Issues and Response Report Version 1
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\ Company Registration no: 2018/217803/07 Issues and Response Report Version 1 Verification of the status of 20 farmsApplication for Suspension of the New Plant Limit and regarding ComplianceProspecting timeframe / Minings of Rights the Minimum located Emission in the ProvincesStandards (MES) for Eskom’sof Limpopo Grootvlei and Power North Station, West Mpumala nga Highveld Annexure 9 to the Public Participation Report (Standalone Document to PP Report) PREPARED BY: Naledzi Environmental Consultants Pty Ltd (NEC) Postnet Suite # 320, Private Bag X 9307, Polokwane, 0700 Prepared for: 160 Marshall Street, Polokwane, 0699 Tel: 015 296 3988 Eskom Holdings SOC Limited Fax: 015 296 4021 Air Quality Centre of Excellence, Email: [email protected] Environmental Management Maxwell Drive, Sunninghill, Sandton 2157 20 March 2020 i PROJECT INFORMATION Title: Application for Suspension of New Plant Limits for NOx and SO2 in terms of the MES for Eskom’s Grootvlei Power Station in the Mpumalanga Highveld Region Author: Marissa Botha Status of Report: Issues and Response Report Version 1 First Issue: March 2020 Applicant for Suspension Eskom Holdings SOC Ltd request: Independent Environmental Naledzi Environmental Consultants (Pty) Ltd (NEC) Assessment Practitioner: This Issues and Response Report has been prepared by Naledzi Environmental Consultants (Pty) Ltd in support of Eskom’s Application for Suspension of the new plant limit compliance timeframe for Nitrogen Oxide (NOx) and Sulphur Dioxide (SO2) in terms of the MES for Eskom’s Grootvlei power station located in the Mpumalanga Highveld. NALEDZI ENVIRONMENTAL CONSULTANTS (PTY) LTD: Approved for Naledzi Environmental Consultants (Pty) Ltd ………………………………………………………. Environmental Assessment Practitioner Marissa Botha, Pr.Sci.Nat ESKOM HOLDINGS LIMITED: Air Quality Centre of Excellence, Environmental Management Approved for Eskom Holdings Limited by: _____________________________ Eskom Environmental Manager Deidre Herbst Issues and Response Report – Version 1 Application for Suspension of the new plant emission limits of the MES for Eskom’s Grootvlei power station Naledzi Environmental Consultants (Pty) Ltd ii INTRODUCTION This Issues and Response Report (IRR) includes all the issues and comments recorded for Grootvlei power station during the first round of public engagements for the 2018 Eskom MES application process, and have been pulled into this separate IRR in support of Grootvlei’s application for the current once-off suspension of the new plant limits and compliance timeframes for NOx and SO2 in terms of the MES. The comments were recorded during engagements with provincial and district licensing authorities on 30 July 2018, the local authority and during the public registration period on the Background Information Document (BID) for the 2018 Eskom MES application process which was available for public review and comment from 13 August to 11 September 2018 including three public engagements on 21 August 2018. The three public engagements included: 21 August 2018 at Balfour Council Chambers at 09:00 – 10:00; 21 August 2018 at Balfour Siyathemba Community Hall from 11:00 – 13:00; and 21 August 2018 at Thabagoadi Community Hall at Grootvlei from 15:00 – 17:00; The IRR thus provides a summary of the issues received during these public engagements and offers a response to the issues raised. In some cases the responses have been updated from previous responses given more information is available and due to changes in planning approaches. Some parties submitted extensive comments on all the 2018 postponement applications, these issues and responses have not been included in this document but are viewable in the 2019 IRR final report. As indicated, the public is consulted in two phases during the application process thus the IRR consists of versions. These versions include: . Version 1 – IRR appended to the draft application documentation . Version 2 – IRR appended to the finalised application documentation which is submitted to National Air Quality Officer for decision making. Version 1 of the IRR is appended to the draft Application documentation made available for public review and comment for a period of 30 calendar days. The public review period will be from Wednesday, 1 July until 30 July 2020 and will be announced through a newspaper advertisement in the Beeld, Daily Sun and Heidelberg-Nigel Heraut. An emailed notification confirming the public review period will also be sent to all registered interested and affected parties on the project database. The IRR will be updated upon the lapse of the public review period and any public comment submitted during this review period either written, verbal or through teleconferences or