2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf

The Refinery Managers’ Environmental Forum (RMEF) submitted comments on August 21, 2009, regarding proposed regulations under the National Environmental Management: Air Quality Act (NEMAQA) in South Africa. The RMEF argues that the proposed minimum emission standards are technically and economically unachievable for existing refineries, particularly the requirement for existing plants to meet new plant standards within eight years. They advocate for a 'bubble approach' to measure total site impact rather than point-source monitoring and request specific adjustments to particulate matter (PM) and volatile organic compound (VOC) limits to align with Best Available Techniques (BAT) and economic viability.

• The RMEF opposes the requirement for existing refineries to meet the emission standards of new plants within an eight-year timeframe, stating that retrofitting existing facilities is often more expensive, less effective, and sometimes technically impossible due to plant configurations.
• The RMEF proposes increasing the Particulate Matter (PM) limit for existing plants from 100 mg/Nm3 to 120 mg/Nm3, arguing that the lower limit is not consistently achievable with first-generation reduction technology and would require costly second-generation retrofits.
• The RMEF advocates for the retention of the 'bubble approach' for measuring emissions, which focuses on the total impact of a site, rather than shifting to point-source monitoring, which they claim may be less appropriate for the South African context.
• The document highlights a potential conflict between air quality regulations and other environmental media, noting that technologies like wet gas scrubbers for SO2 and PM reduction create high sulphate liquid slurry waste that may violate existing legal restrictions on water discharge.
• The RMEF requests that the thresholds for petroleum product storage tanks and transfer facilities be increased from 100 tons per annum and 500 cubic meters to 1,000 tons per annum and 5,000 cubic meters to avoid negatively impacting small depots and rural development.
• The RMEF suggests that the regulations should establish 'ceiling' limits as minimum standards, while stricter, site-specific standards should be managed through the individual licensing process based on local ambient air quality.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA34-RMEF-Comments-21-8-2009.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA34-RMEF-Comments-21-8-2009.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA34-RMEF-Comments-21-8-2009.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa34rmefcomments2182009be1aea94c7e212b4pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA34-RMEF-Comments-21-8-2009.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }