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LİMAK BATI ÇİMENTO SAN. TİC. A.Ş.

TRAKYA CEMENT FACTORY

ENERGY EFFICIENCY AND ENVIRONMENTAL IMPROVEMENT

PROJECT “ENVIRONMENT MANAGEMENT PLAN”

October 2011

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E2682 v6

TABLE OF CONTENTS

PART 1. PROJECT DESCRIPTION

1.1. Project Name

1.2. Project Description

1.3. Project Purpose and Justification

1.4. Project Benefits

PART 2. SCHEDULE PART 3. PREVENTION PLAN

PART 4. MONITORING PLAN

1. PROJECT DESCRIPTION:

1.1. Project Name:

Limak Batı Çimento ve San. Tic A.Ş., Trakya Branch, Energy Efficiency and Environmental

Improvement Project

1.2. Information Regarding the Plant Where the Project will be Implemented “Limak Trakya”:

1959 Activity Commencement

1995 EIA Positive Decision (For New Production Line)

2006 The letter from the Ministry of Environment regarding the fact that the validity of the EIA

Positive Decision given in 1995 is still continuing; that after the decision in 1995, white

clinker and cement production had started with 1 rotary kiln, 1 hot water boiler, 1 transformer

unit within the period until 2003; that there are 3 raw mills in the Provincial Directorate

Report

2007 EIA Not Required Decision (Revision at the project for which EIA Positive decision was

obtained in 1995 – based on the 12.11.2007 dated PTD for Line III with 5000 ton/day)

2011 Letter from the Provincial Environment Directorate regarding the fact that the EIA Not

Required Decision of 2007 is still valid including the amendments at the PTD

The Plant obtained an Environmental Permit License on 26.10.2011, valid for 5 years

concerning emission and waste incineration.

Letter from the Municipality is present concerning the fact that there is no objection in

connecting to the sewerage for domestic wastewater.

Since it obtained the Workplace Opening and Operation License before 2008, it is

exempt from Noise Control Permit Certificate as per Article 33/1-e of the Regulation on

the Control of Environmental Noise.

The Trakya Cement Factory started production with the 1st Line Wet System kiln activated in 1959. In

addition to the Wet System kiln with a capacity of 250 t/day, the Dry System kiln with a capacity of

800 t/day was activated in 1975; and with the addition of the pre-calcination system in 1992 to the dry

system kiln having 800 t/day capacity, the daily production was increased to 1800 t/day.

Considering the changing market conditions, Trakya Cement applied for EIA in 1995 for the

establishment of a new production line and EIA positive decision was obtained. In the scope of the

mentioned EIA, environment and milling investments were made. In order to comply with the New

Environmental standards, requirement to increase capacity arose for deactivating the Wet system kiln

with very high calorie consumption. In this context, it was required to revise the Project description

file for which EIA Positive decision had been taken at the application made to the Kırklareli

Governorship Provincial Environment and Forestry Directorate; thus, the project was revised in 2007

and EIA Not Required Decision was taken for the III. Lime investment with 5000 ton/year capacity

(December 2007).

Trakya Cement is located in Kırklareli Province, Pınarhisar District, upper Kırklareli macadam

Location, 105 island at parcels no. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 15 and 1 island at parcels no. 6, 10.

The mention location is morphologically located on a plateau with an elevation varying in the range of

250-500 m, located between the transition part of the Ergene basin in the form of a meadow and

Istranca Mountains. There is no vegetative cover on or nearby the plant site. There are fields at the part

towards the Ergene basin and Istranca forests towards about 10 km to the north.

The closest residential location to the plant site is the Karadağ Quarters located to 200 m east.

Furthermore, Pınarhisar district is present 1 km to the southeast and Kaynarca Township is present 3

km to the northwest. The site is located on the Pınarhisar, Kırklareli – Istanbul macadam. The plant is

located at a distance of 30 km to Edirne Istanbul E-5 highway and TEM motorway.

Located on the Istranca (Yıldız) Mountains and Ergene Meadow sections of Marmara Region,

Kırklareli, is surrounded by Bulgaria in the north, Black Sea in the north east, Istanbul in the south

east, Tekirdağ in the south and Edirne in the west. Its surface area is 6.550 kilometer square. Kırklareli

has a 180 km-long land border with Bulgaria and 60 km-long sea border with the Black Sea. It is at an

elevation of 203 meters above sea level, its north and east is hilly and forested, whereas the other parts

are generally flat fields. Mostly terrestrial climate is dominant in the region. The winters are rough and

with precipitation, whereas the summers are hot and dry.

Its main rivers are Ergene River and Rezve Brook. The vegetal cover is generally forested and with

steppes.

Pınarhisar is located on the former Istanbul Road, at the Lüleburgaz-Kırklareli road junction. The

north sections of the district are shaped with hills and cliffs reaching up to 500-600 meters.

The north section of the district is covered with forests. It is surrounded with Vize District in the east,

Kırklareli province in the west, Lüleburgaz District in the south and Demirköy District in the north.

The district has a surface area of 581 km2 and is at 192 m above sea level.

Mostly wheat and sunflowers are planted in our district and villages thereof. 85% of the arable fields

are planted with wheat and sunflowers. Cabbage, spinach, leek, tomato, pepper, eggplant, green bean

and curly lettuce are grown as vegetable.

Apiculture and undercover vegetable culture course was arranged in 2005 with the cooperation of the

Agriculture Directorate and Public Training Directorate with the participation of 48 farmers. There are

45 greenhouses at the center and villages of our district and high-tunnel undercover culturing is being

made on a field of 14 decares.

At the geological era, Tethys Sea was present at the place of Yıldız Mountains. The sediments at the

bottom of this sea have formed Yıldız Mountains as a result of the former continent cores at the north

and south approaching to each other, curving and elevating above water surface. During the

subsequent mountain formation, continent formation (epeirogenic) and volcanic movements, the

stones and strata forming Yıldız Mountains were compacted, curved and fractured. Since Yıldız

Mountains are a 1st geological era field, they are called “massif”. Massifs are old and tough masses

that have lost the ability to curve. Kırklareli field is mostly formed from core and cover stones of

Yıldız Massif field of the Paleozoic and 4th Mesozoic era and the sedimentary, metamorphic and

magmatic stones of the tertiary era. In line with the extension of the Yıldız Massif, the fault line lying

in the Northwest-Southeast direction extending from Vize to the east of Kırklareli and the intersecting

secondary faults lying in Northeast-Southwest direction form the tectonic structure of the site. The

fault between Kırklareli and Vize affecting the Yıldız Massif is a normal fault. The secondary fault

system has caused the Black Sea coast to be with indentations and projections (Iğneada-Limanköy).

