record-13.2-pg-31-40-6be014311f3923cd.pdf

This document is an excerpt from the Eskom Air Quality Strategy (Unique Identifier: 32-1143, Revision 1), detailing the risks, financial requirements, and technical challenges associated with meeting Minimum Emission Standards (MES) for its power stations. It outlines the potential legal and operational consequences of non-compliance, provides a scenario analysis for implementation, and lists the specific retrofits and resource increases required for full compliance by April 1, 2020.

• Eskom faces significant risks if it fails to execute its Air Quality Strategy, including criminal prosecution of individuals or the company with penalties of up to 10 years imprisonment and/or fines of up to R 10 million. Other risks include reputational damage that could jeopardize future funding or Atmospheric Emission Licences (AELs), and threats to financial sustainability if non-compliant stations are forced to reduce production or shut down.
• Full compliance with Minimum Emission Standards by April 1, 2020, would require extensive technical retrofits: fabric filter plant retrofits and dust handling upgrades at six full and two half stations; an ESP refurbishment and dust handling upgrade at Matimba; low NOx burner retrofits at eight stations and optimisations at two; and flue gas desulphurisation (FGD) retrofits at 14 stations, including Medupi.
• The resource requirements for achieving full compliance are substantial, including a CAPEX of R224 billion (real costs) and annual OPEX of approximately R6 billion for FGD operation. Environmental and operational impacts include a 20% increase in water consumption (67 million m3/annum), an auxiliary power consumption increase of 2,255 GWh/year, and an increase in coal consumption of 970,000 tons/annum due to low NOx burner retrofits.
• Achieving full compliance would result in significant waste and operational disruptions, including the production of approximately 9.5 million tons/annum of FGD by-product and direct CO2 emissions from the FGD process of 1-4 million tons/annum. Additionally, the required outages of 150 days per unit would mean roughly 16% of the coal-fired fleet would be permanently on outage from 2017 to 2019.
• Eskom's scenario analysis identifies several risks to its Air Quality Strategy. While the 'Base case' assumes sufficient funding in the MYPD3 period, other scenarios include funding shortfalls leading to missed commitments for Medupi and other stations, or the risk of NGO court applications overturning MES postponements, which could lead to the shutdown of all coal-fired power stations and the loss of their licences to operate.
• A SWOT analysis reveals that Eskom's air quality management is hindered by internal weaknesses such as aging plants, limited funds, and a lack of alignment between departments (including Engineering, Finance, and Procurement). External threats include deteriorating coal quality with increasing sulphur content, constraints on water and sorbents, and the impact of climate change on Eskom's activities.

APA

Centre for Environmental Rights (n.d.). record-13.2-pg-31-40-6be014311f3923cd.pdf. https://cer.org.za/wp-content/uploads/2016/05/Record-13.2-pg-31-40.pdf?x21779

Chicago

Centre for Environmental Rights. record-13.2-pg-31-40-6be014311f3923cd.pdf. n.d. https://cer.org.za/wp-content/uploads/2016/05/Record-13.2-pg-31-40.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=record-13.2-pg-31-40-6be014311f3923cd.pdf |url=https://cer.org.za/wp-content/uploads/2016/05/Record-13.2-pg-31-40.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsndrecord132pg31406be014311f3923cdpdf, author = {{Centre for Environmental Rights}}, title = {{record-13.2-pg-31-40-6be014311f3923cd.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2016/05/Record-13.2-pg-31-40.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }