secunda chemicals operations: nitro fertilizers

SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

16.4.28.L2 - CHANGER AT THE LIQUID FERTILIZER PLANT

13 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

16.4.28.L2 - CHANGER AT THE LIQUID FERTILIZER PLANT

SECUNDA CHEMICALS OPERATIONS:

NITRO FERTILIZERS

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: JUNE 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

T: +27 11 361 1392

F: +27 11 361 1381

WSP.COM

Q U A L I T Y M A N A G E M E N T

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

Exemption Ref:

16.4.28.L2

Final – Compliance

Audit

Exemption Ref:

16.4.28.L2

Date April 2019 June 2019

Prepared by Ashlea Strong Ashlea Strong

Signature

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 034 034

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

S I G N A T U R E S

PREPARED BY

Ashlea Strong

Principal Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

of their compliance with the conditions included in the Environmental Authorisation.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance Specialist Broni van der Meer

Nitro Fertilizers Production Senior Manager,

Secunda Chemicals Operations

Tobie Visser

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Auditor Bronwyn Fisher

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA CHEMICALS OPERATIONS: NITRO FERTILIZERS

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Changer at the Liquid Fertilizer Plant

(Authorisation Number: 16.4.28.L2) ...................... 1

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

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

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

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

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

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

3.5 Audit Team ............................................................... 5

3.6 Assumptions and Limitations ................................ 6

4 AUDIT FINDINGS ...................................... 7

5 SUMMARY OF THE AUDIT FINDINGS ... 19

5.1 Environmental Exemption .................................... 19


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL EXEMPTION . 7

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 19

FIGURES

FIGURE 1: LOCATION OF THE LIQUID FERTILIZER PLANT AT SASOL SECUNDA (SOURCE: GOOGLE EARTH, 2018) ............................... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 20

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 20

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 21

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 21

APPENDICES

A ENVIRONMENTAL EXEMPTION (16.4.28.L2)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP

Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit

and compile an audit report according to the requirements of the National Environmental Management Act (No.

107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the

Environmental Exemption (Reference number: 16.4.28.L2 issued on 28 November 2000) for the period

December 2014 to February 2019.

1.2 CHANGER AT THE LIQUID FERTILIZER PLANT

(AUTHORISATION NUMBER: 16.4.28.L2)

The Sasol Fertilizer division markets limestone ammonium nitrate (LAN), ammonium sulphate, ammonium

nitrate-based granular and liquid fertilisers and nitric acid to industrial clients, farmers, traders and fertiliser

companies.

The changer at the Liquid Fertilizer Plant is permitted in terms of Section 22 of the Environment Conservation

Act, 1989 (Act 73 of 1989) (ECA). The Exemption was received from the Mpumalanga Department of

Agriculture, Conservation and Environment (MDACE) on 28 November 2000 (Reference Number: 16.4.28.L2)

with conditions attached within the Record of Decision (RoD) (Appendix A).

It was reported and observed that the Liquid Fertilizer Plant is no longer operational, and is currently being

demolished.

Figure 1 provides an indication of the location of the Liquid Fertilizer Plant.


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Figure 1: Location of the Liquid Fertilizer Plant at Sasol Secunda (Source: Google Earth, 2018)


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

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

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

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

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

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

The objective of the audit was to:

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

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

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

— Ensure the commitments contained in Condition 9.01 of the Exemption are completed, more specifically:

— “Records relating to compliance/ non-compliance with the conditions of this authorization must be

kept in good order. Such records must be made available to the Department within seven (7) days from

the date of written Record of Decision.”


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

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

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

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (15 March 2019);

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

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

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

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

3.2 SITE INSPECTION

Environmental Consultant, Bronwyn Fisher, conducted the site inspection on 15 March 2019. The findings and

observations of the site visit are recorded and summarised in Section 4 with evidence included in Table 2. Key

personnel interviewed included:

— Tobie van der Vyver - Production Senior Manager Nitro Fertilizers;

— Pieter Stadler - Mechanical Senior Manager – Nitro;

— Ilze Swanepoel - SCO Senior Manager Environment; and

— Albert Wolfaardt - SHE Occupational Safety Manager Nitro.

It should be noted that no photographs were able to be taken during the site walk through due to the fact that the

Liquid Fertilizer Plant site was a construction site at the time of the audit and the auditor was unable to enter the

site due to the health and safety risks associated.

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Sasol Compliance Statement – Water;

— 3.05_RESM Weekly Monitoring_2004-2019;

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20;

— Groundwater – Borehole map;

— Surface Water – Biannual monitoring points;

— Surface Water – RESM Points;

— Waste Management Procedure_SGR-SHE-000017_Rev10_2017-09;

— Compliance_Emergency Management_Secunda Complex;

— Environment emergency procedure_SGR-SHE000023_rev6_2015-11;

— Works emergency procedure_CGR-EMP-000001_Rev04_2016-02;

— EA_EX Handover_SCO_Poly_Nitro_Fert;

— Sasol Compliance Statement – Complaints;

— Environmental complaints procedure_SGR-SHE-000022_Rev04_2015-08;


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

— Environmental Complaints Register_2019-02-18;

— AEL Sasol Nitro 0020-2015-F02 (2016); and

— Various email correspondence.

3.4 AUDIT COMPLIANCE ASSESSMENT

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

the conditions and associated requirements as specified in the Exemption.

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

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

associated target completion dates included.

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

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

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

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

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

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

relevant actions were implemented.

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

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

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

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

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

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

is stated and explained within the condition commentary.

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

dates).

3.5 AUDIT TEAM

The Environmental Consultant, Bronwyn Fisher, was hosted by Broni van der Meer; Tobie van der Vyver;

Pieter Stadler; Ilze Swanepoel and Albert Wolfaardt to whom we express our gratitude for their time and

attention during our visit. A brief summary of the external auditors’ experience is provided below.

— Auditor: Bronwyn Fisher

Bronwyn Fisher has 5 years of experience as an Environmental Consultant, undertaking Environmental

Impact Assessments (EIAs) and Basic Assessments. She has experience in developing Environmental

Management Programmes (EMPrs), undertaking site audits (ECO), Water Use Licence Applications and

undertaking Public Participation. Bronwyn’s project experience includes construction of pipelines, diesel

storage installations, waste disposal sites, water treatment facilities, oil refineries, tank farm installations,


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recycling facilities, mixed-use developments, industrial developments and renewable energy technology

projects.

— Lead Auditor and Quality Assurance: Ashlea Strong

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

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

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

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

scoping and impact assessment studies, environmental management plans, waste and water management, as

well as the provision of environmental management solutions and mitigation measures. She has been

involved in the management of a number of large EIAs within South Africa and has environmental auditing

and training experience and expertise. Ashlea has carried out over 50 compliance audits and is well versed

in the audit process.

— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts

no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

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

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

document.

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

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

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

reference to this report. If this report is used as part of a main report, the report in its entirety must be included

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1.01 This authorization refers only to the project specified and

described in the Record of Decision. Other than the area

indicated for in the map any changes in the Fedmis Delmas

Fertilizer Plant, separate application(s) must be lodged with

the Department for any development and/or activity on or

near the relevant property which is covered by Section 21 &

22 of the Act and Government Notices R1182 & R1183 of 5

September 1997.

N/A Noted. None.

1.02 Authorization is granted in terms of Section 22(3) of the

Environment Conservation Act 1989 (Act No. 73 of 1989)

and does not exempt the holder from compliance with any

other relevant legislation.

N/A Noted. None.

1.03 No development will take place in the area of concern

without the necessary permits/approvals and/or service

agreements from other relevant Authorities.

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

(construction pre-2014).

It is therefore considered not applicable.

None.

1.04 Copies of documents mentioned under 1.3 above must be in

possession of this Department before any construction

commences.

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



None.

1.05 This Department may change add or amend any of the

conditions mentioned in this authorization if in the opinion

of the Department it is environmentally justified.

N/A Noted. Sasol has advised that no amendments have been received

in association with this Exemption.

None.


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1.06 A copy of this authorization shall be available at the site

office at all times and staff members and contractors shall be

conversant with its contents.

C Copies of all authorizations and licences are sent to, and details

communicated with, relevant business units. Copies of these

documents are also available at the SHE: Environment department

and on SAP EC and SharePoint.

Evidence:

— EA_EX Handover_SCO_Poly_Nitro_Fert

None.

1.07 The proposed mitigation measures, as set out in the

information provided in the application shall strictly be

adhered to.

NC The mitigation measures, as set out in the information provided in

the application were not available for review. Therefore, this

condition cannot be verified.

None.

1.08 The record of Public participation shall be sent to this

Department for record keeping purpose. N/A This condition is considered outside of the audit period



None.

ESTABLISHMENT OF THE DEVELOPMENT

2.01 This authorization is repealed if development has not started

within three (3) years from the date of issue. N/A This condition is considered outside of the audit period



None.

2.02 If decision is taken to discontinue the operation, sell or

transfer ownership or infra-structure on the site in any way,

this Department must be informed of such decision within

twelve (12) months prior to the date of implementing such a

decision.

NC During the site walkover the auditor was informed that the plant

has been decommissioned.

The auditor was informed that the Department was not informed of

the decision to discontinue the operation within 12 months prior to

the implementation of the decision.

It is recommended that

Sasol inform the

Department that the Plant


Target Completion:

Short Term

2.03 In the event of 2.2 above, this Department shall be notified

about the rehabilitation plans. N/A During the site walkover the auditor was informed that the plant

has been decommissioned. . It is noted that a new plant is being

None.


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built on the site and therefore there are no current plans to

rehabilitate the site.

CONSTRUCTION AND OPERATION

3.01 This development will take place according to conditions

and requirements by the Department of Agriculture,

Conservation & Environment.

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


None.

3.02 If any change(s) need to be made in the plan of the said

development or replacement of any of its structures, this

Department must be informed thirty (30) days in advance to

decide whether such change(s) will need authorization or

not.

N/A During the site walk over, the auditor was informed that the Plant


It was also noted that Sasol are in the process of building a new

facility within the footprint of the previous plant, however it is

noted that the new facility is not related to changer at Liquid

Fertilizer Plant. Sasol informed the Auditor that no authorisations

were required for the new facility.

None.

WATER POLLUTION

4.01 It is the responsibility of Fedmis Delmas Fertilizer and the

Contractor on site to prevent any surface as well as ground

water pollution.

NC The IWWMP aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

The Auditor verified that the Liquid Fertiliser Plant is included in

the IWWMP.

Groundwater:

Ground water monitoring is conducted biannually and quarterly.

JMA Consulting is an independent contractor appointed to

complete sampling and bi-annual reporting for Sasol. The auditor

verified that the Groundwater Quality Report compiled by JMA

Consulting. Report number: JMA/Prj6129 Rev-01; Dated:

It is recommended that a

remediation action plan is

compiled and executed to

rectify the elevated water

quality variables in both the

surface and ground water at

the site.

Target Completion:

Medium Term


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November 2018 included groundwater monitoring of boreholes

established for the Liquid Fertiliser Plant.

The Auditor noted that 19 out of 36 boreholes are monitored

biannually at the Liquid Fertiliser Plant. The water quality analysis

of the borehole samples highlight elevated EC, TDS, Ca, Mg, Na,

SO4, NO3, Mn, NH4, NO2 and E.Coli showing that the

groundwater in this area is polluted.

Surface Water:

Surface water monitoring is done on a weekly basis as well as real

time for the various RESMs. Sasol monitor the Bossiespruit,

Brandspruit, Kleinspruit, Klipspruit and Trichardspruit,

Surface water is also monitored biannually at two sumps at the

Liquid Fertilizer Plant. The water quality analysis of these two

points highlights elevated concentrations for Ca, Mg, Na, K, Cl,

SO4, NO3, Mn, NH4 and B, showing that these surface water points

are polluted.

Evidence:

— Sasol Compliance Statement – Water

— 3.05_RESM Weekly Monitoring_2004-2019

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

20

— Groundwater – Boreholes:


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Monitoring boreholes established at the Liquid Fertiliser Plant

— Surface Water – Biannual monitoring points

Biannual Surface Water monitoring points at the Liquid Fertiliser Plant


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— Surface Water – RESM Points:

Location of the RESM monitoring points monitored on a continuous basis

4.02 In case of non-compliance with regulations, the burden of

proof rests with Fedmis Delmas Fertilizer and/or relevant

contractor.

N/A Noted None

WASTE MANAGEMENT

5.01 All waste generated during the proposed changes in the said

plant or any other related activities will be handled and

disposed of in the registered landfill site and must be to the

satisfaction of this Department and/or any relevant authority.

N/A It is noted that the plant has not been operational since the first half

of 2015 therefore this condition is considered Not Applicable

None.

5.02 Any hazardous waste that may result in the process shall be

disposed of in the environmentally acceptable way and is

directed by this Department and any other relevant authority.

N/A It is noted that the plant has not been operational since the first half

of 2015 therefore this condition is considered Not Applicable

None.


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RISK ASSESSMENT

6.01 All employees who will be working in the construction and

operation of the said development shall be well equipped

with the emergency procedures in case of an accident.

C When an environmental emergency occurs the area / unit must

report it to Emergency Management at Tel: 10- 4444 / 10 2444

who will inform the Environmental Management Services standby

person and Market and Market Integration.

The environmental emergency is addressed in accordance with the

following procedures:

— Sasol Secunda Work Emergency Procedure (Reference

Number: CGR-EMP-000001); and

— Response to environment related emergencies and a guideline

to other incidents (Reference Number: SGR-SHE-000023)

Operation specific Emergency Management Plans can be found on

Sasol’s IMS.

In addition, Sasol advised the auditor that it has a Governance SHE

Risk and Assurance department that assesses environmental risks

and drives implementation by business.

The SHE Environment department facilitates Environmental Risk

Assessments per business entity to ensure that gaps are addressed

through implementation of mitigation measures via the Integrated

Management System. Sasol further addresses all Key Undesirable

Events (KUEs) from a group perspective.

A Procedure was viewed by the auditor that defines the

requirements, responsibilities, and the process to be followed in the

management, execution, and control of environmental risk

assessments.

Evidence:

— Compliance_Emergency Management_Secunda Complex

— Environment emergency procedure_SGR-

SHE000023_rev6_2015-11

None.


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— Works emergency procedure_CGR-EMP-

000001_Rev04_2016-02

6.02 The owner of the property must ensure that all issues and

concerns of the affected parties are addressed as stated in the

information provided in the application.

C All environmental complaints received from interested and

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

recorded in a complaints register that is available at the

Environmental department. Complaints are investigated and

reported in line with the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

A procedure relating to complaints from stakeholders (SGR-SHE-

000022) has been implemented at the Sasol Secunda Complex. The

complaints and/or incidents register verified by the auditors

confirmed that no complaints have been logged regarding the

Liquid Fertiliser Plant during the audit period.

Evidence:

— Sasol Compliance Statement – Complaints

— Environmental complaints procedure_SGR-SHE-

000022_Rev04_2015-08


000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18

None.

AIR POLLUTION

7.1 As directed by relevant authority. C Sasol makes use of an integrated approach to air quality

management as governed by National Environmental

Management: Air Quality Act. Sasol works closely with the local

authority and operates units in line with the relevant AEL and

minimum legal emission requirements.

Evidence:

None.


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— AEL Sasol Nitro 0020-2015-F02 (2016)

MONITORING

8.01 Monitoring systems must be installed by the operator of the

plant to detect any form of ground and or surface water

pollution and to ensure the maintenance of the acceptable

ground and/or surface water quality.

C Groundwater:

Ground water monitoring is conducted biannually and quarterly.

JMA Consulting is an independent contractor appointed to

complete sampling and bi-annual reporting for Sasol. The Auditor

verified that the Groundwater Quality Report compiled by JMA

Consulting. Report number: JMA/Prj6129 Rev-01; Dated:

November 2018 included groundwater monitoring of boreholes

established for the Liquid Fertiliser Plant.

