From: Subject: Gone to Blazes... Burning Hazardous Waste in Cement Kilns Date: Wed, 9 Jul 2008 07:25:28 +0200 MIME-Version: 1.0 Content-Type: multipart/related; type="text/html"; boundary="----=_NextPart_000_0000_01C8E194.F630ECB0" X-MimeOLE: Produced By Microsoft MimeOLE V6.00.2900.3198 This is a multi-part message in MIME format. ------=_NextPart_000_0000_01C8E194.F630ECB0 Content-Type: text/html; charset="Windows-1252" Content-Transfer-Encoding: quoted-printable Content-Location: http://www.foe.co.uk/pubsinfo/briefings/html/19971215145335.html Gone to Blazes... Burning Hazardous Waste in Cement = Kilns


BRIEFING SHEET

GONE TO BLAZES...
BURNING HAZARDOUS WASTE IN CEMENT KILNS =


1. The cement industry mixes it with the = incinerators=20

In a bizarre development the 170 year old1 UK cement industry, along with = that of=20 many other countries, has moved from simply making cement and has = entered=20 the hazardous waste incineration business.

Cement companies are burning wastes made up blends of residues = arising=20 from the solvent and chemical recycling and recovery process. = These=20 blends, sometimes referred to as secondary liquid fuels (SLF) or = recycled=20 liquid fuels (RLF), may contain solvents, resins, pigments,=20 organochlorines and heavy metals. Cement manufacturers are also = keen to=20 burn solid wastes such as tyres.

2. Why is the cement industry burning hazardous wastes ?

The cement manufacturing process is very energy intensive, = with=20 fuel and electricity usage accounting for about 50 per cent of = running=20 costs.2 By burning wastes as a fuel = cement=20 companies avoid some of these energy costs, as the wastes are = cheap;=20 sometimes the companies are paid to burn them. 3

3. Who is burning hazardous waste ?

There are 20 = cement=20 factories in the UK producing about 13 million tonnes of cement. = Ninety=20 percent of the cement sold in the UK is produced by three = companies who=20 are also members of the British Cement Association : Blue Circle, = Castle=20 Cement and Rugby Cement.4 Redland Aggregates makes lime = by a=20 similar process. According to industry sources, 83,000 tonnes of = liquid=20 wastes were burned in kilns, out of a total of 130,000 tonnes = produced in=20 the UK in 1996.5 Four cement and two lime plants = have=20 permanent authorisation from the Environment Agency to burn = solvent or=20 other wastes, and one cement plant has authorisation for burning = tyres.=20 One Scottish plant also has authorisation for SLF from the = Scottish=20 Environment Protection Agency (SEPA). Five other plants have=20

authorisations to trial or are planning to burn wastes. Castle = Cement's=20 fuel has the trade name Cemfuel, whilst Rugby cement burns Dycal, = a nylon=20 waste from Dupont which is contaminated with chromium .

Users of Waste Derived Fuels 6

Company Location Fuel Permanent=20 authorisation
(for fuel at % calorific value) = 		Date
Castle Cement Ribblesdale Cemfuel Yes, 40% Nov 1993
Ketton Cemfuel/ tyres* Yes for 20% Cemfuel only Dec 1995
Padeswood ** **
Rugby Cement Barrington SLF Yes, 25 % Nov 1995
Southam Dycal Yes, 40% Nov 1996
Blue Circle Cement Cauldon tyre chips Yes Nov 1995
Dunbar SLF Yes, 40% 1993
Claydon SLF No, 40% current trial
Northfleet tyres No, has trialed
Weardale SLF No, trialed 40% SLF, tyres = abandoned
Westbury tyres No, has trialed
Redland Aggregates Thrislington SLF Yes, 20 % Jul 1996
(lime) Whitwell SLF Yes, 25% Mar 1996=20

Notes:    * = Castle=20 Cement has been authorised to burn tyres at Ketton only on a trial = basis=20 so far.
** Castle Cement trialed non-chlorinated wastes some = time ago=20 at Padeswood (Clwyd) and are looking at options such as burning = solid=20 wastes like nappies, carpets, plastics and X-ray acetates at = Padeswood. 7 It expressed an =93intention to = utilise =94=20 similar wastes as well as tars and oils at Ribblesdale,8 but later said it had no such = proposals=20 =93currently =94.9

4. Burning mad =

Cement kilns are located near quarries from which the limestone = is=20 extracted, and communities have developed around them . Not = surprisingly,=20 opposition to the burning of solvent wastes in cement kilns has = been=20 vociferous. Communities in such places as the Ribble Valley = (Lancashire),=20 Weardale and Thrislington (County Durham), Barrington = (Cambridgeshire,)=20 Whitwell (Derbyshire), Northfleet (Kent), Ketton (Rutland), = Claydon=20 (Suffolk) and Westbury (Wiltshire) are living in the shadow of an = industry=20 which is operating to lower pollution control standards than = modern=20 hazardous waste incinerators, whilst often burning similar = wastes.

Groups have sprung into action against the burning as fuel of = what the=20 MP for Pendle in a parliamentary debate on Castle Cement's works = at=20 Ribblesdale referred to as =93a real witches' brew=94.10 The burning of wastes near = these=20 villages and rural towns, often in areas of great natural beauty, = has=20 caused outrage among many local citizens whose concerns have not = been=20 sufficiently recognised by industry or Government. Tony Blair, the = MP for=20 Sedgefield (including Thrislington), wrote to Environment = Secretary John=20 Gummer in 1994 calling for a =93total ban=94 on solvent fuels and = an urgent=20 enquiry into their=20

use.11 Several applications for = judicial=20 review of the burning of wastes are currently in progress.

5. Something in the air

The main cause of local concern centres on the air emissions = from=20 cement kilns. Pollutants such as particulates, sulphur dioxide, = nitrogen=20 oxides, volatile organic compounds and the long lived dioxins and = heavy=20 metals all arise from the manufacturing and burning=20 process.

The Environment Committee's report in March = 1997=20 found that there have been serious inadequacies in the way that = air=20 pollution monitoring and data analysis have been conducted. = Analysis=20 carried out by independent consultants found that emissions of = pollutants=20 from kilns burning waste are often far greater than from those = burning=20 coal and coke alone. 12
An American study found = that kilns=20 burning hazardous waste emitted 66% more particles and those = burning=20 chlorinated waste 200% more particles than kilns burning = conventional=20 fuel. 13

In evidence to the Environment Select Committee, Douglas Bryce, = Head of=20 Integrated Pollution Control (IPC) at the Environment Agency, was = asked=20 why the Agency accepted the lowest set of readings of heavy metals = in=20 arriving at the conclusion that emissions declined 75% at = Thrislington=20 while wastes were burned compared with coal. Use of a different = set of=20 readings would have pointed to a level ten times higher. He = replied merely=20 that =93it all depends on the circumstances =94.14

The independent consultants Acer Environmental in their = Review=20 of IPC Authorisation and Variations: Castle Cement Ltd, = Ribblesdale Works=20 (May 1996) gave the following comparative analysis:
Pollutant Emissions = (mg/m3) Percentage change =
Coal Coal + Cemfuel
Particulates 51 71 + 40
Sulphur dioxide 1310 1348 +3
Nitrogen oxides 1216 1212 -
Ammonia 3.8 6.7 +76
Hydrogen fluoride 0.19 0.15 -21
Hydrogen chloride 77 26 -66
Carbon monoxide* 328 419 +28
Total organic carbon 38 35 -8
Lead 0.22 0.34 +55
Manganese 0.018 0.062 +244
Chromium 0.085 0.539 +534
Nickel 0.038 0.346 +810
Mercury <0.003 <0.003 -
Thallium <0.003 <0.003 -
Cadmium <0.006 <0.008 +33
Vanadium 0.013 <0.005 -62
Total metals <0.4 <1.3 +225
Dioxins ng/m3 0.26 0.28 +8 =

Levels of=20 heavy metals and dioxins in cement kiln dust from Ribblesdale are = also=20 higher when Cemfuel was burned; increases of 66%,107%, 242% 47% = for=20 cadmium, lead,=20

copper and dioxins were measured.15 Redland's application at = Thrislington=20 shows increases of 700% copper, 244% lead, 400% thallium and 127%=20 cadmium.16

Although dioxin emissions to air showed little difference in = the above=20 survey this is not necessarily typical. In February 1993 Gibb=20 Environmental found a 53% increase in dioxins emissions during = burning of=20 25% Cemfuel at Ribblesdale. At the Rugby Cement plant at = Barrington early=20 tests by Rugby showed that SLF increased emissions seven fold to = some=20 0.7ng/m3 and also raised particulates. HMIP's [Her = Majesty's=20 Inspectorate of Pollution] contractors have found dioxin levels of = some=20 0.78 ng/m3.17 The Environment Agency, = following=20 criticism of its inadequate answers, told the Environment Select = Committee=20 that in a food chain study at Ribblesdale, HMIP ( the Agency's=20 predecessor) had found an increase in dioxin intake when SLF was = burned.=20 This was in direct contrast to Castle Cement's own findings. 18

Emissions from Blue = Circle's=20 Weardale plant have also been a source of ongoing local = contention,=20 due to the presence of 'auxiliary stacks', which are used from = time to=20 time. The Environment Select Committee was told that, despite = promises to=20 assess the impact of emissions and to close these auxiliary stacks = during=20 waste burning trials, emissions from the stacks had never been = monitored=20 and that the stacks had not been closed. 19

6. Health = effects

The health effects of particulates, heavy metals and dioxins = are well=20 known. Recent evidence suggests that around 10,000 people in = England and=20 Wales die prematurely each year from respiratory and heart = conditions=20 because of the effect of fine particulates. Metals and dioxins are = bioaccumulative and their ill effects can take a long time to = become=20 apparent as they build up in the body . These toxins are = often=20 carried on the particulates. Cadmium may cause lung and kidney = disease,=20 and mercury, which is volatile so escapes in the flue gas, can = affect the=20 nervous system. Chromium and nickel are carcinogenic; no safe = ambient=20 level in air has been recommended by the World Health = Organisation.20

Dioxins are extremely toxic and the World Health Organisation = has=20 recently classed the most toxic one as a known human carcinogen.21 Findings by the US = Environment=20 Protection Agency (EPA ) indicate that at much lower levels = they=20 may have effects on the immune system, on reproductive processes = and on=20 foetal development.22 The tolerable daily intake = (TDI) for=20 dioxins in the USA has now been set 100 times lower than the = official UK=20 level.23

Neither emissions from cement kilns nor their potential local=20 environmental and health effects have been adequately investigated = in the=20 UK. This is of particular concern in view not only of the = concentration of=20 long lived pollutants emitted but also of their far greater mass = compared=20 to plants such as incinerators. The Environment Select Committee = in 1997=20 repeated their 1995 recommendation that a long term human health = study=20 should be carried out into the health effects of cement kiln = emissions.=20 The Department of the Environment replied to the Committee's = original=20 recommendation in only four lines, saying merely that a MAFF study = had=20 found no additional health effects from burning SLF compared to = burning=20 coal.24

A pilot respiratory study in Ribblesdale found significant = increases in=20 ill-health among children in schools near the kiln compared to = those out=20 of the area.25 The Acer report, considering = the=20 overall=20

emissions from Ribblesdale, states that =93it is unreasonable = to conclude=20 that there is no significant risk or problem for local = residents.=94

7. Pollution control equipment

Cement kilns were = designed,=20 often decades ago, to make cement, not to burn waste solvents. = Their=20 design is unable to guarantee the same level of complete = combustion that=20 would be achieved in a purpose built incinerator. There is = evidence that=20 high temperatures cannot be maintained throughout a cement kiln, = that=20 turbulence in the kiln may give rise to pockets of incomplete = combustion,=20 and that the level of excess oxygen is inadequate.

In fact the need to have sufficient oxygen for efficient = combustion is=20 at odds with the atmospheric requirements for good quality = cement.26 Significantly, the new EU = Directive=20 (see section 11 .) which will affect the burning of=20 hazardous wastes in kilns exempts kilns burning wastes at 40% or = less=20 contribution to heat value from the need to have a minimum 6% = oxygen=20 atmosphere. This seems to recognise that low oxygen and thus poor=20 combustion is a feature of cement kilns.27

The absence of systems in cement kilns for rapid quenching of = emissions=20 also provides an environment that encourages formation of dioxins. =

Kilns are regularly prone to =93upsets=94 or = =93trips=94 as carbon=20 monoxide builds up and the precipitator particulate traps, which = in any=20 case do not capture all of the particulates, open automatically to = prevent=20 an explosion in the kiln. This releases large amounts of = particulates and=20 other pollutants. Dr Michael Richard, Professor of Environmental = Health at=20 Colorado State University, states :
=93Simply cement kilns do = not have=20 the necessary reliability and safeguards to ensure 100% = destruction of=20 hazardous wastes.=94

