2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf

The South African Petroleum Industry Association (SAPIA) submitted a set of comments and proposals to the Department of Environmental Affairs (DEA) on December 23, 2012, regarding the regulation of atmospheric emissions. The submission focuses on refining definitions, reporting requirements, compliance timeframes, and specific emission standards for combustion installations and petroleum product storage.

• SAPIA requests that the Department of Environmental Affairs (DEA) clarify the purpose and scope of its study regarding the practicality and implications for existing plants to move toward new plant standards, specifically whether the study will be used to reconsider requirements for existing plants or to inform the DEA on offsetting projects.
• The industry expresses concern over 'reporting overload' due to multiple pieces of legislation and proposes that reporting timeframes be linked to the publication of a reporting template and the company's financial year-end, rather than a fixed one-year period.
• SAPIA proposes that the 'point of compliance' for combinations of off-gasses of the same subcategory sharing a common point source should be the common point source where reasonably practicable; for different subcategories, it should be any point from the last vessel closest to the point source up to the point prior to interference from another Listed Activity.
• SAPIA argues that compliance for pollutants monitored continuously should be based on a monthly average of daily averages, with no more than two consecutive days exceeding requirements, to maintain operational flexibility.
• Regarding combustion installations, SAPIA proposes that refinery boilers be regulated separately in Category 1 or moved to Category 2 because they use process off-gasses (refinery fuel gas) rather than natural gas, which varies in quality and composition.
• SAPIA proposes that the restriction on continuous flaring of hydrogen sulphide-rich gasses be qualified to apply only during 'normal operating conditions' to account for upsets, shutdowns, and start-up abnormalities.
• For the storage of petroleum products, SAPIA suggests that Leak Detection and Repair (LDAR) programs should only apply to products with a vapour pressure greater than 14 kPa, as products with lower volatility, such as lubricating and base oils, do not significantly impact air quality.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA58-SAPIA-submission-23-12-2012.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA58-SAPIA-submission-23-12-2012.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA58-SAPIA-submission-23-12-2012.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa58sapiasubmission231220129221836ad499994fpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA58-SAPIA-submission-23-12-2012.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }