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

The document argues that AMSA's requests for emission standard postponements and alternative limits for hydrogen sulfide (H2S), sulfur dioxide (SO2), and hydrochloric acid (HCl) are unlawful and should be denied. The authors contend that the Vanderbijlpark Works is located in a non-compliant air quality priority area, that AMSA has failed to provide sufficient technical or economic justification for its requests, and that the company's history of non-compliance renders it unfit to receive such concessions.

• AMSA is seeking alternative emission standards for hydrogen sulfide (H2S) and sulfur dioxide (SO2) that are significantly less protective than the legal requirements. The proposed H2S standard of 150 mg/Nm3 is approximately 20 times greater than the new plant standard (7mg/Nm3) and 15 times greater than the existing plant standard (10mg/Nm3). The proposed SO2 standard of 1700 mg/Nm3 is over three times less protective than the applicable new plant standard.
• The application for postponement 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). This contradicts the 2017 Framework, which requires that ambient air quality in the area be in compliance for a postponement to be granted.
• AMSA failed to meet the three statutory requirements for alternative new plant standards under Section 12A of the List of Activities regulation: it is non-compliant with at least three emission standards (H2S, SO2, and HCl); it provided insufficient evidence of previous emission reductions or direct investments; and it did not prove material compliance with ambient air quality standards or conduct a health risk assessment for H2S.
• The Atmospheric Impact Report (AIR) provided by AMSA is described as grossly deficient. Specific failures include reporting maximum pollutant concentrations only at the site boundary rather than the point of maximum impact, using a single monitoring station (Sebokeng) for SO2 that may not be representative, and providing confusing or incorrect modeling results for different scenarios.
• The authors argue that AMSA is not a "fit and proper person" to hold an Atmospheric Emission License (AEL) or receive postponements due to its repeated non-compliance with the Air Quality Act (AQA) and other legislation.

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/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/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/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/gW-VEJA-Objection-to-AMSA-MES-postponement-11.03.2019.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }