Sasol is committed to compliance with all applicable laws and requirements arising from our environmental authorisations. Our environmental managers and subject matter experts support operations in managing compliance with these requirements.
We report incidents and deviations from regulatory requirements and limits and work in a transparent manner with the authorities in addressing any compliance challenges that may arise.
In the past year, our operations globally have been subject to various environmental authority inspections and associated compliance enforcement actions as highlighted below:
- In South Africa, the Department of Water and Sanitation (DWS) conducted various inspections at our Sasol Mining, Secunda Synfuels Operations (SSO) and Secunda Chemical Operations (SCO). They provided a notice of intention to SCO to issue a directive regarding the use of a product dam on-site. SCO subsequently confirmed the closure of the dam, subject to the execution of a rehabilitation plan expected to be completed in 2018. The DWS accepted Sasol’s representations, with ongoing monitoring. All other findings were addressed and satisfactorily closed out.
- The Department of Environmental Affairs (DEA) conducted inspections with a focus on air quality compliance at both Sasol’s and Natref’s operations (Sasol has majority shareholding in Natref) in Sasolburg. They provided a notice of intention to issue a compliance notice relating primarily to compliance challenges experienced by our Sasolburg Operations (SO), with emission limit values for some parameters applicable to three onsite incinerators regulated in terms of an Atmospheric Emissions Licence (AEL). SO provided details of ongoing and planned initiatives to enable and sustain compliance and engagements with the relevant authorities which are ongoing.
Natref received a notice of intention to issue a compliance notice regarding (among other) a perceived exceedance of a sulphur dioxide limit in its AEL. Natref submitted a response explaining the confirmed compliance.
The Gert Sibande District Municipality inspected Sasol’s operations in Secunda (SSO and SCO) with a focus on compliance with air quality and waste management. The outcome is pending. However in June 2017, the DEA issued the outcome of a previous air quality compliance inspection conducted at the Secunda complex and noted no major findings of concern.
- No final enforcement action has been taken, or fines and penalties imposed, as a consequence of any of the inspections in relation to our South African operations.
- In the United States, the Louisiana Department of Environmental Quality conducted inspections at the Lake Charles Chemicals Project (LCCP) and consequently issued a notice to mitigate emissions of nuisance particulates and dust caused by construction-related trucking. A dust control plan has since been implemented. Corrective measures were also implemented in response to a warning letter from the same authority to address a self-reported ethylene release by our Lake Charles Operations in Louisiana. Corrective measures were also implemented to address air permit violations in relation to our Greens Bayou Plant in Houston, Texas, following inspections by the Texas Commission on Environmental Quality.
- In Italy, our operations in Sarroch undertook an impact report and updated its continuous emission monitoring to address emission limit exceedances to air licences following an order issued by the Environmental Agency. Our operations in Augusta and Sarroch continue to engage with the regional environmental agency on remedial action regarding contaminated land and water to address matters raised during site visits conducted by the agency. The Sarroch operations paid a fine of 15 000 Euros regarding a deviation noted by the Ministry of Environment related to the updating of an Emergency Response Plan.
- Our operations in Brunsbüttel, Germany, commenced with a remediation project to address nitrogen oxide limit value exceedances associated with its high pressure hydrogenation unit. This was formally agreed with the applicable regulatory authorities in mitigation of enforcement action. Land risk management activities for the whole site, focusing initially on technical assessments to inform a remediation plan to meet anticipated new legal requirements, are ongoing.
We adopt a transparent and collaborative approach to environmental compliance management and engage with the authorities proactively where we identify compliance challenges. We disclose non-compliance with conditions of authorisations and the management thereof to the relevant authorities. Given specific stakeholder interest in our South African operations, we provide examples in this report of some of the significant compliance challenges reported and addressed:
- Significant environmental incidents associated with water uses and impacts were reported to the DWS. Sasol Mining reported activities in a delineated wetland promptly on becoming aware thereof and ceased all activities pending the implementation of an acceptable solution. Other reported incidents related to the inappropriate management of dirty water.
Natref reported an overflow of an onsite dam due to extreme rainfall experienced in February 2017. SO experienced similar overflows due to the same rainfall and also reported this to the DWS. The necessary remedial actions in all instances have been taken as informed by incident investigations. Following ongoing sampling campaigns, deviations from applicable water quality and discharge limits contained in water use licences (WUL) for our SSO, Satellite, SO and Natref operations were identified. We have addressed these deviations through amendment applications, corrective action plans and also assessed and furthered groundwater remediation options for implementation where necessary.
- Air quality compliance challenges were experienced and reported to the DEA. Our operations in Secunda and Sasolburg experienced deviations from AEL conditions and environmental incidents which were duly reported to the authorities. This included statutory environmental incident reports by SCO on exceedances of emission limit values at the octene regenerator stack. SSO reported an environmental incident regarding exceedances of stack emission limit values at the catalyst manufacturing plant and regarding a gas release related to a ruptured line. In the latter instance, it was necessary to implement emergency procedures to isolate the area to contain a further gas release. An immediate potential safety or environmental risk was thereby successfully averted. The necessary corrective actions were taken to enable and sustain compliance.
Following heavy rains in February 2017, SSO proactively reported anticipated delays with the completion of the construction and safe commissioning of Regenerative Thermal Oxidisers (RTOs) required for emissions abatement. Commissioning activities of the last two RTOs started in May 2017, subject to further modifications being implemented to support safe, reliable and sustainable operations. Other challenges communicated by SSO to the local licensing authority included ammonia venting following start up due to a power dip, and exceedance of hydrogen sulphide emission limits pertaining to the sulphur recovery plant following various unexpected operational incidents during the September shutdown. SSO enabled compliance by undertaking the necessary repairs following the plant shutdown and has since sustained compliance with all applicable limits.
The sulphur oxides (SOx) N-Base scrubber at SO has been experiencing challenges with sulphur trioxide concentrations which was reported to the local licensing authority. Additional sampling has been conducted to support optimisation, which has since enabled compliance. Engagement with the local licensing authority is ongoing. SO also submitted a statutory report regarding a black smoke incident associated with flaring necessitated by a forced shutdown from a complete loss of power supply to parts of the plant. The power supply interruption was unrelated to Sasol’s activities.
Natref in Sasolburg reported an incident following an explosion and fire at a hydrogen compressor. Emergency control and mitigation actions implemented necessitated the shutting down of five affected units and consequently also the Sulphur Recovery Unit (SRU) due to a lack of feed. It therefore did not result in environmental or community impacts.
- SSO is following a licence amendment process to align its licence with changed legal and operational requirements in the interest of sustained compliance.