Supplementary memorandum submitted by
the British Cement Association
The British Cement Association would like to
thank the Environment, Food and Rural Affairs Sub-committee for
inviting it to give oral evidence on 2 July 2002 to its inquiry
into Hazardous Waste, and the invitation to submit supplementary
information for the Committee.
Our key point is that we ask the Committee to
agree to our proposal to revisit the Substitute Fuels Protocol,
which we feel has been superseded, and is redundant, but is still
inhibiting progress. It will be of equal importance that any resulting
revision of policy at national level is implemented at local level
by the Environment Agency's inspectors.
Attached is supplementary information including:
the ability and willingness of the
industry to participate with government as part of the waste management
solution for the disposal of hazardous and other wastes;
factors within UK legislation, notably
the Substitute Fuels Protocol, that are inhibiting action and
innovation by the industry;
the issue of competition with other
the distribution of cement plants
across the UK, and their ability to provide solutions on a relatively
May we reiterate our invitation to the Committee
to visit a cement plant either in the UK or at one of our members
other European sites? Recognising the Committee's time constraints
in producing this report, we stand ready to put arrangements promptly
Should the Committee require any further information
or clarification of the points made in this supplementary submission,
our oral evidence or written submission then we should be pleased
to give it.
The BCA and its members very much look forward
to the publication of the Committee's report.
As the BCA highlighted in both its written submission
to the Committee, and during its oral evidence session, we believe
the cement industry has a significant role to play providing a
beneficial solution to the disposal of hazardous wastes in the
Table 1, below, sets out the potential of the
industry to make use of a range of wastes in cement making processes.
>From a performance last year where 150,000 tonnes of wastes
were used as a fuel, within 3-5 years we could increase this ten-fold.
This offers a major breakthrough in terms of sustainability as:
The energy and material resources in the
wastes will be recovered and used in making an essential building
CEMENT INDUSTRY USE OF ALTERNATIVE FUELS
|Fuel||2001-Actual Use, tonnes
||Next 3-5 yearsestimates of Potential Use, tonnes
|Waste derived liquid fuels||110,000
|Packaging and Packaging Waste||0
|Waste Oils||0||90,000 to 345,000 (see page 4)
|Meat and Bone Meal, (MBM)||0
|Processed sewage pellets, (PSP)||0
|Total||150,000||1,260,000 excluding waste oils
|1,515,000 including waste oils
UK LEGISLATION INHIBITING
In order to realise fully this potential and to compete on
equal terms with other EU cement plants, the use of these materials
in cement kilns should be regulated in accordance with the latest
EU directives[IPPC and WID]supplemented by a transparent
and full-inclusive stakeholder dialogue, that is consistent with
ensuring environmental improvement.
To achieve this it is necessary to address the issue of the
Substitute Fuel Protocol (SFP), whose origins lie in a report
from the present committee's predecessor. As the present Committee
itself noted on 2 July, this Protocol applies only to the cement
and lime sector.
The SFP is an extra-statutory regulation that requires a
prescribed procedure to be followed by the industry when an application
is made to use an alternative fuel. The timetable for permitting
an alternative fuel, following the SFP, sets a minimum timescale
of 17 months, providing that all stages are completed within the
specific period. In reality the actual time taken is substantially
longer, and often dictated by local inspectors operating outside
the national protocol.A breakdown of the stages in this procedure
is set out in Annex 1, and a comparison with much shorter procedure
in France is given in Annex 2. Likewise in Germany, authorisations
are granted much more quickly: for example, RMC in Germany gained
permission to burn animal meal was granted in one month, and a
full permit obtained after a further three months: authorisation
to increase the rate of fuel usage was granted in 10 months.
In addition, the cement industry has demonstrated consistently
that improved environmental performance follows the introduction
of alternative fuels, Annex 3. The SFP requires plants to stop
utilising an alternative fuel after trial and return to using
traditional fuels, a worse environmental option with higher emission
As we stated at our oral evidence session, the SFP was created
at a time when there was a regulatory vacuum in the permitting
of alternative fuels. Since then, regulation has moved on, and
so has the industry. The requirmenets placed on the industry through
IPPC and WID, coupled with our unequivocal committment to stakeholder
dialogue means, in our view, that the SFP has been superseded
and is, therefore, redundant.
As a consequence of its origin, policy makers and regulators
are reluctant to look at this matter without sanction from the
Environment Committee. The BCA therefore asks the Committee, after
reviewing the evidence presented to it, to recommend that an independently
chaired review of the SFP be carried out involving the cement
industry and other stakeholders, and that the review is asked
to report its conclusions and recommendations to the Committee
by the end of 2002.
The Cement Industry stands ready to play its role, along
with other stakeholders, in the process.
To help kick start the review, the cement industry would
be happy to table a new draft proposal that could serve as the
basis for discussion.
The Committee has heard in evidence from a number of witnesses
that the UK relies more heavily on landfill than most other EU
countries, yet these countries in turn have greater recourse to
the use of high temperature incinerators as part of the solution
to their waste disposal problems.
The Environmental Services Association (ESA) suggested to
the Committe that high temperature incineration was subject to
unfair competition for suitable hazardous waste materials from
The cement industry contend that the reasoning behind this
assertion is flawed because:
high temperature incinerators will and must have
a continuing role to play in the disposal of hazardout material;
the cement industry must be selective in the wastes
it uses as fuels, therefore, a wide range of hazardous wastes,
including high calorific value wastes, are still available to
high temperature incinerators.
other EU countries have a lower reliance on landfill
but a higher use of both high temperature incineration and co-incineration
by cement kilns using alternative fuels. It therefore seems unlikely
that the situation in the UK is the result of unfair competition.
Nevertheless, the basic tenet of EU legislation that operations
higher up the waste hierarchy should be favoured should hold true
in this case. Market dynamics can step in here to ensure a balance
between competing services. That is why some of the high temperature
incinerator operators now supply the cement industry with the
blended fuels we require.
The Environment Minister, Michael Meacher, pointed out his
own oral evidence to the Committee, 1 July 2002, an important
distinction between high temperature incinerators and co-incineration
in a cement kiln; the latter process he said recovers energy and
in that there is environmental logic.
The application of the Landfill Directive will require that
more of the current six million tonnes of waste that the UK produces
annually be dealt with differently. Furthermore,
the revision to the Hazardous Waste List will result in an additional
200 wastes (estimated 600,000 tonnes) being classified as hazardous
on the European Waste Catalogue and requiring appropriate treatment.
However, even at
optimum utilisation levels, the UK cement industry has the potential
to make use of 1.5 million tonnes of hazardous and other wastes,
leaving 4.5 million tonnes requiring alternative disposal routes.
The UK cement industry has 16 production facilities spread
across the UK from Dunbar in Scotland, Cookstown in Northern Ireland,
Padeswood and Aberthaw in Wales and 11 plants across England.
Of these, four are already using hazardous wastes as fuels,
compared to only two high temperature incinerators in the UK.
The cement industry therefore has the potential to provide the
environmentally preferable local solutions to local waste disposal
problems, without the need to install new capacity.
Nevertheless, substantial capital investment will be needed
in order to increase the use of alternative fuels by the UK cement
industry to bring it into line with best European practice. It
will take time for the industry to attain such a ten-fold increase
of alternative fule use, and a review of the SFP is critical to
allow this process to start.
The ESA suggested to the Committee that the cement industry
was obliged to meet lower emission limits than those applied to
high temperature incinerators. The facts do not support this.
The reality of the situation is the cement industry complies
fully with the hazardous waste incineration directive. The directive
allows co-incineration and it is under the co-incinerator clauses
of the directive that a cement kiln is regulated. This applies
if there is less than 40 per cent thermal substitution by hazardous
The reason the directive has different limits for cement
kilns is that the emissions from cement kilns arise largely from
the raw materials for making cement (limestone and clay materials)
rather than the fuel, whereas in an incinerator all the emissions
arise from the combustion of wastes.
AND DEFRA EVIDENCE
We have examined the written memorandum from the Environment
Agency and DEFRA and find their tables showing the disposal routes
for hazardous waste confusing, as they seriously underestimate
the utilisation of incineration with energy recovery. Both tables,
Appendix 1 of the Agency's submission and Point 13 of DEFRA's
use the same figures for 1997-98, indicating only some 34,000
tonnes was disposed of via this route. The Agency also includes
figures for 2000 of 57,000 tonnes. We have spoken with the Agency
on the accuracy of this information and they have told the BCA
that they accept our figures that show for the cement industry
alone last year (2001) it used150,000 tonnes of hazardous
waste derived fuel.
The future problem of waste oils
In 2001 Oakdene Hollins reported to DETR that the Recovered
Fuel Oil, (RFO), currently burnt by power stations and road stone
drying plants, would come under the WID or the HWID, depending
on the EA classification of this material, and that they anticipated
that: "from 2006 or possibly sooner the majority of RFO will
be directed to cement and lime kilns". The cement industry
in France and Germany are already the main users of these materials.
Similarly, Annex 4 shows the difference between the UK and Belgian
governments in responding to specific challenges requiring high
temperature incineration. We believe that a joint government,
regulator and cement industry initiative could resolve serious
challenges facing the UK including, for example, waste meals and
The BCA is playing a full role in the current Performance
and Innovation Unit (PIU) work on waste, offering opportunities
to make a contribution to the UK recovery targets. The Association
is also contributing to the DTI consultation on Energy where it
indicates that the use of waste fuels addresses two prime areas
of consideration for that consultation:
increasing the diversity of supply.
reducing emissions of global warming gases.
The cement industry sees the use of waste materials as a
means of controlling its resource use and assisting in its sustainable
The British Cement Association
10 July 2002
Environment Agency submission to EFRA Sub-Committee Hazardous
Waste Inquiry (E20), Appendix 1. Back
DEFRA submission tor EFRA Sub-Committee Hazardous Waste Inquiry
(E21), point 49. Back