SASOL SYNFUELS OPERATIONS: WATER AND ASH
ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
17/2/3/8/G-1 - EMERGENCY STORAGE DAMS
03 JUNE 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
17/2/3/8/G-1 - EMERGENCY STORAGE DAMS
SASOL SYNFUELS OPERATIONS: WATER
AND ASH
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: JUNE 2019
WSP
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Q U A L I T Y M A N A G E M E N T
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft for Review –
Compliance Audit
EA Ref: 17/2/3/8/G-1
Draft v2 for Review –
Compliance Audit
EA Ref: 17/2/3/8/G-1
Final – Compliance
Audit
EA Ref: 17/2/3/8/G-1
Date April 2019 May 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 003 003 003
File reference W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-
REPORTS\003_SSO_WA_EA_17.2.3.8G-1\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
Rakesh Durjan
WSP
Associate Jenny Cope
Lead Auditor Ashlea Strong
Consultant Tutayi Chifadza
ENVIRONMENTAL AUTHORISATION AND ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL SYNFUELS OPERATIONS: WATER AND ASH
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TABLE OF CONTENTS
1 INTRODUCTION ........................................ 1
1.1 Terms of Reference ................................................. 1
1.2 Emergency Storage Dams (Authorisation
Number: 17/2/3/8/G-1) ............................................. 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 ................................ 6
4 AUDIT FINDINGS ...................................... 8
5 SUMMARY OF THE AUDIT FINDINGS ... 39
5.1 Environmental Authorisation ............................... 39
5.2 Environmental Management Plan ........................ 42
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TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES ........................................... 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 8
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................. 27
TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................ 39
TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS .................................... 42
FIGURES
FIGURE 1-1: EMERGENCY STORAGE DAMS B AND C (SOURCE: GOOGLE EARTH, 2018) ............................... 2
FIGURE 5-1: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................ 40
FIGURE 5-2: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................. 40
FIGURE 5-3: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..... 41
FIGURE 5-4: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................ 41
FIGURE 5-5: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..... 43
FIGURE 5-6: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................. 43
FIGURE 5-7: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 44
FIGURE 5-8: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........... 44
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APPENDICES
A ENVIRONMENTAL AUTHORISATION (17/2/3/8/G-1)
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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: 17/2/3/8/G-1 issued on 28 September 2015) as well as the
associated Environmental Management Plan (EMPr) (dated: September 2010) for the period December 2014 to
February 2019.
1.2 EMERGENCY STORAGE DAMS (AUTHORISATION
NUMBER: 17/2/3/8/G-1)
Sasol Secunda Operations produce liquid fuels (petrol, diesel and paraffin), as well as industrial pipeline gas and
a range of chemical feedstock compounds, including the building blocks for industrial solvents and polymers,
through the gasification process of approximately 40 million tons of coal per annum. The mineral content of the
coal reports as coarse ash, which is conveyed to the coarse ash disposal site. Fine ash from the boilers for steam
and electricity generation is pumped to the Fine Ash Dams (FAD) for disposal. Wastewater generated in the Sasol
Complex is treated and upgraded to process water quality. This is then successively stored in a number of process
effluent dams and is subsequently used as process water within the Sasol Complex..
The comprehensive water balance model for the Sasol complex indicates that, for normal rainfall years (barring
major plant upset conditions), the overall complex process water balance should be in balance. Normal rainfall
conditions for this area give rainfall depths that range from 543 to 885 mm/year. This changed during the 2009 /
2010 rainfall period due to exceptionally high rainfall for this period, and the hydrological years before. The dams
within the process water circuit providing the required buffer capacity to balance these circuits over varying
rainfall periods, could not “recover” in terms of water levels, and Sasol was compelled to operate these into their
freeboard capacities to prevent spillages from the circuits/dams to the receiving surface water environment.
Due to excess water in the process and related circuits, Sasol was compelled to urgently construct two process
water emergency storage dams to protect the downstream water environment. A Section 24G Rectification
Application was prepared into the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA)
and submitted to Mpumalanga Department of Agriculture, Rural Development, Land and Environmental Affairs
(MDARLEA) before an EA (Reference number: 17/2/3/8/G-1) dated 28 September 2015 was issued. An EMPr
dated September 2010 was also submitted to support the application for the EA for construction of the dams and
provide Sasol and its contractors with guidance on how to conduct their construction, operational and
decommissioning activities in an environmentally responsible manner.
On 5 February 2016, Sasol submitted a request for an amendment of the issued EA for the emergency storage
dams for process water. The amendment focussed on three aspects within the EA, two conditions and one for
correction of the exact site coordinates. The amendment was issued on 23 March 2016 and the remainder of the
conditions stayed the same.
Both the EA and EMPr are assessed in this compliance audit report and the latest amendment conditions are
audited against. The location of the emergency storage dams are located in Figure 1-1 below.
This authorisation was issued in response to a Section 24G rectification application. Thus, all construction
activities were completed in 2010 before the issuing of the authorisation. Consequently, all construction-related
conditions are considered outside the audit period (2014-2019).
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Figure 1-1: Emergency Storage Dams B and C (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.
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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 (28 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 28 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:
— Simphiwe Njikelane (Area Manager Production); and
— Aaron Matjomane (Production Foreman, W&A Production Water Recovery).
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— IWWMP SIC 2015 Final_2018-05-15;
— 12776_WULApp_Final_27 Aug 2010;
— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-06-14;
— 3.2.2_EA_ 2251_Submit post construct audit Dam10BandC;
— 3.3.1 Organogram_SHE Air_2018-09-17
— 3.3.1 Organogram_SHE WWLB_2018-09-03
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-20;
— Copy of Environment Impact register_ New FY17;
— Environment Impact register_ New FY19_2019-02-18;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— Environmental Complaints Register (2008-2019);
— Tech Support for ESD -20100819;
— Environment emergency procedure_SGR-SHE000023_rev6_2015-11;
— Environmental incident procedure Process flow;
— Works emergency procedure_CGR-EMP-000001_Rev04_2016-02;
— Induction_Mod1_1SHE Excellence;
— Induction_Mod4_ProcessSafetyManagement;
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— Induction_Mod5_WorkPlaceSafety;
— Induction_Mod6_EmergencyManagement;
— Induction_Mod7_Occupational;
— EA_EX Handover_SSO_WA-Process Water;
— EA_EX Handover_SSO_WA-Process Water_Amend VP;
— Compliance_Availability_Secunda Complex;
— EA Name Change applications_Transmittal_2017-03-29_signed;
— DARLEA_Sasol amendments acknowledgements_2017-04-10-1;
— DARLEA_Sasol amendments acknowledgements_2017-04-10-2;
— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage Dams_Amend_2016-03-23;
— Dams 10B & 10 C Control Survey Report 2014;
— Dams 10B & 10 C Control Survey Report 2015;
— 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.
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. Any amended conditions will be audited against instead of the
repealed ones and will be inserted in the audit table underlined below the original condition.
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.
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).
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3.5 AUDIT TEAM
The Auditor, Tutayi Chifadza, was hosted by Broni van der Meer, Simphiwe Njikelane and Aaron Matjomane 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 License 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
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
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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
3.1: SCOPE OF AUTHORISATION
3.1.1 Authorisation of the activity is subject to the conditions
contained in this authorisation which are part of the
environmental authorisation and are legally binding on the
holder of the authorisation.
N/A Noted. None
3.1.2 The holder of the authorisation must ensure compliance with
the conditions by any person acting on his or her behalf,
including but not limited to, an agent, sub-contractor,
employee or person rendering a service to the holder of the
authorisation.
NC All site personnel that work on the dams undergo a Safety, Health
and Environment (SHE) induction to ensure that they are familiar
with the site’s SHE aspects and requirements. All of Sasol’s training
is completed through the regional SHE learning and development
academy.
A post construction audit was conducted in March 2016 as required
by the condition 3.2.2 of this EA in order to ensure compliance with
the construction and rehabilitation activities. A 90% overall
compliance was achieved in this audit with 4 non-compliances
identified from 40 applicable conditions.
There is no requirement within the licence to audit against it
regularly both internally and externally, as such, any audits other
than the post-construction audit are undertaken from a best practice
perspective.
Non-compliances were observed over the course of this audit and
these must be rectified as per the recommendations issued.
Evidence:
— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-
06-14
— 003_41101534_20190125_Sasol_SSO_WA_EA_17.2.3.8G-
1_V1_AS_TC
Rectify all non-compliances
based on the
recommendations provided
in this report.
Target period:
Long term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.1.3 This authorisation refers only to the activity as specified and
described above. Any other activity listed under Section 24 of
the National Environmental Management Act (Act 107 of
1998, as amended) and which is not specified above, is not
covered by this authorisation, and must therefore comply with
the requirements of the National Environmental Management
Act and the regulations promulgated in terms of these laws.
C The EA authorises the construction of a dam and the associated
infrastructure (pipelines). The coordinates provided in the amended
EA show that the 2 dams and the related infrastructure are the only
forms of development within the stipulated development footprint.
No unauthorised activities are within the development footprint as
observed during the site visit.
Evidence:
— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-
02-05
— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage
Dams_Amend_2016-03-23
None
3.1.4 This authorisation does not negate the holder of the
authorisation`s responsibility to comply with any other
statutory requirements that may be applicable to the
undertaking of the activity.
C Sasol also required a Water Use Licence (WUL) for the operation
of the dams and as such, lodged an application for the registration
of water use in 2010. The application was then re-issued in 2015 and
a final electronic submission was completed in 2018. Sasol are still
waiting for DWS’s input. The proof of submission was available for
review.
Sasol has a site wide WUL for all their operations on the Synfuels
facility, however, this does not include the emergency dams. The
site wide Integrated Water and Waste Management Plan (IWWMP)
for the site was available for review and it included the dams
licensed in the EA indicating that they still require a WUL from
DWS.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— 12776_WULApp_Final_27 Aug 2010
None
3.2 MANAGEMENT AND MONITORING OF THE ACTIVITY
3.2.1 The Environmental Management Plan (EMP) submitted as
part of the application for environmental authorisation is NC The approved EMPr was available for review and it indicated that
monthly internal compliance inspections by the Environmental
Ensure that monthly internal
compliance inspections by
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
approved and must be implemented and adhered to
throughout the life cycle of the activities.
Management Officer (EMO) and annual external audits by a
qualified and competent auditor are required during the operational
phase to ensure compliance. The EMPr mitigation measures were
only audited as part of the 2016 EA post-construction audit and not
subsequently. Daily site checks are conducted by site personnel to
ensure that no problems arise, however, no formal audits are done
against the EMPr conditions.
Evidence:
— SSO_WA_17.2.3.8.G-1_EMPr_EmergencyStorageDams_
2010-09
— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-
06-14
the EMO and annual
external audits by a qualified
and competent auditor are
undertaken against the
conditions of the EMPr as
required.
Target period:
Short term
3.2.2 The holder of the authorisation must submit a post-
construction environmental audit report to the Department.
The audit report must be compiled by an accredited
independent auditor.
C Iliso Consulting (Pty) Ltd, an accredited independent auditor, on
behalf of Sasol in March 2016, completed a post construction and
the report was submitted to the Department on 10 April 2017. The
letter of submission was also available for review.
Evidence:
— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-
06-14
— 3.2.2_EA_ 2251_Submit post construct audit Dam10BandC
None
3.2.3 The Department retains the right to monitor and/or inspect the
project during its operational phases C The Department conducts inspections on the dams once a year,
however, no reports have been issued to Sasol to provide feedback.
None
3.2.4 Monitoring of boreholes for ground water quality must be
done monthly and records must be kept at the offices on site.
Amended Condition (Dated 23 March 2016)
Monitoring of boreholes for ground water quality must be
done bi-annually and records must be kept at the offices on
site.
C Groundwater monitoring is conducted biannually and quarterly as
required following the EA amendment received dated March 2016
from a monthly exercise. Thirteen groundwater monitoring points
around the dams were identified. Three groundwater monitoring
reports were available for review.
Evidence:
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-
20
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— GW_Report _Prj6143_2018-06-19
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-
20
— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-
02-05
3.2.5 Any pollution incidents associated with the development in
any nearby watercourse must be reported to DWA within 24
hours.
N/A Sasol uses an incidents register to take note of any environmental
pollution occurrences that occur on site. Incidents are investigated
and reported as required. Following a review of the incident
registers for the period 2015 to 2019, there were no incidents
specifically related to the emergency dams (no spillage or leak
incidents) that needed to be reported to the DWA within 24 hours.
Evidence:
— Copy of Environment Impact register_ New FY17
— Environment Impact register_ New FY19_2019-02-18
None
3.3: SPECIFIC CONDITIONS
3.3.1 The applicant must assign the development to a full time-
based team of Environmental Officers/Scientist who will
among others:
a) Ensure strict compliance of the development with the
conditions of the Environmental Authorisation as well as
measures contained in the Environmental Management Plan;
b) Discuss and advise employees on site about the
environmental good practice:
C Sasol has an environmental team that manages the site according to
the legislative requirements and ensure EA compliance. Due to the
vast number of operations on the Synfuels facility, there is no one
officer assigned to a particular site. The Sasol environmental team
works together to ensure compliance on the emergency dams and
advises employees on the site about good environmental practice as
required.
Whilst non-compliances have been identified in the course of this
audit, this aspect is covered by Condition 3.1.2.
Evidence:
— 3.3.1 Organogram_SHE Air_2018-09-17
— 3.3.1 Organogram_SHE WWLB_2018-09-03
OFI:
Rectify all non-compliances
based on the
recommendations provided
in this report.
Target period:
Long term
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3.3.2 Blocking of storm water drainage system must be prevented
and storm water must be managed to prevent soil erosion C It must be noted that the dams are built at a higher topography than
the surrounding area, therefore, this prevents any potential soil
erosion towards the dams or any blockages of the stormwater drains,
as was observed during the site walk. The dams have stormwater
drains on their edges that were observed to be clean and obstruction
free. Daily site inspections are completed to ensure no such
problems occur on the site. The edges of the dams are also vegetated
(which is maintained to ensure it does not grow out of control),
which also helps in preventing any erosion and lead to blockages.
Evidence:
Vegetated edges of the dams
None
3.3.3 Runoff and storm water must be diverted around the side of
the Emergency storage dams for process water body through
cut-off drains of channels/a system of beams.
C There are cut-off drains surround the dams to divert any runoff and
stormwater around the side of the emergency storage dams as
required. This was observed during the site visit.
Evidence:
None
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Cut-off drain
3.3.4 All waste slug generated on the site must be stored, handled
and disposed of in a registered landfill site or as directed by
any other relevant authority. Under no circumstances shall
burning of waste be allowed on site.
C Sasol use the waste management procedure (SGR-SHE000017) to
manage any waste generated on the site following a waste
management hierarchy.
Waste is disposed of at registered landfill sites, however, little to no
waste is expected to be generated at the dams since they are designed
to be water-holding facilities. No waste is burned on site as required
by the EA.
Evidence:
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09
None
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3.3.5 The soil stockpile must be shaped to reduce soil compaction
and must be managed properly to avert any wash down to
nearby watercourses.
N/A The post-construction audit indicated that all construction activities
were completed in 2010 and that no soil stockpiles were on site. The
dam walls had been shaped and vegetated to control erosion at the
time of the audit.
None
3.3.6 Alien and invader vegetation must be controlled and not
allowed to colonize the area. C Sasol cuts the vegetation once a year around the dam walls for fire
control that helps control invader and alien vegetation to an extent.
The crests of the edges are cut on a monthly basis as it is cheaper
than monthly control of the whole edge of the dam.
Evidence:
Vegetation control on crests
None
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3.3.7 Dust suppression measures must be implemented to avoid
pollution of the environment and diseases that might infect
workers
C According to the post construction audit, the construction of the
dams was completed before the issuing of the EA (c.2010). No
records are available as to the management of construction activities
are available for review regarding dust suppression, however, this
was closed out during the post-construction audit. Dams are now
operational and there are no stockpiles on the site. No dust is
generated on the footprint as the sides are vegetated and the roads
are graded and compacted to prevent any dust generation.
Evidence:
Vegetated edges of the dams
None
3.3.8 Any complaints received from employees or anyone within
the immediate vicinity must be attended to as soon as possible
and addressed to the satisfaction of all concerned
C There have been no complaints received regarding the emergency
dams since the operations commenced. The environmental
complaints register was available for review and contained
complaints for all business units dating back from 2008.
None
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Evidence:
— Environmental Complaints Register (2008-2019)
3.3.9 The Emergency storage dams for process water must be
designed in such a manner that the prevent seepage of
contaminated water from entering and polluting ground water
C According to the IWWMP, the process water emergency storage
dams have dual geosynthetic liners (1.5 and 2mm HDPE) with
leakage detection to prevent the seepage of contaminated water from
entering and polluting groundwater. This was confirmed during the
site walk.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
Dam liner
None
3.3.10 The design of the Emergency storage dams for process water
must ensure adequate capacity to prevent overflowing. C Although the IWWMP indicates that there is no accurate flow
measurement in place at the inflow to the process water dames, mass
balance calculations are used to acquire estimate figures. Process
water can be pumped to the other existing dams in the system to
prevent overflows and water is also pumped back to the primary area
None
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for use as process cooling water or for washing purposes in the
plants. Furthermore, the dams have a capacity of 1 366 599m3 and
1 078 894m3 each which was deemed sufficient during the design
phase and EA application process.
The dams have level meters that are observed on a daily basis to
ensure that they do not overflow and contaminate the Trichardspruit.
In the event of high levels, the valves on the drainage channels are
opened to allow the water to gravitationally flow from one dam to
the next thus preventing any overflows.
Following a review of the emergency dams’ technical support
document, it was indicated that the dams are located well outside the
1:100 year flood line. No overflow incidents have been reported in
the audit period following the review of the incidents register.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— Tech Support for ESD -20100819
— Environment Impact register_ New FY19_2019-02-18
Dam level meter
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3.3.11 The construction and operation activities related to the
infrastructure must comply with the relevant provisions of
Occupational Health and Safety Act (Act No. 85 of 1993).
C All site personnel that work on the dams undergoes SHE induction
to ensure that they are familiar with the site’s SHE aspects and
requirements. All of Sasol’s training is conducted 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.
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
None
3.3.12 An authorisation in terms of the National Water Act, of 1998
(Act No. 36 of 1998) obtainable from the Department of
Water Affairs must be obtained for the operation of all
activities that triggers water use licence.
C Sasol also required a Water Use Licence (WUL) for the operation
of the dams and as such, lodged an application for the registration
of water use in 2010. The application was then re-issued in 2015 and
a final electronic submission was done in 2018.
Sasol has a site wide WUL for all their operations on the Synfuels
facility, which incorporates the emergency dams. The site wide
Integrated Water and Waste Management Plan (IWWMP) for the
site was available for review and it included the dams licensed in the
EA.
Evidence:
— 12776_WULApp_Final_27 Aug 2010
— Tech Support for ESD -20100819
None
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3.3.13 Demarcated walkways must be established to access the
facility. C Demarcated walkways have been provided around the emergency
dams as was confirmed in the post construction audit. The road is
compacted and was observed during the site walk.
Evidence:
Compacted road
None
3.3.14 An Integrated Emergency Plan must be developed and
include; 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. A works emergency procedure is
also available for any Health and Safety incidents.
Evidence:
— Environment emergency procedure_SGR-
SHE000023_rev6_2015-11
— Environmental incident procedure Process flow
— Works emergency procedure_CGR-EMP-
000001_Rev04_2016-02
None
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3.3.15 — Proper communication system between personnel and
other facilities on-site, adjacent neighbours and fire
brigade.
C The Synfuels emergency plan shows that during an incident, the
personnel in the area or unit must report to Emergency Management
at 10-4444 / 10-2444 who will then inform Environmental
Management Services standby person and Market Integrations.
All environmental incidents are recorded in the incident register,
investigated accordingly and reported if there is a need.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Environmental incident procedure process flow
None
3.3.16 — Suitable signage must be clear and interpreted in all
possible languages that can be used on site, in relation to
the danger associated with pollution control dam.
C The site has internationally acceptable pictograms used identify
danger and warn personnel of the dangers associated with the
emergency dams, which is considered acceptable to convey the
dangers. Furthermore, the PCDs are located well within security
contained areas (restricting the likelihood of tresspassers), and
English is the official language for all communication in Sasol.
Evidence:
OFI:
When the signage requires
replacement, ensure that
signage is put up in at least 3
languages, English,
Afrikaans and Zulu.
Target period:
Long term
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Dam dangers sign
3.3.17 — Code to identify the kind and severity of a release or
spillage when communicating it through to one another; C The environmental incidents are recorded in the incident register,
which has a column for indicating the magnitude or severity of the
incident. The column is also used to indicate whether the incident is
a repeat incident. The severity then determines whether the incident
is reported to the Department of Water and Sanitation.
Evidence:
— Environmental Impact Register_ FY17-19
None
3.3.18 — Actions to take in the case of various releases, spillages
and occurrence of the fire; C The environmental emergency procedure shows the actions to be
taken in response to an incident as well as preventative actions that
are tabled to prevent future occurrences. All the relevant
requirements of the emergency plan including releases and spillages
are addressed in Section 9 of the procedure as required. Section 4 of
the works emergency procedure addresses fire procedures.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
None
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— Works emergency procedure_CGR-EMP-
000001_Rev04_2016-02
3.3.19 — Responsible personnel management of different actions C The environmental emergency and the works emergency procedures
show the responsible personnel to manage different actions in an
emergency. There are various designations given to specific
personnel (standby person, shift foreman, area emergency
controller, senior officer of emergency management etc.) who are
mentioned in the management actions taken. These are displayed in
the site offices, on notice boards, as well as signage around the
dams. The emergency phone numbers are also listed accordingly.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Works emergency procedure_CGR-EMP-
000001_Rev04_2016-02
Emergency telephone numbers
None
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3.3.20 In the event of an accidental spillage, clean-up of the spillages
must be undertaken within 48 hours. C The clean-up of spillages is completed immediately after the
Environmental Management Services standby person is informed of
the incident. The procedure also indicates that any reportable
incidents to DWS are completed within 24 hours after they have
occurred, with an action plan presented as part of the reporting.
Furthermore, there have been no spillage events on the dams which
required clean-up and this was confirmed following a review of the
incidents register.
Evidence:
— Environmental emergency procedure (Rev 6): SGR-
SHE000023
— Environmental Impact Register_ FY17-19
None
4: SITE CLOSURE
4.1 Should the activity ever cease or become redundant, the
applicant shall undertake the required actions as prescribed by
legislation at the time and comply with all relevant legal
requirements administered by any relevant and competent
authority at that time.
N/A Noted. The Emergency Dams are currently operational and this will
only be considered when closure is carried out.
None
4.2 A Rehabilitation Plan must be submitted to this Department
for approval at least six (6) months prior to the
decommissioning of the facility.
N/A Noted. The Emergency Dams are not being considered for closure
at this stage.
None
5: GENERAL
5.1 A copy of this authorisation must be kept at the property
where the activity will be undertaken. The authorisation must
be produced to any authorized official of the Department who
C Copies of all authorizations and licenses are sent to, and details
communicated with, relevant business units. Copies of these
documents are also available at the SHE: Environment department
None
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requests to see it and must be made available for inspection
by any employee or agent of the holder of the authorisation
who works or undertakes work at the property.
and on SAP EC and SharePoint. Sasol provided the auditor with the
evidence that the responsible person, Rakesh Durjan (Senior
Manager of Process Water Area), was made aware of the EA on 27
September 2016.
All environmental aspects are shared to site personnel during
induction.
Evidence:
— EA_EX Handover_SSO_WA-Process Water
— EA_EX Handover_SSO_WA-Process Water_Amend VP
— Compliance_Availability_Secunda Complex
5.2 The holder/applicant of this authorisation is responsible for
compliance with the duty of care remediation as contained in
Section 28 of the National Environmental Management Act,
1998 (Act No.107 of 1998).
N/A Sasol advised the auditor that they are aware of their responsibility
for compliance with the provision for Duty of Care and Remediation
of Environmental Damage as contained in Section 28 of the
National Environmental Management Act, 1998 (Act No.107 of
1998).
None
5.3 Any changes to or deviations from the project description set
out in this authorisation must be approved in writing by the
Department before such changes of deviations may be
effected. In assessing whether to grant such approval or not,
the Department may request such information as it deems
necessary to evaluate the significance and impacts of such
changes or deviations
N/A Noted. The EA authorises the construction of two dams and related
infrastructure. No deviations to the authorised EA were observed.
None
5.4 Where any of the applicant`s contact details change, including
the name of the responsible person, the physical or postal
address and/or telephonic details, the applicant must notify the
Department as soon as the new details become known to the
applicant.
C A name change application was lodged in February 16 from Sasol
Synfuels (Pty) ltd to Sasol South Africa (Pty) Limited. This was
captured in the amended EA issued in March 2016.
The name change was communicated to the Mpumalanga
Department of Agriculture, Rural Development, Land and
Environmental Affairs on 27 March 2017 and was received on 29
March 2017.
Evidence:
None
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— EA Name Change applications_Transmittal_2017-03-
29_signed
— DARLEA_Sasol amendments acknowledgements_2017-04-
10-1
— DARLEA_Sasol amendments acknowledgements_2017-04-
10-2
— SSO_WA_17.2.3.8.G-1_EA_Const Emergency Storage
Dams_Amend_2016-03-23
5.5 The holder of the authorisation must notify the Department,
in writing and within 24 (twenty-four) hours, if conditions of
this Environmental Authorisation are not adhered to. Any
notification must be accompanied by reasons for the non-
compliance.
NC Although non-compliances have been observed during this audit, no
evidence of reporting of these non-compliances to the department
was available for review period outside of the post construction
audit that was conducted in March 2016 and submitted in April
2017.
Ensure any non-compliances
submitted to the
Department. Furthermore,
consider an amendment to
have the requirement of
notification within 24 hours
unless it is a major pollution
event.
Target period:
Long term
5.6 Non-compliance with a condition of this authorisation may
result in criminal prosecution or other actions provided for in
the National Environmental Management Act, 1998 and the
regulations.
N/A Noted. None
5.7 National government, provincial government, local
authorities or committees appointed in terms of the conditions
of this authorisation or any other public authority shall not be
held responsible for any damages or losses suffered by the
applicant or his successor in title in any instance where
construction or operation subsequent to construction be
temporarily or permanently stopped for reasons of non-
compliance by the applicant with the conditions of
authorisation as set out in this document or any other
N/A Noted None
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subsequent document emanating from these conditions of
authorisation
6: APPEAL OF AUTHORISATION
6.1 The holder of the authorisation must notify every registered
interested and affected party, in writing and within twelve (12)
days of the date of this decision, of the outcome of the
application.
NC The post construction audit confirmed that the registered interested
and affected parties (I&APs) were notified in writing, however, this
was not within the 12 days of the date of decision as required.
Notification was made on 10 November 2015 but the EA was issued
on 29 September 2015. This was closed out in this audit report, as
notifications cannot be redone.
Evidence:
— 3.2.2_EA_17.2.3.8.G-1_Post Construct Audit Report_2016-
06-14
Not rectifiable.
6.2 The notification referred to above, must –
(a) Specify the date on which the authorisation was issued. C The date of the authorisation was issued was indicated in the
notification.
None
(b) Inform the interested and affected party of the appeal
procedure provided for in Chapter 7 of the Regulations. C The I&APs were notified of the appeal procedure provided in
Chapter 7 of the Regulations.
None
(c) Advise the interested and affected party to the manner in
which the decision can be accessed.
NC Interested and affected parties were not advised as to the manner in
which the decision could be accessed.
Not rectifiable.
(d) Be published in the newspaper contemplated in Regulation
54(2)(c) and which newspaper was used for the placing of
advertisement as part of the public participation process.
C An advertisement was placed in “The Ridge Times” as part of the
public participation process.
None
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Table 3: Audit Findings – Environmental Management Plan
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
CONSTRUCTION PHASE
Terrestrial Ecology Maintain existing ecological function
beyond the boundaries of the construction
site:
— The footprint to be cleared and the area
to be covered by the embankments will
be clearly demarcated. Identified
sensitive areas (e. g. wetlands) will be
avoided as far as possible. Vegetation
will be cleared before the grass owls
start nesting in early spring.
— Laydown of construction materials and
parking of vehicles will take place
within the footprint to be cleared.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Limit the impact to the area of the dam basins
only:
— The area to be excavated will be clearly
demarcated prior to the commencement
of excavation and the excavation
progress will be monitored to ensure its
confinement within the demarcated
area.
— If burrowing animals with young are
encountered, they will be captured and
relocated.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
To maintain control of weeds and invasive
aliens:
— Disturbed areas will be re-vegetated
with locally indigenous grasses
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
None
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(Themeda triandra, Hyparrhennia hirta
and Eragrostis species) and monitored
until the vegetation becomes self-
sustaining.
— The progress of the re vegetation
programme will be monitored quarterly
and corrective action taken as
necessary, with input from a specialist
as may be required.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
Surface Water To prevent pollution of soil and dirty runoff
to Trichardspruit:
— Water quality in the Trichardspruit
downstream of the project site will be
checked with regard to TDS,
hydrocarbons and silt prior to
construction, monthly during
construction and again after completion
of construction.
— Maintenance and refuelling to be done
at contractors’ camp, not within
footprint of new dams.
— Spill kits must be available at site.
— Drip trays will be placed under vehicles
when parked.
— All spillages incidents will be recorded.
— Contaminated soil will be removed
immediately and disposed at an
appropriate facility.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
To prevent transport of silt into the
Trichardspruit:
— A trench will be dug down-gradient of
the dam basin and along the footprint of
each dam wall before clearing of
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
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vegetation. Construction of dam walls
will take place immediately as material
is removed from the dam basin
— The silt content of runoff to the
Trichardspruit will be monitored after
each significant rainfall event during
the construction period.
Groundwater To prevent pollution of soil and
groundwater:
— Ensure proper construction of liner
systems in accordance with design
specifications by diligent supervision
and weekly inspections Groundwater
quality in monitoring boreholes up- and
down-gradient of the site will be
checked and recorded prior to and after
completion of construction
— Maintenance and refuelling to be done
at contractors’ camp, not within
footprint of new dams
— Spill kits must be available at site
— Drip trays will be placed under vehicles
when parked
— All spillages incidents will be recorded
— Contaminated soil will be removed
immediately and disposed at an
appropriate facility.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Air Quality No visible dust at construction sites:
— Install dust buckets up – and down-
wind of the site
— Apply wet suppression, especially on
dry, windy days
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
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— Ensure proper maintenance of vehicles,
especially diesel engines
— Enforce low speed limits on unpaved
areas
No increase in PM10 or PM2.5 at monitoring
points:
— Record weekly measurements of PM10
and monthly mass of dust collected in
fallout buckets.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
No increase in dust fall at monitoring points. N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Noise Non-exceedance of nuisance noise levels at
sensitive receptors. See Table 5-5:
— Noise abatement equipment on
machinery will be properly maintained.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Protection of personnel from health impacts
associated with high noise levels:
— In general, operations must meet the
noise standard requirements of the
Occupational Health and Safety Act
(Act No 85 of 1993).
— Construction staff working in areas
where the 8-hour average ambient noise
levels exceed 75dBA must wear
hearing protection equipment.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Personnel must wear hearing protection
in vicinity of machinery with dBA
levels of 85 dBA or more at 5 metres.
Socio-economic Maximise benefit for local contractors:
— Give preference to local contractors
wherever practicable.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Cultural and heritage
resources
Identification and preservation of cultural
and heritage resources:
— Train supervisory personnel to
recognise human remains and artefacts
of potential cultural and heritage value
that may be unearthed during
construction
— In the event of such artefacts or human
remains being found, work in the
immediate vicinity thereof will be
halted and a specialist will do an
inspection.
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
Dangerous activities
To maintain safe work practices in a safe
environment and to minimise personnel
injuries and damage to assets:
— Toolbox talks/staff briefing sessions
— Site workers’ training programme
— Training in the use and handling of
equipment
N/A This condition is considered outside of the audit period (construction
pre-2014). It is therefore considered not applicable. This authorisation
was issued in response to a Section 24G rectification application.
Thus, all construction activities were completed in 2010 before the
issuing of the authorisation.
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
OPERATIONAL PHASE
Dam Stability To detect signs of instability early enough to
enable the dams to be emptied before any
collapse occurs:
— The vertical positions of the
benchmarks and the monitoring points
will be surveyed before water flows into
the dams, and again weekly until the
design water level is reached. The water
levels will also be surveyed. Thereafter,
the survey will be done monthly until
initial settling has ceased, where after
the survey will be repeated quarterly.
The instruments and methodology used
will determine the vertical positions of
the benchmark beacons and the
monitoring points with an accuracy of <
10mm and will provide early warning
of any signs of instability.
— The data will be monitored for signs of
settling that could herald the onset of
unstable conditions. If such conditions
are detected, the dams will not be
viewed as long-term features, but will
be emptied and closed as soon as
possible.
— If further analysis of the risk parameters
shows a low risk of instability over the
long term and Sasol Synfuels decides to
keep the dams in operation, the survey
intervals may be increased to once per
annum, or the surveys may cease
altogether, depending on the outcome
of the risk analysis.
C This authorisation was issued in response to a Section 24G
rectification application. Thus, all construction activities were
completed in 2010 before the issuing of the authorisation. Therefore,
the first two parts of this authorisation are not applicable.
Nako Lategan Bouwer Consulting Engineers (Nako LBE) conducts
annual dam surveys on behalf of Sasol. The operation and
maintenance manuals of the emergency dams states that both must be
monitored on a yearly basis for any movement from possible roof
instability of the old mined-out areas under the dams. In November
2011, a base survey for vertical movement was conducted at Dam 10B
and during November 2011 at Dam 10C. The base survey for
horizontal movement was only done during October 2012 at both
dams. These surveys were used going forward as a basis to monitor
possible movement of the dam walls. These identified low risk of
instability and surveys have been done on an annual basis.
A sample of the reports were available for review and they indicated
that the measured vertical movements are completely within the norm
and acceptable range as this is expected due to settling over time.
Evidence:
— Dams 10B & 10 C Control Survey Report 2014
— Dams 10B & 10 C Control Survey Report 2015
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Terrestrial Ecology Control of invasive aliens, weeds and exotics
in vicinity of project:
— A programme to eradicate weeds, alien
invasive and exotic plant species will be
instituted and maintained.
— Progress will be monitored quarterly
until the indigenous species have been
restored to good condition, thereafter
annually.
C The auditor was informed that Sasol cuts the vegetation once a year
around the dam walls for fire control as well as removing alien
invasive species, weeds and exotics at the same time. The crests of the
edges of the sides of the road adjacent to the dams are cut on a monthly
basis, as it is cheaper than monthly control of the whole area around
the dam.
Evidence:
Cut road edges
None
Surface water To prevent the existing process water dams
from overflowing and contaminating the
Trichardspruit:
— The emergency dams must be built
before the commencement of the
2010/2011 rain season
C Although the IWWMP indicates that there is no accurate flow
measurement in place at the inflow to the process water dames, mass
balance calculations are used to acquire estimate figures. Process
water can be pumped to the other existing dams in the system to
prevent overflows and water is also pumped back to the primary area
for use as process cooling water or for washing purposes in the plants.
Furthermore, the dams have a capacity of 1 366 599m3 and
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
1 078 894m3 each which was deemed sufficient during the design
phase and EA application process.
The dams have level meters that are observed on a daily basis to ensure
that they do not overflow and contaminate the Trichardspruit. In the
event of high levels, the valves on the drainage channels are opened to
allow the water to gravitationally flow from one dam to the next thus
preventing any overflows.
Following a review of the emergency dams’ technical support
document, it was indicated that the dams are located well outside the
1:100 year flood line. No overflow incidents have been reported in the
audit period following the review of the incidents register.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— Tech Support for ESD -20100819
— Environment Impact register_ New FY19_2019-02-18
Dam level meter
To prevent deterioration of water quality and
habitat in the Trichardspruit due to seepage C According to the IWWMP, the process water emergency storage dams
have dual geosynthetic liners (1.5 and 2mm HDPE) with leakage
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
of contaminated process water from the
emergency dams:
— The emergency dams must be lined as
per the description provided in Section
2.4.
— Water quality and aquatic health in the
Trichardspruit will be monitored at the
sampling points shown in Figure 5-3 on
a quarterly basis (February, May,
August, November), Samples will be
analysed for TDS, silt load, COD, F,
NH3, B, As, Cd and Se
detection to prevent the seepage of contaminated water from entering
and polluting groundwater. This was confirmed during the site walk.
The dams are equipped with a leak detection system and any leaks are
collected and passed back into the surrounding dams. There were
minimal to no leaks observed during the site walk.
Water quality and aquatic health in the Trichardspruit is monitored at
the required sampling points in Figure 5-3 of the EMPr and more
samples are taken along the route as well. The Trichardspruit is
monitored off RESM 2 (for seepage from process water dams 8, 9 and
the main body of process water dams), RESM 4 (for eastern portion of
dam 9 and game and cattle farming as well as historical irrigation
area), RESM 5 (for runoff from Secunda and Sasol general landfill
site) and RESM 26 (for sewage works). RESM 4 and 26 are monitored
on a weekly basis while RESM 2 and 5 are monitored weekly and
continuously. It must be noted that these monitoring locations measure
the impact of the contributions of the facilities in the area and not
specifically to the emergency storage dams alone. Since there have
been no incidents regarding overflows and seepages with regards to
the emergency dams, it can be assumed that they have not contributed
to any potential deterioration in water quality in the Trichardspruit.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
— Environment Impact register_ New FY19_2019-02-18
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Leak detection collection sump
Groundwater To prevent deterioration of groundwater
quality due to seepage of contaminated
process water from the emergency dams:
— The emergency dams must be lined as
per the description provided in section
2.4
— The groundwater status must be
monitored by six-monthly sampling and
analysis of up-gradient and down-
gradient boreholes for TDS, COD, F,
NH3, B, As, Cd and Se
C According to the IWWMP, the process water emergency storage dams
have dual geosynthetic liners (1.5 and 2mm HDPE) with leakage
detection to prevent the seepage of contaminated water from entering
and polluting groundwater. This was confirmed during the site walk.
The dams are equipped with a leak detection system and any leaks are
collected and passed back into the surrounding dams. There were
minimal to no leaks observed during the site walk as shown the leak
detection collection sump image above.
Groundwater monitoring is conducted biannually and quarterly as
required following the EA amendment received dated March 2016
from a monthly exercise. Thirteen groundwater monitoring points
around the dams were identified. Three groundwater monitoring
reports were available for review.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— GWMonitor Report May 2018 Final_Prj6164rev-01_2018-11-20
— GW_Report _Prj6143_2018-06-19
— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20
— 3.2.4_EA_17.2.3.8.G-1_1918_NotEA amend request_2016-02-
05
CLOSURE PHASE
Terrestrial Ecology Prevent invasive aliens, weeds and exotics
from establishing and spreading into the
surrounding veld.
N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Surface Water To prevent pollution of soil and dirty runoff
to Trichardspruit. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Prevent transport of silt into Trichardspruit
by storm water runoff. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Groundwater To prevent pollution of soil and
groundwater. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Air Quality No visible dust at project site. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
No increase in PM10 or PM2.5 at monitoring
points
N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
No increase in dust fall at monitoring points. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Noise Non-exceedance of nuisance noise levels at
sensitive receptors. See Table 5-5 N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Protection of personnel from health impacts
associated with high noise levels. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Land use and land
capability
To rehabilitate the decommissioned dams to
a self-sustaining state after removal of the
ash layer and liners to.
N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
Socio-economic Maximise benefit for local contractors. N/A The Emergency Dams are currently operational and not yet marked for
closure.
None
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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
SCOPE OF AUTHORISATION 4 2 1 1
MANAGEMENT AND MONITORING OF THE ACTIVITY 5 3 1 1
SPECIFIC CONDITIONS 20 19 0 1
SITE CLOSURE 2 0 0 2
GENERAL 7 2 1 4
APPEAL OF AUTHORISATION 5 3 2 0
Total Count 43 29 5 9
Total Percentage 67% 12% 21%
Percentage Compliance with Applicable Conditions 85%
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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
5
10
15
20
25
Scope ofAuthorisation
Managementand
Monitoring ofthe Activity
SpecificConditions
Site Closure General Appeal ofAuthorisation
Sectional Count Contribution
C
NC
N/A
29
5
9
Total Compliance
C
NC
N/A
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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
Scope ofAuthorisation
Managementand Monitoringof the Activity
SpecificConditions
Site Closure General Appeal ofAuthorisation
Sectional Percentage Contribution
C
NC
N/A
67%
12%
21%
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 N/A
CONSTRUCTION PHASE 14 0 0 14
OPERATIONAL PHASE 5 5 0 0
CLOSURE PHASE 11 0 0 11
Total Count 30 5 0 25
Total Percentage 17% 0% 83%
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
0
2
4
6
8
10
12
14
16
Construction Phase Operational Phase Closure Phase
Sectional Count Contribution
C
NC
N/A
5
0
25
Total Compliance
C
NC
N/A
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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 Phase Operational Phase Closure Phase
Sectional Percentage Contribution
C
NC
N/A
17%
0%
83%
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 half of the listed measures are now no longer
applicable, as these related to the construction-phase 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
(17/2/3/8/G-1)
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