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SASOL ENERGY SECUNDA TANKFARM
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17.2.4.GS10 - INSTALLATION OF CONTINGENCY FLARES
03 APRIL 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT
17.2.4.GS10 - INSTALLATION OF CONTINGENCY FLARES
SASOL ENERGY SECUNDA TANKFARM
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: APRIL 2019
WSP
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KNIGHTSBRIDGE, 33 SLOANE STREET
BRYANSTON, 2191
SOUTH AFRICA
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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
Exemption Ref:
17.2.4.GS10
Final – Compliance
Audit
Exemption Ref:
17.2.4.GS10
Date March 2019 April 2019
Prepared by Ziyaad Kadwa and
Bronwyn Fisher
Ziyaad Kadwa
Signature
Checked by Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534
Report number 018 018
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
Ziyaad Kadwa
Consultant
REVIEWED BY
Jenny Cope
Associate
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf
and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding
of their compliance with the conditions included in the Exemption.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report, except where otherwise indicated in the Report.
P R O D U C T I O N T E A M
CLIENT
SHE: Environmental Compliance
Specialist
Broni van der Meer
Tank Farm Production Senior Manager Khutso Mohaleamalla
WSP
Associate Jenny Cope
Lead Auditor Anri Scheepers
Lead Auditor Ashlea Strong
Consultant Ziyaad Kadwa
Consultant Bronwyn Fisher
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL ENERGY SECUNDA TANKFARM
WSP April 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Installation of Temporary Contingency Flares for
Project Turbo (SCC) in the Primary Area
(Exemption Number: 17.2.4.GS10) ........................ 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 .............................. 4
3.5 Audit Team ............................................................... 5
3.6 Assumptions and Limitations ................................ 7
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 11
5.1 Environmental Exemption .................................... 11
ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL ENERGY SECUNDA TANKFARM
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 8
TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 11
FIGURES
FIGURE 1: SEST – CONTINGENCY FLARE (SOURCE: GOOGLE EARTH, 2018) .............................................. 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 11
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 12
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 12
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ............................ ..13
APPENDICES
A ENVIRONMENTAL EXEMPTION (17.2.4.GS10)
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1 INTRODUCTION
1.1 TERMS OF REFERENCE
Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP
Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit
and compile an audit report according to the requirements of the National Environmental Management Act (No.
107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the
Exemption (Reference number: 17.2.4.GS10 issued on 24 June 2005) for the period December 2014 to February
2019.
1.2 INSTALLATION OF TEMPORARY CONTINGENCY
FLARES FOR PROJECT TURBO (SCC) IN THE
PRIMARY AREA (EXEMPTION NUMBER: 17.2.4.GS10)
An application for exemption from requiring a full Environmental Impact Assessment was submitted by Sasol to
the Mpumalanga Department of Agriculture and Land Administration (MDALA) on 07 April 2005; for the
installation of temporary contingency flares for Project Turbo (SCC) in the primary area.
The exemption was granted by the MDALA on 24 June 2005, and included eight (8) commitments which Sasol
are required to comply with.
Figure 1 provides the location of the flare within Sasol Secunda Primary area.
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Figure 1: SEST – Contingency Flare (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.
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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 (11 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 11 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:
— Fanie van der Westhuizen (Process Engineer II).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— AEL Sasol Oil 0019-2015-F02 (2015);
— Environment Impact register_ New FY19_2019-02-18;
— Environmental Complaints Register_2019-02-18;
— 3_EX_APPA2003Cert A1972.27_Valid2005-02-04_2003-08-05;
— 3_EX_APPA2005Cert A1972.27_Valid 2006-11-30_2005-09-19;
— 6_EX_SCCContingencyFlare_APPA app_REF1019_2005-08-11;
— 7_EX_Scope_Current Flare Site;
— 7_EX_Scope_Flare Ground Plan;
— 17.2.4.GS10_2005-04-07;
— 17.2.4.GS10_2005-06-24; 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.
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It should be noted that some of the Exemption conditions were apportioned according to the elements requiring
compliance assessment therein. Although some elements of the condition may have been compliant, if one of
the elements was determined to be non-compliant, the entire condition has been reported as such (and counted
as such during percentage compliance calculation). This apportionment further allowed for the development of
focussed recommendations and timeframes.
Table 1: Compliance Level Definition and Target Completion Dates
COMPLIANCE LEVEL DEFINITION
Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or
relevant actions were implemented.
Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented
according to the requirements of the Exemption. Non-complaint conditions are given target
completion dates, as follows:
— Short term: 0 – 6 months.
