SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS

A formal submission by the Vaal Environmental Justice Alliance (VEJA) and groundWork (gW) objecting to ArcelorMittal South Africa's (AMSA) application for postponements and alternative emission standards at its Vanderbijlpark Works facility.

• ArcelorMittal South Africa (AMSA) is seeking postponements and alternative emission standards for four specific areas at its Vanderbijlpark Works: a postponement for sulphur recovery in combustion installations; an alternative Hydrogen Sulfide (H2S) standard of 150 mg/Nm3 for coke oven emissions; an alternative Sulphur Dioxide (SO2) standard of 1700 mg/Nm3 for Direct Reduction kilns; and a postponement for Hydrochloric Acid emissions at the Lurgi Plant.
• The proposed alternative standard for Hydrogen Sulfide (H2S) is significantly less protective than existing regulations, being approximately 15 times higher than the standard for existing plants (10mg/Nm3) and 20 times higher than the standard for new plants (7mg/Nm3).
• The submission argues that AMSA's requests should be denied because the Vanderbijlpark Works is located within the Vaal Triangle Airshed Priority Area (VTAPA), where ambient air quality does not comply with National Ambient Air Quality Standards (NAAQS), violating the conditions for postponement under the 2017 National Framework.
• The applicants claim AMSA failed to meet the three legal requirements for alternative new plant standards under Section 12A of the List of Activities regulation: it is non-compliant with multiple other emission standards, provided insufficient evidence of previous emission reductions or direct investments, and failed to prove material compliance with ambient air quality standards or assess health risks for H2S.
• The Atmospheric Impact Report (AIR) provided by AMSA is criticized for several technical deficiencies, including reporting maximum pollutant concentrations only at the site boundary rather than the maximum overall, using non-representative monitoring results from a single station (Sebokeng) for SO2, and containing confusing or incorrect modeling results for Scenarios 3 and 4.
• The submission asserts that AMSA is not a "fit and proper person" to hold an Atmospheric Emission License (AEL) or seek postponements due to repeated non-compliance with the Air Quality Act (AQA) and its AEL, as highlighted in a June 2018 letter from the Centre for Environmental Rights.

APA

Centre for Environmental Rights (2019). SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS. https://cer.org.za/wp-content/uploads/2020/10/Annexure-1-gW-VEJA-Objection-to-AMSA-MES-postponement-11.03.2019.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS. 2019. https://cer.org.za/wp-content/uploads/2020/10/Annexure-1-gW-VEJA-Objection-to-AMSA-MES-postponement-11.03.2019.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS |date=11 March 2019 |url=https://cer.org.za/wp-content/uploads/2020/10/Annexure-1-gW-VEJA-Objection-to-AMSA-MES-postponement-11.03.2019.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2019submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS}}, publisher = {Centre for Environmental Rights}, year = {2019}, month = mar, url = {https://cer.org.za/wp-content/uploads/2020/10/Annexure-1-gW-VEJA-Objection-to-AMSA-MES-postponement-11.03.2019.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }