Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd.

This report by Dr. Ranajit Sahu provides technical comments on the Provisional Atmospheric Emission License (PAEL) issued to Thabametsi Power Company (Pty) Ltd. The author argues that the PAEL permits the use of outdated, inefficient sub-critical Circulating Fluidized Bed (CFB) technology and relies on flawed Atmospheric Impact Reports (AIRs) that underestimate pollution impacts. Sahu contends that the plant will exacerbate existing air quality violations in the Waterberg Bojanala Priority Area and that the license lacks adequate emissions monitoring and control requirements.

• The PAEL permits the use of sub-critical Circulating Fluidized Bed (CFB) technology, which the author describes as outdated, less efficient, and more polluting than super-critical boiler technologies. The author notes that CFB boilers were used in the United States over 40 years ago and contrasts the PAEL's permitted emission levels for PM, SO2, and NOx—which are 1.5, 2.5, and 3.5 times higher, respectively—with the performance of a supercritical CFB boiler at the Lagisza power plant in Poland.
• The author asserts that the PAEL is based on flawed Atmospheric Impact Reports (AIRs) that fail to provide crucial data and modelling information. Specifically, the AIRs omit emissions from coal mining activities, coal transport and storage, and ash handling, storage, and disposal, while also inadequately assessing cumulative impacts from the Medupi and Matimba plants and surrounding infrastructure.
• The report claims that the PAEL provides no technical or engineering support for the effectiveness of its proposed air pollution controls. The author argues that the assumed 99.9% cleaning efficiency for fabric filters and the 95% SO2 absorption rate are unsupported, as the documents lack details on maintenance programs or the specific chemical and physical factors affecting SO2 removal.
• The author identifies contradictions and errors in the PAEL regarding nitrogen oxide (NOx) emissions. While the PAEL suggests NOx formation will be prevented, it later admits NOx will be produced; furthermore, the author states the PAEL incorrectly implies a linear relationship between flame temperature and NOx formation, whereas it typically increases exponentially.
• The proposed plant is located in the Waterberg Bojanala Priority Area, where National Ambient Air Quality Standards (NAAQS) are already being violated. Monitoring data from Lephalale between January 2017 and May 2019 shows multiple exceedances for PM10, SO2, and ozone (O3), suggesting that additional emissions from Thabametsi will worsen regional air pollution.
• The author concludes that the monitoring requirements in the PAEL are grossly inadequate because they do not require Continuous Emissions Monitors (CEMs) for the three pollutants and exhaust flow. Instead, the PAEL relies on 'daily' sampling, which the author argues is meaningless given that emissions vary on much shorter time-scales.

APA

Sahu, R. (. (2019). Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2019/11/Annexure-A6-Thabametsi-Sahu-Report-2019-10-30-1.pdf?x21779

Chicago

Sahu, Ranajit (Ron). Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd. Centre for Environmental Rights, 2019. https://cer.org.za/wp-content/uploads/2019/11/Annexure-A6-Thabametsi-Sahu-Report-2019-10-30-1.pdf?x21779.

Wikipedia

{{cite report |last1=Sahu |first1=Ranajit (Ron) |title=Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd. |publisher=Centre for Environmental Rights |date=30 October 2019 |url=https://cer.org.za/wp-content/uploads/2019/11/Annexure-A6-Thabametsi-Sahu-Report-2019-10-30-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{sahu2019comments, author = {Sahu, Ranajit (Ron)}, title = {{Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd.}}, institution = {Centre for Environmental Rights}, year = {2019}, month = oct, url = {https://cer.org.za/wp-content/uploads/2019/11/Annexure-A6-Thabametsi-Sahu-Report-2019-10-30-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }