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Environmental Management Programme Report for the Clean Fuels 2 (CF 2) Proposed Tanks Expansion Project at the Sasol Synfuels Operations in Secunda, Mpumalanga Province

Report Prepared for

Sasol South Africa Limited

Report Number 539945/EMPr

Report Prepared by

June 2019

SRK Consulting: 539945 Sasol CF 2 Tank Expansion Project - EMPr Page i

CADD/coes 539945.2019.06.26.R.Sasol Tanks EMPr.Final Draft June 2019

Environmental Management Programme Report for the Clean Fuels 2 (CF 2) Proposed Tanks Expansion Project at the Sasol Synfuels Operations in Secunda, Mpumalanga Province

Sasol South Africa Limited

SRK Project Number 539945/EMPr

SRK Consulting (South Africa) (Pty) Ltd. Block a, Menlyn Woods Office Park

291 Sprite Avenue

Faerie Glen

Pretoria 0081

South Africa e-mail: [email protected] website: www.srk.co.za Tel: +27 (0) 12 361 9821 Fax:+27 (0) 12 361 9912 June 2019

Compiled by: Peer Reviewed by:

Mr. A. Caddick Senior Environmental Scientist

Dr. L. Coetser Associate Partner

Email: [email protected]

Authors:

Andrew Caddick

mailto:[email protected]

http://www.srk.co.za/

mailto:[email protected]

SRK Consulting: 539945 Sasol CF 2 Tank Expansion Project - EMPr Page ii


Table of Contents Disclaimer .................................................................................................................................................... iv

List of Abbreviations ..................................................................................................................................... v

Key Definitions ............................................................................................................................................ vi

1 Introduction .................................................................................................................. 1

1.1 Background and Project Description ................................................................................................... 1

2 Objectives of the Environmental Management Programme ..................................... 4

2.1 The Polluter-Pays Principle ................................................................................................................. 5

2.2 Concurrent Rehabilitation ................................................................................................................... 5

3 Qualifications of the Environmental Assessment Practitioners .............................. 5

4 Legislative Requirements ............................................................................................ 6

4.1 Environmental Management Programme ........................................................................................... 6

4.2 Other Applicable Legislation ............................................................................................................... 6

4.3 Incidents and Non-Conformances ...................................................................................................... 7

5 Quantitative Impact Assessment Outcomes .............................................................. 8

6 Approach to Environmental Impact Management ................................................... 14

6.1 The Sasol Safety Health and Environmental Policy ......................................................................... 14

6.2 Organisational Structure and Responsibilities .................................................................................. 15

6.2.1 The Project Management Team will: ..................................................................................... 16

6.2.2 The Contractor (including sub-contractors) will be responsible for: ...................................... 16

6.2.3 The Environmental Control Officer will: ................................................................................. 16

6.2.4 The Safety, Health and Environmental Representative will: ................................................. 16

7 Lifecycle of the Project .............................................................................................. 17

7.1 Planning and Design ......................................................................................................................... 17

7.2 Pre-Construction and Construction ................................................................................................... 17

7.3 Operation .......................................................................................................................................... 18

7.4 Decommissioning and Closure ......................................................................................................... 19

8 Checking and Corrective Action ............................................................................... 19

9 Site Documentation and Reporting ........................................................................... 20

10 Monitoring ................................................................................................................... 20

10.1 Monitoring Programme ..................................................................................................................... 21

10.2 Environmental Monitoring ................................................................................................................. 21

11 General Requirements ............................................................................................... 21

12 Specific Environmental Management Requirements .............................................. 23

13 Environmental Awareness Plan ................................................................................ 37

13.1 Aim of the Environmental Awareness Plan ....................................................................................... 37

13.2 Environmental Awareness Training .................................................................................................. 37

13.3 Content of the Environmental Awareness Training .......................................................................... 37

14 External Auditing ........................................................................................................ 38

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15 Commissioning of Tenders ....................................................................................... 38

16 Declaration of Contractor's Acceptance .................................................................. 39

List of Tables Table 1-1: Additional tanks required by Sasol .................................................................................................... 2

Table 3-1: Compilers of the EMPr ...................................................................................................................... 5

Table 4-1: Applicable legislation (not limited to) ................................................................................................. 7

Table 4-2: Classification of Environmental Incident ........................................................................................... 8

Table 5-1: Potential environmental impacts and ratings associated with the CF 2 proposed Tanks Expansion Project ........................................................................................................................ 9

Table 6-1: Approach to impact management ................................................................................................... 14

Table 11-1: General environmental management ............................................................................................ 22

Table 11-2: Environmental Monitoring .............................................................................................................. 22

Table 12-1: Environmental management measures for the proposed CF 2 project ........................................ 24

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Disclaimer The environmental management measures provided in this Environmental Management Programme

(EMPr) are based on information supplied to SRK Consulting (South Africa) (Pty) Ltd (SRK) by Sasol

South Africa Limited (Sasol). This report has been compiled to comply with the specific requirements

of the National Environmental Management Act (Act No. 107 of 1998, as amended) (NEMA)

Environmental Impact Assessment (EIA) Regulations (2014).

SRK has exercised all due care in reviewing the supplied information provided by Sasol during the

course of the Environmental Assessment Process and has included the requirements of commenting

authorities. The appropriateness and practicality of the management measures have been considered

in terms of comments received and discussed with Sasol as necessary. Sasol is fully responsible for

the implementation of the EMPr.

The EMPr has been provided to Sasol for review, prior to submission, to determine whether the EMPr

is implementable and accurate. SRK cannot be held responsible for failure of Sasol to comply with the

EMPr for any reason whatsoever. The EMPr by nature is a dynamic document and the NEMA provides

for continual updating of the EMPr, with approval from the Competent Authority.

SRK does not accept responsibility for any errors or omissions in the information supplied by Sasol

and do not accept any consequential liability arising from commercial decisions, design changes or

actions resulting from such decisions and/or changes. Management measures presented in this report

relate to the project description and plans as they existed at the time of SRK’s investigations, and

those reasonably foreseeable. These management measures do not necessarily apply to conditions

and aspects that may arise after the date of this report, about which SRK had no prior knowledge nor

had the opportunity to evaluate.

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List of Abbreviations

BAP Basic Assessment Process

BAR Basic Assessment Report

CF Clean Fuels

CTN Cold Tar Naphtha / Benzene

DEA Department of Environmental Affairs

EA Environmental Authorisation

ECO Environmental Control Officer

EHN Cetane Enhancer

EIA Environmental Impact Assessment

EMPr Environmental Management Programme

I&AP Interested and Affected Party

MDARDLEA Mpumalanga Department of Agriculture, Rural Development, Land and Environmental

Affairs

MFO Medium Fuel Oil

MSDS Material Safety Data Sheets

NEMA National Environmental Management Act (Act No. 107 of 1998)

PPA Petroleum Products Act (Act No. 120 of 1977)

PPE Personal Protective Equipment

Sasol Sasol South Africa (Pty) Ltd

SHE Safety Health and Environmental

STEL Short Term Exposure Limits

SAHRA South African Heritage Resources Act (Act No. 25 of 1999)

SRK SRK Consulting South Africa (Pty) Ltd

TAME Tertiary Amyl Methyl Ether

TWA Time Weighted Average

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Key Definitions

Approved Professional Person

A person registered in terms of the Engineering Profession of South Africa Act, 1990 (Act 114 of 1990) and approved by the Minister after consultation with the Engineering Council of South Africa (established by section 2 of the National Water Act (Act No. 36 of 1998) (NWA).

Contractor Any provider of services, goods or people to Sasol for the purpose of the CF 2 proposed Tanks Development Project. These may directly or indirectly include contractors, sub-contractors, hired labour agencies and consultants.

DEA Department of Environmental Affairs

Emergency Incident An undesired event that results in an environmental impact and requires the notification relevant statutory bodies and the Project Management Team.

Environment As per definition in the National Environmental Management Act (Act No. 107 of 1998, as amended) (NEMA).

Environmental Consultant

An independent environmental consultant who may provide environmental services to the design and operation of the CF 2 proposed Tanks Expansion Project, guidance of the CF 2 proposed Tanks Expansion Project construction contracts under Sasol control, and auditing of the construction and operation of the CF 2 proposed Tanks Development Project in terms of the Sasol Environmental Authorisation, as required.

Environmental Control Officer

The Environmental Control Officer (ECO) is the person responsible for ensuring that the EMPr is implemented, and that revisions and updates to the EMPr are appropriately recorded in a control document. A control document is official only if the issue/revision has been approved.

Environmental Impact A change in the environment, weather adverse or beneficial, wholly or partly, resulting from an organizations activities, products or services.

Environmental manager

Dedicated Sasol employee that deals with environmental considerations in the management cycle of the Project, i.e. policy, planning and design, implementation (preconstruction, construction, operation, maintenance and decommissioning), monitoring and corrective action and review.

Incident An undesired event that may result in a significant environmental impact, although can be managed through internal response and procedures.

Operational controls Mechanisms used to effect the EMPr requirements as well as the day to day operations of the activities.

Plan Sets out the intended method and/or specific measures required to mitigate and/or enhance the negative and positive impacts of the Project. A plan usually focuses on one project activity, i.e. training and awareness, or phase, i.e. pre-construction construction, operation, maintenance and decommissioning.

Project Management Team

The responsibility of the EMPr implementation resides with this team. This team includes a Project Manager and Section Leader nominated to be of the Inside Ash and Sasol Environmental Department teams, and representatives of the business units contributing to or receiving from the CF 2 proposed Tanks Development Project.

Programme Identifies a series of interrelated measures (often contained in detailed plans) for managing the environmental effects of the Project. A programme provides broad direction and covers more than one project phase.

Safety, Health and Environmental Officer

A representative from each contractor, appointed as a Safety Health and Environmental (SHE) Officer, assisting the construction manager on SHE aspects of the on-going construction and decommissioning of the CF 2 proposed Tanks Development Project.

Sasol Secunda Environmental Management Team

Sasol Secunda employees that deal with environmental considerations in the management cycle of the Sasol Synfuels Operations, and in terms of the EA, and the environmental performance monitoring and auditing of the CF 2 proposed Tanks Development Project, i.e. policy, planning and design, implementation, monitoring, auditing and corrective action and review .

SRK Consulting: 539945 Sasol CF 2 Tank Expansion Project - EMPr Page 1


1 Introduction Sasol South Africa Limited (hereafter referred to as Sasol) is situated in close proximity to the town of

Secunda in the Mpumalanga Province, and approximately 16 km south-east of Kinross and 26 km

south-west of Bethal. Sasol produce liquid fuels (petrol, diesel and paraffin), as well as industrial

pipeline gas and a range of chemical feedstock compounds, including the building blocks for industrial

solvents and polymers, through the gasification process of approximately 40 million tons of coal per

annum. The gasification is done with steam at high pressure to produce hydrogen and carbon

monoxide, followed by the conversion of this gas mixture to hydrocarbons via the Fischer-Tropsch

process.

The main products Sasol produce are:

• Fuel components;

• Chemical components; and

• Co-products.

From these main products and further value-adding processes, Sasol deliver diesel, petrol (gasoline),

naphtha, kerosene (jet fuel), Liquid Petroleum Gas ,olefins, alcohols, polymers, solvents, surfactants,

co-monomers, ammonia, methanol, crude tar acids, sulphur, illuminating paraffin, bitumen and fuel oil.

Even further processing produces numerous additional products (Sasol South Africa (Pty) Ltd, 2018).

The area of Mpumalanga in which Sasol is located was historically a rural farming area. The Highveld

Ridge has since been modified by mining and industrial activities related to coal and gold mining,

power generation and agriculture. In turn, the land-use in the Secunda region has changed significantly

over the last 50 years from a rural agricultural setting to being highly industrialised.

1.1 Background and Project Description

A significant contributor to greenhouse gas emissions is the transport sector posing a risk to the

environmental and human health. More stringent fuel specifications and standards have been

developed aimed at the reduction of emissions from vehicles as well as improved air quality.

New fuel specifications (Clean Fuels (CF) I) were developed and introduced in 2006 in the form of

regulations under the Petroleum Products Act (Act No. 120 of 1977) (PPA) and revised South African

National Standards (SANS) 342:2016 specifications relating to petrol and diesel.

These new petrol specifications prohibited the addition of lead in unleaded petrol, but allowed the use

of other metals, such as manganese and phosphorus in metal-containing unleaded petrol (lead

replacement petrol) to cater for the older vehicles that might suffer from valve seat recession with the

removal of lead from petrol.

The diesel specifications required the sulphur levels in diesel to be dropped from a maximum of 3 000

parts per million (ppm) to 500 ppm, with a niche grade of 50 ppm being introduced. This resulted in an

improvement in the diesel exhaust emissions of vehicles.

Regulations regarding the introduction of CF 2 were gazetted in June 2012 which indicated that it

would come into operation on 1 July 2017. These regulations, among other legislation, indicates

specifications to conform to, such as those contained in the SANS 342: 2016 for petrol and diesel.

These specifications are currently being finalised. The regulations also require other specifications to

conform to such as those contained in the national standards for petrol and diesel. The target date of

July 2017 has been postponed to a date to be determined in the future, once various aspects relating

to the financial implications of producing the cleaner fuels have been finalised.



A market led change to CF 2 fuel quality is currently foreseen to occur by 2021. It is further predicted

that the Department of Energy will regulate the conversion to CF 2 between 2023 and 2025. In line

with these expected changes, Sasol has launched the CF 2 program to lead and coordinate Sasol’s

response to accommodate changes in the market.

To ensure future sustainability it is imperative that the Sasol Synfuels Operations are converted to

CF 2. To support these technical solutions, Sasol will require various additional tankage in the existing

Synfuels Tank Farm area located in Secunda.

The location and layout of the proposed tanks is illustrated in Figure 1-1. The following tanks as

detailed in Table 1-1 will be required:

Table 1-1: Additional tanks required by Sasol

Product Storage Volume (m3)

Number of Tanks

Tank Diameter (m)

Tank Height

Cold Tar Naphtha / Benzene (CTN) 12 000 1 26 25

Tertiary Amyl Methyl Ether (TAME) 30 000 2 29 20

Creosote Diesel 30 000 3 26 21

Medium Fuel Oil (MFO) 3 000 2 13 13

EHN (Cetane Enhancer) 300 2 5 10

Total 75 300 10



SASOL CF 2 TANKS PROJECT

REGIONAL MAP Project No.

539945

Figure 1-1: Regional map illustrating the CF 2 proposed Tanks Expansion Project



2 Objectives of the Environmental Management Programme The key objectives of the Environmental Management Programme (EMPr) are to:

• To avoid, minimise, or correct pollution and degradation of the environment;

• To avoid or minimise waste and to re-use or re-cycle waste where possible;

• To apply a risk averse and cautious approach;

• To anticipate and prevent negative impacts on the environment (physical, biological, social,

economic, and cultural). Where these impacts cannot be prevented, such impacts must be

minimised or remedied;

• That negative impacts on the environment and on people’s environmental rights be anticipated

and prevented, and where they cannot be altogether prevented, are minimised and remedied;

• Environmental management must be integrated, acknowledging that all elements of the

environment are linked and interrelated, and it must take into account the effects of decisions on

all aspects of the environment and all people in the environment by pursuing the selection of the

best practicable environmental option; and

• The social, economic and environmental impacts of activities, including disadvantages and

benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the

light of such consideration and assessment.

The National Environmental Management Act (Act No. 107 of 1998, as amended) (NEMA) stipulates

that anyone who causes pollution or degradation of the environment is responsible for preventing

impacts occurring, continuing or recurring and for the costs of repair of the environment. Other

legislation that contain requirements, which were taken into consideration in drafting the EMPr, include

the:

• NEMA;

• National Water Act (Act No, 36 of 1998, as amended (NWA); and

• Occupational Health and Safety Act (Act No. 85 of 1993).

This EMPr among other things:

• Presents an action plan for the implementation of mitigation measures with the purpose of

regulating the Contractor’s conduct or method of working;

• Provides specific environmental guidance for construction, operation, maintenance and

decommissioning activities;

• Incorporates measures to manage and mitigate construction, operation, maintenance and

decommissioning activities so that negative environmental impacts are avoided or reduced;

• Identifies and allocates responsibilities for specific actions associated with the management of

construction, operation, maintenance and decommissioning activities to mitigate negative

environmental impacts; and

• Provides an outline of the activities, which require monitoring and the assessment thereof.

This EMPr serves as a stand-alone document to be disseminated to and used by the contractor/s and

project managers/supervisors during the construction, operation, maintenance and decommissioning



phases of the project. By its very nature, the EMPr is a dynamic document and updating may be

required.

The EMPr has been compiled on the basis of the outcome of work undertaken during the Basic

Assessment Process (BAP) and represents management commitments of Sasol once approved by

the Competent Authority, whereby the EMPr will be legally binding.

2.1 The Polluter-Pays Principle

This principle provides for “the costs of remedying pollution, environmental degradation and

consequent adverse health effects and of preventing, controlling or minimizing further pollution,

environmental damage or adverse health effects must be paid for by those responsible for harming

the environment.” The Polluter Pays Principle must be rigorously applied throughout the Construction,

Operational and Closure Phase of this project.

2.2 Concurrent Rehabilitation

Concurrent rehabilitation must also be undertaken throughout the Construction and Closure Phase of

the project with areas that have been impacted on. Rehabilitation should commence as soon as

construction is completed in a specific area and not at the end of the construction/closure of the entire

project.

3 Qualifications of the Environmental Assessment Practitioners Table 3-1 provides information on the compilers of this document and their related experience.

Table 3-1: Compilers of the EMPr

Name Qualifications Years of Experience

Andrew Caddick (Pr.Sci Nat) B.Sc. (Hons), M. Geography and Environmental Management

10 years

Laetitia Coetser (Pr.Sci.Nat) PhD (Water Resource Management) 20 years

This EMPr was prepared by Andrew Caddick and reviewed by Dr Laetitia Coetser. Mr Caddick is a

Senior Environmental Consultant with SRK Consulting South Africa (Pty) Ltd (SRK). He has Master’s

degree in Environmental Management and Geography obtained from the North West University, and

has over 10 years of project experience in environmental management. During this time Mr Caddick

has both personally prepared and given input to various EMPr’s. Dr Coetser is a Principal

Environmental Consultant at SRK with over 20 years’ experience. During this time Dr Coetser has

compiled a number of EMPr’s and associated amendments. She has a PhD in Water Resource

Management.



4 Legislative Requirements

4.1 Environmental Management Programme

The Basic Assessment Report (BAR) application was submitted under the National Environmental

Management Act (Act No. 107 of 1998, as amended) (NEMA) Environmental Impact Assessment (EIA)

Regulations (2014) and the EMPr is thus subject to the requirements of the 2014 EIA Regulations.

Appendix 4 of the NEMA EIA Regulations (GR 982) sets out the minimum requirements for the

development of an EMPr. This EMPr has been developed in fulfilment of these requirements for the

construction, operational and decommissioning phases of the project.

The implementation of an EMPr for the proposed activity is a requirement of the NEMA and will be a

condition in the Environmental Authorisation (EA), issued by the Competent Authority. As such, failure

to comply with this EMPr will constitute an offence and Sasol and/or their Contractors may be liable

for penalties and/or legal action. Therefore, it is important that all responsible parties understand their

duties and undertake them with duty and care.

This EMPr should form an integral part of the contract documents, informing the Contractor of his

duties in the fulfilment of the project objectives, with particular reference to the prevention and

mitigation of environmental impacts caused by the proposed activities associated with the project.

The Contractor should note that obligations imposed by the EMPr are legally binding in terms of

environmental statutory legislation. Furthermore, the EMPr is enforceable through additional

conditions to the general conditions of contract that pertain to this project. In the event that any rights

and obligations contained in this document contradict those specified in the standard or project

specifications then the latter shall prevail.

It is expected that the Contractor be conversant with all legislation pertaining to the environment,

including provincial and local government ordinances, which may be applicable to the contract.

All prospective contractors must sign the declaration of acceptance of the EMPr, included at the end

of this document.

It should be noted that the EMPr is a living document that will be periodically reviewed and updated.

As part of on-going implementation, this EMPr will be publicly disclosed during the Stakeholder

Engagement Process of this project. An opportunity will be offered to participating stakeholders to

provide comments for incorporation into the EMPr.

4.2 Other Applicable Legislation

Sasol are responsible for compliance with the provisions for duty of care and remediation of damage

in accordance with Section 28 of NEMA and its obligations regarding the control of emergency

incidents in terms of Section 30. Accordingly, the Mpumalanga Department of Agriculture, Rural

Development, Land and Environmental Affairs (MDARDLEA) must immediately be notified of an

incident as defined in subsection 30(1) (a) of NEMA.

Various environmental legislation and policies relate to the proposed activities. A detailed description

of the legislative context can be found in Section 2 and 3 of the BAR. Table 4-1 provides an overview

of the legislation and respective sections pertaining to the CF 2 proposed Tanks Expansion Project.



Table 4-1: Applicable legislation (not limited to)

Legislation Section Description

The Constitution (Act No. 108 of 1996)

Chapter 2 Bill of Rights.

Section 24 Environmental Rights

NEMA Section 2 Defines the strategic environmental management goals and objectives of the government. Applies throughout the Republic to the actions of all organs of state that may significantly affect the environment.

Section 24 Provides for the prohibition, restriction and control of activities which are likely to have a detrimental effect on the environment.

Section 28 The developer has a general duty to care for the environment and to institute such measures as may be needed to demonstrate such care.

Environment Conservation Act (Act No. 73 of 1989)

Section 19 Prevention of littering by employees and subcontractors during construction, operation, maintenance and decommissioning phases of the proposed improvements to CF 2 proposed Tanks Development Project.

National Environmental Management: Air Quality Act (Act No. 39 of 2004)

Section 23 Provides provision for the control of listed emissions.

Section 32 Provides provision for the control of dust.

Section 34 Provides provision for the control of noise.

Section 35 Provides provision for the control of offensive odours.

Occupational Health and Safety Act (Act No. 85 of 1993)

Section 8 General duties of employers to their employees.

Section 9 General duties of employers and self-employed persons to persons other than their employees.

Hazardous Substances Act (Act No. 5 of 1973)

Act Provides for the definition, classification, use, operation, modification, disposal or dumping of hazardous substances.

National Environmental Management: Waste Act (Act No. 59 of 2008)

Act Provides for specific waste management measures (disposal and storage) and the remediation of contaminated land.

4.3 Incidents and Non-Conformances

According to Section 30 of the NEMA: “Incident” means an unexpected sudden occurrence including

a major emission, fire or explosion leading to serious danger to the public or potential serious pollution

of or detriment to the environment, whether immediate or delayed.

In terms of the above definition:

The Emergency response plan/method statement should be initiated in response to an incident as

classified in Table 4-2. The incident must be reported to the Environmental Control Officer (ECO) and

Department of Environmental Affairs (DEA) as per Section 30 (3) of NEMA. An emergency incident

report required in terms of Section 30(5) of NEMA must be submitted to DEA’s Environmental

Management Inspectorate for processing. A close out certificate issued by the Inspectorate indicating



that measures undertaken were to the department’s satisfaction should obtained by the ECO, if

possible.

A chemical spill is defined as a potential liquid hydrocarbon or chemical spill or other release, which

can create a hazard to life or property or create environmental damage. Examples include liquid

hydrocarbons, compressor or other equipment lube oil, evaporative cooler acid water, liquid odorant,

or other substances that contain controlled or hazardous substances. Spills and other environmental

incidents have been classified according to the risk to the environment and appropriate responses are

indicated in Table 4-2.

Table 4-2: Classification of Environmental Incident

Level Definition Response Required

Level 1 A Minor Emergency, which can be controlled entirely by the personnel and facilities located within the immediate vicinity of the accident/incident site. These include events which cause minor property or equipment damage that are non-disruptive to operations, and do not pose a safety risk to personnel or property outside of the boundaries of the development footprint.

Record in the incidents register and managed accordingly

Level 2 A Level 2 Incident is defined as a Moderate Emergency, which is disruptive, but not extensive, and forces a portion of the employer operation to be temporarily suspended or shut down.

A Level 2 Incident is a spill or hazardous product release which has the potential to cause harm to personnel, the public, or the environment and includes a chemical spill of more than 35 l to land; or any chemical spill to water resources.

Record in the incidents register and managed accordingly

Level 3 to 5 Incidents

A Level 3 to 5 Incident is defined as a Serious (3), Major (4) to Catastrophic (5) alert requiring the intervention of external support services and that can have serious impacts on ecology, humans and on the overall Project.

Report the incident to the ECO immediately. The ECO will submit an emergency incident report to DEA. The incident must also be recorded in the incidents register

In the above cases, it will be the decision of the site management as to whether work stoppage must

be implemented. In most cases, work in the area where the incident occurred will be stopped until all

safety clearances have been given. Unless, there is a fatal accident, then activities on the whole

construction site will stop.

The holder of the authorisation must notify DEA, in writing and within 48 (forty-eight) hours, if any

condition of the EA cannot be or is not adhered to. The notification must be accompanied by reasons

for the non-compliance. Non-compliance with a condition of the EA on may result in criminal

prosecution or other actions provided for in NEMA and the regulations.

In addition, any pollution incidents originating from the proposed project must be reported to the

Regional Office of the Department of Water and Sanitation within 24 (twenty-four) hours.

5 Quantitative Impact Assessment Outcomes The section provides a description of the impact management outcomes, including management

statements, identifying the impacts and risks that need to be avoided, managed and mitigated.

This section contains the assessment of potentially positive and negative environmental impacts that

can be caused by the CF 2 proposed Tanks Development Project. The impacts are linked to the

activities conducted for the proposed development, broadly relating to construction, operation,

maintenance and decommissioning phases. Specific emphasis was placed on any relevant

environmental, social and economic impacts identified by the specialist studies, comments received

during the stakeholder engagement process, issues highlighted by relevant authorities; as well as a



professional judgement of the EAP team through appraisals on the project description, listed activities

and the receiving environment.

The objectives for each of the potential environmental impacts identified was to determine their

significance and to promote mitigation measures to reduce the impacts to an acceptable level where

required.

All of the identified impacts are assessed in this section. Considering the general nature of the

proposed project, this section will take cognisance of the construction, operation, maintenance and

decommissioning phases.

This is intended to:

• Enable to facilitate the preferred alternative during the decision-making process of the MDARDLEA; and

• Enable stakeholders to understand the potential impact of the project.

The anticipated impacts can be found in Table 5-1.

Table 5-1: Potential environmental impacts and ratings associated with the CF 2 proposed Tanks Expansion Project

POTENTIAL ENVIRONMENTAL IMPACT (NATURE OF THE IMPACT)

ENVIRONMENTAL SIGNIFICANCE

BEFORE MITIGATION


AFTER MITIGATION

CONSTRUCTION PHASE

Social-Economic

National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy.

VERY HIGH (+) VERY HIGH (+)

Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations.

HIGH (+) HIGH (+)

Opportunity to keep pace with improved vehicle engine technology and addressing environmental degradation as a result of harmful emissions from vehicles

HIGH (+) HIGH (+)

Possible boost in short term employment and local small business opportunities.

LOW (-) LOW (-)

Generation of dust potentially resulting in a health and nuisance impact. LOW (-) VERY LOW (-)

Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly.

LOW (-) LOW (-)

Clearing of land which may potentially impact on the sense of place. VERY LOW (-) VERY LOW (-)

Possible impact on service provision as a result of construction of temporary ablution facilities, storage areas, and site establishment.

LOW (-) VERY LOW (-)

Potential squatting of job seekers. VERY LOW (-) VERY LOW (-)

Surface Water Quality

Potential deterioration in water quality as a result of accidental spillages of hazardous substances such as hydrocarbons from construction vehicles and machinery.


Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality.


Debris from poor handling of materials and/or waste blocking watercourses may result in flow (-) impediment and pollution.

VERY LOW (-) VERY LOW (-)

Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the construction footprint area.


Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources.


Debris from poor handling of materials and/or waste blocking watercourses nay result in flow (-) impediment and pollution.


Increase of surface runoff and potentially contaminated water that needs to be maintained in the areas where site clearing occurred.


Groundwater

Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination.


Improper storage and handling of hazardous materials leading to groundwater contamination.






BEFORE MITIGATION


AFTER MITIGATION

Wetlands and Aquatic Ecosystems

Potential impacts on wetlands and aquatic ecosystems including: • Localised changes to the riparian areas as a result of vegetation clearing; • Sedimentation of riparian resources leading to smothering of wetland and aquatic flora; • Loss of habitat and riparian zone ecological structure as a result of site clearance activities and uncontrolled riparian zone degradation; • Deterioration of wetland water quality due to accidental spillages of hydrocarbons and poor waste management; • Impact on the riparian systems as a result of changes to the sociocultural service provision of wetlands; • Increased runoff due to topsoil removal and vegetation clearance leading to possible erosion and sedimentation of riparian resources; • Uncontrolled movement of vehicles and construction personnel may result in soil compaction and levelling as well as loss of riparian habitat.


Air Quality

Dust generating activities associated with the construction phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.


Emissions of Green House Gases as a result of the use of construction vehicles and machinery.


Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil.


Clearing of vegetation outside of the Tank Farm footprint area. LOW (-) VERY LOW (-)

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials.

MEDIUM LOW (-) LOW (-)

Potential compaction and erosion of soils removed and stockpiled during excavation activities.


Climate Change



Overall climatic benefits as a result of the production and utilisation of fuel that meets more stringent specifications (cleaner fuels)


Geotechnical Consideration

Potential geotechnical constraints impacting on engineering design of access roads and foundations as a result of collapsible and compressible soil.

Medium High (-) Very Low (-)

Potential degradation of geo-sites. Very Low (-) Very Low (-)

Potential degradation of bedrock and topography as a result of excavations for foundations, pipelines, tanks and other associated infrastructure.

Low (-) Very Low (-)

Potential safety risk as a result of inappropriate founding methods. Medium High (-) Very Low (-)

Potential groundwater, surface and soil contamination as a result of: • High settlements of structures if soils have a low in situ bearing capacity if not compacted or engineered properly; • Using contaminated material as bulk fill in material; • Ground distortion (settlement) caused by construction activities (earthworks, retaining structures etc.); and • Change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level.

Medium High (-) Very Low (-)

Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated soil and building material for the construction of the Tertiary Amyl Methyl Ether (TAME), creosote diesel and Cold Tar Naphtha / Benzene (CTN) tanks.


Cultural and Heritage

Although no additional resources of cultural and/or heritage importance that will be affected by the project, a possibility remains that there may be some resources that may be affected.


Flora

Loss of vegetation species including vegetation species of conversational concern due to site clearance.


Direct loss of habitat and indirect loss of habitat quality. LOW (-) VERY LOW (-)

Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer alien species are provided with a chance to flourish.


Generation of waste and incorrect disposal from construction material leading to disturbance of natural vegetation.






BEFORE MITIGATION


AFTER MITIGATION

Fauna

Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general construction activities.


Loss of faunal diversity and ecological integrity as a result of construction activities, erosion, poaching and faunal species trapping.


Movement of construction vehicles and machinery may result in collision with fauna, resulting in loss of fauna.


Visual

Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure.


Indirect visual impact due to dust generation as a result of the movement of vehicles and materials, to and from the site area.


Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings.


Traffic

Increase in traffic volumes as a result of construction activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the construction site.


Operational Phase

Socio-Economic

National economic benefits by providing a sustainable domestic supply of cleaner fuels to support a more competitive South African economy.


Regional economic benefits as a result of the on-going operation of the Sasol Synfuels Operations.

HIGH (+) HIGH (+)

Opportunity to keep pace with improved vehicle engine technology and addressing environmental degradation as a result of harmful emissions from vehicles.

HIGH (+) HIGH (+)

Risk to the safety of surrounding amenities due to the explosion risk of the stored flammable products.

MEDIUM HIGH (-) VERY LOW (-)

The generation of dust and other gaseous emissions i.e. VOCs resulting in a health and nuisance impact.

MEDIUM LOW (-) VERY LOW (-)

Surface Water

Contamination of runoff by poor materials/waste handling practices, including accidental spillages of hazardous substances from vehicles/pipelines/tanks etc.


Uncontrolled runoff containing suspended solids, sediments and fuel residue may contaminate surface water resources.


Groundwater

The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils.


Contamination of soil and groundwater and possibly bedrock as a result of overspills from the storage tanks.


Leakage of hazardous materials from the transportation pipelines etc. MEDIUM HIGH (-) VERY LOW (-)

Improper storage and handling of hazardous materials. MEDIUM LOW (-) VERY LOW (-)

Air Quality

Gaseous emissions i.e. VOCs will arise from the tanks within the project area.


Climate Change



Overall climatic benefits as a result of the production and utilisation of fuels that meet more stringent specifications (cleaner fuels)


Soil, Land Use and Land Capability

The use of vehicles delivering and transporting chemicals on site poses the risk of chemical spillages including fuel and oils.


Contamination of soil as a result of overspills from the storage tanks. MEDIUM HIGH (-) VERY LOW (-)

Leakage of hazardous materials from the transportation pipelines etc. MEDIUM HIGH (-) VERY LOW (-)

Potential hydrocarbon spillages resulting from a leakage caused by a fracture/crack/corrosion or rupture in the fuel storage tanks may lead to contamination of the soil in and around the site area.


Improper storage and handling of hazardous materials. MEDIUM LOW (-) VERY LOW (-)





BEFORE MITIGATION


AFTER MITIGATION

Geotechnical Considerations

Potential groundwater, surface water and soil contamination as a result of change of groundwater conditions, flow of groundwater, lowering (or rise) of groundwater level.


Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to: • Seismic activities; and • The formation of sinkholes or subsidence caused by the presence of water-soluble rocks (dolomite or limestone).

Very Low (-) Very Low (-)

Potential groundwater, surface water and soil contamination as a result of infrastructure failure due to differential settlement as a result of foundations placed across different soil types or rock which may settle differently.


Topography

Permanent altering of the ground level due to excavation activities and tank erection.


Heritage

Although no additional resources of cultural and/or heritage importance that be affected by the project, a possibility remains that there may be some resources that may be affected.


Flora

Uncontrolled movement of vehicles outside the designated access roads may result in the destruction of potential floral habitats for species of conservational concern.


Failure to initiate an alien species control plan during the construction phase may lead to further impacts during the operation phase.


Fauna

Uncontrolled movement of vehicles may lead to loss of faunal habitat and ecological structure.


Loss of faunal species due to collisions with vehicles transporting the materials to the site.


Failure to initiate an alien species control plan during the construction phase may lead to further impacts on faunal habitat during the operation phase.


Visual

Visual intrusion as a result of the movement of machinery and the establishment of the required infrastructure.




Noise

Localized and temporary increase in noise levels due to the presence of delivery/transporting vehicles in the immediate surroundings.


Traffic

Increase in traffic volumes as a result of delivery which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the operational site.


DECOMMISSIONING AND CLOSURE PHASE

Social-economic

Possible boost in short term employment and local small business opportunities.

LOW (-) LOW (-)

Generation of dust potentially resulting in a health and nuisance impact. LOW (-) VERY LOW (-)

Potential impact on safety and security as a result of theft, the occurrence of additional trucks on the roads, uncontrolled lighting of fires on site, littering and driving irresponsibly.

LOW (-) LOW (-)

Clearing of land which may potentially impact on the sense of place. VERY LOW (-) VERY LOW (-)

Potential squatting of job seekers. VERY LOW (-) VERY LOW (-)

Surface Water Quality

Potential deterioration in water quality as a result of accidental spillages of hazardous substances such as hydrocarbons from construction vehicles and machinery.


Possible contaminated dirty water runoff to surrounding areas resulting in the impact on local surface water quality.


Debris from poor handling of materials and/or waste blocking watercourses may result in flow (-) impediment and pollution.


Increase in silt load in runoff due to site clearing, grubbing and the removal of topsoil from the footprint area.


Poor stormwater management leading containing suspended solids, sediments and fuel residue may contaminate surface water resources.






BEFORE MITIGATION


AFTER MITIGATION

Debris from poor handling of materials and/or waste blocking watercourses nay result in flow (-) impediment and pollution.


Increase of surface runoff and potentially contaminated water that needs to be maintained in the areas where site clearing occurred.


Groundwater

Local spillages of oils/fuels from construction vehicles and machinery leading to groundwater contamination.


Improper storage and handling of hazardous materials leading to groundwater contamination.


Wetlands and Aquatic Ecosystems

Potential impacts on wetlands and aquatic ecosystems including: • Localised changes to the riparian areas as a result of vegetation clearing; • Sedimentation of riparian resources leading to smothering of wetland and aquatic flora; • Loss of habitat and riparian zone ecological structure as a result of site clearance activities and uncontrolled riparian zone degradation; • Deterioration of wetland water quality due to accidental spillages of hydrocarbons and poor waste management; • Impact on the riparian systems as a result of changes to the sociocultural service provision of wetlands; • Increased runoff due to topsoil removal and vegetation clearance leading to possible erosion and sedimentation of riparian resources; • Uncontrolled movement of vehicles and construction personnel may result in soil compaction and levelling as well as loss of riparian habitat.


Air Quality

Dust generating activities associated with the decommissioning and closure phase will cause an increase in atmospheric dust and exposed loose material that may be mobilised by the wind.


Climate change



Soils Land Capability and Land Use impacts

Movement of construction vehicles, machinery and workers in unprotected areas (bare) may result in compacting of the soil.


Clearing of vegetation outside of the Tank Farm footprint area. LOW (-) VERY LOW (-)

Localized and temporary contamination of soil resources as a result of incorrect storage/leakage/spillage of chemicals, hydrocarbons or any other hazardous substances/materials.

MEDIUM LOW (-) LOW (-)

Potential compaction and erosion of soils removed and stockpiled during excavation activities.


Loss of topsoil due to erosion of areas exposed following excavation and stockpiling.


Geotechnical Considerations

No additional impacts identified.

Topography

Temporary disturbance and alteration of ground level as a result of stockpiling of excavated materials, structures and building material from the decommissioning of the CF 2 Expansion Project.


Cultural and Heritage

Although no additional resources of cultural and/or heritage importance that will be affected by the project, a possibility remains that there may be some resources that may be affected.


Flora

Potential spreading of alien invasive species as indigenous vegetation is removed and pioneer alien species are provided with a chance to flourish.


Generation of waste and incorrect disposal from decommissioning material leading to disturbance of natural vegetation.


Fauna

Loss of faunal habitat and ecological structure as a result of site clearing, alien invasive species, erosion, and general decommissioning activities.


Loss of faunal diversity and ecological integrity as a result of decommissioning activities, erosion, poaching and faunal species trapping.


Movement of construction vehicles and machinery may result in collision with fauna, resulting in loss of fauna.






BEFORE MITIGATION


AFTER MITIGATION

Visual

Visual intrusion as a result of the movement of machinery and the decommissioning of the required infrastructure.




Noise

Localized and temporary increase in noise levels due to the presence of construction vehicles and machinery related to the additional activities taking place within the immediate surroundings.


Traffic

Increase in traffic volumes as a result of decommissioning activities which may lead to an increase in traffic congestion on roads around the project area increasing the chances of road accidents.


Waste Management

Possible impact on the surrounding environment as a result of waste generation, incorrect waste disposal (general and hazardous), and housekeeping on the site.


6 Approach to Environmental Impact Management The responsibility of the EMPr implementation will ultimately reside in the Project Management Team

of the CF 2 proposed Tanks Expansion Project. There will be links with other fundamental units such

as Safety Health and Environmental (SHE) representatives of Sasol, Operational and Maintenance

services.

The sections that follow outline the management cycle and responsibilities of the Project Management

Team. Table 6-1 illustrates the range of approaches to be undertaken to manage potential project

activities.

Table 6-1: Approach to impact management

Avoidance Avoiding activities that could result in adverse impacts and/or resources or areas considered sensitive.

Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence having negative impacts.

Preservation Preventing any future actions that might adversely affect an environmental resource.

Minimisation Limiting or reducing the degree, extent, magnitude or duration of adverse impacts through scaling down, relocating, redesigning and/or realigning elements of the project.

Mitigation Measures taken to minimise adverse impacts on the environment.

Enhancement Magnifying and/or improving the positive effects or benefits of a project.

Rehabilitation Repairing affected resources, such as natural habitats or water resources.

Restoration Restoring affected resources to an earlier (possibly more stable and productive) state, typically ‘background’ or ‘pristine’ condition. These resources may include soils and biodiversity.

Compensation Compensating for lost resources, and where possible, the creation, enhancement or protection of the same type of resource at another suitable and acceptable location.

6.1 The Sasol Safety Health and Environmental Policy

Sasol’s Safety Health and Environmental Policy has the goal to reach zero harm through a risk based

approach. Sasol are committed to



As a leading integrated chemicals and energy company, Sasol recognises that we have a particular

responsibility to respect and care for the health and safety of our people, the environment and

communities where we operate. Safety, health and protection of the environment is a way of life and

a top priority, where zero harm is possible through committed leadership, engaged people, teamwork

and dedicated focus. By using a standardised and systematic approach, we aim to sustainably position

Sasol to deliver superior value for our stakeholders through an appropriate and well-reasoned balance

between economic, social and environmental needs.

Our Goal is to:

Reach zero harm through a risk based approach. We will achieve this by:

• Ensuring a safe and healthy workforce;

• Reliable, safe, and sustainable operations; and

• Responsibly addressing our environmental challenges with consideration for the interests of our stakeholders.

We are committed to:

• Visible leadership that demonstrates commitment to and takes accountability for achieving zero harm.

• Responsible use of natural resources to minimise impacts on the environment, our employees and fence line communities.

• Informed decision-making where SHE requirements are integral to the process.

• Engaged employees and service providers who take accountability for their own and others’ safety and behaviour.

• Credible relationships and partnering with our stakeholders through transparent dialogue, reporting and disclosure.

• Continuous improvement on our journey in achieving our goal of zero harm.

We will achieve fundamentals through:

• Equipping our leaders to competently lead SHE performance and create a culture that promotes people engagement and participation;

• Holistically managing the health and wellness of our people;

• Translating our strategic agenda into objectives and targets geared for SHE excellence.

• Understanding the hazards associated with our business to proactively identify, assess, prioritise and manage key undesirable events.

• Adhering to inherent safe design, asset management and operations discipline as guided by international best practice.

• Understanding and implementing the critical controls associated with preventing key undesirable events.

• Implementing integrated and effective management systems, with auditing and assurance to drive mature SHE performance.

• Capturing, applying and communicating SHE learnings and undertaking applicable training for employees and service providers.

• Adhering to the Responsible Care® Global Charter to enable responsible and sustainable development, handling and use of our products.

• Taking appropriate action against deviations from expected SHE behaviour and commitments.

• Implementing internationally recognizable safety, health, environmental and quality management systems;

• Developing and implementing inherently safer and cleaner technologies.

6.2 Organisational Structure and Responsibilities

In order to plan and undertake the CF 2 proposed Tanks Expansion Project, it is important that all

parties understand their functions and responsibilities. Sasol and their contractors will be responsible



for the construction of the CF 2 proposed Tanks Expansion Project and ensure that all activities

undertaken by Sasol are undertaken in compliance with the project’s EA and EMPr. Sasol will monitor

construction activities at a frequency which will be determined by the construction schedule. The

following sections describe the functions of the key team members.

6.2.1 The Project Management Team will:

• Ensure that the Contractors are aware of the specifications, legal constraints and Sasol standards and procedures pertaining to activities taking place regarding the CF 2 proposed Tanks Expansion Project;

• Ensure that all commitments in the EMPr are communicated and adhered to by Sasol employees and contractors involved with the CF 2 proposed Tanks Expansion Project;

• Monitor the implementation of the EMPr throughout the project, by means of site inspections and meetings; and

• Familiarise themselves with the EIA/EMPr for this development, the conditions set out in the EA, and all relevant environmental legislation.

6.2.2 The Contractor (including sub-contractors) will be responsible for:

• Complying with the EMPr commitments and any other legislative requirements;

• Adhering to any instructions issued by the project manager on advice of the Sasol EIA specialist;

• Submitting an environmental report at each site meeting on the environmental incidents that have occurred within the period before the site meeting;

• Appoint a construction Safety Officer and/or SHE representative who will comply to the functions set out below;

• Arrange that all employees and those of the subcontractors receive appropriate training prior to the commencement of construction, taking cognisance of this EMPr and EA.

6.2.3 The Environmental Control Officer will:

• Manage and report on the project’s environmental performance;

• Be responsible for undertaking internal environmental audits and arrange/coordinate external environmental audits;

• Liaise with environmental statutory bodies, should this deem necessary;

• Conduct environmental training and awareness to employees;

• Advise top management on environmental issues and recommendations for the CF 2 proposed Tanks Development Project;

• Arrange for liaison with Interested and Affected parties (I&APs) on environmental issues of concern, if required.

6.2.4 The Safety, Health and Environmental Representative will:

• Oversee all work done by the ECO;

• Ensure corrective actions are followed up and closed out;

• Advise top management on environmental issues and recommendations for the CF 2 proposed Tanks Expansion Project;

• Fully understand the commitments in the EIA/EMPr and EA;

• Familiarise him/herself and ensure compliance will the relevant legislation applicable to the project and Sasol Safety Health and Environmental Policy and procedures;

• Communicate the contents of the EMPr to the contractor and sub-contractor staff members. Training will be required to ensure all staff members are aware of the requirements of this document;

• Regularly undertake site inspections to assess compliance with the EMPr and EA and take appropriate action to rectify non-conformances;

• Authorise the removal of personnel and/or equipment should they contravene the specifications of the EMPr;



• Compile progress reports on a regular basis for submission to the Project Manager;

• Establish a communication path with the Project Manager to discuss monitoring on the site.

7 Lifecycle of the Project The CF 2 proposed Tanks Expansion Project will be undertaken in the following phases:

7.1 Planning and Design

Planning and design is necessary to ensure that the mitigation and impact management can be

effectively implemented through the alternation and amendments of design bases to achieve a more

cost-effective, practical or environmentally friendly development. Planning may involve the following:

• Identifying and defining the environmental aspects and related positive and negative impacts that may result from the development;

• Establish a procedure whereby legal and any other requirements applicable to the CF 2 proposed Tanks Expansion Project development are identified; and

• Identifying and defining appropriate mitigation and management measures which can be incorporated into the on-going review and update of the Operating Envelopes of the business units contributing to the operation of the CF 2 proposed Tanks Expansion Project.

The envisaged impacts to arise from the CF 2 proposed Tanks Expansion Project development have

been detailed and rated in the EIA Report. The management measures presented in this EMPr are

developed in response to these impacts and their associated ratings, and the engineering design that

has subsequently been undertaken for the practical the CF 2 proposed Tanks Expansion Project.

7.2 Pre-Construction and Construction

The EMPr has put in mitigation and management measures to avoid or minimise negative impacts

and optimise the benefits arising from the positive impacts during pre-construction and construction

activities.

Construction activities will include, but are not limited to the following:

• Site preparation – selective clearing of vegetation in areas designated for the CF 2 proposed Tanks Expansion Project;

• Contractor site establishment;

• Earthworks ( if not already done as part of the existing Sasol Synfuels Tank Farm area)

• Stripping of topsoil and sub-soil;

• Stockpiling of topsoil and sub-soil;

• Digging of trenches and foundations;

• Establishing of stormwater controls as per the stormwater management plan;

• Use of soil material from collected from existing berm as backfilling material;

• Civil works:

• Provide a terrace for the CF 2 proposed Tanks Expansion Project;

• Provide a new fence on the road side of the existing security fences near the TAME, CTN

and Diesel Creosote tanks. This fence will serve to provide security for the access road and

the site establishment area;

• A new security fence topped with barbed wire will be installed in the existing Tank Farm area.

This fence will demarcate the area between the primary and secondary area. Demarcation



of the secondary area will make it possible to sign out the area to the contractor and eliminate

working under permit conditions;

• Construction of a new access road that leads from the existing road to the different areas

within the Tank Farm area;

• Piling and tank foundations. The tank walls will be founded on a concrete ring beam above

compacted fill material;

• Concrete work including the mixing of concrete;

• Steelwork including grinding and welding;

• Removal of a section of the existing bund wall;

• Construction of the extension to the exiting bunded wall. The bund wall design would be a

reinforced concrete cantilever. The expansion joints between the bund wall panels will

consist of elastic filler material, stainless steel water-bar, fire retardant rope and hydrocarbon

resistant sealant;

• Bund sizing will be done at 110% of the largest tank volume minus the volume occupied by

any adjacent tanks in the same bund in accordance with SANS 10089-1, with an allowance

of an additional 300 mm used for ballast stones placed in the tank bunds;

• Bund floor sealing and drainage control. Bund areas must be impermeable;

• Amending the oily water drainage system;

• Construction and installation of tanks, pump bays, new pipeline routes, tie-ins to existing

pipelines and other associated infrastructure;

• Installation of pumps;

• Amendment of the fire protection system; and

• Rehabilitation of disturbed areas after general site construction is completed.

The new tanks would be designed in accordance with American Petroleum Institute (API) – 650 (latest

edition). The proposed work will be fully compliant with SANS 10089 –1.

7.3 Operation

The CF 2 proposed Tanks Expansion Project will be an extension to the existing Sasol Synfuels

Operations, specifically the Tank Farm Area.

Roles and responsibilities are defined for the EMPr. These roles include dedicated SHE management

roles as well as the roles of the Sasol Project Management Team and Contractors. To facilitate

coordination and purposeful implementation, the EMPr mitigation and management measures include

programmes and plans.

The activities associated with the operational phase of the CF 2 proposed Tanks Expansion Project

includes, but is not limited to:

• Transfer and storage of Creosote diesel produced in Unit 28 (located within the Sasol Synfuels

Operations) to new creosote diesel storage tanks;

• Transfer and storage of CTN produced in Unit 015 (located within the Sasol Synfuels Operations)

to new CTN storage tank;

• Transfer and storage of TAME produced in Unit 79 (located within the Sasol Synfuels Operations)

to new TAME storage tanks;



• Feeding of existing TAME tanks with TAME from the new TAME storage tanks during shutdown;

• Transfer and storage of MFO produced in Unit 35 (located within the Sasol Synfuels Operations)

to the new storage tanks;

• Exporting of MFO via road loading facilities;

• Importing of additional EHN (used as a Cetane Enhancer in Diesel Blending) by truck;

• Transfer and storage of EHN in new EHN storage tanks;

• Transfer of EHN to new EHN Diesel Blending Pumps to existing Diesel Blender where EHN is

blended into the diesel pool as required using flow control. The final product is then routed to the

final product tanks using existing infrastructure; and

• Maintenance of all tanks, pipelines, bunded areas and other associated infrastructure.

7.4 Decommissioning and Closure

At this point in time, during the BAP, the planning and timing for decommissioning is not known. At the

time decommissioning activities become evident, this will be done in alignment with Sasol Synfuels

Operations. It is expected that the proposed mitigation measures associated with the construction

phase will suffice for the decommissioning phase. All appropriate legal procedures will be followed,

which may include the need to apply for a separate EA in terms of GNR 982 published in terms of the

NEMA. The following activities will be associated with the decommissioning of the CF 2 proposed

Tanks Expansion Project:

• Infrastructure will be removed to ground level;

• All infrastructure for which there is no approved third party post closure use will be dismantled.

Infrastructure where there is a third party use will be legally transferred to the relevant parties and

any other valuable items salvaged during demolition will be sold;

• All equipment will be rinsed with water and where required decontaminated by washing or

chemical decontamination as appropriate;

• Equipment and materials will be sold and removed from the site;

• Where required, the area affected by the CF 2 proposed Tanks Expansion Project will be

backfilled; and

• All potentially contaminated soils are to be identified and demarcated for remediation; and

• Rehabilitation of affected footprints.

8 Checking and Corrective Action Checking and implementing corrective action, should it be required, forms an important component of

the EMPr management cycle. These ensure that:

• The required EMPr management conditions are being implemented;

• The desired outcomes are being achieved;

• Ongoing inspections of operational controls and general state of operation;

• Internal audits to assess the compliance to the EMPr or to focus on a particular performance issue.

Many potential impacts are difficult to monitor quantitatively, such as waste management. However an

ongoing, but pragmatic, inspection regime will be developed that allows for potential environmental



transgressions to be identified proactively so that mitigation can be quickly and effectively

implemented.

There are several mechanisms for implementing corrective action both during construction and

operational phases. The main instruments used to address non compliances are the following:

• Verbal instructions – Minor transgressions from an established procedure;

• Written instructions – Normally following an audit; and

• Contract Notice – Following a breech in contract.

9 Site Documentation and Reporting All non-conformances will be recorded and reported to the responsible personnel. These non-

conformances will be rated according to a developed weighing methodology to determine the

significance of each incident.

The following documentation will be required on site:

• Complaints register;

• Environmental Incident Register;

• Disposal certificates of waste and sewage generated as a result of the CF 2 proposed Tanks

Expansion Project;

• Non – conformance reports;

• Written corrective action instructions;

• EA;

• Standard Sasol operating procedures;

• EMPr.

The findings of all inspections and internal audits will be structured into instructive reporting providing

information to all responsible personnel. Corrective actions must be clearly defined where required.

Within the reporting function a structured review component must be enforced. This review function

will assist in prescribing necessary corrective actions.

10 Monitoring All programmes and plans forming part of this document will be subject to monitoring. Monitoring will

have two elements, namely: routine monitoring against set standards or performance criteria, and

periodic review or evaluation. This will focus on the assessment of the effectiveness of the plan or

programme.

Each business unit associated with the construction, operation, maintenance and decommissioning

phases of the CF 2 proposed Tanks Expansion Project, the generation or management of wastes, and

contractors working for these business units, will ensure that all equipment is well maintained and fully

operational and minimises risk off leaks or spillages.

Each business unit is also responsible to adhere to the EMPr and updates as occur from time to time,

the Regulations of the National Environmental Management: Waste Act (Act No. 59 of 2008)

(NEM: WA) as applicable to waste management, handling, storage, treatment and disposal, and

reporting of such, and updates as occur from time to time.



Monitoring the performance of the CF 2 proposed Tanks Expansion Project construction activities and

the operation thereof in respect of the EMPr will fall under the inspection role of the ECO appointed

by Sasol for the construction, operation, maintenance and decommissioning phases.

It is important to note that the Operational business units remain ultimately responsible for compliance

to all the relevant performance criteria, procedures and legislation and should therefore also institute

the appropriate monitoring to ensure adherence to the relevant requirements.

The compliance monitoring is to verify that the responsible parties are adhering to the procedures,

management conditions, and specifications contained in this EMPr, and associate regulations and

waste management performance conditions.

10.1 Monitoring Programme

The monitoring programme contained in this EMPr shall be used to monitor the impacts associated

with the project and to ensure that the mitigation measures are effective and sustainable.

10.2 Environmental Monitoring

The monitoring programme for the Sasol Synfuels Operations will be sufficient to cover the monitoring

of impacts from the CF 2 proposed Tanks Development Project. The Geotechnical Study

recommended that additional parameters in the groundwater sampling regime for the Tank Farm area

be included.

Sasol will conduct internal audits by means of site visits. Table 11-1, Table 11-2, and Table 12-1

describe the monitoring requirements and general environmental management measures for the CF

2 proposed Tanks Expansion Project.

11 General Requirements The general requirements during construction/decommissioning are to:

• The Project Management Team will be informed of the starting date of any process changes or

construction activities of individual business units contributing wastes or using water from the CF 2

proposed Tanks Expansion Project;

• Ensure proper and continuous liaison between the Sasol and the contractor to ensure that all

parties are informed at all times;

• A physical access plan to the construction area (and camp if to be established) must be compiled

and the contractor must adhere to this plan at all times;

• Ensure that the contractor adhere to all conditions of the EA and EMPr for the CF 2 proposed

Tanks Expansion Project ;

• Compile an emergency response plan summarising steps to take in case of emergency (i.e. major

hydrocarbon spills);

• Documentation and record keeping of all complaints/incidents and actions taken;

• Regular site inspections and control over the construction process throughout the construction

period; and

• The Contractor shall not be released from site until the SHE and Project Manager has signed off

the release documentation and is satisfied with the contractor’s adherence to the EMPr and EA.



Table 11-1: General environmental management

Element Management Plan

Objectives • All personnel involved in the construction, operation, maintenance and decommissioning of the CF 2 proposed Tanks Expansion Project need to be made aware of the EMPr;

• All personnel involved in the operation and maintenance of the CF 2 proposed Tanks Expansion Project will be made aware of the environmental consequences of their individual actions, and in a position to minimise the environmental impact of their activities, particularly with respect to potential land, surface water and groundwater contamination, air emissions, human accidents and waste management of materials removed from the site;

• Roles and responsibilities need to be clearly defined to effectively implement the environmental management procedures.

Sources • Materials handling, storage, and processing leading to the generation of wastes or emissions and discharges to air, land or water;

Action/Controls • Sasol is ultimately responsible for environmental management and costs associated with such management and possible environmental remediation where the case of the incident is not attributed to the contractors responsibility;

• Sasol is responsible to enforce the implementation of the EMPr by its employees;

• All contractors are responsible for the implementation of the EMPr as applied to their specific activities;

• Sasol workforce and any contractors are to undergo an environmental induction covering the EMPr and roles and responsibilities with respect to environmental management; and

• All workers that have completed the induction should sign that they have understood and will implement the measures required.

Monitoring • Sasol Environmental Specialist and Project Manager shall be responsible for adequate monitoring of construction, operation, maintenance and decommissioning activities to ensure compliance with the EMPr.

Corrective Actions/Reporting

• All incidents that occurred on site are to be recorded in an Incident Register, which will be made available to the Authorities upon request;

• Sasol shall implement preventive and corrective actions if necessary in accordance with the requirements of the EMPr, outcomes of environmental audits, and changes to legislation as they may occur from time to time, and report on environmental incidents that may occur on site in accordance with the requirements of the EMPr and environmental legislation to Sasol management responsible for the site.

Table 11-2: Environmental Monitoring


Objective • To monitor compliance with the EMPr and EA;

• To monitor the effectiveness of management measures stipulated in the EMPr.