8. How do we know what is in the waste?

The specification of acceptable levels of halogens = and heavy=20 metals in the wastes is another area of concern. Halogens = including=20 chlorine lead to increased dioxin formation. The chloride level = alone of=20 UK fuels varies from 2 to 7%, much higher than in Sweden where the = maximum=20 halogen content allowed is 0.5%.28 The Environment Agency's = revised=20 Guidance Note for Inspectors says merely that they should = =93consider the=20 need =94 to set limits in the authorisation on individual = constituents of=20 the fuel content such as =93 sulphur, PCBs, chlorine and = metals=94.29 A Cemfuel batch was found to = have=20 greatly exceeded its specification at Ribblesdale in June 1996.30

Pollutant Actual Permitted
Antimony 208 mg/kg 50 mg/kg
Copper 787 mg/kg = 600 mg/kg
Sulphur 0.51 % 0.30%=20

The heavy metal content of = coal is=20 considerably lower for most metals than the current specifications = for=20 waste fuels in UK kilns.31 In Switzerland the metal = levels cannot=20 exceed those of coal .32

9. Plume grounding

In addition to the general pollution problems from cement = kilns,=20 some communities especially in Ribblesdale are inflicted with = appalling=20 air and visual pollution when the plume from a chimney literally = comes=20 down to the ground. It has been compared by one resident to = breathing in =93=20 aerial sludge=94.

Castle Cement has proposed a sulphur dioxide wet scrubber for = one of=20 their kilns=20

which no longer burns Cemfuel as the solution to the problem of = plume=20 grounding at Clitheroe. However, local opponents do not believe = that this=20 will solve the problem, and say that it distracts from the fact = that the=20 two other kilns which do burn Cemfuel also display plume = grounding.33 The Environment Agency = recently=20 admitted that this is the case.34 Furthermore Castle = Cement=20 announced, in a recent Application, their intention to burn = Cemfuel and=20 other solid wastes once the scrubber has been fitted.35

10. Burning tyres

Some cement kilns are now investigating the burning of = tyres in=20 kilns; there have been trials at four UK works so far. Particular=20 controversy has been caused at Blue Circle's Westbury plant, where = local=20 pressure has led to the withdrawal of the company's application = after two=20 trial burns. However, Blue Circle will seek permission to burn = again under=20 new conditions. Dioxins increased significantly during its last = trial.36 Tests of tyre burning at four = California kilns showed the following emission increases compared = with=20 coal 37:

Dioxins: 53% - 100% in 4/4 tests
PAHs*: 296% - 2230% in 3/4=20 tests
Lead: 59% - 475% in 3/4 tests
Chromium: 727% in 1/3 = tests=20
(* Polycyclic Aromatic Hydrocarbons - many are=20 carcinogenic.)

A German study of a Belgian cement=20 kiln
burning tyres found significant increases of zinc and lead = input=20 to the kiln and between a two and five fold increase in dioxin = emissions.=20 38

11. Will cement manufacturers clean up their act?
- The role = of the=20 Environment Agency

The Environment Agency is = responsible for=20 licensing cement kilns by authorisations under the Environment = Protection=20 Act (1990) through the IPC regime which came into force in 1993.39

The ease with which the cement industry was allowed to adapt an = established production process to act as a de facto waste = incinerator=20 technology has exposed startling weaknesses in overall = environmental=20 policing and regulation. The role of the Environment Agency has = been put=20 to the test and found wanting.

In its Supplementary Evidence to the Environment Committee = 1997, five=20 years after kilns started burning waste derived fuels, the = Environment=20 Agency stated that it is =93initiating a research programme to = look at the=20 whole issue of chemical wastes with a view to identifying which = wastes are=20 suitable for incineration, for cement kiln use and landfill. =94 = In other=20 words the Agency admits that it and HMIP allowed these wastes to = be burned=20 in cement kilns for years without knowing whether or not they = should have=20 been!

The policing role of the Environment Agency has been = overshadowed by=20 its remarkable sympathy for the supposed financial plight of the = cement=20 industry. The Agency is clearly not taking a decisive lead in = regulation;=20 in its revised 1996 Guidance Note the Agency has accepted the = arguments of=20 the cement industry that it cannot afford major environmental=20 improvements:40
=93Any further investment = in=20 environmental projects could reduce the return on investment to = levels=20 further below the rate of return required by=20 shareholders=94.

The Department of the Environment = has also=20 expressed its concern =93that the industry should be able to = compete=20 effectively in international markets=94 and clearly implies that = this can=20 only be done by burning SLF.41
Stricter regulation of the = burning=20 of SLF by cement kilns will come through the EU Hazardous Waste=20 Incineration Directive, which states that all cement kilns burning = SLF of=20 more than 40% heat value contribution must conform to the same = emission=20 standards as proper hazardous waste incinerators (see table = below). Kilns=20 burning SLF with less calorific value have looser limits, = calculated in=20 proportion to the heat value of SLF they are burning. There is = debate=20 about how workable this aspect of the Directive will be in = practice.

Unfortunately this Directive currently applies only to new = kilns - it=20 will apply to all kilns from 2000.

Emission limits under the EU Hazardous Waste = Incineration=20 Directive compared with current authorisations for a cement kiln = burning=20 hazardous waste

Pollutant
(all in = mg/m3) 		Directive = Castle=20 Cement
(Ribblesdale)
Particulate matter 10 90/100
NOx no limit 800
SOx 50 2300
CO 50 no limit
HCl 10 no limit
HF 1 no limit
TOC 10 no limit
Dioxins/furans* 0.1 ng/m3 1ng/m3
Cadmium/Thallium total 0.05 0.1
Mercury 0.05 0.1
Group 3 Metals 0.5 1=20

Source: Directive = and=20 Ribblesdale authorisation * Dioxins are measured in=20 nanograms

12. Company finances

Blue Circle Cement

In 1995 Blue Circle Cement made an operating profit of =A365.3 = million=20 and states in the Blue Circle Industries annual report that =93 = the focus=20 will be to continue to reduce costs=94. =93Considerable savings = have been made=20 in recent years in the area of fuel kiln costs =94 and = =93..improvements=20 achieved at Westbury were highlighted in the HMIP Annual report=20 (1994/1995)=94. However, this HMIP report refers to an odour = problem, which=20 Blue Circle's annual report ignores.

The 1995/1996 HMIP report states that there have been = allegations of=20 respiratory problems and that an asthma study was carried out, = whilst Blue=20 Circle reports its =93environmentally responsible use of recycled = fuels=20 thereby recovering energy from=20

materials which would otherwise be wasted.=94

The annual report did not, however, inform shareholders that = there had=20 been a Select Committee inquiry into the use of SLF, nor that = there were=20 continuing local concerns about emissions not only at Westbury but = also at=20 Weardale and Claydon.

Ian McKenzie , Chief Executive of Blue Circle Cement told the=20 Environment Select Committee that the industry was pursuing the = burning of=20 wastes =93to achieve financial gain=94. He referred to pollution = control=20 equipment capable of meeting the standards of the new EU Hazardous = Waste=20 Incineration Directive as being of =93questionable benefit=94 for = his=20 industry.

The British Cement Association, however, wants the industry to = burn=20 wastes at up to 80% heat value while Ian McKenzie for Blue Circle = said=20 that =93 it is certainly not in our minds nor in our discussions = with the=20 Environment Agency .....that we would need to align with the=20 ....Directive.=9442 It seems the industry expects = to burn=20 what it likes until the year 2000, when the Directive affects = it.

However the annual report declares of a separate company : = =93Blue Circle=20 Waste Management 's [three] incinerators made significant = improvements in=20 1995. All are operating to the stringent environmental standards = required=20 as a result of new legislation.=94

Rugby Cement

Rugby Cement made a profit of =A319 million in 1995 and = referred to=20 =93outdated production capacity=94 at Southam which is due to = close and to=20 =93old and relatively inefficient works =94. The new plant at = Rugby =93will=20 achieve a high level of environmental performance=94. The = company's=20 environmental policy is to: =93minimise the use of unsustainable = materials=20 and energy , the production of waste and the impact of operations = on the=20 environment.=94

Castle Cement

Castle Cement made a profit of =A38.7 million in 1995, up from = =A32.5=20 million in 1994. There are no environmental statements in the = annual=20 report. However the company told the Environment Committee that it = was the=20 first cement manufacturer to produce an environmental policy for = all=20 operations. In 1996 Castle Cement made a profit of =A311 million = and an=20 operational saving of =A31.5 million by using Cemfuel. A recent = public=20 statement by Ian Sutheran, the Ribblesdale manager, mentioned that = =93whatever fuels are burned in future=94 must meet three = criteria. In=20 sequence these were ; first that they must help to contain = production=20 costs, second that cement quality must be maintained. The health = of=20 employees and neighbours came third.

13. The planning issue - cement companies find a loophole in = the law=20

Another cause of indignation is the way in which cement=20 manufacturers have skirted the need for planning permission which = would=20 apply to any new incinerator wanting to burn waste. Although they = have=20 changed their fuel in what the Environment Agency now recognises = is a=20 =93substantial change of use=94 they have escaped the full public = enquiry and=20 environmental impact assessment which this should imply. Simply by = being=20 there already cement kilns are able to burn wastes in areas where=20 incinerators would be unlikely to receive permission.

Durham County Council has required Blue Circle and Redland = to seek=20 planning permission for their sites; this will be an important = test of the=20 legislation. Flintshire has also requested planning permission = from Castle=20 Cement at Padeswood. Derbyshire=20

has yet to decide over the Redland site at Whitwell. Judicial = reviews=20 are being brought on behalf of aggrieved individuals over five of = the=20 sites. Cambridgeshire has called upon the Association of County = Councils=20 to lobby the Government to require that planning permission is = mandatory=20 for cement kilns changing to waste burning. Lancashire has taken = the view=20 that planning permission is not required from Castle Cement, and a = judicial review of this decision is also planned. 43

The = Government's own=20 publications indicate that these liquid fuels are both hazardous = and=20 special wastes. Therefore the process of burning them in cement = kilns is=20 one of waste disposal. However, even though the Government and the = Environment Agency accept that these substances are wastes they = have=20 repeatedly shirked responsibility by stating that =93only the = courts can=20 decide the issue=94.44

14. What standards = are there=20 in other countries ?

The Netherlands

Holland has only one kiln which has a permit to burn rubber = chips. This=20 kiln must burn to much tighter limits for most pollutants in the = whole=20 flue gas than apply to UK cement kilns burning waste. The dioxin = limit for=20 the cement kiln is ten times more stringent and the cadmium and = mercury=20 limits are twice as restrictive. Hydrogen fluoride and chloride = are=20 controlled to Directive standards. In a new permit to be issued = later in=20 1997, controls for carbon monoxide, volatile organic compounds = (VOCs) and=20 polyaromatic hydrocarbons (PAHs) will be introduced while most UK = kilns=20 burning wastes do not even have limits for these gases. Sulphur = dioxide,=20 nitrogen oxides and particulate controls are also tighter than for = most UK=20 kilns. Furthermore the Netherlands Environment Minister expressed=20 confidence in 1995 that the provincial regulatory authority will = apply=20 Dutch incinerator limits to the kiln. This would make the controls = twice=20 as tight as the EU Hazardous Waste Incineration Directive for=20 particulates. 45

Germany

Cement kilns are regulated in a similar way
to the Directive = so that=20 the waste fraction of fuel has identical emission limits to new=20 incinerators. These already include limits for carbon monoxide and = VOCs.=20 The sulphur dioxide and particulate limits for the whole flue gas = are more=20 stringent than for many UK kilns, whether burning wastes or not. = 46

New cement kilns in Germany can achieve 5 mg/m3=20 particulates compared to the 40 mg/m3 set by the = Environment=20 Agency as a benchmark for new kilns in the UK.47 The Select Committee was told = by the=20 Environment Agency that the UK approach was =93 not less = stringent=94 than=20 that of Germany but the Agency did not explain how this was the = case.

Norway

The two Norwegian kilns are already regulated in line with the=20 Directive, and even when not burning wastes their licence limits = their=20 emission of particulates and especially sulphur dioxide to levels = which=20 are lower than for most UK kilns. 48

15. The 1997 = Environment=20 Select Committee report - what now for the Environment Agency = ?

The Environment Committee has now reported for the second time = on the=20 burning of hazardous wastes in cement kilns, and severely = criticised the=20 Environment Agency. The Committee called the Environment=20

Agency =93inefficient=94 and =93inconsistent=94 and said that = it had failed to=20 develop coherent policies and apply them rigorously to the cement=20 industry. The MPs found =93serious inadequacies=94 in the = monitoring of=20 pollutants and recommended that all assessments should in future = be based=20 on sound science. The Committee castigated the Agency's = inspectors, saying=20 that they should make more unannounced visits and =93should not=20 automatically believe what they are told by the industry=94.

The Environment Committee also repeated its 1995 recommendation = that a=20 long term health impact study be carried out and recommended that = the=20 burning of any new fuel should not go ahead until a national = regulatory=20 policy for each type of fuel has been drawn up at Director level = of the=20 Environment Agency .49 The need for such a halt is = underlined=20 by the granting of permission to Blue Circle for trial burning of = SLF at=20 Claydon and to Rugby Cement for permanent burning of Dycal at = Southam=20 shortly before the Committee's report was published.

