DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT THE SASOL SECUNDA INDUSTRIAL COMPLEX, MPUMALANGA

Transcription

1 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT THE SASOL SECUNDA INDUSTRIAL COMPLEX, MPUMALANGA Sasol Polymers (Pty) Ltd MDEDET REF: 17/2/3 GS-172 June 2013

2 Client: Sasol Polymers (Pty) Ltd DOCUMENT DESCRIPTION Project Name: Draft Environmental Management Programme for the Proposed Sasol C3 Expansion Project at the Sasol Secunda Industrial Complex, Mpumalanga Royal HaskoningDHV Reference Number: T01.PTA Authority Reference: MDEDET Ref: 17/2/3 GS-172 Compiled by: Phyllis Kalele Date: June 2013 Location: Pretoria Reviewed by: Prashika Reddy Approved by: Prashika Reddy Signature Royal HaskoningDHV All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written permission from Royal HaskoningDHV

3 TABLE OF CONTENTS 1 INTRODUCTION APPLICABLE DOCUMENTATION STRUCTURE OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME OBJECTIVES OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME THE EMPR AS A LIVE DOCUMENT PLAN DO CHECK ACT DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 4 2 MANAGEMENT AND MONITORING PROCEDURES ORGANISATIONAL STRUCTURE AND RESPONSIBILITY ENVIRONMENTAL AWARENESS PLAN MONITORING REPORTING PROCEDURES DOCUMENTATION REPORTING 7 3 ENVIRONMENTAL GUIDELINES, STANDARDS AND PERMITS LEGAL SUMMARY OTHER RELEVANT ACTS AND GUIDELINES 9 4 CONSTRUCTION PHASE 10 5 PRE-COMMISSIONING 15 6 OPERATIONS AND MAINTENANCE 17 7 DECOMMISSIONING PHASE GENERAL PRINCIPLES FOR ENVIRONMENTAL MANAGEMENT DURING DECOMMISSIONING 20

4 LIST OF FIGURES FIGURE 1: DIFFERENT PHASES OF THE PROJECT LIFECYCLE 2 FIGURE 2: DEMING CYCLE OF CONTINUING IMPROVEMENT 3

5 BAR DEA EA EAP EIA EMPr GMLM GSDM LIDP MDEDET NEMA PP RHDHV ACRONYMS Basic Assessment Report Department of Environmental Affairs Environmental Authorization Environmental Assessment Practitioner Environmental Impact Assessment Environmental Management Programme Govan Mbeki Local Municipality Gert Sibande District Municipality Local Integrated Development Plan Mpumalanga Department of Economic Development, Environment and Tourism National Environmental Management Act Polypropylene Royal HaskoningDHV

6 ACCIDENT: An unfortunate incident that happens unexpectedly and unintentionally, consequently causing damage to property or injury to persons 1 BUILDING AND DEMOLITION WASTE: Building and demolition waste means waste, excluding hazardous waste, produced during the construction, alteration, repair or demolition of any structure, and includes rubble, earth, rock and wood displaced during that construction, alteration, repair or demolition. CONTRACTOR: Any provider of services, goods or people to Sasol sites, directly or indirectly, and includes: contractors, sub-contractors, sub-sub contractors, hired labour agency, suppliers, event contractors, consultants and contractors as traditionally defined. DEGRADATION The lowering of the quality of the environment through human activities e.g. river degradation, soil degradation. DOMESTIC WASTE: Domestic waste means waste, excluding hazardous waste, that emanates from premises that are used wholly or mainly for residential, educational, health care, sport or recreation purposes. GLOSSARY OF TERMS i. the land, water and atmosphere of the earth; ii. micro-organisms, plants and animal life; iii. any part or combination of (i) of (ii) and the interrelationships among and between them; and iv. the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing. ENVIRONMENTAL CONTROL OFFICER: An individual nominated through the Client to be present on site to act on behalf of the Client in matters concerning the implementation and day to day monitoring of the EMPr and Environmental Authorisation conditions stipulated by the Authorities. ENVIRONMENTAL IMPACT: A change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation s activities, products or services. ENVIRONMENTAL MANAGEMENT PROGRAMME: A detailed plan of action prepared to ensure that recommendations for enhancing or ensuring positive environmental impacts and limiting or preventing negative environmental impacts are implemented during the life-cycle of the project. EMERGENCY: An undesired event that results in a significant environmental impact and requires the notification of the relevant statutory body such as a local or provincial authority. ENVIRONMENT: In terms of the National Environmental Management Act (NEMA) (No 107 of 1998)(as amended), Environment means the surroundings within which humans exist and that are made up of: GENERAL WASTE: General waste means waste that does not pose an immediate hazard or threat to health or to the environment, and includes (a) domestic waste; (b) building and demolition waste; (c) business waste; and (d) inert waste. HAZARDOUS WASTE: 1 Oxford Dictionary (2013)

7 Hazardous waste means any waste that contains organic or inorganic elements or compounds that may, owing to the inherent physical, chemical or toxicological characteristics of that waste, have a detrimental impact on health and the environment. IMPACT: A description of the potential effect or consequence of an aspect of the development on a specified component of the biophysical, social or economic environment within a defined time and space. INCIDENT: An undesired event which may result in a significant environmental impact but can be managed through internal response. MITIGATION: Measures designed to avoid, reduce or remedy adverse impacts. PROJECT MANAGEMENT TEAM: The responsibility of the team is to ensure the implementation of the EMPr. SAFETY, HEALTH AND ENVIRONMENTAL OFFICER: The SHE officer is a Contractor representative, responsible for the safety, health and environmental aspects on the construction site. WASTE: Waste means any substance, whether or not that substance can be reduced, re-used, recycled and recovered (a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of; (b) which the generator has no further use of for the purposes of production; (c) that must be treated or disposed of; or (d) that is identified as a waste by the Minister by notice in the Gazette, and includes waste generated by the mining, medical or other sector, but (i) a by-product is not considered waste; and (ii) any portion of waste, once re-used, recycled and recovered, ceases to be waste.

8 1 INTRODUCTION The C3 expansion project was initiated to address an estimated 105 ktpa (kilo tons per annum) additional propylene that will be available incrementally from 2014 as a result of various optimisation projects on the upstream Sasol facilities. An opportunity was identified for the additional propylene to be utilised as feed for the polypropylene (PP) plants, namely PP1 and PP2. All the additional propylene will be converted to polypropylene by debottlenecking both the existing PP1 and PP2 plants so as to process the required additional capacity of 105 ktpa. The additional propylene will be split between the two plants: PP1 will convert additional 30 ktpa while PP2 will convert additional 75 ktpa. The PP1 plant has been in operation from February 1990 and has a capacity of tpa (tons per annum) whereas the PP2 plant has been in operation from December 2007 with a capacity of tpa. The operating intent of the PP plants is the maximum conversion of propylene and ethylene from Sasol Synfuels into polypropylene pellets via a polymerization process. The products from this reaction are Homopolymers (constituting only propylene), Impact Copolymers (propylene and ethylene) and Random Copolymers (propylene and ethylene). Presently, the two PP plants produce about 26 different grades of polypropylene for various uses. The C3 expansion project involves upgrading and implementing changes to the existing PP1 and PP2 process equipment to accommodate the increase in throughput. The site of the proposed project is located in the existing PP1 and PP2 plants within the Sasol Polymers plant at the Sasol Secunda Industrial Complex. 1.1 Applicable Documentation The following environmental documentation is applicable for the project, and will be read in conjunction with this EMPr: Basic Assessment Report for the Proposed C3 Expansion Project, Secunda, Mpumalanga Province. Environmental Authorisation (EA) from the Mpumalanga Department of Economic Development, Environment and Tourism (MDEDET) once issued. 1.2 Structure of the Environmental Management Programme The EMPr provides proposed mitigation and management measures for the following phases of the project (refer to FIGURE 1).

9 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA FIGURE 1: DIFFERENT PHASES OF THE PROJECT LIFECYCLE Relevant environmental legislation pertaining to the project is listed within Chapter 3. Sasol shall be responsible for ensuring compliance with the conditions by any person acting on their behalf, including but not limited to, an agent, contractor, sub-contractor, employee or person rendering a service to the holder of the authorisation. This EMPr is a dynamic document which will be updated as required on a continuous basis to ensure environmental best practices. Any amendments made, must be submitted to both the Sasol EIA specialist and Project Manager for approval. Amendments to the EMPr must be submitted to the MDEDET. 1.3 Objectives of the Environmental Management Programme The EMPr has the following objectives: To outline functions and responsibilities of responsible persons. To state standards and guidelines, which are required to be achieved in terms of environmental legislation. To outline mitigation measures and environmental specifications which are required to be implemented for all phases of the project in order to minimise the extent of environmental impacts, and to manage environmental impacts associated with the proposed project. To prevent long-term or permanent environmental degradation. T01.PTA Page 2 RHDHV

10 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 1.4 The EMPr as a live Document The approach adopted for this EMPr is derived from the Deming Cycle (FIGURE 2), a cycle of continuous improvement that entails the reiterative actions of plan, do, check, act, and critically to then return to the planning phase. FIGURE 2: DEMING CYCLE OF CONTINUING IMPROVEMENT Plan Project-specific planning for the proposed project involves consideration of the legal triggers, the specifics of the proposed development, and the nature of the receiving environment. This provides a starting point for targeted environmental management objectives. Environmental performance indicators are then determined with measurable targets prescribed to monitor the environmental performance of the project. Achieving the targets depends on compliance with this EMPr and the legislative requirements that underpin it Do Throughout the development s life-span, the developer and operator will be required to develop and maintain a Quality Management System designed to ensure that best management practices are implemented in day-today management. Such a QMS should at least include the following information: Location and extent of associated infrastructure; Associated activities, such as the transportation of people and equipment; Resources and experience required (staffing); Materials and equipment to be used; Management actions; Human resources used; Construction-monitoring activities; Emergency / disaster incident and reaction procedures; and Rehabilitation procedures for the impacted environment Check A system of assessing monitoring results has been developed to check the environmental management performance. Continuous assessment facilitates proactive management of the environmental issues. Mitigation T01.PTA Page 3 RHDHV

11 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA measures can then be successfully implemented on an ongoing basis to keep environmental indicators within their target thresholds. Moreover, the assessment system also enables the assessment of the efficacy of the EMPr. Regular auditing of environmental performance is prescribed to prove and preserve accountability Act The assessments and monitoring of the results and findings of the regular audits must be documented within a reporting system. Precautionary mitigation measures and corrective actions will be prescribed and instructions will be given in order to implement these in the field. The findings of monitoring and auditing programmes can also be used to update the EMPr. Although the EMPr is a project-specific document, it is dynamic and should be updated regularly to address the changing circumstances of the scheme. 1.5 Details of the Environmental Assessment Practitioner (EAP) Consultant: Contact Person: Royal HaskoningDHV Phyllis Kalele and Prashika Reddy Postal Address PO Box Monument Park 0105 Telephone: (012) / 5973 Facsimile: (012) Expertise: phyllis.kalele@rhdhv.com / prashika.reddy@rhdhv.com Phyllis Kalele is a Senior Environmental Consultant with a MSc. Environment and Development. Ms. Kalele has experience in various facets of environmental management including conducting the Public Participation process; compiling Environmental Impact Reports and Environmental Management Programmes; conducting environmental awareness training; and conducting legal compliance audits. She is a registered Professional Natural Scientist (Pr Sci Nat /11) with the South African Council for Natural Scientific Professions (SACNASP). Prashika Reddy is a Principal Associate / Senior Environmental Scientist (Pr Sci Nat /10) with a BSc Honours in Geography. Ms Reddy has the necessary experience in various environmental fields including: environmental impact assessments, environmental management plans/programmes, public participation and environmental monitoring and auditing. Ms Reddy has extensive experience in compiling environmental reports (Screening, Scoping, EIA and Status Quo Reports). Ms Reddy is/has been part of numerous multi-faceted large scale projects, including the establishment of linear developments (roads, and power lines); industrial plants; electricity generation plants and mining-related projects. T01.PTA Page 4 RHDHV

12 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 2 MANAGEMENT AND MONITORING PROCEDURES 2.1 Organisational Structure and Responsibility The Project Management Team will: Ensure that the Contractor/s is aware of all specifications, legal constraints and Sasol standards and procedures pertaining to the project, specifically with regards to the environment. Ensure that all stipulations within the EMPr are communicated and adhered to by Sasol and its Contractor(s). Be fully conversant with the Environmental Impact Assessment for the project, the conditions of the Environmental Authorisation (once issued), and all relevant environmental legislation. The Sasol Technology EIA Specialist will: Direct the implementation of the EMPr during design. Ensure that the requirements of the EMPr are communicated, understood and enforced by personnel on site during construction and pre-commissioning. Ensure that the aspects/impacts in the EMPr which relates to operations are explained to the business unit SH&E representatives. The SH&E representatives will incorporate requirements into either existing or new environmental management systems. Arrange for undertaking of internal environmental audits and co-ordinate external environmental audits, if necessary. Advise management on environmental issues. The Contractor (including sub-contractors) will be responsible for: Complying with the environmental management specifications. Adhering to any instructions issued by the Project Manager on advice of the Sasol Technology EIA Specialist. Keep record of all incidents that have occurred during construction period. This should be available during audits. Maintaining a public complaints register. Conduct environmental training and awareness to employees. Arrange for all employees and those of subcontractors to receive training before the commencement of construction in order that they are aware of the conditions of the environmental authorisation and the EMPr. The Environmental Control Officer will: Be fully conversant with the Basic Assessment study. Be fully conversant with the conditions of the Environmental Authorisation. Be fully conversant with the EMPr. Be fully conversant with all relevant environmental legislation and Sasol environmental policies and procedures, and ensure compliance with them. Convey the contents of this document to the Contractor site staff and discuss the contents in detail with the Project Manager and Contractor. Undertake regular and comprehensive inspection of the site in order to monitor compliance with the EMPr and Environmental Authorisation. Take appropriate action if the specifications contained in the EMPr are not followed. Monitor and verify that environmental impacts are kept to a minimum, as far as possible. Review and approve construction methods (where it could result in environmental impacts) with input from the Project Manager where necessary. Ensure that activities on site comply with all relevant environmental legislation. T01.PTA Page 5 RHDHV

13 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA Order the removal from the construction site of any person(s) and/or equipment in contravention of the specifications of the EMPr. Report any non-compliance or remedial measures that need to be applied to the appropriate environmental authorities, in line with the requirements of the Environmental Authorisation.. Adhering to any instructions issued by the Project Manager on advice of the Sasol Technology EIA Specialist. Keep record of all incidents that have occurred during construction period. This should be available during audits. Maintaining a public complaints register. Conduct environmental training and awareness to employees. Arrange for all employees and those of subcontractors to receive training before the commencement of construction in order that they are aware of the conditions of the environmental authorisation and the EMPr. 2.2 Environmental Awareness Plan It is important to ensure that the Contractor has the appropriate level of environmental awareness and competence to ensure continued environmental due diligence and ongoing minimisation of environmental harm. To achieve effective environmental management, it is important that employees, contractors and sub-contractors are aware of their responsibilities in terms of the relevant environmental legislation and the contents of this EMPr. Training needs should be identified based on the available and existing capacity of site personnel (including the Contractors and Sub-contractors) to undertake the required EMPr management actions and monitoring activities. It is vital that all personnel are adequately trained to perform their designated tasks to an acceptable standard. The environmental awareness plan is aimed at: promoting environmental awareness amongst all personnel on site; informing personnel of all environmental procedures, policies and programmes applicable; providing generic training on the implementation of environmental management specifications; and providing job-specific environmental training in order to understand the key environmental features of the construction site and the surrounding environment. The environmental awareness training programme will include: the induction of all construction and operation staff; signing by all persons, an acknowledgement of receiving and understanding the induction; identification of environmental risks and job specific training on addressing these risks; and training on the implementation of emergency procedures (where necessary). Topics covered by the Environmental Awareness Programme should include: What is meant by Environment? Why does the environment need to be protected and conserved? How can construction activities impact on the environment? What can be done to mitigate against such impacts? Awareness of emergency and spills response provisions. Training can be done either in a written or verbal format but will be in an appropriate format for the receiving audience. The training must ensure that the contents and requirements of the EMPr are transferred to the audience. Where training has been done verbally, persons having received training must sign an attendance register (which must be properly filed). Training should be conducted monthly by the ECO and can also be dealt with weekly during the Toolbox Talks. T01.PTA Page 6 RHDHV

14 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA In addition to training, general environmental awareness must be fostered among the project s workforce to encourage the implementation of environmentally sound practices throughout its duration. This ensures that environmental accidents are minimised and environmental compliance maximized. 2.3 Monitoring A monitoring programme will be in place not only to ensure compliance with the EMPr through the contract/work instruction specifications, but also to monitor any environmental issues and impacts which have not been accounted for in the EMPr that are, or could result in significant environmental impacts for which corrective action is required. Sasol Polymers will carry out the following: Internal Audits (conducted by Sasol Technology EIA Specialist and Environmental Control Officer by means of site visits). External Audits (conducted by Sasol Technology EIA Specialist and Environmental Management System Auditor). As part of the contract or work instruction, Sasol will stipulate the period and frequency of monitoring required. This will be determined from applicable permits and authorisations from authorities. The Project Manager will ensure that the monitoring is carried out. 2.4 Reporting Procedures Documentation The following documentation must be kept on site in order to record compliance with the EMPr: Record of Complaints Monitoring Results Non-conformance Reports Written Corrective Action Instructions Notification of Emergencies and Incidents Reporting The above records will form an integral part of the Contractors Records. These records will be kept with the EMPr, and will be made available for scrutiny if so requested during audits. T01.PTA Page 7 RHDHV

15 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 3 ENVIRONMENTAL GUIDELINES, STANDARDS AND PERMITS 3.1 Legal Summary The following is a summary of the environmental legislation applicable to the proposed project. LEGISLATION SECTIONS RELATES TO The Constitution (No 108 of 1996) National Environmental Management Act (No 107 of 1998) as amended]) Environment Conservation Act (No 73 of 1989) and regulations National Heritage Resources Act (No 25 of 1999) and regulations Chapter 2 Section 24 Section 2 Section 24 Section 28 Sections 19 and 19A Section 34 Bill of Rights. Environmental rights. Defines the strategic environmental management goals and objectives of the government. Applies throughout the Republic to the actions of all organs of state that may significantly affect the environment. Provides for the prohibition, restriction and control of activities which are likely to have a detrimental effect on the environment. The developer has a general duty to care for the environment and to institute such measures as may be needed to demonstrate such care. Prevention of littering by employees and subcontractors during construction and the maintenance phases of the proposed project. No person may alter or demolish any structure or part of a structure which is older than 60 years without a permit issued by the relevant provincial heritage resources authority. Section 35 Section 36 No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or palaeontological site. No person may, without a permit issued by the South African Heritage Resource Agency (SAHRA) or a provincial heritage resources authority destroy, damage, alter, exhume, remove from its original position or otherwise disturb any grave or burial ground older than 60 years which is situated outside a formal cemetery administered by a local authority. Grave is widely defined in the Act to include the contents, headstone or other marker of such a place, and any other structure on or associated with such place. T01.PTA Page 8 RHDHV

16 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA LEGISLATION SECTIONS RELATES TO Section 38 This section provides for Heritage Impact Assessments (HIAs), which are not already covered under the ECA. Where they are covered under the ECA the provincial heritage resources authorities must be notified of a proposed project and must be consulted during the HIA process. The Heritage Impact Assessment (HIA) will be approved by the authorising body of the provincial directorate of environmental affairs, which is required to take the provincial heritage resources authorities comments into account prior to making a decision on the HIA. National Environmental Management: Air Quality Act (No 39 of 2004) Occupational Health and Safety Act (No 85 of 1993) National Water Act (No 36 of 1998) and regulations Hazardous Substances Act (No 15 of 1973) and regulations National Environmental Management: Waste Act (No. 59 of 2008) Section 32 Section 34 Section 35 Section 8 Section 9 Section 19 Section 20 Control of dust. Control of noise. Control of offensive odours. General duties of employers to their employees. General duties of employers and self employed persons to persons other than their employees. Prevention and remedying the effects of pollution. Control of emergency incidents. Provides for the definition, classification, use, operation, modification, disposal or dumping of hazardous substances. Provides for specific waste management measures and the remediation of contaminated land. 3.2 Other Relevant Acts and Guidelines All applicable environmental standards contained within the environmental legislation will be adhered to. At the time of compiling this final draft EMPr, the following environmental guidelines, department policies, environmental management instruments were identified as being applicable: OTHER RELEVANT ACTS, GUIDELINES, DEPARTMENTAL POLICIES, ENVIRONMENTAL MANAGEMENT INSTRUMENTS Hazardous Substance Act (No 15 of 1973) and Regulations Gert Sibande District Municipality Spatial Development Framework (2009) South African National Standard SANS 10103:2008 (The Measurement and Rating of Environmental Noise with Respect to Annoyance and Speech Communication) National Noise Control Regulations (1998) Sasol Safety, Health and Environmental Policy T01.PTA Page 9 RHDHV

17 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 4 CONSTRUCTION PHASE ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S 1. Appointment of a contractor 2. Environmental Awareness and Safety Training 3. Personal Protective Equipment (PPE) Sasol must ensure that this EMPr forms part of any contractual agreements with a contractor(s) and sub-contractors for the execution of the proposed project. Tool Box Talks The contractor is expected to have safety tool box talks. These talks shall be in accordance with the risks and trends associated with the project. Proof of these talks shall be kept on site. The principal contractor will develop a specific emergency procedure and implement an emergency plan based on the Sasol Business Unit s (SBU s) guidelines for that site. No person is allowed to enter the site without the SBU approved required PPE. All contractors shall be trained on the correct use of PPE. All contractors are required to keep an updated register of all PPE issued. A contractor shall ensure action is taken against an employee who continuously fails to comply. PPE minimum requirement notice boards shall be placed at all entrances. Strict non-compliance measures must be administered to any employees not complying with the use of PPE. Project Manager Contractor Contractor 4. Dust Control (Sources: access roads; bare area cleared for construction; debris handling; movement of There should be strict speed limits on site roads to prevent the liberation of dust into the atmosphere. Dust must be suppressed on the construction site. During the If monitoring results or complaints indicate inadequate compliance with the EMPr, the source of the problem must be identified and existing procedures modified to ensure that Contractor T01.PTA Page 10 RHDHV

18 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S construction machinery and equipment; and trucks transporting spoil and fill material). transportation of material during dry periods by the regular application of water. Water used for this purpose must be used in quantities that will not result in the generation of run-off. To avoid the generation of unnecessary dust, material drop height should be reduced and material storage piles should be protected from wind erosion. This can take the form of wind breaks, water sprays or vegetation of piles. the problem is rectified. 5. Noise (Sources: excavation and site clearing, construction vehicles/machinery, construction staff, blasting and or drilling; operation of pumps). Vehicles and equipment must be maintained in good working order. Construction staff working in area where the 8-hour ambient noise levels exceed 85 dba must have the appropriate Personal Protective Equipment (PPE) e.g. ear protection equipment Where possible, stationary noisy equipment (for example compressors, generators etc. should be encapsulated in acoustic covers, screens or sheds. Portable acoustic shields should be used in the case where noisy equipment is not stationary (for example: drills, angle grinders, chipping hammers). The contractor will respond timeously in the event of any complaints by local residents or others about disturbing noise. The noise source will be identified and appropriate noise mitigatory measures instituted in consultation with the affected party (ies). Contractor Project Manager 6. Storage and Handling of Hazardous Substances (Examples: paint; oils; diesel; thinners; cement) The contractor must comply with all national, regional and local legislation with regard to the storage, transport, use and disposal of chemicals, harmful and hazardous substances and materials. The contractor will be responsible for the training and education of all personnel on site on handling the material, its proper Any accidental chemical/fuel spills to be cleaned up immediately. Keep MSDS records of chemicals in use up to date. Waste records must be kept available for review. Implement appropriate actions and measures to reduce, stop or Contractor T01.PTA Page 11 RHDHV

