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2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf

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This briefing document details the proceedings of a technical working group meeting on April 28, 2009, regarding unresolved air quality emission standards for various industrial categories. It records disputes and agreements between government representatives (DEAT, DEADP), industry bodies (SAISI, RMEF, FAPA, ACMP), and NGOs (LRC, Groundwork) over specific pollutant limits for NOx, SO2, particulate matter (PM), and heavy metals.

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  • There is significant disagreement regarding NOx emission limits for existing plants across multiple categories. For category C4.2, the LRC proposed 1200 mg/Nm3 while SAISI proposed 2000 mg/Nm3. In category C1.2, SAISI suggested a limit of 500 mg/Nm3 for existing plants, with the LRC reserving comment.
  • The RMEF and LRC disagree on the use of a 'bubble' approach for SO2 emissions in existing facilities. The RMEF proposed a bubble of 2.2 kg SO2/ton crude, whereas the LRC proposed 0.63 kg SO2/ton (monthly average) crude. DEAT expressed discomfort with the bubble approach, preferring to regulate each point source separately.
  • Eskom requested an increase in the particulate matter (PM) limit for existing plants in category C1.1 to 100 mg/Nm3, stating that electrostatic precipitators (ESPs) cannot meet a 75 mg/m3 limit. This request specifically concerns return-to-service plants in the Highveld priority area, namely Grootvlei and Komati.
  • For the cement industry (C5.3), the ACMP proposed a PM (kiln) limit of 150 mg/Nm3, which was accepted except for urban plants. For urban plants, the LRC proposed a stricter limit of 50 mg/Nm3, later revised to 100 mg/Nm3 on January 13.
  • The working group agreed on specific VOC emission limits for treatment processes: 40 g/Nm3 for non-thermal treatment and 150 mg/Nm3 for thermal treatment.
  • Monitoring and reporting requirements were established, including the agreement that continuous emission monitoring (CEM) systems must be maintained to provide at least 80% of valid hourly average values during the reporting period.
  • A dispute exists regarding the use of waste as fuel in clamp kilns (C5.2). The CBA objects to the prohibition of waste as fuel, noting that typical wastes are natural biomass. The LRC argues that waste should be prohibited unless incinerator standards can be met.

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APA
Centre for Environmental Rights (n.d.). 2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA27-Unresolved-matters-for-WG2.pdf?x21779
Chicago
Centre for Environmental Rights. 2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA27-Unresolved-matters-for-WG2.pdf?x21779.
Wikipedia
{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA27-Unresolved-matters-for-WG2.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{centreforenvironmentalrightsnd20140530fa27unresolvedmattersforwg2b2f71f4b9934e3ebpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA27-Unresolved-matters-for-WG2.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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