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


APPENDIX 5

Supplementary memorandum submitted by Cleanaway Ltd

  On behalf of Cleanaway, I would like to submit the following brief comments subsequent to the evidence given to your Committee by the British Cement Association (BCA). In particular, we would like to respond to the request made by the BCA for the Substitute Fuels Protocol (SFP) to be revoked.

  Whilst acknowledging the unique demands of the SFP on the cement industry, all other waste treatment processes have to receive planning permission before a permit is applied for. It is inconceivable that the creation of any waste facility, let alone a hazardous waste facility, could be contemplated without going through a democratic planning process, yet the kilns are allowed to convert to waste burning without applying for planning permission.

  We can assure the committee that obtaining planning permission for a hazardous waste facility in today's climate would take considerably longer than the 17 months that the BCA complain about (para 10).

  If the SFP were revoked, the cement kilns would in effect be given carte blanche to negotiate with their local Environment Agency Inspector to burn what they liked.

  We welcome the fact that the BCA has acknowledged that many of the waste materials arising within the UK are not suitable for use as a fuel and we would urge the committee to ensure that a list of those wastes which are suitable should be produced, as recommended by previous Select Committee inquiries.

  The reason that cement kilns are held to provide a solution higher up the waste hierarchy than HTI is only because the Government currently takes that view. In other Member States, high-temperature incinerators are afforded "recovery" status on high CV wastes. We do not accept that the low CV streams and high contaminant streams that are mixed into the blends are being "recovered". We agree with the previous Select Committee report, which concluded that burning SLF is a mixture of recovery and disposal.

  The BCA claims that significant changes and improvements have been made to cement kilns' pollution abatement equipment (BCA para 5.3). Whether the improvements are "significant" is a debatable point. However, the cement kiln that is permitted to accept the most hazardous waste, Castle Cement, Ribblesdale, in fact emitted 30 tonnes of HCl (hydrochloric acid gas), 8 kg of mercury and over 50 kg of chrome into the atmosphere in the year 2000. The high level of HCl emitted is worthy of note, given that in oral evidence the BCA stated that the lime in the kiln acts as a scrubber. During the same period the Cleanaway plant, equipped with efficient gas cleaning technology, emitted less than one tonne of HCl (Source—Environment Agency ISR data).

  Paddy Tipping MP asked a specific question about emission limits. I have set out the actual emission limits for the Cleanaway plant and a cement kiln burning waste:

ParameterMg/m3
Directive
94/67/EC
Cleanaway
AG 8233
Ribblesdale
AI2813
Kilns 5 and 6
Using SLF
Particulate matter
10
10
75
Oxides of nitrogen
350
1,200
Oxides of sulphur
50
50
1,850
Carbon monoxide
50
50
270
Hydrogen chloride
10
10
80
Hydrogen fluoride
1
1
4
Total organic carbon
10
10
35
Dioxins/furans ng/m3
0.1
0.1
0.8
Cadmium & thallium
0.05
0.05
0.05
Mercury
0.05
0.05
0.05
Group III metals
0.5
0.5
0.5


  I also attach for your information some summary data from May 2002, the most recent on the public register, which clearly demonstrates that average emissions from Castle Cement, Ribblesdale's kilns, 5, 6 and 7 increase when Cemfuel waste is burned.

  I hope that this additional information answers some of the questions that your Committee raised. I would like to thank you for the opportunity of explaining the position of the HTI industry and our concerns for its sustainability.

Cleanaway

12 July 2002

SCHEDULE 2—RELEASES INTO AIR

  Operator: Castle Cement Ltd.

  Location: Ribblesdale Works, Clitheroe.

  Authorisation No A12813.

  Variation No BJ1389.

SUMMARY OF STANDARDISED DATA FROM CONTINUOUS MONITORS ON KILN 7 FOR THE PERIOD: 1 APRIL 2002 TO 30 APRIL 2002 (ONE MONTH)

KILN 7

Without Cemfuel
With Cemfuel
Parameter
mg/m3
(1)
95% confidence interval
Maximum daily average
Maximum half-hour average
Monthly average
Days
above
limit value
Maximum daily average
Maximum half-hour average
Monthly average
Days
above
limit value

Oxides of
Nitrogen
(as NO2)
NA
891
498
0
852
910
691
0
Particulates
30%
28
9
0
30
145
13
0
Sulphur dioxide
20%
138
7
0
18
123
1
0
VOCs (as
TOC)
30%
87
35
0
86
96
54
0
Hydrogen Chloride
40%
0
0
0
0
0
0
0
Carbon Monoxide
10%
2,035
937
0
1,824
2,088
1,357
0

1 All data expressed at 273k, 101.3kPa, 11 per cent oxygen, dry. Reported data to make no allowance for 95 per cent confidence interval.


SUMMARY OF STANDARDISED DATA FROM CONTINUOUS MONITORS ON THE COMBINED CHIMNEY FOR KILNS 5 AND 6, FOR THE PERIOD: 1 APRIL 2002 TO 30 APRIL 2002 (ONE MONTH)

KILNS 5 AND 6 COMBINED CHIMNEY
Without Cemfuel
With Cemfuel
Parameter
mg/m3
(1)
95% confidence interval
Maximum daily average
Maximum half-hour average
Monthly average
Days
above
limit value
Maximum daily average
Maximum half-hour average
Monthly average
Days
above
limit value

Oxides of
Nitrogen
(as NO2)
NA
1,476
570
0
935
1,260
590
0
Particulates
30%
79
26
0
45
112
38
0
Sulphur dioxide
20%
2,438
1,008
0
2,298
3,423
1,908
0
VOCs (as
TOC)
30%
15
5
0
10
13
8
0
Hydrogen Chloride
40%
256
56
0
139
319
82
0
Carbon Monoxide
10%
188
94
0
210
467
154
0

1 All data expressed at 273k, 101.3kPa, 11 per cent oxygen, dry. Reported data to make no allowance for 95 per cent confidence interval.





 
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