sasol south africa · 1 sasol south africa secunda synfuels operations annual emission report dated...
TRANSCRIPT
1
Sasol South Africa
Secunda Synfuels Operations
Annual Emission Report
Dated 30 August 2019
prepared for
Gert Sibande District Municipality
regarding atmospheric emission license for Sasol South Africa Limited Secunda Synfuels Operations - number
0016/2019/F03
Reporting period: July 2018 – June 2019
2
TABLE OF CONTENTS
1. INTRODUCTION .............................................................................................................. 1
2. SERVICE PROVIDERS .................................................................................................... 1
3. RESULTS ......................................................................................................................... 2
3.1 Sub-category 1.1: Steam plant ......................................................................................... 2
3.2 Sub-category 1.2: Gas turbines ........................................................................................ 6
3.3 Sub-category 2.1: Refinery heaters .................................................................................. 6
3.4 Sub-category 2.2: Synfuels catalytic cracker (SCC) ......................................................... 9
3.5 Sub-category 3.6: Phenosolvan ........................................................................................ 9
3.6 Sub-category 3.6: Rectisol .............................................................................................. 10
3.7 Sub-category 4.2 and 4.7: Catalyst manufacturing ......................................................... 12
3.8 Sub-category 7.2: Wet sulphuric acid plant (WSA) ......................................................... 13
3.9 Sub-category 8.1: Biosludge and high organic waste incinerators .................................. 13
3.8.1 Annual monitoring ................................................................................................................. 13
3.8.2 Quarter 1: July 2018 to September 2018 .............................................................................. 14
3.8.3 Quarter 2: October 2018 to December 2018 ......................................................................... 16
8.3.4 Quarter 3: January 2019 to March 2019 ............................................................................... 17
8.3.5 Quarter 4: April 2019 to June 2019 ....................................................................................... 18
8.3.6 Sub-category 8.1 emission trends ....................................................................................... 20
3.10 Other: Leak detection and repair (LDAR) and Dust fall out results ............................ 28
4. COMPLIANCE AUDIT REPORTS .................................................................................. 29
5. MAJOR UPGRADE PROJECTS .................................................................................... 29
6. REGENERATIVE THERMAL OXIDISER INCIDENT ..................................................... 29
7. GREENHOUSE GAS (GHG) EMISSIONS ..................................................................... 30
8. PUBLIC CONSULTATION FORUM ............................................................................... 30
3
9. ACTIONS TAKEN ON COMPLAINTS RECEIVED ........................................................ 31
10. HIGHVELD PRIORITY AIR QUALITY MANAGEMENT PLAN AND OFFSET PROGRAMME ................................................................................................................ 42
10.1 Highveld priority air quality management plan ........................................................... 42
10.2 Sasol Secunda offset implementation plan ................................................................ 42
9.3.1 Insulation of reconstruction development programme houses (RDP) .............................. 42
9.3.2 Air quality education and awareness campaign ................................................................. 42
9.3.3 Grass cutting and veld fire management ............................................................................ 43
9.3.4 Waste management .............................................................................................................. 43
9.3.5 Feasibility studies at eMbalenhle and Lebohang ................................................................ 43
9.3.6 Challenges with offset implementation ............................................................................... 43
Annexure 1: Sasol’s 2018 GHG submission to the national GHG reporting regulations .................................................................................................................... 45
Annexure 2: Public consultation forum attendance list and presentation (see attached documents) .................................................................................................... 48
Annexure 3: Highveld Priority Air Quality Management Plan – (see attached document) ..................................................................................................................... 48
Annexure 4: Offset implementation – (see attached documents) .................................. 48
4
Standard abbreviation list
AEL atmospheric emissions license
CH4 methane
CO2 carbon dioxide
CTL coal to liquid
DEFF Department of Environment, Forestry and Fisheries
FY financial year
FY19 financial year 2019 (period July 2018 to June 2019)
FY20 financial year 2020 (period July 2019 to June 2020)
GJ gigajoules
GTC gas to chemicals
H2S hydrogen sulphide
HOW high organic waste
IPCC intergovernmental panel on climate change
kNm3 kilo normal cubic meter
LDAR leak detection and repair programme
LPG liquid petroleum gas
mg/Nm3 milligram per normal cubic meter
N20 nitrous oxide
NAQO national air quality officer
NO2 nitrogen dioxide
NOx oxides of nitrogen
N2O nitrous oxide
O2 oxygen
PCF poly crete foam
PM particulate matter
ppmv parts per million volume
RDP reconstruction development programme
RTO regenerative thermal oxidiser
SHE safety health and environment
SO2 sulphide dioxide
SSO Secunda Synfuels Operations
t/h ton per hour
TAME tertiary amyl methyl ether
VOC volatile organic compound
WA water and ash
5
List of tables: Table 1: Gondwana Environmental Solutions ....................................................................................... 1 Table 2: Future projects (Pty) Ltd ......................................................................................................... 1 Table 3: SNC-Lavalin (Kentz)............................................................................................................... 1 Table 4: Sample results for sub-category 1.1 ....................................................................................... 2 Table 5: Sample results for sub-category 1.2 ....................................................................................... 6 Table 6: Summarised sampling results for refinery heaters .................................................................. 6 Table 7: Sample results for sub-category 2.2 (SCC) ............................................................................ 9 Table 8: Sample results for sub-category 3.6 (Phenosolvan) ............................................................... 9 Table 9: Sample results for sub-category 3.6 ..................................................................................... 10 Table 10: Summarised sampling results for SSO: catalyst manufacturing (sub-category 4.2 and 4.7) 12 Table 11: Summarised sampling results for SSO: wet sulpuric acid plant (sub-category 7.2) ............. 13 Table 12: Summarised results for water and ash plant HOW incinerators (point sources under sub-category 8.1) (components requiring annual monitoring). Refer to attachment L. ............................... 13 Table 13: Summarised results for water and ash plant Biosludge incinerators (point sources under sub-category 8.1) (components requiring annual monitoring). Refer to attachment L. ........................ 14 Table 14: Summarised periodic sampling results for water and ash plant, HOW incinerators (point sources under sub-category 8.1) (quarter 1: July to September 2018). Refer to attachment L and M. 14 Table 15: Summarised periodic sampling results for water and ash plant, Biosludge incenerators (point sources under sub-category 8.1) (quarter 1: July to September 2018). Refer to attachment L and M. ................................................................................................................................................ 15 Table 16: Summarised results for water and ash plant HOW incinerator (point sources under sub-category 8.1) (quarter 2: October to December 2018). Refer to attachment N and O. ........................ 16 Table 17: Summarised results for water and ash plant biosludge incinerator (point sources under sub-category 8.1) (quarter 2: October to December 2018). Refer to attachment N and O. ................. 16 Table 18: Summarised results for water and ash plant HOW incenrators (point sources under sub-category 8.1) (quarter 3: January to March 2019). Refer to attachment P and Q................................ 17 Table 19: Summarised results for water and ash plant biosludge incinerators (point sources under sub-category 8.1) (quarter 3: January to March 2019). Refer to attachment P and Q. ........................ 18 Table 20: Summarised results for water and ash plant HOW incinerators (point sources under sub-category 8.1) (quarter 4: April to June 2019). Refer to attachment R and S. ...................................... 18 Table 21: Summarised results for water and ash plant biosludge incinerators (point sources under sub-category 8.1) (quarter 4: April to June 2019). Refer to attachment R and S. ............................... 19 Table 22: LDAR results for FY19 ....................................................................................................... 28 Table 23: Dust fall out results ............................................................................................................. 28 Table 24: Air related complaints for FY19 .......................................................................................... 31 List of figures: Figure 1: Daily average PM emissions for western stack (point source code B1, unit 43). ................... 3 Figure 2: Daily average PM emissions from eastern stack (point source code B2, unit 243) ................ 3 Figure 3: Daily average SO2 emissions from western stack (point source code B1, unit 43) ................. 4 Figure 4: Daily average SO2 emissions from eastern stack (point source code B2, unit 243) ............... 4 Figure 5: Daily average NO2 emissions from western stack (point source code B1, unit 43) ................ 5 Figure 6: Daily average NO2 emissions from eastern stack (point source code B2, unit 243) ............... 5 Figure 7: Daily average H2S emissions from sulphur recovery west ................................................... 11 Figure 8: Daily average H2S emissions from sulphur recovery east ................................................... 11 Figure 9: H2S load emissions from east and west sulphur recovery combined ................................... 12
6
Figure 10: Daily average PM emissions from the biosludge incinerator .............................................. 20 Figure 11: Daily average SO2 emissions from the biosludge incinerator............................................. 21 Figure 12: Daily average NO2 emissions from the biosludge incinerator ............................................ 21 Figure 13: Daily average CO emissions from the biosludge incinerator .............................................. 22 Figure 14: Daily average TOC emissions from the biosludge incinerator ........................................... 22 Figure 15: Daily average HF emissions from the biosludge incinerator .............................................. 23 Figure 16: Daily average HCl emissions from the biosludge incinerator ............................................. 23 Figure 17: Daily average PM emissions from the HOW incinerator .................................................... 24 Figure 18: Daily average SO2 emissions from the HOW incinerator ................................................... 24 Figure 19: Daily average NO2 emissions from the HOW incinerator ................................................... 25 Figure 20: Daily average CO emissions from the HOW incinerator .................................................... 25 Figure 21: Daily average TOC emissions from the HOW incinerator .................................................. 26 Figure 22: Daily average HF emissions from the HOW incinerator ..................................................... 26 Figure 23: Daily average HCl emissions from the HOW incinerator ................................................... 27
1
1. INTRODUCTION The purpose of this report is to report on compliance monitoring results as required by the atmospheric emission license (AEL) for Sasol South Africa Limited, Secunda Synfuels Operations (SSO) (number 0016/2019/F03). Emission monitoring on identified compliance points at SSO was conducted by various independent service providers. Section 3 of this document summarises the emissions measured compared to the maximum emission rates as per the AEL.
2. SERVICE PROVIDERS Future Projects (Pty) Ltd and Gondwana Environmental Solutions are the independent service providers that conducted the required emission testing. SNC-Lavalin (Kentz) undertook fugitive emission sampling for the leak detection and repair programme (LDAR). Relevant contact details are shown in the tables below.
Table 1: Gondwana Environmental Solutions
Physical address
Gondwana Environmental Solutions International (Pty) Ltd 562 Ontdekkers Road Florida
Postal address PO Box 158 Florida Hills 1716
Telephone No: +27 11 472 3112
Fax No +27 11 674 3705
Email [email protected]
Table 2: Future projects (Pty) Ltd
Physical address
480 Smuts Drive Halfway Gardens Midrand Gauteng 1685
Telephone No: +27 11 052 1250
Email [email protected]
Table 3: SNC-Lavalin (Kentz)
Physical address Kiewiet Office Park, Block E Kiewiet Street Secunda 2302
Postal address PO Box: 89, 14TH Road Erand Johannesburg/Midrand 1685
Telephone number +27 17 631 3080 +27 78 185 4373
Email [email protected]
2
3. RESULTS This sections summarise the results from both the third party emission testing as well as the continuous emission monitoring results for the different subcategories as regulated within the AEL.
3.1 Sub-category 1.1: Steam plant The east and west main stacks contain continuous emission monitors per flue. Daily averages are calculated as per the requirements of the AEL for compliance, with the points of compliance being the eastern and western stacks respectively. The results per emission of the continuous emission monitors are illustrated per flue, along with the daily averages of the flues per stack in figures 1 to 6. Reference to the applicable AEL point sources and limits for compliance purposes are indicated in table 4 below.
Table 4: Sample results for sub-category 1.1
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
B1 (unit 43) Main stack west
PM See figure 1 for online PM data
120 at 10% O2
SO2 See figure 3 for online SO2 data
3 500 at 10% O2
NOx expressed as NO2
See figure 5 for online NOx data
1 100 at 10% O2
B2 (unit 243) Main stack east
PM See figure 2 for online PM data
120 at 10% O2
SO2 See figure 4 for online SO2 data
3 500 at 10% O2
NOx expressed as NO2
See figure 6 for online NOx data
1 100 at 10% O2
3
Figure 1: Daily average PM emissions for western stack (point source code B1, unit 43).
Figure 2: Daily average PM emissions from eastern stack (point source code B2, unit 243)
4
Figure 3: Daily average SO2 emissions from western stack (point source code B1, unit 43)
Figure 4: Daily average SO2 emissions from eastern stack (point source code B2, unit 243)
5
Figure 5: Daily average NO2 emissions from western stack (point source code B1, unit 43)
Figure 6: Daily average NO2 emissions from eastern stack (point source code B2, unit 243)
6
3.2 Sub-category 1.2: Gas turbines
The gas turbines are measured by a third party service provider annually. The results of FY19 are indicated below. The third party report for gas turbine 1 can be located under attachment A and gas turbine 2 under attachment B.
Table 5: Sample results for sub-category 1.2
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
Gas turbine 1 (GT1
PM 6 10 at 15% O2
NOx expressed as NO2
44 300 at 15% O2
SO2 <3 500 at 15% O2
Gas turbine 2 (GT2)
PM 3.3 10 at 15% O2
NOx expressed as NO2
89 300 at 15% O2
SO2 <3 500 at 15% O2
3.3 Sub-category 2.1: Refinery heaters Table 6 summarises the measured NOx and SO2 results for the refinery heaters. The third party sampling report can be located under attachment C. A sampling port has been installed on one heater (U35HT101) in order to undertake isokinetic sampling to develop a baseline for particulate matter emissions. The emission baseline will be conducted after the September 2019 shutdown as per the renewed AEL investigation condition which states: SSO to monitor one refining heater (of total) that will be installed with an isokinetic sampling port in the September 2019 shutdown. This one heater will be baselined after the shutdown to determine efficient and suitable emissions measurement and monitoring method for all heaters. Subsequent to the baseline, Sasol to engage licensing authority to finalise emissions and reporting requirements. Table 6: Summarised sampling results for refinery heaters
Point source code
Pollutant
Measured daily average concentration (mg/Nm3 at 10% O2 )
Reference AEL limit (mg/Nm3 at 10% O2)
R1 (14HT101)
NOx expressed as NO2
Due to stack inaccessibility no sampling could be conducted
1 700
SO2 1 700
R2(14HT201)
NOx expressed as NO2
201 1 700
SO2 <2 1 700
R3(214HT101)
NOx expressed as NO2
213 1 700
SO2 101 1 700
R4(214HT201) NOx expressed as 165 1 700
7
Point source code
Pollutant
Measured daily average concentration (mg/Nm3 at 10% O2 )
Reference AEL limit (mg/Nm3 at 10% O2)
NO2
SO2 76 1 700
R5(228HT101)
NOx expressed as NO2
109 1 700
SO2 46 1 700
R6 (30HT101)
NOx expressed as NO2
108 1 700
SO2 <72 1 700
R7 (30HT102)
NOx expressed as NO2
89 1 700
SO2 102 1 700
R8 (30HT103)
NOx expressed as NO2
83 1 700
SO2 <3 1 700
R9 (30HT104)
NOx expressed as NO2
88 1 700
SO2 39 1 700
R10 (30HT105)
NOx expressed as NO2
90 1 700
SO2 18 1 700
R11 (230HT101)
NOx expressed as NO2
75 1 700
SO2 <28 1 700
R12 (230HT102)
NOx expressed as NO2
121 1 700
SO2 <2 1 700
R13 (230HT103)
NOx expressed as NO2
102 1 700
SO2 22 1 700
R14 (230HT104)
NOx expressed as NO2
95 1 700
SO2 <25 1 700
R15 (230HT105)
NOx expressed as NO2
103 1 700
SO2 34 1 700
R17 (34HT101)
NOx expressed as NO2
96 1 700
SO2 99 1 700
R18 (234HT101)
NOx expressed as NO2
75 1 700
SO2 <3 1 700
R19 (35HT101)
NOx expressed as NO2
108 1 700
SO2 <3 1 700
R20 (35HT102) NOx expressed as 97 1 700
8
Point source code
Pollutant
Measured daily average concentration (mg/Nm3 at 10% O2 )
Reference AEL limit (mg/Nm3 at 10% O2)
NO2
SO2 33 1 700
R22 (235HT101)
NOx expressed as NO2
97 1 700
SO2 119 1 700
R23 (235HT102)
NOx expressed as NO2
85 1 700
SO2 54 1 700
R24 (35HT103)
NOx expressed as NO2
79 1 700
SO2 35 1 700
R25 (35HT104)
NOx expressed as NO2
85 1 700
SO2 <2 1 700
R26 (35HT105)
NOx expressed as NO2
112 1 700
SO2 <3 1 700
R27 (29HT101)
NOx expressed as NO2
117 1 700
SO2 25 1 700
R28 (29HT102)
NOx expressed as NO2
90 1 700
SO2 30 1 700
R29 (229HT101)
NOx expressed as NO2
50 1 700
SO2 <2 1 700
R30 (33HT101)
NOx expressed as NO2
108 1 700
SO2 100 1 700
R31 (33HT102)
NOx expressed as NO2
108 1 700
SO2 122 1 700
R32 (33HT105)
NOx expressed as NO2
83 1 700
SO2 <2 1 700
R33 (233HT101)
NOx expressed as NO2
80 1 700
SO2 24 1 700
R34 (233HT102)
NOx expressed as NO2
105 1 700
SO2 <9 1 700
R35 (233HT105)
NOx expressed as NO2
77 1 700
SO2 10 1 700
R36 (32HT101) NOx expressed as 90 1 700
9
Point source code
Pollutant
Measured daily average concentration (mg/Nm3 at 10% O2 )
Reference AEL limit (mg/Nm3 at 10% O2)
NO2
SO2 82 1 700
R37 (32HT201)
NOx expressed as NO2
43 1 700
SO2 29 1 700
R38 (32HT102)
NOx expressed as NO2
47 1 700
SO2 <3 1 700
R39 (232HT101)
NOx expressed as NO2
80 1 700
SO2 41 1 700
R40 (232HT201)
NOx expressed as NO2
77 1 700
SO2 74 1 700
R41 (232HT102)
NOx expressed as NO2
91 1 700
SO2 66 1 700
3.4 Sub-category 2.2: Synfuels catalytic cracker (SCC)