— Medium term: 6 – 12 months.
— Long term: 12 – 18 months.
Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.
— Conditions marked as “Noted” are considered information points only.
— Where conditions are considered “not auditable” within the scope of this assessment this
is stated and explained within the condition commentary.
Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion
dates).
3.5 AUDIT TEAM
The Consultant, Bronwyn Fisher, was hosted by Broni van der Meer and Fanie van der Westhuizen, to whom
we express our gratitude for their time and attention during our visit. A brief summary of the external auditors’
experience is provided below.
— Auditor: Ziyaad Kadwa
Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal
Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the
Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it
part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural
Development for 3 years. He is currently completing his BSc Honours in Environmental Management part
time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a
number of high profile clients in various industries. He has three years of auditing experience, and has
successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,
Impala Platinum and NPC (InterCement). He has also done environmental management programme audits
for BRPM and for various infrastructure projects as part of environmental control officer duties.
— 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
projects.
— Project Manager and Quality Assurance: Jenny Cope
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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.
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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
GENERAL CONDITIONS
1 The flaring of material will happen inside the Secunda
primary area, Ptns of the farmsGoedehoop 290 IS,
Twistdraai 285 IS andMiddelbult 284 IS, highveld ridge
District.
C The location of the activity has not been changed or altered, and is
occurring on the property as described. The location was verified
during the site visit.
None.
2 Flaring might not happen at all, however it is an option that
must be available when needed. N/A Statement noted by Sasol. None.
3 The flare could be temporarily utilised for a year. C After the initial year, the flare was included in an extension of the
APPA permit. The flare was then included in a NEMAQA
application and was included as part of the license issued for Sasol
Oil (0019/2015/F02).
Evidence:
— AEL Sasol Oil 0019-2015-F02 (2015).
None.
4 Other options were considered i.e. The two existing flares on
the Western side of the factory (Pit flare with capacity of
10m3/h and Sea Dragon Flare with capacity of 20m3/h)
which made the option of utilizing the Eastern site to be a
more viable option as it is big enough to cater for the 40m3/h
of SCC material that could be flared.
N/A Statement noted by Sasol. None.
5 There should not be any explosion issues. C No explosion issues have been reported since the commissioning
of the flare. An environmental impact register is maintained by
Sasol’s Environmental Department. All incidents are investigated
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
and reported in line with the procedure (SGR-SHE-000023) and as
per legal requirements.
The environmental impact register was checked for the 2017, 2018
and 2019 periods, and no incidents related to this specific flare
were recorded for this audit period.
Environmental Risk Assessments are completed every five years
throughout the complex, in order to identify and mitigate any
potential explosion risk.
Evidence:
— Environment Impact register_ New FY19_2019-02-18; and,
— Risk Assessments (SGI-SHE-000014).
6 Flares will be totally smokeless. C As per the documentation submitted with the original APPA
application, a Schlumberger flare is installed which achieves
smokeless flaring with crude oil.
In addition, no complaints have been logged on the complaints
register for the audit period regarding smoke from this flare.
Evidence:
— 8_EX_SCCContingencyFlare_APPA app_REF1019_2005-
08-11; and,
— Environmental Complaints Register_2019-02-18.
None.
7 An internal Scoping Exercise has been undertaken which
has identified and addressed all issues of soil and water
pollution that the project might have.
N/A Statement noted by Sasol. None.
8 You are further required to lodge an application with
CAPCO for a Flaring Permit. C An application to CAPCO was made on 16 August 2005.
Evidence:
— Application for the Registration of a Temporary Contingency
Flare for Project Turbo (SCC) Plant in Terms of the
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Atmospheric Pollution Prevention Act (Act 45 of 1965)
(August 2005).
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5 SUMMARY OF THE AUDIT FINDINGS
5.1 ENVIRONMENTAL EXEMPTION
The audit findings have been summarised into the following categories: compliance, non-compliance and not
applicable. The overall audit findings concerning compliance to the Exemption conditions are as listed in Table
3 below.
Table 3: Summary of Exemption Compliance Audit Findings
SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A
GENERAL CONDITIONS 8 5 0 3
Total Count 8 5 0 3
Total Percentage 63% 0% 38%
Percentage Compliance with Applicable Conditions 100%
Figure 2 illustrates the number/count contribution of the findings of the Exemption Compliance Audit 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
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Figure 3: Overall count findings on compliance to the Exemption conditions
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
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Figure 5: Overall percentage findings on compliance to the Exemption conditions
APPENDIX
A ENVIRONMENTAL EXEMPTION
(17.2.4.GS10)