The Auditor noted that 19 out of 36 boreholes are monitored

biannually at the Liquid Fertiliser Plant.

Surface Water:

Surface water monitoring is done on a weekly basis as well as real

time for the various RESMs. Sasol monitor the Bossiespruit,

Brandspruit, Kleinspruit, Klipspruit and Trichardspruit,

Surface water is also monitored biannually at two sumps at the

Liquid Fertilizer Plant.

Evidence:

— Sasol Compliance Statement – Water

— 3.05_RESM Weekly Monitoring_2004-2019

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

20

— Groundwater – Boreholes:

OFI:

It is recommended that a

remediation action plan is

compiled and executed to

rectify the elevated water

quality variables in both the

surface and ground water at

the site.

Target Completion:

Medium Term


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Monitoring boreholes established at the Liquid Fertiliser Plant

— Surface Water – Biannual monitoring points

Biannual Surface Water monitoring points at the Liquid Fertiliser Plant


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— Surface Water – RESM Points:

Location of the RESM monitoring points monitored on a continuous basis

8.02 The Department must be granted access to the property at

any reasonable time to investigate any possible

environmental impacts that may be caused by the operation

of the facility.

N/A Noted. None

REPORTING

9.01 Records relating to compliance/ non-compliance with the

conditions of this authorization must be kept in good order.

Such records must be made available to the Department

within seven (7) days from the date of written Record of

Decision.

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

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

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

9.02 Non-compliance or any deviation from the conditions of this

authorization will be regarded as an offence, and after

reasonable provision has been made for remedial action,

shall be dealt with in terms of Section 29, 30 & 31A of the

Act.

N/A Noted. Sasol has confirmed to the auditor that no communications

have been received from the Authorities regarding non-

compliances.

None.


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9.03 Any complaint regarding to the said development must be

thoroughly investigated and addressed to the satisfaction of

all parties concerned. Copies of such a complaint must be

forwarded to this Department within forty eight (48) hours.

C All environmental complaints received from interested and

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

recorded in a complaints register that is available and the

Environmental department. Complaints are investigated and

reported in line with the procedure and as per legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

A procedure relating to complaints from stakeholders (SGR-SHE-

000022) has been implemented at the Sasol Secunda Complex. The

complaints and/or incidents register verified by the auditors

confirmed that no complaints have been logged regarding the

Liquid Fertiliser Plant during the audit period.

Evidence:

— Sasol Compliance Statement – Complaints


000022_Rev04_2015-08


000022_Rev05_2019-01

— Environmental Complaints Register_2019-02-18

None.


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Page 19

5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

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

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

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

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

GENERAL CONDITIONS 8 1 1 6

ESTABLISHMENT OF THE DEVELOPMENT 3 0 1 2

CONSTRUCTION AND OPERATION 2 0 0 2

WATER POLLUTION 2 0 1 1

WASTE MANAGEMENT 2 0 0 2

RISK ASSESSMENT 2 2 0 0

AIR POLLUTION 1 1 0 0

MONITORING 2 1 0 1

REPORTING 3 1 0 2

Total Count 25 6 3 16

Total Percentage 24% 12% 64%

Percentage Compliance with Applicable Conditions 67%


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Figure 2 illustrates the number/count contribution of the findings of the Exemption per section while Figure 3

presents the total proportion of compliance for the facility.

Figure 2: Number/Count contribution of findings made to the Exemption conditions per Section

Figure 3: Overall count findings on compliance to the Exemption conditions

0123456789

Sectional Count Contribution

C

NC

N/A

6

316

Total Compliance

C

NC

N/A


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Figure 4 illustrates the percentage contribution of the findings of the Exemption conditions. Figure 5 presents

the total percentage compliance for the facility.

Figure 4: Percentage contribution of findings made to the Exemption conditions per Section

Figure 5: Overall percentage findings on compliance to the Exemption conditions

0102030405060708090

100

Sectional Percentage Contribution

C

NC

N/A

24%

12%64%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION

(16.4.28.L2)