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 (SourceEnvironment 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 2RELEASES 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.
|
|