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2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf
This document is an interim consolidated industry submission regarding the draft schedule for implementing Section 21 of the Air Quality Act. It outlines industry positions on minimum emission values, compliance timeframes, monitoring approaches, and the management of fugitive emissions and upset conditions, emphasizing the need for standards to be based on the Best Practicable Environmental Option (BPEO) principle within the South African context.
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Document type: Report
2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf
A submission by Sasol to Working Group 4 and a Subcommittee dated 9 March 2009 regarding proposed emission standards and the categorization of waste incinerators under the draft Section 21 of the National Environmental Management: Air Quality Act in South Africa.
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Document type: Statement
2014-05-30-fa3-gn-893-of-22-november-2013-8f0fcea586f20225.pdf
This government notice, published on 22 November 2013, amends the list of activities resulting in atmospheric emissions that may have significant detrimental effects on the environment, health, social, economic, ecological, or cultural conditions. Issued by the Minister of Water and Environmental Affairs under the National Environmental Management: Air Quality Act, 2004, the document establishes minimum emission standards (MES) for ten industrial categories, including combustion installations, the petroleum industry, and metallurgical processes. It defines compliance timeframes for new and existing plants, monitoring requirements, and reporting protocols to the National Air Quality Officer.
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Document type: Report
2014-05-30-fa30-s21-industry-input-04-2009-e34ad37457dc488a.pdf
This document is an industry submission from April 2009 regarding a draft notice and schedule for Section 21 of the Air Quality Act (AQA). It proposes minimum emission standards, transitional arrangements, and reporting requirements for various industrial activities, including combustion, petroleum, metallurgical, and chemical industries.
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Document type: Report
2014-05-30-fa31-s21-for-comment-24-07-2009-748f4ef4b33a182c.pdf
This document is a General Notice (No. 1001) published in the Government Gazette of South Africa on 24 July 2009 by the Minister of Water and Environmental Affairs. It outlines a proposed list of activities that result in atmospheric emissions which may have significant detrimental effects on the environment, health, social, economic, ecological, or cultural conditions, as well as their associated minimum emission standards (MES) under section 21 of the National Environmental Management: Air Quality Act, 2004.
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Document type: Report
2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf
The Refinery Managers’ Environmental Forum (RMEF) submitted comments on August 21, 2009, regarding proposed regulations under the National Environmental Management: Air Quality Act (NEMAQA) in South Africa. The RMEF argues that the proposed minimum emission standards are technically and economically unachievable for existing refineries, particularly the requirement for existing plants to meet new plant standards within eight years. They advocate for a 'bubble approach' to measure total site impact rather than point-source monitoring and request specific adjustments to particulate matter (PM) and volatile organic compound (VOC) limits to align with Best Available Techniques (BAT) and economic viability.
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Document type: Statement
2014-05-30-fa36-rmef-letter-to-dea-23-9-2009-4b6f2db104e0a3f1.pdf
A letter from the Refinery Manager’s Environmental Forum (RMEF) to the Department of Water and Environmental Affairs dated 23 September 2009, outlining industry concerns and proposed amendments regarding minimum emission standards for the petroleum sector under the National Environmental Management: Air Quality Act.
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Document type: Statement
2014-05-30-fa37-dea-briefing-document-on-s21-10-2009-44ef770185540c93.pdf
This October 2009 briefing document from the South African Department of Environmental Affairs outlines the logic, guiding principles, and stakeholder responses regarding the establishment of 'Listed Activities' and their associated minimum emission standards under the National Environmental Management: Air Quality Act (AQA). It details the transition from the older Atmospheric Pollution Prevention Act (APPA) to the AQA, the technical process for setting standards via the South African Bureau of Standards (SABS), and the department's refusal to allow 'grandfathering' for old industrial plants.
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Document type: Briefing
2014-05-30-fa38-national-ambient-air-quality-standards-24-12-2009-e2bbb5e911c72e6a.pdf
This government notice, published in the Government Gazette on 24 December 2009, establishes the national ambient air quality standards for South Africa under the National Environmental Management: Air Quality Act, 2004.
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Document type: Statement
2014-05-30-fa39-sapia-letter-to-dea-30-04-2010-0adb799e383a26a3.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Department of Environmental Affairs dated 30 April 2010, expressing concerns over the final 'List of Activities' published under the National Environmental Management: Air Quality Act, 2004. SAPIA argues that the final legislation deviates significantly from the draft version without adequate consultation or explanation, specifically regarding sulphur dioxide limits, timelines for existing refineries, and vapour recovery mandates.
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Document type: Statement
2014-05-30-fa40-dea-busa-meeting-584f2f50a67ba026.pdf
This briefing document records the outcomes of a meeting between the Department of Environmental Affairs (DEA) and Business Unity South Africa (BUSA) regarding the draft regulations for activities resulting in atmospheric emissions that may have detrimental environmental effects. The meeting focused on refining definitions, compliance timeframes, and specific emission standards across various industrial categories to ensure they are based on justifiable reasoning and ambient air quality standards.
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Document type: Briefing
2014-05-30-fa43-letter-from-dea-to-caia-dated-27-july-2011-589b3fd1920cd127.pdf
A letter from the South African Department of Environmental Affairs (DEA) inviting participation in the process of amending listed activities and medium emission standards notice, promulgated under Section 21 of the National Environmental Management: Air Quality Act (AQA) Act, 39 of 2004.
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Document type: Statement
2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf
A June 2012 submission by the Natref refinery to the South African Department of Environmental Affairs (DEA) regarding proposed Minimum Emission Standards (MES). Natref argues that inflexible national point source emission standards are impractical for existing facilities and proposes a 'bubble' approach to emissions management to ensure socio-economic sustainability and energy security.
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Document type: Report
2014-05-30-fa48-sasol-h2s-proposal-a20a27011aaef7b4.pdf
This report by Sasol outlines the company's proposal to the Department of Environmental Affairs (DEA) regarding hydrogen sulphide (H2S) emission standards for its Synfuels facility in Secunda. Sasol argues that the published 2010 standard of 1,000 mg/Nm³ is unachievable within the required timeframes due to technical constraints, the uniqueness of the Sasol process, and market limitations for sulphuric acid. The company proposes alternative standards based on stack averaging and specific points of compliance to ensure practical and sustainable air quality improvement.
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Document type: Report
2014-05-30-fa5-national-framework-75c8ca9b70909c3a.pdf
The 2007 National Framework for Air Quality Management is a regulatory blueprint established by the South African Minister of Environmental Affairs and Tourism under Section 7(1) of the National Environmental Management: Air Quality Act, 2004 (AQA). It provides a medium- to long-term plan to implement the AQA, focusing on pollution prevention at source and impact management to ensure ambient air is not harmful to health or well-being.
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Document type: Report
2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf
This October 2012 submission from the Natref refinery to the South African Department of Environmental Affairs (DEA) argues that the proposed Minimum Emission Standards (MES) are technically and socio-economically unsustainable for existing inland refineries. Natref advocates for a "bubble" approach to emissions management rather than a point-source approach and requests separate, less stringent limits for existing facilities compared to new plants.
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Document type: Report
2014-05-30-fa53-sasol-engagement-with-dea-5-11-2012-feb4ca50f3d43d02.pdf
This document is a confidential briefing regarding an engagement between Sasol and Deputy Director General Judy Beaumont of the Department of Environmental Affairs (DEA) on November 3, 2012, focusing on air quality improvement and emission abatement scenarios at the Secunda complex.
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Document type: Briefing
2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf
This document is a December 2012 submission by Natref to the Department of Environmental Affairs (DEA) regarding the draft Notice of Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act, 2004. Natref, South Africa's only inland oil refinery, argues that the proposed point-source emission limits for sulphur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx) are technically and economically unfeasible due to its unique inland location, fuel oil requirements, and space constraints. The company advocates for a "bubble" approach to emissions management and requests differentiated limits based on fuel type to maintain business sustainability and ensure the success of the Clean Fuels II project.
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Document type: Statement
2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf
The South African Petroleum Industry Association (SAPIA) submitted a set of comments and proposals to the Department of Environmental Affairs (DEA) on December 23, 2012, regarding the regulation of atmospheric emissions. The submission focuses on refining definitions, reporting requirements, compliance timeframes, and specific emission standards for combustion installations and petroleum product storage.
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Document type: Statement
2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf
A letter from Sasol to the South African Department of Environmental Affairs (DEA) providing comments on proposed amendments to the GN 248 List of Activities regarding atmospheric emissions. Sasol expresses support for the industry submission by CAIA/BUSA and highlights four primary concerns regarding the feasibility of standards for existing plants, compliance timelines, changes to activity scopes, and the alignment between waste and air quality regulations.
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Document type: Statement