A SUPPLEMENTARY NOTE TO THE SUBSTITUTE FUELS PROTOCOL

Transcription

1 tyres Environment Agency CONSULTATION ON A TYRES PROTOCOL FOR USE ON CEMENT KILNS A SUPPLEMENTARY NOTE TO THE SUBSTITUTE FUELS PROTOCOL May 2001

2 CONSULTATION ON A TYRES PROTOCOL A SUPPLEMENTARY NOTE TO THE SUBSTITUTE FUELS PROTOCOL FOR USE ON CEMENT PROCESSES SUBJECT TO REGULATION UNDER THE POLLUTION PREVENTION AND CONTROL ACT 1999 Contact for Enquiries: Dr Neil Davies Policy Manager Rio House Waterside Drive Aztec West Almondsbury Bristol BS32 4UD

3 FORWORD The UK produces nearly half a million tonnes of scrap tyres each year and there is a need to develop a robust, sustainable disposal and recovery capacity to deal effectively with existing and projected tyre arisings. Sufficient capacity is needed to address the large quantity of tyres stored in stockpiles and the implications of the landfill Directive, which will ban the disposal of whole tyres in Currently over 70% of scrap tyres produced are recovered through a variety of markets. The bulk of tyres not recovered are currently disposed of legally to landfill, but the final destination of a significant number of tyres is uncertain. Unfortunately rising costs of tyre disposal has increased the financial incentive for illegal disposal, such as large scale dumping or localised fly tipping. Illegal activity has the potential to jeopardise the disposal and recovery network if not addressed through robust enforcement. The Agency has been aware of the environmental problems associated with the disposal of used tyres for many years, and has been involved in a number of initiatives, including the production of a report tyres in the environment in 1998 to influence the debate. The Agency has recognised the magnitude of the problem and we are currently developing a Tyres Campaign in partnership with the tyre industry. The aim of the campaign is: to reduce the impact of tyres in the environment and encourage the sustainable recovery of waste tyres. We have set as our key objectives Reduce the illegal disposal of tyres; Reduce the risk of environmental damage from current tyre dumps; Ensure there is a sustainable disposal/recovery system. We will be developing a hierarchy of the best environmental options for the disposal/recovery of waste tyres. In the meantime, however, it must be recognised that one option for dealing with tyres is as a fuel. Tyres exhibit many of the qualities needed for a fuel and they have been used extensively throughout the world in cement kilns. As well as helping to address the disposal problem, their use in cement kilns means that the amount of fossil fuels used is reduced. Also, tyres have a known and consistent composition, which means that the emissions from burning in kilns can be reliably predicted and therefore controlled. In view of the benefits of using tyres in cement kilns we are setting out a revised process for permitting companies wishing to use tyres in their kilns. This process, known as the Tyres Protocol, is designed to ensure that companies are not discouraged from pursuing using tyres. At the same time, it offers a rigorous approach that companies must take to demonstrate that using tyres has no detrimental effect on the environment. A prime feature of the Protocol is the requirement for companies to consult and inform the local public about all aspects of tyre use in cement kilns. Paul Leinster Director of Environmental Protection

4 TYRES PROTOCOL CONTENTS LIST 1. INTRODUCTION AND PURPOSE PROCEDURAL REQUIREMENTS PROCEDURE 1: APPLICATIONS FOR TYRE TRIALS ON KILNS WHERE THE USE OF TYRES HAS NOT PREVIOUSLY BEEN PERMITTED PROCEDURE 2: APPLICATIONS FOR TYRE TRIALS ON KILNS WHERE THE USE OF TYRES HAS PREVIOUSLY BEEN AUTHORISED FOR CONTINUOUS USE TECHNICAL REQUIREMENTS PRE-TRIAL REQUIREMENTS MONITORING REQUIREMENTS DURING TYRE TRIALS REPORTING OF TYRE TRIALS CONSULTATION ISSUES REFERENCES...16 ANNEX 1 - APPLICABLE STANDARDS...17 ANNEX 2 GLOSSARY OF TERMS...19

5 1. INTRODUCTION AND PURPOSE The European Commission's Landfill Directive a will ban the disposal of whole tyres to landfill by about 2003, and shredded tyres by Some 450,000 tonnes of waste tyres are generated each year in the United Kingdom. Accordingly more reuse, material recycling and energy recovery options are needed. To this end, the use of tyres as a fuel in cement kilns is an important outlet for waste tyres. It has been shown that burning tyres in cement kilns often has a net environmental benefit when compared to conventional fuels, which are usually, coal and petroleum coke. The emissions of nitrogen oxides (a major pollutant emitted from cement kilns) have been shown to be lower when burning tyres. Also, because tyres contain iron, using them as a fuel reduces the amount of iron oxide that must be added to the process. The purpose of this document is to set out for the benefit of Environment Agency ( Agency ) Officers, Industry and for the general public, Agency guidance on the procedures to be followed and the considerations to be given to the use of tyres as a substitute fuel in cement manufacturing processes. The document builds upon the experiences gained by both the Agency and other stakeholders in applying the Substitute Fuels Protocol b (SFP) to tyre burning trials in cement kilns. This Tyres Protocol covers only the use of tyres for substitution of currently authorised fuels in kilns; it does not cover the use, or increased use, of other alternative fuels in the process of making cement, for which the existing SFP must be used. However, the SFP will not be used for applications for tyre use. Furthermore, for any application requesting permission to trial more than one fuel (including tyres) the Tyres Protocol can only be used for tyres. This Tyres Protocol may also be used as guidance for Officers when assessing and deciding applications from Operators for previously unauthorised (i.e. new) kilns, designed to burn tyres (i.e. tyres are burned at the base load condition). Officers should note that the European Commission has replaced both the Hazardous Waste Incineration Directive c (HWID) and the Municipal Waste Incineration Directive d (MWID) with a new Waste Incineration Directive e, which covers most wastes not covered by the HWID. The Agency is currently preparing guidance on implementation of this new Directive. This supplementary note deals only in outline with procedural changes to the SFP. Officers must refer to the existing SFP for details on mechanisms for consultation as well as the legislative basis of the Agency s approach to assessing applications for the use of tyres in cement kilns. 1

6 2. PROCEDURAL REQUIREMENTS There are two distinct procedures for permitting an application to burn tyres in cement kilns: Procedure 1, covering applications for tyre trials on kilns where the use of tyres as fuel has not previously been permitted, and Procedure 2, covering applications for tyre trials on kilns where the use of tyres as fuel has previously been permitted for continuous use and the Operator wishes to increase the substitution rate. The requirements of procedures 1 and 2 are described in sections 2.1 and 2.2 and are outlined in Figures 1 and 2, respectively. This Protocol may also be used as guidance for Officers when assessing and deciding applications from Operators for previously unauthorised (i.e. new) kilns, designed to burn tyres. Under these circumstances, the Operator must demonstrate within the application that the use of tyres as a fuel represents Best Available Techniques (BAT) for the new kiln(s). Also, the Officer must require the Operator to follow the technical requirements, as laid out in Section 3 of this Protocol, during the commissioning phase for the new kiln(s). A comprehensive commissioning report must be submitted to the Agency to demonstrate compliance with the permitted limits. This report will be made widely available. 2.1 Procedure 1: Applications for tyre trials on kilns where the use of tyres has not previously been permitted The procedure for permitting is outlined in Figure 1 and described through the following eight stages. Stage 1: Consultation by Operator Stage 2: Application for tyre burning Stage 3: Consultation and assessment Stage 4: Permit to burn tyres, subject to trial performance Stage 5: Trial phase Stage 6: Reporting Stage 7: Assessment of report Stage 8: Permission to recommence use of tyres Figure 1 Procedure 1 Stage 1 Consultation The Agency considers that pre-application consultation is vital in order that the local public are better able to appreciate fully the issues surrounding the Operator s proposals. Therefore, the Officer should encourage the Operator to undertake extensive local consultation outlining its intentions to use tyres as fuel. Within this consultation the Operator should present as much information as is possible on the strategy for using all substitute fuels at that site. This 2

7 consultation process should begin before an application for a permit is submitted to the Agency. As a result of doing this, the Operator should then address within the application the concerns raised by the public. This consultation exercise should help the Operator to propose Critical Success Factors (CSFs) - the specific factors or benchmarks by which the success of a tyre burning trial can be judged - for tyre burning. Stage 2 Application for tyre burning Should the Operator wish to continue pursuing using tyres then an application shall be submitted to the Agency, detailing the proposals for tyre burning. However, permission to burn tyres continuously will be subject to satisfactory completion of a trial. Only after the Officer is satisfied that the kiln can be operated satisfactorily using tyres should permission to burn continuously be given. The application should clearly address issues highlighted in the initial consultation exercise. Sufficient information should be supplied for Officers to determine the application in accordance with the guidance provided in this Protocol. The kiln to be used must be clearly identified and must be operating within the limits set out in its permit. In some cases, where there is more than one kiln on the site, and the Operator is applying to burn tyres also on other kilns, there would normally be a need for a trial on one kiln only. However, in deciding whether to allow this, Officers should compare the kilns on the basis of the raw materials used, the kiln and kiln-feed design, emissions data, operating regime and management controls. However, should the Officer allow continuous tyre burning on other kilns on the site, it is important that permission is given conditional on adequate performance. Therefore, in these cases, the Officer should require, as a condition of the permit, the operator to submit a report within e.g. 3 months of commencing continuous tyre burning, detailing kiln performance. This report must contain information on the level of emissions of those substances in Table 1 in Section 3.2.4, as well as dioxins and metals. The Officer may also require other substances to be monitored depending on the outcome of the original trial. The Operator should submit a proposed programme for the trial and the Officer will subsequently determine if the programme is acceptable. This may involve agreeing a trial programme that allows setting up and optimisation as well as incremental increases in substitution rates up to the maximum rate applied for. It may also be appropriate for the Operator to stage the tests e.g. trials at different substitution rates are interspersed with periods of operation at baseline conditions. Whilst the trial programme should be completed within a period of six months the Officer may decide that an extension is acceptable in order to allow the programme to be completed. Stage 3 Consultation and Assessment The Officer will consider the application and define or accept draft CSFs, which would include achievement of emission limits and may include considerations of issues raised in earlier consultation and environmental assessments and relevant management procedures. Whether or not the application is determined to be substantial as defined by the PPC Regulations, the Agency will determine that statutory consultation is still required, under its powers in Schedule 7 of the Regulations. The officer will also consider whether, and to what extent, extended public consultation should also be undertaken. If it is decided that extended public consultation should also be undertaken then the Officer should refer to the consultation mechanisms outlined in the Substitute Fuels Protocol. However, the Officer should focus any consultation on the CSFs. In parallel to these activities, the Operator should be encouraged to 3

8 continue consulting with a wider audience. Officers should take care in making clear that this may be the only formal opportunity for the public to make representations over the application. Stage 4 Permit to burn tyres, subject to trial performance Once the CSFs have been finalized, having taken account of representations made during consultation, the Officer may permit the Operator to burn tyres, conditional on satisfactory performance of a trial. The trial will be for a fixed duration specified in terms of operational hours, with a tolerance of about 5% to ensure flexibility at each stage of the trial. Irrespective of whether tyre burning is subsequently granted or refused, the Agency will produce a clear explanation of the reasons for the decision and a response to all the relevant issues raised in the consultation process. If representations are made raising issues relevant to the decision but outside the scope of the Agency's expertise or remit (e.g. issues regarding safety), they should be referred to an appropriate organisation for comment. Comments from that organisation will be incorporated, as appropriate, in the Agency s explanation of its decision. It may also be appropriate to demonstrate how each point has been dealt with by reference to conditions in the permit or variation notice. It is important to ensure that the Agency's decision on the application is properly documented and recorded. A decision document will be made widely available, with documents placed at accessible points, such as the Agency's public registers, libraries and council offices. The decision document should be non-technical wherever possible, easy to read, and should relate the Agency's decision to the key issues raised by the consultation. Stage 5 Trial Phase Throughout the duration of the trial the Operator should again be encouraged to keep the public informed on the progress of the trial e.g. newsletters, weekly reports etc. In addition, the Operator should gather evidence for reporting on the performance of the trial against the CSFs. The trial must stop if, at any stage, non-conformance with CSFs become apparent. Under such circumstances the Officer will have to decide whether the trial can recommence and whether more consultation should be undertaken. In some cases the permit allowing the trials may need to be further varied. Once the trial is complete the Operator must stop burning tyres and shall not recommence until and unless written approval is given by the Officer. A decision would normally be made within 8 weeks. Stage 6 Reporting The Operator must submit a report of the trial to the Agency. This report must contain an evaluation of performance against the CSFs. The Operator should be encouraged to make this report publicly available before submitting to the Agency. In this way, the Operator can address in the report any concerns the public may have, prior to submission to the Agency. All representation made by the public and the action taken by the Operator to address them should be clearly highlighted in the report. The Officer should consider rejecting the report if this is not done. Stage 7 Assessment of Report On receiving the report the Officer will ensure that it is placed on the public registers. At this stage, the Officer should ensure that all CSFs have been achieved and be fully satisfied that the Operator is capable of operating the kiln using tyres. Consultees, including statutory 4

9 consultees, should be given an opportunity to raise any concerns still outstanding and the Officer should be satisfied that they have been addressed before allowing further tyre burning. Stage 8 Permission to recommence use of tyres Subject to satisfactory performance against the CSFs, and providing all representations from consultation are adequately addressed, the Agency would then normally permit, in writing, the continuous use of tyres as fuel. The time from stopping the trial to permitting continuous use should not normally exceed 8 weeks. Key stakeholders should be notified, by letter, of the Agency s decision in conjunction with a subsequent press release. Also, the Officer should produce a document explaining the Agency s decision to allow the Operator to recommence tyre burning. 2.2 Procedure 2: Applications for tyre trials on kilns where the use of tyres has previously been authorised for continuous use The procedure for permitting is outlined in Figure 2 and described through the following three stages. Stage 1: Application for increased substitution rate Stage 2: Consultation and assessment Stage 3: Continuous use of tyres as fuel Figure 2 Procedure 2 Stage 1 Application for increased substitution rate Following authorisation to burn a particular tyre type at a given substitution rate, for example 10%, an Operator may wish to increase the tyre feed rate. In this case, the Operator should submit an application for a variation to increase the substitution rate. The Officer should take a view on whether to pursue this Procedure or Procedure 1, depending on the incremental increase applied for. However, as a general rule the Officer should use this Procedure provided the requested increase is less than, or equal to, a 10% increment (e.g. 10 to 20% or 15 to 25%). Stage 2 Consultation and Assessment On receipt of an application the Officer will consider the application and define or accept CSFs. For this type of trial, a lot of information will already be available on the performance of tyres in the kiln. Whether or not the application is determined to be substantial as defined by the PPC Regulations, the Agency will determine that statutory consultation is still required, under its powers in Schedule 7 of the Regulations. Furthermore, the Officer should consider whether, and to what extent, to undertake wider public consultation. The mechanisms available for undertaking extended public consultation are outlined in the Substitute Fuels Protocol. The Operator should be proactive in informing local residents of the request to increase the substitution rate. Stage 3 Continuous use of tyres as fuel Subject to the Officer being satisfied with the application and, where appropriate, providing all representations from consultation are adequately addressed, the Officer may permit the 5

10 continuous use of tyres as fuel at the new substitution rate. The Officer should, however, require, as a condition of the permit, the Operator to submit a report after a period of tyre burning (e.g. 3 months) outlining the kiln performance. This report must be made available to the public in order that they can comment on the outcome of the trial. Therefore, in addition to placing it on the public registers, key stakeholders should also be notified about the availability of the report. The Operator should also be encouraged to engage with the local community on the findings of this report. At the time of permitting continuous use of tyres a decision document will be made widely available, with documents placed at accessible points, such as the Agency's public registers, libraries and council offices. The decision document should be non-technical wherever possible, easy to read, and should relate the Agency's decision to the key issues raised by the consultation. 3. TECHNICAL REQUIREMENTS This section outlines the information that the operator must include in any application and/or report concerning the use of tyres. 3.1 Pre-trial requirements Specification of Tyres Good generic analytical data are already available on the composition of tyres and it may be appropriate to estimate pollutant inlet burdens from the generic analysis and the measured input tyre feed rate. However, Officers should be aware that commercial vehicle tyres exhibit significantly different compositions to those of car tyres for some important components (e.g. iron and zinc content). Only tyres that can meet a specification agreed in advance with the Agency will be permitted to be trialed. Consequently, Officers should require Operators to notify the Agency concerning the mix of tyres to be trialed Storage, Handling and Control of Tyres Operators should demonstrate in the application that they will put in place measures for suitable storage of tyres. Details of how the thermal substitution rate is to be determined and monitored should be provided. The Operator will also need to confirm the circumstances which will lead to the cessation of tyre feed, e.g. duration of electrostatic precipitator outage Specific Requirements The Operator should demonstrate to the satisfaction of the Officer that the operation of the kiln is properly controlled and that there are safeguards against potential environmentally damaging upsets. This should include assurances that the management controls are adequate. Evidence of compliance with the existing permit should be supported by adequate established emissions data. Furthermore, data must be provided on the operation of the process to demonstrate that the process is capable of sufficiently stable operation. For example, in relation to mean time between stoppages, number, duration and cause (e.g. high carbon monoxide) of Electrostatic Precipitator trips per year. Operators should provide data demonstrating that the number and duration of carbon monoxide trips has been minimised. This will enable meaningful test results to be obtained during the trial period, Officers will then need to consider if each of the current permitted limits is appropriate for the trials. 6

11 It is vital that most sampling is undertaken at the maximum rate of substitution. This will allow comparison with a similar number of valid results obtained over a comparable operational period under baseline conditions (see Section 3.2). If sufficient historic data exist the Officer may permit less testing under baseline conditions, which should be defined as either the design fuel mix for the kiln or the previously tested and permitted substitution rate. The Officer should only use the latter provided the kiln has been recently operating at, or close to, the permitted substitution rate. However, in determining if less monitoring than would normally be required for a baseline is justified, the Officer must be satisfied that for the period over which the Operator wishes to use as baseline monitoring no significant changes to the process have been made. Criteria to be used in determining if less monitoring is justified include: no significant changes being made to the process plant (e.g. change of abatement plant or design fuel); no significant changes being made to process control (e.g. installation of an expert management system); no significant changes to the sampling methods or protocols and the monitoring and analytical methods meet current standards; and no significant changes to the installed plant continuous emission monitors. In view of this, it is important that the Operator notifies the Officer at the earliest opportunity whenever changes to the process control and monitoring systems are proposed. This will enable the Officer to make a judgement on the comparability with the existing controls. It is important that all testing is carried out under comparable operating conditions (e.g. similar coal/coke quality and mesh size, kiln and abatement operation including % Cement Kiln Dust (CKD) recycle, back end temperature, sulphur/alkali ratio etc). It is also important that kilns should be allowed to stabilise before attempting any testing. It should be noted that whilst stabilisation from cold start may take 2 or 3 days, stabilisation periods from one trial condition to another may be considerably shorter. In general, 24 hours should be allowed for stabilisation between different trial conditions Monitoring Arrangements Operators must provide details of continuous monitoring instrumentation and monitoring methods to be used to monitor inputs and outputs from the process as detailed in Section 3.2. The Operator must monitor all significant inputs (including fuels, raw materials, recycled material) and significant outputs (including releases to all media, CKD and products) using approved sampling and analysis contractors e.g. accredited under the United Kingdom Accreditation Scheme (UKAS). The general testing and monitoring regime is detailed in Section 3.2, but the actual monitoring programme must be agreed with the Officer. Operator monitoring will be audited by the Agency on an unannounced basis. Operators will propose a method for estimating or calculating gas dispersion, acceptable to the Agency, to be used in their assessment of environmental impact of emissions from the process. Where concerns are raised about ambient levels of pollutants, the Officer will need to consider if 7

12 ambient monitoring is appropriate and, if so, should be carried out to national network standards (see DETR guidance 1 ). 3.2 Monitoring Requirements during Tyre Trials Wherever possible, and in accordance with the relevant articles of EU Directives, the following requirements will be specified in any permit authorising trials and will be enforced accordingly The Trials Programme The Operator should keep to the agreed trials programme as much as possible but if there are unavoidable disruptions the Agency must be informed, and agreement sought to extend the programme Monitoring Requirements - General Considerations All Operator monitoring must be carried out at the maximum substitution rate and, where appropriate, at baseline conditions. The Officer should also consider requiring the Operator to move from baseline to maximum substitution rates in stages. The Operator should not move to higher substitution rates until the Officer is satisfied with the overall kiln performance. The minimum frequency of testing for each determinand is shown in Figure 3, but actual frequencies will be set by the Agency dependent upon the characteristics of tyres to be trialed. If there are several tests within the trials programme each test should be long enough to stabilise operating conditions for sufficient time to ensure that test results are as representative as possible. Also, tests should be spread evenly over the duration of the trials programme. Examples of approved standard methods, which must be used by Operators, are provided in Annex 1. The Agency also requires that UKAS (or equivalent) accredited sampling and analysis contractors are employed and all sampling and analysis must be representative. The Officer should audit the Operators monitoring arrangements and facilities before a trial commences using the Agency s Operator Monitoring Assessment. Based on this the Officer may decide that Agency check monitoring should also be undertaken during the trial. All monitoring data gathered by the Operator and Agency monitoring programmes will be placed on the Public Register Testing and Monitoring Facilities Sampling locations (for releases into air and water, wastes or products and raw materials/fuels) and procedures to ensure representative sampling should take account of the appropriate sampling standards and must be agreed with the Officer. Facilities for the sampling of emissions to air should at least meet the standards stipulated in Agency Technical Guidance Note M1 (f). It should be noted that M1 is restricted to the application of compact total particulate monitoring equipment. However, platform design and railings must also be suitable to accommodate other more bulky sampling systems as well as there being adequate lifting facilities and power supplies. Additional guidance can be found in the Source Testing Association s booklet Hazards, Risks and Risk Control in Stack Test Operations. 1 Local Authority Air Quality Management Technical Guidance Notes, LAQM TG1. 8

13 If there has been no previous assessment of background surface levels of dioxins and metals it may be prudent to undertake such a study before trials commence. In these cases, soil and vegetation samples should, as a minimum, be taken downwind of the stack, and at least in the area calculated to have the maximum ground level concentration, where practicable. The sampling sites and the pollutants to be monitored must be agreed with the Officer The Operator s Permanently Installed Continuous Emission Monitoring Systems (CEMs) The minimum requirement for continuous monitoring of emissions at baseline conditions and maximum substitution rate, using the Operator s installed continuous emission monitoring systems (CEMs) are given in Table 1. However, Officers must take account of the requirements set within the Waste Incineration Directive. Table 1 Determinands to be monitored using continuous emissions monitors Determinands Particulate matter Oxides of nitrogen (as nitrogen dioxide) Sulphur dioxide Hydrogen chloride Carbon monoxide Oxygen, moisture, temperature and pressure Total organic carbon (TOC) Continuous stack monitoring should take place over a period of at least 6 weeks (in terms of operational hours) at each of the baseline (if appropriate) and maximum substitution conditions. Test periods should be of comparable duration. Data must be recorded/logged as one-minute means but instruments must also be capable of providing data for comparison with ambient air quality standards. In addition, maxima, minima, means, and standard deviations are to be reported for the various averaging periods. Continuous emission monitoring systems for gases must be calibrated immediately before and after each trial and at three monthly intervals if trials continue beyond this period of time. Calibration for gas monitors should follow CEN or British/international standards. The Agency must be notified in advance and given the option of witnessing such calibrations. Where possible the CEMs for gases should also be subject to daily zero and span checks using, for example, certified gas standards. An Agency audit of the Operator's continuous monitoring should also be undertaken, and include a comparison of Operator's continuous monitoring data with extractive data, and an evaluation of the Operator's data logging facility. Continuous particulate monitors must be calibrated against a standard extractive gravimetric method calibrated, before and after each trial, and at least every 6 months Periodic Extractive Sampling of Stack Emissions 9

14 To give greater confidence in the results from CEMs periodic extractive sampling will be required. This could be undertaken using temporary installed extractive instrumental monitoring systems or by employing manual extractive monitoring methods. The determinands, which must be sampled, by the Operator, and the minimum sampling periods, are summarised in Table 2. Table 2 Periodic extractive sampling requirements for stack emissions Determinand Particulate matter PM 10 Oxides of nitrogen (as NO 2 ) Sulphur dioxide Carbon monoxide Oxygen Hydrogen chloride Hydrogen fluoride Total Organic Carbon) Heavy metals (1) Dioxins and furans Polychlorinated biphenyls (PCB's) (2) Polycyclic aromatic hydrocarbons Stack moisture Stack gas flow rate and temperature Minimum sampling period per sample In accordance with approved standard but likely to be around 1 hour per sample As per particulate matter Continuously for at least 12 hours Continuously for at least 12 hours Continuously for at least 12 hours Continuously for at least 12 hours 1 hour 1 hour Continuously for at least 12 hours 1 hr 6 hours 6 hours 6 hours 1 hour In accordance with approved standard Note (1) Arsenic, lead, chromium, copper, cobalt, vanadium, mercury, cadmium, thallium, nickel, manganese, antimony and zinc Note (2) In the absence of a recognised sampling standard, determination of PCB concentration should be undertaken in accordance with the principles and procedures in BS EN1948 Periodic extractive testing for each determinand must be undertaken for the duration shown in Table 3 and should be spread out evenly over each of the baseline (where appropriate) and maximum tyre feed rate trial periods. All periodic manual sampling must be undertaken during steady state operation of the kiln. Where periodic extractive instrumental monitoring systems are employed, these must be fully calibrated immediately before and after each trial. Also, as a minimum, these systems must be spanned and zeroed immediately before and after each sample period using certified standard gas mixtures. Calibration gases shall be certified in conformance with BS 4559 Part 4 (ISO 6141). Operators and monitoring contractors shall procure calibration gases from suppliers having UKAS (or equivalent) accreditation for the analysis of gases. In accordance with BS 4559, each calibration gas cylinder shall have a full certificate of analysis, and a certificate of minimum requirements (extracted from the full certificate of 10

