South Africa Sasols Tender

Sasol participated in the South African Human Rights Commissions SAHRC inquiry into the state of the Vaal River. As an industrial user of this resource we welcome the invitation by the SAHRC to participate and support its mandate. Sasols team of specialists and subject matter experts presented an overview of Sasols reliance on the Integrated Vaal River System IVRS. This will be followed by a written submission to the SAHRC.We have noted the extensive media reports on the raw sewage discharges into the Vaal River in the past several weeks and months. We are deeply concerned about the current state of this vital resource.In the context of the hearing on 20 November Sasol wishes to clarify media reports on 20 and 21 November pertaining to Sasols compliance with waste water discharge and further to the reference to its waste incinerators.Waste water discharge complianceAs stated to the Commission Sasol currently discharges waste water under a Water Use Licence WUL issued in December 2016 by the Department of Water and Sanitation DWS which imposes conditions and strict limits governing discharges of treated water into the river as a lawful water user. These conditions were set with due consideration of the Vaal River Catchment Management Strategy and the relevant resource water quality objectives.Our Sasolburg Operations complies with its WUL and waste water discharge limits. In the event of incidents associated deviances however small are investigated and reported to the authorities in line with the conditions set-out in our WUL. The few incidents where the discharge specifications were exceeded were of short duration in all instances. Moreover we regularly engage with the DWS to ensure our ongoing alignment on the interpretation of the WUL conditions and its application.There were two incidents on 4 December 2017 and 23 March 2018 of sewage overflow into the Leeuwspruit emanating from Sasols waste water treatment facility in Sasolburg which treats the towns sewerage on behalf of the municipality. These were the result of excessive rainfall entering the municipalitys sewage collection infrastructure which placed excessive pressure on Sasols waste water treatment infrastructure beyond its capacity. This was duly reported to the local municipality and the DWS. The overflows were of a short duration and impact assessments were undertaken and reported to the DWS. As the Sasol treatment plant is not designed to handle and treat such excessive flows the municipality has been requested to address the root cause while Sasol has made available additional pumping capacity to help mitigate future excessive flow scenarios. The ingress of high storm water flows can however only be fully mitigated by the municipality.IncineratorA reference was made by the Commission to Sasols incinerators in Sasolburg as mentioned in the Department of Environmental Affairs DEA 20162017 Environmental Compliance Report this was not issued or compiled by the Department of Water and Sanitation. While we welcome questions on our environmental compliance and management by the Commission the Sasolburg incinerators referenced in the DEA report have no operational bearing on our activities linked to the Vaal River and specifically waste water discharge compliance. Notwithstanding as confirmed by the report we experienced some air quality related compliance challenges with our Sasolburg incinerators and voluntarily decommissioned the incinerators with the commitment to only re-commission them if sustained compliance can be ensured.Given the current state of the IVRS and its importance to the entire region Sasol welcomes this inquiry as part of identifying the root causes of the raw sewerage affecting the river and communities residing in its proximity as well as the associated risks with the IVRS. Through this process Sasol intends to foster a collaborative approach in resolving this challenge with key stakeholders.Sasol is a responsible corporate citizen key stakeholder and a lawful responsible water user of the IVRS. Compliance is a priority for Sasol and is a commitment that remains steadfast. As a member of the Strategic Water Partners Network a signatory of the United Nations Global Compact UNGC since 2001 and an endorser of the UNGC CEO Water Mandate we recognise that the responsible management and use of the IVRS by all stakeholders amongst others is key and in the best interest of all those who have the right to it. It is for these reasons that Sasols lawful use of this resource is managed by dedicated operational teams who are supported by subject matter experts in the areas of water waste land and biodiversity management. Furthermore we are also involved in a number of water conservation water demand management initiatives with local and national governments and other key stakeholders in the spirit of continuous improvement and public-private partnerships. Our approach on respecting human rights is incorporated in our Code of Conduct and is guided by the United Nations Guiding Principles on Business and Human Rights the International Bill of Human Rights the International Labour Organizations Declaration on Fundamental Principles and Rights at Work. This forms a cornerstone of our integrated sustainable development framework.We remain committed to supporting the Commissions inquiry and to assisting and collaborating with the institution to advance the objectives of this investigation. To this end we welcome the Commissions intention to conduct a site visit at our discharge points. We deem this as a sustainability imperative in the interest of all who have water use rights especially the vulnerable communities.