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    ACL   ZAE000134961

ARCELORMITTAL SOUTH AFRICA LTD

(ACL)
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ArcelorMittal South Africa : CSP External Audit Report for AMSA Vanderbijlpark August 2021

08/17/2021 EDT

EXTERNAL AUDIT REPORT IN FULLFULLMENT OF THE

ENVIRONMENTAL AUTHORISATION FOR THE

CARBON SEPARATION PLANT

AT

ARCELORMITTAL SOUTH AFRICA

VANDERBIJLPARK WORKS

Report Nr: 2081-ZANAMSA-2021

Audit date: June - July 2021

Report date: 16 August 2021

1

ArcelorMittal South Africa Vanderbijlpark Works

CSP ROD Audit Report - GAUT 006/10-13/N0055

General Information

Report Name:

External Audit Report for the Carbon Separation Plant

Appointed Auditor:

Zantow Environmental Consulting Services CC

22 Delius Street, SW 5

Vanderbijlpark

PO Box 3858

Vanderbijlpark , 1911

Contact Person:

Karien Zantow

Tel: 083 384 3641

Fax: 016 932 4976

Email: karien@zantow.co.za

Auditee:

ArcelorMittal South Africa Vanderbijlpark Works

PO Box 2

55400

Vanderbijlpark

1900

Contact Person:

Environmental Control Officer

Ilze Broekman

Tel: 016 889 3247

Fax: 016 889 2058

Email: ilze.broekman@arcelormittal.com

Report compiled by:

Karien Zantow

Audit Date:

16 July 2021

Report Date:

16 August 2021

Status:

Final

Authorisation Ref Nr:

GAUT 006/10-13/N0055

2

Report: 2081-ZANAMSA-2021

Zantow Environmental Consulting Services

ArcelorMittal South Africa Vanderbijlpark Works

CSP ROD Audit Report - GAUT 006/10-13/N0055

DECLARATION AND REVIEW

I, Karien Zantow, as an independent consultant compiled this audit report and declare that it correctly reflects the findings made at the time of the audit. I further declare that I,

  • Act as an independent consultant;
  • Do not have any financial interest in the undertaking of the activity, other than remuneration for the work performed in terms of the National Environmental Management Act, 1998 (Act107 of 1998) and the National Environmental Management Waste Act;
  • Undertake to disclose, to the competent authority, any material information that has or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the National Environmental Management Act, 1998 (Act 107 of 1998);
  • Based on information provided to me by the project proponent, and in addition to information obtained during the course of this study, will present the results and conclusion within the associated document to the best of my professional judgement.

_____________________________

Karien Zantow

Environmental Specialist

SACNASP Reg Nr 400114/14

3

Report: 2081-ZANAMSA-2021

Zantow Environmental Consulting Services

ArcelorMittal South Africa Vanderbijlpark Works

CSP ROD Audit Report - GAUT 006/10-13/N0055

EXECUTIVE SUMMARY

Zantow Environmental Consulting Services CC was contracted by ArcelorMittal to conduct an independent Compliance Audit on its Record of Decision (RoD) for the Vanderbijlpark Works' Carbon Separation Plant (CSP) (GAUT 006/10-13/N0055), dated 29 August 2006 as amended in 2009, 2010, 2012 and 2013.

The methodology followed for conducting the compliance assessment audit can be described as

  • Document review (RoD)
  • Compilation of audit checklist/questionnaire
  • Document audit (from 21 June 2021 to 16 July 2021)
  • Site Visit - not conducted due to COVID restrictions; and
  • Compilation of compliance audit report

During the document review component of the audit, it was established that the ROD was initially issued to ArcelorMittal Coke and Chemicals, a subdivision of ArcelorMittal. Compliance to the ROD was therefore the responsibility of Coke and Chemicals employees as per condition 3.3.f. Various conditions required the timely submission of information as a once-off condition, thus requiring no further or continues input.

Should such a condition, which mostly occurred at the onset of the project, not be complied with, such a condition will remain a non-compliance as long as the RoD remains in-force. Subsequent to this, the project ownership have been transferred to ArcelorMittal Vanderbijlpark Works. During the handover of the ROD information; proof of submission of the relevant documentation could not be found / produced by Coke and Chemicals. As these were conditions that required some action in the past there is no remedy available to Vanderbijlpark Works to rectify or remedy the situation. To continuously raise the matter would not be reasonable or adding value, as these are historic.

In light of the above, the auditor has, in addition to indicating compliance and non-compliance, ranked the specific non-compliances in terms of the following criteria:

  • Historic Issues
  • Minor Issues
  • Moderate Issues
  • Critical Issues

The assessment was conducted in terms of condition 3.4.c of the Record of Decision (RoD) for the Carbon Separation Plant at ArcelorMittal's Vanderbijlpark Works, dated August 2006, reference GAUT 002/05- 06/0510.

From Table 1, it can be concluded that ArcelorMittal's compliance with the RoD is satisfactory. Some conditions have been met fully, while other conditions have not been met, although due to circumstances and also the lack of practical and non-retrospective conditions. Where non-compliances were recorded, the auditor contextualised the non-compliance in terms of the intensity. This equates to an objective view of the seriousness of the non-compliance and also then leads to recommendations where moderate to major non- compliances have been observed.

The recommended actions plan to improve compliance or to improve on the environmental management system includes the following;

  • Pursue the development of a market or off set for the carbon rich material and commit resources to ensure a consistent delivery of the product once a market is established.
  • Improve on the ambient air quality stations uptime and availability of data.

4

Report: 2081-ZANAMSA-2021

Zantow Environmental Consulting Services

ArcelorMittal South Africa Vanderbijlpark Works

CSP ROD Audit Report - GAUT 006/10-13/N0055

  • Amend the EMP to align the monitoring, reporting and management measures to be implemented in case of abnormal conditions with AEL requirements and re-submit the EMP to
    GDARD.

In the event that the CSP will no longer be operated, the decommissioning thereof should be investigated, and the closure should be communicated accordingly to the department.

5

Report: 2081-ZANAMSA-2021

Zantow Environmental Consulting Services

Disclaimer

ArcelorMittal South Africa Limited published this content on 17 August 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 30 August 2021 08:21:08 UTC.


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