House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by the British Cement Association (BCA)

The British Cement Association (BCA) is pleased to make this submission to the Environment, Food and Rural Affairs Committee inquiry into Hazardous Waste.

The BCA is the Trade Association representing the cement industry in the United Kingdom, and its four members-Castle Cement, Lafarge Cement, Rugby Cement, and Buxton Lime Industries-are responsible for the production of all the cement manufactured within the UK.

This accounts for over 90 per cent of the cement used in the UK, of which 52.2 per cent goes to ready-mixed concrete (includes bulk cement delivered to site), 26.5 per cent goes to pre-cast concrete, and 21.3 per cent is sold as packed cement.

BCA's four member companies operate 16 cement-producing plants across the UK, nine belonging to Lafarge Cement UK, three each to Castle Cement and Rugby Cement, and one to Buxton Lime Industries.

The UK industry has an annual turnover of £600 million, and provides direct employment for ~3,500, and indirect employment for ~15,000.

The submission consists of:

— This Covering Note.

— Executive Summary.

— Main Text for the Submission.

— Three Annexes with further detailed information.

Dealing with waste is a key industry issue for the British cement companies and we therefore trust that the Committee will find this submission a significant and helpful contribution to their inquiry.

EXECUTIVE SUMMARY

1. The Landfill Directive, the Waste Incineration Directive, and other EU legislation, present the UK with a significant challenge to develop solutions to meet its waste disposal obligations. As a result of these, hazardous and other wastes will be shifted from existing disposal routes such as landfill, whilst the burning of waste-derived materials will be subject to stricter control. This will necessitate the development of intelligent and environmentally sound solutions.

2. The cement industry has a significant role to play in developing solutions to current and future problems highlighted by the UK Waste Strategy. The cement-making process provides optimum conditions of temperature and residence time for the destruction of hazardous and other wastes, and the industry has a proven track record in the application of its process technology to the beneficial treatment of a wide range of these materials.

Since the early 1990s, the UK cement industry has been engaged in the development of techniques for the use of waste-derived materials as fuels and as a replacement for certain raw materials. In collaboration with its European partners, the UK cement industry has developed expertise in this area, increasing the range of materials that can be used safely in cement kilns, and demonstrating the consequent environmental benefits.

In addition to mandatory controls, the UK cement industry has introduced environmental management systems in all of its plants, and has frequent and structured contact with stakeholders within the local communities.

The industry is in a strong position to contribute further to the solution of the UK's increasing waste disposal problems, but is prevented from maximising its potential in this area by the application of outdated regulatory controls that apply exclusively to the cement and lime industries in the form of the Substitute Fuels Protocol (SFP).

Furthermore, signature by government of the industry's Climate Change Levy Agreement was on the basis of a year-on-year increase in the use of waste-derived materials as fuels towards a minimum level of 15 per cent replacement by 2010.

In order to realise the cement industry's potential to contribute to the solution to the UK's waste problem it is necessary to achieve a paradigm shift from rigid regulatory controls that work against environmental best practice to regulation and a system that works in support of sustainable development. European best practice holds many of the keys to achieving sustainable development in the cement sector and in turn the cement sector can contribute to broader sustainable development in the UK.

The UK cement industry believes that for this to be achieved:

— All industrial and commercial processes using waste materials, either as fuels or replacement raw materials, must be controlled to the same degree of rigour;

— The operation of such processes should be controlled through the IPPC Directive and the Waste Incineration Directive, supplemented by an extended stakeholder consultation process, based upon the Environment Agency Protocol for burning used tyres in cement kilns;

— The Substitute Fuels Protocol should be replaced with a permitting process that reflects the considerable experience gained across Europe in the use of waste-derived fuels.

Such a breakthrough in permitting processes will enable the UK cement industry to realize its full potential in contributing to speedy and genuine progress towards sustainable waste management and thereby assist government to deliver the policies needed to deal with hazardous and other wastes.

INTRODUCTION

The UK Cement Industry's Track Record in the Use of Waste-derived Materials

3. Waste Derived Materials

3.1 The EU Landfill Directive is diverting many waste materials away from landfill, requiring that alternative recovery or disposal routes are secured. Other EU measures such as the End of Life Vehicles Directive and the Waste Electronic and Electrical Equipment Directive will have a similar effect, but at present the UK is ill prepared to administer the necessary changes, as exemplified by the recent example of refrigerators

3.2 The forthcoming Waste Incineration Directive will further exacerbate the problem by placing constraints on the commercial viability of some waste disposal routes currently in operation, such as those for reclaimed fuel oil, RFO.

3.3 Whilst re-use and recycling routes will become available for some of the resultant material, there will be a large quantity of wastes for which new disposal options must be sought. The UK cement industry has the capacity, the technology and the environmental commitment to accept some of these materials either as a replacement for conventional raw materials or as fuel sources.

3.4 Alternative Raw Materials. Industrial waste streams, which contain high percentages of iron, alumina and silica, have been identified as a potential source of the correctors sometimes needed when mineralogical anomalies occur in the prime raw material source for cement production. When suitably conditioned these could be used as a substitute. Avoidance of such bulk materials in landfill, meeting the needs of the cement process and the ability of the thermal properties of the cement process to sterilize the materials represents a major win-win-win for industry and the environment.

3.5 Waste Derived Fuels. Since the early 1990s, cement kilns have been used to recover energy from hazardous and other wastes. This use is in full compliance with relevant legislation—the Hazardous Waste Incineration Directive, (HWID), the IPPC Directive—and will satisfy the requirements of the forthcoming Waste Incineration Directive.

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3.7 The Environment Agency places unique demands on the cement industry through the requirement for expensive, exacting and time-consuming trials as laid out in the Substitute Fuels Protocol, (SFP), at each and every location a fuel is used. This is enforced regardless of previous experience and knowledge of use of the fuel at other sites, (or at the same site when perhaps just a change in the mix or quantities of fuel are needed).

3.8 The Environment Agency also places artificial limitations on the range of calorific values for fuels that may be used in cement kilns. This prevents the use of waste-derived fuels that would actually contribute to the raw material flows into the kiln systems, or fuels with simply a higher water content.

Material	Potential use in Cement Kilns k tonnes	Total Tonnage of Material in UK k tonnes	per cent UK Total treated in Cement Kilns
Tyres	~213	~427[2]	50
Substitute Liquid Fuel	~118	~236[3]	50
Packaging Waste	~900	~9,000	10

4. In addition, it is considering the following as fuels:

4.4 Waste oils (expected to be designated as hazardous waste);

4.5 Animal products, including tallow, and meat and bone meal (MBM);

4.6 Sewage sludge pellets,

and other waste-derived products as a substitute for raw materials

MEETING THE CHALLENGE

5. In 1995 and in 1997, the Environment Committee published reports relating to the use of alternative fuels in cement kilns.[4], [5]Since these were published, there have been a number of significant changes relating to the disposal of hazardous and other waste materials:

5.1 A wider range of industries outwith the traditional waste management sector is now using waste-derived materials as fuel or as a replacement for more conventionally derived material, eg the power industry;

5.2 New legislation controlling these disposal routes in continually being introduced, notably the IPPC Directive, the Landfill Directive, the Hazardous Waste Incineration Directive, and the forthcoming Waste Incineration Directive;

5.3 Significant changes and improvements have been made in the production of cement, i.e. investment in new plant, improved environmental performance of all cement plants, installation of extended continuous monitoring, structured stakeholder consultation, as described in Annexes 1 and 2.

5.4 These changes have addressed the Committee's recommendations.

6. The cement industry is primarily regulated by the IPPC Directive which, when taken in conjunction with other EU and national regulations and in combination with our active programme of stakeholder dialogue ought to more than meet any reasonable compliance requirements.

7. Nevertheless, the cement and lime industries remain the only sectors to be additionally controlled by the Environment Agency's Substitute Fuel Protocol, (SFP), which inhibits innovation, enforces continued reliance on less environmentally friendly fossil fuels and has an adverse effect on their competitiveness, (see Annex 3).

8. The Substitute Fuels Protocol (SFP) regulates the use of all fuels (other than coal, pet-coke and tyres) in cement and lime kilns. It has no formal legislative basis, and although it provided a framework for the treatment of these materials in the mid-1990s, and in view of the developments described in paragraphs 5.1 to 5.3 has become an inappropriate and outmoded base upon which to develop practical solutions to the UK's waste management problems in 2002 and beyond.

9. As a consequence of the restrictive regulatory approach within the UK, the current levels of usage of waste derived fuels are considerably lower than those on mainland Europe, despite being subject to the same EU legislation.

AVERAGE USE OF WASTE-DERIVED FUELS IN CEMENT KILNS WITHIN EUROPE

United Kingdom[6]	6 per cent
European Average[7]	12 per cent
Germany and France	30 to 40 per cent
Belgium	50 per cent

10. Examples of the time and costs involved in applying the Substitute Fuels Protocol are detailed in paragraph 13 and in Annex III. As a consequence, the cement industry is reluctant to consider using many of the UK's problem wastes. High, up-front costs are essentially risk capital, and extended authorization periods of 15 to 30 months have a significant effect on the payback period. Delays between the end of trials and the granting of permits are problematic in terms of continuity of supplies (of alternative fuel to required quality standards) and operational conditions.

11. With this in mind and in an effort to improve the process of the permitting procedure for the use of waste tyres as a fuel, the Environment Agency introduced the Tyres Protocol for use on cement kilns in December 2001. This includes guidance on the consultation of stakeholders, especially local communities, and suggests that this begins at a very early stage, well before the time comes to submit an application for permitting to the Agency.

12. Despite this limited streamlining, all other waste-derived fuels are still subject to the SFP. However, the industry welcomes the extended consultation contained in the new Tyres Protocol and recommends that this should be the standard model for all industry use of waste-derived fuels, not just tyres in cement kilns.

13. Comparison between use of alternative fuels the UK and France. [8]

13.1 In the UK it takes 17 months or more to secure permission to use a single fuel at a factory. In France it takes a maximum of twelve months to get a permit to use a specified list types of waste as fuels.

WASTE FUELS PERMITTING PROCESS—COMPARISON OF UK AND FRANCE

UK	4 months
Apply for and get permission for a trial using the single new fuel
Run the trial using the fuel	6 months
Prepare report on trial	3 months
Apply for and get permanent permission to use the fuel	4 months
Full time use of single fuel commences after	17 months[9]
France	2 months
Apply for licence to use a list of "wastes" as fuel—negotiation with Prefecture
Public consultation[10]	2 months
Dossier on the application reviewed by committee and signed	2 months
Full time use of the fuels commences after	6 months**

WASTE-DERIVED MATERIAL IN CEMENT KILNS AND WASTE INCINERATORS

14. The cement industry and the waste incineration sector are both significant recipients of waste materials. However, as highlighted earlier in this document:

14.1 The cement industry's requirements for waste are quite specific, and many of the materials arising within the UK are not suitable for use as fuel in a cement kiln, since they are not available in sufficient quantities within the compositional requirements.

14.3 Cement kilns provide an unique combination of high temperature and long residence time that is not available in other disposal routes.

14.4 The treatment of wastes in a cement kilns provides a solution higher up the waste hierarchy than waste disposal through incineration.

15. Cement kilns have the capability of responding to fluctuations in the availability of a number of waste streams without the need to install new capacity with its attendant long-term operational implications.

16. Friends of the Earth state that in view of the extended period required by waste management companies to recover their investment in a new incinerator,[12] long-term contracts with councils must be secured, thus reducing the incentive to minimize waste.

THE UK CEMENT INDUSTRY AND THE UK WASTE STRATEGY

The Way Forward

17. The use of alternative fuels in the UK cement industry delivers benefits including:

17.1 Improving the environmental performance of the factories—enhancing the environment for both the communities living nearby and globally.

17.2 Moving materials up the waste hierarchy from disposal to energy recovery—saving landfill space and helping deliver government waste policy

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17.4 Improving the factories' commercial performance—protecting the jobs of employees and protecting the competitiveness of UK industry.

18. Delivery of these benefits is being hampered by excessive and overly burdensome regulation that is not applied to cement makers in other countries nor to other industries in the UK. The impact of this is to:

18.1 Damage the competitiveness of the British Cement Industry

18.2 Delay the delivery of significant environmental benefits

18.3 Threaten future investment decisions

19. In order to realise the cement industry's potential to contribute to the solution to the UK's waste problem it is necessary to achieve a paradigm shift from rigid regulatory controls that work against environmental best practice to regulation and a system that works in support of sustainable development. European best practice holds many of the keys to achieving sustainable development in the cement sector and in turn the cement sector can contribute to broader sustainable development in the UK.

20. The UK cement industry believes that for this to be achieved:

20.1 All processes using waste materials, either as fuels or replacement raw materials, must be controlled to the same degree of rigour;

20.2 The operation of such processes should be controlled through the IPPC Directive and the Waste Incineration Directive, supplemented by an extended stakeholder consultation process, based upon the Environment Agency Protocol for burning used tyres in cement kilns;

20.3 The Substitute Fuels Protocol should be replaced with a permitting process that reflects the considerable experience gained across Europe in the use of waste-derived fuels.

21. Such a breakthrough in permitting processes will enable the UK cement industry to realize its full potential in contributing to speedy and genuine progress towards sustainable waste management and thereby help to deliver the policies needed to deal with hazardous and other waste.

British Cement Association

17 May 2002

1 Updated information based on BCA original data presented to Rt Hon Michael Meacher MP, Minister for the Environment, 26 May 1998. Back

2 Environmental Agency Web page, The Impact of Tyres on the Environment, 10 May 2002. Back

3 House of Commons Hansard, 18 December 2002, column 13W. Back

4 "The Burning of Secondary Liquid Fuel in Cement Kilns", Second Report of the Environment Committee, 1994-95, HC 479. Back

5 "The Environmental Impact of Cement Manufacture", Third report of the Environment Committee, 1996-97, HC 124-I. Back

6 6 House of Commons Hansard, 17 December 2001, col 126W. Back

7 Data provided by Lafarge Cement UK. Back

8 Data provided by Lafarge Cement UK. Back

9 This is for the shortest possible period both processes can take. In the UK if the final stage alone has been known to take 14 months; in France it usually takes between 9 and 12 months. Back

10 This aspect is at the discretion of the prefecture, depending on the level of interest in the operation-this can be extended. Back