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Reference: PC – AQM

PORTFOLIO COMMITTEE MEMO

BRIEFING BY THE DEPARTMENT OF ENVIRONMENTAL AFFAIRS – APPLICATIONS FOR POSTPONEMENT TO COMPLY WITH MINIMUM EMISSIONS STANDARDS BY INDUSTRY

1. PURPOSEThe purpose of this submission is to update the Portfolio Committee (PC) on the status of the

postponement applications that have been received and approved by the National Air Quality Officer

(NAQO) from 1 April 2014 to date, including progress in the implementation of PC’s recommendations as

made during the sitting of the PC in February 2018. Thus, this memo addresses the following:

1.1 Progress in implementing the PC’s February 2018 recommendations;

1.2 Compliance status of postponement holders (Annexure 1);

1.3 Progress towards the implementation of emissions offsets programmes; and

1.4 Applications for further postponements

2. BACKGROUND AND DISCUSSION2.1 The legal provisions for applications for postponement of compliance timeframes with the Minimum

Emissions Standards (MES) are provided for in terms of Section 21 Notice of the 31 March 2010 and its

amended version of 22 November 2013 published in terms of the National Environmental Management:

Air Quality Act, 39 of 2004.

2.2 With regard to compliance timeframes with MES, Section 21 Notice stipulates that:

2.2.1 New plants must comply with new plant emission standards immediately;

2.2.2 Existing plants must comply with existing plant standards on 01 April 2015; and

2.2.3 Existing plants must comply with new plant standards on 01 April 2020.

2.3 Similarly, as contemplated in the National Framework for Air Quality Management in the Republic of

South Africa, published in terms of the Air Quality Act, applications for postponement of compliance

timeframes may be made with the National Air Quality Officer.

2.4 Following the publications of the Section 21 Notice of 22 November 2013, facilities meeting the CONFIDENTIAL

PROGRESS UPDATE ON THE STATUS OF POSTPONEMENT OF COMPLIANCE TIME FRAMES FOR ALL APPROVED APPLICATIONS

requirements for postponement submitted applications for consideration by the National Air Quality

Officer from 1 April 2014.

2.5 As part of the approval conditions all the facilities were required to make commitments towards meeting

the emission standards.

3. PROGRESS IN THE IMPLEMENTATION OF THE PC’S RECOMMENDATIONSAt the conclusion of the sitting of the PC on 6 February 2018, it was recommended that a Technical

Advisory Panel be established that would undertake an independent assessment of the viability to retrofit

abatement technologies that would mitigate the emissions of SO 2 from old facilities such as Eskom power

stations and Sasol South Africa operations. Preparatory work towards this was done and the Terms of

Reference that would provide guidance on the establishment of the Panel was submitted to the Minister –

as she is legally empowered to establish the Panel. The Minister considered the request and instructed

instead that a Needs Assessment Report be produced on the progress of all the previous postponements

granted and the challenges thereof for the past five years; and what the establishment of the Panel would

entail in line with other expectations for compliance with the minimum emission standards.

• Based on the report, the Minister would decide on the way forward regarding whether or not there is

scientific evidence favouring the establishment of the Panel. The Terms of Reference that would inform

the approach of the needs assessment exercise were drafted. Recent developments, however, are that

the amended Section 21 Notice was promulgated on 31 October 2018. Therein is the new plant standard

for SO2 for existing plants has been revised from 500mg/Nm3 to 1000mg/Nm3 and this is applicable from

1 April 2020. The revised standard opens the scope for a wider range of technologies to be utilized to

achieve compliance – it is not a “no investment” scenario. However, the regulated community will advise

whether there are still major difficulties at this stage or not.

4. ROADMAPS TOWARDS FULL COMPLIANCE BY INDUSTRY

The compliance roadmaps for the facilities that have been granted postponements are submitted to DEA

on a quarterly basis, following a calendar year reporting cycle. The latest results, based on performance

for the quarter ending on 31 December 2017 were presented during the last PC meeting on 6 February

2018. This report (August 2018 Report) presents the assessment of the performance of the facilities for

the quarter ending on 30 June 2018. However, for continuity purposes, progress in some instances,

particularly with regard to Offsets Implementation is also reported for targets achieved before 30 June CONFIDENTIAL2


2018. This is because progress on some of those targets are not broken down into quarterly targets.

4.1 From the quarterly reports of the applications, it is evident that some of the facilities will not be able to

meet their postponement commitments. The facilities of concern remain the Eskom power stations to a

large extent and Sasol facilities, to a lesser extent.

4.2 With regard to Eskom power stations, there is clear evidence that some of the Utility’s power stations will

not be able to meet some of the postponement targets. In summary, the following are the list of

challenges faced by the Utility:

4.2.1 Delays in the procurement of abatement technology and equipment will lead to delays

in the implementation of some of the planned project activities.

4.2.2 Also changes in some of the abatement technologies committed to was cited as a

contributing factor in project delays. However, high cost was cited as the contributing

factor for the consideration of alternative technologies.

4.2.3 Due to the remaining short life span of some of the power stations, there were no

commitments by Eskom to bring these stations to compliance with the minimum

emission standards, some of which may have their lifespan extended by a further 10

years – an undertaking that was not raised during the postponement application and

which Eskom claims no decision has been made yet.

4.2.4 Poor project planning, management and execution.

4.2.5 However, it is important to acknowledge some good progress that the Utility has made

in relation to meeting some of the postponement decisions. This relates to the

development and implementation of Air quality Offsets Plan in some of the Utility’s

power stations. This is aimed at improving indoor air quality in the communities

surrounding the power stations. The affected power stations are: Hendrina, Arnot,

Komati, Matla, Kriel, Duvha, Kendal, Tutuka, Majuba, Grootvlei, Camden and Lethabo

4.3 With regard to Sasol the main issues of concern are as follows:

4.3.1 Undertaking lot of studies to identify possible abatement technologies that will enable

some of their operations to meet emission standards and possible savings on capital

cost.

These further investigations will extend beyond the initial timeframe applied for in their

postponement applications. Therefore, the company is applying for further postponement

on some of the operations on which postponement has already been granted.

4.4 Offsets implementation plans

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As part of postponement decision making process, all facilities in the Priority Areas that were granted

postponement decisions were required to develop and implement emission offsets plans or

programmes. Both Sasol and Eskom have developed such plans which was approved by DEA for

implementation. Below is a progress report on the implementation of the plans, in tabular format.

4.4.1 Sasol Secunda offsets implementationTimeframe Target (Major) Progress

Jan 2016-Dec 2016 Baseline assessment/source apportionment measurements in eMbalenhle /Zamdela

Baseline assessment was initiated in 2016 and concluded during the course of 2017

Initiating feasibility for roads design in Lebohang and eMbalenhle (i.e surfacing of dirt roads using coarse ash)

The feasibility study was conducted and finalised

Testing of materials for formal and informal housing insulation in Lebohang / eMbalenhle

Testing was done

Jan 2017-Dec 2017 Final baseline report for eMbalenhle/Lebohang The results from the first source apportionment measurements confirmed that domestic coal burning contributes significantly to Particulate Matter concentrations in the ambient air near the plant.

