Guidelines COPROCEM Low

8/3/2019 Guidelines COPROCEM Low

1/136

The GTZ-Holcim Public Private Partnership

Guidelines on Co-processingWaste Materials in Cement Production


2/136


3/136

The GTZ-Holcim Public Private Partnership

Guidelines on Co-processingWaste Materials in Cement Production


4/136

Guidelines on co-processing Waste Materials in Cement ProductionB

These Guidelines are addressed to stakeholders and decision makers from the private and public sectorsengaged in waste management and cement production. The document offers guiding principles and gives ageneral orientation concerning the conditions in which co-processing can be applied. They make certain rec-ommendations and provide certain country-specific experiences, but cannot and should not be used as atemplate. Each person, legal entity or country, in engaging in waste co-processing, must develop its ownstandards based on international conventions and national and local conditions and must harmonize themwith its legal framework. These Guidelines shall not be legally binding nor shall they be construed as consti-tuting any obligation, representation or warranty on the part of the authors or the sender or any technical,commercial, legal or any other advice.

While all reasonable care has been taken to ensure accuracy of the information contained in theseGuidelines, none of Holcim Group Support Ltd and Deutsche Gesellschaft fr Technische ZusammenarbeitGmbH (GTZ) and/or any of its respective affiliates, directors, officers, employees, consultants, advisers and/orcontractors accepts any responsibility or liability for any errors, or omissions in or otherwise in relation tothese Guidelines. Nor does the information imply an opinion on the part of or any endorsement by suchentities or persons.

For all purposes, the legal relationship of the legal entities, individuals or any other persons mentionedin these Guidelines (each a Person) to each other shall be that of independent Persons and nothing in theseGuidelines shall be deemed in any way or for any purpose to constitute either Person or any affiliate of a

Person or a member of either Persons group an agent of any of the other Persons or any affiliate of any ofthe other Persons or any member of either Persons group in the conduct of such Person's business or to cre-ate a partnership, an agency or joint venture between such Persons.

Copyright 2006 Holcim Group Support Ltd and

Deutsche Gesellschaft fr Technische Zusammenarbeit (GTZ) GmbHAll rights reserved.

Important Notice


5/136

CGuidelines on co-processing Waste Materials in Cement Production

One of the major objectives of these Guidelines is to help make waste management more efficient by offering objec-tive information about co-processing of waste in the cement industry. This ambitious report is based on intensivedialogues and working sessions.

These Guidelines have been prepared by experts from Holcim and GTZ. Support and advice were given by avariety of external experts from public and private sector as well as from the cement industry and from organizationsworking in international development cooperation. The elaboration of the document was coordinated by theInstitute for Ecopreneurship (IEC) of the University of Applied Sciences Northwestern Switzerland (FHNW).

The Management Team of this initiative wishes to express sincere thanks to the collaborating experts fromHolcim and GTZ and all who participated by sharing their time, information and insights.

Participants of the start-up event in September 2003 in Bonn, Germany

Deutsche Gesellschaft fr

Technische Zusammenarbeit

GmbH (GTZ)

D. Ziegler, W. SchimpfP.O. Box 518065726 EschbornGermanyTel. ++49 6196 79 0Fax ++49 6196 79 11 15

[email protected]

Holcim Group Support Ltd

B. Dubach, J-P. DegrHagenholzstr. 858050 ZrichSwitzerlandTel. ++41 58 858 82 30Fax ++41 58 858 82 [email protected]

Fachhochschule

Nordwestschweiz FHNW

D. MutzGrndenstrasse 404132 MuttenzSwitzerlandTel. ++41 61 467 42 42Fax ++41 467 44 [email protected]

www.fhnw.ch

About these Guidelines

For further information contact: www.coprocem.com


6/136

Guidelines on co-processing Waste Materials in Cement ProductionD

These Guidelines result from a joint initiative by theDeutsche Gesellschaft fr Technische ZusammenarbeitGmbH (GTZ) and Holcim Group Support Ltd (Holcim), topromote the co-processing of waste in cement kilns that is, the use of wastes along with other materials inkilns to produce cement. Holcim (Y www.holcim.com)isa worldwide leading supplier of cement and aggregatesas well as value-adding activities such as ready-mix con-crete and asphalt, including services. GTZ (Ywww.gtz.de)is a government owned corporation for internationalcooperation for sustainable development with world-wide operations. The findings and recommendations arebased on experiences from industrialized and develop-ing countries, as well as from the public and private sec-tors.

The Guidelines are also based on initiatives ofbilateral or multilateral organizations to improve wastemanagement at national and local levels, as well asattempts by the cement industry to reduce the nega-

tive environmental impacts of cement production.

We have paid special attention to the work of theCement Sustainability Initiative (CSI) of the World Busi-ness Council for Sustainable Development (WBCSD),which looks at options for improving environmental per-formance and increasing corporate social responsibility.

Using waste co-processing in cement productionwill help in achieving the targets set in Agenda 21 of theEarth Summit in Rio de Janeiro (1992), theJohannesburg Declaration on Sustainable Develop-

ment (2002) and the Millennium Development Goals.

We prepared the Guidelines taking into considera-tion all related international conventions such as theBasel and the Stockholm Conventions and the UN Frame-work Convention on Climate Change (Kyoto Protocol).

Avoiding the creation of wastes and reducingtheir quantities are the best ways of dealing withcurrent waste problems all over the world. Whereverpossible, the concepts of resource efficiency, cleanerproduction (CP), recycling and reuse must be given firstpriority. Co-processing of wastes does not conflict with

the waste hierarchy, as it can be classified as a technol-

ogy for energy and material recovery.These Guidelines are based on an approach that

aims to reduce existing waste problems in developingcountries and at the same time to encourage the use ofwaste as an alternative source for primary energy andvirgin raw materials in cement kilns.

Close collaboration and co-operation between thepublic and the private sectors are the key to achievingthe maximum benefit from co-processing of waste incement kilns. Innovative techniques and technical know-how are available and will be further developed by theprivate sector, whereas the public sector should ensurethat environmental standards are maintained andhealth and safety regulations are applied and enforced.

There is general agreement that co-processing ofwaste in cement kilns requires:

Y the observation of and compliance with all applicable

laws and regulations (in some jurisdictions the legis-lation in relation to waste processing has yet to beput in place or is in the process of being amended inline with regulatory or technical developments)

Y facility personnel and government regulators/in-spectors knowledgeable and experienced in wastecombustion, including toxic/hazardous waste

Y a proper enforcement of the legal framework for allwaste management activities, combined with moni-toring by the authorities and the strict enforcementof regulations

Y the establishment of local emergency preparedness

and response programs, in addition to any nationalprogramsY health and safety programs for personnel who may

come into contact with toxic or hazardous wasteY a corporate responsibility approach on the parts of

the private and public sectors alikeY transparency in terms of information and communi-

cations.

Thus ethical conduct, good governance and socialresponsibility are prerequisites for successfully imple-menting the Guidelines.

Foreword


7/136

EGuidelines on co-processing Waste Materials in Cement Production

1.0 Executive summary ....................................................................................................................................1

2.0 Introduction .............................................................................................................................................. 3

3.0 Purpose, target groups, and boundaries of the Guidelines ....................................................................5

4.0 General definition and principles of co-processing ................................................................................7

5.0 Main characteristics of co-processing in the cement industry .............................................................. 11

5.1 Cement manufacturing ....................................................................................................................................11

5.2 Co-processing in the cement industry ..........................................................................................................13

5.2.1 The process and its application .........................................................................................................................................135.2.2 Co-processing and waste management ........... ............ ........... ............ ........... ............ ........... ............ ........... ............ .....145.2.3 Pre-processing: From waste to AFR ................................................................................................................................. 165.2.4 Financing of waste services and the polluter-pays principle ............................................................................... 16

5.3 Requirements for the implementation of co-processing ...........................................................................175.3.1 Institutional challenges for co-processing .................................................................................................................... 175.3.2 Areas for capacity building ..................................................................................................................................................175.3.3 Implementation of capacity development .......... ............ ........... ............ ........... ........... ............ ........... ............ ........... ..185.3.4 Implementation of the Guidelines .................................................................................................................................. 19

6.0 Requirements for co-processing in cement kilns ...................................................................................21

6.1 Legal aspects .....................................................................................................................................................21

6.1.1 Principles .....................................................................................................................................................................................216.1.2 The legal framework ..............................................................................................................................................................216.1.3 The institutional framework .............................................................................................................................................. 226.1.4 Emission control and selection of waste: Enforceable standards are needed ............ ........... ............ .......... 226.1.5 Permitting process for co-processing .............................................................................................................................246.1.6 Baseline testing trial burn testing ...............................................................................................................................26

6.2 Environmental aspects of cement production and AFR pre-processing ................................................. 276.2.1 Principles .................................................................................................................................................................................... 276.2.2 Significant emissions ............................................................................................................................................................ 27

6.2.3 Generation of emissions and reduction techniques ........... ............ ........... ............ ........... ............ ........... ............ ....296.2.4 Monitoring and reporting of emissions ........................................................................................................................306.2.5 Environmental impact of pollutants in products .......................................................................................................316.2.6 Leaching of incorporated pollutants from concrete ........... ............ ........... ............ ........... ............ ........... ............ ..... 316.2.7 Special comments regarding Dioxins and Furans .....................................................................................................326.2.8 Management of kiln and bypass dust ........................................................................................................................... 33

6.3 Operational issues ........................................................................................................................................... 34

6.3.1 Principles .................................................................................................................................................................................... 346.3.2 Waste and AFR sourcing ...................................................................................................................................................... 356.3.3 Materials transport, handling and storage .................................................................................................................. 356.3.4 Operational aspects...............................................................................................................................................................366.3.5 Quality control system ......................................................................................................................................................... 376.3.6 Monitoring and auditing .....................................................................................................................................................38

