Atmospheric Impact Report Increased Capacity of the North Flare

SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) ATMOSPHERIC IMPACT REPORT INCREASED CAPACITY OF THE NORTH FLARE

15 JANUARY 2021

ATMOSPHERIC IMPACT REPORT INCREASED CAPACITY OF THE NORTH FLARE

SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

PROJECT NO.: 41102753 DATE: JANUARY 2021

WSP FLOOR 1, PHAROS HOUSE BUCKINGHAM TERRACE WESTVILLE, DURBAN, 3629 SOUTH AFRICA

T +27 31 240 8800 WSP.COM

QUALITY MANAGEMENT

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft AIR

Date 15/01/2021

Prepared by L. Ramsay

Signature

Checked by L. Dyer

Signature

Authorised by L. Ramsay

Signature

Project number 41102753

Report number 1

File reference G:\000 NEW Projects\41102753 - SAPREF North Flare\41 AQ\2-REPORTS

WSP is an ISO9001:2015, ISO14001:2015 and OHSAS18001:2007 certified company

EXECUTIVE SUMMARY

South African Petroleum Refineries (SAPREF), a joint venture between Shell SA Refining and BP Southern Africa, is the largest crude oil refinery in Southern Africa with 35% of South Africa’s refining capacity. SAPREF currently balances any flaring that may be required (i.e. during emergency depressuring, shutdown and start-up situations) between their North and South Flares. With the relief created by the recent hydrogen desulphurisation unit upgrade (HDS4), the North Flare can operate without exceeding the design capacity. However, should the balancing line between the North and South Flares not be available in the future, the North Flare will have insufficient capacity to handle the full load. As such, SAPREF propose to upgrade the North Flare to sufficiently manage such a scenario. To remain within American Petroleum Institute (API) standards, this will require a height increase of 17 m for the North Flare stack. An Atmospheric Emissions License (AEL) amendment is required to reflect the increased flare capacity and increased stack height, requiring an Atmospheric Impact Report (AIR) in support of this application. Atmospheric pollutants of concern associated with SAPREF’s site activities include particulate matter (PM) with a diameter less than 10 microns (PM10), sulphur dioxide (SO2), nitrogen dioxide (NO2) and volatile organic compounds (VOCs). To assess the ambient air quality impacts, a Level 3 air pollution dispersion modelling approach was conducted. The following scenarios were assessed for comparison with the National Ambient Air Quality Standards (NAAQS) as applicable: 1 Worst case scenario: Emergency depressuring of HDS4 (baseline, flare balancing); 2 Worst case scenario: Emergency depressuring of HDS4 (proposed, no flare balancing) 3 Planned shutdown (baseline, based on 2020 shutdown data, flare balancing); and 4 Planned shutddown (proposed, based on 2020 shutdown data but adjusted for no flare balancing). Findings of this assessment can be summarised as follows 1 The emergency depressuring of HDS4 is an upset condition resulting in a worst-case emission scenario from the North Flare. a Even when combining this worst-case emission scenario with the worst-case meteorological scenario, the ambient contributions from the North Flare do not result in exceedances of any pollutants at any sensitive receptors, except for 1-hour average SO2 at Wentworth (baseline) and Ganges and Umlazi (proposed). b The depressuring curves show that the emission event peaks within 15 minutes. The likelihood of an HDS4 depressuring event coinciding with the worst-case meteorological hour across the record for a specific receptor is <0.004%. 2 A planned shutdown occurs annually at the facility. A cumulative (facility-wide) emission scenario was assessed, combining flare emission calculations with emissions from the other on-site emission sources during a previous planned shutdown. Ambient impacts were assessed under a worst meteorological scenario across the modelling domain (i.e. Rank 1 concentrations). a Baseline and proposed receptor concentrations were predicted to be compliant with the PM10 and NO2 NAAQS. There is no significant change in Rank 1 ambient PM10, NO2 or TVOC under the proposed scenario. b The Rank 1 domain peak hourly NO2 under the baseline and proposed scenarios exceeds the 1-hour NO2 th NAAQS. This occurs in the vicinity of the railway. When assessing the 99 percentile (P99) 1-hour NO2 concentrations, full compliance occurs across the model domain. c Rank 1 24-hour and 1-hour SO2 concentrations are predicted to decrease under the proposed scenario at all receptors, except Rank 1 24-hour averages at Prospecton (increases by 2.15% but remains under the NAAQS) and Umlazi (increases by 1.11%). d While Rank 1 simulations show a significant region of exceedance of the SO2 NAAQS under the baseline and proposed cumulative (facility-wide) scenarios, an assessment of the P99 24-hour SO2 concentrations reveals compliance at all receptors except Isipingo Beach. A number of receptors (Settlers, Merewent, Prospecton, Isipingo and Umlazi) fall within NAAQS compliance when assessing the P99 1-hour SO2 values. e The likelihood that the worst-case meteorological conditions would coincide with the day of shutdown at a specific point is 1 in 365 (<0.27%).

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

3 A cumulative assessment combining ambient monitoring data with the model simulations was attempted. a Due to significant gaps in the monitoring data, there are no cumulative results for PM10, NO2 or TVOC. b Data was available in the Ganges monitoring record to assess cumulative concentrations at the time of the Rank 1 24-hour and Rank 1 1-hour SO2 simulations. The cumulative concentrations exceed the NAAQS under both scenarios. The conservatism in assessing the incidence of a planned shutdown during worst-case meteorological conditions is highlighted. These results offer a worst-case scenario. Importantly, the cumulative Rank 1 24-hour and 1-hour SO2 concentrations at Ganges decrease under the proposed scenario. 4 Long term average scenarios could not be simulated, as this would require knowledge of the exact timing of the flaring event/s in the meteorological record. a However, there is no expected increase in flaring associated with the North Flare project, nor is it expected that there will be an increased quantity of gas flared across the facility. The proposed project will limit the requirements for flare balancing but not adjust the quantity of gas flared annually. b As shown in the comparison of the results of Scenario 3 (planned shutdown baseline) and Scenario 4 (planned shutdown proposed), if the amount of flaring remains the same, one would expect a decrease in long term SO2 averages over most of the model domain due to the increased height of the North Flare stack.

In conclusion, this study shows the potential for short-term SO2 exceedances at sensitive receptors during flaring incidents at SAPREF. However, these occur when combining a conservative emission scenario with worst- case meteorological conditions. It is more likely than not that a planned shutdown will occur during meteorological conditions that promote effective dispersion and will not result in ambient exceedances at sensitive receptors. Importantly, the proposed increased height of the North Flare stack decreases the likelihood of exceedances at sensitive receptors, due to increased dispersion of emissions before reaching ground level.

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

TABLE OF 1 INTRODUCTION 1 CONTENTS 1.1 Enterprise Details ...... 1 2 REGULATORY FRAMEWORK 3 2.1 Minimum Emission Standards ...... 3 2.2 National Ambient Air Quality Standards ...... 6 2.3 Regulated Air Pollutants and Their Impacts ...... 7

3 NATURE OF THE PROCESS 9 3.1 Process Description ...... 9 3.2 Unit Processes ...... 10 3.3 Raw Materials and Products ...... 10 3.4 Atmospheric Emissions ...... 12

4 GEOGRAPHIC OVERVIEW 20 4.1 Location and Extent ...... 20 4.2 Meteorology ...... 21 4.3 Ambient Air Quality ...... 26

5 DISPERSION MODELLING 34 5.1 Assessment Level and Proposed Model ...... 34 5.2 Model Inputs ...... 34 5.3 Model Scenarios ...... 36 5.4 Model Outputs ...... 36

6 EMISSIONS INVENTORY 38 6.1 Flare Energy Calculations ...... 38 6.2 Flare Emission Calculations ...... 39 6.3 Scenarios 1 and 2: Emergency HDS4 Depressuring .... 39 6.4 Scenarios 3 and 4: Planned shutdown ...... 41

7 RESULTS 48 7.1 Scenarios 1 and 2: Emergency HDS4 Depressuring .... 48 7.2 Scenarios 3 and 4: Planned Shutdown ...... 52 7.3 Cumulative Assessment ...... 57 7.4 Long-term Averages ...... 57

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

8 ASSUMPTIONS AND LIMITATIONS 59

9 SUMMARY AND CONCLUSION 60

10 FORMAL DECLARATIONS 61 10.1 Declaration of accuracy of information ...... 61 10.2 Declaration of independence ...... 62

APPENDICES A CONCENTRATION ISOPLETHS

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

TABLES Table 1-1: Enterprise details ...... 2 Table 1-2: Contact details ...... 2 Table 2-1: Minimum Emission Standards for Subcategory 2.1 - Combustion installations ...... 4 Table 2-2: Minimum Emission Standards for Subcategory 2.2 - Catalytic Cracking Units ...... 4 Table 2-3: Minimum Emission Standards for Subcategory 2.3 - Sulphur Recovery Units ...... 4 Table 2-4: Minimum emission standards for Subcategory 2.4 - Storage and handling of petroleum products ...... 5 Table 2-5: South African National Ambient Air Quality Standards ...... 6 Table 2-6: Air pollutants of concern and associated human health impacts ...... 7 Table 3-1: Unit processes at SAPREF ...... 10 Table 3-2: Raw material consumption ...... 10 Table 3-3: Production capacity ...... 11 Table 3-4: By-product capacity ...... 11 Table 3-5: Energy sources ...... 11 Table 3-6: Stack parameters (from AEL) ...... 12 Table 3-7: Maximum permitted emission rates (normal operating conditions) ...... 13 Table 3-8: Start-up, shutdown, upset and maintenance conditions ...... 16 Table 3-9: Abatement appliances ...... 17 Table 3-10: Area/line-source parameters (AEL) ...... 18 Table 4-1: Plant location details...... 20 Table 4-2: Details of meteorological stations and dataset recovery ...... 22 Table 4-3: Station information, data recovery and results summary for the period January 2017 – December 2019 ...... 26

Table 4-4: Measured ambient PM10 for 2017, 2018 and 2019 .. 27

Table 4-5: Measured ambient NO2 for 2017, 2018 and 2019 ... 29

Table 4-6: Measured ambient SO2 for 2017, 2018 and 2019 ... 30 Table 5-1: Discrete receptor locations ...... 35

Table 6-1: H2S flare gas constituents ...... 38 Table 6-2: Hydrocarbon flare gas constituents ...... 38 Table 6-3: Baseline HDS4 depressuring (15 minutes) ...... 39 Table 6-4: Proposed HDS4 depressuring (15 minutes) ...... 40

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

Table 6-5: North Flare stack parameters ...... 41 Table 6-6: Scenario 1 and 2 emissions - North flare ...... 41 Table 6-7: Scenarios 3 and 4: Stack parameters...... 42 Table 6-8: Scenario 3 and 4 emissions - planned shutdown .... 43 Table 6-9: Storage tank area dimensions and emission rates .. 45 Table 6-10: Reuse dam and effluent dam parameters and emission rates ...... 46 Table 6-11: Bitumen loading parameters and emission rates ..... 46 Table 6-12: Diesel locomotive parameters and emission rates .. 46 Table 6-13: Emission factors for vehicle exhaust ...... 47 Table 6-14: Emission factors for vehicle tyre, brake and road surface wear ...... 47 Table 6-15: Vehicular traffic emissions ...... 47 Table 6-16: Fugitive leak emission rates ...... 47 Table 7-1: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 PM10 concentrations predicted at discrete receptors ...... 50 Table 7-2: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 NO2 concentrations predicted at discrete receptors ...... 50 Table 7-3: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 SO2 concentrations predicted at discrete receptors ...... 51 Table 7-4: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 TVOC concentrations predicted at discrete receptors ...... 51 Table 7-5: Baseline and proposed planned shutdown - Rank 1 PM10 concentrations predicted at discrete receptors 54 Table 7-6: Baseline and proposed planned shutdown - Rank 1 NO2 concentrations predicted at discrete receptors 54 Table 7-7: Baseline and proposed planned shutdown - Rank 1 SO2 concentrations predicted at discrete receptors. 55

Table 7-8: Baseline and proposed planned shutdown – P99 SO2 concentrations predicted at discrete receptors ...... 55 Table 7-9: Baseline and proposed planned shutdown - Rank 1 TVOC concentrations predicted at discrete receptors ...... 56

Table 7-10: Cumulative PM10 concentrations ...... 57

Table 7-11: Cumulative NO2 concentrations ...... 57 Table 7-12: Cumulative TVOC concentrations ...... 57

Table 7-13: Cumulative SO2 concentrations ...... 58

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

FIGURES Figure 4-1: Site location ...... 21 Figure 4-2: Nocturnal air circulations in Durban (Preston-Whyte and Diab, 1980) ...... 22 Figure 4-3: Location of the Merebank and Athlone Park meteorological stations ...... 23 Figure 4-4: Meteorological summary for Durban South, January 2017 – December 2019 ...... 24 Figure 4-5: Local wind conditions at South Durban ...... 25 Figure 4-6: Ambient air quality monitoring stations ...... 27

Figure 4-7: 24-hour PM10 concentrations measured at Wentworth ...... 28

Figure 4-8: 24-hour PM10 concentrations measured at Ganges 28

Figure 4-9: 24-hour PM10 concentrations measured at Settlers . 29

Figure 4-10: 1-hour NO2 concentrations measured at Ganges .... 30

Figure 4-11: 24-hour SO2 concentrations measured at Wentworth ...... 31

Figure 4-12: 1-hour SO2 concentrations measured at Wentworth 31

Figure 4-13: 24-hour SO2 concentrations measured at Ganges .. 32

Figure 4-14: 1-hour SO2 concentrations measured at Ganges .... 32

Figure 4-15: 24-hour SO2 concentrations measured at Settlers .. 33

Figure 4-16: 1-hour SO2 concentrations measured at Settlers .... 33 Figure 5-1: Sensitive receptors ...... 35 Figure 6-1: Location of area and line sources ...... 44 Figure A-1: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour PM10 concentrations ...... 64 Figure A-2: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour PM10 concentrations ...... 65 Figure A-3: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 1-hour NO2 concentrations ...... 66 Figure A-4: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 1-hour NO2 concentrations . 67 Figure A-5: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour SO2 concentrations ...... 68 Figure A-6: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour SO2 concentrations 69 Figure A-7: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 1-hour SO2 concentrations ...... 70 Figure A-8: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 1-hour SO2 concentrations . 71

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

Figure A-9: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour TVOC concentrations ...... 72 Figure A-10: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour TVOC concentrations ...... 73 Figure A-11: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour PM10 concentrations ...... 74 Figure A-12: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 1- hour NO2 concentrations ...... 75 Figure A-13: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour SO2 concentrations ...... 76 Figure A-14: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 1- hour SO2 concentrations ...... 77 Figure A-15: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour TVOC concentrations ...... 78

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF)

1 INTRODUCTION

South African Petroleum Refineries (SAPREF), a joint venture between Shell SA Refining and BP Southern Africa, is the largest crude oil refinery in Southern Africa with 35% of South Africa’s refining capacity. SAPREF is located in South Durban on the east coast of South Africa. SAPREF currently balances any flaring that may be required (i.e. during emergency depressuring, shutdown and start-up situations) between their North and South Flares. With the relief created by the recent Hydrogen Desulphurisation unit upgrade (HDS4), the North Flare is now able to operate without exceeding the design capacity. However, should the balancing line between the North and South flares not be available in the future, the North Flare will have insufficient capacity to handle the full load. As such, SAPREF propose to upgrade the North Flare to sufficiently manage such a scenario. In order to remain within American Petroleum Institute (API) standards1, this will require a height increase of 17 m for the North Flare stack. SAPREF’s processes trigger the following listed activities under Government Notice 893 of 20132, promulgated in line with Section 21 of the National Environmental Management: Air Quality Act 39 of 2004 (NEM:AQA)3: — Subcategory 2.1: Combustion Installations; — Subcategory 2.2: Catalytic Cracking Units; — Subcategory 2.3: Sulphur Recovery Units; and — Subcategory 2.4: Storage and Handling of Petroleum Products. An Atmospheric Emissions License (AEL) amendment is required to reflect the increased flare capacity and increased stack height, requiring an Atmospheric Impact Report (AIR) in support of this application. WSP Environmental (Pty) Ltd (WSP) were appointed to compile the AIR, assessing the ambient air quality impacts of the proposed North Flare upgrade.

1.1 ENTERPRISE DETAILS

The details of the SAPREF facility are provided in Table 1-1, with the details of the responsible contact persons presented in Table 1-2.

1 API is a leader in the development of petroleum and petrochemical equipment and operating standards covering a range of topics including environmental protection. These embrace proven, sound engineering and operating practices and safe, interchangeable equipment and materials. Many have been adopted by ISO as international best practice (URL: www.api.org). 2 Department of Environmental Affairs: (2013): List of Activities which result in Atmospheric Emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage (No. R. 893), Government Gazette, 22 November 2013, (No. 37054), as amended by GN 551 in 2015 and GN 1207 in 2018. 3 South Africa (2005): National Environmental Management: Air Quality Act (No. R. 39 of 2004) Government Gazette, 24 February 2005 (No. 27318)

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 1

Table 1-1: Enterprise details

Enterprise Name Shell and BP South African Petroleum Refineries (Pty) Ltd Trading as Shell and BP South African Petroleum Refineries (Pty) Ltd Type of Enterprise, e.g. Company/Close Company Corporation/Trust Company/Close Corporation/Trust Registration 1960000007/07 Number (Registration Numbers if Joint Venture) Registered Address 1 Refinery Road Prospection Durban 4110 Postal Address P.O. Box 26312, Isipingo Beach, 4115 Telephone Number (General) (031) 480 1911 Fax Number (General) (031) 480 1422 Industry Type/Nature of Trade Petroleum Refineries Land Use Zoning as per Town Planning Scheme Industrial Land Use Rights if outside Town Planning N/A Scheme

Table 1-2: Contact details

Responsible Person Victor Bester Emission Control Officer Melanie Francis Telephone Number (031) 480 1293 Cell Phone Number 082 556 1609 Fax Number (031) 468 1400 E-mail Address [email protected] After Hours Contact Details (031) 480 1221 / 080 033 0090

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2 REGULATORY FRAMEWORK

Until 2004, South Africa’s approach to air pollution control was driven by the Atmospheric Pollution Prevention Act 45 of 1965 (APPA) which was repealed with the promulgation of National Environmental Management: Air Quality Act 39 of 2004 (NEM:AQA)4. NEM:AQA represents a shift in South Africa’s approach to air quality management, from source-based control to integrated effects-based management. The objectives of NEM:AQA are to: — Protect the environment by providing reasonable measures for: . The protection and enhancement of air quality; . The prevention of air pollution and ecological degradation; . Securing ecologically sustainable development while promoting justifiable economic and social development; and . Give effect to everyone’s right “to an environment that is not harmful to their health and well-being”5 Significant functions detailed in NEM:AQA include: — The National Framework for Air Quality Management6; — Institutional planning matters, including: . The establishment of a National Air Quality Advisory Committee; . The appointment of Air Quality Officers (AQOs) at each level of government; and . The development, implementation and reporting of Air Quality Management Plans (AQMP) at national, provincial and municipal levels; — Air quality management measures including: . The declaration of Priority Areas where ambient air quality standards are being, or may be, exceeded; . The listing of activities that result in atmospheric emissions and which have the potential to impact negatively on the environment and the licensing thereof through an AEL; . The declaration of Controlled Emitters; . The declaration of Controlled Fuels; . Procedures to enforce Pollution Prevention Plans or Atmospheric Impact Reporting for the control and inventory of atmospheric pollutants of concern; and . Requirements for addressing dust and offensive odours.

2.1 MINIMUM EMISSION STANDARDS

The SAPREF AEL was renewed (AEL Reference: AEL003/S3) on 1 April 2017 and is valid until 31 March 2022. SAPREF’s processes trigger the following listed activities under Government Notice 893 of 20137 with associated Minimum Emission Standards (MES) presented in Table 2-1 to Table 2-4: — Subcategory 2.1: Combustion Installations; — Subcategory 2.2: Catalytic Cracking Units; — Subcategory 2.3: Sulphur Recovery Units; and — Subcategory 2.4: Storage and Handling of Petroleum Products.

4 South Africa (2005): National Environmental Management: Air Quality Act (No. R. 39 of 2004) Government Gazette, 24 February 2005 (No. 27318) 5 South Africa (1996): Constitution of the Republic of South Africa (No. 108 of 1996) 6 Department of Environmental Affairs (2018): The 2017 National Framework for Air Quality Management in the Republic of South Africa (No.R.1144 of 2018) Government Gazette, 26 October 2018 (No. 41996) 7 Department of Environmental Affairs: (2013): List of Activities which result in Atmospheric Emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage (No. R. 893), Government Gazette, 22 November 2013, (No. 37054), as amended by GN 551 in 2015 and GN 1207 in 2018.

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 3

Table 2-1: Minimum Emission Standards for Subcategory 2.1 - Combustion installations

Combustion installations not used primarily for steam raising or electricity generation (furnaces or Description heaters). Applications All refinery furnaces and heaters

Substance or mixture of substances mg/Nm3 under normal conditions of 10% Plant status Common name Chemical symbol O2, 273 Kelvin and 101.3 kPa New 70 Particulate matter N/A Existing 120 New 400 Oxides of nitrogen NOx expressed as NO2 Existing 1700 New 1000 Sulphur dioxide SO2 Existing 1700

The following special arrangements shall apply: (i) No continuous flaring of hydrogen sulphide-rich gases shall be allowed. (ii) A bubble cap of all Combustion Installations and Catalytic Cracking Units Shall be at 1.2 Kg SO2/ton for existing plants. (iii) A bubble cap of all Combustion Installations and Catalytic Cracking Units Shall be at 0.4 Kg SO2/ton for new plants.

Table 2-2: Minimum Emission Standards for Subcategory 2.2 - Catalytic Cracking Units

Description Refinery catalytic cracking units Applications All installations

Substance or mixture of substances mg/Nm3 under normal conditions of 10% Plant status Common name Chemical symbol O2, 273 Kelvin and 101.3 kPa New 100 Particulate matter N/A Existing 120 New 400 Oxides of nitrogen NOx expressed as NO2 Existing 550 New 1500 Sulphur dioxide SO2 Existing 3000

The following special arrangements shall apply:

(i) A bubble cap of all Combustion Installations and Catalytic Cracking Units Shall be at 1.2 Kg SO2/ton for existing plants. (ii) A bubble cap of all Combustion Installations and Catalytic Cracking Units Shall be at 0.4 Kg SO2/ton for new plants.

Table 2-3: Minimum Emission Standards for Subcategory 2.3 - Sulphur Recovery Units

Description Sulphur Recovery Units Applications All installations

Substance or mixture of substances mg/Nm3 under normal conditions of 10% Plant status Common name Chemical symbol O2, 273 Kelvin and 101.3 kPa New a Hydrogen Sulphide H2S Existing a

(a) The following special arrangements shall apply: Sulphur recovery units should achieve 95% recovery efficiency and availability of 99%.

ATMOSPHERIC IMPACT REPORT WSP Project No. 41102753 January 2021 SHELL AND BP SOUTH AFRICA PETROLEUM REFINERIES (SAPREF) Page 4

Table 2-4: Minimum emission standards for Subcategory 2.4 - Storage and handling of petroleum products

(A) The following transitional arrangement shall apply for the storage and handling of raw materials, intermediate and final products with a vapour pressure greater than 14kpa at operating temperature: — Leak Detection and Repair (LDAR) program approved by licensing authority to be instituted by 01 January 2014. (B) The following special arrangements shall apply for control of total volatile organic compounds (TVOCS) from storage or raw materials, intermediate and final products with a vapour pressure of up to 14kpa at operating temperature, except during loading and offloading. (alternative control measures that can achieve the same or better results may be used) – (i) Storage vessels for liquids shall be of the following type:

All permanent immobile liquid storage facilities at a Application single site with a combined storage capacity of greater than 1000 cubic meters. True vapour pressure of contents at product storage temperature Type of tank or vessel Fixed-roof tank vented to atmosphere, or as per type 2 and Type 1: Up to 14 kPa 3 Type 2: Above 14 kPa and up to 91 kPa with a throughput of less Fixed-roof tank Pressure Vacuum Vents fitted as a than 50 000 m3 per annum minimum, to prevent “breathing” losses, or as per type 3 a) External floating-roof tank with primary rim seal and secondary rim seal for tank with a diameter greater Type 3: Above 14kPa and up to 91 kPa with a throughput greater than 20m, or than 50 000 m3 per annum b) Fixed-roof tank with internal floating deck / roof fitted with primary seal, or c) Fixed-roof tank with vapour recovery system. Type 4: Above 91 kPa Pressure vessel (ii) The roof legs, slotted pipes and/or dipping well on floating roof tanks (except for domed floating roof tanks or internal floating roof tanks) shall have sleeves fitted to minimise emissions. (iii) Relief valves on pressurised storage should undergo periodic checks for internal leaks. This can be carried out using portable acoustic monitors or if venting to atmosphere with an accessible open end tested with a hydrocarbon analyser as part of an LDAR program. (C) The following special arrangements shall apply for control of total volatile organic compounds (TVOCs) from the loading and unloading (excluding ships) of raw materials, intermediate and final products with a vapour pressure of greater than 14kPa at handling temperature. Alternative control measures that can achieve the same or better results may be used: (i) All installations with a throughput of greater than 50 000m3 per annum of products with a vapour pressure greater than 14 kPa, must be fitted with vapour recovery / destruction units. Emission limits are set out in the table below -

Description Vapour recovery units

Applications All loading/offloading facilities with a throughput greater than 50 000 m3

Substance or mixture of substances Plant mg/Nm3 under normal conditions of 273 status Kelvin and 101.3 kPa Common name Chemical symbol

Total volatile organic compounds from New 150 vapour recovery / destruction units using N/A thermal treatment. Existing 150

Total volatile organic compounds from New 40 000 vapour recovery / destruction units using N/A non-thermal treatment. Existing 40 000

(ii) For road tanker and rail car loading / offloading facilities where the throughput is less than 50 000 m3 per annum, and where the ambient air quality is, or is likely to be impacted, all liquid products shall be loaded using bottom loading, or equivalent, with the venting pipe connected to a vapour balancing system. Where vapour balancing and / or bottom loading is not possible, a vapour recovery system utilizing adsorption, absorption, condensation or incineration of the remaining VOC’s, with a collection efficiency of at least 95%, shall be fitted.

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2.2 NATIONAL AMBIENT AIR QUALITY STANDARDS

Ambient air quality standards are defined as “targets for air quality management which establish the permissible concentration of a particular substance in, or property of, discharges to air, based on what a particular receiving environment can tolerate without significant deterioration”8. The aim of these standards is to provide a benchmark for air quality management and governance. South Africa’s National Ambient Air Quality Standards (NAAQS) are based primarily on guidance offered by two standards set by the South African National Standards (SANS): — SANS 69:2004 Framework for implementing National Ambient Air Quality Standards; and — SANS 1929:2005 Ambient air quality – Limits for common pollutants. SANS 69:2004 makes provision for the establishment of air quality objectives for the protection of human health and the environment as a whole. Such air quality objectives include limit values, alert thresholds and target values. SANS 1929:2005 uses the provisions in SANS 69:2004 to establish air quality objectives for the protection of human health and the environment, and stipulates that limit values are initially set to protect human health. The setting of such limit values represents the first step in a process to manage air quality and initiate a process to ultimately achieve acceptable air quality nationally. The NAAQS presented in Table 2-5 became applicable for air quality management from their promulgation in 20099 and 201210. The NAAQS generally have specific averaging periods, compliance timeframes, permissible frequencies of exceedance and measurement reference methods. Table 2-5: South African National Ambient Air Quality Standards Permissible Frequency Pollutant Averaging Period Concentration (µg/m3) of Exceedance 24 hours 75 4 Particulate Matter (PM10) 1 year 40 0 40 4 24 hour 25a 4 Particulate Matter (PM2.5) 20 0 1 year 15a 0

Benzene (C6H6) 1 year 5 0 10 minutes 500 526 1 hour 350 88 Sulphur Dioxide (SO2) 24 hours 125 4 1 year 50 0 1 hour 200 88 Nitrogen Dioxide (NO2) 1 year 40 0 1 hour 30000 88 Carbon Monoxide (CO) 8 hour 10000 11

Ozone (O3) 8 hour 120 11 Lead (Pb) 1 year 0.5 0 a: Effective date is 01 January 2030

8 Department of Environmental Affairs (2000): Integrated Pollution and Waste Management Policy for South Africa. Government Gazette (No. R 227 of 2000), 17 March 2000 (No. 20978) 9 Department of Environmental Affairs (2009): National Ambient Air Quality Standards. Government Gazette (No. R 1210 of 2009), 24 December 2009 (No. 32816) 10 Department of Environmental Affairs (2012): National Ambient Air Quality Standard for Particulate Matter with Aerodynamic Diameter less than 2.5 Micro Metres (PM2.5). Government Gazette (No. R 486 of 2012), 29 June 2012 (No. 35463)

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2.3 REGULATED AIR POLLUTANTS AND THEIR IMPACTS

The composition of air pollutant mixtures, pollutant concentrations, duration of exposure and other susceptibility factors (e.g. age, nutritional status and predisposing conditions) can lead to diverse impacts on human health. Health effects can range from nausea and skin irritation to cancer and mortality11 (Table 2-6). High risk individuals include the elderly, people with pre-existing heart or lung disease, pregnant women, asthmatics and children. Table 2-6: Air pollutants of concern and associated human health impacts

Pollutant Description Health effects

Sulphur SO2 originates from the combustion of sulphur-rich fuels (principally coal — Nose and throat 12 dioxide (SO2) and heavy oils) and the smelting of sulphur containing ores . Health irritation; — Bronchoconstriction and effects associated with exposure to SO2 are associated with the dyspnoea; and respiratory system13. — Reduced lung function in sensitive individuals. Nitrogen Nitric Oxide is a primary pollutant emitted from combustion processes — Nose and throat dioxide including stationary sources (e.g. heating, power generation, etc.) and irritation; Bronchoconstriction and (NO2) from motor vehicles. Nitrogen dioxide (NO2) is formed through the — dyspnoea; oxidation of nitric oxide. Oxidation of NO by O occurs rapidly, even at 3 — Asthma; low levels of reactants present in the atmosphere. NO contributes to the x — Bronchitis; formation of tropospheric ozone, an important atmospheric oxidant, a — Reduced lung function respiratory irritant and a greenhouse gas14. and tissue damage in sensitive individuals; — Emphysema; and — Premature death Ozone (O3) Ozone in the atmosphere is a secondary pollutant formed through a — Reduced lung function;

complex series of photochemical reactions between NO2 and VOCs in — Inflammation of the the presence of sunlight. Sources of these precursor pollutants include lungs; Pulmonary function motor vehicles and industries. Atmospheric background concentrations — decrements; are derived from both natural and anthropogenic sources. Natural — Asthma; and concentrations of O3 vary with altitude and seasonal variations (i.e. — Exacerbated pre-existing summer conditions favour O3 formation due to increased insolation). lung conditions Ozone is a powerful oxidant and can react with a wide range of cellular components and biological materials15.

Particulate Particles can be classified by their aerodynamic properties into coarse — Increase in lower matter particles, PM10 (particulate matter with an aerodynamic diameter of less respiratory symptoms; Reduced lung function; (PM10 & PM2.5) than 10 μm) and fine particles, PM2.5 (particulate matter with an — aerodynamic diameter of less than 2.5 μm)16. — Inflammation of the lungs; Particulate air pollution affects the respiratory system17. Particle size is — Angina; important for health because it controls how far into the respiratory — Myocardial infraction; system particles are able to permeate. Fine particles have been found to — Bronchitis; and be more damaging to human health than coarse particles as larger — Mortality particles are less respirable in that they do not pass from the lungs into the bloodstream18. Carbon CO is one of the most common and widely distributed air pollutants. CO — Headaches; monoxide (CO) is a tasteless, odourless and colourless gas which has a low solubility in — Nausea and vomiting; water. In the human body, after reaching the lungs it diffuses rapidly — Muscle weakness; across the alveolar and capillary membranes and binds reversibly with — Shortness of breath; haemoglobin, reducing the oxygen carrying capacity of the blood leading — Impaired cognitive ability;

11 Kampa, M. and Castanas, E. (2007): Human health effects of air pollution, Environmental Pollution 151 (2008) 362-367, Elsevier 12 Kampa, M. and Castanas, E. (2007): Human health effects of air pollution, Environmental Pollution 151 (2008) 362-367, Elsevier 13 Maroni, M., Seifert, B., Lindvall, T., (1995): Indoor air quality – a comprehensive reference book, Elsevier, Amsterdam. 14 World Health Organization (2000): Air Quality Guidelines for Europe (2nd edition), Copenhagen, Denmark. (WHO Regional Publications, European Series, No 91) 15 World Health Organization (2000): Air Quality Guidelines for Europe (2nd edition), Copenhagen, Denmark. (WHO Regional Publications, European Series, No 91) 16 Harrison, R.M. and R.E. van Grieken, (1998): Atmospheric Aerosols. John Wiley: Great Britain 17 World Health Organization (2000): Air Quality Guidelines for Europe (2nd edition), Copenhagen, Denmark. (WHO Regional Publications, European Series, No 91) 18 Manahan, E. (1991): Environmental Chemistry.

