Revised Technical Guidelines on the Environmentally Sound Management of
Used Tyres
CEMBUREAU comments on the 28-Feb-2011 draft technical guidelines on ESM
of used tyres
GUIDANCE ON ENVIRONMENTALLY SOUND MANAGEMENT
(ESM)
III.
§194
"Studies on the use of tyres in cement kilns (that) do not present consistent results
about the impacts of co-incineration on the detectable levels of dangerous
substances"
CEMB
References to the “studies” referred to in the statement are missing.
§194
...its safety is dependent on the good operating practice as well as the particular
characteristics of the tyres used and the kiln.
CEMB
“Good operating practice” contemplates the “characteristics of the tyres used”.
It should read instead: ...its safety is dependent on the good operating practice as well
as the particular characteristics of the tyres used and the kiln.
§194
§195
CEMB
“Co-incineration”
§197
Tyres are now established supplementary fuel in cement kilns
CEMB
It should read: “Tyres are now established as alternative fuel in cement kilns.”
Although mentioned the use of both wordings “co-processing” and “co-incineration”
as synonyms, the use of “co-processing” should prevail throughout the text, as it is in
line with the title of the chapter and with the Basel Convention Technical Guidelines
on Co-processing of Hazardous Waste in Cement Kilns, currently being drafted by
Chile.
“Alternative fuel” is the appropriate, accepted and used terminology.
§198
CEMB
It is a way to recover energy and material from refuse, when used to partially
replace fuel and raw material in the production of cement clinker. Basically,
characteristics of the clinker burning process itself allow environmentally beneficial
waste-to-energy and material recycling applications. The essential process
characteristics for the use of waste can be summarised as follows:
Co-processing is not a “waste-to-energy” process, therefore the wording should be
adapted.
“Basically, characteristics of the clinker burning process itself allow
environmentally beneficial energy recovery and material recycling applications”
§198
Product specific wastes are not generated due to a complete material utilisation into
the clinker matrix; however, some cement plants in Europe dispose of bypass dust
chemical-mineralogical incorporation of non-volatile heavy metals into the clinker
matrix.
29 April 2011
CEMB
Cement plants around the world dispose of such device.
Product specific wastes are not generated due to a complete material utilisation into
the clinker matrix; however, some cement plants in Europe dispose of bypass dust
chemical-mineralogical incorporation of non-volatile heavy metals into the clinker
matrix.
§198
CEMB
§202, 203
New bullet:
 chemical-mineralogical incorporation of non-volatile heavy metals
(f) Co-processing
ii. Emissions
Annex C, part II of the Stockholm Convention, lists cement
kilns co-processing hazardous wastes as an industrial source with potential for the
formation and liberation of comparatively high amounts of polychlorinated dibenzop-dioxins (PCDD), dibenzofurans (PCDF), hexachlorobenzene (HCB) and
polychlorinated biphenyls (PCB) into the environment.
The revised draft guidelines on best available techniques
(BAT) and provisional guidance on best environmental practices (BEP) relevant to
Article 5 and Annex C of the Stockholm Convention on persistent organic pollutants,
adopted at the Conference of the Parties to the Stockholm Convention in April-May
2007, address this issue and present valuable information. The BAT/BET guidelines
state the following:
“The combustion process in the kiln has the potential to result in the
formation and subsequent release of chemicals listed in Annex C of
the Stockholm Convention. In addition, releases from storage sites
may occur. Well-designed process conditions, and the installation of
appropriate primary measures, should enable cement kilns firing
hazardous waste to be operated in such a manner that the formation
and release of chemicals listed in Annex C can be minimized
sufficiently to achieve concentrations of PCDD and PCDF in flue
gases of < 0.1 ng I-TEQ/Nm3 (oxygen content 10%), depending on
such factors as the use of clean fuels, waste feeding, temperature
and dust removal. Where necessary, additional secondary measures
to reduce such emissions should be applied.”
CEMB
Although it is correct that cement kilns are listed as a potential source of POPs in
Annex C, part II of the Stockholm Convention, the booklet “Cement kilns firing
hazardous wastes” (attached) within the “Guidelines on Best Available Techniques
and Provisional Guidance on Best Environmental Practices relevant to Article 5 and
Annex C of the Stockholm Convention on POPs” (attached) recognizes the coincineration of wastes in the cement kilns as BAT, provided that it is carried out
under strictly controlled circumstances and BEP.
Please also find attached the study “Formation and Release of POPs in the Cement
Industry, Second edition”, prepared by SINTEF for the WBCSD-CSI, submitted to
the Stockholm Convention and integrated in the above-mentioned guidelines, based
on a thorough survey of dioxins-and-furans emission figures of more than 1000 kilns
worldwide, proving they are compliant with the strict emission limit value prescript
by the Stockholm Convention and elsewhere.
UNEP/CHW/OEWG/6/
(f) Co-processing
iv. Monitoring and measures/techniques for emissions reduction
§209
… Tyre burning should only be allowed on a permanent basis
if the data from the test burn shows that co-processing will not lead to additional risks
to the environment.
CEMB
The requirement should read: “will not lead to significant increase of the emissions of
pollutants with respect to the (permitted) reference situation without the use of tyres”.
It is noteworthy that in Germany, a country with an extremely strict environmental
legislation, already some years ago the environmental ministry of North-Rhine
Westfalia decided to put used tyres on a positive list. This list depicts alternative
materials which are very much suitable for the use in the cement manufacturing
process. This estimation of the German authorities was based upon a long lasting
positive experience with the recovery of used tyres as a fuel in the clinker burning
process. (Please see attachment referenced below)
Source: "Leitfaden zur energetischen Verwertung von Abfällen in Zement-, Kalk- und Kraftwerken in
Nordrhein-Westfalen, Ministerium für Umwelt, Naturschutz, Landwirtschaft und Verbraucherschutz
Nordrhein-Westfalen, 2. Auflage, September 2005
v.
CEMB
[Co-processing/Co-incineration in Plants for Electric Power Generation]
This sub-chapter should compose a separate chapter (as “g”) as the content is clearly
referring to incineration/co-incineration other than in cement kilns.
Appendix I – Public health literature
§226
A Japanese study in 2002 demonstrated that tyres transported for final
disposal operations (in this case, cement kilns) could be infested with mosquitoes:
“In the northernmost limit of the mosquito, Higashiyama located on the
eastern side of Tohoku district, there is a cement plant in which used tyres are
used for fuel and raw materials. These tyres, which could be infested with
mosquitoes, are frequently transported from large cities nearby. It has been
shown that this kind of economic activity has a strong connection to the
spread of Ae. albopictus.”49
KOBAYASHI, M. et al., “Analysis of Northern Distribution of Aedes albopictus (Diptera culidae)
in Japan by Geographical Information System”, Journal of Medical Entomology, Volume 39, No. 1, at
9 (2002).
49
CEMB
In the framework of EU waste legislation, co-incineration of waste (used tyres) in
cement kilns is considered as a recovery operation and not a disposal operation.
The concepts of “disposal” and “recovery” used in EU legislation are essentially
understood as operations defined by their purpose. The key criterion to decide if an
operation is to be considered as recovery is: “if the waste were not available for a
given operation, would that operation nonetheless be carried out using some other
material?” (Opinion of Advocate General Jacobs, Case C-6/00 ASA, 15 November
2001, paragraph 86).
Under the Basel Convention, another terminology which is seemingly in
contradiction with the EU practices is used: Annex IV of the Basel Convention
contains a list of “disposal operations” and part B of that Annex contains the
3
"Operations which may lead to resource recovery, recycling reclamation, direct reuse or alternative uses", which are recovery operations in the EU and not disposal
operations.
Hence the terminology used under the Basel Convention and in particular in this
ESM Guidance document might lead to confusion for companies operating on the EU
market, as co-incineration of waste in cement kilns in the EU is considered recovery
and not disposal.
A clear and consistent separation between “energy recovery” and “disposal” in these
guidelines, in line with the waste hierarchy as defined in the latest EU Waste
Framework Directive, would avoid misinterpretations.
§230
Even fumigation is not fully efficient in eliminating the eggs and larvae in
tyre piles. The suppression of adult mosquitoes requires the use of adulticides, toxic
chemicals that are not environmentally benign. In addition, it is usually difficult for
them to penetrate the pile sufficiently to reach the mosquitoes.61 When fumigating
tyre piles, the mosquitoes tend to concentrate at the bottom of the pile, where
fumigation does not reach them in high enough concentrations. Therefore, it is not
uncommon for them to become resistant to insecticides.
61
University of Rhode Island, Office of Mosquito Abatement Coordination, Mosquitoes, Disease and
Scrap tyres
CEMB
The assumption is wrong, there is no cause-effect to support it. If fumigation does not
reach the insects because they are at a bottom of a pile of used tyres, they cannot
become resistant.
ANNEX I – RECOVERY AND DISPOSAL OF WASTE PNEUMATIC TYRES:
BENEFITS AND DISADVANTAGES
Page 53
Table 19 - Benefits and Disadvantages of the ESD Technologies
Application / Product
Alternative Fuel (Cement kilns
or power stations)
CEMB




Benefits
Conserve natural resources;
High calorific value;
Large volume potential
Recovery of carbon, steel,
rubber
Disadvantages
 Special monitoring
equipment required to
control emissions
 Needs generally shredded
tyres;
 Needs system of supplying
with the separated
waste/tyre fractions
 Costly to operate.
The “disadvantages” are wrong:
1) There is no “special monitoring equipment required to control emissions” other than
what is required in the European Union in cement plants independently of coprocessing tyres.
2) Shredding is not a disadvantage. Furthermore, nearly all of the other applications,
e.g.: Landfill engineering, thermal insulation, sports surfaces, rubber mats, etc. require
clean, finely shredded tyre crumb. This is much more costly and complex shredding,
separating and reclaiming operations than for cement kiln.
Comme
nts
3) A “system of supplying” is simply a part of the waste management chain; it thus
cannot be seen as a disadvantage. Also see elaboration on collection, transport and
UNEP/CHW/OEWG/6/
FRT
blue
storage in chapter D.111 ff and the identified criticality for these activities.
4) The cement plants are operated independently of co-processing tyres; they are
existing installations that are suited for recovery of used tyres as alternative fuels.
Page 56
Table 20 - Problems, Prevention and Control of the ESD technologies
Technology
Co-processing
CEMB
Problems
 Toxic and above
limit air
emissions
(including
PCDD
emissions).
Prevention and Control
 The content of the fuel used and the contents of raw
materials used in cement production;
 Monitoring and stabilization of critical process
parameters, i.e. homogenous raw mix and fuel feed.
 Regular dosage and excess oxygen.
 Limit or avoid alternative raw material feed as part of
raw-material-mix if it includes organic materials and
fuel with low contents of sulphur, nitrogen, chlorine,
metals and VOC.
 TDF can be used no more than 20% as supplementary
fuel.
 Quick cooling of kiln exhaust gases to lower than
200°C in long wet and long dry kilns without
preheating.
 No alternative fuel feed during start-up and shut down.
 Process control optimization, including computerbased automatic control systems;
 The use of modern fuel feed systems;
 Minimizing fuel energy by means of preheating and
precalcination, to the extent possible.
 Preventive measures in non-expected shut down.
The content of this table is unjustifiably, unacceptably and unfairly prejudicial against
co-processing, starting from listing problems as “Toxic and above limit air emissions
(including PCDD emissions)” while other technologies read at the same column “Air
emissions”.
It comes as a surprise that the environmental regulations with strict limit values for
pollutants, including PCDD, that rule co-processing are not taken into consideration.
The EU legislation is well-known worldwide.
The Technical Guidelines on ESM of Used Tyres adress co-processing as a
problematic, dangerous technology, thus suggesting that permits to co-processing are
granted in the EU without necessary provisions.
For the column “Prevention and Control” please refer to the booklet “Cement kilns
firing hazardous wastes” (attached), within the “Guidelines on Best Available
Techniques and Provisional Guidance on Best Environmental Practices relevant to
Article 5 and Annex C of the Stockholm Convention on POPs” (attached), which
recognizes the co-incineration of wastes in the cement kilns as BAT, provided that it is
carried out under strictly controlled circumstances and BEP.
5