APPENDIX 2
Memorandum from the British Cement Association
EXECUTIVE SUMMARY
The UK Waste Strategy 2000 identifies the landfilling
of waste as a "missed opportunity", and states that
a significant change is needed in the way in which waste is managed.
The continuing under-utilisation of the cement industry's existing
facilities for the using waste-derived materials exacerbates this
"missed opportunity", denying this environmentally sound
waste management route to many of the growing quantities of problem
wastes within the Strategy and those resulting from EU legislation—used
tyres, oils, waste solvents, sewage sludge and packaging waste.
The use of alternative fuels in the production
of cement is well understood, and this mature technology should
now be regarded as best practice. France, Germany, and Belgium
replace 30% to 50% of their coal by alternative fuels, whereas
in the United Kingdom the rate is a mere 6%—half the European
average. In a Memorandum of Understanding signed with the cement
industry, the UK government accepted the need for a 1% year-on-year
increase in the use of alternative fuel in order meet targets
within the industry's Climate Change Levy Agreement.
This rate of increase is not being achieved
due to delays in the authorisation process for using these alternative
fuels. This situation will continue unless the out-dated extra-legislative
controls that are unique to cement and lime production are removed,
ie the Substitute Fuels Protocol, SFP. Since the introduction
of the SFP in 1997, there have been a number of important developments
that render it redundant.
The cement industry calls for an urgent review
of this procedure and its replacement by the Waste Incineration
Directive, in combination with procedures for stakeholder engagement
within the Tyres Protocol developed by the Environment Agency.
These will provide the necessary high level of control and consultation
for the use of waste-derived fuels and ensure that the environmental
and other benefits may be quickly realised.
1. BACKGROUND
1.1 The UK Waste Strategy 2000[1],
("the Strategy") identifies the landfilling of waste
as a "missed opportunity", and states that a significant
change is needed in the way in which waste is managed.
1.2 The Strategy notes that much of the
UK's waste comes from industry and commerce[2]
and that just over 1/3 is recycled or composted. However, for
hazardous waste, only 9% is recycled and only 8% has energy recovered
from it.
1.3 Use of waste-derived materials as fuels
in cement kilns results in energy recovery, which is higher up
the waste hierarchy than incineration.
1.4 The target in the strategy is to reduce
the amount of industrial and commercial waste that is landfilled
to 85% of 1998 levels by 2005.
1.5 More than 6 million tonnes of "special
waste" were disposed of in the United Kingdom in 2000[3].
This involved 200,000 producers, of which 90,000 produced special
waste regularly or in large quantities, or both[4].
The three largest streams were oils and water mixtures, construction
and demolition waste, and wastes from organic chemical processes.
1.6 The cement industry has the capacity
and capability to recover energy from waste oils and solvents.
1.7 Additional pressure on the management
of waste will result from new EU legislation, which will act in
two ways:
1.7.1 It will place restrictions and impose
additional controls on existing waste disposal routes, through
the Landfill Directive, the Waste Incineration Directive, and
the Integrated Pollution Prevention and Control Directive.
1.7.2 It will place targets on the recycling
and recovery of waste arisings through the "producer responsibility"
Directives—Packaging and Packaging Waste[5],
End-of-Life Vehicles, and Waste Electrical and Electronic Equipment.
1.8 With the implementation of the EU Landfill
Directive, the number of landfill sites accepting hazardous waste,
currently about 240, will fall to about 150 by mid-2002, and after
July 2004 may be less than 24[6].
More recent information suggests that this last figure may be
closer to 12.
1.9 In addition, the revision of the EU
Hazardous Waste List, and the bringing of the UK "special
waste" regulations into line with the EU Hazardous waste
regulations will result in the number of producers of hazardous
waste increasing threefold to a total of about 600,000[7]
and a further 200 materials being added to the Hazardous Waste
List.
1.10 Specific waste streams that will become
future problems include tyres and waste oils. Furthermore, in
2001, the UK failed to meet the legally binding target for 50%
recovery within the Packaging and Packaging Waste Directive, 94/62/EC,
thus leading to the possibility of infraction proceedings by the
European Commission.
1.10.1 Tyres: The EU Landfill Directive bans
the disposal of whole tyres to landfill by 2003, and shredded
tyres by 2006. Some 450,000 tonnes of waste tyres are generated
each year in the United Kingdom[8].
Accordingly more reuse, material recycling and energy recovery
options are needed. To this end, the use of tyres as a fuel in
cement kilns is an important outlet for waste tyres[9].
1.10.2 Waste Oils: In a 2001 report for DETR,
consultants Oakdene Hollins stated that Recovered Fuel Oil, (RFO),
currently burned by power stations and road stone drying plants
would fall within the Waste Incineration Directive or the Hazardous
Waste Incineration Directive, and anticipated that from 2006,
or possibly sooner, the majority of RFO will be directed to cement
and lime kilns.
In France and Germany, the cement industry is
already the main user of these materials.
1.10.3 Packaging Waste: In 2001, the UK failed
to meet the legally binding target for 50% recovery[10]
within the Packaging and Packaging Waste Directive, 94/62/EC,
thus leading to the possibility of infraction proceedings by the
European Commission.
1.11 The cement industry has the capacity
and capability to recover energy from tyres, recovered fuel oil
and packaging waste.
2. CEMENT MANUFACTURE
WITHIN THE
UNITED KINGDOM
2.1 Four companies—Castle Cement,
Lafarge Cement, Rugby Cement, and Buxton Lime Industries—are
responsible for the production of all the cement manufactured
within the UK. The British Cement Association, BCA, is the Trade
Association that representing the interests of these companies
in the United Kingdom and Europe.
2.2 This production accounts for over 90%
of the cement used in the UK, of which approx 52% goes to ready-mixed
concrete (includes bulk cement delivered to site), approx 27%
goes to pre-cast concrete, and approx 21% is sold as packed cement.
2.3 BCA's four member companies operate
16 cement-producing plants across the UK, nine belonging to Lafarge
Cement UK, three each to Castle Cement and Rugby Cement, and one
to Buxton Lime Industries.
2.4 The UK industry has an annual turnover
of £600 million, and provides direct employment for approx
3,500, and indirect employment for approx 15,000.
3. DRIVERS FOR
AN INCREASED
USE OF
ALTERNATIVE FUELS
IN CEMENT
KILNS
4. GOVERNMENT
4.1 The Waste Strategy 2000 states[11]
that using waste as a fuel in cement kilns can reduce carbon dioxide
and other emissions, and should be considered where the recycling
of waste is not a sensible option. The use of tyres in cement
kilns is highlighted as an example where there is the additional
reduction in emissions of the oxides of nitrogen.
4.2 The Environment Agency states "it
has been shown that burning tyres in cement kilns often has a
net environmental benefit when compared to conventional fuels,
which are usually, coal and petroleum coke. The emissions of nitrogen
oxides (a major pollutant emitted from cement kilns) have been
shown to be lower when burning tyres. Also, because tyres contain
steel, using them as a fuel reduces the amount of iron oxide that
must be added to the process"[12].
4.3 To meet the demanding target of increasing
energy efficiency within the sector by 25.6% in the period 1990
to 2010 under its UK Climate Change Agreement, co-signed with
government, the industry must increase its use of waste-derived
fuels. This was formally acknowledged by government in a Memorandum
of Understanding, paragraph 4.4.
4.4 This Memorandum of Understanding, which
defined the basis of the Climate Change Levy reduction targets,
was signed by DETR and BCA on 20 December 2000. It stated inter
alia that the targets were based upon the installation of
new plant, and on 1% year-on-year increases in the use of waste-derived
material as fuel.
4.5 Confirmation of the 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.
4.6 With such an increase, by 2010 the substitution
rate of waste-derived fuels would be at least 15%.
4.7 However, this increased use of waste-derived
materials is not currently being realised due to the lengthy authorisation
procedure imposed by the Environment Agency and bureaucratic delays
in issuing authorisations, Paragraph 12.
5. INDUSTRY
5.1 The capacity to burn waste-derived fuels
within the cement industry supplements and complements the disposal
routes available within the waste management industry.
5.2 The potential for the increased use
of alternative fuels in cement kilns was acknowledged in evidence
presented to the EFRA Select Committee by waste management companies:
"The cement industry offers additional capacity,
with the ability to process hazardous waste pre-treated to a very
controlled specification with a high calorific value. The emission
standards have been shown by the Environment Agency to give more
environmental benefits as a replacement to fossil fuels. Expansion
in this area must be encouraged"—Onyx[13]
"This option [co-incineration of waste in
cement kilns] has thus far not been incorporated explicitly into
a hazardous waste strategy for the UK, despite the potential that
it offers as a safe alternative under appropriately controlled
conditions".—SITA[14]
5.3 The cement industry's requirements for
waste are quite specific, and many waste materials arising within
the UK are not suitable for use as fuel in a cement kiln, since
they are not available in sufficient quantities within the compositional
requirements.
5.4 Waste management firms work with the
cement industry in the collection and preparation of wastes for
use as fuels.
5.5 The use of waste-derived materials as
fuels in cement kilns comes higher up the waste hierarchy than
their disposal in high temperature incinerators, being regarded
as "recovery" rather than "disposal"[15]
6. PUBLIC RESISTANCE
TO THE
INSTALLATION OF
NEW WASTE
MANAGEMENT FACILITIES
6.1 The Strategy Unit's interim discussion
paper[16]
highlights the public's perception of the potential environmental
and health hazards of waste disposal as one of the barrier to
change.
6.2 Friends of the Earth state that in view
of the extended period required by waste management companies
to recover their investment in a new incinerator[17],
long-term contracts with councils must be secured, thus reducing
the incentive to minimize waste.
6.3 The cement industry can provide a disposal
route for this growing amount of material without the requirement
to install further capacity[18].
6.4 In addition, cement kilns have the capability
of responding to fluctuations in the availability of a number
of waste streams without the need to install new capacity with
its attendant long-term operational implications.
7. EXPERIENCE
WITHIN THE
CEMENT INDUSTRY
IN THE
USE OF
WASTE-BASED
MATERIAL
8. CEMENT MANUFACTURE
8.1 Cement is the "glue" that
holds the modern built infrastructure together. It is made by
reacting limestone and clay minerals together to form calcium
silicates.
8.2 To make these minerals react it is necessary
to grind them very fine and heat them to 1450ºC in a special
rotary kiln. These temperatures, which are higher than those found
in high temperature incinerators, destroy all the organic molecules
in the fuel. There is an alkaline atmosphere in the kiln system
that automatically cleans out all the acid gases formed by the
combustion of fuels. The ash from the fuel contributes to the
raw material supply to the kiln and becomes part of the crystal
structure of the cement.
8.3 Thus, there is complete destruction
of the fuel element of the alternative fuels and there are no
acid gases formed and no ash to dispose of, making cement kilns
and ideal route provide a beneficial use of wastes.
9. WASTE DERIVED
FUELS
9.1 The cement industry has a wealth of
experience in the use of waste-derived fuels, ("alternative
fuels"), and has been using these materials since the early
1990s.
9.2 Currently the industry treats[19]
approx 50% of the used tyres arising[20],
approx 50% of used solvents (as substitute liquid fuel",
but only 10% packaging waste (paper and plastics).
9.3 This current use is half the European
average, and substantially less than many other EU Member States,
Table 1.
Table 1—Average Use of Waste-Derived
Fuels in Cement Kilns within Europe
| Country | Use of Alternative Fuel, %
|
United Kingdom[21]
| 6% |
| European Average[22]
| 12% |
| Germany & France | 30-40%
|
| Belgium | 50% |
| |
9.4 However, the industry has the potential to accept
a substantial quantity of waste-derived materials for use as fuel
within its kilns, Table 2.
Table 2—Cement Industry Use of Alternative Fuels[23]
| Fuel | 2001—Actual Use, tonnes
| Next 3-5 years—estimates of Potential Use, tonnes
|
| Waste derived liquid fuels | 110,000
| 200,000 |
| Used Tyres | 40,000 | 290,000
|
| Packaging and Packaging Waste Paper and plastic materials
| 0 | 500,000 |
| Waste Oils | 0 | 90,000 to 345,000
|
| Meat and Bone Meal, (MBM) | 0
| 140,000 |
| Processed sewage pellets, (PSP) | 0
| 40,000 |
| Total | 150,000 | 1,260,000 excluding waste oils
1,515,000 including waste oils
|
| | |
9.5 The list in Table 2 includes the principal problem
waste streams within the UK highlighted in the Strategy—used
tyres, oils and waste solvents—in addition to other waste
streams that are of growing importance—packaging, sewage
sludge and meat and bone meal.
10. ALTERNATIVE RAW
MATERIALS.
10.1 Industrial waste streams that contain high %ages
of iron, alumina, calcium or silica have been identified as a
potential source of raw materials and can replace the limestone
and clay usually used as raw materials for cement production.
10.2 When suitably conditioned these can be used as a
substitute. Avoidance of such bulk materials in landfill, reducing
the need for natural resources and the ability of the thermal
properties of the cement process to sterilize such materials represents
a major win-win-win for industry and the environment.
11. ENVIRONMENTAL BENEFITS
OF USING
WASTE-DERIVED
MATERIAL IN
CEMENT KILNS
11.1 Since the early 1990s, the UK cement industry has
been engaged in the development of techniques for the use of waste-derived
materials as fuels and as a replacement for certain raw materials.
In collaboration with its European partners, the UK cement industry
has developed expertise in this area, increasing the range of
materials that can be used safely in cement kilns, and demonstrating
the consequent environmental benefits.
11.2 In addition to mandatory controls, the UK cement
industry has introduced environmental management systems in all
of its plants, and has frequent and structured contact with stakeholders
within the local communities.
11.3 UK cement companies are committed to further environmental
improvement through the World Business Council for Sustainable
Development's Cement Sustainability Initiaitve.
11.4 The environmental benefits of using waste-derived
material in cement kilns include:
— improved environmental performance of the cement
kilns—enhancing the environment for both nearby communities
and globally;
— the movement of materials up the waste hierarchy
from disposal to energy recovery—saving landfill space and
helping deliver government waste policy;
— the conservation of fossil fuels for future generations—reducing
CO2 emissions—moving towards sustainability; and
— improved commercial performance—protecting
the jobs of employees and protecting the competitiveness of UK
industry.
11.5 A more detailed description of these improvements
is included in the EFRA Select Committee Report on Hazardous Waste[24].
12. BARRIERS TO
INCREASED USE
OF ALTERNATIVE
FUELS IN
CEMENT KILNS
12.1 The major barrier to the increased use of alternative
fuels in cement kilns, and hence the treatment of many of the
UK's problem waste streams, is the Substitute Fuels Protocol,
SFP[25].
12.2 The Substitute Fuels Protocol (SFP) regulates the
use of all fuels (other than coal, pet-coke and tyres) in cement
and lime kilns. It has no formal legislative basis, and although
it provided a framework for the treatment of these materials in
the mid-1990s.
12.3 The extended periods, (15-30 months), involved before
an authorisation is granted under the SFP, and the high associated
risk capital involved, (£1 million—£2 million),
are a disincentive to the treatment of new sources of waste streams,
particularly if the materials are not available in large quantities.
12.4 In view of technical and legislative developments:
— significant changes and improvements in the production
of cement, ie investment in new plant, improved environmental
performance of all cement plants, installation of extended continuous
monitoring, structured stakeholder consultation;
— new legislation controlling these disposal routes,
notably the IPPC Directive, the Landfill Directive, the Hazardous
Waste Incineration Directive, and the forthcoming Waste Incineration
Directive;
— the SFP has become an inappropriate and outmoded
base upon which to develop practical solutions to the UK's waste
management problems in 2002 and beyond.
12.5 A fuller description of the implications of the
SFP on the increased use of alternative fuels in cement kilns
was presented to the EFRA Select Committee on Hazardous Waste[26].
13. CONCLUSIONS AND
CALL TO
ACTION
14. To realise the cement industry's potential to contribute
to the solution to the UK's waste problem it is necessary to achieve
a paradigm shift from rigid regulatory controls that work against
environmental best practice to regulation and a system that works
in support of sustainable development.
15. European best practice holds many of the keys to
achieving sustainable development in the cement sector and in
turn the cement sector can contribute to broader sustainable development
in the UK.
16. The UK cement industry believes that for this to
be achieved:
16.1 The Substitute Fuels Protocol should be replaced
with a permitting process that reflects the considerable experience
gained across Europe in the use of waste-derived fuels.
16.2 The operation of such processes should be controlled
through the IPPC Directive and the Waste Incineration Directive,
supplemented by an extended stakeholder consultation process,
based upon the Environment Agency Protocol for burning used tyres
in cement kilns
16.3 All industrial and commercial processes using waste
materials, either as fuels or replacement raw materials, must
be controlled to the same degree of rigour.
17. Such a breakthrough in permitting processes will
assist the United Kingdom in meeting its environmental goals and
targets, by allowing the cement industry to realise its full potential
in contributing to speedy and genuine progress towards sustainable
waste.
October 2002
1
"Waste Strategy 2000 for England and Wales", Cm 4693-1
and 2, May 2000. Back
2
Reference 1, and page 4. Back
3
The term "special waste" has its origins in the UK's
Special Waste Regulations 1980, SI 1980/1709, and continues in
use following the implementation of the Hazardous Waste Directive
in 1996. Back
4
House of Commons, Environment, Food and Rural Affairs Committee,
"Hazardous Waste", Eighth Report of Session 2001-01,
HC 919, page 6, para 5. Back
5
Strictly speaking, the objective the Packaging and Packaging
Waste Directive is harmonisation, although its modus operandi
bears close similarities to the ELV and WEEE Directives. Back
6
Reference 4, Page Ev 31. Back
7
Ihid, para 140. Back
8
See reference 20. Back
9
"Tyres Protocol for use on cement kilns: A supplementary
note to the Substitute Fuels Protocol", Environment Agency
November 2001. Back
10
The level of recovery reached was 48%. Back
11
Reference 1, paragraphs 2, 19 and 2.21, page 18. Back
12
"Tyres Protocol for use on cement kilns: A supplementary
note to the Substitute Fuels Protocol", Environment Agency,
November 2001. Back
13
Appendix 3, Reference 4. Back
14
Appendix 6, Reference 4. Back
15
Opinion of Advocate General Jacobs in case C228/00, Commission
of the European Communities v Federal Republic of Germany,
delivered on 26 September 2002. Back
16
"Waste: An interim discussion paper", Strategy Unit,
13 September 2002. Back
17
A period of 15-25 years is quoted by Friends of the Earth. Source:
Friends of the Earth web site http://www.foe.co.uk/campaigns/waste/issues/incineration/. Back
18
In 1997, high temperature incinerators disposed of 126,978 tonnes
of hazardous waste, whilst the cement industry burned 51,895 tonnes
(and imported 3,580 tonnes). In 1999, high temperature incincerators
disposed of 117,996 tonnes of hazardous waste, whilst the cement
industry burned 117,937 (& imported 8,209 tonnes). Written
Answers, 18 December 2000, Cols I 3W. Back
19
Reference 4, Page Ev.105. But see reference 20. Back
20
This figure was presented to the EFRA Committee, and was based
upon a total tonnage of tyre arising of 427 k tonnes, a figure
on the Environment Agency web page, "The impact of Tyres
on the Environment", 10 May 2002. However, suppliers of used
tyres to the cement industry have suggested subsequently that
they consider this total to be too high. Back
21
House of Commons Hansard, 17 Dec 2001, col 126W. Back
22
House of Commons Hansard, 17 Dec 2001, col 126W. Back
23
Reference 4, page Ev 117. Back
24
Page Ev 121, Reference 4. Back
25
Substitute Fucis Protocol for Use on Cement and Lime Kilns, Environment
Agency. Back
26
Substitute Fucis Protocol for Use on Cement and Lime Kilns, Environment
Agency. Back
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