SECUNDA SYNFUELS OPERATIONS: WATER AND …...2019/06/27 · WSP compiled an audit checklist to...

SECUNDA SYNFUELS OPERATIONS: WATER AND ASH

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14.25.16 EV 11 - BLACK PRODUCTS SITE

27 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

14.25.16 EV 11 - BLACK PRODUCTS SITE

SECUNDA SYNFUELS OPERATIONS:

WATER AND ASH

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: 14.25.16 EV

11

Draft v2 for Review –

Compliance Audit

EA Ref: 14.25.16 EV

11

Final – Compliance

Audit

EA Ref: 14.25.16 EV

11

Date April 2019 June 2019 June 2019

Prepared by Tutayi Chifadza Tutayi Chifadza Tutayi Chifadza

Signature

Checked by Ashlea Strong Ashlea Strong Ashlea Strong

Signature

Authorised by Jenny Cope Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534 41101534

Report number 033 033 033

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

REPORTS\033_SSO_WA_EA_14.25.16 EV 11\01 Draft report

S I G N A T U R E S

PREPARED BY

Tutayi Chifadza

Consultant

REVIEWED BY

Ashlea Strong

Principal Consultant

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

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

compliance with the conditions included in the Environmental Authorisation and associated Environmental

Management Plan.

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

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

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

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

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

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

SASOL

SHE: Environmental Compliance

Specialist

Broni van der Meer

Water and Ash Production Senior

Manager, Secunda Synfuels Operations

Timothy Ndlovu

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Tutayi Chifadza

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: WATER AND ASH

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Black Products Site (Authorisation Number:

14.25.16 EV 11)......................................................... 1

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

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

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

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

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

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

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 47

5.1 Environmental Authorisation ............................... 47

5.2 Environmental Management Plan ........................ 50


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TABLES

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

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

TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 20

TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 47

TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 50

FIGURES

FIGURE 1-1: BLACK PRODUCTS SITE (SOURCE: GOOGLE EARTH, 2018) .............................................. 2

FIGURE 5-1: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 48

FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 48

FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 49

FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 49

FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 51

FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 51

FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 52

FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 52


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APPENDICES

A ENVIRONMENTAL AUTHORISATION (14.25.16 EV 11)


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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: 14.25.16 EV 11 issued on 4 December 2000) as well as

the associated Environmental Management Plan (dated: 2002) for the period December 2014 – February 2019.

1.2 BLACK PRODUCTS SITE (AUTHORISATION NUMBER:

14.25.16 EV 11)

The Sasol Synfuels process at Secunda co-produces a spectrum of solid, liquid and gaseous wastes and by-

products. The “Black Products” portion of these waste products were disposed and contained at the “Black

Products Site”. The Black Products Site predominantly contained a mixture of tars and tar solids/sludge, oil, water,

pitch and synthol gunk.

Sasol needed to close and rehabilitate the Black Products site to make the total area available for coarse ash

stacking by 2004. In doing so, Sasol also needed to create an alternative facility for disposal, storage, treatment

or recycling of future black products. The emphasis was on recovery, recycling and treatment of black products

as Sasol recognised major synergies between rehabilitation process for the first Black Products site and a new

processing facility, handling future black products to be generated.

The Environmental Directorate of the Mpumalanga Department of Agriculture, Conservation and Environment

granted the authorisation on 4 December 2000 with reference number 14.25.16 EV 11. The Black Products site is

currently being rehabilitated, ahead of the advancing Coarse Ash Dump that will eventually cover it.

Rehabilitation at this Area entails the removal of some of the products such as pitch for reuse in manufacturing,

mixing the remaining products at a ratio of 1:5 with coarse ash and fine ash and compacting the mixture to

engineering standards. This will significantly reduce the seepage potential, implementing a similar interceptor

drain system as is used for the FADs prior to covering with coarse ash, and finally covering the area with a deep

layer of coarse ash. A Waste Management Licence (WML) was issued for this facility on 4 April 2013.

The location of the Black Products site at the Sasol Synfuels facility is indicated in Figure 1-1 below.


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Figure 1-1: Black Products Site (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,

achieve the objectives and outcomes laid out in these documents;

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

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr;

— Identify the need for any changes to the avoidance, management and mitigation measures provided for in the

EMPr;

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

— Ensure the commitments contained in Condition 7.1 of the EA 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 of 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 EA and associated EMPr conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (26 March 2019);

— Review of documentation relevant to the conditions of the EA and associated EMPr (e.g. records,

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Tutayi Chifadza conducted the site inspection on 26 March 2019. The findings and observations of the site visit

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

interviewed included:

— Broni van der Meer (SHE: Environmental Compliance Specialist);

— Rouxtjie Strydom (Area Manager Production);

— Sipho Mahlangu (Production Foreman); and

— Nonhlanhla Nhlapo (Senior Process Technician).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— SSO DQS ISO 14001 2015;

— Amended Waste Management Licence Waste Ash Site;

— Bi-Annual External Waste Management Licence Compliance Report – Waste Ash Disposal Site_September

2018;

— BP_Aspect register 26 August 2002(revised);

— 3.1_BP6 Seepage Cutoff Kickoff Minutes;

— 15-064_-_BPS_and_BP6_Capping_WORK_-_Quote_on_PMI_022_REV_3_-_2015-06-25;

— 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;

— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4;

— Amended Waste Management Licence Waste Ash Site;

— Fugitive Emission Monitoring Plan_2018-10-18 updated;

— Compliance_Air_Secunda Complex;

— Environmental emergency procedure (Rev 6): SGR-SHE000023;


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— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-000031);

— External WAS Audit_2018-09-18;

— 3.3.1 Organogram_SHE Air_2018-09-17;

— 3.3.1 Organogram_SHE WWLB_2018-09-03;

— Induction_Mod1_1SHE Excellence;

— Induction_Mod4_ProcessSafetyManagement;

— Induction_Mod5_WorkPlaceSafety;

— Induction_Mod6_EmergencyManagement;

— Induction_Mod7_Occupational;

— 6.01_Waste monitoring committee_Terms of Reference_2017-10-24;

— 6.01_Establish waste monitoring committee_2017-10-24;

— Environmental Complaints Register_2019-02-18

— Compliance_Complaints_Secunda Complex;

— Environmental complaints procedure_SGR-SHE-000022_Rev05_2019-01;

— Phase 1_Contaminated Land Assessment_November_2015_Final 1.0;

— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of 2_2018-08-28;

— 033_41101534_20190125_Sasol_SSO_WA_EA_14.25.16 EV 11_V1;

— J.53_EnvNoise 5439(Final) ver1_2016-08-26;

— Environmental Complaints Register_2019-02-18;

— Site photos; and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

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

Where conditions are not directly specified within documentation, for instance within older EMPrs that were

compiled and submitted as Aspect Registers, auditable conditions have been defined by utilising either mitigation

measures or aspects that were defined within the EMPr. In some instances this has required the minor re-wording

of original text contained within the EMPr, in order to specify an auditable condition. WSP has used its

professional expertise and independence to ensure that such interpretation of wording is both auditable and

balanced.

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 and associated EMPr conditions were apportioned according to the elements

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

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

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

development of focussed recommendations and timeframes.


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Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

to the requirements of the EA and associated EMPr. Non-complaint conditions are given target

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Auditor, Tutayi Chifadza was hosted by Broni van der Meer, Rouxtjie Strydom, Sipho Mahlangu and

Nonhlanhla Nhlapo to whom we express our gratitude for their time and attention during our visit. A brief

summary of the external auditors’ experience is provided below.

— Auditor: Tutayi Chifadza

Tutayi Chifadza has 5 years’ experience and is an Environmental Consultant for WSP at the Johannesburg,

Bryanston office in the Environmental Services division. He holds a Bachelor of Science (Honours), Applied

Science in Environmental Technology, and Bachelor of Science, Chemistry from the University of Pretoria.

Tutayi has experience in undertaking Water Use Licence (WUL) applications, Basic Assessments and

Environmental Impact Assessments as well as technical compliance audits including for Transnet and Sasol.

He conducted Water Use Licence audits for four sections at South 32 and its reporting. He is also responsible

for conducting WUL and Waste Management Licence audits.

— Lead Auditor and Quality Assurance: Ashlea Strong

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

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

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

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

impact assessment studies, environmental management plans, waste and water management, as well as the

provision of environmental management solutions and mitigation measures. She has been involved in the

management of a number of large EIAs within South Africa and has environmental auditing and training

experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed in the audit

process.

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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


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

recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts no

liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

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

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

document.

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

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

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

report. If this report is used as part of a main report, the report in its entirety must be included as an appendix or

separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.1 This authorisation refers only to the project specified above

and described in the Record of Decision, hereafter referred to

as "the interface project" or development". 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. None

1.2 Authorisation 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.

Evidence:

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27

— SSO DQS ISO 14001 2015

None

1.3 No development may take place on the area of concern

without the necessary permits/approvals and/or service and/or

lease agreements from other authorities.

C The site was approved for development when an EA was issued by

the Provincial Department on 4 December 2000 with 14.25.16 EV

11 as the reference number. A WML was issued on 4 April 2013 for

the ash handling facility with reference number 12/9/11/L1/6. Four

variations on the amended WML were further issued: which

included:

— Waste Licence Variation for height Increase of Fine Ash Dam

5 (Reference Number: 12/9/11/L1/6/V2);

None


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— Waste Licence Variation for condition 4.7 (Reference Number:

12/9/11/L1/6/V2);

— Waste Licence Variation for condition 4.1 and 4.9 (Reference

Number: 12/9/L1/6/R1/V5);

— Waste Licence Variation for condition 1.1.2, 3.2, 4.5, 6.2.1.1,

6.2.2.2, 6.2.1.3, 6.2.2.1, 6.2.3.1, 6.2.4.1, 6.2.4.3, 6.2.4.2,

6.2.5.1 and 6.2.6.1 (Reference Number: 12/9/L1/6/V3 dated 28

March 2018).

A copy of the WML and the September 2018 compliance audit

report by SRK Consulting was available for review.

Evidence:

— Amended Waste Management Licence Waste Ash Site

— Bi-Annual External Waste Management Licence Compliance

Report – Waste Ash Disposal Site_September 2018

— 14.25.16 EV 11_Black Products Site_2000-12-04

1.4 Copies of relevant documents mentioned in 1.3 above must be

forwarded to this Department for record keeping purposes. N/A This condition is considered outside of the audit period

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

None

1.5 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. None

1.6 An EMP must be formulated to minimise and manage

potential environmental impacts during the closure and

development of the Black products site. The EMP must

include the spill contingency plan with specific emphasis on

the extraction of wastes from the ponds, transportation of the

waste and off-loading.

C An EMP was formulated in the form of an Aspects Register during

the time of application of the EA in order to manage potential

environmental impacts during the closure and development of the

Black products site. The EMP does cover the spill contingency plan

with specific emphasis on the extraction of wastes from the ponds,

transportation of the waste and off-loading. Furthermore, The

capping project is almost done and spills will no longer be an issue

on the site.

Evidence:

None


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— BP_Aspect register 26 August 2002(revised)

1.7 The development must comply to all migratory measures as

set out in the scoping report. C The Scoping Report mitigatory measures were included as part of

the EMPr and have been evaluated in Table 3. No non-compliances

were noted.

None

2. ESTABLISHMENT

2.2 This Authorisation is repealed if construction has not started

within two (2) years from the date of this authorisation. N/A This condition is considered outside of the audit period


None

2.2 Sasol must implement strategies to provide opportunities for

local labour to be involved in the closure and redevelopment

of the site.

C The construction and operational phases of the project are not

applicable and this condition focuses on decommissioning for the

required audit period. Sasol targeted reputable engineering

companies as primary contractors and has used several contractors

for the project at different stages. The main contractors also employ

subcontractors. The site rehabilitation has been divided into phases

with different contractors used at each phase. WBHO was the last

contractor used along with Jones and Wagener, however, Lynco

Projects (Pty) Ltd based out of Evander (local) have been used

before on another phase of the rehabilitation capping work done.

Minutes for kick-off meetings and the quotes submitted were

available for review.

Evidence:

— 3.1_BP6 Seepage Cutoff Kickoff Minutes

— 15-064_-_BPS_and_BP6_Capping_WORK_-

_Quote_on_PMI_022_REV_3_-_2015-06-25

None

2.3 This Department should be notified in the earliest convenient

time of any decision to discontinue operation of the said

development.

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

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

the Black Products site is closed off and has been rehabilitated.

None


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3. WATER POLLUTION

3.1 Prevention of groundwater pollution should receive the

highest priority. C The Outside Ash Disposal Area which includes the Black Product

site consists of 20 groundwater boreholes monitored quarterly, 15

groundwater boreholes monitored bi-annually, and 17 groundwater

boreholes monitored annually. Three groundwater monitoring

reports by JMA Consulting dated November 2017, May 2018 and

August 2018 by JMA Consulting were available for review. Within

these reports groundwater quality is compared to drinking water

quality standards, as presented in SANS 241:2015, or SANS

241:2006 (where 2015 parameters are unavailable). It is recognised

that such standards are considered conservative, as no potable water

abstraction points are located in the vicinity. Boreholes REGM-154

and REGM-154S were identified as reflective of ‘downstream of

Black Products’, and were reported upon for May 2017, August

2017, November 2017 and August 2018 sample runs. REGM-154S

was reported to be impacted, with contaminant concentrations

elevated above drinking water standards for electrical conductivity,

total dissolved solids, calcium, magnesium, sodium, sulphate, lead,

mercury and selenium. The groundwater reports specifically

highlight that the groundwater in REGM-154S is “deteriorating”.

However, the Black Products area is currently being rehabilitated,

and will eventually be covered by the Coarse Ash Heap. Ensuring

ongoing implementation of rehabilitation measures at the Black

Products area is action item 4.5.4 in the Sasol IWWMP 2016 – 2020.

Furthermore, Sasol received authorisation for the installation of

seepage reduction and stream flow monitoring weirs (Ref:

MP/EIA/0000524/2012) from the provincial MDEDET on 12

December 2013. The authorisation included additional cut-off

trenches around the Coarse Ash Dump and van Niekerk Dam, as

well as a pipeline at the Coarse Ash Dump. This project was

authorised during the July – December 2015 period. Construction

on Phase 1a (process water section) and Phase 1b (Dam 11) of the

project have been completed. Phase 2 (WAS section) was completed

In order to remain compliant

with this condition going

forwards, Sasol must

continue to place highest

priority on the prevention of

groundwater pollution by

investing in future-available

mitigation techniques, and

researching best available

technology.

Sasol must demonstrate a

continued focus on

groundwater pollution

prevention.

Target period:

Long term


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in October 2018. Interception drains around FAD 5, Coarse Ash

Dump and the Black Products area are visible.

The water in the ash handling areas is controlled in a closed circuit

via cement channels and is reused in the system as much as possible.

The channels are designed to prevent groundwater pollution.

The entire Outside Ash area is regarded as a “dirty area”, and

contaminated run-off is mostly contained within this area by means

of a stormwater berm and trench along the southern, south-western

and western boundary.

It has been evidenced to the auditor that prevention of groundwater

pollution is receiving high priority, with significant investment

made in pollution mitigation measures. Sasol is taking practical

steps in order to combat the legacy of limited containment structure

practices of the past. This condition has been marked compliance

only on the basis that such investment in pollution prevention has

been made, as deterioration in water quality has been noted.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

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

20

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

20

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31

3.2 Proper drainage for storm water runoff should be put in place. 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

Black Products site falls as part of the outside ash facilities.

As described above, the ash sites have cement lined stormwater

channels and trenches as well as raised walls to allow for stormwater

None


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runoff to containment facilities before discharge. Since the Black

Products site is capped, all the water that flows on the surface is

easily channelled into the existing stormwater drains that lead to the

collecting dams.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

— SIC IWWMP Appendix 1 - Outside Ash 2017 Rev 4

Stormwater collection trenches

3.3 Adhere to any other water management conditions as set out

by DWAF or any other relevant authority. C The Synfuels site as a whole has a WUL. The IWWMP indicates

that “A Water Use Licence (“WUL”) was issued on 21 November

2008 (“2008 WUL”) in terms of Chapter 4 of the National Water

Act 36 of 1998 (“NWA”), and an amendment to this WUL has been

issued on 8 January 2010 (“2010 WUL Amendment”) to authorise

water uses associated with the industrial operations at the SIC.

Condition 5 in the 2008 WUL indicates that the WUL will be

reviewed every three (3) years, and a review was thus initiated

None


WSP June 2019

Page 14


during 2014. The 2010 WUL Amendment specify in condition 12.1

that an Integrated Water and Waste Management Plan (“IWWMP”)

must be submitted for approval when the WUL is being reviewed.”

The WML has recently been amended to reference the quality

requirements listed in the WUL as previously the WML listed its

own requirements.

Evidence:


— IWWMP SIC 2015 Final_2018-05-15


4. AIR POLLUTION

4.1 Air pollution should be handled as indicated by relevant

authorities. C Sasol makes use of an integrated approach to air quality

management as governed by National Environmental Management:

Air Quality Act. Sasol works closely with the local authority and

operates units in line with the relevant AEL and minimum legal

emission requirements.

Sasol AEL and postponement applications as well as Greenhouse

Gas emission plan and Offsetting plan are stored on IMS and on the

Sharepoint.

The site does not require an AEL that is monitored by authorities,

however, air pollution measures are in place to manage air pollution

particularly related to dust. Sasol uses the Fugitive Emissions

Management Plan to manage any air quality issues related to the

Black Products site. Dust suppression is regularly conducted around

the site, especially at locations trucks are actively moving. This was

observed during the site walk. Furthermore an independent

consultant at 3 locations close to the Black Products site (dust

buckets 1 – 3) conducts dust monitoring as shown below.

Evidence:

— Fugitive Emission Monitoring Plan_2018-10-18 updated

None


WSP June 2019

Page 15


— Compliance_Air_Secunda Complex

Dust monitoring locations

4.2 An air quality monitoring programme must be initiated to

assess the potential off-site impacts of the BP site on air

quality during the closure and redevelopment of the site.

C Sasol makes use of an integrated approach to air quality







Sharepoint.








consultant at three locations close to the Black Products site (dust


Evidence:

None


WSP June 2019

Page 16





5. RISK MANAGEMENT

5.1 All employees who will be working in the BP site should be

aware of the emergency procedures in case of any accident. C Sasol have an environment emergency procedure (SGR-

SHE000023) that covers different scenarios on the site as well as an

environmental incident procedure process flow that indicates steps

taken when an incident occurs.

The Black Products site also has its own emergency preparedness

plan (EPP) which also covered Outside Ash. Sasol reported that the

said procedure is included in Induction training. Further to this,

Sasol undertake monthly emergency scenario drills according to the

EPP for the outside ash area.

Evidence:

— Environmental emergency procedure (Rev 6): SGR-

SHE000023

— Emergency Response Plan for Outside Ash (Ref: SGR-EMP-

000031)

None


WSP June 2019

Page 17


— External WAS Audit_2018-09-18

5.2 Sasol must implement a programme to ensure compliance

with recommendations of occupational health and safety

assessment as undertaken for the closure and re-development

of the BP site.

C All site personnel that work on Black Products site undergo SHE

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

and requirements. All of Sasol’s training is done through the

regional SHE learning and development academy. The induction

learning modules were available for review. The Health and Safety

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

the walls in the control room.

Furthermore, Sasol have an environment emergency procedure

(SGR-SHE000023) that covers different scenarios on the site as well

as an environmental incident procedure process flow that indicates

steps taken when an incident occurs.

The Black Products site also has its own EPP which also covered

Outside Ash. Sasol reported that the said procedure is included in

Induction training. Further to this, Sasol undertake monthly

emergency scenario drills according to the EPP for the outside ash

area.

Evidence:

— 3.3.1 Organogram_SHE Air_2018-09-17

— 3.3.1 Organogram_SHE WWLB_2018-09-03

— Induction_Mod1_1SHE Excellence

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod6_EmergencyManagement

— Induction_Mod7_Occupational


SHE000023


000031)


None


WSP June 2019

Page 18


6. MONITORING

6.1 Sasol, in consultation with DACE (Mpumalanga) and DWAF,

must constitute a waste monitoring committee to oversee the

closure and re-development of the BP site.

C A waste monitoring committee was developed to oversee the closure

and re-development of the Black Products site as required. The

committee’s Terms of Reference were available for review as well

as a notification letter to the Department of Environmental Affairs

of the establishment of the committee and it meets twice a year.

Evidence:

— 6.01_Waste monitoring committee_Terms of Reference_2017-

10-24

— 6.01_Establish waste monitoring committee_2017-10-24

None

6.2 Sasol must finalise and implement a long-term monitoring

and management plan in consultation with DACE and

DWAF, to monitor and manage potential ground and surface

water contamination associated with the BP site.

C There is no proof that DACE and DWAF were involved in setting

up of a long term monitoring plan. The set up and their involvement

is also not applicable as it would have been done prior to 2014.

However, 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


20


20

None

6.3 This Department must be granted access at any reasonable

times to the property to investigate any possible

environmental impacts that may be caused by the

rehabilitation and re-development of the BP site.

C The auditor was informed that the Department has been granted

access on a number of occasions however no reports have been

provided regarding feedback following their site visits.

None


WSP June 2019

Page 19


7. REPORTING

7.1 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 of request by this

Department.

N/A There is no set requirement for conducting audits against the

conditions of this licence. No previous audits over the last 5 years

were available for review and there has been no indication that the

Department requested any records.

Ensure this current audit is

kept in good order for future

reference.

Target period:

Long term

7.2 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. None

7.3 Any complaint regarding the said rehabilitation and re-

development of the BP site must be thoroughly investigated

and addressed to the satisfaction of all parties concerned.

Copies of such complaint must be forwarded to this

Department within 48 hours.

C All environmental complaints received from interested and affected

parties, both internal and external to the organisation, are recorded

in a complaints register that is available and the Environmental

department. Complaints are investigated and reported in line with

the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders

There have been no complaints received regarding the Black

Products site since the operations commenced. The environmental

complaints register was available for review and contained

complaints for all business units dating back from 2008.

Evidence:


— Compliance_Complaints_Secunda Complex

— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01

None


WSP June 2019

Page 20

Table 3: Audit Findings – Environmental Management Plan


1. CONSTRUCTION AND PRE-COMMISSIONING

1.1 Transport of feed to plant:

List of documents: Conceptual package, Basic engineering

package, Detail design package, Commissioning plan,

Operations manual, EPCM contract, Contractor procedure

Interface doc's Permits/ROD Plan of execution.



None

1.2 Disposal of used potable water:

Potable water use: HS occupational hygiene requirements to

be obtained and observed. Water to be available for

construction personnel. Documents relating to this aspect to

referenced to project or safety files.



None

1.3 Labour and employment required:

Strategy for employment to be completed. Local people to be

used as labourers. This aspect should be discussed with the

contractor and included in contract or RFQ documents.

Reference to be supplied. Procedure / strategy towards skills

development to be completed. Strategy document to be kept

on file and reference included in closeout documentation.



None

1.4 Permit requirements for TLC / CAPCO / DWAF / Transport /

Excavations etc:

Legal permit requirements to be investigated and expressed in

terms of a schedule for permit application. Application

documents to be kept on the Safety or project file and

references to be included in the closeout documentation. All

relevant emergency plans to be completed



None


WSP June 2019

Page 21


1.5 Steam usage / electricity required / firewater for firefighting.

Confirm availability. Reference to document in project file. N/A This condition is considered outside of the audit period


None

1.6 Firewater tie-in points for firefighting/Water use for

hydrotesting / water use for flushing. Confirm availability.

Reference to document in project file.



None

1.7 Foreign Investment:

The possibilities for foreign investment should be

investigated. Document references required.



None

1.8 ROD Conditions as received on 27 February 2001 should be

implemented and the required accountabilities allocated to all

relevant departments / personnel involved e.g. SSF

Environment.



None

1.9 New Technology:

The use of new technology should be investigated. Document

references required.



None

1.10 Construction / Clean-up kick-off meeting:

All environmental aspects and ROD to be discussed at this

kick-off meeting.



None

1.11 Sandblasting, Welding, Spray Painting:

HS / occupational hygiene requirements to be obtained and

observed (contractor). Document references required.



None


WSP June 2019

Page 22


1.12 Project environmental closeout inspections to be held on time

at the site / safety file. Project manager and process engineer

to assist in the provision of reference documents and site visit.



None

2. COMMISSIONING AND START-UP

2.1 Disposal / routing of spent chemicals for cleaning / pickling /

passivation and desiccants, solvents, catalysts:

Disposal route of chemicals to be confirmed. Suitable site /

system to be identified.



None

2.2 Disposal/routing of off-spec by-products and products:

Disposal route of off-spec material to be confirmed. Suitable

site / system to be identified. Documentation to be kept on file

and reference to document and file to be included in closeout

documents.



None

2.3 Disposal of construction wastes. To include wastes from spray

painting, welding, grinding, cutting of pipes, storage of

cement/grease, oils and paints and during the mixing of

concrete:

HS / occupational hygiene requirements to be obtained and

observed (contractor). Spray painting & welding. Ref to

documents in project or safety file required. H&S aspects and

environmental requirements to be communicated to the

contractor responsible for construction.



None

2.4 Routing/disposal/ re-use/storage of excavated materials /

soils:

To be co-ordinate with SSF Environment. Confirm

availability of a suitable site for storage of topsoil and other

excavated material to be re-used on site, otherwise disposed.



None


WSP June 2019

Page 23


To be included in works instruction documents of contractors

and discussed at construction / commissioning kick-off

meeting. Reference will be the works instruction documents.

2.5 Scoping Report (SR): Contaminated soil and additional soil

contamination: The ultimate closure and redevelopment of the

BPS will however decrease the potential for additional soil

contamination.



None

2.6 Disposal / re-use of building rubble and other construction

waste:

Contractor to responsibly dispose of building rubble and

construction waste at a suitable waste facility. Requirements

to be included in the contractors contract / works instruction.

Reference to be included in closeout documentation.



None

2.7 Handling / storage / disposal of redundant piping and

equipment:

Disposal route to be confirmed. Document addressing this

issue to be referenced to project or safety file.



None

2.8 Disposal of water used for hydro-testing:

Confirm availability and disposal route if applicable. If this

activity is the responsibility of contractor, this issue should be

included in the contract / works instruction documentation and

referenced in the closeout document.



None

2.9 Disposal of water used for flushing:

Confirm availability and disposal route. Interface documents

to be kept on project file. Reference to be included in closeout

documentation.



None


WSP June 2019

Page 24


2.10 Routing/disposal of process effluent:

Disposal route to be confirmed. Acceptable site / equipment

to be indicated. Reference to documentation in safety or

project file required.



None


Number of required additional personnel to be confirmed.

Local construction workers to be used where possible. A

strategy for the use of local people is to be completed.

Procedure / strategy towards skills development to be

completed. Strategy document to be kept on file and reference

included in closeout documentation.



None

2.12 Pressure on infrastructure / roads and services due to

increased workforce.

To be coordinated with the traffic department in terms of

schedule. Communication to be recorded and documents to be

kept on file if required.



None

2.13 Dolorite mining:

Dolorite to mined / obtained from a licensed site only. If this

is also the responsibility of the contractor, he should be

informed in his contract / works instruction documentation as

well as at the relevant kick off meetings.



None

2.14 Permit requirements for TLC / CAPCO / DWAF / Transport /

Excavations etc:

Legal permit requirements to be investigated and expressed in

terms of a schedule for permit application. Application

documents to be kept on the Safety or project file and

references to be included in the closeout documentation.



None


WSP June 2019

Page 25


2.15 Foreign Investment: The possibilities for foreign investment

should be investigated. Document references required. N/A This condition is considered outside of the audit period


None




Environment.



None

2.17 Project Environmental Closeout inspections to be held on time

at the site / safety file. Project manager and process engineer

to assist in the provision of reference documents and site visit.



None

3. OPERATING, MAINTENANCE AND SHUTDOWN

3.1 Transport of chemicals for cleaning / pickling / passivation

and desiccants solvents, catalysts:

Requirements to be obtained from SSF traffic officials.

Emergency procedure for loss of containment to be updated.

Procedure to be referenced in Project file or safety file.




None

3.2 Disposal / routing of off-spec by-products and products:

Obtain and observe Risk and HS requirements. These

requirements to be kept on project file / safety file and

reference to be included in closeout documentation.




None

3.3 Handling and disposal of contaminated equipment:

SR: Contaminated soil: - As a result of disposal of waste at

the BPS has a potential to contribute to groundwater

contamination, additional soil contamination could occur

during the closure and redevelopment of the BPS.

Mitigation:-baseline monitoring mentioned - the ultimate

closure will however decrease the potential for additional soil

C Groundwater monitoring is conducted on a monthly basis and a

sample groundwater monitoring reports by JMA Consulting were

available for review.

Soil pollution monitoring is done as part of contaminated land

management. Phase 1 (December 2015) and Phase 2 (August) land

monitoring reports have been conducted for the Synfuels site as a

whole by Geo Pollution Technologies. Recommendations from each

None


WSP June 2019

Page 26


contamination. In the event of waste product spills during the

closure of the BPS would occur in the vicinity of the BP dams.

Significance of the existing soil contamination associated

with the BPS is considered to be low.

report are marked down for implementation as required.

Contaminated land is managed within legal requirements and

incident registers are maintained in order to monitor any

contamination events.

Evidence:

— Phase 1_Contaminated Land

Assessment_November_2015_Final 1.0

— Secunda Contaminated Land Phase 2 Report_Final v1 part 1 of

2_2018-08-28

— IWWMP SIC 2015 Final_2018-05-15

3.4 Solid waste generated during the regeneration of spent-

catalyst:

Current disposal route to be confirmed. Possible impacts on

water and soil to be mitigated. Documentation on possible

mitigation to be kept on file and reference to be included in

closeout documentation.




None

3.5 Stormwater management (routing of on- spec/contaminated

stormwater):

SR: Stormwater from area adjacent to the BPS is diverted

away from the site. All rainfall falling within the site is

contained within the site and either percolates into the ground

or evaporates. Once the closure and redevelopment of the BPS

is complete and higher coarse ash stacking is occurring,

stormwater within the area, which may be contaminated,

could flow off-site. Appropriate stormwater management will

be established for the closure and redevelopment of the BPS,

although it will have low significance.

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

Black Products site falls as part of the outside ash facilities.






collecting dams as shown below.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

None


WSP June 2019

Page 27




3.6 Routing/disposal of process effluent:

The disposal route is to be confirmed. Acceptable site /

equipment to be indicated. Reference to documentation in

safety or project file required.




None

3.7 Measuring of effluent and method:

Method of measurement to be confirmed. To be reviewed

during a possible HAZOP meeting (only if applicable).

Reference to Documents required.

N/A All the potential seepage generated is collected and channelled

towards the effluent collection dams around the Outside Ash area.

None

3.8 Other emissions: C Sasol makes use of an integrated approach to air quality



None


WSP June 2019

Page 28


Dust emissions to be investigated. SR: Impact on air quality:

Gaseous emissions are the primary emissions to the

atmosphere from the BPS, VOC's, SVOC's, PAH's and

phenols. Increase in ambient temperatures to greater than

25°C result in noticeable increases in ambient concentrations

of organic smelling vapours. Particulate emissions are also

significant in the immediate vicinity, especially during windy

conditions.

During closure an increase in emissions from the site will

occur. Level of contamination in the ambient air is generally

below levels of concern regarding OHS exposure limits.

Sampling during management study suggests gaseous

emissions from the BPS are sufficiently diluted by the

receiving environment. The total particulate load emitted from

the entire waste complex is relatively low. Capping of the BPS

will eliminate the potential for gaseous and particulate

emissions from the area particularly once coarse ash stacking

commences. However, this activity will result in an increase

in particulate emissions from the Sasol industrial complex.

Present situation low significance. Potential impact of the

BPS on air quality during closure medium significance. High

coarse ash stacking on the BPS medium significance.





Sharepoint.

It must be noted that the Black Products site has been capped off and

completely rehabilitated, eliminating the potential for gaseous and

particulate emissions from the area.



particularly related to dust, especially once coarse ash stacking

commences. Sasol uses the Fugitive Emissions Management Plan to

manage any air quality issues related to the Black Products site. Dust

suppression is regularly conducted around the site, especially at

locations trucks are actively moving. This was observed during the

site walk. Furthermore dust monitoring is conducted at 3 locations

close to the Black Products site (dust buckets 1 – 3) as shown below.

Evidence:





WSP June 2019

Page 29



Confirm usage of existing personnel if no additional

temporary people will be used. This confirmation could be an

email document to be kept on the project or safety file.

Procedure / strategy towards skills development to be

completed. Strategy document to be kept on file and reference

included in closeout documentation.

C Sasol subcontracted the work conducted on the Black Products site

to make use of specialised engineering contractors. These

organisations bring in their own personnel who are sufficiently

trained to conduct the work, however, all contractors undergo Sasol

induction before they commence work.

All Sasol personnel that work on Black Products site undergo SHE







None


SR: There is potential for employment opportunities during

the closure and redevelopment of the BPS. Limited

employment are envisaged as OHSA indicated that the use of

manual labour must be limited due to high risks associate with

the work required. Low significance.

C Sasol targeted reputable engineering companies as primary

contractors and has used several contractors for the project at

different stages. The main contractors also employ subcontractors..

These organisations bring in their own personnel who are

sufficiently trained to conduct the work, however, all contractors

undergo Sasol induction before they commence work and hence

limit manual labour. Manual labour is sourced locally, especially if

the contractor is local.

Evidence:

— 3.1_BP6 Seepage Cutoff Kickoff Minutes

— 15-064_-_BPS_and_BP6_Capping_WORK_-

_Quote_on_PMI_022_REV_3_-_2015-06-25

None

3.11 Area influenced by visual impact:

SR: Limited or no impact has been identified. Although the

BP dams is elevated above ground level, they are bordered on

all sides by fine and coarse ash dams which are on average 30

- 40 m higher than the dams and the width of the coarse ash

dams varying between 300 and 1100m. The BP dams is not

directly visible from any of the adjacent residential and/or

commercial areas including the closest formal residential area,

C As noted in the SR, there is negligible significance with regards to

visual impact related to the site. There have been no complaints

received regarding Black Products site, including visual complaints,

since the operations commenced. The environmental complaints

register was available for review and contained complaints for all

business units dating back from 2008.

Evidence:


WSP June 2019

Page 30


Embalenhle (4 km east). Therefore no potential visual impact

is envisaged during the closure and redevelopment of the site,

which has negligible significance.


3.12 Does an emergency plan for major loss of containment in the

plant (with consideration of air, groundwater, soil and surface

water) exist?

All relevant emergency plans to be completed / updated and

communicated with SSF Environment, Anton Noordman and

contractors. Issues to be included are surface water, soil,

ground water, air economy and impacts on humans. Records

of this communication to be kept on file and reference to be

included in closeout documents.

C Sasol have an environment emergency procedure (SGR-








area.

These procedures are communicated to the contractors during

induction.

Evidence:


SHE000023


000031)


None

3.13 Foreign Investment:

The possibilities for foreign investment should be

investigated. Document references required.

C Sasol have investigated the possibilities of foreign investment to

fund the rehabilitation process as required. The Remediation

Programme Progress report was available for review and it focused

on cost estimations for the project. Section 7 of the document

indicated the split of how much foreign investment would be utilised

on the project.

Evidence:

— J.54_ConsBPRemediationProgReport Rev A 00-00667-P5-9_

None


WSP June 2019

Page 31





Environment.

C The ROD conditions are being implemented as required, and no

non-compliances have been noted for the ROD conditions over the

course of this audit.

Evidence:

— 033_41101534_20190125_Sasol_SSO_WA_EA_14.25.16

EV 11_V1

None

3.15 Satellite Industries:

Investigate possible satellite industry development.

Document references required.




None

3.16 Minimise Current Production Losses:

Value improvement practices to be identified and completed.

Document references required.




None

3.17 Optimum Utilisation of Resources:

Impact on operations to be investigated. Document references

required.




None

3.18 ROD Condition: This Authorisation refers to the project

specified above and described in the ROD. Separate

applications must be lodged for any other development and/or

activity at or near the proposed development, which is covered

by Section 21 & 22 of the Act and Government Notice R1182

of 5 September 1997.

N/A Noted. None

3.19 ROD Condition: Authorisation is only granted in terms of

Section 22 of the Act and does not exempt the holder from

compliance with 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.

None


WSP June 2019

Page 32


Evidence:

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27

— SSO DQS ISO 14001 2015

3.20 ROD Condition: Copies of the relevant documents mentioned

in 1.3 above, must be forwarded to this Department within 3

months of the issuing of this Authorisation.



None

3.21 ROD Condition: No development may take place on the area

of concern without the necessary permits/approvals and /or

service agreement from other relevant authorities.

C The site was approved for development when an EA was issued by

the Provincial Department on 4 December 2000 with 14.25.16 EV

11 as the reference number. A WML was issued on 4 April 2013 for

the ash handling facility with reference number 12/9/11/L1/6. Four

variations on the amended WML were further issued: which

included:

— Waste Licence Variation for height Increase of Fine Ash Dam

5 (Reference Number: 12/9/11/L1/6/V2);

— Waste Licence Variation for condition 4.7 (Reference Number:

12/9/11/L1/6/V2);

— Waste Licence Variation for condition 4.1 and 4.9 (Reference

Number: 12/9/L1/6/R1/V5);

— Waste Licence Variation for condition 1.1.2, 3.2, 4.5, 6.2.1.1,

6.2.2.2, 6.2.1.3, 6.2.2.1, 6.2.3.1, 6.2.4.1, 6.2.4.3, 6.2.4.2,

6.2.5.1 and 6.2.6.1 (Reference Number: 12/9/L1/6/V3 dated 28

March 2018).

A copy of the WML and the September 2018 compliance audit

report by SRK Consulting was available for review.

Evidence:




— 14.25.16 EV 11_Black Products Site_2000-12-04

None


WSP June 2019

Page 33


3.22 ROD Condition: An Environmental Management Plan must

be formulated to minimise and manage potential

environmental impacts during the closure and redevelopment

of the Black Products site. The EMP must include a spill

contingency plan with specific emphasis on the extraction of

wastes from the ponds, transportation of the waste and off-

loading.

C An EMPr was formulated in the form of an Aspects Register during

the time of application of the EA in order to manage potential

environmental impacts during the closure and development of the

Black products site. The EMPr does cover the spill contingency plan

with specific emphasis on the extraction of wastes from the ponds,

transportation of the waste and off-loading. Furthermore, The

capping project is almost done and spills will no longer be an issue

on the site.

Evidence:

— BP_Aspect register 26 August 2002(revised)

None

3.23 ROD Condition: This Department may change or amend any

of the conditions in this authorisation if in the opinion of the

Department it is environmentally justified.

N/A Noted. None

3.24 ROD Condition: The development must comply to all

mitigatory measures as set out in the scoping report. C The Scoping Report mitigatory measures were included as part of

the EMPr and have been evaluated in Table 3. No non-compliances

were noted.

None

3.25 ROD Condition: This Authorisation is repealed if the

rehabilitation and redevelopment of the Black Products site

has not commenced within 2 years from the date of this

Authorisation.



None

3.26 ROD Condition: This Department should be notified in the

earliest convenient time of any decision to discontinue the

operation of the said development.



the Black Products site is closed off and has been completely

rehabilitated.

None

3.27 ROD Condition: Sasol must implement strategies to provide

opportunities for local labour to be involved in the closure and

redevelopment of the site.




None


WSP June 2019

Page 34


3.28 ROD Condition: Proper drainage for storm water runoff

should be put in place. C Sasol have an 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 Black Products site falls as part of the outside ash

facilities.






collecting dams as shown below.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


None


WSP June 2019

Page 35



3.29 ROD Condition: Prevention of groundwater pollution should

receive the highest priority. C The Outside Ash Disposal Area which includes the Black Product





August 2018 by JMA Consulting were available for review. Within

these reports groundwater quality is compared to drinking water

quality standards, as presented in SANS 241:2015, or SANS

241:2006 (where 2015 parameters are unavailable). It is recognised

that such standards are considered conservative, as no potable water

abstraction points are located in the vicinity. Boreholes REGM-154

and REGM-154S were identified as reflective of ‘downstream of

Black Products’, and were reported upon for May 2017, August

2017, November 2017 and August 2018 sample runs. REGM-154S

was reported to be impacted, with contaminant concentrations

elevated above drinking water standards for electrical conductivity,

total dissolved solids, calcium, magnesium, sodium, sulphate, lead,

In order to remain compliant

with this condition going

forwards, Sasol must

continue to place highest

priority on the prevention of

groundwater pollution by

investing in future-available

mitigation techniques, and

researching best available

technology.

Sasol must demonstrate a

continued focus on

groundwater pollution

prevention.

Target period:


WSP June 2019

Page 36


mercury and selenium. The groundwater reports specifically

highlight that the groundwater in REGM-154S is “deteriorating”.

However, the Black Products area is currently being rehabilitated,

and will eventually be covered by the Coarse Ash Heap. Ensuring

ongoing implementation of rehabilitation measures at the Black

Products area is action item 4.5.4 in the Sasol IWWMP 2016 – 2020.

Furthermore, Sasol received authorisation for the installation of

seepage reduction and stream flow monitoring weirs (Ref:

MP/EIA/0000524/2012) from the provincial MDEDET on 12

December 2013. The authorisation included additional cut-off

trenches around the Coarse Ash Dump and van Niekerk Dam, as

well as a pipeline at the Coarse Ash Dump. This project was

authorised during the July – December 2015 period. Construction

on Phase 1a (process water section) and Phase 1b (Dam 11) of the

project have been completed. Phase 2 (WAS section) was completed

in October 2018. Interception drains around FAD 5, Coarse Ash

Dump and the Black Products area are visible.

The water in the ash handling areas is controlled in a closed circuit

via cement channels and is reused in the system as much as possible.

The channels are designed to prevent groundwater pollution.

The entire Outside Ash area is regarded as a “dirty area”, and

contaminated run-off is mostly contained within this area by means

of a stormwater berm and trench along the southern, south-western

and western boundary.

It has been evidenced to the auditor that prevention of groundwater

pollution is receiving high priority, with significant investment

made in pollution mitigation measures. Sasol is taking practical

steps in order to combat the legacy of limited containment structure

practices of the past. This condition has been marked compliance

only on the basis that such investment in pollution prevention has

been made, as deterioration in water quality has been noted.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15

Long term


WSP June 2019

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20


20

— GWMonitor Report Aug 2018 Final_Prj6163_2018-10-31

3.30 ROD Condition: Air pollution should be handled as indicated

by relevant authorities. C Sasol makes use of an integrated approach to air quality







Sharepoint.







observed during the site walk. Furthermore dust monitoring is

conducted at 3 locations close to the Black Products site (dust

buckets 1 – 3) as shown below.

Evidence:



None


WSP June 2019

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3.31 ROD Condition: Adhere to any other water management

conditions set out by DWAF or any other relevant authority. C The Synfuels site as a whole has a WUL. The IWWMP indicates

that “A Water Use Licence (“WUL”) was issued on 21 November

2008 (“2008 WUL”) in terms of Chapter 4 of the National Water

Act 36 of 1998 (“NWA”), and an amendment to this WUL has been

issued on 8 January 2010 (“2010 WUL Amendment”) to authorise

water uses associated with the industrial operations at the SIC.

Condition 5 in the 2008 WUL indicates that the WUL will be

reviewed every three (3) years, and a review was thus initiated

during 2014. The 2010 WUL Amendment specify in condition 12.1

that an Integrated Water and Waste Management Plan (“IWWMP”)

must be submitted for approval when the WUL is being reviewed.”

The WML has recently been amended to reference the quality

requirements listed in the WUL as previously the WML listed its

own requirements.

Evidence:


— IWWMP SIC 2015 Final_2018-05-15


None


WSP June 2019

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3.32 ROD Condition: All employees who will be working in the

Black Products site should be aware of emergency procedures

in case of any accidents.

C Sasol have an environment emergency procedure (SGR-








Evidence:


SHE000023


000031)


None

3.33 ROD Condition: An air quality monitoring programme must

be initiated to assess the potential off-site impacts of the Black

Products site on air quality during the closure and

redevelopment of the site.

C Sasol makes use of an integrated approach to air quality







Sharepoint.








consultant at 3 locations close to the Black Products site (dust


Evidence:

None


WSP June 2019

Page 40





3.34 ROD Condition: Sasol in consultation with DACE -MP and

DWAF, must constitute a waste monitoring committee to

oversee the closure and redevelopment of the Black Products

site.

C A waste monitoring committee was developed to oversee the closure

and re-development of the Black Products site as required. The

committee’s Terms of Reference were available for review as well

as a notification letter to the Department of Environmental Affairs

of the establishment of the committee and it meets twice a year.

Evidence:

— 6.01_Waste monitoring committee_Terms of Reference_2017-

10-24

— 6.01_Establish waste monitoring committee_2017-10-24

None

3.35 ROD Condition: Sasol must implement a programme to

ensure compliance with the recommendation of the

occupational health and safety assessment as undertaken for

the closure and redevelopment of the Black Products site.

C All site personnel that work on Black Products site undergo SHE







None


WSP June 2019

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Furthermore, Sasol have an environment emergency procedure

(SGR-SHE000023) that covers different scenarios on the site as well

as an environmental incident procedure process flow that indicates

steps taken when an incident occurs.





area.

Evidence:

— 3.3.1 Organogram_SHE Air_2018-09-17

— 3.3.1 Organogram_SHE WWLB_2018-09-03

— Induction_Mod1_1SHE Excellence

— Induction_Mod4_ProcessSafetyManagement

— Induction_Mod5_WorkPlaceSafety

— Induction_Mod6_EmergencyManagement

— Induction_Mod7_Occupational


SHE000023


000031)


3.36 ROD Condition: This department must be granted access at

any reasonable times to the property to investigate any

possible environmental impacts that may be caused by the

rehabilitation and redevelopment of the Black Products site.

C The auditor was informed that the Department has been granted

access on a number of occasions however no reports have been

provided regarding feedback following their site visits.

None

3.37 ROD Condition: Sasol must finalise and implement a long-

term monitoring and management plan in consultation with

DACE and DWAF, to monitor and manage potential ground

C There was no proof of a long-term monitoring and management plan

that was agreed up with DACE and DWAF to monitor and manage

potential ground and surface water contamination associated with

the BP site. However, Sasol have a ground and surface water

None


WSP June 2019

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and surface water contamination associated with the black

Products site.

monitoring programme as indicated in the IWWMP and as within

the licensed WUL.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15


20


20

3.38 ROD Condition: Non-compliance with or any deviation from

the conditions of this authorisation is regarded as an offence,

and after reasonable provision has been made for the situation

to be remedied, will be dealt with in terms of Section 29, 30

and 31A of the Act.

N/A Noted. None

3.39 ROD Condition: Records relating to the compliance or 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 working days from the date of

written request for such records by the Department.

N/A There is no set requirement for conducting audits against the

conditions of this licence. No previous audits over the last 5 years

were available for review and there has been no indication that the

Department requested any records.

Ensure this current audit is

kept in good order so that it

is readily available on

request in the future.

Target period:

Long term

3.40 ROD Condition: Any complaint regarding the said

rehabilitation and redevelopment of the Black Products site

must be thoroughly investigated and addressed to the

satisfaction of all parties concerned. Copies of such

complaints must be forwarded to this Department within 48

hours of such a complaint being lodged.

C All environmental complaints received from interested and affected

parties, both internal and external to the organisation, are recorded

in a complaints register that is available and the Environmental

department. Complaints are investigated and reported in line with

the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders



None


WSP June 2019

Page 43


complaints register was available for review and contained

complaints for all business units dating back from 2008.

Evidence:


— Compliance_Complaints_Secunda Complex

— Environmental complaints procedure_SGR-SHE-

000022_Rev05_2019-01

3.41 Presentation BP/BE Kick-off: Scope of work: Refer to scope

of work in the database. N/A This condition is considered outside of the audit period



None

3.42 SR: Groundwater contamination: No known formal users of

groundwater within 5km radius of the BPS. Analysis of the

groundwater showed limited contamination by organics and

inorganics. Short-term management is to monitor

groundwater with respect to contaminants from the BPS if

contamination is found to represent a problem. Medium to

long-term management is to install cut-off and interception

trenches for leachate generated at BPS. Abstraction of

groundwater may also be implemented to prevent the

migration of groundwater away from the BPS should it be

required. Impact of groundwater is considered to be of

medium significance.

C Short-term management requirement:

The Outside Ash Disposal Area which includes the Black Product





August 2018 by JMA Consulting were available for review.

Medium to long-term management requirement:

Sasol installed interception drains around the Outside Ash area

which includes the Black Products site. The interception drains are

constructed to effectively intercept and drain any potential surface

and sub-surface seepage generated from the treatment and disposal

area. The drains were observed during the site visit.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15



None

3.43 SR: Surface water contamination: Potential for waste products

to enter nearby surface water bodies as a result of failure of C The Black Products site is closed off and has been completely

rehabilitated. Any surface water that flows on the side is treated as

None


WSP June 2019

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one of the side slopes of the ponds. The option of closure

involves extraction of the liquid phase of the material within

the ponds. The solid/sludge material remaining will be

covered with coarse ash, which will negate the potential for

waste within the ponds to flow off-site in the event of slope

failure. Low significance.

stormwater that will either evaporate or flow over the sides of the

capped site.

Sasol have an 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 Black Products site falls as part of the outside ash

facilities.





easily channelled into the existing stormwater drains shown below

that lead to the collecting dams.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15



WSP June 2019

Page 45



3.44 SR: Noise Potential noise during closure relate primarily to

the use of vehicles and heavy machinery at the site. Noise

generated by such equipment could impact on personnel

within the Sasol industrial complex itself, the neighbouring

residential and commercial areas. Closure will not be an

ongoing activity and will be completed in a limited time.

Closest areas occupied by personnel are at least 2.5 km away.

Low significance.

C Noise surveys are conducted to ensure that Sasol Secunda facilities

do not affect the neighbouring communities. Safetech conducts the

surveys for all Secunda operations and noise measurements are

taken at 5 locations (Sasol entry points, Charlie 15) as shown in the

figure below. These measurements are representative of all of

Sasol’s Secunda operations including the Black Products site. A

sample noise survey report dated 26 August 2016 was available for

review and it indicated none of the points exceeded the SANS limits

for industrial areas for both daytime and nighttime monitoring.



complaints register was available for dating back from 2008.

Evidence:

— J.53_EnvNoise 5439(Final) ver1_2016-08-26

None


WSP June 2019

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Noise monitoring points


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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 4 below.

Table 4: Summary of EA Compliance Audit Findings

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

GENERAL CONDITIONS 7 3 0 4

ESTABLISHMENT 3 1 0 2

WATER POLLUTION 3 3 0 0

AIR POLLUTION 2 2 0 0

RISK MANAGEMENT 2 2 0 0

MONITORING 3 3 0 0

REPORTING 3 1 0 2

Total Count 23 15 0 8

Total Percentage 65% 0% 35%

Percentage Compliance with Applicable Conditions 100%


WSP June 2019

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

presents the total proportion of compliance for the facility.

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

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

0

1

2

3

4

5

6

7

8

Sectional Count Contribution

C

NC

N/A

150

8

Total Compliance

C

NC

N/A


WSP June 2019

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

total percentage compliance for the facility.

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

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

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

65%0%

35%

Total Percentage Compliance

C

NC

N/A


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5.2 ENVIRONMENTAL MANAGEMENT PLAN

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

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

below.

Table 5: Summary of EMPr Compliance Audit Findings

SECTION OF THE EMPR NO. COMMITMENTS C NC NA

CONSTRUCTION AND PRE-COMMISSIONING 12 0 0 12

COMMISSIONING AND START-UP 17 0 0 17

OPERATING, MAINTENANCE AND SHUTDOWN 44 26 0 18

Total Count 73 26 0 47

Total Percentage 36% 0% 64%

Percentage Compliance with Applicable Conditions 100%


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

presents the total proportion of compliance for the facility.

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

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

05

101520253035404550

Construction and Pre-Commissioning

Commissioning and Start-Up Operating, Maintenance andShutdown

Sectional Count Contribution

C

NC

N/A

26

0

47

Total Compliance

C

NC

N/A


WSP June 2019

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

total percentage compliance for the facility.

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

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

0102030405060708090

100

Construction and Pre-Commissioning

Commissioning and Start-Up Operating, Maintenance andShutdown

Sectional Percentage Contribution

C

NC

N/A

36%

0%

64%

Total Percentage Compliance

C

NC

N/A


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5.2.1 EFFECTIVENESS OF THE EMPR

Section 34 and Appendix 7 of the EIA Regulations 2014 (as amended) requires an assessment of the adequacy

and effectiveness of the EMPr as part of the audit scope, as follows:

— Assess the extent to which the avoidance, management and mitigation measures provided for in the EMPr,

achieve the objectives and outcomes laid out in these documents;

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

— Critically evaluate the effectiveness of the EMPr;

— Identify shortcomings in the EMPr; and

— Identify the need for any changes to the avoidance, management and mitigation measures provided for in

the EMPr.

The EMPr compliance audit has identified that approximately 40% of the listed measures are no longer applicable,

as these mostly related to the construction and pre-commissioning, and commissioning and start-up phases only.

The original EMPr document was designed pre-operation principally to govern these construction phase impacts,

and has been superseded during the operational phase by Sasol Business Unit-specific risk assessments;

compliance with the EA, relevant WUL and AEL; and through Sasol’s choice to comply with the ISO 14001

Environmental Management international standard.

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

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

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

ISO 14001 standards.

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

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

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

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

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

Information Management System.

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

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

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

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

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

APPENDIX

A ENVIRONMENTAL AUTHORISATION

(14.25.16 EV 11)

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