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TRANSCRIPT
LİMAK BATI ÇİMENTO SAN. TİC. A.Ş.
TRAKYA CEMENT FACTORY
ENERGY EFFICIENCY AND ENVIRONMENTAL IMPROVEMENT
PROJECT “ENVIRONMENT MANAGEMENT PLAN”
October 2011
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TABLE OF CONTENTS
PART 1. PROJECT DESCRIPTION
1.1. Project Name
1.2. Project Description
1.3. Project Purpose and Justification
1.4. Project Benefits
PART 2. SCHEDULE PART 3. PREVENTION PLAN
PART 4. MONITORING PLAN
1. PROJECT DESCRIPTION:
1.1. Project Name:
Limak Batı Çimento ve San. Tic A.Ş., Trakya Branch, Energy Efficiency and Environmental
Improvement Project
1.2. Information Regarding the Plant Where the Project will be Implemented “Limak Trakya”:
1959 Activity Commencement
1995 EIA Positive Decision (For New Production Line)
2006 The letter from the Ministry of Environment regarding the fact that the validity of the EIA
Positive Decision given in 1995 is still continuing; that after the decision in 1995, white
clinker and cement production had started with 1 rotary kiln, 1 hot water boiler, 1 transformer
unit within the period until 2003; that there are 3 raw mills in the Provincial Directorate
Report
2007 EIA Not Required Decision (Revision at the project for which EIA Positive decision was
obtained in 1995 – based on the 12.11.2007 dated PTD for Line III with 5000 ton/day)
2011 Letter from the Provincial Environment Directorate regarding the fact that the EIA Not
Required Decision of 2007 is still valid including the amendments at the PTD
The Plant obtained an Environmental Permit License on 26.10.2011, valid for 5 years
concerning emission and waste incineration.
Letter from the Municipality is present concerning the fact that there is no objection in
connecting to the sewerage for domestic wastewater.
Since it obtained the Workplace Opening and Operation License before 2008, it is
exempt from Noise Control Permit Certificate as per Article 33/1-e of the Regulation on
the Control of Environmental Noise.
The Trakya Cement Factory started production with the 1st Line Wet System kiln activated in 1959. In
addition to the Wet System kiln with a capacity of 250 t/day, the Dry System kiln with a capacity of
800 t/day was activated in 1975; and with the addition of the pre-calcination system in 1992 to the dry
system kiln having 800 t/day capacity, the daily production was increased to 1800 t/day.
Considering the changing market conditions, Trakya Cement applied for EIA in 1995 for the
establishment of a new production line and EIA positive decision was obtained. In the scope of the
mentioned EIA, environment and milling investments were made. In order to comply with the New
Environmental standards, requirement to increase capacity arose for deactivating the Wet system kiln
with very high calorie consumption. In this context, it was required to revise the Project description
file for which EIA Positive decision had been taken at the application made to the Kırklareli
Governorship Provincial Environment and Forestry Directorate; thus, the project was revised in 2007
and EIA Not Required Decision was taken for the III. Lime investment with 5000 ton/year capacity
(December 2007).
Trakya Cement is located in Kırklareli Province, Pınarhisar District, upper Kırklareli macadam
Location, 105 island at parcels no. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 15 and 1 island at parcels no. 6, 10.
The mention location is morphologically located on a plateau with an elevation varying in the range of
250-500 m, located between the transition part of the Ergene basin in the form of a meadow and
Istranca Mountains. There is no vegetative cover on or nearby the plant site. There are fields at the part
towards the Ergene basin and Istranca forests towards about 10 km to the north.
The closest residential location to the plant site is the Karadağ Quarters located to 200 m east.
Furthermore, Pınarhisar district is present 1 km to the southeast and Kaynarca Township is present 3
km to the northwest. The site is located on the Pınarhisar, Kırklareli – Istanbul macadam. The plant is
located at a distance of 30 km to Edirne Istanbul E-5 highway and TEM motorway.
Located on the Istranca (Yıldız) Mountains and Ergene Meadow sections of Marmara Region,
Kırklareli, is surrounded by Bulgaria in the north, Black Sea in the north east, Istanbul in the south
east, Tekirdağ in the south and Edirne in the west. Its surface area is 6.550 kilometer square. Kırklareli
has a 180 km-long land border with Bulgaria and 60 km-long sea border with the Black Sea. It is at an
elevation of 203 meters above sea level, its north and east is hilly and forested, whereas the other parts
are generally flat fields. Mostly terrestrial climate is dominant in the region. The winters are rough and
with precipitation, whereas the summers are hot and dry.
Its main rivers are Ergene River and Rezve Brook. The vegetal cover is generally forested and with
steppes.
Pınarhisar is located on the former Istanbul Road, at the Lüleburgaz-Kırklareli road junction. The
north sections of the district are shaped with hills and cliffs reaching up to 500-600 meters.
The north section of the district is covered with forests. It is surrounded with Vize District in the east,
Kırklareli province in the west, Lüleburgaz District in the south and Demirköy District in the north.
The district has a surface area of 581 km2 and is at 192 m above sea level.
Mostly wheat and sunflowers are planted in our district and villages thereof. 85% of the arable fields
are planted with wheat and sunflowers. Cabbage, spinach, leek, tomato, pepper, eggplant, green bean
and curly lettuce are grown as vegetable.
Apiculture and undercover vegetable culture course was arranged in 2005 with the cooperation of the
Agriculture Directorate and Public Training Directorate with the participation of 48 farmers. There are
45 greenhouses at the center and villages of our district and high-tunnel undercover culturing is being
made on a field of 14 decares.
At the geological era, Tethys Sea was present at the place of Yıldız Mountains. The sediments at the
bottom of this sea have formed Yıldız Mountains as a result of the former continent cores at the north
and south approaching to each other, curving and elevating above water surface. During the
subsequent mountain formation, continent formation (epeirogenic) and volcanic movements, the
stones and strata forming Yıldız Mountains were compacted, curved and fractured. Since Yıldız
Mountains are a 1st geological era field, they are called “massif”. Massifs are old and tough masses
that have lost the ability to curve. Kırklareli field is mostly formed from core and cover stones of
Yıldız Massif field of the Paleozoic and 4th Mesozoic era and the sedimentary, metamorphic and
magmatic stones of the tertiary era. In line with the extension of the Yıldız Massif, the fault line lying
in the Northwest-Southeast direction extending from Vize to the east of Kırklareli and the intersecting
secondary faults lying in Northeast-Southwest direction form the tectonic structure of the site. The
fault between Kırklareli and Vize affecting the Yıldız Massif is a normal fault. The secondary fault
system has caused the Black Sea coast to be with indentations and projections (Iğneada-Limanköy).
The reef-like limestones of Kırklareli Formation are at medium hardness, with abundant melting gaps,
karstic, porous, articulated and multi-fractured and bear a well-aquifer character. At the unit over the
impermeable levels, the base has graveled sandstone, sandstone, sand and towards the top there are
limestone and sandstone stripped mams. The segments containing clayey levels do not have
underground water. And the sandy section at the formation base and in between, have a low quantity
of groundwater due to insufficient in-feed.
Meteorological State
Kırklareli province located at the Trakya section of Marmara Region experiences Kırklareli climate
varying among the locations. Terrestrial climate is dominant at Kırklareli center. Black Sea climate is
observed at the north-overlooking sectors of the Yıldız Mountains. Accordingly the winters are cool
and cold. At the inland sections away from the sea, terrestrial climate is observed. The summers are
hot; winters are cold and occasionally snowy.
Seismic State
According to the Turkish Earthquake Zones prepared by the Turkish Ministry of Public Works and
Settlement and put into force with the 18.04.1996 dated and 96/8109 referenced decision of the
Cabinet; Pınarhisar District that contains the project site and project area is located on a 4th Degree
Earthquake Zone.
Flora-Fauna
The project site is located in Kırklareli Province, Pınarhisar District, upper Kırklareli macadam
Location. An abundance of plants from Dry Forest Group can be seen at the south hills of the Yıldız
Mountains of Kırklareli and Ergene Basin. The vegetal cover and variety is rich in Kırklareli Region.
Among these natural plants there is oak, hornbeam, red pine, torch pine, ashen and rare elms,
cranberry, blackthorns, wild pears, maple trees and cade juniper from lemur species. Ligneous plants
such as torch pine and red pine have been included to the vegetal cover foresting line of Kırklareli.
Bushes (forest remnants) can be observed at the high elevations of Ergene Basin called as plateau.
However, most part of Ergene Plain is steppes. The plain is devoid of the forested area called as
ligneous plants.
Flora
When the project site’s flora zones are considered, they are classified as European-Siberia Phyto-
geographical Zone type. This phyto-geographical zone covers the Black Sea Region where the Black
Sea climate is effective and the sites of Marmara Region other than the Gallipoli and Biga peninsulas.
The south border of the region forms the hills of the mountain ranges facing north lying roughly in the
east-west direction at the Black Sea and Marmara regions. However in this zone, the tectonic channels
and basins between the hills of the mountains facing south and the mountains create separate media. If
considered in terms of the grid system of P. H. Davis (Flora of Turkey and The East Aegean Islands),
it is located at the A–1 square.
In order to determine the flora of the project location and surroundings, relevant literature survey has
been made and inventory tables have been prepared containing the habitats of the detected flora
elements, their phyto-geographic regions, relative abundance, endemism state and national and
international protection states. As a result of these studies, 55 plant species have been determined that
are present or potentially present at the site. 7 of these species are Mediterranean elements, 11 are
European-Siberian elements, 1 is an East Mediterranean element and 36 are cosmopolite species and
the ones whose phyto-geographic region is unknown.
No plant species have been encountered in the activity site placed under protection in the scope of
Annex-I of the Europe Wild Life and Habitat Preservation Contract (Bern Treaty). In order to
determine the endemic and endangered species among the ones stated above, the publication called
“Red Data Book of Turkish Plants (Turkish Nature Protection Association and Van 100. Yıl
University, 2000)” and the web site http://bioces.tubitak.gov.tr prepared by Tubitak was scanned and
no plant species were found that are endangered.
Fauna
As is known, the Vertebrate Animals fauna is gathered under 4 big classes. These are Amphibians,
Reptiles, Birds and Mammals. The regional fauna has been prepared by scanning the relevant
literature in the scope of the environmental impact studies for the project site and near surroundings.
In order to determine the species placed under protection among the ones stated below, Turkish
Environmental Legislation, Europe Wild Life and Habitat Preservation Contract (Bern Treaty) and
annexes thereof, “Turkey Birds Red List” (Species List in Red Data Book) prepared by Kiziroğlu
(1989) and Demirsoy (2002) “General Zoogeography and Turkish Zoogeography” was examined. As
a result of these studies, inventory tables have been prepared containing fauna elements detected at the
site, their habitats, population intensities, and national and international protection states. The threat
level and the relevant protection status was determined as per the Annex lists of Bern Treaty (Annex-2:
definitely protected fauna species, Annex-3: protected fauna species) and the ERL (European Red List)
and Red Data Book prepared by IUCN (International Union for Conservation of Nature and Natural
Resources).
Besides all these, for the Bird, Reptile and Mammal species, the “2007-2008 Period Central Gaming
Commission Decisions” Annex-I (Wild Animals Placed Under Protection by the Ministry of
Environment and Forestry), Annex-II (Game Animals Placed Under Protection by the Central Gaming
Commission), Annex-III (Game Animals Permitted to be Hunted at the Times Specified by the Central
Gaming Commission) lists put into force by the Turkish Ministry of Environment and Forestry Nature
Protection and National Parks General Directorate by being published at the 06.07.2007 dated and
26574 numbered Official Gazette were entered to the relevant tables. The wild animals at Annex-I list
have been placed under protection by the Ministry of Environment and Forestry as per the first
paragraph of the 4th article of the Terrestrial Hunting Law no. 4915. Hunting the wild animals in this
list, keeping them dead or alive and transporting them are forbidden. The birds and mammals at
Annex-II list have been placed under protection by the Central Gaming Commission as per the
authority granted under the first paragraph of the 4th article of the Terrestrial Hunting Law no. 4915.
Hunting the game animals in this list, keeping them dead or alive and transporting them are forbidden.
The game animals at Annex-III list are the game animals permitted by the Central Gaming
Commission to be hunted at the periods stated in the 2007-2008 hunting period determined by the
Ministry of Environment and Forestry as per the first paragraph of the 4th article of the Terrestrial
Hunting Law no. 4915. As a result of the studies made, no endemic species was encountered at the
project site or surroundings. Furthermore there are no sensitive areas present for the fauna types with
the purpose of propagation, food seeking, staying for winter, nesting and migration.
Birds
Among the 29 bird species possible to be present at the activity site due to habitat conformity, 16 are
present at Bern Annex–2, and 7 are present at Bern Annex–3 list. According to the recent lists
reflecting the “2007-2008 Period Central Gaming Commission Decisions” put into force by the
Turkish Ministry of Environment and Forestry Nature Protection and National Parks General
Directorate by being published at the 06.07.2007 dated and 26574 numbered Official Gazette; 18 bird
species are under Annex-I (Wild Animals Placed Under Protection by the Ministry of Environment
and Forestry), 4 are under Annex-II (Game Animals Placed Under Protection by the Central Gaming
Commission), and 7 are under Annex-III (Game Animals Permitted to be Hunted at the Times
Specified by the Central Gaming Commission) list.
1.2. Project Description:
Limak Batı Çimento San. Tic. A.S. Trakya Cement Factory, located within the boundaries of
Kırklareli province, has totally 790.000 ton/year clinker capacity with the wet system rotary kiln,
which is active since 1958, and the first generation pre-calcined type rotary kiln, that has been
activated in the subsequent years. The plant contains 3 low-capacity raw mills, one being sludge, one
being with ball bearing and the last being vertical type. The plant is able to produce 956.000 tons of
cement with 3 low-capacity ball-bearing cement mill in total (2 open and 1 closed systems). Most of
the transport lines of the plant are open and has a closed clinker stock hall with limited capacity. The
electrification and cabling lines and conduits have used up their usable lifetime, automated viewing
and monitoring systems are realized with partial and old technology. The dedusting units of the plant
are active in a very distributed, inefficient and high power-consumption fashion with continuous new
additions within the period from 1958 until today. The pressurized air requirement of the plant is
supplied with many inefficient compressors distributed to the overall factory.
The Trakya Cement Factory has been taken under the structure of Limak Group on March 2011 and
the operation, quality, energy and environment improvement projects were immediately given a head
start. The leading innovations of the last 15 years of the cement sector in terms of energy efficiency
and environmental improvements are pre-calcined rotary kiln, vertical cement mills and next
generation clinker cooling units. Again the discovery that the cement rotary kilns are perfect natural
cleaners to be used for waste disposal enabled the sector to orient towards design and development
activities aimed at alternative fuel utilization. All these innovations, marking the sector in terms of
energy efficiency and environmental improvements, will take place in the project of Limak Trakya
Factory with its latest, state-of-the-art versions.
The main investment targets can be summarized under the following main headings;
1. Instead of 5 ball-bearing mills and 1 low-capacity vertical mill with open system operating at
the raw material and cement lines with high power consumption and even causing inefficiency
in terms of quality, the installation of 2 next generation vertical mills with low power
consumption.
2. The 1958 model wet system clinker line of the plant, that is environmentally inefficient, being
inactivated and dismounted.
3. Redesigning of the towers of the plant to provide low pressure loss, high efficiency and to
attain 95% calcination level at the pre-calcined rotary kiln currently having an old-generation
tower with low efficiency, high pressure loss, high heat consumption and that can only attain
80% calcination degree.
4. The plant’s new towers being resigned as to maximize alternative fuel utilization, as one of the
main targets to reduce CO2 emission and fossil fuel use; this condition being included to the
contract.
5. At the new investment period of the plant, combustion burners being used that have high
combustion efficiency, high momentum, low NOx and low primary air consumption.
6. The new towers of the plant being designed such that low NOx emission and minimum dust
emission values are warranted under the contract. NOx emission is taking place as a main
heading at the contracts. The NOx legal limit of the plant is currently at 1300 mg/Nm3 and
actually the system operates at values around 1100 mg/Nm3. After the investment, reducer
sections shall be designed at the tower and the plant’s operation at maximum 500 mg/Nm3
NOx value (without the use of any chemical substance) shall be warranted under the contract.
Limak is meeting a higher investment price for this design.
7. The Rotary kiln hood and cooler to be replaced with their next generation versions at high
efficiency, The inlet and outlet sealing systems of the rotary kiln to be replaced with new
design versions minimizing the leaking air, thereby obtaining peak improvements at thermal
consumption and power consumption.
8. The pneumatic transfer lines with high power consumption being replaced with mechanical
type designs with new elevator and low power consumption,
9. The rotary kiln input raw homogenization systems being upgraded to their versions with high
efficiency, lowering their standard deviations and obtaining improvements at quality and
power consumption.
10. Replacing all the raw material, raw and coal weighing systems with their next generation
versions operating at high accuracy (0,5%), obtaining high quality, operation stability and low
emission values, especially attaining complete combustion and zero CO objective at the
Rotary kiln.
11. All the material transport lines being designed as closed gallery type,
12. Building a closed clinker stock hall with 55.000 ton-capacity.
13. Rehabilitating the Rotary kiln-Raw and Cooler Main Filters and ensuring that there is no dust
emitter at the plant exceeding a dust emission of 30 mg/Nm3. (Table 1)
14. All the emission points such as the new cement mill’s next generation system filter, mill
feeding line, bunkers, closed clinker stock hall inlet and outlet to be equipped with next
generation bag filters. (Table 1)
15. The existing filters of the plant being modernized as to perform shaking-out according to
pressure difference as it is at the next generation filters and thereby both minimizing and
optimizing dust emission and power consumption.
16. The electrification and automation structure of the whole system be renewed in order to
minimize, monitor and communicate the line losses; The Energy Monitoring (Scada) System
being activated for the whole plant after the investment.
In the scope of the project, it is foreseen that totally 350 persons will work at the field
preparation and construction works, and 145 persons will work during the operation phase,
and the needs of the employees shall be met from the existing plants/facilities.
1.3. Project Aim and Justification:
The investment to be made at the Trakya plant, that had been serving the region since 1958, shall
transform the plant to an exemplary, next generation plant at international standards in terms of energy,
environmental aspects and technology. The main justifications to make an investment at this plant
operating for 53 years are as follows;
It has become obsolete as compared to the next generation cement factories in terms of power
and fuel consumption,
The existing system cannot respond to the low emission values that can be attained in the
sector with next generation technologies,
Many equipment in the plant have used up their lifetime in mechanical and electrical terms,
The existing plant is not capable of combusting alternative fuels and fuels with low volatility,
The plant does not have any quality and energy efficiency infrastructure, and a system that
cannot be monitored cannot be developed.
The plant losing its competitive edge against the next generation plants.
1.4. Project Benefits:
1.4.1 Emission Limit Values and Target Values for the Plant
Pollutant Limit Values
until
31.12.2012
C (mg/Nm3)*
Limit Values
after
31.12.2012
C
(mg/Nm3)**
IFC
Guideline
Values
C (mg/Nm3)
Values
Measured on
04.08.2011
C (mg/Nm3)
2013 Target
Values after
Investment
C (mg/Nm3)
Total dust 43 30 50 15,05 <10
HCI 26,5 10 10 < 0,75 < 0,75
HF 4,3 1 1 < 0,28 < 0,28
NOx (in terms
of NO2)
1108 800 600 664,54 <500
Cd + Tl 0,091 0,05 0,05 0,0153 0,0153
Hg 0,091 0,05 0,05 0,0028 0,0028
Sb + As + Pb
+ Cr + Co +
Cu + Mn + Ni
+ V
0,91 0,5 0,5 0,1015 0,1015
SO2 256 50 400 ND*** ND***
TOC **** 249 10 10 16,98 16,98
Dioxin -
Furan
0,1 0,1 0,1 0,0126 0,0126
*: Limit Values until 31.12.2012 are the limit values determined based on the trial incineration report by the
Ministry of Environment at waste intake after GFB during the Environmental Permit License process.
**: Limit Values after 31.12.2012 are the limit values indicated at the Waste Incineration Regulation.
***ND: Not Detected
****TOC limit value is defined as the difference between the measured values when the waste is incinerated and
not incinerated. TOC measurement has not been made at the Trakya Factory before waste incineration.
1.4.2. Dust Emissions – Bag Filter Investment and Modernizations – Other Improvements
The existing filtration system operating at the Rotary kiln Unit is comprised of the 2 parallel-
operating Electro-filters present at the system origin and the bag filter later added in series;
and this system is causing an additional 9 kWh/ton clinker energy consumption while ensuring
a dust emission below 30 mg/Nm3. After the investment, the bag filter of the system will be
designed compliant to the capacity, the electro-filters that have used up their lifetime will be
inactivated , and thereby the same dust emission will be attained with 7,2 million kWh /year
lesser energy consumption.
The Rotary kiln Cooling Electro-filter system shall be modernized and optimized. With the
new cooling unit to be installed together with the investment, the cooling exhaust gas amount
shall reduce by 0,5 Nm3/kg clinker and the power consumption of the mentioned filter shall
decrease in the same rate.
Many old generation filters operating at the 3 cement mills of the plant shall be omitted
together with their units; a next generation system filter at the new cement mill unit shall
ensure a high dust collection efficiency (0-10 mg/Nm3) at low energy consumption.
All the conveyor lines feeding the raw material and semi-finished product mills of the plant
shall be designed as closed and equipped with dust-removing systems. Furthermore, all of
these lines shall operate with an automation system and the dedusting systems shall be
designed as an interlock system for the operation of the unit.
Table 1. The Plant filters to be renewed, omitted and rehabilitated at the Trakya Factory
NAME OF RESOURCE DUST EMISSION
(mg/Nm3)
DUST EMISSION
(mg/Nm3)
BEFORE INVESTMENT AFTER INVESTMENT
1 ROTARY KILN I 58,000 0,000
2 ROTARY KILN II 72,600 0-30
3 COOLING I 13,000 0,000
4 COOLING II 3,600 0-10
14 KILN RAW WEIGHING BUNKER FILTER 7.4 0-10
10 CLINKER TRANSPORT LINE FILTER 4.9 0-10
5 COAL MILL II 34,210 34,210
6 COAL MILL II 17,380 17,380
7 CEMENT MILL I 20 0,000
8 CEMENT MILL II 4.9 0,000
9 CEMENT MILL III 22.8 0,000
x NEW CEMENT MILL 0,000 0-10
10 COOLER CLINKER TRANSFER LINE
FILTER
49 0-10
11 RAW HOM. SILO 1 12.3 0-10
12 RAW HOM. SILO 2 10.5 0-10
13 RAW HOM. SILO 3 11.2 0-10
15 COAL TRANSFER FULLER 4.2 0,000
16 IHI COAL FEEDER LINE FILTER 20.7 20.7
18 CEMENT MILL NO. 3 FEEDER BELTS
FILTER
3.2 0,000
19 CEMENT MILL NO.3 STATIC SEPARATOR
FILTER
7.7 0,000
x2 NEW CEMENT MILL SYSTEM FILTER 0-10
x3 NEW CEMENT MILL FEEDER GROUP
FILTER
0-10
x4 NEW CEMENT MILL BUNKER FILTER 0-10
x5 CLOSED CLINKER STOCK HALL
DOWNSTREAM OUTLET FILTER
0-10
x6 CLOSED CLINKER STOCK HALL UPSTREAM
FILTER
0-10
x7 CEMENT MILL TRANSPORT LINE FILTER 0-10
a Filters to be Inactivated
b Filters to be Rehabilitated/Modernized
c Filters to be Maintained/Serviced
d Filters to be Added after Investment
A closed clinker stock hall shall be built at the plant with 55.000 ton capacity, operating at full
automation. The investment amount of this unit, being a completely environmental investment,
is 2 million Euros. The clinkers exiting the rotary kiln cooling unit shall be transferred to the
closed clinker stock hall through a folly closed conveyor with filtration system whereas the
transport of the clinker to the cement mill unit shall be realized with conveyors structured
inside underground closed galleries, equipped with automation and cameras.
After the system investments of the plant are completed, the interim connection roads shall be
laid with concrete, landscaping and afforesting activities shall be conducted.
1.4.3 NOx Emissions
Trakya Factory Rotary kiln Investment is a system
designed under the main heading of “Low NOx”. In the
rotary kiln systems, NOx can be decreased in two
manners:
1) Ammonia or urea pulverization to the system at the
Pre-heater Tower (SNCR system) 2) With the design of
the pre-heater system.
At the Trakya Factory Investment, the increase in the
investment cost shall be faced to assure 500 mg/Nm3
NOx emission with a tower design having Low-NOx
structure. The plant shall have the ability to further
reduce the low emission values with SNCR.
In the present state, the NOx emission of the system is
at 1100 mg/Nm3. After the new investment, the plant
will be easily able to keep the NOx emission value below 500 mg/Nm3 with the new L- NOx Calciner
and L- NOx burners and the use of high nitrogen containing coal (volatile matter ratio in domestic coal
~40%).
1.4.4 CO2 Emission
Among the main fields where the Trakya project will provide best environmental improvement, the
primary field will be CO2 emission reduction.
Figure 1. Obtaining low NOx emission
with In Line Calciner
The 962 kcal/kg clinker heat consumption of the plant shall be reduced to 750 kcal/kg clinker level
after the investment, thereby fossil fuel consumption is reduced from 143 kg fuel/ton clinker level to
112 kg fuel/ton clinker level when considered on the basis of same type of fuel utilization. The
reduction in the coal consumption, when pre- and post-investment state is considered, will be 24.312
ton/year without taking into account alternative fuel use. In this case, the 60.156 ton/year reduction
shall be obtained in the emission of fuel consumption based CO2.
The Rotary kiln of the Plant shall be design such that it will permit the use of alternative fuel at
minimum 50% of the total fuel amount. The factory is located at a distance of 70 km to Çorlu, being
one of the biggest industrial centers of Turkey, thereby it shall possess the technology to dispose both
residential and industrial wastes and also to use it as alternative fuel. The most frequent waste types in
the region are treatment sludge, bleaching soil and waste tires. When the plant attains an alternative
fuel rate at 25% thermal rate with the regional treatment sludge, 8.500 ton/year reduction shall be
obtained in the emission of fuel consumption based CO2.
With the vertical mill investments of the plant, 40% improvement shall be obtained at the emission of
power consumption based CO2 at the milling process. The plant’s current full capacity annual power
consumption at 122,6 million kWh shall be reduced to 86,9 million kWh after the investment, and the
reduction in CO2 emission brought about by this improvement in power consumption shall be
24.258 ton/year.
Table 2. CO2 emission reduction – consolidated
No CO2 Emission Reduction Source Improvement
Amount ton CO2/year
1 With Fossil Fuel Consumption Reduction 60.156
2 With Utilization of Alternative Fuel at 25% of the Thermal
Power
8.500
3 With Power Consumption Reduction 24.258
TOTAL 92.914
1.4.5 Project Benefits
With this project:
20,5% energy saving shall be obtained for the whole factory.
The main stack NOx emission of the plant shall be reduced by 300 mg/Nm3 without the use of
any chemical additional input.
All the dedusting units of the plant shall be modernized by considering power consumption
optimization.
The fossil fuel consumption shall reduce by 24.312 ton/year (by neglecting the consumption
of alternative fuel)
When alternative fuel utilization attains its 25% target, the reduction in the fossil fuel
consumption will be 50.000 ton/year in total.
The total power consumption of the plant shall be reduced by 35,7 million kWh/year.
It is aimed that the CO2 emission of the plant shall be reduced by approximately 92.914
ton/year. This equals to an improvement of 29,19% in the CO2 emission of the plant.
1.4.6 The Process of Introducing the Nearby Public to the Energy Efficiency and Environmental
Improvement Project:
1- For the Public Participation Meeting to be held of 26.10.2011, ANNEX-1 Meeting Call
Minutes was made signed by the Camii Kebir Town Mukhtar (the town that our factory is
located in) on 10.10.2011 and the notice was hung at the Mukhtar’s Office until 24.10.2011.
2- Public Participation Meeting was held on 26.10.2011 at the factory meeting hall and the
Introduction Presentation was shown at the meeting.
3- The questions of the participants and the responses given at the end of the meeting are present
at ANNEX-2 Minutes.
4- The meeting participants were recorded with ANNEX-3 Attendance Minutes.
5- The Introductory Presentation given at the meeting was hung at the Mukhtar’s Office on
26.10.2011 as ANNEX-4 Notice Minutes after the approval of the Camii Kebir Town Mukhtar.
MINUTES OF INVITATION TO MEETING
In order to realize mutual opinion and information exchange on the possible impacts of the
Energy Efficiency and Environmental Improvement Project planned to be realized in your region, a
meeting shall be held, with the participation of the project owner company, on 26.10.2011, at the
address of Camii Kebir Mahallesi, Kırklareli Caddesi, Pınarhisar – KIRKLARELİ, by Limak Batı
Çimento Sanayi ve Ticaret A.Ş. Trakya Branch in the factory meeting hall. All the regional public is
invited to the meeting. We hope that maximum due care shall be paid in participation to the meeting
and we hereby announce this meeting to our community respectfully.
This invitation has been hung up as to be announced at the billboards of Camii Kebir Town
Mukhtar’s Office as to stay on the billboards until 24.10.2011. 10/10/2011
Official Authority Company
Camii Kebir Town Mukhtar’s Office Limak Batı Çimento Sanayi ve Ticaret A.Ş.
Trakya Branch
// seal, stamp, signature // // signatures //
A copy of the minutes has been hung up at the billboard of the mukhtar’s office on 10.10.2011.
SUBJECTS DISCUSSED AT PUBLIC PARTICIPATION MEETING
Place of Meeting: Local Club Meeting Hall
Date of meeting: 26/10/2011
Meeting no: 2011/01
SUBJECTS DISCUSSED
Question Name Response
1 Will new filters be built with the new investments? Yahya ALACA
Dere Town Mukhtar
Our existing quantity of stacks and filters will increase with the new investments.
Our mill quantity will be changed to 2. The filters will be modernized.
2 Will your capacity increase? Vehbi AŞUT
Cooperative Head
Since the 2 kiln capacity present will be met with single kiln, there will be no
capacity increase. Kiln no. 1 with high energy consumption shall be inactivated.
3 Will there be energy savings with the new investments? Ömer Faruk KARALAN
District Agric. Dir.
The aim of the new investments are energy saving and cost reducing
investments, thereby there will be high energy saving.
4 Will you consider to contribute by afforesting trees suitable
in the scope of honey apiculture development just life the
afforesting studies you had made before at Kaynarca mine?
Ali Osman ÇALIK
Honey Producers Union Head
It will be considered provided that you can provide us information concerning
your works.
5 Will there be noise increase at the factory with these new
investments?
Şerafettin ÖZCAN
Town Mukhtar’s Office
Member
Our 4 … mills will be changed as 2 … vertical mills. Therefore, the noise caused
by the mills will decrease.
6 Will the importance placed on Work health and safety be
continued as before?
H. İbrahim YILMAZ
Civil Engineer
It will definitely be continued by increasing.
7 The satisfaction was expressed regarding the fact that these
investments would be very beneficial to provide energy
reduction.
Yekta AKKUŞ
Agriculture Engineer
8 They stated that they were expecting this and similar
investment news and that this investment and energy saving
is very satisfactory.
Yahya ALACA
Dere Town Mukhtar
Ali Osman ÇALIK
Honey Producers Union Head
9
10
11
12
13
14
15
16
17
18
19
20
1
PUBLIC PARTICIPATION MEETING MINUTES
In order to provide information and obtain the opinion of the public on the possible impacts on
the public and environment of the Energy Efficiency and Environmental Improvement Project planned
to be realized within the boundaries of Kırklareli Province Pınarhisar District, Camii Kebir Town,
Kırklareli Street location by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch, a meeting
was held, on 26.10.2011, at 1:00, at the address of Camii Kebir Mahallesi, Kırklareli Caddesi,
Pınarhisar – KIRKLARELİ, by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch.
ATTENDANTS OF THE MEETING
* If the meeting attendants are more than the space provided in the table below, an additional table can
be prepared.
No Name Surname Contact Telephone Signature
1 Ziya Mert Police Chief 02886151386 // signature //
2 Hasan İbrahim Yılmaz Civil eng. 02886151386 // signature //
3 Serhad Günsoy … 02886154449 // signature //
4 Şahin … … // signature //
5 Ali Osman Çalık … // signature //
6 Mehmet Pehlivanoğlu … // signature //
7 Yahya Alaca Dere town Mukhtar … // signature //
8 Şerafettin Özcan Camikebir town … // signature //
9 … Savcı Camikebir town … // signature //
10 Memduh Ürek Camikebir town … // signature //
11 … Cooperative Head // signature //
12 Ömer Faruk Naralan … // signature //
13 Yelda Akkuş P.hisar District Agr. Eng. // signature //
14 Hülya Buluş P.hisar District … // signature //
15 Atanur Sarıkaya P.hisar district … // signature //
16 Deniz Ulaş Karatoprak … // signature //
17 M. Ertan Kocakerim Limak … // signature //
18 Ahmet Müfit Tekin Limak Trakya … // signature //
Official Authority Company
Camii Kebir Town Mukhtar’s Office Limak Batı Çimento Sanayi ve Ticaret A.Ş.
Trakya Branch
// seal, stamp, signature // // signatures //
ANNEX: MEETING MINUTES
Explanation of the project by the Company
Questions and Answers
2
PUBLIC PARTICIPATION MEETING MINUTES
In order to provide information and obtain the opinion of the public on the possible impacts on
the public and environment of the Energy Efficiency and Environmental Improvement Project planned
to be realized within the boundaries of Kırklareli Province Pınarhisar District, Camii Kebir Town,
Kırklareli Street location by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch, a meeting
was held, on 26.10.2011, at 1:00, at the address of Camii Kebir Mahallesi, Kırklareli Caddesi,
Pınarhisar – KIRKLARELİ, by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch.
ATTENDANTS OF THE MEETING
* If the meeting attendants are more than the space provided in the table below, an additional table can
be prepared.
No Name Surname Contact Telephone Signature
19 M. Ferman Ulaş Limak Trakya General Manager // signature //
20 Alp Engin Limak Raw Mat. Dir. // signature //
21 Barış Bademci WHS and Env. … // signature //
22 Y. Özdel Bingöl Limak Trakya Admin. Dir. // signature //
23
24
25
26
27
28
29
30
31
32
33
34
35
36
Official Authority Company
Camii Kebir Town Mukhtar’s Office Limak Batı Çimento Sanayi ve Ticaret A.Ş.
Trakya Branch
// seal, stamp, signature // // signatures //
ANNEX: MEETING MINUTES
Explanation of the project by the Company
Questions and Answers
BILLBOARD MINUTES FOR
THE ENVIRONMENTAL MANAGEMENT PLAN / EIA / PROJECT DESCRIPTION FILE
In order to provide project-related information to the regional community, the Environmental
Management Plan / EIA / Project Description File prepared for the Energy Efficiency and
Environmental Improvement Project to be performed by Limak Batı Çimento Sanayi ve Ticaret A.Ş.
Trakya Branch has been hung at the billboard of Camii Kebir Town Mukhtar’s Office as to stay there
until the end of the project.
This minutes has been prepared in order to determine the fact that the Environmental
Management Plan / EIA / Project Description File has been hung up for presentation. 26/10/2011
Official Authority Company
Camii Kebir Town Mukhtar’s Office Limak Batı Çimento Sanayi ve Ticaret A.Ş.
Trakya Branch
// seal, stamp, signature // // signatures //
2. SCHEDULE
Application Schedule:
The Trakya Energy and Environmental Improvement Project shall be realized with many domestic and
foreign contractors. The target for the mentioned project is the signing of the contracts before the end
of 2011 and the completion of the project within maximum 14 months. The project design shall be
realized as to preserve all the construction and mechanical assembly works (other than the cooling
unit), the existing production and sales volumes of the plant. After the completion of all these studies,
Clinker line shall be halted, and the period foreseen to complete the cooling unit and the new interim
connections is 45 days. The plant shall continue the cement production and sales with the stock clinker.
The general layout plan prepared for the mentioned project is given below (Figure 2)
Accordingly at the energy efficiency and environmental improvement project of the plant, there will
be no halting at any unit other than the last 45-day period of the 14-month project duration; therefore,
the areas where new units are no be built and modifications are to be made aere the areas completely
open and on which there is no unit equipment installation (Figure 2).
There will be 6 main construction sites at the mentioned investment and at these structures to be built
on open areas, the amounts of excavation caused by the foundation are stated at the following table.
The excavation material taking out of the foundation areas shall be taken to the mine site, the required
amounts shall be used as filling material and the remaining shall be utilized in the process as raw
material.
TABLE FOR THE EXCAVATION AND FILLING AMOUNTS
No Name of Unit Excavation (m3) Filling (m
3)
1 Pre-heater Building 1.000 400
2 Raw mill 1.900 915
3 Raw material bunker 1.240 605
4 Cement mill 1.340 580
5 Mill bunkers 1.450 650
6 Clinker stock hall 9.500 3.400
16.430 6.550
The only new unit to take place at the same location as the plant is the cooling unit during that 45-day
halting period. The mentioned until shall be built at 0 elevation and the old dismantled unit shall be
processed as metal scrap.
After the plant commences operation with next generation equipment, all the pipe connections and
filter cases that cannot be made impermeable shall again be processed as scrap metal.
As a result, the wastes to occur during the Trakya Cement Factory investment from the dismantling of
unusable mechanical parts and old bag-filters are listed as follows:
1. Metal Scrap
2. Filter bags
Among these wastes, scrap metal is defined as “17 04 07: Mixed Metals” at Annex-4 Waste List of the
Regulation of the General Fundamentals of Waste Management put into force by being published on
05.07.2008;
And the filter bags are defined as “15 02 02: Absorbers, filter materials (oil filters if not identified
under other items), cleaning cloths, protective clothing polluted with hazardous material” as per the
same legislation.
The filter bags with code no. 15 02 02, shall be incinerated at the rotary kiln of our factory in the scope
of the 26.10.2011 dated Environmental Permit License (certificate no. 72) annexed herewith, and
thereby energy recovery shall be obtained.
Scrap metal with code no. 17 04 07, shall be sent to collection-separation and recycling plants or
directly melting plants as per the Communiqué of 17.06.2011 on the Recycling of Some Non-
Hazardous Wastes (The 05.12.2011 dated letter of the Ministry of Environment and City Planning is
attached. According to this latter, the scrap metal can be sent to the collection-separation and recycling
plants or directly melting plants without seeking any license condition until 1/1/2015).
The closed areas of the plant cover the ball bearing milling circuits to be omitted. The mentioned
equipment do not meet the next generation cement sector needs, therefore they will be put on sales for
the utilization of other sectors. After the mentioned equipment are put on sales, the closed areas shall
be designed as depots, workshop and similar purposes of use.
2
3. PREVENTION PLAN
Phase Topic Mitigating Measures Responsibility
Construction Phase
Positioning of the work
sites and the
infrastructural services
for the worker camps
The worksite and worker camps are located within the boundaries of the Trakya Cement
Factory and outside the forested areas.
Positioning:
(a) At least 3 km away from any protection zone
(b) 50 m away from any surface water and
(c) 1 km away from any village. There is no region around the plant with cultural
properties.
Services
(a) Utilization water and drinking water shall be provided from the network of the
Trakya Cement Factory
(b) The residential type wastewaters shall be disposed of by transferring to the existing
sewerage system of the Trakya Cement Factory,
(c) The organic solid wastes at the camps shall be collected in closed-lid trash bins and
periodically taken by the Pınarhisar Municipality.
The site built as the worksite shall be improved in compliance to its original state after
the completion of the work.
Trakya Cement Factory
Solid waste
management of the
construction (sand,
stone, etc.)
There is no expropriated area inside the project site.
No incineration will be made.
The excavation wastes shall not be carried outside the work site, some of it shall be used as
ground filling within the plant and the residual part will be used as alternative raw meal
Landscaping activity shall be performed with the completion of the construction.
Trakya Cement Factory
Contractor
Exhaust emissions of
the construction
machinery
The exhaust emissions of the construction machinery shall be measured regularly by
authorized institutions and their compliance to the limit values defined for exhaust emissions
shall be certified.
The machines shall not be left open if they will not be used for more than 5 minutes; the idle
operation of the engines shall be minimized.
Trakya Cement Factory
Contractor
3
Phase Topic Mitigating Measures Responsibility
Construction Phase
Storage of construction
machinery
The Storage area will be located within the Trakya Cement Factory. It will be positioned
minimum 50 meters away surface waters, it will be far from villages and other residential
areas.
The equipment shall be placed on impermeable surface, thereby soil pollution from oil leaks
shall be prevented.
Trakya Cement Factory
Noise The noise level will not exceed 70 dB limit.
No blasting shall be made.
Trakya Cement Factory
Dust For minimum dusting the following precautions shall be taken; loading and unloading at the
mission source will be made without scattering, leveling shall be made, the top-side of the
vehicles shall be covered during material transport and the top part of the material shall be
kept at 10% moisture.
The present roads and construction area shall be watered at dry and windy weather.
Trakya Cement Factory
Worker Safety The Trakya Cement Factory is certified for OHSAS 18001 Work Health and Safety
Management. It has received with WHS Performance Award for 2009 granted as a result of
the evaluation of the WHS applications of the member factories by the Cement Industry
Employers Syndicate.
As per the legislation regulating work life, the contractor personnel shall pass health scan
before starting to work and they shall be employed with “report evidencing that the person
can work at heavy and dangerous works” in the scope of the applications at the Trakya
Cement Factory. Health checks shall be made periodically.
Helmet, work boots, ear protectors, masks and other personal protective equipment shall be
provided and used by the workers as necessary.
Trakya Cement Factory
Contractor Company
Present roads Traffic mobility shall be minimized at the existing roads.
The roads present at the project site shall be watered regularly with street sprinklers.
Tonnage control shall be made at the transport vehicles, they will be prevented from
carrying over-load and damaging the present roads.
The damaged roads shall be repaired before the damage becomes permanent.
Mud, remnants and other obstructions shall not be left on the roads.
Trakya Cement Factory
4
Phase Topic Mitigating Measures Responsibility
Construction Phase
Positioning and
construction of the
transport roads
The existing roads are sufficient for transport, new roads shall not be constructed. -----
Routing and
construction of the
transmission lines
A new transmission line shall not be built, but the existing lines shall be modernized. There
will be no need to perform work on the transmission lines outside the factory site.
Trakya Cement Factory
The possibility of
presence of cultural
works, areas and
structures with local
cultural value
All the works shall be realized within the factory site. There is no cultural formation at or
near the factory site. However, if any historical, cultural or archeological asset is
encountered during excavation works, the excavations shall be halted and the local/regional
culture directorates shall be immediately informed. No one shall take out the findings or
damage this area. After the examinations of the construction authorities are completed and
written approval is obtained from the related administrations, The excavation can be
continued.
No transmission network, connection road or structure passes over village cemeteries.
Trakya Cement Factory
Provision of raw
material
Raw materials to be used in the scope of the project, such as sand, stone, etc. shall be
obtained from licensed raw material sites. The concrete to be used shall be obtained from the
concrete power plants of our company.
Trakya Cement Factory
Management of
hazardous materials
(fuels, oils, explosives)
No explosives shall be used. The storage of the oils and fuels will not be necessary during
the construction works. The fuels of the vehicles to be used during the project shall be
obtained from private – independent liquid fuel stations outside the factory site.
The equipment oils / grease to be used during operation shall be kept at well-ventilated,
locked and surrounded buildings on impermeable surfaces. These buildings shall be located
at minimum 50 m away from any surface water. It is located outside residential areas and
forested fields.
Trakya Cement Factory
Management of scrap
metals
Scrap metals shall be kept in the factory site and shall be given to recycling according to
Announcement of Recycling of Some Nonhazardous Wastes
Trakya Cement Factory
Forest loss The area used in the scope of the project is within the limits of the Trakya Cement Factory.
There will be no tree cutting for the project. No afforesting is present on the site.
Trakya Cement Factory
Noise Silencer equipment shall be used to prevent any noise to occur during the project, during and
after the works of activating the equipment. The main equipment to be used in the project
shall be manufactured as per international standards. The noise level shall be below 70 dB.
Trakya Cement Factory
Construction Phase
Dust / Air emissions O2, CO, NOx and SOx and dust amount in the stack gas shall be continuously measured in
order to determine the emission from the combustion system after the project is activated,
and shall be digitally recorded at the automatic computer system. The emission limit values
Trakya Cement Factory
5
Phase Topic Mitigating Measures Responsibility
permitted at the Regulation on the Control of Industrial-Based Air Pollution and Waste
Incineration Regulation.
Construction Phase
Medical wastes Medical wastes shall be collected separately from other wastes and delivered to the medical
waste collection vehicle of Pınarhisar Municipality.
Trakya Cement Factory
Construction Phase
Hazardous wastes The hazardous wastes shall be collected separately according to their waste codes,
accumulated at the waste depot site and kept at the hazardous waste depot site for maximum
180 days , provided that the amount does not exceed 1000 kg/month, and then given to the
licensed recycling /disposal plants. The hazardous wastes in the scope of waste incineration
permit given to the factory shall be incinerated at the rotary kiln.
Trakya Cement Factory
Operation Phase
Residential and
operation wastewaters
Residential type of wastewaters shall be disposed of by giving to the existing sewerage
system of the Trakya Cement Factory. There will be no operation-based wastewater. The
cooling waters are used as closed circuit recirculation.
Trakya Cement Factory
Residential solid
wastes
The residential solid wastes shall be collected inside closed-lid trash bins, and then
periodically gathered by the Pınarhisar Municipality.
Trakya Cement Factory
Operation Phase
Noise Periodical noise measurements shall be made at the plant and it shall be ensured that the
noise level stay within legal limits; when the noise level exceeds the legal limits, necessary
precautions shall be taken such as isolation, provision of personal protective equipment, etc.
Trakya Cement Factory
Operation Phase Medical wastes Medical wastes shall be collected separately from other wastes and delivered to the medical
waste collection vehicle of Pınarhisar Municipality.
Trakya Cement Factory
Operation Phase Hazardous wastes The hazardous wastes shall be collected separately according to their waste codes,
accumulated at the waste depot site and kept at the hazardous waste depot site for maximum
180 days , provided that the amount does not exceed 1000 kg/month, and then given to the
licensed recycling /disposal plants. The hazardous wastes in the scope of waste incineration
permit given to the factory shall be incinerated at the rotary kiln.
Trakya Cement Factory
6
4. MONITORING PLAN
Phase / Topic Which parameters will be
monitored?
Where will this parameter be
monitored?
How will this parameter be
monitored / what is the
monitoring equipment?
When will this parameter be
monitored / What is the
monitoring frequency?
Responsibility
Construction
Positioning of the
infrastructural
services for the
work sites and
worker camps
Place of the work site
Agreements related to water
supply, residential wastewater
and residential solid waste
Has the camp site been
suitable improved?
At the work site
Water supply area, sewerage
and solid waste storage areas
At the work site
Visual At quarterly periods, or more
frequently if any
nonconforming application is
observed
At the end of construction
operation
Trakya Cement
Factory
Management of the
construction solid
wastes (sand, stone,
packaging wastes,
etc.)
Recycling and disposal
applications for the packaging
wastes
Reuse and disposal
applications for the
excavation wastes
Packaging waste storage or
disposal area
Excavations storage area
Visual At monthly periods, or more
frequently if any
nonconforming application is
observed
Every day during excavation
works
Trakya Cement
Factory
Exhaust emissions
of the construction
machinery
Emission measurement
records as per Turkish laws
Equipment not been used in
idle mode
At the entrance of the project
site
At the construction site
Visual Once when the equipment are
taken to the construction site
At monthly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Storage of the
construction
machinery
Is the depot site away from
residential areas and surface
waters?
Has the equipment been
placed on an impermeable
surface?
Equipment storage area Visual Once before site preparation Trakya Cement
Factory
7
Phase / Topic Which parameters will be
monitored?
Where will this parameter be
monitored?
How will this parameter be
monitored / what is the
monitoring equipment?
When will this parameter be
monitored / What is the
monitoring frequency?
Responsibility
Noise Construction hours Construction site Noise measurement device At monthly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Dust Is water sprinkling being
performed regularly and
suitably?
Construction site and existing
connection roads
Visual At hot, dry and windy
weather
Trakya Cement
Factory
Management of
Scrap Metals
Is the storage area
surrounded?
Are precautions taken to
prevent accidents?
Scrap metal storage site Visual examination of the the
site
Weekly during operation, or
more frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Worker Safety Has an acceptable health
scanning been established?
Are the workers provided
with personal protective
equipment?
At the working areas of the
workers
Visual (together with a copy
of the health report)
Before any physical worker
activity starts
Daily
Trakya Cement
Factory
Contractor
Company
Existing roads Status, cleanliness Within the Trakya Cement
Factory site and 3 km
connection roads
Site visit / visual Daily Trakya Cement
Factory
Positioning and
construction of
transport roads
----- ----- ----- ----- -----
The possibility of
presence of cultural
works, areas and
Works of art being uncovered
during excavation
At any excavation site
Have the authorities been
notified and correct procedure
been applied?
During construction
Trakya Cement
Factory
8
Phase / Topic Which parameters will be
monitored?
Where will this parameter be
monitored?
How will this parameter be
monitored / what is the
monitoring equipment?
When will this parameter be
monitored / What is the
monitoring frequency?
Responsibility
structures with
local cultural value
The presence of any area,
building or cemetery with
local value
At any excavation site
Visual examination of the
plans, site visit
Before construction
Provision of raw
materials
The validity of the operation
license of the supplier
At the project site entrance of
the supplier’s office
Visually checking the
operation license
Before signing any agreement
for the provision of raw
materials
Trakya Cement
Factory
Contractor
Company
Management of
hazardous
substances (fuels,
oils, explosives,
etc.)
Are the landfill sites locked,
surrounded, well-ventilated
and on impermeable surface?
Is its location away from the
residential areas?
Hazardous waste storage site Visual examination of the
building and the site
Weekly during operation, or
more frequently if any
nonconforming application is
observed
Before starting constructiom
Trakya Cement
Factory
Operation
Noise Noise levels
Have noise preventing
measures been taken?
On all the project site
Nearly residential areas
(especially where complaints
are received)
Noise measurement device
Visual
At semi-annual periods, or
more frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Dust / Air
emissions
O2, CO, NOx and SOx and
dust at the stack gas
At the rotary kiln incineration
stack
At the computers digitally
recording the stack gas
analysis
Continuous Trakya Cement
Factory
Residential
wastewaters
Are the residential
wastewaters being discharged
to the sewerage system
finalizing with treatment?
At the existing sewerage
system of the Trakya Cement
Factory
Visual At quarterly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory
9
Phase / Topic Which parameters will be
monitored?
Where will this parameter be
monitored?
How will this parameter be
monitored / what is the
monitoring equipment?
When will this parameter be
monitored / What is the
monitoring frequency?
Responsibility
Residential solid
waste
Are the wastes regularly and
suitable stored?
Project site trash bins Visual At weekly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Medical Wastes Are they being collected
separately from other wastes?
Workplace health unit
medical waste box
Visual At weekly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory
Hazardous Wastes Are they being collected
separately from other wastes?
Project site hazardous waste
storage areas
Visual At weekly periods, or more
frequently if any
nonconforming application is
observed
Trakya Cement
Factory