An overview of AQM in Cape Town

Transcription

1 The City of Cape Town Atmospheric Emission Licensing System An overview of AQM in Cape Town Presented by: Ian Gildenhuys Date: Monday, 1 October, 2013 Venue: Cape Town International Convention Centre Acknowledgements to Ed Filby for assisting with the presentation

2 CONTENT: AQM Timeline CoCT AQM System Monitoring Emission Inventory Modelling & ARC GIS CERC-ADMS urban dispersion model-planning, reviewing and verification Tools for AEL Processing HR component EMI resources: Level 1, 2 s and 3 s Fee tariff structure Challenges Conclusion

3 AQ Management Timeline

4 1958 FIRST SMOKE & SO2 MONITOR 1965 APPA CAPE TOWN- AQM TIMELINE: First APCO 1997 CT Brown Haze Report 2002 CT Situation Report CT APC By-law 2000 DVTesting CT AQMP 2004 NEMA:AQA 2007 KAPS Pre-AQM 1958 HISTORICAL BACKGROUND CURRENT STAFFING SITUATION Main AP problems: COAL-FIRED TRAINS INDUSTRY- UNREGISTERED BADLY MAINTAINED FBA S HFO FIRED- POWER STATION METEOROLOGY MAIN FOCUS- COMPLAINTS REGISTER FBA S EMISSION INVENTORY DEDICATED AQM UNIT INSPECTORATE(11) DIESEL VEHICLE TESTING(6) AIR QUALITY MONITORING SERVICE LEVEL AGREEMENT 6 TECHNICIANS

5 CAPE TOWN- AQM TIMELINE: AEL function taken over by the City from DEA S 21 List of Activities & MES promulgated (2010/03/09) Repeal of APC By-law and promulgation of AQM By-law 2010: Emission standards for diesel vehicles stricter Licencing, burning of metal, dust emission and pesticide spraying 2009 Staff trained as EMI's 2011 Emissions inventory & preliminary AQModelling report completed 2012 AQM by-law review Appointment of additional staff AQMP review underway STUDIES, REPORTS AND INITIATIVES CT BROWN HAZE 1 & 2 CT AQ SITUATION ASSESSMENT CT AIR QUALITY MANAGEMENT PLAN STATE OF ENVIRONMENT REPORT KHAYELITSHA AIR POLLUTION SURVEY MORE MONITORS ADDITIONAL DVT TEAM EMISSION INVENTORY AND DATA VALIDATION REPORT

6 AQM SYSTEM INFORMATION 1. Air quality monitoring & Management 2. Emissions inventory 3. Dispersion modelling

7 AQ MANAGEMENT AND MONITORING

8 AQ MANAGEMENT KEY FUNCTIONS Ensure ambient air quality conducive to good health Implement AQM By-law and NEM:AQA Approval and regulation of fuel-burning installations Develop emissions inventory and dispersion modelling Commenting on EIA s and issuing of authorisations of AEL s for listed activities Investigate and mitigate AQ complaints Reporting of air pollution levels: ww.capetown.gov.za/airqual;

9 AIR QUALITY MONITORING LAB Maintains and manages the 13 monitoring stations within the City. Provide an accredited air quality monitoring service in accordance with the principles of ISO Requirements for testing and calibration laboratories. Coordinate and participate in support functions as required in the City of Cape Town s Air Quality Management Plan. Conduct research on Air Quality Monitoring informing the development of Air Quality Management intervention strategies.

10 AQ MONITORING STATIONS 13 ambient air quality monitoring station 56 ambient air analysers 4 monitoring stations with meteorological capabilities. Extensive communication and data logging infrastructure.

11 AQ Monitoring cont.. Network provides a fair reflection of ambient air quality throughout the City. This aids with airshed planning in relation to licensing function And assist with licensing fee determination.

12 AQ Monitoring challenges Scarce skills retention In-consistent year on year allocation of capital budget hampers planning High operational and maintenance costs Slow procurement process result in station downtime and loss of data.

13 EMISSION INVENTORY

14 MS Access based Emission Inventory Developed

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19 ARC GIS Tools

20 ARC GIS EI Fuel Burning appliances and small boilers Listed Activities Major Roads

21 Modelling: ADMS Urban/ Cambridge Environmental (CERC) The City acquired ADMS Urban dispersion modelling software for airshed planning Trained staff in its use. We then undertook an Emission Inventory validation project with CERC in the UK We appointed a Research and Information Specialist - Ed Filby We are able to use this tool to validate EIA dispersion modelling specialist studies and for airshed planning. And to assess impact of AEL applications in relation to existing listed activities in the airshed.

22 Oceanna Animal Matter Processing, Hout Bay Impact of emissions Based on fuel usage AEL info worst case scenario

23 Tools Developed in for Licensing System Review of CoCT Air Pollution By-law: Introduced Chapter on AEL Licensing Delegated authority to: Appoint AQO AQO authority to approve AEL s Can set local emission standards et al

24 Tools Cont City s ERM Department has developed an EIA Tracker system on Sharepoint IT system This facilitates inter-departmental commenting on EIA s AEL Listed activity EI database developed for internal management and tracking progress with AEL applications.

25 Tools Cont HR Capacity Building: NACA / UJ Air Quality Short Course: 6 staff; DEA Training: 4 Staff EMI Training 6 Staff initially trained as EMI s Received appointments for Grade 2 and 3 A further three staff trained last year- awaiting appointment of Grade 1 EMI and two Grade 2 s. Last two staff will receive training in Dec 13.

26 Tools Cont City adopted tariff for AEL application fees TOTAL fees determined Tariff consists of fee bands as per the DEA developed Fee Calculator. Tariff came into effect on 01 July 2012 R Fees received R Fees in progress R

27 Fee calculator implementation: Upon receipt of AEL application, AQ Team conducts a site visit before determining application fees. Assists with verification of emission sources and provides valuable insight into activity relative to surrounding premises Applicant then invited to a fee calculator meeting at AQM Unit

28 Fee calculator implementation cont..: Open and transparent process where the assessment criteria are explained, negotiated and accepted by all before signed off. Formal invoicing then follows. This can take 4 6 weeks! Application acceptance and processing follows note disjuncture with NEMAQA Sect 37

29 Challenges: determining fees Asset value determination Scale of emissions difficult for new green field applications. Existing premises require stack monitoring but what about fugitive emissions determination. Multiple sources/processes Potential mismatch between criteria guideline with actual conditions. Complex City finance invoicing system SAP IT billing system. Tracking of invoices and payments Facilities need to be registered on SAP

30 AEL Technical Challenges Biggest challenge AEL applications are often incomplete. Long delays in applicants supplying additional info. Delays in stack emissions testing and submission of reports Stack emissions reporting often do not comply with Notice No 248 Incorrect methods used. No calibration certificates supplied.

31 AEL Technical Challenges Cont.. No declaration of normal operating conditions. Averaging period problems etc. Addressed issue by writing to all local emissions testing housing and advised on S21 reporting requirements Also met with individual testing housing for oneon-one. Accreditation system for testing houses urgently needed!!! Especially with pending SAAQIS rollout

32 AEL Technical Challenges Cont.. EIA AEL relationship: EIA scoping VS reality once plant commissioned e.g. Gecco Fuels. Initial test plant used for emissions testing showed compliance but technology up-scaling tells a different storey. Potential communications breakdown when EIA competent authority is in Pretoria and LA is in Cape Town e.g. BCL

33 AEL Technical Challenges Cont.. BCL Existing plant /New Plant Scenario Apollo brick existing AEL Clamps/ New activity Ceramic Process. Can the same facility hold PAEL/Final AEL at the same time? NEMAQA does not adequately address this issue Potential communications breakdown when EIA competent authority is in Pretoria (Waste Incineration) and LA is in Cape Town e.g. BCL

34 Gecco fuels, Category 2: Petroleum Industry, Sub-Category 2.3 Fuel Oil Recycler, Philippi

35 AEL s Issued to date: PAEL s Issued ACSA Fuel storage FFS Refiners Fuel Storage, CT Harbour Final AEL s Issued ACSA Fuel Storage NGK Ceramics Ceramic Production Metlight Alloys Oceanna, Hout Bay Animal Matter Process Tydstroom Animal Matter Tydstroom Animal Matter Process SSF Milnerton Fuel storage Gecco Fuels, Fuel Oil Recycler Corobrick, Western Cape Ceramic Production Claytile & Joostenberg Brick Ceramic Production AFROX Organic Chemicals Industry Total: 9 Total: 4 In Process: 40 Applications

36 Other Challenges Loss of scarce HR skills in AQM Lab and AQM Unit New staff capacity and skill set takes time to develop Electronic Systems needed to help improve efficiencies Compliance and Enforcement is the next big hurdle to cross Need dedicated C & E EMI position

37 Conclusion: Slow but steady progress is being made Confident of reaching 31 March 2014 deadline to issue AEL s to all applicants Enjoy your stay in the Mother City!

38 Thank you