2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf

A June 2012 submission by the Natref refinery to the South African Department of Environmental Affairs (DEA) regarding proposed Minimum Emission Standards (MES). Natref argues that inflexible national point source emission standards are impractical for existing facilities and proposes a 'bubble' approach to emissions management to ensure socio-economic sustainability and energy security.

• Natref argues that requiring existing facilities to retrofit to meet the same standards as new plants is not standard international legal practice and is socio-economically unsustainable when combined with other regulatory requirements for waste, water, and carbon emissions up to 2020.
• The refinery's inland location creates specific operational constraints, as it must burn high-sulphur fuel oil internally because there is no local market for bunker fuel, unlike coastal refineries.
• Natref's contribution to the Vaal Triangle Airshed Priority Area (VTAPA) is reported as 10.4% for NOx, 5.4% for SOx, and 4.2% for PM, noting that PM is the priority pollutant in that area.
• The company proposes a 'bubble' approach for emissions management, which it claims is international practice and Best Available Technology (BAT), while suggesting the Fluid Catalytic Cracking (FCC) unit remain a point source for Particulate Matter (PM).
• Natref estimates that the combined investments for Clean Fuels, Air Quality Act (AQA), Water Act, and Waste Act changes over the next 5 to 8 years will exceed R11.5 billion (at +40% accuracy), which could seriously affect refinery profitability.
• The submission highlights a lack of domestic engineering and manufacturing capacity in South Africa, noting that many workshops in the Vaal Triangle are currently occupied by Eskom expansions.
• Natref proposes specific emission limits for existing combustion installations, suggesting 8 mg/Nm3 for PM and 2500 mg/Nm3 for SO2, contrasting with DEA's proposed 120 mg/Nm3 for PM and 1700 mg/Nm3 for SO2.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA46-Natref-submission-05-2012.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA46-Natref-submission-05-2012.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA46-Natref-submission-05-2012.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd20140530fa46natrefsubmission052012018e25d4b2c23688pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA46-Natref-submission-05-2012.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }