SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION … · This audit is designed to meet the requirements...

SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14/2/10/NH/3W - MTGE DE-BOTTLENECKING

02 AUGUST 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14/2/10/NH/3W - MTGE DE-BOTTLENECKING

SECUNDA SYNFUELS OPERATIONS: GAS

PRODUCTION

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: AUGUST 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

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

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

EA Ref:

14/2/10/NH/3W

Final – Compliance

Audit

EA Ref:

14/2/10/NH/3W

Date July 2019 August 2019

Prepared by Jenny Cope Jenny Cope

Signature

Checked by Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 046 046

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

Jenny Cope

Associate

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: Environmental Compliance

Specialist

Broni van der Meer

Gas Production – Production Senior

Manager

Boysie Mokoka and Steve Namane

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION

WSP August 2019

TABLE OF CONTENTS

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

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

1.2 MTGE De-Bottlenecking Project –

14/2/10/NH/3W .......................................................... 1

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

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

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

3.2 Site Discussion ........................................................ 4

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

3.4 Audit Compliance Assessment .............................. 6

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 26

5.1 Environmental Authorisation ............................... 26


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TABLES

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

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

TABLE 3: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 26

FIGURES

FIGURE 1: MTGE DE-BOTTLENECKING PROJECT (UPGRADES WERE UNDERTAKEN ACROSS THE SASOL PRIMARY AREA) (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 27

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 27

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 28

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 28

APPENDICES

A ENVIRONMENTAL AUTHORISATION (14/2/10/NH/3W)


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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: 14.2.10.NH.3W issued on 29 September 1998, as

amended) for the period for the period December 2014 to February 2019.

1.2 MTGE DE-BOTTLENECKING PROJECT –

14/2/10/NH/3W

The Medium Term Gas Expansion (MTGE) project was the outcome of a capacity review. The review

highlighted that there was an optimisation opportunity, to increase capacity of gas production at the Sasol

Synthetic Fuels plant. The increase in gas production was effected largely through existing infrastructure, taking

the form of a ‘de-bottlenecking’ exercise, rather than the establishment of new facilities. The expansion resulted

in gas load ability increase to enable a possible 3.2 million m3n/hour1 annual averaged pure gas load2. Upgraded

equipment included one set of additional heat exchangers in the Gas Cooling water supply system (additional

tempered water cooling), and a surge vessel system on the gas condensate handling (gas liquor) system (see

Figure 1).

1 Cubic metres of gas at “normal conditions” per hour. 2 It is noted that Sasol has not reached that enabled capacity annual average.


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Figure 1: MTGE De-bottlenecking Project (upgrades were undertaken across the Sasol 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). MTGE I and

II projects were completed prior to 2000.

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;

— Ensure the commitments contained in Condition 9.03 of the Authorisation are completed, more specifically:

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

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

of the date on a written request by the Department 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 discussion (19 June 2019);

— 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 DISCUSSION

Jenny Cope conducted a site-specific interview on 19 June 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:

— Ed Koper (TBC)

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— SSO_GP_14.2.10.NH.3W_MTGE_1998-09-29;

— 14.2.10.NH.3W_V1_1998-09-29;

— SSO DQS ISO 14001 2015;

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

— EA_EX Handover_SSO_GP-CP;

— 2.01_EA_MTGE_Poof of commencement_1998-11-04;

— 2.02_EA_MTGE_Poof of commence_1998-04-22;


— 4.02 16.04.2019;

— 4.03 Ambient Air Quality Report;

— 4.03 Passive sampler results;

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— 201904 SSO continuous emission monitoring quaterly report_January to March 2019 rev_final;

— SSO Phenosolvan FY19_Q2;


— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-05;

— 4.07_EA_MTGE_Charlie1Odour_1998-10-29;



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— AEL Sasol Synfuels 0016-2018-F03 (2018)

— 4.08 Secunda Annual Dust Report 2018;

— 201810 SSO continuous emission monitoring monthly report_5 December 2018 rev_02;

— 201901 SSO continuous emission monitoring monthly report for January 2019 rev_00;

— 201902 SSO continuous emission monitoring monthly report for February 2019 rev_00;

— 4.08 Secunda Monthly Dust Report Feb 2019;

— 4.08 Secunda Monthly Dust Report Jan-19;

