Cement Kilns (Hansard, 23 June 1994)

§ Mr. Atkins

Current authorisations of cement kilns provide for certain substitute fuels to be used in trial burning subject to the agreement of Her Majesty's inspectorate of pollution. While each case will be considered on its merits, HMIP, using experience gained, will be requiring trials to be conducted on the following basis. No more such trials will be approved than are necessary to allow HMIP to determine what constitutes best available techniques not entailing excessive costs—BATNEEC—for operations by the cement manufacturing industry in these circumstances.

Before a trial commences, satisfactory baseline data on the normal operation of the cement manufacture will need to be provided to HMIP. These data will have to cover all of the aspects in the following paragraphs, in partiular including full details of the kiln and its operating characteristics, and of the emissions to the environment during normal operation.

Trials will be run in accordance with a schedule of conditions to be agreed in advance with HMIP. This schedule will be placed on the public register. Operators will be required to make on-going reports on the progress of all trials and in particular to clear with HMIP any reasons for slippage in the progress of any trial. HMIP's agreement will be needed to any proposals to use substitute fuels for longer periods than agreed in the trial schedule. Operators will be expected to discontinue any trial in the event of developments which might adversely affect the environment. For monitoring purposes, HMIP will impose an enhanced and stricter regime to meet the particular circumstances of the trials.

Only substitute fuel that can meet a suitable specification, agreed in advance with HMIP and covering, for example, chlorine, polychlorinated biphenyls, sulphur and heavy metals content, will be allowed to be used in the trials. All deliveries of the substitute fuel will be required to meet the agreed specification. Storage to an agreed standard and with adequate control systems will be needed for the substitute fuel. This may call, for example, for tank level indicators, suitable bunding of containment, instrumentation for controlling and measuring the flow of the substitute fuel, appropriate emergency cut-outs and other features.

260W

HMIP will insist on being satisfied in advance of relevant aspects of the trial operations. Details of kiln operating characteristics covering, for example, temperatures in the kiln, percentage recycled electrostatic precipitator dust, oxygen concentration, fuel rate, trip history and feed rate, will need to be supplied to HMIP. Information on the EP make, number of zones, electrical details for each bank, temperature and carbon monoxide concentration will also be required.

The trials will be principally concerned with the testing and monitoring of releases. Continuous monitors for particulate matter, sulphur dioxide, nitrogen oxides, carbon monoxide and oxygen, calibrated to the satisfaction of HMIP, will have to be installed before trials commence. Where emissions, for example, of hydrogen chloride, hydrogen fluoride and total organic carbon are concerned, it may be necessary for operators to hire or import continuous monitors or to use recognised test methods, all in agreement with HMIP. Other testing as specified by HMIP will be needed on the kiln feed, EP dusts, and clinker. The operator will be expected to undertake adequate local area monitoring. Operators will be required to make on-going returns of trial monitoring data to HMIP which, in accordance, with the requirements of the legislation, will enter them on the public register. HMIP will carry out independent testing to verify the results of the trials.

On completion of the agreed trials schedule, operators will be required to revert to routine manufacture not using substitute fuel. If, following completion of the trials, an operator wishes to use substitute fuels on a permanent basis he will have to apply for a variation of the existing authorisation. In this circumstance, the operator will have to provide HMIP with an assessment of the outcome of the trials to justify his proposals. If the proposed variation amounts to a "substantial change" to the process, the application will have to be advertised and be subject to consultation with statutory consultees and the public. The outcome of individual applications cannot be anticipated, but policy in principle will be to require appropriate improvements to the plant, in order to guard against adverse effects on the environment from the burning of substitute fuel.