Criticism of UK Environment Agency over alternative fuels for cement kilnsPublished by MAC on 2003-07-27
Criticism of UK Environment Agency over alternative fuels for cement kilns
27th July 2003
Worldwide the cement industry has embarked on a strategy of burning toxic wastes - including animal corpses and tyres - in its kilns ("co-incineration" as the euphemism goes). Manufacturers argue that this is less pollutive and more sustainable than using coal or coke - and cheaper too. Despite vigorous opposition from local communities, the board of Britain's Environment Agency has now endorsed the industry's position.
In this paper, Alan Dalton argues that the EA's view is ill-considered and scientifically flawed.
Comments on: Review of Agency’s Position and Policies on the use of Substitute Fuels in Cement and Lime Kilns
By AJP Dalton, Joint Director, Centre for Environmental Protection, Working Lives Research Institute, London Metropolitan University, Stapleton House, Holloway Road, London, N7 8HN.
“The Substitute Fuels Policy, SFP, remains a major barrier to fully realizing the potential within the cement industry to address many of the country’s waste management problems.” British Cement Association Annual Review, 2002.
At the May 2003 meeting of the Board of the Environment Agency (EA), way down the agenda at item 10 was the approval of the amalgamation of the EAs Substitute Fuels Protocol and Tyres Protocol, “together with minor technical amendments”.
For those EA Directors who were still awake by this part of the agenda a brief accompanying note by Dr Paul Leinster, the EAs Director of Environmental Protection, explained, “The Agency has considered information on substitute fuel burning around the world and within the UK. It has concluded that overall their use is beneficial in terms of process emissions, primarily by reduction in the principle process pollutant oxides of nitrogen, and contributes to the management of waste streams.”
The note also added that, “The Agency is considering further changes to the Substitute Fuels policy, which will be the subject of consultation….”
According to the minutes of this meeting this proposal was passed with no discussion noted.
By July 2003 Dr Leinster was presenting these proposed “further changes” to various EA regional committees. It was at these committees that the proposals first became public knowledge.
In the UK some cement kilns have been burning toxic waste for over ten years. This has been the subject of much controversy, including two detailed reports by the Environment Committee of the House of Commons. The 1997 report (1) made a number of recommendations, amongst which were:
· The Government should carry out a survey of health effects in the vicinity of cement kilns.
· The Environment Agency must ensure that all its monitoring exercises and environmental assessments are based on sound science.
· There must be greater public access to the decision making process before trials commence.
· The Agency must take a more rigorous and consistent approach to the application of Best Practicable Environmental Option methodology, so that it will no longer be open to charges of manipulating the data to produce the desired result.
There has been no health study of people living around cement kilns, burning toxic waste, to this day. Although a 1995 study (2) of 300 children attending primary schools near the Castle Cement works which was burning 50% recycled liquid fuel - in Clitheroe, Lancashire as compared with 300 children in schools not near cement works, found that they were:
1.7 times more likely to have sore eyes.
1.8 times more likely to suffer from sore throats.
1.6 times more likely to have a blocked nose.
The researchers concluded that, “This excess may be due to emissions from the site.”
The controversy over burning toxic waste in cement kilns continues.
In July 2003, the European Commission announced (3) that it was referring the UK to the European Court of Justice for its failure to carry an Environmental Impact Assessment with regard to changing the fuel to fire the Castle Cement works in Lancashire.
There has been considerable local public concern and national press publicity (4) over the proposal of Rugby Cement, in Rugby, to burn tyres. Both Rugby Council and Rugby Primary Care Trust have been unhappy with the proposals and both commissioned independent health assessments. Rugby Council voted unanimously that it had no confidence in the Environment Agency.
3. The current proposals
A. Some general points:
Dr Paul Leinster, the EAs Director of Environmental Protection, says in his proposals, “The Agency has considered information on substitute fuel burning around the world and within the UK. It has concluded that overall their use is beneficial in terms of process emissions, primarily by reduction in the principle process pollutant oxides of nitrogen, and contributes to the management of waste streams.”
Where is the published review and information that the EA have taken into account?
The only public information on the comparable pollution levels from cement kilns burning toxic waste is the January 2003, AEA Technology report, Review of Tyre Burning in Cement Kilns, produced for the EA. This report looked only at tyre burning and at just four cement kilns in the UK: Cauldon, Ketton, Westbury and Hope.
Before looking at any comparative analytical data it is vital to determine the source and nature of the information. For example:
· Who did the sampling? Were they independent and fully qualified to sample?
· Where did the sampling take place? Was it adequate? Were there enough sampling places? Were they located in the appropriate positions (e.g. where plumes ground, near local schools or centers of population, in the prevailing wind stream)?
· What chemicals were sampled for? Was the sampling accurate and sufficient?
The AEA report notes, “It is important to note that these trends have been observed on the basis of a ‘face value’ review of the data. Assessments of emissions data uncertainties and quality assurance have not been made due to lack of data, and scope of the review. Trends in emissions that are observed need to be viewed in the context of this being a ‘face value’ review. Uncertainty analysis and date quality are key issues when assessing trends, and would need to be addressed more fully in any subsequent reviews.”
In some cases tyre-burning trials have been going on for nine years, why is this independent, scientifically valid and audited information not available? The lack of this adequate data devalues this report and makes it suspect.
The AEA report says that, on the basis of the limited evidence available (see above):
· Nitrogen oxide emissions are reduced at all four sites.
· Sulphur dioxide emissions increased at two sites.
· Carbon monoxide emissions increased at two sites.
· Particulate emissions increased.
· Volatile Organic Compound emissions decreased.
· Zinc emissions increased.
· There was no conclusive evince for an increase or decrease in dioxin or metal emissions.
Given the limitations of this report (possible sampling errors; only one toxic feedstock, tyres; only four UK kilns, no international data) this is not a convincing report that burning tyres in cement kilns is good for people’s health or the environment.
In 1999 the EA published (5) a 100-page report by Chem Systems Ltd on the Life Cycle Analysis of Substitute Liquid Fuels (SLF) used in Cement Kilns. The report noted that, “Recycling of solvents is environmentally preferable to incineration on almost every count.” Although it did suggest that with some solvents, sending SLF to cement kilns may have an environmental advantage over recycling.
The report, importantly, also noted that, “Incinerators are designed for very high retention of certain contaminants, such as sulphur or halogens. The retention in cement kilns, although high, may not be as good…suggestions are therefore made in the report for contaminant levels at which wastes should be excluded from SLF.”
There is a table of suggested maximum concentrations of 11 chemical substances that should be allowed in the SLF, generally speaking wastes should not be allowed with:
· A high halogen content.
· A high concentration of volatile or semi-volatile metals (e.g. Mercury, Thallium and Cadmium).
· Very high contents of metals or ash.
The revision of the Protocol should be the opportunity to take these recommendations into account.
They also raise the question about the appropriate baseline for measuring environmental pollutants around cement kilns.
Currently, the baseline is the cement kiln burning dirty coal and dirty petcoke. But why should this be? Surely the true baseline is the level of environmental pollutants in the air when the cement kiln is not in operation; this would also exclude the effect of pollution from the many large cement wagons traveling to and from the cement plant.
Proper control of the toxic content of the SLF being burnt gives the possibility that the pollution could be lower that when coal and / or petcoke is being burnt; thus offering some real advantage to the communities around cement kilns. Of course, this would need to be verified by the sort of independent and rigorous sampling discussed above.
B. Specific comments on proposals:
1. Minimum Calorific value for substitute fuel.
This would appear to have great significance: from increased importation of toxic wastes to decreased burning of toxic wastes in incinerators. The full implications of this proposal require a much wider public debate.
2. Consultation on proposals to burn substitute fuel.
This proposal downgrades the legal requirement for consultation when the use of substitute fuel is proposed and gives the EA the power to require, “statutory, or even extended consultation” only, “in appropriate cases”.