Contents


8/136

Guidelines on co-processing Waste Materials in Cement ProductionF

6.4 Occupational health and safety (OH&S) ......................................................................................................39

6.4.1 Principles ....................................................................................................................................................................................396.4.2 The cornerstones of an occupational health & safety (OH&S) system .......................................................... 406.4.3 Organization for safety and security .............................................................................................................................. 426.4.4 Spill response plan .................................................................................................................................................................436.4.5 Emergency response plans .................................................................................................................................................43

6.5 Communication issues and social responsibility ........................................................................................ 436.5.1 Principles and requirements .............................................................................................................................................. 436.5.2 The importance of communication ................................................................................................................................446.5.3 A systemic approach to communications ........... ............ ........... ............ ........... ............ ........... ........... ............ ........... ..44

Contents


9/136

GGuidelines on co-processing Waste Materials in Cement Production

Index of Case Studies ................................................................................................................................................... i-ixxCase 1 Selection of adequate feed points - The example of Lgerdorf, Holcim Germany ........... ........... ............ ........ iCase 2 An integrated waste management concept The example from Cartago, Costa Rica ........... ............ ....... iiiCase 3 Pre-processing of waste material - The example of Energis, Holcim Group, in Albox, Spain ............ .........vCase 4 Aspects of permitting The example from North Rhine Westfalia, Germany..............................................viiCase 5 Emissions Monitoring and Reporting (EMR) - The experiences at Holcim .......... ............ ........... ............ ......... ixCase 6 Pre-processing of waste material The example of Ecoltec, Mexico ............ ........... ............ ........... ............ ....... xiCase 7 Test burns with PCDDs/PCDFs monitoring - The Philippines examples ............ ........... ............ ........... ........... xiiiCase 8 AFR quality control laboratory - The example of Resotec, Brasil ........... ............ ........... ............ ........... ............ .... xvCase 9 Erika waste recovery The example of Holcim support for oil tanker spill clean-up, France ........... ....xviiCase 10 Community advisory panel: The example of Energis in Albox, Spain ........... ........... ............ ........... ............ .....xix

Index of Annexes .......................................................................................................................................................A1-A53

Annex 1 Bibliography, Literature and Internet links ........... ............ ........... ............ ........... ............ ........... ........... ............ ........... .A2Annex 2 Waste used for AFR in Europe and Japan ........... ............ ........... ............ ........... ............ ........... ............ ........... ........... ...A5Annex 3 Development of the utilization of alternative fuels in the German cement industry .......... ............ ........ A7Annex 4 Source for contacts and information ............................................................................................................................ A8Annex 5 List of waste material suited for co-processing ...................................................................................................... A10Annex 6 Example of an Accept-Refuse Chart ............ ........... ............ ........... ............ ........... ............ ........... ........... ............ .......... A18

Annex 7 Limit values for waste and AFR .......... ............ ........... ............ ........... ............ ........... ........... ............ ........... ............ ..........A19Annex 8 Justification for the exclusion of certain waste material from co-processing ........... ............ ........... ......... A22Annex 9 Permit model ......................................................................................................................................................................... A25Annex 10 Application form ..................................................................................................................................................................A30Annex 11 Permitting process .............................................................................................................................................................. A34Annex 12 Information on test burn ............ ........... ............ ........... ............ ........... ............ ........... ........... ............ ........... ............ ........A35Annex 13 EPER The European Polluting Emissions Register for the cement industry ........... ............ ........... ........... .A37Annex 14 Ranges of emissions and reduction techniques ............ ........... ............ ........... ............ ........... ........... ............ ......... A38Annex 15 Total emission limit values for cement kilns co-processing waste .......... ............ ........... ........... ............ .......... A41Annex 16 Summary of the WBCSD/UNEP report on POPs ..................................................................................................... A42Annex 17 Template for master data file for commonly used waste ........... ........... ............ ........... ............ ........... ............ ... A45Annex 18 AFR quality control scheme ............ ........... ............ ........... ........... ............ ........... ............ ........... ............ ........... ............ ...A49

Annex 19 Situation analysis how to do it ..................................................................................................................................A50

General and chemical abbreviations & Glossar ........................................................................................................... A51

Glossary ..........................................................................................................................................................A53


10/136


11/136

1Guidelines on co-processing Waste Materials in Cement Production

Different types of wastes have been successfully co-processed as alternative fuels and raw materials (AFR)in cement kilns in Europe, Japan, USA, Canada and Aus-tralia since the beginning of the 1970s.

These Guidelines are meant to gather the lessonsof that experience and offer it particularly to developingcountries that need to improve approaches to wastemanagement. Some developing countries will need ca-pacity building help before launching AFR programs.

The Guidelines, meant for all of the cement indus-try and all of its stakeholders, result from a public-privatepartnership between Deutsche Gesellschaft fr Techni-sche Zusammenarbeit GmbH (GTZ) (Y www.gtz.de) andHolcim Group Support Ltd. (Y www.holcim.com). Thesefindings and recommendations are based on experienc-es from industrialized and developing countries, as wellas from the public and private sectors. They are alsobased on initiatives of bilateral and multilateral organi-

zations to improve waste management at national andlocal levels, as well as attempts by the cement industryto reduce environmental degradation resulting from ce-ment production. They reflect international laws andconventions.

The use of AFR can decrease the environmentalimpacts of wastes, safely dispose of hazardous wastes,decrease greenhouse gas emissions, decrease wastehandling costs and save money in the cement industry.It will help in achieving the targets set in Agenda 21 ofthe Earth Summit in Rio de Janeiro (1992), the Johan-

nesburg Declaration on Sustainable Development(2002) and the Millennium Development Goals. How-ever, there are some basic rules and principles thatshould be observed.

AFR use should respect the waste hierarchy, be inte-grated into waste management programs, support strat-egies for resource efficiency and not hamper waste re-duction efforts. Following certain basic rules assures thatthe use of AFR does not have negative impacts on cementkiln emissions. Co-processing should not harm the quali-ty of the cement produced.

Countries considering co-processing need appro-

priate legislative and regulatory frameworks. Nationallaws should define the basic principles under which co-

processing takes place and define the requirementsand standards for co-processing. Regulators and opera-tors should conduct baseline tests with conventionalfuels and materials so they can compare AFR results tothese. Some wastes should never be co-processed;these range from unsorted municipal garbage and cer-tain hospital wastes to explosives and radioactivewaste. Other wastes will need pre-processing beforethey can be used, and approaches to AFR use shouldtake account of the need to effectively regulate andmanage these pre-processing plants.

Following certain basic rules assures that the useof AFR does not change the emissions of a cement kilnstack. These include feeding alternative fuels into themost suitable zones of the kiln, feeding materials thatcontain a lot of volatile matter into the high tempera-ture zone only, and avoiding materials that contain pol-lutants kilns cannot retain, such as mercury. Emissionsmust be monitored, some only once a year and others

continuously. Environmental impact assessments (EIA)should be done to confirm compliance with environ-mental standards; risk assessments can identify anyweaknesses in the system, and material flux and energyflow analyses help to optimize the use of resources.

Cement plant operators using AFR shall ensuretheir traceability from reception up to final treatment.Transport of wastes and AFR must comply with regula-tions. Plants must have developed, implemented andcommunicated to employees adequate spill responseand emergency plans. For start-up, shut-down and con-

ditions in between, strategies for dealing with AFR mustbe documented and available to plant operators. Plantsneed well-planned and functioning quality control sys-tems, as well as monitoring and auditing protocols.

Risks can be minimized by properly locating plantsin terms of environmental setting, proximity to popula-tions and settlements, and the impact of logistics andtransport. Plants will require good infrastructure interms of technical solutions for vapors, odors, dust, in-filtration into ground or surface waters, and fire protec-tion. All aspects of using AFR must be well documented,as documentation and information are the basis for

openness and transparency about health and safetymeasures, inside and outside the plant.

1.0 Executive Summary


12/136

Guidelines on co-processing Waste Materials in Cement Production2

Management and employees must be trained inhandling and processing of AFR. Hazardous operationstraining for new workers and subcontractors should becompleted before starting with co-processing. Periodicre-certification should be done for employees and sub-contractors. Induction training should be included forall visitors and third parties. Understanding risks andhow to mitigate them are keys to training. Training au-thorities is the basis for building credibility.

Introducing AFR requires open communicationswith all stakeholders. Provide all the information stake-holders need to allow them to understand the purposesof co-processing, the context, the functions of partiesinvolved, and decision-making procedures. Open dis-cussions about good and bad experiences are part oftransparency, leading to corrective actions. Be credibleand consistent, cultivating a spirit of open dialogue andrespect for differing cultures.

In these Guidelines the bar has been kept high interms of environmental, social and health and safetystandards, but they are realistic and achievable. Ambi-tious targets are needed in order to achieve goals

(e.g. the Millennium Development Goals). However, onecannot expect that the public sector in any country oreach and every cement plant operator or waste han-dling company anywhere in the world can implementall the proposed standards straight away. To achieve theproposed standards, a stepwise and country specific(phasing) program or action plan is required, which ide-ally represents a consensus (reflecting the enhancedcooperation) between the public and private sector.

As populations increase in the developing world,so do waste management problems, and so does theneed for more cement and concrete for housing andthe infrastructure of development. The properly man-aged use of wastes as fuels and raw materials in ce-ment kilns can help manage wastes while contributingto the sustainable development of our world.

1.0 Executive Summary


13/136


Greenhouse gases and global warming, the efficientuse of non-renewable fossil fuels, toxic residues, andthe contamination of water and soil resources are inthe forefront of ecological concerns and public discus-sions. Cost competitiveness, global competition andprofitability are the concerns of business. The challengefacing todays society is to balance environmental pro-tection and economic interest.

The cement industry consumes a significantamount of natural resources and energy. It also contrib-utes worldwide to the development and modernizationof cities and infrastructure. The cement industry and itsassociations continuously try to improve environmen-tal performance by optimizing the use of natural re-sources and reducing its overall energy consumption.

Cement consumption is increasing, especially indeveloping countries and countries in transition. World-wide cement production in 2003 was 1.94 billion tons

(metric tons), increasing from 1.69 billion tons in 2001with a steady increase of an estimated 3.6% yearly dueto the strong demand in developing countries andcountries in transition. Europes share of consumptionis 14.4%; USA, 4.7%; the rest of the Americas, 6.6%;Asia, 67.5% (China, 41.9%); Africa, 4.1%, and the rest ofthe world 2.7%. Estimated cement consumption in2004 was 260 kg per capita (Source: Cembureau1).

Whenever possible, best available technology(BAT) should be used2 and can usually achieve signifi-cant reductions in energy consumption. Over the past

20 years, the European cement industry has reduced itsenergy consumption by about 30%, equivalent to sav-ing approximately 11 million tons of coal per year.

Substituting fossil fuel and virgin raw material bywaste (Alternative Fuels and Raw materials AFR) willfurther reduce overall CO2 emissions if the waste mate-rial being used would instead have been burned ordisposed without energy recovery.

The cement industry presents a mixed picture. In-ternational companies, whose market share is increas-ing, usually adopt their own internal standards through-out the world, using best available technologies whenbuilding new facilities. From a technical point of view,all kiln types are suited for co-processing. However,older, polluting, and less integrated technologies aregradually being phased out due to stricter standardsand/or voluntary best practices. Older cement plantsmay fall short of both best available technology stand-ards and standards related to business ethics, laborrights, health, safety and environment. The situationvaries in different countries due to the cement marketstructure and the state of regulations.

Poor waste management is a challenge in develop-ing countries and in countries in transition. In most ofthose countries, waste is discharged to sewers, buried orburned on company premises, illegally dumped at un-suitable locations, or taken to landfills that fail to meet

requirements for the environmentally sound final dis-posal of waste. This can cause contamination of soil,water resources, and the atmosphere, leading to thesustained deterioration of the living conditions andhealth of the adjacent populations. Toxic substances andpersistent compounds escape into the environment, arespread through the air over large areas, and can enterthe food chain, affecting human and animal health.

Several factors can cause these problems:Y Not all developing countries have an integrated

waste management strategy and only a few can of-

fer an appropriate technical infrastructure for dis-posing of waste in a controlled and environmentallysound manner

Y Although in many cases laws concerning the control-led handling of waste exist, they are often not prop-erly enforced

Y Uncontrolled disposal is usually the cheapest way toget rid of the waste, and the waste generators tendto be unwilling to pay much for adequate disposal

1 Cembureau, based in Brussels, is the representative organization of the cement industry in Europe and includes 25 members2 Useful information on BAT can be found in the following two documents:

- Cembureau, 1999. Best Available Technology for the cement industry- Integrated Pollution Prevention and Control (IPPC) 2001. Reference document on Best Available Technology in the Cementand Lime manufacturing industries

2.0 Introduction


14/136

LocationPercentage of thermalenergy substituted by AFR

Year

France 32% 2003Germany 42% 2004

Norway 45% 2003

Switzerland 47% 2002

USA 25% 2003


Y Policy makers rarely pay enough attention to the subject of waste management, and may know littleabout the consequences for human health or thehigh cost of the remediation of the damage causedby uncontrolled waste disposal.

There is general agreement that there is an urgentneed to improve waste management, and different so-lutions are being discussed. Waste avoidance, cleanerproduction, producer responsibility, supply chain man-agement or sustainable use of natural resources areonly a few of the strategies being promoted. In spite oftechnological progress and an increasing social andpolitical awareness, the problem of growing wastestreams persists. The zero waste society is a worthyvision, but we are far from realizing it.

Modern incineration plants and secure landfillsare common disposal options in OECD countries buthave high investment and operating costs and need

qualified personnel. An efficient cement kiln can pro-vide an environmentally sound, and cost-effective treat-ment/recovery option for a number of wastes.

Different types of wastes have been successfullyused as AFR in cement kilns or similar plants in Europe,Japan, USA, Canada and Australia since the beginningof the 1980s [Y see Annex 2: Utilization of alternative

fuels in the European and Japanese cement industry ].

YTable 1 gives an overview of energy substitutionthrough AFR in the cement industry in selectedcountries.