The reef-like limestones of Kırklareli Formation are at medium hardness, with abundant melting gaps,

karstic, porous, articulated and multi-fractured and bear a well-aquifer character. At the unit over the

impermeable levels, the base has graveled sandstone, sandstone, sand and towards the top there are

limestone and sandstone stripped mams. The segments containing clayey levels do not have

underground water. And the sandy section at the formation base and in between, have a low quantity

of groundwater due to insufficient in-feed.

Meteorological State

Kırklareli province located at the Trakya section of Marmara Region experiences Kırklareli climate

varying among the locations. Terrestrial climate is dominant at Kırklareli center. Black Sea climate is

observed at the north-overlooking sectors of the Yıldız Mountains. Accordingly the winters are cool

and cold. At the inland sections away from the sea, terrestrial climate is observed. The summers are

hot; winters are cold and occasionally snowy.

Seismic State

According to the Turkish Earthquake Zones prepared by the Turkish Ministry of Public Works and

Settlement and put into force with the 18.04.1996 dated and 96/8109 referenced decision of the

Cabinet; Pınarhisar District that contains the project site and project area is located on a 4th Degree

Earthquake Zone.

Flora-Fauna

The project site is located in Kırklareli Province, Pınarhisar District, upper Kırklareli macadam

Location. An abundance of plants from Dry Forest Group can be seen at the south hills of the Yıldız

Mountains of Kırklareli and Ergene Basin. The vegetal cover and variety is rich in Kırklareli Region.

Among these natural plants there is oak, hornbeam, red pine, torch pine, ashen and rare elms,

cranberry, blackthorns, wild pears, maple trees and cade juniper from lemur species. Ligneous plants

such as torch pine and red pine have been included to the vegetal cover foresting line of Kırklareli.

Bushes (forest remnants) can be observed at the high elevations of Ergene Basin called as plateau.

However, most part of Ergene Plain is steppes. The plain is devoid of the forested area called as

ligneous plants.

Flora

When the project site’s flora zones are considered, they are classified as European-Siberia Phyto-

geographical Zone type. This phyto-geographical zone covers the Black Sea Region where the Black

Sea climate is effective and the sites of Marmara Region other than the Gallipoli and Biga peninsulas.

The south border of the region forms the hills of the mountain ranges facing north lying roughly in the

east-west direction at the Black Sea and Marmara regions. However in this zone, the tectonic channels

and basins between the hills of the mountains facing south and the mountains create separate media. If

considered in terms of the grid system of P. H. Davis (Flora of Turkey and The East Aegean Islands),

it is located at the A–1 square.

In order to determine the flora of the project location and surroundings, relevant literature survey has

been made and inventory tables have been prepared containing the habitats of the detected flora

elements, their phyto-geographic regions, relative abundance, endemism state and national and

international protection states. As a result of these studies, 55 plant species have been determined that

are present or potentially present at the site. 7 of these species are Mediterranean elements, 11 are

European-Siberian elements, 1 is an East Mediterranean element and 36 are cosmopolite species and

the ones whose phyto-geographic region is unknown.

No plant species have been encountered in the activity site placed under protection in the scope of

Annex-I of the Europe Wild Life and Habitat Preservation Contract (Bern Treaty). In order to

determine the endemic and endangered species among the ones stated above, the publication called

“Red Data Book of Turkish Plants (Turkish Nature Protection Association and Van 100. Yıl

University, 2000)” and the web site http://bioces.tubitak.gov.tr prepared by Tubitak was scanned and

no plant species were found that are endangered.

Fauna

As is known, the Vertebrate Animals fauna is gathered under 4 big classes. These are Amphibians,

Reptiles, Birds and Mammals. The regional fauna has been prepared by scanning the relevant

literature in the scope of the environmental impact studies for the project site and near surroundings.

In order to determine the species placed under protection among the ones stated below, Turkish

Environmental Legislation, Europe Wild Life and Habitat Preservation Contract (Bern Treaty) and

annexes thereof, “Turkey Birds Red List” (Species List in Red Data Book) prepared by Kiziroğlu

(1989) and Demirsoy (2002) “General Zoogeography and Turkish Zoogeography” was examined. As

a result of these studies, inventory tables have been prepared containing fauna elements detected at the

site, their habitats, population intensities, and national and international protection states. The threat

level and the relevant protection status was determined as per the Annex lists of Bern Treaty (Annex-2:

definitely protected fauna species, Annex-3: protected fauna species) and the ERL (European Red List)

and Red Data Book prepared by IUCN (International Union for Conservation of Nature and Natural

Resources).

Besides all these, for the Bird, Reptile and Mammal species, the “2007-2008 Period Central Gaming

Commission Decisions” Annex-I (Wild Animals Placed Under Protection by the Ministry of

Environment and Forestry), Annex-II (Game Animals Placed Under Protection by the Central Gaming

Commission), Annex-III (Game Animals Permitted to be Hunted at the Times Specified by the Central

Gaming Commission) lists put into force by the Turkish Ministry of Environment and Forestry Nature

Protection and National Parks General Directorate by being published at the 06.07.2007 dated and

26574 numbered Official Gazette were entered to the relevant tables. The wild animals at Annex-I list

have been placed under protection by the Ministry of Environment and Forestry as per the first

paragraph of the 4th article of the Terrestrial Hunting Law no. 4915. Hunting the wild animals in this

list, keeping them dead or alive and transporting them are forbidden. The birds and mammals at

Annex-II list have been placed under protection by the Central Gaming Commission as per the

authority granted under the first paragraph of the 4th article of the Terrestrial Hunting Law no. 4915.

Hunting the game animals in this list, keeping them dead or alive and transporting them are forbidden.

The game animals at Annex-III list are the game animals permitted by the Central Gaming

Commission to be hunted at the periods stated in the 2007-2008 hunting period determined by the

Ministry of Environment and Forestry as per the first paragraph of the 4th article of the Terrestrial

Hunting Law no. 4915. As a result of the studies made, no endemic species was encountered at the

project site or surroundings. Furthermore there are no sensitive areas present for the fauna types with

the purpose of propagation, food seeking, staying for winter, nesting and migration.

Birds

Among the 29 bird species possible to be present at the activity site due to habitat conformity, 16 are

present at Bern Annex–2, and 7 are present at Bern Annex–3 list. According to the recent lists

reflecting the “2007-2008 Period Central Gaming Commission Decisions” put into force by the

Turkish Ministry of Environment and Forestry Nature Protection and National Parks General

Directorate by being published at the 06.07.2007 dated and 26574 numbered Official Gazette; 18 bird

species are under Annex-I (Wild Animals Placed Under Protection by the Ministry of Environment

and Forestry), 4 are under Annex-II (Game Animals Placed Under Protection by the Central Gaming

Commission), and 7 are under Annex-III (Game Animals Permitted to be Hunted at the Times

Specified by the Central Gaming Commission) list.

1.2. Project Description:

Limak Batı Çimento San. Tic. A.S. Trakya Cement Factory, located within the boundaries of

Kırklareli province, has totally 790.000 ton/year clinker capacity with the wet system rotary kiln,

which is active since 1958, and the first generation pre-calcined type rotary kiln, that has been

activated in the subsequent years. The plant contains 3 low-capacity raw mills, one being sludge, one

being with ball bearing and the last being vertical type. The plant is able to produce 956.000 tons of

cement with 3 low-capacity ball-bearing cement mill in total (2 open and 1 closed systems). Most of

the transport lines of the plant are open and has a closed clinker stock hall with limited capacity. The

electrification and cabling lines and conduits have used up their usable lifetime, automated viewing

and monitoring systems are realized with partial and old technology. The dedusting units of the plant

are active in a very distributed, inefficient and high power-consumption fashion with continuous new

additions within the period from 1958 until today. The pressurized air requirement of the plant is

supplied with many inefficient compressors distributed to the overall factory.

The Trakya Cement Factory has been taken under the structure of Limak Group on March 2011 and

the operation, quality, energy and environment improvement projects were immediately given a head

start. The leading innovations of the last 15 years of the cement sector in terms of energy efficiency

and environmental improvements are pre-calcined rotary kiln, vertical cement mills and next

generation clinker cooling units. Again the discovery that the cement rotary kilns are perfect natural

cleaners to be used for waste disposal enabled the sector to orient towards design and development

activities aimed at alternative fuel utilization. All these innovations, marking the sector in terms of

energy efficiency and environmental improvements, will take place in the project of Limak Trakya

Factory with its latest, state-of-the-art versions.

The main investment targets can be summarized under the following main headings;

1. Instead of 5 ball-bearing mills and 1 low-capacity vertical mill with open system operating at

the raw material and cement lines with high power consumption and even causing inefficiency

in terms of quality, the installation of 2 next generation vertical mills with low power

consumption.

2. The 1958 model wet system clinker line of the plant, that is environmentally inefficient, being

inactivated and dismounted.

3. Redesigning of the towers of the plant to provide low pressure loss, high efficiency and to

attain 95% calcination level at the pre-calcined rotary kiln currently having an old-generation

tower with low efficiency, high pressure loss, high heat consumption and that can only attain

80% calcination degree.

4. The plant’s new towers being resigned as to maximize alternative fuel utilization, as one of the

main targets to reduce CO2 emission and fossil fuel use; this condition being included to the

contract.

5. At the new investment period of the plant, combustion burners being used that have high

combustion efficiency, high momentum, low NOx and low primary air consumption.

6. The new towers of the plant being designed such that low NOx emission and minimum dust

emission values are warranted under the contract. NOx emission is taking place as a main

heading at the contracts. The NOx legal limit of the plant is currently at 1300 mg/Nm3 and

actually the system operates at values around 1100 mg/Nm3. After the investment, reducer

sections shall be designed at the tower and the plant’s operation at maximum 500 mg/Nm3

NOx value (without the use of any chemical substance) shall be warranted under the contract.

Limak is meeting a higher investment price for this design.

7. The Rotary kiln hood and cooler to be replaced with their next generation versions at high

efficiency, The inlet and outlet sealing systems of the rotary kiln to be replaced with new

design versions minimizing the leaking air, thereby obtaining peak improvements at thermal

consumption and power consumption.

8. The pneumatic transfer lines with high power consumption being replaced with mechanical

type designs with new elevator and low power consumption,

9. The rotary kiln input raw homogenization systems being upgraded to their versions with high

efficiency, lowering their standard deviations and obtaining improvements at quality and

power consumption.

10. Replacing all the raw material, raw and coal weighing systems with their next generation

versions operating at high accuracy (0,5%), obtaining high quality, operation stability and low

emission values, especially attaining complete combustion and zero CO objective at the

Rotary kiln.

11. All the material transport lines being designed as closed gallery type,

12. Building a closed clinker stock hall with 55.000 ton-capacity.

13. Rehabilitating the Rotary kiln-Raw and Cooler Main Filters and ensuring that there is no dust

emitter at the plant exceeding a dust emission of 30 mg/Nm3. (Table 1)

14. All the emission points such as the new cement mill’s next generation system filter, mill

feeding line, bunkers, closed clinker stock hall inlet and outlet to be equipped with next

generation bag filters. (Table 1)

15. The existing filters of the plant being modernized as to perform shaking-out according to

pressure difference as it is at the next generation filters and thereby both minimizing and

optimizing dust emission and power consumption.

16. The electrification and automation structure of the whole system be renewed in order to

minimize, monitor and communicate the line losses; The Energy Monitoring (Scada) System

being activated for the whole plant after the investment.

In the scope of the project, it is foreseen that totally 350 persons will work at the field

preparation and construction works, and 145 persons will work during the operation phase,

and the needs of the employees shall be met from the existing plants/facilities.

1.3. Project Aim and Justification:

The investment to be made at the Trakya plant, that had been serving the region since 1958, shall

transform the plant to an exemplary, next generation plant at international standards in terms of energy,

environmental aspects and technology. The main justifications to make an investment at this plant

operating for 53 years are as follows;

It has become obsolete as compared to the next generation cement factories in terms of power

and fuel consumption,

The existing system cannot respond to the low emission values that can be attained in the

sector with next generation technologies,

Many equipment in the plant have used up their lifetime in mechanical and electrical terms,

The existing plant is not capable of combusting alternative fuels and fuels with low volatility,

The plant does not have any quality and energy efficiency infrastructure, and a system that

cannot be monitored cannot be developed.

The plant losing its competitive edge against the next generation plants.

1.4. Project Benefits:

1.4.1 Emission Limit Values and Target Values for the Plant

Pollutant Limit Values

until

31.12.2012

C (mg/Nm3)*

Limit Values

after

31.12.2012

C

(mg/Nm3)**

IFC

Guideline

Values

C (mg/Nm3)

Values

Measured on

04.08.2011

C (mg/Nm3)

2013 Target

Values after

Investment

C (mg/Nm3)

Total dust 43 30 50 15,05 <10

HCI 26,5 10 10 < 0,75 < 0,75

HF 4,3 1 1 < 0,28 < 0,28

NOx (in terms

of NO2)

1108 800 600 664,54 <500

Cd + Tl 0,091 0,05 0,05 0,0153 0,0153

Hg 0,091 0,05 0,05 0,0028 0,0028

Sb + As + Pb

+ Cr + Co +

Cu + Mn + Ni

+ V

0,91 0,5 0,5 0,1015 0,1015

SO2 256 50 400 ND*** ND***

TOC **** 249 10 10 16,98 16,98

Dioxin -

Furan

0,1 0,1 0,1 0,0126 0,0126

*: Limit Values until 31.12.2012 are the limit values determined based on the trial incineration report by the

Ministry of Environment at waste intake after GFB during the Environmental Permit License process.

**: Limit Values after 31.12.2012 are the limit values indicated at the Waste Incineration Regulation.

***ND: Not Detected

****TOC limit value is defined as the difference between the measured values when the waste is incinerated and

not incinerated. TOC measurement has not been made at the Trakya Factory before waste incineration.

1.4.2. Dust Emissions – Bag Filter Investment and Modernizations – Other Improvements

The existing filtration system operating at the Rotary kiln Unit is comprised of the 2 parallel-

operating Electro-filters present at the system origin and the bag filter later added in series;

and this system is causing an additional 9 kWh/ton clinker energy consumption while ensuring

a dust emission below 30 mg/Nm3. After the investment, the bag filter of the system will be

designed compliant to the capacity, the electro-filters that have used up their lifetime will be

inactivated , and thereby the same dust emission will be attained with 7,2 million kWh /year

lesser energy consumption.

The Rotary kiln Cooling Electro-filter system shall be modernized and optimized. With the

new cooling unit to be installed together with the investment, the cooling exhaust gas amount

shall reduce by 0,5 Nm3/kg clinker and the power consumption of the mentioned filter shall

decrease in the same rate.

Many old generation filters operating at the 3 cement mills of the plant shall be omitted

together with their units; a next generation system filter at the new cement mill unit shall

ensure a high dust collection efficiency (0-10 mg/Nm3) at low energy consumption.

All the conveyor lines feeding the raw material and semi-finished product mills of the plant

shall be designed as closed and equipped with dust-removing systems. Furthermore, all of

these lines shall operate with an automation system and the dedusting systems shall be

designed as an interlock system for the operation of the unit.

Table 1. The Plant filters to be renewed, omitted and rehabilitated at the Trakya Factory

NAME OF RESOURCE DUST EMISSION

(mg/Nm3)

DUST EMISSION

(mg/Nm3)

BEFORE INVESTMENT AFTER INVESTMENT

1 ROTARY KILN I 58,000 0,000

2 ROTARY KILN II 72,600 0-30

3 COOLING I 13,000 0,000

4 COOLING II 3,600 0-10

14 KILN RAW WEIGHING BUNKER FILTER 7.4 0-10

10 CLINKER TRANSPORT LINE FILTER 4.9 0-10

5 COAL MILL II 34,210 34,210

6 COAL MILL II 17,380 17,380

7 CEMENT MILL I 20 0,000

8 CEMENT MILL II 4.9 0,000

9 CEMENT MILL III 22.8 0,000

x NEW CEMENT MILL 0,000 0-10

10 COOLER CLINKER TRANSFER LINE

FILTER

49 0-10

11 RAW HOM. SILO 1 12.3 0-10

12 RAW HOM. SILO 2 10.5 0-10

13 RAW HOM. SILO 3 11.2 0-10

15 COAL TRANSFER FULLER 4.2 0,000

16 IHI COAL FEEDER LINE FILTER 20.7 20.7

18 CEMENT MILL NO. 3 FEEDER BELTS

FILTER

3.2 0,000

19 CEMENT MILL NO.3 STATIC SEPARATOR

FILTER

7.7 0,000

x2 NEW CEMENT MILL SYSTEM FILTER 0-10

x3 NEW CEMENT MILL FEEDER GROUP

FILTER

0-10

x4 NEW CEMENT MILL BUNKER FILTER 0-10

x5 CLOSED CLINKER STOCK HALL

DOWNSTREAM OUTLET FILTER

0-10

x6 CLOSED CLINKER STOCK HALL UPSTREAM

FILTER

0-10

x7 CEMENT MILL TRANSPORT LINE FILTER 0-10

a Filters to be Inactivated

b Filters to be Rehabilitated/Modernized

c Filters to be Maintained/Serviced

d Filters to be Added after Investment

A closed clinker stock hall shall be built at the plant with 55.000 ton capacity, operating at full

automation. The investment amount of this unit, being a completely environmental investment,

is 2 million Euros. The clinkers exiting the rotary kiln cooling unit shall be transferred to the

closed clinker stock hall through a folly closed conveyor with filtration system whereas the

transport of the clinker to the cement mill unit shall be realized with conveyors structured

inside underground closed galleries, equipped with automation and cameras.

After the system investments of the plant are completed, the interim connection roads shall be

laid with concrete, landscaping and afforesting activities shall be conducted.

1.4.3 NOx Emissions

Trakya Factory Rotary kiln Investment is a system

designed under the main heading of “Low NOx”. In the

rotary kiln systems, NOx can be decreased in two

manners:

1) Ammonia or urea pulverization to the system at the

Pre-heater Tower (SNCR system) 2) With the design of

the pre-heater system.

At the Trakya Factory Investment, the increase in the

investment cost shall be faced to assure 500 mg/Nm3

NOx emission with a tower design having Low-NOx

structure. The plant shall have the ability to further

reduce the low emission values with SNCR.

In the present state, the NOx emission of the system is

at 1100 mg/Nm3. After the new investment, the plant

will be easily able to keep the NOx emission value below 500 mg/Nm3 with the new L- NOx Calciner

and L- NOx burners and the use of high nitrogen containing coal (volatile matter ratio in domestic coal

~40%).

1.4.4 CO2 Emission

Among the main fields where the Trakya project will provide best environmental improvement, the

primary field will be CO2 emission reduction.

Figure 1. Obtaining low NOx emission

with In Line Calciner

The 962 kcal/kg clinker heat consumption of the plant shall be reduced to 750 kcal/kg clinker level

after the investment, thereby fossil fuel consumption is reduced from 143 kg fuel/ton clinker level to

112 kg fuel/ton clinker level when considered on the basis of same type of fuel utilization. The

reduction in the coal consumption, when pre- and post-investment state is considered, will be 24.312

ton/year without taking into account alternative fuel use. In this case, the 60.156 ton/year reduction

shall be obtained in the emission of fuel consumption based CO2.

The Rotary kiln of the Plant shall be design such that it will permit the use of alternative fuel at

minimum 50% of the total fuel amount. The factory is located at a distance of 70 km to Çorlu, being

one of the biggest industrial centers of Turkey, thereby it shall possess the technology to dispose both

residential and industrial wastes and also to use it as alternative fuel. The most frequent waste types in

the region are treatment sludge, bleaching soil and waste tires. When the plant attains an alternative

fuel rate at 25% thermal rate with the regional treatment sludge, 8.500 ton/year reduction shall be

obtained in the emission of fuel consumption based CO2.

With the vertical mill investments of the plant, 40% improvement shall be obtained at the emission of

power consumption based CO2 at the milling process. The plant’s current full capacity annual power

consumption at 122,6 million kWh shall be reduced to 86,9 million kWh after the investment, and the

reduction in CO2 emission brought about by this improvement in power consumption shall be

24.258 ton/year.

Table 2. CO2 emission reduction – consolidated

No CO2 Emission Reduction Source Improvement

Amount ton CO2/year

1 With Fossil Fuel Consumption Reduction 60.156

2 With Utilization of Alternative Fuel at 25% of the Thermal

Power

8.500

3 With Power Consumption Reduction 24.258

TOTAL 92.914

1.4.5 Project Benefits

With this project:

20,5% energy saving shall be obtained for the whole factory.

The main stack NOx emission of the plant shall be reduced by 300 mg/Nm3 without the use of

any chemical additional input.

All the dedusting units of the plant shall be modernized by considering power consumption

optimization.

The fossil fuel consumption shall reduce by 24.312 ton/year (by neglecting the consumption

of alternative fuel)

When alternative fuel utilization attains its 25% target, the reduction in the fossil fuel

consumption will be 50.000 ton/year in total.

The total power consumption of the plant shall be reduced by 35,7 million kWh/year.

It is aimed that the CO2 emission of the plant shall be reduced by approximately 92.914

ton/year. This equals to an improvement of 29,19% in the CO2 emission of the plant.

1.4.6 The Process of Introducing the Nearby Public to the Energy Efficiency and Environmental

Improvement Project:

1- For the Public Participation Meeting to be held of 26.10.2011, ANNEX-1 Meeting Call

Minutes was made signed by the Camii Kebir Town Mukhtar (the town that our factory is

located in) on 10.10.2011 and the notice was hung at the Mukhtar’s Office until 24.10.2011.

2- Public Participation Meeting was held on 26.10.2011 at the factory meeting hall and the

Introduction Presentation was shown at the meeting.

3- The questions of the participants and the responses given at the end of the meeting are present

at ANNEX-2 Minutes.

4- The meeting participants were recorded with ANNEX-3 Attendance Minutes.

5- The Introductory Presentation given at the meeting was hung at the Mukhtar’s Office on

26.10.2011 as ANNEX-4 Notice Minutes after the approval of the Camii Kebir Town Mukhtar.

MINUTES OF INVITATION TO MEETING

In order to realize mutual opinion and information exchange on the possible impacts of the

Energy Efficiency and Environmental Improvement Project planned to be realized in your region, a

meeting shall be held, with the participation of the project owner company, on 26.10.2011, at the

address of Camii Kebir Mahallesi, Kırklareli Caddesi, Pınarhisar – KIRKLARELİ, by Limak Batı

Çimento Sanayi ve Ticaret A.Ş. Trakya Branch in the factory meeting hall. All the regional public is

invited to the meeting. We hope that maximum due care shall be paid in participation to the meeting

and we hereby announce this meeting to our community respectfully.

This invitation has been hung up as to be announced at the billboards of Camii Kebir Town

Mukhtar’s Office as to stay on the billboards until 24.10.2011. 10/10/2011

Official Authority Company

Camii Kebir Town Mukhtar’s Office Limak Batı Çimento Sanayi ve Ticaret A.Ş.

Trakya Branch

// seal, stamp, signature // // signatures //

A copy of the minutes has been hung up at the billboard of the mukhtar’s office on 10.10.2011.

SUBJECTS DISCUSSED AT PUBLIC PARTICIPATION MEETING

Place of Meeting: Local Club Meeting Hall

Date of meeting: 26/10/2011

Meeting no: 2011/01

SUBJECTS DISCUSSED

Question Name Response

1 Will new filters be built with the new investments? Yahya ALACA

Dere Town Mukhtar

Our existing quantity of stacks and filters will increase with the new investments.

Our mill quantity will be changed to 2. The filters will be modernized.

2 Will your capacity increase? Vehbi AŞUT

Cooperative Head

Since the 2 kiln capacity present will be met with single kiln, there will be no

capacity increase. Kiln no. 1 with high energy consumption shall be inactivated.

3 Will there be energy savings with the new investments? Ömer Faruk KARALAN

District Agric. Dir.

The aim of the new investments are energy saving and cost reducing

investments, thereby there will be high energy saving.

4 Will you consider to contribute by afforesting trees suitable

in the scope of honey apiculture development just life the

afforesting studies you had made before at Kaynarca mine?

Ali Osman ÇALIK

Honey Producers Union Head

It will be considered provided that you can provide us information concerning

your works.

5 Will there be noise increase at the factory with these new

investments?

Şerafettin ÖZCAN

Town Mukhtar’s Office

Member

Our 4 … mills will be changed as 2 … vertical mills. Therefore, the noise caused

by the mills will decrease.

6 Will the importance placed on Work health and safety be

continued as before?

H. İbrahim YILMAZ

Civil Engineer

It will definitely be continued by increasing.

7 The satisfaction was expressed regarding the fact that these

investments would be very beneficial to provide energy

reduction.

Yekta AKKUŞ

Agriculture Engineer

8 They stated that they were expecting this and similar

investment news and that this investment and energy saving

is very satisfactory.

Yahya ALACA

Dere Town Mukhtar

Ali Osman ÇALIK

Honey Producers Union Head

9

10

11

12

13

14

15

16

17

18

19

20

1

PUBLIC PARTICIPATION MEETING MINUTES

In order to provide information and obtain the opinion of the public on the possible impacts on

the public and environment of the Energy Efficiency and Environmental Improvement Project planned

to be realized within the boundaries of Kırklareli Province Pınarhisar District, Camii Kebir Town,

Kırklareli Street location by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch, a meeting

was held, on 26.10.2011, at 1:00, at the address of Camii Kebir Mahallesi, Kırklareli Caddesi,

Pınarhisar – KIRKLARELİ, by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch.

ATTENDANTS OF THE MEETING

* If the meeting attendants are more than the space provided in the table below, an additional table can

be prepared.

No Name Surname Contact Telephone Signature

1 Ziya Mert Police Chief 02886151386 // signature //

2 Hasan İbrahim Yılmaz Civil eng. 02886151386 // signature //

3 Serhad Günsoy … 02886154449 // signature //

4 Şahin … … // signature //

5 Ali Osman Çalık … // signature //

6 Mehmet Pehlivanoğlu … // signature //

7 Yahya Alaca Dere town Mukhtar … // signature //

8 Şerafettin Özcan Camikebir town … // signature //

9 … Savcı Camikebir town … // signature //

10 Memduh Ürek Camikebir town … // signature //

11 … Cooperative Head // signature //

12 Ömer Faruk Naralan … // signature //

13 Yelda Akkuş P.hisar District Agr. Eng. // signature //

14 Hülya Buluş P.hisar District … // signature //

15 Atanur Sarıkaya P.hisar district … // signature //

16 Deniz Ulaş Karatoprak … // signature //

17 M. Ertan Kocakerim Limak … // signature //

18 Ahmet Müfit Tekin Limak Trakya … // signature //



Trakya Branch


ANNEX: MEETING MINUTES

Explanation of the project by the Company

Questions and Answers

2

PUBLIC PARTICIPATION MEETING MINUTES

In order to provide information and obtain the opinion of the public on the possible impacts on

the public and environment of the Energy Efficiency and Environmental Improvement Project planned

to be realized within the boundaries of Kırklareli Province Pınarhisar District, Camii Kebir Town,

Kırklareli Street location by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch, a meeting

was held, on 26.10.2011, at 1:00, at the address of Camii Kebir Mahallesi, Kırklareli Caddesi,

Pınarhisar – KIRKLARELİ, by Limak Batı Çimento Sanayi ve Ticaret A.Ş. Trakya Branch.

ATTENDANTS OF THE MEETING

* If the meeting attendants are more than the space provided in the table below, an additional table can

be prepared.

No Name Surname Contact Telephone Signature

19 M. Ferman Ulaş Limak Trakya General Manager // signature //

20 Alp Engin Limak Raw Mat. Dir. // signature //

21 Barış Bademci WHS and Env. … // signature //

22 Y. Özdel Bingöl Limak Trakya Admin. Dir. // signature //

23

24

25

26

27

28

29

30

31

32

33

34

35

36



Trakya Branch


ANNEX: MEETING MINUTES

Explanation of the project by the Company

Questions and Answers

BILLBOARD MINUTES FOR

THE ENVIRONMENTAL MANAGEMENT PLAN / EIA / PROJECT DESCRIPTION FILE

In order to provide project-related information to the regional community, the Environmental

Management Plan / EIA / Project Description File prepared for the Energy Efficiency and

Environmental Improvement Project to be performed by Limak Batı Çimento Sanayi ve Ticaret A.Ş.

Trakya Branch has been hung at the billboard of Camii Kebir Town Mukhtar’s Office as to stay there

until the end of the project.

This minutes has been prepared in order to determine the fact that the Environmental

Management Plan / EIA / Project Description File has been hung up for presentation. 26/10/2011



Trakya Branch


2. SCHEDULE

Application Schedule:

The Trakya Energy and Environmental Improvement Project shall be realized with many domestic and

foreign contractors. The target for the mentioned project is the signing of the contracts before the end

of 2011 and the completion of the project within maximum 14 months. The project design shall be

realized as to preserve all the construction and mechanical assembly works (other than the cooling

unit), the existing production and sales volumes of the plant. After the completion of all these studies,

Clinker line shall be halted, and the period foreseen to complete the cooling unit and the new interim

connections is 45 days. The plant shall continue the cement production and sales with the stock clinker.

The general layout plan prepared for the mentioned project is given below (Figure 2)

Figure 2. General Project Layout

Accordingly at the energy efficiency and environmental improvement project of the plant, there will

be no halting at any unit other than the last 45-day period of the 14-month project duration; therefore,

the areas where new units are no be built and modifications are to be made aere the areas completely

open and on which there is no unit equipment installation (Figure 2).

There will be 6 main construction sites at the mentioned investment and at these structures to be built

on open areas, the amounts of excavation caused by the foundation are stated at the following table.

The excavation material taking out of the foundation areas shall be taken to the mine site, the required

amounts shall be used as filling material and the remaining shall be utilized in the process as raw

material.

TABLE FOR THE EXCAVATION AND FILLING AMOUNTS

No Name of Unit Excavation (m3) Filling (m

3)

1 Pre-heater Building 1.000 400

2 Raw mill 1.900 915

3 Raw material bunker 1.240 605

4 Cement mill 1.340 580

5 Mill bunkers 1.450 650

6 Clinker stock hall 9.500 3.400

16.430 6.550

The only new unit to take place at the same location as the plant is the cooling unit during that 45-day

halting period. The mentioned until shall be built at 0 elevation and the old dismantled unit shall be

processed as metal scrap.

After the plant commences operation with next generation equipment, all the pipe connections and

filter cases that cannot be made impermeable shall again be processed as scrap metal.

As a result, the wastes to occur during the Trakya Cement Factory investment from the dismantling of

unusable mechanical parts and old bag-filters are listed as follows:

1. Metal Scrap

2. Filter bags

Among these wastes, scrap metal is defined as “17 04 07: Mixed Metals” at Annex-4 Waste List of the

Regulation of the General Fundamentals of Waste Management put into force by being published on

05.07.2008;

And the filter bags are defined as “15 02 02: Absorbers, filter materials (oil filters if not identified

under other items), cleaning cloths, protective clothing polluted with hazardous material” as per the

same legislation.

The filter bags with code no. 15 02 02, shall be incinerated at the rotary kiln of our factory in the scope

of the 26.10.2011 dated Environmental Permit License (certificate no. 72) annexed herewith, and

thereby energy recovery shall be obtained.

Scrap metal with code no. 17 04 07, shall be sent to collection-separation and recycling plants or

directly melting plants as per the Communiqué of 17.06.2011 on the Recycling of Some Non-

Hazardous Wastes (The 05.12.2011 dated letter of the Ministry of Environment and City Planning is

attached. According to this latter, the scrap metal can be sent to the collection-separation and recycling

plants or directly melting plants without seeking any license condition until 1/1/2015).

The closed areas of the plant cover the ball bearing milling circuits to be omitted. The mentioned

equipment do not meet the next generation cement sector needs, therefore they will be put on sales for

the utilization of other sectors. After the mentioned equipment are put on sales, the closed areas shall

be designed as depots, workshop and similar purposes of use.

2

3. PREVENTION PLAN

Phase Topic Mitigating Measures Responsibility

Construction Phase

Positioning of the work

sites and the

infrastructural services

for the worker camps

The worksite and worker camps are located within the boundaries of the Trakya Cement

Factory and outside the forested areas.

Positioning:

(a) At least 3 km away from any protection zone

(b) 50 m away from any surface water and

(c) 1 km away from any village. There is no region around the plant with cultural

properties.

Services

(a) Utilization water and drinking water shall be provided from the network of the

Trakya Cement Factory

(b) The residential type wastewaters shall be disposed of by transferring to the existing

sewerage system of the Trakya Cement Factory,

(c) The organic solid wastes at the camps shall be collected in closed-lid trash bins and

periodically taken by the Pınarhisar Municipality.

The site built as the worksite shall be improved in compliance to its original state after

the completion of the work.


Solid waste

management of the

construction (sand,

stone, etc.)

There is no expropriated area inside the project site.

No incineration will be made.

The excavation wastes shall not be carried outside the work site, some of it shall be used as

ground filling within the plant and the residual part will be used as alternative raw meal

Landscaping activity shall be performed with the completion of the construction.


Contractor

Exhaust emissions of

the construction

machinery

The exhaust emissions of the construction machinery shall be measured regularly by

authorized institutions and their compliance to the limit values defined for exhaust emissions

shall be certified.

The machines shall not be left open if they will not be used for more than 5 minutes; the idle

operation of the engines shall be minimized.


Contractor

3


Construction Phase

Storage of construction

machinery

The Storage area will be located within the Trakya Cement Factory. It will be positioned

minimum 50 meters away surface waters, it will be far from villages and other residential

areas.

The equipment shall be placed on impermeable surface, thereby soil pollution from oil leaks

shall be prevented.


Noise The noise level will not exceed 70 dB limit.

No blasting shall be made.


Dust For minimum dusting the following precautions shall be taken; loading and unloading at the

mission source will be made without scattering, leveling shall be made, the top-side of the

vehicles shall be covered during material transport and the top part of the material shall be

kept at 10% moisture.

The present roads and construction area shall be watered at dry and windy weather.


Worker Safety The Trakya Cement Factory is certified for OHSAS 18001 Work Health and Safety

Management. It has received with WHS Performance Award for 2009 granted as a result of

the evaluation of the WHS applications of the member factories by the Cement Industry

Employers Syndicate.

As per the legislation regulating work life, the contractor personnel shall pass health scan

before starting to work and they shall be employed with “report evidencing that the person

can work at heavy and dangerous works” in the scope of the applications at the Trakya

Cement Factory. Health checks shall be made periodically.

Helmet, work boots, ear protectors, masks and other personal protective equipment shall be

provided and used by the workers as necessary.


Contractor Company

Present roads Traffic mobility shall be minimized at the existing roads.

The roads present at the project site shall be watered regularly with street sprinklers.

Tonnage control shall be made at the transport vehicles, they will be prevented from

carrying over-load and damaging the present roads.

The damaged roads shall be repaired before the damage becomes permanent.

Mud, remnants and other obstructions shall not be left on the roads.


4


Construction Phase

Positioning and

construction of the

transport roads

The existing roads are sufficient for transport, new roads shall not be constructed. -----

Routing and

construction of the

transmission lines

A new transmission line shall not be built, but the existing lines shall be modernized. There

will be no need to perform work on the transmission lines outside the factory site.


The possibility of

presence of cultural

works, areas and

structures with local

cultural value

All the works shall be realized within the factory site. There is no cultural formation at or

near the factory site. However, if any historical, cultural or archeological asset is

encountered during excavation works, the excavations shall be halted and the local/regional

culture directorates shall be immediately informed. No one shall take out the findings or

damage this area. After the examinations of the construction authorities are completed and

written approval is obtained from the related administrations, The excavation can be

continued.

No transmission network, connection road or structure passes over village cemeteries.


Provision of raw

material

Raw materials to be used in the scope of the project, such as sand, stone, etc. shall be

obtained from licensed raw material sites. The concrete to be used shall be obtained from the

concrete power plants of our company.


Management of

hazardous materials

(fuels, oils, explosives)

No explosives shall be used. The storage of the oils and fuels will not be necessary during

the construction works. The fuels of the vehicles to be used during the project shall be

obtained from private – independent liquid fuel stations outside the factory site.

The equipment oils / grease to be used during operation shall be kept at well-ventilated,

locked and surrounded buildings on impermeable surfaces. These buildings shall be located

at minimum 50 m away from any surface water. It is located outside residential areas and

forested fields.


Management of scrap

metals

Scrap metals shall be kept in the factory site and shall be given to recycling according to

Announcement of Recycling of Some Nonhazardous Wastes


Forest loss The area used in the scope of the project is within the limits of the Trakya Cement Factory.

There will be no tree cutting for the project. No afforesting is present on the site.


Noise Silencer equipment shall be used to prevent any noise to occur during the project, during and

after the works of activating the equipment. The main equipment to be used in the project

shall be manufactured as per international standards. The noise level shall be below 70 dB.


Construction Phase

Dust / Air emissions O2, CO, NOx and SOx and dust amount in the stack gas shall be continuously measured in

order to determine the emission from the combustion system after the project is activated,

and shall be digitally recorded at the automatic computer system. The emission limit values


5


permitted at the Regulation on the Control of Industrial-Based Air Pollution and Waste

Incineration Regulation.

Construction Phase

Medical wastes Medical wastes shall be collected separately from other wastes and delivered to the medical

waste collection vehicle of Pınarhisar Municipality.


Construction Phase

Hazardous wastes The hazardous wastes shall be collected separately according to their waste codes,

accumulated at the waste depot site and kept at the hazardous waste depot site for maximum

180 days , provided that the amount does not exceed 1000 kg/month, and then given to the

licensed recycling /disposal plants. The hazardous wastes in the scope of waste incineration

permit given to the factory shall be incinerated at the rotary kiln.


Operation Phase

Residential and

operation wastewaters

Residential type of wastewaters shall be disposed of by giving to the existing sewerage

system of the Trakya Cement Factory. There will be no operation-based wastewater. The

cooling waters are used as closed circuit recirculation.


Residential solid

wastes

The residential solid wastes shall be collected inside closed-lid trash bins, and then

periodically gathered by the Pınarhisar Municipality.


Operation Phase

Noise Periodical noise measurements shall be made at the plant and it shall be ensured that the

noise level stay within legal limits; when the noise level exceeds the legal limits, necessary

precautions shall be taken such as isolation, provision of personal protective equipment, etc.


Operation Phase Medical wastes Medical wastes shall be collected separately from other wastes and delivered to the medical

waste collection vehicle of Pınarhisar Municipality.


Operation Phase Hazardous wastes The hazardous wastes shall be collected separately according to their waste codes,

accumulated at the waste depot site and kept at the hazardous waste depot site for maximum

180 days , provided that the amount does not exceed 1000 kg/month, and then given to the

licensed recycling /disposal plants. The hazardous wastes in the scope of waste incineration

permit given to the factory shall be incinerated at the rotary kiln.


6

4. MONITORING PLAN

Phase / Topic Which parameters will be

monitored?

Where will this parameter be

monitored?

How will this parameter be

monitored / what is the

monitoring equipment?

When will this parameter be

monitored / What is the

monitoring frequency?

Responsibility

Construction

Positioning of the

infrastructural

services for the

work sites and

worker camps

Place of the work site

Agreements related to water

supply, residential wastewater

and residential solid waste

Has the camp site been

suitable improved?

At the work site

Water supply area, sewerage

and solid waste storage areas

At the work site

Visual At quarterly periods, or more

frequently if any

nonconforming application is

observed

At the end of construction

operation

Trakya Cement

Factory

Management of the

construction solid

wastes (sand, stone,

packaging wastes,

etc.)

Recycling and disposal

applications for the packaging

wastes

Reuse and disposal

applications for the

excavation wastes

Packaging waste storage or

disposal area

Excavations storage area

Visual At monthly periods, or more

frequently if any


observed

Every day during excavation

works

Trakya Cement

Factory

Exhaust emissions

of the construction

machinery

Emission measurement

records as per Turkish laws

Equipment not been used in

idle mode

At the entrance of the project

site

At the construction site

Visual Once when the equipment are

taken to the construction site

At monthly periods, or more

frequently if any


observed

Trakya Cement

Factory

Storage of the

construction

machinery

Is the depot site away from

residential areas and surface

waters?

Has the equipment been

placed on an impermeable

surface?

Equipment storage area Visual Once before site preparation Trakya Cement

Factory

7


monitored?


monitored?







Responsibility

Noise Construction hours Construction site Noise measurement device At monthly periods, or more

frequently if any


observed

Trakya Cement

Factory

Dust Is water sprinkling being

performed regularly and

suitably?

Construction site and existing

connection roads

Visual At hot, dry and windy

weather

Trakya Cement

Factory

Management of

Scrap Metals

Is the storage area

surrounded?

Are precautions taken to

prevent accidents?

Scrap metal storage site Visual examination of the the

site

Weekly during operation, or

more frequently if any


observed

Trakya Cement

Factory

Worker Safety Has an acceptable health

scanning been established?

Are the workers provided

with personal protective

equipment?

At the working areas of the

workers

Visual (together with a copy

of the health report)

Before any physical worker

activity starts

Daily

Trakya Cement

Factory

Contractor

Company

Existing roads Status, cleanliness Within the Trakya Cement

Factory site and 3 km

connection roads

Site visit / visual Daily Trakya Cement

Factory

Positioning and

construction of

transport roads

----- ----- ----- ----- -----

The possibility of

presence of cultural

works, areas and

Works of art being uncovered

during excavation

At any excavation site

Have the authorities been

notified and correct procedure

been applied?

During construction

Trakya Cement

Factory

8


monitored?


monitored?







Responsibility

structures with

local cultural value

The presence of any area,

building or cemetery with

local value

At any excavation site

Visual examination of the

plans, site visit

Before construction

Provision of raw

materials

The validity of the operation

license of the supplier

At the project site entrance of

the supplier’s office

Visually checking the

operation license

Before signing any agreement

for the provision of raw

materials

Trakya Cement

Factory

Contractor

Company

Management of

hazardous

substances (fuels,

oils, explosives,

etc.)

Are the landfill sites locked,

surrounded, well-ventilated

and on impermeable surface?

Is its location away from the

residential areas?

Hazardous waste storage site Visual examination of the

building and the site

Weekly during operation, or



observed

Before starting constructiom

Trakya Cement

Factory

Operation

Noise Noise levels

Have noise preventing

measures been taken?

On all the project site

Nearly residential areas

(especially where complaints

are received)

Noise measurement device

Visual

At semi-annual periods, or



observed

Trakya Cement

Factory

Dust / Air

emissions

O2, CO, NOx and SOx and

dust at the stack gas

At the rotary kiln incineration

stack

At the computers digitally

recording the stack gas

analysis

Continuous Trakya Cement

Factory

Residential

wastewaters

Are the residential

wastewaters being discharged

to the sewerage system

finalizing with treatment?

At the existing sewerage

system of the Trakya Cement

Factory

Visual At quarterly periods, or more

frequently if any


observed

Trakya Cement

Factory

9


monitored?


monitored?







Responsibility

Residential solid

waste

Are the wastes regularly and

suitable stored?

Project site trash bins Visual At weekly periods, or more

frequently if any


observed

Trakya Cement

Factory

Medical Wastes Are they being collected

separately from other wastes?

Workplace health unit

medical waste box

Visual At weekly periods, or more

frequently if any


observed

Trakya Cement

Factory

Hazardous Wastes Are they being collected

separately from other wastes?

Project site hazardous waste

storage areas

Visual At weekly periods, or more

frequently if any


observed

Trakya Cement

Factory

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