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2014-05-30-fa23-sabs-co-ordinators-report-19-11-2008-3d78c2be955cdda8.pdf
This coordinator's report documents a meeting held on 18 November 2008 at the Eskom Research Centre regarding the SABS SC 146 A Quality Standard for Source Emissions. The meeting involved discussions between the Department of Environmental Affairs and Tourism (DEAT), industry representatives (including Eskom, Sasol, and the RMEF), and the Legal Resources Centre (LRC) to negotiate minimum emission standards for various industrial installations, including solid/liquid fuel combustion, petroleum industry processes, and carbonisation/coking plants.
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Document type: Report
2014-05-30-fa24-sabs-sc-146a-minutes-5-11-2008-be24100bff37951d.pdf
The document contains the minutes of the SABS SC 146A Source Emissions meeting held on 5 November 2008 in Pretoria. The meeting focused on reviewing proposed minimum emission standards for South Africa, coordinating the work of various Working Groups (WGs), and addressing technical disagreements regarding emission limits and plant definitions.
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Document type: Report
2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf
This briefing document details the proceedings of a technical working group meeting on April 28, 2009, regarding unresolved air quality emission standards for various industrial categories. It records disputes and agreements between government representatives (DEAT, DEADP), industry bodies (SAISI, RMEF, FAPA, ACMP), and NGOs (LRC, Groundwork) over specific pollutant limits for NOx, SO2, particulate matter (PM), and heavy metals.
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Document type: Briefing
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-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf
The Chemical and Allied Industries Association (CAIA) submitted this statement in August 2009 to express concerns regarding a draft Notice on atmospheric emission limits. CAIA argues that the proposed standards are overly stringent, lack a Regulatory Impact Assessment, and deviate from previous working documents. The association advocates for flexible compliance timeframes, the ability to apply for exemptions based on site-specific impact reports, and the adoption of realistic minimum emission standards that consider technical feasibility and overall environmental footprints.
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Document type: Statement
2014-05-30-fa33-sapia-letter-to-dea-28-08-2009-163f0dfb691f3316.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Director-General of Environmental Affairs dated 28 August 2009, providing comments and proposed amendments to the Listed Activities and Minimum Emission Standards published in Government Notice No. 32434 of 24 July 2009.
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Document type: Statement
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-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-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-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-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-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf
This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.
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Document type: Report
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
2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf
This document is a revised submission by Business Unity South Africa (BUSA) providing detailed comments and proposed amendments to a draft Notice regarding activities resulting in atmospheric emissions. BUSA argues that the proposed emission limits and compliance timeframes are often technically and financially unfeasible, potentially harming the economic viability of the industrial and mining sectors during a period of manufacturing decline.
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Document type: Statement
2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf
This briefing document outlines technical and regulatory issues arising from a May 15, 2013, workshop between the Department of Environmental Affairs (DEA) and industry stakeholders regarding the Section 21 emission standards. It focuses on refining activity descriptions, adjusting emission limits for specific industrial processes, and addressing the legal and practical implications of including 'use of' and 'storage' in the listed activities.
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Document type: Briefing
2015-06-10-thabametsi-appeal-response-part-1-a761f743bf5219c0.pdf
This document is a responding statement submitted by Newshelf 1282 (Pty) Ltd (the Second Respondent) on behalf of the Centre for Environmental Rights (CER) and Earthlife Africa, Johannesburg (the Appellant). It addresses an appeal against the environmental authorisation (EA) granted by the Department of Environmental Affairs (DEA) for the construction of the 1200MW coal-fired Thabametsi power station.
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Document type: Statement
20170413101321307-cdbfe3c3a7e72875.pdf
This internal Eskom memorandum from November 21, 2016, provides legal advice on whether the utility can redact (sever) specific information from records requested by the Centre for Environmental Rights (CER) under the Promotion of Access to Information Act (PAIA). The request concerns a pre-feasibility study into extending the lifespans of several power stations.
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Document type: Briefing