ENVIRONMENTAL MANAGEMENT PLAN - Sasol Convenience Centre, Paul Kruger Street, Secunda

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ENVIRONMENTAL MANAGEMENT PLAN

Sasol Convenience Centre, Paul Kruger
          Street, Secunda
TABLE OF CONTENTS

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

2     OBJECTIVES ............................................................................................................................... 1

3     RESPONSIBLE PARTIES, SCHEDULING AND STAFF RESOURCES...................................... 1

4     MANAGEMENT OBJECTIVES .................................................................................................... 2

5     MANAGEMENT PRINCIPLES ..................................................................................................... 2

    5.1      ENVIRONMENTAL OPERATIONAL PROCEDURES .......................................................................... 3
      5.1.1     Environmental Officer........................................................................................................ 3
      5.1.2     Environmental Management Procedures to ensure compliance with the EMP.................. 3
      5.1.3     Legislation, permits and agreements................................................................................. 3
    5.2      ENVIRONMENTAL ISSUES TO BE MANAGED ................................................................................. 4
      5.2.1     Access control................................................................................................................... 4
      5.2.2     Air quality .......................................................................................................................... 5
      5.2.3     Consultation with Interested and Affected parties (IAPs)................................................... 5
      5.2.4     Effluent handling ............................................................................................................... 6
      5.2.5     Emergency plan ................................................................................................................ 6
      5.2.6     Fire prevention and control................................................................................................ 7
      5.2.7     Illumination ........................................................................................................................ 7
      5.2.8     Labour and social issues................................................................................................... 7
      5.2.9     Materials handling ............................................................................................................. 8
      5.2.10        Noise disturbance.......................................................................................................... 9
      5.2.11        Natural / Resource consumption ................................................................................... 9
      5.2.12        Soil ................................................................................................................................ 9
      5.2.13        Solid waste management ............................................................................................ 10
      5.2.14        Rehabilitation .............................................................................................................. 11
      5.2.15        Underground Storage Tanks and Equipment .............................................................. 11
      5.2.16        Visual Impact............................................................................................................... 13
      5.2.17        Water issues ............................................................................................................... 13
      5.2.18        Removal/replacement of old fuel tank ......................................................................... 13
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1   INTRODUCTION

    This Environmental Management Plan (EMP) addresses the management of environmental impacts
    related to the operation of a service station at Paul Kruger Street in Secunda on Erf 8403/1 of
    Extension 28. The document should be used as a basis for managing, mitigating and monitoring the
    environmental impacts associated with the pre-construction (design), construction and operational
    phases of the Environmental Impact Assessment (EIA) Supplementation study, conducted by SRK
    Consulting. The original Scoping Report and subsequent Supplementation Study will be valuable as a
    reference source for understanding this EMP and for placing it into perspective.

2   OBJECTIVES

    The primary objectives of the EMP are as follows:

    •   To describe action plans for achieving the mitigation measures described in the EIA.
    •   To indicate responsibilities, schedules and staff resources regarding the implementation of these
        action plans.
    •   To highlight a monitoring programme, that will enable review of the success of the EMP and the
        provision of such information to the relevant decision-makers.

3   RESPONSIBLE PARTIES, SCHEDULING AND STAFF RESOURCES

    There are at least three role-players participating in the environmental management of the site,
    including:
         •    Sasol Oil (oil company);
         •    Developer (Mr H. Kruger); and
         •    Contractors and Service Providers.

    This EMP must be attached as an appendix to tender documents and referred to in the tender documents
    as special conditions of tender.

    Overall responsibility for the implementation of the EMP lies with Sasol Oil. This responsibility, in some
    instances may be delegated to contractors in the employ of Sasol Oil for practical purposes, but Sasol Oil
    will retain legal responsibility. In that capacity, Sasol Oil should delegate suitably qualified person(s) with
    the responsibility to ensure implementation of the EMP, and will:
         •    Know the contents and implications of the EIA and monitor the implementation of EIA findings
              using the EMP and Project Aspect Register.
         •    Revise the EMP as required and inform the relevant parties of the changes.
         •    Protect the environment and rehabilitate the environment as prescribed in the EIA.

         The responsibilities of the Developer during the operational phase are inter alia to ensure that:

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         •    All requirements of the EIA and EMP are, communicated to, understood and followed by all
              persons working on the project who may have an impact on the environment.
         •    A procedure exists for reporting incidents and resolving any problems rapidly.
         •    Keep good records relating to the compliance/non-compliance with the conditions of the
              authorisation. These records must be made available to the relevant authority within seven
              days of receipt of a written request.

    The EMP will be presented to Mpumalanga DEAT (MDALA) on request. Once the authority has
    approved the EMP for the project, the management guidelines contained in this document will be
    implemented.

4   MANAGEMENT OBJECTIVES

    In line with Sasol Oil’s Safety, Health and Environmental Policy Declaration & Guidelines, the following
    objectives provide the framework for the environmental principles for environmental management of
    the project:
    •    As a minimum requirement, comply with all relevant local, provincial and national legislation.
    •    Manage and use land, raw materials and resources responsibly in order to minimise the
         disturbance of the prevailing ecology.
    •    Minimise the potential for deterioration of air quality during all project phases.
    •    Avoid “disturbing” noise levels (an increase in the ambient noise level of 7dB (A) or more at the
         border of the property from which the noise emanates).
    •    Minimise the use of clean water and avoid water wastage.
    •    Prevent the contamination of surface and ground water as a result of the service station activities.
    •    Ensure that an appropriate Emergency Procedure is in place to safeguard the environment, local
         community and employees.
    •    Practise the reduction and recycling of waste materials.
    •    Enhance the creation of direct job opportunities for the surrounding community and contribution of
         the project to the local economy, especially during labour intensive phases (construction and
         decommissioning).
    •    Reduce the disturbance of the surrounding community from site activities to a minimum.
    •    Maintain transparent relations with the Interested & Affected Parties (IAPs) (including surrounding
         community, authorities and employees).
    •    Ensure that the community and employees are not subjected to increased safety hazards.

5   MANAGEMENT PRINCIPLES

    These guideline principles will form the basis for environmental management on site. Should these
    principles require modification or additions during the project this should be done at the discretion of
    the responsible person, who will ensure that any modifications are communicated, explained to and
    discussed with all affected parties (i.e. the authorities, Sasol Oil, the contractors and service providers,
    the developer and any infected party who requests this information).

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The environmental operational procedures and environmental issues are identified and managed,
under different phases of the project. The different phases are:
•       Pre-construction (including design);
•       Construction Phase;
•       Operational Phase; and
•       Decommissioning Phase

5.1        Environmental Operational Procedures

5.1.1      Environmental Officer

A senior person from the Developer’s management shall be made responsible for overseeing
compliance with the EMP during the construction and operational phases. This person will also act as
the officially designated Environmental Officer (EO).

5.1.2      Environmental Management Procedures to ensure compliance with the EMP

Construction and Operational Phase
The Developer’s EO must set up and follow environmental management procedures to ensure
compliance with the EMP. This could include an environmental education programme to make all
contractors’ personnel employed on the project, and all personnel employed at the facility, aware of
the needs and desirability to act in an environmentally responsible ways.

5.1.3      Legislation, permits and agreements

           In all instances, Sasol Oil, Service Providers, Contractors and the Developer and its
           employees should remain in compliance with relevant local and national legislation,
           regulations and standards. Particular attention should be paid to the requirements of the
           following national legislation:

           •   Environment Conservation Act No. 73 of 1989
           •   National Environmental Management Act No. 107 of 1998
           •   National Water Act ,No. 36 of 1998
           •   Water Services Act, No. 108 of 1997
           •   Occupational Health and Safety Act, No 85 of 1993
           •   National Building Regulations and Building Standards Act, No 103 of 1977.
           •   South African Heritage Resources Act
           •   Relevant regulations as promulgated under the Standards Act, No 30 of 1982
           •   National Environment Management: Air Quality Act, No. 39 of 2004.
           •   Minerals and Petroleum Resources Development Act, No. 28 of 2002

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          Proof of compliance with the SANS 10089-3 and 1535 Codes of Practice for the Petroleum
          Industry must be forwarded by Sasol Oil to the MDALA prior to operation.

5.2       Environmental issues to be managed

          Pre-Construction Phase
          1. The Mpumalanga DEAT (MDALA) must be notified:
                     •    Within 30 days, of change of ownership / developer.
                     •    Of any change of address of the owner / developer.
                     •    One month prior to commencement of construction activities.
                     •    One month prior to commencement of operation.
          2. Ensure compliance with the conditions described in the Record of Decision.
          3. Records of compliance / non-compliance with the conditions of the authorisation must be
               kept and be available to Mpumalanga DEAT on request.
          4. If required by the Record of Decision, advertise the authorisation for one day for two
               consecutive weeks in two local newspapers.
          5. Records of all environmental incidents must be maintained, and a copy of these records
               be made available to the Mpumalanga DEAT / DWAF on request throughout project
               execution.

          Construction and Operational Phases
          Unless otherwise indicated, the responsibilities of the construction contractor(s) and service
          providers will adhere to specified EMP actions for the construction phase. During the
          operational phase, Sasol Oil will ensure that the following actions are implemented by
          establishing accountability and responsibility between the different role players.

          These actions/measures are as follows:

5.2.1     Access control

          Construction Phase
          1.    Ensure compliance with requirements of the Record of Decision.
          2.    The Local Traffic Department must be informed at least a week in advance if the traffic in
                the area is affected during construction.
          3.    Person and vehicle access should be restricted during construction so as to control
                access to otherwise potential dangerous excavations and materials.
          4.    The remote filler points on the tanks should be so situated that it is possible for the tanker
                to be able to enter and leave the premises without having to reverse, and can park safely
                when bulk fuel deliveries are being made.
          5.    Movement of construction vehicles potentially impacting on urban infrastructure should be
                mitigated through the use of appropriate warning signs, and not entering or leaving the
                site during peak traffic hours.

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          6.    The contractors must comply with the recommendations from the traffic study. Layout
                design should accommodate the impact on existing traffic flow patters (e.g. access
                points).

           Operational Phase
          Vehicles should be able to access and exit the site as follows:
          1. Left-in slip lane from the north-east for vehicles travelling south-west bound.
          2. Stop control at the north-eastern end of the site, which allows vehicles to exit the site into
               the north-east bound lane of Paul Kruger Street.
          3. Stop control for right turning traffic (and access lane) on the south-western end of the site.
               The lane configuration along Paul Kruger Street would allow for: (1) a lane for the main
               stream of traffic flowing past the site; and (2) a slip lane for traffic turning into the proposed
               SCC.
          4. Left-out lane into Paul Kruger Street for vehicles exiting the site in a south-west bound
               direction.
          5. Guidelines will be painted for all access and exit movements, including for the right turning
               movement. Ensure that this is in line with what is proposed in the SDP.
          6. Consideration will be given to constructing raised islands, which are designed to prevent
               motorists from entering and exiting via the wrong access lane.
          7. Pedestrian access from the adjoining sports and recreational facilities should be
               controlled.

5.2.2     Air quality

          Construction Phase
          1.    Dust generated during site clearance and the construction phase should be mitigated
                through dust control measures.
          2.    Vent pipes should be positioned at a point remote form all buildings and neighbouring
                property boundaries to mitigate the impact of vent gases from vent pipes and the
                interceptor chamber.

          Operational Phase
          The impact of vent gases from vent pipes and the interceptor chamber is minimised through
          positioning of the vent pipes at a point remote form all buildings and neighbouring property
          boundaries.

5.2.3     Consultation with Interested and Affected parties (IAPs)

          Construction and Operational Phases
          Open liaison channels should be established between the Sasol Oil, the developer, the
          contractors and IAPs such that any queries, complaints or suggestions can be dealt with
          quickly and by the appropriate person(s).

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5.2.4     Effluent handling

          The agreement with the Local Authority to handle additional sewage and effluent from the site
          must be in place.

          Construction Phase
          1. Dirty water areas must be lined by an impermeable material such as concrete to prevent
               infiltration and contamination of the soils within these areas.
          2. Use should be made of the necessary Local Authority Services for sewage removal.
          3. The site must be serviced by properly managed and maintained toilet facilities. One toilet
               should be provided per 1-15 staff members (male/female) on site. The contractor is to
               ensure that permanent on-site toilet facilities are properly maintained and are in working
               order. No disposal, or leakage, of sewage should occur. The Managing Contractor should
               verify if the necessary services are available for the operational phase.

          Operational Phase
          1.    Clean and dirty water systems must be separated to prevent contaminated run-off from
                entering the surface and groundwater and soil.
          2.    The effluent from the driveway area around the diesel dispensers / dispensing pumps
                must not flow to the street, or into watercourses or into storm water systems without first
                passing through a gravity-separator.
          3.    All waste oils, greases, fuels etc. must be collected and disposed of in an appropriate
                manner off site. The contents of grease traps or other waste oil, grease and/or fuel
                disposal/storage containers must under no circumstances be voided to the surrounding
                area.
          4.    All waste from the workshop must be disposed of in a suitable manner at a registered
                disposal site.
          5.    Should an accidental spill event occur, the effluent must be contained as far as possible
                in the separator pit. If there is a risk that the sump could overflow (such as in a storm
                event) then the spilled material must be stored in a tanker or other appropriate container
                until it can be treated and disposed of.

5.2.5     Emergency plan

          Construction and Operational Phases
          1.    An emergency plan should be available for major / minor spills and fire fighting at the
                service station during construction activities (with consideration of air, groundwater, soil
                and surface water).
          2.    All pollution incidents must be reported to Mpumalanga DWAF and other relevant
                authorities within 24 hours of occurrence. Record(s) of environmental related incidents
                should be maintained and communicated to Sasol Oil.
          3. An emergency plan should be available for major / minor spills at the service station
               during operation activities (with consideration of air, groundwater, soil and surface water)

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               and during the transportation of the product(s) to the service station, and appropriate
               training must be provided therein.

5.2.6     Fire prevention and control

          Construction and Operational Phases
          1.    Smoking must be prohibited in the vicinity of flammable substances.
          2.    The availability of sufficient firewater tie-in points, fire extinguishers and requirements of
                Local Authorities must be ensured.
          3.    Any welding or other sources of heating of materials should be done in a controlled
                environment and under appropriate supervision, in such a manner as to minimise the risk
                of fires and/or injury to staff.
          4.    Training should be provided to the staff members in the use of the appropriate fire-
                fighting equipment.
          5.    There should be close co-operation with the local fire authority to ensure that they know
                the layout of the facility, what equipment and facilities are available, where they are
                located, and how they are used.

5.2.7     Illumination

          Construction and Operational Phases
          1. No spotlight should be directed to the residential area.
          2. Lighting system should not flicker or cause stroboscopic effects.
          3. The receiver should not receive direct illumination.
          4. The signage should not allow the light to shine directly into the properties.

5.2.8     Labour and social issues

          Construction Phase
          1.    The criteria for and selection of labourers, contractors and suppliers for the project should
                demonstrate preference for the local community. Such requirements should be included
                in contract documents and be monitored by Sasol Oil.
          2.    Contractors must ensure proper supervision of employees at all times, undertake regular
                inspections of the workplace, enforce the wearing of safety equipment/clothing and
                ensure compliance with all relevant rules and procedures.
          3.    Staff should be educated as to the need to refrain from indiscriminate waste disposal
                and/or pollution of local soil and water resources and receive the necessary safety
                training.
          4.    The provision and proper utilisation, maintenance and management of toilet, wash and
                waste facilities for staff during construction must be ensured.
          5.    Machine / vehicle operators should receive clear instructions to remain within demarcated
                access routes.

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          6.    Suitable control measures over the contractor’s yard, plant and material storage to
                mitigate any visual impact of the construction activity must be implemented.
          7.    Contractors must adhere to normal working hours and ensuring that all machinery is in a
                good state of maintenance to mitigate noise.
          8.    Any archaeological findings during construction must be reported to the local Monument's
                Office.

          Operational Phase
          1.    Where possible, staff retrenched from existing filling stations following the start-up of the
                new SCC should be recruited and (re) trained by the owner and /or manager.
          2.    Ensure the provision and proper utilisation, maintenance and management of toilet, wash
                and waste facilities for staff.
          3.    Raise awareness under staff to the need to refrain from indiscriminate waste disposal
                and/or pollution of local soil and water resources.
          4.    All employees must undergo the necessary safety, health and environmental training and
                wear the necessary protective clothing.
          5.    Adherence to normal working hours and ensuring that all machinery is in a good state of
                maintenance would mitigate noise.

5.2.9     Materials handling

          Construction Phase
          1.    Proper storage facilities for the storage of oils, paints, grease, fuels, chemicals and any
                hazardous materials to be used must be provided to prevent the migration of spillage into
                the ground and groundwater regime around the temporary storage area(s).
          2.    These storage facilities (including any tanks) must be on an impermeable surface that is
                protected from the ingress of storm water from surrounding areas in order to ensure that
                accidental spillage does not pollute local soil or water resources. Additionally, cement and
                other potential environmental pollutants must be mixed on an impermeable substratum.
          3.    The contractor must ensure that its staff is made aware of the health risks associated with
                any hazardous substances used and has been provided with the appropriate protective
                clothing / equipment in case of spillages or accidents and have received the necessary
                training.

          Operational Phase
          1.    Workers should at all times be made aware of the safety, health and environmental risks
                associated with all identified hazardous substances used and should be provided with
                appropriate protective clothing / equipment in case of spillages or accidents. Records of
                environmental training and incidents should be maintained.
          2.    Storage of flammable stocks for sale must be in a secure area with proper fire fighting
                equipment and hazard signs.

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5.2.10 Noise disturbance

          Construction Phase
          1.    The construction contractor must ensure that construction and other noise generating
                activities are restricted to normal working hours, unless otherwise approved in
                consultation with IAPs.
          2.    The presence of work force may create noise, which should be mitigated by using as far
                as feasible local work force and ensuring that equipment is in a good state of
                maintenance, during construction and operational phase.
          3.    The Managing Contractor during construction must ensure the correct layout of the site to
                address the potential noise impact from the car wash facility.

          Operational Phase
          1. Staff should not make excessive noise especially during late hours.
          2. Equipment used in the operation of the facility must be kept in good state of maintenance
               so that noise is minimised.

5.2.11 Natural / Resource consumption

          1. Water volumes used must at all times remain within permit conditions and the developer
               must ensure that there is always sufficient capacity available in the event of a fire
          2. Whereas it is noted that the facility was not designed to meet the requirement of
               certification under the International Standards Organisations standard ISO 14001 on
               sustainable use of energy and water, and that it would probably not be economically
               viable to expend large capital amounts to ensure compliance with ISO 14001, certain
               principles embodied in those standards are worth noting and should be considered for
               implementation where possible:
               •     Efficiencies in the use of energy can be made in the areas of building, equipment and
                     systems efficiency: less and cheaper energy for the same task.
               •     Ensure that sufficient metering systems are installed to be able to monitor the use of
                     energy and water throughout the development.
               •     Match the use of resources to changes in time of day, day of week, season,
                     occupancy and weather conditions.
               •     Be aware of development in existing and new technology that will provide increased
                     energy and water efficiency.
               •     Good training is probably the best investment in terms of making energy and water
                     savings. Empower front line employees, they can make the difference.

5.2.12 Soil

          Construction and Operational Phases
          1.    Stockpiled soil should be protected by erosion-control beams if exposed for a period of
                greater than 14 days during the wet season.

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          2.    Soil stockpiles should be located away from drainage lines, watercourses and areas of
                temporary inundation.
          3.    All soil excavated during construction must, where practical, be separated into top- and
                subsoil.       Subsoil must be used for backfilling and topsoil for landscaping and
                rehabilitation of disturbed areas.
          4.    On completion of the backfilling of pipe or cable trenches, the topsoil should be replaced
                and the ground restored to its former condition, e.g. grass, artificial surface, etc.
          5.    Where topsoil has become mixed with subsoil or is not up to the original standard,
                fertiliser or new topsoil should be provided by the contractor.
          6.    Sensitive or high-use areas of the site must be paved to manage the impact of the
                operations on the ecology of the site.

          Operational Phase
          Where contamination of soil is expected, analysis must be done prior to disposal of excess
          soil to determine the appropriate disposal route. Proof from an applicable waste disposal site
          where contaminated soils are dumped should be forwarded to the MDALA.