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Pollutant Description Health effects to hypoxia as vital organs (particularly the brain and heart) are starved of — Impaired coordination oxygen. High risk individuals include persons with pre-existing and reflex responses; cardiovascular diseases, pregnant women and infants19. — Haematological problems; Anthropogenic emissions of CO originate from the incomplete — Unconsciousness; and combustion of carbonaceous materials. The largest proportion of these — Mortality. emissions is produced from exhausts of internal combustion engines, in particular petrol vehicles. Other sources include industrial processes, coal power plants and waste incinerators. Ambient CO concentrations in urban areas depend on the density of vehicles and are influenced by topography and weather conditions20. Lead (Pb) Lead is a naturally occurring heavy metal that is found in the earth’s crust. — Muscle pain; Lead can be released into the atmosphere through volcanic eruptions, — Abdominal pain; sea spray and bushfires. Ore mining and metal processing are the largest — Headaches; Nausea and Vomiting; anthropogenic sources of lead emissions21. — — Seizures; Leaded petrol was once a significant source of lead in urban areas, — Coma; however, as a result of national legislation, lead has been phased out of — Learning disabilities; — Impaired coordination; petrol and significant reductions in airborne lead have been achieved. — Increased blood pressure; — Anaemia; — Neuropathies: — Memory disturbances; — Sleep disorders; — Anger; — Fatigue; — Tremors; — Blurred vision; — Miscarriage; and — Premature delivery or stillbirth. Benzene Benzene is a colourless liquid with an aromatic odour. Crude oil is the — Drowsiness;

(C6H6) largest natural source of benzene. Benzene is used in many products, — Dizziness; including plastics, synthetic rubber, glues, paints, furniture wax, — Headaches; Irritation of the eyes, skin lubricants, dyes, detergents, pesticides and some pharmaceuticals. — and respiratory tract; Benzene is emitted from motor engines, wood combustion and stationary — Visual disorders; fossil fuel combustion. The major source is exhaust emissions and — Fatigue; — Impaired coordination; evaporation losses from motor vehicles, and evaporation losses during Haematological 22 — the handling, distribution and storage of petrol . problems; — Adverse foetal development; — Cancer; and — Mortality Total Volatile TVOC refers to a class of several hundred carbon based chemical — Eye, nose and throat Organic compounds that easily vaporize from the solid or liquid phase into a gas. irritation; Compounds Some VOCs have little to no known human health effects while others — Headaches; Nausea; (TVOC) are extremely toxic and potentially carcinogenic. Little is known about — — Dizziness; how VOCs combine in the atmosphere or what the potential cumulative — Fatigue; impacts might be on the human body, making analysis, risk assessment — Dermal irritation; and guideline setting for these collective compounds exceptionally — Damage to the kidneys, difficult. liver and central nervous system; — Loss of coordination; — Cancer; and — Mortality.

19 Kampa, M., and Castanas, E. (2007): Human health effects of air pollution, Environmental Pollution 151 (2008) 362-367, Elsevier 20 Rudolf, W. (1994): Concentration of air pollutants inside cars driving on highways and in downtown areas. Science of the Total Environment, 146, pp 433-444. 21 The Australian Government (date unknown): Lead (www.environment.gov.au) 22 USEPA (2012): Health effects of Hazardous Air Pollutants – Benzene (www.epa.gov/airtoxics)

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3 NATURE OF THE PROCESS

3.1 PROCESS DESCRIPTION

SAPREF's core business activity is petroleum refining, i.e. processing crude oil into refined products. The process facilities are operated on a continuous basis, except for some batch operations for specialty products. The main process operations involved are: — Crude receipt, storage and handling; — Crude oil distillation; — Middle distillate conversion process; — Residue upgrading; — Component and product treatment; and — Product blending, storage and dispatch. Crude oil feed stocks are imported in large ships and discharged via the Single Buoy Mooring (SBM) located off Isipingo Beach. These feed stocks are stored in above ground tanks prior to processing in the refinery. Processes include crude distillation, thermal cracking, fluidized catalytic cracking, platformate production, hydrofluoric acid processing, hydrodesulphurisation, hydrotreatment, isomerisation and sulphur recovery. The Main Processes Crude Distiller physically separates (fractionates) the crude fractions with different boiling points, such as refinery gas, liquid petroleum gas (LPG), naphtha, kerosene, gas oil and long residue. The Thermal Cracker Unit (Visbreaker) is designed to process short residue or propane asphalt. Short residue is obtained from crude distillers. In addition, the unit is designed to split light cycle oil (LCO) from the catalytic cracking unit. Visbreaking (i.e. viscosity reduction or breaking) reduces the viscosity of residue substantially, thereby lessening the diluent requirements and the amount of fuel oil produced in a refinery. The Fluidized Catalytic Cracking Unit (FCCU) converts waxy distillate feed into lighter, saleable products (e.g. LPG and high-octane gasoline and distillate fuel), using a zeolite-based catalyst. The Platformer Unit changes the structure of stabilized hydro treated naphtha into stabilized high-octane product called platformate, used for blending, and hydrogen, used by the Hydrodesulphuriser (HDS), Hydrotreater (HDT) and isomerization units. It works by passing a mixture of hydrogen and naphtha vapor over the platinum catalyst at high temperature. The products are then cooled and separated. The Hydrofluoric Acid Process combines olefins (propylene, butylene, or pentene) with isobutane in the presence of the hydrofluoric acid catalyst to yield a product in the gasoline boiling range. Hydrocarbons, which are too light and too volatile to use in gasoline, are chemically combined to yield a gasoline-boiling range material called alkylate, with high octane number and no sulphur content. Alkylate produced on this unit is used in premium quality motor fuel blending. The sources of olefins that are processed in this unit are from the refinery cracking processes. The Hydrodesulphurisation (HDS) and Hydrotreating (HDT) units process hydrocarbons in the gasoline, kerosene or gasoil boiling ranges to produce desulphurised product. Desulphurization is achieved by passing the hydrocarbon over a catalyst in the presence of hydrogen at elevated temperature and pressure, the sulphur removed from the hydrocarbon stream is converted to hydrogen sulphide, which is routed via the acid gas removal processes to the Sulphur Recovery Processes (SRP). SAPREF has in total 6 HDS and 6 HDT units. The Isomerisation unit takes a feed of hydrocarbons in the light gasoline fraction, and in presence of hydrogen and a platinum catalyst at elevated temperatures, changes the structures of the hydrocarbon molecules to yield a product of significantly increased octane number, for use in gasoline blending. The SAPREF unit has a downstream splitter unit, which separates the isomerized material into three fractions; the lower octane fraction is recycled to the isomerization unit to achieve further octane improvement. The off-gases from the regenerators of the acid gas removal processes and from the sour water strippers are sent to two Sulphur Recovery Units (SRU), where sulphur is recovered and toxic gases such as ammonia are destroyed. The sulphur recovery efficiency of the two SRUs is about 95 - 97%. The two SRUs are lined to a Shell Claus Offgas Treatment (SCOT) unit. In the SCOT all the SO2 in the SRUs tail gas is reduced with hydrogen to

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hydrogen sulphide (H2S) and water in the presence of a catalyst. H2S is then recycled back to the SRU for more sulphur recovery. This offers more than 99.8% removal efficiency of the sulphur in the SRU feed. Other undesirable compounds in the SRU tail gas are carbon monoxide (CO) and carbon disulphide (CS2). These are converted in carbon dioxide (CO2), H2S and water (H2O). There are nine operational Lube Oil Units in the Lube Oil Plant that formulate a range of lubricant products. Finished products are dispatched from the refinery via road, rail and pipelines to the Island View Storage (IVS) depot.

3.2 UNIT PROCESSES

Details of each unit process and function is presented in Table 3-1. Table 3-1: Unit processes at SAPREF

Unit Process Unit Process Function Batch or Continuous Crude Distillation including Separation of the crude into naphtha, kerosene, light gas oil, Continuous Solvents and TCS heavy gas oil and long residue fractions. A catalytic reformer using a platinum-based catalyst to increase Catalytic Reforming Continuous the octane number in naphtha stream to produce petrol. Use of a platinum-based catalyst to increase the octane Isomerization Continuous number in light naphtha stream to produce petrol. Processing of short residue and asphalt propane under Thermal Cracking Continuous high temperature conditions. Use catalyst to convert waxy distillate feed into saleable products, Catalytic Cracking Continuous including blending and bituminous products. Hydrofluoric acid is used as catalyst to combine light and volatile hydrocarbons such as propylene and butylene with isobutene to HF Alkylation Continuous produce alkylate. The alkylate is used in premium quality motor fuel. Hydrodesulphurization / Reduces sulphur content of gasoline, kerosene or gasoil Continuous Hydro treating fraction hydrocarbons. Recover sulphur as a product to clean up sulphur rich refinery Sulphur Recovery Continuous waste gas streams.

Gas recovery &treatment Propylene splitters and light end recovery. Continuous

Utilities Boilers Steam generation and associated facilities. Continuous

Utilities Cooling Water Standard cooling water systems. Continuous

Lube Production Formulation of lubricants. Continuous

Crude Oil Storage Tanks Storage of crude oil before processing. Continuous

Product Storage Tank storage of intermediate and finished products. Continuous

Loading Facility Loading of finished product (LPG, bitumen and solvents). Continuous

3.3 RAW MATERIALS AND PRODUCTS

Maximum permitted raw material consumption rates are presented in Table 3-2. Table 3-2: Raw material consumption

Raw Material Maximum Permitted Consumption Rate Units (Quantity/Period) Crude Oil 180,000 Barrels/day

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Maximum permitted production capacity is presented in Table 3-3. Table 3-3: Production capacity

Product Maximum Permitted Production Capacity Units (Quantity/Period) MOG (Petrol) 9,900 kT/day Solvents 700 kT/day MMFO (Marine Fuel Oil) 7,858 kT/day AGO (Gas oil, Diesel) 9,047 kT/day Lube base oils 2,000 kT/day DPK (Dual Purpose Kerosene) 3,508 kT/day Bitumen 900 kT/day Liquid Petroleum Gas 468 kT/day

Maximum permitted by-product capacity is presented in Table 3-4. Table 3-4: By-product capacity

By-product Maximum Permitted Production Capacity Units (Quantity/Period) Sulphur 282 T/day

Energy sources and consumption rates are presented in Table 3-5. Table 3-5: Energy sources

Product Consumption rate Units (Quantity/Period) Electricity 31,205 MWh/month Refinery gas 1,070 T/day Methane rich gas 200 T/day Liquid fuel oil 205 T/day

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3.4 ATMOSPHERIC EMISSIONS

3.4.1 POINT SOURCE PARAMETERS

Point source parameters as per the AEL are provided in Table 3-6. Table 3-6: Stack parameters (from AEL) Height Height above Stack Act. Gas Act. Gas Point source Point source Latitude Longitude above Act. Gas Vel. Emission Continuous/ nearby Diameter Exit Temp. Vol. Flow code name (ºS) (ºE) Ground (m/s) Hours batch Building (m) (˚C) (m3/hr) (m) (m) SV0001 (P10) SV-F3273 -29.9773 30.9654 30 20 2.19 187 146382 11 24 Intermittent SV0003 (P2) SV-Visbreaker -29.9763 30.9649 100 90 2.15 305 207090 10 24 Intermittent SV0004 (P3) SV-CD2 -29.9749 30.9660 100 90 4.5 310 240991 9 24 Continuous SV0005 (P4) SV-FCCU -29.9736 30.9671 100 90 3.3 295 51788 10 24 Continuous SV0006 (P6) SV-Platformer -29.9720 30.9688 100 90 2.45 235 415941 6.3 24 Continuous SV0007 (P7) SV-Lubes -29.9679 30.9717 100 90 1.9 260 71544 16 24 Continuous SV0008 (P8) SV-Penex -29.9726 30.9682 100 90 1.9 167 51064 5 24 Continuous SV0009 (P9) SV-F4501 -29.9762 30.9635 19.25 10 0.5 462 8950 10 24 Continuous Not in SV0010 (P5)23 SV-Bitumen -29.9727 30.9680 100 90 2.45 Not in use Not in use Not in use Not in use use

23 Stack has not been operational since 2012

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3.4.2 PERMITTED MAXIMUM EMISSION RATES - NORMAL OPERATING CONDITIONS

Maximum permitted emission rates for point sources are presented in Table 3-7. Table 3-7: Maximum permitted emission rates (normal operating conditions) Maximum Point source Reporting group / Pollutant Date to be Averaging Duration of Point source name AEL sub-category Release Rate codes Emission unit Name Achieved By Period Emissions (mg/Nm3) 1700 Immediate SO2 Daily Continuous 1000 1 April 2020 SV-F3273 120 Immediate SV0001 (P10) Subcategory 2.1 EU 0001 PM Daily Continuous (F3273) 70 1 April 2020 1700 Immediate NOx Daily Continuous 400 1 April 2020

1700 Immediate Visbreaker SO2 Daily Continuous RG00037 1000 1 April 2020 (F80001B; F80001C; 120 Immediate F7101B; F8401; Subcategory 2.1 EU0027; EU0183; PM Daily Continuous F8402; F8403; EU0184; EU0192 to 70 1 April 2020 SV0003 (P2) F8404;F8001A; EU0196 1700 Immediate F8601) NOx Daily Continuous 400 1 April 2020 Visbreaker Subcategory 2.3 EU0008 H2S a24 Immediate Daily Continuous (SRU4) 1700 Immediate SO2 Continuous SV-CD2 RG 0083 1000 1 April 2020 Daily

(F8502; F850; F8504; EU0029; EU0030; 120 Immediate SV0004 (P3) Subcategory 2.1 PM Continuous F7101A; F7201; EU0031; EU0032; 70 1 April 2020 Daily F7202; F7401;F7701; EU0033; EU0034; F8501) EU0197 to EU0199 1700 Immediate NOx Continuous 400 1 April 2020 Daily

24 Sulphur recovery units should achieve 95% recovery efficiency and availability of 99%.

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Maximum Point source Reporting group / Pollutant Date to be Averaging Duration of Point source name AEL sub-category Release Rate codes Emission unit Name Achieved By Period Emissions (mg/Nm3) SV-CD2 Subcategory 2.3 EU0201 H2S a25 Immediate Daily Continuous (SRU3) 1700 Immediate SO Continuous 2 Daily RG0039 1000 1 April 2020 SV-FCCU 120 Immediate Subcategory 2.1 EU0004; EU0005; PM Daily Continuous (F3263; F6501) EU0035; EU0003; 70 1 April 2020 EU0186; 1700 Immediate NOx Daily Continuous 400 1 April 2020 SV0005 (P4) SO2 3000 Immediate Daily Continuous 1500 1 April 2020 SV-FCCU PM 120 Immediate Daily Continuous Subcategory 2.2 (F802) 100 1 April 2020

NOx 550 Immediate Daily Continuous 400 1 April 2020 1700 Immediate SO2 Daily Continuous 1000 1 April 2020 SV- Platformer RG0040 SV0006 (P6) 120 Immediate Subcategory 2.1 PM Daily Continuous (F301; F302; F304; EU0038; EU0039; 70 1 April 2020 F305) EU0040; EU0187 1700 Immediate NOx Daily Continuous 400 1 April 2020 1700 Immediate SV-Lubes/NZ RG0042 SO2 Daily Continuous 1000 1 April 2020 SV0007 (P7) (F4001; F4101; Subcategory 2.1 EU0043; EU0044; 120 Immediate F4701;4901) EU0045; EU0046 PM Daily Continuous 70 1 April 2020

25 Sulphur recovery units should achieve 95% recovery efficiency and availability of 99%.

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Maximum Point source Reporting group / Pollutant Date to be Averaging Duration of Point source name AEL sub-category Release Rate codes Emission unit Name Achieved By Period Emissions (mg/Nm3)

1700 Immediate NO Daily Continuous x 400 1 April 2020 1700 Immediate SO2 Daily Continuous 1000 1 April 2020 SV- Penex RG0041 Subcategory 2.1 120 Immediate SV0008 (P8) PM Daily Continuous

(F501; F503) EU0041; EU0042; 70 1 April 2020 1700 Immediate NOx Daily Continuous 400 1 April 2020 1700 Immediate SO2 Daily Continuous 1000 1 April 2020

SV-F4501 120 Immediate PM Daily Continuous SV0009 (P9) EU0047 Subcategory 2.1 70 1 April 2020 (F4501)

1700 Immediate NOx Daily Continuous

400 1 April 2020 1700 Immediate SO2 Daily Continuous 1000 1 April 2020 SV-Bitumen SV0010 (P5) 120 Immediate Subcategory 2.1 EU0037 PM Daily Continuous

(F802) 70 1 April 2020 1700 Immediate NOx Daily Continuous 400 1 April 2020 HCR Flares

P11; P12; P13 N/A EU0207; EU0208 Subject to the conditions listed in section 7.4 of AEL (South HRC; North HRC and South HSR)

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3.4.3 PERMITTED MAXIMUM EMISSION RATES - START-UP, SHUTDOWN, UPSET AND MAINTENANCE CONDITIONS

Emissions associated with start-up, shutdown, upset and maintenance operating conditions as per AEL are provided in Table 3-8. Table 3-8: Start-up, shutdown, upset and maintenance conditions Pollutants and associated amount of Process units Description of Occurrence of Potential Releases Brief outline of back-up plan emissions Start-up and shutdown Staggered shutdown to mitigate/ minimize impacts. Planned phased shutdown of units. Duration 30 H S, SO , NO , PM, HCR/HSR Flaring, Noise, Refinery has shutdown/start-up plans and procedures to Refinery shutdown 2 2 x days. SO2 Ambient exceedances. ensure all pollutants are monitored and effectively managed. Staggered phased start-up of units to mitigate/minimize impacts. Planned phased start-up of units. Duration 15-45 H S, SO , NO , PM, HCR/HSR Flaring, Noise, Refinery start-up 2 2 x Refinery has shutdown/start-up plans and procedures to days. SO Ambient exceedances. 2 ensure all pollutants are monitored and effectively managed. External Power Outage Unplanned shutdown of units. Duration 8 days H S, SO , NO , PM, HCR/HSR Flaring, Noise, Refinery shutdown 2 2 x None provided no mechanical damage. SO2 ambient exceedances. Staggered phased start-up of units to mitigate/minimize impacts. Phased start staggered up of units. Duration 15-45 H S, SO , NO , PM, HCR/HSR Flaring, Noise, Refinery start-up 2 2 x Refinery has shutdown/start up plans and procedures to days. SO ambient exceedances. 2 ensure all pollutants are monitored and effectively managed. Sulphur Recovery Unit H S, SO , HCR/HSR flaring, noise, SO ambient SRU shutdown Planned shutdown of unit. Duration 2 years. 2 2 2 Ensure second SRU is available. exceedances. SRU H S, SO , HCR/HSR flaring, noise, SO ambient Unplanned shutdown of unit. Duration 30 days. 2 2 2 Reduce refinery rates to mitigate/minimize impacts. trip/outage exceedances. H S, SO , HCR/HSR flaring, noise, SO ambient Reduce refinery rates to mitigate/minimize impact and as SRU start-up Planned start-up of unit. Duration 15-25 days. 2 2 2 exceedances, SO2 ambient exceedances. a last resort shutdown responsible unit. SCOT Unit H S, SO , flaring, noise, SO ambient SCOT shutdown Planned shutdown of unit. Duration 60 Days. 2 2 2 Reduce refinery rates to mitigate/minimize impacts. exceedances. H S, SO , flaring, noise, SO ambient SCOT Trip/outage Unplanned shutdown of unit. Duration 30 days. 2 2 2 Reduce refinery rates to mitigate/minimize impacts. exceedances.

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3.4.4 ABATEMENT EQUIPMENT AND APPLIANCES

Point source abatement is presented in Table 3-9. Table 3-9: Abatement appliances

Point source code Point source name Appliance Type Comm. Date Upgrade Date Min. Eff. (%) Min. Util. (%) P2-CD0001 RG 0037 SV-Visbreaker SRU 3 SCOT- Claus Sulphur Recovery 2002 none 95 90% SV0003 P3-CD0001 RG0038 SV-CD2 SRU 4 SCOT- Claus Sulphur Recovery 2002 none 95 90% SV0004 P4-CD0002 EU00036 Bitumen Stack Multi-Cyclones 2002 and 2009 None 95 90% SV0005 P4-CD0003 RG0039 SV-FCCU Boiler Low NOx burners 2002 none 90 95% SV0005 P10-CD0004 EU0001 SV-F3273 Boiler Low NOx burners 2005 none 90 95% SV0001 P7-CD0005 Process Furnace Low NOx burners RG0042 SV-Lubes 2002 and 2005 none 90 95%

SV0007 P8-CD0006 RG0041 SV-Penex Process Furnace Low NOx burners 2002 and 2005 none 90 95% SV0008 P6-CD0007 RG0040 SV-Platformer Platformer Low NOx burners 31/07/2015 none 90 95% SV0006

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3.4.5 AREA SOURCES

Area sources listed in the AEL are provided in Table 3-10 below. Table 3-10: Area/line-source parameters (AEL) Type of Latitude Longitude Height of Source Length of Width of Area Emission Emission Source Code Source Name (decimal (decimal Release above Description Area (m) (m) Hours (Continuous/ degrees) degrees) Ground (m) Intermittent) Area sources Storage Tank 24 hours A1 Crude Oil -29.983056 30.959444 22 450 300 Continuous Farm 365 days Crude Oil Tank 24 hours A2 Midmar 3 -29.582051 30.574786 1 95 50 Continuous Bottoms 365 days Stormwater 24 hours A3 Stormwater -29.584672 30.574850 3 100 40 Continuous Dam 365 days Bitumen 24 hours A4 VB Tanks -29.584499 30.575269 8 100 30 Continuous Products 365 days 24 hours A5 Midmar 2 Effluent Water -29.584290 30.574991 1 110 67 365 days Continuous Emergency 24 hours A6 Water -29.584322 30.574445 1 31 17 Continuous Dam 365 days 24 hours Continuous A7 Solvents Tank Solvents -29.583405 30.574304 8 270 64 365 days Slops and 24 hours AS Slops & Naptha -29.582300 30.580923 7 190 68 Continuous naphtha 365 days 24 hours Continuous A9 Mixing Tank Water -29.582132 30.581336 1 14 9 365 days 24 hours A10 NTF Crude Oil -29.970278 30.969722 18 200 100 Continuous 365 days Lube oil 24 hours A11 Lubes Tanks -29.580079 -30.581464 8 194 95 Continuous components 365 days Gasoil 24 hours A12 Heavy Blending -29.580906 30.580360 7 259 299 Continuous Components 365 days Mogas 24 hours A13 Light Blending -29.971386 30.966667 8 250 250 Continuous Components 365 days LPG 24 hours A14 LPG Storage -29.581888 30.575036 9 123 66 Continuous Components 365 days 24 hours A15 Road Loading LPG Products -29.581057 30.57311 5 52 10 Continuous 365 days

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Type of Latitude Longitude Height of Source Length of Width of Area Emission Emission Source Code Source Name (decimal (decimal Release above Description Area (m) (m) Hours (Continuous/ degrees) degrees) Ground (m) Intermittent) 24 hours A16 Rail Loading LPG Products -29.581477 30.575005 7 35 10 Continuous 365 days 24 hours A17 Bitumen Tanks Bitumen -29.582358 30.574769 8 160 125 Continuous 365 days Bitumen 24 hours A18 Bitumen -29.582447 30.574258 8 50 15 Continuous Loading 365 days Line sources Diesel 24 hours L1 Diesel Engine -29.581797 30.574480 1 820 3 Continuous Locomotive 365 days Diesel 24 hours L2 Diesel Engine -29.581114 30.575186 1 400 3 Continuous Locomotive 365 days

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4 GEOGRAPHIC OVERVIEW

4.1 LOCATION AND EXTENT

SAPREF is located in Prospecton, South Durban in the eThekwini Municipality, adjacent to the former Durban International Airport (Figure 4-1). South Durban comprises heavy industry, congested transport routes and high- density residential areas. Key industrial air pollution sources in the region include pulp and paper mills, petrochemical refineries, light industries and port-related activities. Plant location details are presented in Table 4-1. The property is approximately 177 ha in extent which is mostly occupied by the structures associated with refinery operations, including process areas, storage facilities and administration buildings. The land is currently zoned for industrial use, however adjacent areas are a mix of commercial and residential with the nearest residences situated approximately 0.3 km from the refinery’s fenceline. The coastline lies 0.35 km to the east of the facility. Figure 4-1 shows the location of SAPREF and hospitals, old age homes and key industries within 10 km of SAPREF as well as schools identified within 5 km of the site. Neighbouring residential areas include Isipingo Beach and Prospecton to the southwest, Isipingo and Umlazi to the west, as well as Ganges, Settlers, Merewent and Wentworth to the northeast. Table 4-1: Plant location details

Physical Address of the Premises 1 on Refinery Road Prospecton Durban 4110 Description of Site (Where No Street Address) Remainder of Portion 1 of the Farm Inhlanzi no. 17392 Coordinates of Approximate Centre of Operations Latitude: -29.973611; Longitude: 30.966667 Extent (km²) 1.776 Elevation Above Mean Sea Level (m) 8 Province KwaZulu-Natal Metropolitan/District Municipality eThekwini Metropolitan Municipality Local Municipality N/A Designated Priority Area N/A

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Figure 4-1: Site location

4.2 METEOROLOGY

Seasonal and diurnal pollutant concentration levels fluctuate in response to the changing state of atmospheric stability, to concurrent variations in mixing depth and to the influence of mesoscale and macroscale wind systems on the transport of atmospheric contaminants. This section provides an overview of the atmospheric circulations influencing airflow and the subsequent dispersion and dilution of pollutant concentrations in the Durban South Basin. Localised airflow in South Durban is described as a system of drainage winds that flow down the Umbilo and the Umhlatuzana valleys at night, across the alluvial flats at the head of the bay and up against the Bluff ridge (Figure 4-2)26. From here, the air is diverted between the Bluff and Berea ridges as gentle south-westerly winds towards Durban’s central business district. The accumulation of cold air in the Durban South Basin may lead to valley inversions at night, limiting vertical dispersion. This local wind pattern is regularly disrupted by the passage of coastal lows and westerly wave frontal systems that clear the boundary layer every three to five days during the winter months.

26 Preston-Whyte and Diab, R.D. (1980): Local Weather and Air Pollution: The Case of Durban, Environmental Conservation, 7, 241- 244.

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Figure 4-2: Nocturnal air circulations in Durban (Preston-Whyte and Diab, 1980) Meteorological variables, including hourly temperature, rainfall, humidity, atmospheric pressure, wind speed and wind direction, were obtained from the nearest station operated by the South African Weather Service (SAWS) and analysed for the period January 2017 - December 2019 (i.e. three calendar years as required by the Regulations Regarding Air Dispersion Modelling27, hereafter referred to as ‘the Modelling Regulations’). Data was sourced from the Merebank station (approximately 2 km to the north-northeast of SAPREF) which was moved to Athlone Park (approximately 5 km to the southwest of SAPREF) in May 2018. Station details and data recovery information is given in Table 4-2. Although not specific to site, both stations are located in a similar geophysical context as SAPREF (Figure 4-3), and thus considered representative of meteorological conditions at site. Table 4-2: Details of meteorological stations and dataset recovery

Latitude Longitude Altitude Data recovery Station Name º º ( S) ( E) (m) Temp Rain Wind Humidity Pressure Merebank -29.9560 30.9560 8 100% 97% 99% 97% 100% Athlone Park -30.0130 30.9260 96

27 Department of Environmental Affairs (2014): Regulations Regarding Air Dispersion Modelling (No. R. 533), Government Gazette, 11 July 2014, (No. 37804).

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Figure 4-3: Location of the Merebank and Athlone Park meteorological stations

4.2.1 TEMPERATURE, RAINFALL AND HUMIDITY

Ambient air temperature influences plume buoyancy as the higher the plume temperature is above the ambient air temperature, the higher the plume will rise. Further, the rate of change of atmospheric temperature with height influences vertical stability (i.e. mixing or inversion layers). Rainfall is an effective removal mechanism of atmospheric pollutants. Figure 4-4 illustrates the average monthly temperature, rainfall and humidity as recorded for Durban South. Higher rainfall occurs during the warmer, summer months (December, January and February) with drier conditions during the cooler, winter months (June, July and August). Summer temperatures for the region average at 23.4°C while winter temperatures average at 18.1°C. South Durban received on average 900 mm of rainfall each year, with approximately 35% of that received during the summer months and 5% during the winter months.

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90 180

80 160

70 140

60 120

50 100 C) and humidity (%) humidityandC) ° 40 80 Rainfall (mm) Rainfall

30 60

Temperature ( Temperature 20 40

10 20

0 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Temperature Range Rainfall Average Temperature Humidity Figure 4-4: Meteorological summary for Durban South, January 2017 – December 2019

4.2.2 WIND FIELD

Wind roses (Figure 4-5) summarize wind speed and directional frequency at a location. Each directional branch on a wind rose represents wind originating from that direction. Each directional branch is divided into segments of colour, representative of different wind speeds. Calm conditions are defined as wind speeds less than 1.0 m/s (i.e. based on the typical sensitivity of the wind sensor installed at SAWS stations). Typical wind fields have been analysed using Lakes Environmental WRPlot Freeware (Version 7.0.0) for the full period (January 2017 – December 2019); diurnally for early morning (00h00 – 06h00), morning (06h00 – 12h00), afternoon (12h00 – 18h00) and night (18h00 – 00h00); and seasonally for summer (December, January and February), autumn (March, April and May), winter (June, July and August) and spring (September, October and November): — Calm conditions (wind speeds <1.0 m/s) occurred 8.68% of the time; — Light to fresh winds from the north-northeast and light to strong winds from the south-southeast prevail along Durban’s coastline; — Peak wind speeds occurred from the west (14.9 m/s) and highest average wind speeds occurred from the south and south-southwest (5.2 m/s); — Southerly, south-southwesterly and north-northeasterly winds prevailed in the morning (06h00-12h00); — Winds from the south and northeast prevailed in the afternoon (12h00-18h00); — North-northeasterly and southwesterly winds prevailed during the night (18h00-00h00); — Southwesterly to westerly and northerly winds prevailed during the early morning hours (00h00-06h00); — Diurnal peak (13.2 m/s) and highest average (4.3 m/s) wind speeds occurred during the afternoon; — Prevailing north-northeasterly and southerly to southwesterly winds are noted throughout the year with slight variability in seasonal frequency and strength; — Higher directional variability in the wind field is observed during winter when the frequency of calm conditions increase and westerly drainage winds are more prominent; and — Seasonal peak (13.5 m/s) and highest average (3.8 m/s) wind speeds occur during spring.

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South Durban Early Morning Morning Summer Autumn January 2017 – December 2019 00h00 – 06h00 06h00 – 12h00 December, January & February March, April & May

Calms = 12.96% Calms = 7.30% Calms = 6.62% Calms = 9.5% Afternoon Night Winter Spring September, October & 12h00 – 18h00 18h00 – 00h00 June, July & August November

Calms = 8.68%

Calms = 2.60% Calms = 7.89% Calms = 10.35% Calms = 4.45% Figure 4-5: Local wind conditions at South Durban

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4.3 AMBIENT AIR QUALITY

Ambient air quality monitoring data has been sourced from three monitoring stations in the region, namely Wentworth, Ganges and Settlers. All stations are owned and managed by the eThekwini Metropolitan Municipality. Data for the period January 2017 – December 2019 was assessed for compliance with applicable NAAQS. A minimum data recovery of 90% is required for assessing compliance with national standards28. With the exception of the Wentworth station (i.e. PM10 measured during 2019), data recovery across the pollutant array measured by all stations failed to meet this requirement. Nonetheless, the available information has been used to provide insight into background pollutant concentrations in the study area. The results presented in the sections below must be considered in the context of low data recovery. Where hourly concentrations were provided in parts per billion (ppb), these were converted to micrograms per cubic metre (µg/m3) using temperature and pressure for the corresponding date and hour as measured by the SAWS meteorological station (Section 4.2). Station information and data recovery is presented in Table 4-3. Station proximity to SAPREF is shown in Figure 4-6. Table 4-3: Station information, data recovery and results summary for the period January 2017 – December 2019

Station name Wentworth Ganges Settlers Latitude (oS) -29.934095 -29.948504 -29.958842 Longitude (oE) 30.988598 30.9646 30.978683 Direction from study site NE NNW NNE Distance from study site (km) 2.12 2.82 4.92 2017

PM10 NM 29.4% NM

NO2 0.6% 18.8% NM

SO2 NM NM 37.9% 2018

Data PM10 30.4% 8.9% NM recovery NO2 NM 31.1% NM

SO2 15.4% 18.5% 16.5% 2019

PM10 91.4% 74.3% 48.9%

NO2 NM NM NM

SO2 72.8% 68.6% 52.2% Notes: NM – not measured

28 South African National Accreditation System (SANAS, 2012) in TR 07-03

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Figure 4-6: Ambient air quality monitoring stations

4.3.1 PARTICULATE MATTER LESS THAN 10 MICROMETRES IN DIAMETER

Average PM10 concentrations and the number of recorded NAAQS exceedances measured per year are provided in Table 4-4.

Table 4-4: Measured ambient PM10 for 2017, 2018 and 2019

3 PM10 (µg/m ) Period Wentworth Ganges Settlers 2017 NM 0 NM 24-hour NAAQS 2018 0 0 NM exceedances 2019 35 78 36 Peak 24-hour 2017 - 2019 172.12 287.70 179.87 concentration 2017 NM 16.69 NM Annual average 2018 29.76 10.52 NM concentration 2019 39.87 69.67 53.08 Notes: NM – not measured Red – exceeds NAAQS limits

PM10 concentrations measured at Wentworth (Figure 4-7) for 2018 and 2019 averaged below the annual NAAQS (40 µg/m3) at 29.79 µg/m3 and 39.87 µg/m3 respectively. Ambient concentrations exceeded the 24-hour NAAQS 3 (75 µg/m , four exceedances permitted) 35 times in 2019. PM10 was not measured at Wentworth during 2017.

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180

160 )

3 140

120

100

Concentration (µg/m Concentration 60

0 01 Jul 01 Jul 15 Jul 29 08 Apr 08 Apr 22 Oct 07 Oct 21 01 Jan 01 Jan 15 Jan 29 Jun 03 Jun 17 12 Feb 12 Feb 26 Mar 11 Mar 25 12 Aug 12 Aug 26 Sep 09 Sep 23 Nov 04 Nov 18 Dec 02 Dec 16 Dec 30 06 May 06 May 20 2017 2018 2019 NAAQS

Figure 4-7: 24-hour PM10 concentrations measured at Wentworth

PM10 concentrations measured at Ganges (Figure 4-8) for 2017 and 2018 averaged below the annual NAAQS (40 3 3 3 µg/m ) at 16.69 µg/m and 10.52 µg/m respectively. PM10 concentrations measured for 2019 exceeded the annual NAAQS (40 µg/m3) at 69.67 µg/m3. No exceedances of the 24-hour NAAQS (75 µg/m3, four exceedances 3 permitted) were measured in 2017 and 2018. PM10 concentrations exceeded the 24-hour NAAQS (75 µg/m , four exceedances permitted) 78 times in 2019.

300 ) 3 250

200

150 Concentration (µg/m Concentration 100

Figure 4-8: 24-hour PM10 concentrations measured at Ganges

3 PM10 concentrations measured at Settlers (Figure 4-9) for 2019 exceeded the annual NAAQS (40 µg/m ) at 53.08 3 3 µg/m . PM10 concentrations exceeded the 24-hour NAAQS (75 µg/m , four exceedances permitted) 36 times in 2019. PM10 was not measured at Settlers during 2017 and 2018.

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200

180

) 160 3 140

120

100

Concentration (µg/m Concentration 60

Figure 4-9: 24-hour PM10 concentrations measured at Settlers

4.3.2 NITROGEN DIOXIDE

Average NO2 concentrations and the number of recorded NAAQS exceedances measured per year are provided in Table 4-5.

Table 4-5: Measured ambient NO2 for 2017, 2018 and 2019

3 PM10 (µg/m ) Period Wentworth Ganges Settlers 2017 0 554 NM 1-hour NAAQS 2018 NM 511 NM exceedances 2019 NM NM NM Peak 1-hour 2017 - 2018 8.21 746.08 NM concentration 2017 1.53 165.03 NM Annual average 2018 NM 113.06 NM concentration 2019 NM NM NM Notes: NM – not measured Red – exceeds NAAQS limits

The NO2 dataset for the Wentworth station is too limited (0.6% data recovery for 2017 and not measured in 2018 and 2019) to provide meaningful input to this study and therefore has not been analysed further. NO2 is not measured at the Settlers station.

NO2 concentrations measured at Ganges (Figure 4-10) for 2017 and 2018 exceeded the annual NAAQS (40 3 3 3 µg/m ) at 165.03 µg/m and 113.06 µg/m respectively. NO2 concentrations exceeded the 1-hour NAAQS (200 3 µg/m , 88 exceedances permitted) 554 and 511 times in 2017 and 2018 respectively. NO2 was not measured at Ganges during 2019.

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800

700 )

3 600

500

400

300 Concentration (µg/m Concentration 200

100

Figure 4-10: 1-hour NO2 concentrations measured at Ganges

4.3.3 SULPHUR DIOXIDE

Average SO2 concentrations and the number of recorded NAAQS exceedances measured per year are provided in Table 4-6.

Table 4-6: Measured ambient SO2 for 2017, 2018 and 2019

3 PM10 (µg/m ) Period Wentworth Ganges Settlers 2017 NM NM 3 1-hour NAAQS 2018 0 0 0 exceedances 2019 3 0 1 Peak 1-hour 2017 - 2019 1152.47 193.17 475.02 concentration 2017 NM NM 0 24-hour NAAQS 2018 0 0 1 exceedances 2019 1 0 0 Peak 24-hour 2017 - 2019 172.12 47.02 143.29 concentration 2017 NM NM 14.64 Annual average 2018 15.65 9.48 18.94 concentration 2019 22.78 10.03 18.58 Notes: NM – not measured

3 SO2 concentrations measured at Wentworth for 2018 and 2019 averaged below the annual NAAQS (50 µg/m ) at 15.65 µg/m3 and 22.78 µg/m3 respectively. Ambient concentrations exceeded the 24-hour NAAQS (125 µg/m3, four exceedances permitted) one time in 2019 (Figure 4-11). Ambient concentrations exceeded the 1-hour 3 NAAQS (350 µg/m , 88 exceedances permitted) three times in 2019 (Figure 4-12). SO2 was not measured at Wentworth during 2017.

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160 )

3 140

120

100

Concentration (µg/m Concentration 60

Figure 4-11: 24-hour SO2 concentrations measured at Wentworth

1200 ) 3 1000

800

600 Concentration (µg/m Concentration 400

200

0 01 Jul 01 Jul 15 Jul 29 08 Apr 08 Apr 22 Oct 07 Oct 21 01 Jan 01 Jan 15 Jan 29 Jun 03 Jun 17 12 Feb 12 Feb 26 Mar 11 Mar 25 12 Aug 12 Aug 26 Sep 09 Sep 23 Nov 04 Nov 18 Dec 02 Dec 16 Dec 30 06 May 06 May 20

2017 2018 2019 NAAQS

Figure 4-12: 1-hour SO2 concentrations measured at Wentworth

3 SO2 concentrations measured at Ganges for 2018 and 2019 averaged below the annual NAAQS (50 µg/m ) at 9.48 µg/m3 and 10.03 µg/m3 respectively. No exceedances of the 24-hour NAAQS (125 µg/m3, four exceedances permitted) (Figure 4-13) or the 1-hour NAAQS (350 µg/m3, 88 exceedances permitted) (Figure 4-14) were measured. SO2 was not measured at Ganges during 2017.

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120 ) 3 100

60 Concentration (µg/m Concentration 40

Figure 4-13: 24-hour SO2 concentrations measured at Ganges

500

450

) 400 3 350

300

250

200

Concentration (µg/m Concentration 150

100

Figure 4-14: 1-hour SO2 concentrations measured at Ganges

3 SO2 concentrations measured at Settlers for 2017, 2018 and 2019 averaged below the annual NAAQS (50 µg/m ) at 14.64 µg/m3, 18.94 µg/m3 and 18.58 µg/m3 respectively. Ambient concentrations exceeded the 24-hour NAAQS (125 µg/m3, four exceedances permitted) one time in 2018 (Figure 4-15). Ambient concentrations exceeded the 1-hour NAAQS (350 µg/m3, 88 exceedances permitted) three times in 2017 and one time in 2019 (Figure 4-16).

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160

140 ) 3 120

100

60 Concentration (µg/m Concentration

Figure 4-15: 24-hour SO2 concentrations measured at Settlers

500

450

) 400 3 350

300

250

200

Concentration (µg/m Concentration 150

100

Figure 4-16: 1-hour SO2 concentrations measured at Settlers

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5 DISPERSION MODELLING

5.1 ASSESSMENT LEVEL AND PROPOSED MODEL

A Level 3 modelling assessment was undertaken in line with the Modelling Regulations. Level 3 modelling assessments are recommended for: — Understanding air quality impacts, including spatial and temporal variation in concentrations; — Ensuring causality effects, calms, non-linear plume trajectories, spatial variations in turbulent mixing, multiple emission source types and where chemical transformations need to be accounted for; and — Informing air quality management approaches that involve multi-source, multi-sector contributions from permitted and non-permitted sources in an airshed. CALPUFF is the recommended Level 3 model in the Modelling Regulations. CALPUFF is a multi-layer, multi- species non-steady-state puff dispersion model, which can simulate the effects of time and space, as well as varying meteorological conditions on pollutant transport, transformation and removal. CALPUFF is an internationally recognised dispersion model recommended for: — Long-range transport distances up to 300 km; — Assessment of multiple emission source types (i.e. point, line, area, volume) and emission sectors (i.e. industry, traffic, etc.); — Deposition and light extinction for long-range transport; — Secondary formation of particulate matter in long-range transport; and — Complex non-steady-state meteorological conditions such as inhomogeneous winds, stagnation conditions and inversion breakup dispersion. The CALPUFF atmospheric dispersion modelling system includes three main components: — CALMET: a meteorological model that develops hourly wind and temperature fields on a three-dimensional gridded modelling domain; — CALPUFF: a transport and dispersion model that advects “puffs” of material emitted from modelled sources, simulating dispersion and transformation processes using the fields generated by CALMET. Temporal and spatial variations in the meteorological fields selected are incorporated in the resulting distribution of puffs throughout a simulation period. Output files contain hourly concentration or deposition fluxes evaluated for selected receptor locations; and — CALPOST: a post run processor for tabulating and summarising the results of the simulation for selected averaging times and locations.

5.2 MODEL INPUTS

5.2.1 MODEL DOMAIN

According to the Modelling Regulations, the selected size and extent of the model domain is influenced by factors such as source buoyancy, terrain features (i.e. mountains) and the location of contributing sources. Larger domains are recommended for elevated, buoyant sources (e.g. stacks) while smaller domains are considered sufficient for lower release heights. The modelling domain for this study is thus 20 km x 20 km, centred over the SAPREF site.

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5.2.2 RECEPTORS

RECEPTOR GRID The Modelling Regulations specify the use of a multi-tier grid and recommend specific tier resolutions. In line with these requirements, the risk receptor resolution grid is 100 m x 100 m up to 2 km m from the centre of the site; 250 m x 250 m up to 5 km from the centre of the site and 500 m x 500 m up to 10 km from the centre of the site.

DISCRETE SENSITIVE RECEPTORS Discrete receptors selected for this study are listed in Table 5-1. Receptors were selected based on proximity to the study site and are places where sensitive individuals may be impacted, such as residences, schools or medical facilities. Their proximity to SAPREF is shown in Figure 5-1. Table 5-1: Discrete receptor locations

ID Receptor Name Receptor Type Distance (km) Direction Latitude (oS) Longitude (oE) 1 Wentworth Residential 5.1 NE -29.934249° 30.988975° 2 Ganges Residential/School 2.9 N -29.948745° 30.964660° 3 Settlers Residential/School 2.3 NE -29.958304° 30.978449° 4 Merewent Residential/Hospital 2.0 NE -29.962897° 30.979413° 5 Isipingo Beach Residential 3.0 SW -29.996238° 30.944404° 6 Prospecton Residential 4.5 SW -30.002804° 30.928808° 7 Isipingo Residential 4.1 SW -29.982001° 30.922085° 8 Umlazi Residential 3.0 NW -29.963087° 30.937861°

Figure 5-1: Sensitive receptors

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5.2.3 FACILITY FENCELINE

As defined in the Modelling Regulations, ambient air quality objectives are applied to areas outside the facility fenceline. Within the facility boundary, environmental conditions are prescribed by occupational health and safety criteria. The facility boundary is defined based on these criteria: — The facility fenceline or the perimeter where public access is restricted; — If the facility is located within a larger facility, the facility boundary is that of the encompassing facility; and — If a public access road passes through the facility, the facility boundary is the perimeter of the road.

5.2.4 METEOROLOGY

Meteorological conditions affect how pollutants emitted into the air are directed, diluted and dispersed within the atmosphere, and therefore incorporation of reliable data to an air quality assessment is of the utmost importance. Important parameters for the characterisation of dispersion potential include wind speed, wind direction, extent of atmospheric turbulence, ambient air temperature and mixing depth. To represent meteorological conditions at the site, MM5 data was obtained from Lakes Environmental as recommended by the Modelling Regulations. For the purposes of this study, a CALMET ready MM5 dataset for the years January 2016 – December 2018 centred at SAPREF (-29.973860 °S, 30.965598 °E) was utilised. The CALMET meteorological model contains a diagnostic wind field module that includes parameterized treatments of terrain effects.

5.2.5 TERRAIN AND LAND USE

Terrain influences dispersion of pollutants, especially during periods of stable conditions. The NASA Shuttle Radar Topographic Mission (STRM) digital elevation model (DEM) (resolution 90 m x 90 m) was extracted and inputted to the model to account for terrain influences on dispersion. For the land use categorization, a surface output was created from the Global Land Cover Characterization Global Coverage – Version 2 (1 km x 1 km resolution).

5.2.6 EMISSIONS INVENTORY

A full emissions inventory follows in Section 6.

5.3 MODEL SCENARIOS

Dispersion modelling simulations of PM10, NO2, SO2 and VOCs was undertaken for short-term (i.e. 24-hour and 1-hour) averaging periods for comparison with applicable NAAQS. Model outputs show simulated pollutant concentrations experienced at ground level for the following scenarios: 1 Worst case scenario: Emergency depressuring of HDS4 (baseline, flare balancing); 2 Worst case scenario: Emergency depressuring of HDS4 (proposed, no flare balancing) 3 Planned shutdown (baseline, based on 2020 shutdown data, flare balancing); and 4 Planned shutddown (proposed, based on 2020 shutdown data but adjusted for no flare balancing).

Further details on these emission scenarios follow in the Emisions Inventory in Section 6.

5.4 MODEL OUTPUTS

For Scenarios 1 and 2 (Emergency depressuring of HDS4, baseline and proposed), Rank 1 hourly values were calculated. Rank 1 hourly values are the peak hourly average concentration calculated across the entire meteorological record (i.e. three years, 2016 – 2018, in this case). This assumes that the emergency depressuring event occurred over the hour when meteorological conditions caused the greatest impact at each receptor point.

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Although these Rank 1 results are graphically presented in the maps that follow as concentration isopleths, in reality these values would not occur simultaneously across the model domain. It is emphasised that this is a worst- case scenario, and that the statistical likelihood that the worst-case meteorological conditions would coincide with the emergency depressuring of HDS4 at a specific point is 1 in 26,280 (<0.004%), assuming one emergency depressuring of HDS4 over the three year period. For Scenarios 3 and 4 (Planned shutdown, baseline and proposed), Rank 1 hourly and Rank 1 24-hourly concentrations were calculated. Rank 1 24-hourly values are the peak 24-hour average concentration calculated across the entire meteorological record (i.e. three years, 2016 – 2018, in this case). This assumes that the shutdown event occurred on the day when meteorological conditions caused the greatest impact at each individual receptor point. Although these Rank 1 results are graphically presented in the maps that follow as concentration isopleths, in reality these values would not occur simultaneously across the model domain. It is emphasised that this is a worst-case scenario, and that the statistical likelihood that the worst-case meteorological conditions would coincide with the day of shutdown at a specific point is 1 in 365 (<0.27%), assuming one planned shutdown per annum. No long term average scenarios can be simulated as this would require knowledge of the exact timing of the flaring event/s in the meteorological record. However, a qualitative discussion of any likely changes in long term average emissions of key pollutants associated with the proposed North Flare project is discussed.

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6 EMISSIONS INVENTORY

6.1 FLARE ENERGY CALCULATIONS

CALPUFF requires input of the volume percentage of the flare gas components as well as their respective energy density, J/mol). For the H2S flares, the mol % of each constituent of the flare gas was provided by SAPREF. The molar masses and energy densities of each constituent were then used to calculate m/m % and ultimately J/mol for input to CALPUFF (Table 6-1). The average energy density of the H2S gas to the flare was calculated to be 19.9 MJ/kg.

Table 6-1: H2S flare gas constituents

Molar Mass Gas component ratios Energy Density Compound g/mol Mol % Mass % MJ/kg J/Mol

Hydrogen sulphide H2S 34.081 64.04 69.31 15.25 519680.00

Ammonia NH3 17.030 31.37 16.97 18.65 317545.48

Methane CH4 16.042 0.08 0.04 50.05 802873.02 C2 - C6 hydrocarbons C2-C6 54.966 7.44 12.98 45.63 2508151.65 Benzene, toluene, BTEX 95.644 0.20 0.59 40.65 3887785.90 ethylbenzene and xylene Run as Mercaptans 48.107 0.07 0.10 0.00 0.00 CH4S A similar approach was followed for the hydrocarbon flares (Table 6-2). The average energy density of the hydrocarbon gas to the flare was calculated to be 70.6 MJ/kg. Table 6-2: Hydrocarbon flare gas constituents

Molar Mass Gas component ratios Energy Density Compound g/mol Mass % MJ/kg J/Mol

Hydrogen H2 2.016 37.3 119.96 241800.97

Nitrogen N2 28.013 6.5 0 0

Oxygen O2 31.998 0.1 0 0 Carbon monoxide CO 28.010 0.2 10.11 283234.09

Carbon dioxide CO2 44.009 0.2 0 0

Hydrogen sulphide H2S 34.081 1.10 15.30 521434.40 Methane C1 16.042 11.8 50.05 802873.02 Ethane C2 30.068 7.2 47.61 1431588.50 Ethylene C2= 28.053 2.5 47.13 1322182.68 Propane C3 44.095 9.7 46.33 2042913.01 Propylene C3= 42.079 5.5 45.80 1927182.53 Isobutane iC4 58.121 4.3 45.58 2648989.93 n-Butane nC4 58.121 8.1 45.73 2657591.87 Isobutylene iC4= 56.106 0.9 45.06 2527834.20 1-butene 1-C4= 56.106 0.7 45.33 2543487.64 Trans butene t-C4= 56.106 0.8 45.12 2531705.48 Cis butene Cis C4= 56.106 0.6 45.19 2535632.87

1,3 Butadiene C4H6 54.090 0 44.61 2413110.03 Isopentane iC5 72.148 1.3 45.25 3264605.85 Neo-pentane nC5 72.148 0.4 45.34 3271387.72 Longer hydrocarbons C6 & higher 86.174 0.7 45.00 3877828.20

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6.2 FLARE EMISSION CALCULATIONS

Stack emissions from the flaring stacks were calculated using the following equations provided by SAPREF: Total hydrocarbon flared x (H2S content of flared gas/ 100.0) x 64/34 The factor 64/34 is derived from the stoichiometry of the chemical reaction which takes place when H2S is combusted to form SO2: SO2 H2S + 3/2O2 -> SO2 + H2O i.e. 34g H2S forms 64g SO2 1.1% H2S for the hydrocarbon flares 69.3% H2S for the H2S flare Calculated using flare combustion efficiency, the flare gas volume and composition. NO = mass of gas flared (tons) x 0.0005 x flare efficiency NO 2 2 Default composition for flare with steam injection = 0.0005 Default flare efficiency = 0.98 VOCs = mass of gas flared (tons) x (1-flare efficiency) x VOC content of flare gas VOCs Default VOC content for Shell Downstream refineries = 0.64 Default flare efficiency = 0.98

29 30 The European Environment Agency (2019) recommends that the CONCAWE (2015) PM10 emission factor for the combustion of natural gas (8.90E-01 grams of PM10 per GJ of fuel) is used for oil refinery flaring. However, this source states that for a non-smoking flare, PM10 emissions are negligible so the use of this emission factor is considered environmentally conservative.

6.3 SCENARIOS 1 AND 2: EMERGENCY HDS4 DEPRESSURING

SAPREF provided model case HDS4 depressuring curves for the baseline (313 tonne/hr, with flare balancing) and proposed (460 tonne/hr, no flare balancing) scenarios. The North Flare was simulated on its own for baseline and proposed scenarios (i.e. scenarios 1 and 2), to provide data on flare specific impacts under a worst-case emission and meteorological scenario (assuming that these coincide, and thus providing an absolute worst-case scenario). Cumulative emission scenarios follow for Scenarios 3 and 4. Table 6-3 to Table 6-6 provides emission details for the North Flare for Scenarios 1 and 2 respectively. Table 6-3: Baseline HDS4 depressuring (15 minutes)

Time Pressure Temperature Vent rates Hour Bar °C Tonne/hour m3/hour 0.00 36.50 89.4 312.973 2751.33 0.01 35.44 87.8 306.314 2771.588 0.02 34.24 85.9 292.531 2813.57 0.03 32.91 83.7 277.991 2856.035 0.04 31.47 81.4 262.968 2898.088 0.05 29.94 78.7 247.725 2938.975 0.06 28.36 75.9 232.519 2978.059 0.07 26.76 73.0 217.574 3014.849 0.08 25.16 69.9 203.065 3049.038 0.09 23.57 66.7 189.112 3080.475 0.10 22.03 63.4 175.811 3109.09 0.11 20.53 60.1 163.231 3134.872 0.12 19.10 56.8 151.4 3157.902

29 EMEP/EEA (2019). Air Pollutant Emission Inventory Guidebook, NFR 1.B.2.c Venting and Flaring 30 CONCAWE (2015), ‘Air pollutant emission estimation methods for E-PRTR reporting by refineries, 2015 edition, URL: https://www.concawe.eu/wp-content/uploads/2017/01/rpt_15-3.pdf

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Time Pressure Temperature Vent rates Hour Bar °C Tonne/hour m3/hour 0.13 17.74 53.5 140.332 3178.292 0.14 16.45 50.2 130.019 3196.188 0.15 15.23 46.9 120.448 3211.736 0.16 14.10 43.7 111.59 3225.109 0.17 13.04 40.5 103.414 3236.475 0.18 12.06 37.4 95.893 3245.994 0.19 11.14 34.4 88.981 3253.838 0.20 10.30 31.5 82.637 3260.172 0.21 9.53 28.6 76.828 3265.14 0.22 8.81 25.8 71.514 3268.893 0.23 8.16 23.1 66.654 3271.566 0.24 7.56 20.6 62.215 3273.288 0.25 7.01 18.1 58.161 3274.175

Table 6-4: Proposed HDS4 depressuring (15 minutes)

Time Pressure Temperature Vent Rates Hour Bar °C Tonne/hour m3/hour 0.00 57.013 326.0 459.756 6553.566 0.01 50.305 324.4 437.754 6466.959 0.02 44.461 322.7 396.086 6287.082 0.03 39.498 321.1 359.412 6112.44 0.04 35.322 319.6 327.683 5947.213 0.05 31.777 318.2 300.252 5792.481 0.06 28.743 316.9 276.333 5647.582 0.07 26.127 315.7 255.317 5511.823 0.08 23.858 314.5 236.729 5384.511 0.09 21.877 313.4 220.191 5264.974 0.10 20.138 312.4 205.4 5152.578 0.11 18.605 311.5 192.107 5046.724 0.12 17.245 310.6 180.107 4946.858 0.13 16.034 309.8 169.233 4852.47 0.14 14.952 309.2 159.341 4763.087 0.15 13.981 308.5 150.313 4678.279 0.16 13.105 308.0 142.047 4597.652 0.17 12.314 307.6 134.456 4520.846 0.18 11.597 307.3 127.466 4447.53 0.19 10.944 307.1 121.013 4377.405 0.20 10.35 306.9 115.044 4310.219 0.21 9.805 306.9 109.507 4245.693 0.22 9.305 307.0 104.355 4183.564 0.23 8.845 307.2 99.553 4123.636 0.24 8.422 307.5 95.073 4065.742 0.25 8.03 308.0 90.882 4009.679

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Table 6-5: North Flare stack parameters

AEL ID North HCR Flare Stack height baseline (m) 60 Stack height proposed (m) 77 Stack diameter (m) 0.76 Effective Gas Exit Velocity (m/s) 20 Gas temperature (°C) 1273

Table 6-6: Scenario 1 and 2 emissions - North flare

Scenario 1 - Baseline 2 - Proposed Total Gas g/s 23384.47 40630.97

Energy density MJ/kg 70.56 70.56 J/s 1.65E+09 2.87E+09 Particulate Matter g/s 1.47 2.55

Oxides of Nitrogen (NOX) g/s 11.46 19.91

Sulphur Dioxide (SO2) g/s 514.46 893.88 VOC g/s 299.32 520.08

6.4 SCENARIOS 3 AND 4: PLANNED SHUTDOWN

Peak hourly quantities of gas flared over the 2020 shutdown and start-up periods were identified from modelled data provided by SAPREF. The peak day of SO2 flare emission occurred during the shutdown (13 April 2020 00h15 to 14 April 2020 00h00 inclusive). This day of emissions was used for a worst-case assessment and run for the three year meteorological record to assess the impact of the combination of the worst-case emission with worst-case meteorological conditions, even though their coincidence would be very unlikely. Stack parameters for non-flaring point sources associated with normal operations were sourced from stack emissions monitoring testing conducted by PB Environmental (2019) and Levego (2015). Simulated emissions from the various point sources for the shutdown period were provided by SAPREF and emissions from 13 April 2020 were extracted. Source parameters are summarised in Table 6-7 with emission rates in Table 6-8. As indicated by SAPREF, flare emissions from the North Flare would increase by 20% without flare balancing.

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Table 6-7: Scenarios 3 and 4: Stack parameters SFL Utilities Vis- Lubes South North South CD2 FCCU Bitumen Platform Penex F4501 Boiler Source code name Stack breaker (SAMCO) HCR HCR HSR Stack Stack Stack er Stack Stack Stack Stack (F3271/2) Stack Stack Flare Flare Flare (F3273)

Latitude (ºS) -29.9773 -29.9763 -29.9749 -29.9736 -29.9727 -29.9720 -29.9679 -29.9726 -29.9762 -29.9773° -29.9763° -29.9714° -29.9763°

Longitude (ºE) 30.9654 30.9649 30.9660 30.9671 30.9680 30.9688 30.9717 30.9682 30.9635 30.9655° 30.9668° 30.9703° 30.9669°

Stack Height (m) 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 19.25 30.00 100.00 60.00 100.00

Stack diameter (m) 2.19 2.15 4.50 3.30 2.45 2.45 1.90 1.90 0.50 2.19 0.76 0.76 0.76

Gas Exit Velocity 9.20 8.56 10.50 47.50 Not in use 5.80 8.00 3.70 11.8 12.40 20.00 20.00 20.00 (m/s)

Gas temp (°C) 180 295.55 278.57 638 Not in use 241 248 185 480 179 1273 1273 1273

PB Env Levego Levego PB Env PB Env PB Env PB Env PB Env PB Env Source of info N/A SAPREF SAPREF SAPREF (2019) (2015) (2015) (2019) (2019) (2019) (2019) (2019) (2019)

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Table 6-8: Scenario 3 and 4 emissions - planned shutdown SFL Utilities Vis- South North South CD2 FCCU Platformer Lubes Penex F4501 Boiler Pollutant Scenario Stack breaker HCR HCR HSR Stack Stack Stack (SAMCO)Stack Stack Stack Stack (F3271/2) Stack Flare Flare Flare (F3273)

Baseline 1.99E-05 0.11 0.67 0.69 8.07E-06 1.36E-09 1.62E-03 0.00E+00 1.14E-05 2.30E-08 2.30E-08 3.18E-08 PM (g/s) Proposed 1.99E-05 0.11 0.67 0.69 8.07E-06 1.36E-09 1.62E-03 0.00E+00 1.14E-05 1.84E-8 2.76E-08 3.18E-08

Baseline 6.61E-04 0.65 9.51 0.41 2.46E-04 4.34E-09 5.82E-02 0.00E+00 4.96E-04 0.12 0.15 0.13

NOx (g/s) Proposed 6.61E-04 0.65 9.51 0.41 2.46E-04 4.34E-09 5.82E-02 0.00E+00 4.96E-04 0.09 0.17 0.13

Baseline 1.10E-03 3.11 41.08 20.28 1.95E-03 6.64E-08 1.76E-04 0.00E+00 1.21E-03 66.37 83.51 476.13

SO2 (g/s) Proposed 1.10E-03 3.11 41.08 20.28 1.95E-03 6.64E-08 1.76E-04 0.00E+00 1.21E-03 49.67 100.21 476.13

Baseline NM NM NM NM NM NM NM NM NM 3.01 3.79 0.41 VOC (g/s) Proposed NM NM NM NM NM NM NM NM NM 2.25 4.55 0.41

NM – Not measured

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6.4.1 OTHER EMISSION SOURCES

Area and line sources modelled under scenario 3 and 4 are shown in Figure 6-1 and discussed in more detail in the sections that follow.

Figure 6-1: Location of area and line sources

STORAGE TANKS SAPREF makes use of USEPA TANKS (v.4.0.9) to calculate emissions of TVOC from bulk storage tanks. The TANKS model is applicable for emissions from organic liquids in storage tanks and is based on the USEPA AP- 42 emission factors. Data input includes the storage tank dimensions, physical characteristics, contents and locations. An emissions report is generated for each chemical stored in the tank at various timescales. Both breathing and working losses are accounted for in the estimate. Tank emissions are presented in Table 6-9. The following tank farms have been considered as part of this assessment: — Storage Tank Farm — VB Tanks — Solvent Tanks — Slops and Naphtha — North Tank Farm — Lubes Tank Farm — Heavy Blending — Light Blending — Bitumen Tanks

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Table 6-9: Storage tank area dimensions and emission rates

Slops & Heavy Bitumen AEL ID STF VB Tanks Solvent Tanks NTF Lube Tanks Light Blending Naphtha Blending Tanks

Bitumen Slops and Lube Oil Gasoil Mogas Source description Crude Oil Solvents Crude Oil Bitumen Products Naphtha Components Components Components

Tank numbers T1106 – T1118 T3801 – T3803 T1251 – T1288 T1301 – T1806 T1326 – T1104 T4801 – T4823 T1313 – T7804 T1201 – T1339 T1901 – T2017

Storage area dimensions

Height of release (m) 22 8 8 7 18 8 7 8 8

Length of area (m) 450 100 270 190 200 194 259 250 160

Width of area (m) 300 40 64 68 100 95 299 250 125

Emission rate

TVOC (g/s) 1.21 2.10E-03 2.50 14.39 0.66 0.16 0.42 3.32 4.58E-02

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EFFLUENT AND SLUDGE DAMS WSP were appointed to quantify the TVOC emissions from Midmar 2 (effluent) and Midmar 3 (sludge) dams for SAPREF’s 2019 National Atmospheric Emissions Inventory System (NAEIS) submission. VOC losses from the effluent storage in the Midmar 2 and Midmar 3 dams at SAPREF were calculated using the USEPA WATER9 model (version 3.0). Results are presented in the Table 6-10 below. Table 6-10: Reuse dam and effluent dam parameters and emission rates

Source ID Midmar 2 Midmar 3 Source Description Effluent dam Oily sludge storage dam Dam area dimensions Height of release (m) 1 1 Length of Area (m) 110 95 Width of Area (m) 67 50 Emission rates TVOC (g/s) 6.421E-03 1.377E-02

BITUMEN LOADING AND DIESEL LOCOMOTIVE Emission parameters related to bitumen loading and the diesel locomotive were provided by SAPREF. Emission rates were calculated by SAPREF using product/raw material throughput and provided into the NAEIS emission factors. Quantified emission rates are presented in Table 6-11 and Table 6-12. Table 6-11: Bitumen loading parameters and emission rates

Source ID Bitumen Source Description Bitumen loading area Loading area dimensions Height of release (m) 8 length of Area (m) 50 Width of Area (m) 15 Emission rate TVOC (g/s) 1.36 Table 6-12: Diesel locomotive parameters and emission rates

Source ID Diesel Locomotive Source Description Diesel Engine Locomotive railway line dimensions Height of release (m) 1 Length of track (m) 1051.7 Emission rates

PM10 (g/s) 3.25E-03 NO2 (g/s)* 1.07E-01

*Conservatively assumed that all NOx is emitted as NO2.

