Ar Chivos 1218 A

ENVIRONMENTAL MANAGEMENT PLAN
Operation of the Central Processing Facility, PSA

Liquids and LPG Plant, Production Wells,
Flowlines and Access Roads
Inhambane Province, Mozambique
Revision NUMBER 5
October 2014
Sasol Petroleum Temane – Operations Environmental Management Plan (o-EMP), October 2014
DOCUMENT INFORMATION
Title ENVIRONMENTAL MANAGEMENT PLAN:

Operation of the Central Processing Facility, PSA
Liquids and LPG Plant, Production Wells, Flowlines
and Access Roads
Author (Rev 0, 2002) METAGO
Issue Date (Rev. 0) 2002
Author (Rev 2 & 3) SASOL Petroleum Temane / Metago
Issue Date (Rev. 3) May 2011
Author (Rev. 4) Mark Wood
Issue Date (Rev. 4) July 2013
Current Revision Number 05
Revision Author Golder Associates
Revision Date October 2014 (FINAL)
Status Submitted for approval
Number of Pages 128 (excluding Appendices)
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TABLE OF CONTENTS
1. INTRODUCTION ................................................................................................... 1
1.1. TIMELINE FOR THE PSA DEVELOPMENT & LPG PROJECT AND OTHER CPF
PROJECTS ......................................................................................................3
1.2. ENVIRONMENTAL POLICY ..................................................................................4
1.3. COMMUNITY ENGAGEMENT PRINCIPLES ..............................................................6
1.4. PURPOSE OF THIS DOCUMENT ...........................................................................6
1.5. RELATIONSHIP BETWEEN THE SASOL EMP’S ......................................................8
1.6. SCOPE OF THE OPERATIONS EMP .....................................................................9
1.7. REVISIONS TO THE OPERATIONS ENVIRONMENTAL MANAGEMENT PLAN (O-EMP) 10
1.8. SUMMARY OF PLANT PROCESSES AND OUTPUTS ...............................................12
1.9. DETAILS OF INDIVIDUAL PROCESSES (EXISTING CPF AND ASSOCIATED PRODUCTION
FACILITIES) ...................................................................................................17
1.10. DETAILS OF INDIVIDUAL PROCESSES (INTEGRATED PSA LIQUIDS AND LPG
PLANT) .........................................................................................................22
1.11. UTILITIES (EXISTING CPF) ..............................................................................25
1.12. UTILITIES (5TH GAS TRAIN AND PSA AND LPG PLANT) ......................................35
2. ENVIRONMENTAL MANAGEMENT STRUCTURE ........................................... 39
2.1. ORGANISATIONAL STRUCTURE AND RESPONSIBILITY ..........................................39
2.2. LIAISON, CO-ORDINATION AND REPORTING ........................................................44
2.3. ENVIRONMENTAL MANAGEMENT SYSTEM ..........................................................45
3. ACTIVITY AND IMPACT MANAGEMENT PLAN ............................................... 45
3.1. BACKGROUND TO ENVIRONMENTAL IMPACT MITIGATION AND MANAGEMENT .........45
3.2. ENVIRONMENTAL MANAGEMENT REQUIREMENTS ...............................................46
3.3. ADMINISTRATION AND GENERAL ISSUES ...........................................................50
3.4. EMPLOYMENT AND LABOUR MANAGEMENT ........................................................54
3.5. COMMUNITY, STAKEHOLDER AND GOVERNMENT LIAISON ....................................55
3.6. ACCOMMODATION AND OFFICE MANAGEMENT ...................................................61
3.7. MOSQUITO / VECTOR CONTROL .......................................................................62
3.8. MEDICAL SERVICES AND FACILITIES ..................................................................63
3.9. WATER AND EFFLUENT MANAGEMENT ..............................................................64
3.10. WASTE MANAGEMENT .....................................................................................67
3.11. BUSINESS SERVICES .......................................................................................73
3.12. PRODUCTION .................................................................................................73
3.13. MAINTENANCE/EQUIPMENT REPLACEMENT.......................................................76
3.14. SUPPORT SERVICES .......................................................................................80
3.15. COMMISSIONING AND INITIAL START-UP, START-UP FOLLOWING SHUTDOWNS .......82
3.16. NORMAL START-UP (REQUIREMENTS OF 3.15 INCLUDED WHERE APPLICABLE) ......83
3.17. OPERATION ...................................................................................................84
3.18. NORMAL SHUTDOWN ......................................................................................88
3.19. UPSET CONDITION MANAGEMENT .....................................................................89
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3.20. LAND USE CONTROLS ......................................................................................89

3.21. CORPORATE SOCIAL INVESTMENT ...................................................................90
3.22. DECOMMISSIONING .........................................................................................91
4. PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION ............ 93
4.1. ENVIRONMENTAL MONITORING STRATEGY .........................................................93
4.2. SITE INSPECTION AND AUDITS ........................................................................122
4.3. REVIEWS .....................................................................................................123
4.4. CORRECTIVE AND PREVENTIVE ACTION...........................................................124
5. COMPETENCY, TRAINING AND AWARENESS CREATION ......................... 126
6. CONTINGENCY AND DECOMMISSIONING PLANNING ................................ 126
7. EMERGENCY PREPAREDNESS AND RESPONSE ....................................... 127
8. REPORTING REQUIREMENTS ....................................................................... 127
9. DOCUMENT CONTROL ................................................................................... 128
LIST OF TABLES
TABLE 1-1: SUMMARY OF DESIGN LOAD CONDITIONS (SASOL DESIGN BASIS,
11 DECEMBER, 2007) ........................................................................................... 25
TABLE 3-1: OBJECTIVES OF MITIGATION MEASURES FOR ADVERSE

ENVIRONMENTAL IMPACTS. FIRST PRIORITY IS AVOIDANCE OF NEGATIVE
IMPACTS; THE OBJECTIVES ARE LISTED IN DECREASING ORDER OF
PRIORITY............................................................................................................... 46
TABLE 3-2: REGISTER OF ACTIVITY CATEGORY AND SUB-CATEGORIES

INCLUDED IN THE ACTIVITY MANAGEMENT PROGRAMME (TO BE UDPATED
AFTER SASOL FINAL COMMENTS RECEIVED) ................................................. 47
TABLE 4-1: MONITORING REQUIREMENTS. (IN SOME CASES PERFORMANCE

INDICATORS HAVE BEEN INDICATED IN THE EMP STANDARD AND THUS
ADDITIONAL MONITORING MAY BE REQUIRED TO THAT PRESENTED IN THE
TABLE) .................................................................................................................. 95
TABLE 4-2: GROUNDWATER MONITORING LOCATIONS PRIOR TO

COMPLETION OF THE PSA LIQUIDS AND LPG PROJECT (REFER TO FIGURE 4-
1) .......................................................................................................................... 110
TABLE 4-3: GROUNDWATER MONITORING LOCATIONS AFTER COMPLETION

OF THE PSA LIQUIDS AND LPG PROJECT (REFER TO FIGURE 4-2).............. 111
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TABLE 4-4: PROPOSED SURFACE WATER MONITORING PLAN (REFER TO

FIGURE 4-3) ......................................................................................................... 114
TABLE 4-5: AIR QUALITY MONITORING LOCATIONS, SAMPLING FREQUENCY

AND PARAMETERS (REFER TO FIGURE 4-4)................................................... 117
TABLE 4-6: SOIL MONITORING LOCATION, FREQUENCY AND PARAMETERS

(REFER TO FIGURE 4-5) ........................................................................................... 121
TABLE 4-7: MINIMUM AUDITING REQUIREMENTS FOR THE OPERATIONAL

PHASE OF THE CPF AND ASSOCIATED INFRASTRUCTURE ......................... 123
LIST OF FIGURES
FIGURE 1-1: CONCEPTUAL OVERVIEW OF THE PROJECT IN RELATION TO SASOL'S EXISTING
PRODUCING ASSETS .................................................................................................... 3
FIGURE1-2: TIMELINE FOR THE APPROVED AND PROPOSED PROJECTS BETWEEN 2014 AND
2022 ......................................................................................................................... 4
FIGURE 1-3: ADDITIONAL PLANT AT THE CPF TO BE INSTALLED ................................... 15
FIGURE 1-4: INTEGRATION OF THE EXISTING CPF AND THE PSA LIQUIDS AND LPG PLANT
............................................................................................................................... 17
FIGURE 1-5: CPF WATER TREATMENT PROCESS........................................................ 25
FIGURE 1-6: DOMESTIC SEWAGE TREATMENT ............................................................ 28
FIGURE 2-1: OVERALL ENVIRONMENTAL ORGANISATIONAL STRUCTURE BETWEEN KEY

ROLE PLAYERS DURING THE OPERATIONAL PHASE OF THE CPF .................................. 39
FIGURE 4-1: GROUNDWATER MONITORING LOCATIONS PRIOR TO COMPLETION OF THE PSA

DEVELOPMENT AND LPG PROJECT (REFER TO TABLE 4-2)........................................ 108
FIGURE 4-2: GROUNDWATER MONITORING LOCATIONS AFTER COMPLETION OF THE PSA

DEVELOPMENT AND LPG PROJECT (TABLE4-3) ....................................................... 109
FIGURE 4-3: SURFACE WATER MONITORING LOCATIONS IN AND AROUND THE CPF COMPLEX
(REFER TO TABLE 4-4) ............................................................................................ 113
FIGURE 4-4: AIR QUALITY MONITORING LOCATIONS IN AND AROUND THE CPF COMPLEX
(REFER TO TABLE 4-6) ............................................................................................ 116
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FIGURE 4-5: SOIL MONITORING POINTS IN AND AROUND THE CPF COMPLEX ................ 120
FIGURE 4-6: NOISE MONITORING LOCATIONS AROUND THE CPF COMPLEX .................. 121
LIST OF APPENDICES
APPENDIX 1: Sasol SH&E Policy (Revision 5, November 2012)
APPENDIX 2: Internal and External Reports used to inform Revision 5 of the o-EMP
APPENDIX 3: Organogram of Activities associated with the Onshore Gas Field
APPENDIX 4: Record of Changes to the o-EMP in Revision 5
APPENDIX 5: Schedules in Support of Revised Monitoring Compliance

Requirements
This document is available in English and Portuguese. In the event of any

inconsistency between the English and Portuguese versions of the
document, the English version shall take precedence.
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DEFINITIONS AND ACRONYMNS
ANE Mozambique National Roads Administration

ARA-Sul Mozambique Regional Water Administration (Administração
Regional de Águas) – southern area.
bara Pressure reading in bars relative to absolute pressure
Compressor A device that uses external energy to impart internal energy into the
sales gas in order to raise sales gas pressure by creating a greater
differential pressure between export point to delivery point and so
allowing the gas to flow through the pipeline (gas pumping device).
Condensate: A low-density mixture of hydrocarbon liquids that are present as
gaseous components in the raw natural gas produced from many
natural gas fields.
Corrosion Essentially an O2 scavenger and also a barrier medium that separates
Inhibitor the product (gas) from the containing medium (pipelines, flow lines or
vessels).
Central The CPF consists of the original producing assets of Sasol’s natural
Processing gas processing plant in Mozambique, situated some 50 km north-
Facility (CPF) north-west of Vilanculos.
CPF Complex Operated by SPT (owned by UJV) and consists of original producing
assets of the Central Processing Facility under the expansion
introduced in the NATGAS 183 project, the CPF Facilities Upgrade
Project and the PSA Liquids and LPG Plant and 5th Gas Train.
Drain system: Essentially for containment of process NGL (Ref Condensate
Closed Drain definition). These liquids are all re-directed back into the liquid
System separator. These liquids are also known as “spill back” liquids.
Open Drain Essentially for the direction of storm water and non-contaminated
System utility water.
Effluent A liquid or waste water flowing out of a reservoir or sewer or
purification works that may contain particulates, sediment, chemicals
or waste matter.
EIA Environmental Impact Assessment.
EIA Environmental Impact Study.
EMP Environmental Management Plan. (d-EMP – design EMP; c-EMP –
construction EMP (CPF); c-EMP – construction EMP (Infrastructure);
o-EMP – operations EMP).
Environmental An independent environmental consultant with experience in the
Consultant environmental management of industrial projects.
ENH Empresa Nacional de Hidrocarbonetos, E.P. (the National Oil
Company).
Environmental (i) Defines the measures to be taken during the life of a project,
Management including design, construction, operation and decommissioning to
Plan (EMP) prevent and/or manage adverse environmental and social impacts;
(ii) Defines the actions needed to implement these measures; and
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(iii) Describes how this will be achieved (iv) describes how this will
be monitored, (v) defines inspection and auditing schedule.
Environmental A systematic, documented and objective evaluation of the
Management environmental performance of a project by objectively obtaining and
Plan Audit analysing evidence to determine whether the implementation of the
EMP conforms to its requirements.
Environmental The part of the overall management system that includes
Management organisational structure, planning activities, responsibilities,
System procedures, processes and resources for developing, implementing,
achieving, reviewing and maintaining an environmental policy.
ESO Environmental Site Officer.
Flowline Device for containing and transporting raw gas to a gathering station
where the gas can be processed.
GJ/a Giga Joules per annum.
Glycol A chemical used during pigging that has an affinity for water.
Government The National Government of Mozambique.
Hazardous Waste bearing risk characteristics for being flammable, explosive,
waste corrosive, toxic, infectious or radioactive, or for showing any other
characteristic that constitutes hazard for the life and health of
mankind and other living creatures and for environmental quality.
Industrial Refers in this document to the plant that treats industrial waste water
Treatment (i.e. water containing chemicals) to a level where it can be
Plant discharged safely.
Initial Products The initial products from the wells will be associated with drilling
from Wells: debris, essentially brine, mud, diesel, and mechanical debris such
as metal cuttings etc.
INP Instituto Nacional de Petróleo (National Petroleum Institute).
Liquid A device or vessel that can contain combined condensate and water
Separator for a sufficient retention time that allows both liquids to separate
physically. The use of demulsifiers may be required to break the
emulsion depending on the quantity of combined liquid intake.
Metago Metago Environmental Engineers (Pty) Ltd.
MMscfd Million standard cubic feet per day
MICOA Ministry for the Co-ordination of Environmental Affairs, Mozambique.
MSDS Material Safety Data Sheet.
Non- Waste with no risk characteristics, including but not exclusive to
hazardous paper or paperboard, plastic, glass, metal, domestic rubbish, metal
waste scrap and organic matter.
NTS Non-Technical Summary.
Operations The integrated oil and gas operations in Mozambique, specifically
encompassing: the wells, flowlines, access roads, CPF and PSA
Liquids and LPG Plant.
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Pipeline This refers to an underground pipeline which carries gas or liquid

hydrocarbons from numerous flowlines in a single pipe to a specified
point.
PPA Petroleum Production Agreement
PSA Production Sharing Agreement
POC Potentially Oil Contaminated: Liquids that may contain
Hydrocarbons cannot be allowed to flow into the open drain system.
These liquids are directed through the POC system into the closed
drain system and pumped back into the liquid separator.
Pigging The method used for cleaning flow lines and export lines and also
displacing liquids from the said lines. Pigs are also used as internal
condition monitoring devices within pipelines.
Pipeline Essentially a transmission device that maintains containment of
product (i.e. refined gas or oil) from source to end point.
Produced Water that has been separated out from the liquid phase of the
Water production fluids. This water is essentially a by-product of gas
production.
PSA Liquids & Sasol’s oil “processing” plant, situated immediately adjacent to the
LPG Plant CPF on the north east side. It forms part of the ‘CPF complex’.
Sasol Refers to Sasol (Pty) Ltd and all its affiliate organisations.
SES Simplified Environmental Study
SPI Sasol Petroleum International (Pty) Ltd. SPI is the international
holding company and SPT falls under it. SPI provides support
services to SPT.
SPT Sasol Petroleum Temane Limitada. SPT is a Mozambican registered
company and is part owner and operator of the CPF complex and
associated services.
SHE Safety, Health, Environment.
Sewage A self-contained processing unit that is capable of removing
Treatment suspended solids and bacteria from water to render it more suitable
Plant for any particular service / discharge. In this document it refers the
plant that treats domestic sewage.
stbopd Stock tank barrels of oil per day
TEG Tri Ethylene Glycol. Essentially there are three types of glycol Mono,
Di and Tri, depending on what service or level of absorbency is
required throughout the process.
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1. INTRODUCTION
In October 2000, Sasol Petroleum Temane Limitada (Sasol), Empresa

Nacional de Hidrocarbonetos de Moçambique, E.P. (ENH), Companhia
Moçambicana de Hidrocarbonetos S.A.R.L. (CMH) and the Government of
Mozambique signed a Petroleum Production Agreement (PPA) for the
production and processing of the Temane and Pande gas fields in Inhambane
Province, Mozambique. The main outcome of these agreements was the
production and processing of natural gas resources and the export of the
processed natural gas to Secunda in South Africa via an underground pipeline.
In addition, a Petroleum Production Tax levied by the Mozambique Government
is taken in kind, which has encouraged the development of gas supply offtakes
from the Temane - Secunda pipeline.
The key Operations elements of this first phase of the project were as follows:
1. Exploration activities to determine the extent of the gas reserves and

optimal locations for extraction.
2. Development of a network of production wells and gas flowlines within

the Temane and Pande gas fields and the construction and operation of
a Natural Gas Plant (known as the Central Processing Facility or ‘CPF’)
for the cleaning, drying and compression of the gas.
3. Transportation of the gas from Temane to Secunda (South Africa) and

Maputo (Mozambique) via underground transmission pipeline.
4. Upgrading and conversion of Sasol’s plant infrastructure at Secunda and

Sasolburg (South Africa) to accommodate the natural gas as feedstock.
Sasol has since expanded the CPF and has brought further gas wells on stream
in the Temane and Pande gas fields. At present, the CPF consists of four gas
processing trains, supplied by twenty four (24) onshore production wells, twelve
(12) of which are in the Temane field and twelve (12) of which are in the Pande
field.
Sasol proposes to further expand the CPF to process additional gas,

condensate and oil from the area defined in the Production Sharing Agreement
1
(PSA) with the Mozambique Government. The PSA licence covers all other
formations in the Temane and Pande geographical areas that are currently
being considered for development, and also includes other fields and prospects
where exploration and appraisal wells have been drilled but have not as yet
been declared commercial. The project will significantly increase Sasol’s
capacity to process gas and liquids, and will include the facility to produce
Liquefied Petroleum Gas (LPG), which would provide the local capacity to
substitute much of the 15,000 to 20,000 tonnes per annum that are currently
imported at significant cost to Mozambique.
The proposed development (Figure 1-1) consists of two main components,

which are referred to as the ‘PSA Development and LPG Project’:
1. PSA Gas Development: involving six production wells in the

Temane Field and an additional 5th gas train at the CPF, designed
to process the additional gas and condensate from the wells and
situated within the existing plant boundaries. Production of gas at
the CPF is expected to increase by up to 150 MMscfd (million
standard cubic feet per day) to approximately 600 MMscfd; and
2. PSA Liquids Development, involving twelve oil production wells

and one data-gathering well (not connected to the CPF) in the
Inhassoro field, and a new Liquids Processing plant and Liquefied
Petroleum Gas (LPG) plant, situated adjacent to north east side
of the CPF. This project component is referred to as the ‘PSA
Liquids and LPG Plant’. The plant is expected to produce 15,000
stock tank barrels of oil per day (stbopd1) and 20,000 tonnes per
annum of LPG.
All of the gas and oil wells will be connected to the CPF and PSA Liquids and
LPG Plant by buried pipelines known as ‘flowlines’ or ‘pipelines’, similar in
design to those which currently supply the plant with gas. The new flowlines are
intended to follow existing lines of access as far as possible, and in the section
1
A stock tank barrel refers to the volume occupied by sales oil (i.e. after stabilisation to meet sales specification) and
measured in barrels at standard conditions of 1.01325 bara (14.7 psia) and 15.56°C (60°F).
2
across the Govuro River, the pipes will be connected to existing pipes laid
across the channel during the construction of the Natural Gas Project, so as to
avoid the disturbance caused by further crossings.
Figure 1-1: Conceptual overview of the project in relation to Sasol's existing producing assets
1.1. TIMELINE FOR THE PSA DEVELOPMENT & LPG PROJECT AND OTHER CPF
PROJECTS
The timeline for the PSA Development and LPG Project is shown in Figure 1-
2. The implementation of the project will be preceded by the 'Inhassoro Oil Pilot
(IOP) project', which is the subject of a separate Environmental Assessment,
and which involves the production of oil from two existing wells, I-9z and I-4,
both of which are already connected to the CPF by an existing flowline. The
IOP project will run as long as possible before the wells are shut in and the
flowlines are re-configured to connect into the PSA oil project.
The main construction works of the PSA Development and LPG Project is
scheduled to start in early 2016 and be operational by the last quarter of 2018.
It is noted that a number of PPA activities take place at the CPF between and
at the same time as the PSA development (Figure 1-2). This work consists of
the installation of four Low Pressure (L) compressors at various times between
2014 and 2021 in order to increase the pressure of incoming fluids into the CPF,
as the well pressures begin to reduce, and the installation of an additional
power generator (GTG). These upgrades have already been approved by
MICOA (Environmental License Nr 08/MICOA/GM/189/2014).
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Figure1-2: Timeline for the approved and proposed projects between 2014 and 2022
1.2. ENVIRONMENTAL POLICY
As the Operations owner, Sasol Petroleum International (Pty) Ltd (SPI) is

implementing the following Safety, Health and Environmental Policy declaration
that sets the framework for an integrated management system for the
Operations. All visitors, contractors and employees are required to comply with
the requirements of the policy declaration.
Sasol management and staff fully subscribe to the Sasol SH&E policy
declaration (Revision 5, November 2012 – reproduced in Appendix 1). Sasol
will demonstrate commitment to the policy by:
 Developing and implementing an integrated management system that

will comply with the requirements of the OHSAS 18001 Occupational
Health & Safety, and ISO 14001 Environmental Management Systems;
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 Subjecting itself to third party audits conducted by an internationally

recognised certification body as part of our drive towards continual
improvement;
 Accepting and complying with Sasol Corporate Governance

requirements, Mozambican SH&E - related legislation, all World Bank
Financing obligations and any appropriate, recognised, Sasol codes of
practice;
 Engaging with the Mozambican Government regarding the

implementation framework for any new legislation that affects the
processing facility;
 Sharing safety, health and environmental risk reduction best practices

with other members of the Sasol group of companies;
 Influencing suppliers and contractors to conform as a minimum to the

Mozambican SH&E - related legislation and to respect and adhere to the
Sasol codes of practice;
 Sharing and communicating relevant information about safety, health

and environmental performance with interested and affected parties,
employees and authorities in an open and transparent manner, and
making this declaration available by displaying it in all office buildings
and in the induction training;
 Minimising risks associated with its activities which may impact on the
health and safety of our employees, communities and the environment;
 Enhancing the general awareness of its employees and contractors to

ensure understanding of all the SH&E risks and impacts associated with
their work activities;
 Preventing pollution, accidents, injuries and ill health through setting and
reviewing objectives and programmes;
 Responding effectively to safety, health and environmental

emergencies;
 Providing appropriate resources to implement the above commitments;
5
 Reviewing this declaration of intent on a 3-yearly basis or as and when

required by Sasol Petroleum Temane’s SH&E Governance structure.
1.3. COMMUNITY ENGAGEMENT PRINCIPLES
Sasol’s community engagement principles are centred on:
- Community involvement and ownership

- Strengthen community leadership
- Targeted impacts-driven interventions
- Addressing key community priorities
- Strategic research informed interventions
- Monitoring and evaluation
- Building capacity through partnership
1.4. PURPOSE OF THIS DOCUMENT
This document is the operations Environmental Management Plan (o-EMP) for

the integrated project. Since 2004 when beneficial operation of the CPF started,
there have been several updates of this o-EMP to accommodate expansions of
the plant and this is the fifth revision (Revision 5). It covers the management of
the operations phase of the CPF (including the proposed 5th Gas Train and the
alternative option of a ‘standalone’ LPG plant within the CPF), the PSA Liquids
and LPG Plant, the additional infrastructure approved by MICOA under the CPF
Facilities Upgrade Project (some of which will only be built after 2020), and
associated wells for oil and gas, flowlines and access road infrastructure (refer
to Figure 1-2).
The o-EMP is derived from the 2001 EIA, subsequent impact study updates
and annual monitoring and audit reports, and provides a series of practical
commitments intended to manage and monitor the impacts of the integrated
CPF and PSA Development and LPG Project, and all of the production wells
and flowlines. Subject to the implementation of the management measures
specified in this document, the project impacts should be minimised and of low
significance.
It is the only operational EMP for the project- all other EMPs that are in current
use are intended to manage construction impacts.
The complete set of management plans is as follows:
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1. Construction EMP Metago Environmental Engineers (Pty) Ltd. 2002.

c-EMP (CPF) Construction Environmental Management Plan.
Construction of the Temane Well-sites, Access Roads
and a Natural Gas Plant. Inhambane Province.
Mozambique. (Metago ref. 154-003 report 1). Revised
in 2009 for the NATGAS 183 Expansion Project
(Consultec, 2009) to include construction activities at
the CPF only. Revision 2 by Mark Wood on behalf of
Golder Associates for the CPF Facilities Upgrade
Project (Golder, 2013).Current Revision (Revision 3) by
Mark Wood on behalf of Golder Associates for the PSA
Development and LPG Project. The c-EMP (CPF) is
applicable to all construction works at the CPF complex,
which includes the camp sites and contractor’s yard for
all construction teams working on the project and
resident at the CPF. The c-EMP is included as a free
standing document and as an Appendix to the PSA
Development and LPG Project EIA submitted to MICOA
for consideration of authorisation of the project.
2. Construction EMP (c- Mark Wood Consultants/Impacto Lda. (2004), revised
EMP Infrastructure) by Sasol in 2007. The revision included splitting the
Drilling and Seismic EMP’s into two separate
documents. The Construction EMP (Infrastructure) is a
generic document that manages the impacts of onshore
construction of all flowlines, access roads and well
pads. Current Revision (Revision 2) by Mark Wood on
behalf of Golder Associates includes additional
requirements based on the findings of the PSA
Development and LPG Project EIA.
3. Drilling EMP (d-EMP) Mark Wood Consultants/Impacto Lda. (2004), revised
by Sasol in 2007. The revision included splitting the
Drilling and Seismic EMP’s into two separate
documents. The Drilling EMP is a generic document
that manages the impacts of onshore drilling
programmes. Current Revision (Revision 12) by Mark
Wood on behalf of Golder Associates including
additional requirements based on the findings of the
PSA Development and LPG Project EIA.
4. Operations EMP Metago Environmental Engineers (Pty) Ltd. 2002.
(This document) Operations Environmental Management Plan (o-EMP –
this document). The o-EMP has been reviewed once by
Metago and again by SPT/Metago between the years
2004 and 2011, in order to reflect expansions at the
plant, changes in legislation, best practices and ongoing
experience of operation of the plant. Revision 4, was
prepared by Mark Wood Consultants on behalf of
Golder Associates for the CPF Facilities Upgrades
Project. Current Revision (Revision 5) by Mark Wood on
behalf of Golder Associates including additional
7
requirements based on the findings of the PSA

Development and LPG Project EIA.
1.5. RELATIONSHIP BETWEEN THE SASOL EMP’S
During seismic operations, which includes demining, vegetation clearance and

data acquisition, the seismic EMP applies. At the end of the project all camps
and work areas are rehabilitated and the seismic lines are closed. The
monitoring of the rehabilitation of the seismic lines, camps and work areas falls
under the o-EMP. Monitoring occurs for a minimum of two years after the rainy
season, in accordance with a defined ecological monitoring procedure.
During drilling operations, the construction of camps, roads and well sites
(including the opening of borrow pits) is covered by a construction EMP (c-
EMP). This is distinct from the c-EMP for construction activities at the CPF
which is a separate document.2 Drilling activities themselves, including the
management of muds and completion fluids and work areas, are managed in
accordance with the drilling EMP (d-EMP). At the close of the drilling project,
the d-EMP delegates the rehabilitation of all sites that will not be used in the
future to the c-EMP, since the c-EMP applies to the civil contractors who have
the machinery necessary to implement any civil work required for rehabilitation.
If a well site is developed into a production well it is signed over to the CPF,
following which the o-EMP becomes applicable. Until the sign over, the well site
is not covered by the o-EMP.
During construction of civil infrastructure, such as flowlines, pipelines and

access roads, the c-EMP (Infrastructure) applies. This EMP manages all
impacts associated with the construction of these facilities. Rehabilitation under
the c-EMP covers the replacement of topsoil. At the close of the construction
project all infrastructure and borrow pits that will not be reused must be
rehabilitated. The rehabilitated sites, borrow pits and pipelines are then added
2
Referred to in the PSA Development and LPG Project EIA as the c-EMP (CPF) and the c-EMP (Infrastructure).
8
to the ecological monitoring schedules and are monitored under the o-EMP and
ecological work procedure.
During construction of the CPF, the c-EMP (CPF) applies. In the present case,
this refers to the CPF complex, where it is anticipated that all the construction
teams will be accommodated, with the possible exception of the drilling team,
where accommodation in Inhassoro is being considered in accordance with a
recommendation of the Social Impact Assessment, or elsewhere closer to the
work sites, where in such an event the proposed location will be accompanied
by a full method statement for approval by MICOA.
1.6. SCOPE OF THE OPERATIONS EMP
The operations EMP (o-EMP, this document) contains environmental

management requirements for all activities related to the operation and
decommissioning of the following components of the operation of the CPF
(complex) and associated infrastructure:
 Central Processing Facility (CPF) including the PSA 5th Gas Train (and
the alternative ‘standalone’ LPG plant);
 Integrated PSA Liquids and LPG Plant;
 Production wells (i.e. gas and oil extraction wells, data gathering or
delineation wells – refer to Appendix 4);
 Flowlines and pipelines (i.e. means of transport of fluids from the well-
sites to the CPF and PSA Liquids and LPG Plant); and
 Access roads (to the well-sites and the CPF/PSA Liquids and LPG
Plant);
 Borrow pits.
Note/limitations in the scope of the o-EMP:
1. Issues related to compensation, resettlement and relocation have not been

addressed in this document. Sasol Petroleum International established a
Resettlement Planning and Implementation Programme (RPIP) where these
issues are addressed. The RPIP is updated each time new Sasol activities are
9
scheduled that take place outside of the boundaries of the areas of approved
infrastructure.
2. The o-EMP does not include specifications regarding occupational health,

hygiene or safety requirements. Sasol’s obligations in this regard are set by
legislation and policy commitments and are outside the scope of this EMP. They
are identified in the SPT legal register for the CPF.
3. The o-EMP does not include specifications for Emergency Response in

respect of a major accident, which are contained in a fully separate plan.
1.7. REVISIONS TO THE OPERATIONS ENVIRONMENTAL MANAGEMENT PLAN (O-EMP)
The o-EMP documents the actions, approaches and measures required to

manage, mitigate and monitor environmental risk associated with Operations,
recording not only changes to Operations itself but also the impact of external
factors such as legislation, policy and public and social accountability. To make
provision for these changes, responsibilities have been assigned for identifying
them and revising the EMP (see Section 4).
The 2004 o-EMP (Revision 0) has been revised several times. The following
modifications of the initial design have taken place since 2004 and were taken
into account in the Revision 4 o-EMP:
 Construction of two evaporation ponds for emergency storage of

produced water;
 Decision not to discharge treated effluent into the Govuro River, and to
irrigate it onto the lawns and gardens of the CPF instead;
 Installation of the final effluent irrigation system;
 Installation of two additional water storage tanks;
 Construction of new waste segregation and storage facilities;
 Construction of condensate off- loading facility;
 Construction of additional condensate storage;
 Installation of a new incinerator;
 Construction of a second H:H landfill site and closure of the first landfill
site;
10
 Construction of a new Membrane Bioreactor (MBR) sewage treatment

plant;
 Construction of a temporary hazardous storage facility;
 Construction of a new produced water reinjection well (Temane 25) at
the CPF;
 Operationalisation of additional wells, with associated flowlines, in the
Temane Gas Reservoir;
 Operationalisation of the Pande Gas Reservoir, with associated wells
and flowlines;
 Expansion of the gas processing and condensate storage facilities to
accommodate a capacity increase from 122 MGJ/A to 183 MGJ/A.
The following changes are proposed as of 2013, and will be implemented

between 2014 and 2022 (refer to Figure 1-2):
o Phased installation of four LP Compression units (first two units

to be installed in 2013 / 2014);
o Decommissioning and reinstallation of four like for like HP
Compressors (equipped with low NOX burners) OR installation of
a fifth HP Compression Train to support the existing four HP
Compression Trains;
o Installation of one Gas Turbine Generator (GTG) to provide
redundancy (backup) for the three existing GTG’s and (possibly)
a further one GTG at a later time.
o Decommissioning of the old incinerator.
The current expansion of the gas-producing capability of the CPF consists of

the PSA 5th Gas Train which includes installation of the following:
o Gas/liquid separation unit;

o Liquid/liquid separation unit;
o A TEG dehydration unit;
o Hydrocarbon dewpointing unit; and
o One LP compressor and one HP compressor. .
The new integrated PSA Liquids and LPG Plant will include the following plant
infrastructure:
11
o Slug catcher;
o Oil/water separation unit;
o 7,500 stbopd LPG train;
o 7,500 stbopd oil stabilisation train;
o New flaring system (start up and upset conditions only);
o Four oil tanks (15,000 bbls each);
o Four oil road tanker loading bays;
o Four above ground earth mounded LPG storage bullets;
o Two LPG road tanker loading bays;
o New produced water temporary storage vessel;
o New produced water reinjection well (still to be located)
o Standby/emergency diesel generator;
o Associated utilities (e.g. nitrogen, compressed air);
o New industrial effluent treatment plant (IETP); and
o Note that a package sewage treatment plant may be included as
a possible alternative to a tie-in with the existing CPF system.
A summary listing of all material changes to the approved Revision 4 o-EMP

that are included in the Revision 5 document are listed in Appendix 4.
1.8. SUMMARY OF PLANT PROCESSES AND OUTPUTS
1.8.1. GENERAL OVERVIEW OF THE EXISTING CPF
The Central Processing Facility (CPF) is located in Mozambique in the area of

Temane, 50 km north-west of Vilanculos, and is the collection point for a
network of gas gathering flowlines that transport natural gas produced from
over 1200 meters below the surface from gas wells located over the Temane
and Pande Gas Fields. This natural gas is processed at the CPF and
transported through a 26 inch diameter pipeline over 860 km to Secunda in the
Republic of South Africa (RSA), as well as to emerging markets in Mozambique.
Gas gathering includes all of the facilities and infrastructure required to gather
the gas from the wells to the CPF, where the gas is processed prior to its
injection and transportation through the gas export pipeline. The initial plant
design was capable of processing an average of 122 million GJ (Giga Joules)
12
of gas annually, with a maximum instantaneous design capacity of 136 million

GJ/a. The NATGAS 183 Expansion project, which was commissioned in 2011,
increased the average capacity of the CPF to 183 million GJ/a (equivalent to
an instantaneous capacity of 203 million GJ/a) to cater for the increased gas
demand in South Africa.
The projected development sequence was to initially produce gas from the
Temane Gas Field followed by production from the Pande Gas Field. This has
been achieved, and since 2008 gas from both the fields has been processed at
the CPF.
The processing facility includes gas gathering lines, two-phase production

separators, three-phase liquid separators, tri-ethylene glycol (TEG) dehydration
units, condensate removal via dew point correction, and gas compression3, with
facilities and equipment to store and re-inject produced water into the Temane
23 well, which is a dedicated produced water re-injection well with the Temane
22 well as a backup. After processing and removal of all liquids, the gas is
compressed into the gas transmission pipeline at a pressure of 125,000 kPa.
To confirm the volumes of the exported gas, the gas passes through a (fiscal)
metering station prior to entering the export pipeline.
Liquid hydrocarbons removed from the gas, referred to as condensate, are

stabilised in a column and stored for sale at the gate. The condensate is
subsequently transported by road in tankers to storage facilities in Beira. The
transport of this condensate is the responsibility of the owner (buyer)4, although
Sasol monitors its SHE performance by regularly auditing the companies
contracted by the owner to transport the condensate, in accordance with its
policy of cradle to grave responsibility. In the event that the condensate cannot
be collected from the CPF, and the storage facilities are full (there is storage
capacity on site to store up to 8 days condensate production), the condensate
may be re-injected back into the reservoir from where the natural gas
3
Gas compression includes high pressure units to boost the pressure of the sales gas before it is exported into the
MSP pipeline; and future low pressure units to boost the raw gas pressure at the inlet of the CPF once it drops below
the required minimum suction pressure of the HP compressors.
4
SPT sells the condensate at the CPF gate to Empresa Nacional de Hidrocarbonetos, E.P. (the National Oil Company)
who transport it to Beira for export.
13
originated, through the Temane 23 condensate re-injection well. For

environmental reasons, the condensate may not be flared to the atmosphere.
1.8.2. CPF EXPANSION TO INCLUDE PSA 5TH GAS TRAIN (FIGURE 1-3)
The existing CPF comprises four parallel trains for gas processing, each with a
capacity of approximately 150 MMscfd. These are operated with three trains in
service and one on standby to maximise deliverability of sales gas. The gas
trains are preceded by an LP compression system and followed by an HP
(export) compression system.
PSA gas will be routed to the CPF in new flowlines and will enter the CPF from
the west side. Approximately four new flowlines are envisaged ranging in size
from 6” NB to 12” NB. A new flowline reception area will be created as the CPF
area currently identified for future flowlines is only capable of accepting two 6”
NB flowlines. The flowlines will be routed to a new PSA inlet manifold. Each
flowline will be provided with a connection for a temporary pig receiver.
The CPF’s facilities will be expanded to provide the required additional

processing capacity. One new production separator and one new liquid
separator will be added in parallel with the existing units.
One new gas processing train will be added (the 5th Gas Train) which will be
the same capacity as the existing trains with very similar equipment.
The CPF’s LP and HP gas turbine driven compression systems will be

expanded with the addition of one new unit of each type. The compression
units and ancillaries will be, as near as possible, identical to the existing trains.
The increased condensate at the CPF resulting from the PSA Gas development
will be stabilised in the existing condensate stabilisation system at the CPF. All
stabilised condensate will be sent to the CPF’s storage tanks.
The increased produced water at the CPF resulting from the PSA Gas
development will be treated and disposed of by the existing systems at the CPF
and, if necessary, by an additional produced water reinjection well (still to be
located).
14
Figure 1-3: Additional plant at the CPF to be installed
1.8.3. INTEGRATED PSA DEVELOPMENT AND LPG PROJECT (FIGURE 1-4)
The PSA Liquids Plant and LPG Plant will be designed to produce 15,000 stock
tank barrels of PSA (Inhassoro) oil per day (approximately 2,385 m3),
40 MMscfd of PSA gas and 20,000 tpa of LPG. It will be situated immediately
to the east of the existing CPF. The two plants will be integrated into a single
functional unit. The oil product will be stored in four new tanks on the plant and
exported by road tankers filled at four new dedicated loading bays. The LPG
will be held in four new storage bullets and will also be exported by road tankers
filled at two new dedicated loading bays.
The PSA Liquid and LPG Plant will be integrated with the CPF in the following
ways:
 The low pressure (approximately 10 bara) gases originating at the

integrated plant will be compressed to approximately 61 bara, metered
and routed to the existing gas processing system at the CPF.
 The CPF will supply electrical power, fresh water and possibly diesel fuel
to the integrated plant but other utilities requirements will be met by new
dedicated systems.
15
 The integrated plant is expected to utilise spare capacity in Sasol’s

existing sewage treatment plant or a new small sewage plant may be
built for the 15 members of staff, since the plant is downslope of the
existing plant. A new Industrial Effluent Treatment Plant will be built with
similar specifications to the existing plant.
 Waste management will use existing sorting and recycling capabilities at
the CPF and will utilise the existing incinerator and hazardous waste
disposal site for ash.
 Produced water will be stored in a new produced water tank and will be
reinjected down the existing produced water wells or possibly a new
produced water reinjection well which is still to be located.
 The integrated plant will be controlled by operators in the CPF’s existing
control room. On-site operations staff will be at the plant frequently. The
close location of the plant to the CPF will minimise operator travelling
time between the two. The plant will be provided with a local equipment
room for the marshalling of signals, housing of some computers and
provision of an operator work station but most of the control and
safeguarding systems’ computational hardware will be housed in the
CPF control room’s equipment room. The integrated plant’s local
equipment room building will also house the electrical distribution
equipment.
 Telecommunications between the integrated plant and the CPF control
room will be by a fibre optic cable newly laid alongside the process and
utility interconnecting lines.
 Operation, maintenance and administration of the integrated plant will
be by PPA personnel. Approximately 15 additional personnel are likely
to be required. Accommodation and messing will similarly be provided
from the CPF’s existing facilities.
16
Figure 1-4: Integration of the existing CPF and the PSA Liquids and LPG Plant
1.9. DETAILS OF INDIVIDUAL PROCESSES (EXISTING CPF AND ASSOCIATED

PRODUCTION FACILITIES)
This section describes the various aspects of the process, the inputs, how the
process works and the outputs including produced water discharge.
1.9.1. PROCESS WELLS
Inputs: SPT is operating 12 production wells from the Temane reservoir,

two wells that are especially dedicated to re-inject produced water
(T22 and T25 – T25 is expected to be fully operational in 2013),
and one well that is maintained for condensate re-injection (T23).
Twelve production wells and one monitoring well (AD1) are
operated from the Pande Reservoir.
Flow rates from the gas wells vary depending on demand and on
the nature of geological formation.
Outputs: The process wells have the following outputs:
17
(1) Gas (rates depend on the well)

(2) Liquids (condensate and produced water – quantities depend
on the well production rates and the nature of the reservoir.
Normally liquids are on a ratio of 1:4 for gas in the Temane
Reservoir and less in the Pande Reservoir. The volumes of
condensate transported and the amount of re-injected produced
water is reported to MICOA in Sasol’s six monthly Environmental
Reports.
1.9.2. PRODUCTION SEPARATORS
Inputs: Wet gas and liquids from the wells
Process: The gas is gathered from the reservoirs and routed through the
wells and hydrocarbon gathering lines via the respective Pande
and Temane Inlet Manifolds. It is then fed via the Production
Manifold to Production Separator A and/or B. The Production
Separator acts as a two phase separator to separate out the liquid
phase (condensate and water) from the gas phase.
Outputs: (1) The liquid, from the Production Separator, is routed, under
level control, to the Liquid Separator (s).
(2) Gas from the Production Separator is routed to the Gas

Dehydration Units (TEG Units) for gas dehydration and water dew
point correction.
1.9.3. LOW PRESSURE (LP) COMPRESSION
Input: Wet Gas from the Production Separators
Process: The function of the LP Compression Unit is to boost the raw feed
gas pressure at the inlet of the CPF once it drops below the 61
bara required to maintain the minimum suction pressure of the HP
compressors.
Output: (1) Gas to Gas Dehydration
18
(2) Air Emissions for example: NOX (estimated 134

tonnes/year), CO (estimated 171 tonnes/year) etc – these
emissions are to be monitored.
1.9.4. GAS DEHYDRATION UNIT
Input: Wet Gas from the LP Compression
Process: The Gas Dehydration Units contact wet gas with tri-ethylene
glycol (TEG) in order to reduce the water content of the gas, such
that the sales gas specification of 7 lb H2O/ mm SCF gas (30mg
H2O / Nm3 gas) is met.
Outputs: (1) Gas with the correct specification.
(2) Air emissions from the TEG re-boiler exhaust (e.g. NOx, CO)
– these are monitored.
(3) Water vapour removed from the gas and vented from the
TEG reboiler.
(4) TEG leakages contained within bunded areas, collected and

incinerated. Potential leakages would be monitored but as the
TEG system is closed, these should be rare.
1.9.5. HYDROCARBON DEW POINT CONTROL
Input: Dry gas from the Gas Dehydration Unit
Process: The Gas Dew Point Control Units cool the water-dried gas, using
propane as a refrigerant, and separate the condensed liquid. This
reduces the hydrocarbon dew point of the gas to -6.8 0C at 629
kPa to meet the sales gas specification.
Outputs: (1) Gas to sales gas specification to HP Compressor suction
(2) Condensate to stabilisation
(3) Incidental vents from the Propane Refrigeration System are

routed to the Flare system and incinerated in the Flare stacks. As
the Propane Refrigeration System is a closed system there
should be no leaks of propane into the environment.
19
1.9.6. HIGH PRESSURE (HP) COMPRESSION
Input: Gas to sales gas specification
Process: The function of the HP Compression Units is to boost the pressure

of the sales gas before it is exported into the pipeline. The
compression of the cleaned gas for transmission in the
Mozambique – Secunda pipeline is currently achieved using three
high pressure compressor trains, with a fourth train on standby.
The existing machines have proven to be highly unreliable and
have suffered a number of severe failures since they started
operating in 2004. Major rebuilds typically take in the order of a
year to complete, which exposes Sasol to high levels of risk with
regard to meeting its contractual obligations. Two options to
minimise this risk are under consideration:
- Option 1: Install a fifth compression train as an additional

backup, allowing for the continued operation of four trains
with one train on standby;
- Option 2: Reconstruct the four existing HP Compression

Trains with like for like capacity equipment supplied by
another vendor with a proven track record of reliability. The
new trains would be fitted with low NOX burners. (None of
the existing HP Compression Trains are fitted with low NOX
burners).
Output: (1) Gas to export pipeline
(2) Air Emissions for example NOX (estimated 651 tonnes / year
for the existing burners and 134 tonnes/year for low NOX burners),
CO (estimated 168 tonnes / year with existing burners and 171
tonnes / year for low NOX burners) etc– these emissions are
monitored.
1.9.7. LIQUID SEPARATORS AND CONDENSATE COALESCERS
Inputs: Liquids from the Production Separators and Hydrocarbon Dew

Point Control
20
Process: In the Liquid Separator, any free water in the stream is separated
from the hydrocarbon fraction by density difference.
Outputs: (1) Produced water: The heavier water is collected in the vessel
boot and is then routed under level control to the Produced Water
Storage system, where it is collected for re-injection into one of
two dedicated injection wells. A new reinjection well is due to be
commissioned in 2013, located within the fenced perimeter of the
CPF. This well (T25) will be used as the primary facility in the
future, with T22 being retained as a standby facility for emergency
use.
(2) Gas: from the Liquid Separator is passed to the Fuel Gas
System so as to supplement the gas routed from up-stream of the
HP Compression System. The fuel gas system supplies gas to
the various gas turbines and fired heaters on site.
(3) Condensate: Under normal conditions, Condensate is routed

under level control to the Condensate Stabilisation Unit for further
treatment. During the 183 MGJ/a Expansion Project, 2 Coalescer
filters were installed to further separate any water from the
condensate stream leaving the liquid separators, routing the
water back to the produced water drum and condensate to the
Condensate Stabilisation unit. If, however, the plant status does
not allow for Condensate stabilisation or storage, the flow can be
routed to the Condensate re-injection well, Temane 23.
1.9.8. CONDENSATE STABILISATION
Input: Condensate from the Liquid Separator and Dew Point Control
Units
Process: The Condensate Stabilisation Unit produces stabilised

condensate by stripping the light hydrocarbon components from
the raw condensate using a fired reboiler.
Output: (1) Stabilised condensate: These units are designed to produce

21.9 m3/hr of stabilised condensate. A single unit is provided, as
21
condensate re-injection provides for back-up operation should the

unit require maintenance, or for any other reason.
(2) Stabiliser overhead which is routed to the LP fuel gas

system.
(3) Air emissions: reboiler exhaust (e.g. NOx (estimated 1,7

tonnes/year), CO (estimated 1.8 tonnes/year) – these emissions
are monitored.
1.9.9. CONDENSATE STORAGE / LOADING
Input: Stabilised condensate
Process: Stabilised condensate is routed to the Condensate Storage Tanks

TK-9201 A/B/C each having a diameter of 15m and a height of
12m. Tanker loading is based on loading for twelve hours per day
at the peak design rate.
Output: (1) Stabilised condensate for sale at the gate.
(2) Potentially condensate contaminated runoff from cleaning

of loading area or spills or leakages.
Monitoring is done for leakages. Spills are minimised by

procedure on condensate loading.
Potentially contaminated water is routed to the potentially oil

contaminated (POC) drainage system for treatment via the
Industrial Effluent Treatment Plant.
1.10. DETAILS OF INDIVIDUAL PROCESSES (INTEGRATED PSA LIQUIDS AND LPG PLANT)
It is noted that the PSA Liquids and LPG Plant design has not been finalised
yet. This preliminary description will need to be updated once the plant design
is completed.
The Integrated PSA Liquids Plant and LPG Plant will process:
 15,000 stbopd of PSA (Inhassoro) oil;
22
 Up to 40 MMscfd of PSA gas (approximately 8 MMscfd of associated gas

and up to 32 MMscfd of coning gas); and
 No condensate from the CPF.
The flow rates above are per Stream Day (the maximum flow rate over 24
hours).
The design LPG production rate for the integrated plant is to be 20,000 tpa,
which is less than the maximum that could be extracted from the feed but
satisfies domestic demand in Mozambique. It should be noted that the oil rates
will decline over time and that the LPG production rate given above is the
approximate maximum.
The PSA Liquids reception facilities will consist of connections for a temporary
pipeline pig receiver followed by slug catchers (horizontal gas-liquid separators
with slug handling capacity). Provision is to be made for the future addition of
a second pipeline from Inhassoro. The separator will operate at approximately
11 bara to minimise back pressure at the wellheads and provide the maximum
pressure differential between the Inhassoro field and the plant to maximise the
production rate and velocities in the pipeline (to control liquid hold-up).
The liquid from the slug catchers is routed to an oil-water separator with residual
gas disengagement followed by a coalescer for removal of entrained water from
the oil. This oil, which needs to be stabilised, will be routed to the following two
differently configured oil processing trains:
 1 x 7,500 stbopd LPG train making maximum 20,000 tpa LPG in addition
to stabilised oil.
 1 x 7,500 stbopd oil stabilisation train making only stabilised oil and no
LPG.
The LPG train will use two columns; a deethaniser to remove the components
C2 and lighter from the feed stream and a debutaniser to separate the C4 and
lighter components from the remaining oil in order to produce LPG in the
overhead distillate stream and stabilised oil in the bottoms stream.
The oil stabilisation train will use a single stabiliser column to remove the light
ends to meet the oil export specifications.
23
The gas from the slug catcher will be combined with the off gas from the LPG
train and stabiliser and routed to the compression system. A portion of this gas
will be used as LP fuel gas and the balance will be compressed from 9.6 bara
to 60 bara and routed to the existing CPF’s TEG dehydration units for treatment
and export. The design capacity of the compression system is 40 MMscfd.
There will be no normal flaring of gas. Flaring will occur only during start up and
shut down, upset conditions and emergency conditions. (Normal flaring of gas
at the CPF will continue)
The stabilised oil will be sent to oil storage tanks where it is stored and exported
to the port at Beira by road tankers. Four new 15,000 bbl working volume oil
storage tanks are to be provided at the plant. Four new road tanker loading
bays are to be provided in a new location at the Integrated LPG and PSA
Liquids Plant. LPG will be stored in four above ground, earth mounded LPG
storage bullets (4 x 33%, each bullet is approximately 3.3 m ID x 14.3 m T/T)
and exported using two LPG road tanker loading bays. One of the bullets would
be used to hold off-specification LPG or be undergoing the limited inspection
possible.
Produced water will be treated in a new produced water treatment system and
sent to an existing disposal well or possibly to a new produced water disposal
well, to be determined during the Front End Engineering and Design (FEED)
phase of the project.
24
1.11. UTILITIES (EXISTING CPF)
1.11.1.WATER AND EFFLUENT TREATMENT
Figure 1-5: CPF Water Treatment Process
1.11.1.1 Domestic Sewage Treatment Plant (STP)
Inputs: Effluent water from kitchen, bathrooms, residential area and

administration area.
Process: A waste water treatment facility has been constructed based on a

membrane bioreactor (MBR) process configuration with the
following design loads to produce an effluent quality given in
Section 4, Table 4-1.
TABLE 1-1: SUMMARY OF DESIGN LOAD CONDITIONS (SASOL DESIGN

BASIS, 11 DECEMBER, 2007)
Description Load
Min number of people 60
25
Description Load
200 permanent and 1500 construction
Max number of people
workers
Waste water 650l/d (permanent staff), 50 l/d
production/person (construction personnel)
Total volume per day 205 m3
Avg COD 1000 mg/l
Avg NH4 150 mg/l
An 87.5 m3 equalisation sump provides a storage retention time

of approximately 10 hours at normal flow. This should be sufficient
to balance out the diurnal peaks in the system. Water sources to
this sump include;
 the residential, laundry, kitchen, clinic and admin waste water

that is routed via residential sump,
 construction sewage,
 control room effluent header, and
 TK-9006 (old sewerage collection sump).
Raw sewage is pumped from the equalisation sump to the Anoxic

tank. This tank is a 50 m3 glass fusion bonded steel tank that
serves as both a balance tank as well as an anoxic zone. The
anoxic zone serves the purpose of denitrifying returned waste
activated sludge as well as balancing inflow raw sewage. An
amount of 20 m3 balancing storage (2.3 hours retention) has been
allowed in the anoxic tank to absorb the flow fluctuations from the
equalisation sump (15 m3/h).
The mixed liquor then flows to the FBDA (fine bubble diffused
aeration) tank. The FBDA tank contains fine bubble diffusers
mounted on the floor to efficiently dispense air bubbles into the
mixed liquor for uptake of oxygen by the bacteria. The system is
supplied with the air by its own dedicated FBDA blower.
The FBDA tank is equipped with a dissolved oxygen analyser

which measures the dissolved oxygen in the mixed liquor. The
26
system normally operates at dissolved oxygen concentrations of

2mg/l. Measurement outside this range will cause the FBDA
blower to deliver more or less air. At very low or no influent flows
this blower could be shut down completely.
The FBDA tank contains 2 submerged membrane packs through

which the final effluent permeates. The packs are supplied with a
dedicated membrane blower which supplies air to keep the
membranes clean.
Under normal operating conditions surplus sludge will have to be

removed from the FBDA tank and disposed of to the Incinerator.
Phosphate removal is accomplished by the addition of Aluminium

Sulphate from a dosing station incorporating Alum tank and Alum
dosing pumps.
From the FBDA tank treated water collects in the intermediate

storage sump where it is analysed. If it meets specification it is
routed as make-up water to the firewater tank. If not, it is dosed
with a biocide before routing to the firewater tank. Once the
firewater tank is full the pump to the tank is turned off
automatically and the treated water in the intermediate storage
sump fills up, overtops the weir and flows directly to the final
effluent sump, where it is mixed with water from the IETP.
Treated water from the FBDA tank should meet the minimum
standard for coliforms but provision has been made for biocide
dosing in the event of coliform breakthrough.
Grease and oil is removed via grease traps. In addition there is a

holding tank with additional capacity for upset conditions.
Outputs: (1) Sewage sludge from the STP is periodically pumped to the
Waste Incinerator (2) The liquid waste that meets specification
(see section 4, Table 4-1, Monitoring Requirements) is
discharged to the intermediate effluent sump and is either routed
as make-up water to the firewater tank or overflows to the final
27
effluent sump for irrigation on site. Out of specification effluent is

returned to the sewage treatment works.
(3) Fat from grease traps is collected and incinerated (estimated

less than 5 litres / day).
Figure 1-6: Domestic Sewage Treatment
1.11.1.2 Drainage System – Closed – Potentially Oil Contaminated

Water
Inputs: Potentially hydrocarbon contaminated water. Note that this does

not include potentially TEG contaminated water (see section 1.8.4
for details of this).
Process: Storm water run-off from the plant is collected in the storm water
ponds on a “first flush” basis – the first 10 minutes of rainfall from
the furthest point in the plant is collected. Subsequent run-off is
allowed to overflow the chamber weir and flows off-site. This
ensures that any contaminated water from the plant is “caught”,
after which the site is deemed to be “flushed” of potential
contaminants and the remaining run-off hence clean (note: this is
28
recognised practice internationally– see for example, New South

Wales Government, 26 February 2011).5
Storm water that requires treatment is routed via the Potential Oil
Contaminated (POC) system to storm water ponds (capacity 400
m3)
Normal run-off due to cleaning of the plant or maintenance

activities is also collected in the storm water pond to ensure it is
treated before discharge. This run-off, however, will be tested by
the plant operating personnel who will decide whether run-off is
suitable to be drained to the treatment plant based on monitoring.
Concentrated fluids (such as cleaning fluids and lubrication oils)
are to be collected in containers and disposed of in a manner
appropriate to that fluid (i.e. incineration, etc.).
In the case of a fire breaking out and hence firefighting through

water sprays and foam deluge being required, this run-off would
obviously be contaminated. For this reason, should the fire alarm
be activated, automated valves on the outlet of the storm water
chamber swing for a period of 30 minutes to divert run-off to the
fire water pond instead of the storm water pond (normal route for
any run-off). After the time has elapsed, the valves automatically
revert to their original positions. The water in the fire water pond
can then be tested for contaminants (expected to be mainly oil)
and a decision made as to what course of treatment is required
to clean the water. This ensures that species (such as dissolved
hydrocarbons and other chemicals) that cannot be separated in
the oily water treatment plant are handled correctly and not
allowed to be discharged to the environment.
The development of the 5th Gas Train will result in an increase in

potentially oil contaminated water (POC). The average annual
5
NSW Government, Environment & Heritage; Storm water First Flush Pollution.
http://www.environment.nsw.gov.au/water/storm watermao.htm
29
discharge of utility water into the Industrial Effluent Treatment

Plant (IETP) will increase from around 60 Kl/annum to 66
Kl/annum, The IETP is designed to accommodate the increased
loads associated with expansions and has the capacity to treat
the additional effluent.
The proposed PSA Liquids and LPG Plant will require the
construction of a new IETP similar to that at the CPF. It will involve
a dissolved air flotation (DAF) system which removes oil residues
from the wastewater, and will be irrigated onto the lawns and
gardens of the CPF or onto an additional landscaped area.
Outputs: (1) Potentially oil contaminated water which is routed to the

Industrial Treatment Plant
(2) Water contaminated with other chemicals which is

drummed and incinerated
(3) Treated water used for irrigation purposes.
1.11.1.3 Storm water System - Open
Inputs: Clean water not from the Plant area during rainfall.
Process: Water is routed to the open drainage system and discharged off-
site
Outputs: Clean Storm water
1.11.1.4 Industrial Effluent Treatment Plant (IETP)
Inputs: Potentially oil contaminated water from the drainage system. This
drain system ensures that industrial effluents arising from storm
water run-off, wash-down of equipment, maintenance effluents,
and firewater run-off are adequately routed to the IETP for
treatment.
Process: The Closed Drain Vessel permits collection and retention of

process fluids containing only hydrocarbons and water.
Recovered hydrocarbons are routed to the incinerator for
30
disposal. Note that fluids containing TEG from the Gas

Dehydration Unit are treated separately and are incinerated.
Storm water that requires treatment is routed via the Potentially

Oil Contaminated (POC) system to storm water ponds (capacity
400m3) and then to the IETP which is a dissolved air flotation unit.
The plant is designed with an emergency capacity to treat

300 m3/day to cater for contaminated runoff generated during
heavy rainfall and for emergency situations
The intention is to take regular manual samples from the final

effluent sump and the proving pond, and accurately analyse these
for TSS, oil and grease, BOD5, COD, pH, Total Nitrogen and
conductivity. .
Note that, should the final effluent prove to be unsatisfactory for

irrigation, it can be re-circulated to the storm water pond for
storage and re-treatment.
An additional IETP is to be constructed for the new PSA Liquids and LPG Plant.
Drainage for the new 5th Gas Train will be provided for by extending the
collection systems of the existing drains networks at the
CPF.Outputs: (1) Treated water that meets specifications
in Section 4, Table 4-1 (Monitoring requirements), is either used
for irrigation of the CPF Plant or in heavy rainfall periods,
discharged to the environment
(2) Hydrocarbons that are removed during treatment are

incinerated.
1.11.1.5 Drainage System – TEG
Inputs: Potentially TEG contaminated water from bunded areas around

the dehydration units.
Process: The water is retained in a closed system separated from the open
drain system or POC system. It is routed to the incinerator for
disposal.
31
Outputs: Potentially TEG contaminated water which is routed to the

incinerator.
1.11.2.ELECTRIC POWER GENERATION
Inputs: HP Fuel Gas
Process: Generates electricity for the site. An additional gas turbine

generator is to be installed, it will supply both the PSA 5th Gas Train and the
PSA Liquids and LPG Plant. In addition a standby/emergency diesel generator
will be provided at the new plant to enable safe shutdown of the plant in the
event of a main power failure.
Outputs: (1) Noise – this is being monitored. The design is for less than 85
dbA
(2) Air emission from the turbine exhaust (e.g. NOX, CO) – these
are being monitored
1.11.3.DIESEL FUEL SYSTEM
Inputs: Diesel
Process: Storage of diesel
Outputs: (1) Gas emissions VOC’s – this is being monitored
(2) Diesel contaminated water resulting from spills. This water

is routed to the POC system for treatment through the Industrial
Treatment Plant
1.11.4.PILOT GAS TO FLARES
Inputs: Fuel Gas
Process: To sustain pilot lights to flare. No new flare systems will be added
for the 5th Gas Train facilities.
The integrated PSA and LPG Plant will have its own LP flare system. There
will be no continuous flaring, other than purge (when fuel gas is being used)
and pilots. Flaring will occur only occasionally due to emergency, mal-
operation, start-up, shutdown or maintenance of the plant.
32
There is no continuous venting of hydrocarbons but there may be occasional,

low volume venting during maintenance.
There is continuous venting to atmosphere of exhaust gas from the oil stabiliser,
deethaniser and debutaniser reboiler fired heaters.
Outputs: (1) Air emissions (e.g. NOx (estimated 25 tonnes / year), CO

(estimated 16 tonnes / year) - this is being monitored
1.11.5. INCINERATOR
Inputs: Combustible waste (hazardous and domestic) sewage sludge

and liquid waste
Process: The incinerator consists of two chambers, primary and

secondary. The first is used to load solid material and should
operate between 630 and 650°C. This incinerates the material to
ash, while generating off-gas.
The off-gases from the primary chamber are fed directly to the
secondary chamber. Here the off-gases are incinerated at 1100
to 1200°C to ensure that any remaining hazardous volatile
material is incinerated and converted to CO and CO2.
Also in the secondary chamber, liquid waste is injected (including

sewage sludge) and incinerated. The material is kept in the
secondary chamber long enough to ensure complete combustion
(i.e. longer than 2 seconds).
Off-gas from the incinerator is filtered and cooled properly to

ensure that the gas that is finally exhausted meets the emission
limits. Treatment includes coating of the filter to ensure that acid
gases (e.g., HCl, chlorine, SO2, HF) are trapped and not allowed
to enter the atmosphere. Particulates are also kept low in this
way. To prevent the formation of dioxins, the temperature is
maintained above 400°C until safe to cool.
The new incinerator became operational in 2011, replacing the

old incinerator that has operated since the project start. Features
of the new incinerator include automatic loading (without having
33
to power down the incinerator); automatic de-ashing (minimising

physical labour requirements); maintenance of more constant
temperature, avoiding thermal cycles and providing more stable
operation which causes less mechanical wear and tear; efficient
turnover of incineration material to ensure consistent combustion
of waste; larger load size and continuous operation which
increases throughput of waste; and improved sludge and oil
injection systems, avoiding the need to remove spent oil and oily
material from site.
Incinerator ash from the PSA 5th Gas Train and the PSA Liquids
and LPG Plant will be disposed of at the CPF’s existing facilities.
Outputs: (1) Ash: this is the residue from combustion which will be
disposed of to the landfill. Ash characterisation is undertaken
once a year, including a full range of potential contaminants.
(2) Air emissions: The filtered off-gases are discharged up a

stack to atmosphere. An on-line analyser is provided to ensure
continuous monitoring of the off-gas is available. The analyser
will check levels of O2 (to ensure combustion was complete), CO,
CO2, SO2, HCl, opacity, water vapour and VOC’s. Low NOx
burners are used to ensure that the emission limit for this class of
gases is met. Dioxins and furans are monitored periodically.
The standards to which the off gas has to comply are outlined in
Section 4, Table 4-1 (Monitoring requirements) in the Operations
EMP.
(3) Lime: this is used to neutralise the compounds in the air filters.
This is disposed of in the landfill site with the ash.
1.11.6.LANDFILL SITE
Inputs: Stabilised ash and lime from the incinerator. Occasionally small
quantities of other hazardous when upset conditions occur.
Process: Containment of waste in a manner that minimises the production

of leachate and potential soil and groundwater contamination.
34
The landfill site is PVC lined and complies with the South African
Department of Water Affairs guidelines for disposal of high hazard
(H:H) waste. The site includes a ramp suitable for access for
rubber tyred vehicles for the purposed of access and waste
spreading and covering.
The existing CPF facility for disposal of hazardous waste has sufficient capacity
to accommodate waste generated by the PSA 5th Gas Train and the PSA
Liquids and LPG Plant.
Outputs: (1) Leachate: This is collected and contained in the manholes.

Once the manholes reach 80% of capacity, leachate is irrigated
onto the active cell to allow for evaporation.
1.12. UTILITIES (5TH GAS TRAIN AND PSA AND LPG PLANT)
1.12.1.WATER AND EFFLUENT TREATMENT
The water and effluent utility requirements of the 5th Gas Train were quantified
and compared with spare capacity available from the CPF’s existing systems.
No additional utilities will be required.
1.12.1.1 Utility Water and Fresh Water
The expected usage of water by the PSA Development is as follows:
 3.5 m3 day (domestic water for 15 additional staff members)

 50 m3/day (utility water in the plant including potable water, water for
shower, eyewash, washdown etc)
The CPF’s existing borehole T-9 is rated for continuous use at 450 m3/day. No
additional water supply boreholes will therefore be required. Combined
expected usage of the integrated plant is 204 m3/day. There will therefore be
no requirement for additional supply boreholes for the new facilities (all are low
consumption users); occasionally a bulk requirement may have to be supplied
from a water tanker.
 Utility water system: Supplies utility stations and HVAC.

 Fresh water system: Potable water, water for shower, eyewash, etc.
35
The 5th Gas Train modifications make an allowance for an additional distribution
pump and filter.
1.12.1.2 Sewage Treatment
A decision has not been taken yet whether to utilize the spare capacity of the
MBR sewage treatment works (currently operating at around 50 m3/day; rated
at 205 m3/day), which will involve pumping small quantities of sewage back
(uphill) to the plant at the CPF or to construction a small package plant to treat
the sewage generated by the PSA Liquids and LPG Plant staff complement
(some 15 people). The total additional sewage treatment capacity required for
the PSA development is estimated to be 3.75 m3/day.
1.12.1.3 Closed and Open Drain System
The plant has still to be designed but the principles governing drainage control
are expected to be identical to the existing plant. Potentially contaminated
drainage will be contained and will be routed to the IETP. Uncontaminated
storm water will be collected and distributed off site into the bush (refer to
Sections 1.10.1.2 and 1.10.1.3).
1.12.1.4 Industrial Effluent Treatment Plant
A new Industrial Effluent Treatment Plant will be built at the new PSA Liquids
and LPG Plant to cater for potentially oil - contaminated water from the drainage
system. The design is expected to be very similar to the existing IETP at the
CPF (Section 10.1.4).
This drain system ensures that industrial effluents arising from storm water run-
off, wash-down of equipment, maintenance effluents, and firewater run-off are
routed to the IETP for treatment. It is estimated that a capacity of some 50
m3/day will be required. The treated effluent is likely to be irrigated onto
landscaped areas at the CPF complex – whether it will be routed back to the
existing final effluent pond or separately irrigated is still to be decided.
1.12.2.WASTE MANAGEMENT
1.12.2.1 Kitchen Waste
36
No additional kitchen and laundry facilities will be provided for. PSA Liquids and
LPG Plant staff will utilize the existing CPF kitchen and laundry.
1.12.2.2 Solid Waste Management
Collection facilities for separating waste will be provided at the new plant. Waste
will be transferred to the existing plant for sorting, recycling and disposal
1.12.2.3 Waste Incineration
The existing incinerator at the CPF will be used to incinerate waste designated
for this purpose from the PSA Liquids and LPG Plant.
1.12.2.4 Medical Waste
No additional medical services will be provide at the PSA Liquids and LPG
Plant.
1.12.3.HP AND LP FUEL GAS
A new fuel gas train, sized for the 5th Gas Train, will be provided to supplement
the CPF’s existing system and will be tied into it. For start-up the LP fuel gas
will be sourced from the existing system.
For the integrated plant, the LP fuel gas from the slug catcher, separator and
deethaniser is at low pressure. Some of it will be conditioned (filtered and
superheated) to enable its use as LP fuel gas for the column reboilers, flare
pilots and, if used, flare purge (as back-up to inert gas). Fuel gas for start-up
will be sourced from the CPF.
Diesel is required for the integrated plant’s standby/emergency generator and

diesel engine driven fire water pump. Small storage tanks will be filled from a
diesel tanker.
1.12.4.INSTRUMENT AND UTILITY AIR
A new air compression and drying train, sized for the 5th Gas Train, will be
provided to supplement the CPF’s existing system and will be tied into it.
Additional small instrument and utility air receivers will also be provided.
The integrated plant will have its own instrument and utility air system.
37
1.12.5.NITROGEN (INERT GAS)
A new nitrogen generation package, sized for the 5th Gas Train, will be provided
to supplement the CPF’s existing system and will be tied into it.
The integrated plant will have a new nitrogen generation package to supply
inert gas for purging and blanketing equipment and piping during maintenance.
The flare will normally be purged with inert gas.
1.12.6.CONTROL, ESD AND F&G
The new facilities will require process control, monitoring, and safeguarding
systems in line with the existing provision at the CPF. The new instrumentation
will be routed to the existing equipment room housing marshalling racks and
will be controlled from the CPF’s existing control room and fully integrated into
the CPF’s existing control and safeguarding systems. This will require some
control system physical upgrades and substantial graphic and software
changes.
1.12.7.FIRE PROTECTION
A new fire water storage tank and main pump, sized for the 5 th Gas Train, will
be provided to supplement the CPF’s existing system and will be tied into it.
The water to fill the tank will be supplied from the CPF’s fresh water system.
The integrated plant will be provided with dedicated firewater storage,

distribution pumps, ring main, monitors and hydrants. There may be an
opportunity to tie this system into the CPF’s system to increase redundancy in
both.
38
2. ENVIRONMENTAL MANAGEMENT STRUCTURE
2.1. ORGANISATIONAL STRUCTURE AND RESPONSIBILITY
The overall organisational structure for environmental management on the

Temane Operations is presented in Figure 2-1.
Figure 2-1: Overall Environmental Organisational Structure between Key Role Players during the
Operational Phase of the CPF
39
With regard to environmental and social management during the operational

phase of the CPF, the principal responsibilities of each key party within this
structure will be as follows:
All parties All parties shall comply with all the requirements of the
operations EIA and EMP and shall, in accordance with accepted
standards of the international petroleum, oil and gas industry
and the World Bank, employ such up to date techniques,
practices and methods that will ensure compliance to the
requirements and, in general, minimise environmental damage,
control waste, avoid pollution, prevent loss or damage to natural
resources and minimise effects on surrounding landowners,
occupants and the general public.
All parties shall prevent or minimise the occurrence of accidents
which may cause damage to the environment, prevent or
minimise the effects of such accidents and shall return the
environment to a state as close to the condition existing prior to
any such accident as possible.
All parties shall take proactive steps to ensure that the
requirements in the EMP are met during operation. These shall
include, but not be limited to, the following:
o Employment of competent and dedicated members of
staff to oversee the implementation of the EMP.
o Instruction of staff about the relevant environmental
aspects and the specific measures that each employee
will implement to meet the environmental protection and
management standards defined by the EMP.
Senior SHE Offer advice and support to the Operations Manager, specifically
Manager: in terms of Safety, Health and Environmental matters.
Sasol Visit the site from time to time and ensure that he/she is fully
Petroleum familiar with site happenings so as to actively initiate any
International planning or provide advice on decisions that may be required to
(Rosebank) ensure the protection of the environment and relations with
communities and stakeholders.
Ensure strategic planning with regard to medium and long-term
environmental and social management for SPT operations by:
o Periodically reviewing the SPI SHE Strategy
o Liaising with the SPT Operations, SHE Manager and
Public Affairs/CSI Manager.
o Providing advice and support to the SPT Operations
Manager, SHE Manager and Environmental Site Office
(ESO) and public affairs or CSI officers as required.
o Keeping abreast of local, regional and national
developments in the environmental field
Ensure the adequate allocation of SHE resources to support
safe and environmentally and socially responsible SPT
operations.
Senior Developing and implementing means and approaches for SPT
Environmental to understand its effects on the broader region in which it
Manager: operates in Mozambique and to liaise with the Government of
40
Sasol Mozambique and SPI management to encourage and plan for

Petroleum the effective management of these issues.
International Providing guidance and support to the SPT SHE Manager and
(Rosebank) ESO with regards to environmental management matters
associated with SPT’s operations.
Ensuring that adequate governance is in place aimed at
ensuring compliance with the applicable legal and other
requirements.
Defining and periodically review the environmental strategic
objectives of SPT to ensure alignment with corporate
requirements and industry best practice.
Defining objectives and targets and ensure that plans are in
place to meet these as well as competent resources allocated to
support the meeting of objectives.
Periodically monitoring environmental performance, ensuring
that action plans are in place to address non-compliance and
that issues are investigated and reported to the appropriate
levels within the organisation.
Environmental Providing support to the SPT SHE Manager.
Manager: Providing guidance and technical support to the SPT ESO with
Sasol regards to environmental management matters associated with
Petroleum SPT’s operations.
International Ensure that the relevant environmental and associated licenses,
(Maputo) permits and authorisations are in place.
Monitoring compliance with the applicable legal and other
requirements and ensuring that plans are in place to address
deviations.
Ensuring that plans are in place and actions implemented to
meet the defined environmental strategic objectives of SPT.
Monitoring progress in meeting defined objectives and targets
and intervening to address shortcomings.
Compile and verify regular environmental performance reports
produced for SPI and external stakeholders such as MICOA and
INP.
Conduct regular site visits, environmental audits and
inspections.
Review environmental performance, ensuring that action plans
are in place to address non-compliance and that issues are
investigated and reported to the appropriate levels within the
organisation.
Initiate, co-ordinate and manage all environmental related
communication with the Government (local, provincial and
national) on environmental matters.
Operations The Operations Manager shall ensure that all parties comply to
Manager: all the requirements of the EIS and EMP and shall, in
Sasol accordance with Mozambique Legislation, accepted standards
Petroleum of the international petroleum, oil and gas industry and the World
Temane Bank, employ such up to date techniques, practices and
methods of Operations that will ensure compliance to these
requirements and, in general, minimise environmental damage,
control waste, avoid pollution, prevent damage to natural
41
resources and minimise effects on surrounding landowners,

occupants and the general public.
Ensure the provision of sufficient and suitable resources both on
and off-site to ensure that pollution is prevented, waste
minimised and the rights of the environment protected.
Ensure compliance to all applicable environmental legislation
and commitments at all times.
Ensure the implementation of an environmental management
system to achieve all of the above.
Assume responsibility for all decisions on all environmental
matters.
The Operations Manager shall establish systems and
approaches to prevent or minimise the occurrence of accidents
which may cause damage to the environment, prevent or
minimise the effects of such accidents and shall return the
environment to a state as close to the condition existing prior to
any such accident as possible.
The Operations Manager shall take proactive steps to ensure
that the standards in the EMP are met during operation. These
shall include, but not be limited to, the following:
o Employment of competent and dedicated members of
staff to oversee the implementation of the EMP; and
o Instruction of staff about the relevant environmental
sensitivities and the specific measures that each
employee will implement to meet the environmental
protection and management standards defined by the
EMP.
The Operations Manager shall ensure the availability of
sufficient and suitable resources to ensure the aforementioned.
Production The Production Manager shall be responsible for: Monitoring;
Manager: defining contingency measures; achieving continual
Sasol improvement; and tracking all issues related to environmental
Petroleum management and performance for SPT operations.
Temane The Production Manager shall support the Operations Manager
and SH&E Manager in environmental management. He/she
shall be responsible for meeting the standards of operation to
ensure environmental performance and compliance.
The Production Manager shall assume the responsibilities of the
Operations Manager in the absence of the latter.
SHE Manager, The SHE Manager is responsible for providing overall
Sasol governance for SHE matters relating to SPT’s operations,
Petroleum including the management of resources such as the ESO by
Temane providing guidance and support and monitoring progress against
established work plans to meet defined environmental targets
and objectives:
He/she is specifically responsible for the following:
o Ensuring compliance with the approved EMP for SPT’s
operations
o Ensuring that the ISO 14001 standard requirements are
in place
o Ensure that the environmental parameters are monitored
as per the o-EMP requirements.
42
o Ensuring accurate and timeous reporting on

environmental performance, analysing trends and
ensuring that measures are in place to address
deviations.
o Ensuring that all environmental incidents are reported
and investigated and that measures are in place to
prevent recurrence.
o Chairing the environmental task team meetings and
ensuring that actions are allocated to responsible
persons and that close-out is monitored in SPT’s CPAR
system
o Ensuring that a regular meeting platform is created
where environmental performance is discussed at
employee and management level
o Ensuring that the environmental audit and inspection
programme is carried out
o Ensuring that the independent environmental monitoring
activities are regularly conducted, the reports analysed
and measures put in place to address trends.
Environmental The ESO will act as a guide and advisor to employees and
Site Officer contractors on environmental issues associated with SPT’s
(ESO): Sasol operations. This will be achieved by ongoing inspections /
Petroleum auditing of Operations, identification of problem areas and
Temane provision of actions plans to ensure environment protection.
The ESO will ensure compliance to the requirements of the EMP
by all parties, as well as with any other requirements related to
environmental issues as they become known. Specific
responsibilities of the ESO will be as follows:
o To thoroughly familiarise him/herself with existing
information regarding operations area and the EMP.
o Ensure the protection of the environment.
o Maintain SPT’s ISO14001 Environmental Management
System and ensure that SPT retains its certification
o Perform all of the day-to-day tasks necessary to monitor
performance with regard to the requirements of the EMP
and any other relevant requirements and / or
commitments.
o Update the EMP based on requirements of operations,
the Government or internal Sasol requirements.
o Monitor the impact of operations on the environment with
particular emphasis on areas of environmental
sensitivity.
o Audit compliance by employees, contractor(s) and
suppliers with this environmental standard.
o To liaise with the Operations Manager and SH&E
Manager in the case of incidents, non-compliance or any
matter where the course of action is unclear.
o Prepare environmental audit reports documenting the
effectiveness of environmental management, problem
areas, remedial actions proposed and taken and
compliance/non-compliance by the Contractor(s) with the
Operations standard.
43
o Verify the accuracy of the information contained in the

EMP and to bring any errors, omissions, oversights to
the attention of all parties as necessary.
o Compile regular environmental performance reports
which include trend analysis and which identify areas
and actions for improvement.
o Commission and oversee the execution of regular
independent environmental monitoring activities.
The ESO should have adequate and relevant training in
environmental management and will be required to be able to
evaluate the effectiveness of specified management measures
and be familiar with environmental management techniques. He
/ she should be able to propose solutions to problems identified
as regards the implementation of the plans.
The ESO will liaise closely with the Operations Manager, the
Production Manager, the SHE Manager, and the environmental
supervisors of all appointed contractors. The ESO will be based
on site.
Safety The Safety Practitioner shall assist the ESO in the
Practitioner: environmental management on the Plant and at the well sites,
Sasol with a specific focus on health a safety issues, including
Petroleum emergency response and contingency planning.
Temane The Safety Practitioner shall also undertake the inductions on
site which include environmental aspects, as well as assisting
the ESO with the environmental awareness and training
associated with ISO14001.
The Safety Practitioner will liaise closely with the Operations
Manager, the Production Manager and the SHE Manager. (S)
He will be based at site.
Public To design and manage effective information dissemination and
Relations constructive engagement with District Government and
Officer: Sasol community leaders in the Sasol Temane zone of influence
Petroleum
Temane
Community To keep communities informed and obtain their inputs through
liaison information dissemination, personal contact and meetings, to
officers: Sasol maintain Compliments and Complaints Registers, to register
Petroleum grievances and communicate about their progress and close-
Temane out.
2.2. LIAISON, CO-ORDINATION AND REPORTING
The structure for all communication, correspondence and reporting between

Operations stakeholders will be as per the overall Operations organisational
structure (for environmental and social responsibilities) as presented in Figure
2-1.
44
2.3. ENVIRONMENTAL MANAGEMENT SYSTEM
There are three main tools for the environmental management at the CPF:
 The Environmental Impact Assessment / Study (EIA/EIS);
 The Operational Environmental Management Plan (o-EMP); and
 The Environmental Management System (SPT ISO 14001:2004

Certification Number CN: 01 104 042 161).
The EMP is intended to guide impact management and mitigation associated

with the CPF. It converts EIA mitigation measures into actions and allocates
responsibility and deadlines to those actions. The EMS confirms management
commitment to the EMP and describes how the requirements of the EMP will
be achieved. It sets the management framework in terms of environmental
organisational structure, reporting, review and monitoring, training and public
disclosure. The Operations Manager, in conjunction with the SH&E Manager is
to ensure that a suitable management system is implemented to ensure
compliance (and be able to demonstrate compliance) to the EMP.
3. ACTIVITY AND IMPACT MANAGEMENT PLAN
This section presents specific environmental management requirements for the

operational phases of the CPF and associated infrastructure.
3.1. BACKGROUND TO ENVIRONMENTAL IMPACT MITIGATION AND MANAGEMENT
For environmental management to be effective the primary focus of this

management must be placed on managing activities so as to prevent or
minimise the occurrence of negative impacts. Environmental management
measures can be varied and the measures themselves may have a variety of
objectives, however the first priority is always to prevent adverse impacts,
thereafter management measures with other objectives should be considered.
The various objectives for management measures should be remembered
when using this Environmental Management Plan (Table 3-1).
45
TABLE 3-1: OBJECTIVES OF MITIGATION MEASURES FOR ADVERSE

ENVIRONMENTAL IMPACTS. FIRST PRIORITY IS AVOIDANCE OF NEGATIVE IMPACTS;
THE OBJECTIVES ARE LISTED IN DECREASING ORDER OF PRIORITY
Avoidance  Avoiding activities that could result in adverse impacts.

 Avoiding resources or areas considered as sensitive.
Prevention  Preventing the occurrence of negative environmental impacts and/or
preventing such an occurrence having negative environmental impacts.
Preservation  Preventing any future actions that might adversely affect an
environmental resource. Typically achieved by extending legal
protection to selected resources beyond the immediate needs of
Operations.
Minimisation  Limiting or reducing the degree, extent, magnitude or duration of
adverse impacts. This can be achieved by scaling down, relocating,
redesigning elements of Operations.
Rehabilitation  Repairing or enhancing affected resources, such as natural habitats or
water sources, particularly when previous development has resulted in
significant resource degradation.
Restoration  Restoring affected resources to an earlier (and possibly more stable
and productive) state, typically ‘background / pristine’ condition.
Compensation  Creation, enhancement or protection of the same type of resource at
another suitable and acceptable location, compensating for lost
resources.
Ref: The World Bank. Environment Department. January 1999. Environmental Management Plans. Environmental
Sourcebook Update.
3.2. ENVIRONMENTAL MANAGEMENT REQUIREMENTS
The management requirements presented in this section have been compiled

based on activities required during the operational phase of the CPF. While
specifications have been listed under activities, the requirements are not
necessarily mutually exclusive to the activity under which the specification or
requirement is listed. Should any specification be applicable to any other
activity, listed or otherwise, the intent remains.
Table 3-2 summarises the activities, sub-categories, page and specification

references for the activity and impact management measures specified in this
section.
46
TABLE 3-2: REGISTER OF ACTIVITY CATEGORY AND SUB-CATEGORIES INCLUDED IN

THE ACTIVITY MANAGEMENT PROGRAMME (TO BE UDPATED AFTER SASOL FINAL
COMMENTS RECEIVED)
Specification
Activity category Activity sub-categories
reference
Administration & general issues Release of contracts 3.3.1
Procurement of goods and services 3.3.2 -3 .3.3
Compliance to legislation 3.3.4
Legal register 3.3.5
Environmental management system 3.3.6
Personnel management 3.3.7
Disturbance of archaeological or cultural 3.3.8
sites
Collecting / harvesting plant material 3.3.9
Hunting / harassing / poaching / keeping 3.3.10
wild animals
House-keeping 3.3.11
HIV/Aids, sex worker management 3.3.12
Disease 3.3.13
Access to the CPF, well-sites & 3.3.14
flowlines 3.3.15
Site lighting 3.3.16
Advertising and / or signage on roads 3.3.17
Bush fire prevention and management
Employment & labour Employment 3.4.1
management Employee supervision and training 3.4.2
Community, stakeholder & General 3.5.1
government liaison Respect for local people 3.5.2
Compliments and complaints register 3.5.3
Grievance procedure 3.5.4
Communication with stakeholders 3.5.5-3.5.7
Management of expectations 3.5.8 – 3.5.9
Communication / liaison 3..5.10 – 3.5.12
Access to private / government property 3.5.13
Population influx 3.5.14
Reporting 3.5.15 – 3.5.16
Government liaison 3.5.17
Corporate Social Investment 3.5.18 – 3.5.19
Accommodation & office Electricity 3.6.1
management Food Usage 3.6.2
Air conditioner usage 3.6.3
Mosquito / vector control Mosquito control 3.7.1
Pesticide and larvicide management 3.7.2
Permissible dispersants 3.7.3
Personnel management 3.7.4
Storage of pesticides 3.7.5
Medical services & facilities Health management – HIV 3.8.1
Medical waste storage 3.8.2
Medical waste disposal 3.8.3
Water & effluent management Water provision 3.9.1 – 3.9.3
Storm water management 3.9.4
Open drain system 3.9.5
Final effluent disposal 3.9.6
Effluent management (kitchen & other 3.9.7
wash water)
Effluent management (laundry water) 3.9.8
Sewage management 3.9.9
Shower water 3.9.10
Waste management Overall waste management plan 3.10.1
Legal compliance 3.10.2
Waste storage and transport – general 3.10.3 – 3.10.7
Waste disposal 3.10.8
47
Specification
reference
On-site disposal 3.10.9
Disposal off-site 3.10.10 – 3.10.13
Landfill management 3.10.14
Incinerator operation 3.10.15
Composting of organic waste 3.10.16
Fluorescent tubes 3.10.17
Business services Environmental expenditure 3.11.1
Production Bush fire prevention 3.12.1
Well-site management 3.12.2
Access to well-sites 3.12.3
Opening and rehabilitation of borrow pits 3.12.4
and other sites
Use of compressors and generators at 3.12.5
well-sites
Radioactivity from wells 3.12.6
Maintenance / equipment General 3.13.1
replacement Transformers 3.13.2
Gas turbine / generators 3.13.3
Gas turbine / generators / other noise 3.13.4
generating equipment
Oil pipeline maintenance 3.13.5 – 3.13.7
Excavations 3.13.8
Refuelling and maintenance 3.13.9
Vehicle and equipment maintenance 3.13.10 – 11
Vehicle washing 3.13.12
Well-site work over 3.13.13
Support services General 3.14.1
Expertise, equipment and procedures to 3.14.2
deal with spills
Loss of livelihoods in event of spill 3.14.3 – 3.14.5
New infrastructure within the CPF 3.14.6
Establishment of temporary work areas 3.14.7
outside of the CPF
Storage and handling of hazardous 3.14.8
materials on site
MSDS usage and availability on site 3.14.9
Storage facilities for hydrocarbon 3.14.10
products and chemicals
Health and environmental risks of 3.14.11
hazardous substances
Purchasing 3.14.12
Commissioning and initial start- Internal cleaning of piping 3.15.1
up; start-up following shutdowns Pigging 3.15.2
Water flushing of lines / pump testing 3.15.3
using water
Initial condensate 3.15.4
Initial loading of machinery and 3.15.5
equipment with fuel, lubricants,
chemicals
Normal start-up Flushing 3.16.1
Flushing POC drains with firewater 3.16.2
Operation (External) cleaning / painting of piping 3.17.1
and equipment
Chemical disposal from laboratory / 3.17.2
other 3.17.3
Condensate loading 3.17.4
Condensate loading procedure 3.17.5
Condensate transport 3.17.6
Transport approvals 3.17.7
Auditing of transporters 3.17.8
Off-site spill management 3.17.9
TEG storage and handling 3.17.10
48
Specification
reference
Washing down of paved areas with
utility water / bund cleaning 3.17.11
Emergency situations 3.17.12
Effluent management 3.17.13
Air emissions management 3.17.14
Air quality 3.17.15
Re-injection of produced water 3.17.16
General CPF operations 3.17.17
Sand / silt production from wells 3.17.18
Storage of produced water
Normal shutdown Disposal of liquid hydrocarbon from the 3.18.1
closed drain sump
Flushing of hydrocarbon piping and 3.18.2
equipment with utility water
Emergency shutdown Effluent management 3.19.1
Incinerator management 3.19.2
Land use controls General 3.20.1
PPZ boundary 3.20.2
Corporate Social Investment General 3.21.1
CSI policy 3.21.2
Community interface forums 3.21.3
CSI awareness 3.21.4
CSI local management 3.21.5
Allocation of petroleum tax law funds 3.21.6
Decommissioning General 3.22.1
For each activity identified, the following items are specified in the management
plan:
Ref.: A reference number for the specified management requirement /

specification.
Management requirements: Detail on the management requirements /

specifications required.
Responsible party: The person that will assume overall responsibility for
ensuring that the requirement / specification is met.
Scheduling: The date by which the requirement shall be achieved. Should the
requirement be applicable throughout the life of Operations or a period thereof,
the date will be indicated as ‘ongoing’.
Compliance indicator(s): Indicates means to determine if the requirement has

been met. Additional monitoring requirements are specified under Section 4.
Note that the number of incidents, audit findings etc. shall also be used as
indicators of performance.
49
3.3. ADMINISTRATION AND GENERAL ISSUES
Completion date or
Ref. Activity Requirements / specifications Responsibility Compliance indicator(s)
Scheduling
3.3.1 Release of Relevant SHE requirements extracted from the EMP will be Supply Chain(SC) At the time of Inclusion of EMP as part of
contracts included as part of tender documentation and form part of Manager release of requests relevant tenders (RFT) and
contracts when the scope of the work to be conducted or for quotation. contracts.
service to be provided can impact on the environmental At the time of
performance of the CPF complex. contract preparation.
3.3.2 Procurement of In terms of Decree 24 of 2004 on Petroleum Operations SC Manager Ongoing Local suppliers in service
goods and Regulations SPT has developed its own Local Content provider list
services Policy, focused on stimulating economic growth throughout Register and percentage of
the value chain and creating opportunities for those who do procurement in
not work at the CPF plant. It In line with Sasol’s local communities, the District
content policy, which covers a range of categories, from and Province, and
highly specialised to the commoditised. Local content is an nationally
integral part of tender evaluation criteria in major projects.
Thus goods and services should be procured whenever
possible and whenever these meet established
requirements in communities and the District and Province
3.3.3 Procurement of SPT shall build capacity in the local area for provision of SC Manager Ongoing Goods and services
goods and goods and simple services to the CPF complex. CSI Manager purchased locally as a
services result of Sasol capacity
building
3.3.4 Compliance to In all cases, the requirements of Mozambican legislation Operations Ongoing Legal update system
legislation will be met. Manager Legal register
SHE Manager Audit findings
ESO Absence of legal warnings /
prosecutions / fines.
3.3.5 Legal Register Develop, annually review and where necessary update a Operations Register updated on Legal register document.
legal register identifying all environmental legislation Manager a regular basis. Permit / licence register.
relevant to the operation. This register shall describe the SHE Manager
relevance of applicable legislation to Operations as well as ESO
any permits / licenses that may be required.
A register of all permits and licences (and associated
conditions) issued to Sasol for Operations shall be
50
Completion date or
Scheduling
maintained, with copies of the permits held in Document
Control. The register should include date of issue and date
of expiry.
3.3.6 Environmental Implement an environmental management system for Operations Ongoing Maintain ISO14001:2004
management Operations that is compliant with the requirements of ISO Manager certification
system 14001- 2004. SHE Manager
Conduct regular surveillance audits to ensure compliance ESO
with EMS requirements.
3.3.7 Personnel An appropriate environmental and social awareness ESO Ongoing Environmental and social
management programme shall be implemented on site so as to ensure Safety Practitioner awareness programme
that all employees and contractors are aware of their SPT induction programme
environmental and social responsibilities. includes environmental and
The site induction programme shall address the key social requirements
environmental and social aspects associated with SPT’s
operations.
3.3.8 Disturbance of Should any archaeological or cultural sites be discovered ESO Ongoing As per requirement.
archaeological this shall be reported to the ESO and CLO who shall Chance Find Procedure
or cultural sites determine a course of action based on consultation with developed and available
(e.g. graves) / local, provincial and national government, as necessary. Inclusion in training /
collecting Records shall be kept to document the process followed induction programme(s).
specimens or and measures taken. A “Chance Find Procedure” shall be
Records on process
artefacts developed as a management tool for cultural heritage
followed
impacts, in accordance with the guidelines set out in IFC
Performance Standard 8.
3.3.9 Collecting or All employees shall be prohibited from collecting or Safety Practitioner Ongoing Absence of complaints.
harvesting harvesting fruits, vegetables, grains and any other plant ESO
fruits, material outside of the battery limits of the CPF complex.
vegetables,
grains and any
other plant
material
3.3.10 Hunting / No employee or contractor may hunt, harass, poach or Safety Practitioner Ongoing Absence of complaints.
harassing / keep wild animals. ESO
poaching /
keeping wild
animals
3.3.11 House-keeping At all times the CPF complex, flowlines and well pads will Production Ongoing Absence of litter on site.
51
Completion date or
Scheduling
be maintained in tidy order. No littering will be permitted. Manager Containers with lids
Where necessary, open containers shall be covered with ESO
lids or netting to prevent the occurrence of wind-blown litter.
3.3.12 HIV/Aids, sex The presence of sex-workers inside the CPF complex SHE Manager Ongoing Absence of sex workers on
worker boundary is prohibited. site.
management The presence of sex-workers outside of the CPF and Reduction in sex workers in
campsite must be actively discouraged: Communicate and communities from numbers
coordinate with District health personnel to align with and present during construction
supplement existing programs to prevent or reduce sexually Number and nature of
transmitted diseases. Implement a concerted program of communication and
information provision and awareness creation to prevent or awareness initiatives
reduce sexually transmitted diseases. Work with health Visual observations.
centres, churches, health workers and other respected
Number of CSI projects
community leaders to ensure awareness messages have
focusing on prevention or
credibility. Develop awareness materials in the local
treatment of sexually
language that can be displayed on notice boards and
transmitted diseases.
distributed in communities.
Number of condoms
Condoms must be distributed free of charge to employees,
distributed
contractors and visitors and should be readily available.
Annual survey amongst
men, women and church
leaders in terms of whether
condoms were used and if
not, the reasons
Number of people provided
with voluntary counselling
and testing
Number of
communication/awareness
initiatives in the
communities
Increase or decrease in the
percentage of people with
HIV/AIDs or other sexually
transmitted diseases in the
communities, and number
of people treated
52
Completion date or
Scheduling
number of people on the
antiretroviral program, and
how long they stay on the
program.
3.3.13 Diseases Continue with mitigation measures currently undertaken Doctor Ongoing Health indicators to monitor
selected and agreed with
In coordination with District authorities and with the District Government
specialist advice of a health impact assessment Monitoring of health
professional and following international guidelines, indicators
develop a set of defendable indicators and a monitoring Improvement in health
program for monitoring health in affected communities indicators annually
3.3.14 Access to the Access to areas outside of the CPF complex shall only be ESO Ongoing Absence of new track
CPF, well-sites via existing access routes. The requirements for approval development.
and flowlines and development of new access routes shall follow Ecological monitoring
procedures agreed with the Mozambican regulatory results.
authorities and specifically ANE. Authorisation by
Vehicles may not be used off-road. Mozambican authorities
Access to well-sites shall be restricted to Sasol employees
and the employees of contractors working at the well-sites.
Access over flowlines and along flowline access roads shall
not be restricted.
3.3.15 Site lighting No lighting at the plant shall be directed away from the site Camp Manager Ongoing Absence of complaints
so as to cause a disturbance to surrounding inhabitants. from surrounding
communities.
Periodic inspections of
lighting effects
3.3.16 Advertising and SPT shall ensure that road-side advertising is well SHE Manager Prior to erecting any Government approvals for
/ or signage on considered so as to cause minimal visual pollution as well Communication road-side advertising roadside advertising.
roads as negligible driver distraction. Manager
SPT shall ensure that it has obtained all relevant
Government approvals for the erection of signage along
public access routes.
3.3.17 Bush fire A procedure for the prevention and control of bush fires SHE Manager Ongoing Implementation of a fire
prevention and shall be prepared. The procedure shall include, but not be prevention and fire
53
Completion date or
Scheduling
management limited to, the following: emergency management
 Sources of fire risk; procedure.
 Measures to comply with any requirements of local
authority fire departments;
 Measures to minimise the risk of accidental bush fires
caused by any activity related to the works; and
 Measures to control an accidental bush fire.
3.4. EMPLOYMENT AND LABOUR MANAGEMENT
Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s)

3.4.1 Employment Employment shall be undertaken and managed HR Manager Ongoing Statistics reflecting percentage
according to Mozambican labour law and SPT’s Mozambican employees.
approved labour agreement with the Mozambican Training records.
Government and a specific Project Labour CSI Projects supporting
Agreement with the Union, which support localisation education and training of
of labour. Mozambicans to take up
In particular, employment and skills development of employment in the Oil and Gas
Mozambican employees is an important success sector.
factor and therefore local labour shall be utilised as
far as possible and within the constraints of
Mozambican law. This shall be complimented with
applicable skills training.
3.4.2 Employee Sasol shall ensure proper supervision / management Camp Manager Ongoing Inspection findings.
supervision of employees, including after-hours where Audit findings.
and training employees are resident on site.
Employees shall all receive adequate training based
on the activities they undertake and the associated
SH&E risks. Training shall also comply with any
Mozambican legal requirements.
54
3.5. COMMUNITY, STAKEHOLDER AND GOVERNMENT LIAISON
A key management principle during the operational phase of the CPF shall be that of respect of the rights of the surrounding
community and the land and resources that belong to them.
The Operations area is characterised by the following socio-economic conditions, which shall at all times be taken into consideration:
 Subsistence living;
 Extreme poverty;
 Strong dependence on local natural resources;
 Limited access to health and education facilities, access roads (basic services); and
 Very limited employment opportunities.

3.5.1 General Access over land, the integrity of fences Operations Manager Ongoing Number of complaints
(boundaries), control of bush fires, littering, dust ESO registered
control, noise abatement, harassment of Number of complaints
domestic and wild animals, sedimentation and resolved
contamination of ground and surface water, Number of grievances
damage to the landscape and vegetation and registered
all such environmental matters, shall be
Number of grievances
controlled in the best interests of SPT, the
resolved
environment and the communities in the project
zone of influence. Number of compliments
received
Monitoring records
Audit findings
3.5.2 Respect for There shall be strict induction training for Public Relations Officer Ongoing in standard Included in standard induction
local people project workers and information dissemination and staff, Temane induction training training for staff, visitors and
to communities, so that both groups are clear At least annually for ad hoc contractors to CPF
as to what to expect of the other. communities Evidence of annual
communication initiative in
each community
55

3.5.3 Compliments A Compliments and Complaints Register shall Public Relations Officer Number of complaints
and Complaints be developed and widely communicated to and staff, Temane registered
Register (paper communities as an instrument to air their views. Number of complaints
copies in The Register shall be kept in the community by resolved
communities, the village leader or appointed designate, Number of compliments
electronic should be inspected monthly by a Sasol received
database at Community Liaison Officer, and if complaints
Nature of complaints analysed
CPF) have been registered, follow up and close out
and corrective actions taken
on these. All issues raised by external parties
for trends in complaints
shall be logged in these registers and should
include, but not be limited to: Annual independent
community and stakeholder
 The name of the communicator;
perceptions survey
 Contact details of the communicator;
 Nature of the communication; and
Any action taken or that needs to be taken to
address the issue raised.
3.5.4 Grievance A formal Grievance Procedure shall be Public Relations Officer Ongoing Number of grievances
Procedure developed as required by IFC Performance and staff, Temane registered
Standard 1, and wide communication to Number of grievances
communities of the existence of this instrument resolved
to register grievances when they believe they Nature of grievances analysed
have suffered damages that require and corrective actions taken
compensation as a result of Sasol’s activities. for trends in grievances
3.5.5 Communication Development of an integrated public affairs, Public Relations Officer During construction of Plan developed and annually
with communication and CSI program for the CPF and staff, Temane the PSA and LPG evaluated and updated
stakeholders zone of influence Liquids plant Annual increase in positive
Success evaluated perceptions by communities
and updated monthly and District/provincial
Annual independent stakeholders
community and Number of compliments and
district/provincial complaints registered
stakeholder Number of complaints resolved
perception survey
3.5.6 Communication All communication and awareness programs to Public Relations Officer Ongoing Number of complaints
with communities shall be done in a good mix of and staff, Temane registered
stakeholders written, visual and verbal methodologies. In all Number of complaints
cases, not only Sasol and its community liaison resolved
56

officers should provide this communication, but Number of grievances
the support of respected people in the registered
communities (church leaders, school principals Number of grievances
and educators, health workers, heads of resolved
women, youth and other organisations) shall be
Number of compliments
enlisted to give more credibility to the
received
messages and to carry the messages further
and more consistently over time. This will Annual independent
require train the trainer sessions for the leaders. community and stakeholder
perceptions survey
3.5.7 Communication Sasol is to erect notice boards with village Public Relations Officer During construction of Notice boards constructed
with leader permission in every village and and staff, Temane the PSA and LPG Notice boards updated with
stakeholders constantly update with new information, job Liquids plant new information monthly
advertisements etc. Updated monthly All job advertisements posted
in notice boards
3.5.8 Management of Community leaders and residents may have Public Relations Officer Ongoing Number of complaints
expectations expectations that Sasol will play a supporting and staff, Temane Public registered
and developmental role within the area and that Relations Officer and Number of complaints
Operations will have other positive economic staff, Temane resolved
benefits. In order to maintain realistic Number of grievances
expectations, SPT shall maintain close registered
communication with local communities and
government with the objective of clarifying
resolved
roles, responsibilities and involvement
throughout the Operations phase and ensuring Number of compliments
that Sasol’s role is widely understood. The received
Corporate Social Investment (CSI) programme Annual independent
shall play a critical role in managing community and stakeholder
expectations. perceptions survey
3.5.9 Management of Two Community Development Officers shall be Public Relations Officer Ongoing Opportunities for CSI projects
expectations employed to constantly support the Sasol CSI and staff, Temane Public including local procurement
programme, identification of opportunities Relations Officer and identified.
including procurement, obtaining community staff, Temane Community inputs into
inputs into plans, and ongoing information forthcoming CSI plans
provision. obtained
Number of communication
initiatives inform communities
57

about current CSI projects
3.5.10 Communication Sasol shall employ a Public Relations Officer Public Relations Officer Ongoing Number of complaints
/ liaison (PRO) and two Community Liaison Officers and staff, Temane registered
(CLOs) who are actively involved in the Number of complaints
Operations area. These persons shall liaise resolved
with the local communities and District Number of compliments
authorities regarding Sasol’s activities. In this received
task, the PRO shall ensure the involvement of
the ESO on any environmental matters.
registered
Similarly the ESO will ensure that the PRO is
informed of and involved with any Number of grievances
environmental issues that might relate to the resolved
community, government etc. Annual independent
perceptions survey
3.5.11 Communication The ESO, PRO and or CLOs shall hold regular Public Relations Officer Ongoing Number of complaints
/ liaison meetings with surrounding community leaders and staff registered
often with communities themselves in order to ESO Number of complaints
inform them of any activity that may affect them resolved
in any way. Records of all meetings shall be Number of grievances
kept. registered
resolved
received
Annual independent
perceptions survey
Records of meetings
3.5.12 Communication Build the capacity and status of Community Public Relations Officer
/ liaison Interface Forums to support ongoing and staff
communication in communities and to facilitate
contributions to the Sasol CSI Programme.
Where such Forums no longer exist, re-
establish them in a participatory process with
communities and build their capacity in respect
of their mandate as Interface Forums.
58

3.5.13 Access to The property and rights of all persons shall be Operations Manager Ongoing Absence of complaints or
private / respected at all times. formal grievances
government Sasol personnel and its contractors shall not Number of compliments
property gain access to land outside of its approved
areas of operation without prior consultation
with community leaders and, where considered
necessary by the PRO, the affected families
themselves. No activities that cause damage
may be undertaken without prior approval by
the regulatory authority, and prior
communication with an agreement on
appropriate compensation by the affected
person/s.
3.5.14 Population Ongoing communication, including national Public Relations Officer Ongoing Number of communication
influx coverage from time to time and information and staff, Temane initiatives nationally, in the
meetings in all affected villages, explaining the Province and District and in
negative impacts of population influx, and the communities, at least
harnessing their support to reduce influx of annually
work and opportunity seekers, communicating Survey amongst village
the following Sasol policies: leaders on increase in number
- All ad hoc unskilled employment will be, of new arrivals
without exception, from local villages, Google or satellite imagery
verified by community leaders survey of increase in size of
- No hiring on site for job seekers and no towns
procurement at the gate Reduction in percentage
- Maximising local content in procurement i.e increase of towns
from local people and towns.
Communication and coordination with local
leaders and District Government in terms of
curbing influx, and obtaining their support and
suggestions in this regard.
3.5.15 Reporting Sasol shall report on environmental and social SHE Manager Bi-annually Content of Bi-annual report
performance for the Operation in keeping with
the environmental and social reporting schedule
detailed in the EMP approval conditions letter.
3.5.16 Reporting Sasol shall advise key Government SHE Manager Periodically Proof of notification in
stakeholders and community leaders about the stakeholder meeting records
availability of key environmental and social and other correspondence
59

performance reports and shall assist Number of communication
stakeholders and in particular communities to initiatives and methods to
fully understand these reports. communicate the contents
Interim evaluation tool to
assess degree of
comprehension of information
3.5.17 Government SPT shall actively seek to participate with the Country Manager Ongoing Minutes of meetings
liaison Government on task teams and forums that Government Liaison Number of complaints
relate to the operation of the CPF and Manager, Maputo registered
associated activities and their influence on the PRO, Temane Number of complaints
communities and the environment. This should resolved
ESO
include consideration of forums that address
the following issues in relation to Sasol’s
received
activities in Mozambique:
Annual independent
 Resource use and exploitation.
 Management of exclusion zones. perceptions
 Land use planning and zoning.
 Community needs, comments, issues and
concerns
3.5.18 Corporate Commit to the “Corporate Social Responsibility Country Manager
Social Policy for the Mineral Resources Extractive
Investment Industry” (GoM, 2014) and any legal
(CSI) requirements that may be promulgated in this
regard in the future.
3.5.19 Corporate Develop a CSI program in a transparent Country Manager
Social process through consultation with local
Investment communities, District government, NGOs and
(CSI) other stakeholders in which criteria are
developed for projects and beneficiaries, and
priorities are agreed upon in an open process.
Establish, maintain, fund and support through a
constructive and professional process a CSI
Advisory Committee on which is represented
representatives of communities it its zone of
influence, government, NGOs and other
stakeholders to:
 Build stakeholder capacity and
60

understanding in CSI allocation, spending
and management and in the process build
trusting relationships and partnerships
with stakeholders;
 Support the company in developing a CSI
strategy and plan for Sasol in
Mozambique;
 Reach agreement on sustainability
capitals to pursue for selected periods of
time, and on transparent criteria for
allocation of funding;
 Participate in and advise the company on
annual CSI spending; and
 Support the company in annual review
against agreed criteria of the success or
otherwise of measures implemented.
Publicise the agreed CSI plan and obtain
feedback.
Corporate Put in place failsafe measures to ensure annual Country Manager
Social CSI funding commitments are spent; and
Investment
(CSI)
3.6. ACCOMMODATION AND OFFICE MANAGEMENT

3.6.1 Electricity Accommodation and offices shall be electrified. Camp Manager Ongoing Electrification of offices and
Fires cooking or heating are prohibited except in accommodation
the case of barbeques).
3.6.2 Food usage Left-over food shall be minimised. Camp Manager Ongoing Waste disposal records.
No left-over food shall be provided on an ad hoc Catering contractor Kitchen waste disposal
basis to local communities. ESO records
The alternatives of minimising and/or using left- Composting records
over food shall be investigated as an option.
61

3.6.3 Air Employees shall be encouraged and educated to Camp Manager Ongoing Awareness programmes
conditioner use energy efficiently. ESO
usage
3.7. MOSQUITO / VECTOR CONTROL

3.7.1 Mosquito Implement and maintain a programme to minimise Doctor Ongoing Vector control programme
control malarial incidence among employees, contractors CLOs implemented and maintained
and visitors. .Prevent ponding at all Sasol activities Communication with village
in the rainy season. leaders
Work with village leaders to prevent the Tracking of and reduction in
establishment of informal settlements with bad incidence of malaria among
drainage and lack of sanitation. workers and in communities
3.7.2 Pesticide & The disposal of waste pesticide and pesticide Doctor Ongoing Waste disposal records
larvicide containers will be as per the waste disposal Procedure for medical waste
management requirements of Section 3.10. A procedure for disposal
medical waste storage and disposal shall be
developed in accordance with these requirements
3.7.3 Permissible Diesel shall not be used as a dispersant during Doctor Ongoing Procedure(s) for fogging
dispersants ‘fogging’ Operations.
3.7.4 Personnel Sasol shall ensure that the training of personnel who Doctor Ongoing Records of training
management undertake spraying complies with relevant Government authorisations
Mozambican legislation and authorisations Records of medical check ups
If an external service provider is used the relevant
permissions from the authorities shall be obtained
All personnel responsible for spraying pesticides
shall wear appropriate PPE and receive annual
medical check-ups.
3.7.5 Storage of All pesticides shall be appropriately stored according Production Manager Ongoing Inspections
pesticides to regulatory requirements based on their MSDS,
including temperature control and containment.
62
3.8. MEDICAL SERVICES AND FACILITIES

3.8.1 Health Prepare and implement a programme and Doctor Ongoing Implementation of procedures
management - procedure(s) to minimise the spread of HIV infection. and programmes.
HIV A typical programme would include, among other Increase or decrease in the
things, the implementation of the following: percentage of people with
 See also for sex workers and reduction in HIV/AIDs or other sexually
population influx transmitted diseases in the
 An HIV / Aids training course and on-going communities, and number of
education on transmission of HIV / Aids and people treated
STDs to employees, through workshops, Increase or decrease in the
posters and informal information session, as number of people on the
well as to communities; antiretroviral program, and
 Encouragement of employees and how long they stay on the
community members to determine their HIV program
status; Number of CSI projects
 Supply of condoms to employees focusing on prevention or
 Distribute condoms in the communities, to treatment of sexually
transmitted diseases.
both men and women and to church
Number of people provided
leaders, and explain their use where
with voluntary counselling and
necessary testing
 Continue to promote voluntary counselling Number of
and testing. communication/awareness
 Continue to support treatment and ongoing initiatives in the communities
antiretroviral program Increase or decrease in the
percentage of people with
 Other CSI projects focused on reduction in HIV/AIDs or other sexually
and treatment of HIV/AIDs. transmitted diseases in the
communities, and number of
people treated
number of people on the
antiretroviral program, and
how long they stay on the
program.
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3.8.2 Medical waste Medical waste shall be stored, separately from other Doctor Ongoing Inspection records.
storage waste, prior to incineration as per the requirements Audit findings.
laid down by the World Health Organisation and any
Mozambican regulations on the management of
biomedical waste.
3.8.3 Medical waste Medical waste shall be disposed of by on-site Doctor Ongoing Waste disposal records.
disposal incineration. Records shall be kept of all medical
waste disposed as per the requirements specified in
Section 3.10.
3.9. WATER AND EFFLUENT MANAGEMENT
Section 1.10.1 provides more detail on water and effluent management on site, including the MBR, the Storm water System and the
Industrial Treatment Plants, including potential volumes of inputs and outputs, all based on the design criteria for the CPF complex.
(See Sections 1.10 and 1.11 for details of the effluent management system).
In summary, domestic effluent from bathrooms, the laundry, kitchen, administration and residences is sent to the MBR. After treatment
and once compliant with specifications in Table 4-1, Section 4.1 (these are set by SPT’s agreement with the World Bank and
Mozambican Regulations (see Table 4-1, Section 4.1 Monitoring requirements) , it is discharged to the final effluent pond (the same
discharge point as the Industrial Treatment Plant). If it is not within specification it will be re-treated. Domestic effluent from the PSA
Liquids and LPG Plant may be routed back to the MBR sewage works or may be treated in a new (small) package treatment works.
Kitchens and all laundry facilities will remain at the CPF.
The storm water system consists of two components: (a) uncontaminated storm water is routed off-site, and (b) The first flush (first
ten minutes of flow from the furthest point on the plant) of potentially contaminated storm water is routed to the Potentially Oil
Contaminated (POC) drainage system for treatment through the Industrial Treatment Plant. Further storm water is assumed to be
clean - it overflows the weir and is routed off-site.
64
The Industrial Treatment Plants remove hydrocarbons routed from the POC system. The treated water is discharged to the
stabilisation pond where it is tested to ensure that it meets the specifications in Table 4-1, Section 4.1 (these are set by SPT’s
agreement with the World Bank and Mozambican Regulations. If it meets specification (see Table 4-1, Section 4.1 Monitoring
requirements) it will be used for irrigation on site. If it is not within specification it will be re-treated. Whether the final effluent streams
from the CPF and the PSA Liquids and LPG Plant will be combined or released separately is still to be decided.
Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator

3.9.1 Water Water for Operations shall be obtained from groundwater ESO Ongoing Groundwater monitoring
provision wells. (Operations shall have no detrimental impact on programme (volumes; water
water volumes (groundwater) available to existing users levels).
in the area. Communication with
Water shall not be abstracted from surface water community / complaints
resources without appropriate consultation with recorded in Communications
surrounding communities. Register.
The relevant permits for the abstraction of groundwater Government approvals.
and surface water shall be obtained from the regulatory
authority prior to their use.
3.9.2 Water No seepage fields, ‘soakaways’ or evaporation ponds SHE Manager Ongoing As per requirement.
provision shall be developed without the approval of the SHE ESO
Manager and Environmental Site Officer and based on a
specialist evaluation commensurate with the level of risk
involved.
3.9.3 Water All final effluent discharged from the final effluent sumps Production Ongoing Monitoring records.
provision shall meet the o-EMP specifications set out in Table 2, Manager
Section 4.1. ESO
No effluent or potentially contaminated storm water may
be released from site other than from the final effluent
sump, with the exception of the storm water referred to in
Section1.10.1.2.
Final effluent that does not meet the specification in Table
2 may require re-treatment to ensure that the
specifications are met.
3.9.4 Storm water Rain water falling off-site shall be prevented from entering Production Ongoing Storm water management
management the site. Measures to prevent storm water ingress onto Manager system design as per
site shall typically include storm water diversions, ESO requirements.
65

drainage channels etc. Maintenance of the storm
On-site, clean and contaminated water shall be kept water management system
separate. Clean storm water may be released into the
surrounding environment without treatment. Potentially
contaminated storm water shall be collected for treatment
in the industrial effluent treatment plant in accordance
with the principles set out in Section1.10.1.4.
3.9.5 Open drain Rainwater collected within bunded areas (e.g.: diesel Production Ongoing Monitoring records.
system tanks, stores) may be released to clean (i.e. open) storm Manager Procedure for release of liquid
water drains if it meets the o-EMP minimum discharge ESO from bunded areas.
standards (see Table 4-1, Section 4). If not, the contents
shall be redirected via the closed drain system to the
POC, where it shall either be treated or routed to the
incinerator.
A procedure shall be developed describing the strategy
for release of any liquid within the bunded area. This
should include requirements concerning appropriate
disposal and where required, sampling requirements prior
to release.
3.9.6 Final effluent The final effluent may be disposed of by irrigation onsite if Production Ongoing Monitoring records
disposal the water quality meets the specifications required in Manager Procedure of Final Effluent
Table 4-1 of the o-EMP. ESO Irrigation
3.9.7 Effluent All kitchen waste-water shall be discharged through Catering Ongoing Grease / oil traps installed.
management grease / oil trap(s) into the sewage treatment plant. contractor Records of oil and grease
(kitchen and Cleaning and maintenance shall be in accordance with an ESO disposal.
other wash appropriate maintenance schedule. Inspection reports.
water) Collected grease and oil shall be disposed of via the Records of products used and
incinerator. alternatives considered.
Efforts shall be made to avoid odours from the grease Purchasing procedure
traps. reflecting approach to product
Care should be taken to use efficient and environmentally selection.
friendly cleaning materials.
3.9.8 Effluent Laundry water shall only be discharged to the sewage Cleaning Ongoing Drainage design to sewage
management treatment plant. contractor effluent treatment plant.
(laundry Kitchen and laundry staff shall be trained to avoid the ESO Records of products used and
water) excessive use of detergents. Where practical, alternatives considered.
environmentally friendly cleaning materials shall be used Purchasing procedure
66

in preference to standard materials. reflecting approach to product
selection.
3.9.9 Sewage Toilet facilities shall be properly maintained to minimize Camp Manager Ongoing Inspection records.
management the risk of leakage of un- or partially treated sewage. Production Audit findings.
Manager Monitoring records.
ESO
3.9.10 Shower Shower water shall only be discharged to the sewage Camp Manager Ongoing Effluent design
water treatment facility. ESO Education programme
SPT shall educate employees and contractors to
minimise water use during showering.
3.10. WASTE MANAGEMENT
Waste management at the CPF complex shall comply with the requirements of the Mozambique Waste Management Regulations
(Decree 13/2006) and the regulations concerning the management of Bio-medical Waste (Decree 8/2003).
As per the Mozambican general waste regulations (Decree 13/2006), non-hazardous waste is defined as waste with no risk
characteristics, including but not exclusive to paper or paperboard, plastic, glass, metal, rubbish, metal scrap, and organic matter.
Hazardous waste is defined as waste bearing risk characteristics for being flammable, explosive, corrosive, toxic, infectious or
radioactive, or for showing any other characteristic that constitutes hazard for the life and health of humans and other living creatures
and for environmental quality.
The approach to waste management is to minimise waste production, re-use and recycle where possible and disposal as the final
option. The primary means of disposal will be incineration. For information about how the incinerator operates see section 1.10.5 of
this document).
Ash and lime from the incinerator will be placed in a specifically designed high hazard (H:H) landfill site.
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3.10.1 Overall waste SPT shall define an overall waste management SHE Manager Ongoing (review Documented waste
management plan for Operations that defines, but shall not be annually) management plan.
plan restricted to, the following: Government approval
 Waste minimisation strategy;
 Waste collection strategy;
 Waste separation strategy;
 Waste transport strategy;
 Waste disposal strategy.
 Waste recycling strategy.
This plan shall be submitted to the relevant
authorities for approval and renewed as per the
regulatory requirements in Decree 13/2006 and
Decree 8/2003, as amended.
3.10.2 Legal A procedure shall be developed which provides SHE Manager Review annually Documented procedure
Compliance details of all aspects of waste management and
demonstrates compliance with Mozambique
waste management legislation (Decree 8/2003
and Decree 13/2006).
3.10.3 Waste storage Where markets exist (or could be created) for the ESO Ongoing Disposal records.
and transport re-use or recycling of waste materials these
– general materials shall be separated from the waste
stream at their point of generation and stored
separately for collection by the recycling agent.
No material may be provided to communities
where the material could present a health or
safety risk. Old chemical drums may only be
released for recycling if crushed prior to release
to prevent the containers being used as water
vessels.
3.10.4 Waste storage A clear distinction shall be made between ESO Ongoing Documented and implemented
and transport hazardous and non-hazardous waste streams, waste management strategy.
– general with separation occurring at source. Wastes shall Provision of separate
be placed in separate containers and transported containers for non-hazardous
to the disposal facilities separately. and hazardous waste.
3.10.5 Waste storage In all cases, waste shall be contained. Storage ESO Ongoing As per requirement.
and transport and disposal areas shall be contained / controlled
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– general to prevent scavenging by persons and / or
animals. Wind-blown litter shall be prevented.
3.10.6 Waste storage Waste containers shall bear labels that identify ESO Ongoing As per requirements.
and transport the contents. Where applicable this labelling shall
– general meet the Mozambique legal requirements for the
labelling of hazardous substances. Containers
shall be lined or constructed of materials that are
compatible with the wastes to be stored.
Containers shall be in good condition, free from
corrosion, leaks or ruptures.
3.10.7 Waste storage Waste containers shall be stored above ground ESO Ongoing As per requirement.
and transport on an impermeable surface (where the risk of
– general leaks and resultant contamination is such that
this is required) and under cover or covered by
lids.
3.10.8 Waste All combustible waste that is not recycled shall be ESO Ongoing Documented and implemented
disposal disposed of by incineration in the on-site Production Manager waste management strategy.
incinerator, except in cases where the Waste disposal records.
incineration of any material may result in the
possibility of safety or health risks to operators,
the public or environmental risk in general.
3.10.9 On-site In summary, waste shall be handled as follows: ESO Ongoing Documented and implemented
Disposal  All combustible waste that is not scheduled waste management strategy.
for recycling and is not excluded from Waste disposal records.
incineration for other reasons (refer to Audit records.
Section 3.10.15) shall be disposed of by Certificates of safe disposal for
incineration at the on-site incinerator. off-site disposal
 In situations when the incinerator is shut
down for maintenance all waste shall be
appropriately stored until the incinerator is
operational.
 Ash and spent lime from the incinerator shall
be disposed of in the on-site landfill.
 Medical waste from site shall be incinerated.
 Sewage sludge from site shall be incinerated.
 Hydrocarbon spills shall be immediately
cleaned up (including any contaminated soil)
69

and combustible materials shall be
incinerated. Non-combustible contaminated
material shall be disposed of to the landfill
subject to meeting the conditions specified in
the operations landfill operating manual (still
to be finalised). Should this not be possible,
off-site disposal or bio-remediation may be
required.
 Waste that is not combustible shall be
recycled, reused or if this is not possible,
disposed of in the on-site landfill subject to it
meeting the specification and pre-treatment
specified in the landfill operating manual.
 Waste that is not combustible and not
permissible in the on-site landfill shall be
disposed of off-site. Sasol shall ensure that
this disposal meets Sasol’s Responsible Care
Policy (i.e. a cradle to grave approach) and is
disposed of in a manner that does not cause
environmental contamination and meets the
requirements of Section 3.10.10 of this
document.
3.10.10 Disposal off- Where off-site disposal is the only remaining SHE Manager Ongoing As per requirements
site option (i.e. only for non-combustible hazardous ESO
waste not permissible in the on-site landfill or
wastes prohibited from incineration), then this
must be done in such a manner that it does not
create risks of non-compliance with legislation or
company policy (including Responsible Care).
This is particularly important in the context of the
environment in which the Operations exist, which
is characterised by lack of both waste disposal
facilities and the capacity for transportation of
waste (especially hazardous waste).
The following requirements will therefore apply to
the off-site disposal of waste:
 Transportation shall be undertaken by Sasol
or by a recognised contractor familiar with the
70

requirements for the transporting of
hazardous wastes, and shall meet the
regulatory requirements for such transport
including the Road Code.
 Sasol / the transportation contractor shall
have in place the means to respond
appropriately to spillages of waste anywhere
along the transport route within a time limit
acceptable to Sasol.
 The frequency of waste collection and the
interim measures for the storage of waste on
site must be appropriate, such that the
system as a whole does not pose an
unacceptable risk to either the environment or
health and safety.
 Storage of waste must be on a contained
area underlain by an impermeable
substratum, and covered to protect from
water ingress.
 Certificates of safe disposal must be provided
for all waste removed from site. Such
certificates may only be issued by a
recognised waste disposal operator.
 The site at which waste is disposed must
comply with the Sasol and its shareholders’
requirements. As such it must be audited on
at least an annual basis.
 No waste is to be disposed of off-site, except
with the written approval of the ESO who
shall ensure that all necessary approvals
have been obtained and all risks identified
and managed.
 Where possible, suppliers shall be
encouraged to take back unused products
and the containers of used products.
 An inventory of all waste stored on site for
future off-site disposal shall be maintained.
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3.10.11 Disposal off- SPT shall endeavour to ensure that suppliers of SC Manager Ongoing Certificates of safe disposal
site potentially hazardous substances (chemicals, from the suppliers
batteries, etc.) shall remove used products and
their containers when making their next deliveries
of these substances. Certificates of safe disposal
of the wastes must be provided by the supplier.
3.10.12 Disposal off- Records shall be kept of all waste disposed to the Production Manager Ongoing As per requirements
site incinerator, landfill and any off-site disposal if ESO
applicable (including sales to scrap dealers).
These records should reflect date of disposal
source of waste disposed, quantity of waste,
responsible party for the waste being disposed
and responsible party for the waste receiving
facility. These quantities shall be disclosed in the
6-monthly reporting to the Government.
3.10.13 Disposal off- No waste shall be disposed of on open fires. Operations Manager Ongoing As per requirements
site
3.10.14 Landfill The on-site landfill shall be managed as per the SHE Manager Ongoing. As per requirements
management operations landfill operating manual.
The site shall be fenced with access control. No
ad hoc dumping or scavenging shall be
permitted.
Provision shall be made to prevent the
accumulation of rainwater in the site during the
wet season.
3.10.15 Incinerator A procedure for the safe and efficient operation of Production Manager Ongoing Incinerator operations
operation the incinerator shall be developed. procedure
A list of combustible wastes that may not be
incinerated shall be included in the procedure.
Any such wastes shall be separately stockpiled
and shall either be disposed of in the site landfill
or removed from site in accordance with the
requirements of Section 3.10.10.
The incinerator shall only be operated by trained
personnel.
The incinerator shall be operated so as not to
result in the emission of black smoke from the
72

stack.
The secondary chamber and / or scrubbing stage
of the incinerator process shall not be bypassed
except in an emergency.
The waste holding area at the incinerator shall be
suitably sized so as to accommodate the volume
of waste to be stored prior to incineration and
shall meet the requirements of 3.10.5.
3.10.16 Composting of All compostable organic waste from the kitchen, Catering contractor Ongoing As per requirements.
organic waste except leftover food and garden waste shall be ESO Composting facilities.
disposed of by composting in a dedicated facility.
Alternatively, compostable waste shall be
incinerated when compostable is not viable.
3.10.17 Fluorescent Fluorescent tubes shall be crushed and stored at Maintenance Manager Ongoing As per requirements
tubes the hazardous storage facility(s) until sufficient ESO
volumes are obtained and are transported off-site Catering contractor
by an approved service provider.
3.11. BUSINESS SERVICES

3.11.1 Environmental SPT shall track and record all expenditure on SHE Manager Ongoing Expenditure records.
expenditure environmental or environmentally related items. Sustainable Development
Data reporting tables
3.12. PRODUCTION

3.12.1 Bush fire Specific measures must be taken to prevent the Production Manager Ongoing Records of employee
prevention occurrence and / or spread of bush fires caused by education.
activities at the CPF complex, well-sites and Fire control measures in place.
flowlines. Measures may include the appropriate
instruction of employees concerning fire risks and
the construction of firebreaks around perimeters as
73

required. Fire fighting flails, fire extinguishers and
protective clothing should be readily available for use
where required.
3.12.2 Well-site The Temane 3 and Temane 13 and Temane 19A Production Manager Ongoing Inspection records.
management production well sites are situated in very close
proximity to the wetland areas of the Govuro River
floodplain. Pande 20 is situated in close proximity to
a relic floodplain and associated watercourses.
Pande 17 is subject to annual flooding due to a
perched water table. This must be remembered
when working in and around the area, no pollutants
shall be stored in these areas. The risk of water
contamination must be avoided and no impediments
to natural water flow shall be permitted.
3.12.3 Access to Access to well-sites shall only be gained along Production Manager Ongoing Aerial photography / LandSat
well-sites existing routes. No new route development shall be imagery where available.
permitted without regulatory approvals. Monthly inspection by ESO.
Disturbance to local inhabitants as a result of access
to well sites shall be minimised and where possible
movement at night shall be avoided. Dust resulting
from access to well sites shall be monitored to
ensure that it has no detrimental effect on
landowners, occupants, employees or the general
public. The frequency and severity of complaints
combined with visual inspection periodically by the
ESO shall determine the need for formal dust
monitoring methods and dust mitigation. Measures
that can be utilised, where necessary, include dust
suppression using water sprays and surface binders.
Surface binders shall be ‘environmentally friendly’
products.
3.12.4 Opening and Where the excavation of material for fill for the SHE Manager Prior to Photographic records
rehabilitation maintenance of access routes and well sites is ESO decommissioning / Assessment and monitoring
of borrow pits necessary, the borrow pits shall be opened up in a closure of any well- reports
and other manner which minimises the environmental impact, site site Government permits
sites including:
 Site selection shall be undertaken with the ESO
where an existing borrow-pit is not used; and
74

 The area shall be demined and the vegetation
removed
 30cm topsoil shall be stripped and separated
from lower layers. The topsoil shall be
stockpiled on the periphery of the borrow pit
until required for the re-instatement and
rehabilitation of the borrow pit
 Works shall occur a minimum of 15m from the
topsoil to ensure that during re-instatement the
slopes of the borrow pit can be adequately re-
contoured. This will also allow for access
around the borrow pit by pedestrians and
vehicles if required.
 Relevant Government permits to extract borrow
material shall be obtained.
Borrow pits and other areas disturbed by Sasol
activities that are not needed shall be rehabilitated
according to the following principles:
 Compacted soils shall be tilled and broken to
encourage revegetation.
 The slopes shall be re-contoured to ensure
they are less than 25o to minimise erosion risk.
Stockpiled topsoil and subsoil shall be
reintroduced in the correct order.
 Fertilisation of the soils may be required as per
the recommendations of the soils specialist
study.
 Storm water runoff into the borrow-pit shall be
controlled(e.g. using diversion drains / bunded
sediment walls etc), where necessary, to
ensure that it does not cause excessive erosion
and widening of the pit;
 The entrance of the borrow-pit shall be closed
off with branches to prevent access.
 In order to encourage the establishment of
indigenous plant communities, any areas on
the periphery of the site, where the topsoil was
75

not removed and has become compacted,
must be tilled.
 Revegetation shall be conducted by means of
the encouragement of a natural process of
secondary succession.
 This process shall be guided by the ESO and,
where necessary, a rehabilitation specialist.
 Rehabilitated sites shall be monitored annually
for at least 2 years in accordance with the
requirements for ecological monitoring in
Section 4, Table 4-1.
3.12.5 Use of Use of compressors and generators at well-site sites Production Manager Ongoing As per requirement.
compressors shall be restricted to between the hours from 0700 to SPI SHE Manager
and 1800, except in emergencies. In the event of a well
generators at work-over being required, the responsible contractor
well-sites shall prepare an EMP, which shall be approved by
Sasol. This bridging EMP should address the
management of all potential impacts related to the
work-over and should also specify the requirements
for informing the surrounding communities of the
work and activities required.
3.12.6 Radioactivity Sasol shall confirm radiation levels in gas and oil Production Manager Immediate once Analysis results.
from wells extracted from wells and any silt / sand produced. monitoring results Monitoring records.
Should radiation be detected Sasol shall immediately received. Management plan.
prepare a plan describing the management thereof
as necessary, which shall conform to International
standards.
3.13. MAINTENANCE/EQUIPMENT REPLACEMENT

3.13.1 General The maintenance of all storage, refuelling and other SHE Manager Ongoing See Sections 3.9, 3.10, 3.13
such facilities shall comply with the requirements of Maintenance and 3.14.
Sections 3.9, 3.10, 3.13 and 3.14. Manager
3.13.2 Transformers Transformers shall be free of polychlorinated Maintenance Ongoing No PCBs on site.
biphenyls (PCBs) and shall be bunded and regularly Manager
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inspected and maintained. Electrical technician Inspection schedule & records
3.13.3 Gas Turbines / All replacement gas turbines (HP Compression / LP Production Manager Ongoing All new gas engines to
Generators Compression / generators) shall comply with the Maintenance include low-NOx burners.
Mozambique air emissions standard for Petroleum Manager Air emission and noise
Refineries (Decree 18/2004, Appendix 2, as specifications for generators.
amended – refer to Table 4-1 and Appendix 5 of this
o-EMP) or the Sasol IBRD standards set out in the
project financing agreements; or the IFC standard for
emissions by small combustion sources (IFC: 2007 -
EHS Guidelines for combustion sources
generating<50MWth), whichever is the more
stringent.
All existing gas turbines (HP Compression / LP
Compression / generators) shall comply with the
Mozambique standards and IBRD requirements,
described above, or with the o-EMP (2011)
standards where these have not been superseded
by the above.
3.13.4 Gas Turbines / All noise generating equipment shall be checked to Maintenance Annual Assessment and monitoring
Generators/oth ensure that it is functioning optimally with respect to Manager reports
er noise noise emissions and that emissions do not exceed ESO
generating the original design specification
equipment
3.13.5 Oil Pipeline All pipelines shall be maintained and monitored in Maintenance Monthly (cathodic Assessment and monitoring
Maintenance accordance with best industry standards. Monthly Manager protection), monthly reports
checks on the condition and performance of the ESO (transformer rectifier
transformer rectifier units for the cathodic protection units)
on the oil pipeline shall be made. If there are
indications that the cathodic protection is
inadequate, continuous over line surveys must be
carried out to detect any breaks in the coating and to
have a closer inspection of the levels of cathodic
protection over the suspect parts of the pipeline.
3.13.6 Oil Pipeline Review whether the current frequency of pigging is Maintenance As determined Assessment report
Maintenance adequate, and if necessary increase the frequency Manager
(above the average) in the section of pipeline
between the IMS and the PSA Liquids Plant, so as
to test for corrosion and other defects.
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3.13.7 Oil Pipeline Ensure that the risk of spills from the pipeline is ESO/CLO Ongoing As per requirements.
Maintenance communicated to the relevant authorities to ensure
awareness of, and control over, future developments
near the pipeline servitudes;
Consider (if not already in place) a program of
regular (for example, annual) communication with
the local authorities, to ensure an ongoing
awareness of pipeline servitude risks;
Increase community awareness along the Govuro
River floodplain section of the route to ensure that all
farmers and other stakeholders are knowledgeable
about the risks of excavating in this area and are
fully aware of the location of the pipeline. This needs
to be an ongoing exercise.
Enlist the assistance of local communities in
monitoring the river crossing. This would involve
detailed information sessions to make sure that local
people know what to look for and could also involve
consideration of providing nominated local people
with means of communication with the Sasol HSE
and Emergency team.
3.13.8 Excavations Should any excavations of flowlines or other Maintenance For any excavation As per requirements.
excavations be required, soil management shall be Manager Photographic records.
as follows: ESO Assessment and monitoring
 30 cm of topsoil shall be stripped and placed reports.
on the outer side of the trench
 The subsoil shall be removed and placed on
the inner side of the trench.
 After works the sub-soil shall be replaced first
followed by the topsoil. The soil over the trench
shall be mounded slightly to allow for
subsidence and water runoff.
 This process shall be guided by the ESO and,
where considered necessary by the ESO, an
independent rehabilitation specialist.
 The rehabilitated location shall be monitored
annually for at least 2 years as per the
requirements in Section 4, Table 4-1.
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3.13.9 Refuelling and Refuelling and maintenance of vehicles shall occur Maintenance Ongoing Existence of refuelling and
maintenance within specified depots only. Manager maintenance depots.
Working / fuel transfer areas within these depots As per requirements.
shall be underlain by an impermeable surface and
shall have a drainage and collection sump system
(with oil/water separator) to ensure that no spillage
of greases / oils or fuels occurs into local soil and / or
water resources. No hydrocarbon - contaminated
water shall be discharged into the natural
environment.
Operations personnel shall monitor refuelling
operations in order to prevent overfilling.
3.13.10 Vehicle and All equipment and machinery shall be maintained in Maintenance Ongoing Maintenance and service
equipment good working order so as to prevent oil, fuel or other Manager records.
maintenance such leaks as well as elevated emission levels.
3.13.11 Vehicle and All reasonable precautions shall be taken to prevent Maintenance Ongoing Inspection records.
equipment fuel and lubricant spills. The following shall be Manager
maintenance complied with: ESO
 No overfilling of diesel bowsers and equipment
tanks;
 Initial and regular subsequent inspections to
verify that no leaking or defective equipment is
brought onto site.
 Any oils or lubricants discharged during routine
vehicle servicing on site shall be captured
using drip trays, containers or other appropriate
containment measures.
3.13.12 Vehicle A wash bay(s) shall be designed and constructed at Maintenance Complete Wash bay(s) constructed as
washing which all vehicles and equipment and high pressure Manager per requirement.
washing shall take place. The wash bay shall be Vehicle and equipment
constructed so as to capture all runoff. All wash bay washing procedure.
effluent shall be directed to the industrial effluent Wash bay Operating
treatment plant for further treatment before release. Procedure
3.13.13 Well-site work- In the event of a well-site work-over being required, Operations Manager
over the responsible contractor shall prepare an SHE Manager
operations - specific SHE Plan that shall act as a
bridging document between this EMP and the
79

management actions required for the work-over. This
bridging EMP shall be approved by the Operations
Manager, in conjunction with the SHE Manager, prior
to the commencement of any work and shall form
part of the contractual conditions of the contractor.
3.14. SUPPORT SERVICES

3.14.1 General SPT shall comply with all applicable laws, SHE Manager Ongoing Disposal records
regulations, permit and approval conditions and Audit findings.
requirements relevant to the storage, use and
proper disposal of waste materials.
3.14.2 Expertise, The necessary tools, materials and expertise must SHE Manager Ongoing Register of tools available for
equipment be readily available to deal with spills of oils, fuels, handling spills.
and lubricants and other hazardous materials. Procedure for spill
procedures to Spill clean-up kits shall be available on site. The Training records
deal with capacity and number of spill kits for each area shall
spills be based on the risk associated with a spill
(volume / quantity and severity).
A procedure shall be written for the prevention and
management of spills.
The procedure shall contain:
 Guidance to employees regarding safe
working practices and spill avoidance
 Actions to be taken in the event of a spill
 Ongoing training requirements for employees,
equipment operators and for emergency spill
response teams
3.14.3 Loss of Sasol shall inform people cultivating in the vicinity CLOs Ongoing Records of meetings
livelihoods in of flowlines of the risk of an oil leak and the Community knowledge of oil
the event of a availability of the Sasol grievance procedure. leak hazards
spill
3.14.4 Loss of In the event of a spill, Sasol shall compensate Public Relations When required As per requirement
livelihoods in affected people for crops on the land as per the Officer and staff,
80

the event of a Sasol Resettlement Planning and Implementation Temane
spill Programme (RPIP), as amended.
3.14.5 Loss of In the event of a spill, Sasol shall identify CLOs When required As per requirement
livelihoods in replacement land in the vicinity in consultation with
the event of a the relevant authorities and communities, and shall
spill assist such people to clear the land and re-
establish their fields, including provision of seeds
and fertilizer and pesticides if those were used
previously.
3.14.6 New The SHE Manager shall be consulted during the SHE Manager Ongoing SHE Manager and SPI
infrastructure design of any new infrastructure. The design shall SPI Interface Interface Manager to approve,
within CPF be in accordance with Mozambican legislation and Manager in writing, the establishment of
best practices internationally. new infrastructure.
Prior to development, the relevant authorities shall Government approvals
be notified of any changes to infrastructure within
the plant area and authorisation shall be obtained,
where required.
3.14.7 Establishment No work areas shall be sited in the vicinity of SHE Manager Ongoing SHE Manager and SPI
of temporary sensitive sites, e.g. areas of periodic waterlogging, SPI Interface Interface Manager to approve,
work areas drainage lines and areas of extensive animal Manager in writing, the establishment of
outside of the habitation. The establishment of temporary work any temporary work area.
CPF areas should be minimised. Work areas shall be Government approvals
sited in areas of existing disturbance wherever
possible. No work area shall be sited so as to
cause a nuisance or safety hazard to surrounding
landowners, inhabitants or the general public. All
new work areas that are outside of the areas
authorised for Sasol’s activities shall be approved
by the regulatory authorities prior to their
development.
3.14.8 Storage and A comprehensive inventory of all hazardous SHE Manager Ongoing Inventory.
handling of materials and volumes / quantities on site must be Stores Supervisor
hazardous kept updated and maintained. ESO
materials on
site
3.14.9 MSDS usage MSDS contents shall be used as a mandatory SHE Manager Ongoing MSDS’s available for all
and requirement for the appropriate storage and SC Manager hazardous materials on site.
81

availability on handling of all materials and for assisting to make
site an assessment of the possible risk associated with
any materials. Where necessary, the ESO shall be
consulted as to the environmental risk associated
with the use of any material. MSDS’s shall be
available for all hazardous materials on site and a
summary of requirements shall be immediately
available in areas where such materials are stored
or used.
3.14.10 Storage Proper storage facilities shall be provided for the SC Manager Ongoing Storage areas as per
facilities for storage of oils, grease, fuels, chemicals and any requirement.
hydrocarbon other hazardous materials.
products and These storage facilities (including any tanks) shall
chemicals consist of an impermeable surface and shall be
surrounded by a bund wall in order to fully contain
accidental spillages,
3.14.11 Health and Workers shall be made aware of the health and Occupational Health Ongoing Training records.
environmental environmental risks associated with any hazardous Practitioner Regular inspections
risks of substances used and shall be provided with Health and safety meetings
hazardous appropriate protective clothing (PPE) / equipment minutes
substances in case of spillages or accidents.
3.14.12 Purchasing Business-related non-stock items may not be SC Manager Ongoing MSDS for non-stock items.
purchased and brought to site without prior Approval of P&S Manager for
approval of the Procurement & Supply Department. purchase of all non-stock
items.
3.15. COMMISSIONING AND INITIAL START-UP, START-UP FOLLOWING SHUTDOWNS

3.15.1 Internal In the event of CPF modifications, trunk/flow lines Production Manager Ongoing Records of cleaning.
cleaning of cleaning/pigging activities shall comply with this EMP
piping and project SHE Plan.
3.15.2 Pigging Any effluent produced from pigging shall be diverted Production Manager As per procedure As per requirement.
into the closed drain system. Further containment
82

and treatment of spillage shall be via the POC Record of evaluation of
System. treatment options should
A procedure shall be compiled indicating methods glycol inhibitors be used.
and frequency of pigging. Procedure.
3.15.3 Water Water volumes used for flushing should be Production Manager Ongoing As per requirement.
flushing of minimised. ESO
lines Water flushing shall not be used during normal Record of evaluation of
Pump testing operations. proposed additives and
using water Effluent from flushing of lines or pressure testing required treatment options.
shall be routed to the industrial effluent treatment
plant or the incinerator. Should any additives be
used, the ability of the treatment plant to remove /
treat these additives to ensure no environmental risk
shall be determined prior to the use of the additives.
This may include bioassay testing by specialists
competent to conduct such tests.
3.15.4 Initial Condensate from well testing shall be flared at well Production Manager When required As per requirement.
condensate sites.
3.15.5 Initial Care shall be taken during the initial loading (filling) Maintenance Ongoing Document specifying approach
‘loading’ of of machinery and equipment to prevent spills / Manager to initial loading and indicating
machinery accidents etc. due to the relatively higher volumes / Production Manager precautionary measures,
and quantities of materials involved. An action plan shall safety measures and
equipment be prepared detailing the approach to initial loading responses plans to be initiated
with fuel, and precautions / safety measures to be put in place. in the event of an accident.
lubricants,
chemicals
3.16. NORMAL START-UP (REQUIREMENTS OF 3.15 INCLUDED WHERE APPLICABLE)

3.16.1 Flushing No water flushing of lines shall occur during (or prior Production manager When required As per requirement.
to) normal start-up. Water used to flush and clean Inspection records.
out the lines during commissioning and clean out
shall be routed to POC.
83

3.16.2 Flushing POC Drains shall only be cleaned with water where ‘dry’ Maintenance Ongoing Drains maintenance
drains with cleaning would not be effective and where cleaning Manager programme.
firewater is required to ensure the efficient operation of the Production Manager Inspection records.
drains system. Any water used to clean drains shall
be minimised. Drains should be subjected to a
regular maintenance programme. Any water used to
clean drains shall be routed to the industrial effluent
treatment plant.
3.17. OPERATION

3.17.1 (External) Products used for external cleaning shall be Maintenance Ongoing MSDS for products used.
cleaning / ‘environmentally friendly’ products as determined by Manager Effluent monitoring records.
painting of MSDS specifications. ESO
piping and All effluent shall be routed to the industrial effluent
equipment treatment plants. If uncertain as to treatment
capabilities, the precautionary principle shall be
applied and either the chemical shall not be added to
the effluent stream or the effluent shall be tested to
ensure appropriate quality (specifically for the
pollutant / contaminant) of concern, prior to release.
Contaminated cleaning materials and effluent shall
be disposed of as per Section 3.10.
3.17.2 Chemical Chemicals shall be disposed of into containers Production Manager Ongoing Disposal records.
disposal (incompatible chemicals separated as appropriate) ESO Lab waste disposal procedure.
from for either:
laboratory /  Disposal by incineration (if suitable for
other incineration in relation to air quality risks); or
 Disposal off-site to a disposal facility intended
for the type of waste being disposed.
No laboratory chemical / reagent waste shall be
disposed of into drain systems as the industrial
effluent treatment plant is not designed to treat this
waste.
84

3.17.3 Condensate / The condensate/oil loading bay shall be isolated Production Manager Ongoing Spillage disposal records
oil loading from the surrounding environment. Any spillages at
the loading bays shall be routed to an impermeable
lined facility that has capacity to contain the contents
of a full condensate tanker. Any spillage in the facility
shall be tested and routed either to the industrial
effluent treatment plants or returned to the
processing facility for re-treatment
3.17.4 Condensate Sasol shall prepare and implement a condensate/oil Production Manager Complete Condensate/oil loading and
/oil loading loading procedure that shall address, but not transport procedure.
procedure necessarily be limited to: Spill management plan.
 Minimum vehicle requirements / specifications.
 Detailed instructions for loading of condensate
3.17.5 Condensate / Sasol shall ensure that the buyer completes a risk Operations Manager Complete Documented transport risk
oil transport assessment for the transport of condensate/oil off- assessment and EMP.
site and that all transporters are in possession of a Government approvals
MICOA approved EMP, which are to be approved by
Sasol prior to the start of condensate transport
operations.
The risk assessment is to include a transport risk
management plan, which clearly defines
performance requirements for condensate/oil
transport, and includes all of the necessary
requirements to ensure that the SHE and social risks
of transporting condensate/oil are minimised.
Elements of the plan shall include, but shall not be
limited to:
 Route specifications, including permissible
stopping areas
 Alcohol and drugs policy
 Minimum vehicle specifications to ensure safety
 Vehicle maintenance requirements
 Compliance requirements for drivers regarding
following distances, speeds, driving hours,
behaviour in local communities and other matters
of safety and social concern
85

 Requirements for emergency management of
accidents and spills.
3.17.6 Transport Sasol shall ensure that the buyer of the Operations Manager Ongoing Regulatory approvals
approvals condensate/oil has the necessary regulatory
approvals to transport it in terms of Mozambique law
3.17.7 Auditing of Sasol shall audit the environmental performance of ESO Annually Audit reports and findings.
transporters the condensate/oil buyer/ contractor annually so as SHE Manager
to ensure that all performance requirements are met.
Audits shall be in accordance with Sasol’s minimum
standards for road transport, which are aligned with
other international standards.
3.17.8 Off–site spill Any spillages shall be cleaned up in accordance with Operations Manager Ongoing As per requirement.
management the transport risk management plan and a report SHE Manager
shall be prepared detailing the incident, any injuries ESO
or fatalities, causes of the accident and the success
of the clean-up. If significant spillage has occurred
that requires specialist assessment, Sasol shall
ensure that this is undertaken and any necessary
actions that flow from this assessment are
implemented.
3.17.9 TEG storage The CPF complex is designed to prevent TEG Production Manager Ongoing CPF design as per
and handling contamination of site effluent streams. requirement.
In all areas where TEG is stored, transported or TEG storage, handling and
handled, Sasol shall ensure that the risk of any spill use procedure.
or leaks are prevented or minimised and that the
contamination of soils and water are minimised, if
spills or leaks do occur.
Any BTEX / Glycol contaminated water from the
TEG sumps shall be incinerated. TEG-contaminated
soils shall be removed off – site to a hazardous
waste disposal site.
3.17.10 Washing Sasol shall conduct awareness training of all Production Manager Ongoing As per requirement.
down of personnel in order to encourage them to minimise SHE Manager
paved areas wastage of water at the CPF complex, regardless of ESO
with utility the activity being conducted.
water / bund
cleaning
86

3.17.11 Emergency Sasol shall prepare an emergency preparedness Production Manager Complete Documented and implemented
situations and response plan that shall address, but not be SHE Manager emergency preparedness and
limited to the handling of the following environmental response plan.
emergencies:
 Condensate/oil spills;
 Chemical spills;
 High rainfall / flood combined with effluent in
holding pond outside of specification;
 Sewage treatment plant failure (downtime)
 Flood scenario - condensate transport
prevented due to road and /or bridge damage
 Incinerator failure (downtime)
 High rainfall / flood scenario - inability to irrigate
treated water due to ground saturation
 Bush fires;
 Plant fires and explosions
3.17.12 Effluent Refer to Section 3.9.
management
3.17.13 Air Sasol shall ensure adequate measures to protect ESO Ongoing Monitoring records
emissions both employees and the public from any adverse Non-conformance reports and
management effects related to air emissions from Operations. The corrective action plans
potential for adverse effects caused by emissions
shall be determined on the basis of the compliance
standards for which monitoring is specified in
Section 4. Monitoring shall be undertaken as
specified in Section 4 and corrective action
implemented as required.
3.17.14 Air Quality Air quality around the perimeter of the CPF complex ESO Ongoing Monitoring records
shall comply with the specifications set out in Table
4-1. In the event that the air quality standards set out
in Table 4-1 are exceeded at any monitoring point,
Sasol shall investigate the causes for this and shall
notify MICOA accordingly, following which decisions
concerning any remedial action shall be taken in
consultation with MICOA
87

3.17.15 Re-injection Sasol shall ensure that there is no contamination / Production Manager Ongoing As per procedure
of produced pollution (organic or inorganic) of produced water
water prior to re-injection.
3.17.16 General CPF CPF ambient noise standards are set out in Table 4- ESO Ongoing Monitoring records.
operational 1. If ambient noise monitoring shows that these limits Production Manager Records of action taken as
noise are exceeded and community complaints indicate necessary.
that noise levels from Operations need to be
reduced, SPT shall initiate the action required to
achieve the reduction in noise levels to meet the
Operations standards.
3.17.17 Sand / silt If sand / silt is produced by the wells, it shall be Production Manager When required As per requirement
production filtered out and disposed of under controlled
from wells conditions that must avoid any contamination of soil
or water.
3.17.18 Storage of Storage of produced water shall be in closed tanks ESO Whenever necessary As per requirement
produced with provision made for emergency storage in lined Production Manager
water evaporation ponds at the plant.
Periodic inspections shall ensure that the integrity of
the liner of these emergency ponds is fit for purpose.
Rainwater collecting in these ponds shall be
removed regularly in order to ensure that the ponds
retain capacity for emergency produced water
storage, especially during the rainy season.
Rainwater collected in the ponds may be discharged
to the natural environment, subject to compliance
with the final effluent specification in Section 4-1.
3.18. NORMAL SHUTDOWN

3.18.1 Disposal of As per Section 3.15
liquid
hydrocarbon
from the
closed drain
sump
88

3.18.2 Flushing of As per Sections 3.15.3 and 3.16.1.
hydrocarbon
piping and
equipment
with utility
water
3.19. UPSET CONDITION MANAGEMENT

3.19.1 Effluent No untreated effluent (or effluent outside of Production Manager Ongoing Monitoring records.
management specification) shall be released from site. Untreated ESO
effluent shall be held on site in existing facilities until
such time as treatment is possible.
3.19.2 Incinerator The incinerator may not be operated in the event Production Manager Ongoing Record of incinerator
management that the secondary combustion chamber and / or efficiency.
scrubbing phase are inoperable.
3.20. LAND USE CONTROLS

3.20.1 General The operation of the CPF complex and associated Country Manager ongoing Records of meetings /
activities may influence development in the local Operations Manager communication with the
area, bringing about changes in what was previously Government.
a rural environment. Without proper management Aerial photographs / satellite
this could lead to conflict between the rural and imagery to identify changes in
industrial land uses. SPT shall ensure liaison with activities around the Plant
the Government to encourage suitable planning of
land use and land zoning around the CPF complex,
well-sites, access roads and flowlines.
3.20.2 PPZ Sasol shall approach the relevant Mozambique Country Manager Prior to beneficial Formal agreement with the
boundary authorities to motivate for an extension of the PPZ Operations Manager operation of the PSA Mozambique Government
boundary, within which no building infrastructure or Development
settlement should be permitted.
89
3.21. CORPORATE SOCIAL INVESTMENT
The Sasol CSI program will be continued during with the focus over the next three years on education, health and environment, three
of the Millennium Development Goals. The company has also initiated a range of education and training initiatives. These initiatives
mean that going forward, Mozambicans will be able to participate in specialised projects of this nature. For a partnership to be genuine,
all of the partners need to contribute. Sasol should aim to achieve this, in order to avoid the risk of the CSI program promoting
dependency instead of empowerment. Whereas community members cannot contribute funding, they can contribute ‘sweat equity’
as a minimum, for example, during the construction and maintenance of CSI facilities. This will require concerted communication,
awareness creation and capacity building within the communities.

3.21.1 CSI Policy Implement the intent of the “Corporate Social Public Relations Ongoing As per requirement
Responsibility Policy for the Mineral Resources Officer and staff,
Extractive Industry” (GoM, 2014) Temane
3.21.2 Community The capacity and status of Community Public Relations Ongoing As per requirement
Interface Interface Forums shall be built up to help Officer and staff,
Forums facilitate contributions by community Temane
members. Where such forums no longer exist,
they should be re-established in a participatory
process with communities. They can play a
critical role in community development in the
villages providing they are empowered to do
so. Capacity building would need to start at
‘how to run a committee’.
3.21.3 CSI Awareness Sasol shall publish and create awareness of the Public Relations Ongoing Information campaign records
many CSI projects the company has already Officer and staff,
established and the local benefits derived from Temane
these projects. Use shall be made of a good mix
of verbal, visual and written information. In
villages, the information campaign should be
rolled out to the entire population of the village
and not only to village leaders.
90

3.21.1 CSI Policy Implement the intent of the “Corporate Social Public Relations Ongoing As per requirement
Responsibility Policy for the Mineral Resources Officer and staff,
Extractive Industry” (GoM, 2014) Temane
3.21.2 Community The capacity and status of Community Public Relations Ongoing As per requirement
Interface Interface Forums shall be built up to help Officer and staff,
Forums facilitate contributions by community Temane
members. Where such forums no longer exist,
they should be re-established in a participatory
process with communities. They can play a
critical role in community development in the
villages providing they are empowered to do
so. Capacity building would need to start at
‘how to run a committee’.
3.21.4 CSI Local A stronger CSI management presence at the CPF SHE Manager, Ongoing As per requirement
Management is recommended. Section 2.10 provides details. Rosebank
3.21.5 Allocation of Once the system of setting aside funds for local Public Relations Ongoing As per requirement.
Petroleum Tax communities under the Petroleum Tax Law (Act Officer and staff, Records of fund allocations
Law funds 12/2007) is in place, Sasol should work closely Temane in consultation with District
with District Government to coordinate wise Government
application of these funds in tandem with Sasol’s
CSI program.
3.22. DECOMMISSIONING

3.22.1 General An Environmental Impact Assessment shall be Operations Manager Authorisation required As determined in the EIA and
prepared for the decommissioning of the CPF ESO prior to start of DRP.
complex and all other infrastructure, including wells decommissioning
and flowlines), approximately 2 years before project
closure, in accordance with oil and gas industry best
practice and/or current Mozambique legal
requirements. The EIA shall be used as a basis for
updating the Decommissioning and Rehabilitation
Plan (DRP), which must be approved by MICOA
prior to decommissioning.
91
Note 1: Any additional development activities for Operations must be conducted in terms of the construction and operations EMP for
the CPF and associated facilities. These documents will need to be updated as necessary to reflect the additional Operations activities
and associated management requirements.
Note 2: For any expansions of the CPF complex the following World Bank Guidelines and policies are applicable:
● IFC Performance Standards on Environmental and Social Sustainability (1 January, 2012) PS 1-8.
● IFC Environmental, Health, and Safety Guidelines for Onshore Oil and Gas Development (April, 2007).
● IFC Environmental, Health, and Safety Guidelines – General Guidelines (April 2007).
92
4. PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION
The assessment of performance has three key aims:
i) Confirmation of compliance to the requirements as set out in the

EMP;
ii) Measurement of environmental performance (degree of success of

the EMP and its specifications); and
iii) Ensuring that any deficiencies in the EMP are identified and
remediated.
These aims shall be met by making use of four important tools: monitoring,
auditing / inspections, non-conformance / incident identification and close-out,
and management review. Corrective action will be critical in ensuring that any
identified problem areas are effectively addressed. Specifications for
monitoring, non-conformance identification, auditing and review are provided in
the sections that follow. SPT shall produce procedures for monitoring, auditing
and inspections, management review, non-conformance / incident reporting
and corrective action that will address the requirements of this section.
4.1. ENVIRONMENTAL MONITORING STRATEGY
A monitoring6 strategy must be defined to ensure that the effectiveness of

management and mitigation measures can be tracked and corrective action
(see section 4.4) identified as necessary. Note that monitoring shall be intended
to evaluate the effectiveness of environmental management, independently of
whether the specifications in the EMP have been complied with. Proper
monitoring will enable any impacts of Operations on the environment to be
detected as early as possible and corrective action implemented as required.
Table 4-1 defines the monitoring requirements necessary during the operational
phase of the CPF complex. Where monitoring is specified as a requirement, the
6
Monitoring is a process of surveillance, based on specified approaches and schedules, used to detect whether any
changes have occurred in the predefined, quantifiable properties of the particular environment under consideration.
93
responsible party will develop a monitoring, measurement and reporting

procedure that will outline:
 The monitoring objectives;
 A detailed description of the required monitoring measures, including

responsibilities, parameters to be measured, methods to be used,
sampling locations, frequency of measurement, detection limits and the
definition of thresholds that will signal the need for corrective actions
(see section 4.4);
 The approach to the analysis of results and the identification of activities

and impacts requiring corrective action; and
 Reporting requirements, with defined responsibilities, to ensure early

detection of conditions that require corrective action and approach to
initiating corrective action.
94
TABLE 4-1: MONITORING REQUIREMENTS. (IN SOME CASES PERFORMANCE INDICATORS HAVE BEEN INDICATED IN THE EMP STANDARD AND THUS
ADDITIONAL MONITORING MAY BE REQUIRED TO THAT PRESENTED IN THE TABLE)
Please note that all considerations regarding monitoring, such as parameters and, frequency of sampling are not to be considered fixed and that changes, such as more frequent monitoring, may be required
based on results of previous monitoring data, the advice of professionals, new government requirements through regulations and stakeholder concerns amongst others. The monitoring programme should
continually be evaluated to ensure its effectiveness and appropriateness.
** A detailed breakdown of the derivation of this table, including an explanation of the changes made between the Rev. 3 o-EMP and the Rev. 4 o-EMP, is included in Appendix 5.
Threshold limits per Responsibility

Parameters to be monitored Monitoring location Frequency of monitoring Reporting
parameter7 for monitoring
Water related monitoring (surface)
Sewage treatment plant effluent Outlet from sewage plant Every second day Production Production
quality8 Manager Manager
- pH 6-9 ESO ESO
- BOD 30 mg/L
- COD 125 mg/L
- Oil and grease 10 mg/L
- TSS 50 mg/L
- Total Nitrogen9 10 mg/L
- Phenols 0.5 mg/L
- Phosphorus 2 mg/L
- Residual chlorine (as Cl) 0.2 mg/L
- Coliform count <400 MPN/100ml
- Heavy metals total 10 mg/L Outlet from the sewage plant Twice per year Production Production
- Arsenic 0.1mg/L Manager Manager
- Cadmium 0.1 mg/L ESO ESO
- Chromium10 0.5 mg/L
- Copper 0.5 mg/L
7
Threshold limits for the Final Effluent discharge, and the storm water discharge after ‘first flush’ which are the only discharges into the natural environment, are determined by Mozambique Effluent Emission
Standards (Decree 18/2004), IFC (2007) EHS Guidelines for the Onshore Oil and Gas Industry, IFC (2007) General EHS Guidelines and standards set by Sasol’s agreement with the financiers in 2004. In
each case, the more stringent of the values is used. Refer to Appendix 5 for details.
8 The threshold values set out for the MBR Sewage Treatment Plant and the Industrial Effluent Treatment Plant may be considered to be internal Sasol quality assurance checks rather than compliance
requirements, since this effluent is not released directly into the natural environment. If final effluent from the PSA IETP is separately released into the environment, this must aslo be considered to be ‘Final
Effluent’
9 Threshold values for nitrogen include only total nitrogen (N) as a compliance requirement in accordance with Mozambique legal standards and IFC (2007) guidelines (IFC, 2007 guideline for domestic
wastewater is used). Other forms of nitrogen should be measured as a means of managing the functioning of the sewage treatment works. These may include nitrate nitrogen (NO3-N), ammonia nitrogen (NH3-
N), ammonium nitrogen (NH4-N), nitrite nitrogen (NO2-N) and Kjeldahl nitrogen (TKN).
10
With respect to the limit for chromium, if monitoring shows that the discharge of total chromium equals or exceeds 0.4 mg/L, SPT will then monitor chromium hexavalent to ensure that the discharge of this
substance does not exceed 0.1 mg/L (refer to Appendix 5).
95

- Iron 3.5 mg/L
- Lead 0.1 mg/L
- Mercury 0.01 mg/L
- Nickel 0.5 mg/L
- Selenium 0.1 mg/L
- Silver 0.5 mg/L
- Zinc 2.0 mg/L
- Odour Present / absent at dilution of
1:20
- Colour Present / absent at dilution of Outlet from the sewage plant Every second day Production Production
1:20 Manager Manager
- Temperature <3oC above temp of receiving ESO ESO
waters at point of mixing
<35oC
Industrial effluent treatment plants Outlet from industrial effluent Every second day. Production Production
quality treatment plant Manager Manager
- pH 6-9 ESO ESO
- BOD 30 mg/L
- COD 150 mg/L
- TSS 30 mg/L
- Oil and grease 10 mg/L
- Phenol 0.5 mg/L
- Sulphide 1 mg/L
- Total nitrogen 10 mg/L
- Phosphorous 5 mg/L
- Chrome 0.5 mg/L
- Chrome (CR+6) 0.1 mg/L
- Lead 0.1 mg/L
- Benzene 0.05 mg/L
- Temperature <3oC above temp of receiving
<35oC
Final effluent quality water Effluent holding pond Prior to irrigation. Production Production
discharged into natural environment Manager Manager
- pH 6-9 During storm events when ESO ESO
- BOD 30 mg/L storm water is overflowing
96

- COD 125 mg/L Storm water release from storm from the weir (potentially
- TSS 30 mg/L water holding pond weir after contaminated water) and
- Oil and Grease 10 mg/L containment of first flush discharging into the
- Phenol 0.5 mg/L natural environment.
- Total Nitrogen (N) 10 mg/L Frequency of monitoring to
- Phosphorus 2 mg/L Storm water release from open include at least 20% of
- Residual Chlorine 0.2 mg/L drains release events.
- Sulphide 1 mg/L
- Total coliforms <400 MPN/100 ml During storm events when Production Production
diverted ‘clean’ water is Manager Manager
discharged into the natural ESO ESO
environment from the open Frequency of
drains monitoring per
year
- Total toxic metals (including 5 mg/L Effluent holding pond Prior to irrigation twice per Production Production
antimony, arsenic, beryllium, year Manager Manager
cadmium, chromium, copper, iron, ESO ESO
lead, mercury, nickel, selenium,
silver, thallium, vanadium, zinc)
- Cadmium 0.1 mg/L
- Chrome (Cr +6) 0.1 mg/L
- Chromium 0.4 mg/L
- Copper 0.5 mg/L
- Lead 0.1 mg/L
- Temperature <3oC above temp of receiving
<35oC
- Arsenic 0.1 mg/L
- Iron 3.5 mg/L
- Mercury 0.01 mg/L
- Selenium 0.1 mg/L
- Silver 0.5 mg/L
- Nickel 0.5 mg/L
- Zinc 2 mg/L
- Benzene 0.05 mg/L
Water related monitoring (groundwater)
97

Groundwater quality11 Develop baseline. Monitor Site monitoring boreholes at Twice per annum Production Production
changes in water quality CPF complex, and other site Refer to Figures 4-1 & 4-2 Manager Manager
against baseline during boreholes and community and Tables 4-2 & 4-3 ESO ESO
project operation. Thresholds boreholes throughout the
for investigation of causes potential area of direct
are: influence of the project (refer to
 Any measureable oil and Figures 4-1 & 4-2 and Tables 4-
grease 2 & 4-3 for details).
 Any measureable BTEX
or other hydrocarbon-
related parameters
 Any measureable
naphthalene
 Any increase in other
parameters above
highest seasonal
background in reference
wells by 15% or more
Landfill leachate
Leachate volume (liquid level) Rainwater to be excluded Landfill site leachate collection Twice per month Production Production
from the landfill or leachate to manholes Manager Manager
be maintained at <80% liquid ESO ESO
level.
Leachate quality No threshold. Leachate to be Landfill site leachate collection Once per month Production Production
monitored to verify toxicity in manholes Manager Manager
relation to surrounding ESO ESO
groundwater. In the event of
an increase in the
concentrations of pollutants
pertinent to the waste site in
surrounding groundwater
monitoring boreholes, the
leachate quality will serve as
an initial check as to whether
11
Community groundwater wells to be accessed with community permission.
98

this could be due to a leaking
landfill liner.
Water related monitoring (surface water)
Surface water quality Develop baseline. Monitor Monitor the Govuro River, Refer to Table 4-4 Production Production
changes in water quality barrier lakes and coastal Manager Manager
against baseline during streams (refer to Figure 4-3 and ESO ESO
operation. Thresholds for Table 4-4)
investigation of causes are:
 Any measureable oil and
grease
 Any measureable BTEX
or other hydrocarbon-
related parameters
 Any measureable
naphthalene
 Any increase in other
parameters above
highest seasonal
baseline by 15% or more
Water related monitoring (potable water)
Potable water quality Potable water treatment plant All parameters measured Production Production
- pH* –6,5 – 8,5 twice (in 2013) to establish Manager Manager
- Colour 15 TCU a baseline. Thereafter, ESO ESO
- Smell None parameters marked with
- Conductivity* 50 – 2000 mg/L an asterisk (*) to be
- Taste None monitored once every two
- Total solids 1000 mg/L days.12
- Turbidity 5 NTU
- Faecal coliforms* 0 – 10 MPN/100ml
- Ammonia (NH3-N)* 1,5 mg/L
- Arsenic (As) 0,01 mg/L
- Antimony (Sb) 0,005 mg/L
- Barium (Ba) 0,7 mg/L
- Boron (B) 0,3 mg/L
- Cadmium (Cd) 0,003 mg/L
12
While Mozambique legal standards for untreated potable water supplied by public water utilities do not apply to private users, the same quality standards are adopted for this EMP. Initial monitoring is to
include all parameters to set a baseline. Thereafter, routine monitoring is to include only those parameters marked with an * opposite them. Monitoring of other parameters is at Sasol’s discretion.
99

- Calcium (Ca) 50 mg/L*
- Lead (Pb) 0,01 mg/L
- Cyanide (Cn) 0,07 mg/L
- Chloride (Cl)* 250 mg/L
- Copper (Cu) 0,05 mg/L
- Hardness* 500 mg/L
- Phosphorus (P) 0,1 mg/L
- Total iron (Fe)* 0,3 mg/L
- Fluoride (F)* 1,5 mg/L
- Organic matter* 2,5 mg/L
- Magnesium (Mg) 50 mg/L
- Manganese (Mn) 0,1 mg/L
- Mercury (Hg) 0,001 mg/L
- Molybdenum (Mo) 0,07 mg/L
- Nitrite (NO2-) 3,0 mg/L
- Nitrate nitrogen (NO3-N)* 50 mg/L
- Nickel (Ni) 0,02 mg/L
- Sodium (Na) 200 mg/L
- Sulphate 250 mg/L
- Selenium (Se) 0,01 mg/L
- Total Dissolved Solids* 1000 mg/L
- Zinc (Zn) 3,0 mg/L
- Total pesticides 0,0005 mg/L
Atmospheric related monitoring
Ambient monitoring13
Dust fallout 600 mg/m2/day (DEAT) CPF perimeter, PPZ boundary Annually ESO ESO
Averaging time: 28 days and community sites (refer to Production Production
Figure 4-4). Manager Manager
NO2 concentrations Units=μg/m3 Annually (passive ESO ESO
1-hour: 190 sampling media). Two Production Production
Annual average: 40 week sampling period Manager Manager
(Figure 4-4 and Table 4-5).
SO2 concentrations Units=μg/m3 Annually (passive ESO ESO
24 hour: 100 sampling media). Two Production Production
Annual average: 40 Manager Manager
13
The measurement of ambient concentrations is undertaken annually over a specified period. This period does not always correspond to the reference monitoring period specified in the threshold limits in
Table 4-1. Appendix 5 describes how to interpolate results from the measured monitoring period so as to compare them with the threshold limits.
100

week sampling period
Hydrogen sulphide (H2S) Units=μg/m3 CPF perimeter, PPZ boundary Annually (passive ESO ESO
and community sites (refer to sampling media). Two Production Production
Figure 4-4). week sampling period Manager Manager
Total Suspended Particulates Units = μg/m3 CPF perimeter, PPZ boundary Occasional changeover ESO ESO
24 hours: 150 and community sites (refer to over of e-samplers from Production Production
Annual average: 60 Figure 4-4). PM10 to TSP in order to Manager Manager
measure for compliance
with Mozambique TSP
standard.
PM10 Units = μg/m3 CPF perimeter, PPZ boundary Continuous in the case of ESO ESO
24 hours: 50 and community sites (refer to the e-samplers at well Production Production
Annual average: 20 Figure 4-4). pads T-12 and T-16 Manager Manager
Annually at CPF and PPZ
perimeter sites described
in Figure 4-4 and Table 4-
5.
Odours Odours not offensive at Receptor locations Ad-hoc inspections and in ESO ESO
receptor end (H2S at the response to complaints Production Production
property boundary should be received. Manager Manager
less than 5ug/m3).
Lead Units = μg/m3 CPF perimeter north and south Annually for 2 years after ESO ESO
Annual average: 0.5 (minivol PM10 monitoring sites) PSA Liquids and LPG Production Production
(refer to Figure 4-4). Monitoring Plant is operational Manager Manager
Manganese Units = μg/m3 to use dust sample collected by following PSA plant start- ESO ESO
Annual average: 0.05 minivols. up. Thereafter first two Production Production
years show results for any Manager Manager
Mercury Units = μg/m3 parameter of more than ESO ESO
Annual average: 1.0 25% of standard Production Production
Manager Manager
Arsenic Units = μg/m3 ESO ESO
Annual average: 3x10-3 Production Production
Manager Manager
Chrome7 Units = μg/m3 ESO ESO
Annual average: 9.6x10-1 Production Production
Manager Manager
Nickel Units = μg/m3 ESO ESO
Annual average: 4x10-2
101

Production Production
Manager Manager
Benzene14 Units = μg/m3 CPF perimeter, PPZ boundary Annually (passive ESO ESO
Annual average: 4.4x10-6 and community sites (refer to sampling media). One Production Production
Figure 4-4) and Table 4-5) month sampling period Manager Manager
Ethylbenzyne Units = μg/m3 Annually (passive ESO ESO
24 hours: 100 sampling media). One Production Production
month sampling period Manager Manager
Toluene14 Units = μg/m3 Annually (passive ESO ESO
Weekly average: 260 sampling media). One Production Production
Xylene Units = μg/m3 Annually (passive ESO ESO
24 hours: 100 sampling media). One Production Production
Formaldehyde14 Units = μg/m3 Annually (Dräger method). ESO ESO
30 minutes: 100 One month sampling Production Production
period (Figure 4-4 and Manager Manager
Table 4-5).
Styrene14 Units = μg/m3 Annually (passive ESO ESO
Weekly average: 260 sampling media). One Production Production
Carbon Tetrachloride14 Units = μg/m3 Annually (passive ESO ESO
Annual average: 6.1 sampling media). One Production Production
Meteorological parameters None. Weather station location on top Online monitoring station. None ESO
- Hourly average wind speed and of control room complex. Production
direction Manager
- Hourly ambient temperature
- Hourly precipitation
14
The compliance standards for these parameters are based on world standards including IFC, EC & WHO. Refer to Appendix 6 for the reasons that the Mozambique Decree 67/2010 are not used.
102

- Relative humidity
- Barometric pressure
Emission related monitoring
(incinerator stack, flare,
condensate re-boiler, HP & LP
compression, generators)
Volatile Organic Carbon (VOC) 20 mg/Nm3 Incinerator stack Online monitoring station. Production Production
concentrations Flare Monitoring is done through manager Manager
calculation of inputs and ESO ESO
then potential emissions. It
is not possible to
physically monitor the
flare.
20 mg/Nm3 HP & LP compression stacks, Annually
GTG stacks
Total Suspended Particulates 50 mg/Nm3 Incinerator stack Online monitoring station. ESO ESO
manager Manager
Nitrogen oxides 320 mg/Nm3 Incinerator stack Online monitoring station ESO ESO
Flare Monitoring is done through Production Production
calculation of inputs and manager Manager
is not possible to
flare.
79 mg/Nm3 (15) Electrical generation (GTG’s) Annual
188 mg/Nm3 (16) Mechanical drive (HP & LP Annual
compressors)
Sulphur dioxide17 1000 mg/Nm3 Incinerator stack Online monitoring station. ESO ESO
15
NOx standard for new equipment only. For equipment prior to 2013, the IBRD standard of 320 mg/nm3 applies (which is more stringent than the Mozambique legal standard).
16
As above
17
The Mozambique emission standards (Decree 67/2010) require monitoring of SOx which includes SO 2 and SO3. SO3 can be emitted from a combustion source when SO2 is oxidised in the presence of
oxygen and a catalyst, such as vanadium pentoxide. Combustion sources at a gas processing plant using natural gas and sweet oil as a fuel source will emit negligible quantities of SO3. This is different from
combustion sources that use fuel with catalytic properties such as coal flue particles, which may contain vanadium. Even then, the conversion rate is less than 1% of the SO2. It is therefore not necessary to
103

Flare Monitoring is done through Production Production
calculation of inputs and manager Manager
is not possible to
flare.
150 mg/Nm3 Reboiler unit stacks Annual
500 mg/Nm3 HP & LP compression stacks, Annual
GTG stacks18
Hydrogen sulphide 30 mg/Nm3 Incinerator stack Annually at a time ESO ESO

representative of normal Production Production
operations. manager Manager
- Flare Monitoring is done through
calculation of inputs and
is not possible to
flare.
5 mg/Nm3 (19) HP & LP compression stacks, Annually at a time
GTG stacks representative of normal
operations.
Dioxins and Furans 1ng/N m3 Incinerator stack. Annually at a time ESO ESO
representative of normal Production Production
operations manager Manager
Hydrochloric Acid 50 mg/Nm3 Incinerator stack. Online monitoring station ESO ESO
manager Manager
Carbon monoxide As per advice of supplier / Incinerator stack. Online monitoring station ESO ESO
contractor
monitor SOx, which includes both SO2 and SO3 emissions. Measuring SO2 from combustion and reboiler stacks involves a much simpler methodology than measuring SO 3, and will for all practical intents and
purposes reflect all sulphur oxides emitted. The measurement of SO2 may therefore be considered to be equivalent to measuring SOx, and may be compared with the SOx threshold values in Decree 67/2010.
18
Only one of each of the LP Compressors, HP Compressors and Gas Turbine Generators (GTG’s) requires emissions monitoring as long as the others are of the same specification.
19
H2S standard for new equipment only. For equipment prior to 2013, the Mozambique legal standard applies (15 mg/nm3)
104

manager Manager
Total hydrocarbon compounds 20 mg/Nm3 Incinerator stack. Online monitoring station ESO ESO
manager Manager
Incinerator ash monitoring
Incinerator ash and spent lime None. Demonstrate Incinerator (skips with ash & Annually ESO ESO
characterisation requirement for continued spent lime) Production Production
disposal in a H:H disposal site manager manager
based on the hazard
classification system of the
South African Dept. of Water
Affairs “Minimum
Requirements for the
Classification, Handling and
Disposal of Hazardous
Waste” (Volume 1, Second
Edition, 1998).
Soil monitoring
Soil sampling for: None. As per CPF procedure Pre-determined locations within Annually ESO ESO
Heavy metals based on Dutch target and and outside the PPZ (Refer to
Hydrocarbons intervention guidelines Figure 4-5 and Table 4-6)
Chlorides (Ministerie van
Volkhuisvesting, Ruimtelijke
Ordering en Milieubeheer,
Version February 4th, 2000)20
Parameters exceeding the
procedure’s intervention limits
must trigger an action plan.
Acoustic related monitoring
Ambient noise levels < 55 dBA during day At the receptor points specified Monthly ESO ESO
- dBA < 45 dBA during the night in Figure 4-6 which includes Production Production
Every measurement sample must sites at the CPF complex Samples taken during Manager Manager
be representative of the ambient battery limit, at the PPZ representative periods of
20
Available at www.esdat.net Dutch Target and Intervention Values, 2000 (the New Dutch List).
105

noise level at the time, and have a boundary and at the following the day (0700 to 2200)
minimum duration of 15 minutes closest to beyond the PPZ and night (2200 to 0700)
boundary:
Samples shall reflect typical - Residential
operational conditions at the CPF. - Institutional
- Educational
The subjective impression of the
ambient noise at the measurement
points shall be noted, with specific
reference on the audibility of CPF
and other significant noise sources
in the area.
Ecology related monitoring
Vegetation along flowlines, borrow In accordance with monitoring All flowlines, borrow pits and Every year ESO ESO
pits, seismic lines and access roads and intervention procedure, access roads Production Production
- surface cover as updated Manager Manager
- degree of weed infestation
- erosion
Oil Spill related monitoring Laboratory detectable oil and Govuro River immediately Once per week ESO ESO
grease. upstream and downstream of
the pipeline
Visual observations (Sasol to Govuro River pipeline crossing Once per week when the ESO ESO
develop a procedure for and floodplain river is accessible
monitoring, including visual
observation to check for a
sheen on the water and
training local people in what
to look for. Provision to be
made for rapid community
communication with the CPF
if a leak is identified).
Community Monitoring
Respect for local communities Monitor the following: All project-affected villages Monthly Monthly CLOs
 The number of
compliments vs complaints
recorded in Compliments
and Complaints Registers.
 The percentage of
complaints satisfactorily
resolved and signed off by
106

those who registered the
complaints.
 The number of grievances
registered as part of the
Grievance Procedure
 The percentage of
grievances satisfactorily
resolved and signed off by
those who registered the
grievances.
107
Figure 4-1: Groundwater monitoring locations prior to completion of the PSA Development and LPG Project (refer to Table 4-2)
108
Figure 4-2: Groundwater monitoring locations after completion of the PSA Development and LPG Project (refer to Table4-3)
109
TABLE 4-2: GROUNDWATER MONITORING LOCATIONS PRIOR TO COMPLETION OF THE PSA LIQUIDS
AND LPG PROJECT (REFER TO FIGURE 4-1)
Borehole Sample South East

Site Parameters to be monitored
ID frequency (degrees) (degrees)
CPF 1A CPF Twice per year 21.7452 35.0623 Inorganic Parameters
CPF 1C CPF Twice per year 21.7452 35.0623 pH
Total Dissolved Solids
CPF 2A CPF Twice per year 21.7459 35.0623
Electrical conductivity
CPF 3A CPF Twice per year 21.7478 35.0623 Total Alkalinity
CPF 4A CPF Twice per year 21.7498 35.0621 Total Metals
CPF 5A CPF Twice per year 21.7524 35.0613 Full Metals (Al, As, B, Be,
CPF 6A CPF Twice per year 21.7504 35.0585 Cd, Cr, Cu, Fe, Pb, Mn, Hg,
Ni, K, Se, V, Zn)
Nutrients (Po4, NO3-N, NH3-
CPF 8A CPF Twice per year 21.7502 35.0625 N, N)
CPF 8C CPF Twice per year 21.7501 35.0625 Major ions (Ca, Mg, Na, F,
CPF 9A CPF Twice per year 21.7523 35.0625 SO4, Cl)
T22A CPF Twice per year 21.7955 35.0233
Organic Parameters
T22B CPF Twice per year 21.7955 35.0225 Poly Aromatic Hydrocarbons
W2B CPF Twice per year 21.7500 35.0614 (naphthalene, oil and
W5A CPF Twice per year 21.7503 35.0598 grease, BTEX)
Extractable Petroleum
T8 Well pad T8 Twice per year 21.7328 35.1223
Hydrocarbons (EPHs)
T9 CPF water supply Twice per year 21.7272 35.1489 Gasoline Range Organics
IPF1D PSA Liquids Plant Twice per year 21.7469 35.0647 (GROs)
IPF1S PSA Liquids Plant Twice per year 21.7469 35.0647
IPF2D PSA Liquids Plant Twice per year 21.7451 35.0653
Community borehole
Temane Twice per year 21.7502 35.0290
(Temane)
Community borehole
SBH1 Twice per year 21.7391 35.0696
(Orphanage)
SBH9 I-8 Twice per year 21.6063 35.1500
SBH16 I-9z Twice per year 21.6789 35.2451
SBH33 T-14 Twice per year 21.7281 35.1649
SBH35 T-19 Twice per year 21.7196 35.1662
SBH38 T-18 Twice per year
SBH40A T-9 Twice per year
SBH41A I-10 Twice per year 21.7436 35.2628
SBH42A I-7 Twice per year 21.7829 35.2317
SBH44B I-13 Twice per year 21.8375 35.2248
Community borehole
CBH1 Twice per year 21.7849 35.2328
(Chipongo)
110
Borehole Sample South East

Site Parameters to be monitored
ID frequency (degrees) (degrees)
Community borehole
(Chipongo)
Community
Chitsotso Twice per year 21.7526 35.1098
borehole (Chitsotso)
Community borehole
(Chipongo)
Community borehole
(Mangaralane 1)
Community borehole
(Primary school)
Community borehole
(Mangaralane 1)
Community borehole
SBH 29 Twice per year 21.6014 35.1561
(Primary school)
TABLE 4-3: GROUNDWATER MONITORING LOCATIONS AFTER COMPLETION OF THE PSA LIQUIDS
AND LPG PROJECT (REFER TO FIGURE 4-2)
Borehole Site Sample South East Parameters to be

ID frequency (degrees) (degrees) monitored
CPF 1A CPF Twice per year 21.7452 35.0623 Inorganic Parameters
CPF 1C CPF Twice per year 21.7452 35.0623 pH
Total Dissolved Solids
Electrical conductivity
CPF 3A CPF Twice per year 21.7478 35.0623 Total Alkalinity
CPF 4A CPF Twice per year 21.7498 35.0621 Total Metals
CPF 5A CPF Twice per year 21.7524 35.0613 Full Metals (Al, As, B, Be,
CPF 6A CPF Twice per year 21.7504 35.0585 Cd, Cr, Cu, Fe, Pb, Mn,
Hg, Ni, K, Se, V, Zn)
Nutrients (Po4, NO3-N,
CPF 8A CPF Twice per year 21.7502 35.0625 NH3-N, N)
CPF 8C CPF Twice per year 21.7501 35.0625 Major ions (Ca, Mg, Na,
CPF 9A CPF Twice per year 21.7523 35.0625 F, SO4, Cl)
T22A CPF Twice per year 21.7955 35.0233
Organic Parameters
T22B CPF Twice per year 21.7955 35.0225 Poly Aromatic
W2B CPF Twice per year 21.7500 35.0614 Hydrocarbons
W5A CPF Twice per year 21.7503 35.0598 (naphthalene, oil and
grease, BTEX)
T8 Well pad T8 Twice per year 21.7328 35.1223
Extractable Petroleum
T9 CPF water supply Twice per year 21.7272 35.1489 Hydrocarbons (EPHs)
IPF1D PSA Liquids Plant Twice per year 21.7469 35.0647 Gasoline Range Organics
IPF1S PSA Liquids Plant Twice per year 21.7469 35.0647 (GROs)
IPF2D PSA Liquids Plant Twice per year 21.7451 35.0653
PBH1 Well pad I-G6PX-3 Twice per year 21.6270 35.2113
PBH5 Well pad I-9z Twice per year 21.6789 35.2451
111
Borehole Site Sample South East Parameters to be

ID frequency (degrees) (degrees) monitored
PBH6 Well pad I-4 Twice per year 21.6977 35.2253
PBH10 Well Pad I-G6PX-6 Twice per year 21.7033 35.2616
Inhassoro Manifold
PBH11 Twice per year 21.7262 35.21432
Station (IMS)
Community borehole
Temane Twice per year 21.7502 35.0290
(Temane)
Community borehole
(Orphanage)
Community borehole
(Chipongo)
Community borehole
(Chipongo)
Community
Chitsotso Twice per year 21.7526 35.1098
borehole (Chitsotso)
Community borehole
(Chipongo)
Community borehole
(Mangaralane 1)
Community borehole
(Primary school)
Community borehole
(Mangaralane 1)
Community borehole
SBH 29 Twice per year 21.6014 35.1561
(Primary school)
112
Figure 4-3: Surface water monitoring locations in and around the CPF complex and project area (refer to Table 4-4)
113
TABLE 4-4: PROPOSED SURFACE WATER MONITORING PLAN (REFER TO FIGURE 4-3)
Station Latitude Longitude Parameters

Description Frequency
ID (S) (E)
Govuro River upstream of Inorganic
Twice per year
all project infrastructure Samples
(and once per
GV-SW01 and situated 21.940412° 35.130185°
week for oil and
approximately 1 km east pH
grease *)
of the main road EN1 Total Dissolved
Govuro River crossing at Twice per year Solids
the proposed oil flow line (and once per Electrical
GV-SW04 21.724684° 35.138318°
about 2 km west of week for oil and conductivity
Temane production well 9 grease*) Total Alkalinity
Govuro River about 5 km Total Metals
downstream of GV-SW04. Twice per year
Full Metals (Al, As,
Point not monitored (and once per
GV-SW05 21.695328° 35.115633° B, Be, Cd, Cr, Cu,
before, but selected for week for oil and
future monitoring due to grease *) Fe, Pb, Mn, Hg, Ni,
site accessibility. K, Se, V, Zn)
Govuro River at road Nutrients (Po4,
Twice per year NO3-N, NH3-N, N)
crossing towards
(and once per
GV-SW06 Inhassoro and 21.567053° 35.100460° Major ions (Ca, Mg,
week for oil and
approximately 3.5 km east Na, F, SO4, Cl)
grease *)
of EN-1 road.
Stream flowing east, Organic
IN-SW10 originating 600m south 21.631378° 35.216199° Twice per year Parameters
east of I-G6PX-3 flowline
Poly Aromatic
Perennial Channelled
Valley-bottom wetland Hydrocarbons
IN-SW11 21.723420° 35.256094° Twice per year (naphthalene, oil
situated 200m north east
of I-G6PX-1 and grease, BTEX)
A perennial coastal
Extractable
stream fed by a large
IN-SW12 21.677771° 35.258102° Twice per year Petroleum
wetland and a situated 1.3
km east of I-9Z Hydrocarbons
Permanent Source spring (EPHs)
of Channelled Valley-
IN-SW13 bottom wetland situated 21.676111° 35.228658° Twice per year Gasoline Range
160m south of flowline Organics (GROs)
alignment
A stream 1.5 km west of
GV-SW14 borehole I-14 draining 21.630215° 35.174443° Twice per year
towards Govuro River
A point 5 km downstream
GV-SW15 of GV-SW14 Govuro 21.604360° 35.141072° Twice per year
River
Barrier lake situated 800m
IN-SW07 south of the proposed I- 21.663628° 35.225266° Twice per year
G6PX-2 oil well.
Barrier Lake situated
250m east of proposed oil
GV-SW08 21.718333° 35.170833° Twice per year
well T-19A and adjacent
to GV-SW09
Barrier Lake situated
700m south east of
GV-SW09 proposed oil well T-19A 21.725000° 35.173333° Quarterly
and adjacent to GV-
SW09.
114
Station Latitude Longitude Parameters

Description Frequency
ID (S) (E)
Storm water drain south
PSA- Twice a year
of the proposed site 21.748419° 35.064725°
SW01 during storms
entering the environment
Storm water drain south
PSA- Twice a year
of the proposed site 21.749828° 35.064314°
SW02 during storms
entering the environment
* when accessible
115
Figure 4-4: Air quality monitoring locations in and around the CPF complex (refer to Table 4-5)
116
TABLE 4-5: AIR QUALITY MONITORING LOCATIONS, SAMPLING FREQUENCY AND

PARAMETERS (REFER TO FIGURE 4-4)
Station Latitude Longitude

Description Frequency Parameters
ID (S) (E)
Annually (dust fallout, Dust fallout, SO2,
passive sampling of NO2, H2S, organics,
T-3 Temane 3 well pad 21.7075° 35.08681° NO2, SO2, H2S, metals
organics), annually
(metals)
organics21), annually
(metals)
organics), annually
(metals)
organics), annually
(metals)
organics), annually
(metals)
Temane 10 well
T-10 21.7163° 35.03853° NO2, SO2, H2S, metals
pad
organics), annually
(metals)
Continuous (PM10), , PM10, dust fallout,
annually (dust fallout, SO2, NO2, H2S,
Temane 12 well passive sampling of organics, metals
T-12 21.7278° 35.08258°
pad NO2, SO2, H2S,
organics), annually
(metals)
Temane 13 well
T-13 21.6912° 35.08997° NO2, SO2, H2S, metals
pad
organics), annually
(metals)
Temane 15 well
T-15 21.7518° 35.064° NO2, SO2, H2S, metals
pad
organics), annually
(metals)
21 ‘Organics’ consist of benzene, toluene, ethylbenzene, xylene, styrene, formaldehyde, carbon tetrachloride
117

ID (S) (E)
Continuous (PM10), PM10, dust fallout,
annually (dust fallout, SO2, NO2, H2S,
Temane 16 well passive sampling of organics, metals
T-16 21.707° 35.0078°3
pad NO2, SO2, H2S,
organics), annually
(metals)
Temane 23 well
T-23 21.7458° 35.09886° NO2, SO2, H2S, metals
pad
organics), annually
(metals)
Annually (dust fallout, PM10, dust fallout,
PPZ boundary west passive sampling of SO2, NO2, H2S,
W north west of the 21.7458° 35.05198° NO2, SO2, H2S, organics, metals
CPF organics), annually
(metals)
passive sampling of SO2, NO2, H2S,
CPF western
Site 5 21.7491° 35.05824° NO2, SO2, H2S, organics, metals
boundary
organics), annually
(metals)
CPF north western
boundary
organics), annually
(metals)
CPF northern
boundary
organics), annually
(metals)
Annually (PM10, dust PM10, dust fallout,
fallout and passive SO2, NO2, H2S,
PPZ boundary
sampling of NO2, SO2, organics, metals
S south west of the 21.7595° 35.05581°
H2S, organics),
CPF
annually (metals) for
two years
PPZ boundary passive sampling of SO2, NO2, H2S,
E north east of the 21.7435° 35.06716° NO2, SO2, H2S, organics, metals
CPF organics), annually
(metals)
CPF eastern
boundary
organics), annually
(metals)
CPF southern
boundary
organics), annually
(metals)
PPZ boundary Annually (PM10, dust PM10, dust fallout,
N north - north west 21.7386° 35.05817° fallout and passive SO2, NO2, H2S,
of the CPF sampling of NO2, SO2, organics, metals
118

ID (S) (E)
H2S, organics),
annually (metals) for
two years
119
Figure 4-5: Soil monitoring points in and around the CPF complex (refer to Table 4-6)
120
TABLE 4-6: SOIL MONITORING LOCATION, FREQUENCY AND PARAMETERS (REFER TO FIGURE
4-5)
STATION ID LATITUDE (S) LONGITUDE (N) FREQUENCY PARAMETERS

Sasol Tem 1 21.7588° 35.05588° Annually
As per CPF procedure
Sasol Tem 14 21.7403° 35.06421° Annually based on Dutch target and
Sasol Tem 15 21.7505° 35.06444° Annually intervention guidelines
Sasol Tem 2 21.7708° 35.05022° Annually (Ministerie van Volkhuising,
Sasol Tem 3 21.7398° 35.05805° Annually Ruimtelyke Orderingen
Milieubeheer Versien
February 4th 2000)
T-G8 PX-2 21.7297° 35.05529° Annually
Figure 4-6: Noise monitoring locations around the CPF complex
121
4.2. SITE INSPECTION AND AUDITS
Mozambican regulations promulgated since 2004 require that regular internal and
external inspections and audits must be conducted to evaluate compliance with the
requirements of the EMP. Section 4.2.1 defines the site inspection requirements and
associated responsibilities for the Operations phase of the CPF complex. Section
4.2.2 defines the auditing requirements for the Operations phase of the CPF complex.
4.2.1. SITE INSPECTIONS
The ESO will undertake regular inspections of all works so as to identify any
Operations activities or components that are causing, or may cause, a potential
environmental impact. Inspections will be ongoing and will form part of the day-to-day
function of the ESO. The ESO will immediately bring any identified non-conformances
to the attention of the responsible party for rectification. Any potential problem areas
will be logged and managed as per the requirements of Section 4.4 (non-conformance
and preventative action).
4.2.2. AUDITS
The main goals of an EMP audit are to evaluate compliance with stipulated EMP
requirements, to identify any non-conformance and to assess whether objectives and
targets have been achieved. An audit programme and procedure shall be developed
by Sasol to ensure that the audits are sufficiently comprehensive and scheduled.
Auditing must consider the results obtained from monitoring to assess whether objects
and targets have been met, and whether there is any non-conformance with stipulated
EMP and legal requirements. The audit must also assess whether EMP
implementation has been undertaken according to planned arrangements and that
the EMP itself is being appropriately updated based on Operations requirements and
impacts identified. The audit shall confirm that any identified corrective action has
been undertaken and assess the effectiveness of that action.
Sasol shall develop a procedure for conducting EMP audits that shall incorporate
details of:
 Audit approach;
 Scheduling;
122
 Reporting; and
 Responsibilities.
Table 4-7 defines the minimum requirements in terms of audit types and frequency
that shall be conducted during the operational phase of the CPF complex operations.
TABLE 4-7: MINIMUM AUDITING REQUIREMENTS FOR THE OPERATIONAL PHASE OF THE
CPF AND ASSOCIATED INFRASTRUCTURE
Nature and scope of Frequency of

Conducted by Reported to
audit audit
Internal EMP ESO Operations Manager Entire operations
compliance audit – all SHE Manager to be covered
Operations annually.
components
External EMP Independent ESO Independent
compliance audit consultant – SHE Manager audit annually as
- all Operations appointed by Operations Manager per Government
components Sasol MICOA (with action plan regulations
of how to address
findings)
Government audit MICOA ESO As requested by
As per the SHE Manager Government
requirements of Operations Manager
Government.
Note:
1. It is in the nature of environmental auditing to be conservative. Wherever latitude

exists in interpretation, the auditor will take the most conservative (worse-case)
stance. Credit will only be given for management actions that demonstrably comply
with the Operations standard. Records should be kept of all actions taken to meet the
requirements of the EMP. Similarly records and motivations must be kept of all
changes / modifications to the EMP.
4.3. REVIEWS
Site management at the CPF complex shall establish an environmental committee.

This committee shall meet on at least a monthly basis to review environmental
performance, including incidents/non-conformances reported, corrective actions
implemented, monitoring results, EMP compliance, internal and external audit findings
123
and remedial actions taken. Management actions and planning shall be specified
based on the results of the review. The monthly meeting shall be documented.
In addition, a management review meeting shall be held on at least an annual basis

to review the status of Environmental Management and EMP implementation and to
ensure the continued effectiveness of the EMP as well as its appropriateness. The
review meeting shall be attended by senior management. The meeting shall be
documented.
The management review should:
 Review EMP objectives and evaluate the need for new or revised objectives,
as appropriate;
 Set new objectives as appropriate;
 Evaluate environmental performance and the effectiveness of the EMP by

reviewing monitoring and audit results;
 Evaluate changing circumstances and how these may influence and be

reflected in the EMP. This could include changes to permits, contracts, loan
agreements etc;
 Examine the results of any action items from the previous management review
meeting; and
 Examine the remedial actions taken to address non compliances and close out
of any external audit findings.
4.4. CORRECTIVE AND PREVENTIVE ACTION
The need for setting corrective action will arise from deviations from:
 A predetermined baseline or limit (as detected through monitoring); or
 EMP requirements.
In this regard, Sasol shall establish an incident and non-conformance reporting

procedure. The procedure shall include details for:
 Ensuring the recording of incidents / non-conformances;
 Reporting channels for incidents / non-conformances; and
124
 The identification of corrective and preventative action measures.
Corrective actions shall be identified based on incident / non-conformances reported

and on the results of EMP monitoring, internal or external EMP audits and/or
management review. Corrective action should result in:
 The implementation of a specific action(s) to remedy the identified

deficiency(ies); or
 A change to the targets or objectives set in the EMP; and
 Corrective actions implemented shall be documented.
Should it be considered by Government Authorities that operational activities are

causing unacceptable environmental damage; the ESO and Operations Manager
through the Corporate Affairs Department will immediately consult with the
Government and agree on the remedial measures to be taken. Such agreed
measures shall be undertaken immediately to prevent further damage and to repair
any damage that may have occurred.
125
5. COMPETENCY, TRAINING AND AWARENESS CREATION
Those persons who are involved in activities that could result in an environmental
impact(s) must receive appropriate environmental awareness training (and must also
possess the necessary skills so as to successfully and responsibly undertake their
tasks). All employees must be made aware of Sasol’s undertaking to conduct the
proposed activities in a manner that is respectful to local people, their land and
resources and sensitive biophysical habitats. Training shall take the form of, but not
be limited to: induction training, use of educational posters and toolbox talks.
During these training sessions, the following principles should be presented /

discussed:
 SPI’s environmental, social health and safety policies and applicable

Mozambican environmental regulations.
 EIS and EMP commitments.
 Restrictions and procedures for Operations.
 Restrictions and procedures for collection, treatment and disposal of waste and
hazardous substances.
 Statement and clarifications of Sasol’s communications policies.
 Fire fighting procedures.
 Procedure for emergency response.
 Procedures for incident reporting and handling.
 Need to refrain from destruction of animals and plants, indiscriminate

defecation, waste disposal and/or pollution of local soil and water resources.
6. CONTINGENCY AND DECOMMISSIONING PLANNING
Sasol shall make financial provision for unforeseen potential impacts that may require
specific mitigation / management measures. Furthermore, Sasol shall plan for the
CPF complex and infrastructure decommissioning when it is relevant by:
 Preparing a roll-over five year decommissioning plan (Operations Manager);
126
 Making financial provision for decommissioning requirements (Operations

Manager); and
 Liaising with communities and government with regard to decommissioning

objectives (CLO and ESO).
7. EMERGENCY PREPAREDNESS AND RESPONSE
Sasol shall establish and maintain procedures to identify the potential for, and to
respond to accidents and emergency situations in accordance with recognised
international standards. The procedure(s) shall also address measures to prevent
such situations and to mitigate environmental impacts that may be associated with
them (SHE Manager).
The emergency procedure(s) shall include the establishment of a network of

communication between Sasol, employees, contractors, available emergency
services including police, traffic police, fire departments, community associations,
specialist services etc. that may be available.
The emergency plan shall be tested on a regular basis through the use of drills and
mock emergencies so as to identify and rectify any shortcomings (Production
Manager and SHE Manager).
8. REPORTING REQUIREMENTS
All reporting shall be as per SPT reporting structures and as specified elsewhere in
the EMP, or as per legal requirements.
In addition to all reporting requirements identified in the EMP, records shall be kept of
all monitoring results, monitoring reports, incident records, audit reports and
management reviews. Minutes of all environmental Operations meetings shall be
maintained.
Where monitoring reports are prepared by independent specialists, the recommended

actions in the reports shall be recorded, assessed and acted upon.
All reports shall be managed as per the requirements of Section 9.
127
9. DOCUMENT CONTROL
The EMP forms the basis for environmental management on site. Based on the results
of the performance assessment and review process (Section 4), the EMP may be
modified as the Operations progress. Modifications shall only be permitted by the SHE
Manager and shall be approved by MICOA. A single master copy of this EMP shall
be retained in the document control system. All changes to the EMP shall be made
as per the SPT Document Control Procedure (section 4.2.3 of SPT Integrated
Management System) to which all affected parties shall comply. This procedure
defines document modification, distribution, retention and management of EMP
revisions.
The ESO shall ensure that any modifications are communicated, explained to and
discussed with all affected parties (i.e. the authorities, contractors, employees,
Operations Manager and any affected party who requests this information).
128
APPENDIX 1: Sasol SH&E Policy (Revision 4, June 2012)

APPENDIX 2: Internal and External Reports used to inform Revision 4 of

the o-EMP
2004
COMMON GROUND. July 2003. Natural Gas Project. Consolidated Executive Summary and
Update.
DEACON A. June 2003. Sasol Gas Pipeline: A review of the effect of construction of the
pipeline on the aquatic ecology of selected rivers and streams in the Crocodile River
catchment.
DEACON A. December 2003. Sasol Gas Pipeline: Aquatic ecosystem integrity of the major
river crossings.
EKOREHAB. 20 September 2002. Audit Report 1. Secunda - Komatipoort pipeline.
EKOREHAB. December 2002. MOZAMBIQUE - SECUNDA PIPELINE PROJECT (South
African section). EMP Compliance audit report 2B.
EKOREHAB. March 2003. MOZAMBIQUE - SECUNDA PIPELINE PROJECT (South African
section). EMP Compliance audit report 3.
EKOREHAB. May 2003. MOZAMBIQUE - SECUNDA PIPELINE PROJECT (South African
section). EMP Compliance audit report 4.
EKOREHAB. May 2004. MOZAMBIQUE - SECUNDA PIPELINE PROJECT (South African
section). Quarterly Independent EMP Compliance Audit Report 6.
Metago Environmental Engineers. June 2004. Draft Closure Report for the Temane Drilling
Project.
SEED. 23-27 June 2003. Sasol Natural Gas Project: Environmental Management Plan Audit
1 - Temane Drilling Operations.
SEED. 25-29 August 2003. Sasol Natural Gas Project: Environmental Management Plan
Audit 2 - Temane Drilling Operations.
SEED. 17-21 November 2003. Sasol Natural Gas Project: Environmental Management Plan
Audit 3 - Temane Drilling Operations.
SEED. 23-27 June 2003. Sasol Natural Gas Project: Environmental Management Plan Audit
1 - Temane Well Sites, Flowlines, Access Roads and Central Processing Facility.
SEED. 25-29 August 2003. Sasol Natural Gas Project: Environmental Management Plan
Audit 2 - Temane Well Sites, Flowlines, Access Roads and Central Processing Facility.
SEED. 17-21 November 2003. Sasol Natural Gas Project: Environmental Management Plan
Audit 3 - Temane Well Sites, Flowlines, Access Roads and Central Processing Facility.
SEED. 1 - 4 October 2002. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit
Report No. 1.
SEED. 9-13 December 2002. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit
Report No. 2.
SEED. 3-7 March 2003. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit Report
No. 3.
SEED. 13-19 June 2003. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit
Report No. 4.
SEED. 17-22 October 2003. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit
Report No. 5.
SEED. 16-21 January 2004. Sasol Gas Supply Project (Ressano Garcia to Temane): Audit
Report No. 6.
Shangoni Management Services (Pty) Ltd. September 2003. Mozambique - Secunda Natural
Gas Pipeline Project (South African Section). Quarterly Independent Environmental
Management Plan Compliance Audit Report 5.
SRK. July 2003. SASOL PETROLEUM MOZAMBIQUE LTA SASOL PETROLEUM TEMANE
LTA Resettlement and Compensation Audit on the Central Processing Facility/Gas Field
Development (Temane, Mozambique) of the Sasol Natural Gas Project. AUDIT 1. Report No.
313395/A.
SRK. July 2003. REPUBLIC OF MOZAMBIQUE PIPELINE INVESTMENT COMPANY (PTY)
LTD Resettlement and Compensation Audit on the Mozambique portion of the Pipeline for the
Sasol Natural Gas Project. AUDIT 1. Report No. 313395/B.
SRK. February 2004. SASOL PETROLEUM MOZAMBIQUE LTA SASOL PETROLEUM
TEMANE LTA Resettlement and Compensation Audit on the Central Processing Facility/Gas
Field Development (Temane, Mozambique) of the Sasol Natural Gas Project, AUDIT 2.
Report No. 313395/2/A.
SRK. February 2004. REPUBLIC OF MOZAMBIQUE PIPELINE INVESTMENT COMPANY
(PTY) LTD Resettlement and Compensation Audit on the Mozambique Portion of the Pipeline
for the Sasol Natural Gas Project. AUDIT 2. Report No. 313395/2/B.
SRK. August 2004. SASOL PETROLEUM MOZAMBIQUE LTA SASOL PETROLEUM
Field Development (Temane, Mozambique) of the Sasol Natural Gas Project AUDIT 3. Report
No. 313395/2/A.
SRK. August 2004. SASOL PETROLEUM MOZAMBIQUE LTA SASOL PETROLEUM
Field Development (Temane, Mozambique) of the Sasol Natural Gas Project AUDIT 3. Report
No. 313395/2/B.
2005
Ernst Basson Attorneys, December 2004. Legal Compliance Review Report of Sasol
Petroleum Temane Limitada.
Global Conformity Services (Pty) Ltd SABS ISO 14001 Stage 2 Assessment and Surveillance
Report for the Mozambique-South Africa Pipeline performed on behalf of Sasol Gas. March
2004.
Global Conformity Services (Pty) Ltd SABS ISO 9001/14001 Combined Systems and
Surveillance Audit for the Mozambique-South Africa Pipeline performed on behalf of Sasol
Gas. October 2004.
Mark Wood Consultants, July 2003. Sasol Natural Gas Project: Regional Environmental and
Social Assessment.
Mark Wood Consultants, November 2003. Sasol Gas Supply Project: Environmental
Management Plan for a Proposed Natural Gas Pipeline between Ressano Garcia and
Temane. Part 3: Operation and Decommissioning.
Mark Wood Consultants, September 2004. Natural Gas Project Environmental Maintenance
Manual for the MSP Pipeline.
Mark Wood Consultants, November 2004. Mozambique-Secunda Pipeline: Revegetation
Monitoring. Prepared by Dr M Mentis.
Mark Wood Consultants, January 2005. Mozambique-Secunda Pipeline: Revegetation
Monitoring. Prepared by Dr M Mentis.
MGA Advogados and Consultores, 2005. Sasol Petroleum Temane Environmental Legal
Register.
Metago Environmental Engineers, December 2003. Environmental Management Plan for the
Operation of the Temane Well Sites, Flow Lines, Access Roads and the Sasol Temane (SPT)
Plant. Report No 7, Final Draft Version 4.
Metago Environmental Engineers, November 2004. Final Environmental Report on the
Installation of the Gas Flow lines across the Govuro River and Floodplain.
Metago, November 2004. Environmental Closure Report for the Construction of the Temane
Wellheads, Flowlines, Access Roads and a Central Processing Facility, Inhambane Province,
Mozambique. Report No.1 Draft.
Metago, 2004. Draft Operational Environmental Monitoring Report for the SPT Operations.
February to July 2004.
Sasol, 2004. Draft Localisation Policy.
TÜV Rheinland Group, December 2004. Certification Audit Report pursuant to DIN EN ISO
14001:1996 for the company Sasol Petroleum Limitada Mozambique. Document Reference
CN: 01 104 042 161.
2006
Audit Reports
Ernst Basson Attorneys, 2004. Legal Compliance Review Report of Sasol Petroleum Temane
Limitade, December.
Ernst Basson Attorneys, 2005. Environmental Legal Audit Report Report: Sasol Gas MSP
and Alrode Depot, October.
Global Conformity Services (Pty) Ltd, 2005. SANS ISO 9001/14001/OHSAS 18001 Integrated
Audit Report; Sasol Gas MSP Process, February.
Mark Wood Consultants, 2005. NGP Resettlement and Compensation Monitoring and
Evaluation Programme. Independent Audit, September.
MGA Advogados and Consultores, 2005. Sasol Petroleum Temane Environmental Legal
Register.
MICOA, 2005. Environmental Audit of the Pande and Temane Gas Exploration Project.
Reference 790/DNAIA/GDN/05, October.
MSE Partnership, 2005. External Audit of Sasol Petroleum Temane Seismic Project in 2005.
SABS, 2005. Combined Management Systems Audit. Sasol Gas MSP Process. Reference
EM140306/LS 3360/OHS 180045, November.
SABS, 2005. Combined Management Systems Audit. Sasol Gas MSP Process. Reference
EM140306/LS 3360/OHS 180045, March.
Seed, 2005. Audit Report No. 7. Sasol Gas Supply Project (Ressano Garcia to Temane),
August.
Shepstone & Wylie Attorneys, 2005. Environmental and Social Legal Compliance Audit of the
SPT CPF and the ROMPCO Pipeline Operations, 25 November.
SRK, 2004. Resettlement and Compensation Audit on the Mozambique Portion of the
Pipeline for the Sasol Natural Gas Project ROMPCO Audit 3. Final. Report No. 313395/3/B,
August.
SRK, 2005. Environmental Legal Compliance Assessment Report included in Shepstone &
Wiley Attorneys, 2005, Environmental and Social legal compliance audit of the Sasol
Petroleum Temane Limitada (SPT) Central Processing Facility and the Republic of
Mozambique Pipeline Investment Company (ROMPCO) Pipeline Operations.
SRK, 2005a. Environmental and Social Legal Compliance Audit, included in Shepstone &
Wiley Attorneys, 2005, Environmental and Social legal compliance audit of the Sasol
Petroleum Temane Limitada (SPT) Central Processing Facility and the Republic of
Mozambique Pipeline Investment Company (ROMPCO) Pipeline Operations.
TÜV Rheinland Group, 2005. Report about the upgrade Audit pursuant to ISO 14001:2004 -
CN 01 104 042 161. Prepared on behalf of Sasol Petroleum Temane Limitada. Rev0,
November.
World Bank SARG Supervision Mission, 2006, Aide Memoire, April 2006.
Sasol Reports
IDR, 2005. Natural Gas Project. For and on behalf of Sasol Petroleum Limitade and Republic
of Mozambique Pipeline Investments Company (Pty) Ltd.
Sasol, 2005. Management Programme to meet RESA Obligations: Draft for Comment/Input,
12 June 2005.
Sasol Mozambique, 2005. Minutes of a Discussion Session on the RESA held on 31 May at
the VIP Hotel in Maputo.
Sasol Mozambique, 2005b. Environmental Task Team Meeting Minutes, November.
Sasol Mozambique, 2005. Corporate Social Investment Policy and Strategy, October 2005.
SPI, 2005. Seismics: First Quarterly Environmental Report. Prepared for MICOA, June.
SPT, 2005. Environmental Performance Report, Sasol Petroleum Temane. August 2004 to
January 2005. Prepared for MICOA, March.
SPT, 2005a. Environmental Performance Report, Sasol Petroleum Temane. February 2005 to
July 2005. Prepared for MICOA, October.
SPT, 2005b. Ecological Monitoring Report: Flow Lines. March to July 2005.
SPT, 2005c. Ecological Monitoring Report: Borrow Pits. March to July 2005.
SPT, 2005d. Record of a Workshop on Social Development held on 18 August 2005 at the
VIP Hotel in Maputo, 25 August.
SPT, 2005e. Seismics Project. First Quarterly Environmental Report. April to June 2005.
Prepared for MICOA, June.
Specialist Studies
Deacon, A. 2005. MSP Pipeline, Temane to Ressano Garcia: Rehabilitation Monitoring for
2005.
Deacon, A. 2005a. MSP Komatipoort to Secunda: Aquatic Ecosystems Integrity of the Major
River Crossings, April.
Ecoserv (Pty) Ltd, 2005. Air Quality Monitoring prepared for Sasol Petroleum Limitade:
Natural Gas Central Processing Facility. Reference SS0378, 12 April.
Ecoserv (Pty) Ltd, 2005a. Air Quality Monitoring Report - Additional SO2 and NOx sampling
prepared for Sasol Petroleum Temane Limitade: Natural Gas Central Processing Facility.
Reference SS0378, 12 December.
Ecoserv (Pty) Ltd, 2005b. Dust Deposition Monitoring Survey prepared for Sasol Temane:
Reference SS0378, 5 July.
Ecosun, 2004. Aquatic Ecological Baseline Assessment: Sections of the Govuro River
associated with a Flowline Crossing, March.
Ecosun, 2004a. Aquatic Ecological Baseline Assessment: Sections of the Govuro River
associated with a Flowline Crossing - FINAL, September.
Ecosun, 2005. Aquatic Ecological Baseline Assessment: Sections of the Govuro River
associated with a Flowline Crossing - FINAL, July.
Impacto Lda, 2005. Draft Report on Risk Assessment of Condensate Transport between
Temane and Maputo, August.
Impacto/Mark Wood Consultants, 2005. Sasol Seismic Environmental Management Plan for
Seismics & Exploration. Addendum 3.
Mark Wood Consultants, 2003. Sasol Natural Gas Project: Regional Environmental and
Social Assessment, July.
Mark Wood Consultants, 2001. Sasol Gas Supply Project: Environmental Management Plan
for a Proposed Natural Gas Pipeline between Ressano Garcia and Temane. Part 3:
Operation and Decommissioning.
Mentis M. 2005. Mozambique-Secunda Pipeline. Follow up Rehabilitation. Revision 1.
Prepared on behalf of Mark Wood Consultants.
Mentis M. 2005a. Mozambique-Secunda Pipeline. Highveld Wetlands Project. Revision 0.
Prepared on behalf of Mark Wood Consultants.
Metago Environmental Engineers, 2003. Environmental Management Plan for the Operation
of the Temane Well Sites, Flow Lines, Access Roads and the Sasol Temane (SPT) Plant.
Report No 7, Final Draft Version 4, December 2003.
MRH Groundwater Services, 2005. Temane Monitoring and Production Borehole Evaluation,
20 September.
2007
Audit Reports
IFC, 2006. Summary Report, Condensate Facilities Matola, November
LCS, Legislative Compliance Specialists, 2006, Occupational Health and Safety Legal
Compliance Audit, Sasol Petroleum Temane, Mozambique, October
MICOA, 2006. Report on the Second Public Environmental Audit conducted at Sasol,
September
Shepstone and Wylie Attorneys, 2006. Environmental and Social Legal Compliance Review
Audit for the Sasol Petroleum Temane Limitada ("SPT") Central Processing Facility in
Mozambique, December
TÜV Rheinland Group, 2006. Report on the 1st Surveillance Audit for OHSASA 18001:1999
for the company
Sasol Petroleum Limitada, Mozambique, CN:01 113 050220, November
TÜV Rheinland Group, 2006. Report on the 2nd Surveillance Audit pursuant to
ISO14001:2004 for the company Sasol Petroleum Limitada, Mozambique, CN:01 104
042161, November
TÜV Rheinland Group, 2006. Report on the 2nd Surveillance Audit pursuant to DIN EN ISO
9001:2000 for the company Sasol Petroleum Limitada, Mozambique, CN:01 100 045736,
November
Sasol Reports
IDR, 2006. Natural Gas Project. For and on behalf of Sasol Petroleum Limitada and Republic
of Mozambique Pipeline Investments Company (Pty) Ltd
Sasol and the Government of Mozambique, 2007. Compensation Procedures for Exploration
Activities, Rev 5, January
SPT, 2006. Second Discussion Session on the RESA Regional Environmental and Social
Assessment, Minutes of the Meeting held 3 November at the Girassol Hotel, Maputo
SPT, 2006. Environmental Performance Report Sasol Petroleum Temane, August 2005-
January 2006. Prepared for MICOA, April
SPT, 2006. Environmental Performance Report Sasol Petroleum Temane, February 2006 -
July 2006. Prepared for MICOA, August
SPT, 2006. "Final Report on the Performance of the various Water and Effluent Treatment
Unit Processes”, prepared by OI Mooketsi
SPT, 2006. Works Instruction for Industrial Effluent Treatment Plant, UTIL/WI/02/02, Rev 3,
August
SPT, 2006. Abridged procedure for the classification and investigation of safety, health and
environment and quality related incidents (non-conformances), MS/P/05/06. Abridged version,
April 2006
Sasol Technology (Pty) Ltd, 2006. Water System Management Plan and Implementation
Strategy, prepared by Sunil Pakiri, December
Sasol Technology, 2007. Progress Report on Environmental liabilities and rehabilitation on
sites in
Mozambique. Sasol Technology, Environmental and Risk Engineering. 5 February 2007
Specialist Reports
Consultec and ERM, 2006. EIA for Sasol's Proposed Hydrocarbon Exploration Project in Off-
shore Blocks 16 and 19
Consultec and ERM, 2006, Environmental Management Plans for Exploration Activities in Off-
shore Blocks 16 and 19, December
Deacon AR, 2006. The Sasol Natural Gas Project: Mozambique to South Africa. Pipeline
Rehabilitation Survey. May
Deacon AR, 2006. Sasol Gas Pipeline Monitoring: Aquatic Ecosystem Integrity of the Major
River Crossings.
Ecoserv, 2006. Air Quality Monitoring Report prepared for SPT, Ref SS0378, January
Ecoserv, 2006a. Air Quality Monitoring Report prepared for SPT, Ref SS0462, July
Envirobiz Africa, 2006. Mozambique-Secunda Pipeline, Fraser Alexander Rehabilitation
Contract Progress Reports 1-12, January 06 - December 06.
Enviroserv, 2006. Waste removal Inventory and Invoice, Phase I, May
Enviroserv, 2006. Waste removal Inventory and Invoice, Phase II, August
Mark Wood Consultants, 2006. Sasol Natural Gas Project. Resettlement and Compensation
Monitoring and Evaluation Programme. Independent Audit. November
Prof L van Rensburg, 2005. North West University, Department of Environmental Science and
Management, Correspondence to T Stenden, "Some Comment with Regard to the Irrigation
within the CPF"
Rison Groundwater Consulting, 2006 Groundwater Sampling at the Sasol Temane Gas Field,
Central
Processing Facility, Mozambique, April
Rison Groundwater Consulting, 2006 Groundwater Monitoring at the Sasol Temane Gas
Field, Central
Processing Facility, Mozambique, October
SRK Consulting, 2006. Environmental Impact Report for the Temane-Secunda Natural Gas
Pipeline Upgrade. Report prepared for Sasol Gas (Pty) Ltd. Report No. 368327. December
2008
Audit Reports
DuPont, 2007. Safety Management Evaluation for Sasol Petroleum International: Temane
Operations. March 2007.
IFC, 2006. Summary Report, Condensate Facilities Matola, November 2006.
Impacto Lda., 2007. Independent Environmental Management Plan Audit. October 2007.
INP Audit, 2007. Combined findings and close out/ management actions. 13-17 September
2007.
LCS, Legislative Compliance Specialists, 2006, Occupational Health and Safety Legal
Compliance Audit, Sasol Petroleum Temane, Mozambique, October 2006.
MICOA, 2006. Report on the Second Public Environmental Audit conducted at Sasol,
September 2006.
MICOA, 2007. Summary of MICOA audit findings: 27-28 November 2007.
Mozambique, December 2006.
Mozambique, December
Mozambique and The Republic of Mozambique Pipeline Investment Company (Pty) Ltd
(ROMPCO) and Sasol Gas. January 2008.
TÜV Rheinland Group, 2007. Report on the 2nd Surveillance Audit for OHSAS 18001:1999
for the company Sasol Petroleum Limitada, Mozambique, CN:01 113 050220, November
2007.
TÜV Rheinland Group, 2007. Report on the Repeat Audit: ISO 14001:2004 for the company
Sasol Petroleum Limitada, Mozambique, ZN:01 104 042161.
TÜV Rheinland Group, 2006. Report on the 2nd Surveillance Audit pursuant to DIN EN ISO
9001:2000 for the company Sasol Petroleum Limitada,
Sasol Reports
IDR, 2005. Natural Gas Project. Annual Integrated Disclosure Report. For and on behalf of
Sasol Petroleum Limitada and Republic of Mozambique Pipeline Investments Company (Pty)
Ltd.
Ltd.
Ltd.
Sasol and the Government of Mozambique, 2007. Compensation Procedures for Exploration
Activities, Rev 5, January 2007.
SPT, 2006. Second Discussion Session on the RESA Regional Environmental and Social
Assessment, Minutes of the Meeting held 3 November 2006 at the Girassol Hotel, Maputo.
SPT, 2006. "Final Report on the Performance of the various Water and Effluent Treatment
Unit Processes", prepared by OI Mooketsi.
SPT, 2006. Works Instruction for Industrial Effluent Treatment Plant, UTIL/WI/02/02, Rev 3,
August 2006.
SPT, 2006. Abridged procedure for the classification and investigation of safety, health and
environment and quality related incidents (non-conformances), MS/P/05/06. Abridged version,
April 2006.
SPT, 2007. Monthly environmental reports for SPT.
SPT, 2007. Environmental Performance Report Sasol Petroleum Temane. August 2006 -
January 2007.
SPT, 2007. Environmental Performance Report Sasol Petroleum Temane. February - July
2007.
SPT, 2008. Environmental Performance Report Sasol Petroleum Temane. August 2007 -
January 2008.
Sasol Technology (Pty) Ltd, 2006. Water System Management Plan and Implementation
Strategy, prepared by Sunil Pakiri, December 2006.
Sasol Technology, 2007. Progress Report on Environmental Liabilities and Rehabilitation on
Sites in Mozambique. Sasol Technology, Environmental and Risk Engineering. 5 February
2007.
Sasol Technology, 2007. Kutiyissana Project Quarterly Report Nr.01. May-June 2007.
Sasol, 2007. Minutes of Community Liaison Forum meeting 26 March 2007
Sasol, 2007. Minutes of Community Protection and Liaison Forum 20 July 2007.
Sasol, 2007. MSP Pipeline: Monitoring and Evaluation Report. Report No 12. November
2007.
Sasol, 2007. Gas Field Development (Temane and Pande Gas Fields): Monitoring and
Evaluation Report. Report No 12. November 2007.
Tera Environmental Consulting. 2006. Evaluation of Sasol 2007 drilling mud and drilling waste
disposal options: Pande, Inhassoro and Temane fields. December 2006.
Tera Environmental Consulting. 2007. Technical feasibility of deep well re-injection of whole
drilling mud and drill cuttings. April 2007.
Tera Environmental Consulting. 2007. Notification of Change and Request for Approval to Re-
inject "spent' completion fluids into Temane 22. Document prepared for MICOA, INP and ARA
SUL. February 2007.
Specialist and Other Reports
AICC (African Institute of Corporate Citizenship), 2007. Workshop Proceedings of Southern
Africa Corporate Citizenship Programme: Exploring partnerships to build sustainable
communities in Mozambique, held at Girassol Bahia Hotel, Maputo 19 - 20 February 2007.
Alberta Energy and Utilities Board, 1994. Injection and Disposal Wells - Well classifications,
Completion, Logging and Testing Requirements. Directive 051.
Alberta Energy and Utilities Board, 1996. Guide 50 - Drilling Waste Management.
Alberta Energy and Utilities Board, 2005. Assessing Drilling Waste Disposal Areas:
Compliance Options for Reclamation Certification.
Consultec and ERM, 2006. EIA for Sasol's Proposed Hydrocarbon Exploration Project in
Offshore Blocks 16 and 19, 2006.
Consultec and ERM, 2006, Environmental Management Plans for Exploration Activities in
Offshore Blocks 16 and 19, December, 2006.
Deacon AR, 2005. The Sasol Natural Gas Project: Mozambique to South Africa. 2005
Pipeline Rehabilitation Survey (Mozambique Section). MARK CHECK IF TITLE SAME IN
2005 AS IN 2007
Deacon AR, 2007. The Sasol Natural Gas Project: Mozambique to South Africa. 2007
Pipeline Rehabilitation Survey (Mozambique Section). May 2007.
Deacon AR, 2007. Sasol Gas Pipeline Monitoring: Aquatic Ecosystem Integrity of the Major
River Crossings.
Deacon AR, 2007. Sasol Gas Pipeline Monitoring: 2006 River Monitoring Report (South
African Section). January 2007.
DD Science cc., 2007. Environmental Monitoring Preliminary Test Report (Incinerator Ash)
June 2007.
Ecoserv, 2006. Air Quality Monitoring Report prepared for SPT, Ref SS0378, January
Ecoserv, 2006a. Air Quality Monitoring Report prepared for SPT, Ref SS0462, July
Ecoserv, 2007a. Air Quality Monitoring Report prepared for SPT, Ref SS0603, Oct 2007.
Ecoserv, 2007b. Air Quality Monitoring Report prepared for SPT, Ref SS0530, April 2007.
Ecosun, 2005. Aquatic Ecological Integrity Assessment: sections of the Govuro River
associated with a flowline crossing, SASOL Natural Gas Project (NGP). April 2005
Envirobiz Africa, 2008. Mozambique-Secunda Pipeline: Highveld Wetlands. February 2008.
Envirobiz Africa, 2008. Mozambique-Secunda Pipeline: Fraser Alexander Rehab &
Maintenance Contract - Progress Reports 1 (November 2007), 2 (January 2008) and 3
(February 2008).
Envirobiz Africa, 2008. Mozambique-Secunda Pipeline: Maintenance Manual - Phase 1:
Preliminary Risk Assessment.
Impact Lda, 2005. Sasol Natural Gas Project, Environmental Management Plan for the Road
Transport of Condensate from the Sasol Temane Production Facility. July 2005.
Javelin Trucking, 2008. Transport statistics for 2007.
Mark Wood Consultants, 2001. Environmental Management Plan for a proposed pipeline
between Ressano Garcia and Temane. November 2001.
Monitoring and Evaluation Programme. Independent Audit. November 2006.
Monitoring and Evaluation Programme. Independent Audit. November 2007.
Prof L van Rensburg, 2005. North West University, Department of Environmental Science and
Management, Correspondence to T Stenden, "Some Comment with Regard to the Irrigation
within the CPF".
Rison Groundwater Consulting, 2007. Groundwater Quality Monitoring - Sasol Temane.

November 2007.
SANS (South African National Standard) 1929:2004.
SRK Consulting, 2006. Environmental Impact Report for the Temane-Secunda Natural Gas
Pipeline Upgrade. Report prepared for Sasol Gas (Pty) Ltd. Report No. 368327. December
2006.
Tera Consulting, 2007. Sasol 2007 Drilling Campaign: Disposal of Drill Muds and Cuttings.
Document prepared for MICOA, INP and ARA SUL. March 2007.
Tera Environmental Consulting & M. Cosijn, 2007. Evaluation of Sasol 2007 Drilling Mud and
Drilling Waste Disposal Options - Pande, Inhassoro and Temane Fields. Prepared for Sasol
Temane Lda. Unpublished. March 2007.
Tera Environmental Consulting & M. Cosijn, 2007. Technical feasibility of deep well re-
injection of whole drilling mud and drill cuttings. 20 April 2007.
Tera Environmental Consulting & M. Cosijn, 2007. Notification of Change and Request for
Approval to Re-inject "spent" Completion Fluids into Temane-22. Document prepared for
MICOA, INP and ARA-SUL. February 2007.
Tera Environmental Consulting & M. Cosijn, 2007. Sasol 2007 Drilling Campaign: Disposal of
Drill Muds and Cuttings Downhole. Document Prepared for MICOA, INP and ARA-SUL.
WK Construction, 2007. Method Statement: Excavation and Backfilling of Wet Areas.
2010
Audit Reports
IFC. 2006. Summary Report, Condensate Facilities Matola, November
IMPLEX. 2009. Environmental Legal Compliance Audit - Sasol Gas. June 2009
IMPLEX. 2009. Health, Safety, Legal Compliance Audit - Sasol Gas. May 2009
Metago. 2009. Environmental Internal Audit Reports (sewage & industrial effluent
management; waste management and monitoring; air emissions management and
monitoring; leachate management; transformers and substations, and general site
observations). July-August 2009
Shepstone and Wylie Attorneys. 2009. Environmental and Social Legal Compliance Review
Mozambique and The Republic of Mozambique Pipeline Investment Company (Pty) Ltd
(ROMPCO) and Sasol Gas. December 2009
TÜV Rheinland Group. 2009. Audit Report as per ISO 14001: 2004 for SPT.
CN:01104042161
World Bank SARG Supervision Mission. 2007. Aide Memoire, April
Sasol Reports
De Beer, P. 2010. Final Effluent Sodium Adsorption Ratio Improvement. Report for SPT CPF
IDR. 2006. Natural Gas Project. For and on behalf of Sasol Petroleum Limitada and Republic
of Mozambique Pipeline Investments Company (Pty) Ltd. Prepared by Mark Wood
Consultants
Consultants
Consultants
Consultants
Nkomo, B. 2009. Summary of 1st Monitoring and Evaluation visit to Pande Gas Field for 2009
Sasol and the Government of Mozambique. 2007. Compensation Procedures for Exploration
Activities, Rev 5, January
SPT. 2009. Monthly environmental reports for SPT
SPT. 2009. Environmental Performance Report Sasol Petroleum Temane. February 2009-
July 2009. Report No. 11. Prepared for MICOA
Sasol & World Vision. 2010. Semi-annual ASCAS report: Guija District - Mubangoene.
February 2010
Sasol Technology. 2007. Kutiyissana Project Quarterly Report Nr.01. May-June 2007
UHDE. 2007. Temane Central Processing Facility Expansion - Project Design Basis (U-JP-1-
0003 001)
Specialist Reports
Cosijn, M. 2008. Temane and Inhassoro Ecological Monitoring Report. Report for Sasol
Cosijn, M. 2009. SPT Ecological Monitoring Report 2009. November
Cosijn, M. 2009. Sasol Environmental Close-out Report: 2009 Temane PSA Onshore Seismic
Campaign. March to Dec 2009
Da Castro, T & Cosijn, M. 2009. Report on the erosion in the main channel of the relic
floodplain between Pande 18 and Pande 19
Deacon A. 2005. The Sasol Natural Gas Project: Mozambique to South Africa. 2005 Pipeline
Servitude Rehabilitation (Mozambique Section). July 2005. Prepared for Mark Wood
Consultants
Servitude Rehabilitation (Mozambique Section). May 2006. Prepared for Mark Wood
Consultants
Consultants
Consultants
Servitude Rehabilitation (Mozambique Section). June 2009. Prepared for Mark Wood
Consultants
Deacon A. 2005. The Sasol Natural Gas Project: Mozambique to South Africa: Aquatic
Ecosystem Integrity of the Major River Crossings (South Africa Section). April 2005. Prepared
for Mark Wood Consultants
Ecosystem Integrity of the Major River Crossings (South Africa Section). November 2006.
Prepared for Mark Wood Consultants
Ecosystem Integrity of the Major River Crossings (South Africa Section). February 2008.
Ecosystem Integrity of the Major River Crossings (South Africa Section). May 2009. Prepared
Ecosystem Integrity of the Major River Crossings (South Africa Section). January 2010.
Drizit Environmental cc. 2010. Report for the Land Spreading of NORM and Disposal of
Acetic Acid at Pande Base Camp. January 2010
Ecoserv. 2007. Air Quality Monitoring Report prepared for SPT, Ref SS0603, Oct 2007
Ecoserv. 2007. Air Quality Monitoring Report prepared for SPT, Ref SS0530, April 2007
Ecoserv. 2009. Air Quality Monitoring Report prepared for SPT, Ref SS0820, February 2009
Ecoserv. 2009. Air Quality Monitoring Report prepared for SPT, Ref SS00856, July 2009
Ecoserv. 2010. Emissions Testing Report, Ref SS0948, February 2010
Javelin Trucking. 2009. Internal Transport Statistics
Kula. 2008. Baseline survey of knowledge, attitudes and practices and behaviour related to
HIV and AIDS among Sasol's workforce and Temane Plant Communities. October 2008
Macandza. 2009. Sasol Natural Gas Project: Faunal Study. Contract between Universidade
Eduardo Mondlane and Sasol. November 2009
Magalhães. 2009. Sasol Natural Gas Project: Forest Inventory Report. Contract between
Universidade Eduardo Mondlane and Sasol October 2009
Mark Wood Consultants. 2001. Sasol Gas Supply Project: EMP for a proposed natural gas
pipeline between Ressano Garcia and Temane. November 2001
Mark Wood Consultants. 2007. Sasol Natural Gas Project. Resettlement and Compensation
Monitoring and Evaluation Programme. Independent Audit. November 2007
Mentis, M. February 2008. Mozambique-Secunda Pipeline: Highveld Wetlands
Mentis, M. 2008. Mozambique-Secunda Pipeline: Fraser Alexander Rehab & Maintenance
Contract - Progress Reports 1 (Nov 2007), 2 (Jan 2008) and 3 (Feb 2008)
Mentis, M. 2008. Mozambique-Secunda Pipeline: Maintenance Manual - Phase 1: Preliminary
Risk Assessment
Mentis, M. 2005. Mozambique-Secunda Pipeline Highveld Wetlands. September 2005.
Mentis, M. 2007. Mozambique-Secunda Pipeline Highveld Wetlands. March 2007. Prepared
Mentis, M. 2008. Mozambique-Secunda Pipeline Highveld Wetlands. February 2008.
Mentis, M. 2009. Mozambique-Secunda Pipeline Highveld Wetlands. January 2009. Prepared
Mentis, M. 2010. Mozambique-Secunda Pipeline Highveld Wetlands. January 2010. Prepared
Mentis, M. 2009 a-g. Mozambique-Secunda Pipeline: Rehabilitation and Maintenance.
Progress Reports (Jan, Feb, Mar, Apr, May, July & Nov). Prepared for Mark Wood
Consultants
Metago. 2003. Environmental Management Plan - Operation of the Temane Well Sites,
Flowlines, Access Roads and a Sasol Petroleum Temane (SPT) Plant. December 2003
Metago. 2009a. Soil monitoring at SPT CPF. November 2009
Metago. 2009b. SPT Incinerator Ash and Spent Lime Assessment for 2009. November 2009
Rison Groundwater Consulting. 2007. Groundwater Quality Monitoring - Sasol Temane.
November 2007
Rison Groundwater Consulting. 2009a. Groundwater Quality Monitoring - Sasol Temane. April
2009
Rison Groundwater Consulting. 2009b. Aquifer Sustainability Investigation - Sasol Temane.
May 2009
Rison Groundwater Consulting. 2009c. Groundwater Quality Monitoring - Sasol Temane. Oct
2009
Vermeulen, D. 2009. Groundwater Monitoring Report for the Komatipoort Compressor
Station, U754. University of the Free State, Institute for Groundwater Studies, Report #
2009/10/PDV
2011
Audit Reports
TÜV Rheinland Group. 2010. Audit Report as per ISO 14001:2004 for Sasol Petroleum
Temane Limitada Distrito de Inhassoro Provincia de Inhambane, Mozambique.
MICOA. 2010. Sixth Joint Government Audit- MICOA & Labour Dept. Summary of findings
29th November to 2nd December 2010
Sasol Reports
De Beer. P. 2009.Control of CPF brine employing alternative technologies. August 2009.
De Beer. P. 2010. SPT CPF. Final Effluent SAR Improvement. February 2010.
De Beer, P. 2010. SPT CPF. Restoring and Maintaining Injectivity of the T22 Produced Water
Re-injection Well. March 2010.
De Beer, P. 2010. SPT CPF. Incineration - Reduction of Heavy Metals, Dioxins and Furans.
March 2010.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
July 2010. Report No. 12. Prepared for MICOA.
Specialist Reports
Cosijn, M. 2008. Temane and Inhassoro Ecological Monitoring Report. Report for Sasol.
Cosijn, M. 2009. SPT Ecological Monitoring Report 2009. November.
Campaign. March to Dec 2009.
Javelin Trucking. 2010. Internal Transport Statistics.
Metago. 2003. Environmental Management Plan - Operation of the Temane Well Sites,
Flowlines, Access Roads and a Sasol Petroleum Temane (SPT) Plant. December 2003.
Metago. 2009a. Soil monitoring at SPT CPF. November 2009.
Metago. 2010. Sasol Petroleum Temane Soil Assessment. October 2010_Final.
Metago. 2010. Sasol Petroleum Temane Incinerator Ash Assessment. October 2010.
November 2007
2009
May 2009
2009
Rison Groundwater Consulting. 2010a. Groundwater Quality Monitoring - Sasol Temane.
March 2010.
Rison Groundwater Consulting. 2010b. Groundwater Quality Monitoring - Sasol Temane.
September 2010.
2012
Audit Reports
Legislative Compliance Specialists (Pty) Ltd. 2011. Environmental Legal Compliance Audit for
Sasol Petroleum Temane, August 2011.
MICOA. 2010. Sixth Joint Government Audit- MICOA & Labour Dept. Summary of findings
29th November to 2nd December 2010
TÜV Rheinland Group. 2011. Stage 1 Audit Report as per ISO 14001:2004, CN: 01 104
042161 for Sasol Petroleum Temane Limitada Distrito de Inhassoro Provincia de Inhambane,
Mozambique.
Sasol Reports
March 2010.
De Beer, P. 2010. Final Effluent Sodium Adsorption Ratio Improvement. Report for SPT CPF.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
SPT. 2011. Environmental Performance Report Sasol Petroleum Temane. August 2011-
January 2012. Report No. 15. Prepared for MICOA.
Specialist Reports
Cosijn, M. 2010. Sasol Petroleum Temane Ecological Monitoring Report Number 4, October
2010.
2011.
Servitude Rehabilitation (Mozambique Section). July 2005. Prepared for Mark Wood
Consultants.
Consultants.
Consultants.
Consultants.
Servitude Rehabilitation (Mozambique Section). June 2009. Prepared for Mark Wood
Consultants.
Deacon A. 2011. The Sasol Natural Gas Project: Mozambique to South Africa: Vegetation
Monitoring: Pipeline Servitude Rehabilitation. November 2011.
Ecoserv. 2009. Air Quality Monitoring Report prepared for SPT, Ref SS0820, February 2009
Ecoserv. 2009. Air Quality Monitoring Report prepared for SPT, Ref SS00856, July 2009
Javelin Trucking. 2011. Route Risk Assessment, Temane-Beira 2011.
Mentis, M. 2012. Mozambique-Secunda Pipeline Highveld Wetlands. February 2012.
Metago Environmental Engineers (Pty) Ltd. 2011. Environmental Management Plan -
Operation of the Temane and Pande Well-Sites, Flow lines, Access Roads and the SPT
Plant, Inhambane Province, Mozambique. Revision 3, May 2011.
Metago. 2011. Sasol Petroleum Temane Incinerator Ash Assessment. February 2011.
Metago. 2011. Soil monitoring at Sasol Petroleum Temane CPF. May 2010.
Rison Groundwater Consulting. 2011. Groundwater Quality Monitoring - Sasol Temane. April
2011.
November 2011.
Rison Groundwater Consulting. 2011. Groundwater Supply Monitoring on BH T9 using
Numerical Flow Modelling. June 2011.
SLR Consulting (Africa) (Pty) Ltd. 2011. Sasol Petroleum Temane Incinerator Ash
Assessment. November 2011.
SLR Consulting (Africa) (Pty) Ltd. 2011. Soil Monitoring at Sasol Petroleum Temane CPF.
October 2011.
SGS (2011). Incinerator and Ambient Air Quality Testing Report prepared for the CPF. May
2011.
UL DQS (2011). 2. SURVEILLANCE BS OHSAS 18001:2007; ISO 9001:2008; ISO
14001:2004+COR1:2009. October 2011.
2013
Audit Reports
DQS. 2012. Sasol Gas Recertification Audit ISO 9001:2008, ISO 14001:2004 & BS OHSAS
18001:2007. Ref. No. 360545/1061. November 2012.
TUV Rheinland Group. 2012. Stage 1 Audit Report as per ISO 14001:2004, CN: 01 104
042161 for Sasol Petroleum Temane Limitada Distrito de Inhassoro Provincia de Inhambane,
Mozambique.
Sasol Reports
March 2010.
De Beer, P. 2010. Final Effluent Sodium Adsorption Ratio Improvement. Report for SPT CPF.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
Consultants.
Specialist Reports
Airshed. 2012. Air Quality Impact Assessment for the Sasol Petroleum Temane Natural Gas
Central Processing Facility Expansion. Report Number 12MWC01 Rev 1.0. 9 January 2013.
2010.
2011.
2012.
Deacon A. 2011. The Sasol Natural Gas Project: Mozambique to South Africa: Vegetation
Monitoring: Pipeline Servitude Rehabilitation. November 2011.
De Castro. A. 2001. Management Field Survey of Affected Ecosystems along the Sasol Gas
Pipeline Route between Vilanculos and Ressano Garcia
De Castro A. 2012. Terrestrial Ecological Survey of the proposed 256 km Sasol ROMPCO
Loopline alignment (Inhambane Province, Mozambique). July 2012.
ERM. 2012. Sasol Technology on behalf of ROMPCO (PTY) LTD. Mozambique Secunda
Pipeline (MSP) Pipeline Expansion (ROMPCO Loopline). ENVIRONMENTAL IMPACT
ASSESSMENT (EIA) ADDENDUM. October 2012.
Malherbe F. 2012. Environmental Noise Assessment for the Low Pressure Compression
Project at the Sasol Temane Central Processing Facility. November 2012.
Mark Wood Consultants. 2001. Sasol Natural Gas Project, Mozambique to South Africa:
Environmental Impact Study of a proposed natural gas pipeline between Temane & Ressano
Garcia in Mozambique. August 2001.
Mark Wood Consultants. 2001. Sasol Gas Supply Project: Environmental Management Plan
for a proposed natural gas pipeline between Ressano Garcia and Temane. Part 2 -
Construction. November 2001.
Mark Wood Consultants. 2003. Sasol Natural Gas Project: Regional Environmental and
Social Assessment. July 2003.
Mentis. M. 2012. Sasol MSP. Mozambique-Secunda Pipeline. Highveld Wetlands. February
2012.
Metago Environmental Engineers (Pty) Ltd. 2009. Sasol Petroleum Temane (SPT)
Environmental Internal Audit Report, Sewage and Industrial Effluent Management. August
2009.
Metago Environmental Engineers (Pty) Ltd. 2011. Environmental Management Plan -
Operation of the Temane and Pande Well-Sites, Flow lines, Access Roads and the SPT
Plant, Inhambane Province, Mozambique. Revision 3, May 2011.
Nerscho. 2012. An Environmental Noise Survey conducted at Sasol Petroleum Temane.
Project Number and Report Number 12SHSSASMOZ639. September 2012.
Rison Groundwater Consulting. 2006a&b. Groundwater Quality Monitoring - Sasol Temane.
2006.
November 2007
2009
May 2009
2009
Rison Groundwater Consulting. 2011. Groundwater Quality Monitoring - Sasol Temane. April
2011.
November 2011.
Rison Groundwater Consulting. 2011. Groundwater Supply Monitoring on BH T9 using
Numerical Flow Modelling. June 2011.
Rison Groundwater Consulting. 2012b. Sasol Petroleum Temane Limitada Central
Processing Facility (CPF), Soil Monitoring. October 2012.
SGS. 2012. Incinerator and Ambient Air Quality Testing Report prepared for the CPF.
November 2012.
SLR Consulting (Africa) (Pty) Ltd. 2012. Sasol Petroleum Temane Incinerator Ash and Spent
Lime Assessment. May 2012.
SLR Consulting (Africa) (Pty) Ltd. 2012. Sasol Petroleum Temane Incinerator Ash and Spent
Lime Assessment. October 2012.
SLR Consulting (Africa) (Pty) Ltd. 2012. Soil Monitoring at Sasol Petroleum Temane CPF.
March 2013.
APPENDIX 3: Organogram of Activities associated with the Onshore Gas

Field
APPENDIX 4: Record of Changes to the o-EMP in Revision 4
Subsection
Subsection
Section Number Subsection
Section Name Number (old Details of Revision
Number (Revised Name
oEMP)
oEMP)
- Definitions and - - -  Definitions and acronyms list expanded

