SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION … · report 17.2.3 ev 1 - tail gas...

SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS

INTEGRATION

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.3 EV 1 - TAIL GAS TRANSFER LINE FROM SYNTHOL WEST

03 JUNE 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.3 EV 1 - TAIL GAS TRANSFER LINE FROM SYNTHOL WEST

SECUNDA SYNFUELS OPERATIONS:

MARKET & PROCESS INTEGRATION

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: 17.2.3 EV 1

Final – Compliance

Audit

EA Ref: 17.2.3 EV 1

Date April 2019 June 2019

Prepared by Mpendulo Dlamini Mpendulo Dlamini

Signature

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 025 025

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

S I G N A T U R E S

PREPARED BY

Mpendulo Dlamini

Consultant

REVIEWED BY

Jenny Cope

Associate

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

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

compliance with the conditions included in the Environmental Exemption Authorisation.

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

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

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

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

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

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

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Market and Process Integration

Production Senior Manager

Deon van Zyl

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Mpendulo Dlamini

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: MARKET & PROCESS INTEGRATION

WSP June 2019

TABLE OF CONTENTS

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

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

1.2 Tail Gas Transfer Line From Synthol West

(Exemption Number: 17.2.3 EV 1) .......................... 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 Exemption .................................... 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: THE TAIL GAS TRANSFER PROJECT AREA (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 (17.2.3 EV 1)


WSP June 2019

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: 17.2.3 EV 1 issued on 02 August 2002, as amended) for the period

December 2014 to February 2019.

1.2 TAIL GAS TRANSFER LINE FROM SYNTHOL WEST

(EXEMPTION NUMBER: 17.2.3 EV 1)

An environmental exemption was granted on 02 August 2002 by the Mpumalanga Department of Environmental

Affairs and Tourism, for the construction and operation of a Tail Gas Transfer Line (TGTL). The TGTL runs from

the Synthol West to the Synthol East plant.

Figure 1 provides the location of the pipeline rack where the tail gas transfer pipeline is situated within Sasol

Secunda Primary area.

The TGTL connects the two Synthol plants in the East and West Complexes respectively. Tail gas, which is 80%

to 98% methane, refers to the gas that was not transformed to a product, which remains in the system and goes

through a separation process at the Reforming Plant. At the Reforming Plant, the tail gas is converted to carbon

monoxide and nitrogen through a splitting process, and these are used to make petrol and other Sasol products.

Prior to the implementation of this project, tail gas formerly remained at each complex, and at the end of the

process, it would be flared into the atmosphere. Furthermore, if there was maintenance occurring at either

complex, efficiency was significantly reduced as only one complex would remain active.

Following implementation of the project, flaring of the tail gas decreased as it could then be transferred between

the two complexes, to increase efficiency and the capacity to extract carbon monoxide and nitrogen (hence

generate additional products). Lastly, the project also assists to augment efficiency if one complex undergoes

maintenance.

An amendment to the exemption was granted on 12 March 2003, which removed a former condition associated

with provisioning (formerly condition 3.2). This audit has been carried out against the amended Exemption, and

hence does not include the removed condition.


WSP June 2019

Page 2

Figure 1: The tail gas transfer project area (Source: Google Earth, 2018)


WSP June 2019

Page 3

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 9.01 of the Exemption are completed, more specifically:

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

kept in good order. Such records must be made available to this Department within seven (7) working

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


WSP June 2019

Page 4

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 (29 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

Mpendulo Dlamini conducted the site inspection on 29 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:

— Peet van Zyl - Area Manager Production

— Neeren Naidu - Production Foreman MPI

— Richard Van Den Berg - Production Foreman MPI

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— SSO DQS ISO 14001 2015;

— EA_EX Handover_SSO_MPI;

— EA_EX Handover_SSO_MPI_Amend SM;

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

— Compliance_Water_Secunda Complex.dox;

— IWWMP SIC 2015 Final_2018-05-15;

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2;

— Risk Assessment: SGI-SHE-000014;

— 8.02_Plant inspections U050;



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

— Various email correspondence


WSP June 2019

Page 5

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, Mpendulo Dlamini, was hosted by Broni van der Meer and Peet van Zyl to whom we express our

gratitude for their time and attention during our visit. A brief summary of the external auditors’ experience is

provided below.

— Auditor: Mpendulo Dlamini

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

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

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

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

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

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

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

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

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

(Triplo4 Sustainable Solutions).


WSP June 2019

Page 6

— 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.


WSP June 2019

Page 7

4 AUDIT FINDINGS Table 2: Audit Findings – Environmental Authorisation

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This exemption refers only to the project specified above and

described in the Record of Decision. Other than the Tail gas

transfer line from Synthol East to Synthol West, separate

applications must be lodged for any other development and/or

activity at or near proposed development, which is covered by

Sections 21 and 22 of the Act and Government Notice R670

and R672 of 10 May 2002.

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

the Exemption was granted. No additions or alterations have taken

place on or near the project’s location.

Sasol is aware of the requirement to lodge separate applications

should further works be required for the authorised activity.

None.

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

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

does not exempt the holder from compliance with any other

relevant legislation.

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

audit.

The Sasol Complex operates with a dedicated environmental and

legal 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 specifically

states “the development of the compliance risk management

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

of legal compliance is commendable”.

Evidence:

— SSO DQS ISO 14001 2015;

— 2018 DQS 3rd Party Audit Report_Sasol Secunda Synfuels

Operations.

None.


WSP June 2019

Page 8


1.03 This Department may change, add or amend any of the

conditions in this authorization if, in the opinion of the

Department, it is environmentally justified.

N/A

No changes or amendments have been communicated to Sasol by

the Department since issue of the Exemption.

None.

1.04 A copy of this authorization shall be available at Area Leader

Environment, Sasol Secunda, at all times and all staff,

contractors, contractors and sub-contractors shall be

acquainted with the contents of this exemption.

C Sasol’s environmental team have soft copies of the Exemption and

where/when necessary, communicate any specific details or

requirements to the relevant business units.

Additionally, copies are maintained at the SHE: Environment

department and on SAP EC and SharePoint. Any specific

requirements are communicated during SHE induction training.

Sasol provided the auditor with the evidence that the responsible

persons, Ronel Kotze (Senior Manager of Production Gas VC) and

Ettienne Rademeyer (legal appointee of MPI) were made aware of

the Exemption on September 2016. Deon van Zyl (Senior Manager

of Production Gas VC) and Ettienne Rademeyer (legal appointee of

MPI) were made aware of the Exemption amendment in November

2017.

Evidence:

— EA_EX Handover_SSO_MPI

— EA_EX Handover_SSO_MPI_Amend SM

None.

1.05 The content of this exemption must be made known to all

interested and affected parties within 14 days from the date of

this exemption.

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

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

None.

2. ESTABLISHMENT OF THE ENTERPRISE

2.01 This exemption is repealed if the tail gas transfer line and

associated infrastructure has not taken place within two (2)

years from the date of this exemption.



None.


WSP June 2019

Page 9


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

transfer ownership of the infrastructure, this Department must

be informed of such decision at least 12 months prior the date

of closure or transfer of ownership.

N/A Noted. Sasol have advised that there are no current plans to close or

decommission the facility.

None.

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

monitor and approve the clearing and rehabilitation of the site. N/A The statement is noted by Sasol. None.

3. CONSTRUCTION AND OPERATION

3.01 If any changes need to be made to the development or

associated infrastructure, this Department must be informed

thirty (30) days in advance to decide whether the change will

need authorization.

N/A Noted. Sasol have advised that no changes have been made since the

Exemption date. Furthermore, there are no plans to make changes to

the existing development.

None.

3.02 Upon completion of the associated infrastructures, all excess

construction material should be disposed of in a registered

landfill site.



None.

4. AIR POLLUTION

4.01 Any emissions must be permitted by relevant authority. N/A According to the Area Manager, there are no emissions from the

pipeline as it is a fully closed system.

None.

5. WATER POLLUTION

5.01 It is the responsibility of the applicant and the relevant

contractor on site to prevent any pollution of surface as well

as groundwater.

C According to the Area Manager, there is no possibility of any

surface or groundwater pollution during operation as no liquids

emanate from the pipeline.

None.


WSP June 2019

Page 10


The consultant was notified that during maintenance, liquid traps

that remove condensate which are installed on the pipeline are

unscrewed and drip trays are used to collect small amounts of liquids

that come out. The liquid collected is then disposed of into the oily

water sewer.

Water that used to wash/scrub the pipeline during maintenance is

sent to the Synthol Plants in the East and West complexes where it

is released to the oily water sewer.

Sasol have an Integrated Waste and Water Management Plan

(IWWMP) which aims to identify the activities related to Sasol’s

operations within the context of the receiving environment (with a

focus on water resource protection), identify the risks associated

with these operations, and subsequently manage these risks by

means of an action plan committed to by Sasol management.

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

time for the various Receiving Environmental Surface water

Monitoring points (RESMs)

Ground water monitoring is conducted biannually and quarterly.

The is no groundwater monitoring specific to the tail gas transfer

line area, however there are 6 active boreholes located within the

Primary area which are utilised for monitoring. The auditor note a

number of exceedances in the November 2017 sampling run,

however these exceedances cannot be directly attributed to tail gas

transfer line area.

In addition, all staff, contractors and visitors are provided with

induction training, which includes pollution of the environment.

Evidence:

— Compliance_Water_Secunda Complex.dox

— IWWMP SIC 2015 Final_2018-05-15

— SIC IWWMP Appendix 1 - Solvents 2017 Rev 2


WSP June 2019

Page 11


5.02 In case of non-compliance with Section 19 of the National

Water Act, 1998 (Act 36 of 1998), the applicant will be

responsible to remedy the effects of pollution.

N/A The statement is noted by Sasol. None.

6. WASTE

6.01 All waste generated during the construction and/or operation

of the tail gas transfer line shall be stored, handled and

disposed of in an environmentally acceptable way.

C No solid waste is generated from the operation of the pipeline.

Liquid waste generated scheduled maintenance activities is

collected in drip trays or sent to the Synthol Plants for it to be

disposed of in the oily water sewer.

None.

7. RISK ASSESSMENT

7.01 Risk study, safety measures and emergency plans must be in

place at each Synthol plant. C According to the Production Foremen, Risk Based Inspection are

undertaken on a weekly basis. The reports are uploaded onto the

IMS system every Friday for the midweek inspection and on

Mondays for the weekend inspections. A work instruction for

Minimum requirements for environmental risk assessments for all

Sasol Synfuels and Sasol Chemical Operations is also available on

Sasol’s web-based system, and its latest review date is 01 February

2017.

Safety and emergency information for Sasol is also available on its

web-based system and every staff member has access to it. At each

plant, personnel undergo induction that includes all the health and

safety aspects as well as the emergency procedures of the Synthol

plants. Refresher trainings are held every three years from the initial

induction for each personnel.

Evidence:

— Risk Assessment: SGI-SHE-000014

None.


WSP June 2019

Page 12


— 8.02_Plant inspections U050



7.02 Fire extinguishing equipment should be available at the site

at all times. C The pipeline passes a lot of plant units along Sasol’s internal road

network along with other pipelines. The pipeline therefore depends

on fire-fighting equipment of the plant units that it passes. The

auditor observed the fire-fighting equipment along the route within

the units. Pictures could not be taken as prior permission to enter

the units was not obtained.

According to the Area Manager, the pipeline is mainly dependant

on the Unit 350 fire-fighting equipment as well as fire monitors, fire-

fighting powder as well as hydrants in between the units.

None.

8. MONITORING

8.01 Monitoring should be done as indicated by the relevant

authorities. N/A According to the Environmental Specialist, besides the Exemption

Authorisation, there were no further recommendations received

from the Department.

None.

8.02 Weekly monitoring and inspection of leaks along the

pipeline route must be carried out. C According to the Production Foremen, Risk Based Inspection are

undertaken on a weekly basis. The reports are uploaded onto the

IMS system every Friday for the midweek inspection and on

Mondays for the weekend inspections.

Evidence:




None.


WSP June 2019

Page 13


9. REPORTING

9.01 Records relating to the compliance/non-compliance with the

conditions of the exemption must be kept in good order. Such

records must be made available on to this Department within

seven (7) working days of the written request by the

Department for such records.

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 with, or any deviations from the conditions

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

and, after reasonable provision has been made for remedial

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

of the Act.

N/A Noted. None.

9.03 Any complaint regarding the said development must be

brought to the attention of this office within 24 hours after

receiving the complaint.

C

The complaints register from 2008 to date was available for review

and there have been no complaints lodged with regards to the

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

Evidence:

— Environmental Complaints Register (Period: December 2014 –

March 2019)

None.

9.04 A complaint register must be kept up to date for inspection by

members of this Department. C A complaint register is kept up to date for the entire Sasol Secunda

Operations. Available records go as far back as 2008.

Evidence:

— Environmental Complaints Register (Period: December 2014

– March 2019)

None.


WSP June 2019

Page 14

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 5 1 0 4

ESTABLISHMENT 3 0 0 3

CONSTRUCTION AND OPERATION 2 0 0 2

AIR POLLUTION 1 0 0 1

WATER POLLUTION 2 1 0 1

WASTE 1 1 0 0

RISK ASSESSMENT 2 2 0 0

MONITORING 2 1 0 1

REPORTING 4 2 0 2

Total Count 22 8 0 14

Total Percentage 100% 36% 0% 64%

Percentage Compliance with Applicable Conditions 100%


WSP June 2019

Page 15

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

0

1

2

3

4

5

6

Exemption

Sectional Count Contribution

C

NC

N/A

8

0

14

Total Compliance

C

NC

N/A


WSP June 2019

Page 16

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

36%

0%

64%

Total Percentage Compliance

C NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION (17.2.3

EV 1)

Date post:	17-Jun-2020
Category:	Documents
Upload:	others
View:	6 times
Download:	1 times