2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf

A submission by Sasol to Working Group 4 and a Subcommittee dated 9 March 2009 regarding proposed emission standards and the categorization of waste incinerators under the draft Section 21 of the National Environmental Management: Air Quality Act in South Africa.

• Sasol proposes that waste incinerators in South Africa be divided into three distinct categories based on the IPPC split: municipal waste incinerators, hazardous waste incinerators, and sludge incinerators. This categorization is justified by the fact that plant design varies based on waste chemical composition, physical composition (such as particle size), and thermal characteristics like moisture levels and calorific value.
• Sasol argues that existing incineration facilities should be allowed higher emission concentrations for metals, SO2, HCl, and particulates compared to new plants. This is because older plants have less flexibility for retrofitting abatement technologies and managing fluctuations in waste composition. Sludge incinerators are noted as particularly challenging for particulate reduction because the heat used to evaporate water entrains particulates and saturated steam in the flue gas reduces the effectiveness of certain removal technologies.
• Regarding monitoring, Sasol proposes that continuous emission monitoring be regulated on a permit-by-permit basis due to high costs and technical installation difficulties, such as required stack diameters. Specifically, Sasol requests that sludge incinerators be exempt from continuous monitoring because saturated steam in the flue gas can damage equipment and lead to non-representative results.
• Sasol suggests that monitoring for dioxins and furans should be excluded from permitting requirements if it can be proven in an independently verifiable and auditable way that the waste feed stream contains no chlorinated components. For other applicable cases, metals and dioxin measurements should be conducted by a third party at least once per year.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA29-SASOL-letter-to-WG4-9-03-2009.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA29-SASOL-letter-to-WG4-9-03-2009.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA29-SASOL-letter-to-WG4-9-03-2009.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa29sasollettertowg490320093afa478c91947a8bpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA29-SASOL-letter-to-WG4-9-03-2009.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }