Professor Eugene Cairncross 7/8 November 2017 Report to the PCEA Workshop on the MES, with particular reference to Eskom’s compliance history since the MES came into effect (1 April 2015) Professor Eugene Cairncross 7/8 November 2017

Location of Eskom’s coal power stations

HPA and VTPA stations only

Eskom’s defective postponement appliactions Atmospheric Impact Reports (AIRs) did not include health impact assessments Twelve of Eskom’s coal power stations are located in the contiguous region of the HPA and VTPA, but the impact of each station was modelled in isolation from the others (no cumulative impacts) The comparison between modelled (calculated) ambient concentrations was only done at three of the 12 stations. In these three cases, modelled annual average concentrations underestimated measured values in their vicinity by 60% to 80% at these stations, yet modelling results were used to assert compliance (or otherwise) with air quality standards. It was also assumed that modelled concentrations were adequate and valid estimates of concentrations for all the power stations.

Measured ambient concentrations are high, but Eskom denies responsibility The Eskom AIR’s, while admitting that monitored (measured) data showed widespread non-compliance in the PAs, spuriously introduced a subjective argument that their emissions were not responsible for the non- compliance. Eskom also denies that its SO2 and NOx emissions are contributors to PM2.5 formation and therefore additionally contributors to high ambient PM levels.

Extensive arguments submitted against the granting of postponement applications, but … The NAQO granted substantially all requested postponements Eskom ‘emission reduction’ plans indicated that, on certain power stations, it had no intention of ever complying with the MES. Eskom’s coal power stations are located in Priority Areas, with documented poor air quality that does not meet the NAAQS. On this ground alone, any requests for leniency with respect to the MES and postponement of compliance of future stricter standards should have been refused.

Atmospheric Emission Licences (AELs) issued as per the NAQO’s decisions: The colour coded stations, 8 of 14, indicate that the corresponding limit values are more lenient than the ‘existing plant’ MES.

Does Eskom comply with the relaxed limits? Duvha, Grootvlei, Kendal, Komati, Kriel, Matla, Lethabo (7 of the 12 with data) were very likely or likely non-compliant with their PM10 limit values in 2015/16. Grootvlei was likely compliant with their AEL PM10 limit value but the latter is 3.5 times the ‘existing plant’ MES value. Komati and Kriel power stations probably non-compliant with their NOx AEL limit values

Medupi and Matimba SO2 emissions Medupi and Matimba applied for a further relaxation of their SO2 limit, from 3 500 to 4 000mg/Nm3, indicating that they were unable to meet the 3 500 mg/Nm3 limit. This implies that both Medupi and Matimba are in non-compliance with their SO2 limit values. That is, of the 14 stations, none is consistently compliant with the ‘existing plant’ MES limit values.

Medupi FGD saga (conditions of AfDB/ WB loans) 2017 visit of AfDB/ WB mission to “review the implementation of the Eskom Medupi Power Project and Eskom Investment Support Project (for WB), reported the following concerns with respect to Medupi’s SO2 emissions.” “The Mission expressed concern that Eskom expects that Medupi will not be able to comply with the existing plant standard of 3,500 mg per NM3. .. Future seams of coal from Exxaro mine are likely to have sulphur content higher than 1.7 percent, which will result in possible exceedance of SO2 emission levels. Eskom informed the Mission that blending of coal could in the interim help realize the desired emission levels that meet the emission standards. However, this measure cannot be implemented until the end of 2017 when the coal reclaimer is fully operational and the delivered coal is being systematically delivered and stored with accurate records on sulphur content. The Mission again suggested that Eskom seriously consider an interim strategy to control SO2 emissions for the next six years before the SO2 scrubbers (FGD) are operational. Previous suggestions have included the consideration to adopt a direct furnace limestone injection program which has been tested in the USA and in Europe and shown to reduce SO2 emissions by up to 50%.

Extracts from a partial set of Kendal 2015/16 monthly reports showing non-compliance with PM limit values

Sasol: Substantially all (green) postponements granted

Thank you

Outcome of postponement decisions, relaxed AELs compared with ‘existing plant’ MES: