ENVIRONMENTAL IMPACT ASSESSMENT REPORT Dudfield EIA Report.pdf · The use of waste-derived fuels in a cement kiln therefore, reduces ... Environmental Impact Assessment Report for

ENVIRONMENTAL IMPACT ASSESSMENT REPORT

FOR THE FOR THE PROPOSED IMPLEMENTATION OF

AN ALTERNATIVE FUELS AND RESOURCES

PROGRAMME FOR KILN 3 AT THE

HOLCIM SOUTH AFRICA DUDFIELD PLANT,

NORTH WEST PROVINCE

Compiled by

Bohlweki Environmental(Pty) LtdPO Box 11784Vorna ValleyMIDRAND1686

In association with the following specialists

Dr D Baldwin and Ms M Chettle

Environmental & Chemical Consultants

Dr L Burger and Ms R Thomas

Airshed Planning Professionals

Mr F Joubert

Sustainable Law Solutions

Dr R Meyer

CSIR (Environmentek)

Ms N Wattel and Mr A van den Heever

Stewart Scott International

Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project atthe Holcim South Africa Dudfield Plant, North West Province

Executive Summary 31-Aug-04i

EXECUTIVE SUMMARY

1. INTRODUCTION

Holcim (South Africa) (Pty) Ltd, formerly known as Alpha (Pty) Ltd, is one of

South Africa’s key producers of cement, stone and ready mixed concrete for the

construction industry. Holcim South Africa currently operate three cement plants

in South Africa, one of which is the Dudfield plant, located approximately 20 km

west of Lichtenburg in the North West Province. At Dudfield plant, limestone

(source material) and coal (fuel) are currently the primary raw materials utilised

in the manufacture cement.

The Dudfield plant is situated on a limestone deposit that is mined and milled as

feedstock to the plant. The coal that is utilised in its kilns as the main energy

source for converting the limestone raw meal to manufacture clinker (the base

feedstock for cement), is transported to the plant by rail.

Holcim South Africa are considering implementing the global trend of replacing a

portion of the fossil fuel (coal) used as the energy source with alternative, waste-

derived fuels. That is, the introduction of an Alternative Fuels and Resources

(AFR) programme is proposed for the Dudfield Plant. The AFR project proposes

the replacement of traditional, non-renewable, fossil-based fuel (coal) with

alternative waste-derived fuels and raw materials within the existing Dudfield Kiln

3 at the existing Dudfield plant. This programme aims to reduce traditional fossil

fuel usage by up to 35% or more.

1.1. Motivation for the Proposed Project

The process of cement manufacture is energy intensive. The average energy

required to produce 1 000 tons of cement clinker is approximately 130 tons of

coal. As a result, Holcim South Africa currently requires approximately

350 000 tons of coal per annum to operate their kilns across the country.

The Holcim commitment to promoting development that is sustainable and at the

least cost to future generations has resulted in a drive to substitute a portion of

the traditional non-renewable fossil fuels (that is, coal) used in the production of

cement with suitable alternative waste-derived materials/fuels. This has resulted

in the need to identify alternative renewable fuel sources which would provide

similar energy (i.e. calorific value) when burnt to that provided by coal, would not

be detrimental to the process in the kiln or the product produced, and would be

less costly than coal in the long-term.

The use of alternative fuels and raw materials that are based on selected waste

products and by-products generated from industrial and domestic sources


Executive Summary 31-Aug-04ii

addresses this need, as much of this waste is chemically similar to coal. The use

of this waste as a fuel presents the opportunity to reduce the environmental

impacts of using a non-renewable resource (coal) in the cement manufacturing

process, as well as to reduce the amount of waste material that would

traditionally be disposed of to landfill or incinerated. The utilisation of AFR in the

cement industry is in-line with initiatives of National Government, particularly the

National Waste Management Strategy (NWMS) which focuses on waste

prevention, waste minimisation and the re-use of waste materials. The practice

of employing alternative fuels in cement plants promotes materials recovery and

recycling by the recovery of energy as well as the mineral components from

waste. The use of waste-derived fuels in a cement kiln therefore, reduces fossil

fuel use, and maximises the recovery of energy, without any significant change in

emission levels.

The use of alternative fuels is a well-proven and well-established technology in

the European, American (both North and South) and Asian-Pacific cement

industries. Experience at international plants has shown that alternative fuels can

successfully replace traditional fossil fuels with no adverse impact on the

environment, safety or health of employees and communities, or on the quality of

the final cement product.

1.2. Infrastructure Requirements for the Proposed AFR Programme

The recent upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class

production facility (with a production rate of 3 500 tons per day) included the

installation of a ‘low NOx’-multichannel primary burner (allowing multiple energy

sources to be introduced into the kiln), a pre-calciner, and a bag filter with a

design particulate emission limit of 30mg/Nm3. This upgrade has also resulted in

this plant being in a position to receive and utilise alternative fuels as an energy

source, together with coal.

Kiln 3 will never completely move away from utilising coal as an energy source.

Coal is a constant fuel with a known calorific value, and the AFR programme is

aimed at substituting a portion of the total coal requirement. In order to

successfully operate a facility on an on-going basis, the source of fuel is required

to be stockpiled or stored on site. With the proposed introduction of the AFR

programme, Dudfield plant would be required to store both coal and AFR on site.

Dudfield plant has an existing stockpile site for coal. A second designated area

would be required for the storage of AFR on the site. AFR streams are proposed

to be delivered directly to the kiln, and an on-site storage facility would be

required to accommodate/store an approximate 2-day reserve capacity to ensure

that sufficient volume of AFR is available as feedstock for an extended period. In

order to store sufficient capacity to replace approximately 35% of the fuel


Executive Summary 31-Aug-04iii

currently used at Kiln 3, suitable tanks, silos and bunded/walled areas would be

required to store the waste-derived fuels. An AFR fuel storage area of

approximately 1 600 m2 is proposed to be established within the boundaries of

the existing Dudfield plant.

The proposed AFR storage area is a currently vacant area approximately 20 m to

the north of Kiln 3 to allow for safe and secure feeding of the AFR material from

the storage area to Kiln 3. The demarcated area has been extensively disturbed

by activities associated with the cement manufacture process at the plant,

including the construction activities associated with the recent upgrade of Kiln 3.

The area is devoid of vegetation, and is on level terrain.

The storage facility would be required to be designed according to national

construction, and fuel handling and storage requirements. The area would be

required to have a concrete floor, be bunded to contain any water accumulating

within the storage area, and have a roof to exclude rainwater from entering and

accumulating within the storage facility. Appropriate drainage facilities would be

required to be in place that would facilitate the separation of stormwater and

runoff from the area.

The storage area would be accessed by a levelled and sealed access road, and

would include sufficient area for vehicles to off-load, and manoeuvre, if required.

It is proposed that initially the kiln would be in a position to utilise approximately

70 tons of AFR a day, which represents between 2 and 3 vehicle loads of AFR per

day arriving at the site. It is proposed that in the long-term the volume of AFR

utilise per day could increase to approximately 240 tons per day, which amounts

to 6 – 8 vehicles per day, and the access road and storage area would be

required to support this.

Appropriate fire fighting systems and monitoring equipment would be required to

be installed to service the AFR storage area.

An AFR on-site laboratory would be required at Dudfield plant for control

tests/analyses to be conducted to verify the content of the AFR arriving at the

plant with the 'fingerprint' analyses that were completed at initial acceptance of

the waste (by an external (off-site) accredited laboratory). The Dudfield plant

AFR laboratory would, therefore, have limited capabilities, and will only verify that

the fingerprint matches the waste delivered.

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

Fuels

Waste materials that the global cement industry has utilised as alternative fuels

include scrap tyres, rubber, paper waste, waste oils, waste wood, paper sludge,


Executive Summary 31-Aug-04iv

sewage sludge, plastics and spent solvents, amongst others. Similar waste

materials are proposed to be used as fuel in South Africa, together with other

selected wastes that are considered suitable and desirable (including industrial

hydrocarbon tars and sludges). These wastes could potentially be sourced from a

variety of sources from a variety of geographic locations. Only those waste-

derived fuels that meet the stringent standards set by Holcim will, however, be

considered and accepted for use in the kiln.

The use of alternative fuels is technically sound as the organic component is

destroyed and the inorganic component is trapped and combined in the cement

clinker forming part of the final product. Cement kilns have a number of

characteristics that make them ideal installations in which alternative fuels can be

valorised and burnt safely, such as:

• High temperatures – exceeding 1 400°C

• Long residence time – in excess of 4 seconds

• Oxidising atmosphere

• High thermal inertia

• Alkaline environment

• Ash retention in clinker – fuel ashes are incorporated in the cement clinker,

and there is no solid waste by-product

While many waste streams are suitable for use as alternative fuels or raw

materials, there are others that would not be considered for public health and

safety reasons. No materials that could compromise the environment, the health

and safety of employees or surrounding communities, or the performance of the

cement would be considered for use as a fuel. Strict sampling and testing

procedures would be required to be put in place at the Dudfield plant to ensure

that undesirable fuels and raw materials (such as anatomical hospital wastes,

asbestos-containing wastes, bio-hazardous wastes, electronic scrap, explosives,

radioactive wastes, and unsorted municipal garbage) are excluded from the AFR

programme.

2. ENVIRONMENTAL STUDIES AND PUBLIC PARTICIPATION

As the introduction of AFR at Dudfield will result in a change to a scheduled

process, as defined in the Air Pollution Prevention Act (No 45 of 1965), Holcim

South Africa requires authorisation from the North West Department of

Agriculture, Conservation and Environment (NW DACE) for the undertaking of the

proposed project. This Environmental Impact Assessment (EIA) process for the

proposed introduction of an AFR programme at Kiln 3 at the Holcim South Africa

Dudfield plant has been undertaken in accordance with the EIA Regulations

published in Government Notice R1182 to R1184 of 5 September 1997, in terms

of the Environment Conservation Act (No 73 of 1989), as well as the National


Executive Summary 31-Aug-04v

Environmental Management Act (NEMA; No 107 of 1998). This EIA aimed to

identify and assess potential environmental impacts (both social and biophysical)

associated with the proposed project. Mitigation and management measures

have been proposed, where required.

In undertaking the EIA, Bohlweki Environmental were assisted by a number of

specialists in order to comprehensively assess the significance of potential

positive and negative environmental impacts (social and biophysical) associated

with the project, and to propose appropriate mitigation measures, where

required. These specialist studies included:

• Air quality assessment

• Assessment of the suitability of waste as an alternative fuel resource, and

impacts pertaining to AFR management, storage, transportation etc

• Assessment of surface- and groundwater impacts

• Legal review

A comprehensive public participation process was undertaken as part of the EIA

process, and involved the consultation of individuals and organisations

throughout the broader study area representing a broad range of sectors of

society. This consultation included telephonic interviews, focus group meetings,

interest group meetings, individual meetings/interviews, public meetings and key

stakeholder workshops, through documentation distributed via mail, and via the

printed media throughout the EIA process. Issues and concerns raised during the

EIA process were recorded and captured within an Issues Trail.

3. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE

PROPOSED PROJECT

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

include:

• impacts associated with emissions to air from the plant;

• impacts associated with the transportation of AFR to Dudfield plant;

• impacts associated with the storage of AFR on site for a limited period;

• impacts on the social environment;

• suitability of waste as an alternative fuel resource; and

• potential project benefits.

These are discussed in more detail below.

According to the US Air and Waste Management Association's (A&WMA) Air

Pollution Control Manual, the use of wastes as a fuel and a raw material in

cement kilns is a reliable and proven technology, offering a cost-effective, safe


Executive Summary 31-Aug-04vi

and environmentally sound method of resource recovery for many types of

hazardous and non-hazardous wastes (http://gcisolutions.com/dgawma01.htm).

Conditions needed to manufacture cement (high temperature, turbulence and

long gas residence times) are the same conditions required for total destruction

of hazardous waste. Cement kilns burn hotter, have longer gas residence times,

and are much larger than other commercial thermal treatment facilities. These

advantages, together with the degree of mixing in the kiln, make cement kilns an

excellent technology for recovering energy from hazardous and non-hazardous

waste (www.ckrc.org/issues/99475523.html).

Results of research undertaken world-wide by the cement industry and

independent institutions (such as the US EPA) have indicated that the impacts

associated with the introduction of an AFR programme in cement kilns does not

impact significantly on the environment when compared to the use of traditional

fossil fuels. However, this is reliant on appropriate management of waste,

including the classification, selection, handling and storage thereof. Therefore,

this EIA has placed emphasis on the identification of suitable wastes as

alternative fuels and the waste management requirements associated with the

introduction of an AFR programme at Dudfield plant.

3.1. Impacts Associated with Emissions to Air from the Plant

Releases from the cement kiln are a result of the physical and chemical reactions

of the raw materials and from the combustion fuels. Typical air pollutants from

cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx),

inhalable particulates (PM10), heavy metals, organic compounds and dioxins and

furans.

During the EIA process, concern was raised regarding the potential impacts

associated with dust, and dioxins and furans and the health risk posed to local

communities. From the results of the specialist study undertaken as part of this

EIA, it is anticipated that an impact of low significance on air emissions will result

with the introduction of an AFR programme at Kiln 3 at Dudfield plant as the

emission levels remain below the DEAT guidelines.

The exit gases from Kiln 3 are de-dusted in bag filters, and the dust returned to

the process. Therefore, dust levels associated with this process are low and will

not impact significantly on the surrounding environment. This will continue to be

the case with the introduction of an AFR programme.

Dioxins and furans are a family of persistent organic chemicals detectable in trace

amounts throughout the environment. The US EPA, international Agency for

Cancer Research and US Department of Health report that excessive exposure to

2,3,7,8-tetrachlorodibenzo-p–dioxin (2,3,7,8-TCDD) can cause of wide range of


Executive Summary 31-Aug-04vii

very harmful human health effects, including cancer (EPA, 2004). Studies by the

US EPA and French Academy of Sciences have, however, indicated that it is highly

unlikely that dioxins would increase cancer incidence in people at the low

exposure levels commonly encountered in the environment or from food (Rotard,

1996), and that no fatal case associated with these compounds has ever been

reported (Constans, 1996).

Dioxins can be formed from any burning process, and cement kilns are no

exception. The potential for dioxin formation in cement manufacture is a function

of raw materials and kiln technology, and is not related to the types of fuel used.

Dioxin emissions are generally in the range of detection limits and the level of

emissions can depend on the type of kiln technology employed. “Cement kilns

control dioxin formation by quenching kiln gas temperatures so that gas

temperatures at the inlet to the particulate matter control device are below the

range of optimum dioxin/furan formation” (EPA, 2004).

The cement industry has been more successful than any other in reducing

emissions of dioxins and furans. Through intensive research, an understanding of

the nature of dioxin formation in combustion emissions has been established, and

they have succeeded in learning how to reduce those emissions. As a result since

1990, dioxin emissions from kilns that recover energy from hazardous waste have

been reduced by 97%. This has been corroborated by independent research

undertaken by the US EPA (www.ckrc.org/ncafaq.html).

Conclusions of the specialist air quality study undertaken as part of this EIA (refer

to Chapter 6) are in agreement with these international findings and indicate that

the introduction of an AFR programme at Kiln 3 at Dudfield plant will not have a

significant impact on air quality.

In order to monitor emissions from Dudfield plant, Holcim South Africa has

installed state-of-the art OPSIS continuous emission measuring equipment that

is linked to the kiln operating system. The equipment currently measures 12

emission streams on a continuous basis, with a further annual measurement of

12 heavy metals and dioxins and furans. Emission levels will be subject to the

prescribed requirements of the Stack Registration Permit issued by CAPCO.

Alarms are in place in order to indicate if any emission approaches its limits, thus

allowing for immediate corrective action to be taken. All emission data captured

by the OPSIS equipment will be available to CAPCO for auditing purposes.

3.2. Impacts Associated with the Transportation of AFR to Dudfield

Plant

Issues surrounding the transportation of AFR to Dudfield plant were identified

through the EIA process, including impacts on traffic volumes and the potential


Executive Summary 31-Aug-04viii

disruption to the daily movement patterns of the local population (particularly

residents in Lichtenburg, the Dudfield village and surrounding farming

communities), as well as safety risks to human health and the environment

associated with accidents and spillage of waste. A long-term scenario of six (6)

additional trucks per day transporting AFR to Dudfield plant is anticipated.

Specialist studies undertaken indicate that this will result in a 1% increase in the

traffic volume on the access routes to Dudfield plant, a very small growth in

traffic which is considered to be insignificant. Therefore, impacts in terms of

traffic growth and disruption to traffic patterns are anticipated to be of low

significance. In order to ensure that this impact is minimised, preferred routes to

haul waste to the Dudfield plant have been recommended. These correspond

with those currently being utilised by traffic travelling to Dudfield plant.

In order to minimise the risk to human health and the environment as a result of

potential accidents and spillage of waste, it is essential that appropriate

management and emergency response procedures be in place for the

transportation of AFR to Dudfield. In the event of an accident, the vehicles are

equipped with spill-control kits and action should be taken as soon as possible in

order to contain spillages while waiting for backup. The transport of waste must

be supported by a HazMat Emergency Response team in order to contain and

clean up any spill, in order to minimise impacts on the environment and

surrounding communities.

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

Period

In order to successfully implement the AFR programme at Dudfield plant's Kiln 3,

the feed is preferably required to be of an appropriate volume to supply a

constant flow over an extended period. This minimises the need to adjust the

kilns operating parameters and thus reduces potential risks to the environment.

This, therefore, implies that smaller volume and irregular waste streams should

either not be accepted at Dudfield, or would need to be pre-processed to achieve

a uniform and constant fuel source at an appropriate volume. This pre-treatment

in not anticipated to be undertaken at Dudfield plant.

For the AFR streams that would be delivered directly to the kiln, an on-site

storage facility would need to be provided to accommodate/store an approximate

2-day reserve capacity. The appropriate management of the storage of waste-

derived alternative fuels will minimise environmental impacts and the potential

for pollution of the soil and groundwater. Without the implementation of

appropriate management measures, this impact is potentially of high significance.

The storage of fuels, storage and handling of AFR must be undertaken in an

appropriate manner, as stipulated in this report, to avoid spillage and leaching

and to limit fugitive emissions, odour and noise to acceptable levels. In addition,


Executive Summary 31-Aug-04ix

the amount of AFR stored on site must be appropriately managed in terms of the

operational requirements of the plant, and should be based on a just-in-time

principle.

Storage areas for all alternative fuels and resources must be constructed

according to national engineering standards and specifications required by the

relevant National and Provincial Government Departments. These should have a

concrete floor, should be properly bunded, and if required for operational

reasons, should be covered by a permanent roof structure. The volume of the

bunded area should at least be such that it can contain a 1:50 year rainfall event

over the surface area of the storage area. The concrete base will minimise, if not

totally exclude, leachate infiltration into the groundwater.

3.4. Impacts on the Social Environment

The Holcim Dudfield Plant is located approximately 18 km west of Lichtenburg,

which is the closest town to the facility. The area surrounding Dudfield plant is

sparsely populated, typical of a rural farming community. The greatest

population density in the immediate area surrounding the plant is Dudfield

Village, where approximately 200 people reside. The village is located

approximately 1 km south-west of the plant. Impacts to or the disturbance of

surrounding communities already exist, and have done so since the initial

construction of the facility more than 50 years ago.

Potential impacts on the social environment associated with the introduction of an

AFR programme at Dudfield plant identified and assessed within this EIA include:

• disruption in daily living and movement,

• impacts on public health and safety,

• impacts on infrastructure and community infrastructure needs,

• local and intrusion impacts

• regional benefits.

As impacts in terms of traffic growth and disruption to traffic patterns are

anticipated to be of low significance, no significant impact on daily living and

movement patterns of the local population is anticipated. Risks to human health

are associated with potential vehicle overloading, accidents and spillage of waste

during transportation of the AFR. With the implementation of appropriate

management and emergency response procedures for the transportation of AFR

to Dudfield, this potential impact is considered to be unlikely to occur and of low

significance.

Specialist studies have indicated that no risk to human health is anticipated with

the introduction of an AFR programme as a result of air emissions. Risk


Executive Summary 31-Aug-04x

assessments undertaken internationally have shown that the use of waste

(hazardous and non-hazardous) as fuel in cement kilns poses no increased risk to

human health and the environment (www.ckrc.org/ncafaq.html).

Potential health and safety risks to employees has been identified as a potentially

significant impact. However, with the provision of appropriate precautionary

measures such as strict acceptance procedures, accurate laboratory testing, data

sheets, training, controls, procedures, health monitoring, facility design and

emergency response planning, the potential impacts on the health and safety of

employees will be managed to acceptable levels. In addition, it is important that

relevant safety information is provided to sub-contractors and visitors to the

premises in order to ensure their safety.

Limestone mining and cement manufacture are two of the major economic

activities currently undertaken in the area, providing employment to members of

the local community. The continued operation of the Dudfield plant in an

environmentally and economically sustainable manner will secure these

employment opportunities in the long-term. This is considered to have a positive

impact of high significance on the region.

3.5. Suitability of Waste as an Alternative Fuel Resource

The selection, acceptance and appropriate management of the waste-derived fuel

are critical to the success of this project and its operations. It is essential that

AFR management be carried out in a manner that does not impact on human

health and well-being and the environment.

The management protocol for the utilisation of waste as a alternative fuel follows

a 'cradle to grave' approach. This means that it is the responsibility of Holcim

South Africa to ensure that the alternative fuels and resources are appropriately

managed, from identification of potential fuels to utilisation of the fuel in the kiln

and the control of any emissions from the kiln.

In order to determine the suitability of using AFR in the kiln it is critical to

identify, understand and manage the factors that could potentially create an

impact on health, safety or the environment. In addition, there can be no

compromise on the quality of the clinker and cement produced. Therefore, the

types and nature of the AFR materials and their respective management

procedures that would be acceptable, as well as the limits on specific elements,

need to be specified and adhered to.

The primary management considerations required to ensure the total 'cradle to

grave' management of AFR include:


Executive Summary 31-Aug-04xi

• AFR identification and acceptance procedures

• Documentation

• Packaging and labelling

• Loading at the generator’s premises

• Transportation

• Acceptance procedures at Dudfield plant

• Offloading

• Handling, storage on-site and feeding into the kiln

• Characteristics of the products and, if produced, any by-products from the kiln

In the identification of appropriate sources of AFR, the waste management

hierarchy needs to be taken into consideration. Simply stated, the recycling or

re-use of a waste stream must take preference over the treatment or disposal of

waste, where practical. This principle seeks to ensure that the most appropriate

management processes are selected to manage waste.

In terms of the Holcim Group AFR Policy (Holcim Ltd, 2004), certain waste types

have been identified as unacceptable for an AFR programme at Dudfield. These

wastes will be refused as potential AFR for the following reasons:

• Health and safety issues (waste streams that represent an unacceptable

hazard from an environmental, occupational health or safety point of view).

• To promote adherence to the waste management hierarchy.

The are a variety of products or wastes that should not be processed or utilised

as AFR in the kilns. These include the following:

• Selected extremely toxic ('high risk') wastes, e.g. waste containing free

asbestos fibres and pure carcinogens, which will pose an unacceptable

occupational health and safety risk.

• Wastes that contain unacceptable levels of selected components that will

impact on the kiln performance, the quality of the clinker and cement and

adversely impact on the emissions from the kiln. These can include waste

with unacceptable levels of some heavy metals, e.g. mercury and lead, high

levels of halogenated hydrocarbons, etc.

• Unsorted domestic wastes (municipal garbage) because of the presence of

small amounts of hazardous materials and various metals, etc.

• Small-volume hazardous wastes from households (fluorescent lamps,

batteries etc.).

• Non-identified or insufficiently characterised wastes.

Bearing the exclusionary criteria from the assessment of waste steams in mind,

the list of wastes that are deemed unacceptable for AFR purposes in terms of the


Executive Summary 31-Aug-04xii

Holcim Group AFR Policy (Holcim Ltd, 2004) is supported. These unacceptable

wastes consist of the following:

• Anatomical hospital wastes (without pre-treatment)

• Asbestos-containing wastes

• Bio-hazardous wastes such as infectious waste, sharps, etc. (without pre-

treatment)

• Electronic scrap

• Whole batteries

• Non-stabilised explosives

• High-concentration cyanide wastes

• Mineral acids

• Radioactive wastes

• Unsorted general/municipal/domestic waste

With the correct management and monitoring procedures in place, the utilisation

of AFR in the manufacture of cement could substitute a portion of the fuel load

requirement for Dudfield Kiln 3 and would not represent a significant risk to

human health and the environment.

Wastes that are acceptable as AFR for use by Kiln 3 as an alternative fuel source

include non-hazardous and hazardous wastes such as, but not limited to scrap

tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and

spent solvents.

3.6. Project Benefits

The utilisation of alternative fuels in the cement industry is in-line with initiatives

of National Government, particularly the National Waste Management Strategy

(NWMS) which focuses on waste prevention and waste minimisation. The

practice of employing alternative fuels in cement plants promotes the materials

recovery and recycling industry, which is in line with the principles of the NWMS.

Where recycling of waste is not possible, landfill or incineration is the most

common disposal practice available for many wastes. The introduction of an AFR

programme would assist in the reduction in the amount of waste required to be

disposed of to landfill or other means, and assist in the reduction of greenhouse

gas emissions. The use of waste-derived fuel as AFR in cement kilns provides a

service to society by dealing safely with wastes that are often difficult to dispose

of in any other way (e.g. scrap tyres; www.ckrc.org/issues/993135035.html).

Of particular concern in South Africa is the disposal of scrap tyres to landfill. The

SATRP (South African Tyre Recycling Project) are investigating alternate solutions

to deal with the scrap tyre problem in South Africa. Government is presently


Executive Summary 31-Aug-04xiii

promulgating legislation to discourage the inappropriate disposal of scrap tyres.

As the number of scrap tyres generated in South Africa is estimated at ~10

million per annum, with only ~ 2 million being used to produce recycled rubber

and recycled products the need for an appropriate disposal method is critical.

The use of scrap tyres as an alternative fuel offers an environmentally acceptable

and cost effective option of managing the excess scrap tyre problem in South

Africa, as the landfilling of scrap tyres is no longer an acceptable practise.

The nature of the cement manufacture process makes waste suitable for the use

as AFR by ensuring full energy recovery from various wastes under appropriate

conditions. Any solid residue from the waste then becomes a raw material for the

process and is incorporated into the final clinker. This, therefore, results in the

conservation of non-renewable natural resources, as well as a reduction in the

environmental impacts associated with mining activities.

Depending on the quantity of the waste-derived fuel available and the energy

content of this fuel, Holcim South Africa will be able to replace between 35 - 50%

of their traditional coal-based fuel with AFR. Including the kiln efficiency

upgrade, a total reduction of between 40 000 and 90 000 tons of coal/annum is

estimated by Holcim for Kiln 3.

3.7. Conclusions

The introduction of the AFR programme at Kiln 3 of the Dudfield plant provides

the opportunity to:

• Recover energy from combustible wastes and inorganic materials.

• Conserve non-renewable resources such as fossil fuels, i.e. coal and oil, and

inorganic materials such as iron ore.

• Reduce the volume potentially polluting materials being disposed by landfill

and reducing overall waste volumes to landfill.

For these benefits to be fully realised, strictly controlled management procedures

are required to be implemented for the entire AFR programme process. These

management procedures should be detailed in an Environmental Management

Plan (EMP) which includes inputs from the EIA and the permitting authorities.

This will ensure that the waste materials are managed from 'cradle to grave' and

all potential adverse impacts are managed to acceptable levels.

As Dudfield plant is an ISO 14001 accredited operation, the EMP would be

required to form part of the independently audited ISO 14001 programme.


Table of Contents 31-Aug-04xiv

TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY i

TABLE OF CONTENTS xiv

LIST OF TABLES xx

LIST OF FIGURES xxiii

LIST OF PHOTOGRAPHS xxiv

ACRONYMS AND ABBREVIATIONS xxv

1. INTRODUCTION 1

1.1. Motivation for the Proposed Project 1

1.2. Overview of the existing Dudfield Plant and the proposed

AFR Programme

2

1.2.1. Overview of Dudfield Plant and Kiln 3 2

1.2.2. Infrastructure requirements for the proposed AFR

programme

3

1.2.3. Waste-derived Materials which can be utilised as

Alternative Fuels

5

1.3. Environmental Study Requirements 6

2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS 7

2.1. Approach to Undertaking the Study 7

2.2. Authority Consultation 7

2.2.1. Consultation with Decision-making Authorities 7

2.2.2. Consultation with Other Relevant Authorities (non-

DEAT)

8

2.3. Application for Authorisation in terms of Section 22 of

the Environment Conservation Act (No 73 of 1989) in

respect of an Activity Identified in terms of Section 21 of

the said Act

8

2.4. Application for Exemption from Undertaking an

Environmental Scoping Study in terms of Section 21 of

the Environment Conservation Act (no 73 of 1989)

8

2.5. Environmental Impact Assessment 9

2.5.1. Specialist Studies 9

2.5.2. Assumptions and Limitations of the Study 10

2.5.3. Overview of the Public Participation Process undertaken

within the EIA Process

10

2.5.4. Review of the Draft Environmental Impact Assessment

Report

14

2.5.5. Final Environmental Impact Assessment Report 14

3. DESCRIPTION OF THE EXISTING DUDFIELD PLANT AND

THE SURROUNDING ENVIRONMENT

15


Table of Contents 31-Aug-04xv

3.1. The Existing Dudfield Plant and Kiln 3 15

3.2. Climate 17

3.2.1. Regional Climate 17

3.2.2. Rainfall 17

3.2.3. Temperature 18

3.2.4. Evaporation 18

3.2.5. Wind Data 18

3.3. Topography 19

3.4. Geology 20

3.5. Soils 20

3.6. Surrounding Land Use and Surface Infrastructure 22

3.7. Flora 22

3.8. Fauna 23

3.9. Surface Water 23

3.10. Geohydrological Conditions 24

3.11. Water Consumption at the Dudfield Plant 25

3.12. Air Quality 27

3.13. Noise 30

3.14. Visual Aspects and Aesthetics 31

3.15. Sites of Archaeological, Cultural or Historical Interest 31

3.16. Regional Socio-economic Structure 31

3.16.1. Population Density 31

3.16.2. Major Economic Activity and Sources of Employment 32

4. DESCRIPTION OF THE CEMENT MANUFACTURING

PROCESS

33

4.1. Cement Manufacturing Process at Dudfield Plant 33

4.1.1. Preparation of Raw Materials 33

4.1.2. Process inside the Kiln 35

4.1.3. After the Kiln 35

4.2. Environmental Aspects of Cement Manufacture 37

4.2.1. Raw Materials 37

4.2.2. Emissions to Air 37

4.2.3. Energy 38

4.2.4. Use of Alternative Fuels in the Cement Manufacture

Process

38

4.2.5. How AFR can be utilised in the Kiln 39

4.2.6. Waste Products utilised as Alternative Fuel Sources 42

5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED

WITH THE INTRODUCTION OF THE ALTERNATIVE FUELS

AND RESOURCES PROJECT AT DUDFIELD PLANT

44

5.1. Potential Impacts on Land Use, Vegetation and Heritage

Sites in the area surrounding the Dudfield plant

44


Table of Contents 31-Aug-04xvi

5.1.1. Conclusions and Recommended Management Options 45

5.2. Potential Impacts Associated with the establishment of a

Fuel Storage Area within the Boundaries of the Dudfield

Plant

45


5.3. Potential Impacts on Water Resources 48

5.3.1. Sources of risk to the groundwater and surface water

environment from the AFR project

48


5.4. Potential Impacts on Air Quality 50

5.4.1. Conclusions 52

5.4.2. Recommendations 53

5.5. Potential Traffic Impacts 54

5.5.1. Condition of Roads outside Lichtenburg 54

5.5.2. Condition of Roads within Lichtenburg 59

5.5.3. Existing Traffic 60

5.5.4. Structural Capacity Analysis 61

5.5.5. Assessment of Potential Impacts 62

5.5.6. Conclusions and Recommendations 63

5.6. Potential Impacts on the Social Environment 63

5.6.1. Methodology 65

5.6.2. Formation of Attitudes and Perceptions 66

5.6.3. Disruption in Daily Living and Movement Patterns 67

5.6.4. Impact on Infrastructure and Community Infrastructure

Needs

68

5.6.5. Health and Safety Impacts 69

5.6.6. Local Impacts and Regional Benefits 70

5.6.7. Intrusion Impacts 70

5.7. Assessment of the Suitability of Waste as an Alternative

Fuel Resource

71

5.7.1. Risks and Significance of Risks 75

5.7.2. Recommendation on the determination of suitable AFR 78

5.7.3. Conclusion 80

6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY 82

6.1. Introduction 82

6.2. Terms of Reference 82

6.3. Methodological Overview 83

6.4. Baseline Study 83

6.4.1. Local Wind Field 83

6.4.2. Impact Assessment at Holcim-Dudfield Under Current

Operating Conditions

85

6.5. Environmental Legislation and Air Quality Guidelines 86


Table of Contents 31-Aug-04xvii

6.5.1. Ambient Air Quality Standards and/or Guidelines for

Criteria Pollutants

86

6.5.2. Effect Screening Levels and Health Risk Criteria of Non-

Criteria Pollutants

88

6.5.3. Dioxins and Furans 89

6.5.4. Cancer Risk Factors 93

6.5.5. Permit Specifications 93

6.5.6. Emission Limits 94

6.6. Process Description and Emissions Inventory 94

6.6.1. Studies on Emissions from Cement Kilns Utilising

Alternative Fuels

95

6.6.2. Limitations of the Given Source Inventory 97

6.6.3. Emission Inventory for Proposed Usage of Alternative

Fuels and Resources at Dudfield Plant

98

6.6.4. Emission Estimation 99

6.6.5. Comparison of Simulated Emissions to Permit

Specifications

100

6.7. Dispersion Simulation Methodology And Data

Requirements

100

6.7.1. Meteorological Requirements 101

6.7.2. Receptor Grid 102

6.7.3. Source Data Requirements 102

6.7.4. Building Downwash Requirements 102

6.8. Atmospheric Dispersion Results and Discussion 102

6.8.1. Results of Criteria Pollutants 102

6.8.2. Results for Non-Criteria Pollutants: Potential for

Environmental and Non-Carcinogenic Health Effects

106

6.8.3. Results for Non-Criteria Pollutants: Potential for

Carcinogenic Effect

106

6.9. Significance Rating 110

6.10. Description of Aspects and Impacts 111

6.11. Conclusion and Recommendations 112

6.11.1. Recommendations 113

6.12. Air Quality Management System 114

6.12.1. Emissions Inventory Development and Maintenance 117

6.12.2. Source Monitoring 117

6.12.3. Ambient Air Quality Monitoring 118

6.12.4. Mitigation Strategy Design, Implementation and

Evaluation

118

6.12.5. Record Keeping and Environmental Reporting 119

6.12.6. Consultation 120


Table of Contents 31-Aug-04xviii

7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN

ALTERNATIVE FUEL RESOURCE

121

7.1. Introduction 121

7.2. AFR Specifications 122

7.2.1. Types of Alternate Fuels and Resources 123

7.2.2. Physical and Chemical Characteristics of AFR 124

7.2.3. Summary of Acceptable Waste in terms of SANS 10228 130

7.2.4. Waste and AFR Standards / Specifications 132

7.2.5. Acceptable Limits for Elements in AFR 133

7.3. Environmental Fate of the Elements 135

7.4. AFR Management Procedures 137

7.5. Risks and Significance of Risks 140

7.6. Recommendation on the determination of suitable AFR 143

7.6.1. Typical Wastes Excluded for use as Alternative Fuels 143

7.6.2. Typical Wastes Accepted for use as Alternative Fuels 144

7.6.3. Loading, supply, storage and management of Alternative

Fuels

145

7.7. Proposed Monitoring, Control and Mitigation Measures 145

7.7.1. Environmental Monitoring Programme 145

7.7.2. Initial Acceptance Procedure Control 146

7.7.3. Transport Procedure Control 147

7.7.4. Final Acceptance Procedure Control 147

7.7.5. Compliance Auditing 147

7.7.6. Development of Site Specific Specifications 148

7.8. Conclusion 149

8. CONCLUSIONS AND RECOMMENDATIONS 150

8.1. Evaluation of the Proposed Project 151

8.1.1. Impacts Associated with Emissions to Air from the Plant 152

8.1.2. Impacts Associated with the Transportation of AFR to

Dudfield Plant

154

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

Limited Period

154

8.1.4. Impacts on the Social Environment 155

8.1.5. Suitability of Waste as an Alternative Fuel Resource 156

8.1.6. Project Benefits 158

8.2. Conclusions 159

8.3. Permit Requirements associated with the Introduction of

an AFR Programme at Dudfield Plant

160

9. REFERENCES 163


Table of Contents 31-Aug-04xix

APPENDICES

Appendix A: Application for Exemption from Undertaking an Environmental

Scoping Study for the Alpha Alternative Fuels and Resources

Project

Appendix B: Advertisements placed in Regional and Local Newspapers

Appendix C: I&AP Database

Appendix D: Briefing Paper

Appendix E: Minutes of Meetings held with I&APs during the EIA Process

Appendix F: Issues Trail

Appendix G: Letter from SAHRA

Appendix H: Air Quality Specialist Report

Appendix I: AFR Management Procedures

Appendix J: Environmental Legislation Relevant to the Proposed Alternative

Fuels and Resources Project, Dudfield

Appendix K: Response from Holcim South Africa Regarding the Use of

Hazardous Waste as a Fuel in Cement Kilns


List of Tables 31-Aug-04xx

LIST OF TABLES

PAGE

Table 2.1: Specialist studies undertaken as part of the EIA process 9

Table 3.1: Annual rainfall recorded at Dudfield for the years 1997 –

2001

16

Table 3.2: Chemical character of dolomite groundwater 25

Table 3.3: Borehole yield distribution: Chuniespoort Group 25

Table 3.4: Chemical analyses of different waters at the Holcim Plant

(12 February 2004, Reference 050204/381)

27

Table 3.5: Stack parameters for the Dudfield plant under current

routine operating conditions

28

Table 3.6: Emission rates for criteria and VOC pollutants from the

stacks at the Dudfield plant under current routine

operating conditions

29

Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3

for routine operating conditions

29

Table 3.8: Comparison of measured PM10, NO2 and SO2 emissions to

permit specifications

30

Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in

different districts (refer SABS Code 0103)

30

Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and

traditional fuels

42

Table 5.1: Summary of potential impacts on land use, vegetation and

heritage sites in the area surrounding the Dudfield plant as

a result of the introduction of the AFR programme

46

Table 5.2: Summary of potential impacts associated with the

establishment of a fuel storage area within the boundaries

of the Dudfield plant

46

Table 5.3: Summary of potential impacts on the water environment

associated with the introduction of the AFR programme

51

Table 5.4: Summary of potential impacts on air quality associated

with Dudfield plant

51

Table 5.5: Existing (2004) 12-hour traffic counts 60

Table 5.6: Assessment of potential traffic impacts associated with the

introduction of AFR at Dudfield plant

64

Table 5.7: Summary of potential impacts on the social environment as

a result of the introduction of an AFR programme at

Dudfield plant

72

Table 5.8: Potential Significance of Risks associated with the use of

AFR posed by Natural Events, Technical Problems and

Human Error

76

Table 6.1: Current DEAT NOx guidelines 87

Table 6.2: Air quality standards for nitrogen dioxide (NO2) 87

Table 6.3: Air quality standards for inhalable particulates (PM10) 87


List of Tables 31-Aug-04xxi

Table 6.4: Air quality standards for lead 88

Table 6.5: Air quality standards for benzene 88

Table 6.6: Effect screening and health risk criteria for various

substances included in the investigation

90

Table 6.7: Toxicity equivalency factors for dioxins and furans 92

Table 6.8: Unit risk factors from the US-EPA Integrated Risk

Information System (IRIS) (as at July 2003) and WHO risk

factors (2000)

93

Table 6.9: Permit specifications for stack PM10 emissions 94

Table 6.10: Comparison of EC emission limit values for emissions from

co-incineration of waste in cement kilns (Directive

2000/76/EC) and DEAT class 1 incinerator

94

Table 6.11: International emissions data for cement production

emissions of dioxins

97

Table 6.12: Stack parameters for the Dudfield Plant for proposed usage

of alternative fuels

98

Table 6.13: Emission rates for criteria pollutants from the stacks at the

Dudfield Plant for proposed usage of alternative fuels

99

Table 6.14: Heavy Metal and Dioxin and Furan Emissions from Kiln 3

for proposed usage of alternative fuels (a)

99

Table 6.15: Halogen Compound Emissions from Kiln 3 for proposed

usage of alternative fuels (a)

99

Table 6.16: Maximum offsite concentrations (measured in µg/m³) at

the Dudfield Plant boundary of criteria pollutants predicted

to occur due to proposed usage of alternative fuels also

given as a ratio of various air quality guidelines and

standards (a)(b)

104

Table 6.17: Maximum offsite concentrations (measured in µg/m³) at

the Dudfield Plant boundary of non-criteria pollutants

predicted to occur due to proposed usage of alternative

fuels also given as a ratio of various effect screening and

health risk criteria (a)(b)

107

Table 6.18: Predicted maximum annual average concentrations of

various carcinogens due to proposed usage of alternative

fuels at the Dudfield Plant and resultant cancer risks

(assuming maximum exposed individuals)

109

Table 6.19: Significance rating from the baseline study (a) (for all

pollutants of concern)

111

Table 6.20: Significance rating from the proposed usage of alternative

fuel (for all pollutants of concern)

111

Table 7.1: Calorific Value of Alternative and Natural Fuels 123

Table 7.2: Categories of waste that can be accepted by Kiln 3 and

restrictions by SANS Class

131


List of Tables 31-Aug-04xxii

Table 7.3: Properties of fuel that can potentially affect product

quality, plant operation, health and safety and

environment

133

Table 7.4: AFR Specifications and range of acceptable limits of

elements (including heavy metals)

134

Table 7.5: Typical Concentrations of Selected Trace Elements in Raw

Materials and Coal (mg/kg)

136

Table 7.6: Potential Significance of Risks associated with the use of

AFR posed by Natural Events, Technical Problems and

Human Error

141

Table 7.7: Minimum Background Monitoring Parameters 146

Table 8.1: Summary of the most relevant permits, licences,

certificates and other authorisations required by Holcim

South Africa for the introduction of an AFR programme at

Dudfield

160


List of Figures 31-Aug-04xxiii

LIST OF FIGURES

PAGE

Figure 1.1: Drawing of the area north of Kiln 3 illustrating the

position of area demarcated for the proposed AFR storage

area

4

Figure 1.2: Photograph of the area north of Kiln 3 illustrating the


area in relation to Kiln 3.

4

Figure 3.1: Location of Holcim South Africa Dudfield plant near

Lichtenburg

15

Figure 3.2: Wind roses for the period January 1996 to August 2001 19

Figure 3.3: Geology around Lichtenburg (extract of 1:250 000

Geological map 2626 West Rand, Geological Survey of

South Africa, 1986)

21

Figure 3.4: Water flow/balance diagram for Dudfield plant for July

2004 (Holcim, 2004)

26

Figure 4.1: Schematic representation of the cement manufacture

process from sourcing the raw materials to delivery of the

final product (Source: Cement Industry Federation, 2002)

34

Figure 4.2: Primary components of Kiln 3 (Holcim, 2004) 36

Figure 4.3: Graphic representation of the three locations where

waste-derived fuels can be introduced to Kiln 3 (Holcim,

2004)

41

Figure 5.1: Photograph of the area north of Kiln 3 illustrating the


area in relation to Kiln 3

47

Figure 5.2: Routes currently utilised to access Dudfield plant 56

Figure 5.3: Recommended routes for the transportation of AFR to

Dudfield plant

57

Figure 6.1: Wind roses for the period January 1996 to August 2001 84

Figure 6.2: Schematic diagram illustrating air quality management

plan development, implementation and review by

industrial and mining operations

116


List of Photographs 31-Aug-04xxiv

LIST OF PHOTOGRAPHS

PAGE

Photograph 3.1: Kiln 2 and 3 at the Holcim South Africa Dudfield plant 16

Photograph 3.2: Opsis® Emission and Durag particulate measuring unit

installed at Dudfiled in 2002

28

Photograph 4.1: Multi-channel burner, illustrating the multiple channels

where various fuel lines can be coupled for feeding

alternative fuels into the kiln

40

Photograph 4.2: Burner head illustrating the concentric tubes through

which fuel and air is fed into the kiln

40

Photograph 5.1: Pavement damage at the intersection of Road 52 and

D933

55

Photograph 5.2: Pothole in a section of Kapsteel Road (D933) 55

Photograph 5.3: Pumping in a section of Road D2095 58

Photograph 5.4: Pavement defects at intersection of Road D2095 and

D933

58

Photograph 5.5: Structure Failure on Road P183/1 59


Acronyms and Abbreviations 31-Aug-04xxv

ACRONYMS AND ABBREVIATIONS

AFR Alternative Fuels and Resources

APPA Atmospheric Pollution Prevention Act (No 45 of 1965)

amsl Above mean sea level

ATSDR Agency for Toxic Substances and Disease Registry

CAPCO Chief Air Pollution Control Officer

CFCs Chlorofluorocarbons

CKD Cement kiln dust

CO Carbon monoxide

DEAT Department of Environmental Affairs and Tourism

DME Department of Minerals and Energy

DWAF Department of Water Affairs and Forestry

E80s Equivalent 80 kN single-axle loads

EC European Community

EIA Environmental Impact Assessment

EU European Union

Ha Hectare

hPa Hecto pascalI&APs Interested and affected parties

IBCs Intermediate Bulk Containers

ISCST3 Industrial Source Complex Short Term model (Version 3)

kPa Kilo pascal

LD50 Lethal dose of a chemical required to kill 50% of a population of

experimental mammals and fish

LPG Liquefied petroleum gas

MAP Mean annual precipitation

MJ/kg Mega Joules per kilogram

MRLs Minimal Risk Levels

MSD Mass selective detector

MSDS Material Safety Data Sheet

NEMA National Environmental Management Act (No 107 of 1998)

ng Nanograms

NO2 Nitrogen dioxide

NOx Oxides of nitrogen

NW DACE North West Department of Agriculture, Conservation and

Environment

NWMS National Waste Management Strategy

OEHHA Office of Environmental Health Hazard Assessment

PCCDs Polychlorinated dibenzodioxinsPCDFs Polychlorinated dibenzofuranspH AcidityPPE Personal Protective Equipment


Acronyms and Abbreviations 31-Aug-04xxvi

PM10 Particulate Matter with an aerodynamic diameter of less than10 µm

PM2.5 Particulate Matter with an aerodynamic diameter of less than2.5 µm

ppm Parts per millionRDF Refuse derived fuel

SA South Africa

SABS South African Bureau of Standards

SAHRA South African Heritage Resources Agency

SANS South African National Standard

SO2 Sulphur dioxide

TIS Traffic Impact StudyTOC Total Organic CarbonTremcard Transport Emergency CardTSP Total Suspended Particulatesµg/m³ Micrograms per cubic meterUS-EPA United States Environmental Protection Agency

VOCs Volatile Organic Compounds

WB World Bank

WHO World Health Organisation

WMD Waste Manifest Document


Introduction 31-Aug-041

1. INTRODUCTION

Holcim (South Africa) (Pty) Ltd, formerly known as Alpha (Pty) Ltd, is one of

South Africa’s key producers of cement, stone and ready mixed concrete for the

construction industry. Holcim South Africa currently operate three cement plants

in South Africa, one of which is the Dudfield plant, located approximately 20 km

west of Lichtenburg in the North West Province. At Dudfield plant, limestone

(source material) and coal (fuel) are currently the primary raw materials utilised

in the manufacture cement.

The Dudfield plant is situated on a limestone deposit that is mined and milled as

feedstock to the plant. The coal that is utilised in its kilns as the main energy

source for converting the limestone raw meal to manufacture clinker (the base

feedstock for cement), is transported to the plant by rail.

Holcim South Africa are considering implementing the global trend of replacing a

portion of the fossil fuel (coal) used as the energy source with alternative, waste-

derived fuels. That is, the introduction of an Alternative Fuels and Resources

(AFR) programme is proposed for the Dudfield Plant.

The AFR project proposes the replacement of traditional, non-renewable, fossil-

based fuel (coal) with alternative waste-derived fuels and raw materials within

the existing Dudfield Kiln 3 at the existing Dudfield plant. This programme aims

to reduce traditional fossil fuel usage by up to 35% or more.

1.1. Motivation for the Proposed Project

The process of cement manufacture is energy intensive. The average energy

required to produce 1 000 tons of cement clinker is approximately 130 tons of

coal. As a result, Holcim South Africa currently requires approximately

350 000 tons of coal per annum to operate their kilns across the country.

The Holcim commitment to promoting development that is sustainable and at the

least cost to future generations has resulted in a drive to substitute a portion of

the traditional non-renewable fossil fuels (that is, coal) used in the production of

cement with suitable alternative waste-derived materials/fuels. This has resulted

in the need to identify alternative renewable fuel sources which would provide

similar energy (i.e. calorific value) when burnt to that provided by coal, would not

be detrimental to the process in the kiln or the product produced, and would be

less costly than coal in the long-term.

The use of alternative fuels and raw materials that are based on selected waste

products and by-products generated from industrial and domestic sources

addresses this need, as much of this waste is chemically similar to coal. The use

of this waste as a fuel presents the opportunity to reduce the environmental



impacts of using a non-renewable resource (coal) in the cement manufacturing

process, as well as to reduce the amount of waste material that would

traditionally be disposed of to landfill or incinerated. The utilisation of AFR in the

cement industry is in-line with initiatives of National Government, particularly the

National Waste Management Strategy (NWMS) which focuses on waste

prevention, waste minimisation and the re-use of waste materials. The practice

of employing alternative fuels in cement plants promotes materials recovery and

recycling by the recovery of energy as well as the mineral components from

waste. The use of waste-derived fuels in a cement kiln therefore, reduces fossil

fuel use, and maximises the recovery of energy, without any significant change in

emission levels.

The use of alternative fuels is a well-proven and well-established technology in

the European, American (both North and South) and Asian-Pacific cement

industries. Experience at international plants has shown that alternative fuels can

successfully replace traditional fossil fuels with no adverse impact on the

environment, safety or health of employees and communities, or on the quality of

the final cement product.

1.2. Overview of the existing Dudfield Plant and the proposed AFR

Programme

1.2.1 Overview of Dudfield Plant and Kiln 3

The Dudfield plant is situated on a limestone deposit (the primary raw material

used in the manufacture of cement) that is mined and milled as feedstock to the

plant. Coal is currently utilised for energy generation, and is transported to the

plant by rail. Cement is produced by the calcination of limestone using coal as

the main energy source for converting the limestone raw meal to form cement

clinker (i.e. the base feedstock for cement). This clinker burning takes place at a

material temperature of 1 450°C within a rotary kiln (an inclined rotating steel

cylinder lined with heat resistant bricks). Dudfield plant currently has three kilns.

Kiln 1 has been decommissioned and is no longer operational. Kiln 2 and the

recently upgraded Kiln 3 are still operational.

The recent upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class

production facility (with a production rate of 3 500 tons per day) included the

installation of a ‘low NOx’-multichannel primary burner (allowing multiple energy

sources to be introduced into the kiln), a pre-calciner, and a bag filter with a

design particulate emission limit of 30mg/Nm3. This upgrade has also resulted in

this plant being in a position to receive and utilise alternative fuels as an energy

source, together with coal.



1.2.2. Infrastructure requirements for the proposed AFR programme

The 2003 upgrade to Kiln 3 has satisfied all the requirements of the kiln to

receive and utilise variable fuel sources, that is enable the successful introduction

of alternative waste-derived fuels as an energy source, together with coal.

Kiln 3 will never completely move away from utilising coal as an energy source.

Coal is a constant fuel with a known calorific value, and the AFR programme is

aimed at substituting a portion of the total coal requirement. In order to

successfully operate a facility on an on-going basis, the source of fuel is required

to be stockpiled or stored on site. With the proposed introduction of the AFR

programme, Dudfield plant would be required to store both coal and AFR on site.

Dudfield plant has an existing stockpile site for coal. A second designated area

would be required for the storage of AFR on the site. AFR streams are proposed

to be delivered directly to the kiln, and an on-site storage facility would be

required to accommodate/store an approximate 2-day reserve capacity to ensure

that sufficient volume of AFR is available as feedstock for an extended period. In

order to store sufficient capacity to replace approximately 35% of the fuel

currently used at Kiln 3, suitable tanks, silos and bunded/walled areas would be

required to store the waste-derived fuels. An AFR fuel storage area of

approximately 1 600 m2 is proposed to be established within the boundaries of

the existing Dudfield plant.

The proposed AFR storage area is a currently vacant area approximately 20 m to

the north of Kiln 3 (refer to Figure 1.1 and Figure 1.2) to allow for safe and

secure feeding of the AFR material from the storage area to Kiln 3. The

demarcated area has been extensively disturbed by activities associated with the

cement manufacture process at the plant, including the construction activities

associated with the recent upgrade of Kiln 3. The area is devoid of vegetation,

and is on level terrain.

The storage facility would be required to be designed according to national

construction, and fuel handling and storage requirements. The area would be

required to have a concrete floor, be bunded to contain any water accumulating

within the storage area, and have a roof to exclude rainwater from entering and

accumulating within the storage facility. Appropriate drainage facilities would be

required to be in place that would facilitate the separation of stormwater and

runoff from the area.



Figure 1.1 Drawing of the area north of Kiln 3 illustrating the position of area

demarcated for the proposed AFR storage area.

Figure 1.2 Photograph of the area north of Kiln 3 illustrating the position of

area demarcated for the proposed AFR storage area in relation to

Kiln 3.



The storage area would be accessed by a levelled and sealed access road, and

would include sufficient area for vehicles to off-load, and manoeuvre, if required.

It is proposed that initially the kiln would be in a position to utilise approximately

70 tons of AFR a day, which represents between 2 and 3 vehicle loads of AFR per

day arriving at the site. It is proposed that in the long-term the volume of AFR

utilise per day could increase to approximately 240 tons per day, which amounts

to 6 – 8 vehicles per day, and the access road and storage area would be

required to support this.

Appropriate fire fighting systems and monitoring equipment would be required to

be installed to service the AFR storage area.

An AFR on-site laboratory would be required at Dudfield plant for control

tests/analyses to be conducted to verify the content of the AFR arriving at the

plant with the 'fingerprint' analyses that were completed at initial acceptance of

the waste (by an external (off-site) accredited laboratory). The Dudfield plant

AFR laboratory would, therefore, have limited capabilities, and will only verify that

the fingerprint matches the waste delivered.

1.2.3 Waste-derived Materials which can be utilised as Alternative

Fuels

Waste materials that the global cement industry has utilised as alternative fuels

include scrap tyres, rubber, paper waste, waste oils, waste wood, paper sludge,

sewage sludge, plastics and spent solvents, amongst others. Similar waste

materials are proposed to be used as fuel in South Africa, together with other

selected wastes that are considered suitable and desirable (including industrial

hydrocarbon tars and sludges). These wastes could potentially be sourced from a

variety of sources from a variety of geographic locations. Only those waste-

derived fuels that meet the stringent standards set by Holcim will, however, be

considered and accepted for use in the kiln.

The use of alternative fuels is technically sound as the organic component is

destroyed and the inorganic component is trapped and combined in the cement

clinker forming part of the final product. Cement kilns have a number of

characteristics that make them ideal installations in which alternative fuels can be

valorised and burnt safely, such as:

• High temperatures – exceeding 1 400°C

• Long residence time – in excess of 4 seconds




• Ash retention in clinker – fuel ashes are incorporated in the cement clinker,

and there is no solid waste by-product




materials, there are others that would not be considered for public health and

safety reasons. No materials that could compromise the environment, the health

and safety of employees or surrounding communities, or the performance of the

cement would be considered for use as a fuel. Strict sampling and testing

procedures would be required to be put in place at the Dudfield plant to ensure

that undesirable fuels and raw materials (such as anatomical hospital wastes,

asbestos-containing wastes, bio-hazardous wastes, electronic scrap, explosives,

radioactive wastes, and unsorted municipal garbage) are excluded from the AFR

programme.

1.3. Environmental Study Requirements

As the introduction of AFR at Dudfield will result in a change to a scheduled

process, as defined in the Air Pollution Prevention Act (No 45 of 1965), Holcim

South Africa requires authorisation from the North West Department of

Agriculture, Conservation and Environment (NW DACE) for the undertaking of the

proposed project. In order to obtain this authorisation, Holcim South Africa

acknowledge the need for comprehensive, independent environmental

assessment studies to be undertaken in accordance with the Environmental

Impact Assessment (EIA) Regulations.

Holcim South Africa have appointed Bohlweki Environmental, as independent

consultants, to undertake environmental studies to identify and assess all

potential environmental impacts associated with the proposed project. In order

to achieve this, an Environmental Impact Assessment (EIA) process has been

undertaken. As part of this study, existing information, a site inspection,

specialist studies and the inputs of interested and affected parties (I&APs) have

been used to identify and assess potential environmental impacts (both social and

biophysical) associated with the proposed project. Mitigation and management

measures have been proposed, where required. Chapter 2 provides a full

description of the scope of the environmental investigations.


Scope of Environmental Investigations 31-Aug-047

2. SCOPE OF ENVIRONMENTAL INVESTIGATIONS

2.1. Approach to Undertaking the Study

An Environmental Impact Assessment (EIA) for the proposed AFR project at

Dudfield Plant has been undertaken in accordance with the EIA Regulations

published in Government Notice R1182 to R1184 of 5 September 1997, in terms

of Section 21 of the Environment Conservation Act (No 73 of 1989), as well as

the National Environmental Management Act (NEMA; No 107 of 1998).

In terms of Government Notice R1182 (Schedule 1), the following listed activity

which may have an impact on the environment is applicable:

• Scheduled processes listed in the Second Schedule to the Atmospheric

Pollution Prevention Act, 1965 (Act No 45 of 1965)

The environmental process undertaken for this proposed project is described

below.

2.2. Authority Consultation

2.2.1. Consultation with Decision-making Authorities

Consultation with the National Department of Environmental Affairs and Tourism

(DEAT) and the North West Province Department of Conservation, Agriculture and

Environment (NW DACE) was undertaken prior to the submission of the

application for authorisation for the proposed project. The primary aim of this

pre-application consultation was to determine specific authority requirements

regarding the proposed project, and to agree on the Way Forward for the

environmental studies. The pre-application consultation also confirmed that

NW DACE would act as the lead authority for this proposed project.

The relevant decision-making authorities have been consulted throughout the EIA

process. Authority consultation included the following activities:

• Submission of an application for authorisation in terms of Section 22 of the

Environment Conservation Act (No 73 of 1989).

• Submission of an application for exemption from undertaking a Scoping

Study for the proposed project.

• Undertaking of a site inspection with NW DACE.

• Submission of a Plan of Study to undertake the EIA.

• Consultation with authorities regarding project specifics, and receipt of

Authority approval of the Plan of Study for EIA.



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

Consultation with non-DEAT authorities was undertaken, including:

• North West Department of Water Affairs and Forestry (DWAF)

• North West Department of Health

• North West Department of Transport

• North West Department of Education

• North West Department of Economic Development and Tourism

• South African Heritage Resources Agency (North West Province)

• North West Provincial Government CAPCO

• Ditsobotla Municipality – Lichtenburg

• Itsoseng Council

A Focus Group Meeting was held with provincial authorities in Lichtenburg on

24 March 2004 to actively engage these authorities and provide background

information to the proposed project. This provided a forum for the departments

to formally provide input into the EIA process.

2.3. Application for Authorisation in terms of Section 22 of the

Environment Conservation Act (No 73 of 1989) in respect of an

Activity Identified in terms of Section 21 of the said Act

Application for authorisation was lodged with NW DACE on 8 September 2003.

This application included information regarding the proponent, as well as the

proposed project and was submitted together with a declaration of independence

from the environmental consultants.

2.4. Application for Exemption from Undertaking an Environmental

Scoping Study in terms of Section 21 of the Environment

Conservation Act (No 73 of 1989)

The proposed project involves the implementation of a known and internationally

understood technology within an existing cement plant. This cement plant has

recently been upgraded and is able to successfully implement this technology.

Therefore, no feasible alternatives exist for this proposed project (i.e. alternative

ways in which the same result could be achieved).

This known activity is proposed by Holcim South Africa to be undertaken at their

existing facility at Dudfield, and therefore potential impacts are anticipated to be

of low significance. Therefore, it was agreed with the relevant environmental

authorities that a formal application for exemption be lodged for the undertaking

of the Scoping Phase for this project (in terms of Section 28A of the Environment

Conservation Act, No 73 of 1989), such that only the EIA Phase was required to



be undertaken. This application for exemption, as well as NW DACE’s approval of

this exemption application is included within Appendix A.

2.5. Environmental Impact Assessment

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

• to provide an overall assessment of the social and biophysical environments

affected by the proposed project;

• to assess the proposed project in terms of environmental criteria;

• to identify potential environmental benefits of the project;

• to identify and recommend appropriate mitigation measures for potentially

significant environmental impacts; and

• to undertake a fully inclusive public participation process to ensure that I&AP

issues and concerns are recorded.

2.5.1. Specialist Studies

In undertaking the EIA, Bohlweki Environmental were assisted by a number of

specialists in order to comprehensively assess the significance of potential

positive and negative environmental impacts (social and biophysical) associated

with the project, and to propose appropriate mitigation measures, where

required. These specialist studies are outlined in Table 2.1 below.

Table 2.1: Specialist studies undertaken as part of the EIA process

Company Field of Study

Airshed Planning Professionals Air quality assessment

Environmental & Chemical Consultants Assessment of the suitability of waste as analternative fuel resource, and impactspertaining to AFR management, storage,transportation etc.

CSIR Environmentek Assessment of surface- and groundwaterimpacts

Sustainable Law Solutions Legal review

In order to assess the significance of the identified impacts, the following

characteristics of each potential impact were identified:

• the nature, which shall include a description of what causes the effect, what

will be affected and how it will be affected;

• the extent, wherein it will be indicated whether the impact will be local

(limited to the immediate area or site of development) or regional;

• the duration, wherein it will be indicated whether the lifetime of the impact

will be of a short duration (0–5 years), medium-term (5–15 years), long term

(> 15 years) or permanent;



• the probability, which shall describe the likelihood of the impact actually

occurring, indicated as improbable (low likelihood), probable (distinct

possibility), highly probable (most likely), or definite (impact will occur

regardless of any preventative measures);

• the severity/beneficial scale: indicating whether the impact will be very

severe/beneficial (a permanent change which cannot be mitigated/permanent

and significant benefit, with no real alternative to achieving this benefit),

severe/beneficial (long-term impact that could be mitigated/long-term benefit),

moderately severe/beneficial (medium- to long-term impact that could be

mitigated/ medium- to long-term benefit), slight or have no effect.

• the significance, which shall be determined through a synthesis of the

characteristics described above and can be assessed as low, medium or high;

and

• the status, which will be described as either positive, negative or neutral.

The suitability and feasibility of all proposed mitigation measures are included in

the assessment of significant impacts. This was achieved through the comparison

of the significance of the impact before and after the proposed mitigation

measure is implemented.

2.5.2. Assumptions and Limitations of the Study

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

• Assumptions:

∗ All information provided by Holcim South Africa and I&APs to the

Environmental Team was correct and valid at the time it was provided.

∗ It is not always possible to involve all interested and affected parties

individually. Every effort has, however, been made to involve as many

broad base representatives of the stakeholders in the area. An

assumption has, therefore, been made that those representatives with

whom there has been consultation, are acting on behalf of the parties

which they represent.

• Limitations:

∗ The report is prepared within the project-specific nature of the

investigations, and consequently the environmental team did not

evaluate any strategic alternatives to the AFR project.

2.5.3. Overview of the Public Participation Process undertaken within

the EIA Process

The primary aims of the public participation process included:



• Meaningful and timeous participation of interested and affected parties

(I&APs).

• Identification of issues and concerns of key stakeholders and I&APs with

regards to the proposed development, i.e. focus on important issues.

• Promotion of transparency and an understanding of the proposed project and

its potential environmental (social and biophysical) impacts.

• Accountability for information used for decision-making.

• Provision of a structure for liaison and communication with I&APs.

• Assistance in identifying potential environmental (social and biophysical)

impacts associated with the proposed development.

• Due consideration of alternatives.

• Inclusivity (the needs, interests and values of I&APs must be considered in

the decision-making process).

• Focus on issues relevant to the project, and considered important by I&APs.

• Provision of responses to I&AP queries.

• Encouragement of co-regulation, shared responsibility and a sense of

ownership.

• Advertising:

In terms of the EIA Regulations, the commencement of the EIA process for

the project was advertised within regional and local newspapers in the

predominant languages of the area (refer to Appendix B). These

advertisements were placed in the Noordwester (English and Afrikaans) and

the Beeld (Afrikaans). The primary aim of these advertisements was to

ensure that the widest group of I&APs possible were informed of the project.

Other advertisements placed during the course of the project advertised the

dates of public meetings and the availability of reports for public review.

• Identification of and Consultation with Key Stakeholders:

The first step in the public participation process entailed the identification of

key I&APs for the proposed project, including:

∗ Central and provincial government;

∗ Local authorities;

∗ Affected and neighbouring landowners; and

∗ Environmental NGOs

Identification of I&APs was undertaken through existing contacts and

databases, responses to newspaper advertisements, networking and a

proactive process to identify key I&APs within the study area.

All I&AP information (including contact details), together with dates and

details of consultations and a record of all issues raised were recorded within



a comprehensive database of I&APs. This database was updated on an on-

going basis throughout the project process (refer to Appendix C).

Consultations were held with individuals, businesses, institutions and

organisations, including the following:

* Department Environmental Affairs and Tourism - National

* Department of Water Affairs and Forestry – North West

* Department Environmental Affairs and Tourism – North West

* Department of Transport – North West

* Department of Health – North West

* Department of Education – North West

* Department of Economic Development and Tourism – North West

* North West Provincial Government (CAPCO)

* Ditsobotla Municipality – Lichtenburg

* Itsoseng Council

* Workers from the Holcim Dudfield Plant

* North West Business Forum

* Agri North West

* North West Forum

* Local Farmers from the surrounding area

* Important Non Governmental Organisations (NGO’s)

* Community Groups and local businesses

* Mine workers union

* Dudfield Township and,

* Other parties interested in the proposed project including those from a

business point of view.

• Briefing Paper:

A briefing paper for the project was compiled (refer to Appendix D). The aim

of this document was to provide a brief outline of the proposed project,

provide preliminary details regarding the EIA, and explain how I&APs could

become involved in the project. The briefing paper was distributed to all

identified stakeholders together with a registration/comment sheet inviting

I&APs to submit details of any issues and concerns. Completed comments

forms submitted to the consultants are included within Appendix E.

• Consultation and Public Involvement:

Through consultations, issues for inclusion within the EIA were identified and

confirmed. One-on-one consultation, focus group meetings, interest group

meetings and public meetings with I&APs were undertaken in order to

identify key issues, needs and priorities for input into the proposed project.

Minutes of meetings held with stakeholders and I&APs were prepared and

forwarded to the attendees for verification of their issues. Copies of the



minutes compiled for formal public involvement meetings held during the

process are included within Appendix E.

• Public Meeting and Key Stakeholder Workshop:

A public meeting and key stakeholder workshop were held early in the public

participation process (12 and 13 February 2004 respectively) in order to

inform I&APs and stakeholders of the proposed project. The primary aims of

these meetings were to:

∗ provide I&APs and stakeholders with information regarding the proposed

AFR project;

∗ provide I&APs and stakeholders with information regarding the EIA

process;

∗ provide an opportunity for I&APs and stakeholders to seek clarity on the

project;

∗ record issues and concerns raised; and

∗ provide a forum for interaction with the project team.

In accordance with the requirements of the EIA Regulations, these meetings

were advertised 10 days prior to the event within the Noordwester and The

Star newspapers in the predominant languages of the area (refer to Appendix

B). Registered I&APs and stakeholders were invited to attend the planned

public meeting by letter (refer to Appendix B). Copies of the minutes

compiled are included within Appendix E.

• Stakeholder Focus Group Meetings:

Stakeholder focus group meetings were held with key stakeholder groupings

such as the relevant authorities, landowners and agricultural unions. The

purpose of these meetings was to allow key stakeholders with specific issues

to air their views and to facilitate the interaction of the key stakeholder and

Holcim. The meetings allowed for smaller groups of I&APs and/or

representatives of larger interest groups or organisations to play an active

role in the process and provided an opportunity for consultation with these

parties

• Interest Group Meeting:

The need for an Air Quality and Emissions interest group meeting was

identified. This provided a forum for focussed discussions to be held

regarding air quality and emissions associated with the introduction of the

AFR programme by Holcim South Africa at Dudfield plant. In addition, the

meeting allowed for the transfer of relevant and specific technical

information, and aimed to provide clarity on issues of concern ahead of the

release of the draft EIA Report. Key stakeholders were invited to attend this



meeting by letter (refer to Appendix B). Copies of the minutes compiled are

included within Appendix E.

• Social Issues Trail:

All issues, comments and concerns raised during the public participation

process of the EIA process were compiled into a Social Issues Trail (refer to

Appendix F). These issues formed the basis of the Social Impact Assessment

(SIA).

2.5.4. Review of the Draft Environmental Impact Assessment Report

The draft EIA report has been made available for public review and comment at

the following public locations:

• Holcim South Africa Dudfield Plant

• Ditsobotla Public Library, Lichtenburg

• Itsoseng Public Library

• NWK Limited, Lichtenburg

• Offices of Bohlweki Environmental, Midrand

• www.bohlweki.co.za

A 30-day period will be allowed for this review process. The availability of this

draft report was advertised in the Noordwester, The Star and Die Beeld in the

predominant languages of the area. I&APs registered on the project database

were notified of the availability of this report by letter (refer to Appendix B).

2.5.5. Final Environmental Impact Assessment Report

The final stage of the EIA process will entail the consideration and inclusion of all

relevant comments received from the public on the draft EIA Report within a final

EIA report. This final document will be submitted to NW DACE for Authority

review and authorisation.


Description of the existing Dudfield 31-Aug-04Plant and the Surrounding Environment

15

3. DESCRIPTION OF THE EXISTING DUDFIELD PLANT AND THE

SURROUNDING ENVIRONMENT

The Holcim South Africa Dudfield plant is located on the remaining extent of the

farm Dudfield 57 IP, approximately 416 ha in extent. Dudfield plant is located

approximately 1 km north east of the Dudfield township, 18 km west of

Lichtenburg, 18 km south west of Itsoseng and 64 km south east of Mafikeng in

the North West Province (refer to Figure 3.1). The plant lies approximately

230 km west of Johannesburg by road, and is accessible via the national road

network.

Figure 3.1: Location of Holcim South Africa Dudfield plant near Lichtenburg

3.1. The Existing Dudfield Plant and Kiln 3

The Dudfield plant is one of the primary cement manufacturing operations of

Holcim South Africa. This plant is situated on a limestone deposit that is mined

and milled as feedstock to the plant. The limestone is mined from shallow open

pits, and crushed on-site. The planned life of mine for current mining activities is

estimated at 50 years.

Production at the Dudfield plant began in the early 1950s. Kiln 1 at the plant was

commissioned in 1966 and due to high operating costs, has now been

decommissioned. Kiln 2 (Photograph 3.1) was commissioned in 1972. Kiln 2 will

continue to operate should the market so require, and plans to upgrade this kiln

are currently being considered for the future.



16

Dudfield Kiln 3 (Photograph 3.1) was commissioned in 1977 at an original design

capacity of 2 000 tons per day. Through the implementation of various

improvement initiatives to the plant, this capacity was increased to 2 300 tons

per day, and more recently to a continuous clinker production rate of 3 500 tons

per day. Details of the cement manufacturing process are provided in Chapter 4.

Photograph 3.1: Kiln 2 and 3 at the Holcim South Africa Dudfield plant

Dudfield Kiln 3 currently comprises a vertical raw mill, a four stage preheater and

pre-calciner, a rotary kiln 80 m in length (inclined rotating steel cylinder lined

with heat resistant bricks), grate cooler, and a firing system. Kiln emissions are

controlled by a bag filter with a design particulate emission limit of 30mg/Nm3.

The 2003 upgrade of Dudfield’s Kiln 3 to a state-of-the-art, world-class

production facility included the following changes to the kiln:

• Upgrade of the kiln filter from an electrostatic precipitator to a bag filter with

a design particulate emission limit of 30 mg/Nm3.

• Upgrade of the kiln burner through the installation of a ‘low NOx’-multichannel

primary burner (allowing multiple energy sources to be introduced into the

kiln which allows for fuel versatility).

• Addition of a pre-calciner, which is located at the bottom of the preheater

tower and acts as an auxiliary firing system which increases the raw materials

temperature further prior to introduction into the kiln.

• Installation of a grate cooler in order to improve heat recovery and re-use.



17

The upgrade of the kiln infrastructure and technology has resulted in Kiln 3 being

in a position to receive and utilise alternative fuels as an energy source, together

with coal.

In addition to the kiln infrastructure at Dudfield plant, additional infrastructure on

the property for the operation of the plant includes mills (for raw material and

coal), silos, clinker cooler, packing plant, control room, laboratory, workshops and

ancillary structures linking and serving these structures.

3.2. Climate

3.2.1. Regional Climate

The climatic conditions in the region are temperate, and typical of those of the

Highveld. The area falls within the summer rainfall region that is characterised by

thunderstorms. Clear skies, low relative humidity and low wind velocities are

characteristic of the Highveld winter when anticyclone circulation is dominant.

3.2.2. Rainfall

Rainfall occurs predominantly in the summer months, typically from November to

April (Midgley, 1994a). Annual rainfall recorded at the weather station in

Lichtenburg averages approximately 600 mm. The wettest month of the year in

the Lichtenburg area is February, with an average monthly total rainfall of

103 mm. The driest month of the year in the Lichtenburg area is July, with an

average monthly total rainfall of 1 mm (Weather Bureau, 2004).

Rainfall at Dudfield plant follows the trends of the general area. The monthly

rainfall recorded at the Dudfield site for the years 1997 – 2001 is provided in

Table 3.1 overleaf.

The barometric pressure at Dudfield is approximately 855 mbar and the area is

characterised by a mean relative humidity of 40%.

Table 3.1: Annual rainfall recorded at Dudfield for the years 1997 – 2001

(mm)

Month 1997 1998 1999 2000 2001 Ave

January 94,0 141,0 0 157,0 38,5 86,1

February 37,0 92,0 40,5 198,0 210,0 115,5

March 158,0 86,0 48,0 50,5 39,0 76,3

April 59,0 0 16,0 30,0 160,0 53

May 144,5 0 39,0 64,0 42,0 57,9

June 0 0 0 4,0 0 0,8

July 0 0 0 6,0 0 1,2



18

Month 1997 1998 1999 2000 2001 Ave

August 0 0 0 0 51,0 10,2

September 49,5 15,5 0 9,0 35,0 21,8

October 64,0 87,5 60,5 69,0 99,0 76

November 23,0 67,5 16,5 138,0 95,5 68,1

December 90,0 107,0 183,0 94,5 115,0 117,9

Total 719,0 596,5 403,5 820 885 684,8

3.2.3. Temperature

Mean annual air temperatures range from 12,8°C in June to 24,1°C in January in

the Lichtenburg area. Average daily maxima range from 18,7°C to 29,1°C, and

average daily minima range from –1,2°C to 15,5°C (Weather Bureau, 2004). At

Dudfield, summer maximum temperatures of 37oC can be experienced, with this

maximum being exceeded on occasion. Temperatures of -3oC and occasionally

lower can be experienced at Dudfield in the winter months.

3.2.4. Evaporation

No annual evaporation figures at Lichtenburg or the Dudfield Plant are available,

but records of mean annual S-pan evaporation measurements within a radius of

approximately 100 km of the town vary between approximately 1 700 mm and

2 000 mm per annum, while the mean annual runoff is between 5 mm and

10 mm (Midgley, 1994a; Midgley, 1994b).

3.2.5. Wind Data

Prevailing winds are generally north-easterly. This is evident in the wind rose for

the area (Figure 3.2). The average wind speed monitored at the Lichtenburg

weather station is approximately 0,3 m/s. At Dudfield plant, the wind varies from

mild gusts to turbulent conditions, especially preceding and during summer

thunderstorms.



19

Figure 3.2: Wind roses for the period January 1996 to August 2001

3.3. Topography

Dudfield plant is situated in an area of little relief. The region is generally flat

with a slight gradient sloping towards the south-west. The Dudfield plant is

located at approximately 1 450 m above mean sea level (amsl). The local

topography has been significantly altered by mining activities within the Dudfield

limestone mine which is located adjacent to the plant.



20

3.4. Geology

The most recent regional geological mapping of the area around Lichtenburg and

the Dudfield Plant is captured on the 1:250 000 scale geological maps 2624

Vryburg and 2626 West Rand (refer to Figure 3.3).

Dudfield plant is situated on surficial calcrete deposits with a thickness of up to

20 m in places. These calcrete deposits are mined for the production of cement.

Calcrete is formed by the precipitation of calcium carbonate from groundwater in

soil during long dry spells in semi-arid climates. The calcrete deposits are

underlain by the chert-poor dolomite of the Oaktree Formation of the

Chuniespoort Group. Further to the north, the Oaktree Formation is in turn

overlain by the chert-rich Monte Christo formation. The dolomite formations are

subdivided by diabase dykes trending ENE-WSW and N-S and result in the

compartmentilisation of the dolomites. These compartments have a controlling

influence on the groundwater conditions in the area. The Dudfield plant is located

to the west of the Elizabeth II N-S dyke which forms the western boundary of the

Lichtenburg compartment. The E-W trending Lichtenburg dyke traverses across

the farm Dudfield. The northern portion of the farm is underlain by dolomite from

the Oaktree Formation, while the southern portion is underlain by quartzite of the

Black Reef formation. The general dip of the rocks is towards the north.

Extensive outcrops of the Dwyka formation are present to the south and east of

Lichtenburg. Based on geological borehole descriptions, Taylor (1983) reported

thicknesses of up to 30 m of Dwyka shale and diamictite between the calcrete

and dolomite. The Dwyka shales have a low permeability and therefore provide

good protection to the dolomite aquifer from potential contamination sources

related to industrial activities in the vicinity.

3.5. Soils

The area surrounding Dudfield plant is characterised by a Molopo Form,

Kalkfontein Series soil. This soil type is characteristically reddish sandy to loamy

soil, ranging in depth to 0,8 m, occasionally attaining a depth of 2 m in fissure or

cavity areas of the underlying limestone. The interface zone between the base of

the soil and the underlying limestone is characterised by a gradational mixture of

loamy to clayey soil and nodules of calcrete. The proportion of calcrete nodules

increase with depth grading into the underlying limestone mass.

The soils in the area are suitable for cultivation where soil depth permits (maize

and other grain crops), as well as for cattle grazing purposes. In the case of crop

cultivation, inorganic fertilisation is required to sustain production.



21

Figure 3.3: Geology around Lichtenburg (extract of 1:250 000 Geological map

2626 West Rand, Geological Survey of South Africa, 1986)

Legend: Qs and Qc Surficial deposits (Qs = soil; Qc = calcrete)

C-Pd Dwyka formation ; shale and diamictite

Vo Chuniespoort Group (Vo = Oaktree Formation; Vmm =

Monte Christo Formation

Va Allanridge Formation

Vb Bothaville Formation

R-Vk Kameeldoorns Formation

R-Vr Rietgat Formation

Rgb Goedgenoeg Formation

Zg Basement granite



22

3.6. Land Use and Surface Infrastructure

Land use in the surrounding area is predominantly agricultural, both crop and

grazing (cattle and sheep). Cultivation of maize, sunflowers and other grain

crops is practised where soil depth permits. Due to the nature of the soils,

inorganic fertilisation is required to sustain crop cultivation production.

Insufficient surface water sources and high evaporation rates in the area limit the

irrigation potential to groundwater sources, which occur primarily in the dolomitic

areas to the north of Dudfield.

Dudfield is accessible by tar roads from all major centres. The entrance to the

plant is located on Road D2095, which forms a link road between Road D933

(Kapsteel Road) to the north and Road P183/1 (Deelpan Road) to the south.

These roads provide access to Dudfield from Lichtenburg. Access onto the

Dudfield site for normal heavy vehicles is via the main entrance which is a

concrete road.

Dudfield operates a railway line from the Rietgat siding, which lies approximately

24 km east south east of Dudfield. This railway line is used extensively for the

transport of coal to the plant and cement product from the plant.

Power to Dudfield is supplied by Eskom 88 kV Distribution lines, and a substation

is located at the plant.

The Dudfield Village lies to the south west of the plant. Holcim employees reside

in the village, which comprises houses, a recreation club and sports field. A small

wastewater treatment plant is located approximately 1 km south west of the plant

and services both the plant and the village.

The limestone mine is located adjacent to the plant, and extends to the west and

northwest. An old quarry to the south of the mine has been rehabilitated and is

now utilised for recreation. Due to the flat nature of the surrounding terrain, all

run-off water is contained and channelled to this centralised collection dam on the

site, known as Riveira Dam. This area lies to the east of the Dudfield Village.

3.7. Flora

The Dudfield plant is located within the Northern Variation of the dry

Cymbopogon-Themeda veld (Acocks Veld Type 50a; Acocks, 1988). This

vegetation type occurs within a typically flat, sandy country located at an altitude

ranging from 1300 m to 1350 m above sea level. The climatic constraints include

summer rainfall of between 450 mm and 600 mm per annum, and frosty winters.

This veld type is dominated by Themeda triandra (Red grass), with Cymbapogon



23

plurinodis (Bushveld turpentine grass) being the tallest grass, but usually not

common.

Most of the vegetation on Dudfield farm and in the surrounding area has been

extensively disturbed as a result of agricultural and mining practices. As a result

of the historic disturbance of the Dudfield farm by agricultural activities prior to

mining activities and the Dudfield plant being established on the site, no rare or

endangered flora species would occur within the immediate area, nor have any

been recorded. No invader species were identified on the Dudfield plant site.

Exotic species common to the area include, inter alia, various species of

Eucalyptus, planted by farmers and the mine as windbreaks, Melia azedarach

(Syringa) and Solanum mauritianum (Bug tree).

3.8. Fauna

As a result of the disturbance to habitats within the surrounding area due to

agricultural and mining activities, the occurrence of natural fauna is limited to

small mammals, reptiles and birds. Mammals which have been recorded in the

area include duiker, bat-eared and long-eared fox, warthog, yellow and slender

mongoose, ground squirrel, black-backed jackal, aardwolf, spring and scrub hare,

and porcupine. Reptiles which have been recorded in the area include several

snake species (such as rinkhals, puff adder, cape cobra, house snake, black

mamba, common African python and Boomslang) and tortoises (such as the

Leopard, Kalahari and Hinge backed tortoise). No definitive bird list has been

developed for the Dudfield area. However, more than 200 bird species have been

reported from the Lichtenburg Game Breeding Centre, which lies approximately

20 km north east of Dudfield. No rare or endangered fauna species have been

recorded in the area, largely as a result of the disturbed nature of the available

habitats.

3.9. Surface Water

The Dudfield plant is located within the Quaternary sub-catchment C31A. Springs

which issue from the dolomitic rock formations to the north of Lichtenburg form

the headwaters of the south-westerly flowing Harts River, which is located

approximately 15 km east of Lichtenburg. Due to low rainfall, this section of the

river is dry for the greater part of the year. Stormwater is, however, channelled

to this river from the area surrounding the Dudfield plant via a man-made

drainage feature which is located on the farm Dudfield approximately 8 km east

of the plant.

A shallow natural drainage feature occurs to the west on the farms Kalkfontein

and Bethlehem. The area surrounding the Dudfield plant is characterised by



24

shallow pans. These drainage and pan features are dry for the majority of the

year due to the low rainfall in the region.

Significant runoff is only evident during periods of prolonged high rainfall or

flooding. During such periods, surface rills and sheet wash tend to flow in a

south-westerly direction over the farms Dudfield, Kalkfontein and Bethlehem.

Due to the flat nature of the surrounding terrain, all run-off water is contained

and channelled to a centralised collection dam on the site, known as Riveira Dam.

3.10. Geohydrological Conditions

The regional geohydrological conditions in the area are displayed on the

1:500 000 scale hydrogeological map 2626 (Barnard, 2000). Two aquifers are

present in the area (Jasper Müller Associates cc, 2004), i.e.:

• A major bedrock aquifer system which occurs in the northern chert rich

Monto Christo dolomite towards the north (a distance of approximately 3 –

13 km from Dudfield).

• A minor bedrock aquifer system which occurs in the southern chert poor

Oaktree Formation.

According to a 1983 DWAF report (Taylor, 1983), water levels were at that stage

only a few metres below surface with a gradient of approximately 1:200 to the

south. Groundwater level contours are not affected by the presence of the

Elizabeth II dyke, indicating that at least this dyke is not impermeable. Taylor

(1983) further reports that an east-west trending groundwater divide is located

just to the north of the farm Dudfield 57 IP.

Due to the lack of any perennial surface water resources, the groundwater

resources are exploited at a large scale. The town of Lichtenburg obtains its

water from boreholes tapping the Oaktree and Monte Christo Formations (Botha

and Bredenkamp, 1993; Dziembowski, 1995). According to the 1:500 000

hydrogeological map between 2 and 5 Mm3 per annum is abstracted from the

karst aquifer developed in the dolomite. Because of the lack of surface water

resources and the reliance on the groundwater resources of the dolomitic aquifer,

this aquifer is classified as a Sole Source Aquifer System (Parsons, 1995) and it is

of strategic importance. Groundwater recharge, based on work by Bredenkamp

(1995), is estimated to be about 5% of mean annual precipitation (MAP).

Average quality of groundwater quality from the Chuniespoort Group is provided

in Table 3.2. Borehole yield distribution for the Chuniespoort Dolomite Group is

indicated in Table 3.3.



25

Table 3.2: Chemical character of dolomite groundwater

Element/Parameter Concentration

pH 7,6

Electrical conductivity (mS/m) 63

Total Dissolved Salts (mg/l) 444

Calcium (mg/l) 53

Magnesium (mg/l) 35

Sodium (mg/l) 24

Potassium (mg/l) 2,3

Chloride (mg/l) 38

Sulphate (mg/l) 71

Total alkalinity (mg/l CaCO3) 177

Nitrate (mg/l) 5,6

Fluoride (mg/l) 0,3

Table 3.3: Borehole yield distribution: Chuniespoort Group

Yield range (l/s) % Boreholes within range

<0.1 3.2

0.1 – 0.5 7.2

0.5 – 2 23.6

2 – 5 15.1

>5 50.5

3.11. Water Consumption at the Dudfield Plant

All water consumed at the Dudfield plant is sourced from the Holcim South Africa

wellfield situated on the Portion 5 of the farm Dudfield 35 IP, approximately 7 km

north-east of the plant. The farm Dudfield 35 IP is located along the southern

boundary of the declared Bo-Molopo Government Underground Water Control

Area declared according to Articles 27 to 35 of the previous Water Act (No 54 of

1956) (Dziembowski, 1995). This wellfield supplying the Dudfield plant is also

referred to as the “Waterplaas” and consists of 4 boreholes from which on

average approximately 80 000m3 of water is pumped monthly to supply the

entire water requirements of the Dudfield plant. Of this, about 50 000m3/month

is supplied to the operating kilns. Figure 3.4 provides the water flow/balance

diagram for Dudfield plant for July 2004.

Environmental Impact Assessment Report for the proposed Alternative Fuels and Resources Project at the Holcim South Africa Dudfield Plant, North West Province


26

Figure 3.4: Water flow/balance diagram for Dudfield plant for July 2004 (Holcim, 2004)



27

Process water supply is limited to use by the conditioning towers, where pre-

heater gas temperatures are reduced, as well as for equipment cooling. Water

loss is through evaporation in the cooling towers. Water recovered from the

evaporation and cooling processes is returned to the Riveira Dam to the south of

the plant.

Water quality changes caused by the process are reflected in Table 3.4. Small

volumes of effluent from the water softening plants are also channelled to the

Riveira Dam.

Table 3.4: Chemical analyses of different waters at Dudfield Plant

(12 February 2004, Reference 050204/381)

Element/ Parameter (Units)Raw water

borehole

Treated water (Sagte

Water Huis 32)

Riveira

Dam

pH 8.2 8.0 8.2

Electrical Conductivity (EC) (mS/m) 55 54 114

Turbidity (NTU) 0.6 1.2 2.3

Chloride (Cl) (Mg/l) 10 12 202

Magnesium (Mg) (Mg/l) 21 12 37

Nitrate (NO3 as N) (Mg/l) 9.5 9.3 0.5

Nitrite (NO2) (Mg/l) <0.01 0.02 <0.01

Ortho Phosphate (o-PO4) (mg/l P) <0.1 <0.01 <0.1

Sodium (Na) (Mg/l) 5.9 52 112

Sulphate (SO4) (Mg/l) <20 <20 47

Calcium (Ca) (Mg/l) 76 44 59

Total Hardness (TH) (mg/l CaCO3) 277 158 298

3.12. Air Quality

Evidence of dust pollution within the area surrounding the Dudfield plant is

associated with local mining and agricultural activities, as well as the operation of

the plant.

Under routine operating conditions, the primary constituents of emissions from

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

inhalable particulate (PM10), carbon monoxide (CO) from the kilns, and PM10

emissions from the cement mills. In 2003, Holcim installed Opsis® in-line stack

monitors (see Photograph 3.2) that measure emissions from the Kiln 3 stack on a

continuous basis. SO2, N0, NO2, C0, H2O, HCl, NH3, O2 water vapour, benzene,

toluene and xylene (BTX), total organic carbon (TOC) are monitored by the

Opsis® equipment, and particulate emissions monitored by Durag dust monitors.

In addition, Holcim will do annual or bi-annual isokinetic stack sampling to

monitor the emissions of heavy metals (Hg, Cd, Tl, Pb), other metal components

(Zn, Ag, Sn, Sb, etc), as well as dioxins and furans.



28

Photograph 3.2: Opsis® Emission and Durag particulate measuring unit

installed at Dudfiled in 2002

Information regarding the stack parameters and emission rates is presented in

Table 3.5. A summary of the existing total emissions from the Dudfield plant is

provided in Table 3.6 and heavy metal and dioxin and furan emissions from Kiln 3

for routine operating conditions in Table 3.7.

Table 3.5: Stack parameters for the Dudfield plant under current routine


Source Height (m) Diameter (m)Temperature

(°C)

Exit Velocity

(m/s)

Kiln 3 76 3.75 120 12.4

Cement Mill 1 30 1.162 70 8.6

Cement Mill 2 30 0.710 93.5 18.2



29

Table 3.6: Emission rates for criteria and VOC pollutants from the stacks at

the Dudfield plant under current routine operating conditions

Emissions measured in (g/s)Source

Averaging

Period PM10 CO NOx SO2 Benzene Xylene

Hourly 1.33 3.18 0.88 13.80(c) 0.99 0.71

Daily 0.99 2.27 0.46 1.61 0.48 0.64Kiln 3 (a)

Average 0.80 1.11 0.26 0.35 0.34 0.56

Hourly

Daily 0.33 - - - - -Cement Mill 1

(b)Average

Hourly

Daily 0.43 - - - - -Cement Mill 2

(b)Average

Notes:

(a) Monitored data undertaken by C&M Consulting Engineers (for the period 26 May to 8 June 2004)

under current routine operating conditions, provided by Holcim South Africa (Pty) Ltd.

(b) Monitored data under current routine operating conditions provided by Holcim South Africa (Pty)

Ltd.

(c) This value occurred once for an hour on the 31st May 2004 at 06h00.

Table 3.7: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 for routine


Emission (g/s)Compound

Highest Hourly Highest Daily Average

Beryllium 1.2E-07 9.0E-08 8.0E-08

Vanadium 8.0E-05 6.0E-05 5.0E-05

Chromium 1.3E-04 9.0E-05 8.0E-05

Manganese 4.0E-04 3.0E-04 2.6E-04

Cobalt 4.0E-05 3.0E-05 3.0E-05

Nickel 1.6E-04 1.2E-04 9.0E-05

Copper 6.0E-05 5.0E-05 4.0E-05

Arsenic 2.0E-05 1.3E-05 1.0E-05

Silver 1.2E-05 9.0E-06 7.0E-06

Cadmium (b) 1.5E-05 1.5E-05 1.5E-05

Tin (a) 2.0E-04 1.7E-04 1.3E-04

Antimony 1.0E-05 9.0E-06 7.0E-06

Barium 3.6E-05 2.7E-05 2.2E-05

Mercury (b) 2.0E-05 2.0E-05 2.0E-05

Thallium 3.0E-04 2.5E-04 2.0E-04

Lead 5.0E-05 4.0E-05 3.0E-05

Dioxin Toxic

Equivalence (b) 7.0E-09 7.0E-09 7.0E-09

(a) Of the information provided, the analytical methods utilised to determine the tin emissions

are suspect and it appears that tin contamination may have occurred.

(b) Emissions for these volatile pollutants were taken from measured values from the study

undertaken by C & M Consulting Engineers (2002) as a more conservative approach.



30

Table 3.8 provides a comparison between PM10, SO2 and NO2 emissions provided

by Holcim South Africa and the provisional permit specifications (according to the

Atmospheric Pollution Prevention Act (APPA) Scheduled Process No. 22). It

should be noted that the current PM10, SO2 and NO2 emissions do not exceed

permit specifications.

Table 3.8: Comparison of measured PM10, NO2 and SO2 emissions to permit

specifications

Emissions (mg/Nm³) % Exceeded

SO2 NO2 PM10Appliance

Permit Provided Permit Provided Permit ProvidedSO2 NO2 PM10

Kiln 3 32.18 3.6 800 2.7 50 8.4 N/E N/E N/E

Cement Mill

1- - - - 50 37 - - N/E

Cement Mill

2- - - - 100 90 - - N/E

N/E: Not exceeding

3.13. Noise

The area surrounding the Dudfield plant has a low population density and is

characterised as a rural area. The Dudfield plant and mining area located on

Dudfield farm is characterised as an industrial area.

Typical rating levels for ambient noise in the different districts are set out in Table

2 of the South African Bureau of Standards (SABS) Code of Practice 0103 for “The

measurement and rating of environmental noise with respect to annoyance and to

speech communication”. This code covers a method of measurement and

assessment of noise to determine the suitability of an environment with respect

to possible annoyance (i.e. whether complaints could be expected). Typical

outdoor rating levels, Lr, in dBA are provided in Table 3.9.

Table 3.9: Typical outdoor rating levels (dBA) for ambient noise in different

districts (refer SABS Code 0103)

Type of district Daytime EveningNight-

time

Rural 45 40 35

Suburban with little road traffic 50 45 40

Urban 55 50 45

Urban with some workshops, with business premises &

main roads

60 55 50

Central business 65 60 55

Industrial 70 65 60



31

Noise levels at Dudfield plant are within the limits, as specified in the SABS code,

at the boundary of the plant. The Dudfield Village is the closest residential area

to the plant, and at night plant noise is audible, but not considered a disturbance,

offensive, or detrimental.

Noise generated by the Dudfield plant emanates primarily from the fans, and

intermittent noise is as a result of blasting activities at the adjacent limestone

mine/quarry.

Ambient noise levels in the area surrounding the Dudfield plant are typical of

those associated with rural agricultural activities.

3.14. Visual Aspects and Aesthetics

The study area is characterised by a featureless level plain of no scenic or tourist

potential. The residential area in the immediate vicinity of the Dudfield plant is

limited to the Holcim-owned Dudfield Village. Due to the nature of the cement

plant (and tall structures such as stacks and pre-heater towers), the plant is

visible on a clear day from approximately 30 km.

3.15. Sites of Archaeological, Cultural or Historical Interest

No sites of archaeological, cultural or historical interest are known to occur in the

area immediately surrounding the Dudfield plant. As a result of the intense

agricultural activities in the area, it is likely that any such sites which may have

occurred have been either damaged or destroyed.

3.16. Regional Socio-economic Structure


which is the closest town to the operations. The town forms part of the Central

District Municipality and the Ditsobotla Local Municipality. This town is the centre

of a farming district where maize, groundnuts and sunflower seeds are the main

crops. To the north-east of Dudfield is the town Itsoseng, a small rural

community, supplying labour to the surrounding farms and Lichtenburg.

3.16.1. Population Density

The area surrounding Dudfield plant is sparsely populated, typical of a rural

farming community. Typical of the current trend for urbanisation, the area is

experiencing a slight reduction in population as a result of people relocating to

larger towns in the area. The greatest population density in the immediate area

surrounding the plant is Dudfield Village, where approximately 200 people reside.

The village is located approximately 1 km south-west of the plant.



32

Population density for Lichtenburg and surrounding areas is approximately 9 883,

and 27 891 for Itsoseng and surrounding areas (as per the 1996 census,

Mr Israel Motlhabane pers. comm.). These centres are, however, approximately

20 km away from the Dudfield plant.

3.16.2. Major Economic Activity and Sources of Employment

The Holcim South Africa Dudfield plant is one of two cement manufacturing plants

in the area. Apart from limestone mining and cement manufacture, grain farming

is the major economic activity in the area. The agricultural activities in the area

are overseen by the North-West Co-operation.


Cement Manufacturing Process 31-Aug-0433

4. OVERVIEW OF THE CEMENT MANUFACTURING PROCESS

The basic chemistry of the cement manufacturing process begins with the

decomposition of calcium carbonate (CaCO3) at approximately 900°C to leave

calcium oxide (CaO, lime) and gaseous carbon dioxide (CO2). This process is

known as calcination. This is followed by the clinkering process, in which the

calcium oxide reacts at high temperature (typically 1 400 - 1 500°C) with silica,

alumina, and ferrous oxides to form the silicates, aluminates, and ferrites of

calcium. The resultant clinker is then ground or milled together with gypsum and

other additives to produce cement.

4.1. Cement Manufacturing Process at Dudfield Plant

Dudfield Kiln 3 has a current production rate of 3 500 tons of clinker per day.

The operation utilises dry process technology due to the low water content of the

limestone. Dry process technology is the most modern technology in cement

manufacture.

Dudfield Kiln 3 currently comprises a vertical raw mill, a four stage preheater and

pre-calciner, a rotary kiln 80 m in length (inclined rotating steel cylinder lined

with heat resistant bricks), grate cooler, and a firing system. Kiln dust emissions

are controlled by a bag filter with a design particulate emission limit of

30mg/Nm3.

The cement manufacturing process can be divided into three stages, namely

preparation of raw materials, clinker production in the kiln, and clinker grinding

after the kiln. Figure 4.1 provides a schematic representation of the cement

manufacture process from sourcing the raw materials to delivery of the final

product.

4.1.1. Preparation of Raw Materials

Limestone is the major raw material used to produce cement, and at Dudfield is

mined from quarries located adjacent to the cement plant. The mined limestone

is crushed and blended in precise proportions with other raw materials containing

iron, alumina and silica and fed to a vertical raw mill, where the materials are

milled to a fine powder referred to as 'raw meal'.

This raw meal is fed into the preheater. The preheater comprises a vertical tower

of heat exchange cyclones in which the dry feed is preheated to temperatures of

approximately 900°C by the kiln exit gases. Raw meal is introduced at the top of

the preheater tower and the hot kiln exhaust gases pass counter-current through

the downward moving meal to heat the meal prior to introduction into the kiln.


Cement Manufacturing Process 31-Aug-0434

Figure 4.1: Schematic representation of the cement manufacture process from sourcing the raw materials to delivery of the final

product (Source: Cement Industry Federation, 2002)

1 – Raw MaterialsLimestone is the mainraw material forcement manufacture,and is mined fromadjacent quarries.Other necessaryelements such asiron, alumina andsilica are sourcedfrom additional rawmaterials.

2 - TransportRaw materials aretransported to theplant via conveyor,road or rail.

3 – Transport of fuelFuel required toachieve and maintaintemperatures in thekiln are transported tothe plant (via rail orroad).

4 - HomogenisingRaw materials arehomogenised inpreparation for rawmilling.

5 – Raw MillPrecise proportions ofthe raw materials areblended and milled toa fine powder (‘rawmeal’) in the raw mill.

6 – Bag FilterBag filters removeparticulates from kilnand mill exhaustgases.

7 – Pre-heaterRaw materials areheated to ~900°C incounterflow heatexchange resulting inthe decarbonisation ofcalcim carbonate inthe raw meal.

8 – the KilnRaw materials arefurther heated to1450°C in the rotarykiln. At thistemperature, rawmaterials aretransformed intoClinker.

Clinker productionrequires hightemperatures whichare generated by thecombustion of fuel.The use of waste-derived alternativefuels is being isproposed to replace apercentage of fossilfuel (coal) used.

9 – Grate CoolerClinker is dischargedfrom the kiln at~1000°C andtransferred to thegrate cooler. Clinkeris rapidly cooled toensure the desiredmineralogy is formedin the final product.Heat recovered fromthe kiln and the cooleris recycled in theprocess to reduce fuelrequirements.

10 – Clinker SiloCooled clinker isstored on the clinkersilo.

11 - Cement MillClinker, with theaddition of gypsumand extenders, isground in a ball millto a fine powder toproduce the finalcement product.

12 – Storage SilosThe cement isconveyed to large,vertical storage silos.Cement is conveyedto loading stations inthe plant or directly totransport vehicles fordelivery of the finalcement products inbags or in bulk.

Raw Materials

Clinker ProductionCement grinding and distribution


Overview of the Cement Manufacturing Process 31-Aug-0435

A pre-calciner combustion vessel located at the bottom of the preheater tower

decarbonises the calcium carbonate in the raw meal. The pre-calciner is an

auxiliary firing system which increases the raw materials temperature further

prior to introduction into the kiln (refer Figure 4.2). The pre-calciner is

advantageous in that the calcination process is almost completed before the raw

material enters the kiln, increasing the production capacity of the kiln.

The preheater tower is designed for an optimisation of transfer of heat to take

place between the kiln exhaust gas and the limestone based raw material. Gas

temperature entering the pre-heater are in the order of +900°C, while the

temperature of the gases exiting the preheater tower are approximately 280°C.

Further cooling of the gas stream takes place in the conditioning tower, where

temperatures are reduced to approximately 140°C in a few seconds. Gas

scrubbing effectively takes place in the pre-heater tower through to the area

immediately after the bag-house filters. Due to the alkali environment coupled

with rapid gas cooling, the potential for environmental impacts is minimised.

4.1.2. Process inside the Kiln

The raw material is fed into the upper end of the kiln which is operated in a

'counter-current' configuration, that is gases and solids flow in opposite directions

through the kiln providing for more efficient heat transfer. The raw meal is fed at

the upper (or 'cold' end), and the slope and rotation cause the raw meal to move

toward the lower (or 'hot' end). The rate at which the material passes through

the kiln is controlled by the slope and rotational speed of the kiln.

As the meal moves through the kiln and is heated, the raw materials reach a

temperature of approximately 1 450°C. At this high temperature, a series of

chemical reactions take place with some of the raw materials in molten form,

resulting in the fusion of the materials and the creation of clinker on cooling (solid

greyish-black nodules, the size of marbles or larger).

Fuel, currently consisting of powdered coal, is fed into the lower end of the kiln

via a multi-channel low NOx burner.

4.1.3. After the Kiln

Clinker is discharged at a temperature of about 1 000°C from the lower end of

the kiln and transferred to a grate clinker cooler in order to rapidly lower the

clinker temperature and freeze the mineralogy of the material. The clinker cooler

is a moving grate through which cooling air is blown. Cooled clinker is stored in a

clinker silo. The clinker, with the addition of gypsum and extenders, is ground in

a ball mill to a fine powder to produce the final cement product.



Figure 4.2: Primary components of Kiln 3 (Holcim, 2004)



The cement is conveyed from the cement mill to large, vertical storage silos in

the packhouse or shipping department. Cement is withdrawn from the cement

storage silos by a variety of feeding devices and conveyed to loading stations in

the plant or directly to transport vehicles.

4.2. Environmental Aspects of Cement Manufacture

4.2.1. Raw Materials

In the cement kiln, new mineral compounds are formed giving cement its specific

properties. The main components are the oxides of calcium, silica, aluminium

and iron.

Significant quantities of limestone, clay and other primary raw materials are

quarried to service the demand for cement. Calcium is provided by the

limestone, while other necessary elements such as iron, alumina and silica are

sourced from additional raw materials and added into the process in the desired

quantities. All the natural raw materials which form raw meal also contain a wide

variety of other elements in small quantities (for example zinc).

4.2.2. Emissions to Air

Almost all manufacturing activity results in emissions to the atmosphere, and

cement manufacture is no exception to this. Releases from the cement kiln come

from the physical and chemical reactions of the raw materials and from the

combustion fuels. The main constituents of the exit gases from a cement kiln are

nitrogen from the combustion air, carbon dioxide (CO2) from the calcination and

combustion processes, water vapour, and excess oxygen.

The exit gases also contain small quantities of dust, chlorides, fluorides, sulphur

dioxides, NOx, carbon monoxide, and still smaller quantities of organic and

inorganic compounds. Many of the gases released are harmless, however, some

are either known or suspected to cause damage to the environment. These

emissions are, therefore, required to be carefully monitored and controlled in

terms of the requirements of the Atmospheric Pollution Prevention Act (No 45 of

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

Dudfield plant.

Monitoring equipment is in place at Dudfield to monitor stack emissions. In 2003,

Holcim installed Opsis equipment for Kiln 3 which measures on a continuous

basis SO2, N0, NO2, C0, H2O, benzene, xylene and toluene, and Durag emission

equipment for particulates. Holcim have also extended the range to total organic

compounds as well as HCl and NH3. Twelve heavy metals, as well as dioxins and

furans are measured for on an annual basis.



4.2.3. Energy

In the South African cement industry, the primary fuel used for energy is coal, a

fossil fuel. The average energy requirement to produce 1 000 tons of cement

clinker is approximately 130 tons of coal. Holcim South Africa requires

approximately 350 000 tons per annum of coal to sustain current cement clinker

manufacture rates.

The main constituents of coal ash are silica and aluminia compounds which

combine with the raw materials (limestone) in the kiln to become part of the

clinker. Like other natural products, the coal ashes contain a wide range of trace

elements which are also incorporated in the cement clinker.

With energy typically accounting for 30-40% of the production cost of cement,

the cement industry throughout Europe and developing nations has successfully

concentrated significant efforts on improving energy efficiency of operating kilns

in recent decades. This includes the introduction of energy efficient technologies

such as the use of preheater towers and pre-calciners.

In addition, in an effort to reduce the reliance on fossil fuels to generate and

maintain the flame temperature, the use of alternative sources of fuels (other

than traditional fossil fuels) have been investigated and successfully implemented

in kilns.

4.2.4 Use of Alternative Fuels in the Cement Manufacture Process

A commitment to Sustainable Development has resulted in a drive to replace

traditional non-renewable fossil fuels (such as coal) used in the production of

cement with suitable alternative fuels. This has resulted in the need to identify

alternative renewable fuel sources which would provide similar energy (i.e.

calorific value) to that provided by coal, and would have a reduced environmental

impact when utilised in the kiln.

Using waste generated from other industries addresses this need, as much of this

waste is chemically similar to coal, and has a calorific value similar to that of coal.

The use of this waste as a fuel presents the opportunity to reduce the

environmental impacts of using a non-renewable resource (coal) in the cement

manufacture process, as well as reducing the amount of waste material which

would traditionally be disposed of to landfill or incinerated. The use of waste

derived fuels in a cement kiln, therefore, reduces fossil fuels usage while

maximising the recovery of energy.

The use of alternative waste-derived fuels is a well-proven and well-established

technology in the international cement industry, particularly Europe, Australia and

the Americas. The use of alternative fuels and resources (AFR) has been



practiced in these countries for more than 20 years. In 1995 approximately 10%

of the thermal energy consumption in the European cement industry originated

from alternative fuels. This is equivalent to 2,5 million tonnes of coal

(CEMBUREAU, 1997). The use of alternative fuels has steady increased since

then.

The recent upgrade of the Dudfield’s Kiln 3 has resulted in this plant being in a

position to receive and utilise alternative fuels as an energy source, together with

coal (through the installation of a ‘low NOx’-multichannel primary burner). The

multi-channel burner allows for multiple energy sources to be introduced into the

kiln, which allows for fuel versatility.

4.2.5. How AFR can be utilised in the Kiln

Waste-derived fuels can be introduced to Kiln 3 as a fuel at three locations.

These are illustrated on Figure 4.3:

• The lower end of the kiln directly at the main flame / burner: the AFR is

immediately exposed to the main burner flame and releases energy to

maintain the temperature in excess of 2 000°C.

• In the pre-calciner combustion vessel located at the bottom of the preheater

tower: the AFR is immediately exposed to flame within the auxiliary firing

system, maintaining the temperature at 1 200°C.

• The upper end of the kiln where the raw material is fed: the AFR is fed with

raw materials which are at a temperature of 900°C.

The upgrade of the Kiln 3 burner to a multi-channel burner allows for multiple

energy sources to be introduced into the kiln and allows for fuel versatility. Fuel

is fed into the lower end of the kiln through this burner. Fuel lines can be coupled

to the burner (refer Photograph 4.1), and injected into the kiln through concentric

tubes together with air. The burner head installed at Dudfield plant is illustrated

in Photograph 4.2.



Photograph 4.1: Multi-channel burner, illustrating the multiple channels

where various fuel lines can be coupled for feeding

alternative fuels into the kiln

Photograph 4.2: Burner head illustrating the concentric tubes through which

fuel and air is fed into the kiln



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



4.2.6. Waste Products utilised as Alternative Fuel Sources

Waste materials which the cement industry has utilised as alternative fuels in

Europe include used tyres, rubber, paper waste, waste oils, waste wood, paper

sludge, sewage sludge, plastics and spent solvents. Similar waste materials are

proposed to be utilised as fuel in South Africa, together with other wastes that

are considered suitable and desirable (including industrial hydrocarbon tars and

sludges).

Many waste products are chemically similar to coal, and have a calorific value

(MJ/kg) similar to, and in some instances higher, than coal. Table 4.1 provides

an indication of nett calorific value of alternative fuels, as well as traditional fuels.

The use of materials other than coal to achieve the same effect within the kiln is

beneficial through the maximisation of energy recovery.

Table 4.1: Nett calorific value (MJ/kg) of alternative fuels and traditional fuels

Grade of fuel Fuel typeCalorific value

(MJ/kg)

Pure polyethylene 46

Light oil 42

Heavy oil 40

Pure polystyrene 40

By-products of tar 38

Pure rubber 36

Anthracite 34

Waste oils 30-38

Scrap tyres 28-32

High Grade

Coal 24-29

Pot liners 20

Paint sludge 19

Dried paint 18

Dried wood / sawdust 16

Medium Grade

Rice husks 16

Cardboard / paper 15

Dried sewage sludge 10Low Grade

Wet sewage sludge 7.5

The use of waste as alternative fuels is technically sound as the organic

component is destroyed and the inorganic component is trapped and combined in

the cement clinker forming part of the final product. Cement kilns have a number

of characteristics that make them ideal installations in which alternative fuels can

be valorised and burnt safely, such as:

• High temperatures, i.e. exceeding 1 400°C

• Long residence time, i.e. in excess of 4 seconds






• Ash retention in clinker, i.e. fuel ashes are incorporated in the cement clinker,

with no residual solid waste by-product

Normal operation of cement kilns provides combustion conditions which are more

than adequate for the destruction of organic substances. This is primarily due to

the very high temperatures of the kiln gases (2 000°C in the combustion gas

from the main burners and 1 200°C in the gas from the burners from the pre-

calciner) (Bouwmans and Hakvoort, 1998; CEMBUREAU, 1997). The gas

residence time at high temperature in the kiln is of the order of 5-10 seconds and

in the pre-calciner more than 3 seconds (CEMBUREAU, 1997).

Because a cement kiln is a large manufacturing unit operating in a continuous

process and with a high heat capacity and thermal inertia, a significant change in

kiln temperature in a brief period of time is not possible. The cement kiln

therefore offers an intrinsically safe thermal environment for the use of

alternative fuels.

Metals are not destroyed at high temperatures, therefore those introduced into

the cement kiln via the raw materials or the fuel will be present in the releases or

in the clinker. Extensive studies investigating the behavior of metals in cement

kilns have shown that the vast majority are retained in the clinker. For example,

studies on antimony, arsenic, barium, beryllium, cadmium, chromium, copper,

lead, nickel, selenium, vanadium and zinc have established that near 100% of

these metals are retained in the solids (clinker).


materials, there are those that would not be considered for use as a fuel. For

example, extremely volatile metals such as mercury and thallium are not

incorporated into the clinker to the same degree as other metals are, therefore,

alternative fuels containing these elements are required to be carefully controlled

(CEMBUREAU, 1997).

For public health and safety reasons, no materials that could jeopardise the

health and safety of the employees or the environment, or compromise the

performance of the cement would be considered as a fuel. Therefore, strict

sampling and testing procedures would be required to be put in place at the

Dudfield plant in order to ensure that undesirable fuels are excluded as

alternative fuel sources. Materials excluded are anatomical hospital wastes,

asbestos-containing wastes, bio-hazardous wastes, electronic scrap, entire

batteries, explosives, high-concentration cyanide wastes, mineral acids,

radioactive wastes, and unsorted municipal garbage.


Assessment of Potential Impacts 31-Aug-0444

5. ASSESSMENT OF POTENTIAL IMPACTS ASSOCIATED WITH THE

INTRODUCTION OF THE ALTERNATIVE FUELS AND RESOURCES

PROJECT AT DUDFIELD PLANT

The main environmental impacts associated with cement production are

emissions to air and energy use. Wastewater discharge is generally limited to

surface/stormwater runoff from the plant itself and process cooling water. The

storage and handling of fuel for the kiln is a potential source of contamination of

soil and groundwater. This includes both the storage of traditional fuel (coal) as

well as the proposed alternative waste-derived fuel. Impacts on the social

environment are focussed on potential impacts associated with the transport of

fuels, and benefits associated with employment opportunities. The potential

environmental impacts associated with the introduction of the AFR programme at

the existing Dudfield plant have been assessed through specialist studies

undertaken as part of this EIA.

The environmental assessment aims to provide an integrated and balanced view

of the potential environmental impacts associated with the proposed project, as

well as make recommendations regarding appropriate mitigation measures, such

that informed decision-making can be made by the environmental authorities.

This section includes an assessment of the potential positive and negative

impacts identified through this EIA process, and makes recommendations, where

required, regarding practical and appropriate mitigation and management

measures required to be implemented in order to minimise potentially significant

impacts.

5.1. Potential Impacts on Land Use, Vegetation and Heritage Sites in

the area surrounding the Dudfield plant

The Holcim Dudfield plant was constructed more than 50 years ago and is located

within an area zoned for industrial use. Land use in the immediate surrounding

area is limestone quarrying with other areas under cultivation and used for

grazing. Impacts/disturbance of the land within and surrounding the Dudfield

plant already exists, and has done so since the initial construction of the facility.

Therefore, the proposed project has no significant impacts relating to the change

of land use, loss of land, vegetation or heritage sites in the surrounding area

(refer to Table 5.1 overleaf). The impact is, therefore, rated as insignificant.

The recent upgrade of Dudfield’s Kiln 3 resulted in this kiln being in a position to

receive and utilise alternative fuels as an energy source, together with coal.

Modifications to the plant and kiln infrastructure (within the boundaries of the

existing Dudfield plant) have already been completed. As the AFR programme

proposed at Dudfield’s Kiln 3 involves the reduction in the use of coal through

supplementation of the fuel required with AFR, additional investment would be



required to be made within the site boundaries for the AFR acceptance, chemical

testing, storage and kiln feed infrastructure. This additional infrastructure would

not, however, not require any additional changes to the footprint area of the

existing cement plant.

The area within the boundaries of the existing Dudfield plant has been extensively

disturbed through industrial activities and the construction of auxiliary

infrastructure to support the cement plant since the early 1950s. The

introduction of an AFR programme would require the establishment of a dedicated

fuel storage area, approximately 1 600 m2 in size, where fuels could be off-

loaded, handled, and stored for a limited period before being fed into the kiln

together with coal. This area would be within the existing footprint of the

Dudfield plant, adjacent to Kiln 3. Specific impacts associated with this storage

area are detailed in section 5.2 below. Secondary infrastructure such as roads

accessing this storage area would also be within the boundaries of the plant.

As a result of no additional development being required outside of the boundaries

of the existing Dudfield plant with the introduction of the AFR programme, no

impact on any heritage sites is anticipated. This has been confirmed by the North

West provincial department of the South African Heritage Resources Agency

(SAHRA), who have indicated that they have no objections to this project and did

not require a Heritage Impact Assessment (HIA) to be submitted to the

Department for review (refer to Appendix G).

5.1.1. Conclusions and Recommended Management Options

No significant impacts on land use, vegetation and heritage sites are anticipated

to be associated with the introduction of the AFR programme at Dudfield plant.

Therefore, no mitigation measures are required to be implemented. However, all

current vegetation maintenance practises exercised at Dudfield plant must be

continued in terms of the requirements of the Conservation of Agricultural

Resources Act (No 43 of 1983).

5.2. Potential Impacts Associated with the establishment of a Fuel

Storage Area within the Boundaries of the Dudfield Plant

No preparation of different waste types for use as AFR at Dudfield plant (such as

pre-treatment or blending of wastes) will occur at Dudfield plant. The suitable

AFR received at the plant will be received and stored within a designated storage

area, and then proportioned for feeding into the cement kiln. The AFR fuel

storage area of approximately 1 600 m2 is proposed to be established within the

boundaries of the existing Dudfield plant within the currently vacant area to the

north of Kiln 3 (refer to Figure 5.1). This area has been extensively disturbed



Table 5.1: Summary of potential impacts on land use, vegetation and heritage sites in the area surrounding the Dudfield plant as a

result of the introduction of the AFR programme

Nature of Impact associated

with the introduction of the

AFR programmeExtent Duration Severity Significance Likelihood

Confidencein

assessmentof impact

Mitigation measures

Impacts on land use in the area

surrounding the Dudfield plant

Localised Long-term Slight None Very unlikely

to occur

High Not applicable

Impacts on vegetation in the area

surrounding the Dudfield plant

Localised Permanent Slight None Very unlikely

to occur

High Current vegetation maintenance

practises must be continued.

Impacts on heritage sites in the

area surrounding the Dudfield

plant

Localised Permanent Severe None Very unlikely

to occur

High Not applicable

Table 5.2: Summary of potential impacts associated with the establishment of a fuel storage area within the boundaries of the

Dudfield plant

Nature of Impact associated

with the introduction of the

AFR programmeExtent Duration Severity Significance Likelihood

Confidencein

assessmentof impact

Mitigation measures

Impacts on land use within the

Dudfield plant boundaries

Localised Long-term None None Very unlikely

to occur

High Not applicable

Impacts on vegetation within the

Dudfield plant boundaries

Localised Long-term None None Very unlikely

to occur

High Not applicable

Impacts on groundwater and soil

as a result of the storage of AFR

Localised Long-term Severe High Very unlikely

to occur

High Storage areas must be constructed

according to national engineering

standards & specifications required

by the National & Provincial

Government Departments



through activities associated with the cement manufacture process at the plant,

including the construction activities associated with the recent upgrade of Kiln 3.

The area is devoid of vegetation, as is characteristic of the area, and is on level

terrain.

Limited earthworks would be required in the construction of an appropriately

bunded, concrete lined area. Therefore, the establishment of this fuel storage

area is not anticipated to impact significantly on vegetation or land within the

Dudfield plant boundaries.

Figure 5.1: Photograph of the area north of Kiln 3 illustrating the position of

area demarcated for the proposed AFR storage area in relation to

Kiln 3

The storage of fossil and alternative fuels is, however, identified as an important

potential source of impact on the environment as a result of the potential for

pollution of the soil and groundwater. Without the implementation of appropriate

mitigation measures, this impact is potentially of high significance.

An assessment of the potential impacts associated with the establishment of an

AFR fuel storage area within the boundaries of the Dudfield plant is provided in

Table 5.2.




No significant impacts on land or vegetation is associated with the establishment

of a designated AFR storage area at Dudfield plant. Therefore, no mitigation

measures are required to be implemented prior to the construction of the site.

However, in order to minimise potential impacts on soil and groundwater as a

result of the storage of fuels, storage areas for all alternative fuels and resources

must be constructed according to national engineering standards and

specifications required by the relevant National and Provincial Government

Departments. These should have a concrete floor, should be properly bunded,

and if required for operational reasons, should be covered by a permanent roof

structure. The volume of the bunded area should at least be such that it can

contain a 1:50 year rainfall event over the surface area of the storage area. The

concrete base will minimise, if not totally exclude, leachate infiltration into the

groundwater.

5.3. Potential Impacts on Water Resources

5.3.1. Sources of risk to the groundwater and surface water

environment from the introduction of an AFR programme

Wastewater discharge associated with a cement plant is limited to

surface/stormwater runoff from the plant itself and surrounding surfaced areas,

as well as process cooling water. Current operating activities do not result in any

significant contribution to surface or groundwater pollution.

The introduction of AFR as an energy source in Kiln 3 at Dudfield plant will not

impact on or change the current water demand for cooling purposed within the

cement manufacture process. The kiln will continue operating at capacity, as is

currently the case with the use of coal as a fuel source. The current impacts of

the existing operating kiln on the water quality as a result of surface/stormwater

runoff from the plant itself and surrounding surfaced areas will not be altered. In

addition, the process water used for cooling will remain the same as current

operating conditions. Therefore, it is anticipated that the proposed project will

not further impact on the quality and/or availability of water resources in the

area.

The quality of the water utilised within the cement manufacture process for

cooling purposes will not be contaminated by AFR. Therefore, the introduction of

this programme will not impact on the current quality of the process water, the

cement manufacturing process or the quality of the product. The cement plant is

liquid effluent-free, since any water used in the process is evaporated due the



high temperatures within the kiln. This will continue to be the case with the

introduction of the AFR programme.

Impacts on local water quality could potentially be associated with the AFR

storage area. Should this area be uncovered, the potential exists for the

production of leachate as a result of rainwater or stormwater percolating through

the material. Depending on the type of material and its physical condition, the

leachate produced may result in contamination to surface and/or groundwater

resources if not properly contained or treated. Leachate generated in this way

within the storage area would be required to be chemically tested to determine

compliance to the National Standard Requirements for the Purification of Waste

Water or Effluent, as determined by the Department of Water Affairs and Forestry

(DWAF) before it can be disposed of. In the event of non-compliance, the

leachate would be required to either be treated before disposal to a receiving

water resource, or be evaporated and the resulting sludge be disposed of at an

approved and permitted waste disposal facility.

Currently, all stormwater is directed towards an extensive canal system

constructed around the plant and then collected in a holding dam to the south of

the plant. This canal system is currently being upgraded to a concrete-lined

structure. The holding dam is unlined. The storage area for AFR would be

required to be lined and bunded in order to ensure that the quality of the

stormwater not be affected by implementation of the proposed project.

The potential impacts on the water environment (groundwater and surface water)

associated with the introduction of the AFR programme together with the scale of

impact are detailed in Table 5.3.


The introduction of the AFR programme in Kiln 3 is not anticipated to result in any

significant impacts on the water environment. The amount of water to be used in

the cement manufacture process will not change with the use of AFR as the kiln

will continue operating at capacity as is currently the case with the use of coal as

a fuel source. Therefore, no negative impacts on the surface and groundwater

resources as a result of an increase in the abstraction of groundwater are

expected.

The proposed alternative fuels and resources will be required to be stored in

facilities designed according to national construction, handling and storage

requirements. The area would be required to have a concrete floor, be bunded to

contain any water accumulating within the storage area, and a roof to exclude

rainwater from entering and accumulating within the storage facility. Should

water accumulate within the bunded area, the quality of the wastewater would be



required to be tested, and only discharged to the approved effluent discharge

system of the plant should it meet the specified range for effluent discharge.

Should the quality of the water not be acceptable, it would be required to be

treated to a standard such that it can be disposed of in the effluent disposal

system (Department of Environmental Affairs and Tourism, 1984; Department of

Water Affairs and Forestry, 1996).

5.4. Potential Impacts on Air Quality

Releases from the cement kiln come from the physical and chemical reactions of

the raw materials and from the combustion fuels. The main constituents of the

exit gases from a cement kiln are nitrogen from the air used for combustion,

carbon dioxide (CO2) from limestone calcination and the combustion process, and

excess oxygen. The exit gases also contain small quantities of dust, chlorides,

fluorides, sulphur dioxides, oxides of nitrogen (NOx), carbon monoxide (CO), and

still smaller quantities of organic and inorganic compounds.

The exit gases from Kiln 3 are dedusted in bag filters, and the dust returned to

the process.

The specialist air quality assessment undertaken for this proposed project

considered both the baseline conditions (i.e. with coal as the fuel source) and a

modelled scenario (i.e. with the introduction of AFR). From the results of this

study, it is anticipated that an impact of low significance on air emissions will

result with the introduction of an AFR programme at Kiln 3 at Dudfield plant. As

the emission levels are below the DEAT guidelines, the significance for baseline

conditions (for all pollutants of concern) was predicted to be low (refer to Table

5.4). Under proposed operating conditions (usage of alternative fuels), the

emissions remain below the DEAT guidelines. Therefore, the significance for all

pollutants of concern with the implementation of the proposed project at Dudfield

plant is predicted to remain low (refer to Table 5.4).

A detailed assessment of the potential impacts on air emissions associated with

the introduction of AFR at Dudfield is included within Chapter 6 and Appendix H.



Table 5.3: Summary of potential impacts on the water environment associated with the introduction of the AFR programme

Nature of impactassociated with theintroduction of anAFR programme

Extent Duration Severity Significance LikelihoodConfidence inassessment of

impact

Mitigation and/orEnhancement

Availability of waterresources in the area

Regional Long-term Slight NoneVery unlikelyto occur

High Not applicable

Quality of processwater for coolingpurposes

Localised Short-term Slight NoneVery unlikelyto occur High Not applicable

Off-loading, storageand handling of AFRmaterial

Localised Long-term Slight LowUnlikely tooccur

High

Construction of storage facility

according to construction

standards and monitoring of

quality of any leachate

produced

Table 5.4: Summary of potential impacts on air quality associated with Dudfield plant

Nature of Impact Extent Duration Severity Significance Likelihood

Degree of

certainty or

confidence

Impacts on air quality associated with the baseline study (a)

(for all pollutants of concern)Long term Localised Slight (b) Low (b) May occur (c) Probable

Impacts on air quality associated with the proposed usage of

alternative fuel (for all pollutants of concern)

Long term Localised Slight (b) Low (b) May occur (c) Probable

Notes:

(a) Routine operating conditions using Kiln 3, Cement Mill 1, Cement Mill 2.

(b) Based on criteria pollutants and screened against DEAT guidelines.

(c) Impacts are not constant as they depend on the meteorological conditions and dispersion potential of the atmosphere.



5.4.1. Conclusions

The investigation included the simulation of inhalable particulates, nitrogen

oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and

halogen compounds. For baseline conditions, measured emission values were

simulated in order to determine the current impact on the surrounding

environment. For proposed usage of alternative fuels, EC emission limits were

used to estimate emission rates.

The main conclusions may be summarised as follows:

• The inhalable particulate concentrations (PM10) were predicted to be below

the daily and annual average current DEAT as well as the EC and proposed

South African limits with highest offsite concentrations at 7 µg/m³ and

0,7 µg/m³ respectively for baseline conditions, and 0,3 µg/m³ and

0,57 µg/m³ respectively for predicted AFR use conditions (this excluded

fugitive emissions).

• Gaseous concentrations for NO2 (baseline conditions) did not exceed the

DEAT guidelines with highest predicted off site concentrations estimated to be

3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ for highest hourly, daily and annual

averaging periods respectively. NO2 ground level concentrations with

proposed AFR use were predicted to be 2,8 µg/m³, 0,5 µg/m³ and

0,02 µg/m³ for highest hourly, daily and annual averaging periods. These

concentration levels were below DEAT guidelines as well as EC and proposed

South African limits.

• NOx ground level concentrations for proposed operating conditions were

315 µg/m³, 60 µg/m³ and 2,43 µg/m³ for highest hourly, daily and annual

averaging periods respectively, well below the current DEAT guidelines.

• Predicted sulphur dioxide ground level concentrations were below the current

DEAT guidelines as well as the proposed South African and EC limits with

highest levels predicted to be 50 µg/m³1, 1,2 µg/m³ and 0,01 µg/m³ for

highest hourly, daily and annual averaging periods respectively for baseline

conditions and 20 µg/m³, 2,8 µg/m³ and 0,15 µg/m³ for highest hourly, daily

and annual averaging periods respectively for proposed conditions.

• Current and predicted (with AFR use) lead concentrations were insignificant

when compared to the EU limits respectively.

• Predicted ground level concentrations for non-criteria pollutants did not

exceed the effect screening or health risk criteria for current and proposed

operations.

• Carcinogenic pollutants for baseline conditions were estimated to cause less

than 1 in 1 million chance of cancer (trivial cancer risk criterion). For

1 Using the 98th percentile the predicted hourly value is 20 µg/m³. The predicted

50 µg/m³ was predicted from a peak incident during the monitoring campaign.



proposed conditions (with AFR use) all potential carcinogenic pollutants,

except hexavalent chromium were predicted to be below the 1 in a million

increased cancer risk criterion. Assuming all chromium to be hexavalent, the

estimated cancer risk ranged from 2,2 to 26 in 1 million (WHO unit risk

factors). However, hexavalent chromium is typically 10% of total chromium.

Thus, the incremental cancer risk using the WHO unit inhalation unit risk

factors would be 0,2 to 2,6 in a million. It is therefore broadly acceptable

(less than 1 in 100 thousand).

• Dioxins and furan concentrations were below the relevant guidelines for

current and proposed operating conditions.

• The significance rating for current and proposed operating conditions with

AFR use indicated slight severity due to predicted ground level concentrations

from criteria pollutants with localised, long-term impact.

• Based on the findings above it can be concluded that predicted ground level

impact from alternative fuel usage is similar to, and in some cases marginally

higher than (due to emissions based on EC limits) baseline conditions.

However the predicted impact for the usage of alternative fuel is well below

relative guidelines/limits.

5.4.2. Recommendations

• EC emission limits were used to quantify ground level impact from Kiln 3 with

the proposed usage of alternative fuels. It is recommended that a “trial

burn” be undertaken to verify EC emission limits used in the current study for

the proposed burning of alternative fuels. Pollutants of concern are typically

due to chronic exposures (e.g. dioxins and furans), hence a relatively short

exposure of a few days during a trial burn would have an insignificant impact.

• It is recommended that emissions be monitored once the proposed

operations have commenced and re-simulations undertaken if the order of

magnitude of these emissions is significantly different. This will be required

in order to quantify the ground level impact.

• EC limit allows NOx emission instead of NO2. Previous measurements at

Dudfield Plant indicated approximately 1% NO2 of NOx. This fraction may

however be as high as 10%. If the NO2 emissions were allowed at the EC

limit for NOx, the guidelines of NO2 would be exceeded. It is, therefore,

recommended that both NO2 and NOx be monitored for compliance.

• It is recommended that the hexavalent chromium fraction be determined.

• Although fugitive emissions were not important in establishing the impact of

the use of alternative fuels it is recommended to compile a source inventory

for these emissions to determine the significance of this source.

• An air quality management plan is recommended to improve and extent the

plant’s emissions inventory by:

∗ Undertaking stack (Kiln 3) monitoring following the initiation of the

proposed operations to confirm projected stack emission data.



∗ Identify and quantify all fugitive, diffuse and evaporative sources of

emissions.

5.5. Potential Traffic Impacts

The introduction of an AFR programme at Kiln 3 at Dudfield plant will require the

transportation of alternative fuel sources to the plant. This is proposed to be

undertaken via road, at a projected maximum rate of 6 truckloads per day. The

majority of traffic transporting AFR will access Dudfield plant via Lichtenburg.

Potential impacts associated with the transportation of AFR by road include

increased traffic volumes and potential delays for other traffic in the area,

impacts on the road surface and structure, and an increase in the heavy vehicle

traffic within the areas surrounding Dudfield plant.

Current access to the Dudfield plant is via Road D2095, approximately 3,5 km

from Road P183/1 (refer to Figure 5.2). The entrance is considered to be of

sufficient capacity for traffic entering the plant. The condition of the road at the

entrance is poor and requires rehabilitation.

Figure 5.4 depicts the possible two routes that trucks would be able to use for the

hauling of AFR material, to and from the Dudfield plant via Lichtenburg. The

condition of the roads utilised for the two routes are described below.

5.5.1. Condition of Roads outside Lichtenburg

• R52 to Mmabatho (P28/4)

This road serves as the link between Lichtenburg and Mmabatho. Road

P28/4 is a 7,4 m wide, two lane road with a 2 m gravel shoulder. Some

patchwork does occur on the road with isolated rutting and edge breaking at

entrances to farms and rural roads. Approximately 4 km from Lichtenburg on

route to Mmabatho, Road D933 intersects with Road P28/4 with a T-junction

to the west. This intersection is currently in a poor condition (refer to

Photograph 5.1). Despite these pavement defects, the road is currently in a

good structural and riding condition.



Photograph 5.1: Pavement damage at the intersection of Road 52 and D933

• Kapsteel Road (D933):

This road links Road D2059 with Road P28/4 between Lichtenburg and

Mmabatho (refer to Figure 5.3). This is a 7,4 m wide, two lane road with a

2 m gravel shoulder. The road was designed typically as a lightly trafficked

road with few heavy vehicles, i.e. tractors and trucks carrying maize and

sunflowers. The road, therefore, has a light pavement structure and some

failures and rutting does occur on certain parts along the road (refer to

Photograph 5.2). Despite these pavement defects the road is currently in

good structural and riding condition. However, this road is not suitable to

carry high volumes of heavy vehicle traffic due the design of the pavement.

Photograph 5.2: Pothole in a section of Kapsteel Road (D933)



Figure 5.3: Routes currently utilised to access Dudfield plant



Figure 5.4: Recommended routes for the transportation of AFR to Dudfield plant



• Road D2095:

This road links Roads D933 and P183/1 with each other and provides access

to the Dudfield plant. This is a 7,4 m wide, two lane road with a 2 m gravel

shoulder. The road is in a poor structural condition due to several pavement

defects like pumping, bleeding and potholes (refer to Photograph 5.3). The

intersections of this road with Roads D933 and P183/1 need rehabilitation

(refer to Photograph 5.4).

Photograph 5.3: Pumping in a section of Road D2095

Photograph 5.4: Pavement defects at intersection of Road D2095 and

D933



• Deelpan Road(P183/1):

This road runs between Deelpan and Lichtenburg and provides access to

Dudfield plant via Road D2095. This is a 7,4 m wide, two lane road with a

2 m gravel shoulder. The section of the road between Road D2095 and

Lichtenburg is severely rutted with potholes and structural failures that pose

a safety hazard to road users (refer to Photograph 5.5). This road was

originally designed to carry heavy vehicle traffic, but is near to the end of its

20-year design life and will be rehabilitated in the near future (C Davis, pers

comm., 2004).

Photograph 5.5: Structure Failure on Road P183/1

5.5.2. Condition of Roads within Lichtenburg

• Buiten Street

This road is one of the major streets in Lichtenburg and is currently utilised

by light vehicles as well as heavy vehicles. Traffic signs at the entrance to

the town regulate that all heavy vehicles must travel via Buiten Street

through Lichtenburg to various destinations. This road is an 8 m wide, two

laned with 2 m surfaced shoulders. The travelling width of the road was

resealed recently and is in a good condition. This street is mainly regulated

by stop signs, except at the intersection with Buchanen Street where traffic

lights regulate the movement of traffic.

• Swart Street

This is an 8 m wide, 2-lane road that leads to Road P28/4 to Mmabatho. This

road is in good riding condition.



• Republiek Street

This is an 8m wide, 2-lane road that leads to Road P183/1 and is in good

riding condition.

• Roads P24/8, D933 and associated streets within Lichtenburg:

These roads are of good riding quality and structural condition. Roads

P183/1 and D2095 are currently the preferred access roads to the Dudfield

plant. These roads are near the end of their design life and in need of

rehabilitation from the North West Province Roads Department. According to

the Department (C Davis, pers comm., 2004), these roads are not listed as

roads projects for the year 2004, but may be included within the next 5-year

project list depending on the outcome of their project prioritising procedure.

5.5.3. Existing Traffic

If a single phase development adds less than 500 trips per peak hour to the road

network it is advised by the Traffic Impact Study (TIS) Manual that only the base

year (year development is lodged) traffic is assessed to determine the impact of

new trips on the road network. In this TIS, a worst-case scenario of 6 new trips

per day has been assumed to be added to the road network and thus an

assessment of the current (2004) traffic situation is considered to be sufficient.

In order to measure the impact of the new trips on the existing situation, the

existing traffic classification and volumes were analysed. The process of

obtaining the existing traffic volumes included the counting of the traffic on a

normal day at different locations within the study area (a normal day can be

described as a day that is not a public holiday and one of the following days

Tuesday, Wednesday or Thursday). The traffic was, furthermore, classified as

light and heavy vehicles to estimate the type of delay caused for road-users.

Light vehicles are passenger vehicles (cars) and heavy vehicles are vehicles with

more than three axles.

A twelve-hour daytime classified traffic count was conducted on in July 2004 at

three counting stations (refer to Figure 5.4). The existing twelve-hour traffic

volumes are indicated in Table 5.5.

Table 5.5: Existing (2004) 12-hour traffic counts

Road P28/4 P183/1 Buiten Str

Direction E/W W/E E/W W/E S/N N/S

Light Vehicles 110 124 351 394 1168 1486

Heavy Vehicles 67 76 68 93 571 324

Total Vehicles 177 200 419 487 1739 1810

Percentage

Heavy Vehicles38% 38% 16% 19% 32% 18%



According to the Highway Capacity Manual, roads utilised as routes to access the

Dudfield plant operate at a maximum traffic volume of 1 700 cars per hour per

direction, or 3 200 cars per hour for both directions under ideal conditions. If

these volumes are compared to the existing traffic volumes in Lichtenburg it is

evident that the daily traffic volume on all roads can be described as light, and

thus operating far below the optimum (20 400 cars per 12-hour period). The

traffic volume on Buiten Street is, as expected, higher due to through-traffic from

Gauteng and it is also a local collector road that carries higher volumes of light

traffic. If 6 trucks carrying AFR to Dudfield plant are added to the road system in

a 12-hour period, the traffic will increase by 1,5%. These roads are considered to

have sufficient spare capacity to accommodate these trips in a 12-hour period

without an impact.

From Table 5.5 it is evident that the roads surrounding the Dudfield plant are

carrying high (16-38%) proportions of heavy vehicles if compared to the norm for

rural roads in South Africa that ranges between 15 – 20% of all traffic. This is

due to the opening of the Platinum Toll Highway and the resulting heavy vehicles

detouring through Lichtenburg en route to Mafikeng. This high volume of heavy

traffic can result in a higher than normal delay on the roads surrounding the

plant. However, as the additional trucks associated with the introduction of AFR

at Dudfield plant result in a 1,5% increase in traffic, it is not anticipated that the

delay factor associated with these additional vehicles will be significant.

The heavy vehicles currently travelling to the Dudfield plant arrive from various

destinations in South Africa and are in the order of 23 vehicles per day. These

vehicles travel directly to the plant or via Lichtenburg. The proportion of the

vehicles travelling via Lichtenburg is in the order of 90%, with only 10%

travelling directly to the plant (i.e. not from the Lichtenburg area).

The number of heavy vehicles that utilise the route via P183/1 from Lichtenburg

to the Dudfield plant is approximately 16 vehicles per day, with only 4 vehicles

per day accessing the plant via P24/8. The route via P183/1 is currently the

preferred route, despite its current pavement condition.

The addition of 6 trucks on the route via P183/1 will result in a 1% increase in the

traffic volume. This is a very small growth in traffic and is considered to be

insignificant.

5.5.4. Structural Capacity Analysis

The cumulative damaging effect of all individual axle loads on a road pavement is

expressed as the cumulative number of equivalent 80 kN single-axle loads

(E80s). A road is usually designed in accordance with an estimate of the

cumulative equivalent traffic over the road structure (pavement) during a certain



design period. This design period is usually 20 years. If new unexpected traffic is

added to a road, the influence of the new E80s in proportion to the design E80s

as well as the E80s the road already carries are required to be compared.

Roads D2095 and D933 were typically designed to carry between 300 000 to

1 million E80s over a period of 20 years. Converted back linearly to a daily

loading, this corresponds with 46 – 137 E80s/day. If an additional 6 trucks are

added at an average of 2,56 E80s per truck, the extra daily loading is estimated

to be 15,4 E80s/day. This will result in an increase of 11 – 33% in current E80s.

From a visual assessment of the condition of the two roads utilised to access

Dudfield plant, it is estimated that these roads will be required to be rehabilitated

within the next 10 years as their remaining life of the pavement is in the order of

300 000 E80s. If the additional 6 trucks are added at an average of 2,56 E80s

per truck for 20 days a month over the next 10 years of the remaining life of the

pavement, a total of approximately 50 000 E80s will be added to the total

expected loading on these road pavements. This equates to an increase of 17%

of the loading, which is considered to be significant, but still acceptable

considering the existing load.

Typically, roads such as P183/1 and P28/4 are designed to carry between

1-3 million E80s during a 20-year design life. The impact of the additional 6

trucks associated with the introduction of AFR at Dudfield plant will, therefore, be

acceptable on these roads.

5.5.5. Assessment of Potential Impacts

Potential issues identified through the analysis of the impact of 6 additional trucks

required to haul AFR to the Dudfield plant can be summarised as follows:

• Growth in traffic volume and delay

• The impact on the road structural capacity

• Growth in heavy vehicle traffic.

The result of each assessment is provided in Table 5.6 and can be quantified as:

• Growth in traffic volume and delay: The growth in traffic volumes will

definitely occur and will be permanent unless the hauling of alternative fuels

by road is stopped. A slight delay in travelling time is anticipated for all road

users travelling to and from Lichtenburg via the routes used for hauling of AFR

to Dudfield plant.

• The impact on the road structural capacity: The addition of the extra trucks

will cause slight damage (E80s) to the road structure. This slight damage to

the road can be accommodated, as calculated in the structural capacity



analysis. This is based on the premise that overloading of trucks will not be

allowed. The roads affected by the additional trucks are P183/1 and D2095

that represent the preferred route to carry AFR to Dudfield plant.

• Growth in heavy vehicle traffic: The growth in heavy vehicles will result in a

higher delay factor. The rise in the factor is very low and due to a currently

low factor on these roads, the rise will not be noticeable to the average road

user.

5.5.6. Conclusions and Recommendations

The conclusions and recommendations of this TIA are summarised as follows:

• With the extra waste trucks operating on the road network the delay factor

will rise by an acceptable percentage. The potential impact associated with

this rise is anticipated to be of low significance.

• With the operation of the extra 6 waste trucks on the road network there will

be a growth of 1,5% in the heavy vehicle volumes. This is a low impact of

low significance to the overall network.

• The loading (E80s) added by the 6 waste trucks on Road P183/1 is of an

acceptable level.

• Policies must be in place to ensure compliance with all relevant legislation

and requirements pertaining to the transport of goods by road, in particular

the loading of the vehicles.

• Road P183/1 is near the end of its structural design life. It is advised that

the rehabilitation of the road be incorporated into the budget of the North

West Province, Roads Department budget for the next 5 years.

• The preferred route to haul waste to the Dudfield plant via Lichtenburg is

along Buiten Street, Republiek Street, Roads P183/1 and D2095. This is

currently the route utilised by traffic travelling to Dudfield plant.

5.6. Potential Impacts on the Social Environment

The purpose of the Social Impact Assessment (SIA) is to provide a systematic

analysis in advance of the likely impacts a development event (or project) will

have on the day-to-day life of persons and communities. SIAs are undertaken to

assist individuals, communities, as well as government organisations to

understand and be able to anticipate the possible social consequences on human

populations and communities of proposed project development or policy changes.

It also serves to identify the potential for social mobilisation against the project,

identifies social impacts that cannot be resolved and variables that will need to be

addressed by avoidance or mitigation.



Table 5.6: Assessment of potential traffic impacts associated with the introduction of AFR at Dudfield plant

Issues Road Extent Duration Severity Significance Risk/Likelihood

P28/4 Slight

P183/1 Slight

D2095 Slight

D933 Slight

Swart Street Slight

Republiek street Slight

Growth in Traffic Volume

Buiten Street

Localised Long Term

Moderately Severe

Low Will Definitely occur

P28/4 Slight

P183/1 Moderately Severe

D2095 Moderately Severe

D933 Moderately Severe

Swart Street Slight

Republiek street Slight

Impact on the road structural

capacity

Buiten Street

Localised Long Term

Slight

Low Will Definitely occur

P28/4

P183/1

D2095

D933

Swart Street

Republiek street

Growth in Heavy Vehicle Traffic

volume

Buiten Street

Localised Long Term Slight Low Will Definitely occur



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

• “a process aimed at identifying the future consequences for human

populations of any public or private action that alters the way in which people

live, work, play, relate to one another, organise to meet their needs, and

generally cope as members of society” (Becker, 1999).

• “(an investigation into) the potential change in the activity, interaction and/or

sentiment of the community, as it responds to the impacts resulting from the

alteration in the surrounding social and biophysical environment” (adapted

from Burdge, 1995).

Both definitions highlight fundamental characteristics of the social environment

and the necessity to consider impacts on the individual per se, as well as impacts

on the individual in interaction with the social and biophysical environment. The

social impact assessment variables that were applied for the purposes of the

study (see below) served to elicit information regarding both these aspects.

5.6.1. Methodology

• Scope of the SIA

The SIA was conducted as per the requirements of the EIA regulations

(DEAT, 1998). The Social Impact Assessment contains ten steps that are in

logical sequence (although the implementation often overlaps). This

sequence is patterned on the steps associated with Environmental Impact

Assessment, and include:

∗ obtaining a description of the proposed action, with enough detail to

allow the identification of key data requirements needed from the project

proponent to frame the SIA;

∗ the compilation of a description of the relevant human environment in

which the project activity is to take place, as well as historic and existing

baseline conditions;

∗ the identification of probable impacts (issues and concerns);

∗ an investigation of the probable social impacts including a projection of

estimated effects (duration, intensity, probability and significance);

∗ the determination of the probable response of affected parties

(probability, nature and intensity of social mobilisation); and

∗ the formulation of potential mitigation measures.

The scope of the SIA investigation is based on the SIA variables developed by

Burdge (1995).



• Social Impact Assessment Variables

Social Impact Assessment variables serve to explain the consequences of

specific developments and, as such, do not relate to the total social

environment. The following variables were assessed (Burdge, 1995) on the

basis that they reflect probable social impacts:

∗ Formation of attitudes and perceptions;

∗ Disruption in daily living and movement patterns;

∗ perceptions of public health and safety;

∗ community infrastructure needs;

∗ local impacts and regional benefits; and

∗ intrusion impacts.

Only variables considered to be relevant to this study were assessed, based

on, inter alia, factors relating to the probability of the events occurring and

the number of people impacted upon.

• SIA Data Sources

Information gathered and social issues identified and verified during the

public participation process undertaken as part of the Environmental Impact

Assessment served as key input to the SIA. The Issues Trail (refer to

Appendix F) was a primary data source and included information gathered

during focus group meetings, public meetings and individual consultation

sessions held with stakeholders and I&APs.

The findings from other specialist studies were considered within the

evaluation of social impacts, and served to place the impacts as perceived by

I&APs into perspective, thus facilitating a more accurate rating of impacts.

5.6.2. Formation of Attitudes and Perceptions

Stakeholder perceptions regarding the introduction of an AFR programme at Kiln

3 at Dudfield plant vary greatly. Some stakeholders have expressed concerned

about potential health or environmental impacts from the handling and

combustion of alternative fuels, whilst others are concerned that the quality of

the product may be compromised. The comment has also been raised that the

use of waste and by-products as a fuel will perpetuate the production of these

wastes and by-products in the long-term by offering a legal, cost-effective

alternative to disposal. On the other hand, some stakeholders note the potential

benefits associated with this technology through the reduction in the production

of greenhouse gas emissions and an alternative disposal method for waste and

by-products through use as AFR.



In response to these comments, which have also been widely raised throughout

the world, Holcim has undertaken extensive technical work and environmental

studies together with institutional bodies such as the United States Environmental

Protection Agency (US EPA) in order to investigate and minimise the potential

adverse effects on human health, the environment or product quality as a result

of the use of AFR. Through these studies, the cement industry has been more

successful than any other in reducing its emissions (particularly in terms of

dioxins and furans (www.ckrc.org/ncafaq.html)) and thus its impact on human

health and the environment. In addition, the US EPA has confirmed that the use

of AFR within the cement manufacture process does not increase risks posed to

end users of cement.

5.6.3. Disruption in Daily Living and Movement Patterns

The disruption in daily living and movement patterns refers to the disruption in

activities of residents as a result of project-related activities. Heavy vehicle

movement associated with the transportation of AFR to the Dudfield plant has the

potential to disrupt the daily movement patterns of the local population

(particularly residents in Lichtenburg, the Dudfield village and surrounding

farming communities). However, as detailed in Section 5.5 above, a long-term

scenario of an additional 6 trucks per day transporting AFR to Dudfield plant is

anticipated. This will result in a 1% increase in the traffic volume on the access

routes to Dudfield plant. This is a very small growth in traffic and is considered to

be insignificant.

In addition, the area surrounding Dudfield plant is sparsely populated, typical of a

rural farming community. Population density for Lichtenburg and surrounding

areas is approximately 9 883, and 27 891 for Itsoseng and surrounding areas (as

per the 1996 census, Mr Israel Motlhabane pers. comm.). These centres are,

however, approximately 20 km away from the Dudfield plant. The greatest



approximately 1 km south-west of the plant.

Therefore, the potential impact associated with disruption in daily living and

movement patterns as a result of this additional traffic is not considered to be

significant.

• Mitigation Measures:

In order to minimise potential impacts associated with additional heavy

vehicle movement for the transport of AFR to Dudfield plant, specified routes

(refer to Figure 5.4) should be utilised by vehicles transporting AFR to

Dudfield plant.



In addition, the feasibility of utilising the empty AFR transport trucks leaving

Dudfield plant to transport the cement product from the plant should be

investigated. This may result in a reduction in the total number of heavy

vehicles required at Dudfield plant.

5.6.4. Impact on Infrastructure and Community Infrastructure Needs

Heavy vehicles required for the transportation of AFR to Dudfield plant have the

potential to impact on local road infrastructure. However, as detailed in Section

5.5 above, an increase of 17% of the loading on the road surface is anticipated as

a result of the introduction of these vehicles. This is considered to be a

significant increase, but is still acceptable considering the existing load.

Coal is currently transported to Dudfield plant via railway. This fuel source will

continue to be supplied to the plant in this manner. The potential to utilise the

existing railway to transport AFR in the future will be investigated. However, in

the short-term, this is not considered to be a viable option as the AFR sources will

vary in geographical location.

Dudfield plant is supplied with electricity via a dedicated substation. With the

introduction of the AFR programme at Dudfield plant, the kiln will continue to

operate at capacity. The current power supply to the plant is sufficient for the

operation of the plant with the introduction of the AFR programme and no

additional supply will, therefore, be required. Therefore, no impact on the

electricity supply to the surrounding areas is anticipated as a result of the

proposed project.

Water volumes utilised within the cement manufacture process will not be

required to be increased with the introduction of the AFR programme. Holcim will

continue to abstract and utilise water in terms of their existing water permits.

Therefore, no impact on the available water resources for the surrounding area is

anticipated as a result of the proposed project.

• Mitigation Measures:

In order to minimise potential impacts on road infrastructure as a result of

additional heavy vehicle movement for the transport of AFR to Dudfield plant,

specified routes (refer to Figure 5.4) should be utilised. The routes which

have been recommended are those which are currently utilised by all traffic

to access Dudfield plant.



5.6.5. Health and Safety Impacts

• Potential Safety Impacts associated with Additional Road Traffic

Heavy vehicle movement associated with the transportation of AFR to the

Dudfield plant has the potential to impact on road-users and road safety

conditions. However, as detailed in Section 5.5 above, it is anticipated that

the additional vehicles associated with this transportation of AFR will result in

a 1% increase in the traffic volume on the access routes to Dudfield plant.

This is a very small growth in traffic, which is not anticipated to impact

significantly on road-users or road safety conditions.

With the transportation of AFR to Dudfield plant, the potential exists for

accidents and spillage of the fuel source. Without the implementation of

appropriate mitigation measures and the following of appropriate emergency

procedures, this could potentially impact significantly on road users and the


• Air/Dust Emissions

The potential impacts associated with increases in dust and dioxin levels as a

result of the proposed introduction of AFR at Dudfield plant have been raised

as a concern as they may pose a health risk to local communities. Dust

levels have, however, decreased with the recent implementation of bag filters

at Dudfield plant. A specialist air quality assessment study was undertaken

to evaluate this potential impact (refer to Section 5.4 and Chapter 6) and

indicates an impact of low significance as a result of the proposed AFR

project.

• Potential Safety Impacts for Employees Handling AFR

The introduction of AFR at Dudfield plant will require the handling of

hazardous substances by employees, which may potentially impact on the

health of these employees. However, strict handling procedures will be

implemented at Dudfield plant with the introduction of AFR and employees

will be adequately informed and trained with regards to these procedures.

Therefore, the potential health impact on employees handling hazardous

substances is anticipated to be of low significance.

• Mitigation Measures

∗ In order to minimise potential impacts on road users and road safety

conditions as a result of additional heavy vehicle movement for the

transport of AFR to Dudfield plant, specified routes (refer to Figure 5.2)

should be utilised.

∗ In the case of an accident or spillage, the first concern is for preservation

of human life and well-being. If the driver is alive and able, he should

vacate the vehicle as fast as possible. Damage and danger should be



assessed rapidly. Sufficient information should be given to helpers in

order to get response from emergency services, if required. The driver

should use the vehicle’s communication system, if it is safe to do so, to

relay information to the control centre with regard to the

accident/spillage and they should then in turn notify all relevant parties.

∗ Mitigation measures relating to potential air pollution impacts and

monitoring of air quality by Holcim are addressed in detail within the air

quality specialist report (refer to Chapter 6). In order to ensure that the

potential health impacts associated with air emissions are minimised, it

must be ensured that these mitigation measures are implemented.

∗ Mitigation measures relating to the implementation of appropriate

handling procedures for AFR at Dudfield plant are addressed in detail in

the waste management specialist study (refer to Chapter 7). Specific

mitigation measures relating to the health and safety of employees which

should be implemented include:

- The nature of the facility and its associated activities calls for a

comprehensive training programme for all employees involved in the

handling of waste.

- The employees must undergo thorough medical examinations on an

annual basis. These tests must be specific to the type of work an

employee is doing and the hazards to which that employee is

exposed. Pre-employment and exit medicals are also essential to

ensure that the employee’s health has not been affected by his job.

- Detailed job analyses must be carried out to determine all tasks and

what they involve. This forms the basis of the training needs

analysis, as well as the type of medical tests required. It also

determines what safety precautions need to be taken and the type of

Personnel Protective Equipment to be issued.

5.6.6. Local Impacts and Regional Benefits

The Holcim South Africa Dudfield plant is one of two cement manufacturing plants

in the area. Limestone mining and cement manufacture are two of the major

economic activities currently undertaken in the area, providing employment to

members of the local community. The continued operation of the Dudfield plant

in an environmentally and economically sustainable manner will secure these



5.6.7. Intrusion Impacts

The greatest population density in the immediate area surrounding the plant is

Dudfield Village, where approximately 200 people reside. The village is located

approximately 1 km south-west of the plant. Impacts on or the disturbance of



this community already exist, and have done so since the initial construction of

the facility more than 50 years ago. Potential intrusion impacts associated with

the introduction of an AFR programme at Dudfield plant include:

• air quality impacts,

• visual impacts,

• noise impacts,

• impacts associated with increased heavy traffic, and

• impacts on ground and surface water and soil as a result of the storage of

fuel or potential accidents and spillage.

Results from other specialist studies have indicated that potential intrusion

impacts on air quality, traffic and water resources associated with the

introduction of the AFR programme at Kiln 3 are anticipated to be of low

significance. In addition, as the proposed project will be undertaken within the

boundaries of the existing Dudfield plant and will not require any additional

changes to the plant, no impacts are anticipated in terms of visual intrusion

impacts. The change in technology proposed (i.e. the use of AFR as a fuel

source) will not alter the current noise levels associated with the plant. The

primary source of noise at Dudfield plant is from the fans. Therefore, potential

intrusion impacts of anticipated to be of low significance.

A summary of the significance of the potential impacts on the social environment

as a result of the introduction of an AFR programme at Dudfield plant is provided

in Table 5.7.

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

Resource

In order to generate the high temperatures required for cement manufacture,

large quantities of fuel are required to achieve and maintain kiln temperatures.

The use of waste derived alternative fuels can reduce the reliance of a kiln on a

natural resource while providing an effective method for managing waste

materials. In order to reduce their reliance on non-renewable fuel resources and

provide an innovative waste management solution Holcim South Africa has set an

initial goal of replacing a minimum of 35% of the coal used by Kiln 3 at the

Dudfield Plant with alternative waste derived fuels. Cement kilns are

acknowledged as being able to provide an ideal environment for the complete

combustion of waste derived fuels due to the very high temperatures (up to

2000oC), long solid residence time (up to 30 minutes), long gas residence times

(of 4 to 8 seconds), and the large excess of oxygen used.



Table 5.7: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at Dudfield

plant

Nature of impact

associated with the

introduction of an

AFR programme

Extent Duration Severity Significance Likelihood

Confidence in

assessment of

impact

Mitigation and/or

Enhancement

Disruption in daily

living and movement

patterns

Localised Long-term Slight NoneUnlikely to

occurProbable

Utilisation of specified routes by

vehicles transporting AFR to

Dudfield plant and the

investigation of the feasibility

of utilising the empty AFR

transport trucks leaving

Dudfield plant to transport the

product from the plant.

Impact on

infrastructure and

community

infrastructure needs

Localised Long-term Slight LowUnlikely to

occurProbable



Dudfield plant.

Health and safety

impacts – road safetyLocalised Long-term Severe High

Unlikely to

occurProbable



Dudfield plant, as well as the

implementation of appropriate

emergency response

procedures.Health and safety

impacts – air

emissions

Localised Long-term Slight Low May occur Probable



Table 5.7 cont: Summary of potential impacts on the social environment as a result of the introduction of an AFR programme at

Dudfield plant

Nature of impact

associated with the

introduction of an

AFR programme

Extent Duration Severity Significance Likelihood

Confidence in

assessment of

impact

Mitigation and/or

Enhancement

Health and safety

impacts – employees

handling AFR

Localised Long-term Severe High May occur Probable

Appropriate training and

regular medicals should be

provided. Job analysis should

be undertaken on a regular

basis.

Local impacts and

regional benefitsRegional Long-term Severe High (positive) Will occur Probable

Intrusion impacts Localised Long-term Severe Low May occur Probable

Appropriate mitigation for

potential air quality impacts,

traffic impacts and impacts on

water resources, noise impacts

and visual impacts.



During the development of the National Waste Management Strategy by the

Department of Environmental Affairs and Tourism (DEAT; 1998), cement kilns

were identified as facilities that could effectively utilise waste materials such as

tyres, refuse derived fuel (RDF), hydrocarbon wastes and selected hazardous

wastes as fuels. Utilisation of materials that are normally designated as wastes

as a fuel or alternative feedstock for cement manufacture meets a number of

national strategic goals, including the beneficial use of wastes, conservation of

natural resources such as coal and reduction of the amount of waste being

disposed to landfills.

There are currently no formal regulatory requirements specific to the use of wasre

derived alternative fuels and resources (AFR) in cement kilns. Without

application specific standards and specifications to govern the use of AFR, the

approach has been to adopt the applicable waste standards, specifications and

procedures. This has been done to ensure that the most stringent of measures

are implemented in the utilisation of alternative fuel and resources. The

management procedures fall under the Duty of Care requirements that are

included in National Environmental Management Act (No 107 of 1998), the

Environment Conservation Act (No 73 of 1989), and the Department of Water

Affairs and Forestry’s Minimum Requirements.

Kiln 3 at the Holcim South Africa Dudfield plant has recently been upgraded and

is able to accept and process a variety of fuels. These fuels could include a wide

range of wastes both hazardous and non-hazardous. The fuels can occur in

varying forms including solid, sludge, liquid and gas states. The use of waste,

both as alternative fuels and as raw materials, introduces new challenges for the

cement plant and issues related to the transport, handling, storage and use of the

waste must be strictly controlled to ensure that any risk to the environment and

human health is appropriately managed. However, the classification, handling,

storage and transport of hazardous materials are well understood and are strictly

controlled by current legislation and the environmental authorities. The adoption

of the sound management techniques will ensure that any potential risks to

health, safety and the environment are kept within acceptable levels.


a 'cradle to grave' approach, this means that it is the responsibility of Holcim
















• Documentation



• Transportation


• Offloading



Chapter 7 provides an assessment of the suitability and the risks associated with

the proposed introduction of an alternative fuels and resources (AFR) programme

at Dudfield's Kiln 3, and defines the management procedures that would be

required to be implemented by Holcim South Africa (with details of these

procedures provided in Appendix I).

5.7.1 Risks and Significance of Risks

The potential risks associated with the use of AFR in the manufacture of cement

are included in Table 5.8 together with an assessment of the significance of the

risks posed by natural events, technical problems and human error.



Table 5.8: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human

Error

Aspect Risk Extent Duration Severity Probability Significance

Process

Waste Pre-

acceptance

Incorrect analysis or interpretation

of results could lead to incompatible

waste being accepted by facility.

Local Short term Slight Unlikely Low

Waste

Collection

Poor collection practices could lead

to minor spills.

Local Short term Moderate Unlikely Low

Transport Accidents could lead to spillage of

material.

Local Short term Severe Unlikely Low

Waste

Receiving

Area

Poor off-loading practices could lead

to minor chemical spills.


Waste

Acceptance

Incorrect check analysis or

interpretation of results could lead

to incompatible waste being

accepted by facility.

Local Short term Slight to

Moderate

Unlikely Low

Waste

Storage

Incompatible waste stored or

flammable waste incorrectly

managed could lead to risk of fire or

explosion.

Local Short term Severe Very Unlikely Low to Moderate

Gas Storage Improper storage of the flammable

gas could lead to fire or explosion.


Utilisation of

AFR

Poor operation of the plant could

lead to incomplete combustion.

Local Short term Moderate Very Unlikely Low to Moderate

Products

from the

Kiln

Contaminated clinker and cement

products entering the market.

National Long term Severe Very Unlikely Low




Natural Events

Flooding Flood water may enter waste

storage areas.

Local Short term Severe Very Unlikely Moderate

Fire Fire within the facility would lead to

considerable risks to plant personnel

inside the facility.

Local Short term Very severe Very Unlikely High


considerable risks to the

environment outside the facility.


High Winds High winds could disperse pollutants

into the environment.

Local or

Regional

Short term Moderate Very Unlikely Low

Human Error

Data Entry

Error

Incorrect data could be provided by

the client or be input into the

database.


Unauthorise

d Access

People could gain unauthorised

access and exposed to potentially

hazardous materials.

Local Short to long

term

Severe Unlikely Low

AFR Spills Chemical spills could result in

contamination of soil and water.

Local Short term Severe Very Unlikely Low



5.7.2 Recommendation on the determination of suitable AFR












There are a variety of products or wastes that should not be processed or utilised













batteries etc.).


In addition, some waste streams could be an acceptable fuel, but require pre-

treatment before they would be acceptable for use at the kiln. This pre-

treatment would not be undertaken at Dudfield plant.

Limits of elements have been defined in order to avoid potential risks to human

health and the environment, and have taken the following criteria into

consideration:

• The formation of highly volatile compounds.

• High chloride concentrations.

• The cumulative levels of elements in other input materials.



• The oxidation of some elements to their higher oxidation states. For example,

if an excessive amount of chromium is present in the kiln feedstocks, then the

potential exists for the oxidasation to chromium (VI) and lead to a product

that leaches this relatively mobile species.

Bearing the above criteria and assessment in mind, Holcim has produced a list of

wastes that are deemed unacceptable for AFR purposes. In terms of the Holcim

Group AFR Policy (Holcim Ltd, 2004), these unacceptable wastes consist of the

following:




treatment)


• Whole batteries



• Mineral acids



Wastes that are acceptable as AFR for use by Kiln 3 should be delivered directly

to Dudfield plant. The suitable waste streams could include other non-hazardous

and hazardous wastes such as, but not limited to:

• Scrap tyres

• Rubber

• Waste oils

• Waste wood

• Paint sludge

• Sewage sludge

• Plastics

• Spent solvents

Of particular concern in South Africa is the disposal of scrap tyres to landfill.

Government is presently promulgating legislation to discourage the inappropriate

disposal of scrap tyres. As the number of scrap tyres generated in South Africa is

estimated at ~10 million per annum, with only ~2 million being used to produce

recycled rubber and recycled products the need for an appropriate disposal

method is critical. The use of scrap tyres as an alternative fuel offers an

environmentally acceptable and cost effective option of managing the scrap tyre

problem in South Africa, as the landfilling of scrap tyres is no longer an

acceptable practise.




the feed is preferably required to be of an appropriate volume in order to supply a









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 inorganic materials.

• Conservation of non-renewable resources such as fossil fuels, i.e. coal and

oil, and inorganic materials such as iron ore.

• Reduction in landfill facilities required for the disposal of potentially polluting

materials and an overall reduction in waste volumes to landfill.


Assessment of Potential 31-Aug-04Impacts on Air Quality

82

6. ASSESSMENT OF POTENTIAL IMPACTS ON AIR QUALITY

6.1. Introduction

Typical air pollutants from cement manufacturing include sulphur dioxide (SO2),

oxides of nitrogen (NOx), inhalable particulates (PM10), heavy metals, organic

compounds and dioxins and furans. The objective of the air pollution impact

assessment was to provide best estimates of air concentrations associated with

the introduction of AFR at Dudfield plant.

Specialist investigations conducted as part of an air quality assessment typically

comprise two components, viz. a baseline study and an impact assessment study.

The baseline study includes the review of the site-specific atmospheric dispersion

potential, relevant air quality guidelines and existing ambient air quality in the

region. In this investigation, use was made of readily available meteorological

and air quality data recorded for the region in the characterisation of the baseline

condition.

In assessing the impact associated with the operations at the site, an emissions

inventory was compiled, atmospheric dispersion simulations undertaken, and

predicted concentrations evaluated. The evaluation of simulated concentrations

was based on available ambient air quality standards/guidelines. The comparison

of predicted concentrations with ambient air quality guidelines facilitated a

preliminary assessment of health risks. If concentrations were found to be

unacceptable in terms of such guidelines, a comprehensive quantitative health

risk assessment (based on exposure quantification and dose-response analysis)

was recommended.

A baseline study of the Dudfield Plant was investigated in a previous study

(Burger & Thomas, 2003) under normal routine operating conditions where coal

was used as an energy source. This study has subsequently been updated with

more recent monitored data from C&M Environmental Engineering to more

accurately reflect the associated impacts (refer to Appendix C of the Air Quality

specialist report contained in Appendix H for more detail).

6.2. Terms of Reference

The terms of reference required to assess the impact of air pollution emanating

from the proposed operations, were as follows:

• To obtain and analyse local meteorological data (e.g. wind speed, wind

direction and ambient temperature);

• To identify all pollutants resulting from the use of alternative fuels;



83

• To quantify all significant pollutants resulting from the use of alternative

fuels, including case studies based on local and international emission limits

(e.g. EC Directive);

• Predict the highest hourly, the highest daily, and the annual average ground

level concentration levels;

• Analyse the predicted air concentrations both for compliance and potential

health risks;

• Prepare a significance-rating matrix; and

• Recommend an air quality management plan.

6.3. Methodological Overview

An emissions inventory was established for the proposed sources of emissions at

Dudfield. Such an inventory comprised the identification and quantification of all

significant sources. As inadequate quantifiable emission data was available,

emission limits applicable to similar operations elsewhere were employed.

Once the emission rates were known, mathematical dispersion modelling was

used to predict the dilution and transport of the released substance at various

distances from the sources. The US EPA approved Industrial Source Complex

Short Term (version 3) model (ISCST3) was used to simulate gaseous and

particulate concentrations due to site activities. ISCST3 is a steady state

Gaussian Plume model, which is applicable to multiple point, area and volume

sources.

Detailed hourly average wind speed, wind direction and temperature data was

obtained form the Lichtenburg Weather Service Station for the period January

1996 to August 2001. Detailed meteorological data is a necessity for the

assessment of the atmospheric dispersion potential of the study site.

6.4. Baseline Study

A detailed discussion of the regional climate and atmospheric dispersion potential

is given in Appendix A the Air Quality specialist report contained in Appendix H.

6.4.1. Local Wind Field

Wind roses comprise 16 spokes, which represent the directions from which winds

blew during the period. The colours in the wind rose reflect the different

categories of wind speeds, with the grey area, for example, representing winds of

1 m/s to 2 m/s. The dotted circles provide information regarding the frequency

of occurrence of wind speed and direction categories. For the current wind roses

(Figure 6.1), each dotted circle represents a 5% frequency of occurrence. The



84

figure given in the centre of the circle described the frequency with which calms

occurred, i.e. periods during which the wind speed was below 1 m/s.

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

Annual and monthly wind roses effectively reflect the synoptic systems affecting a

region. In order to investigate the impact of meso-scale circulation patterns it is

also essential to consider the diurnal variations in the wind field at the site. The

typical diurnal variations in the wind regime are evident in the day- and night-

time wind roses illustrated in Figure 6.1.

The spatial and diurnal variability in the wind field is clearly evident in the figure.

The wind dominates from the north with a 20% frequency of occurrence for the

total period. Increased wind frequencies for northerly winds of 5-10 m/s are



85

noted for daytime hours with calm periods of 2,4% occurring for the period

January 1996 – August 2001. Nocturnal airflow is characterised by less frequent

strong winds (5-10 m/s) from the north and more frequent moderate winds

(2-4 m/s). Night time conditions have an increase in calm periods (8,2%) as is

typical of the night time flow regime in most regions.

6.4.2. Impact Assessment at Holcim-Dudfield Under Current Operating

Conditions

Appendix C of the Air Quality specialist report contained in Appendix H provides a

comprehensive discussion on the baseline (current operating conditions) impact

assessment undertaken for the Dudfield Plant.

The main conclusions from this study may be summarised as follows:

• The inhalable particulate concentrations (PM10) were below the daily and

annual average current DEAT as well as EC and proposed South African limits

with highest off-site concentrations at 7 µg/m³ and 0,7 µg/m³ respectively;

• Gaseous concentrations for nitrogen dioxide did not exceed the DEAT

guidelines with highest predicted off-site concentrations predicted at


averaging periods respectively;


DEAT guidelines as well as the proposed South African and EC limits,

measuring 50 µg/m³1, 1,2 µg/m³ and 0.01 µg/m³ for highest hourly, daily

and annual averaging periods respectively;

• Highest predicted hourly carbon monoxide ground level concentration was

less than 0,1% of the current and proposed South African guidelines of

40 000 µg/m³ and 30 000 µg/m³ respectively;

• Predicted lead concentrations were insignificant when compared to the

current guidelines and EU and proposed South African limits;

• Predicted benzene concentrations are below proposed SA limits;

• Non-criteria pollutants are all below the screening levels and health risk

criteria;

• The predicted carcinogenic pollutants were predicted to cause less than 1 in

1 million chance of cancer (trivial cancer risk is considered to be 1 in 1

million, with acceptable cancer risk of 1 in 100 thousand as adopted by the

US-EPA);

• Dioxins and furans were below the relevant guidelines.


50 µg/m³ was predicted for a peak incident during the monitoring campaign.



86

6.5. Environmental Legislation and Air Quality Guidelines

Prior to assessing the impact of the proposed operations at the Dudfield Plant,

Lichtenburg, reference need be made to the environmental regulations and

guidelines governing the emissions and impact of such operations.

Air quality guidelines and standards are fundamental to effective air quality

management, providing the link between the source of atmospheric emissions

and the user of that air at the downstream receptor site. The ambient air quality

guideline values indicate safe daily exposure levels for the majority of the

population, including the very young and the elderly, throughout an individual’s

lifetime. Air quality guidelines and standards are normally given for specific

averaging periods. These averaging periods refer to the time-span over which

the air concentration of the pollutant was monitored at a location. Generally, five

averaging periods are applicable, namely an instantaneous peak, 1-hour average,

24-hour average, 1-month average, and annual average.

The ambient air quality guidelines and standards for pollutants relevant to the

current study are discussed in section 6.5.1. to 6.5.2. Permit specifications for

emission concentrations are discussed in section 6.5.3 and EC emission limits in

Section 6.5.4.

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

Pollutants

A detailed discussion on the health impacts, air quality standards and effect

screening levels is given in Appendix B of the Air Quality specialist report

contained in Appendix H.

There are currently no air quality standards for South Africa. The Department of

Environmental Affairs and Tourism (DEAT) have issued ambient air quality

guidelines to support receiving environment management practices. Local

ambient air quality guidelines are only available for such criteria pollutants that

are commonly emitted, such as sulphur dioxide (SO2), lead (Pb), oxides of

nitrogen (NOx), and particulates. However, a standard has been proposed for

benzene. The level of exposure has as yet not been finalised.

The following tables summarise a number of air quality standards adopted by

certain countries. Also included in the tables are the proposed limit values, which

forms the basis for the proposed South African Air Quality Standards.



87

Table 6.1: Current DEAT NOx guidelines

Ground Level ConcentrationsAveraging Period

µg/m³ ppm

Annual average 283 0.2

Max 24-hour average 566 0.4

Max 1-hour average 1 132 0.8

Table 6.2: Air quality standards for nitrogen dioxide (NO2)

Annual Average Max 1-hour Average

µg/m³ ppm µg/m³ ppm

South Africa (Proposed) (5) 40 0.021 200 0.10

United States EPA 100(1) 0.053(1) - -

European Community 40(2) 0.021(2) 200(3) 0.10(3)

United Kingdom 40 0.021 286 0.15

Canada (4) 100 0.053 400 0.20

Notes:(1)Annual arithmetic mean.(2)Annual limit value for the protection of human health, to be complied with by 1 January 2010.(3)Averaging times represent the 98th percentile of averaging periods; calculated from mean values per

hour or per period of less than an hour taken throughout the year; not to be exceeded more than 8

times per year. This limit is to be complied with by 1 January 2010.(4)Acceptable Canadian air quality objectives.(5)SABS, 2004.

Table 6.3: Air quality standards for inhalable particulates (PM10)

Maximum 24-hour

Concentration (µg/m³)

Annual Average

Concentration (µg/m³)

South Africa (Proposed) (9) 75 40

United States EPA 150(1)(2) 50(3)

European Union (EU)130(4)

250(5) 80

European Community (EC) 50(6) 30(7)

20(8)

Canada 24 -

Reference: Chow and Watson, 1998; Cochran and Pielke, 1992.

Notes:(1)Requires that the three-year annual average concentration be less than this limit;(2)Not to be exceeded more than once per year;(3)Represents the arithmetic mean;(4)Median of daily means for the winter period (1 October to 31 March);(5)Calculated from the 95th percentile of daily means for the year;(6)Compliance by 1 January 2005. Not to be exceeded more than 25 times per calendar year. (By 1

January 2010, no violations of more than 7 times per year will be permitted.)(7)Compliance by 1 January 2005;(8)Compliance by 1 January 2010;(9)SABS, 2004.



88

Table 6.4: Air quality standards for lead

Quarterly Average (µg/m³) Annual Average (µg/m³)

South Africa (Proposed) (2) - 0.5

United States EPA 1.5 -

European Union - 2.0

Germany (1986) - 2.0

United Kingdom - 0.5(1)

Note:(1)Limit to be achieved by 2005, given as part of UK’s national air quality management plan.(2)SABS, 2004.

Table 6.5: Air quality standards for benzene(1)

Country/Organisation Annual Average (µg/m³)Long Term Goal/Limit

(µg/m³)

South Africa (Proposed) (4) 10 5

Australia 10 2.5

Great Britain 10 1.3

Germany 10(3) -

European Community 10 5(2)

Notes:(1)Health risk criteria and screening levels for Benzene are given in Section 2.3(2)Limit value to be reached by 1 January 2010(3)In effect as of 1 July 1998.(4)SABS, 2004.

6.5.2. Effect Screening Levels2 and Health Risk Criteria of Non-Criteria

Pollutants

In the current study (for the proposed usage fuel) reference was made to various

effects screening and health risk criteria to ensure that the potential for risks due

to all pollutants being considered could be gauged. (Effect screening levels are

generally published for a much wider range of pollutants compared to health risk

criteria.) Where various effect screening and health risk thresholds are available

for one pollutant, World Health Organisation (WHO) and Risk Assessment

Information System (RAIS) inhalation reference concentration is considered first.

If health criteria from these sources are not available, Office of Environmental

Health Hazard Assessment (OEHHA) and the Agency for Toxic Substances and

Disease Registry (ATSDR) Minimal Risk Levels (MRLs) has been used (refer to

Table 6.6).

2 Effects Screening Levels (ESLs) are used to evaluate the potential for effects to occur as

a result of exposure to concentrations in air. As no DEAT guidelines are available for

comparison these ESLs will be used for comparison during the current study. ESLs are

based on data concerning health effects, odour nuisance potential, vegetation effects, or

corrosion effects. They are not ambient air standards. If predicted or measured airborne

levels of a constituent do not exceed the screening level, we would not expect any adverse

health or welfare effects to result.



89

6.5.3. Dioxins and Furans

Much of the public concern revolves around the extreme toxicity of dioxins.

These compounds have been shown to be extremely potent in producing a variety

of effects in experimental animals at levels hundreds or thousands of times lower

than most chemicals of environmental interest. Exposure to dioxins has been

linked to a variety of health effects, among others including immunotoxicity,

reproductive and developmental effects, and cancer. Dioxins have been found

throughout the world in practically all media including air, soil, water, sediment,

fish and shellfish, and other food products such as meat and dairy products. A

large proportion of human exposure to dioxins occurs through the food chain, and

it is therefore important to identify and control this potential pathway.

For dioxin-like compounds, the WHO specifies a tolerable daily intake (TDI),

which has been derived in units of toxicity equivalent (TEQ)3 uptakes. The upper

range of the TDI is given by the WHO as being 4 pg TEQ/kg of body weight over a

24-hour averaging period. The WHO stresses that this should be considered as a

maximal tolerable intake on a provisional basis and the ultimate goal is to reduce

human intake levels to below 1 pg TEQ/kg bodyweight. The TDI is given by the

WHO as representing a tolerable daily intake for life-time exposure. Occasional

short-term excursions above the TDI are given as having “no health

consequences provided that the averaged intake over long periods is not

exceeded” (WHO, 2000).

3 The toxic equivalency (TEQ) is determined by multiplying the concentration of a dioxin

congener by its toxicity factor. The total TEQ in a sample is then derived by adding all of

the TEQ values for each congener. While TCDD is the most toxic form of dioxin, 90% of the

total TEQ value results from dioxin-like compounds other than TCDD.



90

Table 6.6: Effect screening and health risk criteria for various substances included in the investigation

RAIS Inhalation Reference

Concentrations (Jan 2004)

(µg/m³)

California OEHHA (Sept

2002) (µg/m³)

ATSDR MRL’s (Jan

2004) (µg/m³)(b)

WHO Guidelines (2000)

(µg/m³)

ConstituentSub-chronic

inhalation

RfCs

Chronic

inhalation

RfCs

Acute RELs

(a)

Chronic

RELsAcute Chronic

Acute & Sub-

acute

Guidelines

Chronic

Guidelines

Acetone 61762 30881

Arsenic & inorganic

compounds

0.19 (4 hrs) 0.03

Barium 0.5(g) 0.5(g)

Benzene 30 (f) 1300 (6hrs) 60 160

Beryllium 0.02 (f)

Cadmium & compounds (as

Cd)

0.9 (h)(e) 0.02 0.005

Chromium (VI) compounds 0.1 (f) 0.2

Cobalt & inorganic

compounds

0.02

Copper: dust & mist 100 (1 hr)

Manganese fume, dust &

inorganic compounds

0.05 (f)(i) 0.2 0.15

Mercury, metal & inorganic

forms

0.3(h) 0.3(f) 1.8 (1 hr) 0.09 1.0

Nickel, metal & insoluble

compounds

6.0 (1 hr) 0.05

Hydrogen chloride 20(f) 2100 (1 hr) 9

Hydrogen fluoride 240 (1 hr)

Silver 1.0(24 hrs)



91

RAIS Inhalation Reference

Concentrations (Jan 2004)

(µg/m³)

California OEHHA (Sept

2002) (µg/m³)

ATSDR MRL’s (Jan

2004) (µg/m³)(b)

WHO Guidelines (2000)

(µg/m³)

ConstituentSub-chronic

inhalation

RfCs

Chronic

inhalation

RfCs

Acute RELs

(a)

Chronic

RELsAcute Chronic

Acute & Sub-

acute

Guidelines

Chronic

Guidelines

Vanadium 1.0 (24 hrs)

Xylene (all isomers except p)

p-xylene100 (k) 22000 (1 hr) 700

4800 (24

hrs)(g)870(i)

(a) Averaging period given in brackets;(b) ARSDR MRL’s are listed for pollutants and averaging periods that do not have other health criteria;(c) Central nervous system effects in human volunteers;(d) Neurotoxicity in rats;(e) Provisional risk assessment values;(f) Source: Integrated Risk Information System (IRIS);(g) Source: Health Effects and Environmental Affects Summary Table (HEAST) 1995; Dates withdrawn(h) July 1997;(i) January 1998.



92

Table 6.7: Toxicity equivalency factors for dioxins and furans

Congener TEF (WHO)

Mono-, di- and tri-chlorodibenzodioxins 0

2,3,7,8,-Tetrachlorodibenzodioxin (TCDD)

Other TCDDs

1

0

1,2,3,7,8-Pentachlorodibenzodioxin (PeCDD)

Other PeCDDs

1

0

1,2,3,4,7,8-Hexachlorodibenzodioxin (HxCDD)

1,2,3,6,7,8- Hexachlorodibenzodioxin (HxCDD)

1,2,3,7,8,9- Hexachlorodibenzodioxin (HxCDD)

Other HxCDDs

0.1

0.1

0.1

0

2,3,7,8-Heptachlorodibenzodioxin (HpCDD)

Other HPCDDs

0.01

0

DIO

XIN

S

Octachlorodibenzodioxin (OCDD) 0.0001

Mono-, di- and tri-chlorodibenzofurans 0

2,3,7,8-Tetrachlorodibenzofuran (TCDF)

Other TCDFs

0.1

0

1,2,3,7,8-Pentachlorodibenzofuran (PeCDF)

2,3,4,7,8-Pentachlorodibenzofuran (PeCDF)

Other PeCDFs

0.05

0.5

0

1,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF)




Other HxCDFs

0.1

0.1

0.1

0.1

0

1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF)

1,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF)

Other HPCDFs

0.001

0.001

0

FU

RA

NS

Octachlorodibenzofuran (OCDF) 0.0001

Assuming that all of the dioxin to which a 70 kg person is exposed is absorbed,

and given an average breathing rate of 1 m3/hr, the tolerable daily intake (TDI)

of the US-EPA, ATSDR and WHO could be calculated to coincide with 24-hour

inhalation concentrations of the following:

• US-EPA - 2.0 x 10-7 µg/m3

• ATSDR - 2.91 x 10-5 µg/m3

• WHO - 2.91 x 10-5 to 1.17 x 10-4 µg/m3

The USEPA unit cancer risk factor for dioxins is 33 (µg TEQ/m3)-1. The annual

average air concentration at the position of maximum exposure corresponding

with a cancer risk of one in a hundred thousand is 3.03 x 10-7 µg/m3. This does

not take into account exposure through the other potential pathways.



93

6.5.4. Cancer Risk Factors

Unit risk factors are applied in the calculation of carcinogenic risks. These factors

are defined as the estimated probability of a person (60-70 kg) contracting

cancer as a result of constant exposure to an ambient concentration of 1 µg/m3

over a 70-year lifetime. In the generic health risk assessment undertaken as part

of the current study, maximum possible exposures (24-hours a day over a 70-

year lifetime) are assumed for all areas beyond the boundary of the site.

Table 6.8: Unit risk factors from the US-EPA Integrated Risk Information

System (IRIS) (as at July 2003) and WHO risk factors (2000)

ChemicalWHO Inhalation Unit Risk

(µg/m³)-1

US-EPA Unit Risk

Factor (µg/m³)-1

US-EPA

Cancer Class(c)

Arsenic, inorganic (a) 1.5E-03 4.3E-03 A

Benzene 4.4E-06 to 7.5E-06 2.2E-06 to 7.8E-06 A

Beryllium 2.4E-03 B1

Cadmium (b) 1.8E-03 B1

Chromium VI

(particulates)

1.1E-02 to 13E-02 1.2E-02 A

Nickel 3.8E-04 2.4E-04 A

Note:

(a) Date withdrawn by US-EPA: January 1998.

(b) Date withdrawn by US-EPA: July 1997.

(c) EPA cancer classifications:

A--human carcinogen.

B--probable human carcinogen. There are two sub-classifications:

B1--agents for which there is limited human data from epidemiological

studies.

B2--agents for which there is sufficient evidence from animal studies and

for which there is inadequate or no evidence from human epidemiological

studies.

C--possible human carcinogen.

D--not classifiable as to human carcinogenicity.

E--evidence of non-carcinogenicity for humans.

Unit risk factors were obtained from the WHO (2000) and from the US-EPA IRIS

database (accessed July 2003). Unit Risk Factors for compounds of interest in

the current study are given in Table 6.8.

6.5.5. Permit Specifications

For the current study the permit specifications for SO2, NO2 and PM10 stack

emissions were used (refer to Table 6.9).



94

Table 6.9: Permit specifications for stack PM10 emissions

Emission Limits

(mg/Nm³)Permit No.Nature of

ProcessDivision

Height

(m)SO2 NO2 PM10

Extraction

System

Kiln 3 76 32.18 800 50 Bag Filter

Cement Mill 1 30 N/A N/A 50 Bag FilterNWPG/DAC&E/

ALPHA/SP22/01

Aug03

Cement

Processes

(No. 22) Cement Mill 2 30 N/A N/A 100Electrostatic

Precipitator

6.5.6. Emission Limits

Air emission limit values for cement kilns are stipulated in Directive 2000/76/EC

of the European Parliament and of the Council (4 December 2000). A synopsis of

these emission limit values as well as a comparison to the DEAT limits for class

1 incinerator is provided in Table 6.10. Emission concentrations specified as part

of these regulations are expressed at 0°C and 101.3 kPa, dry gas and 10%

oxygen.

Table 6.10: Comparison of EC emission limit values for emissions from co-

incineration of waste in cement kilns (Directive 2000/76/EC) and

DEAT class 1 incinerator

Pollutant

DEAT Limit(Class 1

incinerator)

EU Directive

2000/76/ECUnits

Total dust 150 30 mg/Nm³

HCl 30 10 mg/Nm³

HF 30 1 mg/Nm³

NOx for existing plants

NOx for new plants

800 (a)

500 (b)mg/Nm³

SO2 25 50 mg/Nm³

TOC 10 mg/Nm³

Cd + Tl 0.05 (c) 0.05 mg/Nm³

Hg 0.05 0.05 mg/Nm³

Sb + As + Pb + Cr + Co

+ Cu + Mn + Ni + V0.05 (c) 0.5 mg/Nm³

Dioxins toxic equivalence 0.2 0.1 ng/Nm³

Notes:

(a) For existing plants

(b) For new plants

(c) Limit value for each individual element.

6.6. Process Description and Emissions Inventory

The establishment of an emissions inventory comprises the identification of

sources of emission, and the quantification of each source's contribution to



95

ambient air pollution concentrations. The emission sources of concern for

proposed usage of alternative fuels consisted of Kiln 3, Cement Mill 1 and Cement

Mill 2. An emissions inventory for Kiln 3 was established using EC limits (as

inadequate quantitative information was available for the current study), forming

the basis for assessing the impact of the Dudfield Plant on the receiving

environment.

A detailed description of the cement manufacturing process is provided in Chapter

4.

6.6.1. Studies on Emissions from Cement Kilns Utilising Alternative

Fuels

• Oxides of Nitrogen Emissions:

All combustion processes primarily produce NO with a much smaller

proportion of NO2 (<5%). In cement kilns NO is formed only at elevated

temperatures (>800°C). The main areas of formation will consist of the main

flame due to the nitrogen in the air, at the secondary firing from nitrogen in

the fuel as well as small quantities in the raw material. The formation of NO

is determined by flame temperature, oxygen content, residence time and the

nitrogen in the fuel (pers. com. ACMP). As these parameters are to remain

similar and the nitrogen in the alternative fuel not differing from that of coal,

the emissions are expected to remain comparable to that of baseline

conditions.

In addition, the US-EPA emission factors for cement kilns equates to 2.1

kg/tonne clinker (EPA, 1996). The equivalent emission factor using the EC

emission limit for NOx is similar at 2.8 kg/tonne clinker. Measured NOx

emission ranges from European cement kilns are in the range of <0.4-6

kg/tonne clinker (AEA Technology, 2002).

• Sulphur Dioxide Emissions:

SO2 is formed from sulphur in raw material and fuel. Under normal

conditions any sulphur introduced into the rotary kiln or the secondary

firing/precalciner part of the preheater/precalciner kiln system only

marginally contributes to the kiln’s SO2 emissions. This is different with the

sulphur in the form of sulfides and organic sulphur contained in the raw meal

and fed in the usual way to the preheater top cyclone. About 30% of this

sulphide and organic sulphur input leave the preheater as SO2. During direct

operation most of it is emitted to the atmosphere while during compound

operation (that is when the kiln exhaust gases are passing through the raw

mill) 30-90% of the SO2 is absorbed in the raw mill. In some cases the

absorption of fuel sulphur can reach up to 90% (CEMBUREAU, 1999). The

sulphur content in coal is ~0.86% and in alternative fuels (specifically tyres)



96

is approximately 1,63% (pers. Comm. ACMP). However, SO2 emissions are

to a large extent determined by the chemical characteristics of the raw

materials used, and not by the fuel composition (CEMBUREAU, 1999).

The measured baseline emission for the 95th percentile is 1.2 g/s (C & M

Consulting Engineers). The equivalent emission rate using the EC emission

limit for SO2 is 7g/s, more than double the emissions for baseline conditions.

Nonetheless, the predicted impact using the EC emission limit was less than

10% of the respective guidelines.

• Heavy Metal Emissions:

Metals are present in raw materials and fuels at widely variable

concentrations. The behavior of the metals in a cement kiln depends on their

volatility. Non-volatile metals and metal compounds (i.e. arsenic, cobalt,

chromium, copper, manganese, nickel, lead, antimony, tin, vanadium and

zinc) remain within the process and leave the kiln as part of the clinker.

Semi-volatile metals (i.e. cadmium and thallium) are partly taken into the

gas phase at sintering temperatures and condense on the raw material in

cooler parts of the kiln system. Volatile metals (i.e. mercury) can exhibit

similar behaviour but may also be emitted with flue gas (AEA Technology,

2002). Considering car tyres as an alternative fuel it is well known that car

tyres contain more zinc and cadmium, but less mercury and arsenic than

fossil fuels (Mukherjee et al., 2001).

• Dioxin and Furan Emissions:

Any chlorine input in the presence of organic material may potentially cause

the formation of polychlorinated dibenzodioxins (PCDDs) and polychlorinated

dibenzofurans (PCDFs) in heat (combustion) processes. PCDDs and PCDFs

can be formed in/after the preheater and in the air pollution control device if

chlorine and hydrocarbon precursors from the raw materials are available in

sufficient quantities. It is important that as the gases are leaving the kiln

system they should be cooled rapidly through this range. In practice this is

what occurs in preheater systems as the incoming raw materials are

preheated by the kiln gases. Due to the long residence time in the kiln and

the high temperatures, emissions of PCDDs and PCDFs are generally low

during steady kiln conditions. In this case, cement production is rarely a

significant source of PCDD/F emissions. Nevertheless, from the data reported

in the document “Identification of Relevant Industrial Sources of Dioxins and

Furans in Europe” there would still seem to be considerable uncertainty about

dioxin emissions (Landesumweltamt Nordrhein-Westfalen as cited in United

Nations Environment Programme, 2003).

The reported data indicate that cement kilns can mostly comply with an

emission concentration of 0,1 ng TEQ/Nm³, which is the limit value in several



97

Western European legislation for hazardous waste incineration plants.

German measurements at 16 cement clinker kilns (suspension preheater

kilns) during the last 10 years indicate that the average concentration

amounts to about 0,02 ng TEQ/m³ (Schneider et al (1996) as cited in United

Nations Environment Programme, 2003).

There is no significant difference in dioxin emissions associated with the use

of waste derived fuels (including waste oil and scrap tyres) (Mukherjee et al.,

2001) (refer to Table 6.11). Dioxin measurements done by INFOTOX (Pty)

Ltd (2002) at the Dudfield Plant were between 0,014 to 0.28 µg TEQ/tonne

clinker. The equivalent emission factor using the EC emission limit is

0,34 µg TEQ/tonne clinker.

Table 6.11: International emissions data for cement production emissions of

dioxins

Study Dioxin Emissions (µg TEQ/tonne clinker)

Australia

- Standard fuel

- With waste derived fuel

0.0043 – 0.25

0.0087 – 0.28

US (US EPA, 2000)

- Standard fuel


0.27

1.04 (pollution control device inlet temp < 450°F)

UK

- Standard fuel


0.025 – 1.04

0.025 – 1.08

6.6.2. Limitations of the Given Source Inventory

• Process Emissions:

Actual emissions for the proposed usage of alternative fuels in Kiln 3 at the

Dudfield Plant have not been measured (e.g. through a trial burn).

Furthermore, there is inadequate information provided for the current study

of the type and quantity of fuel to be used.

• Fugitive Emissions:

The quantification and impact of fugitive emissions (i.e. materials handling

operations, exposed stockpiles and vehicle emissions) was not investigated

since the introduction of an alternative fuels and resources programme would

only affect stack emissions.

• Decommissioning and Start-Up Phase:

The decommissioning phase of current operations at Kiln 3, as well as the

start-up phase for proposed usage of alternative fuels in Kiln 3 was not

investigated during the current study. Information pertaining to changes in

emission rates, and the duration and sequence of these changes are not



98

known. The process design for the current study was not at an advanced

enough stage to provide this information.

6.6.3. Emission Inventory for Proposed Usage of Alternative Fuels and

Resources at Dudfield Plant

The source data requirements of the model are dependent on the manner in

which sources are classified, viz. as area, point or volume sources. Stack

releases are the only source type evident at the plant and will be modelled as

point sources. Stack parameters required for the simulation of point sources

include: source location, stack height, gas exit velocity, temperature and stack

diameter. The main pollutants of concern resulting from the current and

proposed routine operating conditions consisted of SO2, NOx, PM10, heavy

metals, organic compounds and dioxins and furans from Kiln 3, and PM10

emissions from the two cement mills. Holcim South Africa supplied a range of the

volumetric flow rate for Kiln 3 under proposed operating conditions. This range

was considered for the dispersion simulation in the current study. Information

regarding the stack parameters and emission rates needed for the dispersion

simulations is presented in Table 6.12. A summary of the total emissions from

the Dudfield Plant is given in Table 6.13 to Table 6.15.

Table 6.12: Stack parameters for the Dudfield Plant for proposed usage of

alternative fuels

Exit Velocity (m/s)Source

Height

(m)

Diameter

(m)

Temperature

(°C)Minimum Average Maximum

Kiln 3 76 3.75 110 17.8 20.0 26.7

Cement Mill 1 30 1.162 70 8.6

Cement Mill 2 30 0.710 93.5 18.2

The total given by the EC Directive for heavy metals was used for the study. The

composition of the heavy metals was assumed to be similar to monitored values

by C & M Consulting Engineers (2002). It should be noted however, that these

heavy metals may be emitted in different ratios as notably zinc (although mostly

in particulate form) increases with the use of tyres in comparison to coal, and

similarly mercury decreases.



99

Table 6.13: Emission rates for criteria pollutants from the stacks at the

Dudfield Plant for proposed usage of alternative fuels

Emissions measured in (g/s)

PM10 NOx SO2Source

Min Ave Max Min Ave Max Min Ave Max

Kiln 3 (2) 4.2 4.7 6.3 112.0 126.0 168.0 7.0 7.9 10.5

Cement Mill 1 0.33 (1) - -

Cement Mill 2 0.43 (1) - -(1)Monitored data provided by Holcim South Africa(2)Based on EC emission limits

Table 6.14: Heavy Metal and Dioxin and Furan Emissions from Kiln 3 for

proposed usage of alternative fuels (a)


Minimum Average Maximum

Antimony 8.33E-04 9.39E-04 1.25E-03

Arsenic 1.24E-03 1.40E-03 1.86E-03

Cadmium 1.05E-05 1.19E-05 1.58E-05

Chromium 9.12E-03 1.03E-02 1.37E-02

Cobalt 2.99E-03 3.37E-03 4.50E-03

Copper 4.45E-03 5.01E-03 6.70E-03

Lead 3.95E-03 4.45E-03 5.94E-03

Manganese 3.05E-02 3.44E-02 4.59E-02

Mercury 6.99E-03 7.87E-03 1.05E-02

Nickel 1.13E-02 1.27E-02 1.70E-02

Thallium 6.97E-03 7.86E-03 1.05E-02

Vanadium 5.49E-03 6.19E-03 8.27E-03

Dioxin Toxic Equivalence 1.40E-08 1.57E-08 2.10E-08

(a) Composition of emissions were based on measured emissions from C&M Environmental

Engineers (2002).

Table 6.15: Halogen Compound Emissions from Kiln 3 for proposed usage of

alternative fuels (a)


Minimum Average Maximum

HCl 1.40 1.57 2.1

HF 0.14 0.16 0.21

(a) Emissions were based on EC emission limits

6.6.4. Emission Estimation

Emission limits are given for chromium with no provision being made for the form

in which the chromium is emitted. Since hexavalent chromium is considered to

be a carcinogen, it is significantly more important than the trivalent and other

valencies. Hexavalent chromium from combustion processes is typically 10% of



100

the total chromium emissions (UK, 2002). It will also be important to establish

the actual chromium compounds, because carcinogenicity has been linked only to

certain chromium salts, namely, calcium chromate, chromium trioxide, lead

chromate, strontium chromate and zinc chromate.

6.6.5. Comparison of Simulated Emissions to Permit Specifications

The PM10 emissions from Kiln 3 under proposed (usage of alternative fuels)

operating conditions are within the permit requirements. Holcim are confident

that the SO2 permit of 32 mg/Nm³ will not be exceeded with the proposed usage

of alternative fuel. The PM10 emissions from the Cement Mill 1 and Cement Mill

2 are within the permit requirements.

6.7. Dispersion Simulation Methodology And Data Requirements

Dispersion models compute ambient concentrations as a function of source

configurations, emission strengths and meteorological characteristics, thus

providing a useful tool to ascertain the spatial and temporal patterns in the

ground level concentrations arising from the emissions of various sources.

Increasing reliance has been placed on concentration estimates from models as

the primary basis for environmental and health impact assessments, risk

assessments and emission control requirements. It is, therefore, important to

carefully select a dispersion model for the purpose.

For the purpose of the current study, it was decided to use the well-known US-

EPA Industrial Source Complex Short Term model (ISCST3). The ISCST3 model

is included in a suite of models used by the US-EPA for regulatory purposes.

ISCST3 (EPA, 1995a and 1995b) is a steady state Gaussian Plume model, which

is applicable to multiple point, area and volume sources. Gently rolling

topography may be included to determine the depth of plume penetration by the

underlying surface. A disadvantage of the model is that spatial varying wind

fields, due to topography or other factors cannot be included. A further limitation

of the model arises from the models treatment of low wind speeds. Wind speeds

below 1 m/s produce unrealistically high concentrations when using the Gaussian

plume model, and therefore all wind speeds below 1 m/s are simulated using

1m/s.

Concentration for various averaging periods may be calculated. It has generally

been found that the accuracy of off-the-shelf dispersion models improve with

increased averaging periods. The accurate prediction of instantaneous peaks are

the most difficult and are normally performed with more complicated dispersion

models specifically fine-tuned and validated for the location. The duration of

these short-term, peak concentrations are often only for a few minutes and on-

site meteorological data are then essential for accurate predictions.



101

The Industrial Source Complex model is perhaps the subject of most evaluation

studies in the United States. Reported model accuracies vary from application to

application. Typically, complex topography with a high incidence of calm wind

conditions, produce predictions within a factor of 2 to 10 of the observed

concentrations. When applied in flat or gently rolling terrain, the USA-EPA (EPA,

1986) considers the range of uncertainty to be -50% to 200%. The accuracy

improves with fairly strong wind speeds and during neutral atmospheric

conditions.

There will always be some error in any geophysical model, but it is desirable to

structure the model in such a way to minimise the total error. A model

represents the most likely outcome of an ensemble of experimental results. The

total uncertainty can be thought of as the sum of three components, i.e.:

• the uncertainty due to errors in the model physics;

• the uncertainty due to data errors; and

• the uncertainty due to stochastic processes (turbulence) in the atmosphere.

The stochastic uncertainty includes all errors or uncertainties in data such as

source variability, observed concentrations, and meteorological data. Even if the

field instrument accuracy is excellent, there can still be large uncertainties due to

unrepresentative placement of the instrument (or taking of a sample for

analysis). Model evaluation studies suggest that the data input error term is

often a major contributor to total uncertainty. Even in the best tracer studies,

the source emissions are known only with an accuracy of approximately 5%,

which translates directly into a minimum error of that magnitude in the model

predictions. It is also well known that wind direction errors are the major cause

of poor agreement, especially for relatively short-term predictions (minutes to

hourly) and long downwind distances. All of the above factors contribute to the

inaccuracies not even associated with the mathematical models themselves.

Input data types required for the ISCST3 model include: source data,

meteorological data, terrain data and information on the nature of the receptor

grid.

6.7.1. Meteorological Requirements

ISCST3 requires hourly average meteorological data as input, including wind

speed, wind direction, a measure of atmospheric turbulence, ambient air

temperature and mixing height. The hourly average data was obtained from the

Weather Service in Lichtenburg for the period January 1996 to August 2001. The

mixing height for each hour of the day was estimated for the simulated ambient

temperature and solar radiation data. Daytime mixing heights were calculated

with the prognostic equations of Batchvarova and Gryning (1990), while



102

nighttime boundary layer heights were calculated from various diagnostic

approaches for stable and neutral conditions, as mentioned previously.

6.7.2. Receptor Grid

The dispersion of pollutants emanating from the plant was modelled for an area

covering approximately 5 km by 5 km. The area was divided into a grid matrix

with a resolution of approximately 152 m, with the proposed sites located at the

centre of the receptor area. The ISCST3 simulates ground-level concentrations

for each of the receptor grid points.

6.7.3. Source Data Requirements

Emission rates for Cement Mill 1 and Cement Mill 2 provided by Holcim South

Africa and emission rates based on EC limits for Kiln 3, were used in the

dispersion simulations for proposed (use of alternative fuel) operating conditions

of these sources.

6.7.4. Building Downwash Requirements

Building heights need to be taken into account in the modelling of emissions so as

to account for building downwash effects in the dispersion simulations. The flow

characteristics of air moving over the factory and office buildings may include a

downwash on the leeward side, drawing the plume to the ground near the source.

(Stack heights of greater than twice the height of adjacent buildings are

considered not to give rise to the potential for building downwash effects).

Building down-wash algorithms have been developed for air quality dispersion

models such as the ISCST3. These algorithms require additional input to be

prepared and included in the model runs.

6.8. Atmospheric Dispersion Results and Discussion

6.8.1. Results of Criteria Pollutants

The acceptability of the proposed routine operation (with the usage of alternative

fuels), in terms of its potential air quality impacts, depends on its ability to

demonstrate compliance with both emission limits and ambient air quality

guidelines.

• Permit Specifications:

The SO2 and PM10 emissions from Kiln 3, Cement Mill 1 and Cement Mill 2 for

baseline conditions are within permit requirements. The PM10 emissions

from Kiln 3 under proposed (usage of alternative fuels) operating conditions

are within the SO2 permit requirements. Holcim are confident that the permit



103

of 32 mg/Nm³ will not be exceeded with the proposed usage of alternative

fuel. The PM10 emissions from the Cement Mill 1 and Cement Mill 2 are

within the permit requirements.

• Impact Assessment:

Prior to an analysis of the simulation results, it is recommended that a brief

review be undertaken of the uncertainty associated with these results. The

range of uncertainty of the Industrial Source Complex Model is given by the

US-EPA as being in the range of -50% to +200% when used under the

recommended conditions. Uncertainties are, however, not only associated

with the mathematical models themselves, but also with the generation of

the meteorological and source data used as input to such models. Errors in

source strengths translate directly into errors of similar magnitudes in the

model prediction.

A synopsis of the highest hourly, highest daily and annual average criteria

pollutant concentrations predicted to occur is given in Table 6.16. Predicted

concentrations were compared with current DEAT air quality guidelines to

determine compliance. Since South Africa is in the process of revising these

guidelines it was necessary to compare the predicted concentrations with the

limits proposed for adoption by South Africa. Reference was also made to

the widely referenced EC limit values, which are considered to represent 'best

practice' limits, which closely reflect WHO guidelines. The results of these

comparisons are reflected in Table 6.16.



104

Table 6.16: Maximum offsite concentrations (measured in µg/m³) at the Dudfield Plant boundary of criteria pollutants predicted to

occur due to proposed usage of alternative fuels also given as a ratio of various air quality guidelines and standards (a)(b)

Maximum Predicted GroundLevel Concentrations (µg/m3)

Maximum PredictedConcentrations as a

Percentage of Current SA AirQuality Guidelines (a)


Percentage of Proposed SA AirQuality Limits (a)


Percentage of EC Air QualityLimits (a)Pollutant

EmissionRate

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Min - 6.3E+00 5.7E-01 - 3.5 <1 - 8.4 1.4 - 13 1.9Ave - 6.3E+00 5.7E-01 - 3.5 <1 - 8.4 1.4 - 13 1.9PM10Max - 6.2E+00 5.7E-01 - 3.4 <1 - 8.3 1.4 - 12 1.9Min 3.2E+02 6.0E+01 2.4E+00 2.8 11.0 <1 - - - - - -Ave 2.9E+02 5.0E+01 2.4E+00 25 9.0 <1 - - - - - -N0x(e)Max 2.7E+02 3.4E+01 2.4E+00 23 6.0 <1 - - - - - -Min 2.8E+00 5.0E-01 2.0E-02 <1 <1 <1 1.4 - <1 1.4 - <1Ave 2.6E+00 4.5E-01 2.0E-02 <1 <1 <1 1.3 - <1 1.3 - <1NO2Max 2.4E+00 3.0E-01 2.0E-02 <1 <1 <1 1.2 - <1 1.2 - <1Min 2.0E+01 2.8E+00 1.5E-01 - 2.2 <1 - 2.2 <1 5.7 2.2 <1Ave 1.8E+01 2.2E+00 1.5E-01 - 1.8 <1 - 1.8 <1 5.1 1.8 <1S02Max 1.7E+01 2.0E+00 1.5E-01 - 1.6 <1 - 1.6 <1 4.9 1.6 <1

Min - - 8.7E-05 - - - - -<1(c)

<1(d) - - <1

Ave - - 8.7E-05 - - - -- -<1(c)

<1(d) - - <1Lead

Max - - 8.5E-05 - - - - -<1(c)

<1(d) - - <1

Notes:

(a) A ratio of 1.0 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Ratios of greater than 1.0 indicate an exceedance of such

limits.

(b) The actual air quality guidelines and limits referred to are documented in Section 3.

It has been proposed that the South African limit for lead be revised with the adoption of an annual average limit of (c) 0.5 µg/m3 and (d) 0.25 µg/m3 being recommended

as the level to be aimed for in the longer term.

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

specified for NO2 ground level concentrations (to be complied with by the 1 January 2010).



105

∗ Inhalable Particulates (PM10):

Maximum predicted off-site PM10 ground level concentrations under

current and proposed operating conditions for highest daily and annual

averaging periods are below the current Department of Environmental

Affairs and Tourism (DEAT) guidelines, as well as the EC and proposed

South African limits.

∗ Oxides of nitrogen (NOx):

For current operating conditions (with the installation of the low-NOx

burner), highest predicted off-site NO2 ground level concentrations are

below DEAT as well as EU and proposed South African limits. Highest

hourly, daily and annual ground level concentrations are predicted to be

3 µg/m³, 0,3 µg/m³ and 0,007 µg/m³ respectively. This does not include

the NO2 formed from NO further downwind from the source. However,

the NO concentration at these distances would already be significantly

diluted after the atmospheric conversion.

Under proposed operating conditions, highest predicted off-site NOx

ground level concentrations for highest hourly, daily and annual

averaging concentrations at 315 µg/m³, 60 µg/m³ and 2,4 µg/m³ are

below the current respective DEAT guidelines. The previous

measurements at Dudfield of NO2 and NOx emissions indicated a fraction

of approximately 1% NO2 of total NOx. The general literature concludes

fractions up to 5% (Holcim presentation, 2003). The EU standards (and

proposed SA standards) will still be met even if NO2 were assumed to be

5% (upper estimate) of NOx4.

∗ Sulphur Dioxide (SO2):

For baseline conditions the predicted sulphur dioxide ground level

concentrations are below the current DEAT guidelines as well as proposed

SA and EC limits, measuring 50µg/m³, 1.2 µg/m³, and 0.01 µg/m³ for

highest hourly, daily and annual averaging periods respectively.

Highest predicted ground level concentrations for proposed operating

conditions are less that 10% of the current DEAT guidelines as well as

the proposed South African and current EC limits for all averaging

periods. The potential sulphur content of the alternative fuel may be

higher than the current coal. For example, tyres may have double the

content (approximately 1,6%). However, SO2 are to a large extent

determined by the chemical characteristics of the raw materials used,

4 The formation of NOx is determined by flame temperature, oxygen content, residence

time and nitrogen content in fuel. As these parameters are to remain constant with

nitrogen content of the alternative fuel unknown but not expected to be much different

from coal, NO2 should remain the same as current operating conditions.



106

and not by the fuel composition (CEMBUREAU, 1999). Therefore, the

predicted SO2 emissions (even if tyres would replace all the coal) are

expected to remain relatively similar to that of baseline conditions.

∗ Lead:

Predicted lead concentrations for current and proposed operating

conditions are predicted to be insignificant when compared to EU and

proposed SA limits.

6.8.2. Results for Non-Criteria Pollutants: Potential for Environmental

and Non-Carcinogenic Health Effects

• Impact Assessment:

A synopsis of the highest hourly, highest daily and annual average non-

criteria pollutant concentrations predicted to occur due to the proposed use of

alternative fuel is given in Table 6.18. The predicted concentrations were

compared with the World Health Organisation (WHO) guidelines, Risk

Assessment Integration System (RAIS) Inhalation reference concentrations

(US Environmental Protection Agency (US-EPA)), the California Office of

Environmental Health Hazard Assessment (OEHHA) and the Agency for Toxic

Substances and Disease Registry (ATSDR) Minimal Risk Levels (MRL’s).

However, as indicated in Table 6.17, predicted ground level concentrations

for non-criteria pollutants did not exceed the effect screening or health risk

criteria.

Current maximum predicted off-site benzene ground level concentrations for

annual averaging periods were below the EC and proposed South African

limits. The predicted levels are expected to remain the same due to the high

destruction efficiency (typical destruction efficiencies are 99.99%

(Lemarchand, 2000)).

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

Effect

A synopsis of the maximum annual average concentrations of the carcinogenic

pollutants predicted to occur due to proposed usage of alternative fuels is given in

Table 6.18. The main target organs which may be impacted and the cancer risk

calculated given the predicted concentrations are presented in the table.



107

Table 6.17: Maximum offsite concentrations (measured in µg/m³) at the Dudfield Plant boundary of non-criteria pollutants predicted

to occur due to proposed usage of alternative fuels also given as a ratio of various effect screening and health risk criteria

(a)(b)

Maximum Predicted Ground LevelConcentrations (µg/m3)

Effect Screening or Health RiskCriteria (b)

Maximum PredictedConcentrations as a Ratio of theRespective Effect Screening or

Health Risk Criteria (a)Pollutant Emission Rate

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Min 3.22E-03 4.34E-04 2.73E-05 2.3E-02 - 9.0E-04Ave 2.94E-03 3.50E-04 2.73E-05 2.1E-02 - 9.0E-04ArsenicMax 2.79E-03 3.49E-04 2.65E-05

1.4E-01 (4hrs)

3.0E-022.0E-02 - 9.0E-04

Min 2.73E-05 3.68E-06 2.31E-07 - - 5.0E-05Ave 2.50E-05 2.98E-06 2.32E-07 - - 5.0E-05CadmiumMax 2.37E-05 2.97E-06 2.26E-07

5.0E-03- - 5.0E-05

Min 2.37E-02 3.19E-03 2.01E-04 - - 2.0E-03Ave 2.16E-02 2.58E-03 2.01E-04 - - 2.0E-03ChromiumMax 2.06E-02 2.57E-03 1.96E-04

1.0E-01- - 2.0E-03

Min 7.77E-03 1.05E-03 6.58E-05 - - 3.0E-03Ave 7.08E-03 8.43E-04 6.57E-05 - - 3.0E-03CobaltMax 6.75E-03 8.45E-04 6.42E-05

2.0E-02- - 3.0E-03

Min 1.16E-02 1.56E-03 9.79E-05 1.0E-04 - -Ave 1.05E-02 1.25E-03 9.77E-05 1.0E-04 - -CopperMax 1.01E-02 1.26E-03 9.56E-05

1.0E+021.0E-04 - -

Min 7.93E-02 1.07E-02 6.71E-04 - - 4.5E-03Ave 7.22E-02 8.60E-03 6.71E-04 - - 4.5E-03ManganeseMax 6.89E-02 8.62E-03 6.55E-04

1.5E-01- - 4.5E-03

Min 1.82E-02 2.45E-03 1.54E-04 1.0E-02 - 5.0E-04Ave 1.65E-02 1.97E-03 1.53E-04 9.0E-03 - 5.0E-04MercuryMax 1.58E-02 1.97E-03 1.50E-04

1.8E+00 3.0E-018.8E-03 - 5.0E-04

Min 2.94E-02 3.96E-03 2.49E-04 5.0E-03 - 5.0E-03Ave 2.67E-02 3.18E-03 2.48E-04 4.0E-03 - 5.0E-03NickelMax 2.55E-02 3.19E-03 2.43E-04

6.0E+00 5.0E-024.0E-03 - 5.0E-03

Min 1.43E-02 1.92E-03 1.21E-04 - 1.9E-03 -Ave 1.30E-02 1.55E-03 1.21E-04 - 1.6E-03 -VanadiumMax 1.24E-02 1.55E-03 1.18E-04

1.0E+00- 1.6E-03 -



108

Maximum Predicted Ground LevelConcentrations (µg/m3)

Effect Screening or Health RiskCriteria (b)

Maximum PredictedConcentrations as a Ratio of theRespective Effect Screening or

Health Risk Criteria (a)Pollutant Emission Rate

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Highesthourly

Highestdaily

Annualaverage

Min 3.64E+00 4.90E-01 3.08E-02 1.7E-03 - 1.5E-03Ave 3.30E+00 3.93E-01 3.06E-02 1.6E-03 - 1.5E-03Hydrogen ChlorideMax 3.15E+00 3.94E-01 3.00E-02

2.1E+03 2.0E+011.5E-03 - 1.5E-03

Min 3.64E-01 4.90E-02 3.08E-03 1.5E-03 - -Ave 3.30E-01 3.93E-02 3.06E-03 1.4E-03 - -Hydrogen FluorideMax 3.15E-01 3.94E-02 3.00E-03

2.4E+021.3E-03 - -

Min 3.64E-08 4.90E-09 3.08E-10 - 2.5E-02 -Ave 3.30E-08 3.93E-09 3.06E-10 - 2.0E-02 -

Dioxin ToxicEquivalence

Max 3.15E-08 3.94E-09 3.00E-102.0E-07

- 2.0E-02 -Notes:

(a) A ratio of 1.0 indicates that the predicted concentrations are equivalent to the permissible concentration limit. Ratios of greater than 1.0 indicate an exceedance of such

limits.

(b) Various effect screening levels and health risk criteria is given in Section 3 with a comprehensive review given in Appendix B.

(c) Where an hourly screening level or health criteria was not available but a 6 hour or 4 hour value was present, this was used for comparison of the hourly ground level

concentration as a conservative approach.

(d) This value was withdrawn from the IRIS or HEAST.



109

Table 6.18: Predicted maximum annual average concentrations of various carcinogens due to proposed usage of alternative fuels at

the Dudfield Plant and resultant cancer risks (assuming maximum exposed individuals)

CarcinogenEmission

Rate

Predicted

Maximum

Annual

Average

Concentration

(µg/m3)

WHO

Inhalation

Unit Risk

(µg/m3)-1

US-EPA Unit

Risk Factor

(µg/m3)-1

Cancer Risk (calculated

based on the

application of unit risk

given in the WHO

database)

Cancer Risk (calculated

based on the application of

unit risk given in the RAIS

database)

Min 2.73E-05 4.3 in 100 million 1.17 in 10 million

Ave 2.73E-05 4.3 in 100 million 1.17 in 10 millionArsenic

Max 2.65E-05

1.5E-03 4.3E-03

4.3 in 100 million 1.17 in 10 million

Min 2.31E-07 4.16 in 10 million

Ave 2.32E-07 4.18 in 10 millionCadmium

Max 2.26E-07

1.8E-03

4.06 in 10 million

Min 2.01E-04 2.2 to 26 in 1 million (a) 2.4 in 1 million

Ave 2.01E-04 2.2 to 26 in 1 million (a) 2.4 in 1 millionChromium VI

Max 1.96E-04

1.1E-02 to 13E-

021.2E-02

2.2 to 25.4 in 1 million (a) 2.4 in 1 million

Min 2.49E-04 9.5 in 100 million 5.6 in 100 million

Ave 2.48E-04 9.4 in 100 million 5.9 in 100 millionNickel

Max 2.43E-04

3.8E-04 2.4E-04

9.2 in 100 million 5.8 in 100 million

Min 3.08E-10 1 in 100 million

Ave 3.06E-10 1 in 100 millionDioxin Toxic

EquivalenceMax 3.00E-10

33

0.99 in 100 million

Notes:

(a) Cancer risk exceeding 1 in 1 million (trivial cancer risk criterion)



110

In assessing the results presented in Table 6.18 it is important to note that a

conservative impact assessment methodology was employed. By “conservative”

it is meant that several assumptions were made which is likely to have resulted in

an overestimation in the cancer risks. Such assumptions included the following:

Total chromium was assumed to be completely in the hexavalent form given that

emission limits do not specify the form in which the chromium is to be emitted

and the likely chromium speciation of the emission is not known.

Maximum exposures were assumed to occur to predicted maximum

concentrations, i.e. 24-hour a day exposures over a 70-year lifetime to the

maximum annual pollutant concentrations predicted.

Having characterised a risk and obtained a risk level, it needs to be

recommended whether the outcome is acceptable. There appears to be a

measure of uncertainty as to what level of risk would have to be acceptable to the

public. The US-EPA adopts a range of 1 in 100 thousand to 1 in 1 million as the

acceptable level of risk. As a conservative approach the maximum of 1 in

1 million is considered for trivial level of risk. Initially all chromium was assumed

to be hexavalent and the estimated cancer risk ranged from 2.2 to 26 in 1 million

(WHO unit risk factors). However, the hexavalent chromium is typically 10% of

total chromium. Thus, the incremental cancer risk using the WHO unit inhalation

unit risk factors would be 0,2 to 2,6 in a million.

6.9. Significance Rating

The extent, frequency, severity, duration and significance of the baseline and

proposed usage of alternative fuels is categorised in Table 6.19 and Table 6.20

respectively.

As the emission levels are below the DEAT guidelines, the significance for baseline

conditions (for all pollutants of concern) was predicted to be low (refer to Table

6.19). Under proposed operating conditions (usage of alternative fuels), the

emissions remain below the DEAT guidelines. Therefore, the significance for all

pollutants of concern with the implementation of the proposed project at Dudfield

plant is predicted to remain low (refer to Table 6.20).



111

Table 6.19: Significance rating from the baseline study (a) (for all pollutants of

concern)

Scale Significance Rating

Temporal Long term

Spatial Localised

Severity Slight (b)

Significance Low (b)

Risk or likelihood May occur (c)

Degree of certainty or confidence Probable

Notes:

(a) Routine operating conditions using Kiln 3, Cement Mill 1, Cement Mill 2.

(b) Based on criteria pollutants and screened against DEAT guidelines.

(c) Impacts are not constant as they depend on the meteorological conditions and

dispersion potential of the atmosphere.

Table 6.20: Significance rating from the proposed usage of alternative fuel (for

all pollutants of concern)

Scale Significance Rating

Temporal Long term

Spatial Localised

Severity Slight (a)

Significance Low (a)

Risk or likelihood May occur (b)

Degree of certainty or confidence Probable

Notes:

(a) Based on criteria pollutants and screened against DEAT guidelines.

(b) Impacts are not constant as they depend on the meteorological conditions and

dispersion potential of the atmosphere.

6.10. Description of Aspects and Impacts

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

• The relationship of the impact/issue to temporal scales;

• The relationship of the impact/issue to spatial scales; and

• The severity of the impact/issue.

These three criteria are combined to describe the overall importance rating,

namely the significance (Text Box 6.1). In addition the following parameters are

used to describe the impact/issues:

• The risk or likelihood of the impact/issue occurring; and,

• The degree of confidence placed in the assessment of the impact/issue.



112

6.11. Conclusion and Recommendations

The investigation included the simulation of inhalable particulates, nitrogen

oxides, sulphur dioxide, organic compounds, dioxins and furans, trace metals and

halogen compounds.

For baseline conditions measured emission values were simulated in order to

determine the current impact on the surrounding environment. For proposed

usage of alternative fuels, EC emission limits were used to estimate emission

rates.

The main conclusions may be summarised as follows:

• The inhalable particulate concentrations (PM10) were predicted to be below

the daily and annual average current DEAT as well as the EC and proposed

South African limits with highest offsite concentrations at 7 µg/m³ and

0,7 µg/m³ respectively for baseline conditions and 0,3 µg/m³ and

0,57 µg/m³ respectively for proposed conditions (this excluded fugitive

emissions);

• Gaseous concentrations for NO2 (baseline conditions) did not exceed the

DEAT guidelines with highest predicted off site concentrations predicted to be


averaging periods respectively. Proposed NO2 ground level concentrations

were predicted to be 2,8 µg/m³, 0,5 µg/m³ and 0,02 µg/m³ for highest

hourly, daily and annual averaging periods. These concentration levels were

below DEAT guidelines as well as EC and proposed South African (SA) limits;

• NOx ground level concentrations for proposed operating conditions were

315 µg/m³, 60 µg/m³ and 2,43 µg/m³ for highest hourly, daily and annual

averaging periods respectively, well below the current DEAT guidelines;


DEAT guidelines as well as the proposed South African and EC limits with

highest levels predicted to be 50 µg/m³5, 1,2 µg/m³ and 0,01 µg/m³ for


50 µg/m³ was predicted from a peak incident during the monitoring campaign.

Text Box 6.1: The Significance Scale

Very High Predicted ground level concentrations exceeding the guideline >100%.

High Predicted ground level concentrations exceeding the guideline.

Moderate Predicted ground level concentrations >80% of the guideline.

Low Predicted ground level concentrations below the guideline.

No Significance No ground level concentrations.



113

highest hourly, daily and annual averaging periods respectively for baseline

conditions and 20 µg/m³, 2,8 µg/m³ and 0,15 µg/m³ for highest hourly, daily

and annual averaging periods respectively for proposed conditions;

• Predicted current and proposed lead concentrations were insignificant when

compared to the EU limits respectively;

• Predicted ground level concentrations for non-criteria pollutants did not

exceed the effect screening or health risk criteria for current and proposed

operations.

• Carcinogenic pollutants for baseline conditions were predicted to cause less

than 1 in 1 million chance of cancer (trivial cancer risk criterion). For

proposed conditions all potential carcinogenic pollutants, except hexavalent

chromium were predicted to be less than the 1 in a million increased cancer

risk criterion. Assuming all chromium to be hexavalent, the estimated cancer

risk ranged from 2,2 to 26 in 1 million (WHO unit risk factors). However the

hexavalent chromium is typically 10% of total chromium. Thus the

incremental cancer risk using the WHO unit inhalation unit risk factors would

be 0,2 to 2,6 in a million. It is, therefore, broadly acceptable (less than 1 in

100 thousand);

• Dioxins and furans were below the relevant guidelines for current and

proposed operating conditions;

• The significance rating for current and proposed conditions indicated slight

severity due to predicted ground level concentrations from criteria pollutants

with localised, long-term impact.

• Based on the findings above it can be concluded that predicted ground level

impact from alternative fuel usage is similar to, and in some cases marginally

higher than (due to emissions based on EC limits) baseline conditions.

However the predicted impact for the usage of alternative fuel is well below

relative guidelines/limits.

6.11.1. Recommendations

• EC emission limits were used to quantify ground level impact from the plant

for the proposed usage of alternative fuels. It is recommended that a “Trial

Burn” be done to check EC emission limit used in the current study for the

proposed burning of alternative fuel. Pollutants of concern are typically due

to chronic exposures (e.g. dioxins and furans), hence a relatively short

exposure of a few days during the trial burn would have an insignificant

impact.

• It is additionally recommended that the emissions be monitored once the

proposed operations have commenced and re-simulations undertaken if the

order of magnitude of these emissions is significantly different. This will be

necessitated in order to quantify the ground level impact.

• EC limit allows NOx emission instead of NO2. Previous measurements at

Dudfield Plant indicated approximately 1% NO2 of NOx. This fraction may,



114

however, be as high as 10%. If the NO2 emissions were allowed at the EC

limit for NOx, the guidelines of NO2 would be exceeded. It is, therefore,

recommended that both NO2 and NOx be monitored for compliance.

• It is recommended that the hexavalent chromium fraction be determined.

• Although fugitive emissions were not important in establishing the impact of

the use of alternative fuels it is recommended to compile a source inventory

for these emissions to determine the significance of this source.

• An air quality management plan was provided with the recommendation to

improve and extend the plant’s emissions inventory by:

∗ Undertaking stack (Kiln 3) monitoring following the initiation of the

proposed operations to confirm projected stack emission data.

∗ Identify and quantify all fugitive, diffuse and evaporative sources of

emissions.

6.12. Air Quality Management System

Possible objectives to be met through air quality management planning, given the

local legislative context and international 'best practice' requirements, include:

• identification and quantification of sources of atmospheric emission, and

ranking of sources based on their significance;

• reduction of significant sources through the implementation of the most cost-

effective management and/or control measures possible;

• demonstration of compliance with local (and if necessary international)

regulations;

• demonstration of continuous improvement (e.g. for ISO14000 purposes);

• reduction of risks, both occupational and public;

• facilitation of the participation of interested and affected parties in air quality

management; and,

• disseminate environmental information to stakeholders.

Given these objectives, the following elements are perceived to be integral to

effective air quality management planning within industrial and mining

operations:

• Baseline Assessment. Such an assessment comprises the identification and

quantification of sources of atmospheric emission and the simulation and/or

measurement of air quality impacts associated with such sources. Baseline

assessments typically form the basis for identifying significant sources,

ranking emission reduction strategies and designing suitable source and

ambient air quality monitoring networks. Although air quality impacts related

to stack emissions were quantified during the current study, fugitive

emissions were not considered. The significance of such emissions were

therefore not established.



115

• Source- and Receptor-based Performance Indicators and Associated Targets.

The identification of and commitment to specific source-related and ambient

air quality targets provides the basis for assessing the acceptability of

emission rates and ambient air pollution concentrations. Such targets

should, as a minimum, reflect pertinent local, provincial and national

regulatory limits. Other, more stringent criteria such as emission and air

quality standards issued by other countries or dose-response thresholds

(etc.), could also be used as the basis for such targets. Timeframes should

be set by which targets are to be achieved.

• Source and Ambient Air Quality Monitoring Systems. The monitoring of

sources and ambient air quality is crucial to accurately characterise current

impacts, evaluate the effectiveness of control measures, and quantify

progress against performance indicators. Source-based monitoring can range

from sophisticated continuous stack monitoring to routine visual inspections

of sources. Ambient air quality monitoring, although typically associated with

the acquisition and implementation of mechanical sampling equipment, could

also comprise the maintenance of a complaints register.

• Air Pollution Mitigation Strategy. In the design of the mitigation strategy,

sources classified as significant in terms of their air quality impacts should be

targeted using the most cost-effective measures possible. Mitigation

strategies should include short-, medium- and long-term source management

and control measures in addition to providing for the implementation of

contingency measures in the event that defined targets are not met within

specified timeframes.

• Record Keeping and Documentation Procedure. The implementation of a

documentation procedure ensures continuity beyond the job span of

individuals, assigns responsibility of tasks to posts and contributes to

informed decision making by increasing access to information. Such record

keeping is able to easily facilitate environmental audits, and generally

provides value for money in terms of expenditure on emissions inventory

development, modelling and monitoring.

• Periodic Inspections and Audits. Periodic inspections and external audits are

essential for progress measurement, evaluation and reporting purposes. Site

inspections and progress reporting by plant personnel may, for example, be

undertaken at monthly or quarterly intervals, with annual environmental

audits being conducted on an annual basis.

• Mechanisms for Consultation with Authorities and I&APs. Interactions with

authorities currently typically comprise routine compliance reporting and

intermittent site inspections. Mechanisms for information dissemination to

and consultation with interested and affected parties (I&APs) include the

holding of stakeholder forums. The frequency of such forums is best

determined on an intermittent basis through consultation between the

operation and relevant stakeholders.



116

• Financial Provision. The budget should provide a clear indication of the

capital and annual maintenance costs associated with mitigation measure

implementation and monitoring. Provision should also be made for costs

related to inspections, audits, environmental reporting and I&AP liaison. The

budget could either be established and maintained exclusively to inform

internal decision-making, or could be made available to authorities and/or

I&APs to demonstrate that financial resources have been made available for

air quality management planning.

The interactions of individual components of the air quality management plan

development, implementation and review process are illustrated in Figure 6.2.

These various components are discussed in more detail in subsequent

subsections.

Figure 6.2: Schematic diagram illustrating air quality management plan

development, implementation and review by industrial and mining

operations



117

6.12.1. Emissions Inventory Development and Maintenance

An emissions inventory is a comprehensive, accurate and current account of air

pollutant emissions and associated source configuration data from specific

sources over a specific time period. Source and emission data need to be collated

for routine, upset and accidental emissions to provide a representative account of

the potential for impacts, which exist. Emissions inventories represents the key

elements in all programmes aimed at air pollution management, aiding in the

identification of pollutants and sources of concern and therefore in the selection

of effective air pollution abatement measures. In addition to containing

information on present emission levels from the various source categories, an

emissions inventory could also indicate projected future emission levels for long-

term planning purposes.

The first step in the establishment of an emissions inventory is the identification

of sources of atmospheric emissions. The quantification of sources may be based

on source measurements, mass balance calculations and on the application of

emission factors. In the current study, only stack emissions were quantified for

inclusion in the plant’s emission inventory. Stack emission rates were assumed

to be equivalent to EC emission limits. The plant’s emissions inventory will need

to be improved and extended by:

• undertaking stack monitoring following the initiation of the proposed

operations to confirm projected stack emissions data; and

• identifying and quantifying all fugitive, diffuse and evaporative sources of

emissions.

In future, South African industries will be tasked with the regular reporting of

source and emissions data for both stack and diffuse sources to air quality

management authorities. Reliance on consultants to regularly update the

facility's emissions inventory to fulfil such reporting requirements, should in-

house capacity not have been developed, will prove costly.

6.12.2. Source Monitoring

Source monitoring could range from sophisticated continuous emission monitoring

methods to intermittent monitoring. The type of monitoring adopted will depend

on the nature and extent of an operation's activities and the presence of various

source types (e.g. stacks, vehicle entrainment from unpaved or paved roads,

evaporative emissions from tanks, fugitive dust releases from materials handling

points).

Mandatory in-stack monitoring for all “priority pollutants” may in future be

required by industrial emitters. Alternatively, stack-monitoring campaigns may



118

be required. Stipulations regarding monitory durations, methods and frequencies

will be included in Atmospheric Emission Licences.

For the proposed usage of alternative fuels, the type of monitor will depend on

three aspects, i.e. the stack parameters, composition of fuel and quantity of fuel

used. If these three aspects remain relatively constant intermittent monitoring

would suffice, as emissions should be fairly regular. If any one of these aspects

significantly varies over time continuous monitoring may be required. Monitoring

would be required to establish the chromium composition and to demonstrate

that the emissions emanating from the kiln (for the new facility) can achieve the

given EC emission limits.

6.12.3. Ambient Air Quality Monitoring

Air quality samplers are generally expensive to install and maintain. It is

therefore essential that the type of sampling equipment required and the number

of sampling sites to be established be carefully considered and justified.

Given that predicted pollutant concentrations due to stack emissions are well

within air quality guidelines and health screening levels, ambient air quality

monitoring appears unjustified. It is however strongly recommended that the

need for air quality monitoring be reassessed after the establishment of a

comprehensive emissions inventory for the plant and the simulation of air

pollution concentrations arising from all sources.

6.12.4. Mitigation Strategy Design, Implementation and Evaluation

Mitigation should form an integral component of the environmental management

of industrial plants. Such measures need to be integrated into the day-to-day

operations of the plant and their effectiveness and overall usefulness reviewed

periodically. In assessing the cost effectiveness of controls, costs of measures

may be compared to the emission and/or impact reductions achieved by such

measures.

Should stack emissions be measured to be within emission limits, as assumed in

this study, no mitigation would be required for these sources. The need for the

implementation of mitigative measures for other sources needs however to be

established.



119

6.12.5. Record Keeping and Environmental Reporting

Record-keeping requirements specific to air pollution management include:

• Complaints register. It is essential for all industrial and mining operations to

log the "who", "when" "what" and "where" of a complaint, in addition to

information on action taken by personnel in response to the complaint. This

register should be signed at regular intervals by the environmental manager

to encourage complaints being addressed in a timely and responsible

manner.

• Emissions inventory database - comprising source and emissions data in

addition to information on when the inventory was last changed and audited.

• Dispersion model results - including dispersion model manual and training

notes, list files indicating model inputs and outputs, isopleth plots and

graphs, etc.

• Air monitoring information - comprising the air quality database, information

on the location of sampling sites, sampling durations, calibration certificates,

quality assurance procedures, reasons for peaks in concentrations or

deposition levels observed.

• Reports compiled (e.g. reports prepared to meet internal information

requirements, compliance reports generated for authorities, briefing

documents for circulation to stakeholders, progress reporting against

performance indicators, specialised studies, air quality management plan

reviews, etc.)

Environmental reporting which would typically be undertaken on an annual basis

to document the review of air quality management system components is likely to

include:

• Proof of progress made against performance indicators

• Review of performance indicators

• Review of air quality monitoring and management systems

• Synopsis of complaints received, actions taken and response times

• Synopsis of unplanned emission incidents, causes and actions taken

• Benchmarking against the environmental performance of other industries

locally and abroad (e.g. total particulate emissions per ton product).

The importance of proficient record keeping and environmental reporting cannot

be over-emphasised. This tool forms the basis of all environmental management

systems, and is recognised as one of the main components of ISO14000

management systems.



120

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.


Assessment of the Suitability of 31-Aug-04Waste as an Alternative Fuel

121

7. ASSESSMENT OF THE SUITABILITY OF WASTE AS AN ALTERNATIVE

FUEL RESOURCE

7.1. Introduction

In order to generate the high temperatures required for cement manufacture,

large quantities of fuel are required to achieve and maintain kiln temperatures.

The use of waste derived alternative fuels can reduce the reliance of a kiln on a

natural resource while providing an effective method for managing waste

materials. In order to reduce their reliance on non-renewable fuel resources and

provide an innovative waste management solution Holcim South Africa has set an

initial goal of replacing a minimum of 35% of the coal used by Kiln 3 at the

Dudfield Plant with alternative waste derived fuels. Cement kilns are

acknowledged as being able to provide an ideal environment for the complete

combustion of waste derived fuels due to the very high temperatures (up to

2000oC), long solid residence time (up to 30 minutes), long gas residence times

(of 4 to 8 seconds), and the large excess of oxygen used.

During the development of the National Waste Management Strategy by the

Department of Environmental Affairs and Tourism (DEAT; 1998), cement kilns

were identified as facilities that could effectively utilise waste materials such as

tyres, refuse derived fuel (RDF), hydrocarbon wastes and selected hazardous

wastes, as fuels. Utilisation of materials that are normally designated as wastes

as a fuel or alternative feedstock for cement manufacture meets a number of

national strategic goals, including the beneficial use of wastes, conservation of

natural resources such as coal and reduction of the amount of waste being

disposed to landfills.

There are currently no formal regulatory requirements specific to the use of wasre

derived alternative fuels and resources (AFR) in cement kilns. Without

application specific standards and specifications to govern the use of AFR, the

approach has been to adopt the applicable waste standards, specifications and

procedures. This has been done to ensure that the most stringent of measures

are implemented in the utilisation of alternative fuel and resources. The

management procedures fall under the Duty of Care requirements that are

included in National Environmental Management Act (No 107 of 1998), the

Environment Conservation Act (No 73 of 1989), and the Department of Water


Kiln 3 at the Holcim South Africa Dudfield plant has recently been upgraded and

is able to accept and process a variety of fuels. These fuels could include a wide

range of wastes both hazardous and non-hazardous. The fuels can occur in

varying forms including solid, sludge, liquid and gas states. The use of waste,

both as alternative fuels and as raw materials, introduces new challenges for the



122

cement plant and issues related to the transport, handling, storage and use of the

waste must be strictly controlled to ensure that their risk to the environment and

human health is appropriately managed. However, the classification, handling,

storage and transport of hazardous materials are well understood and are strictly

controlled by current legislation and the environmental authorities. The adoption

of the sound management techniques will ensure the potential risks to health,

safety and the environment are kept within acceptable levels.





and the control of any emissions from the kiln. The primary management

considerations required to be taken in mind to ensure the total 'cradle to grave'

management of AFR include:


• Documentation



• Transportation


• Offloading



This chapter assesses the suitability and the risks associated with the proposed

introduction of an alternatives fuels and resources (AFR) programme at Dudfield's

Kiln 3, and defines the management procedures that would be required to be

implemented by Holcim South Africa (with details of these procedures provided in

Appendix I).

7.2. AFR Specifications

The use of alternative fuels in cement kilns is based upon sound technical

principles as the organic component is destroyed at the very high temperatures

reached in the kiln, i.e. up to 2000°C, and the inorganic components are trapped

and combined with the cement clinker forming part of the final product.

However, in order to determine the suitability of using AFR in the kiln it is critical

to identify, understand and manage the factors that could potentially create an






123



7.2.1. Types of Alternate Fuels and Resources

Waste materials currently utilised internationally as alternative fuels include, but

are not limited to scrap tyres, rubber, paper waste, used oils, waste wood, paper

sludge, sewage sludge, plastics, spent solvents, tars, etc. Waste-derived

alternative fuels can include wastes with high concentrations of substances

beneficial to the cement manufacturing process e.g. wastes with a high iron

content to replace the iron ore normally used in cement manufacture.

The primary consideration for waste to be utilised as a fuel is the energy value,

measured using the Nett Calorific Value (measured in megajoules per kilogram

(MJ/kg)). Table 7.1 lists the typical calorific values of potential alternative fuels

and, for comparison, some common natural fuels (such as oil and coal). Natural

fuels range from a calorific value as low as 16 MJ/kg for some peat or lignite, to

as high as 42 MJ/kg for fuel oil derived from crude oil. To sustain combustion, a

fuel must have a calorific value of at least 7,5 to 9 MJ/kg.

A number of possible alternative fuels are listed in Table 7.1 to compare the

calorific value of alternate fuels to conventional fuels. However, this list is not a

comprehensive listing of all possible AFR materials.

Table 7.1: Calorific Value of Alternative and Natural Fuels

FuelCalorific Value

(MJ/kg)Comment

Pure Polyethylene 46 For example, plastic bags

Light Fuel Oils 42 Diesel

Heavy Fuel Oil 40 Used in boilers

Tar 38 By product of petroleum industry

Pure rubber 36

Anthracite 34 High grade coal

Waste Oils 30 - 38 Used engine oil

Petroleum Coke 33 Coke produced from petroleum

residues

Scrap Tyres 28 - 32 Contain steel and other non-

combustible material

Bituminous Coal 24 - 29 Lower grade coal produced in South

Africa

Landfill Gas 16 - 20 ~60% methane gas

Lignite and Peat 16 - 21

Spent Potliners 20 Carbon and Refractory Waste from

Aluminium Smelters

Paint Sludge 19 By product from paint industry



124

FuelCalorific Value

(MJ/kg)Comment

Palm nut shells/

Sunflower husks

19 From production of vegetable oils

Fuller Earth 13 - 16 A natural clay used to filter vegetable

oils

Dried wood / sawdust 16

Rice Husks 16

Refuse Derived Fuel

(RDF)

15 Domestic waste with metal and other

non-combustible wastes removed

Cardboard/paper 15

Dried Sewage Sludge 10 Sterilised sludge

Domestic Refuse 8.5 Domestic waste with metal and other

non-combustible wastes removed

(comparable to RDF)

Wet Sewage Sludge 7.5

Contaminated Soils 0 - 3 Contain hydrocarbons or other organic

contaminants

Waste Minerals 0 Contain no combustible organic

material

7.2.2. Physical and Chemical Characteristics of AFR

As there are many waste streams that could be considered for acceptance as an

alternative fuel, it is important to define the physical and chemical characteristics

of potential AFR streams to ensure that they can be safely accepted and utilised

in the kiln.

This is important for a number of reasons:

• The safety of persons handling the materials: individuals need to be made

aware of the hazards and provided with the correct protective equipment to

wear while handling the waste.

• The transport of the materials: the materials must be safely transported in

accordance with the relevant legislation. Precautions taken will differ

significantly depending on the type of waste transported. The physical form

of the waste will determine what type of transport container and vehicle is

required. The density of the waste will determine the volume that can be

transported by a particular vehicle to avoid overloading the vehicle. The

waste constituents will also determine the appropriate labelling of the vehicle.

• In cases of emergency, e.g. spillage, vehicle accident etc., it is vital that the

driver, emergency services and persons on the scene of the accident are able

to readily identify and appropriately manage the waste stream.



125

• The type of AFR, its chemical characteristics and its physical form will also

dictate exactly how it should be stored on reaching Dudfield plant.

• For efficient and safe utilisation the chemical composition of the AFR must be

determined.

• Physical State:

The four possible physical states of a waste stream are described below. The

physical state of a waste stream will determine how it is handled,

containerised, transported, stored and fed into the kiln.

∗ Solid

Solid waste generally refers to a waste that is devoid of excess moisture,

and does not generate moisture when subjected to pressure. The solid

can be in a number of forms, generally varying in particle size and

adhesion properties. Examples are:

- Large chunks (rocks) of material.

- Varying sizes smaller than this e.g. gravel size pieces.

- Fine powders,

- Solid wastes, which are 'sticky', e.g. clay-like substances.

∗ Liquid

These are wastes which have little to no solid content, although a certain

amount of settlement may take place leaving a layer of sludge at the

bottom of a container. Liquids can vary greatly in composition e.g. in

colour, odour, toxicity, whether they release fumes or not, viscosity,

clear or opaque, etc.

∗ Sludge

This is generally an intermediate physical form between liquid and solid.

It is determined by its liquid content, which is generally accepted to be

above 40%, although this amount can vary depending on the nature of

the waste materials. Sludges can vary from a stiff consistency to one

that is quite mobile, and this determines how they are handled.

∗ Gases

This class is subdivided into five separate divisions, permanent gases,

compressed gases, liquefied gases, refrigerated liquefied gases and gases

in solution.

• Hazardous characteristics:

Wastes are categorised in terms of their hazardous properties, for transport,

treatment and disposal purposes, using SANS Code 10228 (South Africa



126

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

i.e.:

∗ Class 1 Explosives

∗ Class 2 Gases

∗ Class 3 Flammable Liquids

∗ Class 4 Flammable Solids

∗ Class 5 Oxidising Substances and Organic Peroxides

∗ Class 6 Toxic and Infectious Substances

∗ Class 7 Radioactive Substances

∗ Class 8 Corrosive Substances and

∗ Class 9 Miscellaneous Dangerous Substances

Hazardous substances and wastes have four main hazardous characteristics,

namely flammability, corrosivity, toxicity and reactivity. A hazardous

material is classified according to its primary characteristic, but may also

have secondary characteristics that would determine and influence the

management approach taken.

∗ Explosive Wastes

An explosive substance or waste is a solid or liquid substance, or a

mixture of substances that is capable, by chemical reaction, of producing

a gas at such temperature and pressure and speed as to cause damage

to the surroundings. Similar to explosives are pyrotechnic materials that

are designed to produce heat, light, sound, gas, smoke, or a combination

of these, but the reaction is non-detonative and self-sustaining.

Explosive wastes belong to SANS 10228 Class 1. Waste can range in

behaviour from being insensitive, to very sensitive, to explosive.

∗ Gaseous Wastes

Gases belong to SANS Hazard Class 2, which is divided into a number of

categories:

- A permanent gas is a gas that at a temperature of 50°C has a vapour

pressure exceeding 300 kilo Pascals (kPa) and is completely gaseous

at 20°C with a standard pressure of 101,3 kPa (note that a

permanent gas cannot be liquefied under ambient temperatures, e.g.

oxygen and nitrogen.)

- A compressed gas is a gas (other than in solution), that when

packaged under pressure for transportation, is entirely gaseous at

20°C.

- A liquefied gas is a gas that can become liquid under pressure at

ambient temperatures, e.g. butane.



127

- A refrigerated liquefied gas is a gas that, when packaged for

transportation, is partially liquid due to its low temperature, e.g.

liquid air and liquid oxygen.

- A gas in solution is a gas that can be dissolved under pressure in a

solvent and that can be absorbed in a porous material, e.g.

acetylene.

Gases could include non-inflammable gases such as chlorofluorocarbons

(CFCs), flammable gases and gases that may be toxic.

∗ Flammable Liquid and Solid Wastes

Flammable wastes can belong to SANS 10228 Class 3, or SANS Class 4,

flammable liquids or flammable solids, respectively. The most common

Class 3 flammable liquids are organic solvents including petroleum fuels

that have high calorific values (refer Table 7.1).

Class 4 Flammable Solids include:

- Self reactive and related substances and desensitised explosives.

- Substances liable to Spontaneous Combustion, including Pyrophoric

Substances (which ignite in contact with air), Self-Heating

Substances (which in air are liable to self-heating but do not ignite)

- Substances that on contact with water emit flammable gases.

A flammable waste will ignite when subjected to an open flame or high

temperatures. A waste that has a flash point of 61°C or below is defined

as flammable in terms of the Minimum Requirements (Department of

Water Affairs and Forestry, 1998) for the disposal of waste to landfill.

However, it is important for transport and storage purposes to

identify/classify wastes that have flash points higher than 61°C and which

can combust when heated to higher temperatures.

∗ Oxidising Substances and Peroxides

These wastes belong to SANS Class 5, i.e.:

- Oxidising Substances (Agents), although they themselves may not

be combustible, can either by yielding oxygen or by similar

processes, increase the risk and intensity of fire in other materials

with which they come into contact. Oxidising substances can be

sensitive to impact, friction or a rise in temperature, and some can

react vigorously with moisture, therefore increasing the risk of fire: a

common example is solid pool chlorine.

- Organic peroxides are thermally unstable substances that undergo

exothermic self-accelerating decomposition.



128

∗ Toxic Wastes

Wastes that are toxic can result in the poisoning of humans and other

living organisms. Such waste materials can belong to SANS Class 6.1,

toxic substances, or Class 9, miscellaneous dangerous substances. There

are a number of important parameters used to measure toxicity, i.e. the

chronic toxicity (teratogenicity, mutagenicity, and carcinogenicity), acute

toxicity in terms of the mammalian toxicity, as measured by the

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

LC50 mg/l/96hr for fish. The LD50 is the lethal dose of a chemical

required to kill 50% of a population of experimental mammals, and the

ecotoxicity is the lethal concentration required to kill 50% of a population

of fish. The acute toxicity and chronic toxicity of a waste are vital in

determining the most appropriate handling and storage method, as well

as the type of protective equipment to be worn by employees involved in

handling the material. The ecotoxicity plus other parameters such as

biodegradability, persistence and mobility of a toxic substance is

particularly important when designing emergency procedures, when

determining the risks associated with pollution and the methods and level

of clean up required for accidental spills.

∗ Infectious Wastes

Infectious waste, which is the most important component of the health

care risk waste stream, consists of contaminated wastes from medical

facilities that can or possibly could cause the spread of disease. The

waste belongs to SANS Class 6.2, infectious substances. This is usually

in the form of soiled or contaminated bandages, swabs, gloves, masks,

sharps etc. It is vital that individuals are not exposed to any disease

causing organisms and that this waste stream is completely destroyed or

otherwise sterilised before anybody is exposed to it.

∗ Radioactive Wastes

Radioactive wastes, which belong to SANS Class 7, are materials that

spontaneously emit ionising radiation. Internationally, any material with

a specific activity exceeding 70 Becquerel/g (0,002 µCi/g) is classed as

Class 7 dangerous goods.

∗ Corrosive Wastes

In terms of SANS 10228, corrosive substances, which belong to Class 8,

are solids and liquids that can, in their original state, severely damage

living tissue. All wastes in Class 8 also have some destructive effect on

container materials such as metals. Many substances in this class

become corrosive only after having reacted with water or moisture in the

air. The reaction between water and many substances of Class 8 is often

accompanied by the emission of irritating and corrosive gases. Such



129

gases usually become visible as fumes in the air. This aspect is

particularly important in storage and transport, as it is vital to determine

what type of container to store the wastes in, so that the container will

not corrode, leading to a leakage or spillage.

• The influence of the hazardous waste classification on the selection

of appropriate AFR sources:

∗ Explosive Wastes

Unless the appropriate precautions are in place, and permission for

acceptance of explosive waste for use as an AFR has been obtained from

the Commissioner of Mines and other relevant authorities, explosive

wastes should not be accepted or utilised as an alternative fuel source.

∗ Gaseous Wastes

The kiln offers a unique opportunity to utilise the energy derived from the

processing of some flammable gasses and non-toxic gases such as the

CFCs or hydrochlorofluorocarbons, many of which are now banned in

terms of the Montreal Protocol, United Nations (1993. The possible

amounts of these gases that could be available for use as an AFR by the

kiln would be very low, and would not be expected to exceed 50 to 100

tons per annum.

∗ Flammable Liquid and Solid Wastes

These materials would form a significant portion of the alternative fuels

used at the kiln due to their high calorific values (refer Table 7.1). These

flammable wastes are required to be handled carefully to avoid

conditions which could cause them to ignite during transport and storage,

but pose no higher risk than the management of fuels such as petrol,

diesel and boiler fuels.

Unless the appropriate handling and storage procedures are put in place,

flammable solid wastes that fall into the following three classes should

not be accepted at the kiln due to risks associated with the handling of

these wastes:

- Self reactive and related substances and desensitised explosives.

- Substances liable to Spontaneous Combustion,

- Substances that on contact with water emit flammable gases.

∗ Oxidising Substances and Peroxides

Stable organic peroxides would be acceptable for use/introduction into

the kiln, but inorganic oxidising agents, such as chromates and

permanganates, should not be accepted.



130

∗ Toxic Wastes

Materials that are potentially toxic include petroleum-based fuels and

many waste materials produced by the chemical, pharmaceutical and

petroleum industries. These products can all be utilised as alternative

fuel in a cement kiln. The acceptance procedure for these materials must

determine if the toxicological, chemical and physical nature of the

materials pose any significant threats to human health or the

environment.

∗ Infectious Wastes

Infectious waste and untreated medical waste should not be

processed/accepted as an alternative fuel for the kiln because of the

potential health risks associated with handling the material, and because

it can contain surgical steel items that may not be completely destroyed

in the kiln.

∗ Radioactive Wastes

The kiln must not accept wastes that are determined as radioactive. It is

important that procedures are in place to determine that a waste is not

radioactive both prior to acceptance and when it is received at the

facility.

∗ Corrosive Wastes

The corrosive wastes that could be accepted at the kiln would be largely

organic in nature, e.g. acetic acid (which is the main ingredient in

vinegar). Mineral acid wastes such as sulphuric, hydrochloric and nitric

acid should not be accepted, as they could potentially have a significant

impact on process stability in the kiln.

7.2.3. Summary of Acceptable Waste in terms of SANS 10228

Table 7.2 summarises the wastes acceptable for use as an alternative fuel in

terms of SANS Classes.



131

Table 7.2: Categories of waste that can be accepted by Kiln 3 and restrictions

by SANS Class

Class Description Category Allowed Restrictions/Requirements

Class 1 Explosives Possibly subclass 1.5 – very

insensitive substances and

subclass 1.6 - extremely

insensitive substances.

Must not explode in external

fire test.

Class 2 Gases

compressed,

liquefied or

dissolved

under

pressure

Only selected inert or

flammable gases, e.g. CFCs

No toxic gases

Class 3 Flammable

Liquids

All packing classes I to III

Class 4 Flammable

Solids;

Substances

Liable to

Spontaneous

Combustion;

Substances

that, on

Contact with

Water, Emit

Flammable

Gases

None Substances should pass the

tests for pyrophoric and self-

heating substances and not

emit flammable gases unless

the controls are in place to

handle these types of

compounds.

Class 5.1 Oxidising

Agents

Limited to Organic

Compounds

No strong inorganic oxidising

agents such as chromates and

permanganates

Class 5.2 Organic

Peroxides

All Must be stable for handling,

storage and transport

Class 6.1 Toxic

Substances

All Subject to limits on selected

components.

Class 6.2 Infectious

Substances

None No Exceptions

Class 7 Radioactive

Substances

None No Exceptions

Class 8 Corrosive

Substances

Limited to Organic

Compounds

No mineral acids such as

sulphuric acid, hydrochloric

acid and nitric acid

Class 9 Miscellaneous

Dangerous

Substances

and Goods

The waste should be

evaluated individually

according the Minimum

Requirements and classified

into one of the other

Classes.

See Classes 1 to 8.



132

7.2.4. Waste and AFR Standards / Specifications

AFR specifications would be defined by regulatory requirements and specific

requirements of the kiln.

• Regulatory requirements (operating permits):

There are currently no formal regulatory requirements which govern the use

of alternative fuels and resources (AFR) in South Africa . Without South

African standards and specifications to govern the use of AFR, waste

standards, specifications and procedures have been adopted to ensure that

the risks can be effectively managed. A permit would be required from DWAF

for the short-term storage of waste at Kiln 3. Regulatory requirements would

be required to refer to health, safety and environmental aspects.

• Plant specific requirements:

Plant specific requirements refer to cement plant operations (i.e. stable kiln

operation, handling and storage) and product quality (clinker). Cement plant

requirements are required to be defined individually for each kiln at each

cement plant.

Specifications apply to the four key aspects of AFR quality control, i.e. plant

operation, product quality, health and safety, and environmental impact.

• Plant Operation:

∗ Burning process: moisture/water content, ash content, sulphur, alkalis,

halogens, calorific value.

∗ Materials handling (i.e. storage and feed system): viscosity/density,

solids content, pH value, immiscibility, flash point.

Product Quality:

∗ Ash composition, sulphur, halogens, heavy metals, ‘interfering’ elements

(alkalis, phosphorous), radioactivity.

• Health and Safety:

∗ Physical and chemical properties: flash point, pH value, toxic organics

and inorganics, i.e. heavy metals, free cyanides, PCBs, PAHs, pesticides,

carcinogens, radioactivity, infectious materials and free asbestos fibres.

• Environmental Impact:

∗ Atmospheric emissions: heavy metals (i.e. mercury), Volatile Organic

Compounds (VOCs), sulphur, halogens, cyanides, ammonia.

∗ Effluents and leaching properties: heavy metals, organics and other

soluble components.



133

The relationship between waste/AFR properties (i.e. specifications) and the four

key management aspects is summarised in the matrix in Table 7.3.

Table 7.3: Properties of fuel that can potentially affect product quality, plant

operation, health and safety and environment

PropertiesProduct

Quality

Plant

Operation

Health and

Safety

Environment

Viscosity / density X

pH value X X

Flash point X X

Solids content X

Calorific value X

Water content X

Ash content /

compositionX X

Radioactivity X X X

Sulphur X X X

Halogens X X X

Heavy metals X X X

Alkalis X X

Organics X X

Particle size X

The input of different sources of AFR into the kiln would require the operator to

adjust the fuel feed rate to prevent any fluctuations in the operation of the kiln.

As illustrated in Table 7.3 the physical and chemical properties of AFR can

potentially have an impact on the kiln operation, but these can be successfully

controlled as the fuel types (and characteristics) feeding into the kiln would be

known. For example, the viscosity and density of the AFR will determine the

pump pressure that would be required to deliver the material to the kiln, i.e. it

has an impact on the plant operations but would have almost no effect on the

product quality, health and safety and the environment. Although some sources

of AFR (e.g. radioactive material) have a very low effect on the operation of the

plant, the AFR would be unacceptable as the impact on health, safety and the

environment could be potentially high in the long-term, and the product quality

would be compromised.

7.2.5. Acceptable Limits for Elements in AFR

Table 7.4 lists the limits for various elements as permitted and practised by kilns

accepting AFR internationally. These limits have been proven to be acceptable in

terms of plant operations, the health and safety of the personnel, the

environmental impact and the quality of the end product, i.e. the clinker.



134

The upper and lower limits can vary considerably, and the d’Obourg plant limits

have been included as a guideline, as these are considered acceptable for

Dudfield's Kiln 3.

Table 7.4: AFR Specifications and range of acceptable limits of elements

(including heavy metals)

Unit Low High Holcim

Cement

D’Obourg

Sulphur (S) % 0.5 5.0 3.0

Total organo-chlorine (Cl) % 0.3 6.0 6.0

Total organo-fluorine (F) % 0.02 0.2

Cyanide (CN) ppm 100 1 000 100

PCB ppm 10 150 30

Arsenic (As) ppm 5 200 200

Silver (Ag) ppm 5

Barium (Ba) ppm 1 000

Beryllium (Be) ppm 0.5 50 50

Cadmium (Cd) ppm 0.8 500 100

Cobalt (Co) ppm 6 200 200

Chromium (Cr) ppm 40 3 000 100

Copper (Cu) ppm 100 1 000 1 000

Mercury (Hg) ppm 0.5 50 10

Nickel (Ni) ppm 25 1 000 1 000

Lead (Pb) ppm 50 5 000 1 000

Antimony (Sb) ppm 1 800 50

Selenium (Se) ppm 1 100 50

Thallium (TI) ppm 1 100 100

Vanadium (V) ppm 10 3 000 1 000

Zinc (Zn) ppm 400 15 000 5 000

The limits for the various components listed in Table 7.4 are dependent on a

number of factors including:

• Volatility: This is a major determining factor in the behaviour of chemical

elements and their compounds in the alkaline and oxidising environment of

the kiln and is dependent on the rate of incorporation into the clinker:

∗ Non-volatile components include magnesium oxide (MgO); titanium

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

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

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

oxide (Cr2O3).

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

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



135

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

potassium oxide (K2O); sodium oxide (Na2O); zinc oxide (ZnO); lead (II)

oxide (PbO); and some metal chlorides.

∗ Components of high volatility, which include cadmium oxide (CdO);

thallium oxide (Tl2O); and mercury (Hg).

• The presence of chloride, which can increase the volatility of a few elements,

e.g. Lead.

• The concentrations of the species in other input materials, e.g. coal, clay,

iron ore, etc.

• The oxidation of some elements to their higher oxidation states can occur in

the kiln. For example, if too much chromium in present in the kiln feedstocks

then some can be oxidised to chromium (VI) and lead to a product that

leaches this relatively mobile species.

• The leachability of the final clinker and cement products. The leaching of

toxic components above that normally found in clinker and too much salt can

lead to an unacceptable efflorescence in some cement products.

7.3. Environmental Fate of the Elements

The chemical and physical properties of cement and clinker are specifically

determined by the major elements present in the raw materials and fuels used in

the burning process. The natural materials and fuels used in the system also

contain trace elements, whose concentrations are determined by their

geochemical distribution in ore deposits and may vary in relatively wide ranges.

The introduction of secondary substances, such as AFR could potentially increase

the amounts of these trace elements in the system.

The major raw materials for cement production are combined in typical

proportions of 70% - 90% limestone and 10% - 30% clay plus 0 - 1% of selected

material such as iron oxide, sand and bauxite, which are used to correct any

deficiency in the two primary materials. The coal that is traditionally used

contains reasonable quantities of inorganic materials, for example, some low

grade coal produced in South Africa contains up to 20% by mass of ash, which in

a cement kiln becomes incorporated into the clinker.

Table 7.5 provides some typical concentrations of trace elements found in the

primary raw materials and coal (Zeevalkink, 1997).



136

Table 7.5: Typical Concentrations of Selected Trace Elements in Raw Materials

and Coal (mg/kg)

Element Limestone Clay Coal

Arsenic (As) 0.2 - 12 13 - 23 1 – 13

Chromium (Cr) 0.7 - 12 20 - 90 1 - 50

Mercury (Hg) 0.005 – 0.10 0.02 – 0.15 0.05 – 0.61

Lead (Pb) 0.30 - 21 10 - 40 5 - 27

Zinc (Zn) 1.0 - 57 55 - 110 20 - 150

All three major input materials contribute to the concentrations of trace species,

as they occur naturally in the environment. The addition of AFR will potentially

contribute to these components and, hence, the limits proposed for the most

important elements in the AFR that will be accepted at the kiln. As indicated in

section 7.2.4, the potentially volatile components include sulphur trioxide (SO3),

potassium oxide (K2O), sodium oxide (Na2O), zinc oxide (ZnO), lead (II) oxide

(PbO) and some metal chlorides and those components of high volatility including

cadmium oxide (CdO), thallium oxide (Tl2O), and mercury.

Initially, AFR will only form approximately 35% of the total fuel used, while the

limits provided in Table 7.4 are based on a 100% AFR fuel load. This assumption

has been made to ensure that the levels that could potentially end up in the final

clinker or that are collected in the gas clean-up system are acceptable. In

general, for the low volatility elements, the incorporation rate into the clinker is

very high and very little is found in the dust particles. The more volatile species

tend to vaporise and pass into the gaseous phase of the kiln, where the new

compounds formed condense out on the cooler parts of the kiln or the pre-heater

or precipitate on the feed material of kiln dust. For example, chromium, nickel

and vanadium are incorporated into the clinker and the fraction that collects on

the kiln dust is returned to the kiln when the dust is recycled. It is found that in

kilns with a pre-heater, such as that fitted to Dudfield Kiln 3, even cadmium and

zinc act as low volatility elements. The volatile fraction of lead and zinc, which

averages about 7 - 8% of the total, is incorporated into the dust collected, which

is returned to the kiln. Thus, even the relatively volatile elements are finally fixed

in the clinker matrix and therefore do not pose a significant risk to human health

or the environment.

Chromium, which occurs in the input materials in moderate amounts, can

potentially be oxidised to chromium (VI) in the oxidising atmosphere of a cement

kiln and, therefore, the total chromium (Cr) accepted in the kiln from all sources

must be carefully controlled. The chromium, as Cr(III) or Cr(VI), would be

present in the clinker. Cr(VI), if present in significant amounts could leach from

the cement during use, this is potentially harmful to human health due to the

known carcinogenic nature of Cr(VI).



137

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


It is important to note that leaching tests conducted on cement represents a

worst case scenario, because cement is usually only a fraction of the materials

used to make mortar, concrete and concrete products and the product hardens

into a matrix that is solid and largely impermeable. Leaching tests on cement

products, such as bricks and board, show that they do not leach trace elements in

quantities that are environmentally significant, i.e. they meet the standards

required by the Department of Water Affairs and Forestry’s Minimum

Requirements.

Mantus (1992) and Zeevalkink (1997) provide an in-depth discussion of the

above issues. Section 7.4 provides a further discussion of the environmental fate

of trace elements.

7.4. AFR Management Procedures

As AFR is typically waste-derived fuel, the management procedures fall under the

Duty of Care requirements that are included in National Environmental

Management Act (No 107 of 1998), and the Environment Conservation Act (No 73

of 1989), as well as the Department of Water Affairs and Forestry’s Minimum

Requirements. The primary objectives are to ensure that all potentially

hazardous waste is classified, handled, transported and finally utilised or disposed

of in a safe and environmentally acceptable manner. This section discusses the

major issues and procedures to be adhered to, with a more comprehensive

discussion of the required procedures presented in Appendix I.

• Acceptance Procedures for AFR

∗ Initial Acceptance Procedures: If a waste is being considered as an AFR, a

complete analysis/study of the physical, chemical and toxicological

properties must be undertaken to determine whether the waste can be

safely used as a fuel and the verify it satisfies predetermined and

approved criteria. Documented procedures for analysis of the waste

usually by an off-site accredited laboratory should be prepared, and made



138

available. The acceptability of the material will be determined by the

concentration of various hazardous elements (see table 7.4) and the

ability for the waste to be handled, transported and stored on site. The

form of the waste material is an important consideration at initial

acceptance, as the material is required to be handled and fed into the kiln.

∗ Final Acceptance Procedures: Due to of the nature of waste materials, the

potential hazards and the wide variety generators, it is essential to verify

that the AFR arriving at the Dudfield plant matches the original analysis

profile. A sample of the waste should be taken immediately upon arrival

at the plant and the key analytical parameters, identified during the initial

acceptance study, checked by an on-site laboratory at the Dudfield plant.

This procedure must be adhered to before the AFR is allowed to be

discharged to the storage area or directly into the kiln. Non-conformance

to the requirements would lead to the AFR being sent back to the

generator.

∗ Laboratory and Analytical Requirements: The capability of an on-site

laboratory at the Dudfield plant that would be required to conduct the

quality control tests on AFR is different to that of the laboratory normally

associated with a traditional cement plant. Accordingly the laboratory

must upgraded to be able to analyse for potentially hazardous elements,

e.g. heavy metals including mercury and organic compounds, e.g. PCBs,

as well as bulk parameters such as calorific value and flash point.

• Documentation: A detailed documentation system that tracks the AFR from

the waste generators premises to the Dudfield plant is required to ensure

cradle to grave control over the waste stream. A Waste Manifest Document

must be generated to serve as a tracking document, and should contain

information for the laboratory, the kiln and the accounting department. In

addition, a Transport Emergency Card, which gives information on the AFR to

the emergency services in the event of an accident, plus a Material Safety

Data Sheet, should accompany each vehicle. Procedures must be in place in

order to address the following:

∗ Non-conformance: An investigation into the reasons for the non-

conformance must be initiated and corrective measures implemented to

prevent further non-conformance.

∗ Security: Handling of waste requires strict security as some materials are

valuable, e.g. expired pharmaceuticals and containers may contain highly

hazardous material. The security issues include those at the customer’s

premises, during transport, storage, and the management of empty

containers.

• Packaging and Labelling: Using the correct packaging for the AFR is critical

at all stages of handling. The packaging and labelling required depends on

the physical and chemical properties of the AFR. The specifications for most



139

materials are included in SABS 0229: Packaging of Dangerous Goods for Road

and Rail Transportation in South Africa. Waste which would have to be

packaged and labelled could include solids, liquids, sludges and gases, and

the waste could have one or more hazardous characteristics, i.e. flammability,

reactivity, corrosivity and toxicity.

• Loading: Loading procedures are determined by the physical state of the AFR

(i.e. solid, liquid, sludge or gas) and its hazardous characteristics (i.e.

flammable, reactive, corrosive and toxic). The procedures are well defined

and must be adhered to. When loading, materials must be in a form

appropriate for acceptance by the kiln.

• Transport: The transport of a waste material is controlled strictly by

legislation and a number of SABS / SANS codes of practice (refer Appendix I,

section 5.3 for a list of these codes of practice). Key issues to be considered

when transporting AFR are:

∗ Selection of Transporter/Contractor

− The fitness of the driver to be in control of a vehicle

− The vehicle roadworthiness

− The signage used on the vehicle

− Emergency Procedures

− Selection of Traffic Route

− Overloading of Vehicles

− Securing the Load

− Incompatible Loads

* Physical State: Whether the AFR is a solid, liquid, sludge or gas.

* The Transport Regulations: Appendix I section 5.3 contains a list of these

requirements

* Emergency Procedures

• Off-loading: As with transport, off-loading of an AFR at the Dudfield plant

will depend on its physical and hazardous characteristics. Procedures

required should include those for management of dust, spillages and safety

issues such as the handling of flammable liquids. Off-loading must only be

permitted within the designated storage area, and be supervised by

appropriate personnel.

• Handling, Storage and Feeding to the Kiln: Issues that must be

considered in the handling, storage and feeding include:

* Blending of various AFR streams to ensure that the material that is fed into

the kiln has consistent properties (i.e. is homogenous). This can reduce

the potential environmental impact as a consistent AFR allows the kiln

operator to control the risk of unanticipated reactions in the kiln.



140

* Meet infrastructure requirements to receive, handle and feed various AFR

types. For example, shredded tyres can be readily stored and fed into the

kiln, however whole tyres could be accepted but required specific on-site

infrastructure.

* Storage should be kept to a minimum and should be sufficient for only a

few days. Appropriate storage areas for different types of AFR should be

provided, and the stored AFR protected from the elements.

* Feeding into the Kiln: The feeding into Kiln 3 will depend on the physical

state of the material.

− Solid wastes: Solid wastes will be shredded and fed via a conveyor

and triple flap system into the upper-end of the Dudfield kiln.

− Liquid wastes: Liquid waste can be pumped into the kiln at three

inlets: the pre-calciner, the upper-end or the lower-end. Potential risk

operations include disconnection and cleaning of pipes.

− Sludge Wastes: Sludges, depending on their consistency, can be

handled either as a liquid or solid. The thicker sludges can be diluted

with compatible liquid waste or pumped directly into the kiln. The

thicker sludges can be blended with compatible solid wastes (e.g.

sawdust) and fed into the kiln in a similar manner to the solid wastes.

− Gaseous Wastes: Gaseous wastes should be input into the kiln via a

suitable gas line, which can accept the connection of various types of

cylinders and other containers.

• Power Failure: Dudfield Kiln 3 is fitted with a back-up generator that

ensures the operation of the kiln’s essential systems. The AFR feed would

automatically stop, and would only resume once the power is restored and

the kiln has reached full operating temperature using coal.

• Emergency Procedures: Emergency procedures must be developed to

protect both employees and neighbours to the site from unplanned events at

Dudfield Kiln 3. If AFR is present in such a form or quantity that it has the

potential cause a major incident, then the Dudfield Kiln 3 would be need to be

registered as a Major Hazard Installation in terms of the Occupational Health

and Safety Act (No 85 of 1993; GN R.60).

7.5. Risks and Significance of Risks

The potential risks associated with the use of AFR in the manufacture of cement

are included in Table 7.6 together with an assessment of the significance of the

risks posed by natural events, technical problems and human error.


Assessment of the Suitability of Waste as an Alternative Fuel 31-Aug-04141

Table 7.6: Potential Significance of Risks associated with the use of AFR posed by Natural Events, Technical Problems and Human

Error


Process

Waste Pre-

acceptance

Incorrect analysis or interpretation

of results could lead to incompatible

waste being accepted by facility.

Local Short term Slight Unlikely Low

Waste

Collection

Poor collection practices could lead

to minor spills.


Transport Accidents could lead to spillage of

material.


Waste

Receiving

Area

Poor off-loading practices could lead

to minor chemical spills.


Waste

Acceptance

Incorrect check analysis or

interpretation of results could lead

to incompatible waste being

accepted by facility.

Local Short term Slight to

Moderate

Unlikely Low

Waste

Storage

Incompatible waste stored or

flammable waste incorrectly

managed could lead to risk of fire or

explosion.


Gas Storage Improper storage of the flammable

gas could lead to fire or explosion.


Utilisation of

AFR

Poor operation of the plant could

lead to incomplete combustion.

Local Short term Moderate Very Unlikely Low to Moderate

Products

from the

Kiln

Contaminated clinker and cement

products entering the market.

National Long term Severe Very Unlikely Low


Assessment of the Suitability of Waste as an Alternative Fuel 31-Aug-04142


Natural Events

Flooding Flood water may enter waste

storage areas.



considerable risks to plant personnel

inside the facility.

Local Short term Very severe Very Unlikely High


considerable risks to the

environment outside the facility.


High Winds High winds could disperse pollutants

into the environment.

Local or

Regional

Short term Moderate Very Unlikely Low

Human Error

Data Entry

Error

Incorrect data could be provided by

the client or be input into the

database.


Unauthorise

d Access

People could gain unauthorised

access and exposed to potentially

hazardous materials.

Local Short to long

term

Severe Unlikely Low

AFR Spills Chemical spills could result in

contamination of soil and water.

Local Short term Severe Very Unlikely Low



143

7.6 Recommendation on the determination of suitable AFR






7.6.1. Typical wastes excluded for use as Alternative Fuels.


have been identified as unacceptable for the AFR programme at Dudfield. These





• 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


• Products or wastes that are excluded as a suitable AFR, listed in Table 7.2.




• Wastes that contain unacceptably high levels of selected components that will




levels of halogenated hydrocarbons, etc. (refer to Table 7.4).




batteries etc.).


In addition, some waste streams could be an acceptable fuel, but require pre-

treatment before they would be acceptable for use at the kiln. This pre-

treatment will not be undertaken at Dudfield plant.



144

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:




treatment)


• Whole batteries



• Mineral acids



In addition, wastes or potential alternative fuels that exceed the element limits in

Table 7.4 should be excluded or processed to bring them within the acceptable

parameters.

7.6.2. Typical wastes accepted for use as Alternative Fuels.

Wastes that are acceptable as AFR for use by Kiln 3 should be delivered directly

to Dudfield plant. The suitable waste streams could include other non-hazardous

and hazardous wastes such as, but not limited to:

• Scrap tyres

• Rubber

• Waste oils

• Waste wood

• Paint sludge

• Sewage sludge

• Plastics

• Spent solvents

Of particular concern in South Africa is the disposal of scrap tyres to landfill, no

longer an acceptable waste management practise. The SATRP (South African

Tyre Recycling Project) are investigating alternate solutions to deal with the scrap

tyre problem in South Africa. Government is presently promulgating legislation to

discourage the inappropriate disposal of scrap tyres. As the number of scrap

tyres generated in South Africa is estimated at ~10 million per annum, with

~2 million being used to produce recycled rubber and recycled rubber products

the need for an appropriate disposal method is critical. The use of scrap tyres as



145

an alternative fuel offers an environmentally acceptable and cost effective option

for managing the scrap tyre problem in South Africa.

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


the alternative fuel is required to be of an appropriate volume so as to supply a






will not be undertaken at Dudfield plant.

For the larger AFR streams that would be delivered directly to the kiln, an on-site

storage facility would need to be provided to accommodate/store an appropriate

reserve capacity.

The correct management of the wastes and the AFR is critical to the success of

this project and its operations. It is essential that the use of AFR is carried out in

a manner that does not impact on human health and well being and the

environment. The implementation of the procedures proposed in this section of

the report, and Appendix I, would ensure that any possible impact is minimised

and that the environmental and health risks are acceptable.

7.7 Proposed Monitoring, Control and Mitigation Measures

7.7.1 Environmental Monitoring Programme

As with any process and its associated procedures, the operations must be

carefully monitored for legislative and operational compliance to ensure that no

harmful activities or consequences arise from the use of alternative fuels.

The environmental monitoring requirements would be specified in permits issued

to the Holcim South Africa Dudfield plant in terms of the Environment

Conservation Act and the Atmospheric Pollution Prevention Act (No 45 of 1965)

and the DWAF minimum requirements. The following sections briefly indicate the

type and extent of monitoring that is required.

• Ground and Surface Water

The number of boreholes that will be required to monitor the site will be

determined from the geological studies after discussions with the Department

of Water Affairs and Forestry (DWAF). Any existing borehole network will

most likely have to be expanded by locating additional boreholes. DWAF has



146

specific requirements for borehole water testing, as outlined in the Minimum

Requirements for Water Monitoring at Waste Management Facilities and the

Minimum Requirements for Waste Disposal to Landfill, i.e. for background,

demonstration and regular monitoring. The actual requirements for regular

borehole monitoring will be determined in consultation with DWAF. An

example of the investigative and background monitoring parameters normally

required by DWAF is provided in Table 7.9.

Table 7.7: Minimum Background Monitoring Parameters

Ammonia (NH3 as N) Free and Saline Ammonia as N (NH4-N)

Alkalinity (Total Alkalinity) Lead (Pb)

Boron (B) Magnesium (Mg)

Cadmium (Cd) Mercury (Hg)

Calcium (Ca) Nitrate (as N) (NO3-N)

Chemical Oxygen Demand (COD) pH

Chloride (Cl) Phenolic Compounds

Chromium (Hexavalent) (Cr6+) Potassium (K)

Chromium (Total) (Cr) Sodium (Na)

Cyanide (CN) Sulphate (SO4)

Electrical Conductivity (EC) Total Dissolved Solids (TDS)

The surface water parameters that DWAF requires to be analysed are

normally identical to those for the borehole water samples, although site-

specific parameters may be added.

• Air

The frequency of monitoring and the parameters required for air emissions

will determined by the Chief Air Pollution Control Officer (CAPCO). The kiln

has been upgraded to meet the most stringent European requirements and,

therefore, will conform to the standards set by the Department (refer to the

Air Quality specialist report contained in Appendix H).

7.7.2 Initial Acceptance Procedure Control

Specific acceptance procedures and controls (described in Appendix I) must be in

place in order to verify the type of waste being received for storage and

processing. Records and documentation must be reviewed on a weekly basis to

ensure that each load entering the site has been sampled and analysed.

The procedures used to collect waste from the generator’s premises should be

audited by Holcim on a regular basis (e.g. at least annually) to ensure that the

materials are being handled safely and in accordance with Holcim’s requirements.



147

7.7.3 Transport Procedure Control

The transport of waste materials must be audited on a regular basis to ensure

that procedures are followed and that the legislation pertaining to the transport of

hazardous materials is adhered to. This would apply equally to independent

transporters. Drivers must undergo annual driver and medical check ups, to

ensure their fitness and efficiency. Vehicles must be on a planned maintenance

system to ensure that they are maintained in a condition, which is both

roadworthy and in compliance with the transport of hazardous waste.

7.7.4 Final Acceptance Procedure Control

Specific control procedures must be conducted to verify the type of waste being

received. Records and documentation must be reviewed on a weekly basis in

order to ensure that each load entering the site has been sampled and analysed

in accordance with procedure.

• Offloading:

Offloading must be supervised and audited regularly. Offloading equipment

must be on a planned maintenance programme and undergo regular check-

ups.

• Storage:

Storage facilities must be on a planned maintenance system. Documentation

must be tracked to ensure that the different waste types, e.g. non-hazardous

and hazardous, are managed correctly and the storage facilities must be

regularly audited.

• Kiln:

All operations at the kiln, including the waste feeding system, must be

audited regularly.

7.7.5 Compliance Auditing

Auditing of the facilities and associated services is an essential function to ensure

that operating procedures are being adhered to and that liabilities are minimised.

Commitments to I&APs and legal obligations will ensure that these audits take

place and that the results of the audits are not only made known, but are acted

upon timeously. A number of different compliance audits should take place:

• Internal

An internal audit should take place covering operational, health, safety and

environmental aspects, on a daily, weekly and monthly basis. These audits

normally take the form of a checklist that is used by management and staff



148

to ensure that all requirements (i.e. compliance to permits and to the

company’s internal environmental policy and management system) are being

maintained.

• External

Independent external auditors should be appointed to check compliance to

the permits and authorisations every six months, or as otherwise specified in

the permit that will be obtained from the Department of Water Affairs and

Forestry for the storage and utilisation of hazardous wastes. The audits will

conform to all the Minimum Requirements for auditing.

The controlling authorities can also carry out external audits. The authorities

at all levels (local, provincial or national) have the legislative right to audit

the operation at any time as pre-arranged with the operator.

A monitoring committee including interested and affected parties should be

formed and, in fact, may be a permit requirement. If required, the

committee can conduct independent audits on the storage facility and kiln to

ensure satisfactory operation so as to ensure minimal impacts on the

surrounding environment.

Every generator of waste has a the 'cradle to grave' responsibility to ensure

that their waste is treated and disposed responsibly. Therefore, it is very

likely that generators that could potentially supply wastes for use as AFR

would require confirmation that by utilising this type of waste management

option, that they are not creating a long-term liability for their company.

7.7.6. Development of Site Specific Specifications

Site specific specifications (mainly for heavy metals) for wastes used in cement

manufacturing are to be developed and should include the following:

• Establishment of average levels of heavy metals in plant clinker (including

the 'natural' fluctuations) as a 'baseline' reference

∗ without AFR

∗ with AFR over a period of approximately one year

• Establishment of a heavy metals balance (input – output) for the individual

kiln system without AFR

• Calculation of 'transfer coefficients' for all metals

∗ to stack emissions

∗ to clinker

∗ to cement kiln dust

• Calculation of the impact of heavy metals input through AFR substitution by

means of standard software modelling.



149

• Comparison of model calculations against legal limits (stack emissions) and

against 'baseline' clinker levels and optimisation of AFR substitution rate.

• Verification of the balance model by establishment of a heavy metals balance

with AFR utilisation.

This scheme is to allow for both better prediction and optimisation of the use of

AFR based on the chemical composition and the individual substitution rate of the

AFR under consideration.

7.8. Conclusion





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).


Conclusions and Recommendations 31-Aug-04150

8. CONCLUSIONS AND RECOMMENDATIONS

There is a global trend in the cement production industry to seek more

sustainable production methods through the replacement of existing fossil fuels

(e.g. coal) with alternative waste derived fuels. Following this trend, Holcim

South Africa are considering the implementation of an Alternative Fuels and

Resources (AFR) programme.

The AFR programme proposes the replacement of a portion of Dudfield Kiln 3's

traditional, fossil-based fuel (coal) requirements with alternative fuels and waste-

derived materials. This project aims to ensure that at a minimum, 35% of the

traditional fossil fuel usage is replaced by alternative waste-derived fuels.

This Environmental Impact Assessment (EIA) process for the proposed

introduction of an AFR programme at Kiln 3 at the Holcim South Africa Dudfield

plant has been undertaken in accordance with the EIA Regulations published in

Government Notice R1182 to R1184 of 5 September 1997, in terms of the

Environment Conservation Act (No 73 of 1989), as well as the National

Environmental Management Act (NEMA; No 107 of 1998).

The essence of any EIA process is aimed at ensuring informed decision-making

and environmental accountability, and to assist in achieving environmentally

sound and sustainable development. In terms of NEMA (No 107 of 1998), the

commitment to sustainable development is evident in the provision that

“development must be socially, environmentally and economically

sustainable…and requires the consideration of all relevant factors…”. NEMA also

imposes a duty of care, which places a positive obligation on any person who has

caused, is causing, or is likely to cause damage to the environment to take

reasonable steps to prevent such damage. In terms of NEMA’s preventative

principle, potentially negative impacts on the environment and on people’s

environmental rights (in terms of the Constitution of the republic of South Africa,

Act 108 of 1996) should be anticipated and prevented, and where they cannot be

altogether prevented, they must be minimised and remedied in terms of

“reasonable measures”.

In assessing the environmental feasibility of an AFR programme at Dudfield plant,

the requirements of all relevant legislation has been considered (refer to

Appendix J), including inter alia, those of:

• Environment Conservation Act (No 73 of 1989);

• Atmospheric Pollution Prevention Act (No 45 of 1965);

• National Water Act (No 36 of 1998);

• Occupational Health and Safety Act (No 85 of 93);

• Hazardous Substances Act (No 15 of 1993);and



• Relevant SABS Codes in terms of the identification and classification,

handling, packaging, storage and transport of hazardous substances.

This relevant legislation has informed the identification and development of

appropriate management and mitigation measures that should be implemented in

order to minimise potentially significant impacts associated with the project.

The conclusions of this EIA are the result of comprehensive studies and specialist

assessments. These studies were based on issues identified through the EIA

process and the parallel process of public participation. The public consultation

process has been rigorous and extensive, and every effort has been made to

include representatives of all stakeholders within the process.

8.1. Evaluation of the Proposed Project

The preceding chapters of this report provide a detailed assessment of the

environmental impacts on specific components of the social and biophysical

environment as a result of the proposed project. This chapter concludes the EIA

process by providing a holistic evaluation of the most important environmental

impacts. In so doing, it draws on the information gathered as part of the EIA

process and the knowledge gained by the environmental consultants during the

course of the EIA and presents an informed opinion of the proposed introduction

of an AFR programme at Kiln 3 at the Dudfield plant.

The Holcim Dudfield plant was constructed more than 50 years ago and is located

within an area zoned for industrial use. Impacts to or the disturbance of the land

within and surrounding the Dudfield plant already exist, and have done so since

the initial construction of the facility. The AFR programme proposed at Dudfield’s

Kiln 3 involves the reduction in the use of coal through supplementation of the

fuel required with AFR. As the necessary upgrade of Kiln 3 to accept AFR has

already been undertaken, the use of AFR will not require any additional changes

to the footprint area of the existing cement plant. Therefore, no impact on

surrounding land uses, vegetation or heritage sites are anticipated as a result of

the proposed project.

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

include:

• impacts associated with emissions to air from the plant;

• impacts associated with the transportation of AFR to Dudfield plant;

• impacts associated with the storage of AFR on site for a limited period;

• impacts on the social environment;

• suitability of waste as an alternative fuel resource; and

• potential project benefits.



These are discussed in more detail below.

According to the US Air and Waste Management Association's (A&WMA) Air

Pollution Control Manual, the use of wastes as a fuel and a raw material in

cement kilns is a reliable and proven technology, offering a cost-effective, safe

and environmentally sound method of resource recovery for many types of

hazardous and non-hazardous wastes (http://gcisolutions.com/dgawma01.htm).

Conditions needed to manufacture cement (high temperature, turbulence and

long gas residence times) are the same conditions required for total destruction

of hazardous waste. Cement kilns burn hotter, have longer gas residence times,

and are much larger than other commercial thermal treatment facilities. These

advantages, together with the degree of mixing in the kiln, make cement kilns an

excellent technology for recovering energy from hazardous and non-hazardous

waste (www.ckrc.org/issues/99475523.html).

Results of research undertaken world-wide by the cement industry and

independent institutions (such as the US EPA) have indicated that the impacts

associated with the introduction of an AFR programme in cement kilns does not

impact significantly on the environment when compared to the use of traditional

fossil fuels. However, this is reliant on appropriate management of waste,

including the classification, selection, handling and storage thereof. Therefore,

this EIA has placed emphasis on the identification of suitable wastes as

alternative fuels and the waste management requirements associated with the

introduction of an AFR programme at Dudfield plant.

8.1.1. Impacts Associated with Emissions to Air from the Plant

Releases from the cement kiln are a result of the physical and chemical reactions

of the raw materials and from the combustion fuels. Typical air pollutants from

cement manufacturing include sulphur dioxide (SO2), oxides of nitrogen (NOx),

inhalable particulates (PM10), heavy metals, organic compounds and dioxins and

furans.

During the EIA process, concern was raised regarding the potential impacts

associated with dust, and dioxins and furans and the health risk posed to local

communities. From the results of the specialist study undertaken as part of this

EIA, it is anticipated that an impact of low significance on air emissions will result

with the introduction of an AFR programme at Kiln 3 at Dudfield plant as the

emission levels remain below the DEAT guidelines.

The exit gases from Kiln 3 are de-dusted in bag filters, and the dust returned to

the process. Therefore, dust levels associated with this process are low and will

not impact significantly on the surrounding environment. This will continue to be

the case with the introduction of an AFR programme.



Dioxins and furans are a family of persistent organic chemicals detectable in trace

amounts throughout the environment. The US EPA, international Agency for

Cancer Research and US Department of Health report that excessive exposure to

2,3,7,8-tetrachlorodibenzo-p–dioxin (2,3,7,8-TCDD) can cause of wide range of

very harmful human health effects, including cancer (EPA, 2004). Studies by the

US EPA and French Academy of Sciences have, however, indicated that it is highly

unlikely that dioxins would increase cancer incidence in people at the low

exposure levels commonly encountered in the environment or from food (Rotard,

1996), and that no fatal case associated with these compounds has ever been

reported (Constans, 1996).

Dioxins can be formed from any burning process, and cement kilns are no

exception. The potential for dioxin formation in cement manufacture is a function

of raw materials and kiln technology, and is not related to the types of fuel used.

Dioxin emissions are generally in the range of detection limits and the level of

emissions can depend on the type of kiln technology employed. “Cement kilns

control dioxin formation by quenching kiln gas temperatures so that gas

temperatures at the inlet to the particulate matter control device are below the

range of optimum dioxin/furan formation” (EPA, 2004).

The cement industry has been more successful than any other in reducing

emissions of dioxins and furans. Through intensive research, an understanding of

the nature of dioxin formation in combustion emissions has been established, and

they have succeeded in learning how to reduce those emissions. As a result since

1990, dioxin emissions from kilns that recover energy from hazardous waste have

been reduced by 97%. This has been corroborated by independent research

undertaken by the US EPA (www.ckrc.org/ncafaq.html).

Conclusions of the specialist air quality study undertaken as part of this EIA (refer

to Chapter 6) are in agreement with these international findings and indicate that

the introduction of an AFR programme at Kiln 3 at Dudfield plant will not have a

significant impact on air quality.

In order to monitor emissions from Dudfield plant, Holcim South Africa has

installed state-of-the art OPSIS continuous emission measuring equipment that

is linked to the kiln operating system. The equipment currently measures 12

emission streams on a continuous basis, with a further annual measurement of

12 heavy metals and dioxins and furans. Emission levels will be subject to the

prescribed requirements of the Stack Registration Permit issued by CAPCO.

Alarms are in place in order to indicate if any emission approaches its limits, thus

allowing for immediate corrective action to be taken. All emission data captured

by the OPSIS equipment will be available to CAPCO for auditing purposes.



8.1.2. Impacts Associated with the Transportation of AFR to Dudfield

Plant

Issues surrounding the transportation of AFR to Dudfield plant were identified

through the EIA process, including impacts on traffic volumes and the potential

disruption to the daily movement patterns of the local population (particularly

residents in Lichtenburg, the Dudfield village and surrounding farming

communities), as well as safety risks to human health and the environment

associated with accidents and spillage of waste. A long-term scenario of six (6)

additional trucks per day transporting AFR to Dudfield plant is anticipated.

Specialist studies undertaken indicate that this will result in a 1% increase in the

traffic volume on the access routes to Dudfield plant, a very small growth in

traffic which is considered to be insignificant. Therefore, impacts in terms of

traffic growth and disruption to traffic patterns are anticipated to be of low

significance. In order to ensure that this impact is minimised, preferred routes to

haul waste to the Dudfield plant have been recommended. These correspond

with those currently being utilised by traffic travelling to Dudfield plant.

In order to minimise the risk to human health and the environment as a result of

potential accidents and spillage of waste, it is essential that appropriate

management and emergency response procedures be in place for the

transportation of AFR to Dudfield. In the event of an accident, the vehicles are

equipped with spill-control kits and action should be taken as soon as possible in

order to contain spillages while waiting for backup. The transport of waste must

be supported by a HazMat Emergency Response team in order to contain and

clean up any spill, in order to minimise impacts on the environment and


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

Limited Period


the feed is preferably required to be of an appropriate volume to supply a









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.

8.1.4. Impacts on the Social Environment


which is the closest town to the facility. The area surrounding Dudfield plant is

sparsely populated, typical of a rural farming community. The greatest



approximately 1 km south-west of the plant. Impacts to or the disturbance of

surrounding communities already exist, and have done so since the initial

construction of the facility more than 50 years ago.

Potential impacts on the social environment associated with the introduction of an

AFR programme at Dudfield plant identified and assessed within this EIA include:

• disruption in daily living and movement,

• impacts on public health and safety,

• impacts on infrastructure and community infrastructure needs,

• local and intrusion impacts

• regional benefits.

As impacts in terms of traffic growth and disruption to traffic patterns are

anticipated to be of low significance, no significant impact on daily living and

movement patterns of the local population is anticipated. Risks to human health

are associated with potential vehicle overloading, accidents and spillage of waste

during transportation of the AFR. With the implementation of appropriate

management and emergency response procedures for the transportation of AFR

to Dudfield, this potential impact is considered to be unlikely to occur and of low

significance.



Specialist studies have indicated that no risk to human health is anticipated with

the introduction of an AFR programme as a result of air emissions. Risk

assessments undertaken internationally have shown that the use of waste

(hazardous and non-hazardous) as fuel in cement kilns poses no increased risk to

human health and the environment (www.ckrc.org/ncafaq.html; refer Appendix

J).

Potential health and safety risks to employees has been identified as a potentially

significant impact. However, with the provision of appropriate precautionary

measures such as strict acceptance procedures, accurate laboratory testing, data

sheets, training, controls, procedures, health monitoring, facility design and

emergency response planning, the potential impacts on the health and safety of

employees will be managed to acceptable levels. In addition, it is important that

relevant safety information is provided to sub-contractors and visitors to the

premises in order to ensure their safety.

Limestone mining and cement manufacture are two of the major economic

activities currently undertaken in the area, providing employment to members of

the local community. The continued operation of the Dudfield plant in an

environmentally and economically sustainable manner will secure these



8.1.5. Suitability of Waste as an Alternative Fuel Resource

The selection, acceptance and appropriate management of the waste-derived fuel

are critical to the success of this project and its operations. It is essential that

AFR management be carried out in a manner that does not impact on human

health and well-being and the environment.


















• Documentation



• Transportation


• Offloading














The are a variety of products or wastes that should not be processed or utilised













batteries etc.).




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:




treatment)


• Whole batteries



• Mineral acids







Wastes that are acceptable as AFR for use by Kiln 3 as an alternative fuel source

include non-hazardous and hazardous wastes such as, but not limited to scrap

tyres, rubber, waste oils, waste wood, paint sludge, sewage sludge, plastics, and

spent solvents.

8.1.6. Project Benefits

The utilisation of alternative fuels in the cement industry is in-line with initiatives

of National Government, particularly the National Waste Management Strategy

(NWMS) which focuses on waste prevention and waste minimisation. The

practice of employing alternative fuels in cement plants promotes the materials

recovery and recycling industry, which is in line with the principles of the NWMS.

Where recycling of waste is not possible, landfill or incineration is the most

common disposal practice available for many wastes. The introduction of an AFR

programme would assist in the reduction in the amount of waste required to be

disposed of to landfill or other means, and assist in the reduction of greenhouse

gas emissions. The use of waste-derived fuel as AFR in cement kilns provides a

service to society by dealing safely with wastes that are often difficult to dispose

of in any other way (e.g. scrap tyres; www.ckrc.org/issues/993135035.html).

Of particular concern in South Africa is the disposal of scrap tyres to landfill. The

SATRP (South African Tyre Recycling Project) are investigating alternate solutions



to deal with the scrap tyre problem in South Africa. Government is presently

promulgating legislation to discourage the inappropriate disposal of scrap tyres.

As the number of scrap tyres generated in South Africa is estimated at ~10

million per annum, with only ~ 2 million being used to produce recycled rubber

and recycled products the need for an appropriate disposal method is critical.

The use of scrap tyres as an alternative fuel offers an environmentally acceptable

and cost effective option of managing the excess scrap tyre problem in South

Africa, as the landfilling of scrap tyres is no longer an acceptable practise.

The nature of the cement manufacture process makes waste suitable for the use

as AFR by ensuring full energy recovery from various wastes under appropriate

conditions. Any solid residue from the waste then becomes a raw material for the

process and is incorporated into the final clinker. This, therefore, results in the

conservation of non-renewable natural resources, as well as a reduction in the

environmental impacts associated with mining activities.

Depending on the quantity of the waste-derived fuel available and the energy

content of this fuel, Holcim South Africa will be able to replace between 35 - 50%

of their traditional coal-based fuel with AFR. Including the kiln efficiency

upgrade, a total reduction of between 40 000 and 90 000 tons of coal/annum is

estimated by Holcim for Kiln 3.

8.2. Conclusions

The introduction of the AFR programme at Kiln 3 of the Dudfield plant provides

the opportunity to:

• Recover energy from combustible wastes and inorganic materials.

• Conserve non-renewable resources such as fossil fuels, i.e. coal and oil, and

inorganic materials such as iron ore.

• Reduce the volume potentially polluting materials being disposed by landfill

and reducing overall waste volumes to landfill.

For these benefits to be fully realised, strictly controlled management procedures

are required to be implemented for the entire AFR programme process. These

management procedures should be detailed in an Environmental Management

Plan (EMP) which includes inputs from the EIA and the permitting authorities.

This will ensure that the waste materials are managed from 'cradle to grave' and

all potential adverse impacts are managed to acceptable levels.

As Dudfield plant is an ISO 14001 accredited operation, the EMP would be

required to form part of the independently audited ISO 14001 programme.



8.3. Permit Requirements associated with the Introduction of an AFR

Programme at Dudfield Plant

The manufacture of cement is a mature industrial activity which is strictly

regulated through national and international legislation in terms of environmental

protection, health and safety, and quality of products. The introduction of an

alternative fuels and resources programme at Dudfield plant would also be

regulated by this legislation (refer to Appendix K). In terms of this legislation, a

number of permits are required to be obtained for the implementation of the AFR

programme. A summary of the most relevant permits, licences, certificates and

other authorisations required by Holcim South Africa are detailed in Table 8.1

below. This table must be read in conjunction with the environmental legal

register contained within Appendix K.

Table 8.1: Summary of the most relevant permits, licences, certificates and

other authorisations required by Holcim South Africa for the

introduction of an AFR programme at Dudfield

Applicable Environmental

Law

Aspect Component Compliance Requirement

Environment Conservation

Act, No 73 of 1989 and

Regulations 1182 and 1183

published there under.

Commencement of any activity

that is considered to be

substantially detrimental to the

environment must be preceded

by written authorisation

obtained from the relevant

authority.

An Environmental Impact

Assessment must be submitted

to the Minister of Environmental

Affairs and Tourism (DEAT) or

any other competent authority

identified by the Minister or a

written application for exemption

to conduct an EIA or part thereof

must be submitted to the

relevant authority.

Environment Conservation

Act, No 73 of 1989

Any person, who treats, stores

for a period exceeding 90 days,

or disposes of hazardous waste

on site must apply for a permit

for a waste disposal facility from

DWAF.

If applicable, a written permit

application must be submitted to

DWAF.

Hazardous Substances Act,

No 15 of 1973

The operation may not use,

operate, install or dispose of any

hazardous substance with a

Group I and II: (any substance

or mixture of a substance that

might by reason of its toxic,

corrosive etc.; nature, or

because it generates pressure

through decomposition, heat or

other means, cause extreme risk

of injury etc) or Group III: (any

electronic product with

If applicable, the operation must

apply in writing for a licence at

the Department of Health.




Law


hazardous qualities), unless a

license is in force in respect

thereof.

Occupational Health and

Safety Act, No 85 of 1993 –

GNR 1179 of 25 August

1995

All drivers transporting

hazardous material must be in

possession of a valid Public

Driving Permit: Hazardous, a

medical certificate and a

HazChem training certificate. In

addition they must comply with

the Road Transport Quality

System, have full knowledge of

emergency response procedures,

and be equipped with and

trained in the use of protective

clothing.

Ensure that the relevant drivers

have the correct licences and

that awareness training

programs, highlighting all

transportation of dangerous

goods risks are developed and

implemented on all relevant

driver levels.

Occupational Health and

Safety Act, No 85 of 1993 –

GNR 1179 of 25 August

1995

An employer shall, before any

employee is exposed or may be

exposed to any hazardous

chemical substance, ensure that

the employee is adequately and

comprehensively informed and

trained.

Ensure that awareness-training

programs, highlighting the risks

involved in respect of exposure

to hazardous substances are

developed and implemented on

all employee levels.

Atmospheric Pollution

Prevention Act, No 45 of

1965 (APPA)

No person may conduct a

Scheduled Process in or on any

premises in South Africa unless

that person or company is the

holder of a provisional or current

registration certificate

authorising the carrying on of

the Scheduled Process in or on

the premises concerned.

Apply in writing to the Chief Air

Pollution Control Officer (CAPCO)

at DEAT for provisional or

current registration certificates

for each and every Scheduled

Process, and ensure that the

conditions in the certificate are

complied with at all times.



1965 (APPA)

Any alteration or extension of an

existing building or plant in

respect of which a registration

certificate has been issued is

prohibited unless an application

has been made to the Chief Air

Pollution Control Officer (CAPCO)

for provisional registration of the

proposed alteration or extension.

If applicable, a written

application must be submitted to

the Chief Air Pollution Control

Officer (CAPCO) for provisional

registration of the proposed

alteration or extension.

Alternatively apply for exemption

from CAPCO.

A provisional or current

registration certificate is not

required where the alteration or

extension will not affect the

escape into the atmosphere of

noxious or offensive gases.




Law




1965 (APPA)

The operation shall not install in

or on any premises any fuel-

burning appliance, unless such

an appliance is provided with

effective appliances to limit the

emission of grit and dust to the

satisfaction of the local

authority. A local authority may

require any person to furnish

information as to the fuel or

refuse used in fuel burning

appliances.

A provisional or current

registration certificate is not

required where the alteration or

extension will not affect the

escape into the atmosphere of


Ensure that best practice

technology is used to prevent

the escape into the atmosphere

of noxious or offensive gases.



1965 (APPA)

No local authority shall approve

of any plan that provides for the

installation of any fuel burning

appliance, unless it is satisfied

that a fuel burning appliance is

suitably sited.

If applicable, ensure that all fuel

burning appliances are suitably

sited and that best practice

technology is used to prevent

the escape into the atmosphere

of noxious or offensive gases.



1965 (APPA)

Certain odours may be defined

as noxious or offensive gases

and relevant registration

certificates are needed for the

continued carrying on of those

processes that create these


If applicable, the operation must

have a valid provisional or

current registration certificate to

carry on its business. Submit an

application for the relevant

certificate to CAPCO at DEAT.


References 31-Aug-04163

9. REFERENCES

Acocks, J.P.H. (1988) Veld Types of South Africa, 3rd Edition. Botanical Research

Institute, South Africa.

AEA Technology (2002) Towards a Sustainable Cement Industry: Environment,

Health, and Safety Performance Improvement. An independent study

commissioned by World Business Council for Sustainable Development.

ACMP (Association of Cementitious Material Producers) Air Emissions from a

Cement Kiln: Presentation.

Barnard, H C (2000) An explanation of the 1:500 000 general hydrogeological

map Johannesburg 2526. Department of Water Affairs and Forestry,

Pretoria.

Batchvarova A E and Gryning S E (1990) Applied model for the growth of the

daytime mixed layer, Boundary-Layer Meteorology, 56, 261-274.

Becker, R. (1999) Social Impact Assessment. Netherlands.

Botha, l J and Bredenkamp, D B (1993) Lichtenburg: A case study incorporating

Cumulative Rainfall Departures (CRD). Report No. GH3742, Department of

Water Affairs and Forestry, Pretoria.

Bouwmans I and Hakvoort R (1998) A Framework for the Evaluation of the

Environmental Merits of Waste Co- Incineration. IECEC-98-1225. 33rd

Intersociety Engineering Conference on Energy Conversion, Colorado

Springs, CO, August 2-6, 1998.

Burdge, R.J. (1995) A Community Guide to Social Impact Assessment. Wisconsin:

Social Ecology Press.

Burger L W (1994) Ash Dump Dispersion Modeling, in Held G: Modeling of Blow-

Off Dust From Ash Dumps, Eskom Report TRR/S94/185, Cleveland, 40 pp.

Burger L W, Held G and Snow N H (1995) Ash Dump Dispersion Modeling

Sensitivity Analysis of Meteorological and Ash Dump Parameters, Eskom

Report TRR/S95/077, Cleveland, 18 pp.

CEMBUREAU (1997) Alternative Fuels in Cement Manufacturing, Technical and

Environmental Review. The European Cement Association, April.

CEMBUREAU (1999) ”Best Available Techniques” for the Cement Industry, A

contribution from the European Cement Industry to the exchange of

information and preparation of the IPPC BAT REFERENCE Document for the

cement industry. The European Cement Association, December.

CEPA/FPAC Working Group (1998) National Ambient Air Quality Objectives for

Particulate Matter. Part 1: Science Assessment Document, A Report by the

Canadian Environmental Protection Agency (CEPA) Federal-Provincial

Advisory Committee (FPAC) on Air Quality Objectives and Guidelines.

Chow J C and Watson J G (1998) Applicability of PM2.5 Particulate Standards to

Developed and Developing Countries, Paper 12A-3, Papers of the 11th

World Clean Air and Environment Congress, 13-18 September 1998,

Durban, South Africa.



CIE Document, “Acceptable Levels of Pollutants in Waste for Recovery in the

Cement Industry“ (This is a “Holderbank” Draft Position Paper).

CIE Document, “The Added Value of Waste Recovery in the Cement Industry”

(This is a “Holderbank” Draft Position Paper).

Cochran L S and Pielke R A (1992) Selected International Receptor-Based Air

Quality Standards, Journal of the Air and Waste Management Association,

42 (12), 1567-1572.

Cowherd C, Muleski G E and Kinsey J S (1988) Control of Open Fugitive Dust

Sources, EPA-450/3-88-008, US Environmental Protection Agency,

Research Triangle Park, North Carolina.

Dziembowski, Z M (1995) Grondwatertoestande in die Bo-Molopo Ondergrondse

Staatswaterbeheergebied in 1995. Report GH 2869, Department of Water

Affairs and Forestry, Pretoria.

Department of Environment Affairs and Tourism (2002) White Paper on an

Integrated Pollution and Waste Management Policy for South Africa, April

2002

Department of Environmental Affairs and Fisheries (1984) General and Special

Standards, Requirements for the purification of waste water or effluent.

Government Gazette 18 May 1984, No. 9225, Regulation No 991, 18 May

1984.

Department of Transport (South Africa) (1992) Structural Design of Interurban

and Rural Road Pavements. TRH 4. 9p.

Department of Transport (South Africa) (1995) Manual For Traffic Impact

Studies. 2-1p.

Department of Water Affairs and Forestry (1998) Minimum Requirements for the

Handling, Classification, and Disposal of Hazardous Waste

Department of Water Affairs and Forestry (1998) Minimum Requirements for

Disposal of Waste to Landfill

Department of Water Affairs and Forestry (1998) Minimum Requirements for

Water Monitoring at Waste Management Facilities.

Department of Water Affairs (1996) Amendment of the Requirements for the

purification of waste water or effluent. Government Gazette 15 November

1996, No1864.

Department of Water Affairs and Forestry (1995) Characterisation and mapping

of the groundwater resources, Kwazulu-Natal Province. Mapping Unit 11,

Dept. of Water Affairs and Forestry, Pretoria.

Environmental Protection Agency 40 CFR Parts 63,264,et al. National Emission

Standards for Hazardous Air Pollutants: Proposed Standards for Hazardous

Air Pollutants for Hazardous Waste Combustors (Phase I Final Replacement

Standards and Phase II); Proposed Rule. 20 April 2004 (Page 21205).

Environmental Protection Agency 40 CFR Parts 63,264,et al. National Emission

Standards for Hazardous Air Pollutants: Proposed. Standards for Hazardous

Air Pollutants for Hazardous Waste Combustors (Phase I Final Replacement

Standards and Phase II); Proposed Rule. 20 April 2004 (Page 21249).



EPA (1986) Air Pollution: Improvements Needed in Developing and Managing

EPA’s Air Quality Models, GAO/RCED-86-94, B-220184, General

Accounting Office, Washington, DC.

EPA (1995a) User’s Guide for the Industrial Source Complex (ISC) Dispersion

Model. Volume I - User Instructions, EPA-454/B-95-003a, US-

Environmental Protection Agency, Research Triangle Park, North Carolina.

EPA (1995b) User’s Guide for the Industrial Source Complex (ISC) Dispersion

Model. Volume I - Description of Model Algorithsms, EPA-454/B-95-003b,

US-Environmental Protection Agency, Research Triangle Park, North

Carolina.

EPA (1996) Compilation of Air Pollution Emission Factors (AP-42), 6th Edition,

Volume 1, as contained in the AirCHIEF (AIR Clearinghouse for Inventories

and Emission Factors) CD-ROM (compact disk read only memory), US

Environmental Protection Agency, Research Triangle Park, North Carolina.

Geological Survey, South Africa (1986) Geological Map Sheet 2626 West Rand.

Scale 1:250 000. Geol. Surv., Pretoria.

Godish R (1990) Air Quality, Lewis Publishers, Michigan, 422 pp.

Goldreich Y and Tyson P D (1988) Diurnal and Inter-Diurnal Variations in Large-

Scale Atmospheric Turbulence over Southern Africa, South African

Geographical Journal, 70(1), 48-56.

Gould, Dr R (2000) Gossmann Consulting. Learning Lessons from the Cement Kiln

Saga. (http://gcisolutions.com/dgawma01.htm)

Holcim presentation (2003) Emission Ranges of Cement Kilns. Waltisberg J H,

presentation 20. The Alpha Cement “Understanding Cement Kiln Emission

Coarse and Workshop”.

IRIS (1998) US-EPA's Integrated Risk Information Data Base, available from

www.epa.gov/iris (last updated 20 February 1998).

Jasper, Miller Associates CC (2004) Holcim (South Africa) (Pty) Ltd – Dudfield

[previously Alpha – Dudfield) De-watering Assessment. Ref: JMA/10264.

May 2004.

Junker A and Schwela D (1998) Air Quality Guidelines and Standards Based on

Risk Considerations, Paper 17D-1, Papers of the 11th World Clean Air and

Environment Congress, 13-18 September 1998, Durban, South Africa.

Kletz T.A. (1976) The application of hazardous analysis to risks to the public at

large, World Congress of Chemical Engineering, Amsterdam.

Koenig J.Q. (2000) Health Effects of Ambient Air Pollution. How safe is the air

we breath?, Kluwer Academic Publishers, Boston, pp. 249.

Landesumweltamt Nordrhein-Westfalen (1997) Commissioned by EC DG XI, LUA-

Materialien No. 43, Identification of Relevant Industrial Sources of Dioxins

and Furans in Europe, The European Dioxin Inventory.

Lees F.P. (1980) Loss Prevention in the Process Industries, Butterworths,

London, UK.

Lemarchand D (2000) Burning Issues. Cement Technology, February, pp65 to

67.



Loveday M (1995) Clean Air Around the World. National Approaches to Air

Pollution Control, published by the International Union of Air Pollution

Prevention and Environmental Protection Association, Brighton, 402 pp.

Mantus E K (1992) All Fired Up: Burning Hazardous waste in Cement Kilns,

Environmental Toxicology International, Seattle

Marlowe I and Mansfield D (2002) Toward a Sustainable Cement Industry.

Substudy 10: Environment, Health & Safety Performance Improvement.

AER Technology.

Marticorena B and Bergametti G (1995) Modeling the Atmospheric Dust Cycle: 1.

Design of a Soil-Derived Dust Emission Scheme. Journal of Geophysical

Research, 100, 16 415 - 16 430.

Midgley, D C, Pitman, W V and Middleton, B J (1994a) Surface water resources

of South Africa 1990. Volume II, Drainage Region C: Book of Maps.

Water Research Commission Report No. 298/2.2/94.

Midgley, D C, Pitman, W V and Middleton, B J (1994b) Surface water resources

of South Africa 1990. Volume II, Drainage Region C: Appendices. Water

Research Commission Report No. 298/2.1/94.

Mr Israel Motlhabane (2004) Lichtenburg Municipality: IDP coordinator. Personal

Communication.

Mukherjee A B, Kääntee U and Zevenhoven R (2001) The Effects of Switching

from Coal to Alternative Fuels on Heavy Metals Emissions from Cement

Manufacturing. Proc. Of the 6th Int. Conf. on the Biochemistry of Trace

Elements, Guelph (ON), Canada, Jul. 29 Aug . 2, 2001, p.379.

Oke T T (1990) Boundary Layer Climates, Routledge, London and New York, 435

pp.

ÖKOMETRIC (2001) Analytical Report. ÖKOMETRIC GmbH,· Berneckerstraße 17-

21 · 95448 Bayreuth.

Parsons, R (1995) A South African Aquifer System Management Classification.

WRC report No. KV 77/95, Water Research Commission, Pretoria.

Pasquill F and Smith F B (1983) Atmospheric Diffusion: Study of the Dispersion

of Windborne Material from Industrial and Other Sources, Ellis Horwood

Ltd, Chichester, 437 pp.

Preston-Whyte R A and Tyson P D (1988) The Atmosphere and Weather over

South Africa, Oxford University Press, Cape Town, 374 pp.

SABS (2004) South African National Standards: Ambient air quality – Limits for

common pollutants. Standards South Africa ( a division of SABS). SANS

1929:200x, Edition 1.

Shaw R W and Munn R E (1971) Air Pollution Meteorology, in BM McCormac (Ed),

Introduction to the Scientific Study of Air Pollution, Reidel Publishing

Company, Dordrecht-Holland, 53-96.

Schneider M, Kuhlmann K, Söllenböhmer F (1996) Forschungsinstitut der

Zementindustrie, Düsseldorf, Germany PCDD/F–Emissions from German

Cement Clinker Kilns Organohalogen Compounds, Volume 27.



Schulze B R (1986) Climate of South Africa. Part 8: General Survey, WB 28,

Weather Bureau, Department of Transport, Pretoria, 330 pp.

Schwela D (1998) Health and Air Pollution – A Developing Country’s Perspective,

Paper 1A-1, Papers of the 11th World Clean Air and Environment Congress,

13-18 September 1998, Durban, South Africa.

South African National Standard, 10228:2003

Taylor, C J (1983) Geohydrological investigations in the Lichtenburg Area, Bo-

Molopo Subterranean Water Control Area. Report No GH 3277,

Department of water Affairs and Forestry, Pretoria.

Transportation Research Board (TRB) (U.S.A.) (2000) Highway Capacity Manual.

203p

Travis C.C., Richter S.A., Crouch E.A., Wilson D.E. and Klema A.D. (1987)

Cancer Risk Management, Environmental Science and Technology, 21,

415.

UK (2002) UK Particulate and Heavy Metal Emissions from Industrial Processes.

A Report produced for the Department for Environment, Food & Rural

Affairs, the National Assembly for Wales, The Scottish Executive and the

Department of the Environment in Northern Ireland. AEAT-6270 Issue 2.

United Nations (1993) Handbook for the Montreal Protocol on Substances that

Deplete the Ozone Layer, 3rd Edition

United Nations Environmental Programme (2003) Draft Guidelines on Best

Available Techniques and Best Environmental Practices for Cement Kilns

Firing Hazardous Wastes, UNEP/POPS/EGB.2/INF/8, 23 October 2003.

Website: http://www.eurochlor.org/chlorine/issues/dioxins5.htm. Rotard, 1996

quoted on the Euro Chlor

Website: http://gcisolutions.com/gcitn0596.htm. 1996. DIOXINS - PRIMER AND

COMMENTARY by David L. Constans from GCI Tech Notes

WHO (1997) Environmental Health Criteria 8, Sulphur Oxides and Suspended

Particulate Matter, UNEP and WHO, Geneva.

WHO (2000) Guidelines for Air Quality, World Health Organisation, Geneva.

Wilson, M G C and Anhaeusser, C R (eds.) (1998). The Mineral Resources of

South Africa. Handbook, Council for Geoscience, 16, 740pp.

Zeevalkink J A, (1997) Trace Elements in Cement Products. Institute of

Environmental Sciences, Energy research and Innovation, Netherlands.

Documents

ENVIRONMENTAL IMPACT ASSESSMENT REPORT Dudfield EIA Report.pdf · The use of waste-derived fuels in a cement kiln therefore, reduces ... Environmental Impact Assessment Report for