5.2.13 Solid waste management

          Construction Phase
          1. In general, no littering, discarding or burying of any materials are allowed on site and
               roadways and sidewalks shall be left clear of waste materials.
          2. All waste material must be contained and disposed of according to the relevant legal
               requirements.
          3. Waste must be stored in such a manner that no pollution of the environment occurs at any
               time.
          4. All domestic waste generated must be disposed of in a proper manner at the Local
               Authorities Municipal Landfill site (i.e. no burial on site).
          5. All accumulated and surplus material must be disposed of in a suitable place and manner
               to prevent translocation of invasive plant species, modification of drainage and
               contamination of surface water.
          6. Hydrocarbon (oil, diesel, petrol) waste as well as all hydrocarbon contaminated material
               must be regarded as hazardous waste and separated from general waste.
          7. Spill cleanup kits and absorbent material must be kept on site to assist in immediate
               cleanup of any hazardous material spills
          8. All building rubble must be either:
                     •    removed from site and disposed of at the Local Authorities Municipal Landfill site,
                          subject to all relevant regulations and approval by the Managing Contractor; or
                     •    temporarily stored in a clearly demarcated area on site for future use.

          Operational Phase
          1.    All waste material must be contained and disposed off according to the relevant legal
                requirements.

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          2.    All domestic waste generated must be disposed of in a proper manner at the Local
                Authorities Municipal Landfill site.
          3.    Any hazardous waste (this will need to be clarified and explained to the developer)
                generated must be disposed off at an appropriately classified waste site (unless it is to be
                recycled by approved methods). In all cases proof of safe disposal should be obtained
                and kept.
          4.    In general, littering, discarding or burying of any materials must not be allowed on site.
          5.    In the event of any spill requiring the use of absorbent materials during clean-up
                operations, contaminated material is to be disposed of at an appropriately registered and
                classified waste site. The resulting chain of custody documentation is to be retained on
                file together with a record of the spill details. This should be made available for inspection
                by the relevant authorities whenever required.
          9. A waste management inventory must be compiled during the operational phase to include
               all waste types generated on site.
          10. Waste management procedures stipulating hazard classification, separation, storage,
               handling, transport, recycling, reduction strategy, cleanup and disposal requirements as
               well as personnel responsible for each of these aspects, must be developed and kept on
               site. All employees must be trained with regard to hazardous waste procedures.
          11. Waste management procedures must conform to the DWAF Minimum Requirements for
               waste disposal by landfill.
          12. As a minimum requirement, all hazardous waste must be separated and recycled /
               disposed of according to the DWAF Minimum Requirements for the Handling,
               Classification and Disposal of Hazardous Waste. Safe disposal certificates of hazardous
               waste are to be obtained and kept on site.
          13. Spill cleanup kits and absorbent material must be kept on site to assist in immediate
               cleanup of any hazardous material spills.
          14. Environmentally friendly degreasers for washing and cleaning and bioremediation of
               contaminated soils must be used where practicably possible.
          15. Suitable on-site ablution facilities must be provided during the construction and
               operational phases to cater for all personnel and customers using the site.

5.2.14 Rehabilitation

          Once construction is completed, the contractor must ensure that all redundant construction
          materials and waste are removed from site and disposed off in an appropriate manner.

5.2.15 Underground Storage Tanks and Equipment

          Construction Phase
          1.    The Managing Contractor to ensure that, at locations where conditions of high ground water
                or flood water are known to exist or likely to occur, the tank is safeguarded against
                movement or floating by means of a reinforced concrete slab cast on top of the tank or by

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                means of concrete saddles. The permeability of soils must be taken into consideration when
                installing the tank(s).
          2.    Where required by the Local Authority, the tanks must be installed in brick lined or concrete
                pits.
          3.    The Managing Contractor to ensure that the design include:
                       A filler box, which can contain the contents of a bulk delivery vehicle, discharge
                        hose.
                       Earthing and snap-tight-quick-coupling for loading of material into tanks to minimise
                        risk of fires and prevent spillage and loss of material.
                       An overfill protector fitted on the tanks.
                       A leak detector on all submersible pumps that automatically checks the integrity of
                        the pipework on the pressure side of the pump.
                       That the pipelines do not retain product after use and no joints are made
                        underground.
          4.    The Managing Contractor must ensure that the underground storage tanks are thoroughly
                inspected prior to installation for fracture and damage and that the inspection authority has
                issued test certificates. Leak and pressure tests must be conducted on tanks and pipelines
                to ensure integrity prior to operation and the inspection authority must issue pressure test
                certificates. An Emergency shut-off valve must be supplied between the supply pipeline
                and dispenser inlet.
          5.    A monitoring well must be placed at each corner of the excavation for each underground
                tank prior to backfilling. In sensitive areas, a plastic sheet, which slopes towards the
                monitoring wells, must be provided below the tank.
          6.    Sasol Oil to ensure that a groundwater-monitoring plan is in place prior to the initiation of
                construction activities on site. This plan should address a strategy for the management
                of any groundwater contamination detected as part of the groundwater monitoring
                strategy, and should include the frequency of monitoring, as well as details of stock
                reconciliations.

          Operational Phase
          1.    Regular monitoring (three-monthly) of the monitoring wells must be undertaken to prevent
                pollution. Records of monitoring must be kept and made available to the Mpumalanga
                DEAT / DWAF on request. Should contamination be detected, monitoring must be
                extended to the monitoring boreholes as identified during the hydro census. If
                contamination is detected in the extended borehole survey, a rehabilitation plan must be
                compiled and executed.
          2.    Monthly stock reconciliations must be taken and reported monthly to Mpumalanga
                DWAF.
          3.    The leak detectors must be regularly tested and records kept.
          4.    All machinery must be maintained in good working order as to prevent soil or water
                pollution from oil, fuel or other leaks.

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5.2.16 Visual Impact

          Construction and Operational Phases
          1. During construction, the contractor must provide a sufficient fence around the site and
               storage spaces to visually screen off these activities from the surrounding areas.
          2. There should be a planted landscape that would reduce dust creation and which will only
               start in terms of establishing and retaining long-term ecological values on site.
               Subsequent management of the scheme will either remove potential ecological value or
               could substantially enhance it.
          3. Removal of invasive alien species must be undertaken on continuous basis.

5.2.17 Water issues

          Construction Phase
          1.    The Managing Contractor must ensure that impediments to natural water flow is avoided
                wherever possible, or if unavoidable, be allowed for in the design by means of
                appropriately sized and positioned drains, culverts etc.
          2.    The Managing Contractor must ensure that water use remains at all times within the
                permit conditions and that there is always sufficient capacity available in the event of a
                fire.
5.2.18 Removal/replacement of old fuel tank

          Decommissioning phase
          1. Contaminated metal must be steam-cleaned prior to disposal.               Routing of effluent
               dependant on contaminants.
          2. If any metal, including piping, have future value it may be moved, after cleaning, to a
               storage area for redundant materials.
          3. Reference to Sasol Oil’s existing procedure for the disposal of metal to the scrap metal
               dealer.
          4. On the day of excavation, the site engineer, contractor and environmental consultant
               (contamination expert) must be present either as the tanks are being removed or
               immediately afterwards.
          5. The area to be excavated must be cordoned off with red danger tape and no smoking
               signs displayed around the site.
          6. All fuel inside the tank must be removed and the tank degassed, with the site then
               excavated to expose the tank. In order to ensure the tank is not damaged during
               excavation especially in areas of limited space, a small backactor must be used or the
               area must be manually excavated, with the removed soil stockpiled in a demarcated area
               on site.
          7. All other electrical, stormwater or water pipelines must be located prior to excavation to
               ensure they are not damaged in the excavation process. All pipes and vents connected to
               the tank must be disconnected and sealed before the tank is removed.
          8. If there are no suspected leaks or contamination, the new tank can be installed.

Environmental Management Plan: Sasol Convenience Centre, Paul Kruger Street, Secunda
14

          9. If a leak is suspected, soil samples must be taken from a number of points in the
               excavation as well as from the stockpiled soil. Water samples must also be taken if there
               are free-standing pools in the excavated pit. Background soil and water samples must
               also be taken off-site.
          10. The pit must be left open while the samples are sent to an appropriate laboratory for
               analysis. Should the analysis indicate the soil to be contaminated, soil must be removed
               from the pit until all of the contaminated material has been removed. Contaminated water
               must be pumped out, collected and disposed of in an appropriate manner. Further soil
               samples must be taken and sent for analysis with the process repeated until analysis
               shows contamination to be within acceptable levels.
          11. The contaminated soil must be stockpiled separately and remediated on site or removed
               to an appropriate landfill site.
          12. The new tank can then be placed in the existing hole.
          13. The removed tank will be loaded onto a flat-bed trailer and taken to the contractor’s
               storage yard or to a storage area designated by the Sasol Oil. The tank will be flushed to
               remove any remaining residues with the flushed water either stored for future flushing or
               processed to remove the fuel.

Environmental Management Plan: Sasol Convenience Centre, Paul Kruger Street, Secunda
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