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ENVIRONMENTAL IMPACT ASSESSMENT REPORT
FOR THE FOR THE PROPOSED IMPLEMENTATION OF
AN ALTERNATIVE FUELS AND RESOURCES
PROGRAMME FOR KILN 3 AT THE
HOLCIM SOUTH AFRICA DUDFIELD PLANT,
NORTH WEST PROVINCE
Compiled by
Bohlweki Environmental(Pty) LtdPO Box 11784Vorna ValleyMIDRAND1686
In association with the following specialists
Dr D Baldwin and Ms M Chettle
Environmental & Chemical Consultants
Dr L Burger and Ms R Thomas
Airshed Planning Professionals
Mr F Joubert
Sustainable Law Solutions
Dr R Meyer
CSIR (Environmentek)
Ms N Wattel and Mr A van den Heever
Stewart Scott International
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Executive Summary 31-Aug-04i
EXECUTIVE SUMMARY
1. INTRODUCTION
Holcim (South Africa) (Pty) Ltd, formerly known as Alpha (Pty) Ltd, is one of
South Africa’s key producers of cement, stone and ready mixed concrete for the
construction industry. Holcim South Africa currently operate three cement plants
in South Africa, one of which is the Dudfield plant, located approximately 20 km
west of Lichtenburg in the North West Province. At Dudfield plant, limestone
(source material) and coal (fuel) are currently the primary raw materials utilised
in the manufacture cement.
The Dudfield plant is situated on a limestone deposit that is mined and milled as
feedstock to the plant. The coal that is utilised in its kilns as the main energy
source for converting the limestone raw meal to manufacture clinker (the base
feedstock for cement), is transported to the plant by rail.
Holcim South Africa are considering implementing the global trend of replacing a
portion of the fossil fuel (coal) used as the energy source with alternative, waste-
derived fuels. That is, the introduction of an Alternative Fuels and Resources
(AFR) programme is proposed for the Dudfield Plant. The AFR project proposes
the replacement of traditional, non-renewable, fossil-based fuel (coal) with
alternative waste-derived fuels and raw materials within the existing Dudfield Kiln
3 at the existing Dudfield plant. This programme aims to reduce traditional fossil
fuel usage by up to 35% or more.
1.1. Motivation for the Proposed Project
The process of cement manufacture is energy intensive. The average energy
required to produce 1 000 tons of cement clinker is approximately 130 tons of
coal. As a result, Holcim South Africa currently requires approximately
350 000 tons of coal per annum to operate their kilns across the country.
The Holcim commitment to promoting development that is sustainable and at the
least cost to future generations has resulted in a drive to substitute a portion of
the traditional non-renewable fossil fuels (that is, coal) used in the production of
cement with suitable alternative waste-derived materials/fuels. This has resulted
in the need to identify alternative renewable fuel sources which would provide
similar energy (i.e. calorific value) when burnt to that provided by coal, would not
be detrimental to the process in the kiln or the product produced, and would be
less costly than coal in the long-term.
The use of alternative fuels and raw materials that are based on selected waste
products and by-products generated from industrial and domestic sources
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Executive Summary 31-Aug-04ii
addresses this need, as much of this waste is chemically similar to coal. The use
of this waste as a fuel presents the opportunity to reduce the environmental
impacts of using a non-renewable resource (coal) in the cement manufacturing
process, as well as to reduce the amount of waste material that would
traditionally be disposed of to landfill or incinerated. The utilisation of AFR in the
cement industry is in-line with initiatives of National Government, particularly the
National Waste Management Strategy (NWMS) which focuses on waste
prevention, waste minimisation and the re-use of waste materials. The practice
of employing alternative fuels in cement plants promotes materials recovery and
recycling by the recovery of energy as well as the mineral components from
waste. The use of waste-derived fuels in a cement kiln therefore, reduces fossil
fuel use, and maximises the recovery of energy, without any significant change in
emission levels.
The use of alternative fuels is a well-proven and well-established technology in
the European, American (both North and South) and Asian-Pacific cement
industries. Experience at international plants has shown that alternative fuels can
successfully replace traditional fossil fuels with no adverse impact on the
environment, safety or health of employees and communities, or on the quality of
the final cement product.
1.2. Infrastructure Requirements for the Proposed AFR Programme
The recent upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class
production facility (with a production rate of 3 500 tons per day) included the
installation of a ‘low NOx’-multichannel primary burner (allowing multiple energy
sources to be introduced into the kiln), a pre-calciner, and a bag filter with a
design particulate emission limit of 30mg/Nm3. This upgrade has also resulted in
this plant being in a position to receive and utilise alternative fuels as an energy
source, together with coal.
Kiln 3 will never completely move away from utilising coal as an energy source.
Coal is a constant fuel with a known calorific value, and the AFR programme is
aimed at substituting a portion of the total coal requirement. In order to
successfully operate a facility on an on-going basis, the source of fuel is required
to be stockpiled or stored on site. With the proposed introduction of the AFR
programme, Dudfield plant would be required to store both coal and AFR on site.
Dudfield plant has an existing stockpile site for coal. A second designated area
would be required for the storage of AFR on the site. AFR streams are proposed
to be delivered directly to the kiln, and an on-site storage facility would be
required to accommodate/store an approximate 2-day reserve capacity to ensure
that sufficient volume of AFR is available as feedstock for an extended period. In
order to store sufficient capacity to replace approximately 35% of the fuel
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Executive Summary 31-Aug-04iii
currently used at Kiln 3, suitable tanks, silos and bunded/walled areas would be
required to store the waste-derived fuels. An AFR fuel storage area of
approximately 1 600 m2 is proposed to be established within the boundaries of
the existing Dudfield plant.
The proposed AFR storage area is a currently vacant area approximately 20 m to
the north of Kiln 3 to allow for safe and secure feeding of the AFR material from
the storage area to Kiln 3. The demarcated area has been extensively disturbed
by activities associated with the cement manufacture process at the plant,
including the construction activities associated with the recent upgrade of Kiln 3.
The area is devoid of vegetation, and is on level terrain.
The storage facility would be required to be designed according to national
construction, and fuel handling and storage requirements. The area would be
required to have a concrete floor, be bunded to contain any water accumulating
within the storage area, and have a roof to exclude rainwater from entering and
accumulating within the storage facility. Appropriate drainage facilities would be
required to be in place that would facilitate the separation of stormwater and
runoff from the area.
The storage area would be accessed by a levelled and sealed access road, and
would include sufficient area for vehicles to off-load, and manoeuvre, if required.
It is proposed that initially the kiln would be in a position to utilise approximately
70 tons of AFR a day, which represents between 2 and 3 vehicle loads of AFR per
day arriving at the site. It is proposed that in the long-term the volume of AFR
utilise per day could increase to approximately 240 tons per day, which amounts
to 6 – 8 vehicles per day, and the access road and storage area would be
required to support this.
Appropriate fire fighting systems and monitoring equipment would be required to
be installed to service the AFR storage area.
An AFR on-site laboratory would be required at Dudfield plant for control
tests/analyses to be conducted to verify the content of the AFR arriving at the
plant with the 'fingerprint' analyses that were completed at initial acceptance of
the waste (by an external (off-site) accredited laboratory). The Dudfield plant
AFR laboratory would, therefore, have limited capabilities, and will only verify that
the fingerprint matches the waste delivered.
1.3. Waste-derived Materials which can be utilised as Alternative
Fuels
Waste materials that the global cement industry has utilised as alternative fuels
include scrap tyres, rubber, paper waste, waste oils, waste wood, paper sludge,
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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sewage sludge, plastics and spent solvents, amongst others. Similar waste
materials are proposed to be used as fuel in South Africa, together with other
selected wastes that are considered suitable and desirable (including industrial
hydrocarbon tars and sludges). These wastes could potentially be sourced from a
variety of sources from a variety of geographic locations. Only those waste-
derived fuels that meet the stringent standards set by Holcim will, however, be
considered and accepted for use in the kiln.
The use of alternative fuels is technically sound as the organic component is
destroyed and the inorganic component is trapped and combined in the cement
clinker forming part of the final product. Cement kilns have a number of
characteristics that make them ideal installations in which alternative fuels can be
valorised and burnt safely, such as:
• High temperatures – exceeding 1 400°C
• Long residence time – in excess of 4 seconds
• Oxidising atmosphere
• High thermal inertia
• Alkaline environment
• Ash retention in clinker – fuel ashes are incorporated in the cement clinker,
and there is no solid waste by-product
While many waste streams are suitable for use as alternative fuels or raw
materials, there are others that would not be considered for public health and
safety reasons. No materials that could compromise the environment, the health
and safety of employees or surrounding communities, or the performance of the
cement would be considered for use as a fuel. Strict sampling and testing
procedures would be required to be put in place at the Dudfield plant to ensure
that undesirable fuels and raw materials (such as anatomical hospital wastes,
asbestos-containing wastes, bio-hazardous wastes, electronic scrap, explosives,
radioactive wastes, and unsorted municipal garbage) are excluded from the AFR
programme.
2. ENVIRONMENTAL STUDIES AND PUBLIC PARTICIPATION
As the introduction of AFR at Dudfield will result in a change to a scheduled
process, as defined in the Air Pollution Prevention Act (No 45 of 1965), Holcim
South Africa requires authorisation from the North West Department of
Agriculture, Conservation and Environment (NW DACE) for the undertaking of the
proposed project. This Environmental Impact Assessment (EIA) process for the
proposed introduction of an AFR programme at Kiln 3 at the Holcim South Africa
Dudfield plant has been undertaken in accordance with the EIA Regulations
published in Government Notice R1182 to R1184 of 5 September 1997, in terms
of the Environment Conservation Act (No 73 of 1989), as well as the National
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Executive Summary 31-Aug-04v
Environmental Management Act (NEMA; No 107 of 1998). This EIA aimed to
identify and assess potential environmental impacts (both social and biophysical)
associated with the proposed project. Mitigation and management measures
have been proposed, where required.
In undertaking the EIA, Bohlweki Environmental were assisted by a number of
specialists in order to comprehensively assess the significance of potential
positive and negative environmental impacts (social and biophysical) associated
with the project, and to propose appropriate mitigation measures, where
required. These specialist studies included:
• Air quality assessment
• Assessment of the suitability of waste as an alternative fuel resource, and
impacts pertaining to AFR management, storage, transportation etc
• Assessment of surface- and groundwater impacts
• Legal review
A comprehensive public participation process was undertaken as part of the EIA
process, and involved the consultation of individuals and organisations
throughout the broader study area representing a broad range of sectors of
society. This consultation included telephonic interviews, focus group meetings,
interest group meetings, individual meetings/interviews, public meetings and key
stakeholder workshops, through documentation distributed via mail, and via the
printed media throughout the EIA process. Issues and concerns raised during the
EIA process were recorded and captured within an Issues Trail.
3. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE
PROPOSED PROJECT
The major environmental issues associated with this proposed project, therefore,
include:
• impacts associated with emissions to air from the plant;
• impacts associated with the transportation of AFR to Dudfield plant;
• impacts associated with the storage of AFR on site for a limited period;
• impacts on the social environment;
• suitability of waste as an alternative fuel resource; and
• potential project benefits.
These are discussed in more detail below.
According to the US Air and Waste Management Association's (A&WMA) Air
Pollution Control Manual, the use of wastes as a fuel and a raw material in
cement kilns is a reliable and proven technology, offering a cost-effective, safe
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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and environmentally sound method of resource recovery for many types of
hazardous and non-hazardous wastes (http://gcisolutions.com/dgawma01.htm).
Conditions needed to manufacture cement (high temperature, turbulence and
long gas residence times) are the same conditions required for total destruction
of hazardous waste. Cement kilns burn hotter, have longer gas residence times,
and are much larger than other commercial thermal treatment facilities. These
advantages, together with the degree of mixing in the kiln, make cement kilns an
excellent technology for recovering energy from hazardous and non-hazardous
waste (www.ckrc.org/issues/99475523.html).
Results of research undertaken world-wide by the cement industry and
independent institutions (such as the US EPA) have indicated that the impacts
associated with the introduction of an AFR programme in cement kilns does not
impact significantly on the environment when compared to the use of traditional
fossil fuels. However, this is reliant on appropriate management of waste,
including the classification, selection, handling and storage thereof. Therefore,
this EIA has placed emphasis on the identification of suitable wastes as
alternative fuels and the waste management requirements associated with the
introduction of an AFR programme at Dudfield plant.
3.1. Impacts Associated with Emissions to Air from the Plant
Releases from the cement kiln are a result of the physical and chemical reactions
of the raw materials and from the combustion fuels. Typical air pollutants from
cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx),
inhalable particulates (PM10), heavy metals, organic compounds and dioxins and
furans.
During the EIA process, concern was raised regarding the potential impacts
associated with dust, and dioxins and furans and the health risk posed to local
communities. From the results of the specialist study undertaken as part of this
EIA, it is anticipated that an impact of low significance on air emissions will result
with the introduction of an AFR programme at Kiln 3 at Dudfield plant as the
emission levels remain below the DEAT guidelines.
The exit gases from Kiln 3 are de-dusted in bag filters, and the dust returned to
the process. Therefore, dust levels associated with this process are low and will
not impact significantly on the surrounding environment. This will continue to be
the case with the introduction of an AFR programme.
Dioxins and furans are a family of persistent organic chemicals detectable in trace
amounts throughout the environment. The US EPA, international Agency for
Cancer Research and US Department of Health report that excessive exposure to
2,3,7,8-tetrachlorodibenzo-p–dioxin (2,3,7,8-TCDD) can cause of wide range of
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very harmful human health effects, including cancer (EPA, 2004). Studies by the
US EPA and French Academy of Sciences have, however, indicated that it is highly
unlikely that dioxins would increase cancer incidence in people at the low
exposure levels commonly encountered in the environment or from food (Rotard,
1996), and that no fatal case associated with these compounds has ever been
reported (Constans, 1996).
Dioxins can be formed from any burning process, and cement kilns are no
exception. The potential for dioxin formation in cement manufacture is a function
of raw materials and kiln technology, and is not related to the types of fuel used.
Dioxin emissions are generally in the range of detection limits and the level of
emissions can depend on the type of kiln technology employed. “Cement kilns
control dioxin formation by quenching kiln gas temperatures so that gas
temperatures at the inlet to the particulate matter control device are below the
range of optimum dioxin/furan formation” (EPA, 2004).
The cement industry has been more successful than any other in reducing
emissions of dioxins and furans. Through intensive research, an understanding of
the nature of dioxin formation in combustion emissions has been established, and
they have succeeded in learning how to reduce those emissions. As a result since
1990, dioxin emissions from kilns that recover energy from hazardous waste have
been reduced by 97%. This has been corroborated by independent research
undertaken by the US EPA (www.ckrc.org/ncafaq.html).
Conclusions of the specialist air quality study undertaken as part of this EIA (refer
to Chapter 6) are in agreement with these international findings and indicate that
the introduction of an AFR programme at Kiln 3 at Dudfield plant will not have a
significant impact on air quality.
In order to monitor emissions from Dudfield plant, Holcim South Africa has
installed state-of-the art OPSIS continuous emission measuring equipment that
is linked to the kiln operating system. The equipment currently measures 12
emission streams on a continuous basis, with a further annual measurement of
12 heavy metals and dioxins and furans. Emission levels will be subject to the
prescribed requirements of the Stack Registration Permit issued by CAPCO.
Alarms are in place in order to indicate if any emission approaches its limits, thus
allowing for immediate corrective action to be taken. All emission data captured
by the OPSIS equipment will be available to CAPCO for auditing purposes.
3.2. Impacts Associated with the Transportation of AFR to Dudfield
Plant
Issues surrounding the transportation of AFR to Dudfield plant were identified
through the EIA process, including impacts on traffic volumes and the potential
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disruption to the daily movement patterns of the local population (particularly
residents in Lichtenburg, the Dudfield village and surrounding farming
communities), as well as safety risks to human health and the environment
associated with accidents and spillage of waste. A long-term scenario of six (6)
additional trucks per day transporting AFR to Dudfield plant is anticipated.
Specialist studies undertaken indicate that this will result in a 1% increase in the
traffic volume on the access routes to Dudfield plant, a very small growth in
traffic which is considered to be insignificant. Therefore, impacts in terms of
traffic growth and disruption to traffic patterns are anticipated to be of low
significance. In order to ensure that this impact is minimised, preferred routes to
haul waste to the Dudfield plant have been recommended. These correspond
with those currently being utilised by traffic travelling to Dudfield plant.
In order to minimise the risk to human health and the environment as a result of
potential accidents and spillage of waste, it is essential that appropriate
management and emergency response procedures be in place for the
transportation of AFR to Dudfield. In the event of an accident, the vehicles are
equipped with spill-control kits and action should be taken as soon as possible in
order to contain spillages while waiting for backup. The transport of waste must
be supported by a HazMat Emergency Response team in order to contain and
clean up any spill, in order to minimise impacts on the environment and
surrounding communities.
3.3. Impacts Associated with the Storage of AFR on Site for a Limited
Period
In order to successfully implement the AFR programme at Dudfield plant's Kiln 3,
the feed is preferably required to be of an appropriate volume to supply a
constant flow over an extended period. This minimises the need to adjust the
kilns operating parameters and thus reduces potential risks to the environment.
This, therefore, implies that smaller volume and irregular waste streams should
either not be accepted at Dudfield, or would need to be pre-processed to achieve
a uniform and constant fuel source at an appropriate volume. This pre-treatment
in not anticipated to be undertaken at Dudfield plant.
For the AFR streams that would be delivered directly to the kiln, an on-site
storage facility would need to be provided to accommodate/store an approximate
2-day reserve capacity. The appropriate management of the storage of waste-
derived alternative fuels will minimise environmental impacts and the potential
for pollution of the soil and groundwater. Without the implementation of
appropriate management measures, this impact is potentially of high significance.
The storage of fuels, storage and handling of AFR must be undertaken in an
appropriate manner, as stipulated in this report, to avoid spillage and leaching
and to limit fugitive emissions, odour and noise to acceptable levels. In addition,
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the amount of AFR stored on site must be appropriately managed in terms of the
operational requirements of the plant, and should be based on a just-in-time
principle.
Storage areas for all alternative fuels and resources must be constructed
according to national engineering standards and specifications required by the
relevant National and Provincial Government Departments. These should have a
concrete floor, should be properly bunded, and if required for operational
reasons, should be covered by a permanent roof structure. The volume of the
bunded area should at least be such that it can contain a 1:50 year rainfall event
over the surface area of the storage area. The concrete base will minimise, if not
totally exclude, leachate infiltration into the groundwater.
3.4. Impacts on the Social Environment
The Holcim Dudfield Plant is located approximately 18 km west of Lichtenburg,
which is the closest town to the facility. The area surrounding Dudfield plant is
sparsely populated, typical of a rural farming community. The greatest
population density in the immediate area surrounding the plant is Dudfield
Village, where approximately 200 people reside. The village is located
approximately 1 km south-west of the plant. Impacts to or the disturbance of
surrounding communities already exist, and have done so since the initial
construction of the facility more than 50 years ago.
Potential impacts on the social environment associated with the introduction of an
AFR programme at Dudfield plant identified and assessed within this EIA include:
• disruption in daily living and movement,
• impacts on public health and safety,
• impacts on infrastructure and community infrastructure needs,
• local and intrusion impacts
• regional benefits.
As impacts in terms of traffic growth and disruption to traffic patterns are
anticipated to be of low significance, no significant impact on daily living and
movement patterns of the local population is anticipated. Risks to human health
are associated with potential vehicle overloading, accidents and spillage of waste
during transportation of the AFR. With the implementation of appropriate
management and emergency response procedures for the transportation of AFR
to Dudfield, this potential impact is considered to be unlikely to occur and of low
significance.
Specialist studies have indicated that no risk to human health is anticipated with
the introduction of an AFR programme as a result of air emissions. Risk
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assessments undertaken internationally have shown that the use of waste
(hazardous and non-hazardous) as fuel in cement kilns poses no increased risk to
human health and the environment (www.ckrc.org/ncafaq.html).
Potential health and safety risks to employees has been identified as a potentially
significant impact. However, with the provision of appropriate precautionary
measures such as strict acceptance procedures, accurate laboratory testing, data
sheets, training, controls, procedures, health monitoring, facility design and
emergency response planning, the potential impacts on the health and safety of
employees will be managed to acceptable levels. In addition, it is important that
relevant safety information is provided to sub-contractors and visitors to the
premises in order to ensure their safety.
Limestone mining and cement manufacture are two of the major economic
activities currently undertaken in the area, providing employment to members of
the local community. The continued operation of the Dudfield plant in an
environmentally and economically sustainable manner will secure these
employment opportunities in the long-term. This is considered to have a positive
impact of high significance on the region.
3.5. Suitability of Waste as an Alternative Fuel Resource
The selection, acceptance and appropriate management of the waste-derived fuel
are critical to the success of this project and its operations. It is essential that
AFR management be carried out in a manner that does not impact on human
health and well-being and the environment.
The management protocol for the utilisation of waste as a alternative fuel follows
a 'cradle to grave' approach. This means that it is the responsibility of Holcim
South Africa to ensure that the alternative fuels and resources are appropriately
managed, from identification of potential fuels to utilisation of the fuel in the kiln
and the control of any emissions from the kiln.
In order to determine the suitability of using AFR in the kiln it is critical to
identify, understand and manage the factors that could potentially create an
impact on health, safety or the environment. In addition, there can be no
compromise on the quality of the clinker and cement produced. Therefore, the
types and nature of the AFR materials and their respective management
procedures that would be acceptable, as well as the limits on specific elements,
need to be specified and adhered to.
The primary management considerations required to ensure the total 'cradle to
grave' management of AFR include:
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• AFR identification and acceptance procedures
• Documentation
• Packaging and labelling
• Loading at the generator’s premises
• Transportation
• Acceptance procedures at Dudfield plant
• Offloading
• Handling, storage on-site and feeding into the kiln
• Characteristics of the products and, if produced, any by-products from the kiln
In the identification of appropriate sources of AFR, the waste management
hierarchy needs to be taken into consideration. Simply stated, the recycling or
re-use of a waste stream must take preference over the treatment or disposal of
waste, where practical. This principle seeks to ensure that the most appropriate
management processes are selected to manage waste.
In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types
have been identified as unacceptable for an AFR programme at Dudfield. These
wastes will be refused as potential AFR for the following reasons:
• Health and safety issues (waste streams that represent an unacceptable
hazard from an environmental, occupational health or safety point of view).
• To promote adherence to the waste management hierarchy.
The are a variety of products or wastes that should not be processed or utilised
as AFR in the kilns. These include the following:
• Selected extremely toxic ('high risk') wastes, e.g. waste containing free
asbestos fibres and pure carcinogens, which will pose an unacceptable
occupational health and safety risk.
• Wastes that contain unacceptable levels of selected components that will
impact on the kiln performance, the quality of the clinker and cement and
adversely impact on the emissions from the kiln. These can include waste
with unacceptable levels of some heavy metals, e.g. mercury and lead, high
levels of halogenated hydrocarbons, etc.
• Unsorted domestic wastes (municipal garbage) because of the presence of
small amounts of hazardous materials and various metals, etc.
• Small-volume hazardous wastes from households (fluorescent lamps,
batteries etc.).
• Non-identified or insufficiently characterised wastes.
Bearing the exclusionary criteria from the assessment of waste steams in mind,
the list of wastes that are deemed unacceptable for AFR purposes in terms of the
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Executive Summary 31-Aug-04xii
Holcim Group AFR Policy (Holcim Ltd, 2004) is supported. These unacceptable
wastes consist of the following:
• Anatomical hospital wastes (without pre-treatment)
• Asbestos-containing wastes
• Bio-hazardous wastes such as infectious waste, sharps, etc. (without pre-
treatment)
• Electronic scrap
• Whole batteries
• Non-stabilised explosives
• High-concentration cyanide wastes
• Mineral acids
• Radioactive wastes
• Unsorted general/municipal/domestic waste
With the correct management and monitoring procedures in place, the utilisation
of AFR in the manufacture of cement could substitute a portion of the fuel load
requirement for Dudfield Kiln 3 and would not represent a significant risk to
human health and the environment.
Wastes that are acceptable as AFR for use by Kiln 3 as an alternative fuel source
include non-hazardous and hazardous wastes such as, but not limited to scrap
tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and
spent solvents.
3.6. Project Benefits
The utilisation of alternative fuels in the cement industry is in-line with initiatives
of National Government, particularly the National Waste Management Strategy
(NWMS) which focuses on waste prevention and waste minimisation. The
practice of employing alternative fuels in cement plants promotes the materials
recovery and recycling industry, which is in line with the principles of the NWMS.
Where recycling of waste is not possible, landfill or incineration is the most
common disposal practice available for many wastes. The introduction of an AFR
programme would assist in the reduction in the amount of waste required to be
disposed of to landfill or other means, and assist in the reduction of greenhouse
gas emissions. The use of waste-derived fuel as AFR in cement kilns provides a
service to society by dealing safely with wastes that are often difficult to dispose
of in any other way (e.g. scrap tyres; www.ckrc.org/issues/993135035.html).
Of particular concern in South Africa is the disposal of scrap tyres to landfill. The
SATRP (South African Tyre Recycling Project) are investigating alternate solutions
to deal with the scrap tyre problem in South Africa. Government is presently
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promulgating legislation to discourage the inappropriate disposal of scrap tyres.
As the number of scrap tyres generated in South Africa is estimated at ~10
million per annum, with only ~ 2 million being used to produce recycled rubber
and recycled products the need for an appropriate disposal method is critical.
The use of scrap tyres as an alternative fuel offers an environmentally acceptable
and cost effective option of managing the excess scrap tyre problem in South
Africa, as the landfilling of scrap tyres is no longer an acceptable practise.
The nature of the cement manufacture process makes waste suitable for the use
as AFR by ensuring full energy recovery from various wastes under appropriate
conditions. Any solid residue from the waste then becomes a raw material for the
process and is incorporated into the final clinker. This, therefore, results in the
conservation of non-renewable natural resources, as well as a reduction in the
environmental impacts associated with mining activities.
Depending on the quantity of the waste-derived fuel available and the energy
content of this fuel, Holcim South Africa will be able to replace between 35 - 50%
of their traditional coal-based fuel with AFR. Including the kiln efficiency
upgrade, a total reduction of between 40 000 and 90 000 tons of coal/annum is
estimated by Holcim for Kiln 3.
3.7. Conclusions
The introduction of the AFR programme at Kiln 3 of the Dudfield plant provides
the opportunity to:
• Recover energy from combustible wastes and inorganic materials.
• Conserve non-renewable resources such as fossil fuels, i.e. coal and oil, and
inorganic materials such as iron ore.
• Reduce the volume potentially polluting materials being disposed by landfill
and reducing overall waste volumes to landfill.
For these benefits to be fully realised, strictly controlled management procedures
are required to be implemented for the entire AFR programme process. These
management procedures should be detailed in an Environmental Management
Plan (EMP) which includes inputs from the EIA and the permitting authorities.
This will ensure that the waste materials are managed from 'cradle to grave' and
all potential adverse impacts are managed to acceptable levels.
As Dudfield plant is an ISO 14001 accredited operation, the EMP would be
required to form part of the independently audited ISO 14001 programme.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xiv
TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY i
TABLE OF CONTENTS xiv
LIST OF TABLES xx
LIST OF FIGURES xxiii
LIST OF PHOTOGRAPHS xxiv
ACRONYMS AND ABBREVIATIONS xxv
1. INTRODUCTION 1
1.1. Motivation for the Proposed Project 1
1.2. Overview of the existing Dudfield Plant and the proposed
AFR Programme
2
1.2.1. Overview of Dudfield Plant and Kiln 3 2
1.2.2. Infrastructure requirements for the proposed AFR
programme
3
1.2.3. Waste-derived Materials which can be utilised as
Alternative Fuels
5
1.3. Environmental Study Requirements 6
2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS 7
2.1. Approach to Undertaking the Study 7
2.2. Authority Consultation 7
2.2.1. Consultation with Decision-making Authorities 7
2.2.2. Consultation with Other Relevant Authorities (non-
DEAT)
8
2.3. Application for Authorisation in terms of Section 22 of
the Environment Conservation Act (No 73 of 1989) in
respect of an Activity Identified in terms of Section 21 of
the said Act
8
2.4. Application for Exemption from Undertaking an
Environmental Scoping Study in terms of Section 21 of
the Environment Conservation Act (no 73 of 1989)
8
2.5. Environmental Impact Assessment 9
2.5.1. Specialist Studies 9
2.5.2. Assumptions and Limitations of the Study 10
2.5.3. Overview of the Public Participation Process undertaken
within the EIA Process
10
2.5.4. Review of the Draft Environmental Impact Assessment
Report
14
2.5.5. Final Environmental Impact Assessment Report 14
3. DESCRIPTION OF THE EXISTING DUDFIELD PLANT AND
THE SURROUNDING ENVIRONMENT
15
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xv
3.1. The Existing Dudfield Plant and Kiln 3 15
3.2. Climate 17
3.2.1. Regional Climate 17
3.2.2. Rainfall 17
3.2.3. Temperature 18
3.2.4. Evaporation 18
3.2.5. Wind Data 18
3.3. Topography 19
3.4. Geology 20
3.5. Soils 20
3.6. Surrounding Land Use and Surface Infrastructure 22
3.7. Flora 22
3.8. Fauna 23
3.9. Surface Water 23
3.10. Geohydrological Conditions 24
3.11. Water Consumption at the Dudfield Plant 25
3.12. Air Quality 27
3.13. Noise 30
3.14. Visual Aspects and Aesthetics 31
3.15. Sites of Archaeological, Cultural or Historical Interest 31
3.16. Regional Socio-economic Structure 31
3.16.1. Population Density 31
3.16.2. Major Economic Activity and Sources of Employment 32
4. DESCRIPTION OF THE CEMENT MANUFACTURING
PROCESS
33
4.1. Cement Manufacturing Process at Dudfield Plant 33
4.1.1. Preparation of Raw Materials 33
4.1.2. Process inside the Kiln 35
4.1.3. After the Kiln 35
4.2. Environmental Aspects of Cement Manufacture 37
4.2.1. Raw Materials 37
4.2.2. Emissions to Air 37
4.2.3. Energy 38
4.2.4. Use of Alternative Fuels in the Cement Manufacture
Process
38
4.2.5. How AFR can be utilised in the Kiln 39
4.2.6. Waste Products utilised as Alternative Fuel Sources 42
5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED
WITH THE INTRODUCTION OF THE ALTERNATIVE FUELS
AND RESOURCES PROJECT AT DUDFIELD PLANT
44
5.1. Potential Impacts on Land Use, Vegetation and Heritage
Sites in the area surrounding the Dudfield plant
44
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xvi
5.1.1. Conclusions and Recommended Management Options 45
5.2. Potential Impacts Associated with the establishment of a
Fuel Storage Area within the Boundaries of the Dudfield
Plant
45
5.2.1. Conclusions and Recommended Management Options 48
5.3. Potential Impacts on Water Resources 48
5.3.1. Sources of risk to the groundwater and surface water
environment from the AFR project
48
5.3.2. Conclusions and Recommended Management Options 49
5.4. Potential Impacts on Air Quality 50
5.4.1. Conclusions 52
5.4.2. Recommendations 53
5.5. Potential Traffic Impacts 54
5.5.1. Condition of Roads outside Lichtenburg 54
5.5.2. Condition of Roads within Lichtenburg 59
5.5.3. Existing Traffic 60
5.5.4. Structural Capacity Analysis 61
5.5.5. Assessment of Potential Impacts 62
5.5.6. Conclusions and Recommendations 63
5.6. Potential Impacts on the Social Environment 63
5.6.1. Methodology 65
5.6.2. Formation of Attitudes and Perceptions 66
5.6.3. Disruption in Daily Living and Movement Patterns 67
5.6.4. Impact on Infrastructure and Community Infrastructure
Needs
68
5.6.5. Health and Safety Impacts 69
5.6.6. Local Impacts and Regional Benefits 70
5.6.7. Intrusion Impacts 70
5.7. Assessment of the Suitability of Waste as an Alternative
Fuel Resource
71
5.7.1. Risks and Significance of Risks 75
5.7.2. Recommendation on the determination of suitable AFR 78
5.7.3. Conclusion 80
6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY 82
6.1. Introduction 82
6.2. Terms of Reference 82
6.3. Methodological Overview 83
6.4. Baseline Study 83
6.4.1. Local Wind Field 83
6.4.2. Impact Assessment at Holcim-Dudfield Under Current
Operating Conditions
85
6.5. Environmental Legislation and Air Quality Guidelines 86
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xvii
6.5.1. Ambient Air Quality Standards and/or Guidelines for
Criteria Pollutants
86
6.5.2. Effect Screening Levels and Health Risk Criteria of Non-
Criteria Pollutants
88
6.5.3. Dioxins and Furans 89
6.5.4. Cancer Risk Factors 93
6.5.5. Permit Specifications 93
6.5.6. Emission Limits 94
6.6. Process Description and Emissions Inventory 94
6.6.1. Studies on Emissions from Cement Kilns Utilising
Alternative Fuels
95
6.6.2. Limitations of the Given Source Inventory 97
6.6.3. Emission Inventory for Proposed Usage of Alternative
Fuels and Resources at Dudfield Plant
98
6.6.4. Emission Estimation 99
6.6.5. Comparison of Simulated Emissions to Permit
Specifications
100
6.7. Dispersion Simulation Methodology And Data
Requirements
100
6.7.1. Meteorological Requirements 101
6.7.2. Receptor Grid 102
6.7.3. Source Data Requirements 102
6.7.4. Building Downwash Requirements 102
6.8. Atmospheric Dispersion Results and Discussion 102
6.8.1. Results of Criteria Pollutants 102
6.8.2. Results for Non-Criteria Pollutants: Potential for
Environmental and Non-Carcinogenic Health Effects
106
6.8.3. Results for Non-Criteria Pollutants: Potential for
Carcinogenic Effect
106
6.9. Significance Rating 110
6.10. Description of Aspects and Impacts 111
6.11. Conclusion and Recommendations 112
6.11.1. Recommendations 113
6.12. Air Quality Management System 114
6.12.1. Emissions Inventory Development and Maintenance 117
6.12.2. Source Monitoring 117
6.12.3. Ambient Air Quality Monitoring 118
6.12.4. Mitigation Strategy Design, Implementation and
Evaluation
118
6.12.5. Record Keeping and Environmental Reporting 119
6.12.6. Consultation 120
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xviii
7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN
ALTERNATIVE FUEL RESOURCE
121
7.1. Introduction 121
7.2. AFR Specifications 122
7.2.1. Types of Alternate Fuels and Resources 123
7.2.2. Physical and Chemical Characteristics of AFR 124
7.2.3. Summary of Acceptable Waste in terms of SANS 10228 130
7.2.4. Waste and AFR Standards / Specifications 132
7.2.5. Acceptable Limits for Elements in AFR 133
7.3. Environmental Fate of the Elements 135
7.4. AFR Management Procedures 137
7.5. Risks and Significance of Risks 140
7.6. Recommendation on the determination of suitable AFR 143
7.6.1. Typical Wastes Excluded for use as Alternative Fuels 143
7.6.2. Typical Wastes Accepted for use as Alternative Fuels 144
7.6.3. Loading, supply, storage and management of Alternative
Fuels
145
7.7. Proposed Monitoring, Control and Mitigation Measures 145
7.7.1. Environmental Monitoring Programme 145
7.7.2. Initial Acceptance Procedure Control 146
7.7.3. Transport Procedure Control 147
7.7.4. Final Acceptance Procedure Control 147
7.7.5. Compliance Auditing 147
7.7.6. Development of Site Specific Specifications 148
7.8. Conclusion 149
8. CONCLUSIONS AND RECOMMENDATIONS 150
8.1. Evaluation of the Proposed Project 151
8.1.1. Impacts Associated with Emissions to Air from the Plant 152
8.1.2. Impacts Associated with the Transportation of AFR to
Dudfield Plant
154
8.1.3. Impacts Associated with the Storage of AFR on Site for a
Limited Period
154
8.1.4. Impacts on the Social Environment 155
8.1.5. Suitability of Waste as an Alternative Fuel Resource 156
8.1.6. Project Benefits 158
8.2. Conclusions 159
8.3. Permit Requirements associated with the Introduction of
an AFR Programme at Dudfield Plant
160
9. REFERENCES 163
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Table of Contents 31-Aug-04xix
APPENDICES
Appendix A: Application for Exemption from Undertaking an Environmental
Scoping Study for the Alpha Alternative Fuels and Resources
Project
Appendix B: Advertisements placed in Regional and Local Newspapers
Appendix C: I&AP Database
Appendix D: Briefing Paper
Appendix E: Minutes of Meetings held with I&APs during the EIA Process
Appendix F: Issues Trail
Appendix G: Letter from SAHRA
Appendix H: Air Quality Specialist Report
Appendix I: AFR Management Procedures
Appendix J: Environmental Legislation Relevant to the Proposed Alternative
Fuels and Resources Project, Dudfield
Appendix K: Response from Holcim South Africa Regarding the Use of
Hazardous Waste as a Fuel in Cement Kilns
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
List of Tables 31-Aug-04xx
LIST OF TABLES
PAGE
Table 2.1: Specialist studies undertaken as part of the EIA process 9
Table 3.1: Annual rainfall recorded at Dudfield for the years 1997 –
2001
16
Table 3.2: Chemical character of dolomite groundwater 25
Table 3.3: Borehole yield distribution: Chuniespoort Group 25
Table 3.4: Chemical analyses of different waters at the Holcim Plant
(12 February 2004, Reference 050204/381)
27
Table 3.5: Stack parameters for the Dudfield plant under current
routine operating conditions
28
Table 3.6: Emission rates for criteria and VOC pollutants from the
stacks at the Dudfield plant under current routine
operating conditions
29
Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3
for routine operating conditions
29
Table 3.8: Comparison of measured PM10, NO2 and SO2 emissions to
permit specifications
30
Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in
different districts (refer SABS Code 0103)
30
Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and
traditional fuels
42
Table 5.1: Summary of potential impacts on land use, vegetation and
heritage sites in the area surrounding the Dudfield plant as
a result of the introduction of the AFR programme
46
Table 5.2: Summary of potential impacts associated with the
establishment of a fuel storage area within the boundaries
of the Dudfield plant
46
Table 5.3: Summary of potential impacts on the water environment
associated with the introduction of the AFR programme
51
Table 5.4: Summary of potential impacts on air quality associated
with Dudfield plant
51
Table 5.5: Existing (2004) 12-hour traffic counts 60
Table 5.6: Assessment of potential traffic impacts associated with the
introduction of AFR at Dudfield plant
64
Table 5.7: Summary of potential impacts on the social environment as
a result of the introduction of an AFR programme at
Dudfield plant
72
Table 5.8: Potential Significance of Risks associated with the use of
AFR posed by Natural Events, Technical Problems and
Human Error
76
Table 6.1: Current DEAT NOx guidelines 87
Table 6.2: Air quality standards for nitrogen dioxide (NO2) 87
Table 6.3: Air quality standards for inhalable particulates (PM10) 87
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
List of Tables 31-Aug-04xxi
Table 6.4: Air quality standards for lead 88
Table 6.5: Air quality standards for benzene 88
Table 6.6: Effect screening and health risk criteria for various
substances included in the investigation
90
Table 6.7: Toxicity equivalency factors for dioxins and furans 92
Table 6.8: Unit risk factors from the US-EPA Integrated Risk
Information System (IRIS) (as at July 2003) and WHO risk
factors (2000)
93
Table 6.9: Permit specifications for stack PM10 emissions 94
Table 6.10: Comparison of EC emission limit values for emissions from
co-incineration of waste in cement kilns (Directive
2000/76/EC) and DEAT class 1 incinerator
94
Table 6.11: International emissions data for cement production
emissions of dioxins
97
Table 6.12: Stack parameters for the Dudfield Plant for proposed usage
of alternative fuels
98
Table 6.13: Emission rates for criteria pollutants from the stacks at the
Dudfield Plant for proposed usage of alternative fuels
99
Table 6.14: Heavy Metal and Dioxin and Furan Emissions from Kiln 3
for proposed usage of alternative fuels (a)
99
Table 6.15: Halogen Compound Emissions from Kiln 3 for proposed
usage of alternative fuels (a)
99
Table 6.16: Maximum offsite concentrations (measured in µg/m³) at
the Dudfield Plant boundary of criteria pollutants predicted
to occur due to proposed usage of alternative fuels also
given as a ratio of various air quality guidelines and
standards (a)(b)
104
Table 6.17: Maximum offsite concentrations (measured in µg/m³) at
the Dudfield Plant boundary of non-criteria pollutants
predicted to occur due to proposed usage of alternative
fuels also given as a ratio of various effect screening and
health risk criteria (a)(b)
107
Table 6.18: Predicted maximum annual average concentrations of
various carcinogens due to proposed usage of alternative
fuels at the Dudfield Plant and resultant cancer risks
(assuming maximum exposed individuals)
109
Table 6.19: Significance rating from the baseline study (a) (for all
pollutants of concern)
111
Table 6.20: Significance rating from the proposed usage of alternative
fuel (for all pollutants of concern)
111
Table 7.1: Calorific Value of Alternative and Natural Fuels 123
Table 7.2: Categories of waste that can be accepted by Kiln 3 and
restrictions by SANS Class
131
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
List of Tables 31-Aug-04xxii
Table 7.3: Properties of fuel that can potentially affect product
quality, plant operation, health and safety and
environment
133
Table 7.4: AFR Specifications and range of acceptable limits of
elements (including heavy metals)
134
Table 7.5: Typical Concentrations of Selected Trace Elements in Raw
Materials and Coal (mg/kg)
136
Table 7.6: Potential Significance of Risks associated with the use of
AFR posed by Natural Events, Technical Problems and
Human Error
141
Table 7.7: Minimum Background Monitoring Parameters 146
Table 8.1: Summary of the most relevant permits, licences,
certificates and other authorisations required by Holcim
South Africa for the introduction of an AFR programme at
Dudfield
160
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
List of Figures 31-Aug-04xxiii
LIST OF FIGURES
PAGE
Figure 1.1: Drawing of the area north of Kiln 3 illustrating the
position of area demarcated for the proposed AFR storage
area
4
Figure 1.2: Photograph of the area north of Kiln 3 illustrating the
position of area demarcated for the proposed AFR storage
area in relation to Kiln 3.
4
Figure 3.1: Location of Holcim South Africa Dudfield plant near
Lichtenburg
15
Figure 3.2: Wind roses for the period January 1996 to August 2001 19
Figure 3.3: Geology around Lichtenburg (extract of 1:250 000
Geological map 2626 West Rand, Geological Survey of
South Africa, 1986)
21
Figure 3.4: Water flow/balance diagram for Dudfield plant for July
2004 (Holcim, 2004)
26
Figure 4.1: Schematic representation of the cement manufacture
process from sourcing the raw materials to delivery of the
final product (Source: Cement Industry Federation, 2002)
34
Figure 4.2: Primary components of Kiln 3 (Holcim, 2004) 36
Figure 4.3: Graphic representation of the three locations where
waste-derived fuels can be introduced to Kiln 3 (Holcim,
2004)
41
Figure 5.1: Photograph of the area north of Kiln 3 illustrating the
position of area demarcated for the proposed AFR storage
area in relation to Kiln 3
47
Figure 5.2: Routes currently utilised to access Dudfield plant 56
Figure 5.3: Recommended routes for the transportation of AFR to
Dudfield plant
57
Figure 6.1: Wind roses for the period January 1996 to August 2001 84
Figure 6.2: Schematic diagram illustrating air quality management
plan development, implementation and review by
industrial and mining operations
116
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
List of Photographs 31-Aug-04xxiv
LIST OF PHOTOGRAPHS
PAGE
Photograph 3.1: Kiln 2 and 3 at the Holcim South Africa Dudfield plant 16
Photograph 3.2: Opsis® Emission and Durag particulate measuring unit
installed at Dudfiled in 2002
28
Photograph 4.1: Multi-channel burner, illustrating the multiple channels
where various fuel lines can be coupled for feeding
alternative fuels into the kiln
40
Photograph 4.2: Burner head illustrating the concentric tubes through
which fuel and air is fed into the kiln
40
Photograph 5.1: Pavement damage at the intersection of Road 52 and
D933
55
Photograph 5.2: Pothole in a section of Kapsteel Road (D933) 55
Photograph 5.3: Pumping in a section of Road D2095 58
Photograph 5.4: Pavement defects at intersection of Road D2095 and
D933
58
Photograph 5.5: Structure Failure on Road P183/1 59
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Acronyms and Abbreviations 31-Aug-04xxv
ACRONYMS AND ABBREVIATIONS
AFR Alternative Fuels and Resources
APPA Atmospheric Pollution Prevention Act (No 45 of 1965)
amsl Above mean sea level
ATSDR Agency for Toxic Substances and Disease Registry
CAPCO Chief Air Pollution Control Officer
CFCs Chlorofluorocarbons
CKD Cement kiln dust
CO Carbon monoxide
DEAT Department of Environmental Affairs and Tourism
DME Department of Minerals and Energy
DWAF Department of Water Affairs and Forestry
E80s Equivalent 80 kN single-axle loads
EC European Community
EIA Environmental Impact Assessment
EU European Union
Ha Hectare
hPa Hecto pascalI&APs Interested and affected parties
IBCs Intermediate Bulk Containers
ISCST3 Industrial Source Complex Short Term model (Version 3)
kPa Kilo pascal
LD50 Lethal dose of a chemical required to kill 50% of a population of
experimental mammals and fish
LPG Liquefied petroleum gas
MAP Mean annual precipitation
MJ/kg Mega Joules per kilogram
MRLs Minimal Risk Levels
MSD Mass selective detector
MSDS Material Safety Data Sheet
NEMA National Environmental Management Act (No 107 of 1998)
ng Nanograms
NO2 Nitrogen dioxide
NOx Oxides of nitrogen
NW DACE North West Department of Agriculture, Conservation and
Environment
NWMS National Waste Management Strategy
OEHHA Office of Environmental Health Hazard Assessment
PCCDs Polychlorinated dibenzodioxinsPCDFs Polychlorinated dibenzofuranspH AcidityPPE Personal Protective Equipment
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Acronyms and Abbreviations 31-Aug-04xxvi
PM10 Particulate Matter with an aerodynamic diameter of less than10 µm
PM2.5 Particulate Matter with an aerodynamic diameter of less than2.5 µm
ppm Parts per millionRDF Refuse derived fuel
SA South Africa
SABS South African Bureau of Standards
SAHRA South African Heritage Resources Agency
SANS South African National Standard
SO2 Sulphur dioxide
TIS Traffic Impact StudyTOC Total Organic CarbonTremcard Transport Emergency CardTSP Total Suspended Particulatesµg/m³ Micrograms per cubic meterUS-EPA United States Environmental Protection Agency
VOCs Volatile Organic Compounds
WB World Bank
WHO World Health Organisation
WMD Waste Manifest Document
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Introduction 31-Aug-041
1. INTRODUCTION
Holcim (South Africa) (Pty) Ltd, formerly known as Alpha (Pty) Ltd, is one of
South Africa’s key producers of cement, stone and ready mixed concrete for the
construction industry. Holcim South Africa currently operate three cement plants
in South Africa, one of which is the Dudfield plant, located approximately 20 km
west of Lichtenburg in the North West Province. At Dudfield plant, limestone
(source material) and coal (fuel) are currently the primary raw materials utilised
in the manufacture cement.
The Dudfield plant is situated on a limestone deposit that is mined and milled as
feedstock to the plant. The coal that is utilised in its kilns as the main energy
source for converting the limestone raw meal to manufacture clinker (the base
feedstock for cement), is transported to the plant by rail.
Holcim South Africa are considering implementing the global trend of replacing a
portion of the fossil fuel (coal) used as the energy source with alternative, waste-
derived fuels. That is, the introduction of an Alternative Fuels and Resources
(AFR) programme is proposed for the Dudfield Plant.
The AFR project proposes the replacement of traditional, non-renewable, fossil-
based fuel (coal) with alternative waste-derived fuels and raw materials within
the existing Dudfield Kiln 3 at the existing Dudfield plant. This programme aims
to reduce traditional fossil fuel usage by up to 35% or more.
1.1. Motivation for the Proposed Project
The process of cement manufacture is energy intensive. The average energy
required to produce 1 000 tons of cement clinker is approximately 130 tons of
coal. As a result, Holcim South Africa currently requires approximately
350 000 tons of coal per annum to operate their kilns across the country.
The Holcim commitment to promoting development that is sustainable and at the
least cost to future generations has resulted in a drive to substitute a portion of
the traditional non-renewable fossil fuels (that is, coal) used in the production of
cement with suitable alternative waste-derived materials/fuels. This has resulted
in the need to identify alternative renewable fuel sources which would provide
similar energy (i.e. calorific value) when burnt to that provided by coal, would not
be detrimental to the process in the kiln or the product produced, and would be
less costly than coal in the long-term.
The use of alternative fuels and raw materials that are based on selected waste
products and by-products generated from industrial and domestic sources
addresses this need, as much of this waste is chemically similar to coal. The use
of this waste as a fuel presents the opportunity to reduce the environmental
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Introduction 31-Aug-042
impacts of using a non-renewable resource (coal) in the cement manufacturing
process, as well as to reduce the amount of waste material that would
traditionally be disposed of to landfill or incinerated. The utilisation of AFR in the
cement industry is in-line with initiatives of National Government, particularly the
National Waste Management Strategy (NWMS) which focuses on waste
prevention, waste minimisation and the re-use of waste materials. The practice
of employing alternative fuels in cement plants promotes materials recovery and
recycling by the recovery of energy as well as the mineral components from
waste. The use of waste-derived fuels in a cement kiln therefore, reduces fossil
fuel use, and maximises the recovery of energy, without any significant change in
emission levels.
The use of alternative fuels is a well-proven and well-established technology in
the European, American (both North and South) and Asian-Pacific cement
industries. Experience at international plants has shown that alternative fuels can
successfully replace traditional fossil fuels with no adverse impact on the
environment, safety or health of employees and communities, or on the quality of
the final cement product.
1.2. Overview of the existing Dudfield Plant and the proposed AFR
Programme
1.2.1 Overview of Dudfield Plant and Kiln 3
The Dudfield plant is situated on a limestone deposit (the primary raw material
used in the manufacture of cement) that is mined and milled as feedstock to the
plant. Coal is currently utilised for energy generation, and is transported to the
plant by rail. Cement is produced by the calcination of limestone using coal as
the main energy source for converting the limestone raw meal to form cement
clinker (i.e. the base feedstock for cement). This clinker burning takes place at a
material temperature of 1 450°C within a rotary kiln (an inclined rotating steel
cylinder lined with heat resistant bricks). Dudfield plant currently has three kilns.
Kiln 1 has been decommissioned and is no longer operational. Kiln 2 and the
recently upgraded Kiln 3 are still operational.
The recent upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class
production facility (with a production rate of 3 500 tons per day) included the
installation of a ‘low NOx’-multichannel primary burner (allowing multiple energy
sources to be introduced into the kiln), a pre-calciner, and a bag filter with a
design particulate emission limit of 30mg/Nm3. This upgrade has also resulted in
this plant being in a position to receive and utilise alternative fuels as an energy
source, together with coal.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Introduction 31-Aug-043
1.2.2. Infrastructure requirements for the proposed AFR programme
The 2003 upgrade to Kiln 3 has satisfied all the requirements of the kiln to
receive and utilise variable fuel sources, that is enable the successful introduction
of alternative waste-derived fuels as an energy source, together with coal.
Kiln 3 will never completely move away from utilising coal as an energy source.
Coal is a constant fuel with a known calorific value, and the AFR programme is
aimed at substituting a portion of the total coal requirement. In order to
successfully operate a facility on an on-going basis, the source of fuel is required
to be stockpiled or stored on site. With the proposed introduction of the AFR
programme, Dudfield plant would be required to store both coal and AFR on site.
Dudfield plant has an existing stockpile site for coal. A second designated area
would be required for the storage of AFR on the site. AFR streams are proposed
to be delivered directly to the kiln, and an on-site storage facility would be
required to accommodate/store an approximate 2-day reserve capacity to ensure
that sufficient volume of AFR is available as feedstock for an extended period. In
order to store sufficient capacity to replace approximately 35% of the fuel
currently used at Kiln 3, suitable tanks, silos and bunded/walled areas would be
required to store the waste-derived fuels. An AFR fuel storage area of
approximately 1 600 m2 is proposed to be established within the boundaries of
the existing Dudfield plant.
The proposed AFR storage area is a currently vacant area approximately 20 m to
the north of Kiln 3 (refer to Figure 1.1 and Figure 1.2) to allow for safe and
secure feeding of the AFR material from the storage area to Kiln 3. The
demarcated area has been extensively disturbed by activities associated with the
cement manufacture process at the plant, including the construction activities
associated with the recent upgrade of Kiln 3. The area is devoid of vegetation,
and is on level terrain.
The storage facility would be required to be designed according to national
construction, and fuel handling and storage requirements. The area would be
required to have a concrete floor, be bunded to contain any water accumulating
within the storage area, and have a roof to exclude rainwater from entering and
accumulating within the storage facility. Appropriate drainage facilities would be
required to be in place that would facilitate the separation of stormwater and
runoff from the area.
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Figure 1.1 Drawing of the area north of Kiln 3 illustrating the position of area
demarcated for the proposed AFR storage area.
Figure 1.2 Photograph of the area north of Kiln 3 illustrating the position of
area demarcated for the proposed AFR storage area in relation to
Kiln 3.
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The storage area would be accessed by a levelled and sealed access road, and
would include sufficient area for vehicles to off-load, and manoeuvre, if required.
It is proposed that initially the kiln would be in a position to utilise approximately
70 tons of AFR a day, which represents between 2 and 3 vehicle loads of AFR per
day arriving at the site. It is proposed that in the long-term the volume of AFR
utilise per day could increase to approximately 240 tons per day, which amounts
to 6 – 8 vehicles per day, and the access road and storage area would be
required to support this.
Appropriate fire fighting systems and monitoring equipment would be required to
be installed to service the AFR storage area.
An AFR on-site laboratory would be required at Dudfield plant for control
tests/analyses to be conducted to verify the content of the AFR arriving at the
plant with the 'fingerprint' analyses that were completed at initial acceptance of
the waste (by an external (off-site) accredited laboratory). The Dudfield plant
AFR laboratory would, therefore, have limited capabilities, and will only verify that
the fingerprint matches the waste delivered.
1.2.3 Waste-derived Materials which can be utilised as Alternative
Fuels
Waste materials that the global cement industry has utilised as alternative fuels
include scrap tyres, rubber, paper waste, waste oils, waste wood, paper sludge,
sewage sludge, plastics and spent solvents, amongst others. Similar waste
materials are proposed to be used as fuel in South Africa, together with other
selected wastes that are considered suitable and desirable (including industrial
hydrocarbon tars and sludges). These wastes could potentially be sourced from a
variety of sources from a variety of geographic locations. Only those waste-
derived fuels that meet the stringent standards set by Holcim will, however, be
considered and accepted for use in the kiln.
The use of alternative fuels is technically sound as the organic component is
destroyed and the inorganic component is trapped and combined in the cement
clinker forming part of the final product. Cement kilns have a number of
characteristics that make them ideal installations in which alternative fuels can be
valorised and burnt safely, such as:
• High temperatures – exceeding 1 400°C
• Long residence time – in excess of 4 seconds
• Oxidising atmosphere
• High thermal inertia
• Alkaline environment
• Ash retention in clinker – fuel ashes are incorporated in the cement clinker,
and there is no solid waste by-product
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While many waste streams are suitable for use as alternative fuels or raw
materials, there are others that would not be considered for public health and
safety reasons. No materials that could compromise the environment, the health
and safety of employees or surrounding communities, or the performance of the
cement would be considered for use as a fuel. Strict sampling and testing
procedures would be required to be put in place at the Dudfield plant to ensure
that undesirable fuels and raw materials (such as anatomical hospital wastes,
asbestos-containing wastes, bio-hazardous wastes, electronic scrap, explosives,
radioactive wastes, and unsorted municipal garbage) are excluded from the AFR
programme.
1.3. Environmental Study Requirements
As the introduction of AFR at Dudfield will result in a change to a scheduled
process, as defined in the Air Pollution Prevention Act (No 45 of 1965), Holcim
South Africa requires authorisation from the North West Department of
Agriculture, Conservation and Environment (NW DACE) for the undertaking of the
proposed project. In order to obtain this authorisation, Holcim South Africa
acknowledge the need for comprehensive, independent environmental
assessment studies to be undertaken in accordance with the Environmental
Impact Assessment (EIA) Regulations.
Holcim South Africa have appointed Bohlweki Environmental, as independent
consultants, to undertake environmental studies to identify and assess all
potential environmental impacts associated with the proposed project. In order
to achieve this, an Environmental Impact Assessment (EIA) process has been
undertaken. As part of this study, existing information, a site inspection,
specialist studies and the inputs of interested and affected parties (I&APs) have
been used to identify and assess potential environmental impacts (both social and
biophysical) associated with the proposed project. Mitigation and management
measures have been proposed, where required. Chapter 2 provides a full
description of the scope of the environmental investigations.
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2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS
2.1. Approach to Undertaking the Study
An Environmental Impact Assessment (EIA) for the proposed AFR project at
Dudfield Plant has been undertaken in accordance with the EIA Regulations
published in Government Notice R1182 to R1184 of 5 September 1997, in terms
of Section 21 of the Environment Conservation Act (No 73 of 1989), as well as
the National Environmental Management Act (NEMA; No 107 of 1998).
In terms of Government Notice R1182 (Schedule 1), the following listed activity
which may have an impact on the environment is applicable:
• Scheduled processes listed in the Second Schedule to the Atmospheric
Pollution Prevention Act, 1965 (Act No 45 of 1965)
The environmental process undertaken for this proposed project is described
below.
2.2. Authority Consultation
2.2.1. Consultation with Decision-making Authorities
Consultation with the National Department of Environmental Affairs and Tourism
(DEAT) and the North West Province Department of Conservation, Agriculture and
Environment (NW DACE) was undertaken prior to the submission of the
application for authorisation for the proposed project. The primary aim of this
pre-application consultation was to determine specific authority requirements
regarding the proposed project, and to agree on the Way Forward for the
environmental studies. The pre-application consultation also confirmed that
NW DACE would act as the lead authority for this proposed project.
The relevant decision-making authorities have been consulted throughout the EIA
process. Authority consultation included the following activities:
• Submission of an application for authorisation in terms of Section 22 of the
Environment Conservation Act (No 73 of 1989).
• Submission of an application for exemption from undertaking a Scoping
Study for the proposed project.
• Undertaking of a site inspection with NW DACE.
• Submission of a Plan of Study to undertake the EIA.
• Consultation with authorities regarding project specifics, and receipt of
Authority approval of the Plan of Study for EIA.
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2.2.2. Consultation with Other Relevant Authorities (non-DEAT)
Consultation with non-DEAT authorities was undertaken, including:
• North West Department of Water Affairs and Forestry (DWAF)
• North West Department of Health
• North West Department of Transport
• North West Department of Education
• North West Department of Economic Development and Tourism
• South African Heritage Resources Agency (North West Province)
• North West Provincial Government CAPCO
• Ditsobotla Municipality – Lichtenburg
• Itsoseng Council
A Focus Group Meeting was held with provincial authorities in Lichtenburg on
24 March 2004 to actively engage these authorities and provide background
information to the proposed project. This provided a forum for the departments
to formally provide input into the EIA process.
2.3. Application for Authorisation in terms of Section 22 of the
Environment Conservation Act (No 73 of 1989) in respect of an
Activity Identified in terms of Section 21 of the said Act
Application for authorisation was lodged with NW DACE on 8 September 2003.
This application included information regarding the proponent, as well as the
proposed project and was submitted together with a declaration of independence
from the environmental consultants.
2.4. Application for Exemption from Undertaking an Environmental
Scoping Study in terms of Section 21 of the Environment
Conservation Act (No 73 of 1989)
The proposed project involves the implementation of a known and internationally
understood technology within an existing cement plant. This cement plant has
recently been upgraded and is able to successfully implement this technology.
Therefore, no feasible alternatives exist for this proposed project (i.e. alternative
ways in which the same result could be achieved).
This known activity is proposed by Holcim South Africa to be undertaken at their
existing facility at Dudfield, and therefore potential impacts are anticipated to be
of low significance. Therefore, it was agreed with the relevant environmental
authorities that a formal application for exemption be lodged for the undertaking
of the Scoping Phase for this project (in terms of Section 28A of the Environment
Conservation Act, No 73 of 1989), such that only the EIA Phase was required to
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be undertaken. This application for exemption, as well as NW DACE’s approval of
this exemption application is included within Appendix A.
2.5. Environmental Impact Assessment
The Environmental Impact Assessment (EIA) aims to achieve the following:
• to provide an overall assessment of the social and biophysical environments
affected by the proposed project;
• to assess the proposed project in terms of environmental criteria;
• to identify potential environmental benefits of the project;
• to identify and recommend appropriate mitigation measures for potentially
significant environmental impacts; and
• to undertake a fully inclusive public participation process to ensure that I&AP
issues and concerns are recorded.
2.5.1. Specialist Studies
In undertaking the EIA, Bohlweki Environmental were assisted by a number of
specialists in order to comprehensively assess the significance of potential
positive and negative environmental impacts (social and biophysical) associated
with the project, and to propose appropriate mitigation measures, where
required. These specialist studies are outlined in Table 2.1 below.
Table 2.1: Specialist studies undertaken as part of the EIA process
Company Field of Study
Airshed Planning Professionals Air quality assessment
Environmental & Chemical Consultants Assessment of the suitability of waste as analternative fuel resource, and impactspertaining to AFR management, storage,transportation etc.
CSIR Environmentek Assessment of surface- and groundwaterimpacts
Sustainable Law Solutions Legal review
In order to assess the significance of the identified impacts, the following
characteristics of each potential impact were identified:
• the nature, which shall include a description of what causes the effect, what
will be affected and how it will be affected;
• the extent, wherein it will be indicated whether the impact will be local
(limited to the immediate area or site of development) or regional;
• the duration, wherein it will be indicated whether the lifetime of the impact
will be of a short duration (0–5 years), medium-term (5–15 years), long term
(> 15 years) or permanent;
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• the probability, which shall describe the likelihood of the impact actually
occurring, indicated as improbable (low likelihood), probable (distinct
possibility), highly probable (most likely), or definite (impact will occur
regardless of any preventative measures);
• the severity/beneficial scale: indicating whether the impact will be very
severe/beneficial (a permanent change which cannot be mitigated/permanent
and significant benefit, with no real alternative to achieving this benefit),
severe/beneficial (long-term impact that could be mitigated/long-term benefit),
moderately severe/beneficial (medium- to long-term impact that could be
mitigated/ medium- to long-term benefit), slight or have no effect.
• the significance, which shall be determined through a synthesis of the
characteristics described above and can be assessed as low, medium or high;
and
• the status, which will be described as either positive, negative or neutral.
The suitability and feasibility of all proposed mitigation measures are included in
the assessment of significant impacts. This was achieved through the comparison
of the significance of the impact before and after the proposed mitigation
measure is implemented.
2.5.2. Assumptions and Limitations of the Study
The assumptions and limitations on which this study has been based include:
• Assumptions:
∗ All information provided by Holcim South Africa and I&APs to the
Environmental Team was correct and valid at the time it was provided.
∗ It is not always possible to involve all interested and affected parties
individually. Every effort has, however, been made to involve as many
broad base representatives of the stakeholders in the area. An
assumption has, therefore, been made that those representatives with
whom there has been consultation, are acting on behalf of the parties
which they represent.
• Limitations:
∗ The report is prepared within the project-specific nature of the
investigations, and consequently the environmental team did not
evaluate any strategic alternatives to the AFR project.
2.5.3. Overview of the Public Participation Process undertaken within
the EIA Process
The primary aims of the public participation process included:
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• Meaningful and timeous participation of interested and affected parties
(I&APs).
• Identification of issues and concerns of key stakeholders and I&APs with
regards to the proposed development, i.e. focus on important issues.
• Promotion of transparency and an understanding of the proposed project and
its potential environmental (social and biophysical) impacts.
• Accountability for information used for decision-making.
• Provision of a structure for liaison and communication with I&APs.
• Assistance in identifying potential environmental (social and biophysical)
impacts associated with the proposed development.
• Due consideration of alternatives.
• Inclusivity (the needs, interests and values of I&APs must be considered in
the decision-making process).
• Focus on issues relevant to the project, and considered important by I&APs.
• Provision of responses to I&AP queries.
• Encouragement of co-regulation, shared responsibility and a sense of
ownership.
• Advertising:
In terms of the EIA Regulations, the commencement of the EIA process for
the project was advertised within regional and local newspapers in the
predominant languages of the area (refer to Appendix B). These
advertisements were placed in the Noordwester (English and Afrikaans) and
the Beeld (Afrikaans). The primary aim of these advertisements was to
ensure that the widest group of I&APs possible were informed of the project.
Other advertisements placed during the course of the project advertised the
dates of public meetings and the availability of reports for public review.
• Identification of and Consultation with Key Stakeholders:
The first step in the public participation process entailed the identification of
key I&APs for the proposed project, including:
∗ Central and provincial government;
∗ Local authorities;
∗ Affected and neighbouring landowners; and
∗ Environmental NGOs
Identification of I&APs was undertaken through existing contacts and
databases, responses to newspaper advertisements, networking and a
proactive process to identify key I&APs within the study area.
All I&AP information (including contact details), together with dates and
details of consultations and a record of all issues raised were recorded within
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a comprehensive database of I&APs. This database was updated on an on-
going basis throughout the project process (refer to Appendix C).
Consultations were held with individuals, businesses, institutions and
organisations, including the following:
* Department Environmental Affairs and Tourism - National
* Department of Water Affairs and Forestry – North West
* Department Environmental Affairs and Tourism – North West
* Department of Transport – North West
* Department of Health – North West
* Department of Education – North West
* Department of Economic Development and Tourism – North West
* North West Provincial Government (CAPCO)
* Ditsobotla Municipality – Lichtenburg
* Itsoseng Council
* Workers from the Holcim Dudfield Plant
* North West Business Forum
* Agri North West
* North West Forum
* Local Farmers from the surrounding area
* Important Non Governmental Organisations (NGO’s)
* Community Groups and local businesses
* Mine workers union
* Dudfield Township and,
* Other parties interested in the proposed project including those from a
business point of view.
• Briefing Paper:
A briefing paper for the project was compiled (refer to Appendix D). The aim
of this document was to provide a brief outline of the proposed project,
provide preliminary details regarding the EIA, and explain how I&APs could
become involved in the project. The briefing paper was distributed to all
identified stakeholders together with a registration/comment sheet inviting
I&APs to submit details of any issues and concerns. Completed comments
forms submitted to the consultants are included within Appendix E.
• Consultation and Public Involvement:
Through consultations, issues for inclusion within the EIA were identified and
confirmed. One-on-one consultation, focus group meetings, interest group
meetings and public meetings with I&APs were undertaken in order to
identify key issues, needs and priorities for input into the proposed project.
Minutes of meetings held with stakeholders and I&APs were prepared and
forwarded to the attendees for verification of their issues. Copies of the
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minutes compiled for formal public involvement meetings held during the
process are included within Appendix E.
• Public Meeting and Key Stakeholder Workshop:
A public meeting and key stakeholder workshop were held early in the public
participation process (12 and 13 February 2004 respectively) in order to
inform I&APs and stakeholders of the proposed project. The primary aims of
these meetings were to:
∗ provide I&APs and stakeholders with information regarding the proposed
AFR project;
∗ provide I&APs and stakeholders with information regarding the EIA
process;
∗ provide an opportunity for I&APs and stakeholders to seek clarity on the
project;
∗ record issues and concerns raised; and
∗ provide a forum for interaction with the project team.
In accordance with the requirements of the EIA Regulations, these meetings
were advertised 10 days prior to the event within the Noordwester and The
Star newspapers in the predominant languages of the area (refer to Appendix
B). Registered I&APs and stakeholders were invited to attend the planned
public meeting by letter (refer to Appendix B). Copies of the minutes
compiled are included within Appendix E.
• Stakeholder Focus Group Meetings:
Stakeholder focus group meetings were held with key stakeholder groupings
such as the relevant authorities, landowners and agricultural unions. The
purpose of these meetings was to allow key stakeholders with specific issues
to air their views and to facilitate the interaction of the key stakeholder and
Holcim. The meetings allowed for smaller groups of I&APs and/or
representatives of larger interest groups or organisations to play an active
role in the process and provided an opportunity for consultation with these
parties
• Interest Group Meeting:
The need for an Air Quality and Emissions interest group meeting was
identified. This provided a forum for focussed discussions to be held
regarding air quality and emissions associated with the introduction of the
AFR programme by Holcim South Africa at Dudfield plant. In addition, the
meeting allowed for the transfer of relevant and specific technical
information, and aimed to provide clarity on issues of concern ahead of the
release of the draft EIA Report. Key stakeholders were invited to attend this
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meeting by letter (refer to Appendix B). Copies of the minutes compiled are
included within Appendix E.
• Social Issues Trail:
All issues, comments and concerns raised during the public participation
process of the EIA process were compiled into a Social Issues Trail (refer to
Appendix F). These issues formed the basis of the Social Impact Assessment
(SIA).
2.5.4. Review of the Draft Environmental Impact Assessment Report
The draft EIA report has been made available for public review and comment at
the following public locations:
• Holcim South Africa Dudfield Plant
• Ditsobotla Public Library, Lichtenburg
• Itsoseng Public Library
• NWK Limited, Lichtenburg
• Offices of Bohlweki Environmental, Midrand
• www.bohlweki.co.za
A 30-day period will be allowed for this review process. The availability of this
draft report was advertised in the Noordwester, The Star and Die Beeld in the
predominant languages of the area. I&APs registered on the project database
were notified of the availability of this report by letter (refer to Appendix B).
2.5.5. Final Environmental Impact Assessment Report
The final stage of the EIA process will entail the consideration and inclusion of all
relevant comments received from the public on the draft EIA Report within a final
EIA report. This final document will be submitted to NW DACE for Authority
review and authorisation.
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Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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3. DESCRIPTION OF THE EXISTING DUDFIELD PLANT AND THE
SURROUNDING ENVIRONMENT
The Holcim South Africa Dudfield plant is located on the remaining extent of the
farm Dudfield 57 IP, approximately 416 ha in extent. Dudfield plant is located
approximately 1 km north east of the Dudfield township, 18 km west of
Lichtenburg, 18 km south west of Itsoseng and 64 km south east of Mafikeng in
the North West Province (refer to Figure 3.1). The plant lies approximately
230 km west of Johannesburg by road, and is accessible via the national road
network.
Figure 3.1: Location of Holcim South Africa Dudfield plant near Lichtenburg
3.1. The Existing Dudfield Plant and Kiln 3
The Dudfield plant is one of the primary cement manufacturing operations of
Holcim South Africa. This plant is situated on a limestone deposit that is mined
and milled as feedstock to the plant. The limestone is mined from shallow open
pits, and crushed on-site. The planned life of mine for current mining activities is
estimated at 50 years.
Production at the Dudfield plant began in the early 1950s. Kiln 1 at the plant was
commissioned in 1966 and due to high operating costs, has now been
decommissioned. Kiln 2 (Photograph 3.1) was commissioned in 1972. Kiln 2 will
continue to operate should the market so require, and plans to upgrade this kiln
are currently being considered for the future.
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Dudfield Kiln 3 (Photograph 3.1) was commissioned in 1977 at an original design
capacity of 2 000 tons per day. Through the implementation of various
improvement initiatives to the plant, this capacity was increased to 2 300 tons
per day, and more recently to a continuous clinker production rate of 3 500 tons
per day. Details of the cement manufacturing process are provided in Chapter 4.
Photograph 3.1: Kiln 2 and 3 at the Holcim South Africa Dudfield plant
Dudfield Kiln 3 currently comprises a vertical raw mill, a four stage preheater and
pre-calciner, a rotary kiln 80 m in length (inclined rotating steel cylinder lined
with heat resistant bricks), grate cooler, and a firing system. Kiln emissions are
controlled by a bag filter with a design particulate emission limit of 30mg/Nm3.
The 2003 upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class
production facility included the following changes to the kiln:
• Upgrade of the kiln filter from an electrostatic precipitator to a bag filter with
a design particulate emission limit of 30 mg/Nm3.
• Upgrade of the kiln burner through the installation of a ‘low NOx’-multichannel
primary burner (allowing multiple energy sources to be introduced into the
kiln which allows for fuel versatility).
• Addition of a pre-calciner, which is located at the bottom of the preheater
tower and acts as an auxiliary firing system which increases the raw materials
temperature further prior to introduction into the kiln.
• Installation of a grate cooler in order to improve heat recovery and re-use.
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The upgrade of the kiln infrastructure and technology has resulted in Kiln 3 being
in a position to receive and utilise alternative fuels as an energy source, together
with coal.
In addition to the kiln infrastructure at Dudfield plant, additional infrastructure on
the property for the operation of the plant includes mills (for raw material and
coal), silos, clinker cooler, packing plant, control room, laboratory, workshops and
ancillary structures linking and serving these structures.
3.2. Climate
3.2.1. Regional Climate
The climatic conditions in the region are temperate, and typical of those of the
Highveld. The area falls within the summer rainfall region that is characterised by
thunderstorms. Clear skies, low relative humidity and low wind velocities are
characteristic of the Highveld winter when anticyclone circulation is dominant.
3.2.2. Rainfall
Rainfall occurs predominantly in the summer months, typically from November to
April (Midgley, 1994a). Annual rainfall recorded at the weather station in
Lichtenburg averages approximately 600 mm. The wettest month of the year in
the Lichtenburg area is February, with an average monthly total rainfall of
103 mm. The driest month of the year in the Lichtenburg area is July, with an
average monthly total rainfall of 1 mm (Weather Bureau, 2004).
Rainfall at Dudfield plant follows the trends of the general area. The monthly
rainfall recorded at the Dudfield site for the years 1997 – 2001 is provided in
Table 3.1 overleaf.
The barometric pressure at Dudfield is approximately 855 mbar and the area is
characterised by a mean relative humidity of 40%.
Table 3.1: Annual rainfall recorded at Dudfield for the years 1997 – 2001
(mm)
Month 1997 1998 1999 2000 2001 Ave
January 94,0 141,0 0 157,0 38,5 86,1
February 37,0 92,0 40,5 198,0 210,0 115,5
March 158,0 86,0 48,0 50,5 39,0 76,3
April 59,0 0 16,0 30,0 160,0 53
May 144,5 0 39,0 64,0 42,0 57,9
June 0 0 0 4,0 0 0,8
July 0 0 0 6,0 0 1,2
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Month 1997 1998 1999 2000 2001 Ave
August 0 0 0 0 51,0 10,2
September 49,5 15,5 0 9,0 35,0 21,8
October 64,0 87,5 60,5 69,0 99,0 76
November 23,0 67,5 16,5 138,0 95,5 68,1
December 90,0 107,0 183,0 94,5 115,0 117,9
Total 719,0 596,5 403,5 820 885 684,8
3.2.3. Temperature
Mean annual air temperatures range from 12,8°C in June to 24,1°C in January in
the Lichtenburg area. Average daily maxima range from 18,7°C to 29,1°C, and
average daily minima range from –1,2°C to 15,5°C (Weather Bureau, 2004). At
Dudfield, summer maximum temperatures of 37oC can be experienced, with this
maximum being exceeded on occasion. Temperatures of -3oC and occasionally
lower can be experienced at Dudfield in the winter months.
3.2.4. Evaporation
No annual evaporation figures at Lichtenburg or the Dudfield Plant are available,
but records of mean annual S-pan evaporation measurements within a radius of
approximately 100 km of the town vary between approximately 1 700 mm and
2 000 mm per annum, while the mean annual runoff is between 5 mm and
10 mm (Midgley, 1994a; Midgley, 1994b).
3.2.5. Wind Data
Prevailing winds are generally north-easterly. This is evident in the wind rose for
the area (Figure 3.2). The average wind speed monitored at the Lichtenburg
weather station is approximately 0,3 m/s. At Dudfield plant, the wind varies from
mild gusts to turbulent conditions, especially preceding and during summer
thunderstorms.
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Figure 3.2: Wind roses for the period January 1996 to August 2001
3.3. Topography
Dudfield plant is situated in an area of little relief. The region is generally flat
with a slight gradient sloping towards the south-west. The Dudfield plant is
located at approximately 1 450 m above mean sea level (amsl). The local
topography has been significantly altered by mining activities within the Dudfield
limestone mine which is located adjacent to the plant.
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3.4. Geology
The most recent regional geological mapping of the area around Lichtenburg and
the Dudfield Plant is captured on the 1:250 000 scale geological maps 2624
Vryburg and 2626 West Rand (refer to Figure 3.3).
Dudfield plant is situated on surficial calcrete deposits with a thickness of up to
20 m in places. These calcrete deposits are mined for the production of cement.
Calcrete is formed by the precipitation of calcium carbonate from groundwater in
soil during long dry spells in semi-arid climates. The calcrete deposits are
underlain by the chert-poor dolomite of the Oaktree Formation of the
Chuniespoort Group. Further to the north, the Oaktree Formation is in turn
overlain by the chert-rich Monte Christo formation. The dolomite formations are
subdivided by diabase dykes trending ENE-WSW and N-S and result in the
compartmentilisation of the dolomites. These compartments have a controlling
influence on the groundwater conditions in the area. The Dudfield plant is located
to the west of the Elizabeth II N-S dyke which forms the western boundary of the
Lichtenburg compartment. The E-W trending Lichtenburg dyke traverses across
the farm Dudfield. The northern portion of the farm is underlain by dolomite from
the Oaktree Formation, while the southern portion is underlain by quartzite of the
Black Reef formation. The general dip of the rocks is towards the north.
Extensive outcrops of the Dwyka formation are present to the south and east of
Lichtenburg. Based on geological borehole descriptions, Taylor (1983) reported
thicknesses of up to 30 m of Dwyka shale and diamictite between the calcrete
and dolomite. The Dwyka shales have a low permeability and therefore provide
good protection to the dolomite aquifer from potential contamination sources
related to industrial activities in the vicinity.
3.5. Soils
The area surrounding Dudfield plant is characterised by a Molopo Form,
Kalkfontein Series soil. This soil type is characteristically reddish sandy to loamy
soil, ranging in depth to 0,8 m, occasionally attaining a depth of 2 m in fissure or
cavity areas of the underlying limestone. The interface zone between the base of
the soil and the underlying limestone is characterised by a gradational mixture of
loamy to clayey soil and nodules of calcrete. The proportion of calcrete nodules
increase with depth grading into the underlying limestone mass.
The soils in the area are suitable for cultivation where soil depth permits (maize
and other grain crops), as well as for cattle grazing purposes. In the case of crop
cultivation, inorganic fertilisation is required to sustain production.
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Figure 3.3: Geology around Lichtenburg (extract of 1:250 000 Geological map
2626 West Rand, Geological Survey of South Africa, 1986)
Legend: Qs and Qc Surficial deposits (Qs = soil; Qc = calcrete)
C-Pd Dwyka formation ; shale and diamictite
Vo Chuniespoort Group (Vo = Oaktree Formation; Vmm =
Monte Christo Formation
Va Allanridge Formation
Vb Bothaville Formation
R-Vk Kameeldoorns Formation
R-Vr Rietgat Formation
Rgb Goedgenoeg Formation
Zg Basement granite
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3.6. Land Use and Surface Infrastructure
Land use in the surrounding area is predominantly agricultural, both crop and
grazing (cattle and sheep). Cultivation of maize, sunflowers and other grain
crops is practised where soil depth permits. Due to the nature of the soils,
inorganic fertilisation is required to sustain crop cultivation production.
Insufficient surface water sources and high evaporation rates in the area limit the
irrigation potential to groundwater sources, which occur primarily in the dolomitic
areas to the north of Dudfield.
Dudfield is accessible by tar roads from all major centres. The entrance to the
plant is located on Road D2095, which forms a link road between Road D933
(Kapsteel Road) to the north and Road P183/1 (Deelpan Road) to the south.
These roads provide access to Dudfield from Lichtenburg. Access onto the
Dudfield site for normal heavy vehicles is via the main entrance which is a
concrete road.
Dudfield operates a railway line from the Rietgat siding, which lies approximately
24 km east south east of Dudfield. This railway line is used extensively for the
transport of coal to the plant and cement product from the plant.
Power to Dudfield is supplied by Eskom 88 kV Distribution lines, and a substation
is located at the plant.
The Dudfield Village lies to the south west of the plant. Holcim employees reside
in the village, which comprises houses, a recreation club and sports field. A small
wastewater treatment plant is located approximately 1 km south west of the plant
and services both the plant and the village.
The limestone mine is located adjacent to the plant, and extends to the west and
northwest. An old quarry to the south of the mine has been rehabilitated and is
now utilised for recreation. Due to the flat nature of the surrounding terrain, all
run-off water is contained and channelled to this centralised collection dam on the
site, known as Riveira Dam. This area lies to the east of the Dudfield Village.
3.7. Flora
The Dudfield plant is located within the Northern Variation of the dry
Cymbopogon-Themeda veld (Acocks Veld Type 50a; Acocks, 1988). This
vegetation type occurs within a typically flat, sandy country located at an altitude
ranging from 1300 m to 1350 m above sea level. The climatic constraints include
summer rainfall of between 450 mm and 600 mm per annum, and frosty winters.
This veld type is dominated by Themeda triandra (Red grass), with Cymbapogon
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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plurinodis (Bushveld turpentine grass) being the tallest grass, but usually not
common.
Most of the vegetation on Dudfield farm and in the surrounding area has been
extensively disturbed as a result of agricultural and mining practices. As a result
of the historic disturbance of the Dudfield farm by agricultural activities prior to
mining activities and the Dudfield plant being established on the site, no rare or
endangered flora species would occur within the immediate area, nor have any
been recorded. No invader species were identified on the Dudfield plant site.
Exotic species common to the area include, inter alia, various species of
Eucalyptus, planted by farmers and the mine as windbreaks, Melia azedarach
(Syringa) and Solanum mauritianum (Bug tree).
3.8. Fauna
As a result of the disturbance to habitats within the surrounding area due to
agricultural and mining activities, the occurrence of natural fauna is limited to
small mammals, reptiles and birds. Mammals which have been recorded in the
area include duiker, bat-eared and long-eared fox, warthog, yellow and slender
mongoose, ground squirrel, black-backed jackal, aardwolf, spring and scrub hare,
and porcupine. Reptiles which have been recorded in the area include several
snake species (such as rinkhals, puff adder, cape cobra, house snake, black
mamba, common African python and Boomslang) and tortoises (such as the
Leopard, Kalahari and Hinge backed tortoise). No definitive bird list has been
developed for the Dudfield area. However, more than 200 bird species have been
reported from the Lichtenburg Game Breeding Centre, which lies approximately
20 km north east of Dudfield. No rare or endangered fauna species have been
recorded in the area, largely as a result of the disturbed nature of the available
habitats.
