APPENDIX 7
Memorandum submitted by Lafarge Cement
UK
EXECUTIVE SUMMARY
The UK cement industry has the potential to
be a significant part of the solution to the problem the country
faces in dealing with its disposal obligations for a range of
wastes.
The cement industry and Lafarge Cement UK (LCUK),
previously Blue Circle Cement UK, in particular already has a
strong track record of success in delivering part of the solution.
However, the outdated regulatory process applied by the Environment
Agency restricts the industry's potential to contribute fully
to sustainable development in the cement sector and, in turn,
to sustainable development in the UK.
LCUK urges the Committee to consider initiating
a full review of the regulatory framework governing the use of
waste derived material in cement manufacturing; the cement industry's
potential to contribute to not only the solutions to hazardous
waste disposal but also a wide range of other wastes; and to ensure
that best environmental options are adopted in the use of hazardous
and non-hazardous wastes.
LCUK requests the Committee to consider that
any new regulatory system reflects:
— European best practice in terms of
permitting processes, without loss of environmental rigour;
— The extensive knowledge and experience
gained in the UK and Europe in the use of waste derived material
since the Committee last looked at this issue; and
— The UK cement industry's public commitment
to earning and retaining its "licence to operate" through
its environmental performance and its stakeholder engagement activities.
— The competitive position of the UK
cement industry that can work to maximise environmental additionality.
The cement industry in the rest of Europe is
actively encouraged to play a significant role in providing solutions
to hazardous and non-hazardous waste problems. The UK and its
cement industry must not be left behind in terms of environmental,
economic and socially responsible solutions to waste problems
because of out dated regulatory systems. The Substitute Fuels
Protocol must be re-invented to reflect best practice in the permitting
and use of waste derived materials in the cement process and it
must not be allowed to stifle the developing use of wastes as
alternative raw materials.
Lafarge invites the Committee to visit one or
more of its mainland European plants to see and hear more about
the use of hazardous and non-hazardous waste in the cement manufacturing
process.
Lafarge would be happy to present oral evidence
to the Committee in terms of UK and European comparisons.
INTRODUCTION
LCUK welcomes the Committee's inquiry and the
wider waste review being conducted by the Performance and Innovation
Unit.
Focus of LCUK submission
LCUK's submission to the committee focuses on
the following aspects:
— Experience of constraints in the
UK regulatory system for permitting the use of wastes (including
hazardous wastes) in the cement process-governed by the Environment
Agency's Substitute Fuels Protocol.
— Experience of the regulatory system
in France for permitting the use of wastes (including hazardous
wastes) in the cement process.
LAFARGE CEMENT
UK
Lafarge Cement UK (LCUK) is the largest cement
maker in the UK and is part of the Lafarge Group. LCUK has capacity
to supply more than six million tonnes of cement a year from its
nine cement works and employs over 1,500 people. LCUK was formerly
known as Blue Circle Cement UK, but changed its company name to
Lafarge Cement UK in January 2002. The Blue Circle product brand
name has been retained.
LCUK has been part of the Lafarge Group since
July 2001, when Lafarge acquired Blue Circle Industries PLC. Lafarge
is the world leader in building materials, employing 82,000 employees.
It has leading positions in cement, concrete and aggregates, roofing
and gypsum.
Use of Wastes in the Cement Making Process—The
Riple Bottom Line Effect
The international cement industry has been substituting
waste derived fuels for virgin fossil fuels for over ten years
and can be considered to be highly proficient in its understanding,
handling and environmental control of such wastes.
The vast majority of experience and knowledge
in this area has been developed in main-land European countries
where the cement industry has traditionally been seen as an important
contributor to the waste solution. LCUK now benefits from the
large reservoir of knowledge that resides in its parent company,
Lafarge S.A. of France. This similarly applies to other UK cement
manufacturers who are either German owned or have manufacturing
operations in other European countries.
The cement making process is ideal for realising
material or energy value from waste materials. LCUK is already
engaged in the advantageous use of wastes including hazardous
wastes either as fuel or raw materials in its manufacturing process.
The company is currently using scrap tyres at
three of its factories and recycled liquid fuel (RLF-classified
as hazardous waste) at one. RLF is derived from solvent based
wastes that are blended to a tight specification before they are
suitable for use as cement kiln fuel. An active programme of seeking
permits for trials and permanent permission to use further fuels
is underway. This can include materials manufactured from materials
classified as hazardous.
The use of waste derived material is core to
the company's environmental programme and provides significant
steps forward in terms of sustainability and business performance.
The use of waste delivers the "triple bottom line" of
sustainable development, including:
— Improving the environmental performance
of the factories-enhancing the environment for the communities
living nearby.
— The most recent trials run by LCUK
showed that using RLF cut the overall impact of that factory on
the local environment by 25 per cent.
— Moving materials up the waste hierarchy
from disposal to energy recovery-saving landfill space and helping
deliver government waste policy.
— LCUK's Dunbar Works is permitted
to use up to 40,000 tonnes of RLF a year-liquids that would otherwise
have been disposed of in landfill sites or incinerated.
— Conserving fossil fuels for future
generations-moving towards the more sustainable use of resources.
— A tonne of RLF contains energy equivalent
to 80 per cent of that in a tonne of coal.
— Improving the factories' commercial
performance by helping control rising energy costs-protecting
the jobs of LCUK's 1,500 plus direct employees plus related dependent
jobs.
— Energy represents around 30 per cent
of LCUK's fixed production costs.
Playing a significant role
LCUK can play a significant role in using society's
and industries' wastes and by-products. Through initiatives already
underway the company anticipates that within five years it will
be using annually:
— Up to 150,000 tonnes of used tyres,
one of the UK's key problem wastes, as fuel; and
— 500,000 tonnes of industry by-products
blended to create alternative raw materials
A regulatory system more closely related to
best practice in Europe would enhance the benefits to the country
and environment, by increasing the speed with which the full time
use of the materials could be allowed. This would consequently
give greater scope to use more materials too.
REGULATION APPLIED
TO THE
UK CEMENT INDUSTRY
The Environment Agency regulates the UK cement
industry under the Integrated Pollution Control regime. This regime
is currently in the process of being replaced by the Integrated
Pollution Prevention and Control system for which all cement makers
have submitted permit applications.
The regulations governing the permitting of
alternative fuels is set out in the Agency's guidance note "The
Substitute Fuels Protocol" (SFP). The Agency developed this
from recommendations made following two House of Commons Select
Committee enquiries into the regulation of the cement industry
and alternative fuels held during the mid 1990s.
It applies only to the cement and lime processes,
while other industrial processes utilising the same materials
are not required to follow the same rigourous testing and trials
regime.
The SFP reflects the concerns and issues of
ten years ago, but has been overtaken by a depth on knowledge
and experience gained across the international cement industry,
particularly the main-land European cement industry.
LCUK contends that the SFP is now out-dated
and works against the adoption of best environmental solutions.
This is clearly illustrated by the fact that trials on the same
alternative fuel at another works requires the full testing protocol
even though the environmental benefits have been confirmed at
another works and often on the same type of kiln. The UK cement
industry continues to burn unnecessary amounts of coal when potential
fuel is landfilled or incinerated without energy recovery because
the regulatory system adopted by the Environment Agency makes
it too difficult and costly to use these wastes, despite strict-and
welcome-controls on materials handling and stack emissions.
France, Germany, Belgium and Switzerland now
spearhead best practice in terms of permitting and the use of
waste derived fuels and this is reflected in their recovery rates
of waste (hazardous and non-hazardous) for use in the cement process:
Average Use of Waste Derived Fuels in
Cement Kilns in Europe
| UK | 6 per cent
|
| European Average | 12 per cent
|
| Germany and France | 30-40 per cent
|
| Belgium | 50 per cent |
A comparison of the time it takes to secure permission to
use new fuels in the UK and France shows:
— in the UK it would take seventeen 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 fuels from a list of specified types of
waste.
The full permitting process is set out below:
Waste fuels permitting process-comparison of UK and
France
| UK | |
| Apply for and get permission for a trial using the a single new fuel
| 4 months |
| 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** |
| France | 2 months
|
| Apply for licence to use a list of "wastes" as fuel-negotiation with Prefecture
| 2 months |
| Public consultation* | 2 months
|
| Dossier on the application reviewed by committee and signed
| 2 months |
| Full time use of the fuels commences after |
6 months** |
*This aspect is at the discretion of the prefecture, depending
on the level of interest in the operation-this can be extended
**This is for the shortest possible period both processes
can take. In the UK it the final stage alone has been known to
take 14 months; in France-it usually takes between nine and 12
months.
The cement industry in the rest of Europe is actively encouraged
to play a significant role in providing solutions to hazardous
and non-hazardous waste problems. The UK and its cement industry
must not be left behind in terms of environmental, economic and
socially responsible solutions to waste problems because of out
dated regulatory systems. The Substitute Fuels Protocol must be
re-invented to reflect best practice in the permitting and use
of waste derived fuels in the cement process and it must not be
allowed to stifle the developing use of wastes as alternative
raw materials.
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