Compiled by. Bohlweki Environmental (Pty) Ltd PO Box Vorna Valley MIDRAND In association with the following specialists

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2 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) Ltd PO Box Vorna Valley MIDRAND 1686 In association with the following specialists Dr D Baldwin and Ms M Chettle Environmental & Chemical Consultants Mr F Joubert Sustainable Law Solutions Ms N Wattel and Mr A van den Heever Stewart Scott International Dr L Burger and Ms R Thomas Airshed Planning Professionals Dr R Meyer CSIR (Environmentek)

3 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, wastederived 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 Motivation for the Proposed Project The process of cement manufacture is energy intensive. The average energy required to produce tons of cement clinker is approximately 130 tons of coal. As a result, Holcim South Africa currently requires approximately 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 Executive Summary i

4 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 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 tons per day) included the installation of a low NO x -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/Nm 3. 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 Executive Summary ii

5 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 m 2 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 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, Executive Summary iii

6 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 wastederived 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 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 Executive Summary iv

7 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 Executive Summary v

8 and environmentally sound method of resource recovery for many types of hazardous and non-hazardous wastes ( 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 ( 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 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 (SO 2 ), oxides of nitrogen (NO x ), 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 Executive Summary vi

9 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 ( 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 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 Executive Summary vii

10 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 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 wastederived 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, Executive Summary viii

11 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 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 Executive Summary ix

12 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 ( 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 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: Executive Summary x

13 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 Executive Summary xi

14 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 pretreatment) 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 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; 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 Executive Summary xii

15 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 and tons of coal/annum is estimated by Holcim for Kiln 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 accredited operation, the EMP would be required to form part of the independently audited ISO programme. Executive Summary xiii

16 TABLE OF CONTENTS EXECUTIVE SUMMARY TABLE OF CONTENTS LIST OF TABLES LIST OF FIGURES LIST OF PHOTOGRAPHS ACRONYMS AND ABBREVIATIONS PAGE i xiv xx xxiii xxiv xxv 1. INTRODUCTION Motivation for the Proposed Project Overview of the existing Dudfield Plant and the proposed 2 AFR Programme Overview of Dudfield Plant and Kiln Infrastructure requirements for the proposed AFR 3 programme Waste-derived Materials which can be utilised as 5 Alternative Fuels 1.3. Environmental Study Requirements 6 2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS Approach to Undertaking the Study Authority Consultation Consultation with Decision-making Authorities Consultation with Other Relevant Authorities (non- 8 DEAT) 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 Exemption from Undertaking an 8 Environmental Scoping Study in terms of Section 21 of the Environment Conservation Act (no 73 of 1989) 2.5. Environmental Impact Assessment Specialist Studies Assumptions and Limitations of the Study Overview of the Public Participation Process undertaken 10 within the EIA Process Review of the Draft Environmental Impact Assessment 14 Report Final Environmental Impact Assessment Report DESCRIPTION OF THE EXISTING DUDFIELD PLANT AND THE SURROUNDING ENVIRONMENT 15 Table of Contents xiv

17 3.1. The Existing Dudfield Plant and Kiln Climate Regional Climate Rainfall Temperature Evaporation Wind Data Topography Geology Soils Surrounding Land Use and Surface Infrastructure Flora Fauna Surface Water Geohydrological Conditions Water Consumption at the Dudfield Plant Air Quality Noise Visual Aspects and Aesthetics Sites of Archaeological, Cultural or Historical Interest Regional Socio-economic Structure Population Density Major Economic Activity and Sources of Employment DESCRIPTION OF THE CEMENT MANUFACTURING 33 PROCESS 4.1. Cement Manufacturing Process at Dudfield Plant Preparation of Raw Materials Process inside the Kiln After the Kiln Environmental Aspects of Cement Manufacture Raw Materials Emissions to Air Energy Use of Alternative Fuels in the Cement Manufacture 38 Process How AFR can be utilised in the Kiln Waste Products utilised as Alternative Fuel Sources ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE INTRODUCTION OF THE ALTERNATIVE FUELS AND RESOURCES PROJECT AT DUDFIELD PLANT 5.1. Potential Impacts on Land Use, Vegetation and Heritage Sites in the area surrounding the Dudfield plant Table of Contents xv

18 Conclusions and Recommended Management Options Potential Impacts Associated with the establishment of a 45 Fuel Storage Area within the Boundaries of the Dudfield Plant Conclusions and Recommended Management Options Potential Impacts on Water Resources Sources of risk to the groundwater and surface water 48 environment from the AFR project Conclusions and Recommended Management Options Potential Impacts on Air Quality Conclusions Recommendations Potential Traffic Impacts Condition of Roads outside Lichtenburg Condition of Roads within Lichtenburg Existing Traffic Structural Capacity Analysis Assessment of Potential Impacts Conclusions and Recommendations Potential Impacts on the Social Environment Methodology Formation of Attitudes and Perceptions Disruption in Daily Living and Movement Patterns Impact on Infrastructure and Community Infrastructure 68 Needs Health and Safety Impacts Local Impacts and Regional Benefits Intrusion Impacts Assessment of the Suitability of Waste as an Alternative 71 Fuel Resource Risks and Significance of Risks Recommendation on the determination of suitable AFR Conclusion ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY Introduction Terms of Reference Methodological Overview Baseline Study Local Wind Field Impact Assessment at Holcim-Dudfield Under Current 85 Operating Conditions 6.5. Environmental Legislation and Air Quality Guidelines 86 Table of Contents xvi

19 Ambient Air Quality Standards and/or Guidelines for 86 Criteria Pollutants Effect Screening Levels and Health Risk Criteria of Non- 88 Criteria Pollutants Dioxins and Furans Cancer Risk Factors Permit Specifications Emission Limits Process Description and Emissions Inventory Studies on Emissions from Cement Kilns Utilising 95 Alternative Fuels Limitations of the Given Source Inventory Emission Inventory for Proposed Usage of Alternative 98 Fuels and Resources at Dudfield Plant Emission Estimation Comparison of Simulated Emissions to Permit 100 Specifications 6.7. Dispersion Simulation Methodology And Data 100 Requirements Meteorological Requirements Receptor Grid Source Data Requirements Building Downwash Requirements Atmospheric Dispersion Results and Discussion Results of Criteria Pollutants Results for Non-Criteria Pollutants: Potential for 106 Environmental and Non-Carcinogenic Health Effects Results for Non-Criteria Pollutants: Potential for 106 Carcinogenic Effect 6.9. Significance Rating Description of Aspects and Impacts Conclusion and Recommendations Recommendations Air Quality Management System Emissions Inventory Development and Maintenance Source Monitoring Ambient Air Quality Monitoring Mitigation Strategy Design, Implementation and 118 Evaluation Record Keeping and Environmental Reporting Consultation 120 Table of Contents xvii

20 7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN 121 ALTERNATIVE FUEL RESOURCE 7.1. Introduction AFR Specifications Types of Alternate Fuels and Resources Physical and Chemical Characteristics of AFR Summary of Acceptable Waste in terms of SANS Waste and AFR Standards / Specifications Acceptable Limits for Elements in AFR Environmental Fate of the Elements AFR Management Procedures Risks and Significance of Risks Recommendation on the determination of suitable AFR Typical Wastes Excluded for use as Alternative Fuels Typical Wastes Accepted for use as Alternative Fuels Loading, supply, storage and management of Alternative 145 Fuels 7.7. Proposed Monitoring, Control and Mitigation Measures Environmental Monitoring Programme Initial Acceptance Procedure Control Transport Procedure Control Final Acceptance Procedure Control Compliance Auditing Development of Site Specific Specifications Conclusion CONCLUSIONS AND RECOMMENDATIONS Evaluation of the Proposed Project Impacts Associated with Emissions to Air from the Plant Impacts Associated with the Transportation of AFR to 154 Dudfield Plant Impacts Associated with the Storage of AFR on Site for a 154 Limited Period Impacts on the Social Environment Suitability of Waste as an Alternative Fuel Resource Project Benefits Conclusions Permit Requirements associated with the Introduction of an AFR Programme at Dudfield Plant REFERENCES 163 Table of Contents xviii

21 APPENDICES Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Appendix F: Appendix G: Appendix H: Appendix I: Appendix J: Appendix K: Application for Exemption from Undertaking an Environmental Scoping Study for the Alpha Alternative Fuels and Resources Project Advertisements placed in Regional and Local Newspapers I&AP Database Briefing Paper Minutes of Meetings held with I&APs during the EIA Process Issues Trail Letter from SAHRA Air Quality Specialist Report AFR Management Procedures Environmental Legislation Relevant to the Proposed Alternative Fuels and Resources Project, Dudfield Response from Holcim South Africa Regarding the Use of Hazardous Waste as a Fuel in Cement Kilns Table of Contents xix

22 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 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 27 (12 February 2004, Reference /381) Table 3.5: Stack parameters for the Dudfield plant under current 28 routine operating conditions Table 3.6: Emission rates for criteria and VOC pollutants from the 29 stacks at the Dudfield plant under current routine operating conditions Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 29 for routine operating conditions Table 3.8: Comparison of measured PM10, NO 2 and SO 2 emissions to 30 permit specifications 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 42 traditional fuels 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 46 establishment of a fuel storage area within the boundaries of the Dudfield plant Table 5.3: Summary of potential impacts on the water environment 51 associated with the introduction of the AFR programme Table 5.4: Summary of potential impacts on air quality associated 51 with Dudfield plant Table 5.5: Existing (2004) 12-hour traffic counts 60 Table 5.6: Assessment of potential traffic impacts associated with the 64 introduction of AFR at Dudfield plant Table 5.7: Summary of potential impacts on the social environment as 72 a result of the introduction of an AFR programme at Dudfield plant Table 5.8: Potential Significance of Risks associated with the use of 76 AFR posed by Natural Events, Technical Problems and Human Error Table 6.1: Current DEAT NO x guidelines 87 Table 6.2: Air quality standards for nitrogen dioxide (NO 2 ) 87 Table 6.3: Air quality standards for inhalable particulates (PM10) 87 List of Tables xx

23 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 90 substances included in the investigation Table 6.7: Toxicity equivalency factors for dioxins and furans 92 Table 6.8: Unit risk factors from the US-EPA Integrated Risk 93 Information System (IRIS) (as at July 2003) and WHO risk factors (2000) Table 6.9: Permit specifications for stack PM10 emissions 94 Table 6.10: Comparison of EC emission limit values for emissions from 94 co-incineration of waste in cement kilns (Directive 2000/76/EC) and DEAT class 1 incinerator Table 6.11: International emissions data for cement production 97 emissions of dioxins Table 6.12: Stack parameters for the Dudfield Plant for proposed usage 98 of alternative fuels Table 6.13: Emission rates for criteria pollutants from the stacks at the 99 Dudfield Plant for proposed usage of alternative fuels Table 6.14: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 99 for proposed usage of alternative fuels (a) Table 6.15: Halogen Compound Emissions from Kiln 3 for proposed 99 usage of alternative fuels (a) Table 6.16: Maximum offsite concentrations (measured in µg/m³) at 104 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) Table 6.17: Maximum offsite concentrations (measured in µg/m³) at 107 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) Table 6.18: Predicted maximum annual average concentrations of 109 various carcinogens due to proposed usage of alternative fuels at the Dudfield Plant and resultant cancer risks (assuming maximum exposed individuals) Table 6.19: Significance rating from the baseline study (a) (for all 111 pollutants of concern) Table 6.20: Significance rating from the proposed usage of alternative 111 fuel (for all pollutants of concern) 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 List of Tables xxi

24 Table 7.3: Properties of fuel that can potentially affect product 133 quality, plant operation, health and safety and environment Table 7.4: AFR Specifications and range of acceptable limits of 134 elements (including heavy metals) Table 7.5: Typical Concentrations of Selected Trace Elements in Raw 136 Materials and Coal (mg/kg) Table 7.6: Potential Significance of Risks associated with the use of 141 AFR posed by Natural Events, Technical Problems and Human Error Table 7.7: Minimum Background Monitoring Parameters 146 Table 8.1: Summary of the most relevant permits, licences, 160 certificates and other authorisations required by Holcim South Africa for the introduction of an AFR programme at Dudfield List of Tables xxii

25 LIST OF FIGURES PAGE Figure 1.1: Drawing of the area north of Kiln 3 illustrating the 4 position of area demarcated for the proposed AFR storage area Figure 1.2: Photograph of the area north of Kiln 3 illustrating the 4 position of area demarcated for the proposed AFR storage area in relation to Kiln 3. Figure 3.1: Location of Holcim South Africa Dudfield plant near 15 Lichtenburg Figure 3.2: Wind roses for the period January 1996 to August Figure 3.3: Geology around Lichtenburg (extract of 1: Geological map 2626 West Rand, Geological Survey of South Africa, 1986) Figure 3.4: Water flow/balance diagram for Dudfield plant for July (Holcim, 2004) Figure 4.1: Schematic representation of the cement manufacture 34 process from sourcing the raw materials to delivery of the final product (Source: Cement Industry Federation, 2002) Figure 4.2: Primary components of Kiln 3 (Holcim, 2004) 36 Figure 4.3: Graphic representation of the three locations where 41 waste-derived fuels can be introduced to Kiln 3 (Holcim, 2004) Figure 5.1: Photograph of the area north of Kiln 3 illustrating the 47 position of area demarcated for the proposed AFR storage area in relation to Kiln 3 Figure 5.2: Routes currently utilised to access Dudfield plant 56 Figure 5.3: Recommended routes for the transportation of AFR to 57 Dudfield plant Figure 6.1: Wind roses for the period January 1996 to August Figure 6.2: Schematic diagram illustrating air quality management 116 plan development, implementation and review by industrial and mining operations List of Figures xxiii

26 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 28 installed at Dudfiled in 2002 Photograph 4.1: Multi-channel burner, illustrating the multiple channels 40 where various fuel lines can be coupled for feeding alternative fuels into the kiln Photograph 4.2: Burner head illustrating the concentric tubes through 40 which fuel and air is fed into the kiln Photograph 5.1: Pavement damage at the intersection of Road 52 and 55 D933 Photograph 5.2: Pothole in a section of Kapsteel Road (D933) 55 Photograph 5.3: Pumping in a section of Road D Photograph 5.4: Pavement defects at intersection of Road D2095 and 58 D933 Photograph 5.5: Structure Failure on Road P183/1 59 List of Photographs xxiv

27 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 pascal I&APs Interested and affected parties IBCs Intermediate Bulk Containers ISCST3 Industrial Source Complex Short Term model (Version 3) kpa Kilo pascal LD 50 LPG MAP MJ/kg MRLs MSD MSDS Lethal dose of a chemical required to kill 50% of a population of experimental mammals and fish Liquefied petroleum gas Mean annual precipitation Mega Joules per kilogram Minimal Risk Levels Mass selective detector Material Safety Data Sheet NEMA National Environmental Management Act (No 107 of 1998) ng Nanograms NO 2 Nitrogen dioxide NO x 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 dibenzodioxins PCDFs Polychlorinated dibenzofurans ph Acidity PPE Personal Protective Equipment Acronyms and Abbreviations xxv

28 PM10 PM2.5 ppm RDF SA SABS SAHRA SANS SO 2 TIS TOC Tremcard TSP µg/m³ US-EPA VOCs WB WHO WMD Particulate Matter with an aerodynamic diameter of less than 10 µm Particulate Matter with an aerodynamic diameter of less than 2.5 µm Parts per million Refuse derived fuel South Africa South African Bureau of Standards South African Heritage Resources Agency South African National Standard Sulphur dioxide Traffic Impact Study Total Organic Carbon Transport Emergency Card Total Suspended Particulates Micrograms per cubic meter United States Environmental Protection Agency Volatile Organic Compounds World Bank World Health Organisation Waste Manifest Document Acronyms and Abbreviations xxvi

29 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, wastederived 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, fossilbased 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 Motivation for the Proposed Project The process of cement manufacture is energy intensive. The average energy required to produce tons of cement clinker is approximately 130 tons of coal. As a result, Holcim South Africa currently requires approximately 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 Introduction 1

30 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 Overview of the existing Dudfield Plant and the proposed AFR Programme 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 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 tons per day) included the installation of a low NO x -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/Nm 3. 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. Introduction 2

31 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 m 2 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. Introduction 3

32 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. Introduction 4

33 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 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 wastederived 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 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 Introduction 5

34 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 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. Introduction 6

35 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 Authority Consultation 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. Scope of Environmental Investigations 7

36 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 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 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 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 Scope of Environmental Investigations 8

37 be undertaken. This application for exemption, as well as NW DACE s approval of this exemption application is included within Appendix A 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 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 Airshed Planning Professionals Environmental & Chemical Consultants CSIR Environmentek Sustainable Law Solutions Field of Study 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 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; Scope of Environmental Investigations 9

38 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 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 Overview of the Public Participation Process undertaken within the EIA Process The primary aims of the public participation process included: Scope of Environmental Investigations 10

39 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 Scope of Environmental Investigations 11

40 a comprehensive database of I&APs. This database was updated on an ongoing 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 Scope of Environmental Investigations 12

41 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 Scope of Environmental Investigations 13

42 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) 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 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) 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. Scope of Environmental Investigations 14

43 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 Kiln 2 will continue to operate should the market so require, and plans to upgrade this kiln are currently being considered for the future. Description of the existing Dudfield Plant and the Surrounding Environment 15

44 Dudfield Kiln 3 (Photograph 3.1) was commissioned in 1977 at an original design capacity of tons per day. Through the implementation of various improvement initiatives to the plant, this capacity was increased to tons per day, and more recently to a continuous clinker production rate of 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/Nm 3. 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/nm 3. Upgrade of the kiln burner through the installation of a low NO x -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. Description of the existing Dudfield Plant and the Surrounding Environment 16

45 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 Climate 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 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 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 (mm) Month Ave January 94,0 141, ,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 0,8 July ,0 0 1,2 Description of the existing Dudfield Plant and the Surrounding Environment 17

46 Month Ave August ,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, , 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 37 o C can be experienced, with this maximum being exceeded on occasion. Temperatures of -3 o C and occasionally lower can be experienced at Dudfield in the winter months 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 mm and mm per annum, while the mean annual runoff is between 5 mm and 10 mm (Midgley, 1994a; Midgley, 1994b) 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. Description of the existing Dudfield Plant and the Surrounding Environment 18

47 Figure 3.2: Wind roses for the period January 1996 to August 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 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. Description of the existing Dudfield Plant and the Surrounding Environment 19

48 3.4. Geology The most recent regional geological mapping of the area around Lichtenburg and the Dudfield Plant is captured on the 1: 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 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. Description of the existing Dudfield Plant and the Surrounding Environment 20

49 Figure 3.3: Geology around Lichtenburg (extract of 1: 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 Description of the existing Dudfield Plant and the Surrounding Environment 21

50 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 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 Description of the existing Dudfield Plant and the Surrounding Environment 22

51 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) 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 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 Description of the existing Dudfield Plant and the Surrounding Environment 23

52 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 Geohydrological Conditions The regional geohydrological conditions in the area are displayed on the 1: 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: hydrogeological map between 2 and 5 Mm 3 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. Description of the existing Dudfield Plant and the Surrounding Environment 24

53 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 CaCO 3 ) 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 < > 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 m 3 of water is pumped monthly to supply the entire water requirements of the Dudfield plant. Of this, about m 3 /month is supplied to the operating kilns. Figure 3.4 provides the water flow/balance diagram for Dudfield plant for July Description of the existing Dudfield Plant and the Surrounding Environment 25

54 Figure 3.4: Water flow/balance diagram for Dudfield plant for July 2004 (Holcim, 2004) Description of the existing Dudfield Plant and the Surrounding Environment 26

55 Process water supply is limited to use by the conditioning towers, where preheater 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 /381) Element/ Parameter (Units) Raw water Treated water (Sagte Riveira borehole Water Huis 32) Dam ph Electrical Conductivity (EC) (ms/m) Turbidity (NTU) Chloride (Cl) (Mg/l) Magnesium (Mg) (Mg/l) Nitrate (NO 3 as N) (Mg/l) Nitrite (NO 2 ) (Mg/l) < <0.01 Ortho Phosphate (o-po 4 ) (mg/l P) <0.1 <0.01 <0.1 Sodium (Na) (Mg/l) Sulphate (SO 4 ) (Mg/l) <20 <20 47 Calcium (Ca) (Mg/l) Total Hardness (TH) (mg/l CaCO 3 ) 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 (SO 2 ), oxides of nitrogen (NO x ), 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. SO 2, N0, NO 2, C0, H 2 O, HCl, NH 3, O 2 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. Description of the existing Dudfield Plant and the Surrounding Environment 27

56 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 Exit Velocity ( C) (m/s) Kiln Cement Mill Cement Mill Description of the existing Dudfield Plant and the Surrounding Environment 28

57 Table 3.6: Emission rates for criteria and VOC pollutants from the stacks at the Dudfield plant under current routine operating conditions Source Averaging Emissions measured in (g/s) Period PM10 CO NO x SO 2 Benzene Xylene Hourly (c) Kiln 3 (a) Daily Average Hourly Cement Mill 1 Daily (b) Average Hourly Cement Mill 2 Daily (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 31 st May 2004 at 06h00. Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 for routine operating conditions Compound Emission (g/s) Highest Hourly Highest Daily Average Beryllium 1.2E E E-08 Vanadium 8.0E E E-05 Chromium 1.3E E E-05 Manganese 4.0E E E-04 Cobalt 4.0E E E-05 Nickel 1.6E E E-05 Copper 6.0E E E-05 Arsenic 2.0E E E-05 Silver 1.2E E E-06 Cadmium (b) 1.5E E E-05 Tin (a) 2.0E E E-04 Antimony 1.0E E E-06 Barium 3.6E E E-05 Mercury (b) 2.0E E E-05 Thallium 3.0E E E-04 Lead 5.0E E E-05 Dioxin Toxic Equivalence (b) 7.0E E E-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. Description of the existing Dudfield Plant and the Surrounding Environment 29

58 Table 3.8 provides a comparison between PM10, SO 2 and NO 2 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, SO 2 and NO 2 emissions do not exceed permit specifications. Table 3.8: Comparison of measured PM10, NO 2 and SO 2 emissions to permit specifications Emissions (mg/nm³) % Exceeded Appliance SO 2 NO 2 PM10 Permit Provided Permit Provided Permit Provided SO 2 NO 2 PM10 Kiln N/E N/E N/E Cement Mill N/E Cement Mill N/E N/E: Not exceeding 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, L r, 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 Evening Nighttime Rural Suburban with little road traffic Urban Urban with some workshops, with business premises & main roads Central business Industrial Description of the existing Dudfield Plant and the Surrounding Environment 30

59 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 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 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 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 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. Description of the existing Dudfield Plant and the Surrounding Environment 31

60 Population density for Lichtenburg and surrounding areas is approximately 9 883, and 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 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. Description of the existing Dudfield Plant and the Surrounding Environment 32

61 4. OVERVIEW OF THE CEMENT MANUFACTURING PROCESS The basic chemistry of the cement manufacturing process begins with the decomposition of calcium carbonate (CaCO 3 ) at approximately 900 C to leave calcium oxide (CaO, lime) and gaseous carbon dioxide (CO 2 ). This process is known as calcination. This is followed by the clinkering process, in which the calcium oxide reacts at high temperature (typically 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 Cement Manufacturing Process at Dudfield Plant Dudfield Kiln 3 has a current production rate of 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/Nm 3. 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 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. Cement Manufacturing Process 33

62 Raw Materials 1 Raw Materials Limestone is the main raw material for cement manufacture, and is mined from adjacent quarries. Other necessary elements such as iron, alumina and silica are sourced from additional raw materials. 2 - Transport Raw materials are transported to the plant via conveyor, road or rail. 3 Transport of fuel Fuel required to achieve and maintain temperatures in the kiln are transported to the plant (via rail or road). 4 - Homogenising Raw materials are homogenised in preparation for raw milling. Clinker Production 5 Raw Mill Precise proportions of the raw materials are blended and milled to a fine powder ( raw meal ) in the raw mill. 6 Bag Filter Bag filters remove particulates from kiln and mill exhaust gases. 7 Pre-heater Raw materials are heated to ~900 C in counterflow heat exchange resulting in the decarbonisation of calcim carbonate in the raw meal. 8 the Kiln Raw materials are further heated to 1450 C in the rotary kiln. At this temperature, raw materials are transformed into Clinker. Clinker production requires high temperatures which are generated by the combustion of fuel. The use of wastederived alternative fuels is being is proposed to replace a percentage of fossil fuel (coal) used. Cement grinding and distribution 9 Grate Cooler Clinker is discharged from the kiln at ~1000 C and transferred to the grate cooler. Clinker is rapidly cooled to ensure the desired mineralogy is formed in the final product. Heat recovered from the kiln and the cooler is recycled in the process to reduce fuel requirements. 10 Clinker Silo Cooled clinker is stored on the clinker silo Cement Mill Clinker, with the addition of gypsum and extenders, is ground in a ball mill to a fine powder to produce the final cement product. 12 Storage Silos The cement is conveyed to large, vertical storage silos. Cement is conveyed to loading stations in the plant or directly to transport vehicles for delivery of the final cement products in bags or in bulk. 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) Cement Manufacturing Process 34

63 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 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 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 After the Kiln Clinker is discharged at a temperature of about 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. Overview of the Cement Manufacturing Process 35

64 Figure 4.2: Primary components of Kiln 3 (Holcim, 2004) Overview of the Cement Manufacturing Process 36

65 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 Environmental Aspects of Cement Manufacture 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) 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 (CO 2 ) from the calcination and combustion processes, water vapour, and excess oxygen. The exit gases also contain small quantities of dust, chlorides, fluorides, sulphur dioxides, NO x, 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 SO 2, N0, NO 2, C0, H 2 O, 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 NH 3. Twelve heavy metals, as well as dioxins and furans are measured for on an annual basis. Overview of the Cement Manufacturing Process 37

66 Energy In the South African cement industry, the primary fuel used for energy is coal, a fossil fuel. The average energy requirement to produce tons of cement clinker is approximately 130 tons of coal. Holcim South Africa requires approximately 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 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 Overview of the Cement Manufacturing Process 38

67 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 NO x -multichannel primary burner). The multi-channel burner allows for multiple energy sources to be introduced into the kiln, which allows for fuel versatility 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 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 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. Overview of the Cement Manufacturing Process 39

68 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 Overview of the Cement Manufacturing Process 40

69 Figure 4.3: Graphic representation of the three locations where waste-derived fuels can be introduced to Kiln 3 (Holcim, 2004) Overview of the Cement Manufacturing Process 41

70 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 type Calorific value (MJ/kg) Pure polyethylene 46 Light oil 42 Heavy oil 40 Pure polystyrene 40 High Grade By-products of tar 38 Pure rubber 36 Anthracite 34 Waste oils Scrap tyres Coal Pot liners 20 Paint sludge 19 Medium Grade Dried paint 18 Dried wood / sawdust 16 Rice husks 16 Cardboard / paper 15 Low Grade Dried sewage sludge 10 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 C Long residence time, i.e. in excess of 4 seconds Overview of the Cement Manufacturing Process 42

71 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 C in the gas from the burners from the precalciner) (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. Overview of the Cement Manufacturing Process 43

72 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 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 Assessment of Potential Impacts 44

73 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 m 2 in size, where fuels could be offloaded, 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) 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) 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 m 2 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 Assessment of Potential Impacts 45

74 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 programme Impacts on land use in the area surrounding the Dudfield plant Impacts on vegetation in the area surrounding the Dudfield plant Impacts on heritage sites in the area surrounding the Dudfield plant Extent Duration Severity Significance Likelihood Localised Long-term Slight None Very unlikely to occur Localised Permanent Slight None Very unlikely to occur Localised Permanent Severe None Very unlikely to occur Confidence in assessment of impact High High High Mitigation measures Not applicable Current vegetation maintenance practises must be continued. 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 Confidence Mitigation measures with the introduction of the in Extent Duration Severity Significance Likelihood assessment AFR programme of impact 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 Impacts on groundwater and soil as a result of the storage of AFR Localised Long-term None None Very unlikely to occur Localised Long-term Severe High Very unlikely to occur High High Not applicable Storage areas must be constructed according to national engineering standards & specifications required by the National & Provincial Government Departments Assessment of Potential Impacts 46

75 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. Assessment of Potential Impacts 47

76 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 Potential Impacts on Water Resources 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 Assessment of Potential Impacts 48

77 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 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 Assessment of Potential Impacts 49

78 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) 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 (CO 2 ) 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 (NO x ), 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. Assessment of Potential Impacts 50

79 Table 5.3: Nature of impact associated with the introduction of an AFR programme Availability of water resources in the area Quality of process water for cooling purposes Off-loading, storage and handling of AFR material Summary of potential impacts on the water environment associated with the introduction of the AFR programme Extent Duration Severity Significance Likelihood Regional Long-term Slight None Localised Short-term Slight None Localised Long-term Slight Low Very unlikely to occur Very unlikely to occur Unlikely to occur Confidence in assessment of impact High High High Mitigation and/or Enhancement Not applicable Not applicable 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 Degree of Nature of Impact Extent Duration Severity Significance Likelihood 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 Long term Localised Slight (b) Low (b) May occur (c) Probable alternative fuel (for all pollutants of concern) 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. Assessment of Potential Impacts 51

80 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 NO 2 (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. NO 2 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. NO x 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/m³ 1, 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 98 th percentile the predicted hourly value is 20 µg/m³. The predicted 50 µg/m³ was predicted from a peak incident during the monitoring campaign. Assessment of Potential Impacts 53

81 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 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 NO x emission instead of NO 2. Previous measurements at Dudfield Plant indicated approximately 1% NO 2 of NO x. This fraction may however be as high as 10%. If the NO 2 emissions were allowed at the EC limit for NO x, the guidelines of NO 2 would be exceeded. It is, therefore, recommended that both NO 2 and NO x 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. Assessment of Potential Impacts 54

82 Identify and quantify all fugitive, diffuse and evaporative sources of emissions 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 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. Assessment of Potential Impacts 55

83 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) Assessment of Potential Impacts 56

84 Figure 5.3: Routes currently utilised to access Dudfield plant Assessment of Potential Impacts 57

85 Figure 5.4: Recommended routes for the transportation of AFR to Dudfield plant Assessment of Potential Impacts 58

86 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 Assessment of Potential Impacts 59

87 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/ 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. Assessment of Potential Impacts 60

88 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 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 Heavy Vehicles Total Vehicles Percentage Heavy Vehicles 38% 38% 16% 19% 32% 18% Assessment of Potential Impacts 61

89 According to the Highway Capacity Manual, roads utilised as routes to access the Dudfield plant operate at a maximum traffic volume of cars per hour per direction, or 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 ( 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 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 Assessment of Potential Impacts 62

90 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 to 1 million E80s over a period of 20 years. Converted back linearly to a daily loading, this corresponds with 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 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 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 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 Assessment of Potential Impacts 63

91 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 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 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. Assessment of Potential Impacts 64

92 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 Growth in Traffic Volume D933 Localised Long Term Slight Low Will Definitely occur Swart Street Slight Republiek street Slight Buiten Street Moderately Severe P28/4 Slight P183/1 Moderately Severe D2095 Moderately Severe Impact on the road structural D933 Localised Long Term Moderately Severe capacity Swart Street Slight Low Will Definitely occur Republiek street Slight Buiten Street Slight P28/4 P183/1 D2095 Growth in Heavy Vehicle Traffic D933 volume Swart Street Republiek street Localised Long Term Slight Low Will Definitely occur Buiten Street Assessment of Potential Impacts 65

93 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 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). Assessment of Potential Impacts 66

94 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 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. Assessment of Potential Impacts 67

95 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 ( 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 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 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. Assessment of Potential Impacts 68

96 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 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. Assessment of Potential Impacts 69

97 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 Assessment of Potential Impacts 70

98 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 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 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 Assessment of Potential Impacts 71

99 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 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 2000 o C), long solid residence time (up to 30 minutes), long gas residence times (of 4 to 8 seconds), and the large excess of oxygen used. Assessment of Potential Impacts 72

100 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 Confidence in associated with the Mitigation and/or Extent Duration Severity Significance Likelihood assessment of introduction of an Enhancement impact AFR programme Utilisation of specified routes by vehicles transporting AFR to Dudfield plant and the Disruption in daily Unlikely to investigation of the feasibility living and movement Localised Long-term Slight None Probable occur of utilising the empty AFR patterns transport trucks leaving Dudfield plant to transport the product from the plant. Impact on Utilisation of specified routes by infrastructure and Unlikely to Localised Long-term Slight Low Probable vehicles transporting AFR to community occur Dudfield plant. infrastructure needs Utilisation of specified routes by vehicles transporting AFR to Health and safety Unlikely to Dudfield plant, as well as the Localised Long-term Severe High Probable impacts road safety occur implementation of appropriate emergency response procedures. Health and safety impacts air emissions Localised Long-term Slight Low May occur Probable Assessment of Potential Impacts 73

101 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 Confidence in associated with the Mitigation and/or Extent Duration Severity Significance Likelihood assessment of introduction of an Enhancement impact AFR programme Appropriate training and Health and safety regular medicals should be impacts employees handling AFR Localised Long-term Severe High May occur Probable provided. Job analysis should be undertaken on a regular basis. Local impacts and regional benefits Regional Long-term Severe High (positive) Will occur Probable Appropriate mitigation for Intrusion impacts Localised Long-term Severe Low May occur Probable potential air quality impacts, traffic impacts and impacts on water resources, noise impacts and visual impacts. Assessment of Potential Impacts 74

102 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 Assessment of Potential Impacts 75

103 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) 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. Assessment of Potential Impacts 76

104 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 Preacceptance Waste Collection Transport Waste Receiving Area Waste Acceptance Waste Storage Gas Storage Utilisation of AFR Products from the Kiln Incorrect analysis or interpretation of results could lead to incompatible waste being accepted by facility. Local Short term Slight Unlikely Low Poor collection practices could lead Local Short term Moderate Unlikely Low to minor spills. Accidents could lead to spillage of Local Short term Severe Unlikely Low material. Poor off-loading practices could lead Local Short term Moderate Unlikely Low to minor chemical spills. Incorrect check analysis or interpretation of results could lead to incompatible waste being accepted by facility. Local Short term Slight to Moderate Unlikely Low Incompatible waste stored or Local Short term Severe Very Unlikely Low to Moderate flammable waste incorrectly managed could lead to risk of fire or explosion. Improper storage of the flammable Local Short term Severe Very Unlikely Low to Moderate gas could lead to fire or explosion. Poor operation of the plant could Local Short term Moderate Very Unlikely Low to Moderate lead to incomplete combustion. Contaminated clinker and cement National Long term Severe Very Unlikely Low products entering the market. Assessment of Potential Impacts 77

105 Aspect Risk Extent Duration Severity Probability Significance Natural Events Flooding Flood water may enter waste Local Short term Severe Very Unlikely Moderate storage areas. Fire Fire within the facility would lead to Local Short term Very severe Very Unlikely High considerable risks to plant personnel inside the facility. Fire Fire within the facility would lead to Local Short term Severe Very Unlikely Moderate considerable risks to the environment outside the facility. High Winds High winds could disperse pollutants Local or Short term Moderate Very Unlikely Low into the environment. Regional Human Error Data Entry Incorrect data could be provided by Local Short term Severe Unlikely Low Error the client or be input into the database. Unauthorise People could gain unauthorised Local Short to long Severe Unlikely Low d Access access and exposed to potentially hazardous materials. term AFR Spills Chemical spills could result in contamination of soil and water. Local Short term Severe Very Unlikely Low Assessment of Potential Impacts 78

106 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 pretreatment before they would be acceptable for use at the kiln. This pretreatment 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. Assessment of Potential Impacts 79

107 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 pretreatment) 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. Assessment of Potential Impacts 80

108 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 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. Assessment of Potential Impacts 81

109 6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY 6.1. Introduction Typical air pollutants from cement manufacturing include sulphur dioxide (SO 2 ), oxides of nitrogen (NO x ), 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) 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; Assessment of Potential Impacts on Air Quality 82

110 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 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 Detailed meteorological data is a necessity for the assessment of the atmospheric dispersion potential of the study site 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 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 Assessment of Potential Impacts on Air Quality 83

111 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 nighttime 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 Assessment of Potential Impacts on Air Quality 84

112 noted for daytime hours with calm periods of 2,4% occurring for the period January 1996 August 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 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/m³ 1, 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 µg/m³ and 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 98 th percentile the predicted hourly value is 20 µg/m³. The predicted 50 µg/m³ was predicted for a peak incident during the monitoring campaign. Assessment of Potential Impacts on Air Quality 85

113 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 to Permit specifications for emission concentrations are discussed in section and EC emission limits in Section 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 (SO 2 ), lead (Pb), oxides of nitrogen (NO x ), 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. Assessment of Potential Impacts on Air Quality 86

114 Table 6.1: Current DEAT NO x guidelines Averaging Period Ground Level Concentrations µg/m³ ppm Annual average Max 24-hour average Max 1-hour average Table 6.2: Air quality standards for nitrogen dioxide (NO 2 ) Annual Average Max 1-hour Average µg/m³ ppm µg/m³ ppm South Africa (Proposed) (5) United States EPA 100 (1) (1) - - European Community 40 (2) (2) 200 (3) 0.10 (3) United Kingdom Canada (4) Notes: (1) Annual arithmetic mean. (2) Annual limit value for the protection of human health, to be complied with by 1 January (3) Averaging times represent the 98 th 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 (4) Acceptable Canadian air quality objectives. (5) SABS, 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) United States EPA 150 (1)(2) 50 (3) European Union (EU) 130 (4) 250 (5) 80 European Community (EC) 50 (6) 30 (7) Canada 24 - Reference: Chow and Watson, 1998; Cochran and Pielke, 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 95 th percentile of daily means for the year; (6) Compliance by 1 January 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, (8) Assessment of Potential Impacts on Air Quality 87

115 Table 6.4: Air quality standards for lead Quarterly Average (µg/m³) Annual Average (µg/m³) South Africa (Proposed) (2) United States EPA European Union Germany (1986) United Kingdom (1) Note: (1) Limit to be achieved by 2005, given as part of UK s national air quality management plan. (2) SABS, 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 Great Britain 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 (4) SABS, Effect Screening Levels 2 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. Assessment of Potential Impacts on Air Quality 88

116 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. Assessment of Potential Impacts on Air Quality 89

117 Table 6.6: Effect screening and health risk criteria for various substances included in the investigation Constituent RAIS Inhalation Reference California OEHHA (Sept ATSDR MRL s (Jan WHO Guidelines (2000) Concentrations (Jan 2004) 2002) (µg/m³) 2004) (µg/m³)(b) (µg/m³) (µg/m³) Sub-chronic Chronic Acute & Subacute Acute RELs Chronic Chronic inhalation inhalation Acute Chronic (a) RELs Guidelines RfCs RfCs Guidelines Acetone Arsenic & inorganic compounds 0.19 (4 hrs) 0.03 Barium 0.5(g) 0.5(g) Benzene 30 (f) 1300 (6hrs) Beryllium 0.02 (f) Cadmium & compounds (as Cd) 0.9 (h)(e) Chromium (VI) compounds 0.1 (f) 0.2 Cobalt & inorganic compounds 0.02 Copper: dust & mist 100 (1 hr) Manganese fume, dust & 0.05 (f)(i) inorganic compounds Mercury, metal & inorganic 0.3(h) 0.3(f) 1.8 (1 hr) forms Nickel, metal & insoluble 6.0 (1 hr) 0.05 compounds Hydrogen chloride 20(f) 2100 (1 hr) 9 Hydrogen fluoride 240 (1 hr) Silver 1.0(24 hrs) Assessment of Potential Impacts on Air Quality 90

118 Vanadium Constituent Xylene (all isomers except p) p-xylene RAIS Inhalation Reference Concentrations (Jan 2004) Sub-chronic inhalation RfCs (µg/m³) Chronic inhalation RfCs California OEHHA (Sept 2002) (µg/m³) Acute RELs (a) Chronic RELs 100 (k) (1 hr) 700 (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 ATSDR MRL s (Jan 2004) (µg/m³)(b) Acute Chronic WHO Guidelines (2000) (µg/m³) Acute & Subacute Chronic Guidelines Guidelines 1.0 (24 hrs) 4800 (24 870(i) hrs)(g) Assessment of Potential Impacts on Air Quality 91

119 Table 6.7: DIOXINS FURANS Toxicity equivalency factors for dioxins and furans Congener TEF (WHO) Mono-, di- and tri-chlorodibenzodioxins 0 2,3,7,8,-Tetrachlorodibenzodioxin (TCDD) 1 Other TCDDs 0 1,2,3,7,8-Pentachlorodibenzodioxin (PeCDD) 1 Other PeCDDs 0 1,2,3,4,7,8-Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,6,7,8- Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,7,8,9- Hexachlorodibenzodioxin (HxCDD) 0.1 Other HxCDDs 0 2,3,7,8-Heptachlorodibenzodioxin (HpCDD) 0.01 Other HPCDDs 0 Octachlorodibenzodioxin (OCDD) Mono-, di- and tri-chlorodibenzofurans 0 2,3,7,8-Tetrachlorodibenzofuran (TCDF) 0.1 Other TCDFs 0 1,2,3,7,8-Pentachlorodibenzofuran (PeCDF) ,3,4,7,8-Pentachlorodibenzofuran (PeCDF) 0.5 Other PeCDFs 0 1,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 1,2,3,7,8,9-Hexachlorodibenzofuran (HxCDF) 0.1 2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 Other HxCDFs 0 1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF) ,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF) Other HPCDFs 0 Octachlorodibenzofuran (OCDF) Assuming that all of the dioxin to which a 70 kg person is exposed is absorbed, and given an average breathing rate of 1 m 3 /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 x 10-7 µg/m 3 ATSDR x 10-5 µg/m 3 WHO x 10-5 to 1.17 x 10-4 µg/m 3 The USEPA unit cancer risk factor for dioxins is 33 (µg TEQ/m 3 ) -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/m 3. This does not take into account exposure through the other potential pathways. Assessment of Potential Impacts on Air Quality 92

120 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/m 3 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) WHO Inhalation Unit Risk US-EPA Unit Risk Chemical (µg/m³) -1 Factor (µg/m³) -1 US-EPA Cancer Class Arsenic, inorganic (a) 1.5E E-03 A Benzene 4.4E-06 to 7.5E E-06 to 7.8E-06 A Beryllium 2.4E-03 B1 Cadmium (b) 1.8E-03 B1 Chromium VI 1.1E-02 to 13E E-02 A (particulates) Nickel 3.8E E-04 A Note: (a) Date withdrawn by US-EPA: January (b) Date withdrawn by US-EPA: July (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. (c) 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 Permit Specifications For the current study the permit specifications for SO 2, NO 2 and PM10 stack emissions were used (refer to Table 6.9). Assessment of Potential Impacts on Air Quality 93

121 Table 6.9: Permit specifications for stack PM10 emissions Permit No. NWPG/DAC&E/ ALPHA/SP22/01 Aug03 Emission Limits Nature of Height Extraction Division (mg/nm³) Process (m) System SO 2 NO 2 PM10 Cement Processes Kiln Bag Filter Cement Mill 1 30 N/A N/A 50 Bag Filter (No. 22) Cement Mill 2 30 N/A N/A 100 Electrostatic Precipitator 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 Emission concentrations specified as part of these regulations are expressed at 0 C and kpa, dry gas and 10% oxygen. Table 6.10: Comparison of EC emission limit values for emissions from coincineration of waste in cement kilns (Directive 2000/76/EC) and DEAT class 1 incinerator Pollutant DEAT Limit EU Directive (Class /76/EC incinerator) Units Total dust mg/nm³ HCl mg/nm³ HF 30 1 mg/nm³ NO x for existing plants 800 (a) NO x for new plants 500 (b) mg/nm³ SO mg/nm³ TOC 10 mg/nm³ Cd + Tl 0.05 (c) 0.05 mg/nm³ Hg mg/nm³ Sb + As + Pb + Cr + Co + Cu + Mn + Ni + V 0.05 (c) 0.5 mg/nm³ Dioxins toxic equivalence ng/nm³ Notes: (a) For existing plants (b) For new plants (c) Limit value for each individual element 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 Assessment of Potential Impacts on Air Quality 94

122 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 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 NO 2 (<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 NO x is similar at 2.8 kg/tonne clinker. Measured NO x emission ranges from European cement kilns are in the range of <0.4-6 kg/tonne clinker (AEA Technology, 2002). Sulphur Dioxide Emissions: SO 2 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 SO 2 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 SO 2. 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 SO 2 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) Assessment of Potential Impacts on Air Quality 95

123 is approximately 1,63% (pers. Comm. ACMP). However, SO 2 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 SO 2 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 Assessment of Potential Impacts on Air Quality 96

124 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 US (US EPA, 2000) - Standard fuel With waste derived fuel 1.04 (pollution control device inlet temp < 450 F) UK - Standard fuel With waste derived fuel 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 Assessment of Potential Impacts on Air Quality 97

125 known. The process design for the current study was not at an advanced enough stage to provide this information 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 SO 2, NO x, 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 A summary of the total emissions from the Dudfield Plant is given in Table 6.13 to Table Table 6.12: Stack parameters for the Dudfield Plant for proposed usage of alternative fuels Source Height Diameter Temperature Exit Velocity (m/s) (m) (m) ( C) Minimum Average Maximum Kiln Cement Mill Cement Mill 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. Assessment of Potential Impacts on Air Quality 98

126 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) Source PM10 NO x SO 2 Min Ave Max Min Ave Max Min Ave Max Kiln 3 (2) Cement Mill (1) - - Cement Mill (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) Compound Emission (g/s) Minimum Average Maximum Antimony 8.33E E E-03 Arsenic 1.24E E E-03 Cadmium 1.05E E E-05 Chromium 9.12E E E-02 Cobalt 2.99E E E-03 Copper 4.45E E E-03 Lead 3.95E E E-03 Manganese 3.05E E E-02 Mercury 6.99E E E-02 Nickel 1.13E E E-02 Thallium 6.97E E E-02 Vanadium 5.49E E E-03 Dioxin Toxic Equivalence 1.40E E E-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) Compound Emission (g/s) Minimum Average Maximum HCl HF (a) Emissions were based on EC emission limits 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 Assessment of Potential Impacts on Air Quality 99

127 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 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 SO 2 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 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 onsite meteorological data are then essential for accurate predictions. Assessment of Potential Impacts on Air Quality 100

128 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 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 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 Assessment of Potential Impacts on Air Quality 101

129 nighttime boundary layer heights were calculated from various diagnostic approaches for stable and neutral conditions, as mentioned previously 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 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 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 Atmospheric Dispersion Results and Discussion 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 SO 2 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 SO 2 permit requirements. Holcim are confident that the permit Assessment of Potential Impacts on Air Quality 102

130 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 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 Assessment of Potential Impacts on Air Quality 103

131 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) Pollutant Emission Rate Maximum Predicted Ground Level Concentrations (µg/m3) Maximum Predicted Concentrations as a Percentage of Current SA Air Quality Guidelines (a) Maximum Predicted Concentrations as a Percentage of Proposed SA Air Quality Limits (a) Maximum Predicted Concentrations as a Percentage of EC Air Quality Limits (a) PM10 N0x(e) NO2 S02 Highest hourly Highest daily Annual average Highest hourly Highest daily Annual average Highest hourly Highest daily Annual average Highest hourly Highest daily Min - 6.3E E < Ave - 6.3E E < Max - 6.2E E < Min 3.2E E E < Ave 2.9E E E < Max 2.7E E E < Min 2.8E E E-02 <1 <1 < < <1 Ave 2.6E E E-02 <1 <1 < < <1 Max 2.4E E E-02 <1 <1 < < <1 Min 2.0E E E <1-2.2 < <1 Ave 1.8E E E <1-1.8 < <1 Max 1.7E E E <1-1.6 < <1 Min E <1 (c) Annual average <1 (d) - - <1 Lead Ave E <1 (d) - - <1 <1 (c) Max E <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/m 3 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 NO x. However the Department of Environmental Affairs and Tourism provides guideline levels for this group. EC limits are only specified for NO 2 ground level concentrations (to be complied with by the 1 January 2010). <1 (c) Assessment of Potential Impacts on Air Quality 104

132 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 (NO x ): For current operating conditions (with the installation of the low-no x burner), highest predicted off-site NO 2 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 NO 2 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 NO x 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 NO 2 and NO x emissions indicated a fraction of approximately 1% NO 2 of total NO x. The general literature concludes fractions up to 5% (Holcim presentation, 2003). The EU standards (and proposed SA standards) will still be met even if NO 2 were assumed to be 5% (upper estimate) of NO 4 x. Sulphur Dioxide (SO 2 ): 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, SO 2 are to a large extent determined by the chemical characteristics of the raw materials used, 4 The formation of NO x 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, NO 2 should remain the same as current operating conditions. Assessment of Potential Impacts on Air Quality 105

133 and not by the fuel composition (CEMBUREAU, 1999). Therefore, the predicted SO 2 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 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 noncriteria pollutant concentrations predicted to occur due to the proposed use of alternative fuel is given in Table 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)) 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 The main target organs which may be impacted and the cancer risk calculated given the predicted concentrations are presented in the table. Assessment of Potential Impacts on Air Quality 106

134 Table 6.17: Pollutant Arsenic Cadmium Chromium Cobalt Copper Manganese Mercury Nickel Vanadium 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) Emission Rate Maximum Predicted Ground Level Concentrations (µg/m3) Effect Screening or Health Risk Criteria (b) Maximum Predicted Concentrations as a Ratio of the Respective Effect Screening or Health Risk Criteria (a) Highest Highest Annual hourly daily average Highest hourly Highest daily Annual average Highest hourly Highest daily Annual average Min 3.22E E E E E E-01 (4 Ave 2.94E E E E E E-04 hrs) Max 2.79E E E E E-04 Min 2.73E E E E-05 Ave 2.50E E E E E-05 Max 2.37E E E E-05 Min 2.37E E E E-03 Ave 2.16E E E E E-03 Max 2.06E E E E-03 Min 7.77E E E E-03 Ave 7.08E E E E E-03 Max 6.75E E E E-03 Min 1.16E E E E Ave 1.05E E E E E Max 1.01E E E E Min 7.93E E E E-03 Ave 7.22E E E E E-03 Max 6.89E E E E-03 Min 1.82E E E E E-04 Ave 1.65E E E E E E E-04 Max 1.58E E E E E-04 Min 2.94E E E E E-03 Ave 2.67E E E E E E E-03 Max 2.55E E E E E-03 Min 1.43E E E E-03 - Ave 1.30E E E E E-03 - Max 1.24E E E E-03 - Assessment of Potential Impacts on Air Quality 107

135 Pollutant Emission Rate Maximum Predicted Ground Level Concentrations (µg/m3) Highest hourly Highest daily Annual average Effect Screening or Health Risk Criteria (b) Highest hourly Highest daily Annual average Maximum Predicted Concentrations as a Ratio of the Respective Effect Screening or Health Risk Criteria (a) Highest hourly Highest daily Annual average Min 3.64E E E E E-03 Hydrogen Chloride Ave 3.30E E E E E E E-03 Max 3.15E E E E E-03 Min 3.64E E E E Hydrogen Fluoride Ave 3.30E E E E E Max 3.15E E E E Min 3.64E E E E-02 - Dioxin Toxic Ave 3.30E E E E E-02 - Equivalence Max 3.15E E E E-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. Assessment of Potential Impacts on Air Quality 108

136 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) Carcinogen Arsenic Cadmium Chromium VI Nickel Dioxin Toxic Equivalence Notes: Predicted Cancer Risk (calculated Maximum WHO Cancer Risk (calculated US-EPA Unit based on the Emission Annual Inhalation based on the application of Risk Factor application of unit risk Rate Average Unit Risk unit risk given in the RAIS (µg/m3) -1 given in the WHO Concentration (µg/m3) -1 database) database) (µg/m3) Min 2.73E in 100 million 1.17 in 10 million Ave 2.73E E E in 100 million 1.17 in 10 million Max 2.65E in 100 million 1.17 in 10 million Min 2.31E in 10 million Ave 2.32E E in 10 million Max 2.26E in 10 million Min 2.01E to 26 in 1 million (a) 2.4 in 1 million 1.1E-02 to 13E- Ave 2.01E E to 26 in 1 million (a) 2.4 in 1 million 02 Max 1.96E to 25.4 in 1 million (a) 2.4 in 1 million Min 2.49E in 100 million 5.6 in 100 million Ave 2.48E E E in 100 million 5.9 in 100 million Max 2.43E in 100 million 5.8 in 100 million Min 3.08E-10 1 in 100 million Ave 3.06E in 100 million Max 3.00E in 100 million (a) Cancer risk exceeding 1 in 1 million (trivial cancer risk criterion) Assessment of Potential Impacts on Air Quality 109

137 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 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). Assessment of Potential Impacts on Air Quality 110

138 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 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. Assessment of Potential Impacts on Air Quality 111

139 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 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 NO 2 (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 NO 2 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; NO x 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/m³ 5, 1,2 µg/m³ and 0,01 µg/m³ for 5 Using the 98 th percentile the predicted hourly value is 20 µg/m³. The predicted 50 µg/m³ was predicted from a peak incident during the monitoring campaign. Assessment of Potential Impacts on Air Quality 112