The SCC stack is measured by a third party service provider annually. The results of FY19 is indicated in Table 7. The third party report for can be located under attachment D. Table 7: Sample results for sub-category 2.2 (SCC)
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
SCC 1 stack
PM 84 at 10% O2 330 at 10% O2
SO2 <2 at 10% O2 3 000 at 10% O2
NOx expressed as NO2 <3 at 10% O2 550 at 10% O2
3.5 Sub-category 3.6: Phenosolvan Table 8 summarises the emission monitoring results for the emissions relevant to sub-category 3.6: Table 8: Sample results for sub-category 3.6 (Phenosolvan)
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
PAR phase 1 and 2 saturation column vents (unit 016)
Sampling at the saturation columns of the Phenosolvan plants could not be done in quarter one of FY19 because of delayed commissioning activities after the planned annual shutdown and unstable plant conditions. Sampling was conducted in quarter two and three, results are presented below. The third party
10
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
sampling reports can be located under attachment E (quarter 2) and attachment F (quarter 3). The results are an average of the two factory phases. It should be noted that an abatement project is under way and progressing well to reduce TVOC emissions. Ambient station measurements indicate compliance with the National Ambient Air Quality Standards, as applicable.
VOC quarter 2 (October to December 2018)
50 250 58 000
VOC quarter 3 (January to March 2019 )
11 222 58 000
PAR phase 3 and 4 saturation column vents (unit 216)
VOC quarter 2 (October to December 2018)
11 270 58 000
VOC quarter 3 (January to March 2019 )
13 682 58 000
3.6 Sub-category 3.6: Rectisol Table 9 summarises the sample results for both the eastern and western plants with reference AEL requirements as per sub-category 3.6. For hydrogen sulphide (H2S) the east and west main stacks contain continuous emission monitors per flue. Daily averages are calculated as per the requirements of the AEL for compliance, with the points of compliance being the eastern and western stacks respectively. The graphs in figures 7 to 9 in this section also illustrates the continuous emissions monitoring for H2S. The third party sampling reports can be located under attachments G and H. Table 9: Sample results for sub-category 3.6
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
Rectisol east (off gas to main stack)
H2S (measured as S)
See figure 8 and 9
13,5 t/h maximum daily average during upset conditions
8 400 mg/Nm3 normal operating conditions
VOCs 28,5 300
SO2 <3 3 500
Rectisol west (off gas to main stack)
H2S (measured as sulphur)
See figure 7 and 9
13,5 t/h maximum daily average during upset conditions 8 400 mg/Nm3 normal operating conditions
VOCs 49,5 300
SO2 <3 3 500
11
Figure 7: Daily average H2S emissions from sulphur recovery west
Figure 8: Daily average H2S emissions from sulphur recovery east
12
Figure 9: H2S load emissions from east and west sulphur recovery combined
3.7 Sub-category 4.2 and 4.7: Catalyst manufacturing
The point sources within catalyst manufacturing is measured by a third party service provider annually. The results of FY19 is indicated in Table 10. The third party report for can be located under attachment I and J. Table 10: Summarised sampling results for SSO: catalyst manufacturing (sub-category 4.2 and 4.7)
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
CM1 (West kiln stack)
PM 7 100
NOx expressed as NO2 71 500
SO2 <3 2 000
CM2 (West arc furnace stack)
PM 46 100
NOx expressed as NO2 28 500
SO2 <3 500
CM3 (East kiln A stack)
PM 27 100
NOx expressed as NO2 74 500
SO2 <3 2 000
CM4 (East arc furnace stack)
PM 5 100
NOx expressed as NO2 210 500
SO2 <10 500
13
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
CM5 (East Kiln B stack)
PM 214 100
NOx expressed as NO2 72 500
SO2 <3 2 000
On a daily averaging basis, the PMs measured at CM5 (East Kiln B) exceeded the AEL limit. Subsequent to this measurement the kiln was shutdown and a visual inspection indicated one of the dust collectors showed signs of cartridge damage and excess dust on the inside of the body. Repairs were completed on the cartridges and the kiln started up, however stable operations were only achieved in August 2019. Sampling was completed in August 2019 and the results will be included in the next quarterly report as well as the FY20 annual compliance report. 3.8 Sub-category 7.2: Wet sulphuric acid plant (WSA) The point sources within WSA is measured by a third party service provider annually. The results of FY19 is indicated in Table 11. The third party report for can be located under attachment K. Table 11: Summarised sampling results for SSO: wet sulpuric acid plant (sub-category 7.2)
Point source code
Pollutant Measured daily average concentration (mg/Nm3)
Reference AEL limit (mg/Nm3)
WSA
SO2 253 2 800
SO3 4 100
NOx expressed as NO2 56 2 000
3.9 Sub-category 8.1: Biosludge and high organic waste incinerators Only one biosludge incinerator (WA1) and one high organic waste incinerator (HOW2) is fitted with continuous monitoring systems. As per the requirements of the AEL, Sasol continues with periodic third party sampling on the biosludge and high organic waste (HOW) incinerators up until the completion of the abatement project. These results are reported on a quarterly basis. The tables in this section summarise the online and third party emission results for sub-category 8.1 for both the biosludge and the HOW incinerators. The third party results can be found in attachments L through to attachment S. The sampling results are followed by graphs illustrating the results from the continuous emission monitoring analysers. 3.8.1 Annual monitoring Table 12: Summarised results for water and ash plant HOW incinerators (point sources under sub-
14
category 8.1) (components requiring annual monitoring). Refer to attachment L.
Table 13: Summarised results for water and ash plant Biosludge incinerators (point sources under sub-category 8.1) (components requiring annual monitoring). Refer to attachment L.
3.8.2 Quarter 1: July 2018 to September 2018 Table 14: Summarised periodic sampling results for water and ash plant, HOW incinerators (point
Pollutants
Unit of measurement HOW1 (052CI-101)
HOW2 (252CI-101)
Reference maximum release rate in AEL
Pb+As+Sb+Cr+Co+Cu+Mn+Ni+V mg/Nm3 at 10% O2 <1,916 <5,697 21
Hg mg/Nm3 at 10% O2 0,075 <0,049 0,27
Cd and Tl mg/Nm3 at 10% O2 <0,046 <0,084 0,12
Dioxins and furans
ng.Nm-3 I-TEQ at 10% O2
0,02 0,17 4,2
Measured oxygen % 17,8 19 NA
Sampling dates
2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
NA
Pollutants
Unit of measurement
WA1 (052 WK-2102)
WA2 (052 WK-2202)
WA3 (252 WK-2102)
WA4 (252 WK-2202)
Reference maximum release rate in AEL
Pb+As+Sb+Cr+Co+Cu+Mn+Ni+V mg/Nm
3 at 10% O2 <0,863 <1,418 <2,066 <0,780 2,6
Hg mg/Nm3 at 10% O2 0,727 1,512 1,185 0,800 1
Cd and Tl mg/Nm3 at 10% O2 <0.056 <0,072 <0,086 <0,039 0,12
Dioxins and furans
ng.Nm-3 I-TEQ at 10% O2
0,01 0,01 0,01 0,01 0,3
Measured oxygen % 15,4 16,4 17,8 14,2 NA
Sampling dates 2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
NA
15
sources under sub-category 8.1) (quarter 1: July to September 2018). Refer to attachment L and M.
Table 15: Summarised periodic sampling results for water and ash plant, Biosludge incinerators (point sources under sub-category 8.1) (quarter 1: July to September 2018). Refer to attachment L and M.
Pollutants
Unit of measurement HOW1 (052CI-101)
HOW2 (252CI-101)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 86 75 900
CO mg/Nm3 at 10% O2 252 187 1 300
SO2 mg/Nm3 at 10% O2 20 <16 400
NOx expressed as NO2 mg/Nm3 at 10% O2 1 040 2 470 3 800
HCl mg/Nm3 at 10% O2 0,35 <0,058 55
HF mg/Nm3 at 10% O2 <0,014 <0,019 3
TOC mg/Nm3 at 10% O2 36 N/A1* 38
NH3 mg/Nm3 at 10% O2 7,68 7,62 12
Exit temperature oC 389 341 < 400
Measured oxygen % 18,6 19 NA
Sampling dates 2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
NA
Pollutants
Unit of measurement
WA1 (052 WK-2102)
WA2 (052 WK-2202)
WA3 (252 WK-2102)
WA4 (252 WK-2202)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 164 180 34 81 400
CO mg/Nm3 at 10% O2 1 120 1 568 814 977 4 310
SO2 mg/Nm3 at 10% O2 <6 <7 185 136 210
NOx expressed as NO2
mg/Nm3 at 10% O2 297 317 340 199 630
HCl mg/Nm3 at 10% O2 1,72 0,87 <1,049 0,75 23
HF mg/Nm3 at 10% O2 <1,216 <0,015 <0,814 0,249 20
TOC mg/Nm3 at 10% O2 257 423 406 249 1 500
NH3 mg/Nm3 at 10% O2 14,70 27,39 21,11 10,71 52
Exit temperature oC 62 65 63 62 NA
Measured oxygen % 15,4 16,4 17.8 14,2 NA
Sampling dates 2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
2 Jul –
18 Oct 2018
NA
16
3.8.3 Quarter 2: October 2018 to December 2018
Table 16: Summarised results for water and ash plant HOW incinerator (point sources under sub-category 8.1) (quarter 2: October to December 2018). Refer to attachment N and O.
On a daily averaging basis, the SO2 emissions measured at incinerator HOW1 (052Cl-101) during quarter two exceeded the AEL limit by only 57 mg/Nm3. Sasol is of the view that this exceedance is not significant in terms of impact to the ambient air and:
‒ In evaluating the individual sample runs of quarter two, two out of the three runs can be deemed outliers based on previous technical analysis of data measured over four years.
‒ The results measured in the previous quarter and the following quarter (quarter three, see Table 18 below) were well within the AEL limit.
On a daily averaging basis, the temperature measured at incinerator HOW1 (052Cl-101) exceeded the AEL limit by only 12 degree Celsius; this exceedance is deemed negligible in terms of potential impact.
On a daily averaging basis, the TOC emissions measured at HOW1 (052Cl-101) and HOW2 (252Cl-101) exceeded the AEL limit.
‒ The exceedance recorded at HOW1 is deemed negligible and not significant in terms of potential impact on ambient air quality.
‒ The exceedance recorded at HOW2 is not aligned with the online analyser results on the same day at HOW2 and the third party results in the following quarter indicate a significant improvement. The online analyser results during this time were below the AEL limit.
Table 17: Summarised results for water and ash plant biosludge incinerator (point sources under
Pollutants
Unit of measurement
HOW1 (052CI-101)
HOW2 (252CI-101)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 19 14 900
CO mg/Nm3 at 10% O2 332 804 1 300
SO2 mg/Nm3 at 10% O2 457 <12 400
NOx expressed as NO2
mg/Nm3 at 10% O2
1 567 1 995 3 800
HCl mg/Nm3 at 10% O2 0,98 0,59 55
HF mg/Nm3 at 10% O2 <0,07 <0,06 3
TOC mg/Nm3 at 10% O2 57 130 38
NH3 mg/Nm3 at 10% O2 0,29 1,68 12
Exit temperature oC 412 338 < 400
Measured oxygen % 17,9 18,4 NA
Sampling dates 8 – 29 Nov 2018
8 – 29 Nov 2018
NA
17
sub-category 8.1) (quarter 2: October to December 2018). Refer to attachment N and O.
1* Stack not available for sampling
8.3.4 Quarter 3: January 2019 to March 2019 Table 18: Summarised results for water and ash plant HOW incinerators (point sources under sub-category 8.1) (quarter 3: January to March 2019). Refer to attachment P and Q.
Pollutants
Unit of measurement
WA1 (052 WK-2102)
WA2 (052 WK-2202)
WA3 (252 WK-2102)
WA4 (252 WK-2202)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 99.5 214
N/A1*
98.9 400
CO mg/Nm3 at 10% O2 2 118 2 116 1699 4 310
SO2 mg/Nm3 at 10% O2 <7 <7 <6 210
NOx expressed as NO2
mg/Nm3 at 10% O2 267 248 271 630
HCl mg/Nm3 at 10% O2 2,33 <0,33 0,37 23
HF mg/Nm3 at 10% O2 0,36 0,22 0,23 20
TOC mg/Nm3 at 10% O2 280 524 240 1 500
NH3 mg/Nm3 at 10% O2 36,68 49,72 2,60 52
Exit temperature oC 59 61 60 NA
Measured oxygen % 16,7 16,2 15,3 NA
Sampling dates 8 – 29 Nov 2018
8 – 29 Nov 2018
8 – 29 Nov 2018
NA
Pollutants
Unit of measurement HOW1 (052CI-101)
HOW2 (252CI-101)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 218 13 900
CO mg/Nm3 at 10% O2 <6 565 1 300
SO2 mg/Nm3 at 10% O2 <10 85 400
NOx expressed as NO2 mg/Nm3 at 10% O2 1 350 2 067 3 800
HCl mg/Nm3 at 10% O2 0,62 4,66 55
HF mg/Nm3 at 10% O2 <0,01 <0,015 3
TOC mg/Nm3 at 10% O2 19 42 38
NH3 mg/Nm3 at 10% O2 1,54 1,35 12
Exit temperature oC 394,3 327,1 < 400
Measured oxygen % 17,2 18,7 NA
Sampling dates 16 Jan – 26 March 2019
16 Jan – 26 March 2019
NA
18
On a daily averaging basis, the TOC emissions measured at HOW2 exceeded the AEL limit; however the exceedance is negligible and not aligned with the online analyser results. The results from the online analyser are within the AEL limit for the same period (see figure 23 above).
Table 19: Summarised results for water and ash plant biosludge incinerators (point sources under sub-category 8.1) (quarter 3: January to March 2019). Refer to attachment P and Q.
8.3.5 Quarter 4: April 2019 to June 2019 Table 20: Summarised results for water and ash plant HOW incinerators (point sources under sub-category 8.1) (quarter 4: April to June 2019). Refer to attachment R and S.
