PCEA WORKSHOP ON THE MINIMUM EMISSIONS STANDARDS (MES) IN SOUTH AFRICA

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Presentation transcript:

PCEA WORKSHOP ON THE MINIMUM EMISSIONS STANDARDS (MES) IN SOUTH AFRICA 7- 8 November 2017, Cape Town

What you will hear today Sasol is committed to compliance with all applicable laws including air quality laws. This supports sustainable air quality improvements as envisaged through the Air Quality Act and priority area air quality management plans We are making good progress against our air quality roadmaps as committed in our postponement applications: Continuous improvements and statutory maintenance have realised significant reductions in PM even prior to 2015 Our VOC roadmap in Secunda targets a mass-based reduction of 80% from a 2009 baseline, and we are likely to surpass this Our NOx emissions have been consistently below the Atmospheric Emission License (“AEL”) level as informed by the postponement decisions To support these roadmaps, we have a capital allocation framework to assist us in allocating capital, prioritising capital allocation towards the retention of Sasol’s license to operate We already meet most of the Minimum Emissions Standards (MES) for existing plants, and will also be able to meet most of the new plant standards by latest 2025. This extended timeframe is required to safely implement the necessary abatement technologies in accordance with our roadmap schedules, taking into consideration shutdown and statutory maintenance obligations In this regard, in the past we applied for, and going forward, we will be reliant on further applications for postponements, as the only legal mechanism currently provided for in law. Consequently, our licences, under which we are required to operate during the extended compliance period, contain appropriate limits informed by independent air quality specialist studies on the basis that these do not affect ambient air quality beyond National Ambient Air Quality Standards (NAAQS) However, the new plant standards for boiler plant SO2 pose significant compliance challenges from a feasibility perspective for existing, maturing plants. The measured levels of SO2 in the airsheds where we operate are well below the internationally accepted health standard. Our appeal therefore is to consider alternative mechanisms to enable progressive air quality improvements for maturing facilities. To this extent, we continue to constructively engage in law reform processes and in this regard have recently submitted comments into the DEA’s framework review consultations We believe it is appropriate for the applicable authorities to consider our postponement applications, since we meet the conditions of such applications and in particular demonstrate that our current and proposed contribution does not cause exceedance of the (NAAQS) Regulation of industrial point sources alone, in our view, is insufficient to achieve the NAAQS. Offsets are therefore an important complementary mechanism in achieving the statutory objectives

We are making good progress against our air quality roadmaps

We are making good progress against our air quality roadmaps as committed in our postponement applications Continuous improvements and statutory maintenance have realised significant reductions in particulate matter (PM) even prior to 2015 Our Boiler plant PM levels at Synfuels have been consistently below the existing AEL level as informed by the 2015 postponement decision High-frequency transformer (HFT) (possible cost effective solution) trials to be executed during 2018 Our VOC roadmap in Secunda targets a mass-based reduction of 80% from a 2009 baseline, and significant reductions have already been realised We are likely to surpass our voluntary VOC reduction target Our NOx emissions have been consistently below the AEL level as informed by the 2015 postponement decisions Low NOx burners installed on a boiler in Secunda, and further trials planned in both Secunda and Sasolburg for 2018 We have prioritised investigations for our incinerators in Sasolburg and Secunda in accordance with the waste hierarchy and have identified promising options that are overall more environmentally optimal as well as capital efficient, which require sufficient time to develop and test

Continuous improvements and a rigorous maintenance program have realised significant reductions in PM even prior to 2015 Our boiler plant PM levels have been consistently below the existing AEL level as informed by the postponement decision We continue to focus on 1) increasing boiler stability, 2) proactive maintenance, 3) reduction in mean time between breakdowns and 4) improvement in boiler reliability and availability Whilst feedstock quality remains a challenge as we reach end of life on some of our mines, we continue to look for ways to stabilise coal quality We plan to test alternative, more cost-effective solutions for our Electrostatic precipitator upgrades (e.g. high frequency transformers) within the next 12 months. If successful, this may enable quicker implementation and reductions in PM

Our VOC roadmap targets a mass-based reduction of 80% from a 2009 baseline, and significant reductions have been realised We are likely to surpass our voluntary Group reduction target Project in execution Pre-feasibility Complete FID taken Complete

Secunda Synfuels Operations Our NOx emissions have been below the AEL level as informed by the 2015 postponement decisions Secunda and Sasolburg operations piloting Low NOx Burners to assess technology performance Secunda Synfuels Operations Our Eastern and Western stack average emissions are 913 mg/Nm3 and 843 mg/Nm3 respectively which is below the 2015 existing plant standards Sasol has one boiler retrofitted with LNB. Whilst initial indications yielded positive results in reducing NOx, associated operability challenges resulted in increased PM emissions Our current NOx abatement project has progressed to feasibility. We are optimistic of the solution, however more test work needs to be done Development funding has been approved and test will commence on one boiler early next year Sasolburg Operations Our Sasolburg Operations have realised NOx reductions below the AEL limit Sustaining consistently low emissions below the standard is challenged by varying coal quality and other operational issues Piloting of Low NOx burners on boiler 12 is progressing with an expected start-up date of May 2018 AAEL limit

~86% of total incinerated waste volume from Secunda. We have prioritised investigations for our incinerators in Sasolburg and Secunda in accordance with the waste hierarchy In order to find the most environmentally sustainable solutions, reducing the need for incineration as far as possible, we are investigating promising options which require sufficient time to develop and test ~86% of total incinerated waste volume from Secunda.

We have a capital allocation framework to assist us in allocating capital and prioritising capital allocation towards the retention of Sasol’s license to operate We have invested more than R25 billion on capital projects, over the past twelve years, to minimise our environmental footprint

Volatile Organic Compound (VOC) abatement technologies installed on our Secunda Site Regenerative Thermal Oxidisers (RTOs) Regenerative Thermal Oxidisers (RTOs) Regenerative Thermal Oxidisers (RTOs) Vapour Recovery Unit (VRU)

Our AELs contain appropriate limits, informed by independent air quality specialist studies, under which we are required to operate in the extended compliance period

CURRENT STATE OF AMBIENT AIR QUALITY – SO2 (2013-2015) Ambient SO2 levels in the Secunda region are within the National Ambient Air Quality Standards (NAAQS) SO2 Within NAAQS Exceed NAAQS SO2 2013-2015 13

CURRENT STATE OF AMBIENT AIR QUALITY – NO2 (2013-2015) Ambient NO2 levels in the Secunda region are within the NAAQS Within NAAQS Exceed NAAQS NO2 NO2 2013-2015 14

CURRENT STATE OF AMBIENT AIR QUALITY – PM10 (2013-2015) Ambient PM10 levels in the Secunda region exceed the NAAQS Within NAAQS Exceed NAAQS PM10 PM10 2013-2015

PM10 emissions for 2016 measured at the accredited Sasol Secunda ambient monitoring stations Yearly average at eMbalenhle station exceeds NAAQS

CURRENT STATE OF AMBIENT AIR QUALITY – PM2.5 (2013-2015) Ambient PM2.5 levels in the Secunda region exceed the NAAQS, except in the town of Secunda Within NAAQS Exceed NAAQS PM2.5 PM2.5 2013-2015

PM2.5 emissions for 2016 measured at the accredited Sasol Secunda ambient monitoring stations Yearly average within the NAAQS

PM levels in the vicinity of our plant exceeds the NAAQS Sasol’s simulated contribution between 2 - 3% of actual ambient concentrations Even if the Sasol plant were to be decommissioned, ambient PM levels in the vicinity of our plant would still exceed the NAAQS, therefore offsets provide a complimentary lever to improve ambient air quality

New plant standards for boiler plant SO2 pose significant compliance challenges from a feasibility perspective for existing, maturing plants

Flue gas desulphurisation technologies for boiler SO2 abatement are complex with unintended consequences Formally recognising air emission offsets may represent a sustainable mechanism to improve ambient air quality with the potential to deliver other concurrent environmental and socioeconomic benefits Reduced SO2 emissions - More Water + Reduced co-dispersion of other offgases - More Internal Power consumption - Increased CO2 emissions - Additional Lime or Limestone - Net reduction in power output - Very high investment cost to retrofit complex abatement technology $ Steam & Power Plant New waste stream -

Implementing abatement technologies to meet SO2 new plant standards challenging Space restrictions, construction on a live brownfield site presents challenges

Sasol Secunda SO2 sources do not cause exceedance of NAAQS Boilers: 3,500 mg/Nm3 Boilers: 500 mg/Nm3 Boilers: 2,000 mg/Nm3

We continue to constructively engage in law reform processes and in this regard have recently submitted comments into the DEA’s framework review consultations

Our key comments made on the Framework review Recognising that law reform can address existing challenges, we commented on the following, consistent with Section 5.4.3.3 of the National Air Quality Framework which provides for phase-in and transitional arrangements that distinguish between existing and new plants: Reasonable accommodation of existing and maturing facilities that, for justifiable reasons, cannot meet the same standards as set for new plants, and are not causing significant detriment to ambient air quality. This applies both to existing plants in meeting the current set of new plant standards, and also, looking forward, to current existing and new plants transitioning to any new requirements included in the standards, post 2020

Regulation of industrial point sources alone, in our view, is insufficient to achieve the NAAQS. Offsets are therefore an important complementary mechanism in achieving the statutory objectives

Preliminary source apportionment results indicate that non-industrial sources contribute significantly to ambient air quality Our offset plan for Zamdela initially targets waste burning Zamdela Winter 2016 Coarse Fraction (PM10) Winter 2016 Fine Fraction (PM2.5)

Preliminary source apportionment results indicate that non-industrial sources contribute significantly to ambient air quality Our approved offset plan for eMbalenhle initially targets domestic solid fuel burning eMbalenhle Winter 2016 Coarse Fraction (PM10) Winter 2016 Fine Fraction (PM2.5)

We are on track to delivering on our approved offset plans Insulation of RDP homes Testing of innovative solutions for the insulation of serviced informal dwellings Veld fire management Education and Awareness Initiatives in Secunda focused on reducing domestic solid fuel burning 2016 2017 2018 2019 2020 Baseline (eMbalenhle) (Lebohang) Lebohang , eMbalenhle (Feasibility for Roads) PM (Informal housing insulation) PM, SOx NOx eMbalenhle (Veld fire management) Lebohang, eMbalenhle (Insulation of RDP) PM, SOx , NOx, CO Education and Awareness (Lebohang, eMbalenhle) AQ PM NOx JAN - MAR APR JUN JUL SEP OCT DEC ⦿ Measurement Survey ⦿ Data Collection and Analyses ⦿ Preliminary Results ⦿ Integration of total results ⦿ Final Baseline reports ⦿ Ongoing monitoring ⦿ Ongoing monitoring ⦿ Ongoing monitoring ⦿ Household surveys ⦿ Detailed monitoring ⦿ Final baseline reports ⦿ Ongoing monitoring ⦿ Ongoing monitoring ⦿ literature reviews – kick off of prefeasibility work ⦿ Lab testing of material ⦿ Feasibility study of proposed road design ⦿ Feasibility study concluded not feasible. Awaiting results of source apportionment study to facilitate decision to consider any further work on road surfacing ⦿ Literature reviews kick off of prefeasibility work ⦿ Lab fire testing (highlighted fire risks) ⦿ Testing new fire protection barriers (SNS accreditation) ⦿ Polycrete foam test ⦿ Insulation: pilot on 30 serviced shacks & stove swap test Lebohang ⦿ Measure impact (assess effectiveness & durability of insulation. (Thermal and solid fuel monitoring) ⦿ Approx. 700 - 900 homes per year in total (if pilot is successful) ⦿ Approx. 700 - 900 homes ROLL-OUT ⦿ Veld fire management programme expanded and enhanced for air quality impacts ⦿ Cutting grass and fire breaks ⦿ Cutting grass and fire breaks ⦿ Cutting grass and fire breaks ⦿ Cutting grass and fire breaks AD HOC SUPPORT IN VELD FIRE MANAGEMENT AT REQUEST OF GMM EMERGENCY RESPONSE ⦿ Establish Project Management unit for Procurement & community member training ⦿ Sasol Enterprise Development activities -SMMEs ⦿ Start Insulation of RDP houses in eMbalenhle (1st year: approx. 500 - 700 homes) ⦿ Insulation ramp-up (2nd year: approx. 1900 - 2100 homes) ⦿ Insulation ramp-up (3rd year: approx. 2600 - 2800 homes) CONTINUE ROLL-OUT ⦿ Develop awareness programme for AQ campaign ⦿ Roll out awareness raising campaign ⦿ Measure Effectiveness ON-GOING COMMUNITY EDUCATION AND AWARENESS

We are on track to delivering on our approved offset plans Initiatives in Sasolburg and Natref focused on reducing waste burning Veld fire management Domestic waste management Removal of recyclable waste Education and Awareness 2016 2017 2018 2019 2020 Baseline (eMbalenhle / Zamdela) Education and Awareness (Lebohang, eMbalenhle ,Zamdela) AQ PM NOx Zamdela I (Vehicle emissions) Zamdela II (Veld fire management) PM + TOXINS Zamdela III (Removal of recyclable waste) Zamdela IV Domestic Waste Management) JAN - MAR APR JUN JUL SEP OCT DEC ⦿ Measurement Survey ⦿ Data Collection and Analyses ⦿ Preliminary Results ⦿ Integration of total results ⦿ Final Baseline reports ⦿ Ongoing monitoring ⦿ Ongoing monitoring ⦿ Ongoing monitoring ⦿ Develop awareness programme for AQ campaign ⦿ Roll out awareness raising campaign ⦿ Measure Effectiveness ON-GOING COMMUNITY EDUCATION AND AWARENESS ⦿ Aug 16 - Vehicle emission tests Natref ⦿ Oct 16 Identification & screening of Service providers ⦿ Mar 17 Training of Municipal staff establish testing facility ⦿ Apr 17 Roll out of emission testing (municipality) ON-GOING MONITORING & SUPPORT ⦿ Nov 16 Grass cutting (Fire Prevention) ⦿ Mar 17 Finalisation of business model ⦿ Implement business model & purchase equipment to cut grass before winter ON-GOING MONITORING & SUPPORT ⦿ May – July 16 Engagement with waste pickers Mar – Oct 16 Satellite locations + buyback center (acquire and rezone) ⦿ Mar 17 Rezoning of sites 8 locations 1 buy back center ⦿ Apr 17 Commence roll-out ON-GOING MONITORING & SUPPORT ⦿ Feb – July 16 Consultation with local government + community behaviour assessment ⦿ Nov 16 Piloting of possible Solution (skips + topple trucks) ⦿ Jan 17 Procurement & Community education ⦿ May 17 Rollout Amelia + Iraq, municipal site unlawful, waste site / landfill site. Assist + arrange move to new site) ON-GOING MONITORING & SUPPORT

Insulation of serviced informal houses in Lebohang Ceiling Installation Preparation for Plastering Painting

In conclusion Sasol is committed to compliance with all applicable laws including air quality laws. This supports sustainable air quality improvements as envisaged through the Air Quality Act and priority area air quality management plans We are making good progress against our air quality roadmaps as committed in our postponement applications To support these roadmaps, we have a capital allocation framework to assist us in allocating capital, prioritising capital allocation towards the retention of Sasol’s license to operate We already meet most of the Minimum Emissions Standards (MES) for existing plants, and will also be able to meet most of the new plant standards by latest 2025. This extended timeframe is required to safely implement the necessary abatement technologies in accordance with our roadmap schedules, taking into consideration shutdown and statutory maintenance obligations In this regard, in the past we applied for, and going forward, we will be reliant on further applications for postponements, as the only legal mechanism currently provided for in law. Consequently, our licences, under which we are required to operate during the extended compliance period, contain appropriate limits informed by independent air quality specialist studies on the basis that these do not affect ambient air quality beyond National Ambient Air Quality Standards (NAAQS) However, the new plant standards for boiler plant SO2 pose significant compliance challenges from a feasibility perspective for existing, maturing plants. The measured levels of SO2 in the airsheds where we operate are well below the internationally accepted health standard. Our appeal therefore is to consider alternative mechanisms to enable progressive air quality improvements for maturing facilities. To this extent, we continue to constructively engage in law reform processes and in this regard have recently submitted comments into the DEA’s framework review consultations\. We believe it is appropriate for the applicable authorities to consider our postponement applications, since we meet the conditions of such applications and in particular demonstrate that our current and proposed contribution does not cause exceedance of the (NAAQS) Regulation of industrial point sources alone, in our view, is insufficient to achieve the NAAQS. Offsets are therefore an important complementary mechanism in achieving the statutory objectives