19 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND MONITORING AND RESPONSIBLE CONTROLS CORRECTIVE ACTIONS PERSON/S use, and disposal as well as spill response. Ascertain that the workers understand the content of the hazardous products and the information on the MSDSs. MSDS s of chemicals must always be available. Clear signage must be placed at all storage areas containing hazardous substances / materials. Any hazardous waste from the clean up must be disposed off at a hazardous waste site. In the event of a spillage occurring, clean up must be done immediately to prevent widespread pollution. Ensure that functioning spill kits are available on site to clean up spills and leaks. Lubricants, chemicals and other hazardous substances must be stored in a designated area that is well ventilated, with an impervious surface, bunded, covered, and able to contain 110% of the total volume of materials stored at any given time. Refuelling of machinery must be done using a drip tray and vehicle refuelling must only be done at the designated area. Ensure that only designated areas are used for the handling or storage of construction materials and fuels. Equipment and vehicles should be regularly inspected in order to detect contain a spill of potentially hazardous substances (e.g. fuel or lubricating oil). Implement appropriate actions and measures to reduce or prevent contamination of the ground and surface water as a result of a spill of potentially hazardous substances. Keep written records detailing the type of spill, the corrective and remedial measures implemented in the stopping or reduction of the spill, and the clean up of the spill. Such progress reporting is important for monitoring and auditing purposes and the written reports may afterwards be used for training purposes in an effort to prevent similar future occurrences. Report the nature and extent of the spill to the Construction Safety Officer or Project Manager, as soon as reasonably possible, but within 24 hours. The contractor and the Construction Safety Officer will ensure that preventative measures are implemented in order to prevent spills of potentially hazardous substances. T01.PTA Page 12 RHDHV

20 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND MONITORING AND RESPONSIBLE CONTROLS CORRECTIVE ACTIONS PERSON/S 7. Waste Management (Sources: domestic waste, spent grinding material, mixed concrete, paint cans and brushes, insulation material, building rubble and other construction waste). leaks as early as possible. All diesel generators will be equipped with drip trays and the contractor should ensure that the generators are in good working condition. Access must be strictly controlled and only authorised persons may enter. Fire fighting equipment must be present at all storage facilities. General waste disposal bins will be made available for employees to use throughout the construction phase and littering should not be allowed. Waste will be temporarily stored on site (less than 90 days) before being disposed of appropriately. General waste e.g. packaging material and spent welding rods will be disposed of at an approved waste disposal facility. Records of all waste being taken off site must be kept as evidence. Burning of waste will not be permitted. Hazardous materials will be generated if there are spillages during construction and maintenance periods. This waste should be cleaned up using absorbent material provided in spill kits on site. Absorbent materials used to clean up spillages should be disposed of in a separate hazardous waste bin. Hazardous waste generated e.g. mixed concrete, paint cans and brushes, contaminated soil must be disposed of at a licensed hazardous waste disposal site. Records of waste disposed of must be kept. The storage area for hazardous waste material must be concreted, bunded, Corrective actions are required to be undertaken immediately after a complaint is made or a nonconformance is identified. Contractor Project Manager T01.PTA Page 13 RHDHV

21 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S covered, labelled and well ventilated. Provide employees with appropriate PPE for handling hazardous materials. All hazardous waste will be disposed of in a registered hazardous waste disposal facility. The construction staff handling chemicals or hazardous materials must be trained in the use of the substances and the environmental, health and safety consequences of incidents. The contractor must design, test/exercise appropriate emergency preparedness programmes (plans, schedules, procedures and methods) for addressing environmental accidents, incidents and events such as spills of fuel, lubricants; fires etc. 8. Employment All labour (skilled and unskilled) and contractors should be sourced locally where possible. Recruitment at the construction site will not be allowed. 9. Traffic Routes for the passage of vehicles and machinery must be agreed by the project team to ensure minimal disruption to daily plant activities. Contractor Project Manager Project Manager T01.PTA Page 14 RHDHV

22 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 5 PRE-COMMISSIONING ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S 1. Storage and handling of hazardous substances An inventory of all chemicals on site must be kept. MSDSs must always be available. Access to the store must be controlled and flammable and inflammable materials should be kept separately. Ascertain that the workers understand the content of the products and the information on the MSDSs. All chemicals will be kept in a properly bunded area with access control. Emergency plan and procedures must be put in place. Ensure that used chemicals are disposed of at a permitted hazardous waste disposal site. Any accidental chemical/fuel spills are to be cleared up immediately. Keep MSDS records of chemicals in use up to date. Implement appropriate actions and measures to reduce, stop or contain a spill of potentially hazardous substances (e.g. fuel or lubricating oil). Implement appropriate actions and measures to reduce or prevent contamination of the ground and surface water as a result of a spill of potentially hazardous substances. Keep written records detailing the type of spill, the corrective and remedial measures implemented in the stopping or reduction of the spill, and the clean-up of the spill. Such progress reporting is important for monitoring and auditing purposes and the written reports may afterwards be used for training purposes in an effort to prevent similar future occurrences. Report the nature and extent of the spill to the Construction Safety Officer or Project Manager, as soon as reasonably Project Manager T01.PTA Page 15 RHDHV

23 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND MONITORING AND RESPONSIBLE CONTROLS CORRECTIVE ACTIONS PERSON/S possible, but within 24 hours. The SHE officer will ensure that preventative measures are implemented in order to prevent spills of potentially hazardous substances. 2. Waste water (effluent handling) (Examples: water used for cleaning/flushing of plant equipment; hydraulic testing; circulation; leak testing) Contaminated water should be directed into the correct disposal system and none should go into the stormwater system. Waste water must not be allowed to come into direct contact with exposed soils or run across the plant site. Vehicles and machinery may not be washed on site. All waste water must be collected and disposed of in a correct and environmentally suitable manner. 3. Venting of Equipment Venting of equipment must be minimized to prevent the risk of fire, air and noise pollution. Venting activities should comply with Sasol standards and should be conducted by properly trained personnel. Project Manager Project Manager T01.PTA Page 16 RHDHV

24 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA 6 OPERATIONS AND MAINTENANCE ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S 1. Cleaning of Equipment Chemicals will be disposed of correctly at a permitted site. Contaminated water should be routed to the correct drainage system according to the Water Management Procedure. Cleaning of equipment should be done in a designated bunded area to prevent eventual soil and water pollution. The chemicals used for cleaning must be disposed of correctly. MSDSs of the chemicals should always be available. 2. Water/effluent handling (routing of fire water; management of contaminated and uncontaminated stormwater). 3. Waste management: i.e. hazardous and general wastes generated during operational and maintenance activities e.g. servicing of old equipment Correct disposal of effluent must be ensured. Any spill should be cleaned up immediately and disposed off at a designated site. Ensure uncontaminated and contaminated stormwater are channelled into the correct system. Equipment that has the potential for spillages or leakages shall be equipped with drip-trays. Care should be taken to ensure that spillages of oils and effluent are limited during maintenance. In the event of a spill/leak, the source of the spill or leak must be identified and stopped. The oil/effluent spill/leak must be cleaned immediately and any contaminated soil must be removed and disposed off through a recognisable waste disposal Emergency plan and procedures should be in place. All workers should be trained on the proper procedure for disposal of the contaminated water. A qualified waste disposal company should be contracted to contaminated waste which may be hazardous. Emergency plan and procedures should be in place in the event of spillage. Functioning spill kits must be easily accessible. Any spill should be cleaned up immediately. Emergency plan and procedures should be in place in the event of spillage. Functioning spill kits must be easily accessible. Any spill should be cleaned up immediately and contaminated materials should be disposed off at a designated site. Operations Manager Operations Manager Operations Manager T01.PTA Page 17 RHDHV

25 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S 4. Health and Safety (spillage of products during loading and off-loading; leaking of products) 5. Storage, loading and offloading of catalysts method. Hazardous waste must be stored in a covered, well labelled, ventilated area which is also bunded. Hazardous and general waste must be disposed off at a licensed hazardous waste disposal facility. Evidence of correct disposal of waste must be retained. Uncontaminated equipment can be taken to a recycling facility e.g. metal. All personnel must be well trained to work in the PP plants. Strict access rules should be applied to personnel entering the PP plants. All operators should wear appropriate PPE. Procedures must be put in place for clean-up and incidents to be reported. Appropriate signage e.g. no smoking should be clearly displayed in the PP plant. The PP plants should be regularly maintained as required to ensure that all the fittings and equipment are in good working condition. Procedures to be in place to prevent spillages/clean-up procedures to be followed and incidents to be reported. 6. Noise production Personnel working in the PP plants must have the appropriate Personal Protective Equipment (PPE) since ambient noise levels usually exceed 85 dba. 7. Effluents handling as a result of cleaning vessels and draining of vessels Correct disposal of effluent must be ensured. All workers should be trained on the Emergency plan and procedures should be in place in the event of spillage. Operations Manager Operations Manager Operations Manager Operations Manager T01.PTA Page 18 RHDHV

