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Applications for Postponement of certain requirements of the National Environmental Management: Air Quality Act No 39 of 2004 minimum Emissions
Applications for Postponement of certain requirements of the National Environmental Management: Air Quality Act No 39 of 2004 minimum Emissions Standards for Sasol South Africa Limited (Sasol)
574484
Philippa Burmeister
Tamaryn Hale
thale@srk.co.za
0837912342
SASOL 2020 MES Postponement Applications
Sasol South Africa Limited (Sasol) operating through its Secunda Operations (SO) in Secunda owns and operates a petrochemical facility in the Sasol Secunda complex south of central Secunda, Mpumalanga, among others. Sasol is required to comply with Minimum Emission Standards, 2013 (MES), published in terms of the National Environmental Management: Air Quality Act (Act No 39 of 2004).
Sasol fully intends to meet the MES and has implemented a number of initiatives to do so. However, during SO’s recent Atmospheric Emissions Licence (AEL) renewal process an extensive due diligence exercise was conducted and in the course of reviewing its Secunda facility against the conditions of SO’s previous AEL, certain additional point sources were identified that form part of existing listed activities recorded in the SO AEL. Preliminary baseline emission monitoring and measurement results suggest that SO may not be able to meet certain of the MES new plant standards in relation to volatile organic compounds (VOC’s) and carbon monoxide (CO) for some of the additional point sources.
Sasol therefore applied for postponement of compliance timeframes, as provided for in the MES, for the following sources:
• The Waste Recycling facility
• Coal Tar Filtration stack
• Phenosolvan depitcher
• Sand filter vents.
Secunda
On 20 April 2023 the NAQO, in concurrence with Local Atmospheric Emission Licensing Authority, granted postponement of compliance timeframes (“Postponement Decision”).
In the Postponement Decision, the NAQO granted significantly lower limits for the Phenosolvan depitcher and sand filter vents than those requested / applied for in the Postponement Application, as amended. SO therefore wishes to appeal against this, and only this, component of the Postponement Decision, and requests that the Postponement Decision be varied to authorise the alternative MES limits that the SO applied for, in respect of the Phenosolvan depitcher and sand filter vents, during the postponement period
To this end, an appeal was lodged with the Directorate: Appeals and Legal Review on 12 May 2023
Should you wish to make a responding statement regarding Sasol’s appeal please do so in the Appeal and Response Form. A copy of the applicable form is available on the Department’s website at:
https://www.environment.gov.za/documents/forms#legal_authorisations or on request from appeals@environment.gov.za.
Responding Statements should be submitted to The Directorate: Appeals and Legal Review, within 20 days of date of this notification (7 June 2023), at the details below:
The Director: Appeals and Legal Review - Department of Environmental Affairs
by Email: appeals@environment.gov.za
by Hand: Environment House, 473 Steve Biko, Arcadia, Pretoria, 0083
by Post: Private Bag X447, Pretoria, 0001