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SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
17/2/3 GS-172 - C3 EXPANSION PROJECT
29 MAY 2019
CONFIDENTIAL
WSP Environmental (Pty) Ltd.
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT
17/2/3 GS-172 - C3 EXPANSION PROJECT
SASOL CHEMICALS OPERATIONS:
POLYPROPYLENE 2
TYPE OF DOCUMENT (VERSION)
CONFIDENTIAL
PROJECT NO.: 41101534
DATE: MAY 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 GS-
172
Draft v1a for Review
– Compliance Audit
EA Ref: 17/2/3 GS-
172
Draft v2 for Review –
Compliance Audit
EA Ref: 17/2/3 GS-
172
Final – Compliance
Audit
EA Ref: 17/2/3 GS-
172
Date April 2019 May 2019 May 2019 May 2019
Prepared by Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher Bronwyn Fisher
Signature -
Checked by Jenny Cope Jenny Cope Jenny Cope Jenny Cope
Signature
Authorised by Jenny Cope Jenny Cope Jenny Cope Jenny Cope
Signature
Project number 41101534 41101534 41101534 41101534
Report number 006 006 006 006
File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\
S I G N A T U R E S
PREPARED BY
-
Bronwyn Fisher
Environmental Consultant
REVIEWED BY
Jenny Cope
Associate
This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf
and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding
of their compliance with the conditions included in the 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
CLIENT
SHE: Environmental Compliance
Specialist
Broni van der Meer
Polypropylene Production Senior
Manager
Eric Munyangane
WSP
Associate Jenny Cope
Lead Auditor Ashlea Strong
Consultant Bronwyn Fisher
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2
WSP May 2019
TABLE OF CONTENTS
1 INTRODUCTION ........................................................ 1
1.1 Terms of Reference .................................................................... 1
1.2 C3 Expansion Project (Authorisation Number:
17/2/3 GS-172) ............................................................................. 1
2 AUDIT SCOPE ........................................................... 3
3 AUDIT METHODOLOGY ........................................... 4
3.1 Audit Checklist ........................................................................... 4
3.2 Site Inspection ............................................................................ 4
3.3 Documentation Considered ...................................................... 4
3.4 Audit Compliance Assessment ................................................. 5
3.5 Audit Team .................................................................................. 5
3.6 Assumptions and Limitations ................................................... 6
4 AUDIT FINDINGS ...................................................... 7
5 SUMMARY OF THE AUDIT FINDINGS ................... 34
5.1 Environmental Authorisation .................................................. 34
5.2 Environmental Management Plan ........................................... 37
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2
WSP May 2019
TABLES
TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................................................. 5
TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................................................... 7
TABLE 3: AUDIT FINDINGS – ENVIRONMENTAL MANAGEMENT PLAN ................................................. 18
TABLE 4: SUMMARY OF EA COMPLIANCE AUDIT FINDINGS ........................................................ 34
TABLE 5: SUMMARY OF EMPR COMPLIANCE AUDIT FINDINGS ............................... 37
FIGURES
FIGURE 1: THE LOCATION OF THE C3 EXPANSION PROJECT (RED BLOCK) (SOURCE: GOOGLE EARTH, 2018) ............................................................... 2
FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ............................................................ 35
FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EA CONDITIONS .............................................................. 35
FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EA CONDITIONS PER SECTION ..................................... 36
FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EA CONDITIONS ................................................ 36
FIGURE 6: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................... 38
FIGURE 7: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS .............................................................. 38
FIGURE 8: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EMPR CONDITIONS PER SECTION ..................................................................... 39
FIGURE 9: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EMPR CONDITIONS........................................... 39
ENVIRONMENTAL AUTHORISATION & ENVIRONMENTAL MANAGEMENT PLAN COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL CHEMICALS OPERATIONS: POLYPROPYLENE 2
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APPENDICES
A ENVIRONMENTAL AUTHORISATION (17/2/3 GS-172)
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Page 1
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 GS- 172 issued on 13 November 2013) as well as
the associated Environmental Management Plan (dated: August 2013) for the period December 2014 to
February 2019.
1.2 C3 EXPANSION PROJECT (AUTHORISATION NUMBER:
17/2/3 GS-172)
An Environmental Authorisation (reference 17/2/3 GS-172) for the C3 expansion project was issued on 13
November 2013 by the Department of Economic Development, Environment and Tourism, Mpumalanga
Provincial Government.
The C3 expansion project was commissioned to address an estimated 105 ktpa (kilo tons per annum) additional
propylene that was being produced as a result of various optimisation projects on the upstream Sasol facilities.
An opportunity was identified for the additional propylene to be utilised as feed for the polypropylene (PP)
plants, namely PP1 and PP2.
The operating intent of the PP plants is the maximum conversion of propylene and ethylene from Sasol
operations into polypropylene pellets via a polymerization process. The products from this reaction are
homopolymers (constituting only propylene), impact copolymers (constituting propylene and high concentration
of ethylene) and random copolymers (propylene and low concentration of ethylene).
The C3 expansion project involved the upgrading and implementing of changes to the existing PP1 and PP2
process equipment to accommodate the increase in throughput. Figure 1 and Error! Reference source not
found. provide the location of the C3 Expansion Project.
Construction of the expansion project was completed between 2015 and 2016, therefore any construction related
conditions are considered relevant to the audit period.
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Figure 1: The location of the C3 Expansion Project (red block) (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. Construction of the expansion project was
completed between 2015 and 2016, therefore any construction related conditions are considered relevant to this
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; and
— Make recommendations in order to achieve compliance in terms of the EA and EMPrs.
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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 (11 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
Bronwyn Fisher conducted the site inspection on 11 March 2019. The findings and observations of the site visit
are recorded and summarised in Section 4 with evidence included in Table 2 and Table 3. Key personnel
interviewed included:
— Brinton Walker (Technical Support Group (Polymers))
— Lucky Jiyane (Process Controller Grade 1)
3.3 DOCUMENTATION CONSIDERED
The following documentation was provided and considered:
— EA_C3 Expansion_17.2.3 GS-172_ 2013_11_13;
— EMP_C3 Expansion_17.2.3 GS-172_ 2013_08;
— Sasol C3 Expansion-Final BAR plus App_red;
— Induction_Mod3_Environment;
— EA_EX Handover_SCO_Poly_Nitro_Poly;
— 3.06_EA_C3_Notification of construction_Encore_2016-04-30;
— 3.19_EA_C3_Bund Wall Philosophy_61424R-010-DW-1452-001-1
— Sasol Environmental Emergency Procedure (SGR-SHE-000023 REV6);
— Environmental Complaints Register_2019-02-18;
— SEC-042-2018-GIJ_(NOISE)_(Polymers,_Propylene_Production,_PP2);
— 3.32_EA_C3Expansion_SCO_POL_Amendment_1.3.1.16.4 G-39_2017-04-28;
— 3.26_EA_C3_Steel disposal certificates;
— PP1_PP2 Final Waste Register_2016-05-16;
— PP1_PP2 Final Waste Register_2016-10-21;
— Labour_Sasol IRM Suppliers Industrial Relations Procedure;
— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017- 2022 Rev_0;
— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1- Polymers 2017 Rev 2;
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— SAS-490- Final PP1 and PP2.xlsx;
— Environmental incident procedure Process flow;
— 3.11_EA_C3Expansion_IAP_BA-AppendixC (1);
— 3.12_EA_C3Expansion_IAP_BA-AppendixC (1);
— 3.29_EA_C3Expansion_PolymersEmergManProcedure (1);
— PP2 Production Matrix -New 1;
— Decommission catalyst system for maintenance V1;
— Catalyst, Co-Catalyst and Modifier Neutralization and draining;
— C3 Expansion Project Closeout Report_2016-04-22 (1);
— C3 Expansion Project_Aspect Register (1); 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.
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).
3.5 AUDIT TEAM
The auditor, Bronwyn Fisher, was hosted by Broni van der Meer, Brinton Walker and Lucky Jiyane 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.
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— Auditor: Bronwyn Fisher
Bronwyn Fisher has 6 years of experience as an Environmental Consultant, undertaking Environmental
Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental
Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and
undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel
storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,
recycling facilities, mixed-use developments, industrial developments and renewable energy technology
projects.
— Lead Auditor and Quality Assurance: Ashlea Strong
Ashlea has 16 years’ experience and holds a Masters in Environmental Management; a BTech (Nature
Conservation), and a National Diploma (Nature Conservation); She is also a Certified Environmental
Assessment Practitioner of South Africa (CEAPSA). She currently provides technical and strategic
expertise on a diverse range of projects in the environmental management field, including environmental
scoping and impact assessment studies, environmental management plans, waste and water management, as
well as the provision of environmental management solutions and mitigation measures. She has been
involved in the management of a number of large EIAs within South Africa and has environmental auditing
and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed
in the audit process.
— Project Manager and Quality Assurance: Jenny Cope
Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental
Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;
undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a
range of sectors. Jenny’s recent experience includes completion and management of several pan-European
and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and
providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in
environmental consultancies and with a developer, giving context to understanding the practicalities of
implementing recommendations.
3.6 ASSUMPTIONS AND LIMITATIONS
This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an
understanding of the Relevant Documents.
Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other
than the Client for the contents of, or any omissions from, this Report.
To prepare this Report, we have reviewed only the documents and information provided to us by the Client or
any third parties directed to provide information and documents to us by the Client. We have not reviewed any
other documents in relation to this Report and except where otherwise indicated in the Report.
The findings, recommendations and conclusions given in this report are based on the author’s best scientific and
professional knowledge, as well as available information. This report is based on survey and assessment
techniques which are limited by time and budgetary constraints relevant to the type and level of investigation
undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if
and when new information may become available from on-going research or further work in this field, or
pertaining to this investigation.
Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts
no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and
employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or
in connection with the services rendered, directly or indirectly by the use of the information contained in this
document.
This report must not be altered or added to without the prior written consent of the author. This also refers to
electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.
Similarly, any recommendations, statements or conclusions drawn from or based on this report must make
reference to this report. If this report is used as part of a main report, the report in its entirety must be included
as an appendix or separate section to the main report.
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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
SCOPE OF AUTHORISATION
3.01 Authorisation of the activity is subject to the conditions
contained in this Environmental Authorisation, which form
part of the environmental authorisation and are binding on
the holder of the authorisation.
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
3.02 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 any person rendering a service to the holder of
the authorisation.
C All visitors and contractors entering the Sasol Complex are
required to undergo an SHE induction process. All training is done
through the SHE regional learning and development academy, and
records maintained by Sasol. The auditor was provided with a copy
of the induction training, specifically Module 3, which covers the
environmental aspects and management of the site. Sasol have
advised the auditor that the Conditions of the EA form part of any
contract for the maintenance of the plant.
Evidence:
— Induction_Mod3_Environment
None.
3.03 The activity which is authorised may only be carried out at
the property indicated above. C The description of the location of the project is within Sasol
Secunda. Sasol is compliant with this location description.
The auditor undertook a desktop review of the location of the C3
Stabilisation project and although the coordinates located within
the EA are slightly out it is within the general location of the
Polypropylene plant.
Evidence:
OFI:
Sasol should undertake an
EA amendment process to
amend the coordinates
within the EA to reflect the
true location of the facility.
Target completion:
Long term
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Location of the activity as stated in the EA
The location of the coordinates contained within the EA.
3.04 Any changes to, or deviations from, the project description
set out in this Environmental Authorisation must be
approved, in writing, by the Department before such changes
or 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 and it may be
necessary for the holder of the Environmental Authorisation
to apply for further Environmental Authorisation in terms of
the regulations.
N/A Noted. Sasol has advised the auditor that no changes have been
made to the project description as set out in the Environmental
Authorisation.
None.
3.05 A copy of this Environmental Authorisation must be made
available on site at all times and all relevant staff, contractors
and sub-contractors must be made familiar with the contents
of this Environmental Authorisation.
C Copies of all authorisations and licenses are sent to, and details
communicated with, relevant business units. Copies of these
documents are also available at the SHE: Environment department
and on SAP EC and SharePoint. Sasol provided the auditor with the
evidence that the responsible persons Eric Munyangane and
Francois du Toit, were made aware of the EA in September 2016.
Evidence:
— EA_EX Handover_SCO_Poly_Nitro_Poly
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.06 This activity must commence within a period of three (3)
years from the date of issue. If commencement of the activity
does not occur within that period, the Environmental
Authorisation lapses and a new application for
Environmental Authorisation must be made in order for the
activity to be undertaken.
C Construction commenced on the expansion project at the end of
April 2016. As the EA was issued on 13 November 2013 and
therefore construction commenced within 3 years of the date of
issue of the EA.
Evidence:
— 3.06_EA_C3_Notification of construction_Encore_2016-04-
30
None.
3.07 The Department may change or amend any of the conditions
in this Environmental Authorisation if, in the opinion of the
Department is environmentally justified.
N/A Noted. Sasol advised the auditor that, to their knowledge, the
Department has not changed or amended any conditions within the
EA.
None.
3.08 In the event of any dispute concerning the significance of a
particular impact, the opinion of the Department in respect of
its significance will prevail.
N/A Noted. Sasol has advised the auditor that there has been no dispute
concerning the significance of a particular impact with the
Department to date.
None.
3.09 This Environmental Authorisation does not absolve the
holder of the authorisation, responsibility to comply with any
other statutory requirements that may be applicable to the
undertaking of the activity.
N/A Noted. A full legal review does not form part of the scope of this
Audit.
The site is operated under ISO14001:2015, which requires the
compilation of a legal register. Furthermore, WSP has been
provided with the 2018 ISO audit for review, which specifically
states “the development of the compliance risk management
protocol (CRMP) to assist the organization to reach a higher level
of legal compliance is commendable”.
Evidence:
— SCO DQS ISO 14001 2015;
— 2018 DQS 3rd Party Audit Report_Sasol Secunda Chemicals
Operations.
None.
3.10 The holder of this Environmental Authorisation is
responsible for compliance with the provisions for Duty of
Care and Remediation of Environmental Damage contained
in Section 28 of the National Environmental Management
N/A Noted. 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.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Act, 1998 (Act 107 of 1998).
APPEAL OF AUTHORISATION
3.11 The holder of the Environmental Authorisation must notify
every registered interested and affected party, in writing and
within 12 days, of receiving notice of the Department`s
decision to authorize the activity.
N/A This condition is considered outside of the audit period. The EA
was granted in 2013, therefore notice of the grant of the EA within
12 days would also fall outside of the audit period.
None.
3.12 The notification referred to above must-
a) Specify the date on which the authorisation was issued;
b) Inform the interested and affected parties of the appeal
procedure provided for in Chapter 7 of the regulations; and
c) Advise the interested and affected parties that a copy of
the authorisation and reasons for the decision will be
furnished on request."
N/A This condition is considered outside of the audit period. The EA
was granted in 2013, therefore notice of the grant of the EA within
12 days would also fall outside of the audit period.
None.
MANAGEMENT AND MONITORING OF ACTIVITY
3.13 The Environmental Management Programme (EMPr)
incorporated in the Basic Assessment Report is hereby
approved.
N/A Noted. None.
3.14 The holder of the Environmental Authorisation must submit
a post-construction environmental audit report to the
Department within 30 (thirty) days after completion of
construction activity. The audit report must be compiled by
an independent auditor.
NC Sasol have not provided the auditor with evidence that a post-
construction audit was submitted to the Department.
A HSE Close out report was provided to the auditor, however this
does not discuss environmental aspects, and no evidence of
provision to the Department was provided.
This condition cannot be
rectified, unless such proof
of the audit can be provided.
3.15 This Department retains the right to monitor and/or inspect
the proposed project during both construction and operational
phases.
N/A Noted. Sasol has advised the auditor that the Department comes to
site regularly to monitor operational activities.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
COMMISSIONING AND OPERATION OF THE ACTIVITY
3.16 Fourteen (14) days written notice must be given to the
Department that the activity will commence. Commencement
for the purposes of this condition includes site preparation.
The notice must include a date on which it is anticipated that
the activity will commence.
NC Although the contractor provided notification to the Department of
Labour, there is no evidence that the Provincial Department of
Agriculture, Rural Development, Land and Environmental Affairs
(DARDLEA) formally known as the Department of Economic
Development, Environment and Tourism, was ever notified of the
commencement of construction activities onsite.
This condition cannot be
rectified, unless such proof
of notification can be
provided.
3.17 The conditions stipulated in this Environmental
Authorisation, and the approved Environmental Management
Programme are legally binding components of any contract
and are therefore legally enforceable.
N/A Noted. Sasol have advised the auditor that they are aware of this
condition.
None.
3.18 All hazardous materials must be stored in designated, lined
and bunded areas. C During the site walkover, the auditor observed that all hazardous
materials are stored within tanks. The tanks are located within
bunded and hardsurfaced areas.
None.
3.19 The bund area must have sufficient space for containment of
spillages. C The bund walls have been designed to with the capacity to contain
110% of the volume of the largest tank. This was verified during
the site walkover and through the Bund Wall Philosophy provided
to the auditor by Sasol.
Evidence:
— 3.19_EA_C3_Bund Wall Philosophy_61424R-010-DW-1452-
001-1.
None.
3.2 Should spillages occur due to any reason, clean-up of the
spillages must be undertaken as soon as possible. C Spill kits were observed across the facility. All spills are dealt with
in accordance with the Sasol Environmental Emergency Procedure
(SGR-SHE-000023 REV6).
Evidence:
— Sasol Environmental Emergency Procedure (SGR-SHE-
000023 REV6).
None.
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3.21 Appropriate measures must be taken to prevent and manage
soil erosion during and after construction. N/A As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, there is
no evidence to indicate that this occurred during the construction
phase. However, due to the nature of the project and that it was
undertaken within the existing plant with no soil disturbance, soil
erosion is deemed unlikely.
None.
3.22 The construction camp must be established on an area that
has previously been disturbed. C As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, there is
no evidence to indicate that this occurred during the construction
phase. However, Sasol have verbally advised that the construction
camp was located within the existing operational area between the
truck entrance and the management building (i.e. a disturbed area).
None.
3.23 Mixing of cement and hazardous substances must take place
on impermeable surfaces. N/A Sasol has advised the auditor that no cement mixing was
undertaken onsite. Ready mixed cement was brought in via truck.
None.
3.24 All comments and complaints received from the public
during the construction and operational phases of the activity
must be attended to as soon as possible and addressed to the
satisfaction of all concerned.
C Sasol advised the auditor that 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 at the Environmental department. Complaints are
investigated and reported in line with the Sasol Environmental
Complaints Procedure (SGR-SHE-000022 REV5) and as per legal
requirements.
Environmental complaints contact details are communicated to
internal and external stakeholders.
The auditor was provided with the complaints register and relevant
complaints procedure. No complaints had been lodged against the
C3 Expansion project. It is noted that the complaints register has
been compiled in accordance with the procedure, which ensures
that feedback is provided and proof of the feedback being issued.
Evidence:
— Environmental complaints procedure_SGR-SHE-
000022_Rev05_2019-01;
None.
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— Environmental Complaints Register_2019-02-18.
3.25 Appropriate notification signs must be erected warning the
public of the dangers around the construction site. N/A Due to the location of the site within the existing Polypropylene
Operational area, public access is restricted.
None.
3.26 All waste generated during construction must be stored,
handled and disposed of at a registered waste disposal site. C As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, there is
no evidence to indicate that this occurred during the construction
phase.
However, Sasol have advised the auditor that waste during the
construction phase would have been handled in accordance with
the Sasol Waste Management Procedure. General waste would
have been disposed of at the Sasol waste management facility,
located at Charlie 1, and metal waste would be managed through
the Sasol Redundant Materials Management (RMM). The auditor is
satisfied that this is sufficient to make this condition compliant.
None.
3.27 It is the responsibility of the holder of the Environmental
Authorisation to rectify any source of pollution from their
undertaking and to take appropriate measures to prevent any
pollution of surface as well as ground water.
C Ground water monitoring is conducted biannually and quarterly.
There is no groundwater monitoring specific to the C3 Expansion
Project, however there are six active boreholes located within the
Primary area which are utilised for monitoring. The auditor noted a
number of exceedances in the November 2017 sampling run,
however these exceedances cannot be directly attributed to the C3
Expansion Project.
None.
3.28 Dust, noise, and odour control mechanisms must be
implemented at all times to prevent health risk to the workers
and the surrounding communities.
C Due to the nature of the operations, dust emissions are not deemed
applicable.
In terms of noise, Sasol undertake regular noise surveys and have
signage indicating where noise protection must be worn. All staff
undergo annual medicals which assesses hearing.
A noise zoning survey was undertaken for PP1 and PP2 in 2017.
The report, dated 23 January 2018, it was noted that only the
maximum hearing protection (i.e. 3M Peltor OptimeTM ear muffs)
is suitable to provide adequate protection against noise levels
encountered in all areas of the PP2 plant. Sasol advised that all
None.
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employees are provided with this hearing protection.
Sasol undertake monthly stack monitoring. Odour is not anticipated
to issue at the plant as the entire system is a closed loop system.
Evidence:
— SEC-042-2018-GIJ (NOISE)_
(Polymers,_Propylene_Production,_PP2)
Signage indicating required PPE (including hearing
protection)
3.29 Suitable fire protection systems must be accessible on site
when urgently required to deal with an emergency situation.
[Equipment] such as fire detection and firefighting systems
must be accessible to workers on site.
C The site comprises a number of fire hydrants and hoses located
across the plant. In addition, all tanks are fitted with a fire deluge
system.
Evidence:
None.
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Examples of the firefighting equipment located across
the plant.
SITE CLOSURE AND DECOMMISSIONING
3.30 In case of decommissioning, a detailed Rehabilitation Plan
must be submitted to this Department for approval at least six
(6) months prior to the decommissioning phase.
N/A Noted. Sasol advised the auditor that there are no plans to make
this site redundant in the foreseeable future.
None.
GENERAL
3.31 A copy of this Environmental Authorisation must be kept at
the property where the activity will be undertaken. The
Environmental Authorisation must be produced to any
C Copies of all authorisations 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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authorized official of the Department who requests to see it
and must be made available for inspection by any employee
or agent of the holder of the Environmental Authorisation
who works or undertakes to work at the property.
and on SAP EC and SharePoint. Sasol Provided the auditor with
the evidence that the responsible persons Eric Munyangane and
Francois du Toit, were made aware of the EA in September 2016.
Evidence:
— EA_EX Handover_SCO_Poly_Nitro_Poly
3.32 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 Sasol provided the Department with notification of the change of
ownership from Sasol Synfuels (Pty) Ltd to Sasol South Africa
(Pty) Ltd. The Department issued the Amendment to the
Authorisation (reference number: 1/3/1/16/4 G- 39).
Evidence:
— 3.32_EA_C3Expansion_SCO_POL_Amendment_1.3.1.16.4
G-39_2017-04-28
None.
3.33 The holder of the authorisation must notify the Department,
in writing and within 24 (twenty-four) hours, if conditions of
the Environmental Authorisation are not adhered to. Any
notification in terms of this condition must be accompanied
by reasons for the non-compliance.
NC No evidence has been provided to the auditor that the Department
has been informed of the non-compliances noted associated with
this EA.
For historical non-
compliances, this condition
is considered non-
rectifiable. Going forwards,
Sasol should ensure that all
non-conformances are
reported within 24 hours.
Target completion:
Medium term
3.34 Non-compliance with a condition of this Environmental
Authorisation results in criminal prosecution or other actions
provided for in the National Environmental Management
Act, 1998 and the regulations.
N/A Noted. Sasol has advised the auditor that they are aware of this
condition.
None.
3.35 National government, provincial government, local
authorities or committees appointed in terms of the
conditions of this Environmental Authorisation or any other
public authority shall not be held responsible for any
damages or losses suffered by the applicant or his successor
N/A Noted. Sasol advised the auditor that they are aware of this
condition.
None.
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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 Environmental Authorisation as set out in
this document or any other subsequent document emanating
from these conditions of Environmental Authorisation.
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Table 3: Audit Findings – Environmental Management Plan
REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
CONSTRUCTION PHASE
1.01 Appointment of a contractor:
— EMPr must be included as part of any contractual
documentation.
NC The auditor was provided with a copy of Works Information for
Installation of C3 Administration Building Electrical and HVAC
Systems, which forms a contractual document. However, whilst the
following is stated, no specific reference to the EMPr is made: “The
Contractor complies with all the legal requirements of the Act as
well as any site specific standards, procedures and Safety, Health
and Environmental (SH&E) management rules while working on
the site”.
Additionally, a Closeout report was provided, however this is
principally a H&S document, and does not evidence contractor
appointment documents make reference to the EMPr.
Consequently, the auditor has not been provided with evidence that
the EMPr is included in contractor appointment documentation.
Evidence:
— EMP1.01_C3 Exp_SOW Installation Contract
— C3 Expansion Project Closeout Report_2016-04-22 (1)
This condition relates only
to construction phase and
consequently cannot be
rectified unless such
evidence is available.
1.02 Environmental Awareness and Safety Training:
— Contractor is expected to have safety tool box talks in
accordance with the risks and trends associated with
project. Proof of these talks shall be kept on site.
— The principal contractor will develop a specific
emergency procedure and implement an emergency plan
based on the Sasol Business Unit’s (SBU) guidelines for
that site.
C A HSE Project Closeout Report for the period 05 January 2015 –
22 April 2016, indicates that 46 Toolbox Talks were compiled by
Technip (lead contractor) and issued to Contractors.
The Project Closeout Report also indicates that each contract
submitted a 27 point HSE file to Technip for review, and to Sasol
for final approval. Baseline risk assessments, in addition to issue
based/task specific risk assessments were completed by the Lead
Contractor.
Evidence:
— C3 Expansion Project Closeout Report_2016-04-22 (1)
None.
1.03 Personal Protective Equipment (PPE): C The construction activities were undertaken within the existing
Polypropylene plant operational area. Site access is prohibited
None.
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— No person is allowed to enter the site without the SBU
approved required PPE.
— All contractors shall be trained on the correct use of
PPE. All contractors are required to keep an updated
register of all PPE issued.
— A contractor shall ensure action is taken against an
employee who continuously fails to comply.
— PPE minimum requirement notice boards shall be
placed at all entrances.
without the correct PPE, and evidence of PPE signage was
observed for the wider site.
As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, there is
no evidence to indicate that all contractors kept an updated register
of all PPE issued. However, adherence with PPE requirements are
strictly controlled at Sasol, and contractors are not permitted to
work onsite without abiding by the Sasol policies and procedures.
Furthermore, a copy of the HSE Project Closeout Report was
provided, which includes photographic images of the construction
site. Evidence of adherence with PPE requirements was
demonstrated.
Evidence:
— C3 Expansion Project Closeout Report_2016-04-22 (1)
1.04 Dust Control:
— There should be strict speed limits on site roads to
prevent liberation of dust in to the atmosphere.
— Dust must be suppressed on the construction site during
the transportation of material during dry periods by the
regular application of water.
— To avoid the generation of unnecessary dust, material
drop height should be reduced and material storage piles
should be protected from wind erosion. This can take
the form of wind breaks, water sprays or vegetation of
piles.
C The construction activities were undertaken within the existing
Polypropylene plant operational area. Speed limits within the Sasol
Secunda complex are strictly monitored and implemented onsite.
Due to the location of the construction activities and the nature of
the project, Sasol advised the auditor that no soil was disturbed
during the construction phase, consequently limiting dust
generation potential.
None.
1.05 Noise:
— Vehicles and equipment must be maintained in good
working order.
— Construction staff working in area where the 8-hour
ambient noise levels exceed 85 dBA must have the
appropriate PPE e.g. ear protection equipment.
— Where possible, stationary noisy equipment (e.g.
C As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, there is
no evidence to indicate that vehicles and equipment were
maintained in good working order during the construction phase.
However, maintenance schedules for vehicles and equipment are
routinely utilised to ensure good condition is maintained.
All personnel (including contractors) entering the Polypropylene
plant operational area are required to wear ear protection. Due to
None.
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compressors, generators etc) should be encapsulated in
acoustic covers, screens or sheds. Portable acoustic
shields should be used in the case where noisy
equipment is not stationary (e.g. drills, angle grinders,
chipping hammers).
the location of the construction activities within the Sasol Secunda
Complex, all construction staff will have been required to wear
hearing protection.
1.06 Storage and handling hazardous substances:
— The contractor must comply with all national, regional
and local legislation with regard to the storage,
transportation, use and disposal chemical, harmful and
hazardous substances and materials.
— The contractor will be responsible for the training and
education of all personnel on site on handling the
material, its proper use, and disposal as well as spill
response.
— Ascertain that the workers understand the content of the
hazardous products and the information on the MSDSs.
— MSDSs of chemicals must always be available.
— Clear signage must be placed at all storage areas
containing hazardous substances / materials.
— Any hazardous waste from the clean-up must be
disposed of at a hazardous waste site. In the event of a
spillage occurring, clean up must be done immediately
to prevent widespread pollution.
— Ensure that functioning spill kits are available onsite to
clean-up spills and leaks.
— Lubricants, chemicals and other hazardous substances
must be stored in a designated area that is well
ventilated, with an impervious surface, bunded, covered
and able to contain 110% of the total volume of
materials stored at any given time.
— Refuelling of machinery must be done using a drip tray
and vehicle refuelling must only be done at the
designated area.
— Ensure that only designated areas are used for the
storage and handling of construction materials and fuels.
C As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, verifying
these construction phase conditions retrospectively is challenging.
Sasol provided the auditor with a selection of MSDS for the
chemicals being stored onsite during the site walkover. Signage
relevant to the storage of hazardous materials was observed during
the site walkover.
Access to the area is strictly controlled, and firefighting equipment
was observed.
The HSE Project Closeout Report states that 46 Toolbox talks were
compiled by Technip and issued to contractors, 54 audits on
contractors were completed by Technip, and 48 site management
walks (Sasol) were completed.
The final Basic Assessment Report for the Expansion Project
indicates that all hazardous substances must be stored on an
impervious surface in a designated bunded area, able to contain
110% of the total volume of materials stored at any given time; and
the integrity of the impervious surface and bunded area must be
inspected regularly and any maintenance work conducted must be
recorded in a maintenance report. The BAR further states that
employees and contractors must be trained on the correct handling
of spillages and precautionary measures that need to be
implemented to minimise potential spillages; and employees should
be provided with absorbent spill kits and disposal containers to
handle spillages.
Evidence:
— C3 Expansion Project Closeout Report_2016-04-22 (1)
— Sasol C3 Expansion-Final BAR plus App_red
None.
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— Equipment and vehicles should be regularly inspected in
order to detect leaks as early as possible.
— All diesel generators will be equipped with drip trays
and the contractor should ensure that the generators are
in good working condition.
— Access must be strictly controlled and only authorised
persons may enter.
— Fire fighting equipment must be present at all storage
facilities.
Example of safety signage onsite.
1.07 Waste management:
— General waste disposal bins will be made available for
employees to use throughout construction phase and
littering should not be allowed.
— Waste will be temporarily stored onsite (less than 90
days) before being disposed of at an appropriately.
— General waste e.g. packaging material and spent
welding rods will be disposed of at an approved facility.
— Records of all waste being taken offsite must be kept as
evidence.
— Burning waste will not be permitted.
— Hazardous materials will be generated if there are
spillages during construction and maintenance periods.
This waste should be cleaned up using absorbent
C As there was no requirement for an Environmental Control Officer
(ECO) to undertake monitoring of construction activities, verifying
these construction phase conditions retrospectively is challenging.
Sasol have advised the auditor that all general waste was disposed
of at Sasol’s Waste Management Facility at Charlie 1. Metal waste
was managed through the Sasol Redundant Materials Management
(RMM). Sasol have provided proof that steel was collected from
the Sasol RMM during the construction period.
Waste management is completed via implementation of a Waste
Management procedure that addresses the approach to manage
waste in line with the internationally accepted waste hierarchy,
whereby disposal to land is considered the last management option
to undertake once avoidance, re-use, recycling, recovery and
treatment options have been considered / eliminated. The
procedure further details waste disposal and management through
None.
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material provided in spill kits onsite.
— Absorbent materials used to clean up spillages should be
disposed of in a separate hazardous waste bin.
— Hazardous waste generated e.g. mixed concrete, paint
cans and brushes, contaminated soil must be disposed of
at a licensed hazardous waste disposal site. Records of
waste disposed of must be kept.
— The storage area for hazardous waste material must be
concreted, bunded, covered, labelled and well
ventilated.
— Provide employees with appropriate PPE for handling
hazardous materials.
— All hazardous waste will be disposed of in a registered
hazardous waste disposal facility.
— The construction staff handling chemicals of hazardous
materials must be trained in the use of the substances
and the environmental, health and safety consequences
of incidents.
— The contractor must design, test/exercise appropriate
emergency preparedness programmes (plans, schedules,
procedures and methods) for addressing environmental
accidents, incidents, and events such as spills of fuel,
lubricants; fires etc.
characterization and classification that is detailed in site specific
waste registers.
General waste disposal bins across the Sasol site were observed by
the auditor, and no notable volume of litter was observed during the
site walkover.
Evidence:
— 3.26_EA_C3_Steel disposal certificates;
— PP1_PP2 Final Waste Register_2016-05-16.
— PP1_PP2 Final Waste Register_2016-10-21.
1.08 Employment:
— All labour (skilled and unskilled) and contractors should
be sourced locally where possible recruitment.
— Recruitment at the construction site will not be allowed.
C Sasol has advised the auditor that they have implement a Supplier
Industrial Relations Procedure (SIRP) that aims to provide the
greatest degree of uniformity, consistency and to standardisation of
procedures and practices pertaining to security / site access and
Industrial Relations matters to all Suppliers, their Agents, Sub-
contractors and Labour brokers/TES. Suppliers are required to
ensure that the SIRP, its procedures and practices are
communicated, understood, observed and followed by them and all
their constituents at all times. Non-compliance with the procedure
may result in the termination of the commercial agreement between
the parties.
Evidence:
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— Labour_Sasol IRM Suppliers Industrial Relations Procedure
1.09 Traffic:
— Routes for the passage of vehicles and machinery must
be agreed by the project team to ensure minimal
disruption to daily plant activities.
C Sasol have confirmed that contractors involved with construction
had specific laydown areas and used entrances into the facility as
directed by Sasol. This formed part of the induction process. No
specific route plan is available as the interruption to normal plant
activities was minimal.
None.
PRE COMMISSIONING
2.01 Storage and handling hazardous substances:
— An inventory of all chemicals onsite must be kept.
MSDSs must always be available.
— Access to the store must be controlled and flammable
and inflammable materials should be kept separately.
— Ascertain that the workers understand the content of the
products and the information on the MSDSs.
— All chemicals will be kept in a properly bunded area
with access control.
— Emergency plan and procedures must be put in place.
— Ensure that used chemicals are disposed of at a
permitted hazardous waste disposal site.
C Sasol provided the auditor with a selection of MSDS for the
chemicals being stored onsite during the site walkover. The entire
site is access controlled, and the chemicals being stored are located
within tanks. The tanks are bunded and located on hardsurfacing.
All chemical waste produced at the C3 expansion plant is sent
elsewhere on the site for processing or recovery.
The final Basic Assessment Report (BAR) for the Expansion
Project indicates that all hazardous substances must be stored on an
impervious surface in a designated bunded area, able to contain
110% of the total volume of materials stored at any given time; and
the integrity of the impervious surface and bunded area must be
inspected regularly and any maintenance work conducted must be
recorded in a maintenance report. The BAR further states that
employees and contractors must be trained on the correct handling
of spillages and precautionary measures that need to be
implemented to minimise potential spillages; and employees should
be provided with absorbent spill kits and disposal containers to
handle spillages.
Emergency plans and procedures are in place.
Evidence:
— C3 Expansion Project Closeout Report_2016-04-22 (1)
— Sasol C3 Expansion-Final BAR plus App_red
— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017-
OFI:
The Sasol Polymers Area
Emergency Procedure dates
from 2012, i.e. prior to the
completion of the C3
Expansion Project and
should be updated to ensure
suitability.
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2022 Rev_0;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— Sasol Environmental Emergency Procedure (SGR-SHE-
000023 REV6);
— 3.29_EA_C3Expansion_PolymersEmergManProcedure (1).
2.02 Waste water (effluent handling):
— Contaminated water should be directed into the correct
disposal system and none should go into the stormwater
management system.
— Waste water must not be allowed to come into direct
contact with exposed soils or run across the plant site.
— Vehicles and machinery may not be washed onsite. All
waste water must be collected and disposed of in a
correct and environmentally suitable manner.
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 IWWMP has a detailed description of stormwater management
within the Polymers Plants. The auditor was able to confirm that
the description of the management of contaminated run-off is
implemented onsite. According to the IWWMP “At the Polymers
site there is a prominent segregation of clean and contaminated
storm water runoff. Operational areas where there is the potential
for spillages of chemicals or oil are bunded, and runoff from these
areas drains into the Polymers API dam. The water from the
Polymers API dam is transferred to the Synfuels API East system.
The storm water runoff from the remaining areas drains in a
northerly direction primarily to the Check basin or the Pellet
Separator basin. Any fire water utilised onsite will also report to
the Check Basin.”
Stormwater Management is managed as site-wide within the
Secunda complex, rather than being plant specific.
All operational areas of the Polymers Plant area is hardsurfaced,
restricting the likelihood of wastewater coming into direct contact
with exposed soils.
