The cement industry began exploring the use of alternative fuels, such as scrap tyres and waste solvents, in the early 1990s in order to reduce fuel costs. The plans proved controversial with local communities and in 1997, a parliamentary committee savaged the fledgling Agency over its handling of the issue (ENDS Report 266, pp 30-32 ).
In response, the Agency developed a "substitute fuels protocol", which put in place rigorous testing and public consultation procedures. This was followed by a simplified version for tyre burning trials.
The trial and authorisation process, which can take many months to complete, has vexed the cement industry, which is keen to use waste fuels as the main element in its strategy for complying with its climate change agreement with the Government. Local groups opposed to waste burning have also given the Agency a rough ride under the protocol's enhanced consultation procedures.
The Agency has always argued that the idea of burning waste in cement kilns is in principle an attractive one. However, it has now gone further by strongly endorsing the use of a broad range of waste fuels as a "best available technique" for the sector. The Agency has "concluded that overall the use of substitute fuels in cement and lime kilns is beneficial in terms of reducing local ambient concentrations and emissions....in addition, the use of substitute fuels contributes to the sustainable management of waste materials by substituting fossil fuels."
One key driver for the change in policy is the looming restrictions on disposing of hazardous waste and tyres to landfill brought about by the EU landfill Directive. The UK is facing a potentially serious shortage of hazardous waste management capacity (see pp 30-33 ).
The British Cement Association claims that the Agency's proposals would allow burning of liquid chemical waste in cement kilns to increase from 143,000 tonnes in 2002 to 200,000 tonnes per year within 3-5 years. Kilns could also begin to take waste oils - with a potential to burn 90-345,000 tonnes per year over the same period.
The Agency's plans spell trouble for the UK's two remaining hazardous waste incinerators operated by Shanks and Cleanaway, which have steadily lost ground in their battle to stave off competition from the cement industry. Gill Weeks, Cleanaway's regulatory affairs director, warns that one of the incinerators is likely to shut if cement kilns take up their full potential for burning waste.
Ms Weeks accepted that the increased burning of hazardous waste in cement kilns is "inevitable" and has a "role to play" given the need for additional treatment capacity as a result of the ban on landfill co-disposal. But she questioned whether it is the best environmental option: "Incinerator operators have invested huge sums to minimise pollution and cannot compete with cement kilns which will only have to demonstrate no net detriment to the environment."
The proposals are also likely to be of concern to community groups such those in as the town of Rugby, where Rugby Cement's plans to burn tyres provoked a vociferous campaign (ENDS Report 345, pp 9-10 ).
Helen King, director of public health at Rugby primary care trust, is concerned about the Agency's plans to remove public consultation: "If our experience in Rugby has taught us one thing, it's about the importance of working with the local community." She also feels that there is a lack of scientific knowledge about the potential impact of cement kiln emissions on human health.
Lillian Pallikaropoulos, a campaigner with Rugby in Plume, said that the Agency's proposals would "open the door to UK cement companies importing waste from anywhere in the world....If the Agency remove the people of Rugby's right to public consultation, it would leave us with no option but to take direct action."
The main changes to the protocol are:
The new waste categories have never been burned in UK cement kilns. However, the Agency says, "burning these wastes is unlikely to have any effect on emissions (except perhaps to reduce the most environmentally significant ones) due to the characteristics of cement and lime kilns employing high temperatures, long residence times and an alkaline environment."
Under the procedures outlined in the consultation paper, companies will have to submit a commissioning programme to demonstrate "no net detriment to the environment" - the sole success criterion - using the Agency's H1 BAT assessment methodology. Assuming that commissioning is successful, the company can immediately use the fuel on a permanent basis.