SRK Consulting: Project No: 483038 Foskor PP/CRR Page 24

BURP/JORD 483038_20190204 PP Report_Final January 2019

Annexure 8: Public Open Day Posters

Plant Overview Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

Sulphuric acid is produced in three Sulphuric Acid

Plants namely A”, B” and C” Plants. All three

plants have the same process flow as illustrated in

the adjacent image.

Phosphoric acid is produced by reacting phosphate

rock with sulphuric acid in the named New and Old

Plants respectively. As above the old and new plants

have a similar process flow as illustrated in the

adjacent image. The phosphate rock is received in

powder form mainly from the Foskor Phalaborwa mine

and limited imports.

Phosphoric Acid, Ammonia and sulphuric acid are used together

with Micronutrients, such as Zinc and Sulphur to produce

fertilizer.

The main products are Di-ammonium Phosphate (DAP) and

Mono-Ammonium Phosphate (MAP) but various other compound

fertilisers can also be produced through the addition of various

other raw materials if required.

Improvements Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

Investigated options

Replacement of cold heat exchangers and burners

Changes to catalysts Optimization Investigations

into abatement

Investigations into the

replacement of the Sulphur Acid Plants

Improvements ComplianceNot Feasible

Sulfuric Acid Plants

Phosphoric Acid and Granulation Plants

Investigated options

Identification of scrubbers

Investigations regarding waste disposal options

Investigations into efficiencies

and optimization

Source of significant waste stream

Financial limitations to implementation

Reduction of marine outfall limits

Reasons Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

Year Financialperformance

2015 R536 million loss2016 R568 million loss2017 R903 million loss2018 R782 million loss

FinancialGiven Foskor’s financial performance they are unable to secure finance for the compliance

projects.Foskor’s feasibility investigations have estimated the capital cost of compliance for the Sulphuric

Acid Plants at approximately R740 million.

Reduced marine outfall limitsInstallation of scrubbers is an option to

reduce the emissions from the Phosphoric Acid and Granulation Plant. However it results in increased effluent.

Foskor’s effluent disposal limits have also been reduced in terms of the ICMA

Removal of Fluoride from the waste stream is a viable and feasible option but as above given Foskor’s current financial situation, they are unable to secure finance for the project.

Negative socio-economic impacts associated with closure and decommissioningFoskor Richards Bay currently employs 630 permanent staff members – this doesn’t include

contractors and service providers. The indirect have not been quantified but are expected to be substantial.

Foskor Phalaborwa is reliant on Foskor Richards Bay for raw materials. Phalaborwa cannot continue to operate in the absence of the Richards Bay operations. Therefore closure of Richards Bay would result

in closure to Phalaborwa and the associated impacts to the Palaborwa community also.

Shut Down Periods Foskor cannot implement

compliance projects outside planned shut down periods without seriously impacting on the sustainability of the business. Therefore even if

finance can be obtained it will take some time before

compliance projects can be implemented.

Space Constraints One of the alternatives to

achieve compliance includes decommissioning

the A&B plants and replacing these with a

single new plant. This will however require Foskor to

purchase additional land that will take some time if financing can be obtained.

Findings of the AIR Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

SO2 - Simulated SO2 concentrations for Foskor’s emissions are below

the NAAQS for all three scenarios for all three averaging periods.

Changes in ambient SO2 concentrations between the three scenarios

does not affect compliance with the NAAQS.

PM - While Foskor is not applying for postponement at any sources for

PM, PM concentrations are affected by SO2 concentrations. The

baseline emissions from Foskor result in low ground-level

concentrations of PM (< 4% of the limit. Observed PM concentrations

are however above the NAAQS at Brackenham and the CBD. This

illustrates the impact of other sources of PM on ambient concentrations.

SO3 - Simulated hourly and annual concentrations of SO3 are well

below the NAAQS (<17%) at all monitoring stations. Changes in

ambient SO3 concentrations between the three scenarios are minor and

have no effect on compliance with the NAAQS.

NH3 - Simulated hourly and annual concentrations of NH3 are well

below the NAAQS (<10%) at all monitoring stations. Foskor will not be

seeking postponement for NH3 and therefore only the baseline applies.

The RBCAA does not monitor SO3 so this data is not available for

comparative purposes.

HF - Simulated hourly and annual concentrations of HF are well below the

NAAQS (<20%) at all monitoring stations. Changes in ambient HF concentrations

between the three scenarios does not affect compliance with the NAAQS. The

RBCAA does not monitor HF so this data is not available for comparative

purposes.

Roadmap to compliance

Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in

Richards Bay

There are 4 alternatives available to Foskor. Foskor commits to making a

decision between these 4 alternatives by July 2021.

Option 1 Complete DecommissioningActivity Completion DateBoard Decision on Selected Option Thu 01/07/21Last order of raw materials Fri 23/11/29Cease production and Cool down Fri 29/03/30Plant Isolated and Made Safe Sun 31/03/30

Request for Proposals to dispose ofPlant

Sun 31/03/30

Dismantle and remove equipment Thu 29/01/32Rehabilitation of site Thu 02/11/34Site hand over Thu 14/12/34

Option 2 Partial DecommissioningActivity Completion DateBoard Decision on Selected Option Thu 01/07/21C plant

Call for tenders to replace C Plant Catalyst Mon 29/04/24Delivery of Catalyst Mon 17/02/25Replace C Plant Catalyst Mon 31/03/25C Plant Compliant Task Mon 31/03/25

A&B PlantCall for Tenders to sell A&B plant equipment Sun 31/03/30

Cease production at A&B Plant and dispose ofcatalyst Sun 31/03/30

Dismantle and remove A&B Plant Thu 29/01/32Rehabilitation of A&B Plant site Thu 30/12/32Site available for sale or use by Foskor Thu 10/02/33

Option 3 Improvements

Option 4 Replacement of A&B Plants

Activity Completion DateBoard Decision on Selected Option Thu 01/07/21C plant

Call for tenders to replace C Plant Catalyst Mon 29/04/24Delivery of Catalyst Mon 17/02/25Replace C Plant Catalyst Mon 31/03/25C Plant Compliant Task Mon 31/03/25

A&B PlantTender process to order A and B plant

ConverterThu 11/08/22

Replace A plant converter Thu 28/12/23Detailed Design Thu 15/12/22Equipment Manufacturing Thu 16/11/23Installation and commissioning Thu 28/12/23

Replace B plant converter Mon 31/03/25Design Finalisation Thu 08/02/24Equipment Manufacturing Thu 09/01/25Installation and commissioning Mon 31/03/25

Activity Completion DateBoard Decision on Selected Option Thu 01/07/21Construction of D Plant

Tender Award & Contractnegotiations Mon 04/11/24

Detailed Design Mon 06/10/25Equipment Manufacturing Mon 22/02/27New D Plant Install Equipment Mon 26/11/29

D Plant Commissioning Sun 31/03/30A&B Plant

Call for Tenders to sell A&B plantequipment Sun 31/03/30

Cease production at A&B Plant anddispose of catalyst Mon 07/09/26

Dismantle and remove A&B Plant Mon 24/01/28Rehabilitation of A&B Plant site Mon 25/12/28

C plantTender process to order new Catalyst Mon 29/04/24Delivery Catalyst Mon 17/02/25Replace C Plant Catalyst Mon 31/03/25C Plant Compliant Mon 31/03/25

Public Participation Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

STAKEHOLDERS NOTIFICATION• Make report available for I&AP’s information• Distribute letters, adverts, inform I&AP of report availability & that comments can be submitted to NAQO

PREPARATION OF DRAFT

MOTIVATION

PUBLIC PARTICIPATION PROCESS

COLLATE COMMENTS INTO COMMENT & RESPONSE REPORTS (CRR)

PROJECT ANNOUNCEMENT(21 DAY PUBLIC COMMENT PERIOD)

• Distribute letter, Background Information Document and comment sheet • Advertisements and site notices• Opportunity for I&APs to comment online, by email, fax, tel, comment

sheets

SUBMIT FINAL MOTIVATION DOCUMENT & UPDATED CRR TO NATIONAL AIR QUALITY OFFICER (NAQO) & AIR QUALITY OFFICER (AQO)

May

–Se

ptem

ber 2

018

Janu

ary

2019

Dece

mbe

r 20

18

PUBLIC OPEN DAY

UPDATE MOTIVATION REPORT & AIR

TECHNICAL PROCESS

COMMENT ON DRAFT(30 DAY PUBLIC COMMENT PERIOD)

•Distribute letter, Motivation Report, AIR and comment sheet •Opportunity for I&APs to comment online, by email, fax, tel, comment sheets

PREPARATION OF DRAFT AIR

Nov

embe

r 201

8

Comments Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of

the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions Standards for the Foskor Plant in Richards Bay

For comments on the Draft AIR and Motivation Report to be incorporated into the Final submission to DEA, they should be

submitted by:

Comments can be submitted: • At the public open day • By calling SRK • Electronically via the link https://arcg.is/1meCKj• In writing via mail, email or fax

Tel: +27-31-279-1200; Fax: +27-31-279-1204 Email: RBellusci@srk.co.za

Air Quality Complaints for Richards Bay can be submitted to the Richards Bay Clean Air

Association as follows: http://www.rbcaa.org.za/

COMMUNICATIONS OFFICERSandy Camminga

035 786 0076083 515 2384

info@rbcaa.co.zacomplaints@rbcaa.co.za

To become a supplier to Foskor submit your company profile detailing the product or service offering and BEE certificate reflecting status to KhethoG@foskor.co.za for Acid Division and Jacobethm@foskor.co.za for Mining Division.

For more information regarding employment opportunities visit the Foskor Website

http://www.foskor.co.za

To Report any unethical behaviour: Free-Call: 0800 FOSKOR (367567)

Free-Fax: 0800 00 77 88Email: foskor@tip-offs.comSMS: 32840 (R1 per SMS)Website: www.tip-offs.com

Findings of the AIR

Application for Postponement from Compliance Timeframes in terms of Regulation 11 of Section 21 of the National Environmental Management: Air Quality Act (No. 39 of 2004) Minimum Emissions

Standards for the Foskor Plant in Richards Bay

SO2 - Simulated SO2 concentrations for Foskor’s emissions are

below the NAAQS for all three scenarios for all three averaging

periods. Changes in ambient SO2 concentrations between the three

scenarios does not affect compliance with the NAAQS.

PM - While Foskor is not applying for postponement at any sources for

PM, PM concentrations are affected by SO2 concentrations. The

baseline emissions from Foskor result in low ground-level

concentrations of PM (< 4% of the limit. Observed PM concentrations

are however above the NAAQS at Brackenham and the CBD. This

illustrates the impact of other sources of PM on ambient

concentrations.

SO3 - Simulated hourly and annual concentrations of SO3 are well

below the NAAQS (<17%) at all monitoring stations. Changes in

ambient SO3 concentrations between the three scenarios are minor

and have no effect on compliance with the NAAQS.

NH3 - Simulated hourly and annual concentrations of NH3 are well

below the NAAQS (<10%) at all monitoring stations. Foskor will not

be seeking postponement for NH3 and therefore only the baseline

applies. The RBCAA does not monitor SO3 so this data is not available for comparative purposes.

HF - Simulated hourly and annual concentrations of HF are well below the

NAAQS (<20%) at all monitoring stations. Changes in ambient HF

concentrations between the three scenarios does not affect compliance with

the NAAQS. The RBCAA does not monitor HF so this data is not available for comparative purposes.