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

2. 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

3. 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 (amendments to the 31 March 2010 gazette)

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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