26 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED C3 EXPANSION PROJECT AT SASOL, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND MONITORING AND RESPONSIBLE CONTROLS CORRECTIVE ACTIONS PERSON/S during shutdowns. correct cleaning procedures and draining methods. All workers should wear appropriate PPE. Equipment must be designed and managed properly in accordance with Sasol standards and specifications. Appropriate measures should be taken to avoid spillages. Functioning spill kits must be easily accessible. Any spill should be cleaned up immediately and contaminated materials should be disposed off at a designated site. 8. Management of catalysts during shutdowns. Ensure that disposal procedures are in place and that disposal takes place at permitted sites. Operations Manager T01.PTA Page 19 RHDHV

27 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED SASOL C3 EXPANSION PROJECT AT THE SASOL INDUSTRIAL COMPLEX, SECUNDA, MPUMALANGA 7 DECOMMISSIONING PHASE 7.1 General Principles for Environmental Management during Decommissioning At this point of the project planning process, the necessity for and timing of the decommissioning of the proposed project is not known.. If decommissioning of the PP plants does occur, it will be undertaken together with the entire Sasol Industrial complex s operations. During decommissioning, all appropriate legal procedures will be followed e.g. giving notice to the relevant authorities. Furthermore, an application in terms of Listing Notice 1 of the EIA Regulations (2010) for the relevant Environmental Authorisation will be lodged if applicable. ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND MONITORING AND CORRECTIVE RESPONSIBLE CONTROLS ACTIONS PERSON/S 1. Waste generation during the decommissioning phase will have a negative impact on the environment, if not controlled adequately. Waste includes general waste or hazardous waste. The Contractor must familiarise themselves with the definitions of waste and the handling, storage and transport of waste as prescribed in the applicable environmental legislation. General waste disposal bins will be made available for employees to use and littering should not be allowed. Waste will be temporarily stored on site (less than 90 days) before being disposed of appropriately. General waste e.g. packaging material and spent welding rods will be disposed of at an approved waste disposal facility. Records of all waste being taken off site must be kept as evidence. Burning of waste will not be permitted. Hazardous materials will be generated if there are spillage; this waste should be cleaned up using absorbent material provided in spill kits on site. Absorbent materials used to clean up spillages should be disposed of in a Project Manager T01.PTA Page 20 RHDHV

28 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED SASOL C3 EXPANSION PROJECT AT THE SASOL INDUSTRIAL COMPLEX, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S separate hazardous waste bin. Hazardous waste generated e.g. contaminated soil must be disposed of at a licensed hazardous waste disposal site. Records of waste disposed of must be kept. The storage area for hazardous waste material must be concreted, bunded, covered, labelled and well ventilated. Provide employees with appropriate PPE for handling hazardous materials. All hazardous waste will be disposed of in a registered hazardous waste disposal facility. Ablution facilities in the form of mobile chemical toilets must be provided on site. Chemical toilets must be cleaned and emptied regularly by a registered service provider. All rubble is to be removed from the site to an approved disposal site. 2. Removal of equipment. All structures comprising the construction lay down area and plant are to be removed from site. All areas must be inspected for spills of substances such as oil, paint, etc, and these shall be cleaned up. Fences, barriers and demarcations associated with the deconstruction phase are to be removed from the site. 3. Erosion control. All areas where topsoil was removed or placing of infrastructure should be landscaped in order to reflect surrounding Project Manager Project Manager T01.PTA Page 21 RHDHV

29 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED SASOL C3 EXPANSION PROJECT AT THE SASOL INDUSTRIAL COMPLEX, SECUNDA, MPUMALANGA ACTIVITY / ISSUE ENVIRONMENTAL MEASURES AND CONTROLS MONITORING AND CORRECTIVE ACTIONS RESPONSIBLE PERSON/S conditions. Erosion monitoring and control should be conducted. 4. Dust control There should be strict speed limits on site roads to prevent the liberation of dust into the atmosphere. Dust must be suppressed on the construction site, temporary dirt roads and during the transportation of material during dry periods by the regular application of water. Water used for this purpose must be used in quantities that will not result in the generation of run-off. All site workers during deconstruction will need to wear the appropriate PPE to avoid excessive exposure to dust particles. 5. Noise control Provide all equipment with standard silencers. Maintain silencer units in vehicles and equipment in good working order. Staff working in areas where the 8-hour ambient noise levels exceed 85 dba must have the appropriate Personal Protective Equipment (PPE). 6. Safety on site Ensure the appointment of a Safety Officer to continuously monitor the safety conditions during deconstruction. All staff must have the appropriate PPE. Staff handling chemicals or hazardous materials must be trained in the use of the substances and the environmental, health and safety consequences of incidents. Report and record any environmental, health and safety incidents to the Project Manager Project Manager Project Manager T01.PTA Page 22 RHDHV