecycle

in order to enable the safe and sustainable management of products

during its transportation. This includes the analysis &

interpretation of product transportation risk landscape as well as the

evaluation, identification and characterisation of the legal

landscape for transportation.

The Sasol Product Stewardship team further mitigates risk through

the implementation of the product transportation risk controls.

All road and rail makes use of the Renaissance (RSE) system to

track every detail of transportation.

Whilst performance reports on contractors, and general

transportation risk assessment procedures have been provided, the

auditor has not been provided with evidence that contractual

agreements with transporters include guidelines on official truck

stops and routes.

Contractual agreements with

transporters of the product

must include guidelines on

the official truck stops and

routes.

Target completion

Medium term


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AIR POLLUTION

4.01 Emission limits and operating conditions as stated in the

provisional registration certificates issued in terms of the

Atmospheric Pollution Prevention Act, 1965 (Act 45 of

1965), must be adhered to.

C The Gert Sibande District Municipality issued an Atmospheric

Emissions Licence for the Sasol Solvents Operations (Reference:

11/19/1 Govern Mbeki Sasol South Africa (Pty) Ltd

0017/2015/F02) in March 2015. The AEL covers all Solvent

Operations at the Sasol Secunda Complex including the High

Purity Ethanol Plant.

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

any emission exceedances from the plant.

Evidence:

— Air Pollution license;

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

— Environment Impact register_ New FY19_2019-02-18.

None.

RISK MANAGEMENT

5.01 All employees, contractors and sub-contractors employed by,

or delivering a service to the specific plant with regard to the

High Purity Ethanol Plant must be acquainted with the

characteristics and dangers associated with such a plant.

They must also be familiarised with emergency procedures

associated with the High Purity Ethanol Plant and any other

integrated structures that is relevant to this project.

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

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

Health & Environmental aspects and requirements of that

site/plant.

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

Sasol Solvents Operational areas. No person unaccompanied

unauthorised person will be allowed access to the solvents area

without undertaking solvents induction training. Sasol have advised

the auditor that the training includes risks associated with working

in the solvents area, operational and emergency procedures.

Evidence:

— Induction_Mod3_Environment

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod6_EmergencyManagement

None.


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INSPECTION AND MONITORING

6.01 The High Purity Ethanol Plant and its associated

infrastructure should be regularly checked to prevent

incidents from occurring. Inspection time frames must be

reviewed at pre-determined time-intervals.

C Sasol provided the following checklists to the auditor relating to the

High Purity Ethanol Plant:

— Weekly Plant Inspection on Unit 073

— Rotating Equipment Inspections

Evidence:

— 6.1 U73 HPE plant inspections

— 6.1 073 Rotating maint inspection sheet

— 6.1 073 Stat maintenance inspection task list

None.

DECOMMISSIONING

7.01 Decommissioning of the new High Purity Ethanol Plant may

not commence without the Department receiving, and

approving the formal rehabilitation plan for the plant six (6)

months in advance of the proposed decommissioning date.

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

this site redundant in the foreseeable future.

None.

ENVIRONMENTAL AUDITING

8.01 External environmental audit: Six (6) months after

commissioning of the plant, this Department must be

supplied with the external audit report. The report must cover

all environmental as well as operational aspects associated

with the plant.

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

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

None.

8.02 Internal Environmental Auditing: Sasol must conduct

internal environmental audits on a yearly basis. The results of

this internal audits must be forwarded to this Department for

monitoring purposes.

NC Sasol have not undertaken internal auditing of the EA on an annual

basis. This constitutes the first audit on the conditions of the EA to

date.

Sasol should undertake

annual internal audits going

forward.

Completion Target:

Short term


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REPORTING

9.01 The Department must be notified within 24 hours in the

event of non-compliance with any of the conditions of this

Authorization and/or in the case of an event which results in

people being injured etc.

NC Sasol has not advised the Department of non-compliances (as

identified in this audit) to date. This audit constitutes the first audit

of the EA, although condition 8.2 requires annual internal auditing.

Sasol have advised the auditor that no events which have result in

reportable injuries has occurred at the HPE Plant. The auditor

reviewed the incident register and has confirmed this statement.

Evidence:

— Copy of Environment Impact register_ New FY17;

— Environment Impact register_ New FY19_2019-02-18.

Going forwards, all non-

compliances must be

communicated to the

Department within the

specified timeframes.

Target completion

Short term

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

conditions of the authorization must be kept in good order.

Such records must be made available to this Department

within seven (7) workdays of the date of written request for

such records.

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

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

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

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

as set out in the authorization and Environmental Scoping

Report received by this Department, 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. Sasol has advised the auditor that they are aware of this

condition.

None.

9.04 Any complaint regarding the said activity must be brought to

the attention of the Department within 24 hours after

receiving the complaint. A complaint's register must be kept.

This register must contain up to date information by

members of this Department within seven (7) days, after

requesting such information.

C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the High Purity Ethanol Plant for the audit period.

Sasol have advised that should a copy of the complaints register be

requested by the relevant Department, it will be made available.

Evidence:

— Environmental Complaints Register_2019-02-18.

None.


WSP June 2019

Page 15

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

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

below.

Table 3: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 4 1 0 3

ESTABLISHMENT OF THE HIGH PURITY ETHANOL PLANT 2 1 0 1

CONSTRUCTION AND OPERATION 11 8 2 1

AIR POLLUTION 1 1 0 0

RISK MANAGEMENT 1 1 0 0

INSPECTION AND MONITORING 1 1 0 0

DECOMMISSIONING 1 0 0 1

ENVIRONMENTAL AUDITING 2 0 1 1

REPORTING 4 1 1 2

Total Count 27 14 4 9

Total Percentage 52% 15% 33%

Percentage Compliance with Applicable Conditions 78%


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

the total proportion of compliance for the facility.

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

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

0

2

4

6

8

10

12

Sectional Count Contribution

C

NC

N/A

14

4

9

Total Compliance

C

NC

N/A


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

percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

52%

15%

33%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(14/3/L/A/SAS.HPE)

SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION … · 9.03 Non-compliance with, or any deviations...

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