COMMENTS ON THE FINAL 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, Earthlife Africa, and Concerned Citizens of Lephalale, submitted comments on 15 June 2018 objecting to the Final Environmental Impact Report (FEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that the FEIR is deficient due to missing data, a 'piecemeal' approach to environmental authorisations, and a failure to adequately assess water and waste impacts.

• The FEIR is considered deficient and non-compliant with EIA standards because critical supporting data and reports were withheld from the public and the competent authority. Missing information includes data from plant site visits in China, Europe, and the USA used to justify technology selection, a detailed engineering study on the design and layout of the FGD and inlet cooler, an updated Gypsum Market Feasibility Study (specifically a 2017 Gypsum Commercialisation Strategy), the 2017 Knight and Piesold Storm Water Management Report, and confirmation of limestone availability and quality.
• The CER objects to the selection of the most water-intensive wet FGD technology, arguing that a wet FGD with an inlet cooler operating at 90°C could save 2.4 cubic metres of water per annum (Mm3/a) compared to standard Wet FGD, and 0.5 Mm3/a more than an inlet cooler operating at 100°C. The CER claims Eskom's rejection of the inlet cooler based on the 2018 TSSR lacks verifiable independent data.
• The CER opposes the separate application process for the WML variation, describing it as a 'piecemeal' approach intended to 'fast track' the EIA by deferring waste impact considerations. They argue that water availability, technology selection, and waste volumes are inter-related and must be addressed through an Integrated Environmental Impact Assessment to comply with NEMA.
• The project's waste management strategy is criticized for defaulting to the co-disposal of gypsum and ash in the existing Ash Disposal Facility (ADF) rather than prioritizing waste minimization and commercial resale. The CER notes that disposing of gypsum to landfill increases solid waste requirements by 1.8 million tons per year, while ash disposal adds approximately 5 million tons per year.
• The Surface Water Report (SWR) is identified as containing outdated rainfall data (missing the last 18 years) and failing to account for climate change impacts. Furthermore, the SWR indicates that the ADF area, which is approximately 10km2 in size, encroaches on the 1:100 year floodline, and there is insufficient capacity in the existing Dirty Water Dam (102,000m3 capacity) to store new dirty water runoff volumes.
• The FEIR fails to assess several critical risks and alternatives, including: the lack of a submitted water use licence application; the absence of long-term gypsum storage (current facility only caters for 3 days); salt and sludge waste disposal catered for only 5 of 50 years; ash waste catered for only 20 of 50 years; and the lack of climate change and health impact assessments.

APA

Centre for Environmental Rights (2018). COMMENTS ON THE FINAL 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/Medupi-FGD-FEIR_WML-Comments-15.06.18-1.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE FINAL 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/Medupi-FGD-FEIR_WML-Comments-15.06.18-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE FINAL 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=15 June 2018 |url=https://cer.org.za/wp-content/uploads/2022/06/Medupi-FGD-FEIR_WML-Comments-15.06.18-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE FINAL 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 = jun, url = {https://cer.org.za/wp-content/uploads/2022/06/Medupi-FGD-FEIR_WML-Comments-15.06.18-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }