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SECUNDA SYNFUELS OPERATIONS: POWERSTATION - WATER PRODUCTION

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.10 EV 1 - IMPLEMENTATION OF THE RAND WATER AUGMENTATION PROJECT

13 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT

17.2.10 EV 1 - IMPLEMENTATION OF THE RAND WATER AUGMENTATION PROJECT

SECUNDA SYNFUELS OPERATIONS:

POWERSTATION - WATER PRODUCTION

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: 17.2.10 EV

1

Final – Compliance

Audit

EA Ref: 17.2.10 EV 1

Date April 2019 June 2019

Prepared by Mpendulo Dlamini Mpendulo Dlamini

Signature

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 020 020

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

Mpendulo Dlamini

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 Exemption Authorisation.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

PowerStation - Water Production

Production Senior Manager

Tjaart Kruger

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Mpendulo Dlamini

ENVIRONMENTAL AUTHORISATION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: POWERSTATION - WATER PRODUCTION

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Implementation of the Rand Water Augmentation

Project – 17.2.10 EV 1 ............................................. 1

2 AUDIT SCOPE ........................................... 4

3 AUDIT METHODOLOGY ........................... 5

3.1 Audit Checklist ........................................................ 5

3.2 Site Inspection ......................................................... 5

3.3 Documentation Considered ................................... 5

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

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

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

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

5 SUMMARY OF THE AUDIT FINDINGS ... 12

5.1 Environmental Exemption .................................... 12


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TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 8

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 12

FIGURES

FIGURE 1: THE RAND WATER AUGMENTATION PIPELINE ENTRY POINT (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: THE RAND WATER AUGMENTATION PIPELINE ROUTE (SOURCE: SASOL, 2018) .............................................. 3

FIGURE 3: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 13

FIGURE 4: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 13

FIGURE 5: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 14

FIGURE 6: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 14

APPENDICES

A ENVIRONMENTAL EXEMPTION (17.2.10 EV 1)


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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 Exemption (Reference number: 17.2.10 EV 1 issued on 25 August 2004) for the period December

2014 to February 2019.

1.2 IMPLEMENTATION OF THE RAND WATER

AUGMENTATION PROJECT – 17.2.10 EV 1

An environmental exemption was granted by the Mpumalanga Department of Environmental Affairs and Tourism,

for the construction and operation of an emergency pipeline from Rand Water reservoirs to the Sasol Synfuels

plant.

Figure 1 and Figure 2 provides the route of the pipeline from the Rand Water Reservoirs to Sasol Secunda.

The underground pipeline was constructed from the Wildebeestfontein reservoirs in Kinross outside Secunda to

the Sasol Synfuels plant. This pipeline was constructed to augment Sasol’s water supply, which was depleted due

to the low water levels at its abstraction points. The pipeline was then constructed to feed Unit 534, Unit 518, Unit

505, in addition to Train 16 and Train 17. The facilities utilise the water for cooling purposes.

Presently, the pipeline does not provide a continuous supply of water, but is only used to augment the supply

during emergencies when the three onsite reservoirs are running low.


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Figure 1: The Rand Water Augmentation pipeline entry point (Source: Google Earth, 2018)


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Figure 2: The Rand Water Augmentation pipeline route (Source: Sasol, 2018)

DRIEFONTEIN 137IS

WINKELHAAK 135IS

GOEDEHOOP 290IS

TWEEDRAAI 139IS

MIDDELBULT 284IS

HOLFONTEIN 138IS

TWISTDRAAI 285IS

WILDEBEESTFONTEIN 122IS

GOEDEHOOP 533IS

KOEKOEK 140LS

UITKYK 136IS

LANGVERWACHT 282IS

R

4

R

8

3

1

2

2

7

R 6

9

17

15

3

14

3

7

6

4

7

R

2

5

11

4

64

19

13

20

10

18

20

12

8

9

14

22

23

21

3

11

12

13

5

2

12

14

15 19

1

10

4

248

57

4

7 RESERVOIRS

RESERVOIRS

SASOLKRAAL 289IS

Produced by:

SMRD

PO BOX 699

TRICHARDT

2300

TEL NR. 017 638 0780

FAX NR. 017 638 0595

200 4/ 02/ 27

LEGEN D

Prop osed P ipelin e R oute

Scale 1:50 000

Farm Bou ndry

Farm Portions

Proposed Wa te r Pip eline

N13.5 KM

Proposed Pipeline Route - Water Reservoirs to Sasol Synfuels


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Page 4

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

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

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

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

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

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

The objective of the audit was to:

— Assess the level of compliance with the conditions of the Exemption;

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

— Make recommendations in order to achieve compliance in terms of the Exemption; and,

— Ensure the commitments contained in Condition 7.01 of the Exemption are completed, more specifically:

— “Records relating to the compliance or non-compliance with the conditions of this Exemption must be

kept in good order. Such records must be made available to this Department within seven (07) working

days from the date of a written request for such records by the Department.”


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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents

were utilised as a template during the compliance audit process. This methodology ensures that the compliance

audit was conducted in a systematic and independent manner that was documented and objectively evaluated to

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (26 March 2019);

— Review of documentation relevant to the conditions of the Environmental Exemption (e.g. records,

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

WSP compiled an audit checklist to assist with the Exemption compliance audit (Section 4).

3.2 SITE INSPECTION

Mpendulo Dlamini conducted the site inspection on 26 March 2019. The findings and observations of the site visit

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

— Lucky Nchabeleng - Area Manager Production

— Broni van der Meer - SHE: Environmental Compliance Specialist

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— SSO DQS ISO 14001 2015;

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

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

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the Exemption.

Each condition was verified, either by reviewing documentation, interviewing employees and/or visually

inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with

associated target completion dates included.

It should be noted that some of the Exemption conditions were apportioned according to the elements requiring

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

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

during percentage compliance calculation). This apportionment further allowed for the development of focussed

recommendations and timeframes.


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Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

to the requirements of the Exemption. Non-complaint conditions are given target completion

dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Consultant, Mpendulo Dlamini, was hosted by Rofhiwa Mudau and Broni van der Meer 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: Mpendulo Dlamini

Mpendulo has 5 years’ experience and is a multi-disciplined individual who completed his double major BSc

Environmental Science degree (Life Science and Environmental Science) at the University of KwaZulu-Natal

in 2014. He then further completed his BSc Honours Environmental Science (Spatial Epidemiology Research)

in 2015 at the same institution. Mpendulo has had exposure in the following sectors; oil and gas,

environmental consulting as well as environmental and public health. As a University Student, he has had

extensive training in biodiversity management and monitoring with a focus in plant science (undergraduate),

and with Lakes Environment air quality and modelling software as well as environmental GIS and remote

sensing in spatial modelling (Post graduate). He also has experience as an Environmental Control Officer as

well as with working on Water Use Licence Applications and Integrated Water and Waste Management Plans

(Triplo4 Sustainable Solutions).

— 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.


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3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

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

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

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

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

document.

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

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

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

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

separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This exemption refers only to the project as specified above

and described in the Record of Decision. Separate

application/s must be lodged for any other development and

/or activity at or near the proposed site, which is covered by

section 21 and 22 of the Act and Government Notice R1182

and R1183 of 5 September 1997.

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

the Exemption was granted. No additions or alterations have taken

place on or near the project’s location.

Sasol is aware of the requirement to lodge separate applications

should further works be required for the authorised activity.

None.

1.02 Exemption is only granted in terms of Section 28 (A) of the

Act, and does not exempt the holder from compliance with

any other relevant legislation.

N/A Noted. A full legal review does not form part of the scope of this

audit.

The Sasol Complex operates with a dedicated environmental and

legal teams, and therefore ensures that they comply with applicable

legislation.

In addition, site is operated under ISO14001:2015, which requires

the compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which specifically

states “the development of the compliance risk management

protocol (CRMP) to assist the organization to reach a higher level

of legal compliance is commendable”.

Evidence:

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels

Operations.

None.


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1.03 No development may take place on the area of concern

without the necessary permits/approvals and/or service

agreements, from other relevant authorities.

N/A The pipeline has been constructed, therefore, this condition is

considered outside of the audit period (construction pre-2014). It is

therefore considered not applicable.

Furthermore, according to the Area Manager, no new developments

or upgrades have been made along the pipeline route.

None.

1.04 Copies of relevant permits, approvals and/or service

agreements must be in possession of this Department before

any construction work commences.

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

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

None.

1.05 This Department may change, add to and/or amend any of the

conditions in this exemption if, in the opinion of the

Department, it is environmentally justified.

N/A

No changes or amendments have been communicated to Sasol by

the Department since issue of the Exemption.

None.

2. ESTABLISHMENT OF THE DEVELOPMENT

2.01 This exemption is repealed if the proposed project has not

taken place within one (1) year from the date of this

exemption.



None.

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

Department before any construction activities commence. N/A This condition is considered outside of the audit period


None.

3. CONSTRUCTION AND OPERATION

3.01 If any changes need to be made to the site and/or associated

infrastructure, this Department must be informed at least

thirty (30) days in advance, to be able to decide whether the

changes will need authorization or not.

N/A According to the Area Manager, no new developments or upgrades

have been made along the pipeline route

None.


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3.02 Good environmental practice must be carried out as an

integral aspect of the project implementation. N/A The project has already been implemented and is now in operational

phase. This condition is considered outside of the audit period


None.

4. WASTE

4.01 All waste generated during construction shall be handled and

disposed of in an environmentally acceptable way and as

directed by this Department or any other relevant authority.



None.

5. WATER POLLUTION

5.01 It is the responsibility of the applicant and the relevant

contractor on site to prevent any pollution of surface as well

as groundwater.

N/A The water pipeline is underground and maintenance is carried out as

and when required on the valve chambers. According to the Area

Manager, the likelihood of surface- and groundwater pollution is

minimal, and given that the pipeline is in use for the conveyance of

water only, no sources of pollution associated with this exemption

have been identified.

None.

6. RISK MANAGEMENT

6.01 As indicated by relevant authority. N/A According to the Environmental Specialist, no specific

recommendations have been made over and above legislative

requirements.

Furthermore, Sasol has a Governance SHE Risk and Assurance

department that assesses environmental risks and drives

implementation by business. All risk documentation is available on

the Sasol IMS and on the Sasol Intranet.

None.


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7. REPORTING

7.01 Records relating to the compliance or non-compliance with

the conditions of this Exemption must be kept in good order.

Such records must be made available to this Department

within seven (07) working days from the date of a written

request for such records by the Department.

N/A This audit represents the first required audit for this Exemption.

Prior to the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

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

as set out in the Record of Decision, is regarded as an offence

and, after reasonable provision has been made for remedial

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

of the Act.

N/A Noted.

According to the Environmental Specialist and the Area Manager,

there has not been any non-compliance or deviation from the

conditions set out in this Exemption.

None.

7.03 Any complaints regarding the said development must be

brought to the attention of the Department within 24 hours

after receiving the complaint. A complaint's register must be

kept up to date for inspection by members of this Department.

C

The complaints register from 2008 to date was available for review

and there have been no complaints lodged with regards to the

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

Evidence:

— Environmental Complaints Register (Period: December 2014

– March 2019)

None.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITION 5 0 0 5

ESTABLISHMENT OF THE DEVELOPMENT 2 0 0 2

CONSTRUCTION AND OPERATION 2 0 0 2

WASTE 1 0 0 1

WATER POLLUTION 1 0 0 1

RISK MANAGEMENT 1 0 0 1

REPORTING 3 1 0 2

Total Count 15 1 0 14

Total Percentage 100% 7% 0 93%

Percentage Compliance with Applicable Conditions 100%


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Figure 3 illustrates the number/count contribution of the findings of the Exemption per section while Figure 4

presents the total proportion of compliance for the facility.

Figure 3: Number/Count contribution of findings made to the Exemption conditions per Section

Figure 4: Overall count findings on compliance to the Exemption conditions

0

1

2

3

4

5

6

Sectional Count Contribution

C

NC

N/A

1 0

14

Total Compliance

C

NC

N/A


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Figure 5 illustrates the percentage contribution of the findings of the Exemption conditions. Figure 6 presents

the total percentage compliance for the facility.

Figure 5: Percentage contribution of findings made to the Exemption conditions per Section

Figure 6: Overall percentage findings on compliance to the Exemption conditions

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

7% 0%

93%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION (17.2.10

EV 1)