15 analysis) which shall be attached to the container of calibration gas. These minimum requirements are listed in Table 4. Table 4 Minimum requirements for calibration gas certificates, as attached to calibration gas cylinders. Item Requirement 1 Unique certificate identification 2 Container identification 3 Specified components 4 Composition 5 Expanded uncertainty 6 Filling pressure 7 Valve outlet connection 8 Minimum utilisation pressure 9 Storage/utilisation pressure 10 Expiry date Stack gas testing should meet the following minimum requirements and each of the parameters detailed below must be monitored under baseline conditions (where appropriate) and at maximum substitution rate. To determine the various monitoring options and the minimum number of samples to be taken and the sampling frequency, determinands indicated in Table 2 should be inserted (in turn) in the flow chart given below. Officers should note that Figure 3 represents the required number of samples that must be taken in order to provide the minimum number of valid results. 11

16 START Key Action(s) to be taken Question Measure flow, Oxygen, temperature, moisture and pressure at least twice on each test day Installed stack CEMs for determinand? NO NO Is the contractor using continuous instr? NO Dioxins, PM10, Particulate matter or metals PCBs? YES YES YES YES Operator collects data continuously during trials and validates CEMs Contractor collects data for 12 hrs over each of 6 test days 2 consecutive manual samples on each of 6 test days consecutive manual samples on 1 test day YES Independent continuous instruments used?. NO Monitor for 12 hrs on one test day 6 manual extractive samples 1 1 For particulate matter, if BS3405 is to be satisfied at least two consecutive samples will be required to obtain one valid result. 2 In accordance with BS EN1948, a field blank will additionally be required. Figure 3 Flow chart for determining minimum stack sampling requirements for an individual test Testing of Inputs, Products and Material Collected in Abatement Equipment Testing of feeds, all fuels (excluding tyres), material collected in abatement equipment and products is required under baseline and substitution conditions. The collected samples must be analysed for the following parameters as given in Table 3. 12

17 Table 3 Periodic monitoring requirements for kiln inputs and outputs Parameter Feeds Fuels CKD Clinker (a) (a)(b) (a)(d) (a) Heavy metals (c) (c) (c) (c) Total of each S, F, Cl, Br, I Dioxins and furans Flow (kg/hr) Calorific value (gross) Free lime content, alkalinity, and ph of leachate PCBs content NOTES Denotes that a parameter is to be periodically monitored (a) At least two samples to be taken over each test period (Officers have discretion as to how samples are to be bulked for analysis) (b) Each fuel to be tested separately (c) Arsenic, lead, chromium, copper, cobalt, vanadium, mercury, cadmium, thallium, nickel, manganese, antimony and zinc (d) Sampling not required if 100% of the cement kiln dust is recycled during normal operation. Representative sample increments (using a method (g) agreed with the Officer) should be taken once per hour during the test periods and accumulated to provide a bulk aggregated sample. Where practicable, sample increments should be taken from falling or flowing streams. For solids, any material above 5 cm in size in the bulk aggregate sample should be crushed, then the sample should be mixed and progressively sub-divided (e.g. by cone and quartering) to provide a single representative sub-sample (around 5 kg) for each test period Environmental Monitoring Where there are specific justifiable concerns, a programme of ambient air monitoring may be required to back up the Operator s assessment of environmental impacts from dispersion modelling, and to demonstrate that releases are rendered harmless consistent with BAT. Account should be taken of the Agency s guidance on the monitoring of ambient conditions set out in Technical Guidance Notes M8 (h) and M9 (i) Recording of Process Parameters Plant process conditions shall be recorded during the baseline and tyre burning periods of all trials, and must be included in all monitoring reports. As a typical minimum requirement, this may include readings of the following parameters (example for dry cement kilns): cyclone pre-heater temperatures; primary and secondary air temperatures; clinker cooler temperatures; kiln exit temperatures; kiln throughput; fuel quality and input rates (including tyres when being burned); 13

