Proposed amendments to the listed activities under section 21 of NEM:AQA 2004

About PAMSA Formed in 1992 Promotes the interests and efforts of the South African pulp and paper industry Members – Kimberly-Clark, Mondi, Mpact, Nampak and Sappi Platform for the development and presentation of common views on pre-competitive industry issues – energy, environment, recycling, education, research etc PAMSA also oversees the efforts of: Paper Recycling Association of South Africa (PRASA) Promotes paper recycling in South Africa through increased education and awareness initiatives South African Tissue Manufacturers Association (SATMA) Encourages tissue product manufacturers to maintain the legally required standards

Background PAMSA participated with DEA and SABS in the process of the declaration of listed activities and minimum emission standards PAMSA commented on the draft set of listed activities and minimum emission standards published in the Government Gazette on 31 March 2010 and again on 23 November 2012 (amendments to the 31 March 2010 gazette)

Details of issues of concern Chemical Recovery Copeland Reactors: sub-category 9.3 (note: only 3 in the country) Particulate emissions Pamsa proposed 400mg/Nm3 DEA proposed 250mg/Nm3   DEA published 100mg/Nm3 in GG on 31 March 2010; no new Copelands DEA/BUSA /Stakeholder Consultative Process July 2010 PAMSA raised the issue of 400mg/Nm3 DEA proposed adjustment to 400mg/Nm3 on condition phase-out plan was produced  PAMSA internal review workshops July 2010 – February 2011 Draft minimum emission standard from DEA proposed 150mg/Nm3

Details of issues of concern Chemical Recovery Copeland Reactors: sub-category 9.3 cont. PAMSA presented results of independent air quality monitoring and scenario modelling studies to DEA in February 2012   DEA/PAMSA bilateral meeting in May 2012 DEA proposed 400mg/Nm3 based on independent and scientific evidence in November 2012

PAMSA internal workshops Difficult to measure a hygroscopic (wet) chemical with any accuracy Alternative technologies not cost effective Point source emission monitoring provide variable results and lack confidence Air quality dispersion modelling provided a realistic approach to demonstrating compliance with ambient air quality standards

PAMSA/DEA bilateral meeting July 2011 Agreed for PAMSA to undertake air quality monitoring and scenario modelling studies for the Copeland Reactors in South Africa Independent study undertaken by uMoya-NILU Consulting (Pty) Ltd using input variables of 100, 200 and 400mg/Nm3 Demonstrated that predicted ambient concentrations remained compliant with current and 2015 national ambient standards at all modelled emission concentrations

Second issue of concern Category 1: Combustion installations: Sub-category 1.1 Solid fuel Combustion installations Requested a review of this sub-category Why is “excluding any solid material that is regarded as waste in terms of the Waste Act” included? Biomass may be used as a fuel in Solid Biomass Combustion Installation Sub-category 1.3 No ability to use biomass in conjunction with Solid Fuel Combustion Installation 1.1

Cont. - Biomass regarded as waste under definition of waste in Waste Act Therefore, to burn biomass need to move to sub-category 8.1 Thermal Treatment of General and Hazardous Waste Consequences of exclusion of biomass from 1.1 and current description of 8.1 is that when co-combustion occurs under this category, then the minimum emission standards of 8.1 must apply – which cannot be achieved

Cont. - PAMSA requests a sub-category for co-generation for large boilers, together with minimum emission standards for multi-fuel boilers in line with European regulations

Other issues of concern Thermal Treatment of Hazardous and General Waste Need clarity from DEA as to where multi-fuel boilers fit into the regulations (see also sub-category 1.1) Special compensation should be given to pulp and paper business, as is given to the cement industry

Other issues of concern cont. - Sub-category 9.1 Lime Kiln Recovery and Sub-category 9.2 Chemical Recovery Furnaces No accepted method to measure H2S from the stacks and none described in the draft regulations

Cont. - Category 9.5 Wood burning, Drying and the Production of Manufactured Wood Products Under APPA, treated wood sawmills were included as were compressed wood products No need to regulate untreated burning or drying of wood in the kiln since particulate emission levels are below detectable levels – independent results provided to DEA

Concluding remarks Copeland particulate minimum emission standard has been resolved Need further interaction on – Co-generation (multi-fuel boilers) Clarification on Thermal Treatment of Hazardous and General Waste with regard to co-generation Clarification on the method for H2S monitoring in Lime Recovery Kiln and Chemical Recovery Furnaces Deletion of untreated wood and kilns from the regulations