Pollutants
Unit of measurement
WA1 (052 WK-2102)
WA2 (052 WK-2202)
WA3 (252 WK-2102)
WA4 (252 WK-2202)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 69 150 157 134 400
CO mg/Nm3 at 10% O2 1 674 2 141 1 156 1 617 4 310
SO2 mg/Nm3 at 10% O2 <6 <9 150 <6 210
NOx expressed as NO2
mg/Nm3 at 10% O2 294 286 326 399 630
HCl mg/Nm3 at 10% O2 1,07 2,33 1,15 0,96 23
HF mg/Nm3 at 10% O2 <0,01 0,58 0,56 <0,01 20
TOC mg/Nm3 at 10% O2 513 571 202 297 1 500
NH3 mg/Nm3 at 10% O2 15,25 20 9,05 10,13 52
Exit temperature oC 61,8 58,6 63 62,2 NA
Measured oxygen % 15,5 17,1 16 15,6 NA
Sampling dates 16 Jan – 26 March 2019
16 Jan – 26 March 2019
16 Jan – 26 March 2019
16 Jan – 26 March 2019
NA
Pollutants
Unit of measurement HOW1 (052CI-101)
HOW2 (252CI-101)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 46 106 900
CO mg/Nm3 at 10% O2 116 604 1 300
SO2 mg/Nm3 at 10% O2 79 <14 400
NOx expressed as NO2 mg/Nm3 at 10% O2 1 704 2 251 3 800
HCl mg/Nm3 at 10% O2 0,80 <0,05 55
HF mg/Nm3 at 10% O2 4,25 <0,02 3
TOC mg/Nm3 at 10% O2 33 21 38
19
On a daily averaging basis, the temperature measured at incinerator HOW1 (052Cl-101) exceeded the AEL limit by 41 degree Celsius. This exceedance, based on the sample run during the periodic sampling period only, is deemed negligible in terms of potential impact.
Table 21: Summarised results for water and ash plant biosludge incinerators (point sources under sub-category 8.1) (quarter 4: April to June 2019). Refer to attachment R and S.
On a daily averaging basis, the SO2 emissions measured at incinerator WA3 (252WK-2102) during the sample runs exceeded the AEL limit. Sasol is of the view that this exceedance is not representative of actual performance because:
‒ In evaluating the individual sample runs of quarter four, all three runs can be deemed inexplicable outliers based on previous technical analysis of data measured over four years.
‒ The results measured in all the previous quarters were well within the AEL limit (two digit values) and in our view is representative of actual performance.
On a daily averaging basis, the SO2 emissions measured at incinerator WA4 (252WK-2202) during the sample runs exceeded the AEL limit by only 17 mg/Nm3. Sasol is of the view that this exceedance is not representative of actual performance because:
NH3 mg/Nm3 at 10% O2 1,27 2,58 12
Exit temperature oC 441 335 < 400
Measured oxygen % 17,4 18,8 NA
Sampling dates 02 April – 15 May 2019
02 April – 15 May 2019
NA
Pollutants
Unit of measurement
WA1 (052 WK-2102)
WA2 (052 WK-2202)
WA3 (252 WK-2102)
WA4 (252 WK-2202)
Reference maximum release rate in AEL
PM mg/Nm3 at 10% O2 87 157 128 96 400
CO mg/Nm3 at 10% O2 1 649 3 327 516 1 794 4 310
SO2 mg/Nm3 at 10% O2 <10 <8 494 227 210
NOx expressed as NO2
mg/Nm3 at 10% O2 321 410 255 295 630
HCl mg/Nm3 at 10% O2 1,29 1,29 1,24 0,87 23
HF mg/Nm3 at 10% O2 <0,01 0,20 1,01 <0,01 20
TOC mg/Nm3 at 10% O2 208 433 202 277 1 500
NH3 mg/Nm3 at 10% O2 22,51 7,26 11,56 14,98 52
Exit temperature oC 55 64 65 64 NA
Measured oxygen % 17,8 16,8 16 16,1 NA
Sampling dates 02 April – 15 May 2019
02 April – 15 May 2019
02 April – 15 May 2019
02 April – 15 May 2019
NA
20
‒ In evaluating the individual sample runs of quarter four, one out of three runs can be deemed an inexplicable outlier based on previous technical analysis of data measured over four years.
‒ The results measured in the previous quarter were well within the AEL limit and in our view is representative of actual performance
8.3.6 Sub-category 8.1 emission trends 8.3.6.1 Biosludge incinerator
Figure 10: Daily average PM emissions from the biosludge incinerator
21
Figure 11: Daily average SO2 emissions from the biosludge incinerator
Figure 12: Daily average NO2 emissions from the biosludge incinerator
22
Figure 13: Daily average CO emissions from the biosludge incinerator
Figure 14: Daily average TOC emissions from the biosludge incinerator
23
Figure 15: Daily average HF emissions from the biosludge incinerator
Figure 16: Daily average HCl emissions from the biosludge incinerator
24
8.3.6.2 HOW incinerator
Figure 17: Daily average PM emissions from the HOW incinerator
Figure 18: Daily average SO2 emissions from the HOW incinerator
25
Figure 19: Daily average NO2 emissions from the HOW incinerator
Figure 20: Daily average CO emissions from the HOW incinerator
26
Figure 21: Daily average TOC emissions from the HOW incinerator
Figure 22: Daily average HF emissions from the HOW incinerator
27
Figure 23: Daily average HCl emissions from the HOW incinerator
28
3.10 Other: Leak detection and repair (LDAR) and Dust fall out results Table 22: LDAR results for FY19
Units Number of points measured
Number of leaks detected (from 10 000-100 000 ppmv)
Unit 032-Polymerization west 28 577 526
Identification and reporting of the leaking equipment is based on the leak definition of 10 000 ppmv. The leak report was distributed to the maintenance department to repair the identified leaks.
Table 23: Dust fall out results
Restriction areas Dust fall rate (D) [mg/m2/day 30 days average)
Permitted frequency of exceeding dust fall rate
Residential areas D < 600 2 within a year, not sequential months
Non-residential areas 600 < D < 1200 2 within a year, not sequential months
Location of bucket Coal Separation East (CP1) Coal Separation West (CP2)
July 2018 199 269
August 2018 381 439
September 2018 297 272
October 201 200 240
November 2018 303 238
December 2018 277 239
January 2019 174 199
February 2019 156 250
March 2019 243 210
April 2019 200 157
May 2019 144 230
June 2019 181 208
The dust fall out results indicate all measurements within the specification for non-residential areas.
29
4. COMPLIANCE AUDIT REPORTS
No AEL related audit findings were noted during the third party audit conducted in July 2019.
5. MAJOR UPGRADE PROJECTS
The installation of evapostop disks as abatement technology on the coal tar naphtha (CTN) tank was completed and beneficial operation achieved on 015TK-101. In addition the installation of three separate particulate matter reduction technologies were installed and achieved beneficial operation on three boilers. The efficiencies of the technologies are being evaluated. The following electrostatic precipitator controller technologies were installed:
High frequency controllers (installation on boiler 1 west)
Medium frequency controllers (installation on boiler 2 west)
High voltage pulse energisation controllers (Coromax) (installation on boiler 4 west)
6. REGENERATIVE THERMAL OXIDISER INCIDENT
As previously communicated, on 15 August 2018, one regenerative thermal oxidizer (RTO) at the
tar distillation unit (unit 214) at refining west tripped after a period of stable operation. During the re-commissioning there was an overpressure in the inlet line which, at about 14:42 resulted in an explosion of the RTO. Subsequently, site emergency procedures were immediately activated and the area was isolated to mitigate the exposure risks to the people, property and environment. Consequently, there was no associated significant harm or risk. There was also no immediate risk to the nearby community. The RTO impacted by the incident is out of commission and will require significant repairs before it can be safely commissioned. A second RTO, in close proximity to the primary impacted RTO was also decommissioned given some associated impacts thereto and preliminary investigations confirmed that the second RTO will also require repairs. It will hence also be temporarily de-commissioned for this purpose. A formal investigation was conducted and highlighted the need to update the baseline information, to inform the revised design basis for the rebuild project to restore equipment integrity, process intent, and ensure robust and safe operations.
During January and February 2019 the core operations team involved in the investigation had detailed framing and aligning sessions. Based on the level of understanding of the root cause findings that led to the incident, a preliminary plan was developed for all the action items. During this session it was also identified that critical parameters that lead to the incident were not fully understood that requires fundamental evaluation and understanding to inform a pre-feasibility level design basis definition. Due to this fact the baseline definition of the feed into the RTO needs to be redone before the design basis of the rebuild project can be developed. A sampling campaign on the feed to the RTO unit is planned to be executed to determine the flow
30
rates, temperatures, pressures and compositional breakdown of the volatile organic compounds that enter the system. This will form the foundation for the baseline and subsequent input into the design basis for the rebuild project. To ensure that the abnormal operating conditions are captured and understood, various operating scenarios will be tested in the upstream factory units that feed into the RTO. Currently the sampling facilities at the RTO is being designed and planned for construction to enable the extensive sampling required. Once the results from the campaign is available, a design basis will be developed. This is expected to start towards November 2019. Due to the fundamental understanding required of the baseline and the various scenarios operating associated with it, the hazard and operability study can only be completed once the project definition is being developed during the basic engineering phase currently projected for 2021.