Sources • Work performed on the site that may impact on the environment.

Actions/Controls • Appropriate frequency (weekly) checks during normal operation of the site, to ensure no environmental risks are present as a result of operations/activities and/or tasks;

• Appropriate frequency records during normal operation of the site of activities/task undertaken;

• Records of waste removed from the site, or placed in storage for removal, during all phases of the development, and appropriate frequency records during normal operation of the facility.




Monitoring • Internal audits by Sasol are to be undertaken to monitor compliance with the EMPr during construction, operational and closure phases of the CF 2 proposed Tanks Expansion Project;

• Internal audits by Sasol are to be undertaken to identify any potential risk that may be arising and to promote preventive maintenance and risk reduction as may be required.

Corrective Actions/Reporting

• Should non–compliance with the EMPr be identified, corrective measures should be taken to ensure compliance.

12 Specific Environmental Management Requirements This section of the EMPr deals with key impacts associated with all phases of the CF 2 proposed

Tanks Expansion Project. All activities to be managed, mitigation and management measures to be

implemented, and the responsible individuals/organisations who should implement these measures,

are detailed in sub-sections which follow. This information is the core of this EMPr and should be

adhered to at all times. The sub-sections which follow may be updated as necessary.



Table 12-1: Environmental management measures for the proposed CF 2 project

Objective No Monitoring Project Stage

Mitigation and management measures and principles Timeframe Executing Party

Monitoring Party

Planning and Design

Incorporate design criteria to limit potential environmental impact.

1. The CF 2 proposed Tanks Expansion Project to allow for all hazardous chemical storage equipment (e.g. tanks) to meet appropriate standards for structural design and integrity.

Once-off Project manager

SHE Officer Pre-Construction

2. The CF 2 proposed Tanks Expansion Project to allow for leak detection technology. Once-off Project

manager SHE Officer Pre-Construction

3. The CF 2 proposed Tanks Expansion Project to allow for shutdown vales to shut down or isolate tanks and pipes.

Once-off Project


4. Adequate stormwater management must be incorporated into the design of the project in order to prevent contamination of watercourses and wetlands from dirty water.

Once-off Project


Site Documentation and Reporting

Contingencies for minimising negative impacts anticipated to occur during the construction/ operational/decommissioning phases

5. A physical access plan to the construction area (and camp if to be established) must be compiled and the contractor must adhere to this plan at all times

Once-off Contractor SHE Officer Pre-Construction and Decommissioning

6. Provide ECO with a layout of the site indicating the position of all of the following, as applicable:

• Ablution facilities;

• Storage areas;

• Ready-mix areas;

• Stockpile areas;

• Waste disposal facilities;

• Hazardous substances storage areas, etc.; prior to the site establishment, for approval.

Once-off Contractor SHE Officer Pre-Construction and Decommissioning

7. A complaint’s register to be kept on site On-going Contractor ECO / SHE

Officer Construction, Operational and Decommissioning

8. An environmental incident register to be kept on site On-going Contractor ECO / SHE


9. Safe disposal certificates shall be stored and provided on request On-going Contractor ECO / SHE


10. Non-conformance reports to be kept on site. On-going Contractor ECO / SHE


11. Written corrective actions to be kept on site. On-going Contractor ECO / SHE


12. A copy of the Environmental Authorisation to be kept on site. Once-off Contractor ECO / SHE






Monitoring Party

13. A copy of the EMPr to be kept on site. Once-off Contractor ECO / SHE


14. Copies of applicable Sasol operating procedures to be kept on site. Once-off Contractor ECO / SHE

Officer All

15. Update the Health and Safety Plan to include the CF 2 proposed Tanks Expansion Project.

Once-off Project

Manager ECO / SHE Officer

Pre-Construction,

16. Update the Emergency Response Plan to include the CF 2 proposed Tanks Expansion Project.

Once-off Project


Pre-Construction,

17. Update the Waste Management Plan to include the CF 2 proposed Tanks Expansion Project.

Once-off Project


Pre-Construction,

18. Update the Preventative Maintenance Programme to include the CF 2 proposed Tanks Expansion Project.

Once-off Project


Pre-Construction,

19. The Main Contractor must draw up method statements for relevant construction/decommissioning/maintenance activities.

Once-off Contractor ECO / SHE Officer

Pre-Construction and Decommissioning

Project Contract and Programme

Contingencies for minimising negative impacts anticipated to occur during the construction/decommissioning phases.

20. This EMPr must be included as part of the tender documentation thereby making it part of the required scope of work. The mitigation measures as set out in this EMPr are enforceable under the general conditions of contract.

Once-off PMT Contractor Pre-Construction and Decommissioning

21. Each contractor will employ their own Safety Officer to monitoring the safety conditions during the construction phase. Sasol Safety Officer will oversee the contractor.

Once-off Contractor PMT Pre-Construction and Decommissioning

22. The Main Contractor must draw up method statements for relevant construction/decommissioning/maintenance activities.



Environmental Awareness

Ensure contractors are aware of the required management measures stipulated in the EMPr.

23. The Contractor must ensure that all the personnel on site are familiar with and understand the specifications contained in the EMPr.


Construction, Operational and Decommissioning

24. Contractors and personnel should be required to participate in training and awareness programs. Proof of training to be kept.

On-going Contractor ECO / SHE Officer


25. All workers that have completed the induction should sign that they have understood and will implement the measures required.

On-going Contractor ECO / SHE Officer


26. The contractor is expected to have safety “tool box” talks in accordance with the risks and trends associated with the project. Proof of these talks shall be kept on site.

Daily Contractor ECO / SHE Officer

Construction and Decommissioning

27. The contractor will develop a specific emergency procedure and plan. Once off Contractor ECO / SHE Officer

Pre-Construction

Socio – Economic/Health and Safety

Increase employment opportunities

28. Encourage the local employment for the following:

• Employment opportunities for local Small and medium-sized enterprise (SMME) contractors during site clearance, preparation and construction.

• Secondary service provision of food, toilet hires, and equipment.

• Appointment of contractors as drivers, cleaners and security personnel.

Once-off Contractor Project Manager






Monitoring Party

Reduce potential dust impact 29. Reduce speed limits to 40 km/h or recommended limit based on risk evaluation Daily Contractor

Project Manager,


Minimise exposure of VOCs 30. Sasol are to ensure that exposure to volatile compounds by employees is within acceptable International Exposure Limits such as Time Weighted Average (TWA) limits and Short Term Exposure Limits (STEL).

Weekly Contractor Project Manager, Operational Controls

Operation

31. Regular inspection of tank seals to ensure there are no leaks thus minimising fugitive losses of VOCs

Weekly Contractor Project Manager, Operational Controls

Operation

Reduce potential impact on safety and security

32. Reduce speed limits to 40 km/h or recommended speed limit based on risk evaluation Daily Contractor

Project Manager,


33. An inventory of all chemicals on site must be kept together with the respective Material Safety Data Sheets (MSDS). On-going Contractor ECO


34. No alcohol /drugs are permitted on site. On-going Contractor Project Manager, ECO


35. No firearms allowed on site, unless used by security personnel. On-going Contractor Project Manager, Operational Controls


36. Correct Personal Protective Equipment (PPE) must be worn at all times by the personnel on site. Personnel must be trained on the use of PPE.

Daily Contractor Project Manager, Operational Controls


37. A register will be kept on what PPE has been issued and when. Contractors are to take disciplinary action against employees who fail to adhere to the PPE requirements.

Daily Contractor SHE Officer, Construction and Decommissioning

38. In the event of an emergency, the Contractor shall contact the Sasol emergency services. Telephone numbers of Sasol emergency services must be posted conspicuously at the site.

Once-off Contractor Project Manager, Operational Controls


39. Although not compulsory it is recommended that the foundations excavations must be inspected by a qualified geologist prior to placing any concrete and/or commencing backfilling.

Once-off Contractor Project Manager

Construction

40. No fires are allowed on the site, unless in areas demarked and managed for this purpose.

On-going Contractor Project Manager, Operational Controls


41. All workers will be made aware of fire risks. On-going Contractor, Project Manager, Operational Controls






Monitoring Party

Reduce potential impact on the sense of place as a result of land clearing

42. Limit the aerial extent of the disturbance to the exact footprint of the proposed development, including the laydown areas surrounding the primary footprint.

Weekly Contractor, Project Manager

ECO / SHE Officer

Construction Operation

Ensure that there is enough ablution facilities available and that the ablution facilities are operated in an environmentally responsible manner

43. Sufficient ablution facilities shall be provided to service the site. On-going Contractor, Project Manager

ECO / SHE Officer

Construction Decommissioning

44. The maximum walking distance from a work site to a toilet shall not exceed 200 metres. On-going Contractor, Project Manager

ECO / SHE Officer


45. Ablution facilities shall not be placed within 100-year floodline of any water course, identified wetlands or boreholes used for drinking water.

Daily Contractor, Project Manager

ECO / SHE Officer


46. Ablution facilities shall be serviced on a regular basis by an approved service provider to keep them in good functional working order and in an acceptable state of hygiene.

Monthly Contractor, Project Manager

ECO / SHE Officer


47. Contents from the chemical toilets shall not be discharged into the environment but shall be removed by an approved service provider.


ECO / SHE Officer


48. The necessary agreement between the Service Provider and the Contractor for the removal of the sewage must be in place and shall be made available on request.

Monthly Contractor Project Manager, Operational Controls


Groundwater

Reduce the potential impact on Groundwater as a result of the construction and operation of the CF 2 proposed Tanks Expansion Project

49. The tanks are to be fitted with High Level Alarms. These alarms are activated when product filling approaches the maximum capacity of the tank allowing sufficient time for transfer of product into the tank to be stopped.

When required Contractor, Project Manager

ECO / SHE Officer

Operation

50. Commissioning of the tanks will only occur once a leak test certificate has been issued. Once Off Project Manager

ECO / SHE Officer

Operation

51. The tanks will be placed within a SABS approved bunded area. The bunded area will be frequently inspected and repaired when necessary.

Weekly Project Manager

ECO / SHE Officer

Construction Operation Decommissioning

52. Storm water generated around the site will be diverted away to the clean water environment.


ECO / SHE Officer


53. No washing of vehicles shall be allowed outside demarcated areas. Washing bays for vehicles and other equipment shall be provided with appropriate soakaways, will be clearly demarcated and will not be allowed to contaminate any surface runoff.


ECO / SHE Officer


54. Sufficient areas shall be provided for the maintenance and washing of vehicles. Daily Contractor, Project Manager

ECO / SHE Officer


55. Refuelling of vehicles will only be allowed in designated areas. Daily Contractor, Project Manager

ECO / SHE Officer


56. All construction equipment shall be parked in a demarcated area. Drip trays shall be used when equipment is used for some time.


ECO / SHE Officer






Monitoring Party

57. Surface bulk storage of hydrocarbons must be situated in a dedicated area, which will include a bund or a drain where necessary to contain any spillages during the use, loading and off-loading of the substance.


ECO / SHE Officer


58. Bund sizing will be done at 110% of the largest tank volume minus the volume occupied by any adjacent tanks in the same bund, with an allowance of an additional 300 mm used for ballast stones placed in the tank bunds.

As required Contractor, Project Manager

Project Manager, Operational Controls


59. Bund areas must be impermeable. As required Contractor, Project Manager

ECO / SHE Officer


60. Bund area must have a facility such as a valve/sump to drain or remove clean stormwater.


ECO / SHE Officer


61. Contaminated water shall be pumped into a container for appropriate removal and disposal.


ECO / SHE Officer


62. Regular inspections shall be carried out to ensure the integrity of the bund walls. Weekly Contractor, Project Manager

ECO / SHE Officer


63. All vehicles shall be on a preventative maintenance schedule to ensure that the equipment is in a good working order to prevent the leakages of oil and diesel.


ECO / SHE Officer


64. All preventative servicing of earth moving equipment and construction vehicles shall be serviced off site.


ECO / SHE Officer


65. Tarpaulins will be placed on the ground to prevent oil, grease, hydraulic fluid and diesel spills during emergency repairs. All oil spills will be remedied using approved methodologies. The contaminated soils will be removed and disposed of responsibly.


ECO / SHE Officer


66. The borehole water quality and yield programme for the Sasol Synfuels Operations will be updated to include additional parameters as recommended in the Geotechnical Study and monitored.


ECO / SHE Officer


Surface Water/Wetland/Aquatic Ecosystems

Reduce the potential impact on surface water/wetlands/aquatic ecosystems as a result of the construction and operation of the CF 2 Proposed Tanks Expansion Project

67. Ensure the clean and dirty water segregation. Weekly Project Manager

ECO / SHE Officer


68. Contaminated runoff water, generated during rainstorm events, will be contained in specifically designed structures to enable sedimentation and desilting of the runoff.


ECO / SHE Officer


69. Spill kits to be made available at areas of possible spillages of hazardous substances. Weekly Contractor, Project Manager

ECO / SHE Officer


70. Drivers and operators shall be trained to use spill kits and contain spillages to the smallest possible areas and the training records shall be made available on request.

When needed Contractor, Project Manager

ECO / SHE Officer


71. Remediation of spillages must be conducted on a continual basis. When needed Contractor, Project Manager

ECO / SHE Officer






Monitoring Party

72. Contaminated runoff will be contained and re-used where necessary. Weekly Contractor, Project Manager

ECO / SHE Officer


73. Maintain current monitoring and management of the overall Sasol Synfuels Operations. Weekly Contractor, Project Manager

ECO / SHE Officer


74. Adequate stormwater management must be incorporated into the design of the project in order to prevent contamination of watercourses and wetlands from dirty water.


ECO / SHE Officer

Pre-Construction Construction Operation

75. No direct discharge of polluted water to the environment is permitted, unless authorised by Synfuels Environmental Department


ECO / SHE Officer


76. Ensure that topsoil is properly stored, away from the streams and drainage areas. Weekly Contractor, Project Manager

ECO / SHE Officer


77. No construction is allowed within 100 metres from the nearby steams and 500 meters from wetland and/or riparian areas without consent from the DWS.

Once-off Contractor, Project Manager

ECO / SHE Officer


78. All vehicles shall be on a preventative maintenance schedule to ensure that the equipment is in a good working order to prevent the leakages of oil and diesel.


ECO / SHE Officer


79. An inspection programme shall be implemented to ensure that all the mechanical equipment is inspected regularly to ensure the optimal functioning of the equipment.


ECO / SHE Officer


80. Refuelling of equipment shall occur in designated areas by trained people. Weekly Contractor, Project Manager

ECO / SHE Officer


81. Bund sizing will be done at 110% of the largest tank volume minus the volume occupied by any adjacent tanks in the same bund in accordance with SANS 10089-1, with an allowance of an additional 300 mm used for ballast stones placed in the tank bunds


ECO / SHE Officer


82. Contaminated soil shall be removed and disposed of to an appropriate licensed landfill site, or can be removed by a service provider that is qualified to clean the soil.


ECO / SHE Officer


Air Quality

Reduce the potential for nuisance dust, the emission of carbons and other ambient air pollutants

83. Mitigation measures may be implemented to reduce dust levels from the entrainment of dust. These measures will range from watering of roads, application of a chemical dust suppressant and/or paving of roads.


ECO / SHE Officer


84. A speed limit of 40 km/h (or limit as determined by a risk assessment) shall apply to limit vehicle entrained dust from the unpaved roads.

Weekly Contractor Project Manager


85. All construction equipment must be scheduled for preventative maintenance to ensure the functioning of the exhaust systems to reduce excessive emissions and limit air pollution.


ECO / SHE Officer


86. Chemical toilets must be emptied / serviced on a regular basis. Proof of this must be kept on file.


ECO / SHE Officer






Monitoring Party

Reduce VOC emissions that may arise from operation of the Tanks

87. Regular maintenance will ensure that the technology will continue to meet original equipment manufacturer (OEM) specifications and acceptable international emissions standards.


ECO / SHE Officer

Operation

88. Regular inspection of tank seals to ensure there are no leaks thus minimising fugitive losses of VOCs.


ECO / SHE Officer

Operation

89. Development and implementation of routine emissions and ambient air quality monitoring program to determine whether there are any significant increases in emissions and impacts at sensitive receptors


ECO / SHE Officer

Operation

Climate Change

Reduce the emissions of Green House Gasses as a result of the use of construction vehicles and machinery

90. All the construction vehicles shall undergo maintenance on a regular basis to ensure the combustion engine vehicle efficiency.


ECO / SHE Officer


91. Engine idle speeds during operating times should be reduced Weekly Contractor, Project Manager

ECO / SHE Officer


92. Where applicable, use a fuel sources with low Sulphur content Weekly Contractor, Project Manager

ECO / SHE Officer


93. Ensure regular servicing and maintenance of all combustion engine operated machinery


ECO / SHE Officer


Heritage/Paleontological Resources

Reduce the potential impact on areas of archaeological/paleontological resources

94. Contractors and personnel involved in clearing and earthworks should be required to participate in training and awareness programs to ensure that they are aware of work stoppage and reporting procedures should archaeological sites or graves be exposed during development activities.

Once Off Project Manager

ECO / SHE Officer


95. All employees and contractors are required to stop work and report any additional heritage or archaeological site discovered in the vicinity of the construction activity, to a heritage practitioner so that an investigation and evaluation of the findings can be made. No heritage artefacts or graves may be destroyed or moved without the necessary permits.

When required Contractor ECO / SHE Officer


96. All operational activities will be situated away from any identified grave sites or heritage sites where South African Heritage Resources Act (SAHRA) permits have not been granted.


ECO / SHE Officer






Monitoring Party

Flora

Reduce the potential impact on flora

97. Development footprint:

• Vegetation clearance shall be kept to a minimum and all activities must be contained within the Tank Farm footprint to minimise disturbance outside these areas.

• Vehicles must be restricted to travelling on designated access roads to limit the ecological footprint of the proposed activity.


ECO / SHE Officer


98. Weed Control and Management:

• Removal of the alien and weed species encountered on the property must take place in order to comply with existing legislation.

• Care should be taken with the choice of herbicide to ensure that no additional impact and loss of indigenous plant species occurs due to the herbicide used.

• Removal of species should take place throughout the construction and operational phases.

When Required Project Manager

ECO / SHE Officer


99. Rehabilitation:

• All disturbed habitat areas must be rehabilitated as soon as possible to ensure that floral ecology is re-instated.

• Reseeding with indigenous grasses should be implemented.


ECO / SHE Officer


100. Floral:

• Sensitive floral species, if encountered, must be rescued and relocated. The following should be ensured:

• If any threatened species, or nationally or provincially protected floral will be disturbed, ensure effective relocation of individuals to suitable similar habitat.

• All rescue and relocation plans should be overseen by a suitably qualified specialist.


ECO / SHE Officer


101. All sensitive open space areas will be demarcated and access into these areas shall be prohibited.

When required Contractor ECO / SHE Officer


Fauna

Reduce the potential impact on Fauna

102. The proposed development footprint areas should remain as small as possible and be confined to already disturbed areas within the Tank Farm area.


ECO / SHE Officer


103. No trapping or hunting of fauna is to take place. Weekly Contractor, Project Manager

ECO / SHE Officer


104. Edge effects of all construction and operational activities, such as erosion and alien plant species proliferation, which may affect faunal habitat, need to be strictly managed in disturbed areas.


ECO / SHE Officer


105. Should any SCC be noted within the study area, these species should be relocated to similar habitat within or in the vicinity of the study area with the assistance of a suitably qualified specialist.

Monthly Project Manager

ECO / SHE Officer


106. All informal fires in the vicinity of construction areas should be prohibited. Weekly Contractor ECO / SHE Officer


107. It is recommended that a speed limit of 40km/h is implemented on all roads running through the study area during the construction phase in order to minimise risk to fauna from vehicles.

Weekly Contractor ECO / SHE Officer


108. An alien vegetation control plan must be developed and implemented in order to manage alien plant species occurring within the study area, and to prevent further faunal habitat loss.


ECO / SHE Officer






Monitoring Party

Visual

Reduce the potential visual impact as a result of movement of machinery, the establishment of infrastructure and dust generation

109. The number of construction vehicles and machinery to be used shall be kept to a minimum.


ECO / SHE Officer


110. Site clearance shall be kept to a minimum and limited to the footprint of Tank Farm area.



111. Where required, all lighting shall be kept to a minimum within the requirements of safety, security and efficiency.

Monthly Contractor ECO / SHE Officer


112. Stockpiles will be kept at a height consistent to the surrounding environment. Weekly Contractor ECO / SHE Officer


113. Construction camps will be demarcated. All waste and material stockpiles created during the construction phase will be screened from the public when not in use.



114. The footprint area of the decommissioning activities must be landscaped to represent the surrounding natural environment. Landscaping must be done so that pooling of water does not occur.

Following decommissioning

Contractor ECO / SHE Officer

Decommissioning

115. Disturbed areas will be top soiled in order to promote vegetation growth. Seeing of indigenous species will be conducted should natural succession not establish.



Decommissioning

Noise

Reduce the potential generation of nuisance noise

116. Correct personal Protective Equipment (PPE) must be worn at all times by the personnel on the construction site.



117. If noise levels exceed 85 dBA, acoustic mitigation measures must be installed. Weekly Contractor, Project Manager

ECO / SHE Officer

Construction and Operational

118. Establish noise abatement measures for construction vehicles and activities. When required Contractor, Project Manager

ECO / SHE Officer


119. All equipment should be provided with standard mufflers. Muffling units on vehicles and equipment must be kept in good working order.


ECO / SHE Officer


120. All equipment must be kept in good working order, with immediate attention being paid to defective silencers, slipping fan-belts, worn bearings and other sources of noise.



121. Equipment must be operated within specifications and capacity (e.g. no overloading of machines).



122. Regular maintenance of equipment must be undertaken. Monthly Contractor ECO / SHE Officer


123. Equipment shall be switched off when not in operation. Daily Contractor ECO / SHE Officer


124. Appropriate directional and intensity settings must be maintained on all hooters and sirens.







Monitoring Party

Soils, Land Use and Land Capability

Reduce the potential impact on soils, land use and land capability as a result of compaction, clearing of vegetation and improper storage and handling of oils, fuels and other hazardous substances

125. When mortar is used on site, the following guidelines apply:

• Carefully control all on-site operations that involve the use of mortar and concrete;

• Limit mortar mixing to single sites where possible;

• Use plastic trays or liners when mixing mortar and concrete: Do not mix mortar and concrete directly on the ground;

• Dispose of in the approved manner



126. No waste or spillage of effluent should be allowed to occur within or near sensitive habitat boundaries.



127. A pollution control system/spill handling procedure must be implemented to limit impact of such occurrences and prevent discharge to the receiving environment.


ECO / SHE Officer


128. Contaminated soil shall be removed and disposed of to an appropriate licensed landfill site in terms of NEM: WA, or can be removed by a service provider that is qualified to clean the soil.



129. No field maintenance of equipment shall be permitted. Weekly Contractor ECO / SHE Officer


130. Drip trays shall be used when dispensing fuel or oils from the earthmoving equipment outside designated areas.



131. Drip trays shall only be emptied into a dedicated container. Weekly Contractor ECO / SHE Officer


132. Drip trays shall be used when dispensing fuel or oils from the earthmoving equipment outside designated areas.



133. Dedicated containers must be emptied into containers for removal by an approved contractor.



134. Erosion control measures shall be implemented where deemed necessary. Weekly Project Manager

ECO / SHE Officer


135. Prevent erosion from stockpiles to prevent increase in turbidity of watercourses. Monthly Project Manager

ECO / SHE Officer


136. Stockpiles shall be maintained until the topsoil is required for rehabilitation purposes. Monthly Project Manager

ECO / SHE Officer


137. All erosion damage must be repaired as soon as possible. Monthly Project Manager

ECO / SHE Officer


138. Tarpaulins will be placed on the ground to prevent oil, grease, hydraulic fluid and diesel spills during emergency repairs.



