ArcelorMittal South Africa : COCGW External Audit Report for AMSA Vanderbijlpark August 2021

COCGW-08-2021

ARCELORMITTAL SOUTH AFRICA

VANDERBIJLPARK WORKS

EXTERNAL AUDIT ON ROD FOR THE

COKE OVEN CLEAN GAS AND WATER PROJECT

August 2021

Esicongweni Environmental Services

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REPORT TITLE:

ARCELORMITTAL SOUTH AFRICA, VANDERBIJLPARK WORKS, EXTERNAL AUDIT ON ROD FOR THE COKE OVEN CLEAN GAS AND WATER PROJECT

PREPARED BY		AUTHOR
Esicongweni Environmental Services		Martin Bezuidenhout
		Cell: 073 433 4656
		Fax: [phone]
		e-mail:[e-mail]
Western Cape Branch (Head Office)
Tel: [phone] - office hours
Unit A0, Cape Sands, Strand, 7140
Free State Branch
Tel: [phone] - office hours
PO Box 42360, Heuwelsig, 9332
			JM Bezuidenhout
KEYWORDS:	COCGW, external audit, RoD, compliance, ArcelorMittal,
	Coke Ovens, GDARD
CO-ORDINATES:	Longitude	26°37'50.07" S
	Latitude	27°52'28.75" E
LOCATION:	ArcelorMittal Vanderbijlpark Works, Vanderbijlpark,
	Gauteng Province
DATE:	18 August 2021
ARCELORMITTAL PERSONNEL:	Mr Johan Hattingh
	Mr Terrence Wilson

Table of Contents
1. INTRODUCTION .......................................................................................................................................	5
2. AUDIT OBJECTIVES...................................................................................................................................	6
3. AUDIT METHODOLOGY ...........................................................................................................................	7
4. AUTHORISED ACTIVITIES .........................................................................................................................	7
5. APPRAISAL OF RoD CONDITIONS.............................................................................................................	8
Table 1: RoD Conditions ............................................................................................................................	10
6. DISCUSSION AND RECOMMENDATIONS ...............................................................................................	27

Addendums

Addendum A - RoD dated 24/05/2004

Addendum B - Amendment, dated April 2009

Addendum C - Amendment, dated November 2009

Addendum D - Amendment, dated June 2010

Addendum E - Amendment, dated September 2019

Addendum F - Works Fresh Water Abstraction

Addendum G - Discharge to Rietspruit

Addendum H - Coke Production Dust Emissions

Addendum I - H2S in Coke Oven Gas

Addendum J - Borehole Trend Graphs

Addendum K - Quarterly Progress Report (June 2021)

Addendum L - Rietspruit Discharge: Conductivity

Addendum M - Raw tar to AMCC

Addendum N - Coke Breeze Production

Addendum O - Coal, Tar and Ash Produced / Disposed

Addendum P - EMP for the Operation of the COCGW Project

Esicongweni Environmental Services

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		Abbreviations
C	-	Compliance
NC	-	Non-Compliance
WUL	-	Water Use License
AMSA	-	ArcelorMittal South Africa Limited
AMVW	-	ArcelorMittal South Africa Vanderbijlpark Works
EES	-	Esicongweni Environmental Services cc
DEA	-	Department of Environmental Affairs
DWA	-	Department of Water Affairs
DWAF	-	Department of Water Affairs and Forestry
DWS	-	Department of Water and Sanitation
IWWMP	-	Integrated Water and Waste Management Plan
RSIP	-	Rehabilitation Strategy and Implementation Program
ECA	-	Environment Conservation Act
RoD	-	Record of Decision
CETP	-	Central Effluent Treatment Plant
WUA	-	Water User Association
COG	-	Coke Oven Gas
GDACE	-	Gauteng Department of Agriculture, Conservation and Environment
GDARD	-	Gauteng Department of Agriculture and Rural Development
COCGW	-	Cleaning of Coke Oven Gas and Water (Project)
BAT	-	Best Available Technology

Steam from the quenching of hot coke at the quench tower

Esicongweni Environmental Services

COCGW RoD Audit Report

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1. INTRODUCTION

ArcelorMittal South Africa Limited (AMSA) is the largest steel producer on the African continent. ArcelorMittal operates an integrated production facility north of the town of Vanderbijlpark, Gauteng (Figure 1). The plant has been operational since 1952 and the products are sold on both the local and international markets.

AMSA Vanderbijlpark Works (AMVW) embarked on a holistic integrated environmental study during the period 2000 to 2003 to obtain a better understanding of the environmental risks that the company faced. The main driver of the company's environmental improvement initiatives has been environmental legislation that was supported by environmental management systems certified in accordance with the ISO14001 standard.

An application for a Record of Decision (RoD) was lodged with the Gauteng Department of Agriculture, Conservation and Environment (GDACE) currently known as Gauteng Department of Agriculture and Rural Development (GDARD) to undertake the Coke Oven Clean Gas and Water Project activities. The application was lodged to fulfil the requirements of the Environmental Conservation Act (ECA; No 73 of 1989), which was then repealed and replaced by the National Environmental Management Act (NEMA; No 107 of 1998) (as amended), due to the proposed activity deemed to have a potential impact on the environment. The aim of the project was to improve the combustion efficiency of the coke oven gas and to mitigate air quality impacts arising from the combustion of un-cleaned coke oven gas.

The GDACE granted ISCOR Vanderbijlpark Steel (like AMSA was named in 2004) authorisation via a RoD with reference number Gaut 002/02-03/138 on 24 May 2004.

The RoD defined the project scope as follow:

• Proposed Changes to Coke Ovens by-products Plant
• Proposed Changes to the Gas Cleaning Line
• Cleaning of Excess Process Water

The RoD authorised the activities under the following headings:

• Modification of Gas Line 1
• Primary Coolers - Gas Lines 3 & 4, and Gas Lines 6-9
• Chilled Water Station/ Coo/Ing Water Supply Facilities
• Installation of a New Pre-Decanter/ Modification of Tar Decanters
• Installation of a Gravel Filter Unit
• Upgrading of the Existing Ammonia Stills
• Installation of the New Stripper/ De-acidifier System
• Scrubbing Facilities -Gas Lines 3 & 4
• Scrubbing Facilities - Gas Lines 6-9
• Elementary Sulphur Plant combined with NH3 Cracking
• Control System

There are Specific- and General Conditions in the RoD including Reporting Requirements.

Esicongweni Environmental Services (EES) was appointed by AMSA to undertake an external audit of conditions relating to this RoD.

Esicongweni Environmental Services

COCGW RoD Audit Report

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