Sasol Limited Sustainability Report 2021 - Book - Page 53
SUSTAINABILITY PERFORMANCE AGAINST OUR FOCUS AREAS: MINIMISING OUR ENVIRONMENTAL FOOTPRINT (CONTINUED)
We are committed to complying with all
applicable laws and obligations arising
from our environmental authorisations
and this is embedded in our Code of
OUR SOUTH AFRICAN OPERATIONS
Engagements with DWS
Engagements with the DFFE
In Sasolburg, Natref and SEO continued engagements with the DWS on pending WUL
amendments, aimed at mitigating compliance challenges mainly associated with storm
water management and discharge quality objectives. In April 2021, Natref consequently
received an amended WUL.
At Sasolburg Operations there were loss of containment incidents during the reporting
period, these resulted in no significant environmental impacts due to the effectiveness
of existing mitigation measures and/or the nature of the incident. Nonetheless, the
incidents were reported as per DFFE requirements. We continue engagements with the
DFFE on progressing our air quality compliance roadmaps. For further detail on air quality
management refer to pages 44 to 47.
Natref reported an incident, in terms of section 20 of the National Water Act, 36 of 1998
that occurred in December 2020, associated with the release of out-of-specification
stormwater from the clean stormwater dam. This was after a sudden cloud burst which
resulted in more than 80mm of rainfall within an hour. The release was a preventative
measure to mitigate risk of overflow of the dam. At Natref’s Durban operations there was
a leak in an underground 16” crude oil pipeline which resulted in soil contamination. Natref
notified the relevant authorities and undertook various remedial measures.
In Secunda, Sasol Mining continues engagements with the DWS regarding water use
authorisations and WUL amendment applications previously submitted and reported on.
Due to heavy rainfall in the Secunda area, the stormwater sump at Irenedale shaft filled
up and spilled over. We reported the incident to the DWS and appointed rehabilitation
specialists to assist with the clean-up. In addition, there was an overflow of mine
water from a borehole located within the defunct Sigma Mining Right area adjacent
to the Leeuspruit. We reported on the incident, in terms of section 30 of the National
Environmental Management Act, 107 of 1998 (NEMA), and capped and sealed the
borehole. Mining is planning for the sustainable closure of Sigma Mine. A key element
in this process is to complete investigations into the post-closure water balance of the
underground mine and remaining opencast voids.
Managing and reporting on
our compliance challenges
We engage in a transparent and collaborative manner
with authorities through established forums and where
we anticipate or identify compliance challenges. We report
incidents of non-compliance including details of the
corresponding corrective and preventative measures.
We also continue to engage with the DFFE and local licensing authorities to mitigate any
potential risks of non-compliance associated with our environmental authorisations.
Engagements with the Environmental Management Inspectorate
At our Secunda Operations, the Environmental Management Inspectorate (EMI) is
investigating if any offences have been committed under the NEMA and any Specific
Environmental Management Acts. As a basis, it is using the findings contained in the EMI
inspection report of 2019, on which we have previously reported.
The investigation also pertains to the Benfield plant and the API dams, based on third
party allegations of pollution of the Vaal River. These complaints had already been
considered by the South African Human Rights Commission inquiry, with no adverse
findings against Sasol. We have cooperated fully with the EMI, including facilitating a visit
to Secunda Operations in April 2021, and await the outcome of the investigation.
Secunda Operations has various WUL applications and amendments pending. These
relate to new water uses as well as amendment applications to reflect all water uses and
required changes to some conditions that are not site-specific and feasible. Engagements
with the DWS continue. We reported exceedances of water quality objectives, leaks that
spilled over into the Bossiespruit and effluent spillage at the waste recycling facility. In
addition, there was overflow of stormwater into the nearby environment as a result of
extremely high rainfall in Secunda within a 24-hour period. We reported the incidents to
the relevant authorities. They did not impose any additional requirements following the
incident management actions we had taken.
We submit required periodic, quarterly and annual
reports. We also communicate to our stakeholders on
Sasol follows a robust process aimed at reporting and
mitigating environmental incidents, including any deviations
from legal requirements that could lead to environmental
harm. This approach is based on an incident classification
system which includes assessing incidents based on their
potential to create significant degradation or pollution of
the environment. Incidents are investigated and detailed
assessments are conducted as necessary in order to ensure
effective remedial measures are implemented. We share
learnings from these investigations throughout the Group to
reduce the likelihood of a similar incident occurring again.
We collaborate with the authorities on environmental
inspections conducted at our facilities. Our responses
to findings, include key remedial interventions aimed at
sustaining compliance. For the 2021 financial year no final
enforcement actions were instituted for our South African
OUR GLOBAL OPERATIONS
Our North American Operations was previously notified by the Environmental Protection
Agency (EPA) of potential liability associated with disposal of certain wastes at the former
disposal facility called Pure Earth Recycling Superfund Site in Cumberland County, New
Jersey. In July 2020, Sasol and the 12 other parties agreed and signed an Administrative
Settlement Agreement and Order on Consent for Removal. Each party paid US$150,000 to
the EPA to assist with the clean up of the facility and to resolve any past liabilities.
Various inspections of our Eurasian Operations were carried out by the authorities in
the year. In most instances, there were no deviations and so no material findings were
recorded. There were no final enforcement actions or prosecutions and no fines and
penalties were imposed.
Sasol Sustainability Report 2021
In Mozambique, we submitted an updated environmental monitoring plan to the Ministry
of Land and Environment after our engagements on the impact on operations of COVID-19
global restrictions. In December 2020, the government audited the CPF operations. The
audit found no incidents of non-conformance, however it made certain observations that
we noted and are addressing.
A non-compliance notification was issued by the Department of Territorial Development
and Environment, relating to the compensation process undertaken during debushing for
the PT5-C2D Seismic Campaign. Sasol has engaged the authorities on the notification and a
final outcome is still pending.