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

Memorandum submitted by Brightstar Environmental


  As a recent entrant into the UK waste industry, and as owner and operator of emerging technology, Brightstar Environmental (Brightstar) is well placed to comment on the development of future waste management policy in the UK.

  This submission outlines the technology developed by Brightstar known as Solid Waste and Energy Recycling Facility (SWERFR) which provides a new solution to waste management. The submission sets out how the SWERFR technology using advanced thermal processing technology can assist in moving waste management up the waste hierarchy, and also highlights the issues that need to be overcome if this is to be achieved. In summary these issues are:

    —  The increasing need to ensure flexibility in waste management systems in the future.

    —  That an integrated waste management system has to be a mix of options and not just those obsessively presented by certain groups.

    —  Strong and positive decisions must be made by politicians at local and national level on waste management which are notoriously unpopular otherwise progress is likely to be stifled.

    —  Innovation must not be hampered by over regulation and stringent definitions.

    —  Clear definitions and statements are needed by government and regulators to ensure that that new technology such as advanced thermal processing is correctly understood and perceived.

    —  It is essential that government carry out independent studies into waste disposal options, so that the health impacts and Life Cycle Assessment (LCA) of all options can be considered in a balanced way.

    —  A more regional focus to waste management is needed, which combines responsibilities to deliver a real integrated approach and remove the barriers between Waste Collection and Waste Disposal Authorities.

    —  Procurement appears to counter against emerging technology and Government must create the conditions, which allows new entrants to enter the market and compete for waste on a level playing field.

    —  The problems of the planning system must be tackled head on otherwise the industry's ability to deliver the waste management targets is severely at risk.

    —  Waste management regulation must be consistent and flexible to ensure that new technology is encouraged.

    —  Long term renewable energy support is needed to make new qualifying waste management technologies attractive for long term investment.


  1.1  Brightstar Environmental (Brightstar) is a subsidiary of Energy Developments Limited (EDL), an Australian listed company, who are a global renewable energy generation company. EDL has been operational in the UK for the past six years developing projects under the Non Fossil Fuel Obligation (NFFO).

  1.2  Brightstar is the owner and operator of a new resource recovery technology known as Solid Waste and Energy Recycling Facility (SWERFR). SWERFR incorporates an Advanced Conversion Technology (ACT) as defined in the Renewables Obligation based on pyrolysis and gasification. Its front end separation process removes the recyclable components from the waste stream prior to thermal treatment, which results in the conversion of only the residual organic fraction or renewable biomass into energy.

  1.3  Through EDL, Brightstar Environmental holds 155MW of NFFO five MIW contracts and is seeking to develop these and other projects in the UK. Brightstar's has already secured Planning Permission for a SWERFR in Derby, where the company holds a contract to process 50,000 tpa of MSW with Derby City Council. Brightstar has also been selected with Brett Waste Management to build a SWERF in Canterbury under contract with Kent County Council for up to 100,000 tpa of MSW.


  2.1  SWERFR is designed to maximise value of resources in the waste stream resulting in high levels of recycling and recovery. As currently designed SWERFR will divert approximately 80% of MSW from landfill and with ongoing development programmes it is hoped to eventually increase this level towards 100%.

  2.2  The process incorporates intensive front-end separation of the incoming waste for the removal of recyclable materials with only the residual non recyclable organic fraction being converted into energy. Hence the technology can deal with waste which has either been subject to a high degree of source separation or waste which is completely unsorted.

  2.3  The SWERFR technology has been developed over a ten year period and passed through pilot and demonstration scale testing. The first commercial plant, which has capacity for processing 50,000 tonnes per annum, is currently in the final stages of commissioning in Wollongong in New South Wales, Australia, where Brightstar has a long term waste processing agreement with the City Council. The plant will have an ultimate capacity of over 150,000 tonnes of MSW.

  2.4  A brief description of the SWERFR technology is included as an annex to this submission.


  3.1  Before addressing the issues of the waste hierarchy and how SWERFR could assist in meeting these objectives, we believe that the fundamental issue in developing a future waste management strategy is the need for maximum flexibility. As is argued later, following a path of kerbside recycling and composting is unlikely to deliver all of the objectives on their own.

  3.2  Developing a long term waste management service will no doubt require significant capital investment and therefore long term contracts are usually needed for such investment to proceed. But it is impossible to predict how the quality and quantity of waste will vary over the next 10 to 20 years with the uncertainty of waste growth and to what extent waste reduction and recycling programmes will have an effect. This presents a real dilemma in developing long term strategies and it is often difficult to strike a balance, which safeguards not only the interests of the service provider but also provides the flexibility to deliver the required performance and service over the long term. It is therefore fundamental to ensure that the options selected have the flexibility to enable changes in waste quantity and composition to be accommodated together with a change in market forces without threatening the viability of the waste management service.

  3.3  It is assumed that any long term fully integrated service will require facilities to handle residual waste if recovery levels are to be maximised such as energy generation or biological stabilisation. One of the major criticisms in the past of large scale facilities is the possible disincentive to waste minimisation and recycling programmes which may result due to the demand of the plant to achieve its installed processing capacity to enable the project to be financially bankable.

  3.4  The modular nature of SWERF provides significant flexibility with the ability to deliver viable facilities with a capacity from as little as 50,000 tonnes per annum increasing in increments of 50,000 tonnes per annum. As such the plant is easily expandable if processing demand increases and likewise modules can be removed to reduce capacity if waste arisings fall accordingly.

  3.5  Brightstar's first UK project is in Derby where planning consent has been received for a four module plant with 200,000 tonnes of capacity per annum. There is no requirement for the plant to be built to this capacity but the flexibility exists is to do so if demand requires. It is likely that the plant will be initially sized at 50,000 tonnes per annum until the long term waste management needs of the area can be established together with the success or otherwise of local recycling and waste minimisation programmes. It is hoped to commence the construction of the Derby plant later this year.

  3.6  The following seeks to address the issues of the waste hierarchy and how SWERF could assist meeting the objectives and in delivery of an integrated waste management strategy.


  4.1  It is likely that the promotion of waste minimisation through community education will be a key factor to stem the continued increase in waste production and encourage the participation and use of bring and kerbside recycling facilities.

  4.2  It is acknowledged that criticism has been commonly aimed at the providers of "end of pipe" solutions that their commercial interests are unlikely to be aligned with the concept of waste minimisation.

  4.3  Brightstar acknowledges that certain materials will only command a recycling value if they are of a high quality, which can only be achieved by separate collection. Education will therefore be key to achieving recycling targets. Brightstar's modular technology provides the flexibility to accommodate recycling and waste reduction programmes and this has been demonstrated with our first project in Wollongong with the City Council.


  5.1  It is recognised that recycling is fundamental in any future waste management strategy with the need to increase recycling from the relatively low levels that currently exist. Kerbside collection will no doubt play a major role in delivering future recycling however there appears to be a dogmatic approach in some areas of government and NGO's that kerbside is the only way to recycle and any other route is bad. It is important not to allow the ideological beliefs over ride common sense and pragmatism.

  5.2  We agree that kerb side collection provides high quality recyclables, but evidence to date suggests that:

    —  the economic costs for kerb side collection schemes are often significantly higher than current disposal methods;

    —  participation rates are very sensitive to demographical and geographical effects;

    —  separate collection systems are not necessarily the correct environmental approach; and

    —  a significant cultural shift and change in attitude are required.

  5.3  Recycling is also market dependent and evidence to date suggests that a number of schemes have failed financially because of the insecurity of the markets for recyclates.

  5.4  Whatever the scheme and education programme, kerbside collection certainly in the short to medium term will fall short of meeting the targets, and it is therefore crucial to encourage technologies which provide downstream processing to capture those materials which are missed and end up in the residual waste stream.

  5.5  However as mentioned there appears to be a belief by some that any "end of pipe" solution will have a detrimental effect on local recycling initiatives. We believe that this is a naïve view and biased against the pragmatic need for residual waste processing capacity. This view is certainly not supported when looking at the example of other European countries where high levels of recycling have been achieved alongside large processing plants (often incineration). Integrated waste management is about a mix of options that will achieve the desired goals.

  5.6  SWERFR is highly compatible with current recycling programs by removing those materials from the waste stream either because they are missed or because people fail to participate. Even in communities that enthusiastically recycle, large amounts of residual waste are normally sent to landfill or incineration.

  5.7  In Wollongong, Australia, Brightstar is currently commissioning a SWERFR in conjunction with a separate kerbside collection programme that incorporate separate bins for the collection of dry recyclables and organic waste. Even though this kerbside programme represents one of the most successful in Australia, SWERFR( is still recovering substantial quantities of recyclables from the residual bin from those households who either do not wish to or are unable to participate. As an example, the level of metal recovery through the SWERFR has increased by nearly 300% on levels recovered through the dry recyclables collection. As a result the City Council is considering how to fully integrate its kerbside programme with SWERRF to maximise the recovery of materials and quality recyclates and minimise cost and environmental burden. Here as should be the case in all areas, an integrated strategy is being developed using the options available—it's about using a mix of options, not one.

  5.8  Finally the issue of markets for recyclables is crucial to the success of any scheme. As mentioned above the viability of kerbside collection is highly market dependent on the ability to sell the materials collected. The SWERFR process provides inherent flexibility to take account of these market fluctuations. SWERFR maximises the recovery of materials for recycling including glass, metals and plastics. Where traditional recycling routes are not available for materials, such as plastics and non-recyclable residual organics, its energy value would be utilised by conversion to electricity with a guaranteed end market. In addition SWERFR can provide additional flexibility where contaminated or rejected materials from a MRF can be passed through the SWERF to recover remaining resources and further increase the overall recycling performance.

  5.9  However whilst the above flexibility should be seen as a sensible approach to recycling, it is unfortunately seen as a threat to those obsessively pushing kerbside collection. These groups continue to skew what should be a sensible and objective debate—that is that all the options that need to be considered to provide the most economically as well as environmentally sustainable solution.


  5.10  Whilst composting will without doubt play a fundamental part in recycling, success to date has been limited due to the markets available and the inconsistency of material that can be produced on a long term basis. Added to that the fears of BSE and Foot and Mouth disease has led to more stringent regulation on the methods by which waste derived compost can be produced and used. As a result, it is becoming apparent that low cost windrow composting will not be an environmentally viable solution and more intensive, and more expensive technologies are likely to be required. Even so, the issues of market demand and penetration will still be a major factor of success.

  5.11  The potential environmental and commercial problems in the production of waste derived compost has lead Brightstar to develop alternative products from the organic fraction of waste. Brightstar is developing these products as a major step forward in the value adding process with production being "market driven", not "waste driven".

  5.12  Brightstar proposes to take a portion of the sterilised autoclaved pulp produced during the SWERFR front end process for manufacture of various products, ranging from soil improvers to fertiliser, rather than energy production. This process may also use some of the residues from the plant. Again like recycling, being integrated within the SWERFR process provides flexibility in allowing the plant's outputs to varied to overcome market fluctuations and avoid the need to stockpile product.

  5.13  However as with recycling, composting and organic waste treatment there is a necessity to ensure that "composting" in its traditional sense is not seen as the only solution. There has to be more flexibility in how these targets are achieved, and care must be taken not to stifle innovative processing methods by dogmatic views and by over regulation and stringent definitions.

  5.14  To summarise, our belief is that simply adopting kerbside separation and a reliance on composting will not deliver recycling targets on their own. Recycling markets must be stimulated and more flexible resource recovery systems encouraged and implemented that cater for market fluctuations. Too often recycling programmes have failed due to the collapse of a particular market. Whilst steps are being taken through the likes of Wrap to help overcome this, there is a risk that as more material is produced then an over supply may either cause some schemes to collapse or significantly increase costs as material has to be sent father afield for reprocessing. Germany is a good example of this, where high levels of recycling have been achieved but at a significant cost.


  6.1  To some "thermal treatment" just means "incineration", and with it goes the emotive arguments put forward by the opponents, of unacceptable emissions and impacts on health. These are in the main philosophically driven and based on the experience of old incinerators closed down several years ago, rather than the new breed of plants which have seen a dramatic improvement in standards. However this does not help the opponent's cause and allow us to move into an objective debate of the options available. As a result incineration has become a political "hot potato" which in some parts will not be tolerated at any cost.

  6.2  All waste disposal methods have health impacts. There have been a significant number of reports commissioned by industry or environmental groups to examine health risks of various waste disposal options. Unfortunately many of these reports lack relevant data or are conducted with pre-determined objectives. In addition, very little work has been done on the real health impact of all waste management options.

  6.3  It is essential that government commit funding to independent studies into waste disposal options, so that health impacts of all options can be considered in a balanced way. In addition, Life Cycle Assessment (LCA) must play a greater role for regulators and decision makers, but to date the information available is inadequate. The "Wisard" LCA software tool developed by the Environment Agency still appears to lack the necessary information of all the options available and as such appears to carry little influence.

  6.4  Despite ideological opposition to thermal processing by some groups, advanced thermal conversion technologies are being seen by local authorities and others as being an acceptable alternative to traditional thermal technology due to its efficiency, size and perceived environmental benefit. SWERFR includes the use of advanced thermal processing based on pyrolysis and gasification and has significant advantage over traditional combustion technology. These include:

    —  Front end resource recovery maximises recycling and enables the removal of hazardous materials with the non recyclable organic fraction only being thermally reformed into a clean synthetic fuel, ie waste is not burnt;

    —  The direct firing of syngas in high efficiency spark ignition engines to generate electricity—this provides significantly higher efficiency and electrical output than heat recovery through conventional combustion plant;

    —  The energy generated is eligible for renewable obligation certificates

    —  The modular configuration allows for smaller community-sized facilities, and flexibility to increase or decrease plant capacity; and,

    —  Modular advanced thermal processing and power generation provides for insignificant visual impact.

  6.5  These benefits are one reason why Brightstar was selected for projects in Derby and Kent. However whilst the environmental benefits of SWERFR are extremely attractive to some, the environmental groups continue to be extremely unhelpful and opposed to such technology. Whether this is due to their philosophical dislike to "end of pipe" solutions or their obsession with thermal processing, they continue to scaremonger by arguing that SWERFR is an incinerator and therefore play on the public's emotions of a large building with a large chimney, burning waste to produce unacceptable emissions and associated health impacts.

  6.6  This not surprisingly results in the generation of significant opposition by a poorly informed community who distrust the claims of the developer in favour of environmental and community backed opposition groups. The opponent's arguments that SWERFR is an "incineration" process are unfortunately not helped by a lack of clarification from government and regulators.

  6.7  Advanced thermal conversion is totally different to incineration in its traditional sense. Waste is not burned and this results in a number of benefits as listed above. Hence the public's perception of incineration when applied to advanced thermal processing is totally unjust. Unless government or regulators provide a strong lead on this to provide independent clarity on the differences in technologies, then the advantages of new thermal processing will be lost and the technology could go the same way as incineration and be discriminated against. This is a REAL threat.

  Comment: as a single company submission we will be discounted to an extent anyway—I would leave it in—at least it will be on record

  6.8  All waste disposal options produce emissions which are released into the environment in some way even when waste is simply buried, or turned into compost. It is the need for sound independent information that is crucial to enable people to make their own objective assessment of the options available.

  6.9  In our view SWERFR provides a means of dealing with waste with a low impact on the environment. Rather than have to rely on complex Air Pollution Control (APC) systems to remove or reduce emissions SWERFR can achieve current environmental limits with simple gas clean up technology without generating APC residues. That is not to say that SWERFR does not produce any emissions such as dioxins. Dioxins do occur in the engine exhaust but at levels that are significantly below the new EU emission limits. Dioxins are produced by many industrial processes but again the lack of independent objective assessment of this issue further hinder rational discussion in non-technical circles.


  7.1  Landfill continues to be part of the waste hierarchy and will continue to provide the long term backup for any waste processing facility. Whilst SWERFR is already diverting significant levels of waste away from landfill, residues of up to 20% of the incoming waste will for the immediate term need to be disposed to landfill—the residues from SWERFR are not classed as hazardous and can therefore be taken to non hazardous landfill.

  7.2  Brightstar's objective is to minimise the levels of residue requiring landfill and several development programmes are in place to develop new products and markets using this material. The long term objective is to divert close to 100% of the waste SWERFR receives for processing. However even when this level is achieved landfill may still be required to handle waste which SWERFR is unable to process and to provide a back up facility should SWERFR be out of operation due to planned or unplanned maintenance.

Other issues that need to be addressed in order to encourage innovative solutions to help move up the waste hierarchy


  8.1  A structure with continuity is required to effectively manage waste in the UK. Unfortunately the current system with multi tiered authorities does not create the correct regime for integrated waste management, where the responsibilities and budgets for waste collection and recycling usually sit with a different authority from that which has responsibility for disposal. It is even more illogical that both tiers have targets to achieve for recycling whilst they may not necessarily work in tandem.

  8.2  It is our view that the whole organisation and responsibility of waste management needs review. A more regional focus appears to be a more logical solution, which combines responsibilities to deliver a real integrated approach to waste management to allow the optimisation of the collection of resources and remove the barriers between Waste Collection and Waste Disposal Authorities.


  9.1  In order to be viable, large capital projects such as waste management facilities need secure waste management contracts generally awarded by local authorities. In awarding contracts local authorities will generally seek a risk free position and are therefore likely to source robust technology which has generally been proven in the UK, and is able to guarantee performance.

  9.2  This is one of the key underlying difficulties as a new entrant into the waste market. Local authorities find it difficult to contract their Municipal Solid Waste (MSW) for innovative or emerging technologies due to the perceived underlying technology risks. Their responsibility is to secure the disposal or treatment of waste on a continual basis, and as such can be unwilling to take up technology without a proven track record even though they may have no direct financial risk.

  9.3  To counteract the above, it is common for local authorities to require significant guarantees and warrantees on performance. Such conditions are often unaccommodating of new technologies, and for smaller companies these are generally impossible to provide. Having invested heavily to develop new technology, such further onerous requirements will be seen as disincentives to developers, and thus discourage future investment in emerging technologies.

  9.4  If Government intends to attract new technology into the UK, then they must create the conditions, which allows new entrants to enter the market and compete for waste on a level playing field. Emerging technologies will not be commercialised in an environment where local authorities wish to obtain a risk-free position. The most likely outcome in this scenario is the entrenchment of the status quo that we are trying to supersede. The Private Finance Initiative just reinforces this difficulty.

  9.5  To help overcome these difficulties there is a necessity for more technology demonstration projects. To date government incentives have lacked the flexibility to accommodate new processes like ACT, which has led local authorities to favour established disposal methods like incineration.


  10.1  This remains one of the fundamental hurdles to be overcome by developers of all waste management solutions. Planning permission is becoming an increasingly problematic, controversial and highly political area, where numerous applications experience significant and unreasonable delays and often failure. Without doubt developers will be less inclined to submit proposals unless there is a good chance of success. In reality this means fewer applications resulting in fewer projects.

  10.2  This area of waste management appears to be one of the most contentious, brought about primarily through opposition to landfill and incineration, which now seems to extend to cover all proposals which involve waste. If the Government is serious about achieving a waste strategy and national waste targets, then it must become more proactive in the decision making process. The issue of central determination over local control must be tackled head on otherwise the planning system will gradually swamp and cripple the industry.


  11.1  A further major concern lies with the permitting or licensing of new facilities. This is particularly relevant with ACT projects which rely on waste for its fuel supply and as such are permitted by the Environment Agency under the new Integrated Pollution and Prevention Control (IPPC) licensing system.

  11.2  It appears that this in an area where there is a real lack of continuity across government departments. Whilst there is an apparent wish by government to see the encouragement of new technology, there appears to be a lack of flexibility in the interpretation and enforcement of national and European legislation. This is at odds with most other EU states where a more flexible and accommodating licensing regime is implemented to encourage new technology. This is becoming a serious barrier to progress.

  11.3  Advanced thermal processing technology such as SWERFR is regulated under the EU Waste Incineration Directive (WID). It is our view that WID was specifically developed to apply to incineration technology—that is the combustion of solid waste, and as such is not appropriate for all thermal technologies.

  11.4  SWERFR uses pyrolysis and gasification to produce a clean synthetic fuel (syngas) suitable for direct use in spark ignition engines to generate electricity. The use of spark ignition engines results in far greater energy efficiency than through a conventional steam cycle, which has been adopted method of energy generation for traditional combustion technology.

  11.5  In reality, it is acknowledged that WID was written to cover "incineration" or primarily the combustion of waste or gas, not the generation of electricity directly in an engine. However as currently determined, the legislation sets out the case that the prime mover (in our case a spark ignition engine) is in fact the "incineration" plant. As such WID is entirely inappropriate to this technology.

  11.6  Our prime mover selection has been based on the ability to gain far greater energy efficiency, however WID does not allow for this. It is our view that the legislation needs to be clarified to allow flexibility using Best Available Technology to determine the performance of the technology, and as such specifically consider the environmental advantages or otherwise of each case.


  12.1  Like many in the waste and renewable energy sectors, Brightstar warmly welcomed the inclusion of ACT in the Renewables Obligation (RO), which should greatly assist the encouragement of ACT projects. However there is still a lack of long term security for the sale of energy from ACT. Whilst we understand that the Government has no plans to reduce the scale of the RO, without further guarantees of how long support under the RO will be available, investor confidence in ACT projects may suffer.

  12.2  It is worth noting that incineration had the benefit of the support process under NFFO which ran for several years providing secure contracts for 15 years. Until such time as ACT can be considered to have achieved the same status, it should remain eligible for support under the RO, and using the example of incineration under NFFO, 15 to 20 years should be the minimum term for support.

Bright star Environmental

6 January 2003


Solid Waste and Energy Recycling Facility (SWERF)

  SWERF is made up of three technology components—waste pre-treatment and separation, advanced thermal conversion and electricity generation. A fourth component—the production of organic products is currently being developed.


  Waste arriving at the plant is unloaded into the waste storage building via a chute. The building is enclosed to ensure no escape of dust or litter, and is kept under slight negative pressure to prevent odour release to the external environment. Within the waste storage building the material is visually inspected and unsuitable wastes are removed.

  From the waste storage building, waste is fed into the front end sorting process where the incoming material is first sterilised in a rotating steam autoclave at temperatures between 130° and 150°. The resulting pulp is then separated into a number of resource streams, using separation techniques comprising of a series of trommels, screens, and magnets. Ferrous metals and aluminium are recovered for recycling. Depending on the markets for plastics, these are either recovered for recycling or are size reduced and added to the pulp stream for conversion to electricity.

  At this stage the organic pulp, which contains all biomass material, and film plastics, also contains small pieces of glass and sand/dirt. The organic pulp is treated in a wet separation process to remove the glass, sand and grit prior to being mechanically dewatered. The material is then dried using pressurised superheated steam generated by utilising waste heat from the engine exhausts, to produce a dense, stable organic pulp suitable for medium to long term storage in silos. The glass sand and grit fraction, and other inorganic materials are sorted and processed for reuse.

  Odorous process emissions are collected in an extraction system and destroyed in the engine combustion process.


  The organic pulp is fed to the Advanced Thermal Conversion (ATC) plant which reforms the solid material into synthetic gas (syngas) for use in the engines.

  Brightstar's ATC technology is a gasification process which uses indirect heat in the absence of oxygen to convert solid materials containing carbon into a syngas mixture of predominantly methane, hydrogen, carbon monoxide and carbon dioxide. This syngas can be utilised in high efficiency spark ignition engines to generate electricity for sale to the local electrical grid.

  A lock hopper and macerator arrangement is used on each gasifier to introduce dried organic pulp into the gasification loop. A compressor circulates clean syngas to the lockhopper discharge where the organic material is entrained and conveyed into the gasification process.

  The gasifier module comprises a series of high temperature nickel alloy pipe coils which transport the material through a range of temperature. The external energy for this heating process is provided by burners which utilise processed syngas as fuel.

  During the process the waste material is converted into gaseous matter and char (ash and unreformed carbon). The hot gases are partially cooled in the coils by preheating the incoming materials before exiting the gasifier. The hot syngas from the gasifier module is cooled and cleaned, and delivered to the power plant for the generation of electricity using modular spark ignition engines. The char residue is removed to landfill.

  Waste water which is produced during the process and in cleaning the syngas prior to power generation is processed through an on site water treatment plant to be utilized in plant cooling applications.


  From results at the Wollongong SWERFR in Australia, the resource streams recovered from 200 tonnes of 40% moisture household waste are provided below. This is on the basis of local waste composition in Australia, but it is not expected that this would be significantly different to typical waste composition found in the UK:

    —  100 bone dry tonnes of energy-rich organic pulp comprising putrescible food waste, paper and cardboard plastic film, green and garden waste which becomes the feedstock for gasifiers or potentially bio-fertiliser production;

    —  two tonnes mixed semi-rigid plastic containers comprising mainly PET;

    —  six tonnes +/- 15% of aluminium and ferrous metals (to be recycled via a separate recycling contract);

    —  16 tonnes +/- 15% of co-mingled glass cullet and dirt removed from the pulp stream (to be recycled via a separate recycling contract).

    —  25 tonnes of gasifier solid residue comprising mineral ash and elemental carbon ie the non-reformed part of the 100 tonnes of organic feedstock;

    —  15 tonnes of miscellaneous oversize/unsuitable wastes as residue

    —  140 MWh +/- 10% of electricity.

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