The EAs Industry Board Advisory Group, “believed that extended consultation procedures should always be considered when there was significant public concern.”
It is a fact that the EA often performs badly at public meetings. The answer is not to abolish public meetings, for ‘one-to-one’ seminars as carried out at the EAs ‘consultation’ over the new kiln at Castle Cement’s Padeswood factory, but to train the appropriate EA staff to be able to explain themselves in public and hence become more democratically accountable.
The recent EA hearings, on the proposal of Lafarge Cement at Westbury to burn Recycled Liquid Fuel (RLF), with both a public meeting and smaller seminars, provide one model.
There must be no proposal to reduce the amount of public consultation on this important issue.
3. Exclusion of some wastes.
This proposal appears to go directly against the research (5) that the EA commissioned, as discussed above. The exclusion of especially toxic wastes give the potential opportunity to run a cement kiln that is cleaner in emissions than one burning coal or coal/petcoke.
Because of the potential variability of toxic waste solvents the monitoring should be required to detect any potential pollutant; whether they are currently being detected or not. Just because some pollutants are currently present only in trace quantities does not mean that future batches of toxic waste solvents may not generate these pollutants in greater quantities.
The monitoring must be: independent, scientifically valid, in the appropriate places (from downwind to local schools), audited and presented in such a way that lay people can understand the significance of the results.
The location of monitors should be discussed with the local community.
The consultation to date has been totally inadequate. The current proposals should be withdrawn and a fuller paper addressing all of the issues raised in this paper, and any others that people or groups may raise, produced.
This paper should then be the subject of wide discussion with the cement industry, the waste industry, the scientific community, national and local environmental groups and national and local politicians. It should be the subject of a full debate by the Board of the EA (and not passed on the nod, as this one was).
The cement industry has said (6) that it wants to raise its use of alternative fuels (chemical waste, tyres, packaging waste, waste oils, animal waste and sewage sludge) from 150,000 tonnes per annum in 2001 to 1,515,000 tonnes/annum in 3-5 years time.
If this happens it will have great implications for the waste industry, reuse and recycling, and a full examination of whether this is the best was to utilize these waste resources needs to be examined. The cement industry exists to make cement; it has no incentive to utilize waste in the most environmentally effective manner. It is simply burning toxic waste to save money.
If, after a full Life Cycle Analysis and Environmental and Health Impact Assessment, it appears beneficial to burn some specified and controlled toxic wastes in cement kilns, there will be a great financial saving for the cement companies over conventional fuels (mainly coal and coal/petcoke). Some of this saving should be passed onto the communities that have had to live with the pollution from cement works for years. This may be in the way of cleaner fuels (especially if certain concentrations of toxic wastes are excluded) and/or in the upgrading of air pollution control devices (e.g. fit bag house filters as well as electrostatic precipitators).
The health of communities around cement kilns should be studied and monitored both before and after alternative fuels are introduced.
If these, and other, recommendations are not taken on board in this revision of the Protocol then the common view of many local environmental groups around cement kilns, that the Protocol is being revised to suit cement industry needs, would appear to be true.
1. The Environmental Impact of Cement Kiln Manufacture, Environment Committee, 3rd Report, House of Commons, 1997.
2. Respiratory health effects of industrial air pollution: a study in east Lancashire, UK; SE Ginns and AC Gatrell, Journal of Epidemiology and Community Health, Volume 50, pages 631- 635, 1996.
3. European Commission Press Release, IP/03/1070; 22nd July 2003.
4. See: Agency on the rack in row over health impacts of tyre burning, ENDS Report 328, pages 23 25, May 2002; Burning Issues, page 27, Private Eye 1074, Feb/March 2003; Balls to Rugby cement Say Locals, DIRT 1 magazine, page 16, 2003.
5. Substitute Liquid Fuels (SLF) Used in Cement Kilns Life Cycle Analysis, EA Technical Report P274, 1999.
6. ENDS 333, page 18, October 2002.