Acronyms
1 Introduction 1.2 1.2 Environmental  Sasol SH&E Policy update included as Appendix 1 (Rev. 4,
Policy June 2012
1.3 1.3 Other  Reference to the complete set of Environmental Management
Components Plans for the Natural Gas Project is updated to include a
Making up description of the revisions to the format and organization of the
Sasol’s Suite of plans.
Environmental  A list of specialist studies and monitoring reports used to inform
Management the oEMP is included as Appendix 2.
Plans
- 1.4 Relationship  Handover procedures from Seismic and Drilling operations to
Between the management by the CPF are defined.
Sasol EMP’s
1.4 1.5 Scope of the  An organogram of onshore activities associated with the
Operations EMP onshore gas field is included as Appendix 3.
- 1.6 Revisions to the  Reference is made to the record of changes to the oEMP in
Operations EMP Rev. 4 (changes detailed in Appendix 4).
1.6 1.7 Summary of  The section is updated to include upcoming CPF projects (LP
Plant Processes Compression, HP Compression, Gas Turbine Generators).
and Outputs  Figure 1 Process and Unit Descriptions is updated
 Table 1 Summary of Design Load Conditions for the MBR
sewage works is updated.
 Section 1.7.3.1.3 - reference to ‘first flush’ open drain effluent
philosophy is included.
2 Environmental 2.1 2.1 Organizational  Figure 3 - Overall Environmental Management Structure is
Management Structure and revised.
Structure Responsibility  Key parties’ titles and responsibilities are revised.
 Responsibilities for the SH&E Manager SPT and the
Environmental Manager (Maputo) SPI are added.
Subsection
Subsection
oEMP)
oEMP)
3 Activity and 3.2 3.2 Environmental  Table simplified – colour coding (priority evaluation matrix)
Impact Management removed. Figure 4 deleted.
Management Requirements
3.3 3.3 Administration  Minor editing
and General  Change to Section 3.3.1 regarding availability of the EMP to
Issues contractors
 Change to Section 3.3.4 Legal Register to ensure regular
updating
 Change to Section 3.3.7 Archaeological or Cultural sites to
ensure that records are kept
 Change to Section 3.3.12 where the requirements for the
development of new access routes is to be determined in
discussion with the regulatory authorities
3.4 3.4 Employment and  Change to Section 3.4.2 – additional information regarding
Labour SH&E training requirements
Management  Change to Section 3.5.4 – wording of requirements for
community meetings and record keeping
 Change to Section 3.5.6 – requirements for access to
Government and private property expanded
 Change to Section 3.5.8 – availability of key environmental
performance reports to be made known to Government
stakeholders and community leaders
3.7 3.7 Mosquito/Vector  Change to Section 3.7.2 – a procedure concerning medical
Control waste storage and disposal is required.
 Section 3.7.4 Personnel Management added concerning
training of personnel who spray pesticides to comply with
Mozambican legislation
3.8 3.8 Medical Waste  Change to Section 3.8.2 to include reference to Mozambican
Services and regulations on the management of bio-medical wastes
Facilities
3.9 3.9 Water and  Change to Section 3.9.1 Water Provision to include
Effluent requirements for permits
Management
Subsection
Subsection
oEMP)
oEMP)
 Change to Sections 3.9.3 and 3.9.4 to include reference to

stormwater leaving the site according to the ‘first flush’ principle
 Change to Section 3.9.7 Effluent Management (kitchen)
regarding the maintenance of fat traps in the kitchen area
 Change to Section 3.9.8 Effluent Management (laundry) to
include reference to training of staff to avoid excessive use of
detergents and the use of environmentally friendly materials
3.10 3.10 Waste  Introductory comments to Waste Management edited
Management  Change to Section 3.10.8, 3.10.9 and 3.10.14. Reference to
documentation required to identify any combustible materials
that may not be incinerated.
3.12 3.12 Production  Change to Section 3.12.1 Bush Fire Prevention to include the
CPF in the list of activities that could cause bush fires
 Change to Section 3.12.2 concerning management of water
pollution at well sites to include current information.
 Change to Section 3.12.13 Access to Well Sites to allow the
new development of access, subject to any required regulatory
approvals. Reference to management of disturbance of local
inhabitants expanded.
 Change to Section 3.12.4 Opening and Rehabilitation of Borrow
Pits and Other Sites, revised and expanded.
3.13 3.13 Maintenance  Section 3.13.3 Gas Turbines / Generators expanded to ensure
that any new installations comply with Mozambique emission
regulations and/or IFC emission guidelines for small
installations, whichever is the more stringent.
 Section 3.13.4 Excavations expanded
3.14 3.14 Support Services  Section 3.14.2 General expanded to include specific reference
to training of personnel regarding the management of spills.
 Section 3.14.3 New Infrastructure at the CPF added to ensure
best practice in the design of new infrastructure and to ensure
that any necessary authorizations are obtained prior to
construction and operation.
Subsection
Subsection
oEMP)
oEMP)
 Section 3.14.4 Establishment of Temporary Work Areas outside

of the CPF – reference added to authorizations required, where
necessary.
 Section 3.14.6 Storage and Handling of Hazardous Materials
on Site – reference to MSDS compliance changed from
‘guideline’ to ‘mandatory’.
 Section 3.14.10 Spill Prevention and Management added.
3.17 3.17 Operation  Section 3.17.1 Use of Unsurfaced Access Roads relocated
elsewhere
 Section 3.17.2 Chemical Disposal from Laboratory / Other –
reference to disposal at a ‘registered’ disposal site changed to a
disposal site ‘intended for type of waste being disposed’ in
order to avoid non-compliance where disposal sites in
Mozambique are not formally registered.
 Section 3.17.3 – 3.17.7 Condensate Loading and management
requirements revised and expanded
 Section 3.17.9 TEG Storage and Handling – changed to include
handling of TEG contaminated soils
 Section 3.17.13 Emissions Management – changed to clarify
that the reference is to Air Emissions Management.
 Section 3.17.15 General CPF Operational Noise – wording
changed to make requirements clearer.
 Section 3.17.17 Storage of Produced Water – expanded.
- 3.19 Upset Condition  Section 3.19 on upset conditions added.
Management
- 3.21 Decommissionin  Section 3.21 on decommissioning added.
g  Note 1: Updated World Bank and IFC guideline documents
4 Performance 4.1 4.1 Environmental  Table 3 Monitoring Requirements – extensively revised to
Assessment, Monitoring include current requirements. Supported by Appendix 5
Review and Strategy ‘Schedules in Support of Revised Monitoring Requirements’
Corrective
Action
APPENDIX 5: Schedules in Support of Revised Monitoring Compliance

Appendix 5, Table 5-1: Derivation of the oEMP Wastewater Emissions Standard (2014) – Comparison with Mozambique Legal
Requirements, IBRD Project Agreement, IFC and other Standards and Guidelines
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Project Agreeement Moz. Decree IFC (2007)
Effluent
Agreeement (2004) 18/2004 OHS Oil and IFC (2007)
Standards
(2004) Schedule 1 Effluent Gas OHS
Annex 4 –
Schedule 1 Environmental Standards Guidelines for General
oEMP Revised oEMP Revised Standards
Parameter Environment and Social Annex 3 – Onshore Oil Guildelines
(2011) (2013) oEMP (2014) of
al and Social Compliance – Standards of and Gas – Sanitary
Emissions
Compliance – Process Emissions for Development Sewage
for
Domestic Wastewater and Petroleum – Table 1 Discharges
Domestic
Sewage Potentially Refineries Effluents
Liquid
Effluent Contaminated
Effluents
Stormwater
Sewage treatment plant effluent quality
- pH (pH Units) 6-9 6-9 6-9 6-9 6-9 6-9
- BOD 20 30 30 50 - 30
- COD 150 125 125 250 150 125
- Oil and grease 10 10 10 10 - 10
- TSS 60 50 50 50 60 50
- Total Nitrogen 15 10 10 15 10
- Ammonia-N (NH3-
30 10 10 -
N)
- Nitrate-N (NO3-N) 10 -
- Phenols 0.5 0.5 0.5 -
- Phosphorus 10 2 2 2 10 2
- Residual chlorine
0.4 0.2 0.2 0.2 -
(as Cl)
- Coliform count
<400 <400 <400 <400 - <400
(MPN/100ml)
- Heavy metals total 7.5 10 10 10 -
- Arsenic 0.1 0.1 0.1 0.1 -
- Cadmium 0.1 0.1 0.1 0.1 -
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Effluent
Standards
Annex 4 –
(2011) (2013) oEMP (2014) of
Emissions
for
Domestic
Liquid
Effluents
Stormwater
- Chromium 0.1 0.5 0.5 0.5 -
- Copper 0.5 0.5 0.5 0.5 -
- Iron 3.5 3.5 3.5 3.5 -
- Lead 0.1 0.1 0.1 0.1 -
- Mercury 0.01 0.01 0.01 0.01 -
- Nickel 0.5 0.5 0.5 0.5 -
- Selenium 0.1 0.1 0.1 0.1 -
- Silver 0.5 0.5 0.5 0.5 -
- Zinc 2.0 2.0 2.0 2.0 -
Present /
Present / Present /
absent at
- Odour absent at absent at
dilution of
dilution of 1:20 dilution of 1:20
1:20
Present /
Present / Present /
absent at
- Colour absent at absent at
dilution of
dilution of 1:20 dilution of 1:20
1:20
<3oC above <3oC above
temp of temp of <3oC above
receiving receiving temp of
- Temperature (oC) <3 waters at point waters at point receiving <35oC
of mixing of mixing waters at point
of mixing
<35oC <35oC
Industrial effluent treatment plant quality
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Effluent
Standards
Annex 4 –
(2011) (2013) oEMP (2014) of
Emissions
for
Domestic
Liquid
Effluents
Stormwater
- pH (pH Units) 6-9 6-9 6-9 6-9 6-9
- BOD 20 30 30 50 30
- COD 80 150 150 150
- TSS 50 30 30 50 30
- Oil and grease 20 10 10 20 10
- Phenol 0.5 0.5 0.5 1 0.5
- Sulphide 0.2 1 1 1
- Total Nitrogen - 10 10 10
- Ammonia-N (NH3-
20
N)
- Nitrate-N (NO3-N) 10
- Phosphorous 2 5 5 5
- Total toxic metals
(including antimony,
arsenic, beryllium,
cadmium,
chromium, copper, 5
iron, lead, mercury,
nickel, selenium,
silver, thallium,
vanadium, zinc)
- Residual Chlorine
- Arsenic
- Cadmium
- Chrome 0.5 0.5 0.5
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Effluent
Standards
Annex 4 –
(2011) (2013) oEMP (2014) of
Emissions
for
Domestic
Liquid
Effluents
Stormwater
- Chrome (CR+6) 0.1 0.1 0.1
- Copper
- Iron
- Lead 0.1 0.1 0.1
- Mercury
- Nickel
- Selenium
- Silver
- Zinc
- Cyanide (total)
- Cyanide (free)
- Fluoride
- Benzene 0.05 0.05 0.05
Max 3oC above Max 3oC
Max 3 oCabove
temp of above temp of
temp of receiving
- Temperature (oC) receiving receiving <3oC
waters at point of
waters at point waters at point
mixing
of mixing of mixing
Final Effluent water quality discharged into the natural environment

- pH (pH units) 6-9 6-9 6-9 6-9 6-9 6-9 6-9 6-9
- BOD 20 30 30 50 50 50 30 30
- COD 80 125 125 250 150 150 125
- TSS 50 30 30 50 50 60 30 50
- Oil and Grease 10 10 10 10 20 10 10 10
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Effluent
Standards
Annex 4 –
(2011) (2013) oEMP (2014) of
Emissions
for
Domestic
Liquid
Effluents
Stormwater
- Phenol 0.5 0.5 0.5 0.5 1 0.5
- Nitrogen (total) 20 10 10 15 10 10
- Ammonia nitrogen
20 10 10 10 -
(NH3-N)
- Nitrate nitrogen
5 -
(NO3-N)
- Phosphorus 2 2 2 2 10 - 2
- Free Chlorine 0.2 -
- Residual Chlorine 0.2 0.2 0.2
Max 3oC above Max 3oC Max 3oC
Max 3oC above
temp of above temp of above temp of
temp of receiving
- Temperature (oC) receiving receiving receiving <3oC
waters at point of
waters at point waters at point waters at point
mixing
of mixing of mixing of mixing
- Fluoride 10 -
- Sulphide 0.2 1 1 1
- Total coliforms
<1 <400 <400 - <400
(MPN/100ml)
SPT IBRD
Moz. Decree
SPT IBRD Project
18/2004
Effluent
Standards
Annex 4 –
(2011) (2013) oEMP (2014) of
Emissions
for
Domestic
Liquid
Effluents
Stormwater
- Total toxic metals
(including antimony,
arsenic, beryllium,
cadmium,
chromium, copper, 5 5 5 10 5
iron, lead, mercury,
nickel, selenium,
silver, thallium,
vanadium, zinc)
- Arsenic 0.1 0.1 0.1
- Cadmium 0.1 0.1 0.1
- Chrome (Cr +6) 0.1 0.1 0.1
- Chromium (5) 0.4 0.4 0.5 0.5
- Copper 0.5 0.5 0.5
- Lead 0.1 0.1 0.1 0.1
- Iron 3.5 3.5 3.5
- Mercury 0.01 0.01 0.01
- Selenium 0.1 0.1 0.1
- Silver 0.5 0.5 0.5
- Nickel 0.5 0.5 0.5
- Zinc 2.0 2.0 2.0
- Cyanide (total)
- Cyanide (free)
- Benzene 0.05 0.05 0.05
Applicable Notes:
(i) Multilateral Investment Guarantee Agency (MIGA) standards were applicable at the time the oEMP was first produced in 2004. MIGA has subsequently discontinued these
standards and now refers to the IFC standards and are no longer included in this table. Compliance with MIGA standards was not a requirement for the Natural Gas Project,
which was governed by specific standards set out by the financiers in the IBRD Project Agreement (refer to column 5 above).
(ii) Sasol only discharges wastewater into the natural environment from the Final Effluent Pond and overflow from the ‘first flush’ stormwater management system. Effluent
from the MBR Sewage Treatment Plant and the Industrial Effluent Treatment Plant (IETP) are combined into a sump (the final effluent sump), where quality is measured
before release. Current practice is to irrigate this effluent onto the lawns and gardens at the CPF. Since the domestic effluent and industrial effluent waste streams are
combined in the final effluent sump, the standards that are applicable to domestic effluent and industrial effluent are both applicable to the final effluent stream. The revised
oEMP includes requirements for measuring all of these parameters in the final effluent stream. Where standards are set for both domestic and industrial effluent, the more
stringent standard is used. At present it is uncertain whether additional treated wastewater from the new IETP at the PSA Liquids and LPG Plant will be combined with
wastewater in the existing final effluent sump or will be separately disposed, but whatever the case it is likely to continue to be disposed on landscaped areas around the
CPF complex.
(iii) Where there is a difference between the IBRD, the Mozambique standards and the IFC guidelines, the more stringent of the three is used.
(iv) As is indicated in the main text of the revised oEMP, the standards set out for the sewage treatment plant and the industrial effluent treatment plant may be regarded as
internal Sasol quality assurance checks, since none of this effluent is released into the natural environment. The standards set out under the final effluent sections are
compliance requirements, since this effluent is released into the natural environment.
(v) While Chrome (CR +6) is a Mozambican standard it is not proposed that this is monitored regularly. If monitoring shows that the discharge of total chrome equals or exceeds
0.4 mg/L, SPT will then monitor chrome hexavalent to ensure that the discharge of such substance does not exceed 0.1 mg/L.
(vi) Total metals will be monitored in the final effluent. The monitoring of individual metals is not required by the IFC, but is required in some instances by the current Mozambican
effluent regulations. In addition to these metals (with the exception of Chrome Cr+6, as discussed in point v. above), mercury concentrations will be measured in the final
effluent stream. The frequency of monitoring is indicated in Table 4-1 of the main oEMP.
Appendix 5, Table 5-2: Derivation of the oEMP (2014) Air Emissions Standard – Comparison with Mozambique Legal Requirements, IBRD Project
Agreement, IFC and other Standards and Guidelines
Mozambique
IFC (2007) –
Regulations SPT IBRD South Africa South Africa
General EHS
on Emissions Project NAAQS NAAQS (New
Parameter (in Guidelines
and Agreement (Existing Plant
mg/Nm3 Sasol Sasol (2007) Air
Sasol oEMP Environmenta (2004) Plant Standards) –
unless CPF Facility oEMP oEMP Emissions
(2013 l Quality, Schedule 1 Standards) – Gas
otherwise (2011) (2013) Natural Gas
June 2004 – Environment Gas Combustion
specified) Turbines
Appendix 2 al and Social Combustion Installations
3MWth –
Petroleum Compliance Installations (e)
15MWth
Refineries
Reboilers 150 150 150
Combustion Units
Sulphur
(HP & LP
Oxides (SOx) 500 500 500
Compressors, GTG’s)
(a)
(d)
Incinerator
Combustion Units
Sulphur (HP & LP 500 400
Dioxide (SO2) Compressors GTG’s)
Incinerator 1000 50 50
Electrical Generation
79 86.3(b,c) 42 ppm (c) 300 50
(GTG’s)
Nitrogen Mechanical Drive (HP 460 320
Oxides (NOx) & LP Compressors, 188 205.4(b,c) 100 ppm (c)
GTG’s)
Incinerator 320 320 320 200 200
Combustion Units
Particulate (HP & LP 10 10
Matter Compressors, GTG’s)
Incinerator 50 50 50 25 10
Mozambique
IFC (2007) –
General EHS
specified) Turbines
3MWth –
15MWth
Refineries
Combustion Units
Hydrogen (HP & LP 5 5 15 5
Sulphide (H2S) Compressors, GTG’s)
Incinerator 30 30 30
Nickel + Combustion Units
Vanadium (HP & LP 2
(Ni+V) (f) Compressors, GTG’s)
Volatile Combustion Units
Organic (HP & LP 20 20
Compounds Compressors, GTG’s)
(VOC) Incinerator 20 20
1 Ng –
Dioxins and 1 Ng – 0.1Ng – 0.1Ng –
Incinerator TEQ/Nm
Furans TEQ/Nm3 3
TEQ/Nm3 TEQ/Nm3
Not
Combustion Units offensive Not offensive
(HP & LP at at receptor
Odour
Compressors, GTG’s) receptor end
end
Incinerator
Hydrogen
Incinerator 50 50 10 10
Chloride (HCl)
Mozambique
IFC (2007) –
General EHS
specified) Turbines
3MWth –
15MWth
Refineries
Sum of lead,
arsenic,
antimony,
chromium,
Incinerator 0.5 0.5
cobalt, copper,
manages,
nickel,
vanadium
Mercury Incinerator 0.05 0.05
Cadmium +
Incinerator 0.05 0.05
Thallium
Total Organic
(Hydrocarbon) Incinerator 20 20 10 10
Compounds
Ammonia Incinerator 10 10
(a) SOx: SOx consists of SO2 and SO3. SO3 can be emitted from a combustion source when SO2 is oxidised in the presence of oxygen and a catalyst, such as vanadium
pentoxide. Combustion sources at a gas processing plant using natural gas as a fuel source will emit negligible quantities of SO 3. This is different from combustion sources
that use fuel with catalytic properties such as coal flue particles that may contain vanadium. Even then the conversion rate is less than 1% of the SO2. It is therefore not
necessary to monitor SOx, which includes both SO2 and SO3 emissions. Measuring SO2 from combustion and reboiler stacks involves a much simpler methodology than
measuring SO3, and will for all practical intents and purposes reflect all sulphur oxides emitted. The measurement of SO 2 may therefore be considered to be equivalent to
measuring SOx, and may be compared with the SOx threshold values in Decree 67/2010.
(b ) NOx standard for new equipment only. For equipment prior to 2013, the IBRD standard of 320 mg/nm 3 applies (which is more stringent than the
Mozambique legal standard.
(c) NOX: The IFC emission standards for NOx are quoted in ppm. The conversion from ppm to mg/Nm 3 for NOx at standard IFC temperatures and pressures is:
42 ppm = 86.3 mg/Nm3
100 ppm = 205.4 mg/Nm3
(d) HP = high pressure

LP = low pressure
GTG = gas turbine generator
(e) The South African NAAQS old plant and new plant standards are shown for reference purposes only.
(f) Nickel and vanadium concentrations in the CPF stack gases are expected to be extremely low and no provision is made for monitoring them.
Appendix 5, Table 5-3: Derivation of the oEMP (2014) Air Quality Standard – Comparison with Mozambique Legal Requirements, IBRD Project Agreement,
IFC and other Standards and Guidelines
Mozambique World Bank

Adjusted Regulations on Group South
equivalent Emissions and African
Parameter (in standard Environmental IFC (2007) – Draft
Sasol Sasol Sasol European
µg/m3 unless Reference based on Quality, June Air Quality National
oEMP oEMP oEMP Community
otherwise Period sampling 2004 – Guidelines Dust
(2011) (2013) (2014) (EC)
indicated) period Supplement 31 based on Control
(Refer Dec 2010 Annex WHO Reg. ( 27
Table 5-4) I: Standards of Guideline May, 2011)
Air Quality Values (a)
10 mins 500 500

Sulphur 1 hour 800 350
dioxide (SO2) 87
(b) 24 hours 100 100 100 125 125
1 year 50 40 40 40 20
1 hour 190 190 190 200 200
Nitrogen
dioxide (NO2) 24 hours 62
(b)
1 year 100 10 10 10 (c) 40 40
15 mins 100 000
Carbon 30 mins 60 000
monoxide
(CO) 1 hour 30 000 30 000 30 000
8 hours 10 000 10 000 10 000
1 hour 160
Ozone
8 hours 120 100

(2011) (2013) (2014) (EC)
24 hours 50
1 year 70
Suspended 24 hours 150 150 150 150
particulates
(total) 1 year 60 60 89 60
Suspended 24 hours 75 50 50 50 150 50

particulates
(PM10) 1 year 30 20 20 - 20 40
Dust fallout
(mg/m2/day -
24 hours 1200 1200 600 600 1.2
averaging time
30 days)
Lead 1 year 0.5 0.5 1.3 0.5 0.5
Manganese 1 year 0.05 0.05 0.13 0.05
Mercury 1 year 1 1 2.5 1
Arsenic 1 year 3x10-3 3x10-3 0.008 3x10-3 6.0x10-3
Chrome 1 year 9,6x10-1 9,6x10-1 2.4 9,6x10-1
Nickel 1 year 4x10-2 4x10-2 0.1 4x10-2 2.0x10-2

(2011) (2013) (2014) (EC)
Benzene 1 year 4,4x10-6 5 7.8 4,4x10-6 5

Formaldehyde 30 mins 0.01 100 0.001 0.01 100
Styrene 30 mins 0.28 0.28
1 week 260 205 260
Toluene 1 week 0.26 260 205 0.26 260
Carbon
24 hours 0.25 0.25
Tetrachloride
Annual 6.1 9.5 6.1
Instantaneou
Odours (H2S) 5
s
Not Not
Not
Odours offensive offensive
- offensive at
(qualitative) at at
receptor
receptor receptor
Notes:
(a) IFC/WHO guideline values: The World Bank Group (IFC) make use of the WHO air quality guidelines. Table 1.1.1 of the IFC (2007) General EHS
Guidelines provides a variety of interim targets and guideline values, depending on the parameter. For the purposes of the revised o-EMP (2014), the
IFC/WHO interim target #1 values have been used for SO2, since these are more closely aligned than the guideline values with other world standards
such as the South African NAAQS and the EC Directive. For NO 2, the IFC/WHO guideline values have been used since no interim target values are
published by the IFC/WHO. For PM10, the guideline values have been used.
(b) Equivalent Standards for Non-Standard Monitoring Periods: Historically, the monitoring of ground level concentrations of SO 2 and NO2 and PM10
at the CPF has been by means of passive sampling over a 14-day period. Where such non-standard averaging periods are used (the averaging periods
do not match those required by the standards), it is necessary to calculate an equivalent standard in order to compare measured values with the
standards. Concentrations over different averaging periods can be shown to be approximately logarithmically related to each other, i.e. [log(C x)-
log(C2)]/[log(tx)-log(t2)] = [log(C1)-log(C2)]/[log(t1)-log(t2)], where C1, C2 and Cx are the average concentrations at averaging times t1, t2 and tx,
respectively. Using the concentration standards at averaging times of 1 hour and 1 year, or for other bracketing periods where applicable, it is then
possible to interpolate a standard for any proposed monitoring period.
The averaging periods for monitoring of air quality parameters at the CPF have been changed to the periods set out in Table 5-4 below. In the case of metals
and VOC’s this ambient monitoring was required for the first time by the Rev. 4 o-EMP. Note that because a number of the VOC ambient air quality standards
in the Mozambique Decree 67/2010 regulations bear no relationship to recognized world ambient guidelines (and, in fact, are so low that they cannot be
measured), world standards (IFC, WHO and EC) have been used instead.
Table 5-4: Averaging Periods for Monitoring of Air Quality Parameters at the CPF
Parameter (in µg/m3

Legal Averaging Equivalent Standard based on
unless otherwise Sasol oEMP (2014) Sasol Averaging Period
Period Specified Averaging Period
indicated)
SO2 1 hour 800 28 days 87
24 hours 100
1 year 40
NO2 1 hour 190 28 days 62
1 year 40
TSP 24 hours 150 24 hours 150
1 year 60 14 days 89
PM10 24 hours 50 24 hours 50
1 year 20 1 year 20
Dust fallout 24 hour average over 28 600 24 hour average over 28 – 33 day 600
(mg/m2/day) day period period
Lead Annual 0.5 24 hours 1.3
Manganese Annual 0.05 24 hours 0.13
Mercury Annual 1 24 hours 2.5
Arsenic Annual 3x10-3 24 hours 0.008
Chrome Annual 9,6x10-1 24 hours 2.4
Nickel Annual 4x10-2 24 hours 0.1
Benzene Annual 5 28 days 7.8
Ethylbenzene 24 hours 100 28 days 28
Toluene 1 week 260 28 days 205
Xylene 24 hours 100 28 days 28
Formaldehyde 30 mins 100 30 mins 100
Styrene 1 week 260 28 days 205
Tetrachloride Annual 6.1 28 days 9.5
Odours (qualitative) Not offensive at receptor Not offensive at receptor --
SO2 and NO2: Using the Mozambican standards for SO2 of 800 µg/m³ (1-hour) and 40 µg/m³ (1 year), the 28-day equivalent standard would be 93 µg/m³.
Similarly the Mozambican standards for NO2 of 190 µg/m³ (1-hour) and 10 µg/m³ (1 year), would result in a 28-day equivalent standard of 23 µg/m³. The 28-
day average monitored values can therefore be used to test for compliance by comparing it to the equivalent standard derived in the above manner. Given
the consistently low measured concentrations for SO 2 and NO2 at the CPF boundary, this approximation is considered to be acceptable and more
sophisticated methods of monitoring SO2 and NO2 are not required. However, in the event that measured SO2 or NO2 concentrations over the 28 day period
exceed 75% of the 28-day standard at the CPF or PPZ boundaries, then monitoring methods should be changed to provide a more accurate account of
hourly, daily and annual compliance.
TSP and PM10: Historically, the monitoring of ground level concentrations of PM10 at the CPF has been done by means of a high volume mini-sampler, with
samples taken every twenty four hours over a fourteen day period. For the PSA Development and LPG Project, e-samplers have been installed at two
locations which provide continuous sampling (compliance with the 24 hour or annual standard can be determined without conversion to an equivalent value).
Mini-samplers will only be used in future for the continued monitoring at the CPF southern and northern boundary once per year. These samples are taken
over 24 hours per sample for a period of 14 days.
TSP has not been monitored since it is no longer a parameter widely used by the international community, who recognize PM10 as the more useful parameter.
TSP can be monitored from time to time by the e-samplers in order to verify compliance with the Mozambique air quality standard.
(c) Mozambique NO2 Annual Standard: With regard to the annual NO2 standard set by Mozambican Decree 67/2010, it is noted that this is extremely
stringent, being four times lower than the equivalent World Bank, EU and South African standard. The current revision to the o-EMP has included The
World Bank guideline as the legal compliance requirement.
APPENDIX 6: Notes on Mozambique Decree 67/2010 Organic Parameter

Air Quality Standards
Nitrogen Dioxide
The 10 μg/m³ annual average for the Mozambique Standard is out of line with other world
standards and guidelines. The 40 μg/m³ (the WHO guideline) is used as the annual average
standard in the oEMP.
Benzene
The geometric mean of the range of estimates of the excess lifetime risk of leukaemia (cancer)
at an air concentration of 1 μg/m³ is 6 × 10–6. The concentrations of airborne benzene
associated with an excess lifetime risk of 1/10 000, 1/100 000 and 1/1 000 000 are, respectively,
17 μg/m³, 1.7 μg/m³ and 0.17 μg/m³.
A value of 4.4x10-6 μg/m³, i.e. the Mozambique Standard, is therefore equivalent to a cancer
risk of 4/10 000 000 000. Given that 1/1 000 000 is a more than adequately small risk, complying
with a standard of 4/10 000 000 000 is excessively stringent. The 5 μg/m³ annual guideline
recommended by the EC, which is generally accepted in Europe, is used as the oEMP standard.
Formaldehyde
The lowest concentration that has been associated with nose and throat irritation in humans
after short-term exposure is 100 μg/m³, although some individuals can sense the presence of
formaldehyde at lower concentrations.
To prevent significant sensory irritation in the general population, an air quality guideline value
of 100 μg/m³ as a 30-minute average is recommended by the WHO. Since this is over one
order of magnitude lower than a presumed threshold for cytotoxic damage to the nasal mucosa,
this guideline value represents an exposure level at which there is a negligible risk of upper
respiratory tract cancer in humans.
The Mozambique Standard is 10 000-fold lower than the WHO guideline. The 100 μg/m³ WHO
guideline is used as the basis of the oEMP standard.
Styrene
Although genotoxic effects in humans have been observed at relatively low concentrations, they
were not considered as critical endpoints for development of a guideline, in view of the
equivocal evidence for the carcinogenicity of styrene.
In occupationally exposed populations, subtle effects such as reductions in visuomotor

accuracy and verbal learning skills, and subclinical effects on colour vision have been observed
at concentrations as low as 107–213 mg/m³ (25–50 ppm). Taking the lower number of this
range for precautionary reasons and adjusting this value in order to allow for conversion from
an occupational to a continuous pattern of exposure (a factor of 4.2), and incorporating a factor
of 10 for inter-individual variation and 10 for use of a lowest-observed-adverse -effect level

(LOAEL) rather than a no-observed-adverse-effect level (NOAEL) this results in a WHO
guideline of 0.26 mg/m³ or 260 μg/m³ (weekly average). This value should also be protective
for the developmental neurological effects observed in animal species.
The air quality guideline could also be based on the odour threshold. In that case, the peak
concentration of styrene in air should be kept below the odour detection threshold level of
70 μg/m³ as a 30-minute average.
The Mozambique Standard is approximately 1 000-fold lower than the WHO guideline.
Furthermore, the averaging period for the Mozambique Standard is 30-minutes, whereas the
WHO is a week thereby making it even more conservative (by a minimum of another 3-fold).
The o-EMP standard is based on the WHO weekly average guideline of 260 μg/m³.
Toluene
The LOAEL for effects on the central nervous system based on occupational studies is
approximately 332 mg/m³ (88 ppm). The WHO establishes a guideline value of 0.26 mg/m³
(260 μg/m³) from these data, adjusting for continuous exposure (dividing by a factor of 4.2) and
dividing by an uncertainty factor of 300 (10 for inter-individual variation, 10 for use of a LOAEL
rather than a NOAEL, and an additional factor of 3 given the potential effects on the developing
central nervous system). This guideline value should be applied as a weekly average. This
guideline value should also be protective for reproductive effects (spontaneous abortions).
The air quality guideline could also be based on the odour threshold. In this case, the peak
concentrations of toluene in air should be kept below the odour detection threshold level of 1
mg/m3 as a 30-minute average.
The Mozambique Standard is 1 000-fold lower than the WHO guideline. The o-EMP uses the
WHO weekly average of 260 μg/m³ as the basis of the standard.
Carbon Tetrachloride
The Mozambique Standard of 0.25 μg/m³ is for a 24-hour exposure and more than an order of
magnitude lower than the WHO guideline of 6.1 μg/m³, which is applicable over an annual
exposure period. This means that the Mozambique standard is a further several orders of
magnitude more stringent than the WHO guideline. The WHO annual average guideline of
6.1 μg/m³ is used as the basis of the o-EMP.

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ENVIRONMENTAL MANAGEMENT PLAN

Operation of the Central Processing Facility, PSA

Title ENVIRONMENTAL MANAGEMENT PLAN:

3.20. LAND USE CONTROLS ......................................................................................89

TABLE 3-1: OBJECTIVES OF MITIGATION MEASURES FOR ADVERSE

TABLE 3-2: REGISTER OF ACTIVITY CATEGORY AND SUB-CATEGORIES

TABLE 4-1: MONITORING REQUIREMENTS. (IN SOME CASES PERFORMANCE

TABLE 4-2: GROUNDWATER MONITORING LOCATIONS PRIOR TO

TABLE 4-3: GROUNDWATER MONITORING LOCATIONS AFTER COMPLETION

TABLE 4-4: PROPOSED SURFACE WATER MONITORING PLAN (REFER TO

TABLE 4-5: AIR QUALITY MONITORING LOCATIONS, SAMPLING FREQUENCY

TABLE 4-6: SOIL MONITORING LOCATION, FREQUENCY AND PARAMETERS

TABLE 4-7: MINIMUM AUDITING REQUIREMENTS FOR THE OPERATIONAL

FIGURE 1-3: ADDITIONAL PLANT AT THE CPF TO BE INSTALLED ................................... 15

FIGURE 1-5: CPF WATER TREATMENT PROCESS........................................................ 25

FIGURE 1-6: DOMESTIC SEWAGE TREATMENT ............................................................ 28

FIGURE 2-1: OVERALL ENVIRONMENTAL ORGANISATIONAL STRUCTURE BETWEEN KEY

FIGURE 4-1: GROUNDWATER MONITORING LOCATIONS PRIOR TO COMPLETION OF THE PSA

FIGURE 4-2: GROUNDWATER MONITORING LOCATIONS AFTER COMPLETION OF THE PSA

(REFER TO TABLE 4-6) ............................................................................................ 116

APPENDIX 1: Sasol SH&E Policy (Revision 5, November 2012)

APPENDIX 3: Organogram of Activities associated with the Onshore Gas Field

APPENDIX 4: Record of Changes to the o-EMP in Revision 5

APPENDIX 5: Schedules in Support of Revised Monitoring Compliance

This document is available in English and Portuguese. In the event of any

DEFINITIONS AND ACRONYMNS

ANE Mozambique National Roads Administration

Pipeline This refers to an underground pipeline which carries gas or liquid

In October 2000, Sasol Petroleum Temane Limitada (Sasol), Empresa

1. Exploration activities to determine the extent of the gas reserves and

2. Development of a network of production wells and gas flowlines within

3. Transportation of the gas from Temane to Secunda (South Africa) and

4. Upgrading and conversion of Sasol’s plant infrastructure at Secunda and

Sasol proposes to further expand the CPF to process additional gas,

The proposed development (Figure 1-1) consists of two main components,

1. PSA Gas Development: involving six production wells in the

2. PSA Liquids Development, involving twelve oil production wells

1.2. ENVIRONMENTAL POLICY

As the Operations owner, Sasol Petroleum International (Pty) Ltd (SPI) is

 Developing and implementing an integrated management system that

 Subjecting itself to third party audits conducted by an internationally

 Accepting and complying with Sasol Corporate Governance

 Engaging with the Mozambican Government regarding the

 Sharing safety, health and environmental risk reduction best practices

 Influencing suppliers and contractors to conform as a minimum to the

 Sharing and communicating relevant information about safety, health

 Enhancing the general awareness of its employees and contractors to

 Responding effectively to safety, health and environmental

 Providing appropriate resources to implement the above commitments;

 Reviewing this declaration of intent on a 3-yearly basis or as and when

1.3. COMMUNITY ENGAGEMENT PRINCIPLES

Sasol’s community engagement principles are centred on:

- Community involvement and ownership

1.4. PURPOSE OF THIS DOCUMENT

This document is the operations Environmental Management Plan (o-EMP) for

The complete set of management plans is as follows:

1. Construction EMP Metago Environmental Engineers (Pty) Ltd. 2002.

requirements based on the findings of the PSA

1.5. RELATIONSHIP BETWEEN THE SASOL EMP’S

During seismic operations, which includes demining, vegetation clearance and

During construction of civil infrastructure, such as flowlines, pipelines and

1.6. SCOPE OF THE OPERATIONS EMP

The operations EMP (o-EMP, this document) contains environmental

 Integrated PSA Liquids and LPG Plant;