— 4.08 Secunda Monthly Dust Report Mar 2019;

— WUL SIC SSA_200322144_2008-11-21;

— WUL SIC SSA amendment_200322144_2010-01-08;

— 5.02_EA_MTGE_Design Philosophy_1999-02-11;


— 5.9 Mitigation Measures;

— 5.9 Mitigation Measures 2;

— Environmental Complaints Register (Period: December 2014 – March 2019);

— Copy of Environment Impact register_ New FY17;

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31;

— Environment Impact register_ New FY19_2019-02-18;

— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2;

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

— Gasification_2016-11-28;

— EA_14.25.16 EV 11;

— Risk Assessment: SGI-SHE-000014;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod7_Occupational;

— 5157_Sasol Secunda emissions and dust fallout reports_201905_rev00;

— 201904 SSO continuous emission monitoring monthly report for April 2019 rev_00;

— Annual emission report for Sasol Synfuels 0016-2015-F02_FY18;

— Emission Report for SSO_8 May 2018;

— FY18 Annual emission report for Sasol Oil 0019-2015-F02 final;

— FY18 Annual emission report for SCO_Solvents_0017_2015_F02_final;

— Phenosolvan VOC Sampling Report _FY18_Q2_Resampling_V01;

— VOC Sampling report for Phenosolvan_FY18_Q1_V01;

— AEL 0016-2019-F03 Secunda Synfuels Operations – certificate;

— AEL 0016-2019-F03 Secunda Synfuels Operations - license issued 23 April 2019;

— EIA Final;

— FY19 201903 Dustfall monitoring monthly report_5 May 2019;

— Groundwater monitor WISH Database_Survey New_201900523;

— RESMS Weekly Monitoring_2008-2019;

— RN_1901592_SAS GESI Secunda Monthly Dust Report Mar-19;

— RN_1901557_SAS GESI Secunda Monthly Dust Report Feb-19;

— SSO Stack Sampling Schedule 2019_2020;

— Raw water intake figures for May 2019;

— Raw & Rand water;


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— 5152_Sasol Secunda quarterly emissions and dust fallout reports_201904_rev00;

— 201904 SSO continuous emission monitoring quaterly report_January to March 2019 rev_final;

— FY19 201902 Dustfall monitoring monthly report_5 April 2019;

— SSO Water Recovery FY19_Q2 PM and others;

— SSO Water Recovery FY19_Q2 TOC;

— SSO Water Recovery FY19_Q3 PM and others;

— SSO Water Recovery FY19_Q3 TOC;

— 20190604 Summary of coal contract FY18-19 - May included – West;

— 20190604 Summary of coal contract FY18-19 - May included – East; 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

A brief summary of the external auditors’ experience is provided below.

— Auditor and Project Manager: 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.

— 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.

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 refers only to the project specified above

and described in the Record of Decision. Separate

applications must be lodged for any other development and/

or activity which is covered by Sections 21&22 of the Act

and Government Notice R 1182 of 5 September 1997.

N/A Noted. The project remains as per the authorised activities for

which the EA was granted.

Whilst a number of subsequent improvements to the associated

plant have been made, each of these was accompanied by separate

environmental authorisation applications. Sasol is aware of the

requirement to lodge separate applications should further works be

required for the authorised activity.

None.

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

Environment Conservation Act, 1989 (Act 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 Sasol Complex operates with a dedicated environmental and

legal team, and therefore works to ensure that they comply with

applicable legislation.

In addition, 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:

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels

Operations.

None.


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

conditions in this exemption if, in the opinion of the

Department, it is environmentally justified or if cleaner

technology has been developed.

N/A Noted. Sasol has advised that no changes or amendments have

been communicated to Sasol by the Department since issue of the

EA.

None.

1.04 A copy of this authorisation shall be available at the plant at

all times and all staff, contractors and sub-contractors shall

be acquainted with the contents of this Authorisation and the

Environmental Management Plan of SSF.

C Sasol’s environmental team have soft copies of the authorisation

and where/when necessary, communicate any specific details or

requirements to the relevant business units.

Additionally, copies are maintained at the SHE: Environment

department and on SAP EC and SharePoint. Any specific

requirements are communicated during SHE induction training.

None.

ESTABLISHMENT OF THE ENTERPRISE

2.01 This authorisation is repealed if the project has not

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

authorisation.

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

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

None.

2.02 Fourteen (14) days written notice must be given to this

Department before commencement with construction

activities.



None.

CONSTRUCTION AND OPERATION

3.01 The MTGE project will commence as has been agreed

between the Department and SSF, subject to the conditions

set by this Department.



None.

3.02 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

N/A Noted. The project remains as per the authorised activities for

which the EA was granted.

None.


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advance, to be able to decide whether the changes need

authorisation.

Whilst a number of subsequent improvements to the associated

plant have been made, each of these was accompanied by separate

environmental authorisation applications.

3.03 For the purpose of taking effluent samples and measuring the

flow, the necessary facilities shall be provided in wastewater

outlets. The details shall be agreed with the Department of

Water Affairs & Forestry.

N/A The auditor was advised that there is no net wastewater outflow

from the MTGE project-associated equipment. No wastewater is

released to the environment, as both the ash water and gas liquor

effluents are internal circulated and re-used.

None.

3.04 Increased production of coal for the MTGE project is only to

occur at the Twistdraai East and West shafts. NC 90% of the feedstock to the gas production facility is coal (the

remaining 10% is natural gas from Mozambique). The plant

utilises a blended coal product, supplied by six coal suppliers (five

Sasol-suppliers and one external supplier).

The Twistdraai shafts are no longer utilised, as the product in the

vicinity of these shafts has been extracted, and replacement shafts

have been sunk to access the coal seams in a commercial, practical

and safe manner. These shafts have themselves have been subject

to environmental assessment and authorisation.

There has been no further increase in coal requirements since the

EA was granted.

However, the condition specifically states that “increased

production of coal for the MTGE project is only to occur at the

Twistdraai East and West shafts”, and an amendment should have

been sought at the time that the Twistdraai shafts were identified

for replacement.

This non-compliance is associated with the specific inclusion of

the reference to “shafts” within the condition wording.

An amendment to the

condition should be sought

in order to remove reference

to specific coal shafts, and

reflect the multiple sources

of supply coal.

Target Completion:

Long term

AIR POLLUTION

4.01 Whenever dust or airborne particles from the Plant are

identified as a problem by either this Department or any

other interested or affected party, the necessary steps must be

C The auditor was verbally advised that there are no airborne

particles or dust related issues at the Gas Production Plant. Ash

None.


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taken by SSF to remedy the matter to the satisfaction of all

relevant authorities. Any such events must be recorded in the

occurrence or complaints register which must be available

for inspection by this Department.

from the gasifiers is handled as a wet material and does not

generate dust.

Where there is the potential for airborne particles or dust

generation the emission is passed through a scrubber. The steam

plant utilises pulverised fuel, and electrostatic precipitators are

employed to control particulate matter.

A complaint register for internal and external complaints is kept up

to date for the entire Sasol Secunda Operations. Available records

go as far back as 2008. No complaints related to dust or airborne

particles at the Gas Production plant were identified.

Evidence:

— Environmental Complaints Register (Period: December 2014

– March 2019);

— EIA Final.

4.02 Sulphur emissions to the atmosphere may not increase.

Hydrogen sulphide emissions may not exceed the present

limit of 11.5 Sth (tonnes of sulphur per hour), monthly

average. This is a temporary concession granted to SSF

Sasol subject to a continued programme to reduce the

emissions of sulphur to the atmosphere.

C Two sources of sulphur emissions are identified; the boiler plant

and from the gasification process.

There is commercial benefit to the recovery of elemental sulphur,

hence recovery from H2S is carried out.

Sasol provided the auditor with the Sulphur Recovery Report dated

16 April 2019.

Sasol’s current AEL permit requirements set a limit of 10.50

tonnes of sulphur per hour, and the 30 day average sulphur plant

emissions have not exceeded this limit for the data period provided

(May 2018 – April 2019).

The reduction of the limit from 11.5 to 10.5 tonnes of sulphur per

hour demonstrates that Sasol is committed to reduce the emissions

of sulphur to the atmosphere.

Evidence:

— 4.02 16.04.2019;

— EIA Final.

OFI:

Sasol should seek an

amendment to the EA to

recognise that sulphur

emission levels are reflected

in the current AEL.

Target Completion:

Long term


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4.03 SSF Sasol must institute a programme to investigate

emissions of VOCs (stack and fugitive) to the atmosphere as

well as the control of these emissions. SSF Sasol must

provide the Department of Environmental Affairs and

Tourism (Directorate Air Pollution Control) and the

Department of Environmental Affairs and Tourism

(Mpumalanga) with regular reports (every 3 months)

regarding the progress of these investigations.

NC Sasol has provided the auditor with an Ambient Air Quality

Monitoring Report (October 2016 – March 2017), in addition to

Passive Sampler Results for the period January 2017 – November

2018).

The Ambient Air Quality Monitoring Report includes stack

emissions, and fugitive monitoring is further described in Sasol’s

Fugitive Emission Monitoring Plan.

Evidence of the submission to Gert Sibande District Municipality

of quarterly Dust Fallout Monitoring and Continuous Emissions

Monitoring Reports was provided to the auditor. These reports do

not cover VOC emissions.

VOC emissions for the Phenosolvan plants are reported within the

“Quarterly Continuous Emission Monitoring Report”

(documentation reviewed for April 2019), and Emission Testing

Reports (documentation viewed for December 2018 and February

2019 sample runs). No evidence of VOC sampling for equipment

other than the Phenosolvan plants was viewed, however the auditor

was advised that at the time of the audit Phenosolvan was the only

measuring point.

However, no evidence of submission to the departments listed in

this condition was provided to the auditor, although some evidence

of submission to Gert Sibande District Municipality was provided

(as required by Sasol’s current AEL). It is acknowledged that

submission to these authorities is likely considered superseded by

the AEL requirements.

Evidence:

— 4.03 Ambient Air Quality Report;

— 4.03 Passive sampler results;

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— 5157_Sasol Secunda emissions and dust fallout

reports_201905_rev00;

— EIA Final;

It is recommended that

Sasol seek an amendment to

bring this condition in line

with Sasol’s current AEL

reporting requirements.

Target Completion:

Long term


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— 201904 SSO continuous emission monitoring quaterly

report_January to March 2019 rev_final;



— Annual emission report for Sasol Synfuels 0016-2015-

F02_FY18;

— Emission Report for SSO_8 May 2018;

— FY18 Annual emission report for Sasol Oil 0019-2015-F02

final;

— FY18 Annual emission report for

SCO_Solvents_0017_2015_F02_final;

— Phenosolvan VOC Sampling Report

_FY18_Q2_Resampling_V01;

— VOC Sampling report for Phenosolvan_FY18_Q1_V01.

4.04 SSF Sasol must investigate the factors contributing to the

forming of secondary visible pollution. Where possible, the

necessary preventative steps must be taken. SSF Sasol must

provide the Department of Environmental Affairs and

Tourism (Directorate Air Pollution Control) and the


(Mpumalanga) with regular reports (every 3 months)

regarding the progress of these investigations.

NC The auditor was provided with an Air Quality and Dust Monitoring

Program Report for the Waste Ash Disposal Site (dated July 2010).

Dustfall reporting from 2018 and 2019 was also provided.

Evidence of the submission to Gert Sibande District Municipality

of quarterly Dust Fallout Monitoring and Continuous Emissions

Monitoring Reports was provided to the auditor.

However, no evidence of submission to MDEAT or the Directorate

Air Pollution Control was provided to the auditor. It is

acknowledged that submission to these authorities is likely

considered superseded by the AEL requirements.

Evidence:

— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-

05;

— 5157_Sasol Secunda emissions and dust fallout

reports_201905_rev00;

— FY19 201903 Dustfall monitoring monthly report_5 May

2019;

The condition should be

amended to bring the

monitoring reporting

requirements into line with

the requirements of the

current AEL.


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— RN_1901592_SAS GESI Secunda Monthly Dust Report Mar-

19;

— 4.08 Secunda Annual Dust Report 2018.

4.05 The emission limits and operating conditions as stated in the

provisional registration certificates issued in terms of the

Atmospheric Pollution Act, 1965 (Section 9) for this project

must be adhered to.

C The facility is covered under the current AEL, and documentation

viewed by the auditor indicates that Sasol is operating the facility

within the AEL permitted emission levels.

The auditor notes that the Atmospheric Pollution Act, 1965

(Section 9) has been repealed, and Sasol operates according to the

National Environmental Management: Air. Quality Act

(NEMAQA), 2004 (Act No. 39 of 2004).

Evidence:

— AEL Sasol Synfuels 0016-2018-F03 (2018);

— EIA Final;

— 4.02 16.04.2019;

— 201810 SSO continuous emission monitoring monthly

report_5 December 2018 rev_02;

— 201901 SSO continuous emission monitoring monthly report

for January 2019 rev_00;

— 201902 SSO continuous emission monitoring monthly report

for February 2019 rev_00.

OFI:


amendment to update this

Condition, to remove

reference to superseded

legislation.

Target Completion:

Long term.

4.06 Revised permits must be obtained for the incinerators in

view of the increased throughput anticipated before the

operation of the expanded plant may commence.



Furthermore, the facility is covered under the current AEL.

Evidence:

— AEL Sasol Synfuels 0016-2018-F03 (2018).

None.

4.07 The odour problem experienced at the Charlie 1 domestic

waste disposal site must be addressed, and mitigation N/A The odour problems at Charlie 1 domestic waste disposal site

originated from former disposal of organic material at the site two

years prior to the commencement of the MTGE project. The

practice was abandoned and no further problems have been

OFI:


WSP August 2019

Page 15


measures implemented within a time frame as specified by

this Department and other relevant authorities.

experienced. This occurred outside of the audit period, and

compliance is considered no longer applicable.

Sasol’s provided evidence to the auditor that the authorities had

been advised of the situation.

Evidence:

— EIA Final;




— 4.07_EA_MTGE_Charlie1Odour_1999-01-11.


amendment to remove this

condition.

Target Completion:

Long term

4.08 Increased dust generation potential, as result of the increased

height of the ash dumps and fine coal dams, must be

quantified and appropriate mitigation measures implemented

within a time frame as specified by this Department.

C The auditor was verbally advised that coarse ash is discarded to the

coarse ash stack in a wet condition, which mitigates against dust

generation. Once the maximum permitted height is reached for the

stack, the stack is stabilised with vegetation and topsoil further

stabilising the stack. Sasol is currently not increasing the coarse

ash stack, rather increasing width.

Waste fly ash is also generated wet, and sets hard upon drying,

therefore dust generation is limited.

All fine coal is utilised within the Sasol site (boilers at Steam

Plant), and in the event that the fine coal is not required for use in

the plant it is pumped into water dams (slurry ponds) and kept

underwater and is therefore not at risk of generating dust. Fine coal

is recovered as required, and there is water-spraying in the fine

coal recovery areas to suppress dust (in the event that this is

required).

The EIA states that fly ash emissions (released from the main tall

stacks) will not increase for MTGE (no increased load on the

boilers).

The surface moisture on the coal from the mines means that there

is no dust / fine coal particles into the air. In dry conditions, the

None.


WSP August 2019

Page 16


coal supply stockpiles are coated in water from hydrants to

mitigate against dust generation.

The auditor was provided with dust monitoring reporting, which

evidences that dust generation is quantified and appropriate

mitigation measures implemented.

Evidence:

— EIA Final;

— 4.04 AS335 Air quality-dust monitoring-Ash stack_2010-07-

05;

— 4.08 Secunda Annual Dust Report 2018;

— 4.08 Secunda Monthly Dust Report Feb 2019;

— 4.08 Secunda Monthly Dust Report Jan-19;

— 4.08 Secunda Monthly Dust Report Mar 2019.

WATER POLLUTION

5.01 Water used for the cleaning of the dams and tanks before,

during or after the production season, must be treated

according to the specifications of the Department of Water

Affairs & Forestry (DWAF), or any other relevant authority,

before it is released into the environment. A copy of this

specifications must be forwarded to this Department before

31 October 1998.

C The gas production plant is considered a zero discharge facility.

All stormwater within Sasol is collected onsite and, if deemed

contaminated, is sent to the API oily water sewer and recovery

system.

Water is not utilised for cleaning of the dams. During the tank

cleaning process settlement product is removed as solid waste, and

tanks are only steam-cleaned in the event that the tanks require re-

coating. In such instances the wastewater is contained and removed

from site as liquid waste.

The requirement to forward a copy of the treatment process /

equipment specification prior to 31 October 1998 is considered

outside of the audit period.

Evidence:


— IWWMP SIC 2015 Final_2018-05-15;

None.


WSP August 2019

Page 17


— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2.

5.02 No untreated water may be released into the environment,

and if untreated water cannot be stored or properly treated

onsite, it must be disposed of on a registered waste site for

hazardous waste. The treatment of cleaning water should be

included in the EMP.

C Noted. The SSF factories are considered zero discharge facilities.

All stormwater within Sasol is collected onsite and, if deemed


system.

Evidence:


— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2.

None.

5.03 All storm water that originates on the property must be

collected and treated to specifications set by DWAF or any

other relevant authority, before it is released to the

environment. Where relevant the necessary permits must be

obtained from the relevant authority and copies thereof

forwarded to this Department within 30 days of obtaining the

said permits.

C All stormwater within Sasol is collected onsite and, if deemed


system. The oily water is skimmed and analysed. Upon acceptable

water quality parameters being achieved the treated water is

released to the environment.

The entire Sasol complex is operated under one Water Use Licence

(WUL).

Evidence:



— WUL SIC SSA_200322144_2008-11-21; and,

— WUL SIC SSA amendment_200322144_2010-01-08.

None.

5.04 Splash pads must make provision for the containment of

storm water. No untreated water may be released or allowed

to be released to the environment, and if untreated water

cannot be stored or properly treated onsite, it must be

disposed of on a registered waste site for hazardous waste.

The treatment of runoff water should be included in the

EMP.

C There are no splash pads at the gas production plant. All

stormwater within Sasol Synfuels Operations is collected onsite

and, if deemed contaminated, is sent to the API oily water sewer

and recovery system. The oily water is skimmed and analysed.

Upon acceptable water quality parameters being achieved the

treated water is released to the environment

Evidence:

OFI:

It is recommended that an

amendment is sought to

remove reference to splash

pads.

Target Completion:


WSP August 2019

Page 18


— SIC IWMMP Appendix 1 – Gasification 2017 Rev 2 Long term

5.05 The water balance and the water quality at the various

compliance points may not be impacted on by the MTGE

project.

C The water balance of the Gas Production plant is included in the

Business Unit’s IWWMP. Ground water monitoring is conducted

biannually (every six months) and quarterly. In terms of water

quality, there are no monitoring boreholes in immediate proximity

to the gasification plants both on the East and West complexes.

However, there are six active boreholes located within the Primary

area which are utilised for monitoring. The auditor note a number

of exceedances in the November 2017 sampling run, however

these exceedances cannot be directly attributed to the gasification

plants.

Furthermore, water that is used in the gasification process is

recycled and reused in the process. The SSF factories are

considered zero discharge facilities.

Evidence:



— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31.

None.

5.06 The impact of the surface mine water system must be

resolved before the commissioning of the MTGE project can

commence at the end of 1999.



None.

5.07 The integrated water management plan must be presented to

the Department of Water Affairs and Forestry and the


(Mpumalanga) by December 1998. This integrated

management plan must adequately address the issue of

excess mine water. Mitigation measures to be implemented

must also be proposed and submitted to the relevant

authorities for comments and approval.



None.


WSP August 2019

Page 19


5.08 The integrated water management plan must be approved by

the Department of Water Affairs and Forestry and the


(Mpumalanga) before the commission of the MTGE project

can commence.


(construction pre-2014). The plant is already in operational phase.

It is therefore considered not applicable.

None.

5.09 Mitigation measures are to be implemented to address

surface water, groundwater and soil contamination at the

black products site.

N/A Noted. The Black Products site is closed off and was completely

rehabilitated.

Sasol have a long term monitoring plan which is outlined in the

IWWMP and as required by the WUL and WML.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-

11-20

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

20

None.

WASTE

6.01 All waste from the Plant shall be stored, handled and

disposed of in an environmentally acceptable way, and as

directed by this Department or any other relevant authority.

C The waste register for the gasification plant was viewed, and waste

appear appropriately classified and disposal methods listed are

acceptable.

Waste management is carried out via implementation of a Waste

Management procedure 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.

Evidence:

None.


WSP August 2019

Page 20


— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Gasification_2016-11-28.

6.02 Ash from the incinerators may only be disposed of on an

authorised site. C Fine ash from the incinerators is sent to the ash plant, where it is

reused, or to the fine ash dams (a licensed facility). Coarse ash is

sent to the Outside Ash facility, which is also an authorised site.

Evidence:

— EIA Final

None.

6.03 In order to compensate for the ongoing production of

catalyst waste products and to provide alternative waste

storage, recycling and stabilizing facilities by the year 2004,

details regarding the project must be provided to the

Department of Water Affairs and Forestry and the


(Mpumalanga) through the submission of ongoing progress

reports every (three) 3 months.

N/A A document on the classification of spent catalyst, dated August

1998 was provided to the auditor, in addition to a minimisation

study dated September 1997.

However, compliance with this condition is considered outside of

the audit period, as it is stated that alternative waste storage,

recycling and stabilizing facilities are required by 2004 (i.e.

outside of the audit period).

Evidence:

— 6.03_EA_MTGE_Waste Minimization Study;

— 6.7 Waste stream Audit;

— 6.3 MTGE EA Conditions_Spent Cat treatement

None.

6.04 The MTGE project must slot into the waste minimisation

strategy of the Sasol Secunda Complex. C A waste minimisation study for the MTGE project was completed

in 1997; this document included the waste registers applicable to

the project at the time of commencement. Furthermore, Sasol has a

Waste Management Procedure as well the latest waste registers

applicable to all the business units in its Integrated Management

System.

The MTGE EIA was provided to the auditor, which also references

waste minimisation procedures, and states that MTGE will have no

negative effect on the waste minimisation initiatives that are

currently being implemented.

None.


WSP August 2019

Page 21


Evidence:

— 5.9 Mitigation Measures;

— 5.9 Mitigation Measures 2;

— 6.03_EA_MTGE_Waste Minimization Study;


000017_Rev10_2017-09;


6.05 The MTGE project must also form part of the

comprehensive integrated Sasol Secunda Waste Emissions

Management Programme.

C Waste management across the Sasol complex (including at the

gasification plants) is carried out via implementation of a Waste

Management procedure 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.

Evidence:


000017_Rev10_2017-09;


None.

6.06 The issue of the spent catalyst must be resolved and

approved by the authorities before the MTGE project is

commissioned at the end of 1999.



Regardless, a document on the classification of spent catalyst,

dated August 1998 was provided to the auditor, in addition to a

minimisation study dated September 1997.

Evidence:

— 6.6 MTGE EA Conditions_Spent Cat treatement;

— 6.7 Waste stream Audit.

None.


WSP August 2019

Page 22


6.07 Any lateral expansions of existing solid waste facilities will

require authorisation in terms of the Environment

Conservation Act, 1989 (Act 73 of 1989).

N/A Noted. There have not been any expansions or additions since the

receipt of the RoD (i.e. within the audit period) that have not been

separately authorised.

Evidence:

— 6.7 Waste stream Audit.

None.

6.08 The Black Products Waste Disposal site is to be closed by

2004 and rehabilitated. The rehabilitation plan for the

disposal site must be authorised by the Departments of

Water Affairs and Forestry and Environmental Affairs and

Tourism at least 60 days before planned closure of the site.



The Black Products site is closed off and was completely

rehabilitated.

None.

6.09 Alternative waste storage, recycling and stabilization

facilities are to be identified and authorised by the

Departments of Water Affairs & Forestry and Environmental

Affairs & Tourism before the year 2004.



None.

RISK MANAGEMENT

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

or delivering a service to SSF, shall be acquainted with the

characteristics and dangers associated with the processes

used by SSF. They shall also be familiar with these

processes as well as the emergency plans associated with it,

and shall receive instructions and procedures necessary to

prevent emergency situations.

C A work instruction for Minimum requirements for environmental

risk assessments for all Sasol Synfuels and Sasol Chemical

Operations is also available on Sasol’s web-based system, and its

latest review date is 01 February 2017.

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.

Safety and emergency information for Sasol is also available on its

web-based system and every staff member has access to it. At each

plant, personnel undergo induction that includes all the health and

safety aspects as well as the emergency procedures of the

None.


WSP August 2019

Page 23


gasification plants. Refresher trainings are held every three years

from the initial induction for each personnel.

Evidence:

— Risk Assessment: SGI-SHE-000014;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod7_Occupational.

MONITORING

8.01 After operation of the Plant has commenced, monitoring

results as per the approved monitoring plan, must be

recorded in the monitoring register.

