Cement Manual

8/10/2019 Cement Manual

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Cement Industry Inspection Manual

1. Introduction

The Egyptian Pollution Abatement Project (EPAP) sponsored by FINIDA hasassigned Finish and Egyptian consultants for the tas of de!eloping sector"specific inspection and monitoring guidelines##

A $eneral Inspection %anual& $I%& has been de!eloped co!ering inspectionaspects common to all sectors# The manual '

Discusses the strategy& objecti!es and tass of the inspectorate

management

Identifies the team leader responsibilities and tass

Presents a methodology for performing all types of inspection# Tass

during the !arious phases of planning& performing field inspection&report preparation and follo"up are discussed# e!eral checlists areincluded

ector specific inspection manuals ha!e been de!eloped for the folloingindustries

Te*tile industry

Pulp and paper industry

Food industry

" $rain milling industry" Dairy industry" +arbonated be!erages industry" +onfectionery industry" Fruits and !egetables industry

%etallurgical industry Fabricated metal industry

%otor !ehicle assembly

The de!eloped manuals ere tested through a number of training programs thattargeted ,-.s and E%/s# The inspectors in!ol!ed in the training used thesemanuals to inspect a number of industrial facilities# Feedbac from theconcerned parties led to the impro!ement of these manuals and theircontinuous update#

1.1Preface

As a continuation of the pre!ious effort& manuals for the folloing industrialsectors are being de!eloped

Paint industry

Detergent oil and soap industries

+ement and ceramic industry

Fertili0er industry

Environics June 2002

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1.1.1 Project objectivesThe project aims at the de!elopment of sector"specific guidelines for inspectionto be used by inspectors# These manuals are meant to be simplified but ithoutabstention of any information necessary to the targeted users# Flocharts&tables and highlighted notes are used for easy representation of information#

1.1.2 Organization of the inspection manualThe inspection manual for the cement industry includes ten chapters# The firstchapter represents an introduction to the hole project and to the specific sub"sector of the industry# +hapters to to fi!e deal ith the cement industry andits en!ironmental impacts#

The description of the industry in chapter 1 includes the inputs and outputs& adescription of the different production lines ith their specific inputs andoutputs& a brief description of the ser!ice and au*iliary units that could be

present at the industrial establishment ith their potential sources of pollution

and the !arious emissions& effluents and solid astes generated from thedifferent processes#

+hapter three describes the en!ironmental and health impacts of the !ariouspollutants hereas chapter four gi!es a summary of the articles in the Egyptianen!ironmental las rele!ant to the cement industry# +hapter fi!e gi!ese*amples of pollution abatement techni2ues and measures applicable to thecement industry#

The inspection procedures are described in chapters 3 to 45 starting ith abrief description of the inspection process in chapter 3 then the planningaspects that should be considered at the inspectorate le!el are e*plained inchapter 6# The different tass at the inspectors le!el specific to the cementindustry& ill be described in chapters 7 to 45# The tass before field inspectionare presented in chapter 7 hereas the inspection tass for actually performingthe field !isit are defined in chapter 8# +hapter 45 is concerned ith theconclusion of the field !isit including inspection report riting& supporting theenforcement case and folloing"up the compliance status of the facility#

1.2Introduction to the cement industry

+ement industry is considered one of the important industry in Egypt# Thisindustry is related to the building& construction and infrastructure industries#In the last ten years& there has been a great breathrough in this industry '

+ement manufacturing is being performed by dry process instead of et

process

Aareness of the harmful impact of this industry on en!ironment and

health and trying to find out the solution


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The plants are being distributed in different locations in Egypt instead

of being concentrated in 9elan and Ale*andria

Table (4) shos the daily production of cliner according to design capacity


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2. Description of the Industry

+ement manufacturing is considered one of the strategic industries becauseit is directly related to building and construction# +ement is used as ahydraulic binding material& most often applied as a component of mortar or

concrete#+ement plants are usually sited near limestone& clay 2uarries in order tominimi0e ra material hauling costs#

+ement manufacturing plants !ary idely in !olume and composition ofpollutants discharged# Differences arise from process !ariations& in"plantpractices& houseeeping and other factors#

To types of processes are a!ailable& nominally termed :et; or :dry


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silicate than regular Portland cements# Finergrinding causes 2uicer hardening and a fastere!olution of heat# ,oads constructed from 9Ecan be put into ser!ice#

?" @o heat Portlandcements

+ontain a loer percentage of tricalciumsulfate and tricalcium aluminate& thus loeringthe heat e!olution# +onse2uently& the

percentage of tetracalcium ferro"aluminate isincreased because of addition of ferric o*idesto reduce the amount of tri calcium aluminate

" ulfate resistingPortland cements

+ontain a loer percentage of tricalciumaluminate# -y their composition or processing&they can resist sulfate better than the other fourtypes# This type is used hen high sulfate

resistance is re2uired#

The difference beteen the gray and hite cement are presented in table (>)

"able #% $ "he difference beteen the gray and hite cement

$ray cement =hite cement

Raw materials @ime stone& clay& sandgypsum& iron o*ide

Pure lime stone& aolin&pure sand& gypsum

Cemical composition

i.1 14"1> 1?"13Al1.> 6"8 "3

Fe1.> >"? "

+a. 3?"3 33"36

!pplication Foundation Plastering ors and tilemanufacturing

Note: Defining the inputs and outputs helps predict the expected pollutants.

2.2Production linesTable ? presents the !arious production lines and ser!ice units that could be

present in a facility producing cement#

Note: Knowledge of the processes involved in each production line and unitsallows the prediction of pollution hazards and expected violations and helpsdetermine possibilities for implementing cleaner technology.

"able #&$ Production lines and service units in cement industry

Production 'ines (ervice )nits=et process production line# -oilers


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Dry process production line#emi"dry production line

=ater treatment unit+ooling toersAir compressors@aboratory%echanical B electrical orshops$arage

torage facilities#=asteater Treatment PlantPaper sacs plant,estaurant and 9ousing comple*

+ement is manufactured in fi!e iln types' et process& dry process& preheater&precalciner and semi dry process ilns# The same ra materials are used in etand dry process ilns& hoe!er& the moisture content and processingtechni2ues differ& as does the iln design# The commonly processes used inEgypt are the dry and et processes# emi dry process are commonly used inIndia and +hina#

2.2.1 *et Process production line

The et process is being displaced by the dry process because of sa!ing inenergy& accurate control and mi*ing of the ra mi*ture#

Figure (4) presents the main operations in this process& the inputs to the unitsand the pollution sources# These operations are'

Crusin#$proportionin#

and Mi%in# o&raw materials

The ra materials lime stone& silica& clay& shale ando*ides of chal are crushed& screened and transported

to be stored as piles in open area or co!ered storage#

'rindin# ,a materials are transported to slurry mills to be mi*edith ater to form a slurry# The ra material is groundcontinuously until its mean fineness has reached the desired!alue# The slurry is transported to silos maing the mi*turehomogeneous and alloing the final adjustment incomposition to be made# Periodical samples are taen toensure that the mi*ture composition is identical to there2uired specifications#

lurry is transported to a slurry basin here rotating armsmae the mi*ture homogeneous#


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)iln$ cooler The slurry is ithdran from the bottom of the basin& to befed into the inlet of the rotary iln# The iln is a longcylindrical shaped o!en& internally lined ith refractory

brics# It rotates sloly on an a*is slightly inclined from thehori0ontal# The slight a*is inclination allos the iln

contents to drop forard as the iln rotates# 9ightemperature combustion gas produced at the loer end ofthe iln flos upard& counter current to solid materialmo!ing don the iln#The hot cliner at 4?55C + is cooled by air cooler to 35"155C +#

*inis 'rindin#and +ac,a#in#

The cliner is transported to a cement ball mill here$ypsum is added then grinding taes place# +ement is

paced in paperplastic bags# Fig (1) shos the ball millused in cement industry


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/ote *ind out

=hat happens to the flue gases emitted from the iln and

contains a percentage of soft dust

=hat happens to the rejected paper plastic sacs

/otice Noise is generated from crushers& screens and grinders (mills)

2.2.2 Dry Process production unit-Figure (>) presents the dry and semi dry cement manufacturing processes#Figure (?) presents the processing steps for the dry process production andits potential pollution sources# The processes in!ol!ed are'

Crusin#$proportionin#and Mi%in# o&raw materials

The ra materials lime stone& silica& clay& shale ando*ides of chal are crushed& screened andtransported to be stored as piles in open area andco!ered storage#

'rindin# ,a materials are fed into a rotary dryer& here they aredried by hot air or the flue gases generated from the iln#The dried ra material is grinded in ra materials milland transported to a pre"blending silo to behomogeni0ed by compressed air# The ra material out"

put from the pre"blending silo is transported to thestorage silo#

)iln$ Cooler 9omogni0ed ra material is ithdran from the bottomof the silo& then fed to the pre"heater toer beforefeeding the rotary iln # 9eat is pro!ided by burningfuel oil (ma0ot)or natural gas# Additional heat is

pro!ided by preheated air from cooling the cliner#9igh temperature combustion gas produced at the loerend of the iln flos upard& counter current to solidsmo!ing don the iln# The ilns are slightly inclined& sothat materials fed at the upper end tra!el sloly to theloer firing end& taing from 4 to > hours# +ombustiongases preheat the ra materials at the entrance of theiln to 855C +& and pro!ide the heat necessary for thedecomposition of calcium carbonate# The absence ofater in this process allos the use of shorter ilns ascompared to the et process# =aste heat boilers aresometimes used to conser!e heat and are particularlyeconomical for dry process cement& since the astegases from the iln are hotter than those from the et

process# The by"pass iln dust particulates are separatedfrom e*haust gases by using electrostatic precipitator#-ecause the lining of the iln has to ithstand se!erabrasion and chemical attac at the high temperatures inthe clinering 0one& the choice of a refractory lining isdifficult# For this reason high alumina and high magnesia

brics are idely used# The final product formed consistsof hard granular masses from > to 15 mm in si0e calledcliner# The cliner is discharged


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+igure #&$ Production line for dry ,ement and Related Pollution (ources

In puts Processing steps Pollution sources

@ime stone& ilica& clay&

shale& o*ides of chal

Fuel (%a0otnatural gas)

Fuel (%a0otnatural gas)

$ypsum

Dust emission

Dust emission

Dust emission (chimney)

Noise (or place)

Flue gases

Flue gasesDust emission9eat stress (or place)

Dust emission

Noise (or place)

Dust emission


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+rushing

Proportioningand mi*ing ofra material

,a %aterial$rinding

9omogeni0ing and-lending ilo

iln

+liner+ooler

+liner $rindingand

+ooling

Pacaging

Pre"heater


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from the rotating iln into the air 2uenching coolershich 2uicly bring its temperature don toappro*imately 455 to 155C+# These coolerssimultaneously preheat the combustion air# Figure ()

illustrates the > 0ones in the iln#There are > types of coolers used for cliner cooling&rotary cooler& planetary cooler and grate cooler#$rate cooler is the most common cooler used in the dry

process# Fig (3) shos the grate cooler

ome o& te prolems tat arise due to dust &ormationin te ,iln are

The formation of build"ups and rings in the

cyclones& iln inlet and calcining 0one that could leadto complete blocing and stopping the iln for

se!eral days Alali !apori0ation consumes a large amount of

energy

*inis 'rindin#

and +ac,a#in#

The cliner is transported to tube cement ball mill here$ypsum is added# +ement is paced in paperplastic

bags#

/ote *ind out

=hat happens to the flue gases emitted from the iln and contains

a percentage of soft dust

=hat happen to the rejected paper plastic bags

/otice +hec for noise from grinding and crushing

2.2.% (emiDry Process production unit-

The semi"dry process is a special e*ample of the dry process and uses a @epoliln or shaft iln# In either iln& the ra material ground in the dry process isshaped into pellets ith diameter of 45 to 4 mm& so that about 4>G of ater

is added#

In the case of the @epol iln& the pellets are dried and preheated once by themo!able grate preheater and fed into the iln# This system applies for the firsttime in the cement industry a concept of separating the ra material preheating

process& hich used to be effected in the iln& and preheating by a separatede!ice ith high thermal efficiency#


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In the shaft iln& silica& clay& fuel is added in the pelleti0ing process# All processof drying& sintering and cooling are effected in the !ertical mo!able bed# Thisconcept had been conducted before the rotary iln as spread and& recently& theshaft iln ith a continuous discharging function installed at the furnace bottomis mainly uses in India and +hina# This ilnHs ad!antage is heat economy but it

also has disad!antages since the poing or in the furnace has to be repeatedto retain a stable combustion state and nonuniformity of 2uality cannot bea!oided#


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2.%(ervice units- description and potential pollution sources


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+ig #/$ 0rate cooler


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%edium and large si0e plants ill ha!e someall of the folloing ser!ice andau*iliary units# These units can be pollution sources and therefore should beinspected and monitored# Figure (6) shos the !arious units ith theircorresponding ra materials and potential pollution sources#

2.%.1 oilers

-oilers are used to produce steam for electric poer generation

-oiler grade ater must be lo in TD to minimi0e scale formation# Thereforesoft ater is used as feed to the boilers#+on!entional steam"producing thermal poer plants generate electricitythrough a series of energy con!ersion stages# Fuel is burned in boilers tocon!ert ater to high"pressure steam& hich is then used to dri!e the turbine togenerate electricity#The gaseous emissions generated by boilers are typical of those from

combustion processes# The e*haust gases from burning fuel oil (%a0ot) or gasoil (solar) contain primarily particulates (including hea!y metals if they are

present in significant concentrations in the fuel)& sulfur and nitrogen o*ides(.* and N.*) and unburned hydrocarbonThe concentration of these pollutants in the e*haust gases is a function of firingconfiguration (no00le design& chimney height)& operating practices and fuelcomposition#$as"fired boilers generally produce negligible 2uantities of particulates and

pollutants#=asteater is generated as blodon purged from boilers to eep theconcentration of dissol!ed salts at a le!el that pre!ents salt precipitation and

conse2uently scale formation# The blodon ill be high in TD#In the case of poer plants& ater is used for cooling the turbines and is alsogenerated as steam condensate# The amount of asteater generated dependson hether cooling is performed in open or closed cycle and on the recycling ofsteam condensate# +ontamination may arise from lubricating and fuel oil%ore information about boilers can be found in the inspection manual forenergy generating plant (EPAP& 1551)

2.%.2 ,ooling "oers

+ooling ater is used e*tensi!ely in industry# During the cooling process&

ater heats up and can only be reused if cooled# +ooling toers pro!ide themeans for recycling ater and thus minimi0ing its consumption# The coolingeffect is performed through partial e!aporation# This causes an increase in theconcentration of dissol!ed salts hich is controlled by purifying some ater(blodon)# The blodon ill be high in TD#

Process cooling is the major use for ater in dry process cement manufacture(drying e2uipment and air compressor operation& and cooling of iln bearings&mill bearings& burner pipes& etc#)# Therefore& dry process ater effluents shouldnot normally be contaminated unless poor ater management is practiced#lurry ater used to feed ra materials into the iln for the et process

e!aporates (dissipates in the air as !apor)#


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2.%.% ir ,ompressors

Air compressors are used in cement industry for ra material pneumatictransporting# +ompressors consume a considerable 2uantities of lube oils forlubricating and cooling purposes& in addition to electricity# The major

en!ironmental impacts are noise affecting orers and spent oils#

2.%.& 'aboratories

@aboratories ha!e an important role in the cement industry& as they areresponsible for'

Testing ra materials& chemicals& ater& asteater

uality control of the products and comparing the findings ith the

standard specifications for ra materials and final products

The measured parameters are physical properties& chemical composition

+hemicals used for testing could be ha0ardous# Proper handling and

storage are re2uired for compliance ith en!ironmental la#

2.%.3 *or4shops and 0arage

@arge facilities ha!e electrical and mechanical orshops for maintenance andrepair purposes# Pollution source could be due to'

Noise

,inse ater contaminated ith lube oil

crap metal

Pollution in the garage area ill depend upon the ser!ices offered# Thepresence of a gasoline or diesel station implies fuel storage in underground oro!er the ground tans that re2uire lea and spill control plans#,eplacing lube oil implies discharge of spent oil to the seer lines or selling itto recycling plants#

2.%./ (torage +acilities

The specifications for the storage facilities depend on the stored material#

+hemicals are used as additi!es for the process& for treatment processes#

These chemicals re2uire special handling& storage and management

procedure as re2uired by la# Fuel is used for the boilers& for the cars and deli!ery trucs# It is stored

in underground or o!er ground tans# The types of fuel usually used arefuel oil (%a0ot)& gas oil (solar)& natural gas and gasoline#

crap metal

2.%.5 *asteater "reatment Plants

A cement facility discharges asteater high in Total dissol!ed solid (TD)&Total suspended solid (T)& alalinity& potassium salts and sulfates# The

potential pollution sources are'

ludge hich represents a solid aste problem


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Treated ater& hich could represent a ater pollution problem if

containing pollutants that e*ceed the limits set by rele!anten!ironmental las#

2.%.6 Restaurants! *ashrooms and 7ousing ,omple8

These facilities ill generate domestic asteater as ell as domestic solidaste#

2.%.9 Paper (ac4s Plant

This plant produce sacs from raft paper for cement pacaging# This facilityill generate solid aste of rejected paper#


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+igure #5$ (ervice )nits and "heir Related Pollution (ources

Inputs (ervice )nits Pollution

Fuel J air

=ater

-oiler -lo Don

(TD) Flue $ases

9ot =ater+ooling Toer -lodon

(TD)

+hemicals

=asteater 9a0ardous

%aterials (handling)

@ube .ilFloor and e2uipment

rinse ater+leaning +hemicals

.ily ,inse =ater

olid =astes

Fuel.il

,inse =ater

.ily rinse ater

olid astes

,a materials

Fuel

+hemicalscrap metal

pills

,a material rejects

9a0ardousmaterial

=asteaterTreated ater

ludge

=ater anitary=asteater

raft paper Noiseolid aste (rejected paper)


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-oilers

+ooling Toers

@aboratory

Electrical B

%echanical

=orshops

$arage

team

torage

=asteater

Treatment /nits

,estaurant andrestrooms

acs Plant

+ompressorsbe oilpent .il

Noise


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2.& :missions! :ffluents and (olid *astes

Table () summari0e the major polluting processes& their outputs and thepolluting parameters#

2.&.1 ir:missions

Caron dio%ide emissionsThere are to different sources of +.1 during cement production

+ombustion of fossil fuels

+hemical process of calcining limestone into lime in the cement iln

The most significant ay to reduce +.1emissions is impro!ing the energyefficiency of the cement iln operation# itching to loer +.1fuels such asnatural gas can also reduce emissions# Another strategy& hich addresses the+.1emissions from calcining limestone& is to use aste lime from otherindustries in the iln#

+articulate emissions

,a materials grinding and handling

iln operations and cliner cooling

Product grinding& handling and pacaging

The source of pollution and their emissions are presented in table (3)

"able #/$ Pollution sources and Related emissions

(ource Polluting parameters

,a materials crushing& grinding andhandling

Particulates (dust)

iln operation and cliner cooling Particulates (dust)& +.& .*& N.*&hydrocarbons& aldehydes and etones-y"pass dust

Product grinding& handling andpacaging

Particulates (dust)

A major source of particulate matter (or dust) at most cement plants is the iln#iln rotation and high !elocity flo of combustion gases entrain large2uantities of dust #Table (6) present a total suspended solid measures for a plant at 9elanTypical iln dust constituents compositions of the Egyptian cement industryare shon in table (7)#

Flue gases are resulting from fuel consumption used to generate steam forelectric poer generation# The !iolating parameters ould be' particulatematters& sulfur o*ides& nitrogen o*ides and carbon mono*ide#


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%. "able #3$ *et and dry Processes Pollutants

;ajor Polluting

source

Process Inputs Process Outputs Pollution Parameters Impact

*et process

Crusin# @ime stone& silica&

clay& shale& gypsum

+rushed ra

materials

Dust from ra material Air pollution

+roportionin#

and mi%in# o&

raw materials

'rindin#=ater lurry Noise =orplace

omo#eniin#

and lendin#

)iln and

Clin,er cooler

Fuel

,a meal

+liner =ater !apor =orplace

Filter iln dust Air Pollution

Temp =orplace

*inis #rindin# +liner

$ypsum

+ement Dust Air Pollution

Noise =orplace

+ac,a#in#

macine

+ement olid aste


Dry process

Crusin# @ime stone& silica&clay& shale& gypsum

+rushed ramaterials

Dust from ra material Air Pollution

+roportionin#

and mi%in# o&

raw materials

+rushed ra materials Dust from ra material Air Pollution

'rindin# ,a material ,a meal Noise =orplace

Dust =orplace

omo#eniin#

and lendin#

)iln Fuel

,ae meal

+liner -y"pass iln dust Air Pollution

Temp =orplace

Clin,er cooler 9ot cliner +liner Air pollution

*inis #rindin# +liner

$ypsum


Noise =orplace

+ac,a#in#

macine

+ement olid aste Air pollution

)iln6s cimney E*haust gases J

particulate

E*haust gases J

particulate

Particulate Air pollution


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"able #5$ total suspended solid measures for a plant at 7elan

(urvey zone TP (mgm>) air

,a mills and preheaters of dry line 14

+ement mills and iln of the et line 34

"able #6$ "ypical 4iln dust constituents compositions of the :gyptiancement industry

,onstituents ,omposition # 1">

+a. >7"?1

%g. 1">

1. 1"?

.> "6

+l ?"3Free lime 4>"43

2.&.2 :ffluents

9ighest le!els of ater pollution occur hen ater is alloed to contactcollected iln dusts# Three most significant sources here this contact mayoccur are' The leaching operation (most important) hich remo!es soluble alalie

and reco!ers solid insoluble portions for reuse& and discharges o!erflo(leachate) as aste

Disposal of entire et dust slurry ith no reco!ery or reuse (slurry isfed to a pond& solid settles and o!erflo is discharged)

A2ueous effluents from et scrubbers are used to ash dusts from ilngas emissions#

The other sources of pollution in the cement industry are -lo don from cooling toers and boilers (high in' TD and T)# pent lube oil from garage and orshops if discharged to seer ill

gi!e oily asteater (.B$)# Domestic asteater

The e*pecting polluting parameters are TD& T and hea!y metal

2.&.% (olid aste

iln dust& ra materials& cliner and other substances are fre2uently stored inpiles on plant property# /nless sheltered& rainfall may percolate through thesepiles& dissol!e (or leach) soluble matter and carry them ith the surface run"offater# From 1555 tonday cliner 5 tonday dust is produced# =ater

polluted in this manner can migrate through the sub"surface layers beneath thematerial storage piles and contaminate ground ater source#

Dust also arises from crushing& mi*ing& grinding and final grinding beforepacaging


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.ther sources of solid astes are rejected plastic and paper acs frompacaging process and from the orshops and garage# The asteatertreatment plant also generates sludge#

7y8pass ,iln dustThis dust is entrained ith flue gases in rotary iln# Part of by"pass cement ilndust is ithdran ith flue gases through chimney# Appreciable amount is fedto electrostatic precipitator& in hich high !oltage charges the dust particles#Dust is then collected at the electrode and precipitated# The disposal ofcement dust hether inside or outside the company limits causes an air

pollution problem due to ind effects# $ranulation of cement dust by aterreduces this problem#=hen the company uses the et production line& part of by"pass cement ilndust can be recycled bac to the et production line#

2.&.& *or4place

/oise Noise arises from grinding& crushing& sacs plant andpacaging operations# Noise may reach 455"445 d-

eat tress The orers are e*posed to heat from ilns#


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%. :nvironmental and health impacts of pollutants.

%.1 Impact of air emissions

+articulate

matters

,ecent epidemiological e!idence suggests that much of the

health damage caused by e*posure to particulates isassociated ith particulate matters smaller than 45Km(P%45)# These particles penetrate most deeply into thelungs& causing a large spectrum of illnesses (e#g# asthmaattac& cough& and bronchitis)# Emissions of particulatesinclude ash& soot and carbon compounds& hich are oftenthe result of incomplete combustion# Acid condensate&sulphates and nitrates as ell as lead& cadmium& and othermetals can also be detected#

ul&ur 9%ides Air pollution by sulfur o*ides is a major en!ironmental

problem# This compound is harmful to plant and animal life&as ell as many building materials# Another problem ofgreat concern is acid rain& hich is caused by thedissolution of sulfur o*ides in atmospheric ater dropletsto form acidic solutions that can be !ery damaging hendistributed in the form of rain# Acid rain is corrosi!e tometals& limestone& and other materials#

/itro#en 9%ides .*ides of nitrogen (N.*) include si* non gaseouscompounds' nitric o*ide (N.)& nitrogen dio*ide (N.1)&nitrous o*ide (N1.)& nitrogen ses2uio*ide (N1.>)& nitrogen

tetro*ide (N1.?)& and nitrogen pento*ide (N1.)# The too*ides of nitrogen of primary concern in air pollution arenitric o*ide (N.) and nitrogen dio*ide (N.1)& the only too*ides of nitrogen that are emitted in significant 2uantitiesin the atmosphere# -eing hea!ier than air& nitrogen dio*ide(N.1) is readily soluble in ater& forming nitric acid andeithernitrous acid or nitric o*ide& as indicated in the folloinge2uations'1 N.1J 91. 9N.>J 9N.1

(Nitrous acid)

> N.1J 91. 1 9N.>J N. (Nitric o*ide)-oth nitric and nitrous acid ill dissol!e in the rain orcombine ith ammonia (N9>) in the atmosphere to formammonium nitrate (N9?N.>)# In this instance& the N.1ill

produce a plant nutrient# A good absorber of energy in theultra!iolet range& N.1conse2uently plays a major role inthe production of secondary air contaminants such aso0one (.>)#

Nitric o*ide (N.) is emitted to the atmosphere in muchlarger 2uantities than N.1# It is formed in high"temperature


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combustion processes hen atmospheric o*ygen andnitrogen combine according to the folloing reaction'

N1J .1 1 N.:ffects of nitrogen o8ides on human health

Nitric o*ide (N.) is a relati!ely inert gas and only

moderately to*ic# Although N.& lie +.& can combine ithhemoglobin to reduce the o*ygen"carrying capacity of the

blood& N. concentrations are generally less than 4#11mgm>(4 ppm) in the ambient air& and are thus notconsidered health ha0ards# 9oe!er& N. is readilyo*idi0ed to N.1& hich does ha!e biological significance#

N. J L .1 N.1N.1irritates the al!eoli of the lungs#

Caron dio%ide +ombustion of fossil fuels to produce electricity and heatcontribute to the green house effect caused by the

formation of carbon dio*ide# The greenhouse phenomenonoccurs hen heat radiation from earth is absorbed by thegases causing a surface temperature increase#

:ust .ccupational e*posure to cement dust& presents healthproblems due to its abrasi!e& hygroscopic and alalineproperties& as ell as its content of trace elements&particularly he*a!alent chromium& cobalt and nicel#E*posure to air borne cement dust is a ha0ard in thecement manufacturing plants# +ement orers suffer fromupper respiratory tract irritation and ec0ema& because of

the high dust le!els in the oring areas#

ilicon dio%ide There is sufficient e!idence for the carcinogenicity ofinhaled crystalline silica in the form of 2uart0# The action ofcrystalline silica on the lungs results in the production of adiffuse fibrosis in hich the parenchyma and the lymphaticsystem are in!ol!ed# This fibrosis is& to a certain e*tent

progressi!e& and may continue to increase for se!eral yearsafter e*posure is terminated## The most common physicalsign of silicosis is a limitation of e*pansion of the chest#There may be a dry cough#

;ricalcium silicate Acute inhalation may cause irritation& hee0ing andcoughing# +hronic inhalation has been associated ithchest tightness& coughing& restricti!e lung disease andemphysema#

Prolonged dermal contact ith et cement may causese!ere second or third degree burns& most commonly onthe hand& feet& nees or legs#-ronchitis and emphysema ha!e been reported after many

years of e*posure to cement manufacturing#


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!luminum o%ide Dry poder may cause mared inflammation or corrosionof the sin B mucous membranes# Industrial e*posure tohigh concentrations of Aluminum containing airborne dustshas resulted in a number of cases of occupational

pneumoconiosis# =orers chronically e*posed to aluminum

containing dusts or fumes ha!e de!eloped se!erepulmonary reactions including fibrosis& emphysema andpneumothora*#

*erric o%ide =orers e*posed to iron o*ide fume and silica may de!elopa mi*ed dust pneumoconiosis#

)aolin Clay .ccupationally inhaled aolin produced chronic pulmonaryfibrosis sites of action' lung parenchyma& lymph nodes andhilus#

7entonite clay The poder may contain large amounts of free silica hich

can produce pneumoconiosis ith chronic inhalation#+hronic inhalation e*posure to similar clays& such asfullerHs earth& has been shon to cause pneumoconiosisithout pathological changes of silicosis# ymptomsusually appear after many years of e*posure#Direct eye e*posure resulted in se!ere anterior segmentu!eitis and retrocorneal abscess in a dental assistant#

Calcium sul&ate


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%.& :nvironmental Impact on *or4place

In cement factories& noise is generated from grinding and crushing# +onstantnoise causes an increase in blood pressure and may affect the ner!ous system#

%oreo!er& it can reduce a personHs attention and concentration and causehearing loss as a result of long period of e*posure#


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&. :gyptian las and regulations

There are a number of las and regulations that address the differenten!ironmental !iolations# The folloing are the las applicable to thecement industry#

&.1 ,oncerning air emissions

Article ?5 of @a ?488?& article ?1 of the e*ecuti!e regulations and anne*3 deal ith gaseous emissions from combustion of fuel# The statutesrele!ant to the fuel combustion are'

The use of fuel oil (ma0ot) and other hea!y oil products& as ell crude

oil shall be prohibited in delling 0ones#

The sulfur percentage in fuel used in urban 0ones and near the delling

0ones shall not e*ceed 4#G# The design of the burner and fire"house shall allo for complete mi*ing

of fuel ith the re2uired amount of air& and for the uniform temperaturedistribution that ensure complete combustion and minimi0e gasemissions caused by incomplete combustion##

$ases containing carbon dio*ide shall be emitted through chimneys

rising sufficiently high in order that these gases become lighter beforereaching the ground surface& or using fuel that contains high proportionsof sulfur in poer generating stations& as ell as in industry and otherregions lying aay from inhabited urban areas& pro!iding thatatmospheric factors and ade2uate distances to pre!ent these gases from

reaching the delling and agricultural 0ones and regions& as ell as theater courses shall be obser!ed#

+himneys from hich a total emission of astes reaches 6555 M 4555

ghr& shall ha!e heights ranging beteen 47 M >3 meters#

+himneys from hich a total emission of gaseous astes reaches more

than 4555 ghour& shall ha!e heights e*ceeding at least to and a halftimes the height of surrounding buildings& including the building ser!ed

by the chimney#

The permissible limits of emissions from sources of fuel combustion in

boilers are gi!en in table (8)#(ministerial decree no# ?8&1554)

The permissible limits of emissions from ilns are regulated according

to the limits shon in table (45)

"able #9$. ;a8imum limits of emissions from oilers of fuelcombustion

Pollution;a8imum limit! mg=m%of

e8haust

ulfur Dio*ide# >?55

+arbon %ono*ide# 15

olati0ed ashes in urban

regions#

15

olati0ed ashes in remote 55


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regions#

moe# 5


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"able #1>$;a8imum limits of emissions from 4ilns of fuel combustion

Pollution ;a8imum limit! mg=m%of e8haust

:8isting ?e

ulfur Dio*ide# ?555 155

+arbon %ono*ide# ?555 155Ashes in urban regions# 15 15

Ashes in remote regions# 55 55

moe# 15 15

Anne* 3 of la ?488? states that the emission of total particulate atconcentrations higher than the permissible limit is considered an air pollution#Tables 44&41 present the permissible limits for dust in ambient air andorplace respecti!ely#

"able #11$ "otal particulate matter

@ind of activity;a8imum limit for emissions

mg=m%in e8haust

+ement industry55 e*isting

155 ne

"able #12$ 'imits for nuisance causing dusts

@imits for total dusts 45 mgm>

@imits for inhalable dusts mgm>

&.2 ,oncerning :ffluents

@imits for pollutants in asteater !ary depending on the type of recei!ingater body# The parameters that should be monitored andor inspected areT& TDTable (4>) presents the permissible limits for discharges to the differentrecipients (sea& Nile& canals& agricultural drains& public seer) according to thedifferent rele!ant las#pent lube oil has a negati!e impact on ater and soil and therefore its disposalshould be monitoredinspected# A record should be ept for this purpose#

&.% ,oncerning (olid *aste

A number of las address solid aste management# The folloing las applyto solid aste and sludge from the ==TP'

@a >74836 hich addresses public cleanliness& regulates the

collection and disposal of solid astes from houses& public places&commercial and industrial establishments#


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32


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%inistry of 9ousing& /tilities and /rban +ommunities (%9//+)

decree No# 4>? of 4837& hich pro!ides guidelines from domestic andindustrial sources& including specifications for collection& transportation&composting& incineration and land disposal#

@a >44863& hich amended la >74836

@a ?>4868& the @a of @ocal administration& hich pro!ided that city

councils are responsible for :physical and social infrastructure;&effecti!ely delegating responsibility for infrastructure functions#

@a ?488? regulates incineration of solid aste

&.& ,oncerning *or4 :nvironment

iolations of or en!ironment could be encountered'

In the boiler house' gas emissions& regulated by article ?> of @a

?488?& article ? of the e*ecuti!e regulations and anne* 7#

=here!er heating is performed' temperature and humidity are regulated

by article ?? of @a ?488?& article ?3 of the e*ecuti!e regulations andanne* 8#

Near hea!y machinery' noise is regulated by article ?1 of @a ?488?&

article ?? of the e*ecuti!e regulations and table 4& anne* 6#

entilation is regulated by article ? of @a ?488? and article ?6 of the

e*ecuti!e regulations#

moing is regulated by article ?3 of @a ?488? and article ?7 of the

e*ecuti!e regulations& and @a 14874#

=or en!ironment conditions are addressed in @a 4>64874 for

@abor& %inister of 9ousing Decree >75487>& %inister of IndustryDecree >754871

The limits for the rele!ant pollutants are presented in Table 4?'

"able #1&$ Permissible limits as time average and for short periods

;aterial

'imits

"ime average :8posure limits for short periods

ppm mg=m% ppm mg=m%

,arbon dio8ide 555 8555 4555 16555

,arbon mono8ide 5 ?55 ??5

(ulfur dio8ide 1 45

&.3 ,oncerning 7azardous ;aterial and *aste

@a ?488? introduced the control of ha0ardous materials and astes# Theha0ardous chemicals used in the lab and the fuel for the boilers& fall under the

pro!isions of @a ?488?# Articles 18 and >> of the la maes it mandatory forthose ho produce or handle dangerous materials in gaseous& li2uid or solidform& to tae precautions to ensure that no en!ironmental damage shall occur#

Articles 1& >4 and >1 of the e*ecuti!e regulations (decree >>7488) specify


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the necessary precautions for handling ha0ardous materials# toring of fuel forthe boilers is co!ered by the @a ? as ha0ardous material#

&./ "he :nvironmental RegisterArticle 11 of @a ?488? states that the oner of the establishment shall eep

a register shoing the impact of the establishment acti!ity on the en!ironment#Article 46 and Anne* > of the e*ecuti!e regulations specify the type of datarecorded in the register#


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3. Pollution abatement measures

This section deals ith pollution abatement in the three media air& ater andsoil# Three types of inter!entions ill be considered'

In"plant modifications& hich are changes that are performed in the

plant to reduce pollutant concentrations in streams through reco!ery ofmaterials& segregation andor integration of streams& reducing the florate of the asteater streams that need further treatment to reduce thehold"up of the re2uired ==TP#

In"Process modifications& hich are changes performed on the process

such as the introduction of neer technology& substitution of aha0ardous ra material& performing process optimi0ation and control#

End"of"pipe (EoP) measures& hich in!ol!e treatment of the pollutant

or its separation for further disposal# =hereas in"plant and in"processmodifications usually ha!e an economic return on in!estment& end"of"

pipe measures ill be performed for the sole purpose of complianceith the las ithout economic

Egyptian En!ironmental @as do not re2uire ater and energy conser!ationmeasures# These measures ha!e been considered in this manual since resourcedepletion and hence conser!ation is a orldide"recogni0ed en!ironmentalissue that could be implemented in Egypt in the near future# =ater conser!ationmeasures can lead to higher concentrations of pollutants in the effluent streams#-oth energy and ater conser!ation measures ill pro!ide both financial andeconomic benefits#

The term +leaner Production (+P) refers to the same concepts of pollutionreduction through in"process& in"plant and resource conser!ation& incontradistinction to end"of"pipe treatment# In many cases& the adoption of +Pcan eliminate the need for (EoP) treatment#

The folloing +P and EoP measures ha!e been identified for the cementindustry#


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3.1 ir pollution*lue #ases Particulate matterin flue (e*haust) gases are due to ash and

hea!y metal content of the fuel& lo combustion temperature&lo e*cess o*ygen le!el& high flo rate of flue gases# Sulfurdioxideis due to the sulfur content of the fuel#Nitrogen

oxidesare formed hen ma*imum combustion temperatureand high e*cess o*ygen# arbon monoxideis formed henincomplete combustion occurs at lo air to fuel ratio#The folloing measures can be adopted to minimi0e air

pollution from flue (e*haust) gases'

,eplace %a0ot by solar or natural gas# %a0ot is high

in sulfur content#

,egulate the fuel to air ratio for an optimum e*cess air

that ensures complete combustion of carbon mono*ideto dio*ide#

eep the combustion temperature at a moderate !alue

to minimi0e particulate matter and nitrogen o*ides#

:ust iln operation is the major source of dust and gaseouspollutants due to poor 2uality of ra material# @arger dustparticles can be remo!ed by cyclones or other mechanicalde!ices# mall dust particules can be remo!ed by bag filters&electrostatic precipitators& or et scrubbers# Figures 7&8 shothe baghouse filter and electrostatic precipitators respecti!ely#

:ust8ourceReduction

.ne approach to pollution pre!ention in the cement industryis to minimi0e the production of cement iln dust# There arethree primary means to decrease the amount of dust generated

by the iln# Dust can be minimi0ed by reducing gas turbulencein the iln and a!oiding e*cessi!e flo !elocities# In et

process the use of chains near the cool end of the iln can alsominimi0e dust by trapping the dust before it is released in theiln e*haust# %ost et process ilns are already e2uippedith such cool"end chain sections#

:ust8Recyclin#

and Reuse

+ement iln dust generated from the baghouse dust collectorscan be reused both on"site and off"site# Direct return of dustto the iln is a common recycling practice# The dust may bereturned to the hot end& to the middle of the iln& or to thefeed material# 9oe!er& cement iln dust can only be reused ifcontaminant concentrations fall ithin specified limits&

because cliner 2uality can be affected by the presence ofcertain constituents# Alali metals& such as lithium& sodium and

potassium are of primary concern# The ra materials used toproduce cliner and the iln fuel influence the chemicalcomposition of the dust generated and thus may affectrecycling rates#+ement iln dust can be utili0ed beneficially in a !ariety ofays# It can be used as adsorbent& as a neutrali0ing agent foracidic asteater stream as a soil stabili0er and as aningredient in !arious agricultural and construction products#


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The best practices for air pollution control are summari0ed in table (4)# Themain techni2ues used are described belo#

"able #13$ est Practices in ir Pollution ,ontrol

ir Pollution ,ontrol+apture of iln dust Electrostatic precipitator

-aghouse filter +yclone Noduli0er system

+apture of dust fromcliner cooler

$ranular bed filter Electrostatic precipitator -aghouse filter

+ontrol dust from other

operations

+o!er or enclose con!eyors& crushers&

material transfer points& storage areas Install mechanical dust collectors andor

baghouse filters here needed Pa!e plant road acuum seepers for plant roads prinlers for plant roads and storage piles @ate* stabili0ing sprays for storage piles

Electrostatic precipitator


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>et scruin# =et scrubbing uses ater particles to capture particulatematter in the gas stream# The efficiency of a et scrubber is generallydependent upon the pressure drop#


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3.


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40


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3.2 *ater pollution abatement measures

In8plantmodi&ications

The cement manufacturing process also generates asteaterfrom the cooling of process e2uipment and from the reco!eryof cement iln dust through et scrubbing of iln stac

emissions# The pollutants contained in ra asteater areprincipally dissol!ed solids (potassium and sodium hydro*ide&chlorides& and sulfates)& suspended solids (calcium carbonate)&and asteheat# The main control and treatment methods forasteater in!ol!e recycling and reusing asteater# Thede!ices employed include cooling toers or ponds& settling

ponds& containment ponds& and clarifiers# +ooling toers orponds are used to reduce the temperature of ater used incooling process e2uipment# ettling ponds are used to reducethe concentration of suspended solids# +ontainment ponds areused to dispose of aste iln dust# +larifiers are used to

separate solids#

,ecycling et process aste ater to the iln

+ooling toers and ponds

,unoff control from aste or ra material piles by

diing

Infiltration control from aste or ra material piles by

lining Integration and segregation of seer lines to minimi0e

treatment needs and ensure compliance ith theen!ironmental las& can be an option for many factories#In some cases here there are se!eral discharge pointsfrom the factory& mi*ing of the streams could lead tocompliance# In other cases here treatment is imperati!esome streams could be segregated and dischargedithout !iolation# The remaining streams ill re2uire asmaller treatment unit#

End8o&8pipetreatment

-ecause of the typically high T and TD in the cementindustry aste"streams& end"of"pipe treatment is fre2uentlyre2uired

3.% batement measures for solid aste pollution

+lastic?+apera#s

,ejected plasticPaper bags are collected and sold#

lud#e Effluent treatment processes generate solids& that should bedried and dumped in aste disposal sites#

3.& *ater and :nergy ,onservation

=ater and seer ser!ice costs ha!e been rising& and these increases can cut intoprofits# /sing ater more efficiently can help counter these increases#

>aterConservation

Install ater meters and monitor ater use


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/se automatic shut"off no00les and mar hand"operated

!al!es so that open& close and directed"flo positions areeasily identified#

,ecycle cooling ater through cooling toers#

%inimi0e spills on the floor minimi0es floor ashing#

,epair leas#

9andle solid aste dry#

,ecycle steam condensate hene!er economically !iable#

eat ener#yconservation

measures

=aste heat boilers are used to conser!e heat and are

particularly economical for dry process cement#

In order to obtain greater heat economy& part of the ater is

remo!ed from et process slurry# Techni2ues used employ

slurry filters and Dorr thiceners# Insulation of steam lines#

Installation of steam traps#

,epair or replace steam !al!es#

%a*imi0e boiler efficiency#

Install pressure regulators on steam lines#

Table (43) presents the !arious energy conser!ation techni2ues#

+ower ener#y

conservation

Impro!e poer factor

.ptimum of grinding media in mills


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43


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/. Industrial inspection

The inspection of the cement industry ill follo the procedures described inthe $eneral Inspection %anual ($I%& EPAP 1551)# This chapter presents asummary of the inspection process regarding the purpose and scope of !arious

types of inspection& and the proposed inspection procedure for the +ementIndustry#The o!erall purpose of inspections is to enforce en!ironmental las# Table 46lists the !arious types of inspections and the objecti!es that ha!e to be fulfilledfor each type#

"able #15$ "he different types of inspections and their objectives

Inspection typeObjectives

(ite Inspection

4# +omprehensi!e E!aluate compliance status regarding all aspects of

@a ?1# pecific E!aluate compliance status regarding some aspects

of @a ? ,e!ie special conditions set by EEAA inEIA studies#In!estigate complaints

># Follo"up +hec en!ironmental register and implementation ofcompliance measures

Inspection campaign

4# $eographic +hec pollution sources to specific recei!ing media

1# ector specific +hec aspects rele!ant to specific sector

As e!ident from the abo!e table& comprehensi!e inspection deals ith allaspects of en!ironmental las and therefore is considered in this manual# .therinspection types can be tailored accordingly#De!eloping an inspection strategy and 2uarterly andor monthly plans are theresponsibility of the inspectorate management# De!eloping site"specificinspection plans for carrying out the scope of or that fulfills inspectionobjecti!es is the responsibility of the inspection team# Planning for inspectionsis presented in more detail in the $eneral Inspection %anual& $I% (EPAP"1551)#


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5. Inspection Planning at the Inspectorate 'evel

The responsibilities of the inspectorate management regarding the specificinspection are to state clearly& in riting& the type of inspection and relatedobjecti!es as ell as the time schedule necessary to carry out inspection# The

inspectorate management is also responsible for pro!iding preliminaryinformation about the facility& inspection tools& and logistics#

5.1 ctivities ,haracteristic to the ,ement Industry

Taing the comprehensi!e inspection as an e*ample& the objecti!es stated inTable 46 dictate the acti!ities re2uired for co!ering all aspects of complianceith en!ironmental las and regulations# The re2uired personnel& e2uipmentand logistics are determined accordingly#

The inspectorate management should ha!e a clear idea about ho to proceed

ith inspection of this type of facilities# The main problem in this industry are'

The dust generated from grinding& crushing& iln flue gases and by"pass

cement dust from electrostatic precipitator

The solid aste generated from pacaging (paperplastic sacs) and

piles of dust#

5.2 Providing Information about the +acility

+hapters (1"6) present the technical aspects regarding the cement industry& itspollution sources and rele!ant en!ironmental las# Information regarding

compliance history related to other inspecting parties (irrigation inspectors&occupational health inspectors& etc#) can be helpful in anticipating potential!iolations and preparing necessary e2uipment

5.% Providing Resources

The re2uired personnel& tools and e2uipment depend on the si0e of the facilityto be inspected# The inspection team leaders& in coordination ith theinspectorate management& are responsible for assessing the inspection needs#The number of inspectors re2uired depends on the si0e of the facility and the

planned acti!ities#

/sually the team members are split and assigned different tass during the field!isit to allo the re2uired acti!ities to be performed in parallel# Each tas isrotated among the inspectors to di!ersify their e*perience#


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6. Preparation for +ield Inspection #Inspection "eam$

As presented in the $eneral Inspection %anual& $I% (EPAP"1551)& tassnecessary for preparation for field inspection& are'

$athering information about the specific facility to be inspected

Preparing of the inspection plan

Preparing the checlists

This manual presents the case of a comprehensi!e multi"media site"inspectionof a large cement facility since it represents the highest le!el of inspectioncomple*ity# Tass for carrying out less complicated inspections can be easilydeduced#

6.1 0athering and Revieing Information

The inspection team should re!ie the general information prepared for the

cement industry (chapters 1") and then chec " if possible " hat productionlines and ser!ice units are present at the targeted facility# In addition to there2uired information listed in Anne* (a) of the $eneral Inspection %anual&$I% (EPAP"1551)& it is important at this stage to determine the folloing'

The type of recei!ing body for the industrial asteater and re!ie

rele!ant Egyptian las (+hapter ?)#

The scope of inspection and related acti!ities based on the type and

objecti!es of inspection re2uired by the inspectorate management#

The potential pollution ha0ards as addressed in section 1#?& and

accordingly& define measurement and analyses needs#

Note to inspector:

Some facilities dilute its polluted wastewater with water before

discharging to sewer. Degree !!"#$$$ explicitly prohibits this behavior.

6.2 Preparation of the Inspection Plan

An e*ample of an inspection plan is included in Anne* (b) of the $eneralInspection %anual (EPAP"1551)# The plan should tae into account thefolloing'

For large cement facilities& the inspection team could be di!ided into

smaller groups# Each group ill be responsible for inspecting a numberof production lines and ser!ice units#

At the beginning of the field !isit& the inspection team should chec the

en!ironmental register for completeness using the checlist pro!ided inAnne* (g) of the $eneral Inspection %anual& $I% (EPAP"1551)#

The results of the analyses included in the en!ironmental register should

be checed at the end of the field !isit (if suspicion arises about them)and copies of these results should be obtained#

Notes to inspector:


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%hen the final effluent is expected to be in violation of

environmental laws& sampling should be planned.

'a(e sure that the polluting production lines are in operation

since some factory management resort to halting the pollutinglines during the inspection.

6.% Preparation of the ReAuired ,hec4lists

The checlist for the cement industry is presented in Anne* 4 of this manual#The checlist has been prepared in such a ay that it starts ith generalinformation about the facility and its operation# eparate checlists are thenfilled for each production lineser!ice unit independently for rele!anten!ironmental aspects and media# The inspection team ill compile thecheclists rele!ant to e*isting production lines and ser!ice units in the targetedfacility#The de!elopment of the checlists goes through the folloing steps'

Dra the bloc flo diagrams for the production lines ith their

pollution sources as presented in figures 4 and ?#

Identify the areas of possible non"compliance and the parameters that

need checing# For e*ample& noise should be checed near thecompressors and paper sacs plant# Temperature and humidity heresteam leas occur and near the ilns#

Identify hat to obser!e& as andor estimate that can con!ey

information about pollutants# For e*ample '- the type of detergent or antiseptic determines the contaminant in

the ash streams&

-.ily effluents from production lines or oily cooling aterindicates the contamination of the plant effluent ith oil

/ote to inspector)aw ! does not specify standards for effluent from production lines but onlyfor final disposal points. *owever& effluent +uality from production lines is animportant indicator of the final discharge +uality.


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6.& 'egal aspects

As e!ident from chapter 1& a large cement facility is e*pected to be in !iolationof se!eral en!ironmental las& specifically ith respect to air if no abatement isapplied# The inspection team should be prepared for legally establishing such a

!iolation#

Note to inspector:,t is the responsibility of the inspector to assess the seriousness of theviolation upon which the enforcement action will be based. *is informationabout the nature and cause of the violation must be well documented and theevidence sound. -he case could be contested in court and the inspector willbe as(ed to defend his technical udgement.


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9. Performing the field inspection

9.1 (tarting the field visit

The $eneral Inspection %anual& $I% (EPAP& 1551) describes the procedures

in!ol!ed for entering an industrial facility# The inspectorHs attitude andbeha!ior are !ery important from the start and ill dictate the factoryHspersonnel response to the inspection tass#

Note to inspector:

,t is better at this stage not to as( direct +uestions on cement dust

emission. ,nterviewing the wor(ers on/site in an indirect manner cangive better results.

hec( the results of dust analyses& time and place of sampling. ,f

suspicious&ma(e your own analyses.

0et a s(etch of the factory layout with sewer lines and final disposal

points.

9.2 Proceeding ith the field visit

Information gathered during the facility tour is dependent on inter!ies offacility personnel and !isual obser!ation# Anne* (D) in the $uidelines forInspection Team (EPAP& 1551) presents some useful inter!ieing techni2ues#/sing the facility layout& start by checing the final disposal points and the!arious plants andor ser!ice units connected to each point# This ill determinehere and ho to tae the effluent samples# isual obser!ations about the

condition of the seer manholes should be recorded# In some facilities thedischarge to the recei!ing body is performed through a bayyara (cesspit)& septictans or holding tans# If the holding tan is not properly lined& contaminationof the underground ater could occur#

Note to inspectors:esspits& septic tan(s and holding tan(s are a form of pre/treatment that

generates settled sludge. hec(:

-he presence of accumulated sludge and related hygienic conditions

-he disposal of the sludge

Inspection of the production lines should start ith the feeding of ra materialsand end ith the product pacaging and storage#


4.


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Production 'ines>et +rocess

production line" +hec for noise from grinding and

crushing O" =hat happen to the solid aste

producedO" +hec for heat stress from the ilnO" +hec for the asteater characteristics

from the unit (color& clarification #etc)" +hec for humidity in the orplace O" Are there analyses for dust in

orplace O" +hec the disposal of by"pass iln dust" +hec if the con!eyor used for material

transportation after grinding are co!ered" +hec the disposal of by"pass iln dust

" +hec the using of e2uipment to controldust emission

" +hec the emission from chimney

:ry +rocessproduction line

" +hec for noise from grinding andcrushing

" =hat happen to solid aste produced O" +hec for the heat stress from the iln O" +hec for the !entilation system in the

orplace O" +hec for dust emission in orplace O"+hec the disposal of by"pass iln dust

"+hec if the con!eyor used for material transportationafter grinding are co!ered

"+hec the disposal of by"pass iln dust"+hec the using of e2uipment to control dust emission" +hec the emission from chimney

*or all lines - +hec for losses during pacaging#- +hec for noise near pacaging- 9o is solid aste managedO- +hec for noise in paper sacs plant- +hec for noise near the turbines

(ervice )nits

>ater treatmentunits

-If chemicals and coagulants are used& such as lime&alum and ferric sulfate& inorganic sludge ill begenerated# +hec the amount and method ofdisposal#

- In case of ion"e*change units and re!erse osmosisthe effluent asteater ill be high in dissol!edsolids#

7oilers - +hec the height of the chimney in relation tosurrounding buildings#

- Perform flue gas analysis if ma0ot is used as fuel orif suspicious about results of analysis presented by

facility management in the opening meeting#


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- +hec for fuel storage regulations and spillpre!ention#

Coolin# towers - The amount of blodon from the cooling toers isabout 45"4G of the mae"up ater and is lo in

-.D and high in TD#

'ara#e$ and>or,sops

- +hec for noise and tae measurements if necessary#- +hec solid aste handling and disposal practices#- +hec for spent lube oil disposal method# As for

receipt if resold#

tora#e &acilities - +hec storage of ha0ardous materials and fuel as per@a ?#

- +hec spill pre!ention and containment measures forstorage of li2uids#

>>;+ - +hec for sludge accumulation and disposal#

-Analy0e the treated asteater#

:ffluent analysisReceivin# ody - The nature of the recei!ing body determines the

applicable las#- +hec if effluent discharge is to public seer& canals

and Nile branches& agricultural drains& sea or main,i!er Nile#

- Accordingly& define applicable las& rele!antparameters and their limits#

amplin# - A composite sample must be taen from each finaldisposal point o!er the duration of the shift or a grab

sample at pea discharge# Each sample ill beanaly0ed independently#

- According to legal procedures in Egypt& the effluentsample is spilt and one of them is sealed and eptuntouched#

9.% :nding the field visit

=hen !iolations are detected a legal report is prepared stating informationpertaining to sampling location and time# iolations of or en!ironmentregulations should also state location and time of measurements# .ther !isual

!iolations such as solid aste accumulation& ha0ardous material and astehandling and storage& and material spills should be photographed anddocumented# It is preferable that the facility management signs the field"inspection report but this is not a necessary procedure#A closing meeting ith the facility management can be held to discuss findingsand obser!ations#

Note to inspector:

-he less certain the team leader is about a specific violation the more

reason not to discuss it at the closing meeting.


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1>. ,onclusion of the +ield Inspection

The acti!ities performed during the site inspection are essential for preparationof the inspection report& for assessing the seriousness of the !iolations& for

pursuing a criminal or ci!il suit against the facility& for presenting the legal case

and maing it stand in court ithout being contested& and for further follo"upof the compliance status of the facility#

1>.1 Preparing the inspection report

An e*ample of an inspection report is included in Anne* (F) of the $uidelinesfor Inspection Team (EPAP& 1551)# The inspection report presents the findings&conclusions& recommendations and supporting information in an organi0edmanner# It pro!ides the inspectorate management ith the basis for proposingenforcement measures and follo"up acti!ities#

1>.2 (upporting the enforcement case

%any issues may be raised and disputed in typical enforcement actions#Enforcement officials should alays be prepared to'

Pro!e that a !iolation has occurred# The inspector must pro!ide

information that can be used as e!idence in a court of la#

Establish that the procedures ere fairly folloed#

Demonstrate the en!ironmental and health effect of the !iolating

parameter#

Note to inspectorate management: 1lthough the inspector is not re+uired to suggest pollution abatement

measures& the inspectorate management should be able todemonstrate that a remedy for the violation is available.

1>.% +olloingup compliance status of violating facility

After performing the comprehensi!e inspection and detecting the !iolations theinspectorate management should'

Decide on the sanctions and send the legal report to the judicial

authority#

Plan routine follo"up inspections# This type of inspection focuses on

the !iolating source and its related pollution abatement measure# elf"monitoring results are re!ieed during the !isit#

Follo"up the enforcement case (legal department)

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Cement Manual