No vehicle washing occurs in the Polymers Plant.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— SIC IWWMP Appendix 1- Polymers 2017 Rev 2
An example of a Stormwater drain on the Polypropylene site.
The pellet separator.
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The Check Basin and Polymers API dam.
2.03 Venting of equipment:
— Venting of equipment must be minimized to prevent the
risk of fire, air and noise pollution.
— Venting activities should comply with Sasol standards
and should be conducted by properly trained personnel.
C Sasol advised the auditor that venting is carried out at the plant, but
that it is minimised as required. It was confirmed that all venting is
completed in accordance with the Sasol Venting Standard.
None.
OPERATIONS AND MAINTENANCE
3.01 Cleaning of equipment:
— Chemical will be disposed of correctly at a permitted
site.
— Contamination water should be routed to the correct
drainage system according to the water management
procedure.
— Cleaning of equipment should be done in a designated
bunded area to prevent eventual soil and water
pollution.
C The auditor was advised that chemical wastewater from the
cleaning of equipment is discharged into the oily water sump,
where it goes to the Polymers API dam.
Chemical disposal is carried out in accordance with Sasol’s Waste
Management procedure that addresses the approach to manage
waste in line with the internationally accepted waste hierarchy,
whereby disposal to land is considered the last management option
to undertake once avoidance, re-use, recycling, recovery and
treatment options have been considered / eliminated. The
procedure further details waste disposal and management through
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— The chemicals used for cleaning must be disposed of
correctly. MSDS of the chemicals should always be
available.
characterization and classification that is detailed in site specific
waste registers.
Evidence:
— PP1_PP2 Final Waste Register_2016-05-16;
— PP1_PP2 Final Waste Register_2016-10-21.
3.02 Water/effluent handling (routing of fire water, management
of contaminated and uncontaminated storm water):
— Correct disposal of effluent must be ensured.
— Any spill should be cleaned up immediately and
disposed off at a designated site.
— Ensure uncontaminated and contaminated storm water
are channelled into the correct system.
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 IWWMP has a detailed description of stormwater management
within the Polymers Plants. The auditor was able to confirm that
the description of the management of contaminated run-off is
implemented onsite. According to the IWWMP “At the Polymers
site there is a prominent segregation of clean and contaminated
storm water runoff. Operational areas where there is the potential
for spillages of chemicals or oil are bunded, and runoff from these
areas drains into the Polymers API dam. The water from the
Polymers API dam is transferred to the Synfuels API East system.
The storm water runoff from the remaining areas drains in a
northerly direction primarily to the Check basin or the Pellet
Separator basin. Any fire water utilised onsite will also report to
the Check Basin.”
Stormwater Management is managed as site-wide within the
Secunda complex, rather than being plant specific.
According to the Sasol IWWMP, any fire water utilised onsite will
report to the Check Basin. This was confirmed with Sasol by the
auditor during the site walkover.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1- Polymers 2017 Rev 2.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
3.03 Waste management - i.e. hazardous and general wastes
generated during operational and maintenance activities e.g.
servicing of old equipment:
— Equipment that has the potential for spillages or
leakages shall be equipped with drip-trays.
— Care should be taken to ensure that spillages of oils and
effluent are limited during maintenance. In the event of
a spill/leak, the source of the spill or leak must be
identified and stopped.
— The oil/effluent must be cleaned immediately and any
contaminated soil must be removed and disposed of
through a recognised waste disposal method.
— Hazardous waste must be stored in a covered well
labelled, ventilated area which is also bunded.
— Hazardous and general waste must be disposed of at a
licensed hazardous waste disposal facility.
— Evidence of correct disposal of waste must be retained.
— Uncontaminated equipment can be taken to a recycling
facility, e.g. metal.
C The site generates very little hazardous waste. No spent catalyst is
generated in the manufacturing process, as the catalyst is
incorporated into the final product. Any expired additives are
stored on site in skips and removed to the Holfontein Hazardous
landfill site. Off-spec product is sent back to the feed tank and
reworked to meet the quality specification. Waste storage practices
observed by the auditor were noted to be adequate.
Sasol advised the auditor that waste management is handled
through implementation of a Waste Management Procedure that
addresses the approach to manage waste in line with the
internationally accepted waste hierarchy, whereby disposal to land
is considered the last management option to undertake once
avoidance, re-use, recycling, recovery and treatment options have
been considered / eliminated. The procedure further details waste
disposal and management through characterisation and
classification that is detailed in site specific waste registers.
General waste produced at the plant is disposed of at the Sasol
Waste Management Facility, located at Charlie 1. Scrap metals and
redundant materials are sent to the Sasol Redundant Materials
Management.
Evidence:
— Sasol Secunda Industrial Complex, Mpumalanga IWMP 2017-
2022 Rev_0;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— SAS-490- Final PP1 and PP2.xlsx;
— PP1_PP2 Final Waste Register_2016-05-16;
— PP1_PP2 Final Waste Register_2016-10-21.
None.
3.04 Health and Safety:
— All personnel must be well trained to work in the PP
plants.
— Strict access rules should be applied to personnel
entering the PP plant.
C Site access is strictly controlled at the entrance to the Polymers
Unit. All unauthorised personnel must report to security and sign
in. Access to site without the correct PPE is prohibited across the
Sasol site. PPE requirements are indicated at the entrance to
operational areas. Sasol have a site wide spill procedure which was
provided to the auditor.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
— All operators should wear appropriate PPE.
— Procedures must be put in place for clean up and
incidents to be reported.
— Appropriate signage (e.g. no smoking) should be clearly
displayed in the PP plant.
— The PP plants should be regularly maintained as
required to ensure that all the fittings and equipment are
in good working condition.
During routine shut down (annual) any maintenance and/ or
cleaning that is required is carried out.
Evidence:
— Environment emergency procedure_SGR-
SHE000023_rev6_2015-11
— Response Env Emergency Incidents_SGR-SHE-000023(under
review)_2018-10-08
Example of safety signage onsite.
3.05 Storage, loading and off-loading of catalysts:
— Procedures to be in place to prevent spillages / clean-up.
Procedures to be followed and incidents to be reported.
C Sasol provided the auditor with the procedures for the following,
which includes spillage and clean-up:
— Environmental Emergencies;
— IWWMP;
— Catalyst, co-catalyst and modifier neutralization; and,
— Decommission catalyst system for maintenance.
OFI:
The Sasol Polymers Area
Emergency Procedure dates
from 2012, i.e. prior to the
completion of the C3
Expansion Project and
should be updated to ensure
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Evidence:
— Environment emergency procedure_SGR-
SHE000023_rev6_2015-11
— Decommission catalyst system for maintenance V1;
— Catalyst, Co-Catalyst and Modifier Neutralization and
draining;
— Environmental incident procedure Process flow
— SIC IWWMP Appendix 1 - Polymers 2017 Rev 2
suitability.
3.06 Noise production:
— Personal working in the PP plants must have the
appropriate PPE since ambient noise levels usually
exceed 85 dBA.
C The auditor observed onsite that all personnel entering the PP
operational areas must have hearing protection. Signage has been
erected across the operational areas indicating the use of hearing
protection. Any person not wearing the correct PPE is prohibited
from entering the PP plant.
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
Safety signage indicating the use of hearing protection.
3.07 Effluent handling as a results of cleaning vessels and
draining of vessels during shutdowns:
— Correct disposal of effluent must be ensured.
— All workers should be trained on the correct cleaning
procedures and draining methods.
— All workers should wear appropriate PPE.
— Equipment must be designed and managed properly in
accordance with Sasol standards and specifications.
— Appropriate measures should be taken to avoid
spillages.
C According to the IWWMP chemicals used for the cleaning of
equipment is discharged into the oily water sump, where it goes to
the Polymers API dam. The auditor confirmed this during the site
walkover.
The auditor observed onsite that all personnel entering the PP
operational areas must have hearing protection. Signage has been
erected across the operational areas indicating the use of hearing
protection. Any person not wearing the correct PPE is prohibited
from entering the PP plant.
The final Basic Assessment Report (BAR) for the Expansion
Project indicates that employees and contractors must be trained on
the correct handling of spillages and precautionary measures that
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
need to be implemented to minimise potential spillages; and
employees should be provided with absorbent spill kits and
disposal containers to handle spillages.
The auditor was also provided with the PP2 training matrix; and
SOPs for decommissioning the catalyst system for maintenance,
and catalyst, co-catalyst and modifier neutralization. These
documents evidence the presence of procedural control over
training and awareness.
Evidence:
— IWWMP SIC 2015 Final_2018-05-15;
— SIC IWWMP Appendix 1- Polymers 2017 Rev 2;
— PP2 Production Matrix -New 1;
— Decommission catalyst system for maintenance V1;
— Catalyst, Co-Catalyst and Modifier Neutralization and
draining; and,
— Sasol C3 Expansion-Final BAR plus App_red.
3.08 Management of catalysts during shutdowns:
— Ensure that disposal procedure are in place and that
disposal take place at permitted sites.
C Any expired additives are stored on site in skips and removed to the
Holfontein Hazardous landfill site. The auditor was provided with
the Waste Register for the expired additives. The auditor is
satisfied that the Holfontein Hazardous Waste Landfill site is
appropriately licenced to accept and dispose of this hazardous
waste type.
Evidence:
— SIC IWWMP Appendix 1- Polymers 2017 Rev 2;
— Waste Management Procedure_SGR-SHE-
000017_Rev10_2017-09;
— SAS-490- Final PP1 and PP2.xlsx.
None.
DECOMMISSIONING PHASE
4.01 Waste generation during the decommissioning phase will
have a negative impact on the environment, if not controlled N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
None.
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REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION
adequately waste includes general waste or hazardous waste. decommission the plant.
4.02 Removal of equipment N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
None.
4.03 Erosion control N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
None.
4.04 Dust Control N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
None.
4.05 Noise control N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
None.
4.06 Safety on site N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
None.
4.07 Contamination of surface and groundwater due to spillage
leakage, incorrect storage and handling of chemicals, oil,
lubricants, cement, fuels and other hazardous materials.
N/A Noted. Sasol has advised the auditor that they are aware of this
condition however, there are no plans in the foreseeable future to
decommission the plant.
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 10 4 0 6
APPEAL OF AUTHORISATION 2 0 0 2
MANAGEMENT AND MONITORING OF ACTIVITY 3 0 1 2
COMMISSIONING AND OPERATING OF THE ACTIVITY 14 9 1 4
SITE CLOSURE AND DECOMMISSIONING 1 0 0 1
GENERAL 5 2 1 2
Total Count 35 15 3 17
Total Percentage 43% 9% 49%
Percentage Compliance with Applicable Conditions 83%
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Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents
the total proportion of compliance for the facility.
Figure 2: Number/Count contribution of findings made to the EA conditions per Section
Figure 3: Overall count findings on compliance to the EA conditions
0
2
4
6
8
10
12
14
16
Sectional Count Contribution
C
NC
N/A
15
3
17
Total Compliance
C
NC
N/A
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Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total
percentage compliance for the facility.
Figure 4: Percentage contribution of findings made to the EA conditions per Section
Figure 5: Overall percentage findings on compliance to the EA conditions
0102030405060708090
100
Sectional Percentage Contribution
C
NC
N/A
43%
9%
49%
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 9 8 1 0
PRE COMMISSIONING 3 3 0 0
OPERATIONS AND MAINTENANCE 8 8 0 0
DECOMMISSIONING PHASE 7 0 0 7
Total Count 27 19 1 7
Total Percentage 70% 4% 26%
Percentage Compliance with Applicable Conditions 95%
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Figure 6 illustrates the number/count contribution of the findings of the EMPr per section while Figure 7
presents the total proportion of compliance for the facility.
Figure 6: Number/Count contribution of findings made to the EMPr conditions per Section
Figure 7: Overall count findings on compliance to the EMPr conditions
0123456789
10
Construction Phase Pre Commissioning Operations andMaintenance
DecommissioningPhase
Sectional Count Contribution
C
NC
N/A
19
1
7
Total Compliance
C
NC
N/A
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Figure 8 illustrates the percentage contribution of the findings of the EMPr conditions. Figure 9 presents the
total percentage compliance for the facility.
Figure 8: Percentage contribution of findings made to the EMPr conditions per Section
Figure 9: Overall percentage findings on compliance to the EMPr conditions
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;
0102030405060708090
100
Construction Phase Pre Commissioning Operations andMaintenance
DecommissioningPhase
Sectional Percentage Contribution
C
NC
N/A
70%
4%
26%
Total Percentage Compliance
C
NC
N/A
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— 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 will be no longer
applicable going forwards, as these mostly 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 GS-172)