7. GREENHOUSE GAS (GHG) EMISSIONS
Sasol South Africa Limited is registered as required in terms of the National Greenhouse Gas Emission Reporting Regulations, section 5 (1) with the Department of Environment, Forestry and Fisheries (DEFF). Data has been submitted to the DEFF on 31 March 2019 for calendar year 2018 as per the requirements set out in Annexure 3 of the Regulations. The GHG emissions and activity data relates specifically to all the registered Sasol facilities and not only for SSO. Please refer to Annexure 1 for the GHG emission and activity data that was submitted.
8. PUBLIC CONSULTATION FORUM
One public consultation session was held in financial year 2019 (FY19) to meet the applicable AEL requirements. On 05 December 2018 a public consultation session was held at Sasol eMbalenhle club. The session did not proceed as planned. An organised group that attended the meeting disrupted the session and demanded that the public consultation session end. Sasol personnel were told to leave. Given the inherent safety risks, the facilitator and Sasol personnel complied and ended the meeting. Some of the community members removed the attendance register from the hall. In the interest of safety and wellbeing of all our stakeholders, the sessions in Lebohang and Secunda scheduled for 06 December 2018 were subsequently cancelled. Sasol submitted a letter to the licensing authority on 14 December 2018 outlining the challenges experienced and the associated risks. The letter also included alternative proposals to ensure the objectives of public consultation are met in a constructive and meaningful manner going forward. Further, from the Highveld Priority Area implementation task team (ITT) meeting held on 15 May 2019 it was noted that the licensing authority is currently reviewing the public consultation requirements with a view to optimize these sessions. Following the ITT meeting, Sasol sent a letter to the Gert Sibande District Municipality (GSDM) licensing officer confirming that further public participation sessions are on hold pending clarification from the licensing authority.
31
9. ACTIONS TAKEN ON COMPLAINTS RECEIVED Twenty two complaints were received in the reporting period July 2018 to June 2019. Table 24: Air related complaints for FY19
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
E van Huyssteen
A complaint of black smoke from the western stack was received on 07 October 2018. Commissioning took place at the western factory cold separation phase one following the annual shutdown. The plant data indicated a number of instabilities throughout the day as expected during commissioning.
Not applicable. The commissioning of the cold separation phase one is part of the operations and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. Furthermore, the process is closely monitored and does not exceeds 48 hours.
Not applicable. The complaint was closed
S Reddy Ammonia smell was felt at the east of the Carbo tar plant on 18 October 2018. It was found that daily samples that were drawn by unit (2)52 indicated that the ammonia amount in the stripped gas liquor (SGL) to water recovery was above specification. To correct this, Phenosolvan improved the stripping of ammonia
The calculation of impacts or emissions associated with the complaints were not applicable.
Ensure that the ammonia amount in the SGL to water recovery is within the specification.
On-going process and the date cannot be determined. Feedback was given to the complainant and the complaint was closed.
32
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
in the SGL by optimising the total stripper running temperature and pressure. It was found that during the early hours of the morning, the wind direction was north-easterly. Shortly after sunrise, the wind direction shifted north and by noon the wind was emanating from a north-western direction. At the time of the complaint, the wind was blowing in a north western direction from the Water recovery plant to the carbo tar area.
W Potgieter Ammonia smell was felt at the south clock station area on 20 November 2018. It was found that at Phenosolvan West Unit 52, the gas liquor had high ammonia content. Process adjustments were done to lower the ammonia content in the gas liquor.
Not applicable. Ensure that the ammonia amount in the gas liquor is within the specification.
On-going process and the date cannot be determined. Feedback was given to the complainant and the complaint was closed.
Anonymous A complaint was received on 27 December 2018 about the black smoke from the East stack. Further, that the ambient air monitoring stations are not adequately placed. It was confirmed that boiler two operated with oil burners on the western plant which contributed to the smoke. An electrostatic precipitator on one of the boilers on the western steam plant had problems and this probably resulted in the increase in emissions.
The calculation of impacts or emissions associated with the complaint were not applicable.
The boiler start up is part of the operations and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. Furthermore, the process is monitored to ensure
This is an on-going process and the date cannot be determined. Complaint was closed.
33
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
GPS coordinates are available for position of ambient air quality monitoring stations. Positioning of stations specific to monitor impact on residential areas are determined by the prevailing wind direction and the offsetting project in eMbalenhle and Lebohang. All ambient data is available on the South Africa Ambient Quality Inventory System (SAAQIS) website.
that it does not exceeds 48 hours.
R Malan A complaint of gas liquor released into the air in Secunda was received on 09 April 2019. From the investigation, it was found that there was no upsets in the plant or strong winds at the time of the complaint making it unlikely that gas liquor could disperse up to the town.
Not applicable Not applicable Not applicable Feedback was given to the complainant and the complaint was closed.
I Erasmus Brown smoke from main stacks and rotten egg smell was reported on 03 May 2019. There was a boiler start-up at western plant. Wind direction was towards Secunda and an increase in H
2S emissions was noted at the air
ambient monitoring station in Secunda. However, the AEL compliance was confirmed.
Not applicable. The boiler start up is part of the operations and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. Furthermore, the process is monitored to ensure that it does not exceeds 48 hours.
Start-up conditions are for short durations only and managed in terms of our AEL Feedback was given to the complainant and the complaint was closed.
34
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
Due to adverse atmospheric conditions, elevated H2S was measured at ground level. However, maintenance schedules, best practices are adhered to ensure continuous improvement.
I Erasmus A brown trail floating over Secunda in early morning on 06 May 2019 was noted. Later in the day, large white cloud from the west stack and yellow or brown haze was visible from the eastern stack. The complainant also quoted ambient data from an unknown source. It was confirmed that boiler five operated with oil burners on the western plant which contributed to the smoke. Wind direction was likely towards Secunda town. Recorded ambient air quality remained within South African ambient air quality standard (SA AAQS). Sasol ambient data did not match data reported by complainant. No AEL limit exceedance at main stacks were recorded.
Not applicable. This was part of boiler five start up and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. The process is monitored to ensure that it does not exceeds 48 hours.
Not applicable. Feedback was given to the complainant and the complaint was closed.
I Erasmus Yellow or brown trail blowing to Kruinpark area was observed on 27 April 2019 from Sasol Secunda facility. No upset conditions were noted on the day of the complaint. Wind direction was away from communities. Recorded ambient quality
Not applicable. Not applicable. Not applicable. Feedback was given to the complainant and the complaint was closed.
35
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
remained within SA AAQS. Emissions from the main stacks were below AEL limits. Haze or poor visibility was due to poor vertical mixing (typical of colder months) and low level pollution that gets trapped at ground level.
I Erasmus Visible emissions from the Sasol Secunda facility were observed on 04 May 2019. A yellow or brown haze blew over the Secunda residential area. No upset conditions were reported. The steam plant did have oil burners for short durations. Stack emissions reported below the daily limits as per the AEL. Wind direction was away from Secunda town. Confirmed that stack emissions contain SO
2
emission commonly associated with coal combustion. Ambient quality remained within SA AAQS. No AEL limit exceedance at main stacks
Not applicable. Not applicable. Not applicable. Feedback was given to the complainant and the complaint was closed.
I Erasmus Yellow or brown emissions from stacks and a smell in air was noted on 11 May 2019. It was confirmed that no upset conditions in the plant were experienced on the day of complaint. Wind direction was north east therefore, the plume direction was likely towards Secunda town. Recorded data from Sasol Secunda ambient air monitoring stations located in the communities
Not applicable. Not applicable. Not applicable. Feedback was given to the complainant and the complaint was closed.
36
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
did not exceed SA AAQS limits. Furthermore, stack emissions from the plant were below the AEL limits.
I Erasmus Black smoke from the east stack was reported on 16 May 2019. Wind direction was likely towards Secunda town. It was confirmed that there was a boiler start-up which likely resulted in black smoke. There were no ambient standard and AEL limits exceedances.
Not applicable. The boiler start up is part of the operations and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. The process is monitored to ensure it does not exceeds 48 hours.
Start-up conditions are for short durations only and managed in terms of our AEL Feedback was given to the complainant and the complaint was closed.
I Erasmus Brown or yellow smoke from eastern stack was observed on 21 May 2019. Wind direction was likely towards Secunda town. A precipitator on one of the boilers on the eastern steam plant was offline for maintenance. Stack emissions and ambient air remained below limits.
Not applicable. The maintenance that was undertaken was part of the operations and cannot be prevented. However, the process was monitored to minimise environmental impacts and to ensure it does not exceeds 48 hours.
Start-up conditions are for short durations only and managed in terms of our AEL Feedback was given to the complainant and the complaint was closed.
V Joubert Brown and yellow smoke from eastern and western stacks were observed on 03 June 2019.
There were no upset conditions at the western and eastern steam plants at the time of the
Not applicable. Not applicable. Not applicable. Feedback was given to the complainant
37
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
complaint. The stack emissions reported were below the daily limits as per the atmospheric emission license (AEL).
and the complaint was closed.
H Brewis Brown and yellow smoke was noted on 04 June 2019 at the western stack. Wind direction was likely towards Secunda town. An electrostatic precipitator on one of the boilers on the western steam plant was undergoing maintenance. This planned maintenance most probably resulted in the increase in emissions from the western main stack. The stack emissions reported were below the daily limit as per AEL.
Not applicable. The maintenance that was undertaken was part of the operations and cannot be prevented. However, the process was monitored to minimise environmental impacts and to ensure it does not exceeds 48 hours.
Not applicable. Feedback was given to the complainant and the complaint was closed.
I Erasmus White plume from western stack was noted on 04 June 2019. Wind direction was towards Secunda town. The western steam plant was undergoing maintenance on one of the boiler’s electrostatic precipitator. This planned maintenance most probably resulted in the increase in emissions from the western main stack. We confirm that all stack emissions reported below the daily limits as per the air emission license (AEL) on 04 June 2019.
Not applicable. The maintenance that was undertaken was part of the operations and cannot be prevented. However, the process was monitored to minimise environmental impacts and to ensure it does not exceeds 48 hours.
Not applicable. Feedback was given to the complainant and the complaint was closed.
I Erasmus Black and yellow smoke was noted on 14 June 2019 at the eastern stack.
Not applicable. The boiler start up is part of the operations and cannot be prevented.
Start-up conditions are for short durations only and
38
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
Wind blew in a northerly direction. Boiler eight tripped and during a start-up a plume from the east stack passed over the western residential part of Secunda, but not likely to have passed over eastern Secunda or Trichardt. From Secunda club ambient air monitoring station, H2S and PM10 measurements peak were observed in the morning and evening, typically associated with domestic cooking, heating and other low level sources. SO2 and PM10 ambient levels remain well below the ambient air quality standard limit.
However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. The process is monitored to ensure that it does not exceeds 48 hours.
managed in terms of our AEL Feedback was given to the complainant and the complaint was closed.
I Erasmus A rotten egg smell was experiences in Secunda town on 15 June 2019. The sulphur recovery plant operators indicated that all units were stable and that the plant performance has been consistent for the last two weeks. Therefore, no changes in operations were observed on the day of the complaint that may have caused a change. The wind direction was north east. Stack plumes from the factory may therefore be directed towards Secunda town. H2S is typically associated with a rotten egg smell, therefore ambient measurements at the Secunda club were investigated and included typical stack emissions such as H2S, SO2 and PM10. A peak between 09:00 and 14:00 was observed for H2S and SO2.
Not applicable Not applicable Cannot be determined as the root cause was unknown. Feedback was given to the complainant and the complaint was closed.
39
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
Ambient air quality standard limits for SO2 were not exceeded. Elevated levels of PM10 were observed on various times throughout the night and day. These elevated PM levels did not coincide with the typical stack emissions, thereby indicating the contribution of sources other than industry.
I Erasmus Hazy air was observed at Trichardt town on 20 June 2019. After and before the complaint was lodged at 08:45, the wind blew in north north west direction. This is in the general direction of Kinross and away from adjacent communities such as Secunda and eMbalenhle. While stack emissions do contribute to the hazy conditions, from the photographic evidence provided it was clear that the haze originated upwind of factory. The tall stacks could be seen above the haze layer. The haze is expected to be the result of a complex mixture of natural and anthropogenic activities subject to various chemical and physical reactions in the atmosphere. The main stack emissions were below the atmospheric emission licence limits and no upset or maintenance conditions were reported.
Not applicable Not applicable Not applicable Feedback was given to the complainant and the complaint was closed.
I Erasmus On 21 June 2019, a dust cloud probably full of PM2.5 and PM10 blew directly over Secunda
Not applicable Not applicable Not applicable.
40
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
primary school just around the first break when the kids were outside. The wind direction was blowing in a southern direction. This is in the general direction of eMbalenhle as can be seen from the photos provided. Elevated PM measurements were observed during the time of the call at eMbalenhle ambient air monitoring stations. Data showed that PM10 did exceed the daily ambient air quality standard limit. A high PM baseline was also observed on this day. Adverse atmospheric conditions including mixing and dispersion, contributed to tall stack emissions being measured at ground level. The main stack emissions were below the atmospheric emission licence limits and no upset or maintenance conditions were reported.
Feedback was given to the complainant and the complaint was closed.
A Venter On 28 June 2019, black smoke was observed on the octane flare for more than an hour at the tanker loader entrance on the eastern side. Unit 310 and 320 were commissioned at the Octane plant and off gas was released to the flare. This resulted in black smoke being produced.
Not applicable The commissioning of unit 310 and 320 is part of the operations and cannot be prevented. However, the process is resolved as soon as possible to minimise environmental impact and to ensure plant stability. The process is monitored to ensure that it does not exceeds 48 hours.
Feedback was given to the complainant and the complaint was closed.
41
Source code/ name
Root cause analysis Calculation of impacts/emissions associated with incidents where applicable
Measures implemented to prevent recurrence
Date by which measures will be implemented
I Erasmus A rotten egg smell was smelt in Secunda town on 28 June 2019. The wind from the factory was blowing towards the North East, in the direction of Secunda town during the time of the complaint. Ambient air quality standard limits for SO2 and PM10 were not exceeded. H2S currently has no ambient air quality standard limit in South Africa. The Californian 1984 committee concluded that a 30 ppb hourly average ambient standard for H2S is adequate to protect public health and to significantly reduce odour annoyance. H2S measured before and after the time of the call between 14:00 and 15:00 was 4.7 and 8.8 ppb respectively.
Not applicable Not applicable Feedback was given to the complainant and the complaint was closed.
42
10. HIGHVELD PRIORITY AIR QUALITY MANAGEMENT PLAN AND OFFSET PROGRAMME
10.1 Highveld priority air quality management plan The report on the Highveld priority air quality management plan is in Annexure 3.
10.2 Sasol Secunda offset implementation plan The Sasol Secunda offset plan was approved by the National Air Quality Officer on 29 May 2017. A projects design document is almost finalized to clearly document the scope and measurements for project impacts at eMbalenhle and Lebohang. A study is underway on quantifying the impact of offsetting interventions and demonstration the reduction of particulate matter and sulphur dioxide pollution in the ambient air. The report will be submitted in FY20 as required by the AEL. The information below highlights the progress on the implementation of offset activities as per the approval letter. 9.3.1 Insulation of reconstruction development programme houses (RDP) Basic insulation (ceiling only) of reconstruction development programme (RDP) homes and exchange of solid fuel burning coal stoves with liquid petroleum gas (LPG) stoves and heaters in eMbalenhle and Lebohang is on-going. To ensure successful implementation of insulating RDP houses, a staggered approach was adopted. In FY18, the focus was insulating eligible RDP houses at eMbalenhle and the project was extended to Lebohang in FY19. From July 2017 to June 2019, 3300 RDP houses at eMbalenhle and Lebohang were completed and handed over to the household owners. The exchange of coal stoves with LPG package was done to all houses. The target for FY20 is to insulate 2600 RDP houses to meet our commitment of 5900 RDP house as indicated in the offset approval letter. The training on the use of the LPG equipment is ongoing. The coal stoves were removed and dismantled at a Sasol reclamation yard.