Conclusion of feasibility study on roads designs and identification of other options (if study not feasible

Results showed the approach not feasible due to the nature of the soil type. This option will no longer be considered due to the minimal impact of the unsurfaced roads as proved by further studies (source apportionment)

Jan 2018 – June 2018 Insulation of RDP homes: First focus is on eMbalenhle starting with approximately 500 to 700 houses between July 2017 and June 2018 followed a year later in Lebohang. The stoves in the qualifying households will be exchanged with an LPG stove and a gas heater in 2019.

To ensure successful implementation, a staggered approach is being adopted, with the first focus in eMbalenhle, followed a year later in Lebohang. To date 1064 households have been contracted. Basic insulation (ceiling only) is underway and 505 houses have been completed and handed over to the household owners in line with the offset plan. The solid fuel burning coal stoves in the completed households were exchanged with an LPG stove and a gas heater. The training on the use of the LPG package was done for all households that received the LPG stove and a gas heater.

Grass cutting and veld fire management activities are ongoing by the Secunda Synfuels Operations emergency management team, with their scope of activities enhanced to support greater mitigation of veld fires as part of the offset plan.

Grass cutting and veld fire management.

Insulation of 24 serviced informal houses with Insulation of 24 serviced informal houses with

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Timeframe Target (Major) Progress

polyurethane foam together with a stove swop in Lebohang.

polyurethane foam together with a stove swop in Lebohang has been completed. Summer temperature impact measurements and indoor air quality data collection was completed. The data is being analysed a report with the results will be compiled.

Air quality awareness campaign The target audience are communities of eMbalenhle and Lebohang where offsets are implemented and 27 primary schools in Govan Mbeki Municipality. The door to door campaign survey commenced in eMbalenhle and Lebohang. The educational material to be used for Grades 1 to 7 has been sent to Department of Basic Education for review and comments.

4.4.2 Sasol Sasolburg/Natref offsets implementationTimeframe Target (Major) DEA comment

Jan 2016-Dec 2016 Baseline assessment/source apportionment measurements in Zamdela ( to assess the sources of emissions)

Baseline assessment was initiated in 2016 and concluded during the course of 2017

Initiating programme to reduced smoke (PM) emissions from veld fires in consultation with Metsimaholo LM’s EMS in Zamdela in order to cut grass before winter

Consultations have been concluded with the LM

Initiate domestic waste management project, including waste collection, recycling, and awareness campaigns

Negotiations with waste pickers association, local municipality, communities completed; Identification of sites completed.

Jan 2017-Dec 2017

Final baseline report for Zamdela 1st source apportionment measurement results have been completed. Final results of the baseline campaign may inform longer term projects.

Implementation of waste fire management Rapid response vehicle to be deployed for quick responses to veld and waste fires has been purchased and handed over to local municipality in November 2017.

Purchase of skips for non-recyclable waste management Waste removal piloting activities within Zamdela were successful and as a result, the number of sites will be expanded to 100. To date 75 skips have been placed and the aim is to have the additional 25 skips placed early in 2018. To date approximately 10 000 tons of waste has been removed from the community.

Jan 2018 – June 2018 The two identified sites provided by Metsimoholo Local Municipality (MLM) have to be registered as waste handling facilities under the Norms & Standards contained within NEMWA, due to the size of the transfer stations. Four more properties were identified which is currently under evaluation, however, once approved, these facilities will also need to be registered as indicated.

There are delays in the waste recycling project which are causing a further delay in the development of the transfer stations and its subsequent hand over to the relevant stakeholders.

All training and awareness campaigns regarding the vehicle emission testing have been completed and the equipment was donated to MLM for use.Sasolburg Operations will receive quarterly progress reports on

Quarterly progress reports on the vehicle emission testing received within the Municipality will be shared as part of this report.

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the vehicle emission testing within the Municipality.Non-recyclable waste removal activities within Zamdela are progressing according to plan. Sasol obtained 100 skips and is awaiting the delivery of the compactor vehicle, which will all be donated to the Municipality in order to continue with providing the waste removal service.

The Rapid Intervention Vehicle (RIV) has been in service since November 2017 and continues to respond to various incidents in and around Sasolburg, including waste and veld fires. Discussions with the Municipality is ongoing to ensure that the RIV is predominantly used to address waste and veld fires in the area, especially during the winter period, despite competing priorities within the Municipality from time to time.

It is however not without challenges as the burning of waste sporadically continues in the community. This behaviour change will be addressed via the Education and Awareness program which will commence in due course.

The delivery of the 6 000 litre water tanker, that is intended to support the RIV, has been delayed and is expected at the end of June 2018. This would still be in time to assist the RIV with veld fires within the high risk season.

4.4.3 Sasol’s capital investment/expenditure towards the implementation of offsets

4.4.4 Eskom Power stations offsets implementation Timeframe Target (Major) Progress

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Jan 2017- Dec 2017 Baseline determination, pilot studies and planning for at least one community in each of the powers stations in Nkangala, Gert Sibanda and Fezile Dadi District Municipalities. The affected power stations include: Hendrina, Arnot, Komati, Matla, Kriel, Duvha, Kendal, Tutuka, Majuba, Grootvlei, Camden and Lethabo.It is planned that the intervention solution that will be rolled out at 100% of the qualifying households at KwaZamokuhle and 90% of qualifying households at Ezamokuhle will be electricity with LPG as a back-up

In Sharpeville and Marapong a baseline assessment is being undertaken to help ascertain what interventions will be most effective in curbing waste burning practices in these areas.

The preliminary results of the 30 household’s pilot indicate that it is feasible to switch households from coal to electricity, however there is the risk associated with electricity interruptions in the affected areas. Based on the results of this pilot (electricity) and the previous pilot (LPG), the programme team is now busy evaluating options for large scale implementation. The final report for the electricity pilot is expected by 30 March 2018.

Jan 2018 - June 2018 Beginning of implementation in three of the affected communities. For the lead implementation, offset will be rolled out in 2018/19 financial year in KwaZamokuhle, Ezamokuhle and Sharpeville. In KwaZamokuhle and Ezamokuhle, households will be switched from using coal to electricity with LPG combination.

In Sharpeville/Vaal area, the main sources of ambient air pollution have been identified as road dust, domestic wood & coal burning practices and waste burning. A baseline assessment is being undertaken to help ascertain what interventions to address these sources.

The final report for the 30 household electricity pilot was produced in March 2018. Based on this result and the 2016/17 general pilot study, it is considered feasible to switch households to electricity with a LPG backup.

4.5 Applications for further postponementsIt is acknowledged that the postponement legal framework in its current form has its limitations and as such might

be exposed to abuse. One of such limitations is that there is no limitation in relation to the number of

postponement applications that could be made for a facility. Thus, postponements could be made in perpetuity.

Five applications for further postponement have been lodged with the Department. These applications, together

with the rationale for such applications are indicated in the table below:

4.5.1 Eskom’s further postponement applications Name of Facility Reasons for application Proposed mitigation

measuresDecisions

Eskom Matimba A 5-year [from what period to what

period was not specified] postponement

of the ‘existing plant’ SO2 emission limit

of 3500 mg/Nm3, as stipulated in the

Minimum Emission Standards, for

Matimba Power Station. A more lenient

daily SO2 emission limit of 4000

In the short- to medium-term,

there is no simple remedy to

the situation and all potential

solutions bring along with them

huge operational,

environmental and financial

implications. Load losses, coal

A positive decision for this

application was granted with

an emission limit of 3500

mg/Nm3 on a monthly

averaging period from 10

September 2018 to 31 March

2020. Thereafter, the decision

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mg/Nm3 (at 273 K, 101.3 kPa, dry and

10% O2) or a monthly limit of 3500


10% O2) is requested. The current SO2

daily emission limit of 3500 mg/Nm3 is

exceeded sporadically at the power

station when batches of high Sulphur

coal are received. Eskom faces both

technical and contractual limitations in

sourcing lower Sulphur coal, and flue

gas desulphurisation cannot be installed

in the short-term.

The 2014 application for exiting SO2

standards was rejected but granted for

new standards from 2020 to 2025 on the

basis that emissions result showed that

there was compliance with the

standards and as such the utility was

expected to comply with the existing

standards until 31 March 2025 and

thereafter with the new plant standards.

The availability of new evidence in the

form of continuous emission monitoring

outputs at Matimba Power Station has

confirmed that infrequent exceedances

of the SO2 limit of 3500 mg/Nm3 are

indeed taking place due to daily

fluctuating Sulphur content of coal. For

this reason, Eskom is requesting

postponement of the existing plant limit

for SO2 and requesting either a more

lenient daily limit of 4000 mg/Nm3 or a

monthly limit of 3500 mg/Nm3.

The root cause of the high SO2

emissions experienced at the station is

the high Sulphur content in the coal

supplied by Exxaro Grootegeluk Coal

beneficiation practices,

alterations to existing coal

contracts and options to source

coal from other mines are all

options that have been looked

into to find potential solutions,

but have proven not to be

feasible. Currently Eskom is

liaising with Grootegeluk Mine,

the sole supplier of coal to

Matimba Power Station, to

identify ways in which the

problems can be addressed.

Additionally, Eskom is

conducting internal

investigations to identify

whether anything can be

addressed on the plant directly

to remedy the situation.

Reliance is being placed on

overall air improvement as a

result of FGD in Medupi.

Moreover, since the excessive

cost of FGD at Matimba (which

would raise the electricity tariff

by at least 1%) is not justified

given the very small impact of

Matimba’s emissions on

human health, it is argued that

is in the national interest for

this postponement application

to be approved. Blending of

high S coal and low S coal is

said to have been taking place

since 2015 both in the mine’s

pit and on the stockpiles at the

mine before being dispatched

to the station. It is said that

blending only reduces the

variability of S content but not

reached in 2015 for the period

1 April 2020 to 31March 2025

takes effect, with a monthly

averaging period.

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Mine. The high Sulphur content is an

inherent property of the coal available in

the Waterberg coal seams.

the average S content which

still remains high and leads to

exceedances of the MES.

Eskom Medupi Eskom is making an application to the

National Air Quality Officer for a 5-year

postponement of the ‘existing plant’ SO2

emission limit of 3500 mg/Nm3, as

stipulated in the Minimum Emission

Standards, for Medupi Power Station. A

more lenient daily SO2 emission limit of

4000 mg/Nm3 (at 273 K, 101.3 kPa, dry

and 10% O2) or a monthly limit of 3500


10% O2) is also being requested. The

SO2 emission limit of 3500 mg/Nm3 is

exceeded sporadically at the power

station when batches of high Sulphur

coal are received. Eskom faces both

technical and contractual limitations in

sourcing lower Sulphur coal, and flue

gas desulphurisation cannot be installed

in the short-term. Same reasoning as in

the Matimba, with the exception of a

FGD, which will be installed 6 years

after each of the units were

commissioned, that is from 2021

onwards [From June 2021 to June 2025]

Medupi Power Station will be brought

into compliance with the new plant SO2

emission limit of 500 mg/Nm3 when Flue

Gas Desulphurisation is retrofitted onto

the units six years after they are

commissioned (from 2021 onwards).

FGD, which will be installed 6

years after each of the units

were commissioned, that is

from 2021 onwards to June

2025. Applicant argues that

blending will reduce variability

in S content but does not

provide clarity whether or not

this would bring about

compliance or noncompliance.

A positive decision for this

application was granted with

an emission limit of 3500

mg/Nm3 on a monthly

averaging period from 10

September 2018 to 31 March

2020. Thereafter, the decision

reached in 2015 for the period

1 April 2020 to 31March 2025

takes effect, with a monthly

averaging period.

3.4.2 Sasol’s further postponement applicationsFacility Name Reasons for application Proposed mitigation measures Decision

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Sasol Sasolburg

and Secunda

Between 2013 and 2014 Sasol undertook a

process to apply for postponements from the

2015 compliance timeframes of the MES.

Sasol was granted extended compliance

timeframes by the National Air Quality Officer

(NAQO), with the concurrence of its licensing

officer. The postponement decisions,

including the compliance extensions, for

these sources were subsequently reflected in

Sasol’s varied Atmospheric Emissions

Licence (AEL). In certain instances,

compliance extensions were granted for

three years only from 1 April 2015, with a

resultant 31 March 2018 compliance

timeframe (“2018 compliance timeframe”), in

place of the five years initially requested. The

affected sources are mainly incinerators used

for the treatment of hazardous waste.

The 2014 Postponement Application,

compliance extension was only granted until

31 March 2018 rather than the five years

which was requested in that application. As

set out in this application (hereafter referred

to as the “2017 Postponement Application”),

Sasol will be challenged to meet the MES for

some sources, as reflected within its varied

AEL, by 31 March 2018. Sasol is therefore

applying for a further five-year postponement

to allow the necessary time to conclude on

the feasibility studies and select the optimal

compliance solution, and thereafter, pending

the outcome of that decision, to allow for the

approval and commencement of the safe

execution of the associated projects, which, if

proved feasible, will bring about compliance

with the prescribed existing plant standards

for the affected incinerators. This timeline will

extend beyond the five year extension

requested in this postponement application[to

extend the initial three year compliance

No mitigation measure has been

identified yet and the applicant is

requesting further postponement

in order to conduct further

studies that would help in the

identification of a proper solution.

In the meantime the company is

requesting higher emission limits

than what was granted in the

initial postponement decision.

Further explanation is provided

below

The 2014 baseline sampling

campaigns for the B6993 and

B6990 incinerators, SO2

emissions were virtually non-

existent in the stacks. On this

basis, SO did not apply for a

postponement in this regard.

Subsequent stack

measurements and feedstock

analyses have confirmed that

both incinerators have sulphur

components and hence these

incineration processes produce

SO2 emissions which are

different to the best available

information which informed the

2014 baseline with similar

feedstock. Additionally, the dust

emissions for the B6990

incinerator could be quantified

and hence this is included.

SO is engaging with the

Department of Environmental

Affairs’ Enforcement

Inspectorate as well as its

licensing authority regarding the

elevated emissions measured

A positive decision was

granted. Emission limits

on the decisions were

calculated from the

emission reports

submitted. Based on

DEA’s assessment of the

Emission reports the

limits granted were lower

than that requested by

the applicant, in some

instances. The

postponement period

granted were for

additional 2 years in

order to complete the 5

years cycle running from

2015 to 2020 and thus

shorter than that

requested by the

applicant.

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extension granted to 2023]

The requested postponement period of five

years requested, extends beyond 1 April

2020, the date when the new plant standards

take effect. Therefore, application is

simultaneously being made for a

postponement of both the existing and new

plant standards to align with the five year

postponement period being requested. Sasol

argues that it is likely that a further

postponement application will be required to

be made to extend the postponement period

beyond 2023 to complete execution of the

projects, if proved feasible.

and in order not to act in

contravention of the limits

contained in its AEL, it has

temporarily ceased operation of

the three incinerators; instead

taking the waste stream to

landfill as a provisional solution.

SO has proposed the alternative

emissions limits on the basis of

sampling information which it

believes to be both correct and

representative of the best

available information and with

due regard to measurements,

and statistical analysis which it

believes to be accurate and

reliable.

Even though the temperature

within the B6990 incinerator

remains high, the utilisation of a

titanium probe assembly has

enabled SO to conduct

measurements at elevated

temperatures and this

postponement application

therefore contains a request for

specific alternative emission

limits, rather than on the basis of

the more interim qualitative

measures requested during the

2014 postponement application.

Since the flue gas temperature

on incinerator B6990 exceeds

the 200 ºC temperature limit SO

also applies for a five-year

postponement (1 April 2018 to 1

April 2023) of the compliance

timeframe for special

arrangement 8(a)(vi), and

requests that it be permitted to

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continue operating at current flue

gas exit temperatures (between

500 and 1000 °C).The constraint

regarding the measurement of

emission concentrations for

some of the emission

components at high exit gas

temperatures has been resolved

through the utilisation of the

titanium probe.

Sasol/Natref Extension application for the decision

reached in 2014/15 in relation to existing

plant standards for 17 emission sources [tank

farms, boilers and furnaces, VRUs (for

loading zone)]. Though postponement was

requested up until 31 March 2020, the

decision was only granted until 2018 for 15 of

the 17 applications and up until 2020 for 2

applications. Commits that 11 of these will be

in full compliant with both new and existing

standards by 1 April 2018. Five compliant

points will be challenged to comply with both

new and old standards and thus this

application is for the affected 5 compliance

points [postponement requested from 1 April

2018 to at most March 2022 (but to some, as

early as 2019).

Installation of ESP, VRUs, off

gas amine treatment, etc.

Proposed emissions are

estimated from calculations.

Proposed emissions are higher

than those given in the earlier

postponement decision, in most

cases.

A positive decision was

granted. The applicant

has made tremendous

progress in implementing

most of the commitments

made during the 1st

postponement application

and needs further

postponement to finish off

the work

3.4.3 PPC de Hoek and PPC RiebeeckFacility Name Reasons for application Proposed mitigation measures Decision

PPC de Hoek and

PPC Riebeeck

Currently using two old kiln technologies

that is unable to adequately abate

(scrubbing) SO2 emissions. The SO2

emissions are as a result of the Sulphur

content of lime that is used as input

material in cement production. Initially the

facility was meeting the MES, but due to

different lime (from the second quarry)

Various mitigation options are

being considered that would be

introduced during the upgrades.

These include: scrubbing; re-

routing of the kiln gas and create

means for absorption of SO2;

blending of raw materials; etc.

Replacement of the ESP with

Applications are placed on

hold due to outstanding

information

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which has high Sulphur content, the MES

are exceeded.

bag houses is also being

considered.

4. RECOMMENDATIONSIt is recommended that the Portfolio Committee take note of the following:

4.1 Update on the status of postponement applications

4.2 Roadmaps towards full compliance by industry

4.3 Offsets programmes and their progress

4.4 List of applications for further postponement

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ANNEXURE 1: PROGRESS ON IMPLEMENTATION OF COMPLIANCE

ROADMAPS

Table 1: PROGRESS ON IMPLEMENTATION OF COMPLIANCE ROADMAPS (FOR ALL APPLICATIONS FINALISED BEFORE 1 APRIL 2015: 1ST BATCH)CONFIDENTIAL


Eskom Power StationsPOWER STATTION Postponement

period granted LIMIT GRANTED wrt pollutant/s

PROGRESS COMMENT

Medupi 1 April 2020-31 March 2025

SO2: 3500mg/Nm3 FGD process basic design has been completed.

Planning to conduct detail design work has been initiated.

Rail siding detail designs has been completed. Specialist studies has been completed and highlighted risks with the proposed permanent disposal options evaluated.

Still on track, even though construction delays due to the project management related matters

Majuba 1 April 2020-31 March 2020

SO2: 3200 mg/Nm3 Detailed designs were completed in October 2017. Currently preparing ERA submission to Eskom investment committees.

Challenges of unspecified nature would lead to one of the units not meeting the compliance timeframe of 1 April 2025. Detailed information on how this would be resolved was not provided.

1 April 2015-31 March 2020

NOx : 1500mg/Nm3

Duvha 1 April 2020-31 March 2025

SO2: 2600mg/Nm3

NOx: 1100mg/Nm3

The plans to install FFP on Units 4-6 have been cancelled. Instead, ESPs HFPSs will be installed, and the ESPs, DHPs and SO3 plants will be refurbished and ammonia injection introduced on 3 units. Installation of the HFPSs on unit 5 was completed in June 2017. Basic designs for Units 4 & 6 were completed in August 2017. Investment approval for execution obtained in December 2017.

Risk that units 4 and 6 will not be able to meet emission standards for new plants by 1 April 2020. Eskom plans to request a monthly emission limit for these units.

Tutuka 1 April 2015-31 March 2020 [Granted for existing plant standards]

PM: 350mg/Nm3 PFMA approval was received in January 2017. Project is out on tender and suppliers have requested extension twice.

Delays due to procurement challenges will pose the risk on the last unit not complying with the 1 April 2021 timeframe.

1 April 2015-31 March 2020

NOx: 1200mg/Nm3 Detailed designs have been completed. ERA investment approval process started.

On track

Kriel 1 April 2015-31 March 2020

PM: 350mg/Nm3 PFMA application made to DPE was declined on 9 February 2018 which is based on the need for the integrated Resources Plan (IRP) to be published by DPE.

Delays associated with procurement challenges as a result of the new National Treasury Procurement process requirements and engineering technical design issues. Additional engineering design capacity has been sought to resolve some of the

1 April 2020-31March 2025

SO2: 2800mg/Nm3

CONFIDENTIAL15


challenges. 1 April 2015-31 March 2020

NOx: 1600mg/Nm3

Matla 1 April 2015-31 March 2020

PM: 200mg/Nm3 The plans to install FFP on all units have been cancelled. ESP HFPSs will be installed and ammonia injection may be introduced on all Units. Basic design for HFPS pilot on one unit have been completed and the ERA for the pilot approved. Concept designs completed in August 2017 and basic design have commenced

Risk that units will not be able to meet emission standards for new plants by 1 April 2020. Eskom plans to request a monthly emission limit for these units

1 April 2015-31 March 2020

NOx: 1200mg/Nm3 Basic designs were completed in June 2017. Currently busy with the detailed designs.

Last unit is at risk of not complying with the 1 April 2025 timeframe.

