Annex 1
THE UK CEMENT INDUSTRY'S ENVIRONMENTAL PERFORMANCE
PROCESSING CONDITIONS
1. Processing conditions within a cement
kiln are more extreme than in so-called "high temperature
incinerators", and waste-derived materials are subject to
flame temperatures in excess of 2,000ºC, material temperatures
of at least 1,450ºC, and gas residence times above 1,100ºC
of between four and five seconds. The minimum residence time
for non-gaseous material is about 30 minutes.
2. Cement making requires stable burning
conditions and as such all waste-derived materials to be used
as fuels are subject to strict compositional control. Not all
waste disposal firms are capable of meeting these criteria, and
not all waste streams are suitable for such use.
3. In addition to reducing the requirement
for fossil fuels and other primary materials, the use of alternative
materials results in a net environmental benefit and the potential
for improved kiln performance, such as the reduction of NOx emissions.
4. Within the oxygen rich environment of
the cement kiln, these conditions ensure the complete breakdown
of even the most stable of chemical bonds, and any ash from the
combustion of the hazardous waste is fixed safely into the glassy
matrix of the product clinker.
5. The large mass of alkaline feed material
at high temperature within the kiln imparts a stabilising effect
as a result of its huge thermal inertia, and provides a mechanism
for scrubbing any acidic off-gases that may arise from the combustion
process.
6. For many years continuous emission monitors
have been the industry standard for ensuring regulatory compliance.
The trialling of new fuels is often subject to more stringent
regulatory emission limits and these monitors provide a fast response
to ensure compliance with these requirements.
7. The industry has invested in the installation
of new data acquisition systems that collect and record information
for analysis and presentation to the relevant regulatory bodies
in a way that is easily understood.
Environmental Management Systems
8. All UK cement works are certified to
ISO 14001, the international voluntary standard for Environmental
Management Systems, and over 68 per cent of sites have additionally
chosen to obtain accreditation to EMAS, the European Union Eco-Management
and Audit Scheme. All sites are licensed under the EU IPPC Directive
and will be subject to the Waste Incineration Directive.
STAKEHOLDER ENGAGEMENT
9. The local communities around the factories
are key stakeholders, with further groups including customers
and suppliers. UK cement producers have regular communications
with stakeholders as part of their normal operations. Frequent
community engagement is supplemented on a site-by-site basis focussing
on key licence to operate issues, for example quarry extensions
and alternative fuels trials.
The methods of community communications include:
9.1 Newsletters updating the community on
plans and progress.
9.2 Open Door—members of the community
can phone and request a meeting or site visit.
9.3 Formal Open Days—to allow communities
to see the factory in operation and (where applicable) fuels trials
taking place.
9.4 Liaison committees—to provide a
forum for regular dialogue between the company and representatives
of the local community.
9.5 Weekly reports on the progress of trials.
CLIMATE CHANGE
COMMITMENTS
10. The British Cement Association and each
of its member companies have signed a Climate Change Levy Agreement
with the Government undertaking to deliver an overall energy efficiency
improvement, across the sector, of 25.6 per cent over the 1990-2010
period in order to qualify for the 80 per cent rebate on the levy.
This is in excess of the Government's ambitious aspirational target
of 20 per cent, its legally binding Kyoto target of 12.5 per cent,
and is substantially higher than a number of comparable industry
sectors.
11. Achievement of the sector's Climate
Change targets is dependent upon two factors: the installation
of new, energy efficient plant, and the increased use of waste-derived
fuels, ("alternative fuels").
11.1 A £500 million investment programme
is being undertaken. Each cement company is investing in new
plant and upgrading existing plant and equipment in order to improve
energy efficiency and environmental performance.
11.2 Buxton Lime Industries constructing
new plant at Tunstead, near Buxton to replace old production facility.
11.3 Lafarge Cement UK given planning permission
to develop new plant at Medway in Kent.
11.4 Castle Cement has received planning
permission from the Welsh Assembly for a £48 million investment
in a new kiln to replace old production facilities at Padeswood
in North Wales and Lancashire.
11.5 Rugby Cement has recently commissioned
new plant at Rugby to replace four old facilities (seven kilns)
at a total cost exceeding £170 million.
12. To meet its demanding Climate Change
Agreement targets, the industry has little option but to increase
its use of waste-derived fuels, a condition that has been formally
acknowledged by government.
13. A Memorandum of Understanding defining
the basis of the Climate Change Levy reduction targets was signed
by DETR and BCA on 20 December 2000. This stated inter alia that
the targets were based upon the installation of new plant, and
1 per cent year-on-year increases in the use of waste-derived
material as fuel.
14. Confirmation of an assumed increase
in the usage of waste-derived fuel was given in the exchange of
letters on the Climate Change Levy Agreement between DEFRA and
BCA on 12 October 2001.
15. With such an increase, by 2010 the substitution
rate of waste-derived fuels would be 15 per cent. However, this
potential for increased use of waste-derived materials is not
currently being realised due to the lengthy authorisation procedure
imposed by the Environment Agency as described in Annex III.
16. Within Europe, cement manufactured in
the UK is unique in having a mandatory Climate Change Levy imposed
upon its operation.
17. Additional to the costs of the extra
taxation, there are considerable associated administrative burdens.
18. The practical outcome is the UK manufacturing
operations are placed at a commercial disadvantage when compared
with almost identical operations on mainland Europe. The majority
of UK cement manufacturing capacity is controlled by European-based
parent companies, whose investment and economic decisions are
strongly influenced by factors such as these.
| 
