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SASOL SYNFUELS OPERATIONS - REFINERY

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.22.18 GS 01 - BENZENE PHASE 1

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.22.18 GS 01 - BENZENE PHASE 1

SASOL SYNFUELS OPERATIONS -

REFINERY

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

EA Ref:

17.2.22.18 GS 01

Final – Compliance

Audit

EA Ref:

17.2.22.18 GS 01

Date April 2019 June 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 1 1

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

-

Ziyaad Kadwa

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

Refinery Production Senior Manager Helgard Theron

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SASOL SYNFUELS OPERATIONS - REFINERY

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Benzene Reduction Phase 1 Project

(Authorisation Number: 17.2.22.18 GS 01) ........... 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 ... 14

5.1 Environmental Authorisation ............................... 14


WSP June 2019

TABLES

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

TABLE 2: AUDIT FINDINGS – ENVIRONMENTAL AUTHORISATION ......................... 7

TABLE 3: SUMMARY OF EXEMPTION COMPLIANCE AUDIT FINDINGS .................................... 14

FIGURES

FIGURE 1: SSO – BENZENE REDUCTION PHASE 1 PROJECT (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 15

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 15

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 16

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 16

APPENDICES

A ENVIRONMENTAL EXEMPTION (17.2.22.18 GS 01)


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Page 1

1 INTRODUCTION

1.1 TERMS OF REFERENCE

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

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

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

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

Environmental Exemption (Reference number: 17.2.22.18 GS 01 issued on 20 December 2006) for the period

December 2014 to February 2019.

1.2 BENZENE REDUCTION PHASE 1 PROJECT

(AUTHORISATION NUMBER: 17.2.22.18 GS 01)

Sasol received an Exemption for the benzene reduction phase 1 project, in order to meet the legislated benzene

specifications for fuel. The project aimed to enable the benzene content to be reduced below 3%.

As part of the project, the Exemption described the following activities:

— The routing of Coal Tar Naphtha (CTN) from units 15 and 215 to tank farm (unit 56).

— Internal floating roofs added to two tanks in order to reduce Volatile Organic Compounds emissions.

— The installation of two new pumps in order to ensure that the CTN can be pumped from unit 56 to unit 32

where the benzene is allowed to react with propylene and butylene to reduce propylbenzene to

butylbenzene.

— Unit 32 products are routed to unit 33, where side draw is commissioned to minimise octane loss, a new air

cooler is required.

— At unit 33 a new water cooler; required to help with optimisation of operations.

— A new 6" suction line measuring 59m that ties out of the existing pump suction line to the new pumps, as

well as a 914m, 4" discharge line from the new pumps to unit 32.

— A new 2" return line from the new pumps to the two existing tanks.

— A new 3 line to route the CTN from the discharge line to the existing unit 228 feed line, in the event that

unit 32 not being able to process all of the CTN on a continuous basis.

The Exemption was issued by the Department of Agriculture and Land Administration, Mpumalanga Provincial

Government on 20 December 2006, and it has been confirmed that the construction phase was completed prior

to December 2014 (i.e. outside the audit period).

Figure 1 provides an overview of the location of the facility.


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Figure 1: SSO – Benzene Reduction Phase 1 Project (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;

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

— Ensure the commitments contained in Condition 5.01 of the Exemption are completed, more specifically:

— “Records relating to compliance/non-compliance with the conditions of the Authorisation must be kept

in good order. Records must be made available to Department within 5 days on a written request of the

Department”


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

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

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

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (13 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

Ziyaad Kadwa conducted the site inspection on 13 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:

— Bertus Buys (Area Manager: Production).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— Environmental Authorisation: 17.2.22.18GS01_2006-12-20 original;

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

— IWWMP SIC 2015 Final_2018-05-15;

— AEL Sasol Synfuels 0016-2018-F03 (2018);

— SOX Folder;

— SEC-146-2018-SB (HCS) (Refining Production West South Units 029 032 033;

— Induction_Mod1-8;

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

— Sasol SAWIS upload-2018_Jul-Sep;

— Waste register: Refining_2016-12-04;

— South Units Prod W Mech;

— 4.02_Plant inspections U050;


— 4.02_Plant inspections U350.

— Labour_Sasol IRM Suppliers Industrial Relations Procedure;

— Environmental Complaints Register_2019-02-18; and,

— Various email correspondence.


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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 Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer and Bertus Buys, 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: Ziyaad Kadwa

Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal

Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the

Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it

part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural

Development for 3 years. He is currently completing his BSc Honours in Environmental Management part

time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a

number of high profile clients in various industries. He has three years of auditing experience, and has

successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,

Impala Platinum and NPC (InterCement). He has also done environmental management programme audits

for BRPM and for various infrastructure projects as part of environmental control officer duties.


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— Project Manager and Quality Assurance: Jenny Cope

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

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

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

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

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

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

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

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

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

understanding of the Relevant Documents.

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

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

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

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

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

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

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

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

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

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

pertaining to this investigation.

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

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

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

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

document.

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

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

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

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

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

GENERAL CONDITIONS

1.01 This Exemption refers only to the project as specified above

and described in the Record of Decision. Separate

application/s must be lodged for any other development

and/or activity at or near the proposed development, which is

covered by Section 21 and 22 of the Act and Government

Notice R1182 of 5 September 1997.

N/A The activity remains as specified and no further alterations or

applications have been made.

None.

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

Environmental Conservation Act (Act 73 of 1989) and does

not exempt the holder from compliance with other relevant

legislation.

N/A Noted. The Sasol Complex operates with a dedicated

environmental and legal team, and therefore ensures that they

comply with applicable legislation.

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

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

provided with the 2018 ISO audit for review, which confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

1.03 Necessary permits, approvals and/or service, where it is

relevant must be obtained from or between the following

institutions must be obtained:

1.3.1 CAPCO

1.3.2 Provincial Department of Health

C The Sasol Complex operates with a dedicated environmental and

legal team, and therefore ensures that they comply with applicable

legislation.

Sasol is in possession of an AEL (issued per business unit) and has

an updated Integrated Water and Waste Management Plan

(IWWMP) (updated 2018) that applies to the whole complex.

None.


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1.3.3 Department of Labour Evidence:

— IWWMP SIC 2015 Final_2018-05-15; and,

— AEL Sasol Synfuels 0016-2018-F03 (2018).

1.04 Copies of the documents mentioned in 1.3 above must be in

the possession of this Department before any construction

commences.

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

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

None.

1.05 This Department may change or amend any of the conditions

in this Exemption if, in the opinion of the Department, is

environmentally justifiable.

N/A No changes or amendments have been communicated to Sasol by

the Department since issue of the Exemption.

None.

1.06 A copy of this Exemption must be made available at the

appropriate site office of Sasol Synfuels at all times and all

relevant staff, contractors and sub-contractors must be

acquainted or made acquainted with the contents of this

Exemption.

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

communicated with, relevant business units. Copies of these

documents are also available at the SHE: Environment department

and on SAP EC and SharePoint. Sasol provided the auditor with

the evidence that the responsible persons, Helgard Theron (Senior

Manager of Refining West Production Area) and Willem

Oosthuizen (legal appointee of Refining), were made aware of the

Exemption in October 2016.

Evidence:

— EA_EX Handover_SSO_REF-West.

None.

1.07 The advertisement of the record of decision must at least

include the following :

1) An exemption has been issued to processed with the

activity;

2) The date on which the record of decision was issued

3) Appeals against the authorisation must be lodged with

the MEC for agriculture and Land Administration

within 30 days from the date on which the record of

decision was issued.



None.


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4) Indicate where the copies of the authorization and ROD

can be viewed / obtained.

ESTABLISHMENT OF THE ENTERPRISE

2.01 This authorisation is repealed if the proposed project has not

been constructed within two (2) years from the date this

exemption.



None.

2.02 If the decision is taken to close down the plant, sell and/or

transfer ownership of the infrastructure on the site in any

way, this Department must be informed of such decision at

least three (3) months prior to the date of closure or transfer

of ownership.

N/A Statement noted by Sasol. Closure is not yet planned for, and

according to Sasol, is estimated to occur around 2050.

None.

2.03 In case of closure the site, the Department shall evaluate,

monitor and approve the closure plans. N/A Statement noted by Sasol. Closure is not yet planned for, and

according to Sasol, is estimated to occur around 2050.

None.

CONSTRUCTION & OPERATION

3.01 The adverse human health effects that may be caused by the

proposed development must be documented and made

available.

C Sasol undertakes occupational hygiene monitoring in terms of the

Occupational Health and Safety Act. All records relating to the site

are stored in an Information Management System (IMS).

Proof of completion of a Hazardous Chemical Substances Survey

on 22 August 2018, was provided to the auditor.

Evidence:

— SEC-146-2018-SB (HCS) (Refining Production West South

Units 029 032 033.

None.

3.02 Workers must be made aware of harmful effects of the

project and must be trained on the dangers and safety

measures.

C All visitors, employees and contractors entering the Sasol Complex

are required to undergo an SHE induction process. All training is

None.


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done through the SHE regional learning and development

academy, and records maintained by Sasol.

Dangers and safety measures are included within induction training

material.

Evidence:

— Induction_Mod1-8.

3.03 Appropriate ablution facilities must be provided to the

construction team to prevent pollution of the surrounding

environment.



None.

3.04 Sasol Synfuels is responsible for the removing of all

construction waste and for its appropriate disposal at a

registered landfill site.



None.

3.05 Sasol Synfuels is responsible for the removal and appropriate

disposal at a registered landfill site of all maintenance waste

produced during operational phase.

C No operational waste is generated during normal operating

conditions. Various types of spent catalyst are generated at

irregular intervals and collection and recycling or safe disposal is

specially arranged for via a specialised waste management

contractor.

Sasol makes use of a SAP Sustainability Performance

Management Module (SUPM) as a database for tracking waste

volumes that are managed on and off site.

Sasol further reports the on-site waste management data into the

South African Waste Information System (SAWIS), on a quarterly

basis. The off-site management of waste is reported into SAWIS

by the accredited Waste Management Service Providers on a

quarterly basis.

Evidence:

— Waste Management Procedure_SGR-SHE-

000017_Rev10_2017-09;

— Sasol SAWIS upload-2018_Jul-Sep; and,

None.


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— Waste register: Refining_2016-12-04.

3.06 Construction workers must be informed of the environmental

issues and must adhere to mitigation measures. N/A This condition is considered outside of the audit period


None.

3.07 Local labour and local material must be used, where

possible. C Sasol’s Supplier Industrial Relations Procedure includes provision

for following a preferential recruitment and appointment practice,

whereby a minimum of 70% of general workers up to semi-skilled,

need to be recruited from the local municipal district.

Evidence:

— Labour_Sasol IRM Suppliers Industrial Relations Procedure.

None.

3.08 Sufficient provisions must be made in annual budget for

maintenance of the plant and any negative environmental

impacts during operation.

C Maintenance budgets are compiled by Sasol with budgets being

forecast up to 2021. The budgets were provided to the auditor as

evidence.

Due to being listed on the New York Stock Exchange, Sasol is

required to adhere to the Sarbanes Oxley (SOX) legislation in the

US which requires transparent financial disclosure, including its

environmental liabilities, to be included in the company financial

statements. Provision is made for the removal of surface

infrastructure, in line with the future land use, as well as for the

remediation of areas that would remain a liability post-closure in

terms of potential future contamination.

Evidence:

— South Units Prod W Mech; and,

— Compliance_SOX Provisions_Secunda Complex.

None.

MONITORING AND AUDITING

4.01 A post construction audit must be conducted to ensure that

any shortcomings are identified and addressed. N/A This condition is considered outside of the audit period


None.


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4.02 Sasol Synfuels must ensure that the site is inspected every 6

months to determine the need for maintenance. C Plant inspections are completed and documented on a weekly

basis, according to a pre-set checklist.

Evidence:


— 4.02_Plant inspections U250; and,

— 4.02_Plant inspections U350.

None.

4.03 Sasol Synfuels must maintain a database for all records and

information generated on site. C Sasol utilises a web based Information Management System (IMS)

that includes a comprehensive Document Management System

(Easy DMS) where all supporting documentation is available.

Environmental specific records are maintained by the

environmental team. Additionally, copies of certificates, permits,

etc., are maintained at the SHE: Environment department and on

SAP EC and SharePoint.

None.

REPORTING

5.01 Records relating to compliance/non-compliance with the

conditions of the Authorisation must be kept in good order.

Such records must be made available to Department within 5

workdays of the date on a written request of the Department.

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

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

Environmental Impact Assessment (EIA) regulations, no audit

against this Exemption was required.

None.

5.02 Non-compliance with or any deviations from the conditions

of this Authorization is regarded as an offence and after

reasonable provision has been made for remedial action, will

be dealt with in terms of Section 29, 30 and 31A of the Act.

N/A Statement noted by Sasol. None.

5.03 Any complaints regarding the development must be brought

to the attention of this Department within 24 hours after

receiving the complaint. A complaints register must be kept

up to date for inspection by the Department.

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 maintained by Sasol’s

Environmental Department. Complaints are investigated and

None.


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reported in line with the procedure (SGR-SHE-000022)) and as per

legal requirements.

Environmental complaints contact details are communicated to

internal and external stakeholders.

The complaints register (FY 2014-2019) was checked and no

complaints related to the Benzene operation were recorded for this

audit period.

Evidence:

— Environmental Complaints Register_2019-02-18.


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL AUTHORISATION

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

applicable. The overall audit findings concerning compliance to the 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 7 2 0 5

ESTABLISHMENT OF THE ENTERPRISE 3 0 0 3

CONSTRUCTION & OPERATION 8 5 0 3

MONITORING AND AUDITING 3 2 0 1

REPORTING 3 1 0 2

Total Count 24 10 0 14

Total Percentage - 42% 0% 58%

Percentage Compliance with Applicable Conditions 100%


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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

GeneralConditions

Establish Construction &Operation

Monitoring andAuditing

Reporting

Sectional Count Contribution

C

NC

N/A

10

0

14

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

GeneralConditions

Establish Construction &Operation

Monitoring andAuditing

Reporting

Sectional Percentage Contribution

C

NC

N/A

42%

0%

58%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION

(17.2.22.18 GS 01)

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