139. The footprint area of the decommissioning activities must be landscaped to represent the surrounding environment. Landscaping must be done so that pooling of water does not occur.

Following operation


Decommissioning

140. Demolish and remove all infrastructure not required post-closure. Following operation


Decommissioning

141. Should there be reason or suspect reason the soils are contaminated following decommissioning activities, the soils will be assessed by a competent person and remediated by Sasol within a reasonable timeframe.



Decommissioning





Monitoring Party

Traffic

Reduce the potential impact on traffic as a result of increased vehicle numbers and the impact on road degradation

142. Speed limits will be reduced to 40 km/h (or speed limit determined after risk evaluation) to reduce dust and noise generation.


ECO / SHE Officer


143. Alternative transport routes will be made available during the construction of the TAME, CTN and Diesel Creosote bunded area. Heavy vehicle deliveries must be timed so not to impact on local traffic in the area.

Monthly Project Manager,

ECO / SHE Officer

Construction, and Decommissioning

144. Where possible the transportation of construction materials and rubbish shall be undertaken outside traffic peak hours to minimise inconveniencing other road users.



145. The number of construction vehicles and trips shall be kept to a minimum. Monthly Project Manager,

ECO / SHE Officer


146. All the construction vehicles shall undergo maintenance on a regular basis to ensure the combustion engine vehicle efficiency.



Hazardous Materials

Reduce the potential environmental impact as a result of poor hazardous material management practises

147. Commissioning of the tanks will only occur once a leak test certificate has been issued. Monthly Contractor Project Manager

Construction

148. Establish delivery procedures to ensure that hazardous materials are handled with care and stored correctly.


Construction Operation, and Decommissioning

149. Ensure that subcontractors and delivery companies are informed of delivery procedures and are made aware of restrictions, in terms of where materials can be stored/placed.



150. An appointed representative of the Contractor must supervise all deliveries, particularly those of a hazardous nature.

Monthly Contractor Project Manager


151. The valves of cylinders, both Full and Empty, must be kept properly closed. Monthly Contractor Project Manager


152. Where extreme temperatures prevail (>60˚C Cylinder Surface Temperature), cylinders shall be stored so that they are protected from the direct rays of the sun.

Monthly Contractor Project Manager


153. Cylinders shall always be handled, stored, used and transported upright. They shall not be dropped, dragged or rolled on their sides or allowed to skid. Cylinders that are too large to be carried shall be tilted and rolled on the rims of their foot rings or bases.

Daily Contractor Project Manager


154. Cylinders should always be stored in a well-ventilated area, chained and away from sparks, flames or any source of heat or ignition.



155. All combustible materials to be a radius of 3 m away from any gas storage areas. In the case of any flammable or any other gas storage areas, open flames, welding and cutting operations, smoking etc., shall be prohibited in or near the storage area.



156. Erect suitable warning and information signage near the storage facility. Once Off Contractor SHE Officer Construction Operation, and Decommissioning

157. The tanks are to be fitted with High Level Alarms. These alarms are activated when product filling approaches the maximum capacity of the tank allowing sufficient time for transfer of product into the tank to be stopped.

Monthly SHE Officer Project Manager

Operation,





Monitoring Party

158. The Contractor shall not be released from site until the SHE and Project Manager has signed off the release documentation and is satisfied with the contractor’s adherence to the EMPr and EA.


ECO / SHE Officer


159. All workers that have completed the induction should sign that they have understood and will implement the measures required.


160. An inventory of all chemicals on site must be kept together with the respective Material Safety Data Sheets (MSDS).



Waste Management

Reduce the potential environmental impact as a result of poor waste management practises

161. General:

• No soil, rubble or any other material may be deposited in or within 32 m of any watercourse/wetland;

• Sufficient bins/skips are to be provided for the safe and environmentally responsible disposal of waste;

• Littering on site is forbidden and the site must be cleared of litter at the end of each working day;

• Where possible, materials used or generated by construction activities must be recycled;

• Waste will not be stored for a period exceeding 90 days or volumes exceeding 100 cubic meters.

• Waste generated on the proposed site should be collected by authorised waste contractors and frequently disposed of at a licensed landfill site as the last resort.

Weekly Contractor, Project Manger

ECO / SHE Officer


162. Separation of waste:

• All waste shall be separated into general waste and hazardous waste.

• Hazardous waste shall not be mixed with general waste increasing the quantities of hazardous waste to be managed.

• General waste can further be separated in waste that can be recycled and/or reused.

• No littering shall be allowed in and around the site, a sufficient number of bins shall be provided for the disposal of waste.

• Where necessary dedicate a storage area on site for collection of construction waste.


ECO / SHE Officer


163. Storage of waste:

• General waste will be collected in an adequate number of litter bins located throughout the construction site.

• Bins must have lids in order to keep rain water out.

• Bins shall be emptied regularly to prevent the bins from overflowing.

• All work areas shall be kept clean and tidy at all times.

• All waste management facilities will be maintained in good working order.

• Waste shall be stored in demarcated areas according to type of waste.

• Runoff from any area demarcated for waste will be contained and managed.

• Flammable substances must be kept away from sources of ignition and from oxidizing agents.

• No builder’s rubble shall be disposed of to the riparian area.

• If builder’s rubble is not removed immediately it shall be stockpiled outside the 1:50 year floodline and outside the sensitive riparian areas.

• Demolition waste and surplus concrete shall be disposed of responsibly.


ECO / SHE Officer






Monitoring Party

• Waste shall not be buried or burned on site.

164. Disposal of hazardous waste:

• No indiscriminate dumping shall be allowed in or near the construction site.

• Hazardous containers shall be disposed of at an appropriate licensed site.

• Hazardous waste will be removed and managed by an approved service provider.

• A safe disposal certificate will be provided by the approved service provider as proof of responsible disposal of hazardous waste.

• The safe disposal certificate shall be stored and provided on request.


ECO / SHE Officer


165. Disposal of general waste:

• No dumping shall take place in or near the construction site.

• All general waste shall be disposed of to a licensed landfill site.

• Demolition waste and builder’s rubble shall be disposed of to an appropriate licensed landfill site.


ECO / SHE Officer


Monitoring/Performance Assessment

Contingencies for minimising negative impacts anticipated to occur during all phases. Improvement of existing management measures.

166. Maintain current monitoring and management of the overall Sasol Synfuels Operations system.


SHE Officer Operation

167. Update the groundwater monitoring report to include the parameters recommended to be added to the sampling regime as per Geotechnical Report.



168. Weekly site inspections to be done. Weekly Project Manager


169. Sasol will undertake an internal assessment of this EMPr prior to the commencement of construction.



170. Sasol will undertake an internal assessment of this EMPr after construction activities have ceased.



171. Sasol will undertake an internal assessment of this EMPr on a monthly basis during construction/decommissioning phases and annually during operation.

When Required Project Manager

SHE Officer Construction Operation

172. An external assessment on this EMPr to be done on an annual basis from start of construction.

Annually Project Manager

SHE Officer Construction Operation



13 Environmental Awareness Plan It is important to ensure that the Contractors and employees associated with the CF 2 proposed Tanks

Expansion Project receive the appropriate level of training and awareness to ensure that continual

environmental due diligence and conservation is exercised at all levels of work carried out. Employees,

contractors and sub-contractors must be made aware of their responsibilities in terms of relevant

legislation, guidelines as well as this EMPr and EA.

Environmental conditions will be included in the contracts issued to the contractors, making them

aware of the potential environmental impacts and risks associated with the CF 2 proposed Tanks

Expansion Project. The importance of implementing the conditions in the EMPr and the necessity of

good housekeeping practices will be made known to the contractors and employees of Sasol and the

contractors in order to prevent accidental spillages and avoid subsequent environmental impacts.

Training needs will be identified based on the EMPr requirements and capacity of Sasol employees

and contractors. In order to ensure environmental due diligence and protection of environmental harm,

it is vital that all employees are trained to perform their designated role in alignment with the EMPr and

EA.

13.1 Aim of the Environmental Awareness Plan

The aim of the environmental awareness plan is to:

• Promote environmental education and conservation within the working place;

• Inform employees and contractors on the applicable environmental procedures and programmes

adopted by Sasol;

• Provide job specific training on the specification of environmental conservation and protection

applicable to the respective construction activities.

13.2 Environmental Awareness Training

The training pertaining to the environmental awareness will include the following:

• All personnel (construction and operation staff) will undergo induction, which as a minimum will

include Safety, Health and Environmental awareness;

• All attendees will sign an acknowledgement register upon receiving and understanding the

induction;

• Environmental risks will be identified together with the specific job training that may be required to

address these risks. Construction and operation staff will be trained on the implementation of

emergency procedures where relevant.

13.3 Content of the Environmental Awareness Training

The environmental awareness training material will include, but not limited to, the following:

• Definitions as stipulated in this EMPr;

• How and why environmental protection is necessary;

• Nature of the CF 2 proposed Tanks Expansion Project which can affect the environmental status

quo;

• Management measures required to prevent environmental impacts;

• Awareness of emergency and spills response procedures;



• Environmental conditions in the induction should focus on the following:

• Good house-keeping practices;

• Hydrocarbon spillages;

• Waste Management;

• Proper use of sanitation facilities; and

• Chemicals and materials storage, use and handling.

Environmental training can be done verbally or in written format, depending on the most effective

means of training for the target audience. The contents of this EMPr must be included in the training

material, and proof of such training kept on record.

14 External Auditing The key to a successful EMPr is appropriate monitoring and review to ensure effective functioning of

the EMPr and to identify and implement corrective measures in a timely manner. In the event where

discrepancies are identified, the problem must be investigated and attended to. All the results obtained

during environmental monitoring must be documented for audit purposes.

An audit of the environmental monitoring and management actions undertaken is essential to ensure

that it is effective in operation, is meeting specified goals, and performs in accordance with relevant

regulations and standards. Audits should be conducted during the construction phase of the facility to

ensure adherence to the management measures contained in the EMPr.

The construction audit schedule will be determined by the conditions of the EA. It is not anticipated

that external audits be conducted during the operation phase of the CF 2 proposed Tanks Expansion

Project. Any impacts that may arise from the operational phase will be monitored as part of the Sasol

Synfuels Operations monitoring programmes.

The frequency of the construction audits may vary and will be synchronised with the construction

schedule. Monitoring should take place frequently by the on-site SHE Officer.

15 Commissioning of Tenders All contractors and sub-contractors tendering for any aspect of the CF 2 proposed Tanks Expansion

Project will be made aware of the contents of this EMPr and the consequences and penalties resulting

from non-conformances will be communicated to them.

All appointed contractors and sub–contractors will be made aware of the EMPr and attend an induction

focusing on the main aspects of the EMPr requirements.



16 Declaration of Contractor's Acceptance I, ______________________________________________________, (full name) representing

_______________________________________________________, (company name) have read,

understood and accept the above environmental management plan as a framework for my company’s

environmental performance during the above mentioned project.

Signed: ________________________________ Date: ____________________________



Prepared by

Andrew Caddick

Senior Environmental Scientist

Reviewed by

Dr Laetitia Coetser

Associate Partner

Accepted by

Manda Hinsch

Partner

All data used as source material plus the text, tables, figures, and attachments of this document have

been reviewed and prepared in accordance with generally accepted professional engineering and

environmental practices.

sasol south africa limited - srk · sasol south africa limited report number 539945/empr report...

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