Sasol South Africa · 1 Sasol South Africa Secunda Synfuels Operations Annual Emission Report Dated...

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


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


mailto:[email protected]

mailto:[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


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



Gas turbine 1 (GT1

PM 6 10 at 15% O2


44 300 at 15% O2

SO2 <3 500 at 15% O2

Gas turbine 2 (GT2)

PM 3.3 10 at 15% O2


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)


Due to stack inaccessibility no sampling could be conducted

1 700

SO2 1 700

R2(14HT201)


201 1 700

SO2 <2 1 700

R3(214HT101)


213 1 700

SO2 101 1 700

R4(214HT201) NOx expressed as 165 1 700

7

Point source code

Pollutant



NO2

SO2 76 1 700

R5(228HT101)


109 1 700

SO2 46 1 700

R6 (30HT101)


108 1 700

SO2 <72 1 700

R7 (30HT102)


89 1 700

SO2 102 1 700

R8 (30HT103)


83 1 700

SO2 <3 1 700

R9 (30HT104)


88 1 700

SO2 39 1 700

R10 (30HT105)


90 1 700

SO2 18 1 700

R11 (230HT101)


75 1 700

SO2 <28 1 700

R12 (230HT102)


121 1 700

SO2 <2 1 700

R13 (230HT103)


102 1 700

SO2 22 1 700

R14 (230HT104)


95 1 700

SO2 <25 1 700

R15 (230HT105)


103 1 700

SO2 34 1 700

R17 (34HT101)


96 1 700

SO2 99 1 700

R18 (234HT101)


75 1 700

SO2 <3 1 700

R19 (35HT101)


108 1 700

SO2 <3 1 700

R20 (35HT102) NOx expressed as 97 1 700

8

Point source code

Pollutant



NO2

SO2 33 1 700

R22 (235HT101)


97 1 700

SO2 119 1 700

R23 (235HT102)


85 1 700

SO2 54 1 700

R24 (35HT103)


79 1 700

SO2 35 1 700

R25 (35HT104)


85 1 700

SO2 <2 1 700

R26 (35HT105)


112 1 700

SO2 <3 1 700

R27 (29HT101)


117 1 700

SO2 25 1 700

R28 (29HT102)


90 1 700

SO2 30 1 700

R29 (229HT101)


50 1 700

SO2 <2 1 700

R30 (33HT101)


108 1 700

SO2 100 1 700

R31 (33HT102)


108 1 700

SO2 122 1 700

R32 (33HT105)


83 1 700

SO2 <2 1 700

R33 (233HT101)


80 1 700

SO2 24 1 700

R34 (233HT102)


105 1 700

SO2 <9 1 700

R35 (233HT105)


77 1 700

SO2 10 1 700

R36 (32HT101) NOx expressed as 90 1 700

9

Point source code

Pollutant



NO2

SO2 82 1 700

R37 (32HT201)


43 1 700

SO2 29 1 700

R38 (32HT102)


47 1 700

SO2 <3 1 700

R39 (232HT101)


80 1 700

SO2 41 1 700

R40 (232HT201)


77 1 700

SO2 74 1 700

R41 (232HT102)


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



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



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



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



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



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


SO2 <3 500

CM3 (East kiln A stack)

PM 27 100


SO2 <3 2 000

CM4 (East arc furnace stack)

PM 5 100


SO2 <10 500

13

Point source code



CM5 (East Kiln B stack)

PM 214 100


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



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)


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


HOW2 (252CI-101)


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


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)


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


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


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)


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


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


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)


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


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


HOW2 (252CI-101)


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


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


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)


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


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


HOW2 (252CI-101)


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


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



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)


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


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




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




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




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




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


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


36

Source code/ name




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.


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.


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




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.



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.



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




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




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




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




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


25.3 1 Tech Guidelines;page 52-54

2.53


1A1 1A1c Fuel gas combustion

28,640,347

GJ 1,194,110



2.13


1A1 1A1c Fuel oil combustion

1,100,948

GJ 118,860



0.92


1A1 1A1c Sasol Catalyti

1,199,845

kNm3 188,429



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


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


0.07


1B 1B3 Other Energy Industries: process emissions

30,042,216

kNm3 (pure gas rate for CTL/GTC)

23,227,198


96,416


1B 1B3 Flaring emissions

No activity data due to complexity of the process

N/A 2,027,278


1B 1B3 Wet sulphuric acid process emissions

177,871

kNm3 309,044


1B 1B3 Butanol stripper

182,658

tons of butanol


4D 4D2 Process water dams

23,360 tons process water feed


3,853


47

4D 4D2 Water recovery (including domestic sewage)

119,401

tons COD

180,962


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


7,962


1B 1B1 Sasol Mining

40,020,782

tons of coal mined

3,229


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)

Sasol South Africa · 1 Sasol South Africa Secunda Synfuels Operations Annual Emission Report Dated...

Documents

Transcript of Sasol South Africa · 1 Sasol South Africa Secunda Synfuels Operations Annual Emission Report Dated...