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

The Vaal Environmental Justice Alliance (VEJA) and groundWork (gW) submitted a formal objection on 11 March 2019 against ArcelorMittal South Africa’s (AMSA) application for the postponement and alternative plant standards of minimum emission standards (MES) at its Vanderbijlpark Works. The submitters argue that AMSA's requests are unlawful, fail to meet statutory requirements, and would violate the constitutional right to a healthy environment.

• AMSA is seeking alternative emission standards for Hydrogen Sulfide (H2S) and Sulphur Dioxide (SO2) that are significantly less protective than the legal requirements. The proposed H2S standard of 150 mg/Nm3 is approximately 15 times greater than the existing plant standard (10mg/Nm3) and 20 times greater than the new plant standard (7mg/Nm3). The proposed SO2 standard of 1700 mg/Nm3 is over three times less protective than the applicable new plant standard.
• The submitters argue that AMSA's application for postponement should be denied because the Vanderbijlpark Works is located in the Vaal Triangle Airshed Priority Area (VTAPA), where ambient air quality is non-compliant with National Ambient Air Quality Standards (NAAQS). This contradicts the 2017 Framework, which requires ambient air quality in the area to be in compliance for a postponement to be granted.
• AMSA is requesting a postponement for Hydrochloric Acid (HCI) emissions at the Lurgi Plant from the new plant standard of 30 mg/Nm3, which must be met by 1 April 2020. The submitters note a discrepancy, as the List of Activities regulations regulate hydrogen chloride rather than hydrochloric acid.
• The submitters claim AMSA failed to meet the three requirements of Section 12A of the List of Activities regulation for alternative standards: it is non-compliant with at least three other standards (H2S, SO2, and HCI); it provided insufficient evidence of previous emission reductions or direct investments; and it did not prove material compliance with ambient air quality standards or assess health risks for H2S.
• The Atmospheric Impact Report (AIR) provided by AMSA is described as grossly deficient. Specific failures include reporting maximum concentrations only at the site boundary rather than the highest likely impact, using only one monitor (Sebokeng) for SO2, and providing confusing or incorrect modeling results where different scenarios show identical impacts despite different emission levels.
• The submitters assert that AMSA is not a "fit and proper person" to hold an Atmospheric Emission License (AEL) due to repeated non-compliance with the Air Quality Act (AQA) and other legislation, as highlighted in a letter from the Centre for Environmental Rights dated 18 June 2018.

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} }