SECTORAL PRIORITIES

Emissions

Cement factories have all permits and licenses required for years within the scope of the environmental legislation. Almost all factories have obtained the “Environmental Permit/Environmental Permit and License Certificate” required to be obtained as per the “Regulation on the Permits and Licenses Required As Per the Environmental Law”, which came into force in 2010 and gathered all permits/licenses under one roof.

Cement factories have “Environmental Measurements” performed to obtain the environmental permits from the Ministry. These measurements are repeated at the periods provided in the Regulations and control measurements continue in the flues by means of the continuous measurement devices after the permit is obtained.  Calibrations of the continuous measurement devices are also repeated at the frequencies provided in the legislation. All environmental measurements of the sector are performed by the “independent accredited laboratories” authorized by the Ministry of Environment and Urbanization.

As per the “Regulation on Waste Incineration”, the accredited laboratories, which are authorized by the Ministry of Environment and Urbanization” run test incineration and then periodical measurements are carried out.

Position of the Turkish Cement Sector 

In 1993 and then in 2004, “Cement Industry Environmental Declarations” are signed between the TCMA and the Ministry of Environment and Urbanization. According to these declarations, cement industry agrees to limit the emission values at lower levels than the limit values specified in the regulations. In the years after the signing years of the declarations, the sector made the necessary investments for emission control, improved its processes and completed all environmental permits. Moreover, pilot studies were conducted in a number of areas to comply with the new environmental legislation. Cement sector was the first sector to have completed the permit processes with the Ministry in terms of compliance to the environment. 

With the bag filter investments made in the recent years, emission levels far lower than the legal limits are achieved in a number of facilities.

Reduction systems for nitrogen oxide, which is ammonia waste, have been installed in many facilities to achieve the nitrogen oxide emissions reduced as of 2018. Turkey is the importer of ammonia, which is a consumable in Nox removal plants. During the operation, logistics problems are faced in addition to the procurement costs of the ammonia, which is an imported consumable. Ammonia production facilities are located in Marmara and Mediterranean Regions. It will be required to transport from distances above 1000 km to the facilities located in such regions as Black Sea and Eastern Anatolia. 

TCMA and sector representatives closely follow the studies for the Regulation on Integrated Pollution Prevention and Control to take effect in the upcoming years.

Within this scope, the following documents have been reviewed:

•    Best Available Techniques Reference Document: Within the scope of the EU Directive No.2010/75/EU on Industrial Emissions, Reference Document for the Best Available Techniques for the cement sector (2013)
•    BAT results within the scope of the EU Directive No.2010/75/EU on Industrial Emissions, Results for the Implementation of Best Available Techniques (March 2013)  

It is of vital importance to establish rules that pay attention to the costs, reflect the realities of our country and do not go beyond the requirements of the EU legislation. For example in the coming years, it is important to take account of the additional operating costs to be incurred due to implementing 200-450 mg/Nm3 range in our country and import/logistic problems to be faced under the circumstances in our country.