virtual meetings will be included in the IRR and submitted to the National Air Quality Officer (NAQO) as part of the application documentation. I&APs will be notified of the submission of the final application documentation to the NAQO and have access to final application documents on the Naledzi website: www.naledzi.co.za/publicdocuments. The documents will include Eskom’s motivation for the application, a Variation Request, Atmospheric Impact Report, Public Participation Report and the updated IRR Version 2. This will enable I&APs to confirm whether their comments have been recorded correctly and responded to. Issues and Response Report – Version 1 Application for Suspension of the new plant emission limits of the MES for Eskom’s Grootvlei power station Naledzi Environmental Consultants (Pty) Ltd iii Contents 1. APPLICATION PROCESS ............................................................................................................ 1 2. MOTIVATION / JUSTIFICATION FOR POSTPONEMENT APPLICATION ........................... 2 3. PUBLIC PARTICIPATION PROCESS (PPP) ............................................................................... 3 4. REASON FOR DELAY IN MEETING THE MES AND POSTPONED TIMEFRAMES ........... 5 5. POWER STATION OPERATIONS, DESIGN, RETROFITS, TECHNOLOGY TYPES AND EMISSION REDUCTION PLAN .................................................................................................. 6 6. HEALTH IMPLICATIONS / HUMAN HEALTH RISK ANALYSIS .......................................... 6 7. COMPLIANCE AND COMMISSIONING .................................................................................... 9 8. ECONOMICS / COMPLIANCE COSTS / SOCIAL INVESTMENT BY ESKOM ................... 10 9. ALTERNATIVE TECHNOLOGY / RENEWABLE ENERGY .................................................. 12 10. DECOMMISSINING OF POWER STATIONS AND DECOMMISSIONING SCHEDULE .... 14 11. EMISSIONS / FUGITIVE EMISSIONS ...................................................................................... 15 LIST OF TABLES Table 1: List of comments raised and responses recorded for Grootvlei power station during the first round of public engagements for the 2018 Eskom MES postponement application process........................................................................................................................................ 1 Issues and Response Report – Version 1 Application for Suspension of the new plant emission limits of the MES for Eskom’s Grootvlei power station Naledzi Environmental Consultants (Pty) Ltd iv LIST OF ACRONYMS MES Minimum Emission Standards NEM: AQA National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004) AQA Air Quality Act NAAQS National Ambient Air Quality Standards NEMA National Environmental Management Act, 1998 (Act 107 of 1998) EIA Environmental Impact Assessment Regulations PM Particulate Matter PM10 Particulate Matter 10 micrometers or less in diameter SO2 Sulphur Dioxide NOx Oxides of nitrogen mg/Nm3 Milligrams per cubic metre air` AEL Atmospheric Emission License AIA Atmospheric Impact Assessment AIR Atmospheric Impact Report PPP Public Participation Process PP Report Public Participation Process Report BID Background Information Document IRR Issues and Response Report IRP Integrated Resource Plan I&AP Interested and Affected Party NAQO National Air Quality Officer NEC Naledzi Environmental Consultants (Pty) Ltd Eskom Eskom Holding SOC Ltd HPA ITT Highveld Priority Area Information Task Team VTAPA ITT Vaal Triangle Airshed Priority Area Information Task Team FFP Fabric Filter Plant CBA Cost Benefit Analysis HRA Health Risk Analysis NDM Nkangala District Municipality HPA ITT Highveld Priority Area Information Task Team VTAPA ITT Vaal Triangle Airshed Priority Area Information Task Team LAC Life After Coal Campaign CER Centre of Environmental Rights gW Groundwork ELA Earthlife Africa Johannesburg HEJN Highveld Environmental Justice Alliance Network VEJA Vaal Environmental Justice Alliance AIDC Alternative Information Development Centre SA South Africa FFP Fabric Filter Plant LNB Low Nox Burner JET Just Energy Transition Issues and Response Report – Version 1 Application for Suspension of the new plant emission limits of the MES for Eskom’s Grootvlei power station Naledzi Environmental Consultants (Pty) Ltd v Table 1: List of comments raised and responses recorded for Grootvlei power station during the first round of public engagements for the 2018 Eskom MES postponement application process NO ISSUE RAISED BY WHOM AND RESPONSE GIVEN BY PROJECT TEAM WHEN 1. APPLICATION PROCESS 1.1 Will Eskom encounter complications if it Community Eskom as a responsible company aims to comply with its AEL. Yes Eskom will does not apply for postponement? Member encounter complications in that it would require a higher tariff