Burning Waste in Kilns in the United Kingdom
A Comparison of Regulations in the United Kingdom
versus the United States EPA Regulations

David Constans

Gossman Consulting, Inc.

Presented at the AWMA International Specialty Conference on Waste Combustion in Boilers and Industrial Furnaces April, 1994

ABSTRACT

The paper discusses the general format of environmental regulations in the United Kingdom and how these regulations are being applied to kilns burning hazardous waste fuel. This includes a comparison to the application of the USEPA BIF regulations.

Such topics as facility design requirements, insurance reviews and requirements, overlapping regulatory authorities, environmental testing and methods, baseline emissions versus waste fuel burning emissions restrictions, other operating restrictions, environmental authorities' concerns, and public involvements are discussed. An assessment of the level of environmental regulations for burning hazardous waste fuel in cement kilns in the United Kingdom is provided in comparison with the current BIF regulations.

INTRODUCTION

It is not the intent of this paper to present a guidance document on how to acquire a permit to use hazardous waste fuel (HWF) in cement kilns in the United Kingdom, but rather to illustrate the approach the U.K. has taken in regulating this activity in comparison to current U.S. regulations.

At the present time there are only two cement kilns in the United Kingdom that are utilizing hazardous waste fuel (HWF). Castle cement began using HWF in 1992, and Rugby cement commenced HWF use at one facility in late 1993.

Although using HWF in kilns is fairly new to the United Kingdom, the industry and the regulators were certainly aware of it from successful HWF programs in other countries. Norway, France, Belgium and the United States are just a few of the countries now using HWF.

The current method of disposal of flammable liquid waste in the U.K. is by incineration in purpose-built incinerators. There are about 60 "in-house" incinerators and four commercial incinerators. The commercial incinerators currently dispose of approximately 100,000 metric tons per year, or about two and one-half million U.S. gallons. There is also a large amount of hazardous material, including flammable liquids, that are disposed of in land fills, the U.K. does not currently have a "land ban" standard.

OVERVIEW OF REGULATORY AUTHORITIES

Table 1 is a list of the regulatory authorities that are involved in regulating HWF use in cement kilns in England and Wales. There are minor differences in names and responsibilities for similar agencies in Scotland and Northern Ireland, for the most part, however this is a representative overview. These groups are already involved in the regulation of cement production facilities, so the various aspects of HWF use is regulated by the same agencies. The list starts with the most local to the least local, although submittal of forms or information may not be executed in this order.

• The first item is company policy requirements. This is the familiar feasibility study including technical feasibility through economic justification. Such requirements as Hazop studies (a step by step "what if" review of a hazardous operation) are involved to satisfy insurance carriers.
• Submitting a basic fire response plan to the local fire brigade normally follows the issuance of permission from the various agencies. This is similar to the communication requirements of Subpart D in 264.
• The County Council issues licenses for such things as flammable liquid unloading stations, landfills and administrates waste regulations. The County Council is often the "lead agency" in regulation of industry and to a certain extent can be compared to States. It is not unusual for the local office of the Health and Safety Executive to be located in the same office building. Public involvement in facility siting would normally be manifested through the Council members.
• The Health and Safety Executive (HSE) is similar to OSHA. The HSE may request that a Hazop study be conducted if one had not already been performed.
• The National Rivers Authority executes programs similar to the EPA and State water protection programs.
• Her Majesty's Inspectorate of Pollution (HMIP) sets emissions standards and monitors compliance. The HMIP is comparable to State and Federal permit programs. The HMIP administrates an Integrated Pollution Control program for large companies that would have multiple sites or industries with similar facilities. Consequently HMIP may act as an advisor to the County Council or the National Rivers Authority or directly administrate a program. Additionally the HMIP can specify an emission limit for a particular facility that is higher or lower than the prevailing standard without being subjected to the "rule making" requirements State agencies or the EPA must follow. Unlike the USEPA the HMIP will initiate and contract for their own stack emissions testing as well as requiring the facility to do so.
• The EEC is to establish a set of emissions standards that are to be met by the member nations. These standards are still evolving. The simplest comparison to the U.S. would be federal standards executed by individual states.

Based on this overview comparison, it would be expected that acquiring permission to burn HWF in the United Kingdom would be as difficult as it is in the United States. This, however, is not the case.

Gossman Consulting, Inc. (GCI) assisted Rugby Cement and Organic Technologies, Ltd. in acquiring permission to burn HWF in a cement kiln. It took only five months from the first meeting with the authorities to actual consumption of HWF in the kiln. The differences in approach are telling. The current policy views the use of HWF, provided it is compounded and delivered to the cement kiln facility in conformance to a "product specification", as a secondary fuel not as a waste. The authorities are much less confrontational. Discussions are held without legal council present. The standards are technology based, rather than health based. Consequently, there is less discussion about what is and is not satisfactory compliance. The regulatory personnel are experienced and professional. This is reflected in their understanding of the current and proposed activities and in the questions they ask. Local resistance was minimal - mainly concerned with restricting the transportation of HWF to daylight hours. In all, the process proceeded quickly, dealing with real issues in a realistic manner.

EMISSION STANDARDS

Table 2 is a comparison of current new facility incinerator emission standards in the U.K. (based on the draft EEC directive on Hazardous Waste Incineration) versus the current U.S. BIF and Incinerator standards. Since the British standard is technology based and uses different standard conditions and correction factors than those used in the United States it is difficult to make direct comparisons of the two standards. There are a number of differences that are readily apparent in an examination of Table 2. The most notable of these is the choice of metals and how the metals limits are determined, and the use of the 11% oxygen correction. The 11% oxygen correction will yield a lower emission concentration (by about one third) than the 7% oxygen concentration. When applied to an emission limit, the limit would allow about one third greater emissions than the same value at 7% oxygen.

These emission standards are for "in-house" and "merchant " incinerators built or "substantially changed" after April 1, 1991. At the present time there are no specific emission standards for cement kilns. However kilns are covered under the present regulation as an "Alternative Disposal Route" with the Chief Inspector's Guidance to Inspectors stating: "If chemical wastes were incinerated in such plants, the release limits in this Note should apply to the portion of the exhaust gases attributable to the burning of the waste." Under such a concept using HWF for 30% of the fuel to the kiln would require that 30% of the exhaust gases meet the emission standard. Based on experiences in the U.S. during the BIF Testing it is obvious that the source of fuel for a cement kiln has little impact on cement kiln emissions. Consequently, although there is an emission standard, it is accepted that it is not applicable in its present form. In its letter of authorization the HMIP acknowledged that the draft EEC Directive on Hazardous Waste complicated the issue. The issue was left open, however, by viewing the operation as "merely the use of an alternative fuel" that "will no doubt be resolving this on a national level". The HMIP's focus has become an examination of whether or not the use of this alternative fuel increases stack emissions. To that end baseline and alternate fuel use emission tests were required and subsequently conducted.

EMISSION TESTING

The HMIP's testing requirements are straight forward. Compare an analysis of stack emissions from an alternate fuel test, at 20 - 25% heat replacement, with emissions from a primary fuel test and demonstrate that there are no increases in emissions due to the use of the alternate fuel. This was to be done without "spiking" additional metals into the kiln and at normal operating conditions. There were no requirements to establish operating limits such as minimum or maximum temperatures, a maximum gas velocity or raw feed rate as is required by the BIF regulation. Basically the tests were to confirm that the concept of using HWF as an alternate fuel in a specific kiln did not adversely impact the environment.

Table 3 tabulates the results of these tests for Castle Cement. Not surprisingly the kiln did not achieve the particulate standard. The HCL standard was also exceeded, however the method used to determine the chloride concentration in the flue gas does not account for volatile salts such as ammonium chloride. In all, the values are similar to values from kilns in the U.S. The comparison BIF Test values were taken from a kiln of similar capacity and process type. These values have been expressed in the same units and standard conditions at 11% oxygen as the British standard. Additionally the BIF Test values, though averages of three runs, are the result of the extreme conditions required by BIF. The metals listed were "spiked" to achieve the maximum allowed input levels. The remaining 5 BIF metals were Tier IA metals and their emission rates were not reported in the BIF Test results. The NO_X, SO₂ and the PCDD/PCDF values were taken from a state air permit test report on the same kiln operated at similar conditions.

CONCLUSIONS

The British regulatory authorities have approached the burning of hazardous materials in cement kilns from a very practical view point. They have not viewed this only as an activity that must be regulated but also as the use of an alternate fuel that must be investigated. There are no specific regulations that cover the use of hazardous waste as fuel at the present time. It is hoped that the regulation when enacted will be as intelligently thought out and implemented as the recent experience has indicated is possible.

Bibliography

"Chief Inspector's Guidance to Inspectors", Waste Disposal & Recycling Merchant & In House Chemical Waste Incineration, Process Guidance Note IPR 5/1, HMSO, London, 1990.

Table 1. Overview of Regulating Authorities and Their U.S. Equivalents

ENGLAND and WALES	UNITED STATES
Fire Brigade (Review basic fire response plan.)	City/County/State Laws Subpart D of 264, RCRA
County Council (Issues license for certain activities such as fuel handling and landfills. Is the lead waste regulation authority. Local involvement through Council members.)	State Laws
Health and Safety Executive (Requests Hazop Study. Reviews safety procedures.)	OSHA, MSHA
National Rivers Authority (Siting and discharge to waters.)	EPA, State programs, NPDES, Coast Guard
Her Majesty's Inspectorate of Pollution (Sets emission standards, advises other agencies. Administrates Integrated Pollution Control program.)	EPA and State Air Permits.
EEC Emission Standards for Incinerators (as a draft EEC directive)	Federal BIF and Incinerator Standards

Table 2. Comparison of EEC Incineration Emission Standards Versus USEPA Standards

EEC INCINERATOR STANDARDS	BIF STANDARDS	U.S. INCINERATOR STANDARDS
Standard conditions 0C, 101.3kPa, dry, 11% O2	Standard conditions 68F, 29.92" Hg, dry, 7% O2	Standard conditions 68F, 29.92" Hg, dry,7% O2
CO Daily Average - 50 mg/m3 HRAvg.- 100 mg/m3	CO Based on Tier Level and Testing	CO HRAvg - 100ppm
VOC (as TOC) - 20 mg/m3	VOC Based on Tier Level and Testing	VOC - N/A
Particulate - 20 mg/m3	Particulate - 0.08 g/dscf (167 mg/m3)	Particulate - 0.08 g/dscf (167 mg/m3)
HCl - 10 mg/m3	HCl and Cl2 - Emission limits are based on MEI ground level impact.	HCl and Cl2 - 99% SRE or 4#/Hr., which ever is less stringent.
HF - 2 mg/m3	HF - N/A	HF - N/A
SO2 - 50 mg/m3	SO2 - N/A	SO2 - N/A
NOX (as NO2) - 350 mg/m3	NOX - N/A	NOX - N/A
Dioxins (TEQ by EEC method) - 1 ng/m3	Dioxins (TEQ)* - Emission limits are based on MEI ground level impact.	Dioxins - N/A
Cd + Tl = < 0.1 mg/m3	Metals - As, Sb, Ba, Be, Cd, Cr, Hg, Pb, Ag, and Tl. Emission limits are based on MEI ground level impact.	Metals - N/A
Hg - <0.1 mg/m3
Sb + As + Cr + Co + Cu + Pb + Mn + Ni + Sn + V = <1.0 mg/m3

* Dioxin testing is only required for kilns that exhibit certain conditions. See 40CFR266.104(e).

Table 3. Castle Cement Stack Emission Results

Constituent (all values - mg/m3)	100% Coal	75% Coal 25% HWF	British Incinerator Emission Standard	Comparable Values From BIF Test(1)
Particulate	85.1	56.3	20	42
Sulfur Dioxide	1879	5330	50	205 (2)
Nitrogen Oxides	275	43.7	350	475 (2)
Chlorine	50.6	37.27	10 (as HCl)	HCl + Cl as HCL 18
Fluorine	21.6	16.06	2 (as HF)	N/A
Bromine	5.55	2.11	n/a	N/A
Metals
Cd + Tl	<0.0259	0.00508	<0.1	As 0.0012 Be 0.0002 Cd 0.011 Cr 0.015 Pb 0.185
Hg	<0.0043	<0.00002	<0.1
Sb + As + Cr + Co + Cu + Pb + Mn + Ni + Sn + V	<0.0734	<0.13807	<1.0
Organic Compounds
Dioxins/Furans TEQ(ng/m3)	0.131	0.2005	<1.0	.015 (2)
TOC	19.5	19.3	20	As THC in ppmv 14.5
CO	--	--	D. Avg. - 50 HRA - 100	HRA in ppmv 200

(1) Average COC test values from a kiln of similar capacity corrected to British standard conditions and 11% oxygen.

(2) Average run values taken during state air permit test on the same kiln operated at the same

KEY WORDS

BIF

Cement Kiln

Emissions

Permit Standards

Permitting

United Kingdom