MEPs in the European Parliament's environment committee have reduced the potential for conflict with EU ministers over
new waste incineration rules by watering down proposed stricter emission limits on cement kilns using waste as a fuel.

The committee rejected calls by rapporteur Hans Blokland to tighten a planned limit on nitrogen oxides (NOx) emissions
from all kilns from 800 milligrams per cubic metre (mg/m3) to 500 mg/m3.  They voted instead to apply the limit to new
plants only, despite Mr Blokland's insistence that research published last week showed all kilns could meet the tighter
standard at "very little extra cost."  Environmental groups said the committee had "let the coincinerators off the hook."

Cement kilns, like all plants that "coincinerate" waste, are currently not covered by EU waste incineration standards, and the industry has lobbied strongly against the tighter limits, which in any case are looser than those planned for other types of coincineration plant.  However, MEPs did vote to bring forward by a year, to the start of 2007, the end of weaker limits for particularly polluting "wet-process" kilns, and to reduce a proposed limit on dust emissions from 30 to 15mg/m3.

In other amendments passed today, the committee endorsed new NOx limits for dedicated waste incineration plants, but voted to remove extensive derogations proposed for smaller plants up to 2010 (ENDS Daily 19 January).  It called for emission test measurement conditions to be based on "worst case" scenarios but allowed for reduced frequency monitoring of dioxins and furans when emissions are less than half the maximum permitted level.  MEPs also agreed that firms in the food processing and pulp and paper industries should be exempted from the controls if they coincinerated their waste in situ and recovered the energy.

Follow-up:  European Parliament
 http://www.europarl.eu.int , tel: +32 2 284 2111.  The committee's suggested amendments to the draft incineration
directive will be posted on its website
 http://www.europarl.eu.int/committees/en/default.htm#ENVI
when the meeting finishes tomorrow.

Dioxin emissions from the steel and cement industries and major ozone – depleting emissions from a Teeside chemicals plant – are identified in the latest round of data published in the Environment Agency’s pollution inventory website.  The Agency has improved the quality of data and removed irregularities since the inventory’s launch last year.

The idea of the inventory emerged in the late 1980’s and was inspired by the US Toxics Release Inventory.  The Agency’s version was launched on its website in May 1999 and received more than 2,700 visits in its first week (ENDS Report 292 pp24-27)

The Agency says the inventory continues to be a success – but surprisingly it could not provide information on the number of visitors.  It says the site is widely used by students, residents and environmental groups interested in local emissions.

In July, the Agency added data relating to emissions in 1999, but there is nothing on the website to advertise the fact.  Indeed the inventory is constantly changing and the site gives no indication of how long some of the data have been available.

According to the Agency’s Charlie Corbishley, the range of data reported for 1999 is broadly the same as that for the launch year 1998.  However it has allowed corrections to previous years data and in some cases it is claiming details on the inventory at the time of launch were incorrect.

Some major new dioxin sources have been added including Corus (formerly British Steel) sites at Rotherham and Sheffield.  The two sites both enter the top ten sources, increasing the company’s domination of the league.  Corus now accounts for six of the ten largest dioxin sources with the remaining four being other metal industrial sites.

One significant dioxin source, which may previously have been overlooked, is the cement industry.  According to the 1999 data, the top 30 emission sources consist almost entirely of metals, power station and cement manufacturing sites – the single exception being Sheffield’s troubled municipal waste incinerator.

Castle Cement’s Buckley Works and Rugby Cement’s Ferriby works appear at positions 11 and 12 in the dioxin league – each emitting about 1.5g of dioxin a year, measured as an equivalence (TEQ) of the most toxic dioxin 2,3,7,8 – TCDD. Three other cement works appear in the top 30; Rugby’s Southam Works, Blue Circle’s Hope Works and Castle’s Ribblesdale Works.

Total emissions from the ten largest dioxin emitters declined significantly between 1998 and 1999, but it would be premature to read too much into figures, which still seem likely to change.

In the chemicals sector, meanwhile, Du Pont has achieved a massive reduction in its emissions of nitrous oxide – a significant greenhouse gas- since 1998.  Releases from nylon manufacture at its Teeside works declined from 49,473 tonnes in 1998 to 3,240 tonnes in 1999.  The reduction is equivalent to a 3% cut in the UK’s total greenhouse emissions according to the Agency.

However Du Pont is now under the spotlight relating to another significant release identified in the inventory – methyl bromide, an ozone depleting substance regulated under the Montreal Protocol.  Du Pont’s Sabanci Polyester’s Teeside plant released some 95 tonnes in 1999 – equivalent to a fifth of the UK’s emission from horticulture, where the compound is used as a soil sterilant.

Du Pont pointed to an improvement in the environmental performance of the plant sine 1994 when the business was owned by ICI.  Methyl bromide emissions have declined from 211 tonnes and the company has agreed to a long-term strategy with the Agency to reduce emissions further.

Other information on the ozone –depleting HCFCs is hard to find because of a long-standing error on the database.  Efforts to retrieve data on these compounds fail – despite the fact that ICI continues to be a significant source.  In 1999 ICI released 57 tonnes of HFCs – a three-fold reduction on the previous year - and 2.5 tonnes of HCFCs.  The company is installing an incinerator to stem these releases.

The Agency appears to have resolved inconsistencies in the reporting of releases of traces of toxic compounds such as PCBs, DDT and pesticides.  In 1998 many paper companies appeared to be significant sources of such compounds because they had extrapolated discharge levels from the limits of analytical detection – thereby calculating apparently significant discharges (ENDS Report 292 p.26).

Mr Corbishley said that the situation arose because companies did not follow reporting guidance agreed with the Paper Federation.  Pesticides and trace organics only need to be reported if there is evidence that they are in discharges, he explained.
Companies can use raw material mass balances or emission factors to derive estimates of releases.

The Agency also clarified some issues relating to commercial confidentiality.  Where sites claimed confidentiality last year all data were withheld.  This year only data on particular substances are excluded and viewers are alerted by a warning message.

For a few sites the Agency has also publishes notes which seek to put emissions data in context.  For example data on Sita’s Edmonton waste incinerator are prefixed by a paragraph explaining that £15 million was invested in 1996/97 to upgrade abatement equipment – resulting in large reductions in emissions of dioxins and hydrogen chloride.  The statement will no doubt be appreciated by Sita, which in planning to extend the plant is sensitive to public opinion.

Changes to the scope of the inventory to be announced in the autumn, may go some way to answering criticism from Friends of the Earth, which has said that the inventory is ‘meaningless to everyone except a few boffins’.  It cites the lack of league tables and the absence of health information.  In its own league table FoE highlighted emissions of ‘cancer causing chemicals’ – based on pollution inventory data for compounds, which have been identified as carcinogenic.  Overall FoE’s data show a 25% reduction in such releases from a list of major sites since 1998.

See www.environmentagency.gov.uk
Note:
FoE Report November 2001 lists Castle Padeswood s now the 7th worst dioxin polluter in the UK and STILL the worst polluting cement plant.

The study, by scientists from Belgian universities and the Federal Ministry of Agriculture, is one of the first detailed analyses of the incident and it's aftermath to be made public.

The paper reveals that oil containing 40-50 kilograms of PCBs and one gram of dioxins entered edible oil recycling bins in January 1999.  The bins belonged to Verkest, one of 20 Belgian companies recycling household waste fats and oils for use in animal feed. The fat was delivered to 10 animal feed producers and about 500 tonnes of contaminated feed are believed to have resulted - about 5.5% of national weekly production.

Most of the feed probably went to chicken farms, and the first symptoms were noted in poultry farms in early February. Egg production and hatching declined and chickens began to die in an epidemic of oedema. However, the cause was not recognised and samples of food, meat and eggs were sent for analysis on 18th March. Results showing high levels of dioxins arrived on 26 April and the public were not informed until the 27 May. The Belgian government fell following elections three weeks later.

Although at the time the main contaminant was thought to be dioxins, analyses showed that PCB concentrations exceeded dioxins by 50,000 to one. The PCB pattern was consistent with a mixture of Arochlors - products made by Monsanto - of the kind used in transformer oils.

No systematic sampling of food was carried out during the period of exposure from February-May 1999 and the details of who was exposed and how cannot now be worked out. However, the researchers made some estimates of the likely health impacts based on the available information.

They assumed that some 30% of the PCB contamination was consumed by the 10 million people in Belgium, giving an average PCB dose of 25,000 nanograms per kilogram of body weight. This would increase average body burdens of PCBs by 42% and dioxins by 7%.

Using the available risk assessment data for the carcinogenic effects of PCBs and dioxins, they conclude that the incident would  cause 44 - 8316 cancer deaths. However, they acknowledge "huge uncertainties" because of wide variation in risk assessments and the lack of information on individual doses.

The scientists caution that the incident "probably doubled or tripled the body burdens of selected subpopulations who were intensly exposed to contaminated food." They urge that highly exposed individuals be traced and their health status monitored.

They also point to evidence of non-cancer effects from PCB exposure in babies, infants and children. These include neurological changes, changes in thyroid hormones, changes in the immune system and vitamin K deficiency in new born babies.

The conclusions contrast sharply with a study published by a different group of Belgian academics in September 1999 which found it " very unlikely that the isolated episode of contamination....will cause adverse health effects in the general population." (2).  The study said that the increase in body burdens produced would be at least 100 times lower than those in the notorious Yusho or Seveso incidents where there were acute health impacts.

On this point, the latest study agrees that the exposures in Belgium were relatively low - only 0.5ng/kg expressed as a toxic equivalent (TEQ) of the most toxic dioxin, 2,3,7,8 - TCDD, compared  with 16-78ng/kg TEQ at Seveso. However, the notable feature of the Belgian incident is that millions were exposed rather than only a few thousand.

Another conclusion was that the PCB analyses showed up many instances of PCB food contamination unrelated to the transformer oil incident. "Measures are urgently needed to reduce the overall PCB and dioxin burden for the population," it says, pointing to sources such as fish, vegetable products from countries where DDT is still used, recycled animal fat and any waste fats that may contain mineral oil.

(1) Van Larebeke, et al 2001, Env Health Perspectives, Vol 109, - 265 - 273.

(2) Bernard et al. 1999, Nature, Vol 401, pp 231 - 232

Dr Roberts
Compare this with the bland reassurance given by Dr Richard Roberts in the Conclusion to his original assessment of the likely health impact of the proposed co-incinerator:
'Individuals living in the area of the works are very unlikely to suffer any harmful effects from authorised emissions of any pollutant, including dioxins, from the proposed kiln'
At the very least the huge variation in academic opinion illustrated above serves to show that Dr Roberts could be very, very wrong.

THE HEALTH risks from long-term exposure to particulate air pollution are ten times more significant than those for short-term exposure, according to the Department of Health's Committee on the Medical Effects of Air Pollution (COMEAP).(1) The opinion adds urgency to the pending review of the air quality limit for particulates - a delayed consulation on which is now due in June.

In 1998, COMEAP estimated that short-term air pollution episodes kill up to 24,000 people annually in the UK, and that particulate pollution is responsible for around a third of the deaths. It added that long-term exposure was likely to be even more significant - but, because of the uncertainties involved, it shied away from quantifying the impact (ENDS Report 276, pp 4-5).

Several studies have since clarified the link between particulate pollution and mortality (ENDS Report 307, pp 12 -13).
The new statement from COMEAP draws on this research and on a study by the Institute of Occupational Medicine (IOM) which attempted to quantify the long-term impact on life expectancy (ENDS Report 312, p9).

COMEAP concludes that cutting average annual ambient levels of PM2.5 - particles smaller than 2.5 microns - by 1ug/m3 would increase life expectancy across the UK population by around 0.2 - 0.5 million life-years, or 1.5 - 3.5 days per person. The projections are linear - implying that a 10ug/m3 reduction in concentrations would increase life expectancy by 2-5 million life-years.

But these figures are towards the low end of possible scenarios. The Committee's highest estimate is around an order of magnitude greater.

The Committee is at pains to point out that not everyone is affected by the pollution. "We know that this effect does not apply equally to all of us," said Professor Robert Maynard, medical secretary of COMEAP, at the launch of the report.
Susceptible individuals could see far more significant impacts.

He also pointed out that the figures are far from certain. The lack of long-term cohort studies in the UK forced COMEAP to base it's estimates on US data which may not be transferable to Europe. Studies are now under way in France and the Netherlands.

The long-term effects of particulates relate particularly to heart disease. One theory is that they interfere with the nervous system's control of heart rhythm, and cause inflammation of the arteries. In May, the British Heart Foundation announced a £182,000 project to examine the links between air pollution and heart disease - filling part of the gap left when the Department of Health axed research on air pollution (ENDS REport 309, pp 9-10).

Environment Minister Michael Meacher welcomed the new report. "COMEAP's conclusion that long-term air pollution does substantially impact health is a very important finding in terms of future policy," he said. The long-awaited consultation on a new air quality objective for particles will begin in June, he added.

Average concentrations of PM10 are around 20ug/m3. The statutory objective is currently 40ug/m3 expressed as an annual means, and 50ug/m3 as a daily mean with 35 permitted annual exceedences (ENDS Report 300, pp37-38).

The new objective may well not be in force in time for the second round of reviews and assessments under the local air quality management (LAQM) regime, due by the end of 2003.

Mr Meacher also took the unusual step of naming the 32 local authorities which have yet to complete their reviews and assessments. The initial dealine for this work was the end of 1999, but this has slipped repeatedly.

In March, the Minister signalled his frustration with the slow progress by writing to all authorities whose assessments were outstanding, and demanding to know why they had not completed the exercise. The Environment Act 1995 gives him powers to direct authorities to take action if he believes they are not meeting their duties, but the deadlines are not statutory and Mr Meacher's naming and shaming suggests that he is reluctant to follow this course.

The National Society for Clean Air has produced new guidlines to help authorities produce air quality action plans. (2)ENDS

(1)    Statement and report on long-term effects of particles on mortality, available on Documents at endsreport.com
(2)    NSCA air quality action plan guidance, available at www.uwe.ac.uk/aqm/centre/AQMAs/aqaps.html

Guidance on the application process for cement companies wanting to burn tyres in kilns has been published for consultation by the Environment Agency. But while it sets considerable store by companies consulting the public, it provides few details on how this should be done.

The UK consumes some 450,000 tonnes of tyres per year, 30% of which are disposed of in landfills. The practice is to be banned by the EC landfill directive, by 2003 for whole tyres and 2006 for shredded, although the UK intends to exploit a loophole in the Directive which will put this back to 2009 in the case of "existing" landfill sites (ENDS Report 310, pp16-17).

The Agency is actively encouraging alternative disposal routes for tyres, such as incineration in cement kilns. It says that tyres have a "net environmental benefit" over fossil fuels such as coal or petcoke.

The aim of the guidance is to streamline the permitting process, which can currently take as long as two years. Tyres are burnt at two sites run by Castle and Blue Circle, with trials ongoing at three other Blue Circle sites (ENDS Report 309, p18).

Mindful of public reaction, the Agency is emphasising the need for companies to conduct early and effective public consultation. This should help identify the "critical success factors" (CSFs) - specific factors or benchmarks by which the success of a trial may be judged.

But the guidance does not define what these CSFs might be, or how the Agency expects companies to consult the public. Neither does it give companies any idea on what level of consultation will satisfy the Agency's requirements.

Neil Davies, leading the Agency's work on the protocol, said that the CSF concept was deliberately left "very broad and general". "We want to encourage companies to engage the public, to draw out issues of concern."

CSFs could range from simple emission limits and management techniques, to public concerns over health effects, he added. Companies would then be expected to address any public issues in their subsequent applications.

The Agency could insist on extended public consultation on applications, and companies will be expected to keep local people informed of progress throughout the trials. After a trial, a decision on permitting the continuous use of tyres should take only eight weeks.

The Agency is on more familiar ground with it's ample technical guidance on aspects of designing a tyre burning trial. This includes the specification and handling of tyres, monitoring arrangements and reporting requirements.

The British Cement Association (BCA) is to draft a code of conduct for the industry. But despite the Agency's desire that the industry should seize the initiative, progress on the code has been slow. The signs are that a minimalist approach is being taken.

The BCA's David Pocklington said that he did not want a prescriptive code but a "shopping list" of principles for companies to apply in a case by case basis.

The consultation closes on 31 July 2001.ENDS

(1) Consultation on a tyres protocol for use on cement kilns, from the Environment Agency, tel: 01454-624478.

Steel processes and cement manufacturing will fall under IPPC by August this year, with the exception of hot steel-rolling mills, which will enter the regime in July 2002.

The Agency is producing a new series of sectoral guidance notes on the "best available techniques" (BAT) which companies will be required to use.  The guidance is based on EC-wide BAT reference (BREF) documents produced by the IPPC Bureau in Seville, Spain.

The BREF's for ferrous metals and cement were published last summer. They demonstrated that both industries could achieve substantial improvements in a number of areas such as emissions of particulates, dioxins and Nitrogen Oxides (NOx) (ENDS Report 305, pp 47-48).

But the industries are not to enjoy concessions of the kind offered to the paper industry. These allowed paper companies to submit applications based on their existing environmental performance, with extra baseline information being submitted up to three years later (ENDS Report 310, p36).

The concessions were made because as many as half of the paper companies coming under IPPC had no experience of the previous IPC regime and, as the first entrants to IPPC, had very little time to prepare.

Moreover, both cement and steel are dominated by a few big players, while the paper sector has many smaller companies.
CORUS owns all four of the UK's iron and steel works and two of the 16 electric arc furnaces. The UK's 15 cement plants are largely split between Blue Circle, Castle and Rugby.

Companies in both sectors will have to submit applications in full. The timetable for most improvements is three years. But the blow will be softened by much lengthier deadlines for some costly programmes. The guidance says that deadlines for controlling NOx, SOx, particulates and dioxins will be negotiable.

The steel industry's emissions of particulates from sintering processes is one area where UK plants lag behind the best in other countries. Even with well run electrostatic precipitators (ESPs), UK plants are unlikely to be emitting less than 70mg/m3 of dust. The new guidance tightens this to at least 30mg/m3.

Another major issue for the industry is dioxins. In 1999 the sector emitted 52g TEQ. Sinter plants and electric arc furnaces are major contributors.

The BREF note says that emissions of 0.5-1.5 ng/m3 are common in UK plants. Under the new guidance the standard is set to be tightened to 0.1-0.5 ng/m3.

Operators are required to submit programmes with their applications showing how they will reduce emissions of particulates and dioxins. This will include improving the operation of existing ESPs by using high pulsed voltages and cleaning techniques.

But expensive additional abatement equipment such as bag filters or wet scrubbers will be necessary to attain required levels of performance. The guidance says that fabric filter plants can cost up to £9 million.

However, existing plant will not have to be upgraded to this level until 2007. It is possible that some older works will shut before then.

For cement companies, the Agency's guidance is set to require NOx emissions of 200-500mg/m3. These levels are possible with a combination of flame cooling, low-NOx burners and selective non-catalytic reduction (SNCR).

SNCR is not employed in the UK cement industry, but it is a proven technology  used at 18 plants in other countries. Under IPC guidance, 900mg/m3 was the NOx benchmark, but some kilns emit far more.

The guidance says that "SNCR should normally be used where NOx emissions are above benchmark release levels."
Operators will have to consider the use of SNCR in their applications.

The consultation periods for the iron and steel and cement and lime sectors end on 20 and 27 July respectively. ENDS

(1) IPPC: Guidance for the coke, iron and steel sector, and Guidance for the cement and lime sector,
from the Environment Agency, tel 01454-624400

The news is contained in the latest report on the European dioxin emission inventory, coordinated by the North Rhine
Westphalia state environment agency.  It concludes that "comprehensive abatement measures" carried out over the past
15 years by the EU's most industrialised member states have led to sharp declines in dioxin concentrations in ambient
air.  As a result, concentrations in food, human blood and breast milk are "generally declining".

Despite this success the 90% target will be missed for two main reasons, the report says.  Little progress has been made
in controlling non-industrial sources and some EU member states did not identify important industrial sources until
the early 1990s and therefore have not completed abatement programmes.

Beyond emissions to air, there remains the question of quantifying dioxin emissions to land and water, the report says.  A first report on the issue was completed in 1999, but there are too many data gaps to know whether emissions are rising or falling.

Dioxins are among a group of "dirty dozen" chemical substances targeted for global phase-out or severe reduction under the terms of an international treaty on persistent organic pollutants (POPs) (ENDS Daily 22 May). Once the POPs convention enters into force, the EU will be required to catalogue sources of dioxins and devise an elimination action plan.

However, this should not be used as a reason for rationalising incineration, hazardous or otherwise, which effectively creats point sources of some of the most toxic substances known to man.

Remember, whilst the concentrations may be declining, the chemistry is becoming better understood and the toxicity of dioxins and sub PM2.5 particulates is being regularly revised upwards.

A striving toward zero tolerance of these most pernicious chemical would seem to be the only sane course.

Health authorities have been sent new guidance on how to advise the Environment Agency on the health impacts of industrial sites applying for integrated pollution prevention and control (IPPC) permits. But the document has no official standing with the Department of Health (DoH) or the Agency - confirming the long-standing vacuum in responsibility for the health effects of industrial pollution.

Last year's IPPC regulations introduced a new requirement for health authorities to be consulted on every permit application.

The Agency expects companies applying for a permit to assess their operation's potential impact on the health of the local population. The Agency has little expertise in health matters and is looking to health authorities to advise it on the adequacy of companies' assessments. However, the health authorities have an undistinguished track record of engaging with environmental matters.

The authors of the new guidance, the University of Birmingham's Chemical Hazard Management and Research Centre (CHMRC), warn that many health authorites are unclear about their role in the IPPC process. Even so, they conclude, they are under a duty to protect public health and failing to respond to the consultation process is not acceptable.

CHMRC wrote the guidance for the West Midlands health authority which it advises on environmental health matters. It has now sent it to all authorities and their environmental health service providers in an attempt to draw attention to the issue.

The Agency is also concerned about health authorities' ability to respond. In a recent paper to its regional environment protection committees (REPACs), director of  environmental protection Paul Leinster said "there are doubts whether all health authorities will have the necessary resources and experience to deal with the expected workload."

Professor Rod Griffiths, regional director of public health in the West Midlands NHS Executive, accepts that IPPC is going to be a "learning experience" for all health authorities. But he insists that it also "provided a good opportunity for authorities to engage in the wider environmental health debate."

However, the guidance is not formally endorsed by the DoH or the Agency, underlining the lack of clear responsibility for the health effects of industrial pollution. Professor Griffiths explained that "the brisk pace of IPPC's implementation was too quick for proper DoH guidance which would have taken time to produce."

The Agency's lack of competance on environmental health issues has become an increasingly prominant weakness. The regulator has shied away from debate on health impacts in contentious cases concerning incinerators and cement kilns. The REPAC paper admits that Agency personnel have "difficulty answering" public concerns about the health impacts of industrial releases.

CHMRC's guidance points to a vacuum in the Agency's sector-specific IPPC guidance to companies on how to prepare applications. It warns health authorities that "the lack of specific guidance for applicants on assessing the risk to health from their activities may result in many applications failing to contain sufficient relevant information."

The guidance says that authorities should assess whether an IPPC application identifies all releases to each environmental medium during both normal and abnormal operations. The application should quantify the likely human exposure using the source-pathway-receptor model, and consider health impacts on the exposed population. If an application does not cover these points, the authority should ask the Agency to seek further information from the company.

Rugby and Castle Cement are planning to burn waste in kilns at four sites as the centrepiece of "improvement programmes" under integrated pollution prevention and control (IPPC). But both companies, and also Blue Circle, have failed to justify their emissions against the benchmarks for the "best available techniques" (BAT) set by the Environment Agency.

Cement producers submitted applications last August, but no permits have yet been issued. The Agency's processing of IPPC applications is well behind schedule (ENDS Report 325 p5).

The industry is keen to burn scrap tyres in kilns. The Agency's lengthy authorisation process has proved a barrier, although a new protocol is designed to streamline the process (ENDS Report 316, p41).  The industry is also keen to burn increasing amounts of chemical wastes (ENDS Report 312, p33).

The applications for Rugby's works near Rugby and Castle's Ribbledale works seek authorisation to burn tyres in one kiln at each site. Rugby plans to substitute up to 40% of the heat input to its new semi-wet kiln. Castle plans 25% substitution in trials on its dry kiln at Ribbledale.

Permission is also being sought to burn other wastes at Rugby's Ferriby works and Castle's proposed new kiln at Padeswood. Castle wants to burn Profuel, a paper and plastic waste, at the Ribblesdale works, which already uses Cemfuel, made from chemical wastes.

"Seeking permission to use alternative fuels through the IPPC application process should make the the process much more efficient," explained Paul Stevens, an Agency expert on cement and the inspector for Ribblesdale. He was keen to allay concerns that potentially controversial proposals to burn wastes might become lost in a sea of other issues in the applications.

Mr Stevens said that the cement companies still need to conduct trial burns of waste fuels before full permission is granted. They will also have to follow the new tyres protocol, or the protocol on substitute fuels for other wastes, which requires broader consultation with the public.

For both Castle's Ribblesdale works and Rugby Cement's new kiln, tyre burning is offered as the main proposed improvement - not least for reducing emissions of nitrogen oxides.

Agency guidance highlights NOx as a key issue for the sector. Companies emitting more than the benchmark of 200 - 500mg/m3 must justify why, and should consider possible BAT including flame-cooling, low NOx burners and selective non-catalytic reduction (SNCR) (ENDS Report 316, pp 41-42).

Rugby's semi-wet kiln currently emits a maximum daily average of 800mg/m3, while Castle's dry kiln emits 400 - 800mg/m3. Both firms' applications include lengthy descriptions of the benefits of tyre burning - but say very little about the alternative techniques covered in the Agency's guidance.

Rugby's application says: "With the planned use of alternative fuels it is therefore not appropriate to consider any other technique at the present time." Rugby claims that use of tyres will achieve NOx reductions of 30 - 50%. Castle claims that "through its programme of alternative fuels, the benchmark of 500mg/m3 can be met."

For Castle, the picture is complicated further by the two ageing wet kilns at Ribblesdale which the company admits "cannot be considered BAT". It suggests that the kilns will be closed when the new Padeswood kiln, which recently won planning approval, comes on line. But this could take at least four years - and the agency may press for interim improvements.

Paul Stevens told ENDS that the 200 - 500mg/m3 benchmark value "is achievable using the best combination of techniques." The guidance says that the companies - including operators of wet kilns - "should compare their emissions with the benchmark values. When the benchmarks are not met, companies should justify why not."

However, Rugby claims that "the [NOx] benchmark is a political issue rather than an actual issue." It prefers to use the European cement manufacturer's benchmark of 800mg/m3 which it says it already achieves, to assert that "additional controls do not need to be considered further here."

Blue Circle recently began burning tyres is a wet kiln at its Westbury site in Wiltshire. Agency inspector Colin Babb said tyre burning had reduced NOx emissions to 1,100 - 1,200mg/m3. The company's application uses a NOx limit of 1,200mg/m3, apparently taken from the EU BAT reference document and EU Waste Incineration Directive, as the benchmark for its emissions.

Blue Circle's main proposed improvement for Westbury is to reduce the kiln feed slurry moisture to cut emissions of CO2 and NOx. But the company fails to include details or justify why this option is better than any other.

The Agency has responsed to all three firm's applications by issuing requests for further information. Castle has been asked some 50 questions and Rugby 24.

*Energy:
The cement industry has signed a climate change levy agreement to reduce its energy consumption. Signatories are deemed to have met IPPC requirements on energy use.

Companies are expected to include energy consumption data in their applications. The Agency accepted both Castle and Rugby's claim to treat this as commercially confidential. In contrast, Blue Circle's data are on the public register. The company was recently registered under the European environmental management standard EMAS, so the information is already in the public arena.

Other Issues:
Noise surveys at Westbury and Rugby uncovered potential cause for complaint that requires further investigation. On site contamination, a desktop survey at Ribblesdale highlighted some evidence of problems. A 10 tonne spill of Cemfuel in 1996 and other leaks required remediation (ENDS REport 262, p45). The Agency is likely to seek further investigations.