3.9. Surface Water
The Dudfield plant is located within the Quaternary sub-catchment C31A. Springs
which issue from the dolomitic rock formations to the north of Lichtenburg form
the headwaters of the south-westerly flowing Harts River, which is located
approximately 15 km east of Lichtenburg. Due to low rainfall, this section of the
river is dry for the greater part of the year. Stormwater is, however, channelled
to this river from the area surrounding the Dudfield plant via a man-made
drainage feature which is located on the farm Dudfield approximately 8 km east
of the plant.
A shallow natural drainage feature occurs to the west on the farms Kalkfontein
and Bethlehem. The area surrounding the Dudfield plant is characterised by
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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shallow pans. These drainage and pan features are dry for the majority of the
year due to the low rainfall in the region.
Significant runoff is only evident during periods of prolonged high rainfall or
flooding. During such periods, surface rills and sheet wash tend to flow in a
south-westerly direction over the farms Dudfield, Kalkfontein and Bethlehem.
Due to the flat nature of the surrounding terrain, all run-off water is contained
and channelled to a centralised collection dam on the site, known as Riveira Dam.
3.10. Geohydrological Conditions
The regional geohydrological conditions in the area are displayed on the
1:500 000 scale hydrogeological map 2626 (Barnard, 2000). Two aquifers are
present in the area (Jasper Müller Associates cc, 2004), i.e.:
• A major bedrock aquifer system which occurs in the northern chert rich
Monto Christo dolomite towards the north (a distance of approximately 3 –
13 km from Dudfield).
• A minor bedrock aquifer system which occurs in the southern chert poor
Oaktree Formation.
According to a 1983 DWAF report (Taylor, 1983), water levels were at that stage
only a few metres below surface with a gradient of approximately 1:200 to the
south. Groundwater level contours are not affected by the presence of the
Elizabeth II dyke, indicating that at least this dyke is not impermeable. Taylor
(1983) further reports that an east-west trending groundwater divide is located
just to the north of the farm Dudfield 57 IP.
Due to the lack of any perennial surface water resources, the groundwater
resources are exploited at a large scale. The town of Lichtenburg obtains its
water from boreholes tapping the Oaktree and Monte Christo Formations (Botha
and Bredenkamp, 1993; Dziembowski, 1995). According to the 1:500 000
hydrogeological map between 2 and 5 Mm3 per annum is abstracted from the
karst aquifer developed in the dolomite. Because of the lack of surface water
resources and the reliance on the groundwater resources of the dolomitic aquifer,
this aquifer is classified as a Sole Source Aquifer System (Parsons, 1995) and it is
of strategic importance. Groundwater recharge, based on work by Bredenkamp
(1995), is estimated to be about 5% of mean annual precipitation (MAP).
Average quality of groundwater quality from the Chuniespoort Group is provided
in Table 3.2. Borehole yield distribution for the Chuniespoort Dolomite Group is
indicated in Table 3.3.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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Table 3.2: Chemical character of dolomite groundwater
Element/Parameter Concentration
pH 7,6
Electrical conductivity (mS/m) 63
Total Dissolved Salts (mg/l) 444
Calcium (mg/l) 53
Magnesium (mg/l) 35
Sodium (mg/l) 24
Potassium (mg/l) 2,3
Chloride (mg/l) 38
Sulphate (mg/l) 71
Total alkalinity (mg/l CaCO3) 177
Nitrate (mg/l) 5,6
Fluoride (mg/l) 0,3
Table 3.3: Borehole yield distribution: Chuniespoort Group
Yield range (l/s) % Boreholes within range
<0.1 3.2
0.1 – 0.5 7.2
0.5 – 2 23.6
2 – 5 15.1
>5 50.5
3.11. Water Consumption at the Dudfield Plant
All water consumed at the Dudfield plant is sourced from the Holcim South Africa
wellfield situated on the Portion 5 of the farm Dudfield 35 IP, approximately 7 km
north-east of the plant. The farm Dudfield 35 IP is located along the southern
boundary of the declared Bo-Molopo Government Underground Water Control
Area declared according to Articles 27 to 35 of the previous Water Act (No 54 of
1956) (Dziembowski, 1995). This wellfield supplying the Dudfield plant is also
referred to as the “Waterplaas” and consists of 4 boreholes from which on
average approximately 80 000m3 of water is pumped monthly to supply the
entire water requirements of the Dudfield plant. Of this, about 50 000m3/month
is supplied to the operating kilns. Figure 3.4 provides the water flow/balance
diagram for Dudfield plant for July 2004.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Figure 3.4: Water flow/balance diagram for Dudfield plant for July 2004 (Holcim, 2004)
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Process water supply is limited to use by the conditioning towers, where pre-
heater gas temperatures are reduced, as well as for equipment cooling. Water
loss is through evaporation in the cooling towers. Water recovered from the
evaporation and cooling processes is returned to the Riveira Dam to the south of
the plant.
Water quality changes caused by the process are reflected in Table 3.4. Small
volumes of effluent from the water softening plants are also channelled to the
Riveira Dam.
Table 3.4: Chemical analyses of different waters at Dudfield Plant
(12 February 2004, Reference 050204/381)
Element/ Parameter (Units)Raw water
borehole
Treated water (Sagte
Water Huis 32)
Riveira
Dam
pH 8.2 8.0 8.2
Electrical Conductivity (EC) (mS/m) 55 54 114
Turbidity (NTU) 0.6 1.2 2.3
Chloride (Cl) (Mg/l) 10 12 202
Magnesium (Mg) (Mg/l) 21 12 37
Nitrate (NO3 as N) (Mg/l) 9.5 9.3 0.5
Nitrite (NO2) (Mg/l) <0.01 0.02 <0.01
Ortho Phosphate (o-PO4) (mg/l P) <0.1 <0.01 <0.1
Sodium (Na) (Mg/l) 5.9 52 112
Sulphate (SO4) (Mg/l) <20 <20 47
Calcium (Ca) (Mg/l) 76 44 59
Total Hardness (TH) (mg/l CaCO3) 277 158 298
3.12. Air Quality
Evidence of dust pollution within the area surrounding the Dudfield plant is
associated with local mining and agricultural activities, as well as the operation of
the plant.
Under routine operating conditions, the primary constituents of emissions from
the kiln or cement mills consist of sulphur dioxide (SO2), oxides of nitrogen (NOx),
inhalable particulate (PM10), carbon monoxide (CO) from the kilns, and PM10
emissions from the cement mills. In 2003, Holcim installed Opsis® in-line stack
monitors (see Photograph 3.2) that measure emissions from the Kiln 3 stack on a
continuous basis. SO2, N0, NO2, C0, H2O, HCl, NH3, O2 water vapour, benzene,
toluene and xylene (BTX), total organic carbon (TOC) are monitored by the
Opsis® equipment, and particulate emissions monitored by Durag dust monitors.
In addition, Holcim will do annual or bi-annual isokinetic stack sampling to
monitor the emissions of heavy metals (Hg, Cd, Tl, Pb), other metal components
(Zn, Ag, Sn, Sb, etc), as well as dioxins and furans.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Photograph 3.2: Opsis® Emission and Durag particulate measuring unit
installed at Dudfiled in 2002
Information regarding the stack parameters and emission rates is presented in
Table 3.5. A summary of the existing total emissions from the Dudfield plant is
provided in Table 3.6 and heavy metal and dioxin and furan emissions from Kiln 3
for routine operating conditions in Table 3.7.
Table 3.5: Stack parameters for the Dudfield plant under current routine
operating conditions
Source Height (m) Diameter (m)Temperature
(°C)
Exit Velocity
(m/s)
Kiln 3 76 3.75 120 12.4
Cement Mill 1 30 1.162 70 8.6
Cement Mill 2 30 0.710 93.5 18.2
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Table 3.6: Emission rates for criteria and VOC pollutants from the stacks at
the Dudfield plant under current routine operating conditions
Emissions measured in (g/s)Source
Averaging
Period PM10 CO NOx SO2 Benzene Xylene
Hourly 1.33 3.18 0.88 13.80(c) 0.99 0.71
Daily 0.99 2.27 0.46 1.61 0.48 0.64Kiln 3 (a)
Average 0.80 1.11 0.26 0.35 0.34 0.56
Hourly
Daily 0.33 - - - - -Cement Mill 1
(b)Average
Hourly
Daily 0.43 - - - - -Cement Mill 2
(b)Average
Notes:
(a) Monitored data undertaken by C&M Consulting Engineers (for the period 26 May to 8 June 2004)
under current routine operating conditions, provided by Holcim South Africa (Pty) Ltd.
(b) Monitored data under current routine operating conditions provided by Holcim South Africa (Pty)
Ltd.
(c) This value occurred once for an hour on the 31st May 2004 at 06h00.
Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 for routine
operating conditions
Emission (g/s)Compound
Highest Hourly Highest Daily Average
Beryllium 1.2E-07 9.0E-08 8.0E-08
Vanadium 8.0E-05 6.0E-05 5.0E-05
Chromium 1.3E-04 9.0E-05 8.0E-05
Manganese 4.0E-04 3.0E-04 2.6E-04
Cobalt 4.0E-05 3.0E-05 3.0E-05
Nickel 1.6E-04 1.2E-04 9.0E-05
Copper 6.0E-05 5.0E-05 4.0E-05
Arsenic 2.0E-05 1.3E-05 1.0E-05
Silver 1.2E-05 9.0E-06 7.0E-06
Cadmium (b) 1.5E-05 1.5E-05 1.5E-05
Tin (a) 2.0E-04 1.7E-04 1.3E-04
Antimony 1.0E-05 9.0E-06 7.0E-06
Barium 3.6E-05 2.7E-05 2.2E-05
Mercury (b) 2.0E-05 2.0E-05 2.0E-05
Thallium 3.0E-04 2.5E-04 2.0E-04
Lead 5.0E-05 4.0E-05 3.0E-05
Dioxin Toxic
Equivalence (b) 7.0E-09 7.0E-09 7.0E-09
(a) Of the information provided, the analytical methods utilised to determine the tin emissions
are suspect and it appears that tin contamination may have occurred.
(b) Emissions for these volatile pollutants were taken from measured values from the study
undertaken by C & M Consulting Engineers (2002) as a more conservative approach.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Table 3.8 provides a comparison between PM10, SO2 and NO2 emissions provided
by Holcim South Africa and the provisional permit specifications (according to the
Atmospheric Pollution Prevention Act (APPA) Scheduled Process No. 22). It
should be noted that the current PM10, SO2 and NO2 emissions do not exceed
permit specifications.
Table 3.8: Comparison of measured PM10, NO2 and SO2 emissions to permit
specifications
Emissions (mg/Nm³) % Exceeded
SO2 NO2 PM10Appliance
Permit Provided Permit Provided Permit ProvidedSO2 NO2 PM10
Kiln 3 32.18 3.6 800 2.7 50 8.4 N/E N/E N/E
Cement Mill
1- - - - 50 37 - - N/E
Cement Mill
2- - - - 100 90 - - N/E
N/E: Not exceeding
3.13. Noise
The area surrounding the Dudfield plant has a low population density and is
characterised as a rural area. The Dudfield plant and mining area located on
Dudfield farm is characterised as an industrial area.
Typical rating levels for ambient noise in the different districts are set out in Table
2 of the South African Bureau of Standards (SABS) Code of Practice 0103 for “The
measurement and rating of environmental noise with respect to annoyance and to
speech communication”. This code covers a method of measurement and
assessment of noise to determine the suitability of an environment with respect
to possible annoyance (i.e. whether complaints could be expected). Typical
outdoor rating levels, Lr, in dBA are provided in Table 3.9.
Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in different
districts (refer SABS Code 0103)
Type of district Daytime EveningNight-
time
Rural 45 40 35
Suburban with little road traffic 50 45 40
Urban 55 50 45
Urban with some workshops, with business premises &
main roads
60 55 50
Central business 65 60 55
Industrial 70 65 60
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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Noise levels at Dudfield plant are within the limits, as specified in the SABS code,
at the boundary of the plant. The Dudfield Village is the closest residential area
to the plant, and at night plant noise is audible, but not considered a disturbance,
offensive, or detrimental.
Noise generated by the Dudfield plant emanates primarily from the fans, and
intermittent noise is as a result of blasting activities at the adjacent limestone
mine/quarry.
Ambient noise levels in the area surrounding the Dudfield plant are typical of
those associated with rural agricultural activities.
3.14. Visual Aspects and Aesthetics
The study area is characterised by a featureless level plain of no scenic or tourist
potential. The residential area in the immediate vicinity of the Dudfield plant is
limited to the Holcim-owned Dudfield Village. Due to the nature of the cement
plant (and tall structures such as stacks and pre-heater towers), the plant is
visible on a clear day from approximately 30 km.
3.15. Sites of Archaeological, Cultural or Historical Interest
No sites of archaeological, cultural or historical interest are known to occur in the
area immediately surrounding the Dudfield plant. As a result of the intense
agricultural activities in the area, it is likely that any such sites which may have
occurred have been either damaged or destroyed.
3.16. Regional Socio-economic Structure
The Holcim Dudfield Plant is located approximately 18 km west of Lichtenburg,
which is the closest town to the operations. The town forms part of the Central
District Municipality and the Ditsobotla Local Municipality. This town is the centre
of a farming district where maize, groundnuts and sunflower seeds are the main
crops. To the north-east of Dudfield is the town Itsoseng, a small rural
community, supplying labour to the surrounding farms and Lichtenburg.
3.16.1. Population Density
The area surrounding Dudfield plant is sparsely populated, typical of a rural
farming community. Typical of the current trend for urbanisation, the area is
experiencing a slight reduction in population as a result of people relocating to
larger towns in the area. The greatest population density in the immediate area
surrounding the plant is Dudfield Village, where approximately 200 people reside.
The village is located approximately 1 km south-west of the plant.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment
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Population density for Lichtenburg and surrounding areas is approximately 9 883,
and 27 891 for Itsoseng and surrounding areas (as per the 1996 census,
Mr Israel Motlhabane pers. comm.). These centres are, however, approximately
20 km away from the Dudfield plant.
3.16.2. Major Economic Activity and Sources of Employment
The Holcim South Africa Dudfield plant is one of two cement manufacturing plants
in the area. Apart from limestone mining and cement manufacture, grain farming
is the major economic activity in the area. The agricultural activities in the area
are overseen by the North-West Co-operation.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Cement Manufacturing Process 31-Aug-0433
4. OVERVIEW OF THE CEMENT MANUFACTURING PROCESS
The basic chemistry of the cement manufacturing process begins with the
decomposition of calcium carbonate (CaCO3) at approximately 900°C to leave
calcium oxide (CaO, lime) and gaseous carbon dioxide (CO2). This process is
known as calcination. This is followed by the clinkering process, in which the
calcium oxide reacts at high temperature (typically 1 400 - 1 500°C) with silica,
alumina, and ferrous oxides to form the silicates, aluminates, and ferrites of
calcium. The resultant clinker is then ground or milled together with gypsum and
other additives to produce cement.
4.1. Cement Manufacturing Process at Dudfield Plant
Dudfield Kiln 3 has a current production rate of 3 500 tons of clinker per day.
The operation utilises dry process technology due to the low water content of the
limestone. Dry process technology is the most modern technology in cement
manufacture.
Dudfield Kiln 3 currently comprises a vertical raw mill, a four stage preheater and
pre-calciner, a rotary kiln 80 m in length (inclined rotating steel cylinder lined
with heat resistant bricks), grate cooler, and a firing system. Kiln dust emissions
are controlled by a bag filter with a design particulate emission limit of
30mg/Nm3.
The cement manufacturing process can be divided into three stages, namely
preparation of raw materials, clinker production in the kiln, and clinker grinding
after the kiln. Figure 4.1 provides a schematic representation of the cement
manufacture process from sourcing the raw materials to delivery of the final
product.
4.1.1. Preparation of Raw Materials
Limestone is the major raw material used to produce cement, and at Dudfield is
mined from quarries located adjacent to the cement plant. The mined limestone
is crushed and blended in precise proportions with other raw materials containing
iron, alumina and silica and fed to a vertical raw mill, where the materials are
milled to a fine powder referred to as 'raw meal'.
This raw meal is fed into the preheater. The preheater comprises a vertical tower
of heat exchange cyclones in which the dry feed is preheated to temperatures of
approximately 900°C by the kiln exit gases. Raw meal is introduced at the top of
the preheater tower and the hot kiln exhaust gases pass counter-current through
the downward moving meal to heat the meal prior to introduction into the kiln.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province
Cement Manufacturing Process 31-Aug-0434
Figure 4.1: Schematic representation of the cement manufacture process from sourcing the raw materials to delivery of the final
product (Source: Cement Industry Federation, 2002)
1 – Raw MaterialsLimestone is the mainraw material forcement manufacture,and is mined fromadjacent quarries.Other necessaryelements such asiron, alumina andsilica are sourcedfrom additional rawmaterials.
2 - TransportRaw materials aretransported to theplant via conveyor,road or rail.
3 – Transport of fuelFuel required toachieve and maintaintemperatures in thekiln are transported tothe plant (via rail orroad).
4 - HomogenisingRaw materials arehomogenised inpreparation for rawmilling.
5 – Raw MillPrecise proportions ofthe raw materials areblended and milled toa fine powder (‘rawmeal’) in the raw mill.
6 – Bag FilterBag filters removeparticulates from kilnand mill exhaustgases.
7 – Pre-heaterRaw materials areheated to ~900°C incounterflow heatexchange resulting inthe decarbonisation ofcalcim carbonate inthe raw meal.
8 – the KilnRaw materials arefurther heated to1450°C in the rotarykiln. At thistemperature, rawmaterials aretransformed intoClinker.
Clinker productionrequires hightemperatures whichare generated by thecombustion of fuel.The use of waste-derived alternativefuels is being isproposed to replace apercentage of fossilfuel (coal) used.
9 – Grate CoolerClinker is dischargedfrom the kiln at~1000°C andtransferred to thegrate cooler. Clinkeris rapidly cooled toensure the desiredmineralogy is formedin the final product.Heat recovered fromthe kiln and the cooleris recycled in theprocess to reduce fuelrequirements.
10 – Clinker SiloCooled clinker isstored on the clinkersilo.
11 - Cement MillClinker, with theaddition of gypsumand extenders, isground in a ball millto a fine powder toproduce the finalcement product.
12 – Storage SilosThe cement isconveyed to large,vertical storage silos.Cement is conveyedto loading stations inthe plant or directly totransport vehicles fordelivery of the finalcement products inbags or in bulk.
Raw Materials
Clinker ProductionCement grinding and distribution
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Overview of the Cement Manufacturing Process 31-Aug-0435
A pre-calciner combustion vessel located at the bottom of the preheater tower
decarbonises the calcium carbonate in the raw meal. The pre-calciner is an
auxiliary firing system which increases the raw materials temperature further
prior to introduction into the kiln (refer Figure 4.2). The pre-calciner is
advantageous in that the calcination process is almost completed before the raw
material enters the kiln, increasing the production capacity of the kiln.
The preheater tower is designed for an optimisation of transfer of heat to take
place between the kiln exhaust gas and the limestone based raw material. Gas
temperature entering the pre-heater are in the order of +900°C, while the
temperature of the gases exiting the preheater tower are approximately 280°C.
Further cooling of the gas stream takes place in the conditioning tower, where
temperatures are reduced to approximately 140°C in a few seconds. Gas
scrubbing effectively takes place in the pre-heater tower through to the area
immediately after the bag-house filters. Due to the alkali environment coupled
with rapid gas cooling, the potential for environmental impacts is minimised.
4.1.2. Process inside the Kiln
The raw material is fed into the upper end of the kiln which is operated in a
'counter-current' configuration, that is gases and solids flow in opposite directions
through the kiln providing for more efficient heat transfer. The raw meal is fed at
the upper (or 'cold' end), and the slope and rotation cause the raw meal to move
toward the lower (or 'hot' end). The rate at which the material passes through
the kiln is controlled by the slope and rotational speed of the kiln.
As the meal moves through the kiln and is heated, the raw materials reach a
temperature of approximately 1 450°C. At this high temperature, a series of
chemical reactions take place with some of the raw materials in molten form,
resulting in the fusion of the materials and the creation of clinker on cooling (solid
greyish-black nodules, the size of marbles or larger).
Fuel, currently consisting of powdered coal, is fed into the lower end of the kiln
via a multi-channel low NOx burner.
4.1.3. After the Kiln
Clinker is discharged at a temperature of about 1 000°C from the lower end of
the kiln and transferred to a grate clinker cooler in order to rapidly lower the
clinker temperature and freeze the mineralogy of the material. The clinker cooler
is a moving grate through which cooling air is blown. Cooled clinker is stored in a
clinker silo. The clinker, with the addition of gypsum and extenders, is ground in
a ball mill to a fine powder to produce the final cement product.
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Overview of the Cement Manufacturing Process 31-Aug-0436
Figure 4.2: Primary components of Kiln 3 (Holcim, 2004)
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Overview of the Cement Manufacturing Process 31-Aug-0437
The cement is conveyed from the cement mill to large, vertical storage silos in
the packhouse or shipping department. Cement is withdrawn from the cement
storage silos by a variety of feeding devices and conveyed to loading stations in
the plant or directly to transport vehicles.
4.2. Environmental Aspects of Cement Manufacture
4.2.1. Raw Materials
In the cement kiln, new mineral compounds are formed giving cement its specific
properties. The main components are the oxides of calcium, silica, aluminium
and iron.
Significant quantities of limestone, clay and other primary raw materials are
quarried to service the demand for cement. Calcium is provided by the
limestone, while other necessary elements such as iron, alumina and silica are
sourced from additional raw materials and added into the process in the desired
quantities. All the natural raw materials which form raw meal also contain a wide
variety of other elements in small quantities (for example zinc).
4.2.2. Emissions to Air
Almost all manufacturing activity results in emissions to the atmosphere, and
cement manufacture is no exception to this. Releases from the cement kiln come
from the physical and chemical reactions of the raw materials and from the
combustion fuels. The main constituents of the exit gases from a cement kiln are
nitrogen from the combustion air, carbon dioxide (CO2) from the calcination and
combustion processes, water vapour, and excess oxygen.
The exit gases also contain small quantities of dust, chlorides, fluorides, sulphur
dioxides, NOx, carbon monoxide, and still smaller quantities of organic and
inorganic compounds. Many of the gases released are harmless, however, some
are either known or suspected to cause damage to the environment. These
emissions are, therefore, required to be carefully monitored and controlled in
terms of the requirements of the Atmospheric Pollution Prevention Act (No 45 of
1965) and the permit issued by the Chief Air Pollution Control Officer (CAPCO) to
Dudfield plant.
Monitoring equipment is in place at Dudfield to monitor stack emissions. In 2003,
Holcim installed Opsis equipment for Kiln 3 which measures on a continuous
basis SO2, N0, NO2, C0, H2O, benzene, xylene and toluene, and Durag emission
equipment for particulates. Holcim have also extended the range to total organic
compounds as well as HCl and NH3. Twelve heavy metals, as well as dioxins and
furans are measured for on an annual basis.
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4.2.3. Energy
In the South African cement industry, the primary fuel used for energy is coal, a
fossil fuel. The average energy requirement to produce 1 000 tons of cement
clinker is approximately 130 tons of coal. Holcim South Africa requires
approximately 350 000 tons per annum of coal to sustain current cement clinker
manufacture rates.
The main constituents of coal ash are silica and aluminia compounds which
combine with the raw materials (limestone) in the kiln to become part of the
clinker. Like other natural products, the coal ashes contain a wide range of trace
elements which are also incorporated in the cement clinker.
With energy typically accounting for 30-40% of the production cost of cement,
the cement industry throughout Europe and developing nations has successfully
concentrated significant efforts on improving energy efficiency of operating kilns
in recent decades. This includes the introduction of energy efficient technologies
such as the use of preheater towers and pre-calciners.
In addition, in an effort to reduce the reliance on fossil fuels to generate and
maintain the flame temperature, the use of alternative sources of fuels (other
than traditional fossil fuels) have been investigated and successfully implemented
in kilns.
4.2.4 Use of Alternative Fuels in the Cement Manufacture Process
A commitment to Sustainable Development has resulted in a drive to replace
traditional non-renewable fossil fuels (such as coal) used in the production of
cement with suitable alternative fuels. This has resulted in the need to identify
alternative renewable fuel sources which would provide similar energy (i.e.
calorific value) to that provided by coal, and would have a reduced environmental
impact when utilised in the kiln.
Using waste generated from other industries addresses this need, as much of this
waste is chemically similar to coal, and has a calorific value similar to that of coal.
The use of this waste as a fuel presents the opportunity to reduce the
environmental impacts of using a non-renewable resource (coal) in the cement
manufacture process, as well as reducing the amount of waste material which
would traditionally be disposed of to landfill or incinerated. The use of waste
derived fuels in a cement kiln, therefore, reduces fossil fuels usage while
maximising the recovery of energy.
The use of alternative waste-derived fuels is a well-proven and well-established
technology in the international cement industry, particularly Europe, Australia and
the Americas. The use of alternative fuels and resources (AFR) has been
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practiced in these countries for more than 20 years. In 1995 approximately 10%
of the thermal energy consumption in the European cement industry originated
from alternative fuels. This is equivalent to 2,5 million tonnes of coal
(CEMBUREAU, 1997). The use of alternative fuels has steady increased since
then.
The recent upgrade of the Dudfield’s Kiln 3 has resulted in this plant being in a
position to receive and utilise alternative fuels as an energy source, together with
coal (through the installation of a ‘low NOx’-multichannel primary burner). The
multi-channel burner allows for multiple energy sources to be introduced into the
kiln, which allows for fuel versatility.
4.2.5. How AFR can be utilised in the Kiln
Waste-derived fuels can be introduced to Kiln 3 as a fuel at three locations.
These are illustrated on Figure 4.3:
• The lower end of the kiln directly at the main flame / burner: the AFR is
immediately exposed to the main burner flame and releases energy to
maintain the temperature in excess of 2 000°C.
• In the pre-calciner combustion vessel located at the bottom of the preheater
tower: the AFR is immediately exposed to flame within the auxiliary firing
system, maintaining the temperature at 1 200°C.
• The upper end of the kiln where the raw material is fed: the AFR is fed with
raw materials which are at a temperature of 900°C.
The upgrade of the Kiln 3 burner to a multi-channel burner allows for multiple
energy sources to be introduced into the kiln and allows for fuel versatility. Fuel
is fed into the lower end of the kiln through this burner. Fuel lines can be coupled
to the burner (refer Photograph 4.1), and injected into the kiln through concentric
tubes together with air. The burner head installed at Dudfield plant is illustrated
in Photograph 4.2.
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Photograph 4.1: Multi-channel burner, illustrating the multiple channels
where various fuel lines can be coupled for feeding
alternative fuels into the kiln
Photograph 4.2: Burner head illustrating the concentric tubes through which
fuel and air is fed into the kiln
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Figure 4.3: Graphic representation of the three locations where waste-derived fuels can be introduced to Kiln 3 (Holcim, 2004)
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Overview of the Cement Manufacturing Process 31-Aug-0442
4.2.6. Waste Products utilised as Alternative Fuel Sources
Waste materials which the cement industry has utilised as alternative fuels in
Europe include used tyres, rubber, paper waste, waste oils, waste wood, paper
sludge, sewage sludge, plastics and spent solvents. Similar waste materials are
proposed to be utilised as fuel in South Africa, together with other wastes that
are considered suitable and desirable (including industrial hydrocarbon tars and
sludges).
Many waste products are chemically similar to coal, and have a calorific value
(MJ/kg) similar to, and in some instances higher, than coal. Table 4.1 provides
an indication of nett calorific value of alternative fuels, as well as traditional fuels.
The use of materials other than coal to achieve the same effect within the kiln is
beneficial through the maximisation of energy recovery.
Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and traditional fuels
Grade of fuel Fuel typeCalorific value
(MJ/kg)
Pure polyethylene 46
Light oil 42
Heavy oil 40
Pure polystyrene 40
By-products of tar 38
Pure rubber 36
Anthracite 34
Waste oils 30-38
Scrap tyres 28-32
High Grade
Coal 24-29
Pot liners 20
Paint sludge 19
Dried paint 18
Dried wood / sawdust 16
Medium Grade
Rice husks 16
Cardboard / paper 15
Dried sewage sludge 10Low Grade
Wet sewage sludge 7.5
The use of waste as alternative fuels is technically sound as the organic
component is destroyed and the inorganic component is trapped and combined in
the cement clinker forming part of the final product. Cement kilns have a number
of characteristics that make them ideal installations in which alternative fuels can
be valorised and burnt safely, such as:
• High temperatures, i.e. exceeding 1 400°C
• Long residence time, i.e. in excess of 4 seconds
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• Oxidising atmosphere
• High thermal inertia
• Alkaline environment
• Ash retention in clinker, i.e. fuel ashes are incorporated in the cement clinker,
with no residual solid waste by-product
Normal operation of cement kilns provides combustion conditions which are more
than adequate for the destruction of organic substances. This is primarily due to
the very high temperatures of the kiln gases (2 000°C in the combustion gas
from the main burners and 1 200°C in the gas from the burners from the pre-
calciner) (Bouwmans and Hakvoort, 1998; CEMBUREAU, 1997). The gas
residence time at high temperature in the kiln is of the order of 5-10 seconds and
in the pre-calciner more than 3 seconds (CEMBUREAU, 1997).
Because a cement kiln is a large manufacturing unit operating in a continuous
process and with a high heat capacity and thermal inertia, a significant change in
kiln temperature in a brief period of time is not possible. The cement kiln
therefore offers an intrinsically safe thermal environment for the use of
alternative fuels.
Metals are not destroyed at high temperatures, therefore those introduced into
the cement kiln via the raw materials or the fuel will be present in the releases or
in the clinker. Extensive studies investigating the behavior of metals in cement
kilns have shown that the vast majority are retained in the clinker. For example,
studies on antimony, arsenic, barium, beryllium, cadmium, chromium, copper,
lead, nickel, selenium, vanadium and zinc have established that near 100% of
these metals are retained in the solids (clinker).
While many waste streams are suitable for use as alternative fuels or raw
materials, there are those that would not be considered for use as a fuel. For
example, extremely volatile metals such as mercury and thallium are not
incorporated into the clinker to the same degree as other metals are, therefore,
alternative fuels containing these elements are required to be carefully controlled
(CEMBUREAU, 1997).
For public health and safety reasons, no materials that could jeopardise the
health and safety of the employees or the environment, or compromise the
performance of the cement would be considered as a fuel. Therefore, strict
sampling and testing procedures would be required to be put in place at the
Dudfield plant in order to ensure that undesirable fuels are excluded as
alternative fuel sources. Materials excluded are anatomical hospital wastes,
asbestos-containing wastes, bio-hazardous wastes, electronic scrap, entire
batteries, explosives, high-concentration cyanide wastes, mineral acids,
radioactive wastes, and unsorted municipal garbage.
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5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE
INTRODUCTION OF THE ALTERNATIVE FUELS AND RESOURCES
PROJECT AT DUDFIELD PLANT
The main environmental impacts associated with cement production are
emissions to air and energy use. Wastewater discharge is generally limited to
surface/stormwater runoff from the plant itself and process cooling water. The
storage and handling of fuel for the kiln is a potential source of contamination of
soil and groundwater. This includes both the storage of traditional fuel (coal) as
well as the proposed alternative waste-derived fuel. Impacts on the social
environment are focussed on potential impacts associated with the transport of
fuels, and benefits associated with employment opportunities. The potential
environmental impacts associated with the introduction of the AFR programme at
the existing Dudfield plant have been assessed through specialist studies
undertaken as part of this EIA.
The environmental assessment aims to provide an integrated and balanced view
of the potential environmental impacts associated with the proposed project, as
well as make recommendations regarding appropriate mitigation measures, such
that informed decision-making can be made by the environmental authorities.
This section includes an assessment of the potential positive and negative
impacts identified through this EIA process, and makes recommendations, where
required, regarding practical and appropriate mitigation and management
measures required to be implemented in order to minimise potentially significant
impacts.
5.1. Potential Impacts on Land Use, Vegetation and Heritage Sites in
the area surrounding the Dudfield plant
The Holcim Dudfield plant was constructed more than 50 years ago and is located
within an area zoned for industrial use. Land use in the immediate surrounding
area is limestone quarrying with other areas under cultivation and used for
grazing. Impacts/disturbance of the land within and surrounding the Dudfield
plant already exists, and has done so since the initial construction of the facility.
Therefore, the proposed project has no significant impacts relating to the change
of land use, loss of land, vegetation or heritage sites in the surrounding area
(refer to Table 5.1 overleaf). The impact is, therefore, rated as insignificant.
The recent upgrade of Dudfield’s Kiln 3 resulted in this kiln being in a position to
receive and utilise alternative fuels as an energy source, together with coal.
Modifications to the plant and kiln infrastructure (within the boundaries of the
existing Dudfield plant) have already been completed. As the AFR programme
proposed at Dudfield’s Kiln 3 involves the reduction in the use of coal through
supplementation of the fuel required with AFR, additional investment would be
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required to be made within the site boundaries for the AFR acceptance, chemical
testing, storage and kiln feed infrastructure. This additional infrastructure would
not, however, not require any additional changes to the footprint area of the
existing cement plant.
The area within the boundaries of the existing Dudfield plant has been extensively
disturbed through industrial activities and the construction of auxiliary
infrastructure to support the cement plant since the early 1950s. The
introduction of an AFR programme would require the establishment of a dedicated
fuel storage area, approximately 1 600 m2 in size, where fuels could be off-
loaded, handled, and stored for a limited period before being fed into the kiln
together with coal. This area would be within the existing footprint of the
Dudfield plant, adjacent to Kiln 3. Specific impacts associated with this storage
area are detailed in section 5.2 below. Secondary infrastructure such as roads
accessing this storage area would also be within the boundaries of the plant.
As a result of no additional development being required outside of the boundaries
of the existing Dudfield plant with the introduction of the AFR programme, no
impact on any heritage sites is anticipated. This has been confirmed by the North
West provincial department of the South African Heritage Resources Agency
(SAHRA), who have indicated that they have no objections to this project and did
not require a Heritage Impact Assessment (HIA) to be submitted to the
Department for review (refer to Appendix G).
5.1.1. Conclusions and Recommended Management Options
No significant impacts on land use, vegetation and heritage sites are anticipated
to be associated with the introduction of the AFR programme at Dudfield plant.
Therefore, no mitigation measures are required to be implemented. However, all
current vegetation maintenance practises exercised at Dudfield plant must be
continued in terms of the requirements of the Conservation of Agricultural
Resources Act (No 43 of 1983).
5.2. Potential Impacts Associated with the establishment of a Fuel
Storage Area within the Boundaries of the Dudfield Plant
No preparation of different waste types for use as AFR at Dudfield plant (such as
pre-treatment or blending of wastes) will occur at Dudfield plant. The suitable
AFR received at the plant will be received and stored within a designated storage
area, and then proportioned for feeding into the cement kiln. The AFR fuel
storage area of approximately 1 600 m2 is proposed to be established within the
boundaries of the existing Dudfield plant within the currently vacant area to the
north of Kiln 3 (refer to Figure 5.1). This area has been extensively disturbed
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Table 5.1: Summary of potential impacts on land use, vegetation and heritage sites in the area surrounding the Dudfield plant as a
result of the introduction of the AFR programme
Nature of Impact associated
with the introduction of the
AFR programmeExtent Duration Severity Significance Likelihood
Confidencein
assessmentof impact
Mitigation measures
Impacts on land use in the area
surrounding the Dudfield plant
Localised Long-term Slight None Very unlikely
to occur
High Not applicable
Impacts on vegetation in the area
surrounding the Dudfield plant
Localised Permanent Slight None Very unlikely
to occur
High Current vegetation maintenance
practises must be continued.
Impacts on heritage sites in the
area surrounding the Dudfield
plant
Localised Permanent Severe None Very unlikely
to occur
High Not applicable
Table 5.2: Summary of potential impacts associated with the establishment of a fuel storage area within the boundaries of the
Dudfield plant
Nature of Impact associated
with the introduction of the
AFR programmeExtent Duration Severity Significance Likelihood
Confidencein
assessmentof impact
Mitigation measures
Impacts on land use within the
Dudfield plant boundaries
Localised Long-term None None Very unlikely
to occur
High Not applicable
Impacts on vegetation within the
Dudfield plant boundaries
Localised Long-term None None Very unlikely
to occur
High Not applicable
Impacts on groundwater and soil
as a result of the storage of AFR
Localised Long-term Severe High Very unlikely
to occur
High Storage areas must be constructed
according to national engineering
standards & specifications required
by the National & Provincial
Government Departments
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through activities associated with the cement manufacture process at the plant,
including the construction activities associated with the recent upgrade of Kiln 3.
The area is devoid of vegetation, as is characteristic of the area, and is on level
terrain.
Limited earthworks would be required in the construction of an appropriately
bunded, concrete lined area. Therefore, the establishment of this fuel storage
area is not anticipated to impact significantly on vegetation or land within the
Dudfield plant boundaries.
Figure 5.1: Photograph of the area north of Kiln 3 illustrating the position of
area demarcated for the proposed AFR storage area in relation to
Kiln 3
The storage of fossil and alternative fuels is, however, identified as an important
potential source of impact on the environment as a result of the potential for
pollution of the soil and groundwater. Without the implementation of appropriate
mitigation measures, this impact is potentially of high significance.
An assessment of the potential impacts associated with the establishment of an
AFR fuel storage area within the boundaries of the Dudfield plant is provided in
Table 5.2.
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5.2.1. Conclusions and Recommended Management Options
No significant impacts on land or vegetation is associated with the establishment
of a designated AFR storage area at Dudfield plant. Therefore, no mitigation
measures are required to be implemented prior to the construction of the site.
However, in order to minimise potential impacts on soil and groundwater as a
result of the storage of fuels, storage areas for all alternative fuels and resources
must be constructed according to national engineering standards and
specifications required by the relevant National and Provincial Government
Departments. These should have a concrete floor, should be properly bunded,
and if required for operational reasons, should be covered by a permanent roof
structure. The volume of the bunded area should at least be such that it can
contain a 1:50 year rainfall event over the surface area of the storage area. The
concrete base will minimise, if not totally exclude, leachate infiltration into the
groundwater.
5.3. Potential Impacts on Water Resources
5.3.1. Sources of risk to the groundwater and surface water
environment from the introduction of an AFR programme
Wastewater discharge associated with a cement plant is limited to
surface/stormwater runoff from the plant itself and surrounding surfaced areas,
as well as process cooling water. Current operating activities do not result in any
significant contribution to surface or groundwater pollution.
The introduction of AFR as an energy source in Kiln 3 at Dudfield plant will not
impact on or change the current water demand for cooling purposed within the
cement manufacture process. The kiln will continue operating at capacity, as is
currently the case with the use of coal as a fuel source. The current impacts of
the existing operating kiln on the water quality as a result of surface/stormwater
runoff from the plant itself and surrounding surfaced areas will not be altered. In
addition, the process water used for cooling will remain the same as current
operating conditions. Therefore, it is anticipated that the proposed project will
not further impact on the quality and/or availability of water resources in the
area.
The quality of the water utilised within the cement manufacture process for
cooling purposes will not be contaminated by AFR. Therefore, the introduction of
this programme will not impact on the current quality of the process water, the
cement manufacturing process or the quality of the product. The cement plant is
liquid effluent-free, since any water used in the process is evaporated due the
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high temperatures within the kiln. This will continue to be the case with the
introduction of the AFR programme.
Impacts on local water quality could potentially be associated with the AFR
storage area. Should this area be uncovered, the potential exists for the
production of leachate as a result of rainwater or stormwater percolating through
the material. Depending on the type of material and its physical condition, the
leachate produced may result in contamination to surface and/or groundwater
resources if not properly contained or treated. Leachate generated in this way
within the storage area would be required to be chemically tested to determine
compliance to the National Standard Requirements for the Purification of Waste
Water or Effluent, as determined by the Department of Water Affairs and Forestry
(DWAF) before it can be disposed of. In the event of non-compliance, the
leachate would be required to either be treated before disposal to a receiving
water resource, or be evaporated and the resulting sludge be disposed of at an
approved and permitted waste disposal facility.
Currently, all stormwater is directed towards an extensive canal system
constructed around the plant and then collected in a holding dam to the south of
the plant. This canal system is currently being upgraded to a concrete-lined
structure. The holding dam is unlined. The storage area for AFR would be
required to be lined and bunded in order to ensure that the quality of the
stormwater not be affected by implementation of the proposed project.
The potential impacts on the water environment (groundwater and surface water)
associated with the introduction of the AFR programme together with the scale of
impact are detailed in Table 5.3.
5.3.2. Conclusions and Recommended Management Options
The introduction of the AFR programme in Kiln 3 is not anticipated to result in any
significant impacts on the water environment. The amount of water to be used in
the cement manufacture process will not change with the use of AFR as the kiln
will continue operating at capacity as is currently the case with the use of coal as
a fuel source. Therefore, no negative impacts on the surface and groundwater
resources as a result of an increase in the abstraction of groundwater are
expected.
The proposed alternative fuels and resources will be required to be stored in
facilities designed according to national construction, handling and storage
requirements. The area would be required to have a concrete floor, be bunded to
contain any water accumulating within the storage area, and a roof to exclude
rainwater from entering and accumulating within the storage facility. Should
water accumulate within the bunded area, the quality of the wastewater would be
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required to be tested, and only discharged to the approved effluent discharge
system of the plant should it meet the specified range for effluent discharge.
Should the quality of the water not be acceptable, it would be required to be
treated to a standard such that it can be disposed of in the effluent disposal
system (Department of Environmental Affairs and Tourism, 1984; Department of
Water Affairs and Forestry, 1996).
5.4. Potential Impacts on Air Quality
Releases from the cement kiln come from the physical and chemical reactions of
the raw materials and from the combustion fuels. The main constituents of the
exit gases from a cement kiln are nitrogen from the air used for combustion,
carbon dioxide (CO2) from limestone calcination and the combustion process, and
excess oxygen. The exit gases also contain small quantities of dust, chlorides,
fluorides, sulphur dioxides, oxides of nitrogen (NOx), carbon monoxide (CO), and
still smaller quantities of organic and inorganic compounds.
The exit gases from Kiln 3 are dedusted in bag filters, and the dust returned to
the process.
The specialist air quality assessment undertaken for this proposed project
considered both the baseline conditions (i.e. with coal as the fuel source) and a
modelled scenario (i.e. with the introduction of AFR). From the results of this
study, it is anticipated that an impact of low significance on air emissions will
result with the introduction of an AFR programme at Kiln 3 at Dudfield plant. As
the emission levels are below the DEAT guidelines, the significance for baseline
conditions (for all pollutants of concern) was predicted to be low (refer to Table
5.4). Under proposed operating conditions (usage of alternative fuels), the
emissions remain below the DEAT guidelines. Therefore, the significance for all
pollutants of concern with the implementation of the proposed project at Dudfield
plant is predicted to remain low (refer to Table 5.4).
A detailed assessment of the potential impacts on air emissions associated with
the introduction of AFR at Dudfield is included within Chapter 6 and Appendix H.
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Table 5.3: Summary of potential impacts on the water environment associated with the introduction of the AFR programme
Nature of impactassociated with theintroduction of anAFR programme
Extent Duration Severity Significance LikelihoodConfidence inassessment of
impact
Mitigation and/orEnhancement
Availability of waterresources in the area
Regional Long-term Slight NoneVery unlikelyto occur
High Not applicable
Quality of processwater for coolingpurposes
Localised Short-term Slight NoneVery unlikelyto occur High Not applicable
Off-loading, storageand handling of AFRmaterial
Localised Long-term Slight LowUnlikely tooccur
High
Construction of storage facility
according to construction
standards and monitoring of
quality of any leachate
produced
Table 5.4: Summary of potential impacts on air quality associated with Dudfield plant
Nature of Impact Extent Duration Severity Significance Likelihood
Degree of
certainty or
confidence
Impacts on air quality associated with the baseline study (a)
(for all pollutants of concern)Long term Localised Slight (b) Low (b) May occur (c) Probable
Impacts on air quality associated with the proposed usage of
alternative fuel (for all pollutants of concern)
Long term Localised Slight (b) Low (b) May occur (c) Probable
Notes:
(a) Routine operating conditions using Kiln 3, Cement Mill 1, Cement Mill 2.
(b) Based on criteria pollutants and screened against DEAT guidelines.
(c) Impacts are not constant as they depend on the meteorological conditions and dispersion potential of the atmosphere.
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5.4.1. Conclusions
The investigation included the simulation of inhalable particulates, nitrogen
oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and
halogen compounds. For baseline conditions, measured emission values were
simulated in order to determine the current impact on the surrounding
environment. For proposed usage of alternative fuels, EC emission limits were
used to estimate emission rates.
The main conclusions may be summarised as follows:
• The inhalable particulate concentrations (PM10) were predicted to be below
the daily and annual average current DEAT as well as the EC and proposed
South African limits with highest offsite concentrations at 7 µg/m³ and
0,7 µg/m³ respectively for baseline conditions, and 0,3 µg/m³ and
0,57 µg/m³ respectively for predicted AFR use conditions (this excluded
fugitive emissions).
• Gaseous concentrations for NO2 (baseline conditions) did not exceed the
DEAT guidelines with highest predicted off site concentrations estimated to be
3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ for highest hourly, daily and annual
averaging periods respectively. NO2 ground level concentrations with
proposed AFR use were predicted to be 2,8 µg/m³, 0,5 µg/m³ and
0,02 µg/m³ for highest hourly, daily and annual averaging periods. These
concentration levels were below DEAT guidelines as well as EC and proposed
South African limits.
• NOx ground level concentrations for proposed operating conditions were
315 µg/m³, 60 µg/m³ and 2,43 µg/m³ for highest hourly, daily and annual
averaging periods respectively, well below the current DEAT guidelines.
• Predicted sulphur dioxide ground level concentrations were below the current
DEAT guidelines as well as the proposed South African and EC limits with
highest levels predicted to be 50 µg/m³1, 1,2 µg/m³ and 0,01 µg/m³ for
highest hourly, daily and annual averaging periods respectively for baseline
conditions and 20 µg/m³, 2,8 µg/m³ and 0,15 µg/m³ for highest hourly, daily
and annual averaging periods respectively for proposed conditions.
• Current and predicted (with AFR use) lead concentrations were insignificant
when compared to the EU limits respectively.
• Predicted ground level concentrations for non-criteria pollutants did not
exceed the effect screening or health risk criteria for current and proposed
operations.
• Carcinogenic pollutants for baseline conditions were estimated to cause less
than 1 in 1 million chance of cancer (trivial cancer risk criterion). For
1 Using the 98th percentile the predicted hourly value is 20 µg/m³. The predicted
50 µg/m³ was predicted from a peak incident during the monitoring campaign.
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proposed conditions (with AFR use) all potential carcinogenic pollutants,
except hexavalent chromium were predicted to be below the 1 in a million
increased cancer risk criterion. Assuming all chromium to be hexavalent, the
estimated cancer risk ranged from 2,2 to 26 in 1 million (WHO unit risk
factors). However, hexavalent chromium is typically 10% of total chromium.
Thus, the incremental cancer risk using the WHO unit inhalation unit risk
factors would be 0,2 to 2,6 in a million. It is therefore broadly acceptable
(less than 1 in 100 thousand).
• Dioxins and furan concentrations were below the relevant guidelines for
current and proposed operating conditions.
• The significance rating for current and proposed operating conditions with
AFR use indicated slight severity due to predicted ground level concentrations
from criteria pollutants with localised, long-term impact.
• Based on the findings above it can be concluded that predicted ground level
impact from alternative fuel usage is similar to, and in some cases marginally
higher than (due to emissions based on EC limits) baseline conditions.
However the predicted impact for the usage of alternative fuel is well below
relative guidelines/limits.
5.4.2. Recommendations
• EC emission limits were used to quantify ground level impact from Kiln 3 with
the proposed usage of alternative fuels. It is recommended that a “trial
burn” be undertaken to verify EC emission limits used in the current study for
the proposed burning of alternative fuels. Pollutants of concern are typically
due to chronic exposures (e.g. dioxins and furans), hence a relatively short
exposure of a few days during a trial burn would have an insignificant impact.
• It is recommended that emissions be monitored once the proposed
operations have commenced and re-simulations undertaken if the order of
magnitude of these emissions is significantly different. This will be required
in order to quantify the ground level impact.
• EC limit allows NOx emission instead of NO2. Previous measurements at
Dudfield Plant indicated approximately 1% NO2 of NOx. This fraction may
however be as high as 10%. If the NO2 emissions were allowed at the EC
limit for NOx, the guidelines of NO2 would be exceeded. It is, therefore,
recommended that both NO2 and NOx be monitored for compliance.
• It is recommended that the hexavalent chromium fraction be determined.
• Although fugitive emissions were not important in establishing the impact of
the use of alternative fuels it is recommended to compile a source inventory
for these emissions to determine the significance of this source.
• An air quality management plan is recommended to improve and extent the
plant’s emissions inventory by:
∗ Undertaking stack (Kiln 3) monitoring following the initiation of the
proposed operations to confirm projected stack emission data.
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∗ Identify and quantify all fugitive, diffuse and evaporative sources of
emissions.
5.5. Potential Traffic Impacts
The introduction of an AFR programme at Kiln 3 at Dudfield plant will require the
transportation of alternative fuel sources to the plant. This is proposed to be
undertaken via road, at a projected maximum rate of 6 truckloads per day. The
majority of traffic transporting AFR will access Dudfield plant via Lichtenburg.
Potential impacts associated with the transportation of AFR by road include
increased traffic volumes and potential delays for other traffic in the area,
impacts on the road surface and structure, and an increase in the heavy vehicle
traffic within the areas surrounding Dudfield plant.
Current access to the Dudfield plant is via Road D2095, approximately 3,5 km
from Road P183/1 (refer to Figure 5.2). The entrance is considered to be of
sufficient capacity for traffic entering the plant. The condition of the road at the
entrance is poor and requires rehabilitation.
Figure 5.4 depicts the possible two routes that trucks would be able to use for the
hauling of AFR material, to and from the Dudfield plant via Lichtenburg. The
condition of the roads utilised for the two routes are described below.
5.5.1. Condition of Roads outside Lichtenburg
• R52 to Mmabatho (P28/4)
This road serves as the link between Lichtenburg and Mmabatho. Road
P28/4 is a 7,4 m wide, two lane road with a 2 m gravel shoulder. Some
patchwork does occur on the road with isolated rutting and edge breaking at
entrances to farms and rural roads. Approximately 4 km from Lichtenburg on
route to Mmabatho, Road D933 intersects with Road P28/4 with a T-junction
to the west. This intersection is currently in a poor condition (refer to
Photograph 5.1). Despite these pavement defects, the road is currently in a
good structural and riding condition.
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Photograph 5.1: Pavement damage at the intersection of Road 52 and D933
• Kapsteel Road (D933):
This road links Road D2059 with Road P28/4 between Lichtenburg and
Mmabatho (refer to Figure 5.3). This is a 7,4 m wide, two lane road with a
2 m gravel shoulder. The road was designed typically as a lightly trafficked
road with few heavy vehicles, i.e. tractors and trucks carrying maize and
sunflowers. The road, therefore, has a light pavement structure and some
failures and rutting does occur on certain parts along the road (refer to
Photograph 5.2). Despite these pavement defects the road is currently in
good structural and riding condition. However, this road is not suitable to
carry high volumes of heavy vehicle traffic due the design of the pavement.
Photograph 5.2: Pothole in a section of Kapsteel Road (D933)
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province
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Figure 5.3: Routes currently utilised to access Dudfield plant
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province
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Figure 5.4: Recommended routes for the transportation of AFR to Dudfield plant
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
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• Road D2095:
This road links Roads D933 and P183/1 with each other and provides access
to the Dudfield plant. This is a 7,4 m wide, two lane road with a 2 m gravel
shoulder. The road is in a poor structural condition due to several pavement
defects like pumping, bleeding and potholes (refer to Photograph 5.3). The
intersections of this road with Roads D933 and P183/1 need rehabilitation
(refer to Photograph 5.4).
Photograph 5.3: Pumping in a section of Road D2095
Photograph 5.4: Pavement defects at intersection of Road D2095 and
D933
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• Deelpan Road(P183/1):
This road runs between Deelpan and Lichtenburg and provides access to
Dudfield plant via Road D2095. This is a 7,4 m wide, two lane road with a
2 m gravel shoulder. The section of the road between Road D2095 and
Lichtenburg is severely rutted with potholes and structural failures that pose
a safety hazard to road users (refer to Photograph 5.5). This road was
originally designed to carry heavy vehicle traffic, but is near to the end of its
20-year design life and will be rehabilitated in the near future (C Davis, pers
comm., 2004).
Photograph 5.5: Structure Failure on Road P183/1
5.5.2. Condition of Roads within Lichtenburg
• Buiten Street
This road is one of the major streets in Lichtenburg and is currently utilised
by light vehicles as well as heavy vehicles. Traffic signs at the entrance to
the town regulate that all heavy vehicles must travel via Buiten Street
through Lichtenburg to various destinations. This road is an 8 m wide, two
laned with 2 m surfaced shoulders. The travelling width of the road was
resealed recently and is in a good condition. This street is mainly regulated
by stop signs, except at the intersection with Buchanen Street where traffic
lights regulate the movement of traffic.
• Swart Street
This is an 8 m wide, 2-lane road that leads to Road P28/4 to Mmabatho. This
road is in good riding condition.
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• Republiek Street
This is an 8m wide, 2-lane road that leads to Road P183/1 and is in good
riding condition.
• Roads P24/8, D933 and associated streets within Lichtenburg:
These roads are of good riding quality and structural condition. Roads
P183/1 and D2095 are currently the preferred access roads to the Dudfield
plant. These roads are near the end of their design life and in need of
rehabilitation from the North West Province Roads Department. According to
the Department (C Davis, pers comm., 2004), these roads are not listed as
roads projects for the year 2004, but may be included within the next 5-year
project list depending on the outcome of their project prioritising procedure.
5.5.3. Existing Traffic
If a single phase development adds less than 500 trips per peak hour to the road
network it is advised by the Traffic Impact Study (TIS) Manual that only the base
year (year development is lodged) traffic is assessed to determine the impact of
new trips on the road network. In this TIS, a worst-case scenario of 6 new trips
per day has been assumed to be added to the road network and thus an
assessment of the current (2004) traffic situation is considered to be sufficient.
In order to measure the impact of the new trips on the existing situation, the
existing traffic classification and volumes were analysed. The process of
obtaining the existing traffic volumes included the counting of the traffic on a
normal day at different locations within the study area (a normal day can be
described as a day that is not a public holiday and one of the following days
Tuesday, Wednesday or Thursday). The traffic was, furthermore, classified as
light and heavy vehicles to estimate the type of delay caused for road-users.
Light vehicles are passenger vehicles (cars) and heavy vehicles are vehicles with
more than three axles.
A twelve-hour daytime classified traffic count was conducted on in July 2004 at
three counting stations (refer to Figure 5.4). The existing twelve-hour traffic
volumes are indicated in Table 5.5.
Table 5.5: Existing (2004) 12-hour traffic counts
Road P28/4 P183/1 Buiten Str
Direction E/W W/E E/W W/E S/N N/S
Light Vehicles 110 124 351 394 1168 1486
Heavy Vehicles 67 76 68 93 571 324
Total Vehicles 177 200 419 487 1739 1810
Percentage
Heavy Vehicles38% 38% 16% 19% 32% 18%
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According to the Highway Capacity Manual, roads utilised as routes to access the
Dudfield plant operate at a maximum traffic volume of 1 700 cars per hour per
direction, or 3 200 cars per hour for both directions under ideal conditions. If
these volumes are compared to the existing traffic volumes in Lichtenburg it is
evident that the daily traffic volume on all roads can be described as light, and
thus operating far below the optimum (20 400 cars per 12-hour period). The
traffic volume on Buiten Street is, as expected, higher due to through-traffic from
Gauteng and it is also a local collector road that carries higher volumes of light
traffic. If 6 trucks carrying AFR to Dudfield plant are added to the road system in
a 12-hour period, the traffic will increase by 1,5%. These roads are considered to
have sufficient spare capacity to accommodate these trips in a 12-hour period
without an impact.
From Table 5.5 it is evident that the roads surrounding the Dudfield plant are
carrying high (16-38%) proportions of heavy vehicles if compared to the norm for
rural roads in South Africa that ranges between 15 – 20% of all traffic. This is
due to the opening of the Platinum Toll Highway and the resulting heavy vehicles
detouring through Lichtenburg en route to Mafikeng. This high volume of heavy
traffic can result in a higher than normal delay on the roads surrounding the
plant. However, as the additional trucks associated with the introduction of AFR
at Dudfield plant result in a 1,5% increase in traffic, it is not anticipated that the
delay factor associated with these additional vehicles will be significant.
The heavy vehicles currently travelling to the Dudfield plant arrive from various
destinations in South Africa and are in the order of 23 vehicles per day. These
vehicles travel directly to the plant or via Lichtenburg. The proportion of the
vehicles travelling via Lichtenburg is in the order of 90%, with only 10%
travelling directly to the plant (i.e. not from the Lichtenburg area).
The number of heavy vehicles that utilise the route via P183/1 from Lichtenburg
to the Dudfield plant is approximately 16 vehicles per day, with only 4 vehicles
per day accessing the plant via P24/8. The route via P183/1 is currently the
preferred route, despite its current pavement condition.
The addition of 6 trucks on the route via P183/1 will result in a 1% increase in the
traffic volume. This is a very small growth in traffic and is considered to be
insignificant.
5.5.4. Structural Capacity Analysis
The cumulative damaging effect of all individual axle loads on a road pavement is
expressed as the cumulative number of equivalent 80 kN single-axle loads
(E80s). A road is usually designed in accordance with an estimate of the
cumulative equivalent traffic over the road structure (pavement) during a certain
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design period. This design period is usually 20 years. If new unexpected traffic is
added to a road, the influence of the new E80s in proportion to the design E80s
as well as the E80s the road already carries are required to be compared.
Roads D2095 and D933 were typically designed to carry between 300 000 to
1 million E80s over a period of 20 years. Converted back linearly to a daily
loading, this corresponds with 46 – 137 E80s/day. If an additional 6 trucks are
added at an average of 2,56 E80s per truck, the extra daily loading is estimated
to be 15,4 E80s/day. This will result in an increase of 11 – 33% in current E80s.
From a visual assessment of the condition of the two roads utilised to access
Dudfield plant, it is estimated that these roads will be required to be rehabilitated
within the next 10 years as their remaining life of the pavement is in the order of
300 000 E80s. If the additional 6 trucks are added at an average of 2,56 E80s
per truck for 20 days a month over the next 10 years of the remaining life of the
pavement, a total of approximately 50 000 E80s will be added to the total
expected loading on these road pavements. This equates to an increase of 17%
of the loading, which is considered to be significant, but still acceptable
considering the existing load.
Typically, roads such as P183/1 and P28/4 are designed to carry between
1-3 million E80s during a 20-year design life. The impact of the additional 6
trucks associated with the introduction of AFR at Dudfield plant will, therefore, be
acceptable on these roads.
5.5.5. Assessment of Potential Impacts
Potential issues identified through the analysis of the impact of 6 additional trucks
required to haul AFR to the Dudfield plant can be summarised as follows:
• Growth in traffic volume and delay
• The impact on the road structural capacity
• Growth in heavy vehicle traffic.
The result of each assessment is provided in Table 5.6 and can be quantified as:
• Growth in traffic volume and delay: The growth in traffic volumes will
definitely occur and will be permanent unless the hauling of alternative fuels
by road is stopped. A slight delay in travelling time is anticipated for all road
users travelling to and from Lichtenburg via the routes used for hauling of AFR
to Dudfield plant.
• The impact on the road structural capacity: The addition of the extra trucks
will cause slight damage (E80s) to the road structure. This slight damage to
the road can be accommodated, as calculated in the structural capacity
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analysis. This is based on the premise that overloading of trucks will not be
allowed. The roads affected by the additional trucks are P183/1 and D2095
that represent the preferred route to carry AFR to Dudfield plant.
• Growth in heavy vehicle traffic: The growth in heavy vehicles will result in a
higher delay factor. The rise in the factor is very low and due to a currently
low factor on these roads, the rise will not be noticeable to the average road
user.
5.5.6. Conclusions and Recommendations
The conclusions and recommendations of this TIA are summarised as follows:
• With the extra waste trucks operating on the road network the delay factor
will rise by an acceptable percentage. The potential impact associated with
this rise is anticipated to be of low significance.
• With the operation of the extra 6 waste trucks on the road network there will
be a growth of 1,5% in the heavy vehicle volumes. This is a low impact of
low significance to the overall network.
• The loading (E80s) added by the 6 waste trucks on Road P183/1 is of an
acceptable level.
• Policies must be in place to ensure compliance with all relevant legislation
and requirements pertaining to the transport of goods by road, in particular
the loading of the vehicles.
• Road P183/1 is near the end of its structural design life. It is advised that
the rehabilitation of the road be incorporated into the budget of the North
West Province, Roads Department budget for the next 5 years.
• The preferred route to haul waste to the Dudfield plant via Lichtenburg is
along Buiten Street, Republiek Street, Roads P183/1 and D2095. This is
currently the route utilised by traffic travelling to Dudfield plant.
5.6. Potential Impacts on the Social Environment
The purpose of the Social Impact Assessment (SIA) is to provide a systematic
analysis in advance of the likely impacts a development event (or project) will
have on the day-to-day life of persons and communities. SIAs are undertaken to
assist individuals, communities, as well as government organisations to
understand and be able to anticipate the possible social consequences on human
populations and communities of proposed project development or policy changes.
It also serves to identify the potential for social mobilisation against the project,
identifies social impacts that cannot be resolved and variables that will need to be
addressed by avoidance or mitigation.
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Table 5.6: Assessment of potential traffic impacts associated with the introduction of AFR at Dudfield plant
Issues Road Extent Duration Severity Significance Risk/Likelihood
P28/4 Slight
P183/1 Slight
D2095 Slight
D933 Slight
Swart Street Slight
Republiek street Slight
Growth in Traffic Volume
Buiten Street
Localised Long Term
Moderately Severe
Low Will Definitely occur
P28/4 Slight
P183/1 Moderately Severe
D2095 Moderately Severe
D933 Moderately Severe
Swart Street Slight
Republiek street Slight
Impact on the road structural
capacity
Buiten Street
Localised Long Term
Slight
Low Will Definitely occur
P28/4
P183/1
D2095
D933
Swart Street
Republiek street
Growth in Heavy Vehicle Traffic
volume
Buiten Street
Localised Long Term Slight Low Will Definitely occur
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The following operational definitions of a social impact assessment, apply:
• “a process aimed at identifying the future consequences for human
populations of any public or private action that alters the way in which people
live, work, play, relate to one another, organise to meet their needs, and
generally cope as members of society” (Becker, 1999).
• “(an investigation into) the potential change in the activity, interaction and/or
sentiment of the community, as it responds to the impacts resulting from the
alteration in the surrounding social and biophysical environment” (adapted
from Burdge, 1995).
Both definitions highlight fundamental characteristics of the social environment
and the necessity to consider impacts on the individual per se, as well as impacts
on the individual in interaction with the social and biophysical environment. The
social impact assessment variables that were applied for the purposes of the
study (see below) served to elicit information regarding both these aspects.
5.6.1. Methodology
• Scope of the SIA
The SIA was conducted as per the requirements of the EIA regulations
(DEAT, 1998). The Social Impact Assessment contains ten steps that are in
logical sequence (although the implementation often overlaps). This
sequence is patterned on the steps associated with Environmental Impact
Assessment, and include:
∗ obtaining a description of the proposed action, with enough detail to
allow the identification of key data requirements needed from the project
proponent to frame the SIA;
∗ the compilation of a description of the relevant human environment in
which the project activity is to take place, as well as historic and existing
baseline conditions;
∗ the identification of probable impacts (issues and concerns);
∗ an investigation of the probable social impacts including a projection of
estimated effects (duration, intensity, probability and significance);
∗ the determination of the probable response of affected parties
(probability, nature and intensity of social mobilisation); and
∗ the formulation of potential mitigation measures.
The scope of the SIA investigation is based on the SIA variables developed by
Burdge (1995).
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• Social Impact Assessment Variables
Social Impact Assessment variables serve to explain the consequences of
specific developments and, as such, do not relate to the total social
environment. The following variables were assessed (Burdge, 1995) on the
basis that they reflect probable social impacts:
∗ Formation of attitudes and perceptions;
∗ Disruption in daily living and movement patterns;
∗ perceptions of public health and safety;
∗ community infrastructure needs;
∗ local impacts and regional benefits; and
∗ intrusion impacts.
Only variables considered to be relevant to this study were assessed, based
on, inter alia, factors relating to the probability of the events occurring and
the number of people impacted upon.
• SIA Data Sources
Information gathered and social issues identified and verified during the
public participation process undertaken as part of the Environmental Impact
Assessment served as key input to the SIA. The Issues Trail (refer to
Appendix F) was a primary data source and included information gathered
during focus group meetings, public meetings and individual consultation
sessions held with stakeholders and I&APs.
The findings from other specialist studies were considered within the
evaluation of social impacts, and served to place the impacts as perceived by
I&APs into perspective, thus facilitating a more accurate rating of impacts.
5.6.2. Formation of Attitudes and Perceptions
Stakeholder perceptions regarding the introduction of an AFR programme at Kiln
3 at Dudfield plant vary greatly. Some stakeholders have expressed concerned
about potential health or environmental impacts from the handling and
combustion of alternative fuels, whilst others are concerned that the quality of
the product may be compromised. The comment has also been raised that the
use of waste and by-products as a fuel will perpetuate the production of these
wastes and by-products in the long-term by offering a legal, cost-effective
alternative to disposal. On the other hand, some stakeholders note the potential
benefits associated with this technology through the reduction in the production
of greenhouse gas emissions and an alternative disposal method for waste and
by-products through use as AFR.
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In response to these comments, which have also been widely raised throughout
the world, Holcim has undertaken extensive technical work and environmental
studies together with institutional bodies such as the United States Environmental
Protection Agency (US EPA) in order to investigate and minimise the potential
adverse effects on human health, the environment or product quality as a result
of the use of AFR. Through these studies, the cement industry has been more
successful than any other in reducing its emissions (particularly in terms of
dioxins and furans (www.ckrc.org/ncafaq.html)) and thus its impact on human
health and the environment. In addition, the US EPA has confirmed that the use
of AFR within the cement manufacture process does not increase risks posed to
end users of cement.
5.6.3. Disruption in Daily Living and Movement Patterns
The disruption in daily living and movement patterns refers to the disruption in
activities of residents as a result of project-related activities. Heavy vehicle
movement associated with the transportation of AFR to the Dudfield plant has the
potential to disrupt the daily movement patterns of the local population
(particularly residents in Lichtenburg, the Dudfield village and surrounding
farming communities). However, as detailed in Section 5.5 above, a long-term
scenario of an additional 6 trucks per day transporting AFR to Dudfield plant is
anticipated. This will result in a 1% increase in the traffic volume on the access
routes to Dudfield plant. This is a very small growth in traffic and is considered to
be insignificant.
In addition, the area surrounding Dudfield plant is sparsely populated, typical of a
rural farming community. Population density for Lichtenburg and surrounding
areas is approximately 9 883, and 27 891 for Itsoseng and surrounding areas (as
per the 1996 census, Mr Israel Motlhabane pers. comm.). These centres are,
however, approximately 20 km away from the Dudfield plant. The greatest
population density in the immediate area surrounding the plant is Dudfield
Village, where approximately 200 people reside. The village is located
approximately 1 km south-west of the plant.
Therefore, the potential impact associated with disruption in daily living and
movement patterns as a result of this additional traffic is not considered to be
significant.
• Mitigation Measures:
In order to minimise potential impacts associated with additional heavy
vehicle movement for the transport of AFR to Dudfield plant, specified routes
(refer to Figure 5.4) should be utilised by vehicles transporting AFR to
Dudfield plant.
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In addition, the feasibility of utilising the empty AFR transport trucks leaving
Dudfield plant to transport the cement product from the plant should be
investigated. This may result in a reduction in the total number of heavy
vehicles required at Dudfield plant.
5.6.4. Impact on Infrastructure and Community Infrastructure Needs
Heavy vehicles required for the transportation of AFR to Dudfield plant have the
potential to impact on local road infrastructure. However, as detailed in Section
5.5 above, an increase of 17% of the loading on the road surface is anticipated as
a result of the introduction of these vehicles. This is considered to be a
significant increase, but is still acceptable considering the existing load.
Coal is currently transported to Dudfield plant via railway. This fuel source will
continue to be supplied to the plant in this manner. The potential to utilise the
existing railway to transport AFR in the future will be investigated. However, in
the short-term, this is not considered to be a viable option as the AFR sources will
vary in geographical location.
Dudfield plant is supplied with electricity via a dedicated substation. With the
introduction of the AFR programme at Dudfield plant, the kiln will continue to
operate at capacity. The current power supply to the plant is sufficient for the
operation of the plant with the introduction of the AFR programme and no
additional supply will, therefore, be required. Therefore, no impact on the
electricity supply to the surrounding areas is anticipated as a result of the
proposed project.
Water volumes utilised within the cement manufacture process will not be
required to be increased with the introduction of the AFR programme. Holcim will
continue to abstract and utilise water in terms of their existing water permits.
Therefore, no impact on the available water resources for the surrounding area is
anticipated as a result of the proposed project.
• Mitigation Measures:
In order to minimise potential impacts on road infrastructure as a result of
additional heavy vehicle movement for the transport of AFR to Dudfield plant,
specified routes (refer to Figure 5.4) should be utilised. The routes which
have been recommended are those which are currently utilised by all traffic
to access Dudfield plant.
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5.6.5. Health and Safety Impacts
• Potential Safety Impacts associated with Additional Road Traffic
Heavy vehicle movement associated with the transportation of AFR to the
Dudfield plant has the potential to impact on road-users and road safety
conditions. However, as detailed in Section 5.5 above, it is anticipated that
the additional vehicles associated with this transportation of AFR will result in
a 1% increase in the traffic volume on the access routes to Dudfield plant.
This is a very small growth in traffic, which is not anticipated to impact
significantly on road-users or road safety conditions.
With the transportation of AFR to Dudfield plant, the potential exists for
accidents and spillage of the fuel source. Without the implementation of
appropriate mitigation measures and the following of appropriate emergency
procedures, this could potentially impact significantly on road users and the
surrounding communities.
• Air/Dust Emissions
The potential impacts associated with increases in dust and dioxin levels as a
result of the proposed introduction of AFR at Dudfield plant have been raised
as a concern as they may pose a health risk to local communities. Dust
levels have, however, decreased with the recent implementation of bag filters
at Dudfield plant. A specialist air quality assessment study was undertaken
to evaluate this potential impact (refer to Section 5.4 and Chapter 6) and
indicates an impact of low significance as a result of the proposed AFR
project.
• Potential Safety Impacts for Employees Handling AFR
The introduction of AFR at Dudfield plant will require the handling of
hazardous substances by employees, which may potentially impact on the
health of these employees. However, strict handling procedures will be
implemented at Dudfield plant with the introduction of AFR and employees
will be adequately informed and trained with regards to these procedures.
Therefore, the potential health impact on employees handling hazardous
substances is anticipated to be of low significance.
• Mitigation Measures
∗ In order to minimise potential impacts on road users and road safety
conditions as a result of additional heavy vehicle movement for the
transport of AFR to Dudfield plant, specified routes (refer to Figure 5.2)
should be utilised.
∗ In the case of an accident or spillage, the first concern is for preservation
of human life and well-being. If the driver is alive and able, he should
vacate the vehicle as fast as possible. Damage and danger should be
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assessed rapidly. Sufficient information should be given to helpers in
order to get response from emergency services, if required. The driver
should use the vehicle’s communication system, if it is safe to do so, to
relay information to the control centre with regard to the
accident/spillage and they should then in turn notify all relevant parties.
∗ Mitigation measures relating to potential air pollution impacts and
monitoring of air quality by Holcim are addressed in detail within the air
quality specialist report (refer to Chapter 6). In order to ensure that the
potential health impacts associated with air emissions are minimised, it
must be ensured that these mitigation measures are implemented.
∗ Mitigation measures relating to the implementation of appropriate
handling procedures for AFR at Dudfield plant are addressed in detail in
the waste management specialist study (refer to Chapter 7). Specific
mitigation measures relating to the health and safety of employees which
should be implemented include:
- The nature of the facility and its associated activities calls for a
comprehensive training programme for all employees involved in the
handling of waste.
- The employees must undergo thorough medical examinations on an
annual basis. These tests must be specific to the type of work an
employee is doing and the hazards to which that employee is
exposed. Pre-employment and exit medicals are also essential to
ensure that the employee’s health has not been affected by his job.
- Detailed job analyses must be carried out to determine all tasks and
what they involve. This forms the basis of the training needs
analysis, as well as the type of medical tests required. It also
determines what safety precautions need to be taken and the type of
Personnel Protective Equipment to be issued.
5.6.6. Local Impacts and Regional Benefits
The Holcim South Africa Dudfield plant is one of two cement manufacturing plants
in the area. Limestone mining and cement manufacture are two of the major
economic activities currently undertaken in the area, providing employment to
members of the local community. The continued operation of the Dudfield plant
in an environmentally and economically sustainable manner will secure these
employment opportunities in the long-term. This is considered to have a positive
impact of high significance on the region.
5.6.7. Intrusion Impacts
The greatest population density in the immediate area surrounding the plant is
Dudfield Village, where approximately 200 people reside. The village is located
approximately 1 km south-west of the plant. Impacts on or the disturbance of
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this community already exist, and have done so since the initial construction of
the facility more than 50 years ago. Potential intrusion impacts associated with
the introduction of an AFR programme at Dudfield plant include:
• air quality impacts,
• visual impacts,
• noise impacts,
• impacts associated with increased heavy traffic, and
• impacts on ground and surface water and soil as a result of the storage of
fuel or potential accidents and spillage.
Results from other specialist studies have indicated that potential intrusion
impacts on air quality, traffic and water resources associated with the
introduction of the AFR programme at Kiln 3 are anticipated to be of low
significance. In addition, as the proposed project will be undertaken within the
boundaries of the existing Dudfield plant and will not require any additional
changes to the plant, no impacts are anticipated in terms of visual intrusion
impacts. The change in technology proposed (i.e. the use of AFR as a fuel
source) will not alter the current noise levels associated with the plant. The
primary source of noise at Dudfield plant is from the fans. Therefore, potential
intrusion impacts of anticipated to be of low significance.
A summary of the significance of the potential impacts on the social environment
as a result of the introduction of an AFR programme at Dudfield plant is provided
in Table 5.7.
5.7. Assessment of the Suitability of Waste as an Alternative Fuel
Resource
In order to generate the high temperatures required for cement manufacture,
large quantities of fuel are required to achieve and maintain kiln temperatures.
The use of waste derived alternative fuels can reduce the reliance of a kiln on a
natural resource while providing an effective method for managing waste
materials. In order to reduce their reliance on non-renewable fuel resources and
provide an innovative waste management solution Holcim South Africa has set an
initial goal of replacing a minimum of 35% of the coal used by Kiln 3 at the
Dudfield Plant with alternative waste derived fuels. Cement kilns are
acknowledged as being able to provide an ideal environment for the complete
combustion of waste derived fuels due to the very high temperatures (up to
2000oC), long solid residence time (up to 30 minutes), long gas residence times
(of 4 to 8 seconds), and the large excess of oxygen used.
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Table 5.7: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at Dudfield
plant
Nature of impact
associated with the
introduction of an
AFR programme
Extent Duration Severity Significance Likelihood
Confidence in
assessment of
impact
Mitigation and/or
Enhancement
Disruption in daily
living and movement
patterns
Localised Long-term Slight NoneUnlikely to
occurProbable
Utilisation of specified routes by
vehicles transporting AFR to
Dudfield plant and the
investigation of the feasibility
of utilising the empty AFR
transport trucks leaving
Dudfield plant to transport the
product from the plant.
Impact on
infrastructure and
community
infrastructure needs
Localised Long-term Slight LowUnlikely to
occurProbable
Utilisation of specified routes by
vehicles transporting AFR to
Dudfield plant.
Health and safety
impacts – road safetyLocalised Long-term Severe High
Unlikely to
occurProbable
Utilisation of specified routes by
vehicles transporting AFR to
Dudfield plant, as well as the
implementation of appropriate
emergency response
procedures.Health and safety
impacts – air
emissions
Localised Long-term Slight Low May occur Probable
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Table 5.7 cont: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at
Dudfield plant
Nature of impact
associated with the
introduction of an
AFR programme
Extent Duration Severity Significance Likelihood
Confidence in
assessment of
impact
Mitigation and/or
Enhancement
Health and safety
impacts – employees
handling AFR
Localised Long-term Severe High May occur Probable
Appropriate training and
regular medicals should be
provided. Job analysis should
be undertaken on a regular
basis.
Local impacts and
regional benefitsRegional Long-term Severe High (positive) Will occur Probable
Intrusion impacts Localised Long-term Severe Low May occur Probable
Appropriate mitigation for
potential air quality impacts,
traffic impacts and impacts on
water resources, noise impacts
and visual impacts.
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During the development of the National Waste Management Strategy by the
Department of Environmental Affairs and Tourism (DEAT; 1998), cement kilns
were identified as facilities that could effectively utilise waste materials such as
tyres, refuse derived fuel (RDF), hydrocarbon wastes and selected hazardous
wastes as fuels. Utilisation of materials that are normally designated as wastes
as a fuel or alternative feedstock for cement manufacture meets a number of
national strategic goals, including the beneficial use of wastes, conservation of
natural resources such as coal and reduction of the amount of waste being
disposed to landfills.
There are currently no formal regulatory requirements specific to the use of wasre
derived alternative fuels and resources (AFR) in cement kilns. Without
application specific standards and specifications to govern the use of AFR, the
approach has been to adopt the applicable waste standards, specifications and
procedures. This has been done to ensure that the most stringent of measures
are implemented in the utilisation of alternative fuel and resources. The
management procedures fall under the Duty of Care requirements that are
included in National Environmental Management Act (No 107 of 1998), the
Environment Conservation Act (No 73 of 1989), and the Department of Water
Affairs and Forestry’s Minimum Requirements.
Kiln 3 at the Holcim South Africa Dudfield plant has recently been upgraded and
is able to accept and process a variety of fuels. These fuels could include a wide
range of wastes both hazardous and non-hazardous. The fuels can occur in
varying forms including solid, sludge, liquid and gas states. The use of waste,
both as alternative fuels and as raw materials, introduces new challenges for the
cement plant and issues related to the transport, handling, storage and use of the
waste must be strictly controlled to ensure that any risk to the environment and
human health is appropriately managed. However, the classification, handling,
storage and transport of hazardous materials are well understood and are strictly
controlled by current legislation and the environmental authorities. The adoption
of the sound management techniques will ensure that any potential risks to
health, safety and the environment are kept within acceptable levels.
The management protocol for the utilisation of waste as a alternative fuel follows
a 'cradle to grave' approach, this means that it is the responsibility of Holcim
South Africa to ensure that the alternative fuels and resources are appropriately
managed, from identification of potential fuels to utilisation of the fuel in the kiln
and the control of any emissions from the kiln.
In order to determine the suitability of using AFR in the kiln it is critical to
identify, understand and manage the factors that could potentially create an
impact on health, safety or the environment. In addition, there can be no
compromise on the quality of the clinker and cement produced. Therefore, the
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types and nature of the AFR materials and their respective management
procedures that would be acceptable, as well as the limits on specific elements,
need to be specified and adhered to.
The primary management considerations required to ensure the total 'cradle to
grave' management of AFR include:
• AFR identification and acceptance procedures
• Documentation
• Packaging and labelling
• Loading at the generator’s premises
• Transportation
• Acceptance procedures at Dudfield plant
• Offloading
• Handling, storage on-site and feeding into the kiln
• Characteristics of the products and, if produced, any by-products from the kiln
Chapter 7 provides an assessment of the suitability and the risks associated with
the proposed introduction of an alternative fuels and resources (AFR) programme
at Dudfield's Kiln 3, and defines the management procedures that would be
required to be implemented by Holcim South Africa (with details of these
procedures provided in Appendix I).
5.7.1 Risks and Significance of Risks
The potential risks associated with the use of AFR in the manufacture of cement
are included in Table 5.8 together with an assessment of the significance of the
risks posed by natural events, technical problems and human error.
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Table 5.8: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human
Error
Aspect Risk Extent Duration Severity Probability Significance
Process
Waste Pre-
acceptance
Incorrect analysis or interpretation
of results could lead to incompatible
waste being accepted by facility.
Local Short term Slight Unlikely Low
Waste
Collection
Poor collection practices could lead
to minor spills.
Local Short term Moderate Unlikely Low
Transport Accidents could lead to spillage of
material.
Local Short term Severe Unlikely Low
Waste
Receiving
Area
Poor off-loading practices could lead
to minor chemical spills.
Local Short term Moderate Unlikely Low
Waste
Acceptance
Incorrect check analysis or
interpretation of results could lead
to incompatible waste being
accepted by facility.
Local Short term Slight to
Moderate
Unlikely Low
Waste
Storage
Incompatible waste stored or
flammable waste incorrectly
managed could lead to risk of fire or
explosion.
Local Short term Severe Very Unlikely Low to Moderate
Gas Storage Improper storage of the flammable
gas could lead to fire or explosion.
Local Short term Severe Very Unlikely Low to Moderate
Utilisation of
AFR
Poor operation of the plant could
lead to incomplete combustion.
Local Short term Moderate Very Unlikely Low to Moderate
Products
from the
Kiln
Contaminated clinker and cement
products entering the market.
National Long term Severe Very Unlikely Low
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Aspect Risk Extent Duration Severity Probability Significance
Natural Events
Flooding Flood water may enter waste
storage areas.
Local Short term Severe Very Unlikely Moderate
Fire Fire within the facility would lead to
considerable risks to plant personnel
inside the facility.
Local Short term Very severe Very Unlikely High
Fire Fire within the facility would lead to
considerable risks to the
environment outside the facility.
Local Short term Severe Very Unlikely Moderate
High Winds High winds could disperse pollutants
into the environment.
Local or
Regional
Short term Moderate Very Unlikely Low
Human Error
Data Entry
Error
Incorrect data could be provided by
the client or be input into the
database.
Local Short term Severe Unlikely Low
Unauthorise
d Access
People could gain unauthorised
access and exposed to potentially
hazardous materials.
Local Short to long
term
Severe Unlikely Low
AFR Spills Chemical spills could result in
contamination of soil and water.
Local Short term Severe Very Unlikely Low
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5.7.2 Recommendation on the determination of suitable AFR
In the identification of appropriate sources of AFR, the waste management
hierarchy needs to be taken into consideration. Simply stated, the recycling or
re-use of a waste stream must take preference over the treatment or disposal of
waste, where practical. This principle seeks to ensure that the most appropriate
management processes are selected to manage waste.
In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types
have been identified as unacceptable for an AFR programme at Dudfield. These
wastes will be refused as potential AFR for the following reasons:
• Health and safety issues (waste streams that represent an unacceptable
hazard from an environmental, occupational health or safety point of view).
• To promote adherence to the waste management hierarchy.
There are a variety of products or wastes that should not be processed or utilised
as AFR in the kilns. These include the following:
• Selected extremely toxic ('high risk') wastes, e.g. waste containing free
asbestos fibres and pure carcinogens, which will pose an unacceptable
occupational health and safety risk.
• Wastes that contain unacceptable levels of selected components that will
impact on the kiln performance, the quality of the clinker and cement and
adversely impact on the emissions from the kiln. These can include waste
with unacceptable levels of some heavy metals, e.g. mercury and lead, high
levels of halogenated hydrocarbons, etc.
• Unsorted domestic wastes (municipal garbage) because of the presence of
small amounts of hazardous materials and various metals, etc.
• Small-volume hazardous wastes from households (fluorescent lamps,
batteries etc.).
• Non-identified or insufficiently characterised wastes.
In addition, some waste streams could be an acceptable fuel, but require pre-
treatment before they would be acceptable for use at the kiln. This pre-
treatment would not be undertaken at Dudfield plant.
Limits of elements have been defined in order to avoid potential risks to human
health and the environment, and have taken the following criteria into
consideration:
• The formation of highly volatile compounds.
• High chloride concentrations.
• The cumulative levels of elements in other input materials.
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• The oxidation of some elements to their higher oxidation states. For example,
if an excessive amount of chromium is present in the kiln feedstocks, then the
potential exists for the oxidasation to chromium (VI) and lead to a product
that leaches this relatively mobile species.
Bearing the above criteria and assessment in mind, Holcim has produced a list of
wastes that are deemed unacceptable for AFR purposes. In terms of the Holcim
Group AFR Policy (Holcim Ltd, 2004), these unacceptable wastes consist of the
following:
• Anatomical hospital wastes (without pre-treatment)
• Asbestos-containing wastes
• Bio-hazardous wastes such as infectious waste, sharps, etc. (without pre-
treatment)
• Electronic scrap
• Whole batteries
• Non-stabilised explosives
• High-concentration cyanide wastes
• Mineral acids
• Radioactive wastes
• Unsorted general/municipal/domestic waste
Wastes that are acceptable as AFR for use by Kiln 3 should be delivered directly
to Dudfield plant. The suitable waste streams could include other non-hazardous
and hazardous wastes such as, but not limited to:
• Scrap tyres
• Rubber
• Waste oils
• Waste wood
• Paint sludge
• Sewage sludge
• Plastics
• Spent solvents
Of particular concern in South Africa is the disposal of scrap tyres to landfill.
Government is presently promulgating legislation to discourage the inappropriate
disposal of scrap tyres. As the number of scrap tyres generated in South Africa is
estimated at ~10 million per annum, with only ~2 million being used to produce
recycled rubber and recycled products the need for an appropriate disposal
method is critical. The use of scrap tyres as an alternative fuel offers an
environmentally acceptable and cost effective option of managing the scrap tyre
problem in South Africa, as the landfilling of scrap tyres is no longer an
acceptable practise.
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In order to successfully implement the AFR programme at Dudfield plant's Kiln 3,
the feed is preferably required to be of an appropriate volume in order to supply a
constant flow over an extended period. This minimises the need to adjust the
kilns operating parameters and thus reduces potential risks to the environment.
This, therefore, implies that smaller volume and irregular waste streams should
either not be accepted at Dudfield, or would need to be pre-processed to achieve
a uniform and constant fuel source at an appropriate volume. This pre-treatment
in not anticipated to be undertaken at Dudfield plant.
For the AFR streams that would be delivered directly to the kiln, an on-site
storage facility would need to be provided to accommodate/store an approximate
2-day reserve capacity.
5.7.3 Conclusion
The correct management of the wastes and the AFR is critical to the success of
this project and its operations. It is essential that AFR management is carried out
in a manner that does not impact on human health and well being and the
environment. The implementation of the procedures proposed in Chapter 7 (and
Appendix I) would ensure that any possible impact is minimised and that the
environmental and health risks are acceptable.
With the correct management and monitoring procedures in place, the utilisation
of AFR in the manufacture of cement could substitute a portion of the fuel load
requirement for Dudfield Kiln 3 and would not represent a significant risk to
human health and the environment.
The practice of using AFR in kilns has the following benefits to the environment
and the waste industry:
• Through the utilisation of waste materials, energy is recovered from
combustible wastes and inorganic materials.
• Conservation of non-renewable resources such as fossil fuels, i.e. coal and
oil, and inorganic materials such as iron ore.
• Reduction in landfill facilities required for the disposal of potentially polluting
materials and an overall reduction in waste volumes to landfill.
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6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY
6.1. Introduction
Typical air pollutants from cement manufacturing include sulphur dioxide (SO2),
oxides of nitrogen (NOx), inhalable particulates (PM10), heavy metals, organic
compounds and dioxins and furans. The objective of the air pollution impact
assessment was to provide best estimates of air concentrations associated with
the introduction of AFR at Dudfield plant.
Specialist investigations conducted as part of an air quality assessment typically
comprise two components, viz. a baseline study and an impact assessment study.
The baseline study includes the review of the site-specific atmospheric dispersion
potential, relevant air quality guidelines and existing ambient air quality in the
region. In this investigation, use was made of readily available meteorological
and air quality data recorded for the region in the characterisation of the baseline
condition.
In assessing the impact associated with the operations at the site, an emissions
inventory was compiled, atmospheric dispersion simulations undertaken, and
predicted concentrations evaluated. The evaluation of simulated concentrations
was based on available ambient air quality standards/guidelines. The comparison
of predicted concentrations with ambient air quality guidelines facilitated a
preliminary assessment of health risks. If concentrations were found to be
unacceptable in terms of such guidelines, a comprehensive quantitative health
risk assessment (based on exposure quantification and dose-response analysis)
was recommended.
A baseline study of the Dudfield Plant was investigated in a previous study
(Burger & Thomas, 2003) under normal routine operating conditions where coal
was used as an energy source. This study has subsequently been updated with
more recent monitored data from C&M Environmental Engineering to more
accurately reflect the associated impacts (refer to Appendix C of the Air Quality
specialist report contained in Appendix H for more detail).
6.2. Terms of Reference
The terms of reference required to assess the impact of air pollution emanating
from the proposed operations, were as follows:
• To obtain and analyse local meteorological data (e.g. wind speed, wind
direction and ambient temperature);
• To identify all pollutants resulting from the use of alternative fuels;
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• To quantify all significant pollutants resulting from the use of alternative
fuels, including case studies based on local and international emission limits
(e.g. EC Directive);
• Predict the highest hourly, the highest daily, and the annual average ground
level concentration levels;
• Analyse the predicted air concentrations both for compliance and potential
health risks;
• Prepare a significance-rating matrix; and
• Recommend an air quality management plan.
6.3. Methodological Overview
An emissions inventory was established for the proposed sources of emissions at
Dudfield. Such an inventory comprised the identification and quantification of all
significant sources. As inadequate quantifiable emission data was available,
emission limits applicable to similar operations elsewhere were employed.
Once the emission rates were known, mathematical dispersion modelling was
used to predict the dilution and transport of the released substance at various
distances from the sources. The US EPA approved Industrial Source Complex
Short Term (version 3) model (ISCST3) was used to simulate gaseous and
particulate concentrations due to site activities. ISCST3 is a steady state
Gaussian Plume model, which is applicable to multiple point, area and volume
sources.
Detailed hourly average wind speed, wind direction and temperature data was
obtained form the Lichtenburg Weather Service Station for the period January
1996 to August 2001. Detailed meteorological data is a necessity for the
assessment of the atmospheric dispersion potential of the study site.
6.4. Baseline Study
A detailed discussion of the regional climate and atmospheric dispersion potential
is given in Appendix A the Air Quality specialist report contained in Appendix H.
6.4.1. Local Wind Field
Wind roses comprise 16 spokes, which represent the directions from which winds
blew during the period. The colours in the wind rose reflect the different
categories of wind speeds, with the grey area, for example, representing winds of
1 m/s to 2 m/s. The dotted circles provide information regarding the frequency
of occurrence of wind speed and direction categories. For the current wind roses
(Figure 6.1), each dotted circle represents a 5% frequency of occurrence. The
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figure given in the centre of the circle described the frequency with which calms
occurred, i.e. periods during which the wind speed was below 1 m/s.
Figure 6.1: Wind roses for the period January 1996 to August 2001
Annual and monthly wind roses effectively reflect the synoptic systems affecting a
region. In order to investigate the impact of meso-scale circulation patterns it is
also essential to consider the diurnal variations in the wind field at the site. The
typical diurnal variations in the wind regime are evident in the day- and night-
time wind roses illustrated in Figure 6.1.
The spatial and diurnal variability in the wind field is clearly evident in the figure.
The wind dominates from the north with a 20% frequency of occurrence for the
total period. Increased wind frequencies for northerly winds of 5-10 m/s are
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noted for daytime hours with calm periods of 2,4% occurring for the period
January 1996 – August 2001. Nocturnal airflow is characterised by less frequent
strong winds (5-10 m/s) from the north and more frequent moderate winds
(2-4 m/s). Night time conditions have an increase in calm periods (8,2%) as is
typical of the night time flow regime in most regions.
6.4.2. Impact Assessment at Holcim-Dudfield Under Current Operating
Conditions
Appendix C of the Air Quality specialist report contained in Appendix H provides a
comprehensive discussion on the baseline (current operating conditions) impact
assessment undertaken for the Dudfield Plant.
The main conclusions from this study may be summarised as follows:
• The inhalable particulate concentrations (PM10) were below the daily and
annual average current DEAT as well as EC and proposed South African limits
with highest off-site concentrations at 7 µg/m³ and 0,7 µg/m³ respectively;
• Gaseous concentrations for nitrogen dioxide did not exceed the DEAT
guidelines with highest predicted off-site concentrations predicted at
3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ for highest hourly, daily and annual
averaging periods respectively;
• Predicted sulphur dioxide ground level concentrations were below the current
DEAT guidelines as well as the proposed South African and EC limits,
measuring 50 µg/m³1, 1,2 µg/m³ and 0.01 µg/m³ for highest hourly, daily
and annual averaging periods respectively;
• Highest predicted hourly carbon monoxide ground level concentration was
less than 0,1% of the current and proposed South African guidelines of
40 000 µg/m³ and 30 000 µg/m³ respectively;
• Predicted lead concentrations were insignificant when compared to the
current guidelines and EU and proposed South African limits;
• Predicted benzene concentrations are below proposed SA limits;
• Non-criteria pollutants are all below the screening levels and health risk
criteria;
• The predicted carcinogenic pollutants were predicted to cause less than 1 in
1 million chance of cancer (trivial cancer risk is considered to be 1 in 1
million, with acceptable cancer risk of 1 in 100 thousand as adopted by the
US-EPA);
• Dioxins and furans were below the relevant guidelines.
1 Using the 98th percentile the predicted hourly value is 20 µg/m³. The predicted
50 µg/m³ was predicted for a peak incident during the monitoring campaign.
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6.5. Environmental Legislation and Air Quality Guidelines
Prior to assessing the impact of the proposed operations at the Dudfield Plant,
Lichtenburg, reference need be made to the environmental regulations and
guidelines governing the emissions and impact of such operations.
Air quality guidelines and standards are fundamental to effective air quality
management, providing the link between the source of atmospheric emissions
and the user of that air at the downstream receptor site. The ambient air quality
guideline values indicate safe daily exposure levels for the majority of the
population, including the very young and the elderly, throughout an individual’s
lifetime. Air quality guidelines and standards are normally given for specific
averaging periods. These averaging periods refer to the time-span over which
the air concentration of the pollutant was monitored at a location. Generally, five
averaging periods are applicable, namely an instantaneous peak, 1-hour average,
24-hour average, 1-month average, and annual average.
The ambient air quality guidelines and standards for pollutants relevant to the
current study are discussed in section 6.5.1. to 6.5.2. Permit specifications for
emission concentrations are discussed in section 6.5.3 and EC emission limits in
Section 6.5.4.
6.5.1. Ambient Air Quality Standards and/or Guidelines for Criteria
Pollutants
A detailed discussion on the health impacts, air quality standards and effect
screening levels is given in Appendix B of the Air Quality specialist report
contained in Appendix H.
There are currently no air quality standards for South Africa. The Department of
Environmental Affairs and Tourism (DEAT) have issued ambient air quality
guidelines to support receiving environment management practices. Local
ambient air quality guidelines are only available for such criteria pollutants that
are commonly emitted, such as sulphur dioxide (SO2), lead (Pb), oxides of
nitrogen (NOx), and particulates. However, a standard has been proposed for
benzene. The level of exposure has as yet not been finalised.
The following tables summarise a number of air quality standards adopted by
certain countries. Also included in the tables are the proposed limit values, which
forms the basis for the proposed South African Air Quality Standards.
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Table 6.1: Current DEAT NOx guidelines
Ground Level ConcentrationsAveraging Period
µg/m³ ppm
Annual average 283 0.2
Max 24-hour average 566 0.4
Max 1-hour average 1 132 0.8
Table 6.2: Air quality standards for nitrogen dioxide (NO2)
Annual Average Max 1-hour Average
µg/m³ ppm µg/m³ ppm
South Africa (Proposed) (5) 40 0.021 200 0.10
United States EPA 100(1) 0.053(1) - -
European Community 40(2) 0.021(2) 200(3) 0.10(3)
United Kingdom 40 0.021 286 0.15
Canada (4) 100 0.053 400 0.20
Notes:(1)Annual arithmetic mean.(2)Annual limit value for the protection of human health, to be complied with by 1 January 2010.(3)Averaging times represent the 98th percentile of averaging periods; calculated from mean values per
hour or per period of less than an hour taken throughout the year; not to be exceeded more than 8
times per year. This limit is to be complied with by 1 January 2010.(4)Acceptable Canadian air quality objectives.(5)SABS, 2004.
Table 6.3: Air quality standards for inhalable particulates (PM10)
Maximum 24-hour
Concentration (µg/m³)
Annual Average
Concentration (µg/m³)
South Africa (Proposed) (9) 75 40
United States EPA 150(1)(2) 50(3)
European Union (EU)130(4)
250(5) 80
European Community (EC) 50(6) 30(7)
20(8)
Canada 24 -
Reference: Chow and Watson, 1998; Cochran and Pielke, 1992.
Notes:(1)Requires that the three-year annual average concentration be less than this limit;(2)Not to be exceeded more than once per year;(3)Represents the arithmetic mean;(4)Median of daily means for the winter period (1 October to 31 March);(5)Calculated from the 95th percentile of daily means for the year;(6)Compliance by 1 January 2005. Not to be exceeded more than 25 times per calendar year. (By 1
January 2010, no violations of more than 7 times per year will be permitted.)(7)Compliance by 1 January 2005;(8)Compliance by 1 January 2010;(9)SABS, 2004.
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Table 6.4: Air quality standards for lead
Quarterly Average (µg/m³) Annual Average (µg/m³)
South Africa (Proposed) (2) - 0.5
United States EPA 1.5 -
European Union - 2.0
Germany (1986) - 2.0
United Kingdom - 0.5(1)
Note:(1)Limit to be achieved by 2005, given as part of UK’s national air quality management plan.(2)SABS, 2004.
Table 6.5: Air quality standards for benzene(1)
Country/Organisation Annual Average (µg/m³)Long Term Goal/Limit
(µg/m³)
South Africa (Proposed) (4) 10 5
Australia 10 2.5
Great Britain 10 1.3
Germany 10(3) -
European Community 10 5(2)
Notes:(1)Health risk criteria and screening levels for Benzene are given in Section 2.3(2)Limit value to be reached by 1 January 2010(3)In effect as of 1 July 1998.(4)SABS, 2004.
6.5.2. Effect Screening Levels2 and Health Risk Criteria of Non-Criteria
Pollutants
In the current study (for the proposed usage fuel) reference was made to various
effects screening and health risk criteria to ensure that the potential for risks due
to all pollutants being considered could be gauged. (Effect screening levels are
generally published for a much wider range of pollutants compared to health risk
criteria.) Where various effect screening and health risk thresholds are available
for one pollutant, World Health Organisation (WHO) and Risk Assessment
Information System (RAIS) inhalation reference concentration is considered first.
If health criteria from these sources are not available, Office of Environmental
Health Hazard Assessment (OEHHA) and the Agency for Toxic Substances and
Disease Registry (ATSDR) Minimal Risk Levels (MRLs) has been used (refer to
Table 6.6).
2 Effects Screening Levels (ESLs) are used to evaluate the potential for effects to occur as
a result of exposure to concentrations in air. As no DEAT guidelines are available for
comparison these ESLs will be used for comparison during the current study. ESLs are
based on data concerning health effects, odour nuisance potential, vegetation effects, or
corrosion effects. They are not ambient air standards. If predicted or measured airborne
levels of a constituent do not exceed the screening level, we would not expect any adverse
health or welfare effects to result.
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6.5.3. Dioxins and Furans
Much of the public concern revolves around the extreme toxicity of dioxins.
These compounds have been shown to be extremely potent in producing a variety
of effects in experimental animals at levels hundreds or thousands of times lower
than most chemicals of environmental interest. Exposure to dioxins has been
linked to a variety of health effects, among others including immunotoxicity,
reproductive and developmental effects, and cancer. Dioxins have been found
throughout the world in practically all media including air, soil, water, sediment,
fish and shellfish, and other food products such as meat and dairy products. A
large proportion of human exposure to dioxins occurs through the food chain, and
it is therefore important to identify and control this potential pathway.
For dioxin-like compounds, the WHO specifies a tolerable daily intake (TDI),
which has been derived in units of toxicity equivalent (TEQ)3 uptakes. The upper
range of the TDI is given by the WHO as being 4 pg TEQ/kg of body weight over a
24-hour averaging period. The WHO stresses that this should be considered as a
maximal tolerable intake on a provisional basis and the ultimate goal is to reduce
human intake levels to below 1 pg TEQ/kg bodyweight. The TDI is given by the
WHO as representing a tolerable daily intake for life-time exposure. Occasional
short-term excursions above the TDI are given as having “no health
consequences provided that the averaged intake over long periods is not
exceeded” (WHO, 2000).
3 The toxic equivalency (TEQ) is determined by multiplying the concentration of a dioxin
congener by its toxicity factor. The total TEQ in a sample is then derived by adding all of
the TEQ values for each congener. While TCDD is the most toxic form of dioxin, 90% of the
total TEQ value results from dioxin-like compounds other than TCDD.
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Table 6.6: Effect screening and health risk criteria for various substances included in the investigation
RAIS Inhalation Reference
Concentrations (Jan 2004)
(µg/m³)
California OEHHA (Sept
2002) (µg/m³)
ATSDR MRL’s (Jan
2004) (µg/m³)(b)
WHO Guidelines (2000)
(µg/m³)
ConstituentSub-chronic
inhalation
RfCs
Chronic
inhalation
RfCs
Acute RELs
(a)
Chronic
RELsAcute Chronic
Acute & Sub-
acute
Guidelines
Chronic
Guidelines
Acetone 61762 30881
Arsenic & inorganic
compounds
0.19 (4 hrs) 0.03
Barium 0.5(g) 0.5(g)
Benzene 30 (f) 1300 (6hrs) 60 160
Beryllium 0.02 (f)
Cadmium & compounds (as
Cd)
0.9 (h)(e) 0.02 0.005
Chromium (VI) compounds 0.1 (f) 0.2
Cobalt & inorganic
compounds
0.02
Copper: dust & mist 100 (1 hr)
Manganese fume, dust &
inorganic compounds
0.05 (f)(i) 0.2 0.15
Mercury, metal & inorganic
forms
0.3(h) 0.3(f) 1.8 (1 hr) 0.09 1.0
Nickel, metal & insoluble
compounds
6.0 (1 hr) 0.05
Hydrogen chloride 20(f) 2100 (1 hr) 9
Hydrogen fluoride 240 (1 hr)
Silver 1.0(24 hrs)
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RAIS Inhalation Reference
Concentrations (Jan 2004)
(µg/m³)
California OEHHA (Sept
2002) (µg/m³)
ATSDR MRL’s (Jan
2004) (µg/m³)(b)
WHO Guidelines (2000)
(µg/m³)
ConstituentSub-chronic
inhalation
RfCs
Chronic
inhalation
RfCs
Acute RELs
(a)
Chronic
RELsAcute Chronic
Acute & Sub-
acute
Guidelines
Chronic
Guidelines
Vanadium 1.0 (24 hrs)
Xylene (all isomers except p)
p-xylene100 (k) 22000 (1 hr) 700
4800 (24
hrs)(g)870(i)
(a) Averaging period given in brackets;(b) ARSDR MRL’s are listed for pollutants and averaging periods that do not have other health criteria;(c) Central nervous system effects in human volunteers;(d) Neurotoxicity in rats;(e) Provisional risk assessment values;(f) Source: Integrated Risk Information System (IRIS);(g) Source: Health Effects and Environmental Affects Summary Table (HEAST) 1995; Dates withdrawn(h) July 1997;(i) January 1998.
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Table 6.7: Toxicity equivalency factors for dioxins and furans
Congener TEF (WHO)
Mono-, di- and tri-chlorodibenzodioxins 0
2,3,7,8,-Tetrachlorodibenzodioxin (TCDD)
Other TCDDs
1
0
1,2,3,7,8-Pentachlorodibenzodioxin (PeCDD)
Other PeCDDs
1
0
1,2,3,4,7,8-Hexachlorodibenzodioxin (HxCDD)
1,2,3,6,7,8- Hexachlorodibenzodioxin (HxCDD)
1,2,3,7,8,9- Hexachlorodibenzodioxin (HxCDD)
Other HxCDDs
0.1
0.1
0.1
0
2,3,7,8-Heptachlorodibenzodioxin (HpCDD)
Other HPCDDs
0.01
0
DIO
XIN
S
Octachlorodibenzodioxin (OCDD) 0.0001
Mono-, di- and tri-chlorodibenzofurans 0
2,3,7,8-Tetrachlorodibenzofuran (TCDF)
Other TCDFs
0.1
0
1,2,3,7,8-Pentachlorodibenzofuran (PeCDF)
2,3,4,7,8-Pentachlorodibenzofuran (PeCDF)
Other PeCDFs
0.05
0.5
0
1,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF)
1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF)
1,2,3,7,8,9-Hexachlorodibenzofuran (HxCDF)
2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF)
Other HxCDFs
0.1
0.1
0.1
0.1
0
1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF)
1,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF)
Other HPCDFs
0.001
0.001
0
FU
RA
NS
Octachlorodibenzofuran (OCDF) 0.0001
Assuming that all of the dioxin to which a 70 kg person is exposed is absorbed,
and given an average breathing rate of 1 m3/hr, the tolerable daily intake (TDI)
of the US-EPA, ATSDR and WHO could be calculated to coincide with 24-hour
inhalation concentrations of the following:
• US-EPA - 2.0 x 10-7 µg/m3
• ATSDR - 2.91 x 10-5 µg/m3
• WHO - 2.91 x 10-5 to 1.17 x 10-4 µg/m3
The USEPA unit cancer risk factor for dioxins is 33 (µg TEQ/m3)-1. The annual
average air concentration at the position of maximum exposure corresponding
with a cancer risk of one in a hundred thousand is 3.03 x 10-7 µg/m3. This does
not take into account exposure through the other potential pathways.
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6.5.4. Cancer Risk Factors
Unit risk factors are applied in the calculation of carcinogenic risks. These factors
are defined as the estimated probability of a person (60-70 kg) contracting
cancer as a result of constant exposure to an ambient concentration of 1 µg/m3
over a 70-year lifetime. In the generic health risk assessment undertaken as part
of the current study, maximum possible exposures (24-hours a day over a 70-
year lifetime) are assumed for all areas beyond the boundary of the site.
Table 6.8: Unit risk factors from the US-EPA Integrated Risk Information
System (IRIS) (as at July 2003) and WHO risk factors (2000)
ChemicalWHO Inhalation Unit Risk
(µg/m³)-1
US-EPA Unit Risk
Factor (µg/m³)-1
US-EPA
Cancer Class(c)
Arsenic, inorganic (a) 1.5E-03 4.3E-03 A
Benzene 4.4E-06 to 7.5E-06 2.2E-06 to 7.8E-06 A
Beryllium 2.4E-03 B1
Cadmium (b) 1.8E-03 B1
Chromium VI
(particulates)
1.1E-02 to 13E-02 1.2E-02 A
Nickel 3.8E-04 2.4E-04 A
Note:
(a) Date withdrawn by US-EPA: January 1998.
(b) Date withdrawn by US-EPA: July 1997.
(c) EPA cancer classifications:
A--human carcinogen.
B--probable human carcinogen. There are two sub-classifications:
B1--agents for which there is limited human data from epidemiological
studies.
B2--agents for which there is sufficient evidence from animal studies and
for which there is inadequate or no evidence from human epidemiological
studies.
C--possible human carcinogen.
D--not classifiable as to human carcinogenicity.
E--evidence of non-carcinogenicity for humans.
Unit risk factors were obtained from the WHO (2000) and from the US-EPA IRIS
database (accessed July 2003). Unit Risk Factors for compounds of interest in
the current study are given in Table 6.8.
6.5.5. Permit Specifications
For the current study the permit specifications for SO2, NO2 and PM10 stack
emissions were used (refer to Table 6.9).
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Table 6.9: Permit specifications for stack PM10 emissions
Emission Limits
(mg/Nm³)Permit No.Nature of
ProcessDivision
Height
(m)SO2 NO2 PM10
Extraction
System
Kiln 3 76 32.18 800 50 Bag Filter
Cement Mill 1 30 N/A N/A 50 Bag FilterNWPG/DAC&E/
ALPHA/SP22/01
Aug03
Cement
Processes
(No. 22) Cement Mill 2 30 N/A N/A 100Electrostatic
Precipitator
6.5.6. Emission Limits
Air emission limit values for cement kilns are stipulated in Directive 2000/76/EC
of the European Parliament and of the Council (4 December 2000). A synopsis of
these emission limit values as well as a comparison to the DEAT limits for class
1 incinerator is provided in Table 6.10. Emission concentrations specified as part
of these regulations are expressed at 0°C and 101.3 kPa, dry gas and 10%
oxygen.
Table 6.10: Comparison of EC emission limit values for emissions from co-
incineration of waste in cement kilns (Directive 2000/76/EC) and
DEAT class 1 incinerator
Pollutant
DEAT Limit(Class 1
incinerator)
EU Directive
2000/76/ECUnits
Total dust 150 30 mg/Nm³
HCl 30 10 mg/Nm³
HF 30 1 mg/Nm³
NOx for existing plants
NOx for new plants
800 (a)
500 (b)mg/Nm³
SO2 25 50 mg/Nm³
TOC 10 mg/Nm³
Cd + Tl 0.05 (c) 0.05 mg/Nm³
Hg 0.05 0.05 mg/Nm³
Sb + As + Pb + Cr + Co
+ Cu + Mn + Ni + V0.05 (c) 0.5 mg/Nm³
Dioxins toxic equivalence 0.2 0.1 ng/Nm³
Notes:
(a) For existing plants
(b) For new plants
(c) Limit value for each individual element.
6.6. Process Description and Emissions Inventory
The establishment of an emissions inventory comprises the identification of
sources of emission, and the quantification of each source's contribution to
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ambient air pollution concentrations. The emission sources of concern for
proposed usage of alternative fuels consisted of Kiln 3, Cement Mill 1 and Cement
Mill 2. An emissions inventory for Kiln 3 was established using EC limits (as
inadequate quantitative information was available for the current study), forming
the basis for assessing the impact of the Dudfield Plant on the receiving
environment.
A detailed description of the cement manufacturing process is provided in Chapter
4.
6.6.1. Studies on Emissions from Cement Kilns Utilising Alternative
Fuels
• Oxides of Nitrogen Emissions:
All combustion processes primarily produce NO with a much smaller
proportion of NO2 (<5%). In cement kilns NO is formed only at elevated
temperatures (>800°C). The main areas of formation will consist of the main
flame due to the nitrogen in the air, at the secondary firing from nitrogen in
the fuel as well as small quantities in the raw material. The formation of NO
is determined by flame temperature, oxygen content, residence time and the
nitrogen in the fuel (pers. com. ACMP). As these parameters are to remain
similar and the nitrogen in the alternative fuel not differing from that of coal,
the emissions are expected to remain comparable to that of baseline
conditions.
In addition, the US-EPA emission factors for cement kilns equates to 2.1
kg/tonne clinker (EPA, 1996). The equivalent emission factor using the EC
emission limit for NOx is similar at 2.8 kg/tonne clinker. Measured NOx
emission ranges from European cement kilns are in the range of <0.4-6
kg/tonne clinker (AEA Technology, 2002).
• Sulphur Dioxide Emissions:
SO2 is formed from sulphur in raw material and fuel. Under normal
conditions any sulphur introduced into the rotary kiln or the secondary
firing/precalciner part of the preheater/precalciner kiln system only
marginally contributes to the kiln’s SO2 emissions. This is different with the
sulphur in the form of sulfides and organic sulphur contained in the raw meal
and fed in the usual way to the preheater top cyclone. About 30% of this
sulphide and organic sulphur input leave the preheater as SO2. During direct
operation most of it is emitted to the atmosphere while during compound
operation (that is when the kiln exhaust gases are passing through the raw
mill) 30-90% of the SO2 is absorbed in the raw mill. In some cases the
absorption of fuel sulphur can reach up to 90% (CEMBUREAU, 1999). The
sulphur content in coal is ~0.86% and in alternative fuels (specifically tyres)
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is approximately 1,63% (pers. Comm. ACMP). However, SO2 emissions are
to a large extent determined by the chemical characteristics of the raw
materials used, and not by the fuel composition (CEMBUREAU, 1999).
The measured baseline emission for the 95th percentile is 1.2 g/s (C & M
Consulting Engineers). The equivalent emission rate using the EC emission
limit for SO2 is 7g/s, more than double the emissions for baseline conditions.
Nonetheless, the predicted impact using the EC emission limit was less than
10% of the respective guidelines.
• Heavy Metal Emissions:
Metals are present in raw materials and fuels at widely variable
concentrations. The behavior of the metals in a cement kiln depends on their
volatility. Non-volatile metals and metal compounds (i.e. arsenic, cobalt,
chromium, copper, manganese, nickel, lead, antimony, tin, vanadium and
zinc) remain within the process and leave the kiln as part of the clinker.
Semi-volatile metals (i.e. cadmium and thallium) are partly taken into the
gas phase at sintering temperatures and condense on the raw material in
cooler parts of the kiln system. Volatile metals (i.e. mercury) can exhibit
similar behaviour but may also be emitted with flue gas (AEA Technology,
2002). Considering car tyres as an alternative fuel it is well known that car
tyres contain more zinc and cadmium, but less mercury and arsenic than
fossil fuels (Mukherjee et al., 2001).
• Dioxin and Furan Emissions:
Any chlorine input in the presence of organic material may potentially cause
the formation of polychlorinated dibenzodioxins (PCDDs) and polychlorinated
dibenzofurans (PCDFs) in heat (combustion) processes. PCDDs and PCDFs
can be formed in/after the preheater and in the air pollution control device if
chlorine and hydrocarbon precursors from the raw materials are available in
sufficient quantities. It is important that as the gases are leaving the kiln
system they should be cooled rapidly through this range. In practice this is
what occurs in preheater systems as the incoming raw materials are
preheated by the kiln gases. Due to the long residence time in the kiln and
the high temperatures, emissions of PCDDs and PCDFs are generally low
during steady kiln conditions. In this case, cement production is rarely a
significant source of PCDD/F emissions. Nevertheless, from the data reported
in the document “Identification of Relevant Industrial Sources of Dioxins and
Furans in Europe” there would still seem to be considerable uncertainty about
dioxin emissions (Landesumweltamt Nordrhein-Westfalen as cited in United
Nations Environment Programme, 2003).
The reported data indicate that cement kilns can mostly comply with an
emission concentration of 0,1 ng TEQ/Nm³, which is the limit value in several
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Western European legislation for hazardous waste incineration plants.
German measurements at 16 cement clinker kilns (suspension preheater
kilns) during the last 10 years indicate that the average concentration
amounts to about 0,02 ng TEQ/m³ (Schneider et al (1996) as cited in United
Nations Environment Programme, 2003).
There is no significant difference in dioxin emissions associated with the use
of waste derived fuels (including waste oil and scrap tyres) (Mukherjee et al.,
2001) (refer to Table 6.11). Dioxin measurements done by INFOTOX (Pty)
Ltd (2002) at the Dudfield Plant were between 0,014 to 0.28 µg TEQ/tonne
clinker. The equivalent emission factor using the EC emission limit is
0,34 µg TEQ/tonne clinker.
Table 6.11: International emissions data for cement production emissions of
dioxins
Study Dioxin Emissions (µg TEQ/tonne clinker)
Australia
- Standard fuel
- With waste derived fuel
0.0043 – 0.25
0.0087 – 0.28
US (US EPA, 2000)
- Standard fuel
- With waste derived fuel
0.27
1.04 (pollution control device inlet temp < 450°F)
UK
- Standard fuel
- With waste derived fuel
0.025 – 1.04
0.025 – 1.08
6.6.2. Limitations of the Given Source Inventory
• Process Emissions:
Actual emissions for the proposed usage of alternative fuels in Kiln 3 at the
Dudfield Plant have not been measured (e.g. through a trial burn).
Furthermore, there is inadequate information provided for the current study
of the type and quantity of fuel to be used.
• Fugitive Emissions:
The quantification and impact of fugitive emissions (i.e. materials handling
operations, exposed stockpiles and vehicle emissions) was not investigated
since the introduction of an alternative fuels and resources programme would
only affect stack emissions.
• Decommissioning and Start-Up Phase:
The decommissioning phase of current operations at Kiln 3, as well as the
start-up phase for proposed usage of alternative fuels in Kiln 3 was not
investigated during the current study. Information pertaining to changes in
emission rates, and the duration and sequence of these changes are not
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known. The process design for the current study was not at an advanced
enough stage to provide this information.
6.6.3. Emission Inventory for Proposed Usage of Alternative Fuels and
Resources at Dudfield Plant
The source data requirements of the model are dependent on the manner in
which sources are classified, viz. as area, point or volume sources. Stack
releases are the only source type evident at the plant and will be modelled as
point sources. Stack parameters required for the simulation of point sources
include: source location, stack height, gas exit velocity, temperature and stack
diameter. The main pollutants of concern resulting from the current and
proposed routine operating conditions consisted of SO2, NOx, PM10, heavy
metals, organic compounds and dioxins and furans from Kiln 3, and PM10
emissions from the two cement mills. Holcim South Africa supplied a range of the
volumetric flow rate for Kiln 3 under proposed operating conditions. This range
was considered for the dispersion simulation in the current study. Information
regarding the stack parameters and emission rates needed for the dispersion
simulations is presented in Table 6.12. A summary of the total emissions from
the Dudfield Plant is given in Table 6.13 to Table 6.15.
Table 6.12: Stack parameters for the Dudfield Plant for proposed usage of
alternative fuels
Exit Velocity (m/s)Source
Height
(m)
Diameter
(m)
Temperature
(°C)Minimum Average Maximum
Kiln 3 76 3.75 110 17.8 20.0 26.7
Cement Mill 1 30 1.162 70 8.6
Cement Mill 2 30 0.710 93.5 18.2
The total given by the EC Directive for heavy metals was used for the study. The
composition of the heavy metals was assumed to be similar to monitored values
by C & M Consulting Engineers (2002). It should be noted however, that these
heavy metals may be emitted in different ratios as notably zinc (although mostly
in particulate form) increases with the use of tyres in comparison to coal, and
similarly mercury decreases.
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Table 6.13: Emission rates for criteria pollutants from the stacks at the
Dudfield Plant for proposed usage of alternative fuels
Emissions measured in (g/s)
PM10 NOx SO2Source
Min Ave Max Min Ave Max Min Ave Max
Kiln 3 (2) 4.2 4.7 6.3 112.0 126.0 168.0 7.0 7.9 10.5
Cement Mill 1 0.33 (1) - -
Cement Mill 2 0.43 (1) - -(1)Monitored data provided by Holcim South Africa(2)Based on EC emission limits
Table 6.14: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 for
proposed usage of alternative fuels (a)
Emission (g/s)Compound
Minimum Average Maximum
Antimony 8.33E-04 9.39E-04 1.25E-03
Arsenic 1.24E-03 1.40E-03 1.86E-03
Cadmium 1.05E-05 1.19E-05 1.58E-05
Chromium 9.12E-03 1.03E-02 1.37E-02
Cobalt 2.99E-03 3.37E-03 4.50E-03
Copper 4.45E-03 5.01E-03 6.70E-03
Lead 3.95E-03 4.45E-03 5.94E-03
Manganese 3.05E-02 3.44E-02 4.59E-02
Mercury 6.99E-03 7.87E-03 1.05E-02
Nickel 1.13E-02 1.27E-02 1.70E-02
Thallium 6.97E-03 7.86E-03 1.05E-02
Vanadium 5.49E-03 6.19E-03 8.27E-03
Dioxin Toxic Equivalence 1.40E-08 1.57E-08 2.10E-08
(a) Composition of emissions were based on measured emissions from C&M Environmental
Engineers (2002).
Table 6.15: Halogen Compound Emissions from Kiln 3 for proposed usage of
alternative fuels (a)
Emission (g/s)Compound
Minimum Average Maximum
HCl 1.40 1.57 2.1
HF 0.14 0.16 0.21
(a) Emissions were based on EC emission limits
6.6.4. Emission Estimation
Emission limits are given for chromium with no provision being made for the form
in which the chromium is emitted. Since hexavalent chromium is considered to
be a carcinogen, it is significantly more important than the trivalent and other
valencies. Hexavalent chromium from combustion processes is typically 10% of
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the total chromium emissions (UK, 2002). It will also be important to establish
the actual chromium compounds, because carcinogenicity has been linked only to
certain chromium salts, namely, calcium chromate, chromium trioxide, lead
chromate, strontium chromate and zinc chromate.
6.6.5. Comparison of Simulated Emissions to Permit Specifications
The PM10 emissions from Kiln 3 under proposed (usage of alternative fuels)
operating conditions are within the permit requirements. Holcim are confident
that the SO2 permit of 32 mg/Nm³ will not be exceeded with the proposed usage
of alternative fuel. The PM10 emissions from the Cement Mill 1 and Cement Mill
2 are within the permit requirements.
6.7. Dispersion Simulation Methodology And Data Requirements
Dispersion models compute ambient concentrations as a function of source
configurations, emission strengths and meteorological characteristics, thus
providing a useful tool to ascertain the spatial and temporal patterns in the
ground level concentrations arising from the emissions of various sources.
Increasing reliance has been placed on concentration estimates from models as
the primary basis for environmental and health impact assessments, risk
assessments and emission control requirements. It is, therefore, important to
carefully select a dispersion model for the purpose.
For the purpose of the current study, it was decided to use the well-known US-
EPA Industrial Source Complex Short Term model (ISCST3). The ISCST3 model
is included in a suite of models used by the US-EPA for regulatory purposes.
ISCST3 (EPA, 1995a and 1995b) is a steady state Gaussian Plume model, which
is applicable to multiple point, area and volume sources. Gently rolling
topography may be included to determine the depth of plume penetration by the
underlying surface. A disadvantage of the model is that spatial varying wind
fields, due to topography or other factors cannot be included. A further limitation
of the model arises from the models treatment of low wind speeds. Wind speeds
below 1 m/s produce unrealistically high concentrations when using the Gaussian
plume model, and therefore all wind speeds below 1 m/s are simulated using
1m/s.
Concentration for various averaging periods may be calculated. It has generally
been found that the accuracy of off-the-shelf dispersion models improve with
increased averaging periods. The accurate prediction of instantaneous peaks are
the most difficult and are normally performed with more complicated dispersion
models specifically fine-tuned and validated for the location. The duration of
these short-term, peak concentrations are often only for a few minutes and on-
site meteorological data are then essential for accurate predictions.
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The Industrial Source Complex model is perhaps the subject of most evaluation
studies in the United States. Reported model accuracies vary from application to
application. Typically, complex topography with a high incidence of calm wind
conditions, produce predictions within a factor of 2 to 10 of the observed
concentrations. When applied in flat or gently rolling terrain, the USA-EPA (EPA,
1986) considers the range of uncertainty to be -50% to 200%. The accuracy
improves with fairly strong wind speeds and during neutral atmospheric
conditions.
There will always be some error in any geophysical model, but it is desirable to
structure the model in such a way to minimise the total error. A model
represents the most likely outcome of an ensemble of experimental results. The
total uncertainty can be thought of as the sum of three components, i.e.:
• the uncertainty due to errors in the model physics;
• the uncertainty due to data errors; and
• the uncertainty due to stochastic processes (turbulence) in the atmosphere.
The stochastic uncertainty includes all errors or uncertainties in data such as
source variability, observed concentrations, and meteorological data. Even if the
field instrument accuracy is excellent, there can still be large uncertainties due to
unrepresentative placement of the instrument (or taking of a sample for
analysis). Model evaluation studies suggest that the data input error term is
often a major contributor to total uncertainty. Even in the best tracer studies,
the source emissions are known only with an accuracy of approximately 5%,
which translates directly into a minimum error of that magnitude in the model
predictions. It is also well known that wind direction errors are the major cause
of poor agreement, especially for relatively short-term predictions (minutes to
hourly) and long downwind distances. All of the above factors contribute to the
inaccuracies not even associated with the mathematical models themselves.
Input data types required for the ISCST3 model include: source data,
meteorological data, terrain data and information on the nature of the receptor
grid.
6.7.1. Meteorological Requirements
ISCST3 requires hourly average meteorological data as input, including wind
speed, wind direction, a measure of atmospheric turbulence, ambient air
temperature and mixing height. The hourly average data was obtained from the
Weather Service in Lichtenburg for the period January 1996 to August 2001. The
mixing height for each hour of the day was estimated for the simulated ambient
temperature and solar radiation data. Daytime mixing heights were calculated
with the prognostic equations of Batchvarova and Gryning (1990), while
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nighttime boundary layer heights were calculated from various diagnostic
approaches for stable and neutral conditions, as mentioned previously.
6.7.2. Receptor Grid
The dispersion of pollutants emanating from the plant was modelled for an area
covering approximately 5 km by 5 km. The area was divided into a grid matrix
with a resolution of approximately 152 m, with the proposed sites located at the
centre of the receptor area. The ISCST3 simulates ground-level concentrations
for each of the receptor grid points.
6.7.3. Source Data Requirements
Emission rates for Cement Mill 1 and Cement Mill 2 provided by Holcim South
Africa and emission rates based on EC limits for Kiln 3, were used in the
dispersion simulations for proposed (use of alternative fuel) operating conditions
of these sources.
6.7.4. Building Downwash Requirements
Building heights need to be taken into account in the modelling of emissions so as
to account for building downwash effects in the dispersion simulations. The flow
characteristics of air moving over the factory and office buildings may include a
downwash on the leeward side, drawing the plume to the ground near the source.
(Stack heights of greater than twice the height of adjacent buildings are
considered not to give rise to the potential for building downwash effects).
Building down-wash algorithms have been developed for air quality dispersion
models such as the ISCST3. These algorithms require additional input to be
prepared and included in the model runs.
6.8. Atmospheric Dispersion Results and Discussion
6.8.1. Results of Criteria Pollutants
The acceptability of the proposed routine operation (with the usage of alternative
fuels), in terms of its potential air quality impacts, depends on its ability to
demonstrate compliance with both emission limits and ambient air quality
guidelines.
• Permit Specifications:
The SO2 and PM10 emissions from Kiln 3, Cement Mill 1 and Cement Mill 2 for
baseline conditions are within permit requirements. The PM10 emissions
from Kiln 3 under proposed (usage of alternative fuels) operating conditions
are within the SO2 permit requirements. Holcim are confident that the permit
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of 32 mg/Nm³ will not be exceeded with the proposed usage of alternative
fuel. The PM10 emissions from the Cement Mill 1 and Cement Mill 2 are
within the permit requirements.
• Impact Assessment:
Prior to an analysis of the simulation results, it is recommended that a brief
review be undertaken of the uncertainty associated with these results. The
range of uncertainty of the Industrial Source Complex Model is given by the
US-EPA as being in the range of -50% to +200% when used under the
recommended conditions. Uncertainties are, however, not only associated
with the mathematical models themselves, but also with the generation of
the meteorological and source data used as input to such models. Errors in
source strengths translate directly into errors of similar magnitudes in the
model prediction.
A synopsis of the highest hourly, highest daily and annual average criteria
pollutant concentrations predicted to occur is given in Table 6.16. Predicted
concentrations were compared with current DEAT air quality guidelines to
determine compliance. Since South Africa is in the process of revising these
guidelines it was necessary to compare the predicted concentrations with the
limits proposed for adoption by South Africa. Reference was also made to
the widely referenced EC limit values, which are considered to represent 'best
practice' limits, which closely reflect WHO guidelines. The results of these
comparisons are reflected in Table 6.16.
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Table 6.16: Maximum offsite concentrations (measured in µg/m³) at the Dudfield Plant boundary of criteria pollutants predicted to
occur due to proposed usage of alternative fuels also given as a ratio of various air quality guidelines and standards (a)(b)
Maximum Predicted GroundLevel Concentrations (µg/m3)
Maximum PredictedConcentrations as a
Percentage of Current SA AirQuality Guidelines (a)
Maximum PredictedConcentrations as a
Percentage of Proposed SA AirQuality Limits (a)
Maximum PredictedConcentrations as a
Percentage of EC Air QualityLimits (a)Pollutant
EmissionRate
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Min - 6.3E+00 5.7E-01 - 3.5 <1 - 8.4 1.4 - 13 1.9Ave - 6.3E+00 5.7E-01 - 3.5 <1 - 8.4 1.4 - 13 1.9PM10Max - 6.2E+00 5.7E-01 - 3.4 <1 - 8.3 1.4 - 12 1.9Min 3.2E+02 6.0E+01 2.4E+00 2.8 11.0 <1 - - - - - -Ave 2.9E+02 5.0E+01 2.4E+00 25 9.0 <1 - - - - - -N0x(e)Max 2.7E+02 3.4E+01 2.4E+00 23 6.0 <1 - - - - - -Min 2.8E+00 5.0E-01 2.0E-02 <1 <1 <1 1.4 - <1 1.4 - <1Ave 2.6E+00 4.5E-01 2.0E-02 <1 <1 <1 1.3 - <1 1.3 - <1NO2Max 2.4E+00 3.0E-01 2.0E-02 <1 <1 <1 1.2 - <1 1.2 - <1Min 2.0E+01 2.8E+00 1.5E-01 - 2.2 <1 - 2.2 <1 5.7 2.2 <1Ave 1.8E+01 2.2E+00 1.5E-01 - 1.8 <1 - 1.8 <1 5.1 1.8 <1S02Max 1.7E+01 2.0E+00 1.5E-01 - 1.6 <1 - 1.6 <1 4.9 1.6 <1
Min - - 8.7E-05 - - - - -<1(c)
<1(d) - - <1
Ave - - 8.7E-05 - - - -- -<1(c)
<1(d) - - <1Lead
Max - - 8.5E-05 - - - - -<1(c)
<1(d) - - <1
Notes:
(a) A ratio of 1.0 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Ratios of greater than 1.0 indicate an exceedance of such
limits.
(b) The actual air quality guidelines and limits referred to are documented in Section 3.
It has been proposed that the South African limit for lead be revised with the adoption of an annual average limit of (c) 0.5 µg/m3 and (d) 0.25 µg/m3 being recommended
as the level to be aimed for in the longer term.
(e) Guidelines are not usually specified for NOx. However the Department of Environmental Affairs and Tourism provides guideline levels for this group. EC limits are only
specified for NO2 ground level concentrations (to be complied with by the 1 January 2010).
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∗ Inhalable Particulates (PM10):
Maximum predicted off-site PM10 ground level concentrations under
current and proposed operating conditions for highest daily and annual
averaging periods are below the current Department of Environmental
Affairs and Tourism (DEAT) guidelines, as well as the EC and proposed
South African limits.
∗ Oxides of nitrogen (NOx):
For current operating conditions (with the installation of the low-NOx
burner), highest predicted off-site NO2 ground level concentrations are
below DEAT as well as EU and proposed South African limits. Highest
hourly, daily and annual ground level concentrations are predicted to be
3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ respectively. This does not include
the NO2 formed from NO further downwind from the source. However,
the NO concentration at these distances would already be significantly
diluted after the atmospheric conversion.
Under proposed operating conditions, highest predicted off-site NOx
ground level concentrations for highest hourly, daily and annual
averaging concentrations at 315 µg/m³, 60 µg/m³ and 2,4 µg/m³ are
below the current respective DEAT guidelines. The previous
measurements at Dudfield of NO2 and NOx emissions indicated a fraction
of approximately 1% NO2 of total NOx. The general literature concludes
fractions up to 5% (Holcim presentation, 2003). The EU standards (and
proposed SA standards) will still be met even if NO2 were assumed to be
5% (upper estimate) of NOx4.
∗ Sulphur Dioxide (SO2):
For baseline conditions the predicted sulphur dioxide ground level
concentrations are below the current DEAT guidelines as well as proposed
SA and EC limits, measuring 50µg/m³, 1.2 µg/m³, and 0.01 µg/m³ for
highest hourly, daily and annual averaging periods respectively.
Highest predicted ground level concentrations for proposed operating
conditions are less that 10% of the current DEAT guidelines as well as
the proposed South African and current EC limits for all averaging
periods. The potential sulphur content of the alternative fuel may be
higher than the current coal. For example, tyres may have double the
content (approximately 1,6%). However, SO2 are to a large extent
determined by the chemical characteristics of the raw materials used,
4 The formation of NOx is determined by flame temperature, oxygen content, residence
time and nitrogen content in fuel. As these parameters are to remain constant with
nitrogen content of the alternative fuel unknown but not expected to be much different
from coal, NO2 should remain the same as current operating conditions.
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and not by the fuel composition (CEMBUREAU, 1999). Therefore, the
predicted SO2 emissions (even if tyres would replace all the coal) are
expected to remain relatively similar to that of baseline conditions.
∗ Lead:
Predicted lead concentrations for current and proposed operating
conditions are predicted to be insignificant when compared to EU and
proposed SA limits.
6.8.2. Results for Non-Criteria Pollutants: Potential for Environmental
and Non-Carcinogenic Health Effects
• Impact Assessment:
A synopsis of the highest hourly, highest daily and annual average non-
criteria pollutant concentrations predicted to occur due to the proposed use of
alternative fuel is given in Table 6.18. The predicted concentrations were
compared with the World Health Organisation (WHO) guidelines, Risk
Assessment Integration System (RAIS) Inhalation reference concentrations
(US Environmental Protection Agency (US-EPA)), the California Office of
Environmental Health Hazard Assessment (OEHHA) and the Agency for Toxic
Substances and Disease Registry (ATSDR) Minimal Risk Levels (MRL’s).
However, as indicated in Table 6.17, predicted ground level concentrations
for non-criteria pollutants did not exceed the effect screening or health risk
criteria.
Current maximum predicted off-site benzene ground level concentrations for
annual averaging periods were below the EC and proposed South African
limits. The predicted levels are expected to remain the same due to the high
destruction efficiency (typical destruction efficiencies are 99.99%
(Lemarchand, 2000)).
6.8.3. Results for Non-Criteria Pollutants: Potential for Carcinogenic
Effect
A synopsis of the maximum annual average concentrations of the carcinogenic
pollutants predicted to occur due to proposed usage of alternative fuels is given in
Table 6.18. The main target organs which may be impacted and the cancer risk
calculated given the predicted concentrations are presented in the table.
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Table 6.17: Maximum offsite concentrations (measured in µg/m³) at the Dudfield Plant boundary of non-criteria pollutants predicted
to occur due to proposed usage of alternative fuels also given as a ratio of various effect screening and health risk criteria
(a)(b)
Maximum Predicted Ground LevelConcentrations (µg/m3)
Effect Screening or Health RiskCriteria (b)
Maximum PredictedConcentrations as a Ratio of theRespective Effect Screening or
Health Risk Criteria (a)Pollutant Emission Rate
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Min 3.22E-03 4.34E-04 2.73E-05 2.3E-02 - 9.0E-04Ave 2.94E-03 3.50E-04 2.73E-05 2.1E-02 - 9.0E-04ArsenicMax 2.79E-03 3.49E-04 2.65E-05
1.4E-01 (4hrs)
3.0E-022.0E-02 - 9.0E-04
Min 2.73E-05 3.68E-06 2.31E-07 - - 5.0E-05Ave 2.50E-05 2.98E-06 2.32E-07 - - 5.0E-05CadmiumMax 2.37E-05 2.97E-06 2.26E-07
5.0E-03- - 5.0E-05
Min 2.37E-02 3.19E-03 2.01E-04 - - 2.0E-03Ave 2.16E-02 2.58E-03 2.01E-04 - - 2.0E-03ChromiumMax 2.06E-02 2.57E-03 1.96E-04
1.0E-01- - 2.0E-03
Min 7.77E-03 1.05E-03 6.58E-05 - - 3.0E-03Ave 7.08E-03 8.43E-04 6.57E-05 - - 3.0E-03CobaltMax 6.75E-03 8.45E-04 6.42E-05
2.0E-02- - 3.0E-03
Min 1.16E-02 1.56E-03 9.79E-05 1.0E-04 - -Ave 1.05E-02 1.25E-03 9.77E-05 1.0E-04 - -CopperMax 1.01E-02 1.26E-03 9.56E-05
1.0E+021.0E-04 - -
Min 7.93E-02 1.07E-02 6.71E-04 - - 4.5E-03Ave 7.22E-02 8.60E-03 6.71E-04 - - 4.5E-03ManganeseMax 6.89E-02 8.62E-03 6.55E-04
1.5E-01- - 4.5E-03
Min 1.82E-02 2.45E-03 1.54E-04 1.0E-02 - 5.0E-04Ave 1.65E-02 1.97E-03 1.53E-04 9.0E-03 - 5.0E-04MercuryMax 1.58E-02 1.97E-03 1.50E-04
1.8E+00 3.0E-018.8E-03 - 5.0E-04
Min 2.94E-02 3.96E-03 2.49E-04 5.0E-03 - 5.0E-03Ave 2.67E-02 3.18E-03 2.48E-04 4.0E-03 - 5.0E-03NickelMax 2.55E-02 3.19E-03 2.43E-04
6.0E+00 5.0E-024.0E-03 - 5.0E-03
Min 1.43E-02 1.92E-03 1.21E-04 - 1.9E-03 -Ave 1.30E-02 1.55E-03 1.21E-04 - 1.6E-03 -VanadiumMax 1.24E-02 1.55E-03 1.18E-04
1.0E+00- 1.6E-03 -
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Maximum Predicted Ground LevelConcentrations (µg/m3)
Effect Screening or Health RiskCriteria (b)
Maximum PredictedConcentrations as a Ratio of theRespective Effect Screening or
Health Risk Criteria (a)Pollutant Emission Rate
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Highesthourly
Highestdaily
Annualaverage
Min 3.64E+00 4.90E-01 3.08E-02 1.7E-03 - 1.5E-03Ave 3.30E+00 3.93E-01 3.06E-02 1.6E-03 - 1.5E-03Hydrogen ChlorideMax 3.15E+00 3.94E-01 3.00E-02
2.1E+03 2.0E+011.5E-03 - 1.5E-03
Min 3.64E-01 4.90E-02 3.08E-03 1.5E-03 - -Ave 3.30E-01 3.93E-02 3.06E-03 1.4E-03 - -Hydrogen FluorideMax 3.15E-01 3.94E-02 3.00E-03
2.4E+021.3E-03 - -
Min 3.64E-08 4.90E-09 3.08E-10 - 2.5E-02 -Ave 3.30E-08 3.93E-09 3.06E-10 - 2.0E-02 -
Dioxin ToxicEquivalence
Max 3.15E-08 3.94E-09 3.00E-102.0E-07
- 2.0E-02 -Notes:
(a) A ratio of 1.0 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Ratios of greater than 1.0 indicate an exceedance of such
limits.
(b) Various effect screening levels and health risk criteria is given in Section 3 with a comprehensive review given in Appendix B.
(c) Where an hourly screening level or health criteria was not available but a 6 hour or 4 hour value was present, this was used for comparison of the hourly ground level
concentration as a conservative approach.
(d) This value was withdrawn from the IRIS or HEAST.
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Table 6.18: Predicted maximum annual average concentrations of various carcinogens due to proposed usage of alternative fuels at
the Dudfield Plant and resultant cancer risks (assuming maximum exposed individuals)
CarcinogenEmission
Rate
Predicted
Maximum
Annual
Average
Concentration
(µg/m3)
WHO
Inhalation
Unit Risk
(µg/m3)-1
US-EPA Unit
Risk Factor
(µg/m3)-1
Cancer Risk (calculated
based on the
application of unit risk
given in the WHO
database)
Cancer Risk (calculated
based on the application of
unit risk given in the RAIS
database)
Min 2.73E-05 4.3 in 100 million 1.17 in 10 million
Ave 2.73E-05 4.3 in 100 million 1.17 in 10 millionArsenic
Max 2.65E-05
1.5E-03 4.3E-03
4.3 in 100 million 1.17 in 10 million
Min 2.31E-07 4.16 in 10 million
Ave 2.32E-07 4.18 in 10 millionCadmium
Max 2.26E-07
1.8E-03
4.06 in 10 million
Min 2.01E-04 2.2 to 26 in 1 million (a) 2.4 in 1 million
Ave 2.01E-04 2.2 to 26 in 1 million (a) 2.4 in 1 millionChromium VI
Max 1.96E-04
1.1E-02 to 13E-
021.2E-02
2.2 to 25.4 in 1 million (a) 2.4 in 1 million
Min 2.49E-04 9.5 in 100 million 5.6 in 100 million
Ave 2.48E-04 9.4 in 100 million 5.9 in 100 millionNickel
Max 2.43E-04
3.8E-04 2.4E-04
9.2 in 100 million 5.8 in 100 million
Min 3.08E-10 1 in 100 million
Ave 3.06E-10 1 in 100 millionDioxin Toxic
EquivalenceMax 3.00E-10
33
0.99 in 100 million
Notes:
(a) Cancer risk exceeding 1 in 1 million (trivial cancer risk criterion)
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In assessing the results presented in Table 6.18 it is important to note that a
conservative impact assessment methodology was employed. By “conservative”
it is meant that several assumptions were made which is likely to have resulted in
an overestimation in the cancer risks. Such assumptions included the following:
Total chromium was assumed to be completely in the hexavalent form given that
emission limits do not specify the form in which the chromium is to be emitted
and the likely chromium speciation of the emission is not known.
Maximum exposures were assumed to occur to predicted maximum
concentrations, i.e. 24-hour a day exposures over a 70-year lifetime to the
maximum annual pollutant concentrations predicted.
Having characterised a risk and obtained a risk level, it needs to be
recommended whether the outcome is acceptable. There appears to be a
measure of uncertainty as to what level of risk would have to be acceptable to the
public. The US-EPA adopts a range of 1 in 100 thousand to 1 in 1 million as the
acceptable level of risk. As a conservative approach the maximum of 1 in
1 million is considered for trivial level of risk. Initially all chromium was assumed
to be hexavalent and the estimated cancer risk ranged from 2.2 to 26 in 1 million
(WHO unit risk factors). However, the hexavalent chromium is typically 10% of
total chromium. Thus, the incremental cancer risk using the WHO unit inhalation
unit risk factors would be 0,2 to 2,6 in a million.
6.9. Significance Rating
The extent, frequency, severity, duration and significance of the baseline and
proposed usage of alternative fuels is categorised in Table 6.19 and Table 6.20
respectively.
As the emission levels are below the DEAT guidelines, the significance for baseline
conditions (for all pollutants of concern) was predicted to be low (refer to Table
6.19). Under proposed operating conditions (usage of alternative fuels), the
emissions remain below the DEAT guidelines. Therefore, the significance for all
pollutants of concern with the implementation of the proposed project at Dudfield
plant is predicted to remain low (refer to Table 6.20).
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Table 6.19: Significance rating from the baseline study (a) (for all pollutants of
concern)
Scale Significance Rating
Temporal Long term
Spatial Localised
Severity Slight (b)
Significance Low (b)
Risk or likelihood May occur (c)
Degree of certainty or confidence Probable
Notes:
(a) Routine operating conditions using Kiln 3, Cement Mill 1, Cement Mill 2.
(b) Based on criteria pollutants and screened against DEAT guidelines.
(c) Impacts are not constant as they depend on the meteorological conditions and
dispersion potential of the atmosphere.
Table 6.20: Significance rating from the proposed usage of alternative fuel (for
all pollutants of concern)
Scale Significance Rating
Temporal Long term
Spatial Localised
Severity Slight (a)
Significance Low (a)
Risk or likelihood May occur (b)
Degree of certainty or confidence Probable
Notes:
(a) Based on criteria pollutants and screened against DEAT guidelines.
(b) Impacts are not constant as they depend on the meteorological conditions and
dispersion potential of the atmosphere.
6.10. Description of Aspects and Impacts
The rating system used for assessing impacts is based on three criteria, namely:
• The relationship of the impact/issue to temporal scales;
• The relationship of the impact/issue to spatial scales; and
• The severity of the impact/issue.
These three criteria are combined to describe the overall importance rating,
namely the significance (Text Box 6.1). In addition the following parameters are
used to describe the impact/issues:
• The risk or likelihood of the impact/issue occurring; and,
• The degree of confidence placed in the assessment of the impact/issue.
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6.11. Conclusion and Recommendations
The investigation included the simulation of inhalable particulates, nitrogen
oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and
halogen compounds.
For baseline conditions measured emission values were simulated in order to
determine the current impact on the surrounding environment. For proposed
usage of alternative fuels, EC emission limits were used to estimate emission
rates.
The main conclusions may be summarised as follows:
• The inhalable particulate concentrations (PM10) were predicted to be below
the daily and annual average current DEAT as well as the EC and proposed
South African limits with highest offsite concentrations at 7 µg/m³ and
0,7 µg/m³ respectively for baseline conditions and 0,3 µg/m³ and
0,57 µg/m³ respectively for proposed conditions (this excluded fugitive
emissions);
• Gaseous concentrations for NO2 (baseline conditions) did not exceed the
DEAT guidelines with highest predicted off site concentrations predicted to be
3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ for highest hourly, daily and annual
averaging periods respectively. Proposed NO2 ground level concentrations
were predicted to be 2,8 µg/m³, 0,5 µg/m³ and 0,02 µg/m³ for highest
hourly, daily and annual averaging periods. These concentration levels were
below DEAT guidelines as well as EC and proposed South African (SA) limits;
• NOx ground level concentrations for proposed operating conditions were
315 µg/m³, 60 µg/m³ and 2,43 µg/m³ for highest hourly, daily and annual
averaging periods respectively, well below the current DEAT guidelines;
• Predicted sulphur dioxide ground level concentrations were below the current
DEAT guidelines as well as the proposed South African and EC limits with
highest levels predicted to be 50 µg/m³5, 1,2 µg/m³ and 0,01 µg/m³ for
5 Using the 98th percentile the predicted hourly value is 20 µg/m³. The predicted
50 µg/m³ was predicted from a peak incident during the monitoring campaign.
Text Box 6.1: The Significance Scale
Very High Predicted ground level concentrations exceeding the guideline >100%.
High Predicted ground level concentrations exceeding the guideline.
Moderate Predicted ground level concentrations >80% of the guideline.
Low Predicted ground level concentrations below the guideline.
No Significance No ground level concentrations.
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highest hourly, daily and annual averaging periods respectively for baseline
conditions and 20 µg/m³, 2,8 µg/m³ and 0,15 µg/m³ for highest hourly, daily
and annual averaging periods respectively for proposed conditions;
• Predicted current and proposed lead concentrations were insignificant when
compared to the EU limits respectively;
• Predicted ground level concentrations for non-criteria pollutants did not
exceed the effect screening or health risk criteria for current and proposed
operations.
• Carcinogenic pollutants for baseline conditions were predicted to cause less
than 1 in 1 million chance of cancer (trivial cancer risk criterion). For
proposed conditions all potential carcinogenic pollutants, except hexavalent
chromium were predicted to be less than the 1 in a million increased cancer
risk criterion. Assuming all chromium to be hexavalent, the estimated cancer
risk ranged from 2,2 to 26 in 1 million (WHO unit risk factors). However the
hexavalent chromium is typically 10% of total chromium. Thus the
incremental cancer risk using the WHO unit inhalation unit risk factors would
be 0,2 to 2,6 in a million. It is, therefore, broadly acceptable (less than 1 in
100 thousand);
• Dioxins and furans were below the relevant guidelines for current and
proposed operating conditions;
• The significance rating for current and proposed conditions indicated slight
severity due to predicted ground level concentrations from criteria pollutants
with localised, long-term impact.
• Based on the findings above it can be concluded that predicted ground level
impact from alternative fuel usage is similar to, and in some cases marginally
higher than (due to emissions based on EC limits) baseline conditions.
However the predicted impact for the usage of alternative fuel is well below
relative guidelines/limits.
6.11.1. Recommendations
• EC emission limits were used to quantify ground level impact from the plant
for the proposed usage of alternative fuels. It is recommended that a “Trial
Burn” be done to check EC emission limit used in the current study for the
proposed burning of alternative fuel. Pollutants of concern are typically due
to chronic exposures (e.g. dioxins and furans), hence a relatively short
exposure of a few days during the trial burn would have an insignificant
impact.
• It is additionally recommended that the emissions be monitored once the
proposed operations have commenced and re-simulations undertaken if the
order of magnitude of these emissions is significantly different. This will be
necessitated in order to quantify the ground level impact.
• EC limit allows NOx emission instead of NO2. Previous measurements at
Dudfield Plant indicated approximately 1% NO2 of NOx. This fraction may,
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however, be as high as 10%. If the NO2 emissions were allowed at the EC
limit for NOx, the guidelines of NO2 would be exceeded. It is, therefore,
recommended that both NO2 and NOx be monitored for compliance.
• It is recommended that the hexavalent chromium fraction be determined.
• Although fugitive emissions were not important in establishing the impact of
the use of alternative fuels it is recommended to compile a source inventory
for these emissions to determine the significance of this source.
• An air quality management plan was provided with the recommendation to
improve and extend the plant’s emissions inventory by:
∗ Undertaking stack (Kiln 3) monitoring following the initiation of the
proposed operations to confirm projected stack emission data.
∗ Identify and quantify all fugitive, diffuse and evaporative sources of
emissions.
6.12. Air Quality Management System
Possible objectives to be met through air quality management planning, given the
local legislative context and international 'best practice' requirements, include:
• identification and quantification of sources of atmospheric emission, and
ranking of sources based on their significance;
• reduction of significant sources through the implementation of the most cost-
effective management and/or control measures possible;
• demonstration of compliance with local (and if necessary international)
regulations;
• demonstration of continuous improvement (e.g. for ISO14000 purposes);
• reduction of risks, both occupational and public;
• facilitation of the participation of interested and affected parties in air quality
management; and,
• disseminate environmental information to stakeholders.
Given these objectives, the following elements are perceived to be integral to
effective air quality management planning within industrial and mining
operations:
• Baseline Assessment. Such an assessment comprises the identification and
quantification of sources of atmospheric emission and the simulation and/or
measurement of air quality impacts associated with such sources. Baseline
assessments typically form the basis for identifying significant sources,
ranking emission reduction strategies and designing suitable source and
ambient air quality monitoring networks. Although air quality impacts related
to stack emissions were quantified during the current study, fugitive
emissions were not considered. The significance of such emissions were
therefore not established.
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• Source- and Receptor-based Performance Indicators and Associated Targets.
The identification of and commitment to specific source-related and ambient
air quality targets provides the basis for assessing the acceptability of
emission rates and ambient air pollution concentrations. Such targets
should, as a minimum, reflect pertinent local, provincial and national
regulatory limits. Other, more stringent criteria such as emission and air
quality standards issued by other countries or dose-response thresholds
(etc.), could also be used as the basis for such targets. Timeframes should
be set by which targets are to be achieved.
• Source and Ambient Air Quality Monitoring Systems. The monitoring of
sources and ambient air quality is crucial to accurately characterise current
impacts, evaluate the effectiveness of control measures, and quantify
progress against performance indicators. Source-based monitoring can range
from sophisticated continuous stack monitoring to routine visual inspections
of sources. Ambient air quality monitoring, although typically associated with
the acquisition and implementation of mechanical sampling equipment, could
also comprise the maintenance of a complaints register.
• Air Pollution Mitigation Strategy. In the design of the mitigation strategy,
sources classified as significant in terms of their air quality impacts should be
targeted using the most cost-effective measures possible. Mitigation
strategies should include short-, medium- and long-term source management
and control measures in addition to providing for the implementation of
contingency measures in the event that defined targets are not met within
specified timeframes.
• Record Keeping and Documentation Procedure. The implementation of a
documentation procedure ensures continuity beyond the job span of
individuals, assigns responsibility of tasks to posts and contributes to
informed decision making by increasing access to information. Such record
keeping is able to easily facilitate environmental audits, and generally
provides value for money in terms of expenditure on emissions inventory
development, modelling and monitoring.
• Periodic Inspections and Audits. Periodic inspections and external audits are
essential for progress measurement, evaluation and reporting purposes. Site
inspections and progress reporting by plant personnel may, for example, be
undertaken at monthly or quarterly intervals, with annual environmental
audits being conducted on an annual basis.
• Mechanisms for Consultation with Authorities and I&APs. Interactions with
authorities currently typically comprise routine compliance reporting and
intermittent site inspections. Mechanisms for information dissemination to
and consultation with interested and affected parties (I&APs) include the
holding of stakeholder forums. The frequency of such forums is best
determined on an intermittent basis through consultation between the
operation and relevant stakeholders.
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• Financial Provision. The budget should provide a clear indication of the
capital and annual maintenance costs associated with mitigation measure
implementation and monitoring. Provision should also be made for costs
related to inspections, audits, environmental reporting and I&AP liaison. The
budget could either be established and maintained exclusively to inform
internal decision-making, or could be made available to authorities and/or
I&APs to demonstrate that financial resources have been made available for
air quality management planning.
The interactions of individual components of the air quality management plan
development, implementation and review process are illustrated in Figure 6.2.
These various components are discussed in more detail in subsequent
subsections.
Figure 6.2: Schematic diagram illustrating air quality management plan
development, implementation and review by industrial and mining
operations
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6.12.1. Emissions Inventory Development and Maintenance
An emissions inventory is a comprehensive, accurate and current account of air
pollutant emissions and associated source configuration data from specific
sources over a specific time period. Source and emission data need to be collated
for routine, upset and accidental emissions to provide a representative account of
the potential for impacts, which exist. Emissions inventories represents the key
elements in all programmes aimed at air pollution management, aiding in the
identification of pollutants and sources of concern and therefore in the selection
of effective air pollution abatement measures. In addition to containing
information on present emission levels from the various source categories, an
emissions inventory could also indicate projected future emission levels for long-
term planning purposes.
The first step in the establishment of an emissions inventory is the identification
of sources of atmospheric emissions. The quantification of sources may be based
on source measurements, mass balance calculations and on the application of
emission factors. In the current study, only stack emissions were quantified for
inclusion in the plant’s emission inventory. Stack emission rates were assumed
to be equivalent to EC emission limits. The plant’s emissions inventory will need
to be improved and extended by:
• undertaking stack monitoring following the initiation of the proposed
operations to confirm projected stack emissions data; and
• identifying and quantifying all fugitive, diffuse and evaporative sources of
emissions.
In future, South African industries will be tasked with the regular reporting of
source and emissions data for both stack and diffuse sources to air quality
management authorities. Reliance on consultants to regularly update the
facility's emissions inventory to fulfil such reporting requirements, should in-
house capacity not have been developed, will prove costly.
6.12.2. Source Monitoring
Source monitoring could range from sophisticated continuous emission monitoring
methods to intermittent monitoring. The type of monitoring adopted will depend
on the nature and extent of an operation's activities and the presence of various
source types (e.g. stacks, vehicle entrainment from unpaved or paved roads,
evaporative emissions from tanks, fugitive dust releases from materials handling
points).
Mandatory in-stack monitoring for all “priority pollutants” may in future be
required by industrial emitters. Alternatively, stack-monitoring campaigns may
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be required. Stipulations regarding monitory durations, methods and frequencies
will be included in Atmospheric Emission Licences.
For the proposed usage of alternative fuels, the type of monitor will depend on
three aspects, i.e. the stack parameters, composition of fuel and quantity of fuel
used. If these three aspects remain relatively constant intermittent monitoring
would suffice, as emissions should be fairly regular. If any one of these aspects
significantly varies over time continuous monitoring may be required. Monitoring
would be required to establish the chromium composition and to demonstrate
that the emissions emanating from the kiln (for the new facility) can achieve the
given EC emission limits.
6.12.3. Ambient Air Quality Monitoring
Air quality samplers are generally expensive to install and maintain. It is
therefore essential that the type of sampling equipment required and the number
of sampling sites to be established be carefully considered and justified.
Given that predicted pollutant concentrations due to stack emissions are well
within air quality guidelines and health screening levels, ambient air quality
monitoring appears unjustified. It is however strongly recommended that the
need for air quality monitoring be reassessed after the establishment of a
comprehensive emissions inventory for the plant and the simulation of air
pollution concentrations arising from all sources.
6.12.4. Mitigation Strategy Design, Implementation and Evaluation
Mitigation should form an integral component of the environmental management
of industrial plants. Such measures need to be integrated into the day-to-day
operations of the plant and their effectiveness and overall usefulness reviewed
periodically. In assessing the cost effectiveness of controls, costs of measures
may be compared to the emission and/or impact reductions achieved by such
measures.
Should stack emissions be measured to be within emission limits, as assumed in
this study, no mitigation would be required for these sources. The need for the
implementation of mitigative measures for other sources needs however to be
established.
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6.12.5. Record Keeping and Environmental Reporting
Record-keeping requirements specific to air pollution management include:
• Complaints register. It is essential for all industrial and mining operations to
log the "who", "when" "what" and "where" of a complaint, in addition to
information on action taken by personnel in response to the complaint. This
register should be signed at regular intervals by the environmental manager
to encourage complaints being addressed in a timely and responsible
manner.
• Emissions inventory database - comprising source and emissions data in
addition to information on when the inventory was last changed and audited.
• Dispersion model results - including dispersion model manual and training
notes, list files indicating model inputs and outputs, isopleth plots and
graphs, etc.
• Air monitoring information - comprising the air quality database, information
on the location of sampling sites, sampling durations, calibration certificates,
quality assurance procedures, reasons for peaks in concentrations or
deposition levels observed.
• Reports compiled (e.g. reports prepared to meet internal information
requirements, compliance reports generated for authorities, briefing
documents for circulation to stakeholders, progress reporting against
performance indicators, specialised studies, air quality management plan
reviews, etc.)
Environmental reporting which would typically be undertaken on an annual basis
to document the review of air quality management system components is likely to
include:
• Proof of progress made against performance indicators
• Review of performance indicators
• Review of air quality monitoring and management systems
• Synopsis of complaints received, actions taken and response times
• Synopsis of unplanned emission incidents, causes and actions taken
• Benchmarking against the environmental performance of other industries
locally and abroad (e.g. total particulate emissions per ton product).
The importance of proficient record keeping and environmental reporting cannot
be over-emphasised. This tool forms the basis of all environmental management
systems, and is recognised as one of the main components of ISO14000
management systems.
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6.12.6. Consultation
Consultation with relevant authorities and communities should be undertaken.
The frequency of such meetings should be determined based on the number of
complaints received, the level of community interest in plant performance, and
the extent of attendance at meetings. The plant should set up meetings with the
community of the surrounding areas to provide information on emissions and
monitoring results from the plant.
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7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN ALTERNATIVE
FUEL RESOURCE
7.1. Introduction
In order to generate the high temperatures required for cement manufacture,
large quantities of fuel are required to achieve and maintain kiln temperatures.
The use of waste derived alternative fuels can reduce the reliance of a kiln on a
natural resource while providing an effective method for managing waste
materials. In order to reduce their reliance on non-renewable fuel resources and
provide an innovative waste management solution Holcim South Africa has set an
initial goal of replacing a minimum of 35% of the coal used by Kiln 3 at the
Dudfield Plant with alternative waste derived fuels. Cement kilns are
acknowledged as being able to provide an ideal environment for the complete
combustion of waste derived fuels due to the very high temperatures (up to
2000oC), long solid residence time (up to 30 minutes), long gas residence times
(of 4 to 8 seconds), and the large excess of oxygen used.
During the development of the National Waste Management Strategy by the
Department of Environmental Affairs and Tourism (DEAT; 1998), cement kilns
were identified as facilities that could effectively utilise waste materials such as
tyres, refuse derived fuel (RDF), hydrocarbon wastes and selected hazardous
wastes, as fuels. Utilisation of materials that are normally designated as wastes
as a fuel or alternative feedstock for cement manufacture meets a number of
national strategic goals, including the beneficial use of wastes, conservation of
natural resources such as coal and reduction of the amount of waste being
disposed to landfills.
There are currently no formal regulatory requirements specific to the use of wasre
derived alternative fuels and resources (AFR) in cement kilns. Without
application specific standards and specifications to govern the use of AFR, the
approach has been to adopt the applicable waste standards, specifications and
procedures. This has been done to ensure that the most stringent of measures
are implemented in the utilisation of alternative fuel and resources. The
management procedures fall under the Duty of Care requirements that are
included in National Environmental Management Act (No 107 of 1998), the
Environment Conservation Act (No 73 of 1989), and the Department of Water
Affairs and Forestry’s Minimum Requirements.
Kiln 3 at the Holcim South Africa Dudfield plant has recently been upgraded and
is able to accept and process a variety of fuels. These fuels could include a wide
range of wastes both hazardous and non-hazardous. The fuels can occur in
varying forms including solid, sludge, liquid and gas states. The use of waste,
both as alternative fuels and as raw materials, introduces new challenges for the
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cement plant and issues related to the transport, handling, storage and use of the
waste must be strictly controlled to ensure that their risk to the environment and
human health is appropriately managed. However, the classification, handling,
storage and transport of hazardous materials are well understood and are strictly
controlled by current legislation and the environmental authorities. The adoption
of the sound management techniques will ensure the potential risks to health,
safety and the environment are kept within acceptable levels.
The management protocol for the utilisation of waste as a alternative fuel follows
a 'cradle to grave' approach. This means that it is the responsibility of Holcim
South Africa to ensure that the alternative fuels and resources are appropriately
managed, from identification of potential fuels to utilisation of the fuel in the kiln
and the control of any emissions from the kiln. The primary management
considerations required to be taken in mind to ensure the total 'cradle to grave'
management of AFR include:
• AFR identification and acceptance procedures
• Documentation
• Packaging and labelling
• Loading at the generator’s premises
• Transportation
• Acceptance procedures at Dudfield plant
• Offloading
• Handling, storage on-site and feeding into the kiln
• Characteristics of the products and, if produced, any by-products from the kiln
This chapter assesses the suitability and the risks associated with the proposed
introduction of an alternatives fuels and resources (AFR) programme at Dudfield's
Kiln 3, and defines the management procedures that would be required to be
implemented by Holcim South Africa (with details of these procedures provided in
Appendix I).
7.2. AFR Specifications
The use of alternative fuels in cement kilns is based upon sound technical
principles as the organic component is destroyed at the very high temperatures
reached in the kiln, i.e. up to 2000°C, and the inorganic components are trapped
and combined with the cement clinker forming part of the final product.
However, in order to determine the suitability of using AFR in the kiln it is critical
to identify, understand and manage the factors that could potentially create an
impact on health, safety or the environment. In addition, there can be no
compromise on the quality of the clinker and cement produced. Therefore, the
types and nature of the AFR materials and their respective management
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procedures that would be acceptable, as well as the limits on specific elements,
need to be specified and adhered to.
7.2.1. Types of Alternate Fuels and Resources
Waste materials currently utilised internationally as alternative fuels include, but
are not limited to scrap tyres, rubber, paper waste, used oils, waste wood, paper
sludge, sewage sludge, plastics, spent solvents, tars, etc. Waste-derived
alternative fuels can include wastes with high concentrations of substances
beneficial to the cement manufacturing process e.g. wastes with a high iron
content to replace the iron ore normally used in cement manufacture.
The primary consideration for waste to be utilised as a fuel is the energy value,
measured using the Nett Calorific Value (measured in megajoules per kilogram
(MJ/kg)). Table 7.1 lists the typical calorific values of potential alternative fuels
and, for comparison, some common natural fuels (such as oil and coal). Natural
fuels range from a calorific value as low as 16 MJ/kg for some peat or lignite, to
as high as 42 MJ/kg for fuel oil derived from crude oil. To sustain combustion, a
fuel must have a calorific value of at least 7,5 to 9 MJ/kg.
A number of possible alternative fuels are listed in Table 7.1 to compare the
calorific value of alternate fuels to conventional fuels. However, this list is not a
comprehensive listing of all possible AFR materials.
Table 7.1: Calorific Value of Alternative and Natural Fuels
FuelCalorific Value
(MJ/kg)Comment
Pure Polyethylene 46 For example, plastic bags
Light Fuel Oils 42 Diesel
Heavy Fuel Oil 40 Used in boilers
Tar 38 By product of petroleum industry
Pure rubber 36
Anthracite 34 High grade coal
Waste Oils 30 - 38 Used engine oil
Petroleum Coke 33 Coke produced from petroleum
residues
Scrap Tyres 28 - 32 Contain steel and other non-
combustible material
Bituminous Coal 24 - 29 Lower grade coal produced in South
Africa
Landfill Gas 16 - 20 ~60% methane gas
Lignite and Peat 16 - 21
Spent Potliners 20 Carbon and Refractory Waste from
Aluminium Smelters
Paint Sludge 19 By product from paint industry
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FuelCalorific Value
(MJ/kg)Comment
Palm nut shells/
Sunflower husks
19 From production of vegetable oils
Fuller Earth 13 - 16 A natural clay used to filter vegetable
oils
Dried wood / sawdust 16
Rice Husks 16
Refuse Derived Fuel
(RDF)
15 Domestic waste with metal and other
non-combustible wastes removed
Cardboard/paper 15
Dried Sewage Sludge 10 Sterilised sludge
Domestic Refuse 8.5 Domestic waste with metal and other
non-combustible wastes removed
(comparable to RDF)
Wet Sewage Sludge 7.5
Contaminated Soils 0 - 3 Contain hydrocarbons or other organic
contaminants
Waste Minerals 0 Contain no combustible organic
material
7.2.2. Physical and Chemical Characteristics of AFR
As there are many waste streams that could be considered for acceptance as an
alternative fuel, it is important to define the physical and chemical characteristics
of potential AFR streams to ensure that they can be safely accepted and utilised
in the kiln.
This is important for a number of reasons:
• The safety of persons handling the materials: individuals need to be made
aware of the hazards and provided with the correct protective equipment to
wear while handling the waste.
• The transport of the materials: the materials must be safely transported in
accordance with the relevant legislation. Precautions taken will differ
significantly depending on the type of waste transported. The physical form
of the waste will determine what type of transport container and vehicle is
required. The density of the waste will determine the volume that can be
transported by a particular vehicle to avoid overloading the vehicle. The
waste constituents will also determine the appropriate labelling of the vehicle.
• In cases of emergency, e.g. spillage, vehicle accident etc., it is vital that the
driver, emergency services and persons on the scene of the accident are able
to readily identify and appropriately manage the waste stream.
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• The type of AFR, its chemical characteristics and its physical form will also
dictate exactly how it should be stored on reaching Dudfield plant.
• For efficient and safe utilisation the chemical composition of the AFR must be
determined.
• Physical State:
The four possible physical states of a waste stream are described below. The
physical state of a waste stream will determine how it is handled,
containerised, transported, stored and fed into the kiln.
∗ Solid
Solid waste generally refers to a waste that is devoid of excess moisture,
and does not generate moisture when subjected to pressure. The solid
can be in a number of forms, generally varying in particle size and
adhesion properties. Examples are:
- Large chunks (rocks) of material.
- Varying sizes smaller than this e.g. gravel size pieces.
- Fine powders,
- Solid wastes, which are 'sticky', e.g. clay-like substances.
∗ Liquid
These are wastes which have little to no solid content, although a certain
amount of settlement may take place leaving a layer of sludge at the
bottom of a container. Liquids can vary greatly in composition e.g. in
colour, odour, toxicity, whether they release fumes or not, viscosity,
clear or opaque, etc.
∗ Sludge
This is generally an intermediate physical form between liquid and solid.
It is determined by its liquid content, which is generally accepted to be
above 40%, although this amount can vary depending on the nature of
the waste materials. Sludges can vary from a stiff consistency to one
that is quite mobile, and this determines how they are handled.
∗ Gases
This class is subdivided into five separate divisions, permanent gases,
compressed gases, liquefied gases, refrigerated liquefied gases and gases
in solution.
• Hazardous characteristics:
Wastes are categorised in terms of their hazardous properties, for transport,
treatment and disposal purposes, using SANS Code 10228 (South Africa
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National Standard 10228). There are nine SANS hazard classes for wastes,
i.e.:
∗ Class 1 Explosives
∗ Class 2 Gases
∗ Class 3 Flammable Liquids
∗ Class 4 Flammable Solids
∗ Class 5 Oxidising Substances and Organic Peroxides
∗ Class 6 Toxic and Infectious Substances
∗ Class 7 Radioactive Substances
∗ Class 8 Corrosive Substances and
∗ Class 9 Miscellaneous Dangerous Substances
Hazardous substances and wastes have four main hazardous characteristics,
namely flammability, corrosivity, toxicity and reactivity. A hazardous
material is classified according to its primary characteristic, but may also
have secondary characteristics that would determine and influence the
management approach taken.
∗ Explosive Wastes
An explosive substance or waste is a solid or liquid substance, or a
mixture of substances that is capable, by chemical reaction, of producing
a gas at such temperature and pressure and speed as to cause damage
to the surroundings. Similar to explosives are pyrotechnic materials that
are designed to produce heat, light, sound, gas, smoke, or a combination
of these, but the reaction is non-detonative and self-sustaining.
Explosive wastes belong to SANS 10228 Class 1. Waste can range in
behaviour from being insensitive, to very sensitive, to explosive.
∗ Gaseous Wastes
Gases belong to SANS Hazard Class 2, which is divided into a number of
categories:
- A permanent gas is a gas that at a temperature of 50°C has a vapour
pressure exceeding 300 kilo Pascals (kPa) and is completely gaseous
at 20°C with a standard pressure of 101,3 kPa (note that a
permanent gas cannot be liquefied under ambient temperatures, e.g.
oxygen and nitrogen.)
- A compressed gas is a gas (other than in solution), that when
packaged under pressure for transportation, is entirely gaseous at
20°C.
- A liquefied gas is a gas that can become liquid under pressure at
ambient temperatures, e.g. butane.
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- A refrigerated liquefied gas is a gas that, when packaged for
transportation, is partially liquid due to its low temperature, e.g.
liquid air and liquid oxygen.
- A gas in solution is a gas that can be dissolved under pressure in a
solvent and that can be absorbed in a porous material, e.g.
acetylene.
Gases could include non-inflammable gases such as chlorofluorocarbons
(CFCs), flammable gases and gases that may be toxic.
∗ Flammable Liquid and Solid Wastes
Flammable wastes can belong to SANS 10228 Class 3, or SANS Class 4,
flammable liquids or flammable solids, respectively. The most common
Class 3 flammable liquids are organic solvents including petroleum fuels
that have high calorific values (refer Table 7.1).
Class 4 Flammable Solids include:
- Self reactive and related substances and desensitised explosives.
- Substances liable to Spontaneous Combustion, including Pyrophoric
Substances (which ignite in contact with air), Self-Heating
Substances (which in air are liable to self-heating but do not ignite)
- Substances that on contact with water emit flammable gases.
A flammable waste will ignite when subjected to an open flame or high
temperatures. A waste that has a flash point of 61°C or below is defined
as flammable in terms of the Minimum Requirements (Department of
Water Affairs and Forestry, 1998) for the disposal of waste to landfill.
However, it is important for transport and storage purposes to
identify/classify wastes that have flash points higher than 61°C and which
can combust when heated to higher temperatures.
∗ Oxidising Substances and Peroxides
These wastes belong to SANS Class 5, i.e.:
- Oxidising Substances (Agents), although they themselves may not
be combustible, can either by yielding oxygen or by similar
processes, increase the risk and intensity of fire in other materials
with which they come into contact. Oxidising substances can be
sensitive to impact, friction or a rise in temperature, and some can
react vigorously with moisture, therefore increasing the risk of fire: a
common example is solid pool chlorine.
- Organic peroxides are thermally unstable substances that undergo
exothermic self-accelerating decomposition.
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∗ Toxic Wastes
Wastes that are toxic can result in the poisoning of humans and other
living organisms. Such waste materials can belong to SANS Class 6.1,
toxic substances, or Class 9, miscellaneous dangerous substances. There
are a number of important parameters used to measure toxicity, i.e. the
chronic toxicity (teratogenicity, mutagenicity, and carcinogenicity), acute
toxicity in terms of the mammalian toxicity, as measured by the
LD50 mg/kg (oral) preferably for rats, and ecotoxicity as measured by its
LC50 mg/l/96hr for fish. The LD50 is the lethal dose of a chemical
required to kill 50% of a population of experimental mammals, and the
ecotoxicity is the lethal concentration required to kill 50% of a population
of fish. The acute toxicity and chronic toxicity of a waste are vital in
determining the most appropriate handling and storage method, as well
as the type of protective equipment to be worn by employees involved in
handling the material. The ecotoxicity plus other parameters such as
biodegradability, persistence and mobility of a toxic substance is
particularly important when designing emergency procedures, when
determining the risks associated with pollution and the methods and level
of clean up required for accidental spills.
∗ Infectious Wastes
Infectious waste, which is the most important component of the health
care risk waste stream, consists of contaminated wastes from medical
facilities that can or possibly could cause the spread of disease. The
waste belongs to SANS Class 6.2, infectious substances. This is usually
in the form of soiled or contaminated bandages, swabs, gloves, masks,
sharps etc. It is vital that individuals are not exposed to any disease
causing organisms and that this waste stream is completely destroyed or
otherwise sterilised before anybody is exposed to it.
∗ Radioactive Wastes
Radioactive wastes, which belong to SANS Class 7, are materials that
spontaneously emit ionising radiation. Internationally, any material with
a specific activity exceeding 70 Becquerel/g (0,002 µCi/g) is classed as
Class 7 dangerous goods.
∗ Corrosive Wastes
In terms of SANS 10228, corrosive substances, which belong to Class 8,
are solids and liquids that can, in their original state, severely damage
living tissue. All wastes in Class 8 also have some destructive effect on
container materials such as metals. Many substances in this class
become corrosive only after having reacted with water or moisture in the
air. The reaction between water and many substances of Class 8 is often
accompanied by the emission of irritating and corrosive gases. Such
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gases usually become visible as fumes in the air. This aspect is
particularly important in storage and transport, as it is vital to determine
what type of container to store the wastes in, so that the container will
not corrode, leading to a leakage or spillage.
• The influence of the hazardous waste classification on the selection
of appropriate AFR sources:
∗ Explosive Wastes
Unless the appropriate precautions are in place, and permission for
acceptance of explosive waste for use as an AFR has been obtained from
the Commissioner of Mines and other relevant authorities, explosive
wastes should not be accepted or utilised as an alternative fuel source.
∗ Gaseous Wastes
The kiln offers a unique opportunity to utilise the energy derived from the
processing of some flammable gasses and non-toxic gases such as the
CFCs or hydrochlorofluorocarbons, many of which are now banned in
terms of the Montreal Protocol, United Nations (1993. The possible
amounts of these gases that could be available for use as an AFR by the
kiln would be very low, and would not be expected to exceed 50 to 100
tons per annum.
∗ Flammable Liquid and Solid Wastes
These materials would form a significant portion of the alternative fuels
used at the kiln due to their high calorific values (refer Table 7.1). These
flammable wastes are required to be handled carefully to avoid
conditions which could cause them to ignite during transport and storage,
but pose no higher risk than the management of fuels such as petrol,
diesel and boiler fuels.
Unless the appropriate handling and storage procedures are put in place,
flammable solid wastes that fall into the following three classes should
not be accepted at the kiln due to risks associated with the handling of
these wastes:
- Self reactive and related substances and desensitised explosives.
- Substances liable to Spontaneous Combustion,
- Substances that on contact with water emit flammable gases.
∗ Oxidising Substances and Peroxides
Stable organic peroxides would be acceptable for use/introduction into
the kiln, but inorganic oxidising agents, such as chromates and
permanganates, should not be accepted.
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∗ Toxic Wastes
Materials that are potentially toxic include petroleum-based fuels and
many waste materials produced by the chemical, pharmaceutical and
petroleum industries. These products can all be utilised as alternative
fuel in a cement kiln. The acceptance procedure for these materials must
determine if the toxicological, chemical and physical nature of the
materials pose any significant threats to human health or the
environment.
∗ Infectious Wastes
Infectious waste and untreated medical waste should not be
processed/accepted as an alternative fuel for the kiln because of the
potential health risks associated with handling the material, and because
it can contain surgical steel items that may not be completely destroyed
in the kiln.
∗ Radioactive Wastes
The kiln must not accept wastes that are determined as radioactive. It is
important that procedures are in place to determine that a waste is not
radioactive both prior to acceptance and when it is received at the
facility.
∗ Corrosive Wastes
The corrosive wastes that could be accepted at the kiln would be largely
organic in nature, e.g. acetic acid (which is the main ingredient in
vinegar). Mineral acid wastes such as sulphuric, hydrochloric and nitric
acid should not be accepted, as they could potentially have a significant
impact on process stability in the kiln.
7.2.3. Summary of Acceptable Waste in terms of SANS 10228
Table 7.2 summarises the wastes acceptable for use as an alternative fuel in
terms of SANS Classes.
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Table 7.2: Categories of waste that can be accepted by Kiln 3 and restrictions
by SANS Class
Class Description Category Allowed Restrictions/Requirements
Class 1 Explosives Possibly subclass 1.5 – very
insensitive substances and
subclass 1.6 - extremely
insensitive substances.
Must not explode in external
fire test.
Class 2 Gases
compressed,
liquefied or
dissolved
under
pressure
Only selected inert or
flammable gases, e.g. CFCs
No toxic gases
Class 3 Flammable
Liquids
All packing classes I to III
Class 4 Flammable
Solids;
Substances
Liable to
Spontaneous
Combustion;
Substances
that, on
Contact with
Water, Emit
Flammable
Gases
None Substances should pass the
tests for pyrophoric and self-
heating substances and not
emit flammable gases unless
the controls are in place to
handle these types of
compounds.
Class 5.1 Oxidising
Agents
Limited to Organic
Compounds
No strong inorganic oxidising
agents such as chromates and
permanganates
Class 5.2 Organic
Peroxides
All Must be stable for handling,
storage and transport
Class 6.1 Toxic
Substances
All Subject to limits on selected
components.
Class 6.2 Infectious
Substances
None No Exceptions
Class 7 Radioactive
Substances
None No Exceptions
Class 8 Corrosive
Substances
Limited to Organic
Compounds
No mineral acids such as
sulphuric acid, hydrochloric
acid and nitric acid
Class 9 Miscellaneous
Dangerous
Substances
and Goods
The waste should be
evaluated individually
according the Minimum
Requirements and classified
into one of the other
Classes.
See Classes 1 to 8.
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7.2.4. Waste and AFR Standards / Specifications
AFR specifications would be defined by regulatory requirements and specific
requirements of the kiln.
• Regulatory requirements (operating permits):
There are currently no formal regulatory requirements which govern the use
of alternative fuels and resources (AFR) in South Africa . Without South
African standards and specifications to govern the use of AFR, waste
standards, specifications and procedures have been adopted to ensure that
the risks can be effectively managed. A permit would be required from DWAF
for the short-term storage of waste at Kiln 3. Regulatory requirements would
be required to refer to health, safety and environmental aspects.
• Plant specific requirements:
Plant specific requirements refer to cement plant operations (i.e. stable kiln
operation, handling and storage) and product quality (clinker). Cement plant
requirements are required to be defined individually for each kiln at each
cement plant.
Specifications apply to the four key aspects of AFR quality control, i.e. plant
operation, product quality, health and safety, and environmental impact.
• Plant Operation:
∗ Burning process: moisture/water content, ash content, sulphur, alkalis,
halogens, calorific value.
∗ Materials handling (i.e. storage and feed system): viscosity/density,
solids content, pH value, immiscibility, flash point.
Product Quality:
∗ Ash composition, sulphur, halogens, heavy metals, ‘interfering’ elements
(alkalis, phosphorous), radioactivity.
• Health and Safety:
∗ Physical and chemical properties: flash point, pH value, toxic organics
and inorganics, i.e. heavy metals, free cyanides, PCBs, PAHs, pesticides,
carcinogens, radioactivity, infectious materials and free asbestos fibres.
• Environmental Impact:
∗ Atmospheric emissions: heavy metals (i.e. mercury), Volatile Organic
Compounds (VOCs), sulphur, halogens, cyanides, ammonia.
∗ Effluents and leaching properties: heavy metals, organics and other
soluble components.
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The relationship between waste/AFR properties (i.e. specifications) and the four
key management aspects is summarised in the matrix in Table 7.3.
Table 7.3: Properties of fuel that can potentially affect product quality, plant
operation, health and safety and environment
PropertiesProduct
Quality
Plant
Operation
Health and
Safety
Environment
Viscosity / density X
pH value X X
Flash point X X
Solids content X
Calorific value X
Water content X
Ash content /
compositionX X
Radioactivity X X X
Sulphur X X X
Halogens X X X
Heavy metals X X X
Alkalis X X
Organics X X
Particle size X
The input of different sources of AFR into the kiln would require the operator to
adjust the fuel feed rate to prevent any fluctuations in the operation of the kiln.
As illustrated in Table 7.3 the physical and chemical properties of AFR can
potentially have an impact on the kiln operation, but these can be successfully
controlled as the fuel types (and characteristics) feeding into the kiln would be
known. For example, the viscosity and density of the AFR will determine the
pump pressure that would be required to deliver the material to the kiln, i.e. it
has an impact on the plant operations but would have almost no effect on the
product quality, health and safety and the environment. Although some sources
of AFR (e.g. radioactive material) have a very low effect on the operation of the
plant, the AFR would be unacceptable as the impact on health, safety and the
environment could be potentially high in the long-term, and the product quality
would be compromised.
7.2.5. Acceptable Limits for Elements in AFR
Table 7.4 lists the limits for various elements as permitted and practised by kilns
accepting AFR internationally. These limits have been proven to be acceptable in
terms of plant operations, the health and safety of the personnel, the
environmental impact and the quality of the end product, i.e. the clinker.
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The upper and lower limits can vary considerably, and the d’Obourg plant limits
have been included as a guideline, as these are considered acceptable for
Dudfield's Kiln 3.
Table 7.4: AFR Specifications and range of acceptable limits of elements
(including heavy metals)
Unit Low High Holcim
Cement
D’Obourg
Sulphur (S) % 0.5 5.0 3.0
Total organo-chlorine (Cl) % 0.3 6.0 6.0
Total organo-fluorine (F) % 0.02 0.2
Cyanide (CN) ppm 100 1 000 100
PCB ppm 10 150 30
Arsenic (As) ppm 5 200 200
Silver (Ag) ppm 5
Barium (Ba) ppm 1 000
Beryllium (Be) ppm 0.5 50 50
Cadmium (Cd) ppm 0.8 500 100
Cobalt (Co) ppm 6 200 200
Chromium (Cr) ppm 40 3 000 100
Copper (Cu) ppm 100 1 000 1 000
Mercury (Hg) ppm 0.5 50 10
Nickel (Ni) ppm 25 1 000 1 000
Lead (Pb) ppm 50 5 000 1 000
Antimony (Sb) ppm 1 800 50
Selenium (Se) ppm 1 100 50
Thallium (TI) ppm 1 100 100
Vanadium (V) ppm 10 3 000 1 000
Zinc (Zn) ppm 400 15 000 5 000
The limits for the various components listed in Table 7.4 are dependent on a
number of factors including:
• Volatility: This is a major determining factor in the behaviour of chemical
elements and their compounds in the alkaline and oxidising environment of
the kiln and is dependent on the rate of incorporation into the clinker:
∗ Non-volatile components include magnesium oxide (MgO); titanium
dioxide (TiO2); phosphorus pentoxide (P2O5); manganese (III) oxide
(Mn2O3); barium oxide (BaO); strontium oxide (SrO); nickel oxide (NiO);
cobalt (III) oxide (Co2O3); copper (II) oxide (CuO); and chromium (III)
oxide (Cr2O3).
∗ Components with low volatility include vanadium pentoxide (V2O5);
arsenic (III) oxide (As2O3); and some metal fluorides.
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∗ Components of considerable volatility include sulphur trioxide (SO3);
potassium oxide (K2O); sodium oxide (Na2O); zinc oxide (ZnO); lead (II)
oxide (PbO); and some metal chlorides.
∗ Components of high volatility, which include cadmium oxide (CdO);
thallium oxide (Tl2O); and mercury (Hg).
• The presence of chloride, which can increase the volatility of a few elements,
e.g. Lead.
• The concentrations of the species in other input materials, e.g. coal, clay,
iron ore, etc.
• The oxidation of some elements to their higher oxidation states can occur in
the kiln. For example, if too much chromium in present in the kiln feedstocks
then some can be oxidised to chromium (VI) and lead to a product that
leaches this relatively mobile species.
• The leachability of the final clinker and cement products. The leaching of
toxic components above that normally found in clinker and too much salt can
lead to an unacceptable efflorescence in some cement products.
7.3. Environmental Fate of the Elements
The chemical and physical properties of cement and clinker are specifically
determined by the major elements present in the raw materials and fuels used in
the burning process. The natural materials and fuels used in the system also
contain trace elements, whose concentrations are determined by their
geochemical distribution in ore deposits and may vary in relatively wide ranges.
The introduction of secondary substances, such as AFR could potentially increase
the amounts of these trace elements in the system.
The major raw materials for cement production are combined in typical
proportions of 70% - 90% limestone and 10% - 30% clay plus 0 - 1% of selected
material such as iron oxide, sand and bauxite, which are used to correct any
deficiency in the two primary materials. The coal that is traditionally used
contains reasonable quantities of inorganic materials, for example, some low
grade coal produced in South Africa contains up to 20% by mass of ash, which in
a cement kiln becomes incorporated into the clinker.
Table 7.5 provides some typical concentrations of trace elements found in the
primary raw materials and coal (Zeevalkink, 1997).
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Table 7.5: Typical Concentrations of Selected Trace Elements in Raw Materials
and Coal (mg/kg)
Element Limestone Clay Coal
Arsenic (As) 0.2 - 12 13 - 23 1 – 13
Chromium (Cr) 0.7 - 12 20 - 90 1 - 50
Mercury (Hg) 0.005 – 0.10 0.02 – 0.15 0.05 – 0.61
Lead (Pb) 0.30 - 21 10 - 40 5 - 27
Zinc (Zn) 1.0 - 57 55 - 110 20 - 150
All three major input materials contribute to the concentrations of trace species,
as they occur naturally in the environment. The addition of AFR will potentially
contribute to these components and, hence, the limits proposed for the most
important elements in the AFR that will be accepted at the kiln. As indicated in
section 7.2.4, the potentially volatile components include sulphur trioxide (SO3),
potassium oxide (K2O), sodium oxide (Na2O), zinc oxide (ZnO), lead (II) oxide
(PbO) and some metal chlorides and those components of high volatility including
cadmium oxide (CdO), thallium oxide (Tl2O), and mercury.
Initially, AFR will only form approximately 35% of the total fuel used, while the
limits provided in Table 7.4 are based on a 100% AFR fuel load. This assumption
has been made to ensure that the levels that could potentially end up in the final
clinker or that are collected in the gas clean-up system are acceptable. In
general, for the low volatility elements, the incorporation rate into the clinker is
very high and very little is found in the dust particles. The more volatile species
tend to vaporise and pass into the gaseous phase of the kiln, where the new
compounds formed condense out on the cooler parts of the kiln or the pre-heater
or precipitate on the feed material of kiln dust. For example, chromium, nickel
and vanadium are incorporated into the clinker and the fraction that collects on
the kiln dust is returned to the kiln when the dust is recycled. It is found that in
kilns with a pre-heater, such as that fitted to Dudfield Kiln 3, even cadmium and
zinc act as low volatility elements. The volatile fraction of lead and zinc, which
averages about 7 - 8% of the total, is incorporated into the dust collected, which
is returned to the kiln. Thus, even the relatively volatile elements are finally fixed
in the clinker matrix and therefore do not pose a significant risk to human health
or the environment.
Chromium, which occurs in the input materials in moderate amounts, can
potentially be oxidised to chromium (VI) in the oxidising atmosphere of a cement
kiln and, therefore, the total chromium (Cr) accepted in the kiln from all sources
must be carefully controlled. The chromium, as Cr(III) or Cr(VI), would be
present in the clinker. Cr(VI), if present in significant amounts could leach from
the cement during use, this is potentially harmful to human health due to the
known carcinogenic nature of Cr(VI).
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The clinker is milled and, after addition of gypsum the final cement products that
are sold throughout South Africa are produced. As the cement contains most of
the trace elements that arise from the materials used in its manufacture, the
environmental fate of these elements is of prime importance. During the cement
manufacturing process, trace elements become trapped in the cement matrix and
because cement has a high pH due to of the high lime content, relatively insoluble
hydroxides and oxides are present. The leachability of most heavy metals is,
therefore, low and they are not released in amounts that are above their
acceptable risk limits, when cement is subjected to standard leach procedures,
such as the Acid Rain Leaching Procedure, specified by the Department of Water
Affairs and Forestry’s Minimum Requirements.
It is important to note that leaching tests conducted on cement represents a
worst case scenario, because cement is usually only a fraction of the materials
used to make mortar, concrete and concrete products and the product hardens
into a matrix that is solid and largely impermeable. Leaching tests on cement
products, such as bricks and board, show that they do not leach trace elements in
quantities that are environmentally significant, i.e. they meet the standards
required by the Department of Water Affairs and Forestry’s Minimum
Requirements.
Mantus (1992) and Zeevalkink (1997) provide an in-depth discussion of the
above issues. Section 7.4 provides a further discussion of the environmental fate
of trace elements.
7.4. AFR Management Procedures
As AFR is typically waste-derived fuel, the management procedures fall under the
Duty of Care requirements that are included in National Environmental
Management Act (No 107 of 1998), and the Environment Conservation Act (No 73
of 1989), as well as the Department of Water Affairs and Forestry’s Minimum
Requirements. The primary objectives are to ensure that all potentially
hazardous waste is classified, handled, transported and finally utilised or disposed
of in a safe and environmentally acceptable manner. This section discusses the
major issues and procedures to be adhered to, with a more comprehensive
discussion of the required procedures presented in Appendix I.
• Acceptance Procedures for AFR
∗ Initial Acceptance Procedures: If a waste is being considered as an AFR, a
complete analysis/study of the physical, chemical and toxicological
properties must be undertaken to determine whether the waste can be
safely used as a fuel and the verify it satisfies predetermined and
approved criteria. Documented procedures for analysis of the waste
usually by an off-site accredited laboratory should be prepared, and made
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available. The acceptability of the material will be determined by the
concentration of various hazardous elements (see table 7.4) and the
ability for the waste to be handled, transported and stored on site. The
form of the waste material is an important consideration at initial
acceptance, as the material is required to be handled and fed into the kiln.
∗ Final Acceptance Procedures: Due to of the nature of waste materials, the
potential hazards and the wide variety generators, it is essential to verify
that the AFR arriving at the Dudfield plant matches the original analysis
profile. A sample of the waste should be taken immediately upon arrival
at the plant and the key analytical parameters, identified during the initial
acceptance study, checked by an on-site laboratory at the Dudfield plant.
This procedure must be adhered to before the AFR is allowed to be
discharged to the storage area or directly into the kiln. Non-conformance
to the requirements would lead to the AFR being sent back to the
generator.
∗ Laboratory and Analytical Requirements: The capability of an on-site
laboratory at the Dudfield plant that would be required to conduct the
quality control tests on AFR is different to that of the laboratory normally
associated with a traditional cement plant. Accordingly the laboratory
must upgraded to be able to analyse for potentially hazardous elements,
e.g. heavy metals including mercury and organic compounds, e.g. PCBs,
as well as bulk parameters such as calorific value and flash point.
• Documentation: A detailed documentation system that tracks the AFR from
the waste generators premises to the Dudfield plant is required to ensure
cradle to grave control over the waste stream. A Waste Manifest Document
must be generated to serve as a tracking document, and should contain
information for the laboratory, the kiln and the accounting department. In
addition, a Transport Emergency Card, which gives information on the AFR to
the emergency services in the event of an accident, plus a Material Safety
Data Sheet, should accompany each vehicle. Procedures must be in place in
order to address the following:
∗ Non-conformance: An investigation into the reasons for the non-
conformance must be initiated and corrective measures implemented to
prevent further non-conformance.
∗ Security: Handling of waste requires strict security as some materials are
valuable, e.g. expired pharmaceuticals and containers may contain highly
hazardous material. The security issues include those at the customer’s
premises, during transport, storage, and the management of empty
containers.
• Packaging and Labelling: Using the correct packaging for the AFR is critical
at all stages of handling. The packaging and labelling required depends on
the physical and chemical properties of the AFR. The specifications for most
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materials are included in SABS 0229: Packaging of Dangerous Goods for Road
and Rail Transportation in South Africa. Waste which would have to be
packaged and labelled could include solids, liquids, sludges and gases, and
the waste could have one or more hazardous characteristics, i.e. flammability,
reactivity, corrosivity and toxicity.
• Loading: Loading procedures are determined by the physical state of the AFR
(i.e. solid, liquid, sludge or gas) and its hazardous characteristics (i.e.
flammable, reactive, corrosive and toxic). The procedures are well defined
and must be adhered to. When loading, materials must be in a form
appropriate for acceptance by the kiln.
• Transport: The transport of a waste material is controlled strictly by
legislation and a number of SABS / SANS codes of practice (refer Appendix I,
section 5.3 for a list of these codes of practice). Key issues to be considered
when transporting AFR are:
∗ Selection of Transporter/Contractor
− The fitness of the driver to be in control of a vehicle
− The vehicle roadworthiness
− The signage used on the vehicle
− Emergency Procedures
− Selection of Traffic Route
− Overloading of Vehicles
− Securing the Load
− Incompatible Loads
* Physical State: Whether the AFR is a solid, liquid, sludge or gas.
* The Transport Regulations: Appendix I section 5.3 contains a list of these
requirements
* Emergency Procedures
• Off-loading: As with transport, off-loading of an AFR at the Dudfield plant
will depend on its physical and hazardous characteristics. Procedures
required should include those for management of dust, spillages and safety
issues such as the handling of flammable liquids. Off-loading must only be
permitted within the designated storage area, and be supervised by
appropriate personnel.
• Handling, Storage and Feeding to the Kiln: Issues that must be
considered in the handling, storage and feeding include:
* Blending of various AFR streams to ensure that the material that is fed into
the kiln has consistent properties (i.e. is homogenous). This can reduce
the potential environmental impact as a consistent AFR allows the kiln
operator to control the risk of unanticipated reactions in the kiln.
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* Meet infrastructure requirements to receive, handle and feed various AFR
types. For example, shredded tyres can be readily stored and fed into the
kiln, however whole tyres could be accepted but required specific on-site
infrastructure.
* Storage should be kept to a minimum and should be sufficient for only a
few days. Appropriate storage areas for different types of AFR should be
provided, and the stored AFR protected from the elements.
* Feeding into the Kiln: The feeding into Kiln 3 will depend on the physical
state of the material.
− Solid wastes: Solid wastes will be shredded and fed via a conveyor
and triple flap system into the upper-end of the Dudfield kiln.
− Liquid wastes: Liquid waste can be pumped into the kiln at three
inlets: the pre-calciner, the upper-end or the lower-end. Potential risk
operations include disconnection and cleaning of pipes.
− Sludge Wastes: Sludges, depending on their consistency, can be
handled either as a liquid or solid. The thicker sludges can be diluted
with compatible liquid waste or pumped directly into the kiln. The
thicker sludges can be blended with compatible solid wastes (e.g.
sawdust) and fed into the kiln in a similar manner to the solid wastes.
− Gaseous Wastes: Gaseous wastes should be input into the kiln via a
suitable gas line, which can accept the connection of various types of
cylinders and other containers.
• Power Failure: Dudfield Kiln 3 is fitted with a back-up generator that
ensures the operation of the kiln’s essential systems. The AFR feed would
automatically stop, and would only resume once the power is restored and
the kiln has reached full operating temperature using coal.
• Emergency Procedures: Emergency procedures must be developed to
protect both employees and neighbours to the site from unplanned events at
Dudfield Kiln 3. If AFR is present in such a form or quantity that it has the
potential cause a major incident, then the Dudfield Kiln 3 would be need to be
registered as a Major Hazard Installation in terms of the Occupational Health
and Safety Act (No 85 of 1993; GN R.60).
7.5. Risks and Significance of Risks
The potential risks associated with the use of AFR in the manufacture of cement
are included in Table 7.6 together with an assessment of the significance of the
risks posed by natural events, technical problems and human error.
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Table 7.6: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human
Error
Aspect Risk Extent Duration Severity Probability Significance
Process
Waste Pre-
acceptance
Incorrect analysis or interpretation
of results could lead to incompatible
waste being accepted by facility.
Local Short term Slight Unlikely Low
Waste
Collection
Poor collection practices could lead
to minor spills.
Local Short term Moderate Unlikely Low
Transport Accidents could lead to spillage of
material.
Local Short term Severe Unlikely Low
Waste
Receiving
Area
Poor off-loading practices could lead
to minor chemical spills.
Local Short term Moderate Unlikely Low
Waste
Acceptance
Incorrect check analysis or
interpretation of results could lead
to incompatible waste being
accepted by facility.
Local Short term Slight to
Moderate
Unlikely Low
Waste
Storage
Incompatible waste stored or
flammable waste incorrectly
managed could lead to risk of fire or
explosion.
Local Short term Severe Very Unlikely Low to Moderate
Gas Storage Improper storage of the flammable
gas could lead to fire or explosion.
Local Short term Severe Very Unlikely Low to Moderate
Utilisation of
AFR
Poor operation of the plant could
lead to incomplete combustion.
Local Short term Moderate Very Unlikely Low to Moderate
Products
from the
Kiln
Contaminated clinker and cement
products entering the market.
National Long term Severe Very Unlikely Low
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Aspect Risk Extent Duration Severity Probability Significance
Natural Events
Flooding Flood water may enter waste
storage areas.
Local Short term Severe Very Unlikely Moderate
Fire Fire within the facility would lead to
considerable risks to plant personnel
inside the facility.
Local Short term Very severe Very Unlikely High
Fire Fire within the facility would lead to
considerable risks to the
environment outside the facility.
Local Short term Severe Very Unlikely Moderate
High Winds High winds could disperse pollutants
into the environment.
Local or
Regional
Short term Moderate Very Unlikely Low
Human Error
Data Entry
Error
Incorrect data could be provided by
the client or be input into the
database.
Local Short term Severe Unlikely Low
Unauthorise
d Access
People could gain unauthorised
access and exposed to potentially
hazardous materials.
Local Short to long
term
Severe Unlikely Low
AFR Spills Chemical spills could result in
contamination of soil and water.
Local Short term Severe Very Unlikely Low
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7.6 Recommendation on the determination of suitable AFR
In the identification of appropriate sources of AFR, the waste management
hierarchy needs to be taken into consideration. Simply stated, the recycling or
re-use of a waste stream must take preference over the treatment or disposal of
waste, where practical. This principle seeks to ensure that the most appropriate
management processes are selected to manage waste.
7.6.1. Typical wastes excluded for use as Alternative Fuels.
In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types
have been identified as unacceptable for the AFR programme at Dudfield. These
wastes will be refused as potential AFR for the following reasons:
• Health and safety issues (waste streams that represent an unacceptable
hazard from an environmental, occupational health or safety point of view).
• To promote adherence to the waste management hierarchy.
• Have a potentially negative impact on the final product quality.
There are a variety of products or wastes that should not be processed or utilised
as AFR in the kilns. These include the following:
• Products or wastes that are excluded as a suitable AFR, listed in Table 7.2.
• Selected extremely toxic ('high risk') wastes, e.g. waste containing free
asbestos fibres and pure carcinogens, which will pose an unacceptable
occupational health and safety risk.
• Wastes that contain unacceptably high levels of selected components that will
impact on the kiln performance, the quality of the clinker and cement and
adversely impact on the emissions from the kiln. These can include waste
with unacceptable levels of some heavy metals, e.g. mercury and lead, high
levels of halogenated hydrocarbons, etc. (refer to Table 7.4).
• Unsorted domestic wastes (municipal garbage) because of the presence of
small amounts of hazardous materials and various metals, etc.
• Small-volume hazardous wastes from households (fluorescent lamps,
batteries etc.).
• Non-identified or insufficiently characterised wastes.
In addition, some waste streams could be an acceptable fuel, but require pre-
treatment before they would be acceptable for use at the kiln. This pre-
treatment will not be undertaken at Dudfield plant.
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Bearing the above criteria and assessment in mind, Holcim has produced a list of
wastes that are deemed unacceptable for AFR purposes. In terms of the Holcim
Group AFR Policy (Holcim Ltd, 2004), these unacceptable wastes consist of the
following:
• Anatomical hospital wastes (without pre-treatment)
• Asbestos-containing wastes
• Bio-hazardous wastes such as infectious waste, sharps, etc. (without pre-
treatment)
• Electronic scrap
• Whole batteries
• Non-stabilised explosives
• High-concentration cyanide wastes
• Mineral acids
• Radioactive wastes
• Unsorted general/municipal/domestic waste
In addition, wastes or potential alternative fuels that exceed the element limits in
Table 7.4 should be excluded or processed to bring them within the acceptable
parameters.
7.6.2. Typical wastes accepted for use as Alternative Fuels.
Wastes that are acceptable as AFR for use by Kiln 3 should be delivered directly
to Dudfield plant. The suitable waste streams could include other non-hazardous
and hazardous wastes such as, but not limited to:
• Scrap tyres
• Rubber
• Waste oils
• Waste wood
• Paint sludge
• Sewage sludge
• Plastics
• Spent solvents
Of particular concern in South Africa is the disposal of scrap tyres to landfill, no
longer an acceptable waste management practise. The SATRP (South African
Tyre Recycling Project) are investigating alternate solutions to deal with the scrap
tyre problem in South Africa. Government is presently promulgating legislation to
discourage the inappropriate disposal of scrap tyres. As the number of scrap
tyres generated in South Africa is estimated at ~10 million per annum, with
~2 million being used to produce recycled rubber and recycled rubber products
the need for an appropriate disposal method is critical. The use of scrap tyres as
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an alternative fuel offers an environmentally acceptable and cost effective option
for managing the scrap tyre problem in South Africa.
7.6.3. Loading, supply, storage and management of Alternative Fuels.
In order to successfully implement the AFR programme at Dudfield plant's Kiln 3,
the alternative fuel is required to be of an appropriate volume so as to supply a
constant flow over an extended period. This minimises the need to adjust the
kilns operating parameters and thus reduces potential risks to the environment.
This, therefore, implies that smaller volume and irregular waste streams should
either not be accepted at Dudfield, or would need to be pre-processed to achieve
a uniform and constant fuel source at an appropriate volume. This pre-treatment
will not be undertaken at Dudfield plant.
For the larger AFR streams that would be delivered directly to the kiln, an on-site
storage facility would need to be provided to accommodate/store an appropriate
reserve capacity.
The correct management of the wastes and the AFR is critical to the success of
this project and its operations. It is essential that the use of AFR is carried out in
a manner that does not impact on human health and well being and the
environment. The implementation of the procedures proposed in this section of
the report, and Appendix I, would ensure that any possible impact is minimised
and that the environmental and health risks are acceptable.
7.7 Proposed Monitoring, Control and Mitigation Measures
7.7.1 Environmental Monitoring Programme
As with any process and its associated procedures, the operations must be
carefully monitored for legislative and operational compliance to ensure that no
harmful activities or consequences arise from the use of alternative fuels.
The environmental monitoring requirements would be specified in permits issued
to the Holcim South Africa Dudfield plant in terms of the Environment
Conservation Act and the Atmospheric Pollution Prevention Act (No 45 of 1965)
and the DWAF minimum requirements. The following sections briefly indicate the
type and extent of monitoring that is required.
• Ground and Surface Water
The number of boreholes that will be required to monitor the site will be
determined from the geological studies after discussions with the Department
of Water Affairs and Forestry (DWAF). Any existing borehole network will
most likely have to be expanded by locating additional boreholes. DWAF has
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specific requirements for borehole water testing, as outlined in the Minimum
Requirements for Water Monitoring at Waste Management Facilities and the
Minimum Requirements for Waste Disposal to Landfill, i.e. for background,
demonstration and regular monitoring. The actual requirements for regular
borehole monitoring will be determined in consultation with DWAF. An
example of the investigative and background monitoring parameters normally
required by DWAF is provided in Table 7.9.
Table 7.7: Minimum Background Monitoring Parameters
Ammonia (NH3 as N) Free and Saline Ammonia as N (NH4-N)
Alkalinity (Total Alkalinity) Lead (Pb)
Boron (B) Magnesium (Mg)
Cadmium (Cd) Mercury (Hg)
Calcium (Ca) Nitrate (as N) (NO3-N)
Chemical Oxygen Demand (COD) pH
Chloride (Cl) Phenolic Compounds
Chromium (Hexavalent) (Cr6+) Potassium (K)
Chromium (Total) (Cr) Sodium (Na)
Cyanide (CN) Sulphate (SO4)
Electrical Conductivity (EC) Total Dissolved Solids (TDS)
The surface water parameters that DWAF requires to be analysed are
normally identical to those for the borehole water samples, although site-
specific parameters may be added.
• Air
The frequency of monitoring and the parameters required for air emissions
will determined by the Chief Air Pollution Control Officer (CAPCO). The kiln
has been upgraded to meet the most stringent European requirements and,
therefore, will conform to the standards set by the Department (refer to the
Air Quality specialist report contained in Appendix H).
7.7.2 Initial Acceptance Procedure Control
Specific acceptance procedures and controls (described in Appendix I) must be in
place in order to verify the type of waste being received for storage and
processing. Records and documentation must be reviewed on a weekly basis to
ensure that each load entering the site has been sampled and analysed.
The procedures used to collect waste from the generator’s premises should be
audited by Holcim on a regular basis (e.g. at least annually) to ensure that the
materials are being handled safely and in accordance with Holcim’s requirements.
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7.7.3 Transport Procedure Control
The transport of waste materials must be audited on a regular basis to ensure
that procedures are followed and that the legislation pertaining to the transport of
hazardous materials is adhered to. This would apply equally to independent
transporters. Drivers must undergo annual driver and medical check ups, to
ensure their fitness and efficiency. Vehicles must be on a planned maintenance
system to ensure that they are maintained in a condition, which is both
roadworthy and in compliance with the transport of hazardous waste.
7.7.4 Final Acceptance Procedure Control
Specific control procedures must be conducted to verify the type of waste being
received. Records and documentation must be reviewed on a weekly basis in
order to ensure that each load entering the site has been sampled and analysed
in accordance with procedure.
• Offloading:
Offloading must be supervised and audited regularly. Offloading equipment
must be on a planned maintenance programme and undergo regular check-
ups.
• Storage:
Storage facilities must be on a planned maintenance system. Documentation
must be tracked to ensure that the different waste types, e.g. non-hazardous
and hazardous, are managed correctly and the storage facilities must be
regularly audited.
• Kiln:
All operations at the kiln, including the waste feeding system, must be
audited regularly.
7.7.5 Compliance Auditing
Auditing of the facilities and associated services is an essential function to ensure
that operating procedures are being adhered to and that liabilities are minimised.
Commitments to I&APs and legal obligations will ensure that these audits take
place and that the results of the audits are not only made known, but are acted
upon timeously. A number of different compliance audits should take place:
• Internal
An internal audit should take place covering operational, health, safety and
environmental aspects, on a daily, weekly and monthly basis. These audits
normally take the form of a checklist that is used by management and staff
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to ensure that all requirements (i.e. compliance to permits and to the
company’s internal environmental policy and management system) are being
maintained.
• External
Independent external auditors should be appointed to check compliance to
the permits and authorisations every six months, or as otherwise specified in
the permit that will be obtained from the Department of Water Affairs and
Forestry for the storage and utilisation of hazardous wastes. The audits will
conform to all the Minimum Requirements for auditing.
The controlling authorities can also carry out external audits. The authorities
at all levels (local, provincial or national) have the legislative right to audit
the operation at any time as pre-arranged with the operator.
A monitoring committee including interested and affected parties should be
formed and, in fact, may be a permit requirement. If required, the
committee can conduct independent audits on the storage facility and kiln to
ensure satisfactory operation so as to ensure minimal impacts on the
surrounding environment.
Every generator of waste has a the 'cradle to grave' responsibility to ensure
that their waste is treated and disposed responsibly. Therefore, it is very
likely that generators that could potentially supply wastes for use as AFR
would require confirmation that by utilising this type of waste management
option, that they are not creating a long-term liability for their company.
7.7.6. Development of Site Specific Specifications
Site specific specifications (mainly for heavy metals) for wastes used in cement
manufacturing are to be developed and should include the following:
• Establishment of average levels of heavy metals in plant clinker (including
the 'natural' fluctuations) as a 'baseline' reference
∗ without AFR
∗ with AFR over a period of approximately one year
• Establishment of a heavy metals balance (input – output) for the individual
kiln system without AFR
• Calculation of 'transfer coefficients' for all metals
∗ to stack emissions
∗ to clinker
∗ to cement kiln dust
• Calculation of the impact of heavy metals input through AFR substitution by
means of standard software modelling.
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• Comparison of model calculations against legal limits (stack emissions) and
against 'baseline' clinker levels and optimisation of AFR substitution rate.
• Verification of the balance model by establishment of a heavy metals balance
with AFR utilisation.
This scheme is to allow for both better prediction and optimisation of the use of
AFR based on the chemical composition and the individual substitution rate of the
AFR under consideration.
7.8. Conclusion
With the correct management and monitoring procedures in place, the utilisation
of AFR in the manufacture of cement could substitute a portion of the fuel load
requirement for Dudfield Kiln 3 and would not represent a significant risk to
human health and the environment.
The practice of using AFR in kilns has the following benefits to the environment
and the waste industry:
• Through the utilisation of waste materials, energy and mineral components
are recovered from selected wastes.
• Conservation of non-renewable resources such as fossil fuels, i.e. coal and
oil, and inorganic materials such as iron ore.
• Reduction in landfill facilities required for the disposal of potentially polluting
materials and an overall reduction in waste volumes to landfill.
These issues and a discussion on the added value that waste recovery has in the
cement industry are discussed in more detail in Mantus (1992) and Zeevalkink
(1997).
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8. CONCLUSIONS AND RECOMMENDATIONS
There is a global trend in the cement production industry to seek more
sustainable production methods through the replacement of existing fossil fuels
(e.g. coal) with alternative waste derived fuels. Following this trend, Holcim
South Africa are considering the implementation of an Alternative Fuels and
Resources (AFR) programme.
The AFR programme proposes the replacement of a portion of Dudfield Kiln 3's
traditional, fossil-based fuel (coal) requirements with alternative fuels and waste-
derived materials. This project aims to ensure that at a minimum, 35% of the
traditional fossil fuel usage is replaced by alternative waste-derived fuels.
This Environmental Impact Assessment (EIA) process for the proposed
introduction of an AFR programme at Kiln 3 at the Holcim South Africa Dudfield
plant has been undertaken in accordance with the EIA Regulations published in
Government Notice R1182 to R1184 of 5 September 1997, in terms of the
Environment Conservation Act (No 73 of 1989), as well as the National
Environmental Management Act (NEMA; No 107 of 1998).
The essence of any EIA process is aimed at ensuring informed decision-making
and environmental accountability, and to assist in achieving environmentally
sound and sustainable development. In terms of NEMA (No 107 of 1998), the
commitment to sustainable development is evident in the provision that
“development must be socially, environmentally and economically
sustainable…and requires the consideration of all relevant factors…”. NEMA also
imposes a duty of care, which places a positive obligation on any person who has
caused, is causing, or is likely to cause damage to the environment to take
reasonable steps to prevent such damage. In terms of NEMA’s preventative
principle, potentially negative impacts on the environment and on people’s
environmental rights (in terms of the Constitution of the republic of South Africa,
Act 108 of 1996) should be anticipated and prevented, and where they cannot be
altogether prevented, they must be minimised and remedied in terms of
“reasonable measures”.
In assessing the environmental feasibility of an AFR programme at Dudfield plant,
the requirements of all relevant legislation has been considered (refer to
Appendix J), including inter alia, those of:
• Environment Conservation Act (No 73 of 1989);
• Atmospheric Pollution Prevention Act (No 45 of 1965);
• National Water Act (No 36 of 1998);
• Occupational Health and Safety Act (No 85 of 93);
• Hazardous Substances Act (No 15 of 1993);and
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• Relevant SABS Codes in terms of the identification and classification,
handling, packaging, storage and transport of hazardous substances.
This relevant legislation has informed the identification and development of
appropriate management and mitigation measures that should be implemented in
order to minimise potentially significant impacts associated with the project.
The conclusions of this EIA are the result of comprehensive studies and specialist
assessments. These studies were based on issues identified through the EIA
process and the parallel process of public participation. The public consultation
process has been rigorous and extensive, and every effort has been made to
include representatives of all stakeholders within the process.
8.1. Evaluation of the Proposed Project
The preceding chapters of this report provide a detailed assessment of the
environmental impacts on specific components of the social and biophysical
environment as a result of the proposed project. This chapter concludes the EIA
process by providing a holistic evaluation of the most important environmental
impacts. In so doing, it draws on the information gathered as part of the EIA
process and the knowledge gained by the environmental consultants during the
course of the EIA and presents an informed opinion of the proposed introduction
of an AFR programme at Kiln 3 at the Dudfield plant.
The Holcim Dudfield plant was constructed more than 50 years ago and is located
within an area zoned for industrial use. Impacts to or the disturbance of the land
within and surrounding the Dudfield plant already exist, and have done so since
the initial construction of the facility. The AFR programme proposed at Dudfield’s
Kiln 3 involves the reduction in the use of coal through supplementation of the
fuel required with AFR. As the necessary upgrade of Kiln 3 to accept AFR has
already been undertaken, the use of AFR will not require any additional changes
to the footprint area of the existing cement plant. Therefore, no impact on
surrounding land uses, vegetation or heritage sites are anticipated as a result of
the proposed project.
The major environmental issues associated with this proposed project, therefore,
include:
• impacts associated with emissions to air from the plant;
• impacts associated with the transportation of AFR to Dudfield plant;
• impacts associated with the storage of AFR on site for a limited period;
• impacts on the social environment;
• suitability of waste as an alternative fuel resource; and
• potential project benefits.
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These are discussed in more detail below.
According to the US Air and Waste Management Association's (A&WMA) Air
Pollution Control Manual, the use of wastes as a fuel and a raw material in
cement kilns is a reliable and proven technology, offering a cost-effective, safe
and environmentally sound method of resource recovery for many types of
hazardous and non-hazardous wastes (http://gcisolutions.com/dgawma01.htm).
Conditions needed to manufacture cement (high temperature, turbulence and
long gas residence times) are the same conditions required for total destruction
of hazardous waste. Cement kilns burn hotter, have longer gas residence times,
and are much larger than other commercial thermal treatment facilities. These
advantages, together with the degree of mixing in the kiln, make cement kilns an
excellent technology for recovering energy from hazardous and non-hazardous
waste (www.ckrc.org/issues/99475523.html).
Results of research undertaken world-wide by the cement industry and
independent institutions (such as the US EPA) have indicated that the impacts
associated with the introduction of an AFR programme in cement kilns does not
impact significantly on the environment when compared to the use of traditional
fossil fuels. However, this is reliant on appropriate management of waste,
including the classification, selection, handling and storage thereof. Therefore,
this EIA has placed emphasis on the identification of suitable wastes as
alternative fuels and the waste management requirements associated with the
introduction of an AFR programme at Dudfield plant.
8.1.1. Impacts Associated with Emissions to Air from the Plant
Releases from the cement kiln are a result of the physical and chemical reactions
of the raw materials and from the combustion fuels. Typical air pollutants from
cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx),
inhalable particulates (PM10), heavy metals, organic compounds and dioxins and
furans.
During the EIA process, concern was raised regarding the potential impacts
associated with dust, and dioxins and furans and the health risk posed to local
communities. From the results of the specialist study undertaken as part of this
EIA, it is anticipated that an impact of low significance on air emissions will result
with the introduction of an AFR programme at Kiln 3 at Dudfield plant as the
emission levels remain below the DEAT guidelines.
The exit gases from Kiln 3 are de-dusted in bag filters, and the dust returned to
the process. Therefore, dust levels associated with this process are low and will
not impact significantly on the surrounding environment. This will continue to be
the case with the introduction of an AFR programme.
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Dioxins and furans are a family of persistent organic chemicals detectable in trace
amounts throughout the environment. The US EPA, international Agency for
Cancer Research and US Department of Health report that excessive exposure to
2,3,7,8-tetrachlorodibenzo-p–dioxin (2,3,7,8-TCDD) can cause of wide range of
very harmful human health effects, including cancer (EPA, 2004). Studies by the
US EPA and French Academy of Sciences have, however, indicated that it is highly
unlikely that dioxins would increase cancer incidence in people at the low
exposure levels commonly encountered in the environment or from food (Rotard,
1996), and that no fatal case associated with these compounds has ever been
reported (Constans, 1996).
Dioxins can be formed from any burning process, and cement kilns are no
exception. The potential for dioxin formation in cement manufacture is a function
of raw materials and kiln technology, and is not related to the types of fuel used.
Dioxin emissions are generally in the range of detection limits and the level of
emissions can depend on the type of kiln technology employed. “Cement kilns
control dioxin formation by quenching kiln gas temperatures so that gas
temperatures at the inlet to the particulate matter control device are below the
range of optimum dioxin/furan formation” (EPA, 2004).
The cement industry has been more successful than any other in reducing
emissions of dioxins and furans. Through intensive research, an understanding of
the nature of dioxin formation in combustion emissions has been established, and
they have succeeded in learning how to reduce those emissions. As a result since
1990, dioxin emissions from kilns that recover energy from hazardous waste have
been reduced by 97%. This has been corroborated by independent research
undertaken by the US EPA (www.ckrc.org/ncafaq.html).
Conclusions of the specialist air quality study undertaken as part of this EIA (refer
to Chapter 6) are in agreement with these international findings and indicate that
the introduction of an AFR programme at Kiln 3 at Dudfield plant will not have a
significant impact on air quality.
In order to monitor emissions from Dudfield plant, Holcim South Africa has
installed state-of-the art OPSIS continuous emission measuring equipment that
is linked to the kiln operating system. The equipment currently measures 12
emission streams on a continuous basis, with a further annual measurement of
12 heavy metals and dioxins and furans. Emission levels will be subject to the
prescribed requirements of the Stack Registration Permit issued by CAPCO.
Alarms are in place in order to indicate if any emission approaches its limits, thus
allowing for immediate corrective action to be taken. All emission data captured
by the OPSIS equipment will be available to CAPCO for auditing purposes.
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8.1.2. Impacts Associated with the Transportation of AFR to Dudfield
Plant
Issues surrounding the transportation of AFR to Dudfield plant were identified
through the EIA process, including impacts on traffic volumes and the potential
disruption to the daily movement patterns of the local population (particularly
residents in Lichtenburg, the Dudfield village and surrounding farming
communities), as well as safety risks to human health and the environment
associated with accidents and spillage of waste. A long-term scenario of six (6)
additional trucks per day transporting AFR to Dudfield plant is anticipated.
Specialist studies undertaken indicate that this will result in a 1% increase in the
traffic volume on the access routes to Dudfield plant, a very small growth in
traffic which is considered to be insignificant. Therefore, impacts in terms of
traffic growth and disruption to traffic patterns are anticipated to be of low
significance. In order to ensure that this impact is minimised, preferred routes to
haul waste to the Dudfield plant have been recommended. These correspond
with those currently being utilised by traffic travelling to Dudfield plant.
In order to minimise the risk to human health and the environment as a result of
potential accidents and spillage of waste, it is essential that appropriate
management and emergency response procedures be in place for the
transportation of AFR to Dudfield. In the event of an accident, the vehicles are
equipped with spill-control kits and action should be taken as soon as possible in
order to contain spillages while waiting for backup. The transport of waste must
be supported by a HazMat Emergency Response team in order to contain and
clean up any spill, in order to minimise impacts on the environment and
surrounding communities.
8.1.3. Impacts Associated with the Storage of AFR on Site for a
Limited Period
In order to successfully implement the AFR programme at Dudfield plant's Kiln 3,
the feed is preferably required to be of an appropriate volume to supply a
constant flow over an extended period. This minimises the need to adjust the
kilns operating parameters and thus reduces potential risks to the environment.
This, therefore, implies that smaller volume and irregular waste streams should
either not be accepted at Dudfield, or would need to be pre-processed to achieve
a uniform and constant fuel source at an appropriate volume. This pre-treatment
in not anticipated to be undertaken at Dudfield plant.
For the AFR streams that would be delivered directly to the kiln, an on-site
storage facility would need to be provided to accommodate/store an approximate
2-day reserve capacity. The appropriate management of the storage of waste-
derived alternative fuels will minimise environmental impacts and the potential
for pollution of the soil and groundwater. Without the implementation of
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appropriate management measures, this impact is potentially of high significance.
The storage of fuels, storage and handling of AFR must be undertaken in an
appropriate manner, as stipulated in this report, to avoid spillage and leaching
and to limit fugitive emissions, odour and noise to acceptable levels. In addition,
the amount of AFR stored on site must be appropriately managed in terms of the
operational requirements of the plant, and should be based on a just-in-time
principle.
Storage areas for all alternative fuels and resources must be constructed
according to national engineering standards and specifications required by the
relevant National and Provincial Government Departments. These should have a
concrete floor, should be properly bunded, and if required for operational
reasons, should be covered by a permanent roof structure. The volume of the
bunded area should at least be such that it can contain a 1:50 year rainfall event
over the surface area of the storage area. The concrete base will minimise, if not
totally exclude, leachate infiltration into the groundwater.
8.1.4. Impacts on the Social Environment
The Holcim Dudfield Plant is located approximately 18 km west of Lichtenburg,
which is the closest town to the facility. The area surrounding Dudfield plant is
sparsely populated, typical of a rural farming community. The greatest
population density in the immediate area surrounding the plant is Dudfield
Village, where approximately 200 people reside. The village is located
approximately 1 km south-west of the plant. Impacts to or the disturbance of
surrounding communities already exist, and have done so since the initial
construction of the facility more than 50 years ago.
Potential impacts on the social environment associated with the introduction of an
AFR programme at Dudfield plant identified and assessed within this EIA include:
• disruption in daily living and movement,
• impacts on public health and safety,
• impacts on infrastructure and community infrastructure needs,
• local and intrusion impacts
• regional benefits.
As impacts in terms of traffic growth and disruption to traffic patterns are
anticipated to be of low significance, no significant impact on daily living and
movement patterns of the local population is anticipated. Risks to human health
are associated with potential vehicle overloading, accidents and spillage of waste
during transportation of the AFR. With the implementation of appropriate
management and emergency response procedures for the transportation of AFR
to Dudfield, this potential impact is considered to be unlikely to occur and of low
significance.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04156
Specialist studies have indicated that no risk to human health is anticipated with
the introduction of an AFR programme as a result of air emissions. Risk
assessments undertaken internationally have shown that the use of waste
(hazardous and non-hazardous) as fuel in cement kilns poses no increased risk to
human health and the environment (www.ckrc.org/ncafaq.html; refer Appendix
J).
Potential health and safety risks to employees has been identified as a potentially
significant impact. However, with the provision of appropriate precautionary
measures such as strict acceptance procedures, accurate laboratory testing, data
sheets, training, controls, procedures, health monitoring, facility design and
emergency response planning, the potential impacts on the health and safety of
employees will be managed to acceptable levels. In addition, it is important that
relevant safety information is provided to sub-contractors and visitors to the
premises in order to ensure their safety.
Limestone mining and cement manufacture are two of the major economic
activities currently undertaken in the area, providing employment to members of
the local community. The continued operation of the Dudfield plant in an
environmentally and economically sustainable manner will secure these
employment opportunities in the long-term. This is considered to have a positive
impact of high significance on the region.
8.1.5. Suitability of Waste as an Alternative Fuel Resource
The selection, acceptance and appropriate management of the waste-derived fuel
are critical to the success of this project and its operations. It is essential that
AFR management be carried out in a manner that does not impact on human
health and well-being and the environment.
The management protocol for the utilisation of waste as a alternative fuel follows
a 'cradle to grave' approach. This means that it is the responsibility of Holcim
South Africa to ensure that the alternative fuels and resources are appropriately
managed, from identification of potential fuels to utilisation of the fuel in the kiln
and the control of any emissions from the kiln.
In order to determine the suitability of using AFR in the kiln it is critical to
identify, understand and manage the factors that could potentially create an
impact on health, safety or the environment. In addition, there can be no
compromise on the quality of the clinker and cement produced. Therefore, the
types and nature of the AFR materials and their respective management
procedures that would be acceptable, as well as the limits on specific elements,
need to be specified and adhered to.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04157
The primary management considerations required to ensure the total 'cradle to
grave' management of AFR include:
• AFR identification and acceptance procedures
• Documentation
• Packaging and labelling
• Loading at the generator’s premises
• Transportation
• Acceptance procedures at Dudfield plant
• Offloading
• Handling, storage on-site and feeding into the kiln
• Characteristics of the products and, if produced, any by-products from the kiln
In the identification of appropriate sources of AFR, the waste management
hierarchy needs to be taken into consideration. Simply stated, the recycling or
re-use of a waste stream must take preference over the treatment or disposal of
waste, where practical. This principle seeks to ensure that the most appropriate
management processes are selected to manage waste.
In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types
have been identified as unacceptable for an AFR programme at Dudfield. These
wastes will be refused as potential AFR for the following reasons:
• Health and safety issues (waste streams that represent an unacceptable
hazard from an environmental, occupational health or safety point of view).
• To promote adherence to the waste management hierarchy.
The are a variety of products or wastes that should not be processed or utilised
as AFR in the kilns. These include the following:
• Selected extremely toxic ('high risk') wastes, e.g. waste containing free
asbestos fibres and pure carcinogens, which will pose an unacceptable
occupational health and safety risk.
• Wastes that contain unacceptable levels of selected components that will
impact on the kiln performance, the quality of the clinker and cement and
adversely impact on the emissions from the kiln. These can include waste
with unacceptable levels of some heavy metals, e.g. mercury and lead, high
levels of halogenated hydrocarbons, etc.
• Unsorted domestic wastes (municipal garbage) because of the presence of
small amounts of hazardous materials and various metals, etc.
• Small-volume hazardous wastes from households (fluorescent lamps,
batteries etc.).
• Non-identified or insufficiently characterised wastes.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04158
Bearing the exclusionary criteria from the assessment of waste steams in mind,
the list of wastes that are deemed unacceptable for AFR purposes in terms of the
Holcim Group AFR Policy (Holcim Ltd, 2004) is supported. These unacceptable
wastes consist of the following:
• Anatomical hospital wastes (without pre-treatment)
• Asbestos-containing wastes
• Bio-hazardous wastes such as infectious waste, sharps, etc. (without pre-
treatment)
• Electronic scrap
• Whole batteries
• Non-stabilised explosives
• High-concentration cyanide wastes
• Mineral acids
• Radioactive wastes
• Unsorted general/municipal/domestic waste
With the correct management and monitoring procedures in place, the utilisation
of AFR in the manufacture of cement could substitute a portion of the fuel load
requirement for Dudfield Kiln 3 and would not represent a significant risk to
human health and the environment.
Wastes that are acceptable as AFR for use by Kiln 3 as an alternative fuel source
include non-hazardous and hazardous wastes such as, but not limited to scrap
tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and
spent solvents.
8.1.6. Project Benefits
The utilisation of alternative fuels in the cement industry is in-line with initiatives
of National Government, particularly the National Waste Management Strategy
(NWMS) which focuses on waste prevention and waste minimisation. The
practice of employing alternative fuels in cement plants promotes the materials
recovery and recycling industry, which is in line with the principles of the NWMS.
Where recycling of waste is not possible, landfill or incineration is the most
common disposal practice available for many wastes. The introduction of an AFR
programme would assist in the reduction in the amount of waste required to be
disposed of to landfill or other means, and assist in the reduction of greenhouse
gas emissions. The use of waste-derived fuel as AFR in cement kilns provides a
service to society by dealing safely with wastes that are often difficult to dispose
of in any other way (e.g. scrap tyres; www.ckrc.org/issues/993135035.html).
Of particular concern in South Africa is the disposal of scrap tyres to landfill. The
SATRP (South African Tyre Recycling Project) are investigating alternate solutions
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04159
to deal with the scrap tyre problem in South Africa. Government is presently
promulgating legislation to discourage the inappropriate disposal of scrap tyres.
As the number of scrap tyres generated in South Africa is estimated at ~10
million per annum, with only ~ 2 million being used to produce recycled rubber
and recycled products the need for an appropriate disposal method is critical.
The use of scrap tyres as an alternative fuel offers an environmentally acceptable
and cost effective option of managing the excess scrap tyre problem in South
Africa, as the landfilling of scrap tyres is no longer an acceptable practise.
The nature of the cement manufacture process makes waste suitable for the use
as AFR by ensuring full energy recovery from various wastes under appropriate
conditions. Any solid residue from the waste then becomes a raw material for the
process and is incorporated into the final clinker. This, therefore, results in the
conservation of non-renewable natural resources, as well as a reduction in the
environmental impacts associated with mining activities.
Depending on the quantity of the waste-derived fuel available and the energy
content of this fuel, Holcim South Africa will be able to replace between 35 - 50%
of their traditional coal-based fuel with AFR. Including the kiln efficiency
upgrade, a total reduction of between 40 000 and 90 000 tons of coal/annum is
estimated by Holcim for Kiln 3.
8.2. Conclusions
The introduction of the AFR programme at Kiln 3 of the Dudfield plant provides
the opportunity to:
• Recover energy from combustible wastes and inorganic materials.
• Conserve non-renewable resources such as fossil fuels, i.e. coal and oil, and
inorganic materials such as iron ore.
• Reduce the volume potentially polluting materials being disposed by landfill
and reducing overall waste volumes to landfill.
For these benefits to be fully realised, strictly controlled management procedures
are required to be implemented for the entire AFR programme process. These
management procedures should be detailed in an Environmental Management
Plan (EMP) which includes inputs from the EIA and the permitting authorities.
This will ensure that the waste materials are managed from 'cradle to grave' and
all potential adverse impacts are managed to acceptable levels.
As Dudfield plant is an ISO 14001 accredited operation, the EMP would be
required to form part of the independently audited ISO 14001 programme.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04160
8.3. Permit Requirements associated with the Introduction of an AFR
Programme at Dudfield Plant
The manufacture of cement is a mature industrial activity which is strictly
regulated through national and international legislation in terms of environmental
protection, health and safety, and quality of products. The introduction of an
alternative fuels and resources programme at Dudfield plant would also be
regulated by this legislation (refer to Appendix K). In terms of this legislation, a
number of permits are required to be obtained for the implementation of the AFR
programme. A summary of the most relevant permits, licences, certificates and
other authorisations required by Holcim South Africa are detailed in Table 8.1
below. This table must be read in conjunction with the environmental legal
register contained within Appendix K.
Table 8.1: Summary of the most relevant permits, licences, certificates and
other authorisations required by Holcim South Africa for the
introduction of an AFR programme at Dudfield
Applicable Environmental
Law
Aspect Component Compliance Requirement
Environment Conservation
Act, No 73 of 1989 and
Regulations 1182 and 1183
published there under.
Commencement of any activity
that is considered to be
substantially detrimental to the
environment must be preceded
by written authorisation
obtained from the relevant
authority.
An Environmental Impact
Assessment must be submitted
to the Minister of Environmental
Affairs and Tourism (DEAT) or
any other competent authority
identified by the Minister or a
written application for exemption
to conduct an EIA or part thereof
must be submitted to the
relevant authority.
Environment Conservation
Act, No 73 of 1989
Any person, who treats, stores
for a period exceeding 90 days,
or disposes of hazardous waste
on site must apply for a permit
for a waste disposal facility from
DWAF.
If applicable, a written permit
application must be submitted to
DWAF.
Hazardous Substances Act,
No 15 of 1973
The operation may not use,
operate, install or dispose of any
hazardous substance with a
Group I and II: (any substance
or mixture of a substance that
might by reason of its toxic,
corrosive etc.; nature, or
because it generates pressure
through decomposition, heat or
other means, cause extreme risk
of injury etc) or Group III: (any
electronic product with
If applicable, the operation must
apply in writing for a licence at
the Department of Health.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04161
Applicable Environmental
Law
Aspect Component Compliance Requirement
hazardous qualities), unless a
license is in force in respect
thereof.
Occupational Health and
Safety Act, No 85 of 1993 –
GNR 1179 of 25 August
1995
All drivers transporting
hazardous material must be in
possession of a valid Public
Driving Permit: Hazardous, a
medical certificate and a
HazChem training certificate. In
addition they must comply with
the Road Transport Quality
System, have full knowledge of
emergency response procedures,
and be equipped with and
trained in the use of protective
clothing.
Ensure that the relevant drivers
have the correct licences and
that awareness training
programs, highlighting all
transportation of dangerous
goods risks are developed and
implemented on all relevant
driver levels.
Occupational Health and
Safety Act, No 85 of 1993 –
GNR 1179 of 25 August
1995
An employer shall, before any
employee is exposed or may be
exposed to any hazardous
chemical substance, ensure that
the employee is adequately and
comprehensively informed and
trained.
Ensure that awareness-training
programs, highlighting the risks
involved in respect of exposure
to hazardous substances are
developed and implemented on
all employee levels.
Atmospheric Pollution
Prevention Act, No 45 of
1965 (APPA)
No person may conduct a
Scheduled Process in or on any
premises in South Africa unless
that person or company is the
holder of a provisional or current
registration certificate
authorising the carrying on of
the Scheduled Process in or on
the premises concerned.
Apply in writing to the Chief Air
Pollution Control Officer (CAPCO)
at DEAT for provisional or
current registration certificates
for each and every Scheduled
Process, and ensure that the
conditions in the certificate are
complied with at all times.
Atmospheric Pollution
Prevention Act, No 45 of
1965 (APPA)
Any alteration or extension of an
existing building or plant in
respect of which a registration
certificate has been issued is
prohibited unless an application
has been made to the Chief Air
Pollution Control Officer (CAPCO)
for provisional registration of the
proposed alteration or extension.
If applicable, a written
application must be submitted to
the Chief Air Pollution Control
Officer (CAPCO) for provisional
registration of the proposed
alteration or extension.
Alternatively apply for exemption
from CAPCO.
A provisional or current
registration certificate is not
required where the alteration or
extension will not affect the
escape into the atmosphere of
noxious or offensive gases.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
Conclusions and Recommendations 31-Aug-04162
Applicable Environmental
Law
Aspect Component Compliance Requirement
Atmospheric Pollution
Prevention Act, No 45 of
1965 (APPA)
The operation shall not install in
or on any premises any fuel-
burning appliance, unless such
an appliance is provided with
effective appliances to limit the
emission of grit and dust to the
satisfaction of the local
authority. A local authority may
require any person to furnish
information as to the fuel or
refuse used in fuel burning
appliances.
A provisional or current
registration certificate is not
required where the alteration or
extension will not affect the
escape into the atmosphere of
noxious or offensive gases.
Ensure that best practice
technology is used to prevent
the escape into the atmosphere
of noxious or offensive gases.
Atmospheric Pollution
Prevention Act, No 45 of
1965 (APPA)
No local authority shall approve
of any plan that provides for the
installation of any fuel burning
appliance, unless it is satisfied
that a fuel burning appliance is
suitably sited.
If applicable, ensure that all fuel
burning appliances are suitably
sited and that best practice
technology is used to prevent
the escape into the atmosphere
of noxious or offensive gases.
Atmospheric Pollution
Prevention Act, No 45 of
1965 (APPA)
Certain odours may be defined
as noxious or offensive gases
and relevant registration
certificates are needed for the
continued carrying on of those
processes that create these
noxious or offensive gases.
If applicable, the operation must
have a valid provisional or
current registration certificate to
carry on its business. Submit an
application for the relevant
certificate to CAPCO at DEAT.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
References 31-Aug-04163
9. REFERENCES
Acocks, J.P.H. (1988) Veld Types of South Africa, 3rd Edition. Botanical Research
Institute, South Africa.
AEA Technology (2002) Towards a Sustainable Cement Industry: Environment,
Health, and Safety Performance Improvement. An independent study
commissioned by World Business Council for Sustainable Development.
ACMP (Association of Cementitious Material Producers) Air Emissions from a
Cement Kiln: Presentation.
Barnard, H C (2000) An explanation of the 1:500 000 general hydrogeological
map Johannesburg 2526. Department of Water Affairs and Forestry,
Pretoria.
Batchvarova A E and Gryning S E (1990) Applied model for the growth of the
daytime mixed layer, Boundary-Layer Meteorology, 56, 261-274.
Becker, R. (1999) Social Impact Assessment. Netherlands.
Botha, l J and Bredenkamp, D B (1993) Lichtenburg: A case study incorporating
Cumulative Rainfall Departures (CRD). Report No. GH3742, Department of
Water Affairs and Forestry, Pretoria.
Bouwmans I and Hakvoort R (1998) A Framework for the Evaluation of the
Environmental Merits of Waste Co- Incineration. IECEC-98-1225. 33rd
Intersociety Engineering Conference on Energy Conversion, Colorado
Springs, CO, August 2-6, 1998.
Burdge, R.J. (1995) A Community Guide to Social Impact Assessment. Wisconsin:
Social Ecology Press.
Burger L W (1994) Ash Dump Dispersion Modeling, in Held G: Modeling of Blow-
Off Dust From Ash Dumps, Eskom Report TRR/S94/185, Cleveland, 40 pp.
Burger L W, Held G and Snow N H (1995) Ash Dump Dispersion Modeling
Sensitivity Analysis of Meteorological and Ash Dump Parameters, Eskom
Report TRR/S95/077, Cleveland, 18 pp.
CEMBUREAU (1997) Alternative Fuels in Cement Manufacturing, Technical and
Environmental Review. The European Cement Association, April.
CEMBUREAU (1999) ”Best Available Techniques” for the Cement Industry, A
contribution from the European Cement Industry to the exchange of
information and preparation of the IPPC BAT REFERENCE Document for the
cement industry. The European Cement Association, December.
CEPA/FPAC Working Group (1998) National Ambient Air Quality Objectives for
Particulate Matter. Part 1: Science Assessment Document, A Report by the
Canadian Environmental Protection Agency (CEPA) Federal-Provincial
Advisory Committee (FPAC) on Air Quality Objectives and Guidelines.
Chow J C and Watson J G (1998) Applicability of PM2.5 Particulate Standards to
Developed and Developing Countries, Paper 12A-3, Papers of the 11th
World Clean Air and Environment Congress, 13-18 September 1998,
Durban, South Africa.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
References 31-Aug-04164
CIE Document, “Acceptable Levels of Pollutants in Waste for Recovery in the
Cement Industry“ (This is a “Holderbank” Draft Position Paper).
CIE Document, “The Added Value of Waste Recovery in the Cement Industry”
(This is a “Holderbank” Draft Position Paper).
Cochran L S and Pielke R A (1992) Selected International Receptor-Based Air
Quality Standards, Journal of the Air and Waste Management Association,
42 (12), 1567-1572.
Cowherd C, Muleski G E and Kinsey J S (1988) Control of Open Fugitive Dust
Sources, EPA-450/3-88-008, US Environmental Protection Agency,
Research Triangle Park, North Carolina.
Dziembowski, Z M (1995) Grondwatertoestande in die Bo-Molopo Ondergrondse
Staatswaterbeheergebied in 1995. Report GH 2869, Department of Water
Affairs and Forestry, Pretoria.
Department of Environment Affairs and Tourism (2002) White Paper on an
Integrated Pollution and Waste Management Policy for South Africa, April
2002
Department of Environmental Affairs and Fisheries (1984) General and Special
Standards, Requirements for the purification of waste water or effluent.
Government Gazette 18 May 1984, No. 9225, Regulation No 991, 18 May
1984.
Department of Transport (South Africa) (1992) Structural Design of Interurban
and Rural Road Pavements. TRH 4. 9p.
Department of Transport (South Africa) (1995) Manual For Traffic Impact
Studies. 2-1p.
Department of Water Affairs and Forestry (1998) Minimum Requirements for the
Handling, Classification, and Disposal of Hazardous Waste
Department of Water Affairs and Forestry (1998) Minimum Requirements for
Disposal of Waste to Landfill
Department of Water Affairs and Forestry (1998) Minimum Requirements for
Water Monitoring at Waste Management Facilities.
Department of Water Affairs (1996) Amendment of the Requirements for the
purification of waste water or effluent. Government Gazette 15 November
1996, No1864.
Department of Water Affairs and Forestry (1995) Characterisation and mapping
of the groundwater resources, Kwazulu-Natal Province. Mapping Unit 11,
Dept. of Water Affairs and Forestry, Pretoria.
Environmental Protection Agency 40 CFR Parts 63,264,et al. National Emission
Standards for Hazardous Air Pollutants: Proposed Standards for Hazardous
Air Pollutants for Hazardous Waste Combustors (Phase I Final Replacement
Standards and Phase II); Proposed Rule. 20 April 2004 (Page 21205).
Environmental Protection Agency 40 CFR Parts 63,264,et al. National Emission
Standards for Hazardous Air Pollutants: Proposed. Standards for Hazardous
Air Pollutants for Hazardous Waste Combustors (Phase I Final Replacement
Standards and Phase II); Proposed Rule. 20 April 2004 (Page 21249).
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
References 31-Aug-04165
EPA (1986) Air Pollution: Improvements Needed in Developing and Managing
EPA’s Air Quality Models, GAO/RCED-86-94, B-220184, General
Accounting Office, Washington, DC.
EPA (1995a) User’s Guide for the Industrial Source Complex (ISC) Dispersion
Model. Volume I - User Instructions, EPA-454/B-95-003a, US-
Environmental Protection Agency, Research Triangle Park, North Carolina.
EPA (1995b) User’s Guide for the Industrial Source Complex (ISC) Dispersion
Model. Volume I - Description of Model Algorithsms, EPA-454/B-95-003b,
US-Environmental Protection Agency, Research Triangle Park, North
Carolina.
EPA (1996) Compilation of Air Pollution Emission Factors (AP-42), 6th Edition,
Volume 1, as contained in the AirCHIEF (AIR Clearinghouse for Inventories
and Emission Factors) CD-ROM (compact disk read only memory), US
Environmental Protection Agency, Research Triangle Park, North Carolina.
Geological Survey, South Africa (1986) Geological Map Sheet 2626 West Rand.
Scale 1:250 000. Geol. Surv., Pretoria.
Godish R (1990) Air Quality, Lewis Publishers, Michigan, 422 pp.
Goldreich Y and Tyson P D (1988) Diurnal and Inter-Diurnal Variations in Large-
Scale Atmospheric Turbulence over Southern Africa, South African
Geographical Journal, 70(1), 48-56.
Gould, Dr R (2000) Gossmann Consulting. Learning Lessons from the Cement Kiln
Saga. (http://gcisolutions.com/dgawma01.htm)
Holcim presentation (2003) Emission Ranges of Cement Kilns. Waltisberg J H,
presentation 20. The Alpha Cement “Understanding Cement Kiln Emission
Coarse and Workshop”.
IRIS (1998) US-EPA's Integrated Risk Information Data Base, available from
www.epa.gov/iris (last updated 20 February 1998).
Jasper, Miller Associates CC (2004) Holcim (South Africa) (Pty) Ltd – Dudfield
[previously Alpha – Dudfield) De-watering Assessment. Ref: JMA/10264.
May 2004.
Junker A and Schwela D (1998) Air Quality Guidelines and Standards Based on
Risk Considerations, Paper 17D-1, Papers of the 11th World Clean Air and
Environment Congress, 13-18 September 1998, Durban, South Africa.
Kletz T.A. (1976) The application of hazardous analysis to risks to the public at
large, World Congress of Chemical Engineering, Amsterdam.
Koenig J.Q. (2000) Health Effects of Ambient Air Pollution. How safe is the air
we breath?, Kluwer Academic Publishers, Boston, pp. 249.
Landesumweltamt Nordrhein-Westfalen (1997) Commissioned by EC DG XI, LUA-
Materialien No. 43, Identification of Relevant Industrial Sources of Dioxins
and Furans in Europe, The European Dioxin Inventory.
Lees F.P. (1980) Loss Prevention in the Process Industries, Butterworths,
London, UK.
Lemarchand D (2000) Burning Issues. Cement Technology, February, pp65 to
67.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
References 31-Aug-04166
Loveday M (1995) Clean Air Around the World. National Approaches to Air
Pollution Control, published by the International Union of Air Pollution
Prevention and Environmental Protection Association, Brighton, 402 pp.
Mantus E K (1992) All Fired Up: Burning Hazardous waste in Cement Kilns,
Environmental Toxicology International, Seattle
Marlowe I and Mansfield D (2002) Toward a Sustainable Cement Industry.
Substudy 10: Environment, Health & Safety Performance Improvement.
AER Technology.
Marticorena B and Bergametti G (1995) Modeling the Atmospheric Dust Cycle: 1.
Design of a Soil-Derived Dust Emission Scheme. Journal of Geophysical
Research, 100, 16 415 - 16 430.
Midgley, D C, Pitman, W V and Middleton, B J (1994a) Surface water resources
of South Africa 1990. Volume II, Drainage Region C: Book of Maps.
Water Research Commission Report No. 298/2.2/94.
Midgley, D C, Pitman, W V and Middleton, B J (1994b) Surface water resources
of South Africa 1990. Volume II, Drainage Region C: Appendices. Water
Research Commission Report No. 298/2.1/94.
Mr Israel Motlhabane (2004) Lichtenburg Municipality: IDP coordinator. Personal
Communication.
Mukherjee A B, Kääntee U and Zevenhoven R (2001) The Effects of Switching
from Coal to Alternative Fuels on Heavy Metals Emissions from Cement
Manufacturing. Proc. Of the 6th Int. Conf. on the Biochemistry of Trace
Elements, Guelph (ON), Canada, Jul. 29 Aug . 2, 2001, p.379.
Oke T T (1990) Boundary Layer Climates, Routledge, London and New York, 435
pp.
ÖKOMETRIC (2001) Analytical Report. ÖKOMETRIC GmbH,· Berneckerstraße 17-
21 · 95448 Bayreuth.
Parsons, R (1995) A South African Aquifer System Management Classification.
WRC report No. KV 77/95, Water Research Commission, Pretoria.
Pasquill F and Smith F B (1983) Atmospheric Diffusion: Study of the Dispersion
of Windborne Material from Industrial and Other Sources, Ellis Horwood
Ltd, Chichester, 437 pp.
Preston-Whyte R A and Tyson P D (1988) The Atmosphere and Weather over
South Africa, Oxford University Press, Cape Town, 374 pp.
SABS (2004) South African National Standards: Ambient air quality – Limits for
common pollutants. Standards South Africa ( a division of SABS). SANS
1929:200x, Edition 1.
Shaw R W and Munn R E (1971) Air Pollution Meteorology, in BM McCormac (Ed),
Introduction to the Scientific Study of Air Pollution, Reidel Publishing
Company, Dordrecht-Holland, 53-96.
Schneider M, Kuhlmann K, Söllenböhmer F (1996) Forschungsinstitut der
Zementindustrie, Düsseldorf, Germany PCDD/F–Emissions from German
Cement Clinker Kilns Organohalogen Compounds, Volume 27.
Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province
References 31-Aug-04167
Schulze B R (1986) Climate of South Africa. Part 8: General Survey, WB 28,
Weather Bureau, Department of Transport, Pretoria, 330 pp.
Schwela D (1998) Health and Air Pollution – A Developing Country’s Perspective,
Paper 1A-1, Papers of the 11th World Clean Air and Environment Congress,
13-18 September 1998, Durban, South Africa.
South African National Standard, 10228:2003
Taylor, C J (1983) Geohydrological investigations in the Lichtenburg Area, Bo-
Molopo Subterranean Water Control Area. Report No GH 3277,
Department of water Affairs and Forestry, Pretoria.
Transportation Research Board (TRB) (U.S.A.) (2000) Highway Capacity Manual.
203p
Travis C.C., Richter S.A., Crouch E.A., Wilson D.E. and Klema A.D. (1987)
Cancer Risk Management, Environmental Science and Technology, 21,
415.
UK (2002) UK Particulate and Heavy Metal Emissions from Industrial Processes.
A Report produced for the Department for Environment, Food & Rural
Affairs, the National Assembly for Wales, The Scottish Executive and the
Department of the Environment in Northern Ireland. AEAT-6270 Issue 2.
United Nations (1993) Handbook for the Montreal Protocol on Substances that
Deplete the Ozone Layer, 3rd Edition
United Nations Environmental Programme (2003) Draft Guidelines on Best
Available Techniques and Best Environmental Practices for Cement Kilns
Firing Hazardous Wastes, UNEP/POPS/EGB.2/INF/8, 23 October 2003.
Website: http://www.eurochlor.org/chlorine/issues/dioxins5.htm. Rotard, 1996
quoted on the Euro Chlor
Website: http://gcisolutions.com/gcitn0596.htm. 1996. DIOXINS - PRIMER AND
COMMENTARY by David L. Constans from GCI Tech Notes
WHO (1997) Environmental Health Criteria 8, Sulphur Oxides and Suspended
Particulate Matter, UNEP and WHO, Geneva.
WHO (2000) Guidelines for Air Quality, World Health Organisation, Geneva.
Wilson, M G C and Anhaeusser, C R (eds.) (1998). The Mineral Resources of
South Africa. Handbook, Council for Geoscience, 16, 740pp.
Zeevalkink J A, (1997) Trace Elements in Cement Products. Institute of
Environmental Sciences, Energy research and Innovation, Netherlands.