The Agency and the Government have been asked to respond = quickly to the=20 report. However, the Government took one year to reply to the 1995 = inquiry=20 recommendations, and rejected many of them. Will the Agency = continue to=20 act as an industry lap dog or will it develop teeth? =

The=20 Environment Agency now admits that it has important challenges = ahead and=20 promises that it will be =93developing expertise=94 and new = policies.50 The urgent need is for the = Agency to=20 draw a clear line over a history of regulatory inadequacy and = unscientific=20 muddle.

16. The way forward

In the light of the Environment Agency's record Friends of the = Earth is=20 now calling for much tougher and more decisive action. Friends of = the=20 Earth gave evidence to both of the Environment Committee's = inquiries (in=20 1995 and 1997), and while it welcomes many of the Committee's = criticisms=20 of the Environment Agency and some of its recommendations, Friends = of the=20 Earth does not accept that burning hazardous wastes in cement = kilns =93can=20 have positive benefits for the environment =94. 51

It is not acceptable to permit these wastes to be burned while=20 communities wait for health studies to be commissioned, and cement = kilns=20 continue to operate without the best pollution control = equipment.

Friends of the Earth is calling for an immediate halt to the = burning of=20 all wastes in cement kilns while detailed health impact studies = are=20 carried out while conventional fuels are burned. Friends of the = Earth=20 believes meanwhile that the only way in which public confidence in = the=20 regulation of the cement and other polluting industries can be = restored is=20 if there is an independent enquiry by a body such as the = Royal=20 Commission on Environmental Pollution into the Environment = Agency's=20 handling of the industry.

The inquiry's remit should include an investigation of = pollution=20 monitoring, site visits, company prosecution records , maintenance = of=20 public registers and the involvement of local communities in = decision=20 making. The people suffering at the hands of the cement companies = deserve=20 no less.

Echoing the Environment Committee's press statement, Friends of = the=20 Earth does not wish to have to give evidence to a third = Select=20 Committee inquiry into the cement industry as a result of the = continuing=20 failure of the Environment Agency to carry out its proper=20 function.
17. Further Reading

Up in Smoke .Why Friends of the Earth opposes = incineration ,=20 FOE Briefing Sheet, February 1997 . =A30.50

Planning Campaigns, FOE Local Groups Briefing Sheet, June = 1994

Using your right to know, FOE Local Groups Briefing Sheet, June = 1994

Environment Committee, Third Report,
The Environmental = Impact of=20 Cement Manufacture, Stationery Office, March 1997, =A312.50

Environment Committee, Third Report, The Environmental Impact = of Cement=20 Manufacture, Minutes of Evidence and Appendices , = Stationery=20 Office, March 1997, =A319.50

FOE priced=20 publications can be ordered from Publications Despatch , Friends = of the=20 Earth 56-58 Alma St, Luton, LU1 2PH

Local Group briefings are free to local campaigners only and = available from Margaret Hook at the London office of Friends of = the=20 Earth.

Written by Mick O'Connell, April = 1997
Enquiries to Dr.=20 Michael Warhurst

Published by Friends of the Earth Ltd

Friends = of the=20 Earth, England Wales and Northern Ireland
26-28 Underwood = St
London=20 N1 7JQ
Tel : 020 7490 1555
Fax: 020 7490 0881 =
Email:=20 info@foe.co.uk
Printed on 100% recycled=20 paper.
References


Copyright =A9 Friends of the Earth | Contact Us |=20 Support=20 Friends of the=20 Earth

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1.British Cement Association = (BCA),=20 Cement Manufacture and the Environment (1995)
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2. BCA evidence, Environment = Committee,=20 Third Report , The Environmental Impact of Cement Manufacture , 1997
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3. BCA , Minutes of Evidence,=20 Environment Committee, 1997
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4. BCA Minutes of Evidence, = Environment=20 Committee, 1997
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5. ERA Ltd and CMR Ltd, = Minutes of=20 Evidence , Environment Committee, 1997
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6. Appendices to op cit, ENDS = 250,252,=20 255, 263, and communications with Environment Agency
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7. Castle Cement Cemfuel = Report sheets=20 distributed in Padeswood. Communication with Environment Agency April = 1997
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8. Castle Cement , Application = for=20 Variation
Ribblesdale Works A6044, p 2 , 20.12.1996
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9. Statement from Ian Sutheran = , General=20 Manager at Ribblesdale Works read out at public meeting , Clitheroe = Grammar=20 School March 14 1997
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10. Hansard Mar 20 1996
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11. ENDS p 10, November 1994 =
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12. Review of IPC = Authorisation and=20 Variations, Castle Cement, Ribblesdale, Acer Environmental Ltd, May 1996 =
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13. Rachel' s Hazardous Waste = News,=20
28.3.1990
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14. ENDS p 14, Dec 1996
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15. Gibb Environmental Survey = on Public=20 Register, November 1994
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16. Calculated from data = submitted with=20 Redland Aggregates application for permanent authorisation 1996. = Environment=20 Agency variation granted AU8504
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17. ENDS Oct 1994, p 12, and = Minutes of=20 Evidence CAMAIR, Environment Committee , 1997.
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18. Environment Agency Minutes of Evidence, op cit
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19. ENDS , p 14, Dec 1996 =
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20. World Health = Organisation, Air=20 Quality Guidelines, 1987
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21. ENDS, p7, Feb 1997
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22. Draft chapter on dioxin = risk=20 assessment US EPA , May 1994
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23. ENDS, p3, April 1996
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24. DoE Minutes of Evidence , = Environment Committee, 1997
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25. S. Ginns, Minutes of = Evidence, op=20 cit
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26. 1. David B Kopel, = Environmental Law=20 Reporter, 4, 1993. 2. EW Kleppinger, Folly or Redemption? Can cement = kilns=20 really do the job?, Air & Waste Management Association, Clearwater, = Florida=20 2.3.1993.
3. Letter to Director of EPA from coalition of US citizen = groups=20 16.1.1995
4. Citizens Briefing Book on Cement Kiln Incineration of = Hazardous=20 Wastes in Texas
prepared for Texas Air Control Board Policy Task = Force,=20 20.11.1992. 5. Paul Connett, Professor of Chemistry, St Lawrence = University New=20 York , Air Watch public
meeting ,Clitheroe, March 23 1997
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27. EU Hazardous Waste = Incineration=20 Directive 94/67, Article 3, Article 6.2.
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28. Communication with Per = Junker, a=20 director at SNV, the Swedish official environmental body
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29. Environment Agency, IPC = Guidance=20 Note S2. 301. Cement manufacture, lime manufacture. , Sept 1996
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30. Environment Committee = Report,=20 1997
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31. National Alliance for = Cleaner Kilns=20 data submitted op cit , Annexe 1 Table 22
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32. Environment Agency = Minutes of=20 Evidence , op cit
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33. ENDS , p6, May 1996
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34. Environment Agency = Minutes of=20 Evidence, Environment Committee 1997
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35. Castle Cement Application = for=20 Variation
A 6044, p 2, 20.12 1966
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36. Tyre burning trial = data No. 2,=20 Blue Circle Westbury, October/November 1996
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37. Seymour Schwartz et al, = Domestic=20 Markets for California's Used and Waste Tires, University of California, = October=20 1996
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38. L. Lhose, Critique on the = Environmental Assessment on the Lixhe Dry Cement Kiln, Wallony, Belgium. = Oekopol=20 Institut, Hamburg, 1996
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39. Environment Committee , = Second=20 Report, The Burning of Secondary Liquid Fuels in Cement Kilns , 1995
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40. ENDS , p32-, October 1996 =
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41. DoE Minutes of Evidence,=20 Environment Committee 1997
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42. Blue Circle & BCA = Minutes of=20 Evidence, op cit
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43. Phil Shiner, Appendix = Minutes of=20 Evidence , Environment Committee, 1997
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44. DoE Minutes of Evidence,=20 Environment Committee, 1997, DoE Circular 11/94 2.45
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45. Permit for ENCI kiln = 1996, Permit=20 office in Provincie Limburg, Communication with NGO Waste & = Environment,=20 Netherlands
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46. Federal Ministry of = Environment=20 Seventeenth Ordinance =9317.Bim.SchVO=94 1990, Technical Instructions on = Air Quality=20 Control, 1986
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47. L. Lhose, Critique on the = Environmental Assessment on the Lixhe Dry Cement Kiln, Wallony, Belgium. = Oekopol=20 Institut, Hamburg, 1996
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48. Letter from Tor Faerden, = Norwegian=20 Pollution Control Authority, March 9, 1997.
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49. Environment Committee = Report,=20 1997
return to text
50. Environment Agency Press = release=20 March 6 1997
return to text
51. Environment Committee = Press Notice=20 March 5 1997=20

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