18 abatement operation (including details of abnormal operation and times); kiln exit carbon monoxide and oxygen concentrations; CKD recycle rate; and alkali/sulphur ratios. 3.3 Reporting of Tyre Trials Content of Report To enable an Officer to evaluate the results of tyre trials it will be necessary to submit a comprehensive report, which is complete in its own right. Officers should not have to make reference to documents elsewhere or to ones that have been submitted to the Agency on some earlier occasion. Therefore, the report should include the following: a) Covering letter explaining what has been submitted and a synopsis of the company's findings; b) Performance and degree of achievement against the CSFs; c) Comparative data for both baseline testing and trials testing at the maximum substitution rate, comprising results from all process measurements and analysis, measurements and analyses for all inputs and outputs from the process, and mass balances where possible; d) All other relevant testing and monitoring including environmental sampling and analyses; e) Information regarding issues raised during consultation and how they have been addressed; f) Conclusions and recommendations including justification; and g) Non-technical summary of the application Reporting of Monitoring Data Monitoring results must be reported on Environment Agency standard report forms (where available) for monitoring of emissions to atmosphere. All reports shall include the following features, as a minimum requirement: Details of all methods employed for sampling and analysis, including reference to standard methodologies; Details of plant layout, sampling ports and planes with diagrams; Limits of detection, accuracy and precision on an individual basis for all samples; How the limits of detection, accuracy and precision of measurements have been determined; Plant operating conditions - any abnormalities should be highlighted (with timings) for the period of the trials; Summary tables of all monitoring results; Start and end times of all sampling; Full presentation of pitot and temperature traverses taken before, during and after sampling, along with gas flow rate results; Full raw monitoring data in appendices, including all laboratory measurements and test variables; Presentation of calculations of concentrations, flows and mass emissions; 14

19 Details of any non-compliance with standards employed; Dioxin test reports should include determined levels of all congeners and full tabulation of spike recoveries by congener; Metals test reports for stack emissions should tabulate each metal measured in both particle and vapour phases. The combined emission should be reported for each metal. The mass of each determinand collected in the particle phase, the bulked impinger solutions (excluding the final impinger solution) and the final impinger solution must be measured and reported separately; and Derivation of monitoring results used for dispersion, dioxin trail and BPEO assessments. 4. CONSULTATION ISSUES 4.1 The Agency welcomes your comments on the proposals we have set out in this Tyres Protocol and, in particular, your responses to the following questions. 1. Do you agree with the concept of using well-defined success criteria as a basis for aiding the Agency s decision making process? 2. What sort of performance measures do you consider should be success criteria? 3. Are you broadly supportive of the proposal to encourage the industry to play a greater role in the consultation process? 4. How would you assess the effectiveness of this Protocol? The Agency will review this Protocol following the external consultation process. Responding to the consultation 4.2 The closing date for the consultation is 31 July Please send your response to: Dr N H Davies Environment Agency Rio House Waterside Drive Aztec West Almondsbury Bristol BS32 4UD Phone: Fax: {TyresProtocol@environment-agency.gov.uk} This consultation document can also be viewed on our website ( from where consultation responses can be sent directly. This consultation is being carried out in accordance with the principles of the Code of practice on written consultation issued by the Cabinet Office in November This is available on ( 15

20 5. REFERENCES (a) Directive 1999/31/EC of The European Parliament and of The Council of April on the Landfill of Waste. Official Journal of the European Communities L 182, 16/07/1999 p (b) Substitute Fuels Protocol for Use on Cement and Lime Kilns. Environment Agency Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol. BS32 4UD (c) Directive 94/67/EC of The European Parliament and of The Council of 16 December 1994 on the incineration of hazardous waste. Official Journal L p.34 (d) Council Directive of 8 June 1989 on the prevention of air pollution from municipal waste incineration plants (89/369/EEC). (e) Directive 2000/76/EC of The European Parliament and of The Council of 4 December 2000 on the incineration of waste. Official Journal L 332/ , p.1. (f) Technical Guidance Note M1 Sampling facility requirements for the monitoring of particulates in gaseous releases to atmosphere, March 1993, ISBN (g) Environment Agency Guidelines for Ash Sampling (h) Environment Agency Technical Guidance Note M8 - Monitoring Methods for Ambient Air (in preparation). (i) Environment Agency Technical Guidance Note M9 - Environmental Monitoring Strategy: Ambient Air (in preparation). 16