Industrialized countries have had more than 20years of positive experiences with AFR [Y see Annex 3: AFR development in Germany ]. Why then are wastesnot being used routinely as AFR in the cement plants ofdeveloping countries, and why has co-processing notbeen better promoted as an ecologically beneficial formof energy and material recovery? The main reasons arelimited knowledge of the potential of AFR and of legis-lative and institutional requirements related to co-processing, political reservations, legal uncertaintiesand concerns of the public and NGOs over environmen-tal and health damage.

Co-processing of hazardous waste in cement pro-duction has been recognized as an environmentallysound disposal method in the context of the Basel Con-

vention3. This addresses the suitability of co-processingof hazardous waste in cement production and the con-ditions to which it should be subject.

These Guidelines are intended to make decisionmakers from public authorities, the cement industry andthe interested public aware of co-processing as a tool inwaste management and to increase the quality of dis-cussion and decision making in waste management.

Table 1: Share of AFR in the total fuel demand in the cement industry in selected countries (Source: CEMBUREAU, SINTEF)

3 The Basel Convention Technical Guidelines on Incineration on Land, SBC, 1995 (paragraphs 26-27)

The General technical Guidelines for the environmentally sound management of wastes consisting of, containing or contaminated withpersistent organic pollutants, SBC, 2004 (section G.2.c)

2.0 Introduction


15/136


3.0 Purpose, Target Groupsand Boundaries of the Guidelines

We have tried to make these Guidelines valid for allcountries, independent of location or level of industriali-zation. However they focus mainly on the use of wastematerial as AFR in cement production in developingcountries and countries in transition, thereby offeringan environmentally sound and financially feasible alter-native use for some waste material. One of our majorobjectives is to help reduce the deficiencies in wastemanagement. We aim to offer objective informationabout co-processing of waste in the cement industry.

[ A comprehensive list of literature and Internet links is

attached asAnnex 1]

The Guidelines are meant to provide various targetgroups with relevant information on (i) technical andlegal conditions, (ii) environmental, safety and healthstandards, and (iii) professional requirements needed toensure that co-processing of waste does not have nega-tive environmental or human health impacts.

The Guidelines offer an overview of strategies forcommunication and stakeholder engagement and rec-ommendations for the legal framework needed toguide the permitting process and the control and en-forcement procedures.

The Guidelines offer links to organizations, institu-tions, and companies active in the field of co-processingand propose ways and means for capacity building atall levels to ensure sound application of the technology.They give references to relevant international environ-

mental agreements.

Beside these core objectives the Guidelines arealso meant to help:Y to promote dialogue among public authorities, pri-

vate enterprises, and civil society, leading to a better-informed discussion among the various groups

Y to raise awareness and build technical know-how,which can have positive effects across the entirewaste management sector

Y to show that waste can be an alternative resource forenergy and material recovery.

The topics of the Guidelines include the prepara-tion of AFR before feeding them into the kiln (pre-processing) and their use as an energy source and rawmaterial in the kiln itself (co-processing). They also con-sider topics such as storage, transport, and environ-mental awareness. The Guidelines do not cover quarryissues and the re-use of concrete.

The Guidelines are aimed at the following target

groups:Y government organizations and public institutionsY local communitiesY non-governmental organizationsY the cement industry, their associations and feder-

ations as well as the concrete industryY operators of waste handling facilitiesY laboratories involved in waste quality controlY waste generators.


16/136


17/136


4.0 General Definitionsand Principles of Co-processing

These Guidelines use the following definitions:

YWaste: The EC Framework Waste Directive 75/442/EEC,Article 1 defines waste as any substance or object,which (a) the holder discards or intends or is requiredto discard or (b) has to be treated in order to protectthe public health or the environment. Waste materi-al can be solid, liquid, or pasty. Any waste material canbe defined by its origin (industry, agriculture, miningetc), hence a proper list should always be establishedat national level to help create a common under-standing and define a legal framework. Where nospecific list has been defined, the EC Waste Cataloguemight serve as a reference.

YHazardous and non-hazardous waste: The EC Directive91/689/EC on Hazardous Waste defines hazardouswaste by reference to two Annexes that evaluate thelevel of danger of a material (harmful, irritating, com-bustible). However, legislation can vary greatly be-

tween countries (except within the EU), leading todifferences in determining whether a waste is hazard-ous or not. For countries where no classification ofwaste exists, either the Waste List of the Basel Conven-tion4 or the EC Waste Catalogue5 is recommended.

YCo-processing: This refers to the use of waste materi-als in industrial processes, such as cement, lime, orsteel production and power stations or any other

large combustion plants. Even though the EU callsthis process co-incineration, for the purpose of theseGuidelines, co-processing means the substitution ofprimary fuel and raw material by waste. It is a recov-ery of energy and material from waste. Co-processingis further explained in Y see chapter 5.

YAFR (Alternative Fuel and Raw Materials): This refersto waste materials used for co-processing. Suchwastes typically include plastics and paper/card fromcommercial and industrial activities (e.g. packagingwaste or rejects from manufacturing), waste tires,waste oils, biomass waste (e.g. straw, untreated wastewood, dried sewage sludge), waste textiles, residuesfrom car dismantling operations (automative shred-der residues - ASR), hazardous industrial waste (e.g.certain industrial sludges, impregnated sawdust,spent solvents) as well as obsolete pesticides, out-dated drugs, chemicals and pharmaceuticals.

Y Pre-processing: Transforming waste to AFR requirescertain standards. AFR does not always consist of aspecific waste stream (such as tires or solvents) butmust be prepared from different waste sources beforebeing used as fuel or raw material in the cement plant.The preparation process is needed to produce an AFRstream that complies with the technical and adminis-trative specifications of cement production and toguarantee that environmental standards are met.

4 http://www.basel.int/text/con-e-rev.pdf5 http://www.vrom.nl/get.asp?file=/docs/milieu/eural_engelse_versie.pdf


18/136

Principle I

Co-processing respects the waste hierarchy:Y Co-processing does not hamper waste reduction efforts, and waste shall not be used in

cement kilns if ecologically and economically better ways of recovery are available.Y Co-processing shall be regarded as an integrated part of modern waste management, as it

provides an environmentally sound resource recovery option for the management of wastes.

Y Co-processing is in line with relevant international environmental agreements, namely theBasel and Stockholm Conventions.

Principle II

Additional emissions and negative impacts on human health must be avoided:Y To prevent or keep to an absolute minimum the negative effects of pollution on the

environment as well as risks to human health.Y On a statistical basis, emissions into the air shall not be higher than those from cement

production with traditional fuel.

Principle III

The quality of the cement product remains unchanged:Y The product (clinker, cement, concrete) shall not be abused as a sink for heavy metals.Y The product should not have any negative impact on the environment as e.g. demonstrated

with leaching tests.Y The quality of cement shall allow end-of-life recovery.

Principle IV

Companies engaged in co-processing must be qualified:Y Have good environmental and safety compliance track records and to provide relevant infor-

mation to the public and the appropriate authorities.Y Have in place personnel, processes, and systems demonstrating commitment to the

protection of the environment, health, and safety.Y Assure that all requirements comply with applicable laws, rules and regulations.Y Be capable of controlling inputs and process parameters required for the effective

co-processing of waste materials.Y

Ensure good relations with the public and other actors in local, national and internationalwaste management schemes.

Principle V

Implementation of co-processing has to consider national circumstances:Y Country specific requirements and needs must be reflected in regulations and procedures.Y A stepwise implementation allows for the build-up of required capacity and the set-up

of institutional arrangements.Y Introduction of co-processing goes along with other change processes in the waste manage-

ment sector of a country.


The following general principles should be followed:

4.0 General Definitionsand Principles of Co-processing


19/136


20/136


21/136


5.0 Main Characteristics of co-processingin the Cement Industry

5.1 Cement Manufacturing

Cement manufacturing is a material-intensive process.After mining, grinding and homogenization of raw ma-terials, the next step in cement manufacturing is calci-nation of calcium carbonate, followed by sintering theresulting calcium oxide with silica, alumina, and ironoxide at high temperatures to form clinker. The clinkeris then ground or milled with gypsum and other con-stituents to produce cement. Naturally occurring cal-careous deposits such as limestone, marl, or chalk pro-vide the source for calcium carbonate. Silica, iron oxideand alumina are found in various ores and minerals,such as sand, shale, clay, and iron ore. However, processresidues are more and more used as replacements forthe natural raw materials. Producing one ton of clinkerrequires an average of 1,5 1,6 tons of raw materials.Most of the material is lost from the process as carbondioxide emissions to air in the calcination reaction(CaCO3YCaO + CO2).

Cement production also has high energy require-ments, which typically account for 30-40% of the pro-duction costs (excluding capital costs). Traditionally,the primary fuel has been coal, but a wide range ofother fuels is also used, including petroleum coke,natural gas and oil. In addition to these fuels, varioustypes of waste are used as fuel. Clinker is burned in arotary kiln that can be part of a wet or dry long kilnsystem, a semi-wet or semi-dry grate preheater (Lepol)kiln system, a dry suspension preheater kiln system, ora preheater/precalciner kiln system6. The best availabletechnique for the production of cement clinker is a dryprocess kiln with multi-stage suspension preheatingand precalcination. Modern cement plants have anenergy consumption of 3,000-3,300 MJ per ton ofclinker, whereas the wet process with long kilns con-sumes up to 6,000 MJ per ton.

6 A detailed description of the different kiln types is given in the chapters 3.4 & 3.5 of the CEMBUREAU BAT document (2000). The documentcan be downloaded under: http://www.cembureau.be/Documents/Publications/CEMBUREAU_BAT_Reference_Document_2000-03.pdf

Figure 2: The process of cement production (Source: VDZ)


22/136

Characteristics Temperature and time

Temperature atmain burner

>1450C: material>1800C: flame temperature.