The pictures showing different activities are included in Annexure 4.
Three ambient air quality monitoring stations were installed at eMbalenhle north (Buyani primary school), eMbalenhle south (KI Twala secondary school) and Lebohang (Chief Ampie Mayisa high school). These ambient air quality monitoring stations measure the emissions from all activities including non-industrial sources. 9.3.2 Air quality education and awareness campaign
The target audience are communities of eMbalenhle and Lebohang where offsets are implemented and twenty seven primary schools in the Govan Mbeki local municipality. To reach the community in the target areas, various mediums of communication were used to execute the activities planned for this initiative. These activities included the development of booklets and pamphlets on air quality and various air pollutants, which were used as educational tools for both young and old community members.
In eMbalenhle and Lebohang, 4900 and 2800 households were reached at respectively. Six sessions were covered on different topics during the door to door campaign in eMbalenhle and Lebohang. Door to door visits and engagement were undertaken by trained field workers on air quality related topics. They engaged and assessed the community of understanding on air quality related matters.
43
Furthermore, fliers were distributed and placed in the public areas. Adverts were placed in the local newspapers. The education and awareness campaign have a wide coverage. The door to door campaign is on-going. Post assessment using the pre-assessment forms used during baseline will be done after the implementation of the campaign.
Twenty seven schools started implementing the activities for various grades and is on-going. Continuous monitoring of all the activities is underway. Eleven schools completed all the activities from Grade one to seven and are in the process of being assessed. One hundred percent of the schools completed the Grade one to four activities. Eighty percent of the schools completed grade five to seven activities. The target date for completion of these activities is 30 September 2019. Assessment tools such as rubrics and multiple choice questions for various grades have been prepared.
The impact assessment report for education and awareness campaign will be compiled after the implementation of the project.
9.3.3 Grass cutting and veld fire management Grass cutting and veld fire management activities are ongoing by the Sasol Secunda’s emergency management team, with their scope of activities enhanced to support greater mitigation of veld fires to reduced smoke (PM) emissions from veld fires. Cutting of grass is done at eMbalenhle. 9.3.4 Waste management Waste management at eMbalenhle and Lebohang is underway. Communities through education and awareness campaign are informed on best practices such as separation, sorting and recycling waste to avoid burning it. About 123 tons of recyclable waste was collected and taken to buyback center by households. The inorganic waste was used as natural organic fertilizer for the soil. Illegal dumping sites were cleaned and converted into gardens at eMbalenhle. The crops from the gardens are harvested by the community and some are donated to orphanages and vulnerable people in the communities. 9.3.5 Feasibility studies at eMbalenhle and Lebohang
Feasibility for roads (Lebohang and eMbalenhle) Source apportionment results confirmed that the impact of dust from unsurfaced roads is minimal, therefore this option will not be considered further. Therefore, additional 500 RDP homes will be insulated with a coal stove swop.
Informal housing insulation at Lebohang and eMbalenhle Insulation of twenty four serviced informal houses with spray polyurethane foam together with a stove swap in Lebohang was completed in 2017. The pilot programme proved unsuccessful, therefore an additional 400 RDP homes will be insulated with a coal stove swop. 9.3.6 Challenges with offset implementation Despite the many successes of the off-setting project, various challenges have also been experienced throughout the year. These can be summarised as follow:
44
Projects and awareness campaign interruptions
Social unrest due to unemployment and poor service delivery.
Access and availability of households during project planned working hours.
Theft of tools used in household contracting staff such as cell phones. Safety concerns
Community protests and interruption of bi-annual public consultation sessions.
Illegal electrical connections impacting on safety of households and workers when installing insulation.
Liquid petroleum gas (LPG) equipment being moved from trained households to non-trained households.
Procurement and enterprise and supplier development (E&SD)
Limited small medium micro enterprise (SMMEs) and suppliers in the local community. Education and awareness
Lack of enthusiasm during LPG awareness training.
Households not being available for follow up training on LPG awareness.
Schools not willing to participate in the campaign due to lack of resources.
School coordinators or teachers not implementing the activities.
45
Annexure 1: Sasol’s 2018 GHG submission to the national GHG reporting regulations
Name of Data Provider
Herman van der Walt/Shamini Harrington
Data Provider ID 170500107
Date of Submission:
31-Mar-19
Year of data: 2018
Comments: Activity data has been supplied however it must be noted that a carbon mass balance has been used to determine GHG data. In most cases the activity data can not be directly translated to GHG data. Flaring actvity data can not be supplied due to various streams entering the flare at any given time.
IPCC Code (see Annexure 1)
Sub category⁴ (disaggregated by fuel / product type / production process)
Activity data⁵ Emissions (tonnes/year)
Name of activity data
Value of activity data
Units of activity data
CO2⁶ CH4 N20
Value Tier
Ref Value
Tier
Ref Value
Tier
Ref
1A1 1A1c Boiler coal combustion
14,977,374
tons of run of mine coal
25,429,246
3 Tech Guidelines;page 52-54
300 1 Tech Guidelines;page 52-54
449 1 Tech Guidelines;page 52-54
1A1 1A1c Gas to power plants
750,271
kNm3 1,420,641
3 Tech Guidelines;page 52-54
25.3 1 Tech Guidelines;page 52-54
2.53
1 Tech Guidelines;page 52-54
1A1 1A1c Fuel gas combustion
28,640,347
GJ 1,194,110
3 Tech Guidelines;page 52-54
21.3 1 Tech Guidelines;page 52-54
2.13
1 Tech Guidelines;page 52-54
1A1 1A1c Fuel oil combustion
1,100,948
GJ 118,860
3 Tech Guidelines;page 52-54
4.6 1 Tech Guidelines;page 52-54
0.92
1 Tech Guidelines;page 52-54
1A1 1A1c Sasol Catalyti
1,199,845
kNm3 188,429
3 Tech Guidelines;page 52-54
7.3 1 Tech Guidelines;page 52-54
1.46
1 Tech Guidelines;
46
c Cracker
page 52 -54
1A1 1A1c Wet sulphuric acid combustion emissions
177,871
kNm3 68,055 3 Tech Guidelines;page 52-54
1.2 1 Tech Guidelines;page 52-54
0.12
1 Tech Guidelines;page 52 -54
1A 1A1c Natural gas combustion
910,988
GJ natural gas
39,454 3 Tech Guidelines;page 52-54
0.7 1 Tech Guidelines;page 52-54
0.07
1 Tech Guidelines;page 52-54
1B 1B3 Other Energy Industries: process emissions
30,042,216
kNm3 (pure gas rate for CTL/GTC)
23,227,198
3 Tech Guidelines;page 52-54
96,416
3 Tech Guidelines;page 52-54
1B 1B3 Flaring emissions
No activity data due to complexity of the process
N/A 2,027,278
3 Tech Guidelines;page 52-54
1B 1B3 Wet sulphuric acid process emissions
177,871
kNm3 309,044
3 Tech Guidelines;page 52-54
1B 1B3 Butanol stripper
182,658
tons of butanol
15,323 3 Tech Guidelines;page 52-54
4D 4D2 Process water dams
23,360 tons process water feed
7,065 3 Tech Guidelines;page 52-54
3,853
3 Tech Guidelines;page 52-54
47
4D 4D2 Water recovery (including domestic sewage)
119,401
tons COD
180,962
3 Tech Guidelines;page 52-54
2B 2B2 Nitric acid production
643,962
tons 692 3 Tech Guidelines;page 52-54
2B 2B1 Ammonia production
313,043
tons of ammonia
241,415
3 Tech Guidelines;page 52-54
7,962
3 Tech Guidelines;page 52-54
1B 1B1 Sasol Mining
40,020,782
tons of coal mined
3,229
2 Tech Guidelines;page 52-54
1B2 1B2b Natural gas venting from the pipeline
4,555,664
kNm3 11 2 Tech Guidelines;page 52-54
4C 4C2 Open burning of waste
Not applicable
1A5 1A5b Mobile combustion: Mining machinery
245,406
litres of petrol and diesel
19,410 1 Carbon budget reporting requirement
48
Annexure 2: Public consultation forum attendance list and presentation (see attached documents)
Annexure 3: Highveld Priority Air Quality Management Plan – (see attached document)
Annexure 4: Offset implementation – (see attached documents)