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SASOL CHEMICAL OPERATIONS: SOLVENTS DIVISION

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17/2/5 EV 7 - UPGRADE OF THE O&S RAIL LOADING

06 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17/2/5 EV 7 - UPGRADE OF THE O&S RAIL LOADING

SASOL CHEMICAL OPERATIONS:

SOLVENTS DIVISION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref: 17/2/5 EV 7

Final – Compliance

Audit

EA Ref: 17/2/5 EV 7

Date April 2019 June 2019

Prepared by Bronwyn Fisher Bronwyn Fisher

Signature -

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 021 021

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

S I G N A T U R E S

PREPARED BY

-

Bronwyn Fisher

Environmental Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

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

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

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

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

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

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

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

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

CLIENT

SHE Specialist: Environment Broni van der Meer

Solvents Production Senior Manager Wikus Vermeulen

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Bronwyn Fisher

ENVIRONMENTAL EXEMPTION 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 O&S Loading Zone (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(Authorisation Number: 17.2.5 EV 7) ..................... 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 ... 14

5.1 Environmental Exemption .................................... 14


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 14

FIGURES

FIGURE 1: THE O&S LOADING BAY (RED BLOCK) WITHIN SASOL SECUNDA PRIMARY AREA (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 15

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 15

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 16

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 16

APPENDICES

A ENVIRONMENTAL AUTHORISATION (17.2.5 EV 7)


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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 Exemption (Reference number: 17.2.5 EV 7 issued on 26 August 2003) for the period for the

period December 2014 to February 2019.

1.2 O&S LOADING ZONE (SASOL CHEMICAL

OPERATIONS: SOLVENTS DIVISION)

(AUTHORISATION NUMBER: 17.2.5 EV 7)

An Environmental Exemption (Reference number: 17.2.5 EV 7) was granted on 26 August 2003 by the

Mpumalanga Department of Agriculture, Conservation and Environment (MDACE) for the upgrading of the by-

pass track and shunting leg at the entrance to olefins and Surfactants and the re-configuration of the rail tanker

loading racks.

The Olefins and Surfactants Rail Loading Zone (Figure 1), known as the 1-hexene rail loading facility, is used

to load pentene and hexene into the RTCs and/ or ISOs destined for Richards Bay, KwaZulu- Natal. The daily

dispatch list consisting of all order numbers, RTCs / ISOs serial numbers and scheduled dispatch generated by

the SAP R/3 business system, is forwarded via the loading / dispatch offices Management System interfacing

with the metering/billing system (PLC based) located at the loading rack. Loading of 1-hexene and 1-pentene

products can only commence after it has been confirmed that the hexene and pentene products tanks (300TK-

6001 and 300TK-6002) is on full specification.

The 1-hexene and 1-pentene loading stations, have two cable pull cars and whinhes (300ME- 8103/4). The

RTC/ISO flat bed rail car brake system is released by the operator before the car puller is moved towards the rail

car (s) until it reaches them. Thereafter, the car puller is coupled to RTC/ISO container. All the empty

RTC/ISOs containers (max 9/car puller) are pulled in to the loading bay until the first three in case of hexene

and the first two for pentene to be loaded reach the dedicated loading positions respectively.


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Figure 1: The O&S Loading Bay (Red Block) within Sasol Secunda Primary Area (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

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

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

kept in good order. Such records must be made available on request by this Department.”


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

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

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

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (14 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

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:

— Lawrence Ratombo (Area Manager Production);

— Lazarus Moropa (Area Manager Octene); and

— Petunia Zondi (Production Asset Management Specialist, SOL Hex,Oct 1&2 & Rail Production).

It should be noted that due to the fact that the site is a National Key Point, and that an intrinsically safe camera

was not available, no photographs were able to be taken during the site walk through.

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— 17.2.5EV7_ROD_2003-09-26;

— SCO DQS ISO 14001 2015;

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

— EA_EX Handover_SCO_Solvents_Hex_OC1_2_Rail;

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

— Air Pollution license;

— Top Risk Rail FY19 – Phineas.

— Hexene Pentene operating Manual;

— Compliance_Water_Secunda Complex.dox;

— Induction Mod3_Environment;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;

— 3.05_GW_Report _Prj6143_2018-06-19;

— 3.06_RMM SW management_2016-11-24;


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— 3.05_RESM Weekly Monitoring_2004-2019;

— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09

— Hexene_SAS490_2017-06-15;

— 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 Exemption.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The auditor, Bronwyn Fisher, was hosted by Broni van der Meer, Lawrence Ratombo, Lazarus Moropa and

Petunia Zondi 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,


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

projects.

— Lead Auditor and Quality Assurance: Ashlea Strong

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

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

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

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

scoping and impact assessment studies, environmental management plans, waste and water management, as

well as the provision of environmental management solutions and mitigation measures. She has been

involved in the management of a number of large EIAs within South Africa and has environmental auditing

and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed

in the audit process.

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

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

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

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

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

document.

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

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

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

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

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This exemption refers only to the project specified above and

described in the Record of Decision. Separate application/s

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

or near proposed development, which is covered by section

21 and 22 of the Environment Conservation Act, No. 73 of

1989 Act and Government Notice R1182 and R1183 of 5

September 1997.

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

condition.

None.

1.02 Exemption is only granted in terms of Section 28A of the

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

exempt the holder from compliance with any other relevant

legislation.

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

Audit.

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

compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

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

of legal compliance is commendable”.

Evidence:

— SCO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals

Operations

None.

1.03 No development may take place on the area of concern

without the necessary permits/approvals and/or service

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

between the following institutions:

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

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

None.


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1.3.1 Govan Mbeki Municipality

1.3.2 DWAF

1.3.3 Spoornet

1.04 This Department may change, add 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 added or amended any of the conditions within

this authorisation.

None.

1.05 A copy of this authorization shall be available at the

applicant office at all times and all staff, contractors and sub-

contractors shall be acquainted with the contents of this

exemption.

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 evidence that the responsible persons, Wikus Vermeulen

(Senior Manager of Hexene, Octene 1 & 2 and Railing Production)

and Willem Jacobs (legal appointee of Solvents), were made aware

of the Exemption in September / October 2016.

Evidence:

— EA_EX Handover_SCO_Solvents_Hex_OC1_2_Rail.

None.

2. ESTABLISHMENT

2.01 This exemption is repealed if the development has not taken

place within 2 years from the date of this exemption. N/A This condition is considered outside of the audit period


None.

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

monitor and approve the clearing and rehabilitation of the

site.

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

redundant in the foreseeable future.

None.


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3. CONSTRUCTION AND OPERATION

3.01 An Environmental Management Plan must be compiled and

submitted for approval. NC Sasol have advised the auditor that no EMPr has been developed

for the rail loading facility.

Sasol should develop an

EMPr for the operating of

the rail loading zone.

Target Completion

Medium term

3.02 Material for constructing the railway foundations must be

obtained from a commercial source. N/A This condition is considered outside of the audit period


None.

3.03 Where vegetation cover has been removed, control measures

must be used to prevent soil pollution. N/A This condition is considered outside of the audit period


None.

3.04 If any changes need to be made to the development or

associated infrastructure, this Department must be informed

thirty (30) days in advance to decide whether the change will

need authorization.

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

to the development or associated infrastructure.

None.

4. AIR POLLUTION

4.01 Air pollution should be handled as indicated by relevant

authorities.

C Sasol have a registered certificate (APPA) for the Alpha Olefins

Plant (certificate number: 1308/5) issued on 11th March 2002. This

was then converted to an Atmospheric Emissions Licence (AEL),

with the promulgation of the National Environmental

Management: Air Quality Act (Act No. 39 of 20014) which

required the conversion from APPA to an AEL.

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.

None.


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Evidence:

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

— Air Pollution license.

5. WATER POLLUTION

5.01 Any water pollution of surface as well as ground water

should be prevented at all cost.

C Sasol have an Integrated Waste and Water Management Plan

(IWWMP) which aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

The auditor noted the following precautions that have been put in

place to prevent surface and ground water pollution:

— The entire loading zone is bunded and hardsurfaced;

— Each tanker loading bay is provided with a drain to the oily

water sewer via a slop pit kept under water level. The slop pit

is situated 40 m west of the slap south of the rail lines;

— Surface and groundwater monitoring is carried out in

accordance with the IWWMP.

Surface water monitoring is conducted on a weekly basis as well as

real Surface water monitoring is conducted on a weekly basis as

well as real time for the various Receiving Environmental Surface

water Monitorings (RESMs).

Ground water monitoring is conducted biannually and quarterly for

the various Receiving Environmental Groundwater Monitorings

(REGMs).

The November 2017 Water Quality Monitoring Report compiled

JMA Consulting, dated November 2017, was provided to the

auditor to review. The report confirmed the number of sampling

points and the frequency in which they are sampled. In addition, all

None.


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staff, contractors and visitors are provided with induction training,

which includes pollution of the environment.

Evidence:

— Hexene Pentene operating Manual;

— 3.05_GW_Report _Prj6143_2018-06-19;

— 3.06_RMM SW management_2016-11-24;

— 3.05_RESM Weekly Monitoring_2004-2019

— Compliance_Water_Secunda Complex.dox;

— Induction Mod3_Environment;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.

6. WASTE

6.01 All waste generated shall be stored, handled and disposed off

in a licensed landfill site. C The auditor was advised that waste management is completed via

implementation of a Waste Management procedure (SGR-SHE-

000017 REV10) that addresses the approach to manage waste in

line with the internationally accepted waste hierarchy, whereby

disposal to land is considered the last management option to

undertake once avoidance, re-use, recycling, recovery and

treatment options have been considered / eliminated. The

procedure further details waste disposal and management through

characterization and classification that is detailed in site specific

waste registers.

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

the registers specifically related to the Solvent operations were

checked during the audit. It is however noted that little to no waste

is produced at the loading zone.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Hexene_SAS490_2017-06-15.

None.


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7. RISK MANAGEMENT

7.01 Risk associated with transportation of products/by-products

must be identified, quantified and mitigation measures put in

place.

C The auditor was presented with part of a document which

evidenced that Sasol had acknowledged a ‘key undesirable event

during product transportation, storage or handling’ as a top risk.

The document for FY19 presents causes, consequences,

mitigations (preventative and corrective) and a risk assessment

taking into account probability and impact.

Evidence:

— Top Risk Rail FY19 – Phineas.

None.

8. MONITORING

8.01 Monitoring should be done as indicated by relevant

authorities.

C Due to the nature of the facility (rail loading), there is no

Atmospheric Emissions Monitoring required at the loading zone.

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

time for the various Receiving Environmental Surface water

Monitorings (RESMs)

Groundwater monitoring is conducted biannually and quarterly.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2.

None.

8.02 This Department will monitor compliance with this

authorization. N/A Noted. Sasol advised the auditor that the Department routinely

attends site to inspect the rail loading facility.

None.

9. REPORTING

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

conditions of the authorization must be kept in good order. N/A This audit represents the first required audit for this Exemption.

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

None.


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Such records must be made available on request by this

Department.

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

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

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

offence and, after reasonable provision has been made for

remedial action, will be dealt with in terms of section 29, 30

and 31A of the Act.

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

condition.

None.

9.03 Any complaint regarding the said development must be

brought to the attention of this office within 24 hours after

receiving the complaint.

C The auditor has reviewed the complaints register maintained by

Sasol. No complaints have been received in relation to the

operating of the loading zone for the audit period.

Evidence:

— Environmental Complaints Register_2019-02-18

None.

9.04 A complaint register must be kept up to date for inspection

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

Sasol. No complaints have been received in relation to the

operating of the loading zone for the audit period.

Evidence:

— Environmental Complaints Register_2019-02-18

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITIONS 5 1 0 4

ESTABLISHMENT 2 0 0 2

CONSTRUCTION AND OPERATION 4 0 1 3

AIR POLLUTION 1 1 0 0

WATER POLLUTION 1 1 0 0

WASTE POLLUTION 1 1 0 0

RISK MANAGEMENT 1 1 0 0

MONITORING 2 1 0 1

REPORTING 4 2 0 2

Total Count 21 8 1 12

Total Percentage 38% 5% 57%

Percentage Compliance with Applicable Conditions 89%


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

presents the total proportion of compliance for the facility.

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

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

0

1

2

3

4

5

6

Sectional Count Contribution

C

NC

N/A

8

1

12

Total Compliance

C

NC

N/A


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

the total percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

38%

5%

57%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(17.2.5 EV 7)

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