Grootvlei 1 April 2015-31 March 2018

PM: 350mg/Nm3

FFP retrofits have been completed on Units 2, 3 and 4 and handed over to Generation for operation.

On track: FFP retrofits have been completed on Units 2, 3 and 4 and handed over to Generation for operation.

1 April 2015-31 March 2020

SO2: 3800mg/Nm3

1 April 2015-31 March 2020

NOx:1200mg/Nm3

Komati 1 April 2015-31 March 2020

NOx: 1400mg/Nm3 No commitments made. due to the fact that the facility has a short remaining life (scheduled to be decommissioned between 2024 and 2028

N/A`

1 April 2020-31March 2025

SO2: 3200mg/Nm3

Camden 1 April 2015-31 March 2020

SO2: 4000mg/Nm3 LBN technology replacements have been completed on two units, with the third unit in progress as of December 2016. Five units are still to be retrofitted

Four Units (1, 2, 4 & 6) have been retrofitted with LNB, completed and handed back to generation for operation.

1 April 2015-31 March 2020

NOx: 1700mg/Nm3

Power Station Postponement Period granted

Limit(mg/Nm3) Progress Comment

Acacia 2020-25 NOX : 750 Uncertain Info not available

Arnot 2020 -25 SO2: 2500 Uncertain Eskom is now saying that no decisions have yet been made as to when to decommission any power station. This leaves the matter open ended.

2020-25 NOX: 750

Camden 2020-25 SO2 : 3500 Uncertain Eskom is now saying that no decisions have yet been made as to when to decommission any power station. This leaves the

CONFIDENTIAL16


matter open ended. 2015-20 NOX: 1300

Hendrina 2020-25 SO2: 3200 Uncertain Eskom is now saying that no decisions have yet been made as to when to decommission any power station. This leaves the matter open ended.

2015-20 NOX: 1200

Kendal 2020-25 SO2: 3200 Uncertain PM emissions to be reduced through the installation of high frequency transformers, and the refurbishment of the electrostatic precipitators, SO3 plants and dust handling plants. No mention is made however on the plans to comply with the SO2 limit of 500 mg/Nm3 by 2025.

Komati 2020-25 SO2: 2600 Uncertain Eskom is now saying that no decisions have yet been made as to when to decommission any power station. This leaves the matter open ended.

2015-20 NOX: 1300

Lethabo Dec 2015 PM: 100 Extensive repairs have been performed on Lethabo’s ESP’s to repair the damage caused by the ash backlogs in November 2014. PM emission performance has improved as a result. PM emissions to be further reduced through the installation of high frequency transformers, an upgrade of the SO3 plants, and the refurbishment of the electrostatic precipitators and dust handling plants

Progress noted

2020-25 SO2 : 2600

2015-20 NOX :1300

Matimba 2020-25 SO2 : 3500 Uncertain PM emissions to be reduced through the installation of high frequency transformers, and the refurbishment of the electrostatic precipitators, SO3 plants and dust handling plants. No mention is made however on the plans to comply with the SO2 limit of 500 mg/Nm3 by 2025.

Port Rex 2020-25 NOX : 600 Uncertain Info not available

SHELL (PTY) LTD: Progress report on Shell facilitiesNAME OF FACILITY Postponement LIMIT GRANTED wrt ACTIVITY TO MEET PROGRESS COMMENT

CONFIDENTIAL17


period granted pollutant/s COMPLIANCE AND TARGET DATE

Shell Kimberly fuel storage facility

1 April 2015-31 March 2017

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU Shell has embarked in a process to sell this facility.

Storage of petrochemicals has been significantly reduced with current throughput not exceeding 50 000m3 per annum.

Negotiations with potential buyers are being concluded with the deal planned to be finalized by the end of 2016.

Shell is in the process of selling this facility hence the installation of the VRU is not going to happen.

Shell Ladysmith fuel storage facility

1 April 2015-31 March 2017

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU VRU has been installed and functioning optimally. The postponement application has been closed.

Upgrade is completed and target has been achieved

Shell Polokwane fuel storage facility

1 April 2015-31 March 2017

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU VRU has been installed and functioning optimally. The postponement application has been closed.


Shell Port Elizabeth terminal

1 April 2015-31 March 2020

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU The motivation for the postponement was that the site will be decommissioned and relocated to the new site by end of 2017, hence the postponement was granted till 2017. There has been new developments communicated by the TNPA that the lifetime at PE has been extended to 2019 as the new site (Coega IDZ) is not yet ready.

Shell has applied for a new postponement until 2020 when the facility will be moved to the new terminal that will be equipped with a state-of-the-art Vapour Recovery Unit (VRU).

Postponement decision was granted on 14 February 2017 on condition that the tank farm would have been relocated to the Coega IDZ by 31

The construction of the new tank farm at Coega IDZ where the VRU will be installed is ongoing.

CONFIDENTIAL18


March 2020. Alternatively, the facility is required to have an operational VRU in its current location by 1 April 2020.

PPC: Progress report on PPC facilitiesNAME OF FACILITY Postponement period

granted LIMIT GRANTED wrt pollutant/s

ACTIVITY TO MEET COMPLIANCE AND TARGET DATE

PROGRESS COMMENT

PPC De Hoek Plant Finishing Mill 6

1 April 2015-31 December 2016

PM: 100mg/Nm3 Installation of a bag filter to replace existing ESP

Upgrade completed emissions below 10mg/Nm3 for PM.

Upgrade Completed for PM.

However, PPC De Hoek has applied for a new postponement for SO2.

PPC Dwaalboom PlantKiln 1


PM: 200mg/Nm3 Bag filter upgrade Feasibility studies commenced for bag filter upgrade – upgrade to commence January 2017

Upgrade Completed

PPC Port Elizabeth PlantKiln 4


PM: 200mg/Nm3 Installation of a bag filter to replace Kiln ESP

To be decommissioned beyond June 2019. The clinker rail facility is under construction for commissioning by April

On track

PPC Port Elizabeth PlantFinishing Mill 4


PM: 400mg/Nm3 Installation of a bag filter to replace existing dust collector

EIA approved, upgrade completed, performance testing took place in July 2016

Upgrade Completed

PPC Slurry PlantKiln 7


PM: 350mg/Nm3 Upgrade of Kiln 8 while Kiln 7 is operational. Afterwards Kiln 7 is under care and maintenance

Construction of Slurry Kiln 9 is completed

Construction is completed

PPC Slurry PlantRaw Mill 3


PM: 250mg/Nm3 Upgrade of Raw Mill 3 The facility is not in use NA

Progress report on Engen facilitiesNAME OF FACILITY Postponement LIMIT GRANTED wrt ACTIVITY TO MEET PROGRESS COMMENT

CONFIDENTIAL19


ENGEN

period granted pollutant/s COMPLIANCE AND TARGET DATE

Engen Petroleum

Limited

1 April 2015-31

March 2019

PM: 140mg/Nm3 Retrofit - FCCU

Particulate Matter

Compliance

Engen has interrogated the work done to date

as well as additional information on emissions

gathered over the last 2 years. The proposed

technology namely, a Wet Gas Scrubber

(WGS) was reviewed. Engen has also

investigated in parallel other improvement

mechanisms, and has decided not to proceed

with the WGS option due to additional

environmental and sustainability concerns

arising around vast quantities of water that

would be needed for cooling as well as a

resultant effluent waste stream high in

sulphates that would not meet the Refinery’s

Trade Effluent Permit limits without further

treatment. Treatment options result in a

hazardous waste sludge that would require

landfill disposal. After assessing the above

holistically and in terms of a cost benefit

analysis as well as recent stack emissions

testing, it has been decided to focus on the

operational improvements that can be made to

ensure the particulate matter specification is

met. Stack emission testing has shown that

the particulate matter emissions are meeting

the 2015 specification for existing plant hence

Engen will continue to drive the operational

optimization to maintain the compliance.

PM emission in compliance with existing plant standard

CONFIDENTIAL20


1 April 2015-31

March 2016

TVOCs:

150mg/Nm3

40000mg/Nm3

Installation of a Vapor

Recovery Unit at

Gasoline Rail Loading

Installation of the Vapour Recovery Unit has

been completed at the rail loading facility. Unit

is currently not in use (no gasoline loading

taking place) and will be online when gasoline

rail loading resumes.


1 April 2015-31

March 2016

TVOCs Installation of internal

floating roofs on 2

tanks within the

Refinery viz X-239 and

X-240

Manufacturing of X-239 and X-240 internal

floating roofs completed.

Tank X240 was commissioned and is in

service with internal floating roof in place.

Tank X239 is currently not in use


Progress report on Total DepotNAME OF FACILITYTOTAL

Postponement period granted

LIMIT GRANTED wrt pollutant/s


PROGRESS COMMENT

Total Polokwane depot

1 April 2015-31 March 2016

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU VRU order was completed in November 2014.

VRU delivery was completed in August 2015.

The installation of VRU is in progress.

VRU was installed by the John Zink Company

based in Luxembourg. It was commissioned

on 25 August 2016 and declare safe and

ready for use by the consulting engineering

group JGP.


Total Polokwane depot

1 April 2015-31 March 2016

TVOCs:150mg/Nm3

40000mg/Nm3

Retrofit- VRU VRU was installed by the John Zink Company

based in Luxembourg. It was commissioned

on 25 August 2016 and declare safe and

ready for use by the consulting engineering


CONFIDENTIAL21


group JGP.

Progress report on Anglo AmericanNAME OF FACILITYANGLO AMERICAN PLATINUM (AAP)




PROGRESS COMMENT

AAP – Mortimer Smelter

1 April 2015-31 March 2020

SO2: 30000mg/Nm3

Retrofit- SO2 abatement equipment

The meeting of the 20 June 2018 between the

DG of DEA and AAP CEO has the following

outcome: postponement application of the

implementation of the April 2020

1,200mg/Nm3 emission limit for Mortimer until

end 2023 to be submitted – to allow time to

prove the new technology at Polokwane and

build the plant at Mortimer.

Environmental authorisation for the SO2

abatement project was issued 12 March 2018

and there is no new water uses that was

triggered.

The installation of SO2 abatement equipment at Mortimer smelter is in progress.

AAP – Polokwane Smelter

1 April 2015-31 March 2020

SO2: 30000mg/Nm3 Retrofit- SO2

abatement equipmentThe meeting of the 20 June 2018 between

DEA DG and AAP CEO has the following

outcome:

1. AAP would prefer to resolve the current

legal action on mutually acceptable terms and,

if necessary, make such settlement an order

out of court.

2. Request an interim emission level of up to

57,000mg/Nm3 (based on actual data and

design calculations) for Polokwane Smelter

during the construction and commissioning

periods; and

Environmental authorization for the SO2

abatement project was issued 26 October

2017. Water use license was issued 13

February 2018.

CONFIDENTIAL22


3. Submit a postponement of the

implementation of the April 2020

1,200mg/Nm3 emissions limit at Polokwane

until the end of 2020.

Progress report for SASOL SECUNDANAME OF FACILITY POSTPONEMENT

PERIOD GRANTED

LIMIT GRANTED wrt POLLUTANT/S


PROGRESS COMMENT

Sub-category 1.1:

Solid Fuel

Combustion

Installations (Steam

Plant)

1 April 2015-31

March 2020

1 April 2020-31

March 2025

NA

PM – 120 mg/Nm3

SO2 – 2000 mg/Nm3

NOx – postponement

is declined

Retrofit- PM - Capital was approved to install test units

of three technologies on different boilers. The

technologies are high frequency transformers,

medium frequency transformers and high

frequency, short pulse transformers. The

installation of HFT on two other boilers is

planned to commence from July 2018

SO2 - Sasol faces significant challenges in

identifying implementable technologies to

sustainably meet some of the new plant

standards in the MES. A further emissions

reduction towards new plant standards

continues to pose a significant challenge for

Sasol.

NOx - Current NOx abatement project has

progressed to feasibility engineering.

Installation of LNB on one boiler is expected

during a general overhaul of a boiler in 2019.

PM: On track

SO2 – The facility is facing challenges with

abatement equipment for SO2

NOx – There is an ongoing abatement

project for NOx even though the

postponement is declined

Sub-category 2.2: 1 April 2015-31 PM – 330 mg/Nm3 Retrofit- The project to reduce PM emissions at the Facility is facing challenges with technology

CONFIDENTIAL23


Catalytic Cracking

Unit (Superflex

Catalytic Cracker)

March 2020 SCC unit will continue to develop the most

feasible option further and the feasibility phase

has commenced.

options

Sub-category 3.6:

Synthetic Gas

Production &Cleanup

(Rectisol &Sulphur

Recovery Plants)

1 April 2015-31

March 2020

1 April 2015-31

March 2020

1 April 2015-31

March 2017

H2S – 8400 mg/Nm3

TVOCs – 300

mg/Nm3

SO2 – 3500 mg/Nm3

(undertake emission

measurement and

report quarterly until

1 April 2017)

Retrofit- H2S – Discussions with the Local Licensing

Authority took place to confirm the monitoring

requirements, as per the AEL, in the interest

of sustained compliance.

TVOCs – upgrade is completed

SO2 – upgrade is completed

H2S - On track

TVOCs – Upgrade is completed and target

has been achieved

SO2 – Upgrade is completed and target

has been achieved

Sub-category 3.6:

Synthetic Gas

Production &Cleanup

(Phenosolvan Plant)

1 April 2015-31

March 2018

TVOCs – 250

mg/Nm3

(undertake emission

measurement and

report quarterly until

1 April 2018)

Retrofit- It was confirmed that sufficient spare capacity

is available at the existing regenerative

thermal oxidisers (RTOs) that were

commissioned in 2017 to tie in this project.

The project is continuing with the development

of this action.

On track

Sub-category 3.3 &

3.6: Tar Processes

Synthetic Gas

Production &

Cleanup (Tar Value

Chain-Value 1)

1 April 2015-31

March 2017

TVOCs – Emissions

are to be

incorporated into the

site fugitive

emissions monitoring

plan

Retrofit- TVOCs – upgrade is completed TVOCS – Upgrade is completed and target

has been achieved

Sub-category 3.3:

Tar Processes (Tar

1 April 2015-31

March 2020

TVOCs – Emissions

are to be

Retrofit- The project was approved for implementation.

Detail engineering is on schedule and

On track

CONFIDENTIAL24


Value Chain-Value 2) incorporated into the

site fugitive


plan

procurement of long lead items is in progress.

Category : Organic

Chemicals Industry

(Tanks Solvents)

1 April 2015-31

March 2020

TVOCs – Emissions

are to be


site fugitive


plan

Retrofit- Technology selection is in progress for the

Carbonyl tanks. Baseline sampling will

commence over the next eighteen months,

together with tanks under sub-category 2.4.

On track

Sub-category 2.4:

Storage & Handling

of Petroleum

Products (Tanks

Synfuels)

1 April 2015-31

March 2020

TVOCs – Emissions

are to be


site fugitive


plan

Retrofit- It is planned to install abatement technology

on the second coal tar naphtha tank during the

September 2018 shutdown.

On track

Sub-category 2.4:

Storage & Handling

of Petroleum

Products (Loading

Station

1 April 2015-31

March 2020

TVOCs – Emissions

are to be


site fugitive


plan

Retrofit- TVOCs – upgrade is completed TVOCS – Upgrade is completed and target

has been achieved

Sub-category 8.1:

Thermal Treatment

of Hazardous &

General Waste (How

& Biosludge

Incinerators)

1 April 2015-31

March 2020

Various pollutants –

with different

emission limits

specified for the

different pollutants

Retrofit- A project, which is in the pre-feasibility

engineering phase, is in progress to

investigate various incinerator technology

options in the interest of integrated

environmental management.

How & Biosludge Incinerator – on track

CONFIDENTIAL25


Sewage Solids

Incinerators

Completed - The incinerator was

decommissioned and the waste stream is

being managed by a third party disposal

solution.

Sewage Solids Incinerator - This is

completed as the incinerator has been

decommissioned

Progress report for SASOL SASOLBURG

NAME OF FACILITYSASOL-SECUNDA




PROGRESS COMMENT

Sub-category 1.1:

Solid Fuel

Combustion

Installations

(Steam station 1)

1 April 2015-31

March 2020

1 April 2020-31

March 2025

1 April 2015-31

March 2020

PM – 165 mg/Nm3

SO2 – 2000 mg/Nm3

NOx – 1450 mg/Nm3

Retrofit- PM - Technical work is ongoing to confirm

practical capital expenditure and operational

solutions




standards in the MES

NOx - The Low NOx burner piloting which will

take place at Steam Station 2, as indicated

below, will inform the technology selection for

Steam Station 1 as well.

On track

SO2 – facility is facing technical challenges

NOx – On track

Sub-category 1.1

(Steam station 2)

NA PM – Postponement

is declined

Retrofit- PM - The 1st ESP upgrade on Boiler 12 has

been completed in May 2018 and will undergo

PM – There is an ongoing abatement

project for PM even though the

CONFIDENTIAL26


1 April 2020-31

March 2025

1 April 2015-31

March 2020

SO2 – 2000 mg/Nm3

NOx – 1250 mg/Nm3

rigorous testing to ensure compliance with the

new plant standards




standards in the MES

NOx - The first LNB upgrade on Boiler 12 has

been completed in May 2018 and will undergo

rigorous testing to ensure compliance with the

new plant standards

postponement is declined

SO2 – facility has technical challenges

NOx – on track

Sub-category 8.1

(B6930 - High

Sulphur pitch

incinerator)

1 April 2015-31

March 2020


with different

emission limits

specified for the


Retrofit- The values received on the decision in the

postponement application were lower that

what was requested so the units will remain

shut down while evaluations are continuing on

whether sustainable and compliant operations

can be assured. Should SO decide to re-

commission the units the Fezile Dabi District

Municipality Air Quality Officer will be duly

informed.

A new postponement decision has been

granted until 31 March 2020

Sub-category 8.1

(B6993 - Spent

caustic incinerator)

1 April 2015-31

March 2020


with different

emission limits

specified for the


Retrofit- Same as above in B6930 A new postponement decision has been


Sub-category 8.1

(B6990 - Heavy end

B incinerator)

1 April 2015-31

March 2018


with different

emission limits

Retrofit- Same as above in B6930 A new postponement decision has been


CONFIDENTIAL27


specified for the


Progress report for NATREFNAME OF FACILITYNATREF




PROGRESS COMMENT

Sub-category 2.1:

Combustion

Installations (Boilers

& hot oil heaters

1 April 2015-31

March 2020

PM – 350 mg/Nm3

SO2 – 1700 mg/Nm3

NOx – 1700 mg/Nm3

Retrofit- Basic engineering was completed in October

2017. The project is currently in the detailed

engineering phase. Capital was approved on

24 April 2018 to execute this project.



Sub-category 2.1:

Combustion

Installations

(Vacuum off-gas

furnace and

CDU/VDU furnaces)

1 April 2015-31

March 2021

PM – 180 mg/Nm3

SO2 – 1700 mg/Nm3

NOx – 1700 mg/Nm3

Retrofit- Technology selection was completed and

capital expenditure for the basic engineering

phase was approved in January 2017. The

basic engineering is currently progressing

according to the planned project schedule as

aligned with the roadmap.



Sub-category 2.2:

Catalytic Cracking

Unit (FCC)

1 April 2015-31

March 2022

PM – 150 mg/Nm3

SO2 – 3000 mg/Nm3

NOx – 550 mg/Nm3

Retrofit- ESP

technology was

selected as the optimal

solution

The basic engineering phase has been

concluded in November 2017. The final

investment decision for the execution phase of

the project was submitted to the investment

governance structures. Investment decision

planned for 31 July 2018.



Sub-category 2.3:

Sulphur Recovery

Unit - SRU

1 April 2015-31

March 2020

Postponement

granted with a

condition of 95%

Retrofit- The feasibility study was concluded in

November 2017. A series of potential

incremental improvements, including solutions



CONFIDENTIAL28


availability for the unit to increase SRU availability, have been

identified for further development in the basic

engineering phase which is in progress.

Sub-category 2.4:

Storage & Handling

of Petroleum

Products (Tank farm)

1 April 2015-31

March 2019

Postponement

granted with

emissions reported

as part of the site

fugitive emissions

monitoring plan

Retrofit- Natref has completed an internal technology

screening and selection process of the

prescribed control measures and determined

that a VRU is the technology of choice. The

basic engineering development of the VRU

was concluded in December 2017 and

detailed engineering development of the VRU

is in progress and orders for long leads have

been placed.



Table 2: Progress report for all applications received after 1 April 2015 (Second batch)

NAME OF FACILITY POSTPONEMENT PERIOD GRANTED

LIMIT GRANTED wrt POLLUTANT/S


PROGRESS COMMENT

Quantum Crushing &

Screening (Pty) Ltd [Sub-

category 3.4: Char,

charcoal and carbon

black production]

31 May 2017-31

March 2020

PM: 6276mg/Nm3 Construction of a new

plant to replace the

existing two non-

compliant plants

Funding for the construction of the

new plant has been secured from

ABSA. In the meantime there are

consideration to reduce emissions

from the two plants by installing

control devices (bag filters).

Capital funding is in the process

of being sourced for purchasing

the bag-filters.

Good progress is being made and there are

commitments to finalise the project before

the end of the granted postponement

period.

CONFIDENTIAL29


Chevron Port Elizabeth

Terminal [Sub-category

2.4: Handling and

Storage of Petroleum

Products]

1 December 2016-31

March 2020

TVOCs: N/A Installation of Vapour

Recovery Unit (VRU)

Chevron is actively working on the

decommissioning and relocation

of the Port Elizabeth tank farm.

In the case of the tank farm not

being relocated; Chevron will

activate a contingent plan but this

will only be at the beginning of

2019 to install a VRU and

commission the unit in the 1st

quarter of 2020.

Postponement is granted on condition that

the tank farm will have been relocated to

the Coega IDZ by 31 March 2020

Chevron Refinery Cape

Town [2.1 Combustion

installations; 2.4: handling

and storage of petroleum

products]

1 April 2016-31 July

2017: Combustion

installations

SO2: 2400 mg/Nm3 Making changes and

refinements to the

Process furnace to

reduce emissions in order

to achieve compliance

with MES

Refinements had been completed

before 31 July 2017. Emissions

tests have been conducted and

verified by an independent

consultant and show that

emissions are below existing

MES(i.e 770 mg/Nm3 vs 1700 for

existing MES and 1000 for new

MES)

Sulphur Dioxide emissions from Process

Furnace 02F201 is in compliance with

MES.

All upgrades are completed.

1 April 2016-31 March

2020: Storage &

Handling of petroleum

products

TVOC: N/A Installation of roof leg

sleeves on floating roof

tanks to minimize

emissions

Progress being made as planned,

even exceeding originals

scheduled in some instance.

Nineteen (19) tanks out of 42

have been fitted with sleeves and

work is in progress on other tanks

Good progress is being made and there is

likelihood that target will be met.

BPSA Watloo Depot

[Category 2.4: Handling


products]

N/A: application was

withdrawn/closed due

to compliance

TVOC: N/A Installation of Vapour

Recovery Unit (VRU)

Installation has been completed

while the application was being

considered

The installation and operationalization of

the Vapour Recovery Unit (VRU) has been

confirmed by the facility. All upgrade is

completed

CONFIDENTIAL30


BPSA East London Depot



products]



to compliance


Recovery Unit (VRU)



considered




completed

BPSA Cape Town Depot



products]



to compliance


Recovery Unit (VRU)



considered




completed

Silicon Smelters (Pty) Ltd

- Rand Carbide [4.9:

Ferro-alloy production]

Calciner 1:

PM – 3800 mg/Nm3

100 mg/Nm3

50 mg/Nm3

SO2 – 3700 mg/Nm3

500 mg/Nm3

1 Mar 2017 – 1 May 20191 May 20191 April 2020

1 Mar 2017 – 1 May 20191 May 2019

Retrofit - Pilot plant has been designed and

tested by the University of

Pretoria. Detailed designs for the

full-scale project have been

completed. Manufacture of

equipment for Calciner 1 and

construction of civil work have

been completed.

Good progress has been made and if the

planned project schedule is followed

thoroughly, compliance can be achieved by

the due date.

Calciner 2:

PM – 3800 mg/Nm3

100 mg/Nm3

50 mg/Nm3

SO2 – 3700 mg/Nm3

500 mg/Nm3

1 Mar 2017 – 1 May 20191 May 20191 April 2020

1 Mar 2017 – 1 May 20191 May 2019

Retrofit - Manufacture of equipment and

installation of equipment for

Calciner 2 will only take place in

2019.

AEL Mining Services

[Category 7.2: Production

of acids; Production of

Chemical Fertilizers]

24 April 2017 - 30

March 2020

STILLS PLANT NOx- 4500 mg/Nm3

Converting the current

scrubbing technology into

the one that will improve

efficiency for the Stills

Plant;

A Service Provider has been

appointed to undertake the project

AEL are in the process of

finalizing the capital cost required

and expect the conversion of the

Stills scrubbing process to be




the due date.

CONFIDENTIAL31


implemented in November 2019.

PETN PLANT NOx-120 kg/day

Retrofit - Stacks have been merged to form

one combined stack and this was

completed in December 2017.

Isokinetic sampling conducted in

March 2018 reported NOx

emission levels of 100mg/Nm3




the due date.

ANS 1 & 2 PLANTS via ANSSER PLANT NH3-

2800mg/Nm3 (Minimum

availability of ANSSER

plant is 90%)

Installation of ammonia

scrubber

Tender documents for the design,

supply and installation of the

scrubber have been compiled.

AEL has received tender

proposals and are in the process

of evaluating these tenders to

allow for submission of a detailed

expenditure proposal for internal

group approval.




the due date.

NO. 3 AN Plant PM:

1900mg/Nm3

Installation of candle

filters for PM

Pre-sanction expenditure

proposal has been approved to

conduct a detailed design and

costing of the dual ammonia

scrubber to reduce NH3 emissions

using nitric acid and candle filters

to remove PM.




the due date.

NO. 3 AN Plant NH3:

900mg/Nm3

Installation of ammonia

scrubber

Vanchem Vanadium

Products (VVP) [Category

4.18: Vanadium Ore

Processing]

31 May 2017-31

March 2022

(extended beyond

2020 due to the fact

that its supplier of raw

material was

SO2: 22331 mg/Nm3 Investigation and

installation of abatement

technology

The company has ceased

operation due the fact that the

mine that was supplying input

material (vanadium ore) has

suspended operations. The

company was placed under care

The company has ceased operation and

thus no emissions into the atmosphere.

CONFIDENTIAL32


undergoing business

rescue)

and maintenance.

Illovo Sugar (Gledhow

Sugar Mill) [Category 1.1:

Solid Fuel combustion

installations; and 1.3:

Solid Biomass

Combustion installations]

23 March 2017 – 1

November 2019

1 Nov 2019

1 April 2020

PM –

3800mg/Nm3

100mg/Nm3

50mg/Nm3

Investigation and

installation of PM

abatement technology

(cyclones) and usage of

alternative fuel sources

Investigation of alternative fuel

sources as been completed and

correct type of abatement

technology has been identified.

Approval for capital investment is

completed and abatement

equipment has been ordered.

High pressure cleaning of boilers

1-3 main banks and the

refurbishing of soot blowers,

installation and commissioning

completed.




the due date.

Illovo Sugar (Noodsberg

Sugar Mill)

23 Mar 2017 – 28 Feb

2020

28 Feb 2020

1 April 2020

PM –

3000mg/Nm3

100mg/Nm3

50mg/Nm3

Investigation and

installation of PM


Engineering design for the

abatement equipment has been

completed and capital injection

has been approved. Releasing of

funding to perform engineering on

abatement equipment selection is

also completed.




the due date

Illovo Sugar (Sezela

Sugar Mill)

23 Mar 2017 – 21 Dec

2019

29 Dec 2019

1 April 2020

PM –

300mg/Nm3

100mg/Nm3

50mg/Nm3

Investigation and

installation of PM


Installation of new scrubber is

expected to take place by 31

March 2020 and capital

investment in this regard has

been secured. Annual

maintenance on boiler equipment

completed. Capital application




the due date

CONFIDENTIAL33


has been made to Illovo

Shareholding company, ABF, for

funding of detailed design of

scrubber equipment.

CONFIDENTIAL34

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