21 ANNEX 1 - APPLICABLE STANDARDS Table A1 - Reference Test Methods 1 Pollutant Standard Reference Title Hydrogen chloride BS EN1911: 1998, Parts 1 to 3 Air Quality - Stationary source emissions - Manual method of determination of HCl Hydrogen halides 2 US EPA Method 26A Determination of Hydrogen halide and halogens from stationary sources Dioxins and furans BS EN1948: 1997, Parts 1 to 3 Stationary source emissions - Determination of mass concentration of PCDDs/PCDFs PCDDs/PCDF S - Part 1: Sampling, Part 2 Extraction and clean-up, Part 3: Identification and quantification Particulate matter 3 BS3405 : 1983 British Standard Method for Measurement of particulate emission including grit and dust (simplified method) Particulate matter BS : 1992 (ISO 9096) Stationary Source emissions - Determination of concentration and mass flow rate of particulate material in gas carrying ducts - Manual gravimetric method Gas velocity 4 BS 1042 Part 2.1:1977 (ISO 3966) Measurement of fluid flow in closed conduits - Velocity area method using Pitot static tubes. Gas velocity ISO Stationary source emissions - Measurement of velocity and volume flowrate of gas streams in ducts Sulphur dioxide 5 BS : 1989/Corr1998 (ISO 7934) Stationary Source emissions - Determination of the mass concentration of sulphur dioxide - Hydrogen peroxide/barium perchlorate/thorin method. Sulphur dioxide 6 ISO : 1992 Stationary source emissions - Determination of the mass concentration of sulphur dioxide - Ion chromatography method Nitrogen oxides 7 BS ISO : 1998/Corr2000 ISO 11564:1998 Stationary source emissions -- Determination of the mass concentration of nitrogen oxides -- Naphthylethylenediamine photometric method Heavy metals US EPA Method 29 Determination of metals emissions from stationary sources Total Organic Carbon BS EN12619 : 1999 Stationary source emissions - Determination of the mass concentration of total gaseous organic carbon at low concentrations in flue gases - Continuous flame ionization method Moisture US EPA Method 4 Determination of moisture in stack gases Notes: 1 This table should be used for guidance purposes only and should not be regarded as an authoritative summary. Sampling of all pollutants as well as reference measurements to calibrate automated measurement systems or to provide correction of data to reference conditions shall be carried out as given by CEN standards. If CEN standards are not available, ISO standards, national or international standards which will ensure the provision of data of an equivalent scientific quality shall apply, subject to approval from the Agency. (Last updated 1 March 2001). If instrumental methods are to be used for reference testing, then refer to the standards in Table A2 for the applicable performance standards. 2 This method is used for determining the concentration of fluoride in the stack gas emissions. 3 BS 6069 Part 4.3 is recommended, unless there is a sound reason to justify the use of BS ISO is recommended, unless there is a sound reason to justify the use of BS The correction from 1998 must be applied. 6 This method is not recommended if sulphur trioxide is present, or if ammonia and/or volatile sulphates are present at a concentration more than 5% by volume. 7 The correction from 2000 must be applied. 17

22 Table A2 - Standards for continuous emissions monitoring systems 1 Pollutant Standard Reference Title Particulate matter BS ISO 10155:1995 Stationary source emissions - Automated monitoring of mass concentrations of particles Performance characteristics, test methods and specifications Gas flow BS ISO 14164: 1999 Stationary source emissions - Determination of the volume flowrate of gas streams in ducts - Automated method Sulphur dioxide BS :1992 (ISO 7935) Stationary source emissions - Determination of the mass concentration of sulphur dioxide - performance characteristics of automated measuring systems Nitrogen oxides 2 ISO 10849: 1996 Stationary source emissions - Determination of the mass concentration of nitrogen oxides - Performance characteristics for automated measuring systems Carbon monoxide, carbon dioxide and oxygen 3 ISO/DIS 12039:2001 Stationary Source Emissions - Determination of the volumetric concentration of CO, CO 2 and oxygen - Performance characteristics and calibration of an automated measuring method Total Organic Carbon BS EN12619:1999 Stationary source emissions - Determination of the mass concentration of total gaseous organic carbon at low concentrations in flue gases - Continuous flame ionization method General requirements ISO Stationary source emissions - Sampling for the automated determination of gas concentrations Notes: 1 These standards contain performance specifications for continuous emissions monitoring systems. 2 ISO is to be adopted by the British Standards Institution as BS ISO Although ISO/DIS was still technically a draft standard at the time of writing, the formal process of voting was scheduled for April

23 ANNEX 2 GLOSSARY OF TERMS BPEO Best Practicable Environmental Option Br Bromide as bromine CEN Committee European de Normalisation (European standards committee) CKD Cement Kiln Dust (dust collected in air pollution control equipment) Cl Chloride as chlorine DETR Department of Environment Transport and the Regions Dioxins A series of polychlorinated dioxin and furan ring compounds numbering over 200. TEQ refers to a toxic equivalent rating which is usually applied to the seventeen 2,3,7,8 chloro-substituted congeners. EIA Environmental Impact Assessment EP Electrostatic Precipitator EU European Union F Fluorine HCl Hydrogen chloride HF Hydrogen fluoride HWD Hazardous Waste Directive I Iodide as iodine MWID NO Municipal Waste Incineration Directive Nitrogen monoxide (nitric oxide) NO 2 Nitrogen dioxide NOx Total oxides of nitrogen (NO + NO 2 ) O 2 Oxygen 19

24 PCBs Polychlorinated Biphenyls PPC Pollution Prevention And Control Regulations Sample A small representative part of a material flow taken during a test period S Sulphur SO 2 Sulphur Dioxide Test TOC Trial UKAS A period during which burning is carried out at a single condition (eg tyre substitution rate) and a number of samples are taken Total Organic Carbon A series of tests undertaken at different conditions (eg tyre feed rate varies) with a specific objective United Kingdom Accreditation Service (now replaces NAMAS) USEPA United States Environmental Protection Agency Valid result VOC A monitoring result that is considered by the Agency to be acceptable for monitoring method applied and representative of the measured process parameter Volatile Organic Compounds WID Waste Incineration Directive 20