2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf

This October 2012 submission from the Natref refinery to the South African Department of Environmental Affairs (DEA) argues that the proposed Minimum Emission Standards (MES) are technically and socio-economically unsustainable for existing inland refineries. Natref advocates for a "bubble" approach to emissions management rather than a point-source approach and requests separate, less stringent limits for existing facilities compared to new plants.

• Natref argues that requiring existing facilities to retrofit to meet the same standards as new plants is not standard international practice and is socio-economically unsustainable when combined with other regulatory requirements like Waste and Water Use legislation, Carbon Emission Reductions, and Clean Fuels II.
• The refinery's inland location creates specific operational constraints, as it cannot sell high-sulphur fuel oil as bunker fuel (as coastal refineries do), forcing it to burn this fuel internally, which increases emissions.
• Natref reports its specific contributions to the Vaal Triangle Airshed Priority Area (VTAPA) as 5.4% for SOx, 10.4% for NOx, and 4.2% for Particulate Matter (PM), noting that PM is the priority pollutant in the region.
• The document claims that engineering and manufacturing capacity within South Africa is currently limited and overstretched due to Eskom projects and other major developments, which could lead to projects being moved overseas and a loss of local jobs.
• Natref proposes the adoption of a "bubble" approach for emissions management, which it describes as an internationally accepted practice and Best Available Technique (BAT) according to CONCAWE 4/2003, while maintaining that the Fluid Catalytic Cracking (FCC) unit should remain a point source for Particulate Matter.
• Natref asserts that a five to ten year implementation timeframe for existing plants to meet new plant standards is unachievable due to the scale and complexity of the required technical solutions.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA52-NATREF-submission-to-DEA-10-2012.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA52-NATREF-submission-to-DEA-10-2012.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA52-NATREF-submission-to-DEA-10-2012.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd20140530fa52natrefsubmissiontodea102012530e4ff6e1ac4773pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA52-NATREF-submission-to-DEA-10-2012.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }