Ulco AFR EIA Draft Report.Pdf

ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR THE FOR THE PROPOSED IMPLEMENTATION OF AN ALTERNATIVE FUELS AND RESOURCES PROGRAMME FOR KILN 5 AT THE HOLCIM SOUTH AFRICA ULCO PLANT, NORTHERN CAPE PROVINCE

Compiled by

Bohlweki Environmental (Pty) Ltd PO Box 11784 Vorna Valley MIDRAND 1686

In association with the following specialists

Dr D Baldwin and Ms M Chettle Dr L Burger and Ms R Thomas Environmental & Chemical Consultants Airshed Planning Professionals Mr F Joubert Ms C Herrera Sustainable Law Solutions Stewart Scott International Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

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 Ulco plant, located approximately 80 km north west of Kimberley in the Northern Cape Province. At Ulco plant, limestone (source material) and coal (fuel) are currently the primary raw materials utilised in the manufacture cement.

Ulco plant is situated on a limestone deposit that is mined and milled as feedstock to the plant. The coal that is utilised in its kiln as the main energy source for converting the limestone raw meal into 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 primary energy source, with alternative waste-derived fuels. That is, the introduction of an Alternative Fuels and Resources (AFR) programme is proposed for the Ulco plant.

The AFR programme aims to reduce traditional fossil fuel usage at the existing plant by up to 35% or more through the replacement of coal with alternative waste-derived fuels and raw materials. These alternative fuels would be sourced from selected waste products and by-products generated from selected existing industrial and domestic sources.

1.1. Motivation for the Proposed Project

The process of cement manufacture is energy intensive. The average energy required to produce 1 000 tons of cement clinker is approximately 130 tons of coal. As a result, Holcim South Africa currently requires approximately 350 000 tons of coal per annum to operate their kilns across the country.

The Holcim commitment to promoting development that is sustainable and at the least cost to future generations has resulted in a drive to substitute a portion of the traditional non-renewable fossil fuel (coal) used in the production of cement clinker 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.

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The use of alternative fuels and raw materials selected from 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 impacts of using a non-renewable resource (coal) in the cement clinker 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 consistent 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 the energy, as well as the mineral components, from waste. The use of waste-derived fuels in a cement kiln reduces fossil fuel use, and maximises the recovery of energy, without any significant change in emission levels.

The use of alternative fuels is a well-proven and well-established technology in the European, American (both North and South) and Asian-Pacific cement industries. Experience at international plants has shown that alternative fuels can successfully replace traditional fossil fuels with no adverse impact on the environment, safety or health of employees and communities, or on the quality of the final cement product.

1.2. Infrastructure Requirements for the Proposed AFR Programme

Kiln 5 at Ulco Plant is capable of implementing the technology associated with the acceptance and use of alternative fuels as an energy source, together with coal.

Coal will continue to form the primary energy source in Kiln 5. The AFR programme is aimed at substituting a portion of the total coal requirement. The proposed introduction of the AFR programme would require the continued storage of coal on the existing stockpile, as well as the creation of a second designated storage area/facility for an approximate 2-day supply of approved AFR. This AFR storage area would be required to comprise suitable storage tanks, silos and bunkers in close proximity to the kiln. Two AFR fuel storage areas are proposed to be established within the boundaries of the existing Ulco plant, i.e. an undercover storage area of approximately 300 m2 and an open storage area of approximately 2 000 m2.

The proposed AFR storage areas are located adjacent to the plant within the plant footprint to allow for safe and secure feeding of the AFR material from the storage area to Kiln 5. The demarcated areas have been extensively disturbed through previous use for construction purposes. The sites are devoid of vegetation, and on level terrain.

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The AFR storage facility would be required to be designed according to national construction, and fuel handling and storage requirements. This would include a bunded concrete base complete with stormwater containment and handling facilities, as well as monitoring and fire-fighting equipment.

The storage area would be accessed by a levelled and sealed access road, and would include sufficient area to all for safe vehicle off-loading and manoeuvring, as required. It is proposed that initially the kiln would be in a position to utilise approximately 70 tons of AFR a day (represented by between 2 and 3 vehicle loads of AFR per day). It is proposed that the volume of AFR utilise per day could increase to approximately 240 tons per day. The acceptance and storage facilities would be required to be designed to safely handle and feed these volumes.

A dedicated AFR on-site laboratory would be required at Ulco plant to conduct 'fingerprint' analyses on all AFR materials arriving at the operation to verify that the arriving material is consistent with the original waste acceptance criteria. Only after laboratory approval would the AFR waste stream be accepted for offloading to the Ulco AFR storage facility. Any waste-derived fuels received which do not match the original 'fingerprint' criteria would be returned to the supplier and the incident reported.

1.3. Waste-derived Materials which can be utilised as Alternative Fuels

Waste materials currently utilised by the global cement industry 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 AFR in South Africa, together with other wastes considered suitable (including industrial hydrocarbon tars and sludges). These wastes could potentially be sourced from a variety of existing sources from a variety of geographic locations.

Only those waste-derived fuels that meet the stringent standards set by Holcim and approved by the authorities will, however, be considered and accepted for use in the kiln.

International experience has proven that 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. These include:

• High temperatures – exceeding 1 400°C (flame temperature ~2 000°C)

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• 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 process, public health and/or 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 Ulco 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 Ulco 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 Northern Cape Department of Tourism, Environment and Conservation (NC DTEC) for the undertaking of the proposed project. This Environmental Impact Assessment (EIA) process for the proposed introduction of an AFR programme at Kiln 5 at the Holcim South Africa Ulco plant has been undertaken in accordance with the EIA Regulations published in Government Notice R1182 to R1184 of 5 September 1997, in terms of the Environment Conservation Act (No 73 of 1989), as well as the National Environmental Management Act (NEMA; No 107 of 1998). 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

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• 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 identified through the EIA studies include:

• Potential impacts associated with emissions to air from the plant; • Potential impacts associated with the transportation of AFR to Ulco plant; • Potential impacts associated with the storage of AFR on site for a limited period; • Potential 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 and environmentally sound method of resource recovery for many types of hazardous and non-hazardous wastes (http://gcisolutions.com/dgawma01.htm). Conditions needed to manufacture cement (high temperature, turbulence and long gas residence times) are the same conditions required for total destruction of hazardous waste. Cement kilns burn hotter, have longer gas residence times, and are much larger than other commercial thermal treatment facilities. These advantages, together with the degree of mixing in the kiln, make cement kilns an excellent technology for recovering energy from hazardous and non-hazardous waste (www.ckrc.org/issues/99475523.html).

Executive Summary v 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province 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 Ulco plant.

3.1. Impacts Associated with Emissions to Air from the Plant

Releases from the cement kiln are a result of the physical and chemical reactions of the raw materials and from the combustion fuels. Typical air pollutants from cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx), inhalable particulates (PM10), heavy metals, organic compounds and dioxins and furans.

During the EIA process, concern was raised regarding the potential impacts associated with dust, and dioxins and furans and the health risk posed to local communities. From the results of the specialist study undertaken as part of this EIA, it is anticipated that the significance for all criteria pollutants of concern is predicted to remain low with the significance for non-criteria pollutants (based on hexavalent chromium) as high with the introduction of an AFR programme at Kiln 5 at Ulco plant. However, 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.

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) could cause of wide range of very harmful human health effects, including cancer (EPA, 2004). Studies by the US EPA and French Academy of Sciences have, however, indicated that it is highly unlikely that dioxins would increase cancer incidence in people at the low exposure levels commonly encountered in the environment or from food (Rotard, 1996), and that no fatal case associated with these compounds has ever been reported (Constans, 1996).

Dioxins can be formed from any burning process, and cement kilns are no exception. The potential for dioxin formation in cement manufacture is a function of raw materials and kiln technology, and is not related to the types of fuel used. Dioxin emissions are generally in the range of detection limits and the level of emissions can depend on the type of kiln technology employed. “Cement kilns control dioxin formation by quenching kiln gas temperatures so that gas temperatures at the inlet to the particulate matter control device are below the range of optimum dioxin/furan formation” (EPA, 2004).

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The cement industry has been more successful than any other in reducing emissions of dioxins and furans. Through intensive research, an understanding of the nature of dioxin formation in combustion emissions has been established, and they have succeeded in learning how to reduce those emissions. As a result since 1990, dioxin emissions from kilns that recover energy from hazardous waste have been reduced by 97%. This has been corroborated by independent research undertaken by the US EPA (www.ckrc.org/ncafaq.html).

Conclusions of the specialist air quality study undertaken as part of this EIA (refer to Chapter 6) are in agreement with these international findings and indicate that predicted ground level impacts from the introduction of an AFR programme at Kiln 5 at Ulco plant will not have a significant impact on air quality as these are well below relative guidelines/limits.

In order to monitor emissions from Ulco plant, Holcim South Africa has installed state-of-the art OPSIS continuous emission measuring equipment that is linked to the kiln operating system. The equipment currently measures 12 emission streams on a continuous basis, with a further annual measurement of 12 heavy metals and dioxins and furans. Emission levels will be subject to the prescribed requirements of the Stack Registration Permit issued by CAPCO. Alarms are in place in order to indicate if any emission approaches its limits, thus allowing for immediate corrective action to be taken. All emission data captured by the OPSIS equipment will be available to CAPCO for auditing purposes.

3.2. Impacts Associated with the Transportation of AFR to Dudfield Plant

Issues surrounding the transportation of AFR to Ulco plant were identified through the EIA process, including impacts on traffic volumes and the potential disruption to the daily movement patterns of the local population (particularly residents in Ulco, Delpoortshoop, Barkly West, and surrounding landowners and places of interest such as the Vaalbos Nature Reserve who all use the R31 as an access route), 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 Ulco plant is anticipated. Specialist studies undertaken indicate that this will result in a 0,3% increase in the traffic volume on the access routes to Ulco 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.

Executive Summary vii 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province transportation of AFR to Ulco. In the event of an accident, the vehicles are equipped with spill-control kits and action should be taken as soon as possible in order to contain spillages while waiting for backup. The transport of waste must be supported by a HazMat Emergency Response team in order to contain and clean up any spill, in order to minimise impacts on the environment and surrounding communities.

3.3. Impacts Associated with the Storage of AFR on Site for a Limited Period

In order to successfully implement the AFR programme at Ulco plant's Kiln 5, 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 Ulco, or would need to be pre-processed to achieve a uniform and constant fuel source at an appropriate volume. This pre-treatment will not be undertaken at Ulco plant.

For the AFR streams that would be delivered directly to the kiln, an on-site storage facility would need to be provided to accommodate/store an approximate 2-day reserve capacity. The appropriate management of the storage of waste- derived alternative fuels will minimise environmental impacts and the potential for pollution of the soil and groundwater. Without the implementation of appropriate management measures, this impact is potentially of high significance. The storage of fuels, storage and handling of AFR must be undertaken in an appropriate manner, as stipulated in this report, to avoid spillage and leaching and to limit fugitive emissions, odour and noise to acceptable levels. In addition, 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.

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3.4. Impacts on the Social Environment

The Holcim Ulco Plant is located approximately 1 km north east of the Ulco township, 17 km north west of Delportshoop, 24 km south east of Koopmansfontein, 42 km north west of Barkly West, and 80 km north west of Kimberley in the Northern Cape Province. The area surrounding Ulco plant is sparsely populated, typical of a rural farming community. The greatest population density in the immediate area surrounding the plant is Ulco Village. The village is located approximately 1 km south west of the plant and is predominantly utilised by the employees from the Ulco plant. Impacts to or the disturbance of surrounding communities already exist, and have done so since the initial construction of the facility more than 60 years ago.

Potential impacts on the social environment associated with the introduction of an AFR programme at Ulco 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 Ulco, this potential impact is considered to be unlikely to occur and of low significance.

Specialist studies have indicated the following:

• Non-criteria pollutants – non-carcinogenic health effects: Predicted concentrations are all below the screening levels and health risk criteria; • Non-criteria pollutants – carcinogenic health effects: Carcinogenic pollutants for baseline conditions (based on initial baseline monitored emissions during 2002) are predicted to cause less than 1 in 1 million chance of cancer (trivial cancer risk criterion), with the exception of benzene and hexavalent chromium. The cancer risk due to benzene ranged from 0.4 to 1.5 in 1 million (based on US-EPA unit risk factors). Assuming all chromium to be hexavalent, the estimated cancer risk ranged from 1.6 to 19.5 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

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inhalation risk factors would be 0,2 to 2 in a million. It is, therefore, broadly acceptable (i.e. less than 1 in 100 thousand);

Risk assessments undertaken internationally have shown that the use of waste (hazardous and non-hazardous) as fuel in cement kilns poses no increased risk to human health and the environment (www.ckrc.org/ncafaq.html; refer Appendix J).

Potential health and safety risks to employees have 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 Ulco plant in an environmentally and economically sustainable manner will secure these employment opportunities in the long-term. This is considered to have a positive impact of high significance on the region.

3.5. Suitability of Waste as an Alternative Fuel Resource

The selection, acceptance and appropriate management of the waste-derived fuel are critical to the success of this project and its operations. It is essential that AFR management be carried out in a manner that does not impact on human health and well-being and the environment.

The management protocol for the utilisation of selected wastes as an 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 cement clinker 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 certain elements in the AFR, need to be specified and adhered to.

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The primary management considerations to be borne in mind to ensure 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 Ulco plant • Offloading • Handling, on-site storage 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 must 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 Ulco. 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. • Potential negative impacts on the final product quality.

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 carcinogens, which could pose an unacceptable occupational health and safety risk. • Wastes that contain unacceptable levels of certain components that will impact on the kiln performance, the quality of the clinker and cement or adversely impact on the emissions from the kiln. These can include waste with unacceptable levels of some heavy metals (e.g. mercury and lead) or high levels of halogenated hydrocarbons, etc. • Unsorted domestic wastes (municipal garbage) because of the potential presence of hazardous materials. • Small-volume hazardous wastes from households (fluorescent lamps, batteries etc.). • Non-identified or insufficiently characterised wastes.

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Bearing the exclusionary criteria from the assessment of waste steams in mind, the list of wastes that are deemed unacceptable for AFR purposes in terms of the Holcim Group AFR Policy (Holcim Ltd, 2004) is supported. These unacceptable wastes consist of the following:

• Anatomical hospital wastes • Asbestos-containing wastes • Bio-hazardous wastes such as infectious waste, sharps, etc. • 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 5 as an alternative fuel source include non-hazardous and hazardous wastes such as, but not limited to scrap tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and spent solvents.

3.6. Project Benefits

The utilisation of alternative fuels in the cement industry is in-line with initiatives of National Government, particularly the National Waste Management Strategy (NWMS) which focuses on waste prevention and waste minimisation. The practice of employing alternative fuels in cement plants promotes the materials recovery and recycling industry, which is in line with the principles of the NWMS.

Where recycling of waste is not possible, landfill or incineration is the most common disposal practice available for many wastes. The introduction of an AFR programme would assist in the reduction in the amount of waste required to be disposed of to landfill or other means, and assist in the reduction of greenhouse gas emissions. The use of waste-derived fuel as AFR in cement kilns provides a service to society by dealing safely with wastes that are often difficult to dispose of in any other way (e.g. scrap tyres; www.ckrc.org/issues/993135035.html).

Of particular concern in South Africa is the disposal of scrap tyres to landfill, which is no longer considered to be an acceptable management practice in terms

Executive Summary xii 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province of the requirements of the NWMS. The South African Tyre Recycling Process Company (SATRP) are investigating alternate solutions to deal with the scrap tyre problem in South Africa. Government is presently drafting legislation to discourage the inappropriate disposal of scrap tyres. As the number of scrap tyres generated in South Africa is estimated at ~10 to 12 million per annum, with only ~12% being recycled to produce rubber crumb and recycled rubber 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.

The nature of the cement manufacture process makes waste suitable for the use as AFR by ensuring full energy recovery from various wastes under appropriate conditions. Any solid residue from the waste then becomes a raw material for the process and is incorporated into the final clinker. This, therefore, results in the conservation of non-renewable natural resources, as well as a reduction in the environmental impacts associated with mining activities.

Depending on the quantity of the waste-derived fuel available and the energy content of this fuel, Holcim South Africa will be able to replace between 35 - 50% of their traditional coal-based fuel with AFR. Including the kiln efficiency upgrade, a total reduction of between 40 000 and 90 000 tons of coal/annum is estimated by Holcim for Kiln 5.

3.7. Conclusions

The introduction of the AFR programme at Kiln 5 of the Ulco plant provides the opportunity to:

• Recover energy from combustible wastes, as well as the mineral component from 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 Ulco plant is an ISO 14001 accredited operation, the EMP would be required to form part of the independently audited ISO 14001 programme.

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TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY i TABLE OF CONTENTS ix LIST OF TABLES xx LIST OF FIGURES xxiii LIST OF PHOTOGRAPHS xxiv ACRONYMS AND ABBREVIATIONS xxv

1. INTRODUCTION 1 1.1. Motivation for the Proposed Project 1 1.2. Overview of the existing Ulco Plant and the proposed 2 AFR Programme 1.2.1. Overview of Ulco Plant and Kiln 5 2 1.2.2. Infrastructure requirements for the proposed AFR 2 programme 1.2.3. Waste-derived Materials which can be utilised as 4 Alternative Fuels 1.3. Environmental Study Requirements 5

2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS 6 2.1. Approach to Undertaking the Study 6 2.2. Authority Consultation 6 2.2.1. Consultation with Decision-making Authorities 6 2.2.2. Consultation with Other Relevant Authorities (non- 7 DEAT) 2.3. Application for Authorisation in terms of Section 22 of 7 the Environment Conservation Act (No 73 of 1989) in respect of an Activity Identified in terms of Section 21 of the said Act 2.4. 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 8 2.5.1. Specialist Studies 8 2.5.2. Assumptions and Limitations of the Study 10 2.5.3. Overview of the Public Participation Process undertaken 10 within the EIA Process 2.5.4. Review of the Draft Environmental Impact Assessment 14 Report 2.5.5. Final Environmental Impact Assessment Report 14

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3. DESCRIPTION OF THE EXISTING ULCO PLANT AND THE 15 SURROUNDING ENVIRONMENT 3.1. The Existing Ulco Plant and Kiln 5 15 3.2. Climate 17 3.2.1. Regional Climate 17 3.2.2. Rainfall 17 3.2.3. Temperature 17 3.2.4. Evaporation 18 3.2.5. Wind Data 19 3.2.6. Extreme Weather Conditions 20 3.3. Topography 21 3.4. Geology 21 3.5. Soils 22 3.6. Surrounding Land Use and Surface Infrastructure 24 3.7. Flora 24 3.8. Fauna 25 3.9. Surface Water 26 3.10. Geohydrological Conditions 26 3.11. Water Consumption at the Dudfield Plant 27 3.12. Air Quality 31 3.13. Noise 33 3.14. Visual Aspects and Aesthetics 34 3.15. Sites of Archaeological, Cultural or Historical Interest 34 3.16. Regional Socio-economic Structure 34 3.16.1. Population Density 35 3.16.2. Major Economic Activity and Sources of Employment 35

4. DESCRIPTION OF THE CEMENT MANUFACTURING 36 PROCESS 4.1. Cement Manufacturing Process at Ulco Plant 36 4.1.1. Preparation of Raw Materials 36 4.1.2. Process inside the Kiln 38 4.1.3. After the Kiln 40 4.2. Environmental Aspects of Cement Manufacture 40 4.2.1. Raw Materials 40 4.2.2. Emissions to Air 40 4.2.3. Energy 41 4.2.4. Use of Alternative Fuels in the Cement Manufacture 41 Process 4.2.5. How AFR can be utilised in the Kiln 42 4.2.6. Waste Products utilised as Alternative Fuel Sources 44

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5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED 47 WITH THE INTRODUCTION OF THE ALTERNATIVE FUELS AND RESOURCES PROJECT AT DUDFIELD PLANT 5.1. Potential Impacts on Land Use, Vegetation and Heritage 47 Sites in the area surrounding the Dudfield plant 5.1.1. Conclusions and Recommended Management Options 48 5.2. Potential Impacts Associated with the establishment of a 48 Fuel Storage Area within the Boundaries of the Dudfield Plant 5.2.1. Conclusions and Recommended Management Options 52 5.3. Potential Impacts on Water Resources 52 5.3.1. Sources of risk to the groundwater and surface water 52 environment from the AFR project 5.3.2. Conclusions and Recommended Management Options 53 5.4. Potential Impacts on Air Quality 55 5.4.1. Conclusions 57 5.4.2. Recommendations 58 5.5. Potential Traffic Impacts 59 5.5.1. Condition of Roads around Ulco Plant 60 5.5.2. Existing Traffic 60 5.5.3. Structural Capacity Analysis 64 5.5.4. Assessment of Potential Impacts 64 5.5.5. Conclusions and Recommendations 65 5.6. Potential Impacts on the Social Environment 67 5.6.1. Methodology 67 5.6.2. Formation of Attitudes and Perceptions 68 5.6.3. Disruption in Daily Living and Movement Patterns 69 5.6.4. Impact on Infrastructure and Community Infrastructure 70 Needs 5.6.5. Health and Safety Impacts 70 5.6.6. Local Impacts and Regional Benefits 72 5.6.7. Intrusion Impacts 72 5.7. Assessment of the Suitability of Waste as an Alternative 73 Fuel Resource 5.7.1. Risks and Significance of Risks 77 5.7.2. Recommendation on the determination of suitable AFR 77 5.7.3. Conclusion 83

6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY 84 6.1. Introduction 84 6.2. Terms of Reference 84 6.3. Methodological Overview 85 6.4. Baseline Study 85 6.4.1. Local Wind Field 86

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6.4.2. Impact Assessment at Holcim-Dudfield Under Current 88 Operating Conditions 6.5. Environmental Legislation and Air Quality Guidelines 89 6.5.1. Ambient Air Quality Standards and/or Guidelines for 89 Criteria Pollutants 6.5.2. Volatile Organic Compounds 92 6.5.3. Effect Screening Levels and Health Risk Criteria of Non- 93 Criteria Pollutants 6.5.4. Dioxins and Furans 93 6.5.5. Cancer Risk Factors 96 6.5.6. Permit Specifications 96 6.5.7. Emission Limits 96 6.6. Process Description and Emissions Inventory 98 6.6.1. Studies on Emissions from Cement Kilns Utilising 99 Alternative Fuels 6.6.2. Limitations of the Given Source Inventory 96 6.6.3. Emission Inventory for Proposed Usage of Alternative 101 Fuels and Resources at Ulco Plant 6.6.4. Emission Estimation 103 6.6.5. Comparison of Simulated Emissions to Permit 103 Specifications 6.7. Dispersion Simulation Methodology And Data 104 Requirements 6.7.1. Meteorological Requirements 105 6.7.2. Receptor Grid 105 6.7.3. Source Data Requirements 106 6.7.4. Building Downwash Requirements 106 6.8. Atmospheric Dispersion Results and Discussion 106 6.8.1. Results of Criteria Pollutants 106 6.8.2. Results for Non-Criteria Pollutants: Potential for 111 Environmental and Non-Carcinogenic Health Effects 6.8.3. Results for Non-Criteria Pollutants: Potential for 111 Carcinogenic Effect 6.9. Significance Rating 112 6.10. Description of Aspects and Impacts 114 6.11. Conclusion and Recommendations 115 6.11.1. Recommendations 117 6.12. Air Quality Management System 118 6.12.1. Emissions Inventory Development and Maintenance 120 6.12.2. Source Monitoring 121 6.12.3. Ambient Air Quality Monitoring 122 6.12.4. Mitigation Strategy Design, Implementation and 122 Evaluation 6.12.5. Record Keeping and Environmental Reporting 122

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6.12.6. Consultation 123

7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN 124 ALTERNATIVE FUEL RESOURCE 7.1. Introduction 124 7.2. AFR Specifications 125 7.2.1. Types of Alternate Fuels and Resources 126 7.2.2. Physical and Chemical Characteristics of AFR 127 7.2.3. Summary of Acceptable Waste in terms of SANS 10228 133 7.2.4. Waste and AFR Standards / Specifications 135 7.2.5. Acceptable Limits for Elements in AFR 136 7.3. Environmental Fate of the Elements 138 7.4. Scrap Tyres 140 7.5. AFR Management Procedures 142 7.6. Risks and Significance of Risks 145 7.7 Recommendation on the determination of suitable AFR 148 7.7.1. Typical Wastes Excluded for use as Alternative Fuels 148 7.7.2. Typical Wastes Accepted for use as Alternative Fuels 149 7.7.3. Loading, supply, storage and management of Alternative 149 Fuels 7.8. Proposed Monitoring, Control and Mitigation Measures 150 7.8.1. Environmental Monitoring Programme 150 7.8.2. Initial Acceptance Procedure Control 151 7.8.3. Transport Procedure Control 151 7.8.4. Final Acceptance Procedure Control 152 7.8.5. Compliance Auditing 152 7.8.6. Development of Site Specific Specifications 153 7.9. Conclusion 154

8. CONCLUSIONS AND RECOMMENDATIONS 155 8.1. Evaluation of the Proposed Project 156 8.1.1. Impacts Associated with Emissions to Air from the Plant 157 8.1.2. Impacts Associated with the Transportation of AFR to 159 Dudfield Plant 8.1.3. Impacts Associated with the Storage of AFR on Site for a 159 Limited Period 8.1.4. Impacts on the Social Environment 160 8.1.5. Suitability of Waste as an Alternative Fuel Resource 162 8.1.6. Project Benefits 164 8.2. Conclusions 165 8.3. Permit Requirements associated with the Introduction of 165 an AFR Programme at Dudfield Plant

9. REFERENCES 169

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APPENDICES Appendix A: Application for Exemption from Undertaking an Environmental Scoping Study for the Alpha Alternative Fuels and Resources Project Appendix B: Advertisements placed in Regional and Local Newspapers Appendix C: I&AP Database Appendix D: Briefing Paper Appendix E: Minutes of Meetings held with I&APs during the EIA Process Appendix F: Issues Trail Appendix G: Letter from SAHRA Appendix H: Air Quality Specialist Report Appendix I: AFR Management Procedures Appendix J: Environmental Legislation Relevant to the Proposed Alternative Fuels and Resources Project, Dudfield Appendix K: Response from Holcim South Africa Regarding the Use of Hazardous Waste as a Fuel in Cement Kilns Appendix L: Issues Trail: Summary of Issues Raised by I&APs, Comments Received During Review Period And Responses Appendix M: Comments Received during the Review Period for the Draft EIA Report Appendix N: Selected International Studies relating to Dioxin Emissions and Alternative Fuels

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LIST OF TABLES PAGE Table 2.1: Specialist studies undertaken as part of the EIA process 9 Table 3.1: Highest monthly rainfall recorded at Ulco Weather Station 18 (1940 – 2004) Table 3.2: Mean, maximum and minimum temperatures recorded at 18 Koopmansfontein Weather Station (1961 – 1990) Table 3.3: Quality analysis of Bergville borehole water (March 1995) 27 Table 3.4: Water quality analysis from boreholes downstream of the 28 coal stockpile area at Ulco Mine (Umhlaba Environmental Consulting, 2004) Table 3.5: Stack parameters for the Ulco plant under current routine 31 operating conditions Table 3.6: Emission rates for criteria, HCl and VOC pollutants from the 31 stacks at the Ulco plant under current routine operating conditions Table 3.7: Heavy Metal and Dioxin and Furan Emissions from the Kiln 32 for routine operating conditions Table 3.8: The comparison of measured PM10 emissions to permit 33 specifications Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in 33 different districts (refer SABS Code 0103) Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and 45 traditional fuels Table 5.1: Summary of potential impacts on land use, vegetation and 49 heritage sites in the area surrounding the Ulco plant as a result of the introduction of the AFR programme 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 54 associated with the introduction of the AFR programme at Ulco plant Table 5.4: Summary of potential impacts on air quality associated 56 with Ulco plant Table 5.5: 12-hour traffic counts for the R31 for 1996 and 1997, and 62 extrapolated for 2004 Table 5.6: 12-hour E80s per counting station along the R31 64 Table 5.7: Assessment of potential traffic impacts associated with the 66 introduction of AFR at Ulco plant Table 5.8: Summary of potential impacts on the social environment as 74 a result of the introduction of an AFR programme at Ulco plant

List of Tables xx 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 5.9: Potential Significance of Risks associated with the use of 78 AFR posed by Natural Events, Technical Problems and Human Error Table 6.1: Ambient air quality guidelines and standards for sulphur 90 dioxide for various countries and organisations

Table 6.2: Current DEAT NOx guidelines 90

Table 6.3: Air quality standards for nitrogen dioxide (NO2)91 Table 6.4: Air quality standards for inhalable particulates (PM10) 91 Table 6.5: Air quality standards for lead 92 Table 6.6: Air quality standards for benzene 92 Table 6.7: Effect screening and health risk criteria for various 94 substances included in the investigation Table 6.8: Toxicity equivalency factors for dioxins and furans 95 Table 6.9: Unit risk factors from the US-EPA Integrated Risk 97 Information System (IRIS) (as at July 2003) and WHO risk factors (2000) Table 6.10: Permit specifications for stack PM10 emissions 97 Table 6.11: Comparison of EC emission limit values for emissions from 98 co-incineration of waste in cement kilns (Directive 2000/76/EC) and DEAT class 1 incinerator Table 6.12: International emissions data for cement production 101 emissions of dioxins Table 6.13: Stack parameters for the Dudfield Plant for proposed usage 102 of alternative fuels Table 6.14: Emission rates for criteria pollutants from the stacks at the 102 Dudfield Plant for proposed usage of alternative fuels Table 6.15: Heavy Metal and Dioxin and Furan Emissions from the Kiln 103 for proposed usage of alternative fuels (a) Table 6.16: Halogen Compound Emissions from the Kiln for proposed 103 usage of alternative fuels (a) Table 6.17: Maximum offsite concentrations (measured in µg/m³) at 107 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 6.18: Maximum offsite concentrations (measured in µg/m³) at 108 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 6.19: 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)

List of Tables xxi 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 6.20: Significance rating from the baseline study (for all criteria 113 pollutants of concern) Table 6.21: Significance rating from the baseline study (for all non- 113 criteria pollutants of concern) Table 6.22: Significance rating from the proposed usage of alternative 114 fuel (for all criteria pollutants of concern) Table 6.23: Significance rating from the proposed usage of alternative 114 fuel (for all non-criteria pollutants of concern) Table 7.1: Calorific Value of Alternative and Natural Fuels 126 Table 7.2: Categories of waste that can be accepted by Kiln 3 and 134 restrictions by SANS Class Table 7.3: Properties of fuel that can potentially affect product 136 quality, plant operation, health and safety and environment Table 7.4: AFR Specifications and range of acceptable limits of 137 elements (including heavy metals) Table 7.5: Typical Concentrations of Selected Trace Elements in Raw 139 Materials and Coal (mg/kg) Table 7.6: Potential Significance of Risks associated with the use of 146 AFR posed by Natural Events, Technical Problems and Human Error Table 7.7: Minimum Background Monitoring Parameters 151 Table 8.1: Summary of the most relevant permits, licences, 166 certificates and other authorisations required by Holcim South Africa for the introduction of an AFR programme at Dudfield

List of Tables xxii 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

LIST OF FIGURES PAGE Figure 1.1: Drawing illustrating the positions of the undercover and 3 open storage areas adjacent to Kiln 5, Ulco plant Figure 3.1: Locality map indicating the proximity of Ulco to 15 neighbouring towns Figure 3.2: Layout of Ulco plant 16 Figure 3.3: Wind roses recorded at Kimberley Weather Station for the 19 period January 1996 to August 2001 Figure 3.4: Wind frequency graph calculated using wind field data 20 recorded at Ulco Weather Station (Umhlaba Environmental Consulting, 2004) Figure 3.5: Regional geology for the Ulco area 23 Figure 3.6: Water Balance Diagram for Ulco plant and Ulco mine 30 indicating average monthly flow (January – June 2004) Figure 5.1: Aerial photograph illustrating the position of the areas 50 demarcated for the proposed AFR storage areas in relation to Kiln 5 Figure 5.2: Locality map indicating the accessibility of Ulco, the R31 and 61 neighbouring towns Figure 4.1: Schematic representation of the cement manufacture 37 process from sourcing the raw materials to delivery of the final product (Source: Cement Industry Federation, 2002) Figure 4.2: Primary components of Kiln 5 (Holcim, 2004) 39 Figure 4.3: Graphic representation of the three locations where 43 waste-derived fuels can be introduced to Kiln 5 (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: Locality map indicating the accessibility of Ulco, the R31 61 and neighbouring towns Figure 5.3: Position of stations for the twelve-hour daytime classified 63 traffic counts conducted by Department of Transport during 1996 and 1997 Figure 6.1: Wind roses for the period January 1996 to August 2001 87 Figure 6.2: Schematic diagram illustrating air quality management 120 plan development, implementation and review by industrial and mining operations

List of Figures xxiii 09-Nov- Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

LIST OF PHOTOGRAPHS PAGE Photograph 4.1: Burner head illustrating the concentric tubes through 44 which fuel and air is fed into the kiln Photograph 5.1: Photograph illustrating the area demarcated as the 51 undercover storage area (approximately 300 m2) adjacent to Kiln 5 Photograph 5.2: Photograph of the historically disturbed area 51 demarcated as the open storage area (approximately 2000 m2) Photograph 5.3: Pumping in a section of Road D2095 59 Photograph 5.4: Pavement defects at intersection of Road D2095 and 59 D933 Photograph 5.5: Structure Failure on Road P183/1 60

List of Photographs xxiv 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

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

LD50 Lethal dose of a chemical required to kill 50% of a population of experimental mammals LPG Liquefied petroleum gas MAP Mean annual precipitation MJ/kg Mega Joules per kilogram MRLs Minimal Risk Levels MSD Mass selective detector MSDS Material Safety Data Sheet NEMA National Environmental Management Act (No 107 of 1998) ng Nanograms

NO2 Nitrogen dioxide

NOx Oxides of nitrogen NW DACE North West Department of Agriculture, Conservation and Environment NWMS National Waste Management Strategy OEHHA Office of Environmental Health Hazard Assessment PCDDs Polychlorinated dibenzodioxins PCDFs Polychlorinated dibenzofurans pH Acidity PPE Personal Protective Equipment

Acronyms and Abbreviationsxxv 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

PM10 Particulate Matter with an aerodynamic diameter of less than 10 µm PM2.5 Particulate Matter with an aerodynamic diameter of less than 2.5 µm ppm Parts per million RDF Refuse derived fuel SA South Africa SABS South African Bureau of Standards SAHRA South African Heritage Resources Agency SANS South African National Standard

SO2 Sulphur dioxide TIS Traffic Impact Study TOC Total Organic Carbon Tremcard Transport Emergency Card TSP Total Suspended Particulates µg/m³ Micrograms per cubic meter US-EPA United States Environmental Protection Agency VOCs Volatile Organic Compounds WB World Bank WHO World Health Organisation WMD Waste Manifest Document

Acronyms and Abbreviationsxxvi 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

1. INTRODUCTION

1.1. Motivation for the Proposed Project

Introduction 1 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province fuel presents the opportunity to reduce the environmental impacts of using a non-renewable resource (coal) in the cement clinker 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 consistent 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 the energy, as well as the mineral components, from waste. The use of waste-derived fuels in a cement kiln reduces fossil fuel use, and maximises the recovery of energy, without any significant change in emission levels.

1.2. Overview of the existing Ulco Plant and the proposed AFR Programme

1.2.1 Overview of Ulco Plant and Kiln 5

The Ulco plant is situated on a limestone deposit (the primary raw material used in the manufacture of cement) that is mined and milled as feedstock to the plant. Coal is currently utilised for energy generation, and is transported to the plant by rail. Cement is produced by the calcination of limestone using coal as the main energy source for converting the limestone raw meal to form cement clinker (i.e. the base feedstock for cement). This clinker burning takes place at a material temperature of 1 450°C within a rotary kiln (an inclined rotating steel cylinder lined with heat resistant refractory bricks). The kiln currently in operation at Ulco plant was commissioned in 1984, and is known as Kiln 5. This kiln currently produces up to 1 200 000 tons of cement clinker each year.

1.2.2. Infrastructure requirements for the proposed AFR programme

Kiln 5 at Ulco Plant is capable of implementing the technology associated with the acceptance and use of alternative fuels as an energy source, together with coal.

Introduction 2 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province storage area would be required to comprise suitable storage tanks, silos and bunkers in close proximity to the kiln. Two AFR fuel storage areas are proposed to be established within the boundaries of the existing Ulco plant, i.e. an undercover storage area of approximately 300 m2 and an open storage area of approximately 2 000 m2.

The proposed AFR storage areas are located adjacent to the plant within the plant footprint (refer to Figure 1.1) to allow for safe and secure feeding of the AFR material from the storage area to Kiln 5. The demarcated areas have been extensively disturbed through previous use for construction purposes. The sites are devoid of vegetation, and on level terrain.

Figure 1.1 Drawing illustrating the positions of the undercover and open storage areas adjacent to Kiln 5, Ulco plant

Introduction 3 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

1.2.3 Waste-derived Materials which can be utilised as Alternative Fuels

Only those waste-derived fuels that meet the stringent standards set by Holcim and approved by the authorities will, however, be considered and accepted for use in the kiln.

• High temperatures – exceeding 1 400°C (flame temperature ~2 000°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 4 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province scrap, explosives, radioactive wastes, and unsorted municipal garbage) are excluded from the AFR programme.

1.3. Environmental Study Requirements

As the introduction of AFR at Ulco 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 Northern Cape Department of Tourism, Environment and Conservation (NC DTEC) 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 5 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS

2.1. Approach to Undertaking the Study

An Environmental Impact Assessment (EIA) for the proposed AFR project at Ulco plant has been undertaken in accordance with the EIA Regulations published in Government Notice R1182 to R1184 of 5 September 1997, in terms of Section 21 of the Environment Conservation Act (No 73 of 1989), as well as the National Environmental Management Act (NEMA; No 107 of 1998).

In terms of Government Notice R1182 (Schedule 1), the following listed activity which may have an impact on the environment is applicable:

• Scheduled processes listed in the Second Schedule to the Atmospheric Pollution Prevention Act, 1965 (Act No 45 of 1965)

The environmental process undertaken for this proposed project is described below.

2.2. Authority Consultation

2.2.1. Consultation with Decision-making Authorities

Consultation with the Northern Cape Province Department of Tourism, Environment and Conservation (NC DTEC) was undertaken prior to the submission of the application for authorisation for the proposed project. The pre- application consultation meeting was held at the Ulco plant and included a site inspection and presentation of the proposed project by Holcim South Africa. 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 confirmed that NC DTEC 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 NC DTEC. • 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 Investigations6 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

2.2.2. Consultation with Other Relevant Authorities (non-DEAT)

Consultation with non-DEAT authorities was undertaken, including:

• Northern Cape Department of Water Affairs and Forestry (DWAF) • Northern Cape Premier's Office • Northern Cape Department of Health • Northern Cape Department of Transport • Northern Cape Department of Education • Northern Cape Department of Economic Development and Tourism • South African Heritage Resources Agency (Northern Cape Province) • Northern Cape Provincial Government Chief Air Pollution Control Officer (CAPCO) • Northern Cape Department of Roads and Public Works • Northern Cape Department of Housing • Northern Cape Department of Planning and Project Management • Northern Cape Department of Minerals and Energy • Sol Plaatjie Municipality – Kimberley • Frances Baard District Municipality - Kimberley • Dikgatlong Municipality – Barkly West and Delportshoop • South African National Parks (SANParks)

The Northern Cape Department of Water Affairs and Forestry (DWAF) attended the pre-application consultation meeting held at the Ulco plant at the start of the project.

A meeting with key stakeholders was held with provincial authorities in Kimberley on 23 June 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. In addition, two Focus Group Meetings were held with the Dikgatlong Municipality (in Barkley West and Delportshoop) on 22 June 2004 to directly engage the relevant municipal officials. Representatives from SANParks were also consulted at a focus group meeting held at Vaalbos National Park on 22 June 2004.

2.3. Application for Authorisation in terms of Section 22 of the Environment Conservation Act (No 73 of 1989) in respect of an Activity Identified in terms of Section 21 of the said Act

Application for authorisation was lodged with NC DTEC on 8 April 2004. 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.

Scope of Environmental Investigations7 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

2.4. Application for Exemption from Undertaking an Environmental Scoping Study in terms of Section 21 of the Environment Conservation Act (No 73 of 1989)

The proposed project involves the implementation of a known and internationally understood technology within an existing cement plant which is capable of implementing this technology. Therefore, no feasible alternatives exist for this proposed project (i.e. alternative ways in which the same result could be achieved).

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 the EIA Phase only be undertaken. The EIA would comprehensively assess the potential impacts associated with the project, and include a comprehensive public participation process to allow for full public involvement. This application for exemption, as well as NC DTEC’s approval of this exemption application is included within Appendix A.

2.5. Environmental Impact Assessment

The Environmental Impact Assessment (EIA) aims to achieve the following:

• to provide an overall assessment of the social and biophysical environments affected by the proposed project; • to assess the proposed project in terms of environmental criteria; • to identify potential environmental benefits of the project; • to identify and recommend appropriate mitigation measures for potentially significant environmental impacts where needed; and • to undertake a fully inclusive public participation process to ensure that I&AP issues and concerns are recorded.

2.5.1. Specialist Studies

In undertaking the EIA, Bohlweki Environmental were assisted by a number of specialists in order to comprehensively assess the significance of potential positive and negative environmental impacts (social and biophysical) associated with the project, and to propose appropriate mitigation measures where required. These specialist studies are outlined in Table 2.1.

Scope of Environmental Investigations8 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 2.1: Specialist studies undertaken as part of the EIA process Company Field of Study Airshed Planning Professionals Air quality assessment Environmental & Chemical Consultants Assessment of the suitability of waste as an alternative fuel resource, and impacts pertaining to AFR management, storage, transportation etc. Stewart Scott International Assessment of traffic impacts Sustainable Law Solutions Legal review

In order to assess the significance of the identified impacts, the following characteristics of each potential impact were identified:

• the nature, which shall include a description of what causes the effect, what will be affected and how it will be affected; • the extent, wherein it will be indicated whether the impact will be local (limited to the immediate area or site of development) or regional; • the duration, wherein it will be indicated whether the lifetime of the impact will be of a short duration (0–5 years), medium-term (5–15 years), long term (> 15 years) or permanent; • 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.

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2.5.2. Assumptions and Limitations of the Study

The assumptions and limitations on which this study has been based include:

• Assumptions: ∗ All information provided by Holcim South Africa and I&APs to the Environmental Team was correct and valid at the time it was provided. ∗ It is not always possible to involve all interested and affected parties individually. Every effort has, however, been made to involve as many broad base representatives of the stakeholders in the area. An assumption has, therefore, been made that those representatives with whom there has been consultation, are acting on behalf of the parties which they represent.

• Limitations: ∗ The report is prepared within the project-specific nature of the investigations, and consequently the environmental team did not evaluate any strategic alternatives to the AFR project.

2.5.3. Overview of the Public Participation Process undertaken within the EIA Process

The primary aims of the public participation process included:

• 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.

Scope of Environmental Investigations10 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

• 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 “Noordkaap” (Afrikaans) on 26 May 2004, Northern News Digest (Kitsnuus) (Afrikaans) on 28 May 2004, and the Diamond Field Advertiser (English) on 28 May 2004.

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. Ample opportunity was provided for interested and affected parties to become involved in the EIA process.

All I&AP information (including contact details), together with dates and details of consultations and a record of all issues raised were recorded within a comprehensive database of I&APs. This database was updated on an on- going basis throughout the project process (refer to Appendix C).

Consultations were held with individuals, businesses, institutions and organisations, including the following:

* Department Environmental Affairs and Tourism - National * Department of Water Affairs and Forestry – National * Northern Cape Premier's Office * Department of Water Affairs and Forestry – Northern Cape * Northern Cape Department of Tourism Environment and Conservation * Northern Cape Department of Health * Northern Cape Department of Transport * Northern Cape Department of Education

Scope of Environmental Investigations11 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

* Northern Cape Department of Economic Development and Tourism * South African Heritage Resources Agency (Northern Cape Province) * Northern Cape Provincial Government Chief Air Pollution Control Officer (CAPCO) * Northern Cape Department of Roads and Public Works * Northern Cape Department of Housing * Northern Cape Department of Planning and Project Management * Northern Cape Department of Minerals and Energy * Sol Plaatjie Municipality – Kimberley * Frances Baard District Municipality - Kimberley * Dikgatlong Municipality – Barkly West and Delportshoop * South African National Parks (SANParks) * Vaalbos Nature Reserve * Ulco Community and Township * Employees of the Holcim South Africa Ulco Plant * Mine Workers Union (Solidarity) * Northern Cape Mine Managers Association * Northern Cape Business Forum * Agri Northern Cape * Northern Cape Forum * Local Farmers from the surrounding area * Key Non Governmental Organisations (NGO’s) * Community Groups and local businesses * Water Institute of South Africa * Kimberley SAPS and emergency services * 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. This briefing paper was posted on the internet on a webpage dedicated to the EIA process for the project. 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 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

Scope of Environmental Investigations12 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

with stakeholders and I&APs were prepared and forwarded to the attendees for verification of their issues. Copies of the minutes compiled for formal public involvement meetings held during the process (including attendance registers) 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 (22 June 2004 in Ulco at the Alpha Hall and 23 June 2004 in Kimberley 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, registered stakeholders and I&APs were notified of these meetings via letter 10 days prior to the event (i.e. 10 June 2004). In addition, these meetings were advertised within weekly local newspapers, i.e. Northern News Digest (18 June 2004) and Diamond Field Advertiser (17 June 2004) in the predominant languages of the area (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. These included meetings with the Dikgatlong Municipality – Barkly West and Delportshoop. 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 South Africa. 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. In addition, the meeting allowed for the transfer of relevant and specific technical information, and aimed to

Scope of Environmental Investigations13 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

provide clarity on issues of concern ahead of the release of the draft EIA Report. Key stakeholders were invited to attend this meeting by letter (refer to Appendix B). Copies of the minutes compiled are included within Appendix E.

• Social Issues Trail: All issues, comments and concerns raised during the public participation process of the EIA process were compiled into a Social Issues Trail (refer to Appendix F). These issues formed the basis of the Social Impact Assessment (SIA).

2.5.4. Review of the Draft Environmental Impact Assessment Report

The draft EIA report has been made available for public review and comment at the following public locations:

• Ulco Public Library, Ulco • Holcim South Africa Ulco Plant • Dikgatlong Public Library, Barkly West • Kimberley Public Library, Kimberley • Offices of Bohlweki Environmental, Midrand • www.bohlweki.co.za

A 30-day period will be allowed for this review process. The availability of this draft report was advertised in the Northern News Digest and Diamond Field Advertiser in the predominant languages of the area. I&APs registered on the project database were notified of the availability of this report by letter (refer to Appendix B).

2.5.5. Final Environmental Impact Assessment Report

The final stage of the EIA process will entail the consideration and inclusion of all relevant comments received from the public on the draft EIA Report within a final EIA report. This final document will be submitted to NC DTEC for Authority review and authorisation.

Scope of Environmental Investigations14 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

3. DESCRIPTION OF THE EXISTING ULCO PLANT AND THE SURROUNDING ENVIRONMENT

The Holcim South Africa Ulco plant is located on Lot 1 of Erf 1 and 2 of Farm Harison GR109/1936 (Delpoortshoop commonage). Ulco plant is located approximately 1 km north east of the Ulco township, 17 km north west of Delportshoop, 24 km south east of Koopmansfontein, 42 km north west of Barkly West, and 80 km north west of Kimberley in the Northern Cape Province (refer to Figure 3.1). The plant is accessible along the R31 between Kimberley and Kuruman. The Vaalbos National Park (VNP) lies approximately 10 km north west of Delportshoop.

Figure 3.1 Locality map indicating the proximity of Ulco to neighbouring towns

3.1. The Existing Ulco Plant and Kiln 5

The Ulco 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 estimated remaining life of mine for current mining activities is estimated at 50 years. Coal is transported by rail to the plant and is the main energy source used in the kiln for converting the limestone raw meal to cement clinker, the base feedstock for cement.

Description of the existing Ulco15 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Ulco Plant was originally established by the Union Lime Company in 1936, and cement has been produced at the plant since 1949. Kilns 1, 2, 3 and 4 have been decommissioned. The kiln (known as Kiln 5) currently in operation at Ulco was constructed in 1984, and produces up to 1 200 000 tons of clinker each year. The design of Kiln 5 allows for the acceptance and use of alternative fuels as an energy source together with coal. Details of the cement manufacturing process are provided in Chapter 4.

Ulco Kiln 5 currently comprises a vertical raw mill, a cyclone pre-heater and calciner, a rotary kiln ~70 m in length (inclined rotating steel cylinder lined with heat resistant refractory bricks), clinker cooler, and a firing system. Kiln dust emissions are controlled by an electrostatic precipitator with a particulate emission limit of 150 mg/Nm3, vented to the atmosphere via a stack at a height of 110 m above ground level.

In addition to the kiln infrastructure at Ulco 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. The layout of the Ulco plant is illustrated in Figure 3.2.

1 Conveyor from raw 6 Quality assurance 11 Main administration material stockpiles laboratory buildings 2 Raw mill and raw meal silo 7 Stores 12 Cement silos 3 Pre-heater and calciner 8 Plant administration 13 Packing plant buildings 4 Rotary kiln 9 Cement mill 14 Rail yard and rail dispatch 5 Clinker cooler 10 Clinker silo 15 Access road to plant Figure 3.2 Layout of Ulco plant

Description of the existing Ulco16 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

3.2 Climate

The climatic data for the area has been compiled from three sources: • Ulco Weather Station: Rainfall information is available for the period 1940 to 2004. Daily temperature, and wind speed and direction have only been recorded at this weather station since July 2003. • Koopmansfontein AGR II Weather Station (Station No. 0323102 6): Located approximately 20 km north west of the plant. Historical data is available from this weather station for the period 1961 to 1990. No wind data is available for this station. • Kimberley Weather Station: recorded wind data has been obtained from the Kimberley South African Weather Services station. As the general topography between Ulco and Kimberley is flat, it has been assumed that the wind data recorded at Kimberley would be representative for Ulco.

3.2.1 Regional Climate

The regional climatic conditions are representative of those of a typical Karoo climate, with a high daily maximum temperature throughout the year and a low minimum temperature at night during the winter months. The rainy season extends from November to April, with the wettest months being December to March.

3.2.2 Rainfall

Rainfall in the area surrounding the Ulco plant occurs predominantly in the summer months (that is, November to April). Annual rainfall recorded at the weather station at Ulco averages approximately 385 mm. Table 3.1 below indicates the highest monthly rainfall recorded at Ulco Weather Station for the period 1940 to 2004.

3.2.3 Temperature

Mean annual air temperatures recorded at Koopmansfontein Weather Station range from 9,2°C in June and July to 23,7°C in January. Average daily maxima range from 18,1°C to 31,6°C, and average daily minima range from –0,3°C to 15,7°C (Weather Bureau, 2004). At Ulco, summer maximum temperatures of 38,5oC can be experienced.

Description of the existing Ulco17 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 3.1: Highest monthly rainfall recorded at Ulco Weather Station (1940 – 2004) Month Highest monthly rainfall recorded (mm) January 263 February 320 March 332 April 162 May 74 June 66 July 49 August 108 September 90 October 128 November 117 December 264

Table 3.2: Mean, maximum and minimum temperatures recorded at Koopmansfontein Weather Station (1961 – 1990) Temperature (°C) Month Maximum Minimum Mean January 31.6 15.7 23.7 February 30.0 15.1 22.6 March 27.9 13.1 20.5 April 24.5 8.8 16.7 May 21.3 3.8 12.6 June 18.1 0.3 9.2 July 18.6 -0.3 9.2 August 21.1 1.7 11.4 September 25.2 6.0 15.6 October 27.6 9.4 18.5 November 29.8 12.2 21.0 December 31.4 14.2 22.8

3.2.4 Evaporation

Monthly evaporation data measured by the Class-A-Pan Evaporation method was available from the Koopmansfontein Weather Station located approximately 20 km north west of the plant. The mean annual evaporation recorded at this weather station is 2 553 mm. The rate of evaporation considerably exceeds the mean annual rainfall for the area, resulting in the dry conditions experienced.

Description of the existing Ulco18 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

3.2.5 Wind Data

As no wind data were available from Koopmansfontein, information has been obtained from the South African Weather Services station in Kimberley. As the general topography between Ulco and Kimberley is flat, it has been assumed that the wind data recorded at Kimberley will represent a similar pattern for Ulco. Wind field data recorded at Ulco since July 2003 has been compared with the Kimberley data.

The dominant wind direction recorded at Kimberley Weather Station is from the north with a 22% frequency of occurrence. Wind speeds of between 10–15 m/s are recorded from this dominant wind direction with few calm periods of 6,5%. Increased wind frequencies from the north-westerly sector are noted for daytime hours with calm periods of 3,2% occurring. Nocturnal airflow is characterised by more frequent winds from the north-north-east. Night-times have an increase in calm periods (10,1%) as is typical of the night-time flow regime in most regions (refer to Figure 3.3).

Figure 3.3: Wind roses recorded at Kimberley Weather Station for the period January 1996 to August 2001

Description of the existing Ulco19 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

From the 11-month data set recorded at Ulco, it is evident that the dominant wind direction experienced is from the west-north-west to north-western sector (300°). Gusts of more than 8,8 m/s were also recorded from these sectors (300° and 310°). Overall, the wind speeds recorded at Ulco are lower than those recorded at Kimberley, with wind speeds greater then 5,7 m/s not being recorded from the north-eastern sector, through the south-eastern quadrant to the south- south-western sector (refer to Figure 3.4).

The primary difference between the wind field data recorded at Kimberly and Ulco is the dominant wind direction. Although this may be a variation between the two sites, given Ulco’s proximity to the Ghaap escarpment to the west, it must be noted that the wind field data for Ulco has only been recorded for an 11 month period. Over an extended monitoring period, the dominant wind direction may vary. Overall, the frequency and strength of the winds recorded at both stations show similar trends.

Figure 3.4: Wind frequency graph calculated using wind field data recorded at Ulco Weather Station (Umhlaba Environmental Consulting, 2004)

3.2.6 Extreme Weather Conditions

The extreme weather conditions in this area are limited to extremes in temperature variations, thunder and hail. Monthly maximum and minimum temperatures can vary up to 30° for example, the maximum and minimum temperatures recorded at Ulco during July 2003 were 27°C and -1°C and during

Description of the existing Ulco20 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

August 2003 were 31°C and -5°C. In Koopsmanfontein, thunderstorms are experienced on average 39,1 times per year, with the majority of these occurring between the months of October and April. Hail occurs on average 1,6 times per year.

3.3 Topography

Ulco plant is situated in an area which is predominately flat terrain, with two prominent base levels, namely one below the Ghaap escarpment to the west of Ulco, and the Ghaap Plateau. The edge of the scarp trends in a north-east south- westerly direction, and reaches a maximum exposed height of 100 m some distance south of Ulco. At Ulco and its surroundings, the height of the scarp averages 75 m to 80 m, being near vertical except where secondary limestone deposits drape over it such as the Bergville-Harrison quarry area.

Beneath the escarpment, the terrain drops gently away from the Ulco township and Ulco plant area at a gradient of ~1:110 (i.e. 90 m over 10 km) eastwards down to the confluence of the Harts and Vaal rivers. West of the sharp scarp, the Ghaap Plateau rises at an average gradient of 1:60 (122 m in 7 km) in a westerly direction. Small gently rounded hillocks of up to 15 m in height occur on the escarpment which is incised by many intermittent streams, especially at the escarpment edge.

The natural topography of the immediate area has been significantly altered by mining activities of the Ulco limestone mine which is located adjacent to the plant. The Ulco mining operation and the mining activities have lowered the topography of mined-out areas.

3.4 Geology

The area surrounding the Ulco plant is underlain by rocks of the Transvaal, Ventersdorp, and Karoo Supergroups which are tertiary to recent secondary deposits (refer to Figure 3.5). Mainly carbonate rocks predominate, together with surficial deposits, lavas, and sub-ordinate shales and dolerites.

Dominating the western portion of the area is the Griqualand West Sequence of the Transvaal Supergroup that discordantly overlies the uneven paleofloor of the Ventersdorp lava. Two stratigraphic units, the Campbell Group and Vryburg Formation of the Griqualand West Sequence outcrop in the area in which Ulco is located.

Outcropping prominently in the western to north western portion of the area, forming the prominent Ghaap Plateau is the rock sequence comprising the Ulco member of the Ghaap Group (Transvaal Supergroup – Campbell Rand Sub-

Description of the existing Ulco21 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Group). The Ulco member is estimated to comprise some 220 m thickness of the estimated 900 to 1 600 m total thickness of the Ghaap formation. This member is comprised of fine, crystalline dolomite with limestone lenses occurring prominently at the base. Thin, often highly irregular layers and lenses of chert, as well as prominent, highly developed and characteristic, stromatolytic layers occur in the Ulco member.

The Ghaap Plateau formation rests comfortably on the Schmidtsdrift Sub-Group. However, this Sub-Group does not outcrop in the area surrounding the plant, probably due to the extensive cover of Karoo rocks, particularly calcretes/tufas. However, the formation is known to exist within the broader area as it has been intersected by boreholes. Shale sequences dominate the Schmidtsdrift formation which is also characterised by facies changes and great variations in thickness of member units.

The lithologically transitional Schmidtsdrift formation rests on the underlying Vryburg formation which represents a beach deposit on an uneven floor of Allanridge lava. These rocks outcrop in 'windows' in the Delportshoop allotment area relatively close to the course of the Vaal River. This formation comprises mainly of quartzites, grits, siltstones and shales, and is highly variable and subject to rapid facies changes. Subordinate lenses of limestone occur towards the top of this sequence increasing in frequency, extent and persistence the higher in the sequence. The thickness of this formation varies between 30 m to 40 m in this area.

Exposed in the quarry excavations at Ulco mine is a thick sequence of Dwyka shales which have been intruded by various irregular dolerite intrusions. This shale sequence exceeds 65 m in thickness. The dolerites outcrop in the northern to north eastern portions of the area surrounding Ulco. Shale together with dolerite outcrops further to the north-east.

The only fault which has been recorded as intersecting the Ulco mine and extending beyond the property boundary is the fault that follows the Ghaap Escarpment.

3.5 Soils

The area surrounding the Ulco plant is characterised by “lime generally present in the entire landscape" (soil type Fc). Soil in the area is not abundant and soil depth varies over the area from 0 cm to a maximum of 30 cm. In some areas the only soil is constituted by pockets of wind blown sand only, with limited vegetation occurring.

Description of the existing Ulco22 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Figure 3.5 Regional geology for the Ulco area

Description of the existing Ulco 23 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

The natural soil of the area, which influences the vegetation type present on the soil, is of poor agricultural quality. Any alteration or disturbance of the chemical and physical properties of the natural soil will encourage vegetation growth which is not endemic to the area.

3.6 Land Use and Surface Infrastructure

Historically the area surrounding the Ulco plant was utilised by San inhabitants for resources such as water and food. Prior to the undertaking of mining activities within the area, the land was used for grazing of livestock such as cattle, goats and sheep. Since the commencement of mining in the area in 1936, grazing remains the predominant use (approximately 85%) of the immediate surrounding land (within a 6 km radius from Ulco), with the remainder of the land use being demarcated as a wilderness area (i.e. the Ghaap plateau).

The limestone mining operation is located adjacent to the plant, and extends to the north and west.

Ulco is accessible via the R31 between Kimberley and Kuruman. Access to the Ulco plant for all vehicles is via the tarred secondary road to Ulco town, and the main access road to the plant.

Ulco operates a 16 km railway branch line from the Ulco Station to the mine siding. This railway line is used extensively for the transport of coal to the plant and cement product from the plant.

Power to Ulco is supplied via an Eskom substation, located near the entrance to Ulco Mine. This substation supplies power to the cement manufacture plant, the mine and the Ulco Village.

The entire plant area is concreted or paved. Stormwater runoff is directed to stormwater drains which flow off the plant area directly into the natural vegetation surrounding the plant.

The Ulco Village lies to the south west of the plant. Holcim employees reside in the village, which comprises houses, schools, recreation and sports facilities, health care and commercial facilities. The Ulco sewage works and the Ulco water purification works service the village, the plant and the mine.

3.7 Flora

The Ulco plant falls on the boundary (transitional zone) between the Kimberley Thorn Bushveld (from the Ghaap escarpment Eastwards) and the Kalahari Plateau Bushveld (Ghaap escarpment and plateau). The Ghaap plateau and escarpment

Description of the existing Ulco24 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province is physiographically and geomorphologically distinct from the plains, therefore flora composition of these areas is distinct.

The vegetation of the Kalahari Plateau Bushveld of the Ghaap plateau grows on calcareous tufa, dark brown to red sands and acid gravels, underlain by dolomite. Calcareous pans or shallow depressions support plant species especially adapted to survive in pan habitats, a number of which are range-restricted endemics such as Ruschia lawsonii. The vegetation is composed of a relatively dense bushveld consisting of shrubs with some tall trees and tree clumps, in mixed grassland.

Along the escarpment there is a transition from the Kalahari Plateau Bushveld of the Ghaap plateau to Kimberley Thorn Bushveld, with elements of both vegetation types present. The kloofs are composed of dense woodlands, with characteristic plant species associated with sheltered habitats. These include certain lichens and mosses, a number of herbs, and large shrubs and trees.

The vegetation of the Kimberley Thorn Bushveld of the plains is found on sandy to loamy sands underlain by calcrete. It is an open savannah to closed woodland dominated by Acacia tortilis (Umbrella Thorn), with Acacia erioloba (Camel Thorn Trees) occurring on deep red sands, and scattered individuals of Boscia albitrunca (Shephard’s Tree) and Acacia karroo (Sweet Thorn). Dwarf shrubs are common on the dolerite hills.

Most of the vegetation in the area surrounding the Ulco plant has been extensively disturbed as a result of agricultural and mining practices. As a result, no rare or endangered flora species are anticipated to occur within the immediate vicinity of the Ulco plant.

Invasive plant species have recently been recorded in the vicinity of the Ulco plant (Umhlaba Environmental Consulting, 2004), including Mesquite (Prosopis glandulosa), Russian Tumble Weed (Salsola Kali), Wild Tobacco (Nicotiana glauca), Fountain Grass (Pennisetum setaceum), Red River Gum (Eucalyptus camaldulensis) and Pepper Tree (Schinus molle).

3.8 Fauna

As a result of the disturbance to habitats in the immediate vicinity of the Ulco plant due to agricultural and mining activities, the occurrence of natural fauna is limited. However, a diversity of fauna is found in the ravines on the edge of the escarpment, and extending in some instances to the active quarry areas. Common species include Kudu and smaller buck such as duiker. Jackal, baboons and possibly caracal also frequent this area. A large population of dassies has been recorded in the area adjacent to the mine dumps. A wide variety of birdlife has been recorded in the area, including the Goshawk, Rock Kestrel and Black

Description of the existing Ulco25 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Eagle. No rare or endangered fauna species have been recorded in the area, largely as a result of the disturbed nature of the available habitats (Umhlaba Environmental Consulting, 2004).

3.9 Surface Water

The Ulco plant is located within the Quaternary sub-catchment C92A (Water Research Commission, 1990). The plant and mine lie approximately 9 km north west of the confluence of the Vaal and Hartz Rivers, and approximately 3,5 km north of the non-perennial Steenbok River, which flows over the Ghaap escarpment at Grootkloof (Umhlaba Environmental Consulting, 2004). A number of seasonal stream beds, which only flow for short periods after a heavy downpour, occur in the vicinity of the Ulco plant. As the Ulco plant falls within a local endoreic area (i.e. an area where runoff usually does not reach the river system), it is not anticipated that run-off from Ulco will flow into the Vaal River (Water Research Commission, 1990). All stormwater runoff is directed to stormwater drains which flow off the plant area directly into the natural vegetation surrounding the plant.

3.10 Geohydrological Conditions

The Weltevrede and Kneukel Dykes traversing the region dam the water behind the escarpment, which results in the occurrence of springs in the area. The average depth of the water table in the vicinity of Ulco is 23 m, with the shallowest being 18 m and the deepest being 84 m.

The quality of the water abstracted from boreholes in the area is not used for continuous human consumption as it is hard, and has a high electro-conductivity. It is for this reason that borehole water is only used for gardening and dust suppression purposes. The quality of a water test conducted in March 1995 is indicated in Table 3.3.

Holcim South Africa monitors the quality of the water from three boreholes which are 'downstream' (south east, as determined by the groundwater flow model) of the coal stockpile area. Recently, two additional boreholes have been drilled and tested. The summarised quality of the water tested from these boreholes are presented in Table 3.4.

A flow model conducted for Ulco Mine indicates that groundwater flows from north-west to south-east. It is estimated that groundwater flows/migrates at 1 m/annum. The source for groundwater recharge in the vicinity of Ulco is rainfall. A conservative estimate of recharge is 8% of the annual rainfall, i.e. 8% of 385 mm is 30,8 mm. This translates to 308 m3/ha/annum (i.e. 30 800 m3/km2/annum) (Umhlaba Environmental Consulting, 2004).

Description of the existing Ulco26 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 3.3: Quality analysis of Bergville borehole water (March 1995) Ideal maximum for Element BG1 BG2 BG3 drinking water (Class 0) Total Alkalinity mg/ℓ 478 496 493 Calcium mg/ℓ 92 91 98 80 Calcium Hardness mg/ℓ 230 227 245 Chloride mg/ℓ 50 44 42 100 Electrical Conductivity 101 104 106 70 Magnesium mg/ℓ 87 83 85 30 Magnesium Hardness mg/ℓ 358 342 350 pH 7.24 7.47 7.3 6 - 9 Sodium mg/ℓ 2.4 2.6 2.4 100 Nitrite mg/ℓ 23 26 23 6 Sulphate mg/ℓ 41 39 39 200 Total Hardness mg/ℓ 588 569 595 20 – 300 Nitrate as mg/ℓ 0.1 5.2 4.9 6 Carbonate mg/ℓ 111 Bi-carbonate mg/ℓ 582 603 600 Dissolved solids 707 728 742 450 Fluoride mg/ℓ 0.35 0.33 0.32 0.7 Langelier index mg/ℓ 0.37 0.61 0.47 >0

3.11 Water Consumption at the Ulco Plant

All water consumed at the Ulco plant is sourced either from the Vaal River or groundwater extracted from boreholes. Water from the Vaal River is purified at the on-site water purification plant and is utilised for processing purposes and for potable water. Borehole water is used for watering gardens and dust suppression. On average, approximately 38 300 m3 per month of water from the extraction from the Vaal River supplies the water requirements of the Ulco plant. In addition, approximately 2 000 m3/month purified water is utilised as potable water by the plant. Figure 3.6 illustrates the water flow/balance for Ulco plant and Ulco Mine for the period January – June 2004.

Process water supply is limited to use by the conditioning towers, where preheater gas temperatures are reduced, as well as for cement mill and raw mill cooling. Water loss is through evaporation.

Description of the existing Ulco27 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 3.4: Water quality analysis from boreholes downstream of the coal stockpile area at Ulco Mine (Umhlaba Environmental Consulting, 2004) Total Manganese alkalinity EC Sulfate Nitrate Calcium Magnesium Sodium Fluoride Chloride pH Iron (Mn) as CaCO3 mS/m mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l Class 0 (Ideal) <70 6 - 9 <200 6 <0.010 <0.050 80 30 100 0.7 100 Class 1 (Acceptable) <150 5.5 - 9.5 <400 10 <0.200 <0.1 150 70 200 1 200 Class 2 (max allowed) <370 <4 - >10 <600 20 <2.000 <1 300 100 400 1.5 600 January 2002 CS-BH-1 353 86 7.87 55 5.07 0.024 0.019 68 65 21 38 CS-BH-2 366 89 8.00 69 4.60 0.012 0.019 76 66 21 36 CS-BH-3 384 83 7.82 2.8 0.05 0.091 1.081 60 34 83 54 February 2002 CS-BH-1 376 85 7.73 56 5.52 0.019 0.014 69 62 21 0.26 30 CS-BH-2 412 85 7.61 21 1.56 0.024 0.437 59 32 82 0.24 37 CS-BH-3 393 85 7.50 42 3.03 0.022 0.018 75 63 22 0.17 33 March 2002 CS-BH-1 369 83.9 7.50 54 5.55 0.014 0.013 68.4 69.1 22 0.25 34 CS-BH-2 379 87.3 7.75 66 4.91 0.015 0.015 73.2 68.4 22 0.23 32 CS-BH-3 394 81.3 7.71 1.5 0.07 0.033 0.744 56.4 34.2 82 0.12 48 April 2002 CS-BH-1 375 84.1 7.38 53 5.28 0.049 0.015 73 73 21 0.20 33.2 CS-BH-2 390 88.1 7.54 66 4.91 0.034 0.012 82 74 22 0.17 32.1 CS-BH-3 397 80.4 8.07 2 0.07 0.228 0.877 61 34 88 0.14 48.3 May 2002 CS-BH-1 355 83.2 7.29 54 4.74 0.065 0.011 68.1 65.1 22 0.27 34 CS-BH-2 409 91.1 7.57 66 4.38 0.020 0.011 84.4 70.3 22 0.23 34 CS-BH-3 368 77.8 7.99 6.9 <0.045 0.071 0.881 58.4 30.4 78 0.11 48 January 2003 CS-BH-1 368 82.1 7.64 54.93 0.12 0.085 0.011 70 61 20.8 0.33 35.08 CS-BH-2 394 86.8 7.56 63.32 5.79 0.091 0.009 78 62 20.3 0.29 33.94 CS-BH-3 375 84.6 7.80 43.38 0.17 0.170 0.504 66 38 71.4 0.10 58.2

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Table 3.4 cont: Water quality analysis from boreholes downstream of the coal stockpile area at Ulco Mine (Umhlaba Environmental Consulting, 2004)

Total Manganese alkalinity EC Sulfate Nitrate Calcium Magnesium Sodium Fluoride Chloride pH Iron (Mn) as CaCO3 mS/m mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l August 2003 CS-BH-1 353 77.5 7.57 53.8 5.90 0.008 0.007 71 74 21 0.24 36.1 CS-BH-2 369 84.6 7.77 63.8 5.97 0.007 0.016 78 73 23.5 0.34 35.6 CS-BH-3 345 77.6 7.50 58.4 0.71 0.007 0.219 70 45 72.9 0.27 56.9 March 2004 CS-BH-1 360 83 8.08 52.0 3.99 0.016 0.339 72 60 22 0.34 32.0 CS-BH-2 411 92 8.02 59.0 4.39 0.007 0.008 84 69 21 0.28 32.0 CS-BH-3 352 88 8.23 72.0 0.25 0.008 0.207 69 45 61 0.14 53.0 ASHDUMP: BH-1 385 107 7.70 149.0 7.68 0.017 0.031 107 65 34.0 0.21 47.0 ASHDUMP: BH-2 599 134 7.15 84.0 0.97 0.012 0.134 128 93 40 0.37 80.0

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Figure 3.6: Water Balance Diagram for Ulco plant and Ulco mine indicating average monthly flow (January – June 2004)

Description of the existing Ulco 30 9-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

3.12 Air Quality

Evidence of dust pollution within the area surrounding the Ulco plant is associated with local mining and agricultural activities, as well as the operation of the plant.

Under routine operating conditions, the primary constituents of emissions from

the kiln or cement mills consist of sulphur dioxide (SO2), oxides of nitrogen (NOx),

inhalable particulate (PM10), carbon monoxide (CO) and carbon dioxide (CO2) from the kilns, and PM10 emissions from the cement mills. Information regarding the stack parameters and emission rates is presented in Table 3.5.

Table 3.5: Stack parameters for the Ulco plant under current routine operating conditions Temperature Exit Velocity Source Height (m) Diameter (m) (°C) (m/s) Kiln 110 4.5 115.6 11 Cement Mill 5 50 1.25 96 2 Cement Mill 6 50 1.5 98 2 Raw Mill* 110 4.5 115.6 11 Coal Mill 50 1.4 85 7.2 * The emissions are diverted to the kiln stack.

Particulate matter, heavy metals, and dioxin and furan emissions from the Kiln were monitored by C & M Consulting Engineers (2002) for current routine operating conditions. Volatile organic compounds (i.e. benzene and toluene) were measured during a monitoring study carried out by C & M Consulting Engineers during March 2003. These results were from a first baseline test and should be considered as preliminary. During a more recent study undertaken by

C & M Consulting Engineers (for the period September 2004) HCl, CO, SO2, NO2, and NO emissions were measured (refer to Table 3.6 and Table 3.7 below).

Table 3.6: Emission rates for criteria, HCl and VOC pollutants from the stacks at the Ulco plant under current routine operating conditions Emissions measured in (g/s) Averaging Source (3) (3) (3) (3) (3) Ben- Tolu- period PM10 NO NO2 CO SO2 HCl zene(2) ene(2) Hourly 104 10 133 0.7 12 Kiln Daily 15*(1) 80 5 70 0.3 4 0.9 0.8 Average 69 4 50 0.2 2 Hourly Cement Daily 0.1 ------Mill 5 (4) Average Hourly Cement Daily 1.8 ------Mill 6 (4) Average

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Emissions measured in (g/s) Averaging Source (3) (3) (3) (3) (3) Ben- Tolu- period PM10 NO NO2 CO SO2 HCl zene(2) ene(2) Hourly Coal Mill (5) Daily 1.8 ------Average * These emissions are an average over a day from the kiln stack taking into account that the raw mill runs for approximately 18-20 hours of the day and the kiln runs for 24 hours of the day. (1) Monitored data (for the period 2002) provided by Holcim South Africa (2) Monitored data (for the period March 2003) provided by Holcim South Africa (3) Monitored data (for the period September 2004) provided by Holcim South Africa (4) Estimated data provided by Holcim South Africa. (5) Emissions based on permit specifications.

Table 3.7: Heavy Metal and Dioxin and Furan Emissions from the Kiln for routine operating conditions (a) Compound Emission (g/s) Beryllium 3.8 x 10-7 Vanadium ND Total Chromium 1.4 x 10-3 Manganese ND Cobalt 1.3 x 10-4 Nickel 3.2 x 10-4 Copper 6.8 x 10-4 Arsenic 5.3 x 10-5 1. Silver 9.9 x 10-5 Cadmium 1.6 x 10-6 Antimony 3.6 x 10-5 Barium 1.9 x 10-4 Mercury 2.3 x 10-6 Thallium 1.1 x 10-3 Lead 6.7 x 10-4 Dioxin Toxic Equivalence 4.6 x 10-9 ND: Not detected (a) Monitored data (for the period 2002) provided by Holcim South Africa

Table 3.8 provides a comparison between PM10 emissions provided by Holcim South Africa (for the Kiln and Raw Mill, Cement Mill 5, Cement Mill 6, and the Coal Mill), and the provisional permit specifications (according to the Atmospheric Pollution Prevention Act (APPA) Scheduled Process No. 22). It should be noted

that the current PM10, SO2 and NO2 emissions do not exceed permit specifications.

Description of the existing Ulco32 09-Nov-04 Plant and the Surrounding Environment Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Table 3.8: The comparison of measured PM10 emissions to permit specifications Permit Emissions Current Emissions Appliance % Exceeded (mg/Nm³) (mg/Nm³) Kiln and Raw Mill 150 120 N/E Cement Mill 5 150 30 N/E Cement Mill 6 150 115 N/E Coal Mill 150 150 N/E N/E: Not exceeding

3.13 Noise

The area surrounding the Ulco plant has a low population density and is characterised as a rural area. The Ulco plant and mining area is characterised as an industrial area.

Typical rating levels for ambient noise in the different districts are set out in Table 2 of the South African Bureau of Standards (SABS) Code of Practice 0103 for “The measurement and rating of environmental noise with respect to annoyance and to speech communication”. This code covers a method of measurement and assessment of noise to determine the suitability of an environment with respect to possible annoyance (i.e. whether complaints could be expected). Typical outdoor rating levels, Lr, in dBA are provided in Table 3.9.

Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in different districts (refer SABS Code 0103) Night- Type of district Daytime Evening time Rural 45 40 35 Suburban with little road traffic 50 45 40 Urban 55 50 45 Urban with some workshops, with business premises & 60 55 50 main roads Central business 65 60 55 Industrial 70 65 60

Noise generated by the Ulco plant emanates primarily from the fans, with intermittent noise as a result of blasting activities at the adjacent limestone mine/quarry. Noise levels at the plant are within the limits, as specified in the SABS code, at the boundary of the plant. The Ulco Village is the closest residential area to the plant. Noise from the plant and mine is audible at night, and can be considered to be a disturbance at times (mainly as a result of the mine and train shunting) (Umhlaba Environmental Consulting, 2004).

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Ambient noise levels in the area surrounding the Ulco plant are generally typical of those associated with rural agricultural activities.

3.14 Visual Aspects and Aesthetics

The natural topography of the study area is generally flat, particularly to the south and south east. The residential area in the immediate vicinity of the Dudfield plant is limited to the Ulco 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 45 km.

3.15 Sites of Archaeological, Cultural or Historical Interest

No sites of archaeological, cultural or historical interest are known to occur in the area immediately surrounding the Ulco plant. Two areas in the greater surrounding area have been identified as being of potential archaeological importance (Morris, 1999), however these are beyond the present an future areas to be affected by activities at Ulco (refer Appendix G). These were identified by an archaeological and cultural survey conducted by the McGregor Museum in August 1999, with excavations tentatively planned for 2005 (Morris, 2004):

• Gorrokop: Later Stone Age and Middle Stone Age material was found on the surface in the general vicinity of springs at the crest of the escarpment (more than 3 km from the current active Ulco mining operation). A grave (dated 1894) is located in close proximity to the springs.

• Grootkloof: Stone artefacts were recorded on the slopes of the escarpment in the vicinity of the hut built by the mine manager in 1963. On the southern side of the kloof, which is conserved by the mine as a nature reserve, three localities containing finger paintings of exceptional quality have been identified. These paintings are well preserved and are amongst the most elaborate of their kind along the Ghaap escarpment (Morris, 1999).

3.16 Regional Socio-economic Structure

Ulco plant falls with in the Dikgatlong Municipality, which forms part of the Frances Baard District Municipality of the Northern Cape. The local municipality area measures 2 377,6 km2 in extend and comprises of Barkly West, Delportshoop, Windsorton, as well as a part of the former Diamantveld District Council now the Frances Baard District Municipality. The Dikgatlong area of jurisdiction consists of 7 wards of which Ulco falls within Ward 6 (IDP Dikgatlong Municipality, 2003).

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The Ulco village is located approximately 1 km south west of the operation and is predominantly utilised by the employees from the Ulco plant. Services not available in Ulco village can be accessed in Delportshoop, which is located approximately 17 km from Ulco. Two junior schools are available in Ulco, with a high school in Delportshoop and Kimberley. Other facilities in Ulco include a clinic and sport facilities.

3.16.1 Population Density

The population of Dikgatlong Municipal area is 36 947 and represents 11,35% of the Frances Baard District Municipality and 4,4% of the Northern Cape (IDP Dikgatlong Municipality, 2003). Of the population groups in Ward 6, coloured are the most predominant, followed by African, and then Whites. The population of Ward 6 is concentrated within Delportshoop and Ulco.

3.16.2 Major Economic Activities

Ulco plant is situated on the growth corridor between Kimberley and Postmasburg. The major economic activities in the area, apart from the Holcim Ulco plant, are the diamond digging operations along the Vaal River and the farming operations in the area. As of April 2004, Ulco employs 199 permanent staff members and 173 contractors which vary throughout the year (Umhlaba Environmental Consulting, 2004).

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4. OVERVIEW OF THE CEMENT MANUFACTURING PROCESS

The basic chemistry of the cement manufacturing process begins with the decomposition of limestone or calcium carbonate (CaCO3) at approximately 900°C to leave calcium oxide (CaO, lime) and gaseous carbon dioxide (CO2). This process is known as calcination. This is followed by the clinkering process, in which the calcium oxide reacts at high temperature (typically 1 400 - 1 500°C) with silica, alumina, and ferrous oxides to form the silicates, aluminates, and ferrites of calcium. The resultant product, called cement clinker is then ground or milled together with gypsum and other additives to produce cement.

4.1. Cement Manufacturing Process at Ulco Plant

Ulco Kiln 5 has a current production rate of approximately 1 200 000 tons of clinker per year. The operation utilises dry process technology. Dry process technology is the most modern technology in cement manufacture.

Ulco Kiln 5 currently comprises a vertical raw mill, a cyclone pre-heater and pre- calciner, a rotary kiln ~70 m in length (inclined rotating steel cylinder lined with heat resistant bricks), clinker cooler, and a firing system. Kiln dust emissions are controlled by an electrostatic precipitator with a design particulate emission limit of 150 mg/Nm3, vented to the atmosphere via a stack with a height of 110 m.

The cement manufacturing process can be divided into three stages, namely preparation of raw materials, clinker production in the kiln, and clinker grinding after the kiln. Figure 4.1 provides a schematic representation of the cement manufacture process from sourcing the raw materials to delivery of the final product.

4.1.1. Preparation of Raw Materials

Limestone is the major raw material used to produce cement, and at Ulco 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'.

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Clinker Production Cement grinding and distribution 5 – Raw Mill 8 – the Kiln Precise proportions of Raw materials are 9 – Clinker Cooler 11 - Cement Mill the raw materials are further heated to 2 - Transport Clinker is discharged Clinker, with the blended and milled to 1450°C in the rotary Raw materials are from the kiln at addition of gypsum a fine powder (‘raw kiln. At this transported to the ~1000°C and and extenders, is meal’) in the raw mill. temperature, raw plant via conveyor, transferred to the ground in a ball mill materials are Raw Materials road or rail. 6 – Electrostatic clinker cooler. Clinker to a fine powder to transformed into Precipitator (EP) is rapidly cooled to produce the final Clinker. 3 – Transport of fuel An EP removes ensure the desired cement product. 1 – Raw Materials Fuel required to mineralogy is formed Limestone is the main particulates from kiln achieve and maintain Clinker production in the final product. 12 – Storage Silos raw material for and mill exhaust temperatures in the requires high Heat recovered from The cement is cement manufacture, gases. kiln are transported to temperatures which the kiln and the cooler conveyed to large, and is mined from the plant (via rail or 7 – Pre-heater are generated by the is recycled in the vertical storage silos. adjacent quarries. road). Raw materials are combustion of fuel. process to reduce fuel Cement is conveyed Other necessary heated to ~900°C in The use of waste- requirements. to loading stations in elements such as 4 - Homogenising counterflow heat derived alternative the plant or directly to iron, alumina and Raw materials are exchange resulting in fuels is being is 10 – Clinker Silo transport vehicles for silica are sourced homogenised in the decarbonisation of proposed to replace a Cooled clinker is delivery of the final from additional raw preparation for raw calcium carbonate in percentage of fossil stored on the clinker cement products in materials. milling. the raw meal. fuel (coal) used. silo. 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)

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This raw meal is fed into the pre-heater. The pre-heater comprises a vertical tower of heat exchange cyclones in which the dry feed is heated to temperatures of approximately 900°C by the kiln exit gases. Raw meal is introduced at the top of the pre-heater tower and the hot kiln exhaust gases pass counter-current through the downward moving meal to preheat the meal prior to introduction into the kiln.

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 to optimise the transfer of heat between the kiln exhaust gas and the limestone based raw material. Gas temperatures entering the pre-heater are in the order of +900°C, while the temperature of the gases exiting the preheater tower are approximately 280°C. Further cooling of the gas stream takes place in the conditioning tower, where temperatures are reduced to approximately 140°C in a few seconds. Gas scrubbing effectively takes place in the pre-heater tower through to the area immediately after the bag-house filters. Due to the alkali environment coupled with rapid gas cooling, the potential for environmental impacts is minimised.

4.1.2. Process inside the Kiln

The raw material is fed into the upper end of the kiln which is operated in a 'counter-current' configuration, that is gases and solids flow in opposite directions through the kiln providing for more efficient heat transfer. The raw meal is fed at the upper (or 'cold' end), and the slope and rotation cause the raw meal to move toward the lower (or 'hot' end). The rate at which the material passes through the kiln is controlled by the slope and rotational speed of the kiln.

As the meal moves through the kiln, it is heated and reaches a temperature of approximately 1 450°C. At this high temperature, a series of chemical reactions take place with some of the raw materials which are now in molten form. The materials fuse together and create 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.

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Figure 4.2: Primary components of Kiln 5 (Holcim, 2004)

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4.1.3. After the Kiln

Clinker is discharged at a temperature of about 1 000°C from the lower end of the kiln and transferred to a 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.

The cement is conveyed from the cement mill to large, vertical storage silos in the packhouse or shipping department. Cement is withdrawn from the cement storage silos by a variety of feeding devices and conveyed to loading stations in the plant or directly to transport vehicles.

4.2. Environmental Aspects of Cement Manufacture

4.2.1. Raw Materials

In the cement kiln, new mineral compounds are formed giving cement its specific properties. The main components are the oxides of calcium, silica, aluminium and iron.

Significant quantities of limestone, clay and other primary raw materials are quarried to provide the raw materials for the production of cement. Calcium is provided by the limestone, while other necessary elements such as iron, alumina and silica are sourced from additional raw materials and added into the process in the desired quantities. All the natural raw materials which form raw meal also contain a wide variety of other elements in small quantities (for example zinc).

4.2.2. Emissions to Air

Almost all manufacturing activity results in emissions to the atmosphere, and cement manufacture is no exception to this. Releases from the cement kiln come from the physical and chemical reactions of the raw materials and from the combustion fuels. The main constituents of the exit gases from a cement kiln are nitrogen from the combustion air, carbon dioxide (CO2) from the calcination and combustion processes, water vapour, and excess oxygen.

The exit gases also contain small quantities of dust, chlorides, fluorides, sulphur dioxides, NOx, carbon monoxide, and still smaller quantities of organic and inorganic compounds. Many of the gases released are harmless, however, some are either known or suspected to cause damage to the environment. These emissions are, therefore, required to be carefully monitored and controlled in terms of the requirements of the Atmospheric Pollution Prevention Act (No 45 of

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1965) and the permit issued by the Chief Air Pollution Control Officer (CAPCO) to Ulco plant.

Monitoring equipment is in place at Ulco to monitor stack emissions. Holcim  installed Opsis equipment for Kiln 5 which measures on a continuous basis SO2,

N0, NO2, C0, H2O, benzene, xylene and toluene, and Durag emission equipment for particulates. Holcim have also extended the range to total organic compounds as well as HCl and NH3. Twelve heavy metals, as well as dioxins and furans are measured for on an annual basis.

4.2.3. Energy

In the South African cement industry, the primary fuel used for energy is coal, a fossil fuel. The average energy requirement to produce 1 000 tons of cement clinker is approximately 130 tons of coal. Holcim South Africa requires approximately 350 000 tons per annum of coal to sustain current cement clinker manufacture rates.

The main constituents of coal ash are silica and aluminia compounds which combine with the raw materials (limestone) in the kiln to become part of the clinker. Like other natural products, the coal ashes contain a wide range of trace elements which are also incorporated in the cement clinker.

With energy typically accounting for 30-40% of the production cost of cement, the cement industry throughout Europe and developing nations has successfully concentrated significant efforts on improving energy efficiency of operating kilns in recent decades. This includes the introduction of energy efficient technologies such as the use of preheater towers and pre-calciners.

In addition, in an effort to reduce the reliance on fossil, the use of alternative sources of fuels (other than traditional fossil fuels) have been investigated and successfully implemented in kilns.

4.2.4 Use of Alternative Fuels in the Cement Manufacture Process

A commitment to Sustainable Development has resulted in a drive to replace traditional non-renewable fossil fuels (such as coal) used in the production of cement with suitable alternative fuels. This has resulted in the need to identify alternative renewable and/or replaceable 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

Overview of the Cement Manufacturing Process41 08/10/04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province environmental impacts of using a non-renewable resource (coal) in the cement manufacturing 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 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 steadily increased since then.

The design of Ulco plant Kiln 5 allows for the acceptance and use of alternative fuels as an energy source together with coal.

4.2.5. How AFR can be utilised in the Kiln

Waste-derived fuels can be introduced to Kiln 5 as a fuel at three feed points. These are illustrated on Figure 4.3:

• The lower end of the kiln directly at the main flame/burner: the AFR is immediately exposed to the main burner flame and releases energy to maintain the temperature in excess of 2 000°C. • In the pre-calciner combustion vessel located at the bottom of the preheater tower: the AFR is immediately exposed to flame within the auxiliary firing system, maintaining the temperature at 1 200°C. • The upper end of the kiln where the raw material is fed: the AFR is fed with raw materials which are at a temperature of 900°C.

The design of Kiln 5 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 the main burner. Fuel lines can be coupled to this multi-channel burner and fuel injected into the kiln through concentric tubes, together with air. The type of burner head installed at Ulco plant is illustrated in Photograph 4.1.

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Figure 4.3: Graphic representation of the three feed points where waste-derived fuels can be introduced to Kiln 5 (Holcim, 2004)

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Photograph 4.1: Burner head illustrating the concentric tubes through which fuel and air is fed into the kiln

4.2.6. Waste Products utilised as Alternative Fuel Sources

Waste materials which the cement industry has utilised as alternative fuels in Europe include used tyres, rubber, paper waste, waste oils, waste wood, paper sludge, sewage sludge, plastics and spent solvents. Similar waste materials are proposed to be utilised as fuel in South Africa, together with other wastes that are considered suitable and desirable (including industrial hydrocarbon tars and sludges).

Many waste products are chemically similar to coal, and have a calorific value (MJ/kg) similar to, and in some instances higher, than coal. Table 4.1 provides an indication of nett calorific value of alternative fuels, as well as traditional fuels. The use of materials other than coal to achieve the same effect within the kiln is beneficial through the maximisation of energy recovery.

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Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and traditional fuels Calorific value Grade of fuel Fuel type (MJ/kg) Pure polyethylene 46 Light oil 42 Heavy oil 40 Pure polystyrene 40 By-products of tar 38 High Grade Pure rubber 36 Anthracite 34 Waste oils 30-38 Scrap tyres 28-32 Coal 24-29 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 (Note: highlighted fuel types indicate traditional fuel types and respective calorific values)

The use of waste as alternative fuels is technically sound as the organic component is destroyed and the inorganic component is trapped and combined in the cement clinker forming part of the final product. Cement kilns have a number of characteristics that make them ideal installations in which alternative fuels can be valorised and burnt safely, such as:

• High temperatures, i.e. exceeding 1 400°C (flame temperature ~2 000°C) • Long residence time, i.e. in excess of 4 seconds • Oxidising atmosphere • High thermal inertia • Alkaline environment • Ash retention in clinker, i.e. fuel ashes are incorporated in the cement clinker, with no residual solid waste by-product

Normal operation of cement kilns provides combustion conditions which are more than adequate for the destruction of organic substances. This is primarily due to the very high temperatures of the kiln gases (2 000°C in the combustion gas from the main burners and 1 200°C in the gas from the burners from the pre- calciner) (Bouwmans and Hakvoort, 1998; CEMBUREAU, 1997). The gas residence time at high temperature in the kiln is of the order of 5-10 seconds and in the pre-calciner more than 3 seconds (CEMBUREAU, 1997).

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As 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 Ulco plant in order to ensure that undesirable fuels are excluded as alternative fuel sources. Materials excluded are anatomical hospital wastes, asbestos-containing wastes, bio-hazardous wastes, electronic scrap, entire batteries, explosives, high- concentration cyanide wastes, mineral acids, radioactive wastes, and unsorted municipal garbage.

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5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE INTRODUCTION OF THE ALTERNATIVE FUELS AND RESOURCES PROJECT AT ULCO 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 Ulco plant have been assessed through specialist studies undertaken as part of this EIA.

The environmental assessment aims to provide an integrated and balanced view of the potential environmental impacts associated with the proposed project, as well as make recommendations regarding appropriate mitigation measures, such that informed decision-making can be made by the environmental authorities. This section includes an assessment of the potential positive and negative impacts identified through this EIA process, and makes recommendations, where required, regarding practical and appropriate mitigation and management measures required to be implemented in order to minimise potentially significant impacts.

5.1. Potential Impacts on Land Use, Vegetation and Heritage Sites in the area surrounding the Ulco plant

The original infrastructure at Ulco plant was constructed more than 60 years ago (Union Lime Company established in 1936), with Kiln 5 being constructed and operational since the 1980's. The plant is located within an area zoned for industrial use. Land use in the immediate surrounding area is limestone quarrying. Impacts/disturbance of the land within and surrounding the Ulco 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 design of Ulco’s Kiln 5 has resulted in this kiln being in a position to receive and utilise alternative fuels as an energy source, together with coal. As the AFR programme proposed at Ulco’s Kiln 5 involves the reduction in the use of coal through supplementation of the fuel required with AFR, additional investment would be required to be made within the site boundaries for the AFR acceptance,

Assessment of Potential Impacts47 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province chemical testing, storage and kiln feed infrastructure. This additional infrastructure would not, however, require any additional changes to the footprint area of the existing cement plant.

The area within the boundaries of the existing Ulco plant has been extensively disturbed through industrial activities and the construction of auxiliary infrastructure to support the cement plant. The introduction of an AFR programme would require the establishment of two dedicated fuel storage areas, where fuels could be off-loaded, handled, and stored for a limited period before being fed into the kiln together with coal. The two areas would comprise an undercover storage area of approximately 300 m2 and an open storage area of approximately 2 000 m2. These areas would be within the existing footprint of the Ulco plant. 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 Ulco plant with the introduction of the AFR programme, no impact on any heritage sites is anticipated. The Northern Cape provincial department of the South African Heritage Resources Agency (SAHRA), as well as the National office in Cape Town have been consulted in this regard. In addition, no sites at the Ulco plant were identified by an archaeological and cultural survey conducted by the McGregor Museum in August 1999 (Morris, 1999; Morris, 2004; refer to Appendix G).

5.1.1. Conclusions and Recommended Management Options

No significant impacts on land use, vegetation and heritage sites are anticipated to be associated with the introduction of the AFR programme at Ulco plant. Therefore, no mitigation measures are required to be implemented. However, all current vegetation maintenance practises exercised at Ulco plant must be continued in terms of the requirements of the Conservation of Agricultural Resources Act (No 43 of 1983).

5.2. Potential Impacts Associated with the establishment of a Fuel Storage Area within the Boundaries of the Ulco Plant

No preparation of different waste types for use as AFR at Ulco plant (such as pre- treatment or blending of wastes) will occur at Ulco plant. The suitable AFR received at the plant will be received and stored within designated storage areas, and then proportioned for feeding into the cement kiln.

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Table 5.1: Summary of potential impacts on land use, vegetation and heritage sites in the area surrounding the Ulco plant as a result of the introduction of the AFR programme Nature of Impact associated Confidence Mitigation measures in with the introduction of the Extent Duration Severity Significance Likelihood assessment AFR programme of impact Impacts on land use in the area Localised Long-term Slight None Very unlikely High Not applicable surrounding the Ulco plant to occur Impacts on vegetation in the area Localised Permanent Slight None Very unlikely High Current vegetation maintenance surrounding the Ulco plant to occur practises must be continued. Impacts on heritage sites in the Localised Permanent Severe None Very unlikely High Not applicable area surrounding the Ulco plant to occur

Table 5.2: Summary of potential impacts on land use, vegetation and heritage sites associated with the establishment of a fuel storage area within the boundaries of the Ulco plant Nature of Impact associated Confidence Mitigation measures in with the introduction of the Extent Duration Severity Significance Likelihood assessment AFR programme of impact Impacts on land use within the Localised Long-term None None Very unlikely High Not applicable Ulco plant boundaries to occur Impacts on vegetation within the Localised Long-term None None Very unlikely High Not applicable Ulco plant boundaries to occur Impacts on groundwater and soil Localised Long-term Severe High Very unlikely High Storage areas must be constructed as a result of the storage of AFR to occur according to national engineering standards & specifications required by the National & Provincial Government Departments

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Two AFR fuel storage areas are proposed to be established within the boundaries of the existing Ulco plant, i.e. an undercover storage area of approximately 300 m2 and an open storage area of approximately 2 000 m2. These storage areas are proposed to be established within the boundaries of the existing Ulco plant (refer to Figure 5.1). These areas have been extensively disturbed through activities associated with the cement manufacture process at the plant. The areas are devoid of vegetation and on level terrain, as is characteristic of the area (Photograph 5.1 and 5.2).

Limited earthworks would be required in the construction of appropriately bunded, concrete lined areas. Therefore, the establishment of these fuel storage areas is not anticipated to impact significantly on vegetation or land within the Ulco plant boundaries.

Figure 5.1: Aerial photograph illustrating the position of the areas demarcated for the proposed AFR storage areas in relation to Kiln 5

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Photograph 5.1 Photograph illustrating the area demarcated as the undercover storage area (approximately 300 m2) adjacent to Kiln 5

Photograph 5.2 Photograph of the historically disturbed area demarcated as the open storage area (approximately 2000 m2)

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.

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An assessment of the potential impacts associated with the establishment of an AFR fuel storage area within the boundaries of the Ulco plant is provided in Table 5.2.

5.2.1. Conclusions and Recommended Management Options

No significant impacts on land or vegetation is associated with the establishment of designated AFR storage areas at Ulco plant. Therefore, no mitigation measures are required to be implemented prior to the construction of the site.

However, in order to minimise potential impacts on soil and groundwater as a result of the storage of fuels, storage areas for all alternative fuels and resources must be constructed according to national engineering standards and specifications required by the relevant National and Provincial Government Departments. These should have a concrete floor, should be properly bunded, and if required for operational reasons, should be covered by a permanent roof structure. The volume of the bunded area should at least be such that it can contain a 1:50 year rainfall event over the surface area of the storage area. The concrete base will minimise, if not totally exclude, leachate infiltration into the groundwater.

5.3. Potential Impacts on Water Resources

5.3.1. Sources of risk to the groundwater and surface water environment from the introduction of an AFR programme

Wastewater discharge associated with a cement plant is limited to surface/stormwater runoff from the plant itself and surrounding surfaced areas, as well as process cooling water. Current operating activities do not result in any significant contribution to surface or groundwater pollution.

The introduction of AFR as an energy source in Kiln 5 at Ulco 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, that is there will be not impact on the Vaal River system.

The quality of the water utilised within the cement manufacture process for cooling purposes will not be contaminated by AFR. Therefore, the introduction of

Assessment of Potential Impacts52 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province 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 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 areas. The potential exists for the production of leachate as a result of rainwater or stormwater percolating through the material within the uncovered storage area. 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 adequately contained or treated. Leachate generated in this way within the storage areas 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 runoff from the plant area is directed to stormwater drains which flow off the plant area directly into the natural vegetation surrounding the plant. The storage area for AFR would be required to be lined and bunded in order to ensure no contamination of the stormwater runoff as a result of the implementation of the proposed project. Any collected stormwater from the storage areas would be required to be appropriately disposed of.

The potential impacts on the water environment (groundwater and surface water) associated with the introduction of the AFR programme together with the scale of impact are detailed in Table 5.3.

5.3.2. Conclusions and Recommended Management Options

The introduction of the AFR programme in Kiln 5 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.

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Table 5.3: Summary of potential impacts on the water environment associated with the introduction of the AFR programme at Ulco 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 Availability of water Very unlikely Regional Long-term Slight None High Not applicable resources in the area to occur Quality of process Very unlikely water for cooling Localised Short-term Slight None High Not applicable to occur purposes Construction of storage facility Off-loading, storage according to construction Unlikely to and handling of AFR Localised Long-term Slight Low High standards and monitoring of occur material quality of any leachate produced

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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 required to be tested, and only discharged to the approved effluent discharge system of the plant should it meet the specified range for effluent discharge. Should the quality of the water not be acceptable, it would be required to be treated to a standard such that it can be disposed of in the effluent disposal system (Department of Environmental Affairs and Tourism, 1984; Department of Water Affairs and Forestry, 1996).

5.4. Potential Impacts on Air Quality

Releases from a cement kiln come from the physical and chemical reactions of the raw materials and from the combustion of fuels. The main constituents of the exit gases from a cement kiln are nitrogen from the air used for combustion, carbon dioxide (CO2) from limestone calcination and the combustion process, and excess oxygen. The exit gases also contain small quantities of dust, chlorides, fluorides, sulphur dioxides, oxides of nitrogen (NOx), carbon monoxide (CO), and still smaller quantities of organic and inorganic compounds.

The 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, the significance for baseline conditions (for all pollutants of concern) was predicted to be low for criteria pollutants and moderate for non-criteria pollutants (refer to Table 5.4). Under proposed operating conditions (i.e. usage of alternative fuels), the significance for all criteria pollutants of concern was predicted to remain low with the significance for non-criteria pollutants (based on hexavalent chromium) as high (refer to Table 5.4). In assessing the results presented in Table 5.4 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.

A detailed assessment of the potential impacts on air emissions associated with the introduction of AFR at Ulco is included within Chapter 6 and Appendix H.

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Table 5.4: Summary of potential impacts on air quality associated with Ulco 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 Localised Long term Slight (b) Low (b) May occur (c) Probable all criteria pollutants of concern) Impacts on air quality associated with the baseline study(a) (for Moderately Localised Long term Moderate (d) May occur (c) Probable all non-criteria pollutants of concern) severe (d) Impacts on air quality associated with the proposed usage of Localised Long term Slight (b) Low (b) May occur (c) Probable alternative fuel(a) (for all criteria pollutants of concern) Impacts on air quality associated with the proposed usage of Moderately Localised Long term Moderate (d) May occur (c) Probable alternative fuel(a) (for all non-criteria pollutants of concern) severe (d) Notes: (a) Routine operating conditions using the Kiln, Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill. (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. (d) Based on hexavalent chromium assuming 10% of total chromium exceeding the cancer risk criteria of 1 in 1 million (trivial cancer risk), but below the cancer risk of 1 in 100 thousand (broadly acceptable cancer risk).

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5.4.1. Conclusions

The investigation included the simulation of inhalable particulates, nitrogen oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and halogen compounds.

For baseline conditions measured emission values were used to simulate the current impact on the surrounding environment. For proposed usage of alternative fuels, EC emission limits were used to estimate emission rates and simulate the impact on the surrounding environment.

The main conclusions may be summarised as follows:

• Inhalable particulate concentrations (PM10): For current and proposed operating conditions predicted ground level concentrations were below current DEAT guideline as well as the EC and proposed South African limits;

• NO2: Current predicted off site concentrations of 57 µg/m³, 7 µg/m³ and 0,85 µg/m³ did not exceed the DEAT guidelines for highest hourly, daily and

annual averaging periods respectively. Predicted NO2 ground level concentrations for proposed operating condition were predicted to be 80 µg/m³, 20 µg/m³ and 3 µg/m³ for highest hourly, daily and annual averaging periods. These concentration levels were below DEAT guidelines as well as EC and proposed South African (SA) limits;

• NOx: Ground level concentrations for proposed operating conditions were 550 µg/m³, 140 µg/m³ and 22 µg/m³ for highest hourly, daily and annual averaging periods respectively, which reflect values below the current DEAT guidelines;

• SO2: Predicted ground level concentrations during baseline conditions were below the current DEAT guidelines as well as the proposed South African and EC limits, with highest hourly, daily and annual average ground level concentrations of 4 µg/m³, 0,43 µg/m³ and 0,043 µg/m³ respectively. Similarly highest hourly, daily and annual average ground level concentrations of 35 µg/m³, 9 µg/m³ and 1,3 µg/m³ were below the respective guidelines sites due to proposed conditions; • Lead: current and proposed predicted concentrations were less than 2% of the EU limits respectively; • Non-criteria pollutants – non-carcinogenic health effect: Predicted ground level concentrations did not exceed the effect screening or health risk criteria during current or proposed operations. • Non-criteria pollutants – carcinogenic health effect: With the exception of benzene (current operations) and hexavalent chromium (current and proposed operations), all carcinogenic pollutants were predicted to cause less than 1 in 1 million chance of cancer (trivial cancer risk):

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∗ Benzene: Under current operating conditions the cancer risk due to benzene ranged from 0.4 to 1.5 in 1 million (based on US-EPA unit risk factors), which is broadly acceptable (1 in 1 million) .No Benzene emission EC limit exists that could be used for the proposed introduction of alternative fuels and therefore the ground level impact could not be predicted. ∗ Hexavalent chromium: Assuming hexavalent chromium is typically 10% of total chromium, the incremental cancer risk using the WHO inhalation unit risk factors would be 0.6 in a million (based on the geometric mean). This is broadly acceptable (less than 1 in 1 million). However, using EC limits (proposed operating conditions) the cancer risk for hexavalent chromium, increases to 1.1 in 1 hundred thousand (WHO unit risk factors), assuming chromium VI is representative of 10% of total chromium; • Dioxins and furans: The predicted ground level concentrations were below the relevant guidelines for current and proposed operating conditions; • Significance Rating: Based on the significance rating categories (see Section 6.4), current and proposed conditions indicated slight severity due to predicted ground level concentrations from criteria pollutants with localised, long-term impact. For non-criteria pollutants (based on hexavalent chromium) the severity increased from moderate (baseline conditions) to high (proposed conditions). It should be noted, however, that EC emission limits were used to simulate the hexavalent chromium ground level impact for proposed operating conditions as no measured data was available for the current study. Thus the high severity of the significance rating for hexavalent chromium under proposed operating conditions should be seen in context. However, in order to ensure that this impact does not manifest, no AFR containing chromium should be utilised within the kiln.

Based on the findings of the specialist air quality study it can be concluded that predicted ground level impacts from alternative fuel usage is well below relative guidelines/limits.

5.4.2. Recommendations

• EC emission limits have been utilised as a benchmark for the quantification of ground level impact from the plant emissions that may result from the proposed partial substitution of coal with alternative fuels. Based on the “predictive” nature and conservative approach of the simulated ground level results, and associated uncertainties, it is recommended that Trial Burns, under controlled conditions, be initiated with the object of verifying that the EC emission limits and destruction removal efficiencies can in practice be met. It should be noted that pollutants of concern, which may be emitted during a trial burn, typically result in health impacts due to chronic exposures

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(e.g. dioxins and furans); hence a relatively short exposure of a few days during the trial burn would have an insignificant impact. • An annual “spot check” emission measuring programme be implemented on kiln emissions for all pollutants identified in this, with particular attention on those pollutants identified as having potentially higher risks, namely, particulate, Chrome VI and benzene. If the order of magnitude of these emissions is significantly different to those used in the current assessment, re-simulation is recommended to be undertaken in order to quantify ground level impacts. • Due to the relative uncertainty of the conservative conclusions drawn on the cancer risks associated with hexavalent chromium, it is recommended that the total chromium and hexavalent chromium fractions of the PM10 particulate be determined through additional measurement, and that, in order to more accurately assess the associated risks re-simulation be conducted of the chrome be conducted on an annual basis.

• NO and NO2 emissions at the plant from the kiln, under both current and alternative fuel conditions, be monitored and recorded on a continuous basis for comparison with EC emission limit values. Collected data to be utilised for re-simulation as and when required by the authorities. • Although fugitive emissions were not important in establishing the impact of the use of alternative fuels, it is recommended that a source inventory be compiled for these emissions to determine the significance of this source. • The Air Quality Management Plan (AQMP) be implemented with the objective of improving and extending the plants emissions inventory and database by: ∗ Undertaking stack (Kiln) monitoring following the initiation of the proposed operations to confirm projected stack emission data. ∗ Identify and quantify all fugitive, diffuse and evaporative sources of emissions.

5.5. Potential Traffic Impacts

The introduction of an AFR programme at Kiln 5 at Ulco 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. Traffic transporting AFR will access Ulco plant via Kimberley, Kuruman or Postmasburg. These towns are linked to the plant via the R31 and DR3388, owned by the Northern Cape Province and Frances Baard District Municipality respectively. A 7,4 m wide tarred road provides access to the Ulco plant from Road DR3388 (refer to Figure 5.2). This access road has been rehabilitated during the last 6 years and has a good structural capacity and riding quality.

Potential impacts associated with the transportation of AFR by road include increased traffic volumes and potential delays for other traffic in the area,

Assessment of Potential Impacts59 9-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province impacts on the road surface and structure, and an increase in the heavy vehicle traffic within the areas surrounding Ulco plant.

5.5.1. Condition of Roads around Ulco Plant

• R31 The R31 serves as the link between Barkly West and Postmansburg. This road is a 7,4 m wide, two-lane road with a 2 m gravel shoulder. The road is owned by the Northern Cape Province and well maintained. The first 30 km of this road from Barkly West underwent surface rejuvenation in 1999, and a 9 mm Latex seal was applied to the remainder of the road in 1995 (i.e. up to Koopmansfontein). Although some structural defects such as pumping and bleeding do occur, this can be addressed through the scheduled maintenance cycle which is due in the next 3 - 4 years. This road is thus in a good structural condition and riding quality.

• DR3388 DR3388 is owned and maintained by the Frances Baard District Municipality. The road is well-maintained and in good structural and riding condition.

5.5.2. 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.

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Figure 5.2 Locality map indicating the accessibility of Ulco, the R31 and neighbouring towns

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The Northern Cape Province Department of Transport conducted twelve-hour daytime classified traffic counts at three positions in the study area during 1996 and 1997 (refer to Figure 5.3 and Table 5.5). These counts were extrapolated by a growth rate to reflect the existing (2004) traffic volumes (refer to Table 5.5). The growth as calculated by the Northern Cape Department of Transport is 3% per year.

Table 5.5: 12-hour traffic counts for the R31 for 1996 and 1997, and extrapolated for 2004 Station Station 1 Station 2 Station 3 Year 1996 2004 1996 2004 1997 2004 Light Vehicles 821 1010 1072 1358 1304 1652 Heavy Vehicles 235 289 317 402 265 336 Total Vehicles 1056 1299 1389 1760 1569 1988 Percentage Heavy 22% 22% 30% 22% 20% 17% Vehicles

If the maximum traffic of 1988 on the R31 is compared to the standards set in the Capacity Analysis of Two-lane Undivided Highways Guideline, the road is operating at a Level of Service A (LOS A). The guideline states that if a road carries up to 4 000 vehicles per 12-hour interval, it is operating at a LOS A. Typical roads such as the R31 are designed to operate at a LOS C and, therefore, have sufficient spare capacity to accommodate the additional 6 trips per 12 hours which are anticipated to be associated with the transport of AFR to Ulco plant without an impact.

The gradient of the road plays an important role when calculating the LOS. If steep gradients occur, the delay on the road increases and the level of service decreases. The average gradient between Barkly West and Postmasburg (R31) is 1:0,0025, which can be seen as level. There will, therefore, be no effect on the LOS due to the gradient.

From Table 5.5 it is evident that the roads surrounding the Ulco plant are carrying the normal (17% - 30%) proportion of heavy vehicles, if compared to the norm for rural roads in South Africa that ranges between 15% – 20% of all traffic. The additional trucks associated with the introduction of AFR at Ulco plant result in a 0,5% increase in heavy vehicle traffic. These roads have sufficient spare capacity to accommodate these trips in a twelve-hour period.

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Figure 5.3 Position of stations for the twelve-hour daytime classified traffic counts conducted by Department of Transport during 1996 and 1997

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The heavy vehicles currently travelling to Ulco Plant arrive from various destinations in South Africa and are in the order of 45 - 50 vehicles per day. The number of truck to the plant may vary from day to day due to the demand for cement. These vehicles travel to the plant via Kimberley, Postmasburg or Kuruman. It is assumed that the heavy vehicles hauling fuel to the plant will be split with 80% travelling via Kimberley, and 20% travelling via Postmasburg and Kuruman. The roads linking these towns to the plant were designed to accommodate a large proportion of heavy vehicle traffic, and will easily accommodate these vehicles.

The addition of 6 trucks on the route via R31 will result in a 0,3% increase in the total traffic volume. The road has enough spare capacity to accommodate these trips in a twelve-hour period. This is a very small growth in traffic and is considered to be insignificant.

5.5.3. 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 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.

Road R31 was typically designed to carry between 1 to 3 million E80s over a period of 20 years. If the additional 6 trucks are added at an average of 2,56 E80s per truck, the daily loading will be about 15 E80s/day. From Table 5.6 it is shown that the current loading on the roads vary between 200 and 300 E80s/day. The proportion of the extra loading is therefore about 5 – 7%. This proportion of extra loading on these roads under consideration is acceptable considering the existing load.

Table 5.6: 12-hour E80s per counting station along the R31 Station Station 1 Station 1 Station 2 Station 2 Station 3 Station 3 Year 1996 2004 1996 2004 1997 2004 E80s 190 234 234 296 229 290

5.5.4. Assessment of Potential Impacts

Potential issues identified through the analysis of the impact of 6 additional trucks required to haul AFR to the Ulco plant can be summarised as follows:

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• 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 5.7 and can be quantified as:

• Growth in traffic volume and delay: A small growth in traffic volumes will definitely occur and will be permanent unless the hauling of alternative fuels by road is stopped. All road-users travelling between Kimberley and Postmasburg via the routes used for hauling will experience a slight rise in traffic volume. These roads have enough spare capacity to accommodate these trips in a twelve-hour period. • The impact on the road structural capacity: The addition of the additional trucks will definitely increase the loading on the various road pavements. This will in turn lead to an increase in the rate of deterioration of the pavements. The effect of this deterioration will, however, be acceptable, i.e. less than 10%, and can easily be negated by normal scheduled road maintenance. The roads affected by the additional trucks carrying waste to the plant are R31 and DR3388. • Growth in heavy vehicle traffic: The growth in heavy vehicles will result in a higher heavy vehicle factor. However, the rise in this factor is very low and the road users will hardly recognise the rise.

5.5.5. Conclusions and Recommendations

The conclusions and recommendations of this traffic impact assessment are summarised as follows:

• With the additional waste trucks operating on the road network, the delay factor will rise with an insignificant and still acceptable percentage. • With the operation of the additional 6 waste trucks on the road network there will be a growth of 0,5% in the heavy vehicle volumes that can be classified as a very low impact. • The loading (E80s) of 5 – 7% added by the 6 waste trucks on road is of an acceptable level. • The road R31 owned by Northern Cape Province is currently well maintained. • The road DR3388 providing access to the plant is owned by the Frances Baard District Municipality and is well maintained.

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Table 5.7: Assessment of potential traffic impacts associated with the introduction of AFR at Ulco plant Temporal Significance Issues Road Spatial Scale Severity Risk/Likelihood Confidence Level Scale Scale Growth in R31 Traffic Long Term Localised Slight Low Will Definitely occur Probable DR3388 Volume

Impact on R31 the road Long Term Localised Slight Low Will Definitely occur Probable structural DR3388 capacity

Growth in R31 Heavy Vehicle Long Term Localised Slight Low Will Definitely occur Probable Traffic DR3388 volume

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5.6. Potential Impacts on the Social Environment

The purpose of the Social Impact Assessment (SIA) is to provide a systematic analysis in advance of the likely impacts a development event (or project) will have on the day-to-day life of persons and communities. SIAs are undertaken to assist individuals, communities, as well as government organisations to understand and be able to anticipate the possible social consequences on human populations and communities of proposed project development or policy changes. It also serves to identify the potential for social mobilisation against the project, identifies social impacts that cannot be resolved and variables that will need to be addressed by avoidance or mitigation.

The following operational definitions of a social impact assessment, apply:

• “a process aimed at identifying the future consequences for human populations of any public or private action that alters the way in which people live, work, play, relate to one another, organise to meet their needs, and generally cope as members of society” (Becker, 1999). • “(an investigation into) the potential change in the activity, interaction and/or sentiment of the community, as it responds to the impacts resulting from the alteration in the surrounding social and biophysical environment” (adapted from Burdge, 1995).

Both definitions highlight fundamental characteristics of the social environment and the necessity to consider impacts on the individual per se, as well as impacts on the individual in interaction with the social and biophysical environment. The social impact assessment variables that were applied for the purposes of the study (see below) served to elicit information regarding both these aspects.

5.6.1. Methodology

• Scope of the SIA The SIA was conducted as per the requirements of the EIA regulations (DEAT, 1998) and included a number of steps patterned on the steps associated with Environmental Impact Assessment:

∗ 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);

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∗ 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).

• Social Impact Assessment Variables Social Impact Assessment variables serve to explain the consequences of specific developments and, as such, do not relate to the total social environment. The following variables were assessed (Burdge, 1995) on the basis that they reflect probable social impacts:

∗ Formation of attitudes and perceptions; ∗ Disruption in daily living and movement patterns; ∗ perceptions of public health and safety; ∗ community infrastructure needs; ∗ local impacts and regional benefits; and ∗ intrusion impacts.

Only variables considered to be relevant to this study were assessed, based on, inter alia, factors relating to the probability of the events occurring and the number of people impacted upon.

• SIA Data Sources Information gathered and social issues identified and verified during the public participation process undertaken as part of the Environmental Impact Assessment served as key input to the SIA. The Issues Trail (refer to Appendix F) was a primary data source and included information gathered during focus group meetings, public meetings and individual consultation sessions held with stakeholders and I&APs.

The findings from other specialist studies were considered within the evaluation of social impacts, and served to place the impacts as perceived by I&APs into perspective, thus facilitating a more accurate rating of impacts.

5.6.2. Formation of Attitudes and Perceptions

Stakeholder perceptions regarding the introduction of an AFR programme at Kiln 5 at Ulco plant vary greatly. Some stakeholders have expressed concern about potential health or environmental impacts from the handling and combustion of alternative fuels, while others are concerned that the quality of the

Assessment of Potential Impacts68 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province 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.

In response to these comments, which have also been widely raised throughout the world, Holcim has undertaken extensive technical work and environmental studies. Other institutional bodies such as the United States Environmental Protection Agency (US EPA) have also investigated the potential adverse effects on human health, the environment or product quality as a result of the use of AFR. Through these studies, the cement industry has been more successful than any other in reducing its emissions (particularly in terms of dioxins and furans (www.ckrc.org/ncafaq.html)) and thus its impact on human health and the environment. In addition, the US EPA has confirmed that the use of AFR within the cement manufacture process does not increase risks posed to end users of cement.

5.6.3. Disruption in Daily Living and Movement Patterns

The disruption in daily living and movement patterns refers to the disruption in activities of residents as a result of project-related activities. Heavy vehicle movement on the R31 associated with the transportation of AFR to the Ulco plant has the potential to disrupt the daily movement patterns of the local population (particularly residents in Ulco, Delpoortshoop, Barkly West, and surrounding landowners and places of interest such as the Vaalbos Nature Reserve who all use the R31 as an access route).

However, as detailed in Section 5.5 above, a long-term scenario of an additional 6 trucks per day transporting AFR to Ulco plant is anticipated. The addition of 6 trucks on the R31 route will result in a 0,3% increase in the total traffic volume. The road has enough spare capacity to accommodate these trips in a twelve-hour period. This is a very small growth in traffic and is considered to be insignificant.

The area surrounding Ulco plant is sparsely populated. Population density for Ward 6 of the Dikgatlong Municipality is 6 982 (as recorded within the 2001 census; Umhlaba Environmental Consulting, 2004). The population of Ward 6 is concentrated within Delpoortshoop and Ulco.

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.

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5.6.4. Impact on Infrastructure and Community Infrastructure Needs

Heavy vehicles required for the transportation of AFR to Ulco plant have the potential to impact on local road infrastructure. However, as detailed in Section 5.5 above, an increase of 5 – 7% of the loading on the road surface is anticipated as a result of the introduction of the additional six vehicles per day (maximum vehicles anticipated). This is considered to be acceptable considering the existing load.

At present, coal is transported to Ulco 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. Under current conditions, 65% of the cement product is transported from Ulco via rail, and 35% via road. The heavy vehicles currently travelling to Ulco Plant are in the order of 45 - 50 vehicles per day. The number of vehicles may vary from day to day due to the demand for cement, and travel to various destinations in South Africa. The additional vehicles associated with the transport of AFR (maximum 6 per day) do not significantly increase the number of vehicles currently accessing the plant via the existing infrastructure.

Ulco plant is supplied with electricity via a dedicated substation. With the introduction of the AFR programme at Ulco 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.

Therefore, the potential impacts associated with impact on infrastructure and community infrastructure needs are not considered to be significant.

5.6.5. Health and Safety Impacts

• Potential Safety Impacts associated with Additional Road Traffic Heavy vehicle movement associated with the transportation of AFR to the Ulco 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

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a 0,3% increase in the traffic volume on the access routes to Ulco 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 Ulco 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 Ulco plant have been raised as a concern as they may pose a health risk to local communities. 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 Ulco 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 Ulco 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 ∗ Transport: In the case of an accident or spillage while transporting AFR, 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 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. ∗ Air Emissions: 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.

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∗ Handling Procedures: Mitigation measures relating to the implementation of appropriate handling procedures for AFR at Ulco plant are addressed in detail in the waste management specialist study (refer to Chapter 7). Specific mitigation measures relating to the health and safety of employees which should be implemented include: - The nature of the facility and its associated activities calls for a comprehensive training programme for all employees involved in the handling of waste. - The employees must undergo thorough medical examinations on an annual basis. These tests must be specific to the type of work an employee is doing and the hazards to which that employee is exposed. Pre-employment and exit medicals are also essential to ensure that the employee’s health has not been affected by his job. - Detailed job analyses must be carried out to determine all tasks and what they involve. This forms the basis of the training needs analysis, as well as the type of medical tests required. It also determines what safety precautions need to be taken and the type of Personnel Protective Equipment to be issued.

5.6.6. Local Impacts and Regional Benefits

The major economic activities in the area apart from cement manufacturing at Ulco plant include limestone mining, diamond digging operations in the proximity of the Vaal River, conservation and tourism activities within the Vaalbos National Park, and farming operations in the broader 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 Ulco plant in an environmentally and economically sustainable manner will secure these employment opportunities in the long-term. This is considered to have a positive impact of high significance on the region.

5.6.7. Intrusion Impacts

The greatest population density in the immediate area surrounding the plant is Ulco Village. The village is located within 1 km to the south-west of the plant. Impacts on or the disturbance of this community already exist, and have done so since the initial construction of the facility more than 60 years ago. Potential intrusion impacts associated with the introduction of an AFR programme at Ulco plant include:

• air quality impacts, • visual impacts, • noise impacts,

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• 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 5 are anticipated to be of low significance. In addition, as the proposed project will be undertaken within the boundaries of the existing Ulco 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. 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 Ulco plant is provided in Table 5.7.

5.7. Assessment of the Suitability of Waste as an Alternative Fuel Resource

In order to generate the high temperatures required for cement clinker 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 selected 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 5 at the Ulco 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 their very high temperatures (up to 2000oC), long solid residence times (up to 30 minutes), long gas residence times (of 4 to 8 seconds), and the large excess of oxygen used in the combustion process.

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 of to landfills.

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Table 5.8: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at Ulco 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 Disruption in daily Ulco plant and the investigation Unlikely to living and movement Localised Long-term Slight None Probable of the feasibility of utilising the occur patterns empty AFR transport trucks leaving Ulco 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 Ulco plant. infrastructure needs Utilisation of specified routes by vehicles transporting AFR to Health and safety Unlikely to Ulco plant, as well as the Localised Long-term Severe High Probable impacts – road safety occur implementation of appropriate emergency response procedures. Only use AFR if trial burns show Health and safety compliance with EU Standards impacts – air Localised Long-term Slight Low May occur Probable on particulates (PM10), emissions benzene and Cr+6

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Table 5.8 cont: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at Ulco 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 Localised Long-term Severe High May occur Probable provided. Job analysis should handling AFR be undertaken on a regular basis. Local impacts and Regional Long-term Severe High (positive) Will occur Probable regional benefits Appropriate mitigation for potential air quality impacts, Intrusion impacts Localised Long-term Severe Low May occur Probable traffic impacts and impacts on water resources, noise impacts and visual impacts.

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There are currently no formal regulatory requirements specific to the use of waste derived alternative fuels and resources (AFR) in cement kilns. Without application-specific standards 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 waste-derived 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.

The design of Kiln 5 at the Holcim South Africa Ulco plant enables this kiln to accept and process a variety of fuels. These fuels could include a wide range of both hazardous and non-hazardous wastes. These waste-derived 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 to the cement plant and the transport, handling, storage and use of the waste must be strictly controlled to ensure that the potential 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 sound management techniques will, therefore, ensure the potential risks to health, safety and the environment are kept within acceptable levels.

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:

• AFR identification and acceptance procedures • Documentation • Packaging and labelling

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• Loading at the generator’s premises • Transportation • Acceptance procedures at Ulco 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 Ulco’s Kiln 5, and defines the management procedures that would be required to be implemented by Holcim South Africa (with details of these procedures provided in Appendix I).

5.7.1 Risks and Significance of Risks

The potential risks associated with the use of AFR in the manufacture of cement are included in Table 5.8 together with an assessment of the significance of the risks posed by natural events, technical problems and human error. The potential risks associated with the use of scrap tyres as AFR are assessed and the results included in the last column of Table 5.8.

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.

• 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. • They could have a potentially negative impact on the final product quality.

There are a variety of products or wastes that should not be processed or utilised as AFR in the kilns. These include the following:

• Selected extremely toxic ('high risk') wastes, e.g. waste containing free asbestos fibres and benzene (pure carcinogens), which could pose an unacceptable occupational health and safety risk.

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Table 5.9: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human Error Significance Significance Aspect Risk Extent Duration Severity Probability – hazardous – Scrap tyres waste Process Incorrect analysis or interpretation Waste Pre- of results could lead to in- Local Short term Slight Unlikely Low Low acceptance compatible waste being accepted by facility. Accidents could lead to spillage of Transport Local Short term Severe Unlikely Low Not applicable material. Waste Receiving Poor off-loading practices could Local Short term Moderate Unlikely Low Not applicable Area lead to minor chemical spills. Incorrect check analysis or interpretation of results could lead Slight to Waste Acceptance Local Short term Unlikely Low Low to incompatible waste being Moderate accepted by facility. Incompatible waste stored or flammable waste incorrectly Low to Waste Storage Local Short term Severe Very Unlikely Low managed could lead to risk of fire Moderate or explosion. Improper storage of the flammable Low to Gas Storage Local Short term Severe Very Unlikely Low gas could lead to fire or explosion. Moderate Poor operation of the plant could Low to Low to Utilisation of AFR Local Short term Moderate Very Unlikely lead to incomplete combustion. Moderate moderate Products from the Contaminated clinker and cement National Long term Severe Very Unlikely Low Low Kiln products entering the market.

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Significance Significance Aspect Risk Extent Duration Severity Probability – hazardous – Scrap tyres waste Natural Events Flood water may enter waste Flooding Local Short term Severe Very Unlikely Moderate Low storage areas. High winds could disperse Local or High Winds Short term Moderate Very Unlikely Low Not applicable pollutants into the environment. Regional Human Error Incorrect data could be provided by Data Entry Error the client or be input into the Local Short term Severe Unlikely Low Very Low database. People could gain unauthorised Unauthorised Short to long access and exposed to potentially Local Severe Unlikely Low Not applicable Access term hazardous materials. Chemical spills could result in AFR Spills Local Short term Severe Very Unlikely Low Not Applicable contamination of soil and water.

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• Wastes that contain unacceptable levels of certain components that will impact on the kiln performance, the quality of the clinker and cement or adversely impact on the emissions from the kiln. These can include waste with unacceptable levels of some heavy metals (e.g. mercury and lead) or high levels of halogenated hydrocarbons, etc. • Unsorted domestic wastes (municipal garbage) because of the potential presence of hazardous materials. • Small-volume hazardous wastes from households (fluorescent lamps, batteries etc.). • Non-identified or insufficiently characterised wastes.

In addition, some waste streams could be an acceptable fuel, but require pre- treatment before they would be acceptable for use at the kiln. This pre- treatment would not be undertaken at Ulco plant, that is, there would be no blending of wastes at Ulco.

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. • 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 oxidisation to chromium (VI).

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:

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Wastes that are acceptable as AFR for use by Kiln 5 should be delivered directly to Ulco plant. The suitable waste streams could include 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

An estimated 22 million scrap tyres are currently stockpiled in Gauteng alone (RéSource, May 2004). Between 10 and 12 million scrap tyres are generated in South Africa per annum, with some being disposed of to landfill (www.fleetwatch.co.za), and about 12% being recycled to produce rubber crumb and recycled rubber products (www.news24.com; www.engineeringnews.co.za).

Scrap tyres are currently disposed of using the following methods that result in significant environmental consequences:

• Landfill disposal – the dumping of tyres in landfills is causing the landfill sites to fill up at an unacceptable rate. • Illegal and uncontrolled burning of tyres – tyres are burnt by the informal sector to recover the steel content. This results in significant emissions to the atmosphere • Illegal dumping – due to the high cost of disposing tyres in landfill sites, tyres are being indiscriminately dumped in vacant lands

Of particular concern in South Africa is the disposal of scrap tyres to landfill, which is no longer considered to be an acceptable waste management practise in terms of the requirements of the National Waste Management Strategy. The South African Tyre Recycling Process company (SATRP) are investigating alternate solutions to deal with the scrap tyre problem in South Africa. Government is presently drafting legislation that will encourage the recycling of waste tyres (www.engineeringnews.co.za) and discourage the inappropriate disposal. Once promulgated, this legislation will enable the levying of a “green” fee, the proceeds of which will be used to defray the costs of transporting scrap tyres from tyre dealers to rubber-recycling plants (www.engineeringnews.co.za) and companies with an interest in tyre-derived fuels. The collection of tyres nationally will be administered and managed by the SATRP (RéSource, May 2004).

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Currently, there are 12 local companies that recycle tyres to various degrees (www.engineeringnews.co.za). The need for additional facilities that offer an appropriate disposal method is critical. The use of scrap tyres as an alternative fuel offers an environmentally acceptable and cost effective option for managing the scrap tyre problem in South Africa.

The Ulco plant envisages using scrap tyres as a major component of their AFR requirement, due to the relative abundance of scrap tyres and the availability of the scrap tyres in close proximity to the Kiln. The use of scrap tyres as an AFR has been an accepted world-wide practice for the past ten years (www.cement.bluecircle.co.uk), and has assisted in improving global waste management practices.

Tyres have the potential to be an ideal source of alternative fuel due to their inherent physical and chemical properties, such as:

• Environmentally inert – a tyre does not present a risk to the environment in its original form i.e. there is no risk of emissions to the environment. • Calorific Value - tyres have a higher calorific value (28 - 32 Mj/kg) than coal and therefore are an ideal candidate as a fuel resource. • Chemical composition – the hydrocarbon is totally consumed as energy, while the steel in tyres provides iron required in the cement production process. • Mechanical manipulation – tyres can be chipped, shredded or quartered to produce an easily manipulated fuel to feed into the kiln. • Transported and stored safely – the transport of tyres does not present a risk to the environment due to their physically and chemically inert nature. This is a major advantage over other forms of AFR.

In addition, there are a number of environmental advantages to using tyres as fuel as opposed to the stockpiling of the scrap tyres, including:

• Health benefits – scrap tyre stockpiles are ideal breeding habitats for a number of disease vectors e.g. mosquitoes and rodents. The utilisation of the tyres will result in the elimination of these breeding sites • Road Safety – a reduction in road accidents as fewer scrap tyres can be sold to unsuspecting vehicle owners as second hand tyres. Road accident statistics reveal that up to 53% of vehicle accidents are tyre related.

As a cement kiln burns fuel at temperatures in excess of 1 400°C (up to 2 000°C in the main flame), it is considered ideally suited to using tyres as a fuel (www.cement.bluecircle.co.uk; www.rmc.co.uk) as this ensures:

• complete destruction of the rubber and nylon content of the tyre, • no black smoke (from uncombusted components),

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• no smell, • the metal content of the tyre is incorporated into the cement clinker.

In order to successfully implement the AFR programme at Ulco plant's Kiln 5, 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 Ulco, 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 Ulco plant.

For the AFR streams that would be delivered directly to the kiln, an on-site storage facility would need to be provided to accommodate/store an approximate 2-day reserve capacity.

5.7.3 Conclusion

The correct management of the wastes and the AFR is critical to the success of this project and its operations. It is essential that AFR management is carried out in a manner that does not impact on human health and well being and the environment. The implementation of the procedures proposed in Chapter 7 (and Appendix I) would ensure that any possible impact is minimised and that the environmental and health risks are acceptable.

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 the material components from inorganic materials. • Conservation of non-renewable resources such as fossil fuels, i.e. coal and oil, and inorganic materials such as iron ore. • Reduction in landfill facilities required for the disposal of potentially polluting materials and an overall reduction in waste volumes to landfill.

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6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY

6.1 Introduction

Typical air pollutants from cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx), inhalable particulates (PM10), heavy metals, halogen compounds and dioxins and furans. The objective of the current investigation is to provide best estimates of air concentrations associated with the introduction of alternative fuels and resources (AFR).

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 will be made of readily available meteorological and air quality data recorded for the region.

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 will be based on available ambient air quality standards/guidelines. The comparison of predicted concentrations with ambient air quality guidelines facilitates a preliminary assessment of health risks.

A baseline study (current operating conditions) of the Ulco Plant has already been completed (Burger & Thomas, 2003) where coal was used as an energy source. C&M Environmental Engineering completed a more recent emissions monitoring campaign in September of 2004.

6.2 Terms of Reference

The terms of reference required to assess the impact of air pollution emanating from the proposed operations, are as follows:

• Update the baseline assessment using more recent emissions monitored data; • To identify pollutants resulting from the use of alternative fuels; • To quantify emissions of significant pollutants resulting from the use of alternative fuels; • Predict the highest hourly, the highest daily, and the annual average ground level concentration levels of the proposed use of alternative fuels; • Analyse the predicted air concentrations both for compliance and potential health risks; • Prepare a significance-rating matrix; and,

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• Recommend an air quality management plan.

6.3 Methodological Overview

An emissions inventory would be established for the proposed sources of emissions at Ulco. Such an inventory comprises of the identification and quantification of all significant sources. As inadequate quantifiable emission data is available, emission limits applicable to similar operations elsewhere would be employed.

Once the emission rates are known, mathematical dispersion modelling would be 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) will be 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 meteorological data is a necessity for the assessment of the atmospheric dispersion potential of the study site. Detailed hourly average wind speed, wind direction and temperature data was obtained from the Kimberley Weather Service Station for the period January 1996 to August 2001.

There are currently no air quality standards for South Africa. The Department of Environmental Affairs and Tourism (DEAT) have issued ambient air quality guidelines to support receiving environment management practices. Local ambient air quality guidelines are only available for such criteria pollutants that are commonly emitted, such as sulphur dioxide (SO2), lead (Pb), oxides of nitrogen (NOx), and particulates. The impact would be assessed using both these guidelines and peer-reviewed health risk criteria, such as those issued by the World Health Organisation (WHO), United States Environmental Protection Agency (US-EPA) and Agency for Toxic Substances and Disease Registry (ATSDR).

It is also important to ensure that the changes in the process would comply with the current Scheduled Process Certificates, which have been issued by the Chief Air Pollution Officer.

6.4 Baseline Assessment

A detailed discussion of the regional climate and atmospheric dispersion potential is given in Appendix A of the Air Quality specialist report contained in Appendix H.

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A summary of a previous baseline study done for the Ulco Plant (use of coal as a combustion fuel) is similarly included to provide insight as to the current air quality impacts. A more detailed discussion of this baseline is provided in Appendix C of the Air Quality specialist report contained in Appendix H.

6.4.1 Local Wind Field

The meteorological characteristics of a site impact on the rate of emissions from fugitive sources, and govern the dispersion, transformation and eventual removal of pollutants from the atmosphere (Pasquill and Smith, 1983; Godish, 1990). The extent to which pollution will accumulate or disperse in the atmosphere is dependent on the degree of thermal and mechanical turbulence within the earth’s boundary layer. Dispersion comprises vertical and horizontal components of motion. The vertical component is defined by the stability of the atmosphere and the depth of the surface mixing layer. The horizontal dispersion of pollution in the boundary layer is primarily a function of the wind field. The wind speed determines both the distance of downwind transport and the rate of dilution as a result of plume ‘stretching’. The generation of mechanical turbulence is similarly a function of the wind speed, in combination with the surface roughness. The wind direction, and the variability in wind direction, determines the general path pollutants will follow, and the extent of crosswind spreading (Shaw and Munn, 1971; Pasquill and Smith, 1983; Oke, 1990). Pollution concentration levels therefore fluctuate in response to changes in atmospheric stability, to concurrent variations in the mixing depth, and to shifts in the wind field. A detailed discussion of the regional climate and atmospheric dispersion potential is given in Appendix A of the Air Quality specialist report contained in Appendix H. A summation of the atmospheric dispersion potential for the area is discussed below.

Wind roses comprise 16 spokes, which represent the directions from which winds blew during the period. The colours and thickness of the spokes of the wind rose reflected the different categories of wind speeds, with the grey area (thinnest part of the spoke), 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, each dotted circle represents a 10% frequency of occurrence. The figure given in the centre of the circle described the frequency with which calms occurred, i.e. periods during which the wind speed was less than 1 m/s.

Annual and monthly wind roses effectively reflect the synoptic systems affecting a region. In order to investigate the impact of meso-scale circulation patterns it is also essential to consider the diurnal variations in the wind field at the site. The typical diurnal variations in the wind regime are evident in the day- and night- time wind roses illustrated in Figure 6.1.

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Figure 6.1: Wind roses for the period January 1996 to August 2001

The dominant wind direction is from the north with a 22% frequency of occurrence for the total period. Wind speeds of between 10–15 m/s are recorded from this dominant wind direction with few calm periods of 6,5%. Increased wind frequencies from the north-westerly sector are noted for daytime hours with calm periods of 3,2% occurring. Nocturnal airflow is characterised by more frequent winds from the north-north-east. Night-times have an increase in calm periods (10,1%) as is typical of the night-time flow regime in most regions.

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6.4.2 Impact Assessment at Holcim-Ulco 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 Ulco Plant. The guidelines used in the assessment are discussed in detail in Appendix B of the Air Quality specialist report contained in Appendix H and are further summarised in Section 6.5.

The main conclusions of the baseline impact assessment may be summarised as follows:

• PM10: The inhalable particulate concentrations (PM10) were below the daily and annual average current DEAT guidelines as well as the EC and proposed South African limits with highest offsite concentrations at 40 µg/m³ and 8 µg/m³ respectively;

• NO2: Predicted concentrations do not exceed the DEAT guidelines, with highest predicted off site concentrations measured at 57 µg/m³, 7 µg/m³ and 0.85 µg/m³ for highest hourly, daily and annual averaging periods respectively; • NO: Predicted ground level concentrations are below the DEAT guidelines by 21%, 69% and 92% for highest hourly, daily and annual averaging periods respectively;

• SO2: Predicted ground level concentrations are below the current DEAT guidelines as well as the proposed South African and EC limits, measuring 4µg/m³, 0.43 µg/m³ and 0.043 µg/m³ for highest hourly, daily and annual averaging periods respectively; • CO: Highest predicted hourly ground level concentration is less than 5% of the current and proposed South African guidelines of 40 000 µg/m³ and 30 000 µg/m³ respectively; • Lead: Predicted concentrations are less than 1% of the EU and proposed South African limits; • Benzene: Predicted concentrations are below proposed South African and EU limits; • Non-criteria pollutants – non-carcinogenic health effects: Predicted concentrations are all below the screening levels and health risk criteria; • Non-criteria pollutants – carcinogenic health effects: Carcinogenic pollutants for baseline conditions (based on initial baseline monitored emissions during 2002) are predicted to cause less than 1 in 1 million chance of cancer (trivial cancer risk criterion), with the exception of benzene and hexavalent chromium. The cancer risk due to benzene ranged from 0.4 to 1.5 in 1 million (based on US-EPA unit risk factors). Assuming all chromium to be hexavalent, the estimated cancer risk ranged from 1.6 to 19.5 in 1 million (WHO unit risk factors). However the hexavalent chromium is typically 10%

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of total chromium. Thus the incremental cancer risk using the WHO unit inhalation risk factors would be 0.2 to 2 in a million. It is therefore broadly acceptable (less than 1 in 100 thousand); • Dioxins and furans: Predicted concentrations are below the relevant guidelines for current and proposed operating conditions.

6.5 Environmental Legislation and Air Quality Guidelines

Prior to assessing the impact of the proposed operations at the Ulco Plant, reference need be made to the DEAT guidelines and other criteria 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 Sections 6.5.1 to 6.5.6. Permit specifications for emission concentrations are discussed in Section 6.5.7 and EC emission limits in Section 6.5.8.

6.5.1 Ambient Air Quality Standards and/or Guidelines for Criteria Pollutants

A detailed discussion on the health impacts, air quality standards and effect screening levels is given in Appendix B of the Air Quality specialist report contained in Appendix H.

There are currently no air quality standards for South Africa. DEAT have issued ambient air quality guidelines to support receiving environment management practices. Local ambient air quality guidelines are only available for such criteria pollutants that are commonly emitted, such as sulphur dioxide (SO2), lead (Pb), oxides of nitrogen (NOx), and particulates.

The following tables summarise a number of air quality standards adopted by certain countries. Also included in the tables are the proposed limit values, which forms the basis for the proposed South African Air Quality Standards.

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Table 6.1: Ambient air quality guidelines and standards for sulphur dioxide for various countries and organisations World World Health South European Averaging Bank Organisation US-EPA Africa Community Period (2002) (1999) µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 50(3) Annual Average 50(7) 50 80(1) 20(2) 10-30(10) Max. 24-hour 125(7) 125 125(3) 365(4) 125(5) Ave Max 1-hour Ave - - 350(9) - 350(6) Instantaneous 500(7)(8) - 500(3)(8) -- Peak Notes: (1) Arithmetic mean. (2) Limited value to protect ecosystems. Applicable two years from entry into force of the Air Quality Framework Directive 96/62/EC. (3) Air Quality guidelines (issued by the WHO for Europe) for the protection for human health (WHO, 2000). (4) Not to be exceeded more than 1 day per year. (5) Limit to protect health, to be complied with by 1 January 2005 (not to be exceeded more than 3 times per calendar year). (6) Limit to protect health, to be complied with by 1 January 2005 (not to be exceeded more than 4 times per calendar year). (7) Recommended interim guidelines for South Africa (Government Gazette, 21 Dec. 2001). (8) 10 minute average. (9) WHO 1994. (10) Represents the critical level of ecotoxic effects (issued by WHO for Europe); a range is given to account for different sensitivities of vegetation types.

Table 6.2: Current DEAT NOx guidelines. Ground Level Concentrations Averaging Period µg/m³ ppm Annual average 283 0.2 Max 24-hour average 566 0.4 Max 1-hour average 1132 0.8

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Table 6.3: Air quality standards for nitrogen dioxide (NO2). Annual Average Max 1-hour Average µg/m³ ppm µg/m³ ppm South Africa (Proposed) (5) 40 0.021 200 0.10 United States EPA 100(1) 0.053(1) -- European Community 40(2) 0.021(2) 200(3) 0.10(3) United Kingdom 40 0.021 286 0.15 Canada (4) 100 0.053 400 0.20 Notes: (1) Annual arithmetic mean. (2) Annual limit value for the protection of human health, to be complied with by 1 January 2010. (3) Averaging times represent the 98th percentile of averaging periods; calculated from mean values per hour or per period of less than an hour taken throughout the year; not to be exceeded more than 8 times per year. This limit is to be complied with by 1 January 2010. (4) Acceptable Canadian air quality objectives. (5) SABS, 2004.

Table 6.4: Air quality standards for inhalable particulates (PM10) Maximum 24-hour Annual Average Concentration (µg/m³) Concentration (µg/m³) South Africa (Proposed) (9) 75 40 United States EPA 150(1)(2) 50(3) European Union (EU) 130(4) 80 250(5) European Community (EC) 30(7) 50(6) 20(8) Canada 24 - Reference: Chow and Watson, 1998; Cochran and Pielke, 1992. Notes: (1) Requires that the three-year annual average concentration be less than this limit; (2) Not to be exceeded more than once per year; (3) Represents the arithmetic mean; (4) Median of daily means for the winter period (1 October to 31 March); (5) Calculated from the 95th percentile of daily means for the year; (6) Compliance by 1 January 2005. Not to be exceeded more than 25 times per calendar year. (By 1 January 2010, no violations of more than 7 times per year will be permitted.) (7) Compliance by 1 January 2005; (8) Compliance by 1 January 2010; (9) SABS, 2004.

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Table 6.5: Air quality standards for lead Quarterly Average (µg/m³) Annual Average (µg/m³) South Africa (Proposed) (2) -0.5 United States EPA 1.5 - European Union - 2.0 Germany (1986) - 2.0 United Kingdom - 0.5(1) Note: (1) Limit to be achieved by 2005, given as part of UK’s national air quality management plan. (2) SABS, 2004.

6.5.2 Volatile Organic Compounds

The volatile organic compounds of benzene and toluene were analysed during the current study. The standards for benzene, as proposed by various countries, are provided in the table below.

Table 6.6: Air quality standards for benzene Long Term Goal/Limit Country/Organisation Annual Average (µg/m³) (µg/m³) South Africa (Proposed) (3) 10 5 Australia 10 2.5 Great Britain 10 1.3 Germany 10(2) - European Community 10 5(1) Notes: (1) Limit value to be reached by 1 January 2010 (2) In effect as of 1 July 1998. (3) SABS, 2004.

In humans, toluene is a known respiratory irritant with central nervous system (CNS) effects. The inhalation Reference Concentration (RfC) is based on the assumption that thresholds exist for certain toxic effects such as cellular necrosis. The inhalation RfC considers toxic effects for both the respiratory system (portal- of-entry) and for effects peripheral to the respiratory system (extra respiratory effects). For toluene the RfC is 0,4 mg/m³. In general, the RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily inhalation exposure of the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime (EPA, 1992).

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6.5.3 Effect Screening Levels1 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 Level’s (MRLs) have been used (see Table 6.7).

6.5.4 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, including among others 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.

1 Effects Screening Levels (ESLs) are used to evaluate the potential for effects to occur as a result of exposure to concentrations in air. As no DEAT guidelines are available for comparison these ESLs will be used for comparison during the current study. ESLs are based on data concerning health effects, odour nuisance potential, vegetation effects, or corrosion effects. They are not ambient air standards. If predicted or measured airborne levels of a constituent do not exceed the screening level, we would not expect any adverse health or welfare effects to result.

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Table 6.7: Effect screening and health risk criteria for various substances included in the investigation RAIS Inhalation Reference California OEHHA (Sept ATSDR MRL’s (Jan WHO Guidelines (2000) Concentrations (Jan 2002) (µg/m³) 2004) (µg/m³)(b) (µg/m³) 2004) (µg/m³) Constituent Sub- Chronic Acute & Sub- chronic Acute RELs Chronic Chronic inhalation Acute Chronic acute inhalation (a) RELs Guidelines RfCs Guidelines RfCs Arsenic & inorganic compounds 0.19 (4 hrs) 0.03 Barium 0.5(e) 5(e) Benzene 30 (d) 1300 (6hrs) 60 160 Beryllium 0.02 (d) Cadmium & compounds (as Cd) 0.9 (f)(c) 0.02 0.005 Chromium (VI) compounds 0.1 (d) 0.2 Cobalt & inorganic compounds 0.02 0.1 Copper: dust & mist 100 (1 hr) Mercury, metal & inorganic forms 0.3(f) 0.3(d) 1.8 (1 hr) 0.09 0.2 1.0 Nickel, metal & insoluble compounds 6.0 (1 hr) 0.05 0.09 Hydrogen chloride 20(d) 2100 (1 hr) 9 Hydrogen fluoride 240 (1 hr) 16 (a) Averaging period given in brackets; (b) ATSDR MRL’s are listed for pollutants and averaging periods that do not have other health criteria; (c) Provisional risk assessment values; (d) Source: Integrated Risk Information System (IRIS); (e) Source: Health Effects and Environmental Affects Summary Table (HEAST) 1995; Dates withdrawn (f) July 1997.

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Table 6.8: Toxicity equivalency factors for dioxins and furans Congener TEF (WHO) Mono-, di- and tri-chlorodibenzodioxins 0 2,3,7,8-Tetrachlorodibenzodioxin (TCDD) 1 Other TCDD’s 0 1,2,3,7,8-Pentachlorodibenzodioxin (PeCDD) 1 Other PeCDD’s 0 1,2,3,4,7,8-Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,6,7,8- Hexachlorodibenzodioxin (HxCDD) 0.1

DIOXINS 1,2,3,7,8,9- Hexachlorodibenzodioxin (HxCDD) 0.1 Other HxCDD’s 0 2,3,7,8-Heptachlorodibenzodioxin (HpCDD) 0.01 Other HPCDD’s 0 Octachlorodibenzodioxin (OCDD) 0.0001 Mono-, di- and tri-chlorodibenzofurans 0 2,3,7,8-Tetrachlorodibenzofuran (TCDF) 0.1 Other TCDF’s 0 1,2,3,7,8-Pentachlorodibenzofuran (PeCDF) 0.05 2,3,4,7,8-Pentachlorodibenzofuran (PeCDF) 0.5 Other PeCDF’s 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 FURANS 2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 Other HxCDF’s 0 1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF) 0.001 1,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF) 0.001 Other HPCDF’s 0 Octachlorodibenzofuran (OCDF) 0.0001

For dioxin-like compounds, the WHO specifies a tolerable daily intake (TDI), which has been defined in units of toxicity equivalent (TEQ)2 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).

Assuming that all of the dioxin to which a 70 kg person is exposed is absorbed, and given an average breathing rate of 1 m3/hr, the tolerable daily intake (TDI)

2 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 Impacts on Air Quality95 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province of the US-EPA, ATSDR and WHO could be calculated to coincide with 24-hour inhalation concentrations of the following:

• US-EPA: 2.0 x 10-7 µg/m3 • ATSDR: 2.91 x 10-5 µg/m3 • WHO: 2.91 x 10-5 to 1.17 x 10-4 µg/m3

The USEPA unit cancer risk factor for dioxins is 33 (µg TEQ/m3)-1. The annual average air concentration at the position of maximum exposure corresponding with a cancer risk of one in a hundred thousand is 3.03 x 10-7 µg/m3. This does not take into account exposure through the other potential pathways.

6.5.5 Cancer Risk Factors

Unit risk factors are applied in the calculation of carcinogenic risks. These factors are defined as the estimated probability of a person (60-70 kg) contracting cancer as a result of constant exposure to an ambient concentration of 1 µg/m3 over a 70-year lifetime. In the generic health risk assessment undertaken as part of the current study, maximum possible exposures (24-hours a day over a 70-year lifetime) are assumed for all areas beyond the boundary of the site.

Unit risk factors were obtained from the WHO (2000) and from the US-EPA IRIS database (accessed July 2003). Unit Risk Factors for compounds of interest in the current study are given in Table 6.9.

6.5.6 Permit Specifications

For the current study the permit specifications for PM10 stack emissions were used (see Table 6.10). Emission concentrations specified as part of this permit are expressed at 0°C and 101.3 kPa.

6.5.7 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 incinerators is given in Table 6.11. Emission concentrations specified as part of these regulations are expressed at 0°C and 101,3 kPa, dry gas and 10% oxygen.

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Table 6.9: Unit risk factors from the US-EPA Integrated Risk Information System (IRIS) (as at July 2003) and WHO risk factors (2000) US-EPA WHO Inhalation Unit Risk US-EPA Unit Risk Chemical -1 -1 Cancer Class (µg/m³) Factor (µg/m³) (a)

Arsenic, inorganic 1.5 x10-3 4.3 x10-3 A Benzene 6 x10-6 2.2 x10-6 to 7.8 x10-6 A Beryllium - 2.4 x10-3 B1 Cadmium - 1.8 x10-3 B1 Chromium VI 1.1 x10-2 to 13 x10-2 and a 1.2 x10-2 A (particulates) geometric mean of 4 x10-2 Nickel 3.8 x10-4 2.4 x10-4 A Note: (a)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.

Table 6.10: Permit specifications for stack PM10 emissions Emission Permit Nature of Height Limits for Division Extraction System No. Process (m) Particulates (mg/Nm³) Electrostatic Kiln and Raw Mill 110 150 Precipitator Cement Coal Mill 50 150 Bag Filter 65/6 Processes Cement Mill 5 50 150 Bag Filter (No. 22) Electrostatic Cement Mill 6 50 150 Precipitator

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Table 6.11: The comparison of EC emission limit values for emissions from co- processing of waste in cement kilns (Directive 2000/76/EC) and DEAT class 1 incinerator DEAT Limit EU Directive 2000/76/EC Pollutant (Class 1 (Cement Kiln co- Units incinerator) processing) Total dust 150 30 mg/Nm³ HCl 30 10 mg/Nm³ HF 30 1 mg/Nm³ (a) NOx for existing plants 800 (b) mg/Nm³ NOx for new plants 500

SO2 25 50 mg/Nm³ TOC 10 mg/Nm³ Cd + Tl 0.05 (c) 0.05 mg/Nm³ Hg 0.05 0.05 mg/Nm³ Sb + As + Pb + Cr + Co 0.5 (c) 0.5 mg/Nm³ + Cu + Mn + Ni + V Dioxins toxic equivalence 0.2 0.1 ng/Nm³ Notes: (a) For existing plants (b) For new plants (c) Limit value for each individual element.

6.6 Process Description and Emissions Inventory

The establishment of an emissions inventory comprises the identification of sources of emission, and the quantification of each source's contribution to ambient air pollution concentrations. The emission sources of concern for proposed usage of alternative fuels consisted of the Kiln, Cement Mill 5 and Cement Mill 6, Raw Mill, and the Coal Mill. An emissions inventory for the Kiln (with the exception of PM10) was established using EC limits (as inadequate quantitative information was available for the current study), forming the basis for assessing the impact of the Ulco Plant on the receiving environment. Proposed PM10 emissions were based on 50 mg/Nm³, as this emission concentration is likely to be the proposed permit for the kiln.

The following summary has been included, detailing findings made available in literature regarding the emissions previously quantified due to the combustion of alternative fuels in cement kilns. In addition Holcim will be looking at using tyres as their primary alternative fuel source for the partial substitute for coal, and thus particular information regarding this source has been included in the summary

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6.6.1 Studies on Emissions from Cement Kilns Burning Alternative Fuels

• Oxides of Nitrogen Emissions All combustion processes primarily produce NO with a much smaller

proportion of NO2 (<5%). In cement kilns NO is formed only at elevated temperatures (>800°C). The main areas of formation will be from the main flame and 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. Flame temperature, oxygen content, residence time and the nitrogen in the fuel and in the air determines the formation of NO. As these parameters are to remain similar and the nitrogen in the alternative fuel not differing significantly from that of coal the emissions are expected to remain comparable to that of baseline conditions. In the combustion of waste tyres

in particular, it has been found to results in lower NOx emissions when compared to many U.S. coals, particularly the high-sulphur coals.

In addition, the US-EPA emission factors for cement kilns equates to 2,1 kg/tonne clinker (EPA, 1996). The equivalent emission factor using the

EC emission limit for NOx is similar at 1,96 kg/tonne clinker. Measured NOx emission ranges from European cement kilns are in the range of <0,4-6 kg/tonne clinker (AEA Technology, 2002).

• Sulphur Dioxide Emissions

SO2 is formed from sulphur in raw material and fuel. Under normal conditions any sulphur introduced into the rotary kiln or the secondary firing/precalciner part of the preheater/precalciner kiln system only

marginally contributes to the kiln’s SO2 emissions. This is different with the sulphur in the form of sulphides and organic sulphur contained in the raw meal and fed in the usual way to the preheater top cyclone. About 30% of

this sulphide and organic sulphur input leave the preheater as SO2. The sulphur content in coal is ~0.86% and in alternative fuels (specifically tyres)

is ~1.63% (pers. comm. ACMP). However, SO2 emissions are to a large extent determined by the chemical characteristics of the raw materials used, and not by the fuel composition (CEMBUREAU, 1999).

The 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 behaviour 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 predominantly leave the kiln as part

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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. In practice this is what occurs in preheater systems as the kiln gases preheat the incoming raw materials. 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 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) (see Table 6.12). Dioxin measurements done by INFOTOX (Pty) Ltd (2002) at the Ulco Plant were between 0,086 to 0,094 µg TEQ/tonne clinker. The equivalent emission factor using the EC emission limit is 0,25 µg TEQ/tonne clinker.

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Table 6.12: International emissions data for cement production emissions of dioxins Study Dioxin Emissions (µg TEQ/tonne clinker) Australia - Standard fuel 0.0043 – 0.25 - With waste derived fuel 0.0087 – 0.28 US (US EPA, 2000) - Standard fuel 0.27 - With waste derived fuel 1.04 (pollution control device inlet temp < 450°F) UK - Standard fuel 0.025 – 1.04 - With waste derived fuel 0.025 – 1.08

6.6.2 Limitations of the Given Source Inventory

• Process Emissions Actual emissions for the proposed usage of alternative fuels in the Kiln at the Ulco 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 potentially affect stack emissions.

• Decommissioning and Start-Up Phase The decommissioning phase of current operations at the Kiln, as well as the start-up phase for proposed usage of alternative fuels in the Kiln was not investigated during the current study. Information pertaining to changes in emission rates, and the duration and sequence of these changes are not known. The process design for the current study was not at an advanced enough stage to provide this information.

6.6.3 Emission Inventory for Proposed Usage of Alternative Fuels and Resources

The source data requirements of the model are dependent on the manner in which sources are classified, viz. as area, point or volume sources. Stack releases are the only source type evident at the plant and will be modelled as point sources. Stack parameters required for the simulation of point sources include: source location, stack height, gas exit velocity, temperature and stack diameter. The main pollutants of concern resulting from the current and proposed routine operating conditions consisted of SO2, NOx, PM10, heavy metals and

Assessment of Impacts on Air Quality101 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province dioxins and furans from the Kiln, and PM10 emissions from the two Cement Mills, Raw Mill and Coal Mill. As the volumetric flow rate of the Kiln with the proposed usage of alternative fuel is unknown, the volumetric flow rate under current operating conditions was assumed. Information regarding the stack parameters and emission rates needed for the dispersion simulations is presented in Table 6.13. A summary of the total emissions from the Ulco Plant is given in Table 6.14 to Table 6.16.

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 the current monitored emissions provided 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, while mercury similarly decreases.

Table 6.13: Stack parameters for the Ulco Plant for proposed usage of alternative fuels Temperature Exit Velocity Source Height (m) Diameter (m) (°C) (m/s) Kiln(2) 110 4.5 115.6 11 Cement Mill 5 50 1.25 96 2 Cement Mill 6 50 1.5 98 2 Raw Mill(1) 110 4.5 115.6 11 Coal Mill 50 1.4 85 7.2 (1) The emissions are diverted to the Kiln stack; (2) As the volumetric flow rate of the Kiln with the proposed usage of alternative fuel is unknown, the volumetric flow rate under current operating conditions was assumed.

Table 6.14: Emission rates for criteria pollutants from the stacks at the Ulco Plant for proposed usage of alternative fuels Emissions measured in (g/s) Source PM10 NOx SO2 Kiln (1) 6.2 (5) 99.96 6.25 Cement Mill 5 (2) 0.1 Cement Mill 6 (2) 1.8 Coal Mill (3)(4) 1.8 (1) Emissions based on EC limits. (2) Estimated data provided by Holcim South Africa. (3) Emissions based on permit specifications. (4) As the quantity of coal to be replaced by alternative fuel was unknown for the current study, current baseline conditions were assumed as a conservative approach. (5) An emission concentration at 50mg/Nm³ was simulated, as this is likely to be the proposed permit for the kiln.

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Table 6.15: Heavy Metal and Dioxin and Furan Emissions from the Kiln with proposed usage of alternative fuels (a). Compound Emission (g/s) Beryllium 7.2 x10-6 Total Chromium 2.7 x10-2 Cobalt 2.5 x10-3 Nickel 6.1 x10-3 Copper 1.3 x10-2 Arsenic 1.0 x10-3 Silver 1.9 x10-3 Cadmium 9.1 x10-6 Antimony 6.8 x10-4 Mercury 6.2 x10-3 Thallium 6.2 x10-3 Lead 1.3 x10-2 Dioxin Toxic Equivalence 1.2 x10-8 (a) Composition of emissions were based on measured emissions from C&M Environmental Engineers (2002).

Table 6.16: Halogen Compound Emissions from the Kiln for proposed usage of alternative fuels (a) Compound Emission (g/s) HCl 1.25 HF 0.13 (a) Emissions were based on EC emission limits.

6.6.4 Emission Estimation

Emission limits are given for chromium with no provision being made for the form in which the chromium is emitted. Since hexavalent chromium is considered to be a carcinogen, it is significantly more important than the trivalent and other valences. Hexavalent chromium from combustion processes is typically 10% of the total chromium emissions (UK, 2002). It will also be important to establish the actual chromium compounds, because carcinogenicity has been linked only to certain chromium salts, namely, calcium chromate, chromium trioxide, lead chromate, strontium chromate and zinc chromate.

6.6.5 The Comparison of Simulated Emissions to Permit Specifications

The PM10 emissions from the Kiln under proposed (usage of alternative fuels) operating conditions (50 mg/Nm³) are within the current permit requirements of 150 mg/Nm³. The PM10 emissions from the Cement Mill 5, Cement Mill 6 and Coal Mill are within the permit requirements.

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6.7 Dispersion Simulation Methodology and Data Requirements

Dispersion models compute ambient concentrations as a function of source configurations, emission strengths and meteorological characteristics, thus providing a useful tool to ascertain the spatial and temporal patterns in the ground level concentrations arising from the emissions of various sources. Increasing reliance has been placed on concentration estimates from models as the primary basis for environmental and health impact assessments, risk assessments and emission control requirements. It is therefore important to carefully select a dispersion model for the purpose.

For the purpose of the current study, it was decided to use the well-known US- EPA Industrial Source Complex Short Term model (ISCST3). The ISCST3 model is included in a suite of models used by the US-EPA for regulatory purposes. ISCST3 (EPA, 1995a and 1995b) is a steady state Gaussian Plume model, which is applicable to multiple point, area and volume sources. Gently rolling topography may be included to determine the depth of plume penetration by the underlying surface. A disadvantage of the model is that spatial varying wind fields, due to topography or other factors cannot be included. A further limitation of the model arises from the models treatment of low wind speeds. Wind speeds below 1 m/s produce unrealistically high concentrations when using the Gaussian plume model, and therefore all wind speeds below 1 m/s are simulated using 1m/s.

Concentration for various averaging periods may be calculated. It has generally been found that the accuracy of off-the-shelf dispersion models improve with increased averaging periods. The accurate prediction of instantaneous peaks are the most difficult and are normally performed with more complicated dispersion models specifically fine-tuned and validated for the location. The duration of these short-term, peak concentrations are often only for a few minutes and on- site meteorological data are then essential for accurate predictions.

The Industrial Source Complex model is perhaps the most used model for 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

Assessment of Impacts on Air Quality104 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province total uncertainty can be thought of as the sum of three components: 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. At best the source emissions are known with an uncertainty of only ±5%. It is more common to have uncertainties in emissions data of ±10% and process variations of up to ±50%. These variations translate directly into a minimum error of that magnitude in the model predictions. It is also well known that wind direction errors are the major cause of poor agreement, especially for relatively short-term predictions (minutes to hourly) and long downwind distances. All of the above factors contribute to the inaccuracies not even associated with the mathematical models themselves.

Input data types required for the ISCST3 model include: source data, meteorological data, terrain data and information on the nature of the receptor grid.

6.7.1 Meteorological Requirements

ISCST3 requires hourly average meteorological data as input, including wind speed, wind direction, a measure of atmospheric turbulence, ambient air temperature and mixing height. The hourly average data was obtained from the Weather Service in Kimberley for the period January 1996 to August 2001. The mixing height for each hour of the day was estimated for the simulated ambient temperature and solar radiation data. Daytime mixing heights were calculated with the prognostic equations of Batchvarova and Gryning (1990), while nighttime boundary layer heights were calculated from various diagnostic approaches for stable and neutral conditions.

6.7.2 Receptor Grid

The dispersion of pollutants emanating from the plant was modelled for an area covering ~5 km by ~5 km. The area was divided into a grid matrix with a resolution of ~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.

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The two prominent base levels, one below the escarpment delineating the edge of the Ghaap Plateau and the other that of the Ghaap Plateau which lies to the west of Ulco, was inputted as topography into the ISCST3 model.

6.7.3 Source Data Requirements

Emission rates for Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill provided by Holcim South Africa and emission rates based on EC limits for the Kiln, were used in the dispersion simulations for proposed (use of alternative fuel) operating conditions of these sources.

6.7.4 Building Downwash Requirements

Building heights need to be taken into account in the modelling of emissions so as to account for building downwash effects in the dispersion simulations. The flow characteristics of air moving over the factory and office buildings may include a downwash on the leeward side, drawing the plume to the ground near the source. (Stack heights of greater than twice the height of adjacent buildings are considered not to give rise to the potential for building downwash effects). Building down-wash algorithms have been developed for air quality dispersion models such as the ISCST3. These algorithms require additional input to be prepared and were included in the model runs.

6.8 Atmospheric Dispersion Results and Discussion

6.8.1 Impact Assessment of Criteria Pollutants

A synopsis of the highest hourly, highest daily and annual average criteria pollutant concentrations predicted to occur is given in Table 7-1 (plots indicating the impact due to these pollutants are given in Appendix D). Predicted concentrations were compared with current DEAT air quality guidelines to determine compliance. Since South Africa is in the process of revising these guidelines it was necessary to compare the predicted concentrations with the limits proposed for adoption by South Africa. Reference was also made to the widely referenced EC limit values, which are considered to represent 'best practice' limits, which closely reflect WHO guidelines. The results of these comparisons are reflected in Table 6.17.

• Inhalable Particulates (PM10) Highest daily and annual predicted off-site PM10 ground level concentrations under current and proposed operating conditions are below the current Department of Environmental Affairs and Tourism (DEAT) guidelines as well as the EC and proposed South African limits.

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Table 6.17: Maximum offsite concentrations of criteria pollutants (measured in µg/m³) at the Ulco Plant boundary predicted to occur with the introduction of alternative fuels. Table includes predicted emissions as a percentage of listed air quality guidelines and standards (a)(b) Maximum Predicted Maximum Predicted Concentrations Maximum Predicted Maximum Predicted Ground Level Concentrations as a Percentage as a Percentage of Proposed SA Air Concentrations as a Percentage Concentrations (µg/m³) of Current SA Air Quality Pollutant Quality Limits (a) of EC Air Quality Limits (a) Guidelines (a) Highest Highest Annual Highest Highest Annual Highest Highest Annual Highest Highest Annual hourly daily average hourly daily average hourly daily average hourly daily average PM10(c) - 31.5 6.5 - 18 11 - 42 16 - 63 22 (d) NOx 550 140 22 49 25 8 ------

NO2 80 20 3 21 10 3 40 - 7.5 40 - 7.5

SO2 35 9 1.3 - 7 3 - 7 3 10 7 7 <1 (e) Lead - - 0.0028 ------<1 1 (f) Notes: (a) A percentage of 100 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Greater than 100 indicates an exceedance of such limits. (b) The actual air quality guidelines and limits referred to are documented in Section 3. (c) Emissions from the Kiln were proposed to be 50 mg/Nm³ (proposed permit emission level).

(d) Guidelines are not usually specified for NOx. However the Department of Environmental Affairs and Tourism provides guideline levels for this group.

EC limits are only specified for NO2 ground level concentrations (to be complied with by the 1 January 2010). (e) It has been proposed that the South African limit for lead be revised with the adoption of an annual average limit of 0.5 µg/m3 (f) The proposed South African limit for lead of 0.25 µg/m3 is recommended as the level to be aimed for in the longer term.

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Table 6.18: Maximum offsite concentrations of non-criteria pollutants (measured in µg/m³) at the Ulco Plant boundary predicted to occur with the introduction of alternative fuels. Table includes predicted emissions as a percentage of various effect screening and health risk criteria (a)(b)

Maximum Predicted Concentrations as a Maximum predicted ground level Effect Screening or Health Risk Criteria (b) Percentage of the Respective Effect concentrations (µg/m³) Screening or Health Risk Criteria (a) Pollutant

Highest Annual Highest Annual Highest Annual Highest daily Highest daily Highest daily hourly average hourly (c) average hourly average

Total Chromium 1.71 x 10-1 2.09 x 10-2 2.85 x 10-3 - - 1 x 10-1 --3 Cobalt 1.58 x 10-2 1.9 x 10-3 2.66 x 10-4 - - 2 x 10-2 --1 Beryllium 4.75 x 10-5 5.7 x 10-6 7.98 x 10-7 - - 2 x 10-2 --<1 Nickel 3.99 x 10-2 4.94 x 10-3 6.84 x 10-4 6 x 100 -5 x 10-2 1-1 Copper 8.36 x 10-2 1.04 x 10-2 1.42 x 10-3 1 x 102 --<1-- Arsenic 6.46 x 10-3 7.98 x 10-4 1.1 x 10-4 1.9 x 10-1 -3 x 10-2 3-<1 Cadmium 5.67 x 10-5 7.37 x 10-6 1.02 x 10-6 - - 5 x 10-3 --<1 Mercury 4.07 x 10-2 4.89 x 10-3 6.79 x 10-4 1.8 x 100 -3 x 10-1 2-<1 Dioxin Toxic equivalence 6.90 x 10-8 1.7 x 10-8 2.7 x 10-9 -2 x 10-7 --9- HCl 6.9 x 100 1.7 x 100 2.7 x 10-1 2.1 x 103 -2 x 101 <1 - 1 HF 6.9 x 10-1 1.7 x 10-1 2.7 x 10-2 1.6 x 101 --4-- Notes: (a) A percentage of 100 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Greater than 100 indicates 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.

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Table 6.19: Predicted maximum annual average concentrations of various carcinogens through the combined use of alternative fuel and coal at the Ulco Plant and resultant cancer risks (assuming maximum exposed individuals) Cancer Risk (calculated Predicted Maximum Cancer Risk (calculated based on the WHO Inhalation US-EPA Unit Risk based on the application Carcinogen Annual Average application of unit risk given in the Unit Risk (µg/m³)-1 Factor (µg/m³)-1 of unit risk given in the Concentration (µg/m³) WHO database) RAIS database)

Arsenic 1.10 x 10-4 1.5 x 10-3 4.3 x 10-3 1.7 in 10 million 4.7 in 10 million Cadmium 1.02 x 10-6 -1.8 x 10-3 - 1.8 in 1 billion Chromium VI (b) 2.85 x 10-4 4 x 10-2 (c) 1.2 x 10-2 1.1 in 100 thousand (a)(c) 3.4 in 1 million (a) Nickel 6.84 x 10-4 3.8 x 10-4 2.4 x 10-4 2.6 in 10 million 1.6 in 10 million Dioxin Toxic Equivalence 2.7 x 10-9 - 33 - 8.9 in 100 million Notes: (a) Cancer risk exceeding 1 in 1 million (trivial cancer risk criterion) (b) Chromium VI is assumed to be 10% of the total chromium (c) Based on the cancer risk factor represented as the geometric mean. The unit cancer risk as stipulated by the WHO to ranges from 1.1E-02 to 13E-02 respectively.

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• Oxides of nitrogen (NOx)

For current operating conditions, highest predicted off-site NO2 and NO

ground level concentrations are below DEAT as well as the NO2 EU and

proposed South African limits. Highest hourly, daily and annual NO2 ground level concentrations are predicted to be 57µg/m³, 7 µg/m³ and 0.85 µg/m³

respectively. This does not include the NO2 formed from NO further downwind from the source. However, the NO concentration at these distances would already be significantly diluted after the atmospheric conversion.

Under proposed operating conditions, highest predicted off-site NOx ground level concentrations for highest hourly, daily and annual average concentrations at 550 µg/m³, 140 µg/m³ and 22 µg/m³ are below the current respective DEAT guidelines.

Based on current monitored data from C&M Consulting (September, 2004)

NO2 emissions consisted 14,5% of the total NOx emissions. Using this criteria 3 for proposed operating conditions, predicted NO2 ground level concentrations are 75% of the current DEAT guidelines and less than 60% of the EU standards.

• Sulphur Dioxide (SO2) For baseline conditions the predicted sulphur dioxide ground level concentrations are below the current DEAT guidelines as well as proposed SA and EC limits, measuring 4 µg/m³, 0,43 µg/m³, and 0,043 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 (~1.6%).

However, SO2 are to a large extent determined by the chemical characteristics of the raw materials used, and not by the fuel composition

(CEMBUREAU, 1999). Therefore the predicted SO2 emissions (even if tyres would replace all the coal) are expected to remain relatively similar to that of baseline conditions.

3 The formation of NO emissions released from the kiln, is determined by flame temperature, oxygen content, residence time and nitrogen content in fuel and in air. As these parameters are to remain constant with nitrogen content of the alternative fuel unknown but not expected to be much different from coal, NO2 should remain the same as current operating conditions.

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• Lead Predicted lead concentrations for current and proposed operating conditions are predicted to be less than 2% of the EU and proposed SA limits.

• Permit Specifications The PM10 emissions from the Kiln, Cement Mill 5, Cement Mill 6, and Coal Mill for baseline conditions are within permit requirements. The PM10 emissions (50 mg/Nm³) from the Kiln under proposed (usage of alternative fuels) operating conditions are within the current permit requirements of 150 mg/Nm³.

6.8.2 Results for Non-Criteria Pollutants: Potential for Environmental and Non-Carcinogenic Health Effects

• Impact Assessment A synopsis of the highest hourly, highest daily and annual average non- criteria pollutant concentrations predicted to occur due to the proposed use of alternative fuel is given in Table 6.18. The predicted concentrations were compared with the World Health Organisation (WHO) guidelines, Risk Assessment Integration System (RAIS) Inhalation reference concentrations (US Environmental Protection Agency (US-EPA)), the California Office of Environmental Health Hazard Assessment (OEHHA) and the Agency for Toxic Substances and Disease Registry (ATSDR) Minimal Risk Levels (MRLs).

However, as indicated in Table 6.18 (proposed operating conditions) and Table C-7 in Appendix C (current operating conditions) of the Air Quality specialist study contained within Appendix H, predicted ground level concentrations for non-criteria pollutants did not exceed the effect screening or health risk criteria.

Predicted benzene ground level concentrations (see Table C-8: Appendix C of the Air Quality specialist study contained within Appendix H) for annual averaging periods under current operating conditions were below the EC and proposed South African limits. The predicted levels are expected to remain the same due to the high destruction efficiency (typical destruction efficiencies are 99.99% (Lemarchand, 2000)).

6.8.3 Results for Non-Criteria Pollutants: Potential for Carcinogenic Effect

A synopsis of the maximum annual average concentrations of the carcinogenic pollutants predicted to occur due to proposed usage of alternative fuels is provided in Table 6.19.

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In assessing the results presented in Table 6.19 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:

• Hexavalent chromium was assumed to be 10% of the total chromium. This assumption is based on an overview of a report produced for the Department for Environment, Food & Rural Affairs, the National Assembly for Wales, The Scottish Executive and the Department of the Environment in Northern Ireland entitled, UK Particulate and Heavy Metal Emissions from Industrial Processes. (UK, 2002). • 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.

With the exception of benzene (current operating conditions) and hexavalent chromium (current and proposed operating conditions), all carcinogenic pollutants for current and proposed operating conditions were predicted to cause less than 1 in 1 million chance of cancer (trivial cancer risk). Under current operating conditions the cancer risk due to benzene (see Table C-9: Appendix C of the Air Quality specialist study contained within Appendix H) ranged from 0,4 to 1,5 in 1 million (based on US-EPA unit risk factors), which is broadly acceptable (1 in 1 million).

Based on the assumption that hexavalent chromium is typically 10% of total chromium, the incremental cancer risk using the WHO unit inhalation risk factors would be 0,6 in a million for baseline conditions. This is broadly acceptable (less than 1 in 1 million). However, using EC limits (i.e. proposed operating conditions) the cancer risk for hexavalent chromium increases to 1,1 in one hundred thousand (WHO unit risk factors) assuming 10% of total chromium.

6.9 Significance Rating

The extent, frequency, severity, duration and significance of the baseline and proposed usage of alternative fuels is categorised in Table 6.20 to Table 6.23 respectively.

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Based on the significance rating categories supplied by Bohlweki Environmental (Pty) Ltd, the significance for baseline conditions (for all pollutants of concern) was predicted to be low for criteria pollutants (see Table 6.20) and moderate for non-criteria pollutants (see Table 6.21) based on hexavalent chromium.

Under proposed operating conditions (usage of alternative fuels), the significance for all criteria pollutants of concern is predicted to remain low (see Table 6.22) with the significance for non-criteria pollutants (based on hexavalent chromium) as high (see Table 6.23).

Table 6.20: Significance rating from the baseline study (a) (for all criteria 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 the Kiln, Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill. (b) Based on criteria and screened against DEAT guidelines. (c) Impacts are not constant as they depend on the meteorological conditions and dispersion potential of the atmosphere.

Table 6.21: Significance rating from the baseline study (a) (for all non-criteria pollutants of concern) Scale Significance Rating Temporal Long term Spatial Localised Severity Moderately severe (b) Significance Moderate (b) Risk or likelihood May occur (c) Degree of certainty or confidence Probable Notes: (a) Routine operating conditions using the Kiln, Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill. (b) Based on hexavalent chromium assuming 10% of total chromium exceeding the cancer risk criteria of 1 in 1 million (trivial cancer risk), but below the cancer risk of 1 in 100 thousand (broadly acceptable cancer risk). (c) Impacts are not constant as they depend on the meteorological conditions and dispersion potential of the atmosphere.

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Table 6.22: Significance rating including the proposed usage of alternative fuel (a) (for all criteria 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 the Kiln, Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill. (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 6.23: Significance rating including the proposed usage of alternative fuel (a) (for all non-criteria pollutants of concern). Scale Significance Rating Temporal Long term Spatial Localised Severity Moderately severe (b) Significance High (b) Risk or likelihood May occur (c) Degree of certainty or confidence Probable Notes: (a) Routine operating conditions using the Kiln, Cement Mill 5, Cement Mill 6, Raw Mill and Coal Mill. (b) Based on hexavalent chromium assuming 10% of total chromium exceeding the cancer risk criteria of 1 in 1 million (trivial cancer risk), but below the cancer risk of 1 in 100 thousand (broadly acceptable cancer risk). (c) Impacts are not constant as they depend on the meteorological conditions and dispersion potential of the atmosphere.

6.10 Description of Aspects and Impacts

The rating system used for assessing impacts is based on three criteria, namely:

• The relationship of the impact/issue to temporal scales; • The relationship of the impact/issue to spatial scales; and, • The severity of the impact/issue.

These three criteria are combined to describe the overall importance rating, namely the significance (Text Box 6.1). In addition the following parameters are used to describe the impact/issues:

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• The risk or likelihood of the impact/issue occurring; and, • The degree of confidence placed in the assessment of the impact/issue.

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.

6.11 Conclusions and Recommendations

The investigation included the simulation of inhalable particulates, nitrogen oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and halogen compounds.

The main conclusions may be summarised as follows:

• NO2: Current predicted off site concentrations of 57 µg/m³, 7 µg/m³ and 0,85 µg/m³ did not exceed the DEAT guidelines for highest hourly, daily and

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concentrations of 35 µg/m³, 9 µg/m³ and 1,3 µg/m³ were below the respective guidelines sites due to proposed conditions; • Lead: current and proposed predicted concentrations were less than 2% of the EU limits respectively; • Non-criteria pollutants – non-carcinogenic health effect: Predicted ground level concentrations did not exceed the effect screening or health risk criteria during current or proposed operations. • Non-criteria pollutants – carcinogenic health effect: With the exception of benzene (current operations) and hexavalent chromium (current and proposed operations), all carcinogenic pollutants were predicted to cause less than 1 in 1 million chance of cancer (trivial cancer risk): ∗ Benzene: Under current operating conditions the cancer risk due to benzene ranged from 0.4 to 1.5 in 1 million (based on US-EPA unit risk factors), which is broadly acceptable (1 in 1 million) .No Benzene emission EC limit exists that could be used the proposed introduction of alternative fuels and therefore the ground level impact could not be predicted. ∗ Hexavalent chromium: Assuming hexavalent chromium is typically 10% of total chromium, the incremental cancer risk using the WHO inhalation unit risk factors would be 0.6 in a million (based on the geometric mean). This is broadly acceptable (less than 1 in 1 million). However, using EC limits (proposed operating conditions) the cancer risk for hexavalent chromium, increases to 1.1 in 1 hundred thousand (WHO unit risk factors), assuming chromium VI is representative of 10% of total chromium; • Dioxins and furans: The predicted ground level concentrations were below the relevant guidelines for current and proposed operating conditions; • Significance Rating: Based on the significance rating categories, current and proposed conditions indicated slight severity due to predicted ground level concentrations from criteria pollutants with localised, long-term impact. For non-criteria pollutants (based on hexavalent chromium) the severity increased from moderate (baseline conditions) to high (proposed conditions). It should be noted, however, that EC emission limits were used to simulate the hexavalent chromium ground level impact for proposed operating conditions as no measured data was available for the current study. Thus the high severity of the significance rating for hexavalent chromium under proposed operating conditions should be seen in context. However, in order to ensure that this impact does not manifest, no AFR containing chromium should be utilised within the kiln; • Overall conclusion: Based on the findings above it can be concluded that predicted ground level impacts from alternative fuel usage is well below relative guidelines/limits.

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6.11.1 Recommendations

• Recommendation 1: EC emission limits have been utilised as a benchmark for the quantification of ground level impact from the plant emissions that may result from the proposed partial substitution of coal with alternative fuels. Based on the “predictive” nature and conservative approach of the simulated ground level results, and associated uncertainties, it is recommended that Trial Burns, under controlled conditions, be initiated with the object of verifying that the EC emission limits and destruction removal efficiencies can in practice be met. It should be noted that pollutants of concern, which may be emitted during a trial burn, typically result in health impacts due to chronic exposures (e.g. dioxins and furans); hence a relatively short exposure of a few days during the trial burn would have an insignificant impact.

• Recommendation 2: An annual “spot check” emission measuring programme be implemented on kiln emissions for all pollutants identified in this, with particular attention on those pollutants identified as having potentially higher risks, namely, particulate, Chrome VI and benzene. If the order of magnitude of these emissions is significantly different to those used in the current assessment, re-simulation is recommended to be undertaken in order to quantify ground level impacts.

• Recommendation 3: Due to the relative uncertainty of the conservative conclusions drawn on the cancer risks associated with hexavalent chromium, it is recommended that the total chromium and hexavalent chromium fractions of the PM10 particulate be determined through additional measurement, and that, in order to more accurately assess the associated risks re-simulation be conducted of the chrome be conducted on an annual basis.

• Recommendation 4:

NO and NO2 emissions at the plant from the kiln, under both current and alternative fuel conditions, be monitored and recorded on a continuous basis for comparison with EC emission limit values. Collected data to be utilised for re-simulation as and when required by the authorities.

• Recommendation 5: Although fugitive emissions were not important in establishing the impact of the use of alternative fuels, it is recommended that a source inventory be compiled for these emissions to determine the significance of this source.

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• Recommendation 6: The Air Quality Management Plan (AQMP) be implemented with the objective of improving and extending the plants emissions inventory and database by: ∗ Undertaking stack (Kiln) monitoring following the initiation of the proposed operations to confirm projected stack emission data. ∗ Identify and quantify all fugitive, diffuse and evaporative sources of emissions.

6.12 Air Quality Management System

Possible objectives to be met through air quality management planning, given the local legislative context and international 'best practice' requirements, include:

• Identification and quantification of sources of atmospheric emission, and ranking of sources based on their significance; • Reduction of significant sources through the implementation of the most cost- effective management and/or control measures possible; • Demonstration of compliance with local (and if necessary international) regulations; • Demonstration of continuous improvement (e.g. for ISO14000 purposes); • Reduction of risks, both occupational and public; • Facilitation of the participation of interested and affected parties in air quality management; and, • Disseminate environmental information to stakeholders.

Given these objectives, the following elements are perceived to be integral to effective air quality management planning within industrial and mining operations:

• Baseline Assessment. Such an assessment comprises the identification and quantification of sources of atmospheric emission and the simulation and/or measurement of air quality impacts associated with such sources. Baseline assessments typically form the basis for identifying significant sources, ranking emission reduction strategies and designing suitable source and ambient air quality monitoring networks. Although air quality impacts related to stack emissions were quantified during the current study, fugitive emissions were not considered. The significance of such emissions were therefore not established.

• Source- and Receptor-based Performance Indicators and Associated Targets. The identification of and commitment to specific source-related and ambient air quality targets provides the basis for assessing the acceptability of emission rates and ambient air pollution concentrations. Such targets should, as a minimum, reflect pertinent local, provincial and national

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regulatory limits. Other, more stringent criteria such as emission and air quality standards issued by other countries or dose-response thresholds (etc.), could also be used as the basis for such targets. Timeframes should be set by which targets are to be achieved.

• Source and Ambient Air Quality Monitoring Systems. The monitoring of sources and ambient air quality is crucial to accurately characterise current impacts, evaluate the effectiveness of control measures, and quantify progress against performance indicators. Source-based monitoring can range from sophisticated continuous stack monitoring to routine visual inspections of sources. Ambient air quality monitoring, although typically associated with the acquisition and implementation of mechanical sampling equipment, could also comprise the maintenance of a complaints register.

• Air Pollution Mitigation Strategy. In the design of the mitigation strategy, sources classified as significant in terms of their air quality impacts should be targeted using the most cost-effective measures possible. Mitigation strategies should include short-, medium- and long-term source management and control measures in addition to providing for the implementation of contingency measures in the event that defined targets are not met within specified timeframes.

• Record Keeping and Documentation Procedure. The implementation of a documentation procedure ensures continuity beyond the job span of individuals, assigns responsibility of tasks to posts and contributes to informed decision making by increasing access to information. Such record keeping is able to easily facilitate environmental audits, and generally provides value for money in terms of expenditure on emissions inventory development, modelling and monitoring.

• Periodic Inspections and Audits. Periodic inspections and external audits are essential for progress measurement, evaluation and reporting purposes. Site inspections and progress reporting by plant personnel may, for example, be undertaken at monthly or quarterly intervals, with annual environmental audits being conducted on an annual basis.

• Mechanisms for Consultation with Authorities and I&APs. Interactions with authorities currently typically comprise routine compliance reporting and intermittent site inspections. Mechanisms for information dissemination to and consultation with interested and affected parties (I&APs) include the holding of stakeholder forums. The frequency of such forums is best determined on an intermittent basis through consultation between the operation and relevant stakeholders.

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• Financial Provision. The budget should provide a clear indication of the capital and annual maintenance costs associated with mitigation measure implementation and monitoring. Provision should also be made for costs related to inspections, audits, environmental reporting and I&AP liaison. The budget could either be established and maintained exclusively to inform internal decision making or could be made available to authorities and/or I&APs to demonstrate that financial resources have been made available for air quality management planning.

The interactions of individual components of the air quality management plan development, implementation and review process are illustrated in Figure 6.2. These various components are discussed in more detail in subsequent subsections.

Figure 6.2: Schematic diagram illustrating air quality management plan development, implementation and review by industrial operations

6.12.1 Emissions Inventory development and Maintenance

An emissions inventory is a comprehensive, accurate and current account of air pollutant emissions and associated source configuration data from specific sources over a specific time period. Source and emission data need to be collated for routine, upset and accidental emissions to provide a representative account of the potential for impacts, which exist. Emissions inventories represents the key elements in all programmes aimed at air pollution management, aiding in the

Assessment of Impacts on Air Quality120 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province identification of pollutants and sources of concern and therefore in the selection of effective air pollution abatement measures. In addition to containing information on present emission levels from the various source categories, an emissions inventory could also indicate projected future emission levels for long-term planning purposes.

The first step in the establishment of an emissions inventory is the identification of sources of atmospheric emissions. The quantification of sources may be based on source measurements, mass balance calculations and on the application of emission factors. In the current study, only stack emissions were quantified for inclusion in the plant’s emission inventory. Stack emission rates were assumed to be equivalent to EC emission limits. The plant’s emissions inventory will need to be improved and extended by:

• Undertaking stack monitoring following the initiation of the proposed operations to confirm projected stack emissions data; • Identifying and quantifying all fugitive, diffuse and evaporative sources of emissions.

In future, South African industries will be tasked with the regular reporting of source and emissions data for both stack and diffuse sources to air quality management authorities. Reliance on consultants to regularly update the facility's emissions inventory to fulfil such reporting requirements, should in- house capacity not have been developed, will prove costly.

6.12.2 Source Monitoring

Source monitoring could range from sophisticated continuous emission monitoring methods to intermittent monitoring. The type of monitoring adopted will depend on the nature and extent of an operation's activities and the presence of various source types (e.g. stacks, vehicle entrainment from unpaved or paved roads, evaporative emissions from tanks, fugitive dust releases from materials handling points).

Mandatory in-stack monitoring for all 'priority pollutants' may in future be required by industrial emitters. Alternatively, stack-monitoring campaigns may be required. Stipulations regarding monitory durations, methods and frequencies will be included in Atmospheric Emission Licences.

For the proposed usage of alternative fuels, the type of monitor will depend on three aspects, i.e. the stack parameters, composition of fuel and quantity of fuel used. If these three aspects remain relatively constant intermittent monitoring

Assessment of Impacts on Air Quality121 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province would suffice, as emissions should be fairly regular. If any one of these aspects significantly varies over time continuous monitoring may be required. Monitoring would be required to establish the chromium composition and to demonstrate that the emissions emanating from the kiln (for the new facility) can achieve the given EC emission limits.

6.12.3 Ambient Air Quality Monitoring

Air quality samplers are generally expensive to install and maintain. It is therefore essential that the type of sampling equipment required and the number of sampling sites to be established be carefully considered and justified.

Given that predicted pollutant concentrations due to stack emissions are well within air quality guidelines and health screening levels, ambient air quality monitoring appears unjustified. It is however strongly recommended that the need for air quality monitoring be reassessed after the establishment of a comprehensive emissions inventory for the plant and the simulation of air pollution concentrations arising from all sources.

6.12.4 Mitigation Strategy Design, Implementation and Evaluation

Mitigation should form an integral component of the environmental management of industrial plants. Such measures need to be integrated into the day-to-day operations of the plant and their effectiveness and overall usefulness reviewed periodically. In assessing the cost effectiveness of controls, costs of measures may be compared to the emission and/or impact reductions achieved by such measures.

Should stack emissions be measured to be within emission limits, as assumed in this study, no mitigation would be required for these sources. The need for the implementation of mitigative measures for other sources needs however to be established. These mitigation measures could for instance extent to the replacement of electrostatic precipitators with bag houses on the stack sources. Bag houses already exist on the Cement Mill 5 and the Coal Mill. Electrostatic precipitators are still on the Kiln and the Cement Mill 6.

6.12.5 Record Keeping and Environmental Reporting

Record-keeping requirements specific to air pollution management include:

• Complaints register. It is essential for all industrial and mining operations to log the "who", "when" "what" and "where" of a complaint, in addition to information on action taken by personnel in response to the complaint. This

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register should be signed at regular intervals by the environmental manager to encourage complaints being addressed in a timely and responsible manner. • Emissions inventory database - comprising source and emissions data in addition to information on when the inventory was last changed and audited. • Dispersion model results - including dispersion model manual and training notes, list files indicating model inputs and outputs, isopleth plots and graphs, etc. • Air monitoring information - comprising the air quality database, information on the location of sampling sites, sampling durations, calibration certificates, quality assurance procedures, reasons for peaks in concentrations or deposition levels observed. • Reports compiled (e.g. reports prepared to meet internal information requirements, compliance reports generated for authorities, briefing documents for circulation to stakeholders, progress reporting against performance indicators, specialised studies, air quality management plan reviews, etc.)

Environmental reporting which would typically be undertaken on an annual basis to document the review of air quality management system components is likely to include:

• Proof of progress made against performance indicators • Review of performance indicators • Review of air quality monitoring and management systems • Synopsis of complaints received, actions taken and response times • Synopsis of unplanned emission incidents, causes and actions taken • Benchmarking against the environmental performance of other industries locally and abroad (e.g. total particulate emissions per ton product).

The importance of proficient record keeping and environmental reporting cannot be overemphasised. This tool forms the basis of all environmental management systems, and is recognised as one of the main components of ISO14000 management systems.

6.12.6 Consultation

Consultation with relevant authorities and communities should be undertaken. The frequency of such meetings should be determined based on the number of complaints received, the level of community interest in plant performance, and the extent of attendance at meetings. The plant should set up meetings with the community of the surrounding areas to provide information on emissions and monitoring results from the plant.

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7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN ALTERNATIVE FUEL RESOURCE

7.1. Introduction

In order to generate the high temperatures required for cement clinker 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 selected 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 5 at the Ulco 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 their very high temperatures (up to 2 000oC), long solid residence times (up to 30 minutes), long gas residence times (of 4 to 8 seconds), and the large excess of oxygen used in the combustion process.

Assessment of the Suitability of124 09-Nov-04 Waste as an Alternative Fuel Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province both as alternative fuels and as raw materials, introduces new challenges to the cement plant and issues related to the transport, handling, storage and use of the waste must be strictly controlled to ensure that the potential 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 sound management techniques will, therefore, ensure the potential risks to health, safety and the environment are kept within acceptable levels.

This chapter assesses the suitability and the risks associated with the proposed introduction of an alternative fuels and resources (AFR) programme at Ulco's Kiln 5, and defines the management procedures that would need to be implemented by Holcim South Africa (with details of these procedures provided in Appendix I).

7.2. AFR Specifications

The use of alternative fuels in cement kilns is based upon sound technical principles as the organic component is destroyed by the very high temperatures reached in the kiln (i.e. up to 2 000°C) while the inorganic components are trapped and combined with the cement clinker forming part of the final product.

Assessment of the Suitability of125 09-Nov-04 Waste as an Alternative Fuel Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province and nature of the AFR materials and their respective management procedures that would be acceptable, as well as the limits on certain elements in the AFR need to be specified and adhered to.

7.2.1. Types of Alternate Fuels and Resources

Waste materials currently utilised internationally as alternative fuels include, but are not limited to scrap tyres, rubber, paper waste, used oils, waste wood, paper sludge, sewage sludge, plastics, spent solvents, tars, etc. Waste-derived alternative fuels can include wastes with high concentrations of mineral components beneficial to the cement manufacturing process (e.g. wastes with a high iron content to replace the iron ore normally used in cement manufacture).

The primary consideration for a waste to be utilised as a fuel is the energy value, stated as the Nett Calorific Value (measured in megajoules per kilogram (MJ/kg)). Table 7.1 below provides typical calorific values of some potential alternative fuels and, for comparison purposes, some common natural fuels (such as oil and coal). Natural fuels range from calorific values as low as 16 MJ/kg for some peat or lignites, to as high as 42 MJ/kg for fuel oil derived from crude oil. To sustain combustion, a fuel must have a calorific value of at least 7,5 to 9 MJ/kg.

Table 7.1: Calorific Value of Alternative and Natural Fuels Calorific Value Fuel* Comment (MJ/kg) Pure Polyethylene 46 For example, plastic bags Light Fuel Oils 42 Diesel Heavy Fuel Oil 40 Used in boilers Tar 38 By product of petroleum industry Pure rubber 36 Anthracite 34 High grade coal Waste Oils 30 - 38 Used engine oil Petroleum Coke 33 Coke produced from petroleum distillate residues Scrap Tyres 28 - 32 Contain steel and other non- combustible material Bituminous Coal 24 - 29 Lower grade coal produced in South Africa Landfill Gas 16 - 20 ~60% methane gas Lignite and Peat 16 - 21 Spent Potliners 20 Carbon and Refractory Waste from Aluminium Smelters Paint Sludge 19 By product from paint industry Palm nut shells/ 19 From production of vegetable oils Sunflower husks

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Calorific Value Fuel* Comment (MJ/kg) Fuller's Earth 13 - 16 A natural clay used to filter vegetable oils Dried wood / sawdust 16 Rice Husks 16 Refuse Derived Fuel 15 Domestic waste with metal and other (RDF) non-combustible wastes removed Cardboard/paper 15 Dried Sewage Sludge 10 Sterilised sludge Domestic Refuse 8.5 Domestic waste with metal and other non-combustible wastes removed (comparable to RDF) Wet Sewage Sludge 7.5 Contaminated Soils 0 - 3 Contain hydrocarbons or other organic contaminants Waste Minerals 0 Contain no combustible organic material *Note: This list is not a comprehensive listing of all possible AFR materials.

7.2.2. Physical and Chemical Characteristics of AFR

As there are many waste streams that could be considered for use as an alternative fuel, it is important to define the physical and chemical characteristics of potential AFR streams to ensure that they can be safely accepted and utilised in the kiln.

This is important for a number of reasons:

• The safety of persons handling the materials: individuals need to be made aware of the potential hazards and provided with the correct protective equipment to wear while handling the waste. • The transport of the materials: the materials must be safely transported in accordance with relevant legislation. Precautions which are required to be taken will differ significantly depending on the type of waste transported. The physical form of the waste will determine the type of transport container and vehicle which is required. The density of the waste will determine the volume that can be transported by a particular vehicle to avoid overloading the vehicle. The waste constituents will also determine the appropriate labelling of the vehicle. In cases of emergency (e.g. spillage, vehicle accident etc.) it is vital that the driver, emergency services and persons on the scene of the accident are able to readily identify and appropriately manage the waste stream.

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• The type of AFR, its chemical characteristics and its physical form will dictate exactly how it should be stored on reaching Ulco plant. • For efficient and safe utilisation the chemical composition of the AFR must be determined.

• Physical State: The four possible physical states of a waste stream are described below. The physical state of a waste stream will determine how it is handled, containerised, transported, stored and fed into the kiln.

∗ Solid Solid waste generally refers to a waste that is devoid of excess moisture, and does not generate moisture when subjected to pressure. The solid can be in a number of forms, generally varying in particle size and adhesion properties. Examples are:

- Large chunks (rocks) of material. - Varying sizes smaller than this (e.g. gravel size pieces). - Fine powders. - Solid wastes, which are 'sticky' (e.g. clay-like substances).

∗ Liquid These are wastes which have little to no solid content, although a certain amount of settlement may take place leaving a layer of sludge at the bottom of a container. Liquids can vary greatly in composition (e.g. in colour, odour, toxicity, whether they release fumes or not, viscosity, clear or opaque, etc).

∗ Sludge This is generally an intermediate physical form between liquid and solid. It is determined by its liquid content, which is generally accepted to be above 40%, although this amount can vary depending on the nature of the waste materials. Sludges can vary from a stiff consistency to one that is quite mobile. The consistency of the sludge determines how it will be handled.

∗ Gases This class is subdivided into five separate divisions, i.e. permanent gases, compressed gases, liquefied gases, refrigerated liquefied gases and gases in solution.

• Hazardous characteristics: Wastes are categorised in terms of their hazardous properties using SANS Code 10228 for transport, treatment and disposal purposes (South Africa

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National Standard 10228). There are nine SANS hazard classes for wastes, i.e.:

∗ Class 1 Explosives ∗ Class 2 Gases ∗ Class 3 Flammable Liquids ∗ Class 4 Flammable Solids ∗ Class 5 Oxidising Substances and Organic Peroxides ∗ Class 6 Toxic and Infectious Substances ∗ Class 7 Radioactive Substances ∗ Class 8 Corrosive Substances ∗ Class 9 Miscellaneous Dangerous Substances

Hazardous substances and wastes have four main hazardous characteristics, namely flammability, corrosivity, toxicity and reactivity. A hazardous material is classified according to its primary characteristic, but may also have secondary characteristics that would determine and influence the management approach taken.

∗ Explosive Wastes An explosive substance or waste is a solid or liquid substance, or a mixture of substances that is capable, by chemical reaction, of producing a gas at such temperature, pressure and speed as to cause damage to the surroundings. Similar to explosives are pyrotechnic materials that are designed to produce heat, light, sound, gas, smoke, or a combination of these, but the reaction is non-detonative and self-sustaining. Explosive wastes belong to SANS 10228 Class 1. Waste can range in behaviour from being insensitive, to very sensitive, to explosive.

∗ Gaseous Wastes Gases belong to SANS Hazard Class 2, which is divided into a number of categories: - A permanent gas is a gas that at a temperature of 50°C has a vapour pressure exceeding 300 kilo Pascals (kPa) and is completely gaseous at 20°C with a standard pressure of 101,3 kPa (note that a permanent gas cannot be liquefied under ambient temperatures, e.g. oxygen and nitrogen). - A compressed gas is a gas (other than in solution) that, when packaged under pressure for transportation, is entirely gaseous at 20°C. - A liquefied gas is a gas that can become liquid under pressure at ambient temperatures, e.g. butane.

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- A refrigerated liquefied gas is a gas that, when packaged for transportation, is partially liquid due to its low temperature, e.g. liquid air and liquid oxygen. - A gas in solution is a gas that can be dissolved under pressure in a solvent and that can be absorbed in a porous material, e.g. acetylene.

Gases could include non-inflammable gases such as chlorofluorocarbons (CFCs), flammable gases and toxic gases.

∗ Flammable Liquid and Solid Wastes Flammable wastes can belong to SANS 10228 Class 3, or SANS Class 4, flammable liquids or flammable solids, respectively. The most common Class 3 flammable liquids are organic solvents including petroleum fuels that have high calorific values (refer to Table 7.1).

Class 4 Flammable Solids include: - Self reactive and related substances and desensitised explosives. - Substances liable to spontaneous combustion, including Pyrophoric Substances (which ignite on contact with air), - Self-Heating Substances (which in air are liable to self-heating but do not ignite) - Substances that on contact with water emit flammable gases.

A flammable waste will ignite when subjected to an open flame or high temperatures. A waste that has a flash point of 61°C or below is defined as flammable in terms of the Minimum Requirements for the disposal of waste to landfill (Department of Water Affairs and Forestry, 1998). However, it is important for transport and storage purposes to identify/ classify wastes that have flash points higher than 61°C and which can combust when heated to higher temperatures.

∗ Oxidising Substances and Peroxides These wastes belong to SANS Class 5, i.e.: - Oxidising Substances (Agents), although they themselves may not be combustible, can either by yielding oxygen or by similar processes, increase the risk and intensity of fire in other materials with which they come into contact. Oxidising substances can be sensitive to impact, friction, or a rise in temperature, and some can react vigorously with moisture, therefore increasing the risk of fire. A common example is solid pool chlorine. - Organic peroxides are thermally unstable substances that undergo exothermic self-accelerating decomposition.

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∗ Toxic Wastes Wastes that are toxic can result in the poisoning of humans and other living organisms. Such waste materials can belong to SANS Class 6.1, toxic substances, or Class 9, miscellaneous dangerous substances. There are a number of important parameters used to measure toxicity, i.e. the chronic toxicity (teratogenicity, mutagenicity, and carcinogenicity), acute toxicity in terms of the mammalian toxicity, as measured by the

LD50 mg/kg (oral) preferably for rats, and ecotoxicity as measured by its

LC50 mg/l/96hr for fish. The LD50 is the lethal dose of a chemical required to kill 50% of a population of experimental mammals, and the

LC50 is the lethal concentration required to kill 50% of a population of fish. The acute toxicity and chronic toxicity of a waste are vital in determining the most appropriate handling and storage method, as well as the type of protective equipment to be worn by employees involved in handling the material. The ecotoxicity together with other parameters such as biodegradability, persistence and mobility of a toxic substance is particularly important when designing emergency procedures, when determining the risks associated with pollution and the methods and level of clean up required for accidental spills.

∗ Infectious Wastes Infectious waste, the most important component of the health care risk waste stream, consists of contaminated wastes from medical facilities that can or possibly could cause the spread of disease. The waste belongs to SANS Class 6.2, infectious substances. This is usually in the form of soiled or contaminated bandages, swabs, gloves, masks, sharps, etc. It is vital that individuals are not exposed to any disease-causing organisms and that this waste stream is completely destroyed or otherwise sterilised before anybody is exposed to it.

∗ Radioactive Wastes Radioactive wastes, which belong to SANS Class 7, are materials that spontaneously emit ionising radiation. Internationally, any material with a specific activity exceeding 70 Becquerel/g (0,002 µCi/g) is classed as Class 7 dangerous goods.

∗ Corrosive Wastes In terms of SANS 10228, corrosive substances which belong to Class 8 are solids and liquids that can, in their original state, severely damage living tissue. All wastes in Class 8 also have some destructive effect on container materials such as metals. Many substances in this class become corrosive only after having reacted with water or moisture in the air. The reaction between water and many substances of Class 8 is often accompanied by the emission of irritating and corrosive gases. Such

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gases usually become visible as fumes in the air. This aspect is particularly important in storage and transport, as it is vital to determine what type of container to store the wastes in, so that the container will not corrode, leading to a leakage or spillage.

• The influence of the hazardous waste classification on the selection of appropriate AFR sources:

∗ Explosive Wastes Unless the appropriate precautions are in place, and permission for acceptance of explosive waste for use as an AFR has been obtained from the relevant authorities, explosive wastes should not be accepted or utilised as an alternative fuel source.

∗ Gaseous Wastes The kiln offers a unique opportunity to utilise the energy derived from the processing of some flammable gasses and non-toxic gases such as the CFCs or hydrochlorofluorocarbons, many of which are now banned in terms of the Montreal Protocol, United Nations (1993). The possible amounts of these gases that could be available for use as an AFR by the kiln would be very low, and would not be expected to exceed 50 to 100 tons per annum. The gasses provide no energy or mineral fraction, and are therefore not desirable as a fuel source.

∗ Flammable Liquid and Solid Wastes These materials would form a significant portion of the alternative fuels used at the kiln due to their high calorific values (refer to Table 7.1). These flammable wastes are required to be handled carefully in order to avoid conditions which could cause them to ignite during transport and storage, but pose no higher risk than fuels such as petrol, diesel and boiler fuels.

Unless the appropriate handling and storage procedures are put in place, flammable solid wastes that fall into the following three classes should not be accepted at the kiln due to risks associated with the handling of these wastes:

- Self reactive and related substances and desensitised explosives. - Substances liable to spontaneous combustion, - Substances that on contact with water emit flammable gases.

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∗ Oxidising Substances and Peroxides Stable organic peroxides would be acceptable for use/introduction into the kiln, but inorganic oxidising agents, such as chromates and permanganates, should not be accepted.

∗ Toxic Wastes Materials that are potentially toxic include petroleum-based fuels and many waste materials produced by the chemical, pharmaceutical and petroleum industries. These products can all be utilised as alternative fuel in a cement kiln. However, the acceptance procedure for these materials must determine if the toxicological, chemical and physical nature of the materials pose any significant threats to human health or the environment.

∗ Infectious Wastes Infectious waste and untreated medical waste should not be processed/accepted as an alternative fuel in the kiln due to the potential health risks associated with handling these materials, and because they could contain surgical steel items that may not be completely destroyed in the kiln.

∗ Radioactive Wastes The kiln must not accept wastes that are determined to be radioactive. It is important that procedures are in place to determine that a waste is not radioactive both prior to acceptance and when it is received at the facility.

∗ Corrosive Wastes The corrosive wastes that could be accepted at the kiln would be largely organic in nature, e.g. acetic acid. Mineral acid wastes such as sulphuric, hydrochloric and nitric acid should not be accepted, as they could potentially have a significant impact on process stability in the kiln.

7.2.3. Summary of Acceptable Waste in terms of SANS 10228

Table 7.2 summarises the wastes acceptable for use as an alternative fuel in terms of SANS Classes.

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Table 7.2: Categories of waste that can be accepted by Kiln 5 and restrictions by SANS Class Class Description Category Allowed Restrictions/Requirements Class 1 Explosives Possibly subclass 1.5 – very Must not explode in external insensitive substances and fire test. subclass 1.6 - extremely insensitive substances. Class 2 Gases Only selected inert or No toxic gases compressed, flammable gases, e.g. CFCs liquefied or dissolved under pressure Class 3 Flammable All packing classes I to III Liquids Class 4 Flammable None Substances should pass the Solids; tests for pyrophoric and self- Substances heating substances and not liable to emit flammable gases unless spontaneous the controls are in place to combustion; handle these types of substances compounds. that, on contact with water, emit flammable gases Class 5.1 Oxidising Limited to Organic No strong inorganic oxidising Agents Compounds agents such as chromates and permanganates Class 5.2 Organic All Must be stable for handling, Peroxides storage and transport Class 6.1 Toxic All Subject to limits on selected Substances components. Class 6.2 Infectious None No Exceptions Substances Class 7 Radioactive None No Exceptions Substances Class 8 Corrosive Limited to Organic No mineral acids such as Substances Compounds sulphuric acid, hydrochloric acid and nitric acid Class 9 miscellaneous The waste should be See Classes 1 to 8. dangerous evaluated individually substances according to the Minimum and goods Requirements and classified into one of the other Classes.

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7.2.4. Waste and AFR Standards / Specifications

AFR specifications would be defined by regulatory requirements and specific requirements of the kiln.

• Regulatory requirements (operating permits): There are currently no formal regulatory requirements which govern the use of AFR in South Africa . Without South African standards and specifications to govern the use of AFR, waste standards, specifications and procedures have been adopted to ensure that the risks can be effectively managed. A permit would be required from DWAF for the short-term storage of waste at Kiln 5. Regulatory requirements would be required to refer to health, safety and environmental aspects.

• Plant specific requirements: Plant specific requirements refer to cement plant operations (i.e. stable kiln operation, handling and storage) and product quality (clinker). Cement plant requirements are required to be defined individually for each kiln at each cement plant.

Specifications apply to the four key aspects of AFR quality control, i.e. plant operation, product quality, health and safety, and environmental impact.

• Plant Operation: ∗ Burning process: moisture/water content, ash content, sulphur, alkalis, halogens, calorific value. ∗ Materials handling (i.e. storage and feed system): viscosity/density, solids content, pH value, immiscibility, flash point.

Product Quality: ∗ Ash composition, sulphur, halogens, heavy metals, ‘interfering’ elements (alkalis, phosphorous), radioactivity.

• Health and Safety: ∗ Physical and chemical properties: flash point, pH value, toxic organics and inorganics, i.e. heavy metals, free cyanides, PCBs, PAHs, pesticides, carcinogens, radioactivity, infectious materials and free asbestos fibres.

• Environmental Impact: ∗ Atmospheric emissions: heavy metals (i.e. mercury), Volatile Organic Compounds (VOCs), sulphur, halogens, cyanides, ammonia. ∗ Effluents and leaching properties: heavy metals, organics and other soluble components.

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The relationship between waste/AFR properties (i.e. specifications) and the four key management aspects is summarised in the matrix in Table 7.3.

Table 7.3: Properties of fuel that can potentially affect product quality, plant operation, health and safety and environment Product Plant Health and Properties Environment Quality Operation Safety Viscosity / density X pH value X X Flash point X X Solids content X Calorific value X Water content X Ash content / XX composition Radioactivity X X X Sulphur X X X Halogens X X X Heavy metals X X X Alkalis X X Organics X X Particle size X

The input of different sources of AFR into the kiln would require the operator to adjust the fuel feed rate to prevent any fluctuations in the operation of the kiln.

As illustrated in Table 7.3, the physical and chemical properties of AFR can potentially have an impact on the kiln operation, but these can be successfully controlled as the fuel types (and characteristics) feeding into the kiln would be known. For example, the viscosity and density of the AFR will determine the pump pressure that would be required to deliver the material to the kiln, i.e. it has an impact on the plant operations but would have almost no effect on the product quality, health and safety and the environment. Although some sources of AFR (e.g. radioactive material) have a very low effect on the operation of the plant, the AFR would be unacceptable as the impact on health, safety and the environment could be potentially high in the long-term, and the product quality would be compromised.

7.2.5. Acceptable Limits for Elements in AFR

Table 7.4 lists the limits for various elements as permitted and practised by kilns accepting AFR internationally. These limits have proven to be acceptable in terms of plant operations, the health and safety of the personnel, the environmental impact and the quality of the end product, i.e. the clinker.

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The upper and lower limits can vary considerably, and the Holcim Ciment d’Obourg plant limits have been included as a guideline, as these are considered acceptable for Ulco's Kiln 5.

Table 7.4: AFR Specifications and range of acceptable limits Holcim Unit Low High Ciment D’Obourg Sulphur (S) % 0.5 5.0 3.0 Total organo-chlorine (Cl) % 0.3 6.0 6.0 Total organo-fluorine (F) % 0.02 0.2 Cyanide (CN) ppm 100 1 000 100 PCB ppm 10 150 30 Arsenic (As) ppm 5 200 200 Silver (Ag) ppm 5 Barium (Ba) ppm 1 000 Beryllium (Be) ppm 0.5 50 50 Cadmium (Cd) ppm 0.8 500 100 Cobalt (Co) ppm 6 200 200 Chromium (Cr) ppm 40 3 000 100 Copper (Cu) ppm 100 1 000 1 000 Mercury (Hg) ppm 0.5 50 10 Nickel (Ni) ppm 25 1 000 1 000 Lead (Pb) ppm 50 5 000 1 000 Antimony (Sb) ppm 1 800 50 Selenium (Se) ppm 1 100 50 Thallium (Ti) ppm 1 100 100 Vanadium (V) ppm 10 3 000 1 000 Zinc (Zn) ppm 400 15 000 5 000

The limits for the various components listed in Table 7.4 are dependent on a number of factors including:

• Volatility is a major determining factor in the behaviour of chemical elements and their compounds in the alkaline and oxidising environment of the kiln and is dependent on the rate of incorporation into the clinker: ∗ Non-volatile components include magnesium oxide (MgO); titanium

dioxide (TiO2); phosphorus pentoxide (P2O5); manganese (III) oxide

(Mn2O3); barium oxide (BaO); strontium oxide (SrO); nickel oxide (NiO);

cobalt (III) oxide (Co2O3); copper (II) oxide (CuO); and chromium (III)

oxide (Cr2O3).

∗ Components with low volatility include vanadium pentoxide (V2O5);

arsenic (III) oxide (As2O3); and some metal fluorides.

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∗ Components of considerable volatility include sulphur trioxide (SO3);

potassium oxide (K2O); sodium oxide (Na2O); zinc oxide (ZnO); lead (II) oxide (PbO); and some metal chlorides. ∗ Components of high volatility include cadmium oxide (CdO); thallium

oxide (Tl2O); and mercury (Hg). • The presence of chloride, which can increase the volatility of a some elements, e.g. Lead. • The concentrations of the species in other input materials, e.g. coal, clay, iron ore, etc. • The oxidation of some elements to their higher oxidation states can occur in the kiln. For example, if too much chromium is present in the kiln feedstocks then some can be oxidised to chromium (VI). • The leachability of the final clinker and cement products. The leaching of components above that normally found in clinker and too much salt can lead to an unacceptable efflorescence in some cement products.

7.3. Environmental Fate of the Elements

The chemical and physical properties of cement and clinker are specifically determined by the major elements present in the raw materials and fuels used in the burning process. The natural materials and fuels used in the system also contain trace elements, whose concentrations are determined by their geochemical distribution in ore deposits and may vary in relatively wide ranges. The introduction of secondary substances, such as AFR could potentially increase the amounts of these trace elements in the system.

The major raw materials for cement production are combined in typical proportions of 70% - 90% limestone, 10% - 30% clay and 0 - 1% of selected materials such as iron oxide, sand and bauxite, which are used to correct any deficiency in the two primary materials. The coal that is traditionally used also contains quantities of inorganic materials, for example, some low grade coal produced in South Africa contains up to 20% by mass of ash, which in a cement kiln becomes incorporated into the cement clinker.

Table 7.5 provides some typical concentrations of trace elements found in the primary raw materials and coal (Zeevalkink, 1997).

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Table 7.5: Typical Concentrations of Selected Trace Elements in Raw Materials and Coal (mg/kg) Element Limestone Clay Coal Arsenic (As) 0.2 - 12 13 - 23 1 – 13 Chromium (Cr) 0.7 - 12 20 - 90 1 - 50 Mercury (Hg) 0.005 – 0.10 0.02 – 0.15 0.05 – 0.61 Lead (Pb) 0.30 - 21 10 - 40 5 - 27 Zinc (Zn) 1.0 - 57 55 - 110 20 - 150

All three major input materials contribute to the concentrations of trace species as found naturally in the environment. The addition of AFR will potentially contribute to these trace species and, hence, the limits proposed for the most important elements in the AFR that will be accepted at the kiln. As indicated in section 7.2.4, the potentially volatile components include sulphur trioxide (SO3), potassium oxide (K2O), sodium oxide (Na2O), zinc oxide (ZnO), lead (II) oxide (PbO) and some metal chlorides and those components of high volatility including cadmium oxide (CdO), thallium oxide (Tl2O), and mercury.

Initially, AFR will only form approximately 35% of the total fuel used, while the limits provided in Table 7.4 are based on a 100% AFR fuel load. This assumption has been made to ensure that the levels that could potentially end up in the final clinker or that are collected in the gas clean-up system are acceptable. In general, for the low volatility elements, the incorporation rate into the clinker is very high and very little is found in the dust particles. The more volatile species tend to vaporise and pass into the gaseous phase inside the kiln. They tend to condense out on the cooler parts of the kiln or the pre-heater or precipitate on the kiln dust. For example, chromium, nickel and vanadium are incorporated into the clinker and the fraction that collects on the kiln dust is returned to the kiln when the dust is recycled. It is found that in kilns with a pre-heater, such as that fitted to Ulco Kiln 5, even cadmium and zinc act as low volatility elements. The volatile fraction of lead and zinc, which averages about 7 - 8% of the total, is incorporated into the dust collected, which is returned to the kiln. Thus, even the relatively volatile elements are finally fixed in the clinker matrix and therefore do not pose a significant risk to human health or the environment.

Chromium, which occurs in the input materials in moderate amounts, can potentially be oxidised to chromium (VI) in the oxidising atmosphere of a cement kiln and, therefore, the total chromium (Cr) accepted in the kiln from all sources must be carefully controlled as the chromium, as Cr(III) or Cr(VI), would be present in the clinker. Cr(VI), if present in significant amounts could leach from the cement during use, this is potentially harmful to human health due to the known carcinogenic nature of Cr(VI).

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The clinker is milled and, after addition of gypsum, the final cement products that are sold throughout South Africa are produced. As the cement contains most of the trace elements that arise from the materials used in its manufacture, the environmental fate of these elements is of prime importance. During the cement manufacturing process, trace elements become trapped in the cement matrix and because cement has a high pH due to of the high lime content, relatively insoluble hydroxides and oxides are present. The leachability of most heavy metals is, therefore, low and they are not released in amounts that are above their acceptable risk limits, when cement is subjected to standard leach procedures, such as the Acid Rain Leaching Procedure, specified by the Department of Water Affairs and Forestry’s Minimum Requirements.

It is important to note that leaching tests conducted on cement represent a worst case scenario, because cement is usually only a fraction of the materials used to make mortar, concrete and concrete products and the product hardens into a matrix that is solid and largely impermeable. Leaching tests on cement products, such as bricks and board, show that they do not leach trace elements in quantities that are environmentally significant, i.e. they meet the standards required by the Department of Water Affairs and Forestry’s Minimum Requirements.

Mantus (1992) and Zeevalkink (1997) provide an in-depth discussion of the above issues. Section 7.5 provides a further discussion of the environmental fate of trace elements.

7.4 Scrap Tyres

An estimated 22 million scrap tyres are currently stockpiled in Gauteng alone (RéSource, May 2004). Between 10 and 12 million scrap tyres are generated in South Africa per annum, with only a small volume being disposed of to landfill (www.fleetwatch.co.za), and about 12% being recycled to produce rubber crumb and recycled rubber products (www.news24.com; www.engineeringnews.co.za).

Scrap tyres are currently disposed of using the following methods that result in significant environmental consequences:

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Of particular concern in South Africa is the disposal of scrap tyres to landfill, which is no longer considered to be an acceptable waste management practise in terms of the requirements of the National Waste Management Strategy. The South African Tyre Recycling Process company (SATRP) are investigating alternate solutions to deal with the scrap tyre problem in South Africa. Government is presently drafting legislation that will empower it to recycle the waste tyres produced (www.engineeringnews.co.za) and to discourage the inappropriate disposal of scrap tyres. Once promulgated, this legislation will enable the levying of a “green” fee, the proceeds of which will be used to defray the costs of transporting scrap tyres from tyre dealers to rubber-recycling plants (www.engineeringnews.co.za) and companies interested in tyre-derived fuels (AFR). The collection of tyres nationally will be administered and managed by the SATRP (RéSource, May 2004).

The Ulco plant envisages using scrap tyres as a major component of their AFR requirement, due to the relative abundance of scrap tyres and the availability of the scrap tyres in close proximity to the Kiln. The use of scrap tyres as an AFR has been an accepted practice world-wide for the past ten years (www.cement.bluecircle.co.uk), and has assisted in improving global waste management practices.

Tyres have the potential to be an ideal source of alternative fuel due to their inherent physical and chemical properties. These include:

• Environmentally inert– a tyre does not present a risk to the environment in its original form i.e. there is no risk of emissions to the environment. • Calorific Value - tyres have a higher calorific value (28 - 32 Mj/kg) than coal and therefore are an ideal candidate as a fuel resource. • Chemical composition – the hydrocarbon is totally consumed as energy, while the steel in tyres provides iron required in the cement production process. • Mechanical manipulation – tyres can be chipped, shredded or quartered to produce an easily manipulated fuel to feed into the kiln. • Transported and stored safely – the transport of tyres does not present a risk to the environment due to their physically and chemically inert nature. This is a major advantage over other forms of AFR.

In addition, there are a number of environmental advantages to using scrap tyres as fuel as opposed to their stockpiling, including:

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• complete destruction of the rubber and nylon content of the tyre, • no black smoke (resulting from uncombusted components), • no odour, • the metal content of the tyre is incorporated into the cement clinker.

7.5. AFR Management Procedures

As AFR is a waste-derived fuel, the management procedures fall under the Duty of Care requirements that are included in National Environmental Management Act (No 107 of 1998), and the Environment Conservation Act (No 73 of 1989), as well as the Department of Water Affairs and Forestry’s Minimum Requirements. The primary objectives are to ensure that all potentially hazardous waste is classified, handled, transported and finally utilised or disposed of in a safe and environmentally acceptable manner. This section discusses the major issues and procedures to be adhered to, with a more comprehensive discussion of the required procedures presented in Appendix I.

• Acceptance Procedures for AFR ∗ Initial Acceptance Procedures: If a waste is being considered as an AFR, a complete analysis/study of the physical, chemical and toxicological properties must be undertaken to determine whether it can be safely used as a fuel and to verify that it satisfies predetermined and approved criteria. Documented procedures for analysis of the waste, usually by an off-site accredited laboratory, should be prepared, and made available. The acceptability of the material will be determined by the concentration of various hazardous elements (see table 7.4) and the ability for the waste to be handled, transported and stored on site. The form of the waste material is an important consideration at initial acceptance, as the material is required to be handled and fed into the kiln. ∗ Final Acceptance Procedures: Due to of the nature of waste materials, the potential hazards and the wide variety of waste generators, it is essential to verify that the AFR arriving at the Ulco plant matches the original

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analysis profile. A sample of the waste should be taken immediately upon arrival at the plant and the key analytical parameters, identified during the initial acceptance study, checked by an on-site laboratory at the Ulco plant. This procedure must be adhered to before the AFR is allowed to be discharged to the storage area. Non-conformance to the requirements would lead to the AFR being sent back to the generator. ∗ Laboratory and Analytical Requirements: The capability of an on-site laboratory at the Ulco plant that would be required to conduct the quality control tests on AFR is different to that of the laboratory normally associated with a traditional cement plant. Accordingly the laboratory must upgraded to be able to analyse for potentially hazardous elements, (e.g. heavy metals including mercury) and organic compounds (e.g. PCBs), as well as bulk parameters such as calorific value and flash point.

• Documentation: A detailed documentation system that tracks the AFR from the waste generators premises to the Ulco plant is required to ensure cradle- to-grave control of the waste stream. A Waste Manifest Document must be generated to serve as a tracking document, and should contain information for the laboratory, the kiln and the accounting department. In addition, a Transport Emergency Card, which gives information on the AFR to the emergency services in the event of an accident, plus a Material Safety Data Sheet, should accompany each vehicle. Procedures must be in place in order to address the following: ∗ Non-conformance: An investigation into the reasons for the non- conformance must be initiated and corrective measures implemented to prevent further non-conformance. ∗ Security: Handling of waste requires strict security as some materials are valuable (e.g. expired pharmaceuticals) and containers may contain highly hazardous material. The security issues include those at the customer’s premises, during transport, storage, and the management of empty containers.

• Packaging and Labelling: Using the correct packaging for the AFR is critical at all stages of handling. The packaging and labelling required depends on the physical and chemical properties of the AFR. The specifications for most materials are included in SABS 0229: Packaging of Dangerous Goods for Road and Rail Transportation in South Africa. Waste which would have to be packaged and labelled could include solids, liquids, sludges and gases, and the waste could have one or more hazardous characteristics, i.e. flammability, reactivity, corrosivity and toxicity.

• Loading: Loading procedures are determined by the physical state of the AFR (i.e. solid, liquid, sludge or gas) and its hazardous characteristics (i.e. flammable, reactive, corrosive and toxic). The procedures are well defined

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and must be adhered to. When loading, materials must be in a form appropriate for acceptance by the kiln.

• Transport: The transport of a waste material is strictly controlled by legislation and a number of SABS / SANS codes of practice (refer Appendix I, section 5.3 for a list of these codes of practice). Key issues to be considered when transporting AFR are: ∗ Selection of Transporter/Contractor − The fitness of the driver to be in control of a vehicle − The vehicle roadworthiness − The signage used on the vehicle − Emergency Procedures − Selection of Traffic Route − Overloading of Vehicles − Securing the Load − Incompatible Loads * Physical State: Whether the AFR is a solid, liquid, sludge or gas. * The Transport Regulations: Appendix I section 5.3 contains a list of these requirements * Emergency Procedures

• Off-loading: As with transport, off-loading of an AFR at the Ulco plant will depend on its physical and hazardous characteristics. Procedures required should include those for management of dust, spillages and safety issues such as the handling of flammable liquids. Off-loading must only be permitted within the designated storage area, and be supervised by appropriate personnel.

• Handling, Storage and Feeding to the Kiln: Issues that must be considered in the handling, storage and feeding include: * Blending of various AFR streams to ensure that the material that is fed into the kiln has consistent properties (i.e. is homogenous). This can reduce the potential environmental impact as a consistent AFR allows the kiln operator to control the risk of unanticipated reactions in the kiln. * Infrastructure requirements to receive, handle and feed various AFR types. For example, shredded tyres can be readily stored and fed into the kiln, however whole tyres could be accepted but could require specific on-site infrastructure. * Storage should be kept to a minimum and should be sufficient for only a few days. Appropriate storage areas for different types of AFR should be provided, and the stored AFR protected from the elements. * Feeding into the Kiln: The feeding into Kiln 5 will depend on the physical state of the material.

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− Solid wastes: Solid wastes will be shredded and fed via a conveyor and triple flap feed system into the upper-end of the Ulco kiln. − Liquid wastes: Liquid waste can be pumped into the kiln at three inlets: the pre-calciner, the upper-end or the lower-end. Potential risk operations include disconnection and cleaning of pipes. − Sludge Wastes: Sludges, depending on their consistency, can be handled either as a liquid or solid. − Gaseous Wastes: Gaseous wastes should be input into the kiln via a suitable gas line, which can accept the connection of various types of cylinders and other containers.

• Power Failure: Ulco Kiln 5 is fitted with a back-up generator that ensures the operation of the kiln’s essential systems. The AFR feed would automatically stop, and would only resume once the power is restored and the kiln has reached full operating temperature using coal.

• Emergency Procedures: Emergency procedures must be developed to protect both employees and neighbours to the site from unplanned events at Ulco Kiln 5. If AFR is present in such a form or quantity that it has the potential to cause a major incident, then Ulco Kiln 5 would be need to be registered as a Major Hazard Installation in terms of the Occupational Health and Safety Act (No. 85 of 1993; GN R60).

7.6. Risks and Significance of Risks

The potential risks associated with the use of AFR in the manufacture of cement are included in Table 7.6 together with an assessment of the significance of the risks posed by natural events, technical problems and human error. The potential risks associated with the use of scrap tyres as AFR are assessed and the results included in the last column of the table.

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Table 7.6: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human Error Significance Significance Aspect Risk Extent Duration Severity Probability – hazardous – Scrap tyres waste Process Incorrect analysis or interpretation Waste Pre- of results could lead to in- Local Short term Slight Unlikely Low Low acceptance compatible waste being accepted by facility. Accidents could lead to spillage of Transport Local Short term Severe Unlikely Low Not applicable material. Waste Receiving Poor off-loading practices could Local Short term Moderate Unlikely Low Not applicable Area lead to minor chemical spills. Incorrect check analysis or interpretation of results could lead Slight to Waste Acceptance Local Short term Unlikely Low Low to incompatible waste being Moderate accepted by facility. Incompatible waste stored or flammable waste incorrectly Low to Waste Storage Local Short term Severe Very Unlikely Low managed could lead to risk of fire Moderate or explosion. Improper storage of the flammable Low to Gas Storage Local Short term Severe Very Unlikely Low gas could lead to fire or explosion. Moderate Poor operation of the plant could Low to Low to Utilisation of AFR Local Short term Moderate Very Unlikely lead to incomplete combustion. Moderate moderate

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Significance Significance Aspect Risk Extent Duration Severity Probability – hazardous – Scrap tyres waste Products from the Contaminated clinker and cement National Long term Severe Very Unlikely Low Low Kiln products entering the market. Natural Events Flood water may enter waste Flooding Local Short term Severe Very Unlikely Moderate Low storage areas. High winds could disperse Local or High Winds Short term Moderate Very Unlikely Low Not applicable pollutants into the environment. Regional Human Error Incorrect data could be provided by Data Entry Error the client or be input into the Local Short term Severe Unlikely Low Very Low database. People could gain unauthorised Unauthorised Short to long access and exposed to potentially Local Severe Unlikely Low Not applicable Access term hazardous materials. Chemical spills could result in AFR Spills Local Short term Severe Very Unlikely Low Not Applicable contamination of soil and water.

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7.6 Recommendation on the determination of suitable AFR

7.6.1. Typical wastes excluded for use as Alternative Fuels.

In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types have been identified as unacceptable for the AFR programme at Ulco. 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. • They could have a potentially negative impact on the final product quality.

There are a variety of products or wastes that should not be processed or utilised as AFR in the kilns. These include the following:

• Products or wastes that are excluded as a suitable AFR, as listed in Table 7.2. • Selected extremely toxic ('high risk') wastes, e.g. waste containing free asbestos fibres and pure carcinogens, which will pose an unacceptable occupational health and safety risk. • Wastes that contain unacceptably high levels of certain components that will impact on the kiln performance, the quality of the clinker and cement or adversely impact on the emissions from the kiln. These can include waste with unacceptable levels of some heavy metals (e.g. mercury and lead) or high levels of halogenated hydrocarbons, etc. (refer to Table 7.4). • Unsorted domestic wastes (municipal garbage) because of the potential presence of hazardous materials. • Small-volume hazardous wastes from households (fluorescent lamps, batteries etc.). • Non-identified or insufficiently characterised wastes.

In addition, some waste streams could be an acceptable fuel, but require pre- treatment before they would be acceptable for use at the kiln. This pre- treatment will not be undertaken at Ulco plant.

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In addition, wastes or potential alternative fuels that exceed the element limits in Table 7.4 should be excluded or processed to bring them within the acceptable parameters.

7.6.2. Typical wastes accepted for use as Alternative Fuels.

• Scrap tyres • Rubber • Waste oils • Waste wood • Paint sludge • Sewage sludge • Plastics • Spent solvents

7.6.3. Loading, supply, storage and management of Alternative Fuels.

In order to successfully implement the AFR programme at Ulco Kiln 5, the alternative fuel is required to be of an appropriate volume so as to supply a constant feed 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 Ulco, or would need to be pre-processed to achieve a

Assessment of the Suitability of149 09-Nov-04 Waste as an Alternative Fuel Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province uniform and constant fuel source at an appropriate volume. This pre-treatment will not be undertaken at Ulco plant.

For the larger AFR streams that would be delivered directly to the kiln, an on-site storage facility would need to be provided to accommodate/store an appropriate reserve capacity.

The correct management of the wastes and the AFR is critical to the success of this project and its operations. It is essential that the use of AFR is carried out in a manner that does not impact on human health and well-being or the environment. The implementation of the procedures proposed in this section of the report, and Appendix I, would ensure that any possible impact is minimised and that the environmental and health risks are acceptable.

7.7 Proposed Monitoring, Control and Mitigation Measures

7.7.1 Environmental Monitoring Programme

As with any process and its associated procedures, the operations must be carefully monitored for legislative and operational compliance to ensure that no harmful activities or consequences arise from the use of alternative fuels.

The environmental monitoring requirements would be specified in permits issued to the Holcim South Africa Ulco plant in terms of the Environment Conservation Act, the Atmospheric Pollution Prevention Act (No 45 of 1965), and the DWAF minimum requirements. The following sections briefly indicate the type and extent of monitoring that is required.

• Ground and Surface Water The number of boreholes that will be required to monitor the site will be determined from the geological studies after discussions with the Department of Water Affairs and Forestry (DWAF). Any existing borehole network will most likely have to be expanded by locating additional boreholes. DWAF has specific requirements for borehole water testing, as outlined in the Minimum Requirements for Water Monitoring at Waste Management Facilities and the Minimum Requirements for Waste Disposal to Landfill, i.e. for background, demonstration and regular monitoring. The actual requirements for regular borehole monitoring will be determined in consultation with DWAF. An example of the investigative and background monitoring parameters normally required by DWAF is provided in Table 7.7.

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Table 7.7: Minimum Background Monitoring Parameters

Ammonia (NH3 as N) Free and Saline Ammonia as N (NH4-N) Alkalinity (Total Alkalinity) Lead (Pb) Boron (B) Magnesium (Mg) Cadmium (Cd) Mercury (Hg)

Calcium (Ca) Nitrate (as N) (NO3-N) Chemical Oxygen Demand (COD) pH Chloride (Cl) Phenolic Compounds Chromium (Hexavalent) (Cr6+) Potassium (K) Chromium (Total) (Cr) Sodium (Na)

Cyanide (CN) Sulphate (SO4) Electrical Conductivity (EC) Total Dissolved Solids (TDS)

The surface water parameters that DWAF requires to be analysed are normally identical to those for the borehole water samples, although site- specific parameters may be added.

• Air The frequency of monitoring and the parameters required for air emissions will determined by the Chief Air Pollution Control Officer (CAPCO). The kiln will be required to conform to the standards set by the Department (refer to the Air Quality specialist report contained in Appendix H).

7.7.2 Initial Acceptance Procedure Control

Specific acceptance procedures and controls (described in Appendix I) must be in place in order to verify the type of waste being received for storage and processing. Records and documentation must be reviewed on a weekly basis to ensure that each load entering the site has been sampled and analysed.

The procedures used to collect waste from the generator’s premises should be audited by Holcim on a regular basis (e.g. at least annually) to ensure that the materials are being handled safely and in accordance with Holcim’s requirements.

7.7.3 Transport Procedure Control

The transport of waste materials must be audited on a regular basis to ensure that procedures are followed and that the legislation pertaining to the transport of hazardous materials is adhered to. This would apply equally to independent transporters. Drivers must undergo annual driver and medical check ups, to ensure their fitness and efficiency. Vehicles must be on a planned maintenance schedule to ensure that they are maintained in a condition, which is both roadworthy and in compliance with the transport of hazardous waste.

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7.7.4 Final Acceptance Procedure Control

Specific control procedures must be implemented to verify the type of waste being received. Records and documentation must be reviewed on a weekly basis to ensure that each load entering the site has been sampled and analysed in accordance with procedure.

• Offloading: Offloading must be supervised and audited regularly. Offloading equipment must be on a planned maintenance schedule and undergo regular check-ups.

• Storage: Storage facilities must be on a planned maintenance schedule. Documentation must be tracked to ensure that the different waste types, e.g. non-hazardous and hazardous, are managed correctly and the storage facilities must be regularly audited.

• Kiln: All operations at the kiln, including the waste feeding system, must be audited regularly.

7.7.5 Compliance Auditing

Auditing of the facilities and associated services is an essential function to ensure that operating procedures are being adhered to and that potential liabilities are minimised. Commitments to I&APs and legal obligations will ensure that these audits take place and that the results of the audits are not only made known, but are acted upon timeously. A number of different compliance audits should take place:

• Internal An internal audit should take place covering operational, health, safety and environmental aspects, on a daily, weekly and monthly basis as required. These audits normally take the form of a checklist that is used by management and staff to ensure that all requirements (i.e. compliance to permits and to the company’s internal environmental policy and management system) are being maintained.

• External Independent external auditors should be appointed to check compliance to the permits and authorisations every six months, or as otherwise specified in the permit that will be obtained from the Department of Water Affairs and Forestry for the storage and utilisation of hazardous wastes. The audits will conform to all the Minimum Requirements for auditing.

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The controlling authorities can also carry out external audits. The authorities at all levels (local, provincial or national) have the legislative right to audit the operation at any time as pre-arranged with the operator.

A monitoring committee including interested and affected parties should be formed and, in fact, may be a permit requirement. If required, the committee can conduct independent audits on the storage facility and kiln to ensure satisfactory operation and minimal impacts on the surrounding environment.

Every generator of waste has a 'cradle to grave' responsibility to ensure that their waste is treated and disposed responsibly. Therefore, it is very likely that generators that could potentially supply wastes for use as AFR would require confirmation that by utilising this type of waste management option, they are not creating a long-term liability for their company.

7.7.6. Development of Site Specific Specifications

Site specific specifications (mainly for heavy metals) for wastes used in cement manufacturing are to be developed and should include the following:

• Establishment of average levels of heavy metals in plant clinker (including the 'natural' fluctuations) as a 'baseline' reference ∗ without AFR ∗ with AFR over a period of approximately one year • Establishment of a heavy metals balance (input – output) for the individual kiln system without AFR • Calculation of 'transfer coefficients' for all metals ∗ to stack emissions ∗ to clinker ∗ to cement kiln dust • Calculation of the impact of heavy metals input through AFR substitution by means of standard software modelling. • Comparison of model calculations against legal limits (stack emissions) and against 'baseline' clinker levels and optimisation of AFR substitution rate. • Verification of the balance model by establishment of a heavy metals balance with AFR utilisation.

This scheme is to allow for both better prediction and optimisation of the use of AFR based on the chemical composition and the individual substitution rate of the AFR under consideration.

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7.8. Conclusion

With the correct management and monitoring procedures in place, the utilisation of AFR in the manufacture of cement could substitute a portion of the fuel load requirement for Ulco Kiln 5 and would not represent a significant risk to human health and the environment. In particular, the use of scrap tyres as an AFR presents a significant opportunity for South Africa to manage the growing problem of disposing of scrap tyres, and is an extremely safe form of AFR to transport, handle, store and process.

The practice of using AFR in kilns has the following benefits to the environment and the waste industry:

• Through the utilisation of waste materials, energy and mineral components are recovered from selected wastes. • Conservation of non-renewable resources such as fossil fuels, i.e. coal and oil, and inorganic materials such as iron ore. • Reduction in landfill facilities required for the disposal of potentially polluting materials and an overall reduction in waste volumes to landfill.

These issues and a discussion on the added value that waste recovery has in the cement industry are discussed in more detail in Mantus (1992) and Zeevalkink (1997).

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8. CONCLUSIONS AND RECOMMENDATIONS

There is a global trend in the cement production industry to seek more sustainable production methods through the replacement of existing fossil fuels (e.g. coal) with alternative waste derived fuels. Following this trend, Holcim South Africa is considering the implementation of an Alternative Fuels and Resources (AFR) programme.

The AFR programme proposes the replacement of a portion of Ulco Kiln 5's traditional, fossil-based fuel (coal) requirements with alternative waste-derived fuels and materials. This project aims to ensure that at a minimum, 35% of the traditional fossil fuel usage is replaced by alternative waste-derived fuels.

This Environmental Impact Assessment (EIA) process for the proposed introduction of an AFR programme at Kiln 5 at the Holcim South Africa Ulco plant has been undertaken in accordance with the EIA Regulations published in Government Notice R1182 to R1184 of 5 September 1997, in terms of the Environment Conservation Act (No 73 of 1989), as well as the National Environmental Management Act (NEMA; No 107 of 1998).

The essence of any EIA process is aimed at ensuring informed decision-making and environmental accountability, and to assist in achieving environmentally sound and sustainable development. In terms of NEMA (No 107 of 1998), the commitment to sustainable development is evident in the provision that “development must be socially, environmentally and economically sustainable…and requires the consideration of all relevant factors…”. NEMA also imposes a duty of care, which places a positive obligation on any person who has caused, is causing, or is likely to cause damage to the environment to take reasonable steps to prevent such damage. In terms of NEMA’s preventative principle, potentially negative impacts on the environment and on people’s environmental rights (in terms of the Constitution of the republic of South Africa, Act 108 of 1996) should be anticipated and prevented, and where they cannot be altogether prevented, they must be minimised and remedied in terms of “reasonable measures”.

In assessing the environmental feasibility of an AFR programme at Ulco plant, the requirements of all relevant legislation has been considered (refer to Appendix J), including inter alia, those of:

• Environment Conservation Act (No 73 of 1989); • Atmospheric Pollution Prevention Act (No 45 of 1965); • National Water Act (No 36 of 1998); • Occupational Health and Safety Act (No 85 of 1993); • Hazardous Substances Act (No 15 of 1993); and

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• Relevant SABS Codes in terms of the identification and classification, handling, packaging, storage and transport of hazardous substances.

This relevant legislation has guided the identification and development of appropriate management and mitigation measures that should be implemented in order to minimise potentially significant impacts associated with the project.

The conclusions of this EIA are the result of comprehensive studies and specialist assessments. These studies were based on issues identified through the EIA process and the parallel process of public participation. The public consultation process has been rigorous and extensive, and every effort has been made to include representatives of all stakeholders within the process.

8.1. Evaluation of the Proposed Project

The preceding chapters of this report provide a detailed assessment of the environmental impacts on specific components of the social and biophysical environment as a result of the proposed project. This chapter concludes the EIA process by providing a holistic evaluation of the most important environmental impacts. In so doing, it draws on the information gathered as part of the EIA process and the knowledge gained by the environmental consultants during the course of the EIA and presents an informed opinion of the proposed introduction of an AFR programme at Kiln 5 at the Ulco plant.

The Holcim Ulco plant was constructed more than 60 years ago (Union Lime Company established in 1936), with Kiln 5 being constructed and operation since the 1980s. The plant is located within an area zoned for industrial use.. Impacts to or the disturbance of the land within and surrounding the Ulco plant already exist, and have done so since the initial construction of the facility. The design of Ulco’s Kiln 5 has resulted in this kiln being in a position to receive and utilise alternative fuels as an energy source, together with coal. As the AFR programme proposed at Ulco’s Kiln 5 involves the reduction in the use of coal through supplementation of the fuel required with AFR, additional investment would be 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, require any additional changes to the footprint area of the existing cement plant. Therefore, no impact on surrounding land uses, vegetation or heritage sites are anticipated as a result of the proposed project.

The major environmental issues associated with this proposed project, therefore, include:

• Potential impacts associated with emissions to air from the plant; • Potential impacts associated with the transportation of AFR to Ulco plant;

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• Potential impacts associated with the storage of AFR on site for a limited period; • Potential impacts on the social environment; • Suitability of waste as an alternative fuel resource; and • Potential project benefits.

These are discussed in more detail below.

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 Ulco plant.

8.1.1. Impacts Associated with Emissions to Air from the Plant

Conclusions and Recommendations157 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province

Kiln 5 at Ulco plant. However, 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.

Conclusions and Recommendations158 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province 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.

8.1.2. Impacts Associated with the Transportation of AFR to Ulco 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 Ulco. In the event of an accident, the vehicles are equipped with spill-control kits and action should be taken as soon as possible in order to contain spillages while waiting for backup. The transport of waste must be supported by a HazMat Emergency Response team in order to contain and clean up any spill, in order to minimise impacts on the environment and surrounding communities.

8.1.3. Impacts Associated with the Storage of AFR on Site for a Limited Period

Conclusions and Recommendations159 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province derived alternative fuels will minimise environmental impacts and the potential for pollution of the soil and groundwater. Without the implementation of appropriate management measures, this impact is potentially of high significance. The storage of fuels, storage and handling of AFR must be undertaken in an appropriate manner, as stipulated in this report, to avoid spillage and leaching and to limit fugitive emissions, odour and noise to acceptable levels. In addition, 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.

8.1.4. Impacts on the Social Environment

Potential impacts on the social environment associated with the introduction of an AFR programme at Ulco plant identified and assessed within this EIA include:

Conclusions and Recommendations160 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province during transportation of the AFR. With the implementation of appropriate management and emergency response procedures for the transportation of AFR to Ulco, this potential impact is considered to be unlikely to occur and of low significance.

Specialist studies have indicated the following:

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8.1.5. Suitability of Waste as an Alternative Fuel Resource

The primary management considerations to be borne in mind to ensure total 'cradle to grave' management of AFR include:

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The are a variety of products or wastes that should not be processed or utilised as AFR in the kilns. These include the following:

Wastes that are acceptable as AFR for use by Kiln 5 as an alternative fuel source include non-hazardous and hazardous wastes such as, but not limited to scrap

Conclusions and Recommendations163 09-Nov-04 Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Ulco Plant, Northern Cape Province tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and spent solvents.

8.1.6. Project Benefits

Of particular concern in South Africa is the disposal of scrap tyres to landfill, which is no longer considered to be an acceptable management practice in terms of the requirements of the NWMS. The South African Tyre Recycling Process Company (SATRP) are investigating alternate solutions to deal with the scrap tyre problem in South Africa. Government is presently drafting legislation to discourage the inappropriate disposal of scrap tyres. As the number of scrap tyres generated in South Africa is estimated at ~10 to 12 million per annum, with only ~12% being recycled to produce rubber crumb and recycled rubber 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.

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8.2. Conclusions

The introduction of the AFR programme at Kiln 5 of the Ulco plant provides the opportunity to:

As Ulco plant is an ISO 14001 accredited operation, the EMP would be required to form part of the independently audited ISO 14001 programme.

8.3. Permit Requirements associated with the Introduction of an AFR Programme at Ulco Plant

The manufacture of cement is a mature industrial activity which is strictly regulated through national and international legislation in terms of environmental protection, health and safety, and quality of products. The introduction of an alternative fuels and resources programme at Ulco plant would also be regulated by this legislation (refer to Appendix K). In terms of this legislation, a number of permits are required to be obtained for the implementation of the AFR programme. A summary of the most relevant permits, licences, certificates and other authorisations required by Holcim South Africa are detailed in Table 8.1 below. This table must be read in conjunction with the environmental legal register contained within Appendix K.

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Table 8.1: Summary of the most relevant permits, licences, certificates and other authorisations required by Holcim South Africa for the introduction of an AFR programme at Ulco Applicable Aspect Component Compliance Requirement Environmental Law Environment Commencement of any activity An Environmental Impact Assessment Conservation Act, No that is considered to be must be submitted to the Minister of 73 of 1989 and substantially detrimental to Environmental Affairs and Tourism Regulations 1182 and the environment must be (DEAT) or any other competent 1183 published there preceded by written authority identified by the Minister or a under. authorisation obtained from written application for exemption to the relevant authority. conduct an EIA or part thereof must be submitted to the relevant authority. Environment Any person, who treats, stores If applicable, a written permit Conservation Act, No for a period exceeding 90 days, application must be submitted to 73 of 1989 or disposes of hazardous waste DWAF. on site must apply for a permit for a waste disposal facility from DWAF. Hazardous Substances The operation may not use, If applicable, the operation must apply Act, No 15 of 1973 operate, install or dispose of in writing for a licence at the any hazardous substance with Department of Health. a Group I and II: (any substance or mixture of a substance that might by reason of its toxic, corrosive etc.; nature, or because it generates pressure through decomposition, heat or other means, cause extreme risk of injury etc) or Group III: (any electronic product with hazardous qualities), unless a license is in force in respect thereof. Occupational Health All drivers transporting Ensure that the relevant drivers have and Safety Act, No 85 hazardous material must be in the correct licences and that of 1993 – GNR 1179 of possession of a valid Public awareness training programs, 25 August 1995 Driving Permit: Hazardous, a highlighting all transportation of medical certificate and a dangerous goods risks are developed HazChem training certificate. and implemented on all relevant driver In addition they must comply levels. with the Road Transport Quality System, have full knowledge of emergency response procedures, and be equipped with and trained in the use of protective clothing.

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Applicable Aspect Component Compliance Requirement Environmental Law Occupational Health An employer shall, before any Ensure that awareness-training and Safety Act, No 85 employee is exposed or may be programs, highlighting the risks of 1993 – GNR 1179 of exposed to any hazardous involved in respect of exposure to 25 August 1995 chemical substance, ensure hazardous substances are developed that the employee is and implemented on all employee adequately and levels. comprehensively informed and trained. Atmospheric Pollution No person may conduct a Apply in writing to the Chief Air Prevention Act, No 45 Scheduled Process in or on any Pollution Control Officer (CAPCO) at of 1965 (APPA) premises in South Africa unless DEAT for provisional or current that person or company is the registration certificates for each and holder of a provisional or every Scheduled Process, and ensure current registration certificate that the conditions in the certificate authorising the carrying on of are complied with at all times. the Scheduled Process in or on the premises concerned. Atmospheric Pollution Any alteration or extension of If applicable, a written application Prevention Act, No 45 an existing building or plant in must be submitted to the Chief Air of 1965 (APPA) respect of which a registration Pollution Control Officer (CAPCO) for certificate has been issued is provisional registration of the proposed prohibited unless an application alteration or extension. Alternatively has been made to the Chief Air apply for exemption from CAPCO. Pollution Control Officer A provisional or current registration (CAPCO) for provisional certificate is not required where the registration of the proposed alteration or extension will not affect alteration or extension. the escape into the atmosphere of noxious or offensive gases. Atmospheric Pollution The operation shall not install A provisional or current registration Prevention Act, No 45 in or on any premises any fuel- certificate is not required where the of 1965 (APPA) burning appliance, unless such alteration or extension will not affect an appliance is provided with the escape into the atmosphere of effective appliances to limit the noxious or offensive gases. emission of grit and dust to the satisfaction of the local Ensure that best practice technology is authority. A local authority may used to prevent the escape into the require any person to furnish atmosphere of noxious or offensive information as to the fuel or gases. refuse used in fuel burning appliances. Atmospheric Pollution No local authority shall approve If applicable, ensure that all fuel Prevention Act, No 45 of any plan that provides for burning appliances are suitably sited of 1965 (APPA) the installation of any fuel and that best practice technology is burning appliance, unless it is used to prevent the escape into the satisfied that a fuel burning atmosphere of noxious or offensive appliance is suitably sited. gases.

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Applicable Aspect Component Compliance Requirement Environmental Law Atmospheric Pollution Certain odours may be defined If applicable, the operation must have Prevention Act, No 45 as noxious or offensive gases a valid provisional or current of 1965 (APPA) and relevant registration registration certificate to carry on its certificates are needed for the business. Submit an application for the continued carrying on of those relevant certificate to CAPCO at DEAT. processes that create these noxious or offensive gases.

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