2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf

This document is a December 2012 submission by Natref to the Department of Environmental Affairs (DEA) regarding the draft Notice of Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act, 2004. Natref, South Africa's only inland oil refinery, argues that the proposed point-source emission limits for sulphur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx) are technically and economically unfeasible due to its unique inland location, fuel oil requirements, and space constraints. The company advocates for a "bubble" approach to emissions management and requests differentiated limits based on fuel type to maintain business sustainability and ensure the success of the Clean Fuels II project.

• Natref requests the adoption of a "bubble" approach for SO2 emissions management, arguing that a point-source approach threatens refinery business sustainability and that the bubble approach allows for "continual improvement in emissions management".
• As the only inland refinery in South Africa, Natref faces unique challenges with SO2 and PM emissions because it must burn fuel oil internally due to a "limited inland market for fuel oil and no access to the bunker fuel market".
• Natref argues that proposed NOx limits for new installations in Category 1.2 are not achievable based on literature, proposing instead a limit of "300 — 450 mg/Nm?" depending on the liquid fuel used.
• The company claims that achieving low SO2 emission levels via scrubbing is unsustainable at its inland location due to "water and waste constraints" and stricter freshwater-based water specifications compared to coastal refineries.
• Natref expresses concern that the draft Notice does not differentiate emission limits by fuel type, which it describes as "international practice" for petroleum refineries using internal fuel gas and fuel oil.
• The document highlights a conflict in investment timing, noting that the capital required for both the Air Quality Act and Clean Fuels II projects creates a "high negative NPV impact" that could threaten the security of fuel supply to inland markets and OR Tambo.
• Natref asserts that its physical layout, where most process units feed into a "single stack", and limited available space make it problematic to install the abatement technology required to meet new plant standards for particulates.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA56-Notice-964-submission-by-NATREF-12-2012.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA56-Notice-964-submission-by-NATREF-12-2012.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA56-Notice-964-submission-by-NATREF-12-2012.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa56notice964submissionbynatref122012d6e2e025dcf9eaafpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA56-Notice-964-submission-by-NATREF-12-2012.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }