COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE

The Centre for Environmental Rights (CER), acting for groundWork and Earthlife Africa, submitted comments on April 19, 2018, regarding the Draft Environmental Impact Report (DEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that Eskom has adopted a 'piecemeal approach' to the environmental impact assessment (EIA), deferring critical issues such as water security, waste minimisation, and health impacts to separate processes to 'fast track' the project. The submission specifically challenges the rejection of inlet gas cooler technology, which could reduce water consumption by approximately 30%, and criticizes the plan to co-dispose of gypsum and ash, which would destroy the commercial value of the gypsum.

• The CER contends that Eskom is using a 'piecemeal approach' to the EIA process by excluding critical aspects of the FGD project from the EIA and deferring them to later stages or separate applications, such as Water Use Licence Applications (WULAs) and WML Variation Applications.
• The 2014 Technology Selection Study Report (TSSR) indicated that using a flue gas cooler could reduce process water consumption by approximately 29% with no significant difference in total life-cycle costs, yet Eskom rejected this in the 2018 TSSR without providing what the CER deems rational reasons.
• Eskom's justification for rejecting the flue gas cooler includes reported operational challenges at three European plants and a claimed lack of space for maintenance, though the CER notes that space was not listed as an impediment in the 2014 TSSR.
• Water security for the project is critical; the first three units rely on MCWAP phase 1 (10.9 Mm3/a), while the last three units depend on MCWAP phase 2, which is approximately 9 years behind schedule.
• The CER objects to the proposed co-disposal of gypsum and ash on the Ash Disposal Facility (ADF), arguing it is negligent and destroys the potential for commercial resale of gypsum in the construction and agricultural sectors.
• The ADF site is located within a 1:100 year floodline area, creating a risk that contents, including potentially toxic trace elements like arsenic, cadmium, and lead, could be washed into the receiving environment if flood controls are insufficient.
• The project's waste management capacity is insufficient for its intended lifespan; disposal for salt and sludge waste is only catered for 5 years, and the ADF for 20 years, despite a project lifespan of 50 years.
• The CER argues that the FGD retrofit is mandatory for Medupi to comply with the 2020 minimum emission standards (MES) for sulphur dioxide (SO2) and to meet loan agreement conditions with the World Bank, which required all units to be operational by December 31, 2021.
• The DEIR is criticized for missing essential documentation, including design reports (pages 36-37), Appendices D1-12, and Appendix F2, as well as the lack of a full health impact study.

APA

Centre for Environmental Rights (2018). COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE. https://cer.org.za/wp-content/uploads/2022/06/CER-DEIR-WML-comments-19-April-2018.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE. 2018. https://cer.org.za/wp-content/uploads/2022/06/CER-DEIR-WML-comments-19-April-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE |date=19 April 2018 |url=https://cer.org.za/wp-content/uploads/2022/06/CER-DEIR-WML-comments-19-April-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = apr, url = {https://cer.org.za/wp-content/uploads/2022/06/CER-DEIR-WML-comments-19-April-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }