Examination of Witnesses (Questions 100
MONDAY 10 JUNE 2002
100. As I said, we are new to this area. Given
a free hand, how would you tweak the regulatory approach to achieve
the policy objective that you have just defined?
(Mr Averill) By outlawing the environmentally unacceptable
treatment of hazardous waste.
101. That would be possible within UK law because
it would simply mean you are going beyond the minimum that is
required within the current regulatory framework.
(Mr Averill) Yes. You can use the IPPC Directive.
When a waste producing industry is being analysed for an IPPC
permit you can say with respect to waste production, "Sorry,
chaps. This used to go to landfill but we are not going to allow
it any more."
102. Can I pick up this point that the CIA were
talking to us about, this notion of an industrial waste forum.
(Mr Averill) We are always happy to cooperate in such
things, and it would certainly add value, in as much as it would
give our industry a clearer idea of the size of the opportunity.
If we could get some good data on the waste that they are producing,
it would help us with investment. But, as I said, I believe that
the primary thrust here must be regulatory.
103. So it is helpful but it is not a key driver?
(Mr Averill) It would not be a key driver, no. My
belief is that we need to get the waste acceptance criteria in
for landfill to make sure that they outlaw landfill for unacceptable
wastes and the market will do the rest.
104. I want to move on to an area which causes
enormous controversy. In your own paper you indicate in the area
of incineration and you give us a very helpful example about what
has happened in Pontypool. On the one hand you are saying that
incineration deals with about 10 or 15 per cent of hazardous waste.
On the other hand, as soon as anybody suggests building an incinerator
for any purpose in the United Kingdom, you can guarantee there
will be a huge campaign against it; people do not, for whatever
reason, like incineration. Why do you think it is so difficult
to convince people that modern incinerators are "safe"?
(Mr Averill) Because there is an intense amount of
opposition from the likes of the NGOs on the subject. That is
why I think what incineration capacity we have is relatively precious
and should be preserved, because getting new permissions is not
going to be easy.
105. What are the factors at this Pontypool
(Mr Averill) It has no work.
106. It is as simple as that?
(Mr Averill) It is as simple as that. We announced
on the Stock Exchange 10 days ago our results for the year. I
had to concede to our shareholders a £4 million loss in this
107. That is simply because the cheaper alternatives
for disposing of waste.
(Mr Averill) Yes. It goes to landfill.
108. And you cannot import.
(Mr Averill) No. You used to be able to import, but
under the government regulation of the early Nineties that was
stopped. As I indicated when the forerunner of this Committee
looked at the issue of hazardous waste under Sir Hugh Rossi back
in the late Eighties, it came up with this distinctionin
my opinion a good distinctiona differentiation between
waste disposal and waste destruction, and because waste is destroyed
in the incineration process and the hazardous content is destroyed
to 99.9999 per cent and beyond as a minimum, the Committee decided
that that was waste destruction, and therefore it was a good industry,
just like the rest of UK plc, and it should be allowed to operate
overseas. I heard from the CIA that perhaps this waste would be
109. You cannot do that.
(Mr Averill) No, you cannot do it, but personally,
I do not see why you cannot. I believe in high standards, but
then I believe in free competition between all of the people who
are qualified to those high standards. I am sure the gentleman
in question is facing some fierce competition from European and
other overseas companies. Why should you not have the same competition
in this industry?
110. Was there an energy output from the Pontypool
(Mr Averill) Energy in many areas is beneficially
re-used in exactly the same way as it is in, say, a cement kiln.
Not all hazardous waste for incineration has a high calorific
value, so you use the heat generated from that which has to destroy
that which has not.
111. In your evidence in appendix 1 you have
an interesting paragraph. You say, "Whilst we recognise that
co-incineration is an important option, a level playing field
needs to be established. Recovery of energy during the destruction
of waste by HTI is of equal value to the recovery of energy during
cement manufacture." Could you just explain that?
(Mr Averill) It is back to one of these idiosyncracies
of the legislation. Mr Tipping quite rightly points out that we
are not allowed to import for incineration, because that is classified
as a disposal activity. If you were to import the self-same waste
to a cement kiln, where you are "re-using the energy"
to make cement, that is classified as re-cycling. So you are allowed
to import it into a cement kiln but you are not allowed to import
it into an incinerator, even though the use of energy is identical.
112. When you talk about cement kilns, I would
hate people to think there was illicit incineration going on in
cement kilns. Are you suggesting that that is what is going on?
(Mr Averill) I am not alleging for a moment that anything
illegal is happening but an awful lot of hazardous waste is burnt
in cement kilns. Cement kilns are not interested in burning hazardous
waste; they are interested in mitigating their fuel costs. The
fuel cost in cement manufacture is one of the greatest costs.
If instead of burning fuel for which they have to pay they can
burn waste for which they are paid, they can greatly improve the
economics of their process.
113. There are some cement kilns burning tyres
and some secondary liquid fuel.
(Mr Averill) I am not saying that is an activity which
should stop. Many of these secondary liquid fuels, although waste-derived,
are to quite a tight standard, and are in many ways cleaner than
the coal which they substitute. My complaint is this: the re-use
of the energy is exactly the same in the case of incineration
as it is in a cement kiln, but we get completely different regulatory
114. In terms of hazardous waste incineration
capacity, do we have enough in the UK if what we have currently
were to be fully utilised?
(Mr Averill) That depends entirely upon the regulatory
regime which forces the waste towards incineration. At the moment
there is a surplus of incineration capacity for hazardous wasteI
am talking exclusively hazardous wasteand that is why we
have had to take the action that we have taken to cease operations
at Pontypool, because there is no work.
115. I was going to ask you to explain why it
certainly appears that other people are investing in incineration,
but presumably their proposals are focussed on the broader marketplace
of incinerating household waste.
(Mr Averill) Yes. You must not confuse the two. The
temperatures in the incineration of hazardous waste are far higher
than the temperatures for the incineration of municipal solid
waste. The plants technically speaking are completely different.
They share the name "incinerator" and that is where
it begins and ends. The problem we have is not shared by a municipal
116. Presumably you have those sorts of operations
(Mr Averill) We do not as a company have municipal
waste incinerators, no.
117. You touched on re-cycling and indeed outlined
some interesting developments that you were involved in in other
parts of Europe. What scope do you think there is for increasing
the amount of re-cycling that can be generated from this particular
form of waste disposal?
(Mr Averill) Again, very simply, by adjusting the
118. So that you would place an obligation for
a proportion of specified waste to be re-cycled in some way. How
is it done in Europe?
(Mr Averill) It almost happens as an automatic consequence.
We have a high temperature soil cleaner for polluted soils containing
oil contaminants in the Netherlands. In the UK all of that simply
goes to landfill. Here what we do is we use the oil from our oil-water
separation plant to provide the heat for the soil cleaning. So
the oil is completely re-cycled into the thermal process, and
the interesting bit is the output is the clean soil which goes
back for beneficial re-use.
119. So there is not a regulatory obligation
to re-cycle a particular item; it is just that there is an economic
advantage attached to it.
(Mr Shaughnessy) Absolutely. Economically delivered