C A Department-approved consolidated monitoring register and

monitoring plan for gas production were not provided to the

auditor.

However, the auditor was provided with a stack sampling schedule

(2019-2020), and evidence of both groundwater and surface water

monitoring. Monitoring is completed in line with the AEL and

WUL.

Monitoring requirements and results are logged into a central

Environmental Information System, and the auditor was provided

with screenshot evidence of this record.

Evidence:

— SSO Stack Sampling Schedule 2019_2020;

— RESMS Weekly Monitoring_2008-2019;

— Groundwater monitor WISH Database_Survey

New_201900523.

OFI:

An amendment should be

sought to bring the

monitoring recording and

reporting requirements into

line with the current AEL

and WUL requirements.

Target Completion:

Long term

8.02 Monitoring for water pollution must be carried out according

to the existing monitoring programme. C An IWWMP for the Gas Production business unit exists, and

groundwater monitoring takes place annually.

Monitoring is completed as stipulated in the requirements of the

Sasol Complex-wide WUL.

None.


WSP August 2019

Page 24


Evidence:


— WUL SIC SSA_200322144_2008-11-21; and,

— WUL SIC SSA amendment_200322144_2010-01-08.

REPORTING

9.01 SSF shall keep regular records of use of raw materials,

auxiliary materials water and all other materials potentially

hazardous to the environment, and of the generation and

disposal of wastewater and waste. These records shall be

audited by this Department as well as any other relevant

authority, and shall be available for inspection at all times.

C Sasol keeps records of the volumes of raw materials used and

waste disposed of, principally for commercial purposes. The main

inputs are coal and water. The auditor was provided with evidence

of the water usage records and coal usage records.

Sasol makes use of a web based Information Management System

(IMS) that includes a comprehensive Document Management

System (Easy DMS) where all supporting documentation for all its

authorisations and other legal obligations are kept and are available

to prove compliance with legal requirements. These shall be made

available to the department upon request.

Evidence:

— Raw & Rand water

— 20190604 Summary of coal contract FY18-19 - May included

– East

— 20190604 Summary of coal contract FY18-19 - May included

- West

None.

9.02 The company must notify this authority within 24 hours in

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

the authorisation and/ or in the case of any event which

results in emissions or discharges of pollutants.

NC Non-compliances have been noted during this audit relating to air

quality reporting requirements and coal supply source, and it is

understood that the department has not been notified as such.

Going forwards, Sasol

should notify the

department of any non-

compliances with this EA in

a timely manner, in

accordance with this

condition.

Target Completion:


WSP August 2019

Page 25


Medium term

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

conditions of the Authorisation must be kept in good order.

Such records must be made available to this Department

within seven (7) workdays of the date on a written request by

the Department for such records.

N/A This audit represents the first required audit for this EA. Prior to

the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this EA was required.

None.

9.04 Non-compliance with, or any deviation from the conditions

as set out in the Exemption is regarded as an offence and,

after reasonable provision has been made for remedial

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

of the Act.

N/A Noted. None.

9.05 Any complaints regarding the said development must be

brought to the attention of the Department within 24 hours

after receiving the complaint. A complaints register must be

kept for inspection by members of this Department.

C

The complaints register from 2008 to date was available for review

and there have been no complaints lodged with regards to the

operation of the pipeline for the 2014-2018 audit period.

Evidence:

— Environmental Complaints Register (Period: December 2014

– March 2019).

None.


WSP August 2019

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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 ENTERPRISE 2 0 0 2

CONSTRUCTION AND OPERATION 4 0 1 3

AIR POLLUTION 8 4 2 2

WATER POLLUTION 9 5 0 4

WASTE 9 4 0 5

RISK MANAGEMENT 1 1 0 0

MONITORING 2 2 0 0

REPORTING 5 2 1 2

Total Count 44 19 4 21

Total Percentage 43% 9% 48%

Percentage Compliance with Applicable Conditions 83%


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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

0123456789

10

Sectional Count Contribution

C

NC

N/A

19

4

21

Total Compliance

C

NC

N/A


WSP August 2019

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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

43%

9%

48%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(14/2/10/NH/3W)

SECUNDA SYNFUELS OPERATIONS: GAS PRODUCTION … · This audit is designed to meet the requirements...

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