ONSITE TRAFFIC The SAPREF carpark has capacity for 1,155 vehicles. The daily average number of trucks that visit the plant is 35. It was assumed that 1,155 passenger vehicles visit the facility per day, travelling to the car park and then returning. This is considered environmentally conservative. Similarly it is estimated that 35 heavy vehicles visit the facility daily, travelling approximately 300 m on-site and 300 m return. Emission factors are provided in Table 6-13 and Table 6-14. Emission estimates are presented in Table 6-15.

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Table 6-13: Emission factors for vehicle exhaust31

Typical fuel Emission Factor (g/kg) Category Fuel consumption a figures (g/km) NOx SO2 CO PM NMVOC Lead Motorcycles Gasoline 35 6.64 - 497.7 2.2 131.4 0.000033 Gasoline 70 8.73 - 84.7 0.03 10.05 0.000033 Passenger cars Diesel 50(b) 60 12.96 0.1 3.33 1.1 0.7 0.000052

Light-duty Gasoline 100 13.22 - 152.3 0.02 14.59 0.000033 vehicles Diesel 50(b) 80 14.91 1 7.4 1.52 1.54 0.000052 Heavy-duty vehicles and Diesel 500(c) 240 33.37 1 7.58 0.94 1.92 0.000052 buses

a: assuming that the sulphur content of the fuel is completely transformed into SO2 b: maximum sulphur content for low-grade diesel = 50 mg/kg c: maximum sulphur content for standard grade diesel = 500 mg/kg Table 6-14: Emission factors for vehicle tyre, brake and road surface wear32

Emission Factor (g/km/vehicle) Category TSP PM10 PM2.5 Motorcycles 0.0143 0.0094 0.005 Passenger cars 0.0332 0.0213 0.0115 Light-duty vehicles 0.0436 0.0291 0.0158 Heavy-duty vehicles and buses 0.1537 0.097 0.0521 Table 6-15: Vehicular traffic emissions

Parameter Light (passenger) motor vehicles Heavy motor vehicles Distance (m) 5000 (2500 return) 600 (300 return) Number of vehicles per day 1155 35 NOx (g/s) 8.66E-02 1.95E-03 SO2 (g/s) 6.68E-04 5.83E-05 PM (g/s) 9.57E-03 9.22E-05 VOC (g/s) 6.72E-02 1.12E-04

FUGITIVE LEAKS Emission parameters related to fugitive leak emissions measured from the Leak Detection and Repair (LDAR) program for annual reporting to NAEIS are presented in Table 6-16 below. Table 6-16: Fugitive leak emission rates

Area Area (m2) TVOC (g/s) TVOC (g/s/m2) North Zone 16,334 7.74 4.74E-04 Centre Zone 13,272 15.79 1.19E-03 South Zone 20,938 6.32 3.02E-04 Emissions from the following sources listed in the AEL are considered negligible and are not assessed further: — Stormwater dam — Emergency water dam — Mixing tank containing water — LPG storage – fully enclosed system — Road Loading – fully enclosed system — Rail loading – fully enclosed system

31 European Environmental Agency: Exhaust emissions from road transport. EMEP/EEA emission inventory guidebook 32 European Environmental Agency: Road vehicle tyre, brake and road surface wear. EMEP/EEA emission inventory guidebook

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7 RESULTS

This section presents the results of the atmospheric dispersion modelling conducted for the four assessment scenarios. Air pollution concentrations at specified sensitive receptors are presented in this section, while concentration isopleth maps can be found in Appendix A.

7.1 SCENARIOS 1 AND 2: EMERGENCY HDS4 DEPRESSURING

7.1.1 PARTICULATE MATTER

The predicted Rank 1 24-hour average PM10 concentrations associated with the baseline and proposed emergency HDS4 depressuring scenarios at each discrete receptor are presented in Table 7-1. Plume isopleths for Rank 1 24- hour average PM10 concentrations for the baseline and proposed scenarios are shown in Figure A-1 and Figure A-2 respectively. The predicted Rank 1 24-hour average PM10 concentrations for the baseline and proposed scenarios demonstrate compliance with the NAAQS at all receptors. The highest predicted 24-hour average PM10 receptor concentrations occur at Wentworth for the baseline scenario and at Umlazi for the proposed scenario. Rank 1 24-hour PM10 concentrations are expected to decrease at the Wentworth and Isipingo Beach receptors, and increase at the remaining receptors under the proposed scenario. The most significant increase is at the Umlazi receptor.

7.1.2 NITROGEN DIOXIDE

The predicted Rank 1 1-hour NO2 concentrations associated with the baseline and proposed emergency HDS4 depressuring scenarios at each discrete receptor are presented in Table 7-2. Plume isopleths for Rank 1 1-hour average NO2 concentrations for the baseline and proposed scenarios are shown in Figure A-3 and Figure A-4 respectively. The predicted Rank 1 1-hour average NO2 concentrations for the baseline and proposed scenarios demonstrate compliance with the NAAQS at all receptors. The highest predicted 1-hour average NO2 receptor concentrations occur at Wentworth for the baseline scenario and at Umlazi for the proposed scenario. Rank 1 1- hour NO2 concentrations are expected to decrease at the Wentworth and Isipingo Beach receptors, and increase at the remaining receptors under the proposed scenario. The most significant increase is at the Umlazi receptor.

7.1.3 SULPHUR DIOXIDE

The predicted Rank 1 24-hour average SO2 concentrations associated with the baseline and proposed emergency HDS4 depressuring scenarios at each discrete receptor are presented in Table 7-3. Plume isopleths for Rank 1 24- hour average SO2 concentrations for the baseline and proposed scenarios are shown in Figure A-5 and Figure A-6 respectively. The predicted Rank 1 24-hour average SO2 concentrations for the baseline and proposed scenarios demonstrate compliance with the NAAQS at all receptors. The highest predicted 24-hour average SO2 receptor concentrations occur at Wentworth for the baseline scenario and at Umlazi for the proposed scenario. Rank 1 24-hour SO2 concentrations are expected to decrease at the Wentworth and Isipingo Beach receptors, and increase at the remaining receptors under the proposed scenario. The most significant increase is at the Umlazi receptor.

The predicted Rank 1 1-hour SO2 concentrations associated with the baseline and proposed emergency HDS4 depressuring scenarios at each discrete receptor are presented in Table 7-3. Plume isopleths for Rank 1 1-hour average SO2 concentrations for the baseline and proposed scenarios are shown in Figure A-7 and Figure A-8 respectively. Predicted Rank 1 1-hour average SO2 concentrations exceed the NAAQS at Wentworth (baseline) as well as at Ganges and Umlazi (proposed). The highest predicted 1-hour average receptor SO2 concentrations occur at Wentworth for the baseline scenario and at Umlazi for the proposed scenario. Rank 1 1-hour SO2 concentrations are expected to decrease at the Wentworth and Isipingo Beach receptors, and increase at the remaining receptors under the proposed scenario. The most significant increase is at the Umlazi receptor.

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7.1.4 TOTAL VOLATILE ORGANIC COMPOUNDS

The predicted Rank 1 24-hour average TVOC concentrations associated with the baseline and proposed HDS4 depressuring scenarios at each discrete receptor are presented in Table 7-4. Plume isopleths for Rank 1 24-hour average TVOC concentrations for the baseline and proposed scenarios are shown in Figure A-9 and Figure A-10 respectively. No NAAQS is available for short term TVOC concentrations for comparison here. The highest predicted 24-hour average TVOC receptor concentrations occur at Wentworth for the baseline scenario and at Umlazi for the proposed scenario. Rank 1 24-hour TVOC concentrations are expected to decrease at the Wentworth and Isipingo Beach receptors, and increase at the remaining receptors under the proposed scenario. The most significant increase is at the Umlazi receptor.

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Table 7-1: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 PM10 concentrations predicted at discrete receptors

Rank 1 24-hour Baseline Rank 1 24-hour Proposed Receptor 24-hour NAAQS (µg/m3) Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) Wentworth 6.40E-02 5.41E-02 -9.95E-03 -15.54

Ganges 5.08E-02 5.22E-02 1.40E-03 2.76

Settlers 6.55E-03 1.31E-02 6.56E-03 100.07

Merewent 5.22E-03 7.22E-03 2.00E-03 38.20

Isipingo Beach 75 1.44E-02 1.07E-02 -3.78E-03 -26.17

Prospecton 1.15E-02 1.26E-02 1.06E-03 9.23

Isipingo 2.77E-02 3.32E-02 5.50E-03 19.83

Umlazi 5.33E-02 1.04E-01 5.07E-02 95.26

Domain Max 9.94E-02 1.13E-01 1.35E-02 13.56

Table 7-2: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 NO2 concentrations predicted at discrete receptors

Rank 1 1-hour Baseline Rank 1 1-hour Proposed Receptor 1-hour NAAQS (µg/m3) Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) Wentworth 8.96 3.39 -5.58 -62.22

Ganges 6.37 7.87 1.50 23.56

Settlers 0.86 1.22 0.36 41.77

Merewent 0.44 0.55 0.11 26.37

Isipingo Beach 200 1.47 1.36 -0.11 -7.18

Prospecton 1.77 2.08 0.31 17.42

Isipingo 4.46 5.00 0.54 12.08

Umlazi 6.24 17.32 11.09 177.73

Domain Max 12.85 17.58 4.73 36.82

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Table 7-3: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 SO2 concentrations predicted at discrete receptors

24-hour Rank 1 24- Rank 1 24- Rank 1 1-hour Rank 1 1-hour 1-hour NAAQS Receptor NAAQS hour Baseline hour Proposed Δ (µg/m3) Δ (%) Baseline Proposed Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) Wentworth 22.43 18.95 -3.49 -15.54 402.47 152.05 -250.42 -62.22

Ganges 17.79 18.28 0.49 2.76 286.10 353.50 67.40 23.56

Settlers 2.29 4.59 2.30 100.07 38.64 54.78 16.14 41.78

Merewent 1.83 2.53 0.70 38.20 19.57 24.74 5.16 26.37

Isipingo Beach 125 5.06 3.74 -1.32 -26.17 350 65.86 61.14 -4.72 -7.17

Prospecton 4.04 4.41 0.37 9.23 79.48 93.33 13.85 17.42

Isipingo 9.71 11.63 1.93 19.83 200.30 224.48 24.18 12.07

Umlazi 18.66 36.43 17.77 95.25 280.03 777.74 497.71 177.73

Domain Max 34.82 39.54 4.72 13.56 576.76 789.11 212.35 36.82 Red – Exceeds NAAQS

Table 7-4: Baseline and proposed HDS4 emergency depressuring to North Flare - Rank 1 TVOC concentrations predicted at discrete receptors

Receptor Rank 1 24-hour Baseline (µg/m3) Rank 1 24-hour Proposed (µg/m3) Δ (µg/m3) Δ (%) Wentworth 13.05 11.02 -2.03 -15.54

Ganges 10.35 10.64 0.29 2.75

Settlers 1.34 2.67 1.34 100.07

Merewent 1.06 1.47 0.41 38.20

Isipingo Beach 2.94 2.17 -0.77 -26.17

Prospecton 2.35 2.57 0.22 9.23

Isipingo 5.65 6.77 1.12 19.83

Umlazi 10.86 21.20 10.34 95.26

Domain Max 20.26 23.00 2.75 13.56

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7.2 SCENARIOS 3 AND 4: PLANNED SHUTDOWN

7.2.1 PARTICULATE MATTER

The predicted Rank 1 24-hour average PM10 concentrations associated with the baseline and proposed planned shutdown scenarios at each discrete receptor are presented in Table 7-5. Plume isopleths for the Rank 1 24-hour average PM10 concentrations are shown in Figure A-11 (the difference between the baseline and proposed scenarios is not visually detectable and thus both scenarios are represented by a single map). The predicted Rank 1 24-hour average PM10 concentrations for the baseline and proposed scenarios demonstrate compliance with the NAAQS at all receptors. The highest predicted 24-hour average PM10 receptor concentrations occur at Ganges for the baseline and proposed scenarios. There is no significant change in Rank 1 24-hour average PM10 concentrations under the proposed scenario (Table 7-5).

7.2.2 NITROGEN DIOXIDE

The predicted Rank 1 1-hour NO2 concentrations associated with the baseline and proposed planned shutdown scenarios at each discrete receptor are presented in Table 7-6. Plume isopleths for Rank 1 1-hour average NO2 concentrations are shown in Figure A-12 (the difference between the baseline and proposed scenarios is not visually detectable and thus both scenarios are represented by a single map). The predicted Rank 1 1-hour average NO2 concentrations for the baseline and proposed scenarios demonstrate compliance with the NAAQS at all receptors. The highest predicted 1-hour average NO2 receptor concentrations occur at Umlazi for the baseline and proposed scenarios. There is no significant change to Rank 1 1-hour average NO2 concentrations under the proposed scenario. There is an area of Rank 1 exceedance along SAPREF’S western fenceline, in the vicinity of the railway (domain maximum is 219.22 µg/m3). However, the 99th percentile (P99) domain maximum is 44.41 µg/m3, falling well below the relevant NAAQS.

7.2.3 SULPHUR DIOXIDE

The predicted Rank 1 24-hour SO2 concentrations associated with the baseline and proposed planned shutdown scenarios at each discrete receptor are presented in Table 7-7. Plume isopleths for Rank 1 24-hour average SO2 concentrations are shown in Figure A-13 (the difference between the baseline and proposed scenarios is not visually detectable and thus both scenarios are represented by a single map). The predicted Rank 1 24-hour average SO2 concentrations for the baseline and proposed scenarios demonstrate non-compliance with the NAAQS at all receptors except Prospecton (baseline) as well as Prospecton and Merewent (proposed). The conservatism in assessing the incidence of a planned shutdown during worst-case meteorological conditions is highlighted. These results offer a worst-case scenario. The P99 24-hour receptor concentrations are presented in Table 7-8 for comparison. All receptor concentrations except for Isipingo Beach fall into NAAQS compliance when assessing the P99 values. The highest predicted Rank 1 24-hour average SO2 receptor concentrations occur at Ganges for the baseline and proposed scenarios. Rank 1 24-hour average SO2 concentrations are predicted to decrease at all receptors except Prospecton and Umlazi under the proposed scenario.

The predicted Rank 1 1-hour average SO2 concentrations associated with the baseline and proposed planned shutdown scenarios at each discrete receptor are presented in Table 7-7. Plume isopleths for the Rank 1 1-hour average SO2 concentrations are shown in Figure A-14 (the difference between the baseline and proposed scenarios is not visually detectable and thus both scenarios are represented by a single map). The predicted Rank 1 1-hour average SO2 concentrations for the baseline and proposed scenarios demonstrate non-compliance with the NAAQS at all receptors. The conservatism in assessing the incidence of a planned shutdown during worst-case meteorological conditions is highlighted. These results offer a worst-case scenario. The P99 1-hour receptor concentrations are presented in Table 7-8 for comparison. A number of receptors (Settlers, Merewent, Prospecton, Isipingo and Umlazi) fall within NAAQS compliance when assessing the P99 values. The highest predicted Rank 1 1-hour average SO2 receptor concentrations occur at Ganges for the baseline and proposed scenarios. Rank 1 1-hour average SO2

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concentrations are predicted to decrease at all receptors under the proposed scenario. The most significant decrease is at Ganges.

7.2.4 TOTAL VOLATILE ORGANIC COMPOUNDS

The predicted Rank 1 24-hour average TVOC concentrations associated with the baseline and proposed planned shutdown scenarios at each discrete receptor are presented in Table 7-9. Plume isopleths for Rank 1 24-hour average TVOC concentrations are shown in Figure A-15 (the difference between the baseline and proposed scenarios is not visually detectable and thus both scenarios are represented by a single map). No NAAQS is available for short term TVOC concentrations for comparison here. The highest predicted 24-hour average TVOC receptor concentrations occur at Merewent for the baseline and proposed scenarios. There is no significant change in Rank 1 24-hour average TVOC concentrations under the proposed scenario (Table 7-9).

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Table 7-5: Baseline and proposed planned shutdown - Rank 1 PM10 concentrations predicted at discrete receptors Rank 1 24-hour Baseline Rank 1 24-hour Proposed Receptor 24-hour NAAQS (µg/m3) Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) Wentworth 0.24 0.24 0.00 0.00 Ganges 0.30 0.30 0.00 0.00 Settlers 0.08 0.08 0.00 0.00 Merewent 0.06 0.06 0.00 0.00 Isipingo Beach 75 0.18 0.18 0.00 0.00 Prospecton 0.13 0.13 0.00 0.00 Isipingo 0.16 0.16 0.00 0.00 Umlazi 0.20 0.20 0.00 0.00 Domain Max 0.95 0.95 0.00 0.00

Table 7-6: Baseline and proposed planned shutdown - Rank 1 NO2 concentrations predicted at discrete receptors Rank 1 1-hour Baseline Rank 1 1-hour Proposed Receptor 1-hour NAAQS (µg/m3) Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) Wentworth 15.43 15.43 0.0040 0.03

Ganges 12.20 12.23 0.0330 0.27

Settlers 8.95 8.95 -0.0002 0.00

Merewent 8.07 8.07 0.0000 0.00

Isipingo Beach 200 9.52 9.51 -0.0095 -0.10

Prospecton 12.59 12.59 0.0020 0.02

Isipingo 10.35 10.35 0.0020 0.02

Umlazi 17.50 17.50 -0.0020 -0.01

Domain Max 219.22 219.22 0.0000 0.00 Red – Exceeds NAAQS

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Table 7-7: Baseline and proposed planned shutdown - Rank 1 SO2 concentrations predicted at discrete receptors 24-hour Rank 1 24- Rank 1 24- Rank 1 1-hour Rank 1 1-hour 1-hour NAAQS Receptor NAAQS hour Baseline hour Proposed Δ (µg/m3) Δ (%) Baseline Proposed Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) Wentworth 189.90 189.50 -0.40 -0.21 1308.80 1300.70 -8.10 -0.62

Ganges 269.04 259.80 -9.24 -3.43 1559.20 1476.60 -82.60 -5.30

Settlers 153.58 145.97 -7.61 -4.96 1471.30 1447.90 -23.40 -1.59

Merewent 127.64 123.05 -4.59 -3.60 1026.20 998.82 -27.38 -2.67

Isipingo Beach 125 181.88 176.54 -5.34 -2.94 350 1041.90 1039.20 -2.70 -0.26

Prospecton 111.71 114.11 2.40 2.15 1075.00 1066.50 -8.50 -0.79

Isipingo 168.58 165.00 -3.58 -2.12 1153.30 1145.20 -8.10 -0.70

Umlazi 154.01 155.72 1.71 1.11 1279.80 1277.40 -2.40 -0.19

Domain Max 332.04 324.38 -7.66 -2.31 3670.20 3702.80 32.60 0.89 Red – Exceeds NAAQS

Table 7-8: Baseline and proposed planned shutdown – P99 SO2 concentrations predicted at discrete receptors 24-hour P99 24-hour P99 24-hour P99 1-hour P99 1-hour 1-hour NAAQS Receptor NAAQS Baseline Proposed Δ (µg/m3) Δ (%) Baseline Proposed Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) Wentworth 120.47 119.47 -1.00 -0.83 374.54 368.07 -6.47 -1.73

Ganges 114.86 113.58 -1.28 -1.11 374.29 370.55 -3.74 -1.00

Settlers 119.01 112.85 -6.16 -5.18 340.49 332.37 -8.12 -2.38

Merewent 88.13 80.88 -7.25 -8.23 186.79 180.50 -6.29 -3.37

Isipingo Beach 125 140.58 137.04 -3.54 -2.52 350 361.87 357.30 -4.57 -1.26

Prospecton 87.16 85.83 -1.33 -1.53 277.34 274.58 -2.76 -1.00

Isipingo 69.90 69.47 -0.42 -0.61 249.38 245.13 -4.25 -1.70

Umlazi 74.12 73.69 -0.44 -0.59 262.28 262.39 0.11 0.04

Domain Max 189.14 183.08 -6.06 -3.20 581.38 570.24 504.48 767.15 Red – Exceeds NAAQS

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Table 7-9: Baseline and proposed planned shutdown - Rank 1 TVOC concentrations predicted at discrete receptors Rank 1 24-hour TVOC Baseline Rank 1 24-hour TVOC Proposed Receptor Δ (µg/m3) Δ (%) (µg/m3) (µg/m3) Wentworth 67.79 67.70 -0.082 -0.121

Ganges 135.85 135.84 -0.010 -0.007

Settlers 352.15 352.15 0.000 0.000

Merewent 469.85 469.83 -0.020 -0.004

Isipingo Beach 125.02 125.01 -0.010 -0.008

Prospecton 93.09 93.05 -0.039 -0.042

Isipingo 61.11 61.07 -0.037 -0.061

Umlazi 133.28 133.28 0.000 0.000

Domain Max 4842.00 4842.00 0.000 0.000

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7.3 CUMULATIVE ASSESSMENT

A cumulative assessment combining monitoring data with the model simulations was attempted, but due to significant gaps in the monitoring data, there are no cumulative results for PM10 (Table 7-10), NO2 (Table 7-11) or TVOC (Table 7-12).

Table 7-10: Cumulative PM10 concentrations

24-hour Date of peak 24- Monitoring value Cumulative Receptor Δ (µg/m3) NAAQS (µg/m3) hour simulation (µg/m3) (µg/m3) Wentworth 30/11/16 0.00 No data No data Ganges 75 22/12/16 0.00 No data No data Settlers 05/10/17 0.00 No data No data

Table 7-11: Cumulative NO2 concentrations Date and time of 1-hour NAAQS Monitoring Cumulative Receptor peak 1-hour Δ (µg/m3) (µg/m3) value (µg/m3) (µg/m3) simulation Wentworth 06h00, 30/11/16 0.0040 No data No data Ganges 200 08h00, 05/03/17 0.0330 No data No data Settlers 11h00, 20/05/17 -0.0002 No data No data

Table 7-12: Cumulative TVOC concentrations

24-hour Date of peak 24- Monitoring value Cumulative Receptor Δ (µg/m3) NAAQS (µg/m3) hour simulation (µg/m3) (µg/m3) Wentworth 10/03/16 -0.082 No data No data Ganges NA 07/09/17 -0.010 No data No data Settlers 10/03/16 0.000 No data No data

Data was available in the Ganges record to assess cumulative concentrations at the time of the Rank 1 24-hour and Rank 1 1-hour SO2 simulations (Table 7-13). It was conservatively assumed that the monitoring data excluded SAPREF emissions, and the simulated SAPREF emissions were then added to this33. The proposed cumulative Rank 1 24-hour and 1-hour concentrations decrease from the baseline scenario. However, the cumulative concentrations exceed the NAAQS under both scenarios. The conservatism in assessing the incidence of a planned shutdown during worst-case meteorological conditions is highlighted. These results offer a worst-case scenario.

7.4 LONG-TERM AVERAGES

No long term average scenarios can be simulated, as this would require knowledge of the exacting timing of the flaring event/s in the meteorological record. However, there is no expected increase in flaring associated with this North Flare project, nor is it expected that there will be an increased quantity of gas flared across the facility (i.e. the proposed project will limit the requirements for flare balancing but not adjust the quantity of gas flared annually). As shown in the comparison of the results of Scenario 3 (baseline) and Scenario 4 (proposed), if the amount of flaring remains the same, one would expect a decrease in long term SO2 averages over most of the model domain due to the increased height of the North Flare under the proposed scenario. .

33 This is a double accounting of SAPREF emissions that were occurring at the time of measurement.

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Table 7-13: Cumulative SO2 concentrations

24-hour Date of peak Monitoring Baseline Proposed 1-hour Date and time of Baseline Proposed Δ Monitoring Receptor NAAQS 24-hour Value Cumulative Cumulative NAAQS peak 1-hour Δ (µg/m3) Cumulative Cumulative (µg/m3) Value (µg/m3) (µg/m3) simulation (µg/m3) (µg/m3) (µg/m3) (µg/m3) simulation (µg/m3) (µg/m3)

Wentworth 16/02/16 -0.40 No data No data No data 09h00, 01/07/16 -8.10 No data No data No data

Ganges 125 16/01/16 -9.24 15.98 286.02 275.78 350 07h00, 05/04/16 -82.60 0.60 1559.8 1477.2

Settlers 15/11/17 -7.61 No data No data No data 10h00, 27/06/16 -23.40 No data No data No data

Red – Exceeds NAAQS

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8 ASSUMPTIONS AND LIMITATIONS

— All NOx emitted by the facility was assumed to be NO2 and there was no transformation of NO2 to secondary pollutants within the study boundaries for a conservative comparison with the NO2 NAAQS.

— In the absence of PM10 specific emissions data, it was conservatively assumed that all PM is emitted as PM10.

— As stated in the Modelling Regulations, “the oxidation of SO2 in the atmosphere is a highly complex process, which is influenced by many factors, including relative humidity, pH, concentrations of catalysts and other reactive species.” It was assumed that there was no transformation of the SO2 emitted by the facility to secondary pollutants within the study domain for a conservative comparison with the SO2 NAAQS. SO2 transformation to sulphates occurs on a regional scale over a period of hours to days, i.e. largely outside of modelling domain of this assessment. The Modelling Regulations stipulate a half-life for SO2 transformation of 4 hours. With an average wind speed of ~3.1 m/s as calculated for this study, the plume would have moved a distance of 44.6 km on average within four hours. The SAPREF study domain was 20 km x 20 km. The plume in this study would move outside of the study domain (10 km in each direction of the source) within an hour on average. — All stacks at the refinery are above 80 m high and significantly above the heights of nearby buildings for building downwash effects to become negligible, with the exception of F3273 (30 m) and F4501 (19.25 m). Stack F3273 is located some distance from any buildings while the emissions from F4501 are negligible for the assessment scenarios here (Table 6-8). — No long term average scenarios can be simulated, as this would require knowledge of the exacting timing of the flaring event/s in the meteorological record. — Data input to the model was based on the information provided by SAPREF where indicated. It is assumed that this information is accurate and complete at the time of modelling.

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9 SUMMARY AND CONCLUSION

Findings of this assessment can be summarised as follows: 1 The emergency depressuring of HDS4 is an upset condition resulting in a worst-case emission scenario from the North Flare. a Even when combining this worst-case emission scenario with the worst-case meteorological scenario, the ambient contributions from the North Flare do not result in exceedances of any pollutants at any sensitive receptors, except for 1-hour average SO2 at Wentworth (baseline) and Ganges and Umlazi (proposed). b The depressuring curves show that the emission event peaks within 15 minutes. The likelihood of an HDS4 depressuring event coinciding with the worst-case meteorological hour across the record for a specific receptor is <0.004%. 2 A planned shutdown occurs annually at the facility. A cumulative (facility-wide) emission scenario was assessed, combining flare emission calculations with emissions from the other on-site emission sources during a previous planned shutdown. Once again, ambient impacts were assessed under a worst meteorological scenario across the modelling domain (i.e. Rank 1 concentrations). a Baseline and proposed receptor concentrations were predicted to be compliant with the PM10 and NO2 NAAQS. There is no significant change in Rank 1 ambient PM10, NO2 or TVOC under the proposed scenario. b The Rank 1 domain peak hourly NO2 under the baseline and proposed scenarios exceeds the 1-hour NO2 NAAQS. This occurs in the vicinity of the railway. When assessing the P99 1-hour NO2 concentrations, full compliance occurs across the model domain. c Rank 1 24-hour and 1-hour SO2 concentrations are predicted to decrease under the proposed scenario at all receptors, except Rank 1 24-hour averages at Prospecton (increases by 2.15% but remains under the NAAQS) and Umlazi (increases by 1.11%). d While Rank 1 simulations show a significant region of exceedance of the SO2 NAAQS under the baseline and proposed scenarios, an assessment of the P99 24-hour SO2 concentrations reveals compliance at all receptors except Isipingo Beach. A number of receptors (Settlers, Merewent, Prospecton, Isipingo and Umlazi) fall within NAAQS compliance when assessing the P99 1-hour SO2 values. e The likelihood that the worst-case meteorological conditions coinding with the day of shutdown at a specific point is 1 in 365 (<0.27%). 3 A cumulative assessment combining ambient monitoring data with the model simulations was attempted. a Due to significant gaps in the monitoring data, there are no cumulative results for PM10, NO2 or TVOC. b Data was available in the Ganges monitoring record to assess cumulative concentrations at the time of the Rank 1 24-hour and Rank 1 1-hour SO2 simulations. The cumulative concentrations exceed the NAAQS under both scenarios. The conservatism in assessing the incidence of a planned shutdown during worst-case meteorological conditions is highlighted. These results offer a worst-case scenario. Importantly, the cumulative Rank 1 24-hour and 1-hour SO2 concentrations at Ganges decrease under the proposed scenario. This can be explained by the increased height of the North Flare, which improves the likelihood of dispersion before emissions reach ground level.

In conclusion, this study shows the potential for short-term SO2 exceedances at sensitive receptors during flaring incidents at SAPREF. However, these occur when combining a conservative emission scenario with worst- case meteorological conditions. It is more likely than not that a planned shutdown will occur during meteorological conditions that promote effective dispersion and will not result in ambient exceedances at sensitive receptors. Importantly, the proposed increased height of the North Flare decreases the likelihood of exceedances at sensitive receptors, due to increased dispersion of emissions before reaching ground level.

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10 FORMAL DECLARATIONS

10.1 DECLARATION OF ACCURACY OF INFORMATION

______

DECLARATION OF ACCURACY OF INFORMATION - APPLICANT

______

Name of Enterprise: Shell and BP South African Petroleum Refineries (Pty) Ltd

Declaration of accuracy of information provided:

Atmospheric Impact Report in terms of section 30 of the Act.

I, Melanie Francis (duly authorised), declare that the information provided in this atmospheric impact report is, to the best of my knowledge, in all respects factually true and correct. I am aware that the supply of false or misleading information to an air quality officer is a criminal offence in terms of section 51(1) (g) of this Act.

Signed at__Durban______on this ___15th______day of January 2021

SIGNATURE

Emission Control Officer CAPACITY OF SIGNATORY

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10.2 DECLARATION OF INDEPENDENCE

______

DECLARATION OF INDEPENDENCE - PRACTITIONER ______

Name of Practitioner: Lisa Ramsay

Declaration of independence and accuracy of information provided:

Atmospheric Impact Report in terms of Section 30 of the Act.

I, Lisa Ramsay, declare that I am independent of the applicant. I have the necessary expertise to conduct the assessments required for the report and will perform the work relating the application in an objective manner, even if this results in views and findings that are not favourable to the applicant. I will disclose to the applicant and the air quality officer all material information in my possession that reasonably has or may have the potential of influencing any decision to be taken with respect to the application by the air quality officer, The information provided in this atmospheric impact report is, to the best of my knowledge, in all respects factually true and correct. I am aware that the supply of false or misleading information to an air quality officer is a criminal offence in terms of section 51(1) (g) of this Act.

Signed at Westville on this 15th day of January 2021

______SIGNATURE

Air Quality Specialist CAPACITY OF SIGNATORY

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APPENDIX

CONCENTRATION ISOPLETHS

APPENDIX

Figure A-1: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour PM10 concentrations

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APPENDIX

Figure A-2: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour PM10 concentrations

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APPENDIX

Figure A-3: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 1-hour NO2 concentrations

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APPENDIX

Figure A-4: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 1-hour NO2 concentrations

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APPENDIX

Figure A-5: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour SO2 concentrations

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APPENDIX

Figure A-6: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour SO2 concentrations

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APPENDIX

Figure A-7: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 1-hour SO2 concentrations

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APPENDIX

Figure A-8: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 1-hour SO2 concentrations

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APPENDIX

Figure A-9: Scenario 1 (baseline emergency HDS4 depressuring) - Rank 1 24-hour TVOC concentrations

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APPENDIX

Figure A-10: Scenario 2 (proposed emergency HDS4 depressuring) - Rank 1 24-hour TVOC concentrations

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APPENDIX

Figure A-11: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour PM10 concentrations

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APPENDIX

Figure A-12: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 1-hour NO2 concentrations

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APPENDIX

Figure A-13: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour SO2 concentrations

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APPENDIX

Figure A-14: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 1-hour SO2 concentrations

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APPENDIX

Figure A-15: Scenario 3 (baseline planned shutdown) and Scenario 4 (proposed planned shutdown) - Rank 1 24-hour TVOC concentrations

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