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

Supplementary memorandum submitted by the British Cement Association

  The British Cement Association would like to thank the Environment, Food and Rural Affairs Sub-committee for inviting it to give oral evidence on 2 July 2002 to its inquiry into Hazardous Waste, and the invitation to submit supplementary information for the Committee.

  Our key point is that we ask the Committee to agree to our proposal to revisit the Substitute Fuels Protocol, which we feel has been superseded, and is redundant, but is still inhibiting progress. It will be of equal importance that any resulting revision of policy at national level is implemented at local level by the Environment Agency's inspectors.

  Attached is supplementary information including:

    —  the ability and willingness of the industry to participate with government as part of the waste management solution for the disposal of hazardous and other wastes;

    —  factors within UK legislation, notably the Substitute Fuels Protocol, that are inhibiting action and innovation by the industry;

    —  the issue of competition with other industries; and

    —  the distribution of cement plants across the UK, and their ability to provide solutions on a relatively localised basis.

  May we reiterate our invitation to the Committee to visit a cement plant either in the UK or at one of our members other European sites? Recognising the Committee's time constraints in producing this report, we stand ready to put arrangements promptly in place.

  Should the Committee require any further information or clarification of the points made in this supplementary submission, our oral evidence or written submission then we should be pleased to give it.

  The BCA and its members very much look forward to the publication of the Committee's report.


  As the BCA highlighted in both its written submission to the Committee, and during its oral evidence session, we believe the cement industry has a significant role to play providing a beneficial solution to the disposal of hazardous wastes in the UK.

  Table 1, below, sets out the potential of the industry to make use of a range of wastes in cement making processes. >From a performance last year where 150,000 tonnes of wastes were used as a fuel, within 3-5 years we could increase this ten-fold. This offers a major breakthrough in terms of sustainability as:

  The energy and material resources in the wastes will be recovered and used in making an essential building material.

Table 1


Fuel2001-Actual Use, tonnes Next 3-5 years—estimates of Potential Use, tonnes
Waste derived liquid fuels110,000 200,000
Packaging and Packaging Waste0 500,000
Waste Oils090,000 to 345,000 (see page 4)
Meat and Bone Meal, (MBM)0 140,000
Processed sewage pellets, (PSP)0 40,000
Total150,0001,260,000 excluding waste oils
1,515,000 including waste oils


  In order to realise fully this potential and to compete on equal terms with other EU cement plants, the use of these materials in cement kilns should be regulated in accordance with the latest EU directives—[IPPC and WID]—supplemented by a transparent and full-inclusive stakeholder dialogue, that is consistent with ensuring environmental improvement.

  To achieve this it is necessary to address the issue of the Substitute Fuel Protocol (SFP), whose origins lie in a report from the present committee's predecessor. As the present Committee itself noted on 2 July, this Protocol applies only to the cement and lime sector.

  The SFP is an extra-statutory regulation that requires a prescribed procedure to be followed by the industry when an application is made to use an alternative fuel. The timetable for permitting an alternative fuel, following the SFP, sets a minimum timescale of 17 months, providing that all stages are completed within the specific period. In reality the actual time taken is substantially longer, and often dictated by local inspectors operating outside the national protocol.A breakdown of the stages in this procedure is set out in Annex 1, and a comparison with much shorter procedure in France is given in Annex 2. Likewise in Germany, authorisations are granted much more quickly: for example, RMC in Germany gained permission to burn animal meal was granted in one month, and a full permit obtained after a further three months: authorisation to increase the rate of fuel usage was granted in 10 months.

  In addition, the cement industry has demonstrated consistently that improved environmental performance follows the introduction of alternative fuels, Annex 3. The SFP requires plants to stop utilising an alternative fuel after trial and return to using traditional fuels, a worse environmental option with higher emission levels.

  As we stated at our oral evidence session, the SFP was created at a time when there was a regulatory vacuum in the permitting of alternative fuels. Since then, regulation has moved on, and so has the industry. The requirmenets placed on the industry through IPPC and WID, coupled with our unequivocal committment to stakeholder dialogue means, in our view, that the SFP has been superseded and is, therefore, redundant.

  As a consequence of its origin, policy makers and regulators are reluctant to look at this matter without sanction from the Environment Committee. The BCA therefore asks the Committee, after reviewing the evidence presented to it, to recommend that an independently chaired review of the SFP be carried out involving the cement industry and other stakeholders, and that the review is asked to report its conclusions and recommendations to the Committee by the end of 2002.

  The Cement Industry stands ready to play its role, along with other stakeholders, in the process.

  To help kick start the review, the cement industry would be happy to table a new draft proposal that could serve as the basis for discussion.


  The Committee has heard in evidence from a number of witnesses that the UK relies more heavily on landfill than most other EU countries, yet these countries in turn have greater recourse to the use of high temperature incinerators as part of the solution to their waste disposal problems.

  The Environmental Services Association (ESA) suggested to the Committe that high temperature incineration was subject to unfair competition for suitable hazardous waste materials from cement kilns.

  The cement industry contend that the reasoning behind this assertion is flawed because:

    —  high temperature incinerators will and must have a continuing role to play in the disposal of hazardout material;

    —  the cement industry must be selective in the wastes it uses as fuels, therefore, a wide range of hazardous wastes, including high calorific value wastes, are still available to high temperature incinerators.

    —  other EU countries have a lower reliance on landfill but a higher use of both high temperature incineration and co-incineration by cement kilns using alternative fuels. It therefore seems unlikely that the situation in the UK is the result of unfair competition.

  Nevertheless, the basic tenet of EU legislation that operations higher up the waste hierarchy should be favoured should hold true in this case. Market dynamics can step in here to ensure a balance between competing services. That is why some of the high temperature incinerator operators now supply the cement industry with the blended fuels we require.

  The Environment Minister, Michael Meacher, pointed out his own oral evidence to the Committee, 1 July 2002, an important distinction between high temperature incinerators and co-incineration in a cement kiln; the latter process he said recovers energy and in that there is environmental logic.

  The application of the Landfill Directive will require that more of the current six million tonnes of waste that the UK produces annually be dealt with differently. [18]Furthermore, the revision to the Hazardous Waste List will result in an additional 200 wastes (estimated 600,000 tonnes) being classified as hazardous on the European Waste Catalogue and requiring appropriate treatment. [19]However, even at optimum utilisation levels, the UK cement industry has the potential to make use of 1.5 million tonnes of hazardous and other wastes, leaving 4.5 million tonnes requiring alternative disposal routes.


  The UK cement industry has 16 production facilities spread across the UK from Dunbar in Scotland, Cookstown in Northern Ireland, Padeswood and Aberthaw in Wales and 11 plants across England.

  Of these, four are already using hazardous wastes as fuels, compared to only two high temperature incinerators in the UK. The cement industry therefore has the potential to provide the environmentally preferable local solutions to local waste disposal problems, without the need to install new capacity.

  Nevertheless, substantial capital investment will be needed in order to increase the use of alternative fuels by the UK cement industry to bring it into line with best European practice. It will take time for the industry to attain such a ten-fold increase of alternative fule use, and a review of the SFP is critical to allow this process to start.

  The ESA suggested to the Committee that the cement industry was obliged to meet lower emission limits than those applied to high temperature incinerators. The facts do not support this.

  The reality of the situation is the cement industry complies fully with the hazardous waste incineration directive. The directive allows co-incineration and it is under the co-incinerator clauses of the directive that a cement kiln is regulated. This applies if there is less than 40 per cent thermal substitution by hazardous wastes.

  The reason the directive has different limits for cement kilns is that the emissions from cement kilns arise largely from the raw materials for making cement (limestone and clay materials) rather than the fuel, whereas in an incinerator all the emissions arise from the combustion of wastes.


  We have examined the written memorandum from the Environment Agency and DEFRA and find their tables showing the disposal routes for hazardous waste confusing, as they seriously underestimate the utilisation of incineration with energy recovery. Both tables, Appendix 1 of the Agency's submission and Point 13 of DEFRA's use the same figures for 1997-98, indicating only some 34,000 tonnes was disposed of via this route. The Agency also includes figures for 2000 of 57,000 tonnes. We have spoken with the Agency on the accuracy of this information and they have told the BCA that they accept our figures that show for the cement industry alone last year (2001) it used—150,000 tonnes of hazardous waste derived fuel.

The future problem of waste oils

  In 2001 Oakdene Hollins reported to DETR that the Recovered Fuel Oil, (RFO), currently burnt by power stations and road stone drying plants, would come under the WID or the HWID, depending on the EA classification of this material, and that they anticipated that: "from 2006 or possibly sooner the majority of RFO will be directed to cement and lime kilns". The cement industry in France and Germany are already the main users of these materials. Similarly, Annex 4 shows the difference between the UK and Belgian governments in responding to specific challenges requiring high temperature incineration. We believe that a joint government, regulator and cement industry initiative could resolve serious challenges facing the UK including, for example, waste meals and MBM.


  The BCA is playing a full role in the current Performance and Innovation Unit (PIU) work on waste, offering opportunities to make a contribution to the UK recovery targets. The Association is also contributing to the DTI consultation on Energy where it indicates that the use of waste fuels addresses two prime areas of consideration for that consultation:

    —  increasing the diversity of supply.

    —  reducing emissions of global warming gases.

  The cement industry sees the use of waste materials as a means of controlling its resource use and assisting in its sustainable development strategy.

The British Cement Association

10 July 2002

18   Environment Agency submission to EFRA Sub-Committee Hazardous Waste Inquiry (E20), Appendix 1. Back

19   DEFRA submission tor EFRA Sub-Committee Hazardous Waste Inquiry (E21), point 49. Back

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