Global authority inspections
During the reporting period, our operations globally have been subject to various environmental authority inspections and associated compliance enforcement actions. We collaborated fully with the authorities during these inspections, resolved enquiries and duly responded to subsequent enforcement actions. Key aspects are highlighted below.
In South Africa, the Department of Water and Sanitation (DWS) conducted various routine inspections at some of our mining collieries in Secunda and Sasolburg, at the Secunda Synfuels Operations’ (SSO) sewage plant, as well as at our Sasolburg Operations (SO) and Natref in Sasolburg. The reports for SO and SSO are still awaited. Sasol Mining has subsequently submitted requests for amendment of impractical monitoring conditions (which have already been discussed with the DWS). The findings at Natref were related to water quality exceedances as a consequence of the specified location for monitoring, with the associated unintended consequence that Natref’s monitoring results are impacted by downstream users. This is being addressed through a pending amendment application.
Air Quality compliance
The Gert Sibande local licensing authority conducted an air quality compliance inspection at our Secunda Chemical Operations (SCO) in Secunda and the report is awaited. We previously reported that the Department of Environmental Affairs’ (DEA) enforcement directorate communicated its intentions regarding enforcement action related to air quality exceedances associated with three thermal oxidation units at SO. This was surpassed by a new, but related notice of intention to implement administrative enforcement action, issued in early 2018. Following an extensive response submitted by SO, the DEA confirmed that it would not proceed with further administrative enforcement action in this matter. It remains SO’s intent to only re-commission these incinerators when it is satisfied that ongoing compliance can be sustained with the requirements of its recently varied atmospheric emission licence (AEL).
No final enforcement actions were instituted and no fines and penalties were imposed as a consequence of these inspections or the enforcement actions reported in 2017.
In Mozambique, the environmental authority conducted an environmental compliance inspection at Sasol’s operations, and commended Sasol on its commitment to and overall compliance performance. Our Eurasian Operations underwent various inspections. No deviations were noted at our operations in Novaky, Solvakia. A hazardous waste warehouse at our China operations was upgraded to meet the specifications of the Nanjing Environmental Bureau. At our operations in Augusta, Italy, a joint inspection and sampling campaign were undertaken by Sasol and the authorities. The sampling results confirmed compliance with applicable groundwater limits. At our Brunsbüttel operations in Germany, the industrial emissions directive inspection noted no deviations from a waste management perspective, but abatement equipment was subsequently installed to bring the plant into compliance with the applicable atmospheric emission limits. No deviations were noted at Hamburg Sasol Wax’s tank farm, hydrogenation plants and the ammonia cooling plant. Following an inspection at our operations in Marl, the authority confirmed its support for the plant’s mitigation of dioxin levels in waste water and periodic status reports are submitted to the authority.
In North America, a warning letter was received from the environmental regulatory authorities following a previous inspection, noting concerns regarding water sampling. Sasol submitted a response, thereby preventing further enforcement action being instituted. In addition, a notice of potential penalty (NOPP) was received from the authorities in Louisiana in relation to an unauthorised release from the Comonomer Unit. In the same NOPP received, a dust complaint was also cited in relation to the Lake Charles Chemical Project (LCCP) construction activities. A settlement offer in the amount of USD 2500 has been proposed to settle this enforcement matter.
Proactively reporting on significant compliance challenges
Our approach to environmental compliance management continues to be transparent and collaborative. We engage with authorities regularly through established forums and also proactively where we anticipate or identify compliance challenges. We report non-compliances with conditions of authorisations and the management thereof, as well as corrective and preventative measures to address these. This includes the reporting of environmental incidents as per statutory requirements and the submission of periodic, quarterly and annual reports. We also communicate to our stakeholders on our performance.
Engagements with Department of Water and Sanitation
Our South African operations had several engagements with the DWS for purposes of clarifying requirements under water use licenses (WULs) or aspects pertaining to pending license or amendment applications. In an effort to streamline registrations and applications, Satellite Operations and SO engaged around general authorisations, involving river crossing and other impacts to water courses, as these relate to pipeline construction and related maintenance work. Risk assessments to inform general authorisation registrations are under way. Our Base Chemicals (BC) operations invited the DWS to its operations in Witbank to confirm its general authorisation registrations and other water use requirements. Subsequently, a new WUL application was submitted.
At our SSO, the DWS was engaged on a number of water related matters including the water quality objective exceedance at a surface monitoring station and challenges experienced with sewage effluent quality that do not consistently meet bacteriological specifications. Apart from the pending amendment application, which address these challenges, mitigation actions also include the feasibility assessment of a wetland, seepage trenches and the progression of an extensive Graben study. Authorisation for additional water uses has been submitted. Ad hoc water challenges, including those relating to contaminated storm water run-off and groundwater contamination, are being investigated and reported to the DWS by SO and Satellite Operations for its Ekandustria operations. Our Satellite Operations submitted a WUL amendment application to appropriately address challenges with groundwater limits being exceeded.
Engagements with Department of Environmental Affairs
Engagements with the local licensing authority and the DEA are ongoing to conclude the required review of the atmospheric emissions license (AEL) for our Satellite operations in Ekandustria and for the waste management licenses for SCO. SSO’s waste management license was reviewed without any issues being raised by the authorities. Natref, SSO and SO received varied AELs, reflecting the postponement decisions received from the National Air Quality Officer with regards to applicable minimum emission standards for certain point sources. In addition, Natref sought a variation to include specific operating conditions to apply during start-up and shutdown to pro-actively address challenges experienced outside of normal operating conditions. SSO continues to engage with the DEA and local licensing authorities to enable sustained compliance in transitioning to the requirements of the varied AEL and clarifying the monitoring requirements related to hydrogen sulphide in anticipation of meeting the applicable new plant standards in 2020. Engagements regarding the challenges associated with meeting the new plant standards for boiler sulphur dioxide in 2020 are also ongoing.
Engagement with environmental authorities
In Mozambique the environmental authorities are also engaged regarding approvals required for the landfilling of waste, the renewal of existing licenses to operate and new authorisation requirements for looplines.
Incidents reported during the period
Incidents reported by the South African operations, in accordance with statutory requirements, include reporting of an interruption in the 12-month SO2 running average monitoring required for the burning grounds of the Satellite operations in Ekandustria. The required air quality monitoring has subsequently been restored.
Sasol Mining reported pipeline leaks, the overflow of pollution control dams, and alleged pollution from one of its storage dams. Base Chemicals reported a spill of approximately 2 000 litres of diesel associated with the attempted theft of product from a tanker and SO reported the release of vinyl chloride into atmosphere on account of a ruptured pipeline.
A leak from an underground pipeline at operations of Natcos in Durban resulted in the contamination of land and surface water and was consequently reported by Natref.