Over a 21-month period, Eskom's coal-fired power plants spewed pollutants that exceeded the embattled utility's already weak licence conditions almost 3200 times.
A report by US coal plant expert, Dr Ranajit Sahu, has shown how pollution from nearly all of Eskom’s coal-fired power plants "persistently" and "significantly" violated the air pollution limits stipulated in its licences.
His report, based on Eskom’s own monthly reports of emissions from its coal power plants, was commissioned by the Life After Coal Campaign, a joint campaign by Earthlife Africa Johannesburg, groundWork, and the Centre for Environmental Rights (CER).
Sahu, who has 28 years of experience in air pollution consulting and engineering, reviewed hardcopy monthly monitoring reports from 17 Eskom coal and gas power stations from April 2016 through to December 2017.
"Based on my review, and after excluding the gas plants due to incomplete data, I have determined that the coal fired power stations reported nearly 3200 exceedances of applicable daily atmospheric emissions licences limits for particulate matter (PM), sulphur oxides (SO2), and oxides of nitrogen (NOx)."
His conclusions are "conservative and underestimate the true scope of the problem because I did have access to clear and comprehensive data," he writes in the report, Eskom Power Station Exceedances of Applicable Atmospheric Emission Licence (AEL) Limit Values for PM, SO2 and NOx During April 2016 to December 2017.
“Because the applicable limits in the AEL are quite lax compared to those recommended by the World Bank Group, or those adopted by China, for example, having any excessive emissions of the AEL limits is very troubling.
"Even perfect compliance with AEL limits allows for discharges of pollution at unhealthy levels. Exceedances are even more troubling since most of these plants are located in (an) area that is already significantly impaired from an air pollution standpoint (the Mpumalanga Highveld Priority Area)."
The CER, the campaign's attorneys, term the violations not only illegal, but points out how they also mean that "Eskom is continuously endangering the health and violating the human rights of millions of people affected by this pollution.
"The exceedances relate to all three regulated pollutants for coal plants, namely SO2, NOx and PM, including soot and ash. The offending plants with the most frequent licence exceedances were Lethabo, Matla, Matimba, and Kriel.
"The plants with the highest PM exceedances were Grootvlei (at times as much as 15 times the limit), Kriel (at times as much as six times the limit), and Duvha and Lethabo (at times as much as five times the limit)," says the CER.
It argues that non-compliance with an AEL is a criminal offence, but the Department of Environmental Affairs has taken no enforcement action against Eskom.
Sahu writes that many of the exceedances are frequent at particular plants as opposed to being sporadic, indicating that the underlying causes are not being addressed by Eskom.
"It is imperative that every effort should be made to eliminate to the greatest extent possible any exceedances in heavily populated areas already impaired by air pollution," he writes.
He notes how, in some instances, Eskom provided exact duplicate reports for the same station for multiple months.
In July 2017, the CER had to use the Promotion of Access to Information Act to access monthly emission reports from Eskom.
The bulk of these reports were only received in January 2018 after Eskom’s refusal to disclose the reports under PAIA, despite multiple extensions and an appeal, was raised with the Portfolio Committee on Environmental Affairs, it says.
Last month, Eskom applied for the fourth time, for more time to comply with South Africa’s minimum emission standards (MES) – and in some cases asked for permission not to comply at all for the remaining lives of certain of its oldest and dirtiest power stations, says the CER.
"The Life After Coal campaign argues that, if Eskom’s coal plants cannot comply with South Africa’s already-weak MES, they should be decommissioned urgently, and an inclusive, transparent, and just transition plan put in place to support workers and their families."
Pollution from Eskom’s coal power stations has been estimated to cause the premature deaths of more than 2200 people every year, and to result in thousands of cases of bronchitis and asthma in adults and children annually. This costs South Africa more than R33 billion annually, through hospital admissions and lost working days.
"The crisis at Eskom provides an opportunity for a new energy system that generates cheap electricity in a way that doesn’t poison our people," says Thomas Mnguni, community campaigner for groundWork.
Eskom says its stations generally comply with the conditions of their AEL and the stipulated limits specifically in the period analysed by Sahu.
"Dr Sahu’s report illustrates that there are periods on exceedance of the emission levels but most of these exceedances are not legal non-compliances and are explainable with detailed review.
"His report also illustrates the difficulty in interpreting monitoring results without the full understanding on factors and context."
It acknowledges that emissions from its power stations can lead to negative health impacts "as can many other activities such as transport emissions, dust blow off disturbed land, etc.
"It is for this reason that Eskom has been monitoring ambient air quality in Mpumalanga for the past 30 years. Eskom does have to balance the costs of the current electricity generation with the benefits of providing affordable electricity to underpin economic activity.
"Further, electricity is the cleanest source of energy for households to use. Recognising its environmental impacts and legislative requirements, Eskom is actively working to reduce its environmental impact with its approach to improving air quality being described in the Air Quality Improvement Plan."
Its plan to mitigate the negative impacts of power station emissions includes a programme to reduce emissions through upgrades and retrofits. "The retrofits are focussed on Eskom’s higher emitting and newer power stations, and are estimated to cost over R100-billion (in nominal terms) between now and March 2030.
"For the Eskom fleet, relative particulate emissions should be reduced by 49%, relative SO2 emissions should be reduced by 52% and relative NOx emissions by 32% by 2030."
Another measure includes air quality offsets to improve air quality in communities near Eskom’s power stations by reducing emissions from domestic coal and wood burning and domestic waste burning.
"It is estimated that up to 40 000 households in Mpumalanga will be switched to cleaner energy by 2025. Over R4 billion (in nominal terms) has been allocated for the roll-out of offsets between now and March 2025."
Others include improved operational and maintenance practices at power stations "to ensure optimal operation of pollution abatement equipment and a continued reduction in emissions".
Eskom power stations in the Highveld "mostly comply with the MES for existing plants, which came into effect in April 2015.
"There are five power stations which emit slightly above the 1100mg limit. Three of these power stations, Majuba, Matla and Tutuka will be installing low NOx burners from 2021 to 2027.
"The MES for new plant standards come into effect in April 2020. These are more stringent and also apply to existing power stations, even those constructed as far back as 1970. The legislation makes provision to apply for alternate limits. Eskom is applying for alternate limits for most of the power stations."
It says ambient air quality monitoring carried out for the last 30 years by Eskom and the DEA and provincial authorities do not record exceedances of ambient air quality standards for NOx.
"To spend R2-billion per power station to reduce an emission, which is not exceeded on ground level, where people may be exposed to pollution is not deemed prudent.
"Further to this several power stations will be reducing production and or shutting down before 2030. This means that emissions have already peaked and will continue to decrease going forward. New coal plants will be required to comply with new plant standards and therefore any introduction of new coal would also ensure that there is a continued decrease in emissions."
Yesterday, Greenpeace Africa welcomed the news that Eskom has decommissioned three units of the Hendrina power station in Mpumalanga.
“Despite not having a clear plan for a just transition that will protect coal workers, shutting down units of dirty coal-fired power stations is the first clear display of action South Africa has taken against climate change and the air pollution crisis," stated Melita Steele, Greenpeace Africa’s senior climate and energy campaign manager.
"This needs to be followed through with steps that will ensure a just transition away from coal and towards clean, renewable energy production as further units are decommissioned, in line with our international commitments to the Paris Agreement."