fa50-letter-from-natref-to-dea-1-09-2011-35f20012a3dd2a8b.pdf

A letter from National Petroleum Refiners of South Africa (Natref) to the Department of Environmental Affairs (DEA) dated September 1, 2011, detailing the refinery's air quality compliance status and proposing amendments to the Minimum Emission Standards (MES). Natref argues that the proposed 2015 SO2 limits are unachievable and requests that the DEA recognize the emissions reductions achieved through its Residual Crude Desulphurization (RCD) unit.

• Natref asserts that the proposed 2015 Minimum Emissions Standard limit of 0.8 kg SO2/ton crude throughput is "completely unachievable for Natref’s operations," as it would require a reduction of more than 50% compared to its current emissions.
• In the 2010/11 financial year, which Natref describes as the best year in its history for crude oil processing and Sulphur Recovery Unit efficiency, the average SO2 emissions intensity was 1.67 kg SO2/ton of crude throughput.
• Natref proposes specific 2020 limits for pollutants: a Particulate Matter (PM) limit of 75 mg/Nm3 and a NOx limit of 300 mg/Nm3. It also suggests that Carbon Monoxide (CO) and Hydrogen Sulphide (H2S) be removed from the list of monitored pollutants.
• Natref proposes that the SO2 limit for refineries be set at 28 ton/day (1.9 kg SO2/ton crude throughput) for 2015, and 20 ton/day (1.4 kg SO2/ton crude throughput) for 2020.
• Natref requests that the DEA recognize the benefits of its Residual Crude Desulphurization (RCD) unit, which hydro-treats the Fluidized Catalytic Cracking (FCC) unit's feed. Natref claims this technology reduces SO2 emissions by approximately 730 t/a (about 9%) compared to non-hydro-treated feed.
• Regarding Sulphur Recovery Units (SRU), Natref agrees with a minimum conversion efficiency of 95% but proposes an SRU availability of 96% (excluding turnaround and inspection shutdowns).
• Natref identifies several compliance challenges, including its inland location (which increases wastewater treatment costs), the lack of a bunker fuel outlet for fuel oil management, and resource competition with the implementation of the Clean Fuels 2 Specification by 2017.

APA

Centre for Environmental Rights (n.d.). fa50-letter-from-natref-to-dea-1-09-2011-35f20012a3dd2a8b.pdf. https://cer.org.za/wp-content/uploads/2014/06/FA50-Letter-from-NATREF-to-DEA-1-09-2011.pdf?x21779

Chicago

Centre for Environmental Rights. fa50-letter-from-natref-to-dea-1-09-2011-35f20012a3dd2a8b.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/FA50-Letter-from-NATREF-to-DEA-1-09-2011.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=fa50-letter-from-natref-to-dea-1-09-2011-35f20012a3dd2a8b.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/FA50-Letter-from-NATREF-to-DEA-1-09-2011.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndfa50letterfromnatreftodea109201135f20012a3dd2a8bpdf, author = {{Centre for Environmental Rights}}, title = {{fa50-letter-from-natref-to-dea-1-09-2011-35f20012a3dd2a8b.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/FA50-Letter-from-NATREF-to-DEA-1-09-2011.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }