Memorandum submitted by the British Cement
Association (BCA) (X16)
EXECUTIVE SUMMARY
1. The cement sector has encountered difficulties
similar to those experienced by most parts of UK industry in relation
to the introduction of the Landfill Directive, viz.
1.1 Uncertainty regarding the waste acceptance
criteria, (WAC).
1.2 Confusion as to whether on-site landfill
was to be covered within the IPPC regulations and permits, or
whether a separate landfill permit was required.
1.3 Delays, lack of communication, and absence
of pragmatism in the process of applying for landfill permits.
2. The British Cement Association and its
members believe that important components in the provision of
new waste treatment facilities are:
2.1 certainty in the scope and applicability
of new regulations, particularly in the UK implementation of EU
provisions, eg the Waste Acceptance Criteria;
2.2 certainty in the ambit of the existing
EU definition of "waste", the associated definitions
of "disposal", "recovery", and "recycling",
and the relative importance of the waste treatment options within
the waste hierarchy;
2.3 securing funding for new plant in the
United Kingdom from UK and foreign-controlled parent companies;
2.4 obtaining planning permission; and
2.5 obtaining operating permits from the
regulatory authorities.
3. A major obstacle to the installation
of new waste treatment facilities is a poor public perception
of waste treatment, on the grounds of perceived health and environmental
problems. The cement industry believes that both government and
industry have an important part to play in allaying these concerns,
and it is engaged in a wide number of to stakeholder engagement
initiatives.
4. The next two to three years will br critical,
for although the Landfill Directive and new hazardous waste provisions
will effective, the waste industry will not have installed the
requisite treatment capacity. It is therefore of the greatest
importance that the EA's proposed modifications to the Substitute
Fuels Protocol are introduced as soon as possible, to enable the
installed capacity with the cement industry to be employed.
BACKGROUND
1. Wastes generated by the UK Cement Industry
The British Cement Association is the trade
and research organisation that represents the interests of the
United Kingdom's cement industry in its relations with Her Majesty's
Government, the European Union and relevant organisations in the
United Kingdom. The members of the BCA (Buxton Lime Industries,
Castle Cement, Lafarge Cement UK and Rugby Cement) are the major
domestic manufacturers of Portland Cement producing over 90% of
the cement sold in the UK.
2. A relatively small quantity of waste
is generated in the cement manufacturing process. The major waste
arisings are cement kiln dust, CKD, or by-pass dust, BPD. Kiln
dusts from the cement manufacturing process are historically referred
to as either cement kiln dust or by-pass dust, depending on the
type of process.
3. Cement kiln dust is classified as non-hazardous
waste, whereas by-pass dust is classified as hazardous waste on
account of its higher content of calcium oxide, which categorizes
it as an irritant.
4. Where feasible, CKD and BPD are recovered
within the manufacturing process. If this is not possible due
to quality or other constraints, then alternative uses are sought.
The landfill of these dusts is used as a last resort.
5. The industry is proactive in reducing
the quantity of CKD and BPD sent to landfill. In 1998 a total
of 289,207 tonnes of these dusts were disposed of off-site by
landfill, whereas in 2002, the figure was 110,069 tonnes.
6. Under the Environment Agency Sector Plan
for the cement industry[48]
the sector will set targets to further reduce the quantity of
CKD, BPD and other dust sent to landfill[49]
7. The cement sector has encountered difficulties
similar to those experienced by most parts of UK industry as a
consequence of the introduction of the Landfill Directive, viz.
7.1 Uncertainty regarding the waste acceptance
criteria, (WAC).
7.2 Confusion as to whether on-site landfill
was to be covered within the IPPC regulations and permits, or
whether a separate landfill permit was required.
7.3 Delays, lack of communication and absence
of pragmatism in the process of applying for landfill permits,
which has resulted in an additional, unnecessary workload for
all concerned.
8. Wastes Recovered by the UK Cement Industry
BCA has presented evidence on the recovery of
waste by the UK cement industry to this and other Select Committees[50],[51]
, [52],
[53]and
to the Hazardous Waste Forum. Annex I updates and supplements
this earlier information.
9. Waste-derived fuels. In the early
1990s cement manufacturers in the UK were among the first to burn
waste-derived fuels, but as a consequence of the extra statutory
Substitute Fuels Protocol, the rate of the substitution has fallen
behind those in other European countries[54]
10. From a level of 3% substitution in 1990,
the average rate in Europe rose sharply to 12.2% in 2001, saving
3.5 million tonnes of coal and resulting in significant reduction
in stack emissions. However, in almost half of European countries,
cement works burn extremely high levels of waste-derived fuel:
>40%, Switzerland, Austria.
>30%, Belgium, France, Germany, Norway, (Sweden
29%).
11. In 2001, 4,370,000 tonnes of waste were
recovered in European cement kilns. Of these, 20% were liquid,
80% were solid, and about one-third were hazardous wastes.
12. In addition to the many different categories
of waste-derived fuel recovered on a country basis—14 solid
fuels and three liquids—in Europe it is common practice
to burn four or more of these materials [up to nine at the Obourg
plant] at a given kiln.
13. In contrast to European practice, the
level of substitution within the United Kingdom is only 7%, and
the majority of plants using waste-derived fuels are permitted
to use no more than two.
14. Waste-derived substitute raw materials.
Waste-derived materials are also used as a substitute for
other cement-making minerals, and in 2001 the European cement
industry achieved a direct saving of 11.5% of its natural mineral
raw materials usage, which is equivalent to almost 35 million
tonnes of these materials.
15. Other EU countries have a lower reliance
on landfill but a higher use of both co-incineration by cement
kilns using alternative fuels and high temperature incineration.
Cement kilns, therefore, have a very positive role to play within
the UK's waste infrastructure.
16. These advantages cannot be fully realized
due to substantial inertia within the regulatory regime, principally
through the Substitute Fuels Protocol, (SFP), see section 24 &
seq. Innovation is stifled and the inherent flexibility
of the cement making process is thereby limited.
17. To realise the industry's potential,
a more efficient process for granting PPC authorizations for using
waste-derived fuels is required urgently, replacing the voluntary,
extra-statutory SFP with a permitting process that reflects the
considerable experience gained across Europe.
THE FUTURE
CONTRIBUTION OF
THE UK CEMENT
INDUSTRY TO
WASTE MANAGEMENT
IN THE
UK
18. The implementation of the Landfill Directive
and the recent modifications to the regulation of hazardous wastes
are changing the management of waste within the United Kingdom,
placing more rigorous controls on those materials that continue
to be disposed of by landfill, and requiring the development of
a modern waste infrastructure in which a much greater emphasis
is places upon recovery and recycling.
19. With its large potential capacity for
waste-derived fuels, Annex I, and its growing use of waste-replacements
for traditional raw materials, the UK cement industry has an important
role to play in the development of this new infrastructure.
20. In its report The State of the Nation—2004,
the Institute of Civil Engineers estimates that up to 2,300 new
waste treatment facilities must be operational by 2020 to avoid
a major crisis involving millions of tonnes of untreated waste.
21. The British Cement Association and its
members believe that important components in the provision of
new facilities are:
21.1 certainty in the scope and applicability
of new regulations, particularly in the UK implementation of EU
provisions, eg the Waste Acceptance Criteria;
21.2 certainty in the ambit of the existing
EU definition of "waste", the associated definitions
of "disposal", "recovery", and "recycling",
and the relative importance of the waste treatment options within
the waste hierarchy;
21.3 securing funding for new plant in the
United Kingdom from UK and foreign-controlled parent companies;
21.4 obtaining planning permission; and
21.5 obtaining operating permits from the
regulatory authorities.
22. With regard to the developing the required
infrastructure within the UK to treat wastes, the cement industry
is in a strong position, viz:
22.1 a substantial part of the cement industry's
major capital expenditure is completed and the requisite planning
permissions have been obtained; and
22.2 operations within the cement industry
currently fall within the IPPC regime, with its strict requirements
on the measurement and reporting of emissions.
Consequently, the introduction of the Waste Incineration
Directive in 2005 is likely to be less problematic, compared for
example with the burning of waste oils and meat and bone meal,
(MBM), by the power industry and roadstone producers.
23. The next two to three years will critical,
for although the Landfill Directive and new hazardous waste provisions
will effective, the waste industry will not have installed the
requisite treatment capacity. It is therefore of the greatest
importance that the EA's proposed modifications to the Substitute
Fuels Protocol are introduced as soon as possible, to enable the
installed capacity with the cement industry to be employed.
THE SUBSTITUTE
FUELS PROTOCOL,
SFP
24. The major barrier to realizing the industry's
potential waste treatment capacity is obtaining permission from
the Environment Agency for burning waste-derived fuels. This falls
within the voluntary, non-statutory Substitute Fuels Protocol,
(SFP), a measure about which the British Cement Association has
informed this and other Select Committees on a number of occasions50,
51, 52, 53.
25. In its submission to this Committee's
inquiry into Hazardous Waste, BCA requested that the Environment
Agency "review the operation of the Substitute Fuels Protocol
and speed up the adoption of alternative fuels (by the cement
industry)". The Committee concluded[55]
The Committee believes that the primary consideration
in allowing waste to be incinerated should be the overall environmental
impact of doing so. It remains for the Environment Agency to decide
how best to ensure that the environmental impact of waste management
is minimized within the current regulatory regime.
26. The determining role of the Environment
Agency in relation to the current proposed modification of the
SFP has been further emphasized by the Prime Minister, who stated
in response to a recent PMQ[56]
The Environment Agency explanation, of course,
is that there will be sufficient controls [under the proposed
revision to the SFP] to meet environmental objections. It is important
to realise that the Agency's position is not that it does not
accept that there is a legitimate issue that must be dealt with,
but it has proposed safeguards and controls that it says are adequate
to meet those objections. When we have an independent Environment
Agency, it is important that we take account of what it says.
27. The Environment Agency has concluded
recently its consultation into modification to the Substitute
Fuels Protocol, details of which are to be presented to the EA
Board on 13 October 2004.
PUBLIC CONCERN
REGARDING THE
POTENTIAL HEALTH
RISKS OF
WASTE TREATMENT
PLANT
28. Whilst there is growing public enthusiasm
for "recycling" (ie segregation of domestic refuse at
source), this is at odds with its attitude towards plant for the
treatment of this material.
29. An obstacle to achieving the goal of
new waste treatment facilities is the perception of waste treatment
as being inherently bad for the health of those living in the
vicinity of an installation, and the translation of these fears
into concerted action to shut down existing facilities and prevent
new ones being built.
30. In a bid to inform the debate about
waste policy, Defra commissioned Enviros and the University of
Birmingham[57]to
produce a report comparing the environmental impacts of various
waste options[58]The
report focuses on air quality and provides an indication to local
communities that in comparison to other sources of pollutants
encountered in daily life, the health risks associated with the
treatment of municipal waste are minor.
31. The British Cement Association welcomes
this report, and recognizes the important of addressing stakeholder
concerns in this area. The industry is committed to stakeholder
engagement through its sustainable development initiatives, which
include:
31.1 The concrete sector sustainability strategy.
31.2 The World Business Council for Sustainable
Development, (WBCSD), Cement Sector Initiative, (CSI), in addition
to company-specific initiatives.
32. In addition, a two-day master class
for the CEOs of BCA's Member Companies was recently run by Jonathon
Porritt, following which the UK cement industry committed to the
five year goal of becoming an industry leader on sustainable development
through its goal directed plan UK Cement Industry: Creating Societal
Value.
33. The local communities around cement
factories are among the industry's key stakeholders. UK cement
producers have regular communications with local stakeholders
as part of their normal day-to-day operations. Frequent community
engagement is supplemented on a site-by-site basis focussing on
key licence to operate issues, for example quarry extensions and
waste-derived fuels trials.
34. Communications take the form of:
— Newsletters explaining plans and
progress on such issues such as plant developments and the introduction
of waste-derived fuels.
— Open Days allowing communities to
see the working operations.
— Open Door Policies under which members
of the community can telephone and request a meeting or a site
visit.
— Liaison committees providing a regular
forum for dialogue between companies and community representatives.
(The Environment Agency is represented on these liaison committees.)
Targets relating to stakeholder engagement are
incorporated in the EA Cement Sector Plan, Annex II.
35. To supplement these initiatives, the
BCA is in discussion with the Environment Council, with a view
to extending the effectiveness of its stakeholder engagement.
36. In response to a parliamentary question
on the environmental impact of using recycled liquid fuels in
cement kilns, Environment Minister Elliot Morley stated:
It is perfectly reasonable for people to raise
questions about the impact of changes, in this case in relation
to what is burned in cement kilns, but I am sure that the Hon.
Gentleman would agree that, if one is to take people's legitimate
concerns seriously, it is not reasonable to distort the arguments
or unnecessarily frighten or worry people when there are no grounds
to do so. Such waste liquid solvents have been used in other cement
works in the UK and elsewhere in Europe for over a decade, so
the technology is not new and the risks associated with it are
well known and understood[59]
37. The cement industry wholeheartedly supports
the Minister's view.
38. Responsibility for waste policy is vested
across many disparate parts of Government and its agencies. Policy
needs to be drawn together into a clear framework and a coherent
and complimentary strategy. It is imperative in order that industry
and government can deliver the investment necessary to put in
place an infrastructure that can deal with the UK's waste problem
as the landfill directive is fully implemented.
Annex I
PRESENT AND FUTURE WASTE RECOVERY BY THE
CEMENT INDUSTRY
| Fuel | 2001
| 2001 | 2002 |
2002 | 2003 | 2004 to 2007
|
| Permitted Capacity |
Actual | Actual |
Actual | Actual |
Estimate |
| BCA Submission to EFRA Committee5
| Hansard[60]
| Hansard60 | BCA data[61]
| BCA data | BCA Submission to EFRA Committee5
|
| Waste-derived liquid fuels | 110,000
| 83,502 | 98,345 | 118,474
| 115,665 | 200,000 |
| Waste oils | 0 | 0
| 0 | | | 90,000 to
345,000
|
| Tyres | 40,000 | 30,674
| 37,481 | 42,778 | 65,621
| 290,000 |
| Paper, plastic, and packaging | 0
| 0 | 7,890 | 8,200
| 0 | 500,000 |
| Meat and Bone Meal, MBM | 0 |
0 | 0 | 0 | 0
| 140,000 |
| Processed Sewage Pellets, PSP | 0
| 0 | 0 | 836 |
10,675 | 40,000 |
| TOTAL | 150,000
| 114,176 | 143,716
| 169,288 | 191,961
| 1,260,000
excl waste oils
1,515,000
incl waste oils
|
| 8 October 2004 | |
| | |
| |
Annex II
COMMUNITY ENGAGEMENT WITHIN THE EA CEMENT INDUSTRY SECTOR
PLAN[62]
OBJECTIVE 7: TO
IMPROVE TRANSPARENCY,
UNDERSTANDING AND
ENGAGEMENT BETWEEN
THE AGENCY,
INDUSTRY AND
OTHER STAKEHOLDERS
Background
It is important that all stakeholders know how environmental
goals and objectives for the industry can be achieved and what
barriers exist. In particular, the Agency and industry should
look to build upon initiatives to engage with the public to achieve
the environmental benefits of the use of waste resources.
Performance indicators
7.1 Number (and proportion) of plants with local liaison
groups who were active during the year.
7.2 Number (and proportion) of environmentally significant
proposals during the year that were pro-actively communicated
by companies to local communities.
7.3 Number (and proportion) of local liaison meetings
attended by Agency inspectors.
7.4 Number (and proportion) of substitute fuel decisions
during the year for which an Agency Decision Document was issued.
48
To be published shortly. Back
49
Tonnes landfilled per tonne of cement manufactured. Back
50
House of Commons, Environment, Food and Rural Affairs Committee:
"Hazardous Waste", Eighth Report of Session 2001-02,
HC 919. Back
51
Environmental Audit Committee Inquiry into Waste, October 2002.
House of Commons Environmental Audit Committee: "Waste-An
Audit", Fifth Report of Session 2002-03, HC99-I and HC 99-II,
page Ev 163. Back
52
EFRA Select Committee Inquiry on the Future of Waste Management,
January 2003. House of Commons, Environment, Food and Rural Affairs
Committee: "The Future of Waste Management", Eighth
Report of Session 2002-03, HC 385-II, page Ev 207. Back
53
House of Lords Select Committee on the European Union, Sub Committee
D (Environment, Agriculture, Public Health and Consumer Protection)-"European
Union Waste Management Policy, HL Paper 194, 18 November 2003,
page 105. Back
54
Data from CEMBUREAU. Back
55
Reference 3 at paragraph 63, page 19, and Conclusion (o), page
26. Back
56
Prime Minister's Questions, 23 June. Prime Minister's reply to
Q4, [178979], Dr Andrew Murrison (Westbury) (Con). Back
57
Mark Broomfield of Enviros and Professor Roy Harrison were the
authors of this report, "The review of environmental and
health effects of waste management-municipal waste and similar
wastes", which is available at www.defra.gov.uk/environment/waste/health-effects/index.htm Back
58
"Probe clears waste emission", Air Quality Management,
June 2004, Issue 102, pages 1, 6-8. Back
59
Hansard, House of Commons-Adjournment Debate, 27 November
2003: Columns 230-236. Back
60
Elliott Morley, Hansard, 18 June 2003, Col 288W; Alun Michael,
Hansard, 3 June 2003, col 18W. Back
61
The higher usage within the BCA data is possibly a combination
of the omission of PSP at Cauldon, and the non-inclusion of Dunbar
works, (which falls within the control of SEPA rather than the
Environment Agency\. Back
62
Environment Agency Sector Plan for the Cement Industry, in preparation.
See "Greener Business is Good Business: Spotlight on Business,
Environmental Performance in 2003", Environment Agency, July
2004, page 7; and "Performance: A corporate responsibility
report from the UK Cement Industry", July 2004, page 10. Back
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