Residence time atmain burner

>12-15 sec and >1200C>5-6 sec and >1800C

Temperature atprecalciner

>850C: material>1000C: flame temperature

Residence time atprecalciner

>2 - 6 sec and >800C



The emissions from cement plants that cause the great-est concern are nitrogen oxides (NOx), sulfur dioxide(SO2), and dust. Other important emissions to be consid-ered are carbon oxides (CO, CO2), volatile organic com-pounds (VOC), dioxins (PCDDs) and furans (PCDFs), andmetals. The emission values depend mainly on inputmaterials (raw material and fuel), the temperature level,and the oxygen content during the combustion stages.In addition, kiln emissions can be influenced by flame

shape and temperature, combustion chamber geometry,the reactivity of the fuel, the presence of moisture, theavailable reaction time, and the burner design.

Although high temperature at the main burner isthe main reason for the formation of thermal NOx, thisheat is also able to completely destroy unwanted or-ganic substances present in the input material, a greatenvironmental advantage.

Dust is released from cement production process-es either as point source dust (kiln stack, cooler stack,cement mill stack) or as fugitive (dispersed dust fromstockpiles, material transfer points, and road transpor-tation). Most of the dust is pure pulverized raw mate-rial. Second in importance is clinker and cement mill

dust. The cement production process does not (with afew local exceptions) produce liquid effluents. All waterconsumed (mainly for gas cooling purposes) is releasedto the atmosphere as water vapor. Surface water qualitymight be impaired if storm waters flush large quanti-ties of settled dust out of a dusty plant and directly intoadjacent small surface waters.

The optimization of the clinker burning processand the continuous development and introduction ofabatement techniques (such as dust filters, desulphuri-

zation, or selective non-catalytic reduction) have low-ered certain cement kiln emissions considerably.

The process, the best available technologies, andenvironmental impacts are described comprehensivelyin the reference document produced under the EC Inte-

grated Pollution and Prevention process7

and in theBAT-BEP Guidelines on Best Available Technology andprovisional guidance on best environmental practices8.In addition, the Cement Sustainability Initiative of theWBCSD has come up with Guidelines on co-processingthat reflect a consensus of the private sector.

7 http://eippcb.jrc.es8 for example the BAT-BEP on best environmental practices relevant to Article 5 and Annex Cof the Stockholm Convention can be found under http://www.pops.int/documents/batbep_advance/default.htm

Table 2: Temperature and residence time during cement production


23/136

1 2

4

3

5 6

2

3

4 5

6

Gas Temp. Special Features

2000-1050 All organics burnt, fuelash =

raw material, incorporated in clinker

1200-880 SO2and HCI trapped due to

presence of CaO

880-100 Act as a 5-stage dry scrubber

for combustion gases

80-100 99.999% dedusting effinciencyClinker

ExhaustGas

Natural andAlternativeRaw Materials

Conventionaland Alternative

1

2

3

4

5

6

Clinker Cooler

Rotary Kiln

Precalciner

Raw Meal (Cyclone) Preheater

Raw Mill

Bag Filter (or Electrostatic Separator)


5.2.1 The process and its application

Co-processing refers to the use of waste materials inindustrial processes, such as cement, lime, or steel pro-duction and power stations or any other large combus-tion plants. Co-processing means the substitution ofprimary fuel and raw material by waste, recoveringenergy and material from waste. Waste materials usedfor co-processing are referred to as alternative fuels andraw materials (AFR).

Different feed points can be used to insert AFRinto the cement production process. The most com-mon ones are:Y via the main burner at the rotary kiln outlet endY via a feed chute at the transition chamber at the

rotary kiln inlet end (for lump fuel)Y via secondary burners to the riser ductY via precalciner burners to the precalcinerY via a feed chute to the precalciner (for lump fuel)Y via a mid kiln valve in the case of long wet and

dry kilns (for lump fuel).

[Y see Case Study 1: Selection of adequate feed points-

The example of Lgerdorf, Holcim Germany ]

Alternative raw materials are typically fed to thekiln system in the same way as traditional raw materi-als, e.g. via the normal raw meal supply. Alternative rawmaterials containing components that can be volatil-ized at low temperatures (for example, hydrocarbons)have to be fed into the high temperature zones of thekiln system (as above).

Co-processing has the following characteristicsduring the production process:Y The alkaline conditions and the intensive mixing fa-

vor the absorption of volatile components from thegas phase. This internal gas cleaning results in lowemissions of components such as SO2, HCl, and, withthe exception of mercury and thallium, this is alsotrue for most of the heavy metals.

Y The clinker reactions at 1450C allow incorporation of

ashes and in particular the chemical binding of met-als to the clinker.

Y The direct substitution of primary fuel by high calo-rific waste material causes a higher efficiency onenergy recovery in comparison to other waste toenergy technologies

5.2 Co-processing in the Cement Industry

Figure 3: Clinker process and special characteristics (example: pre-calciner kiln)


24/136

Phys.-chem.treatment

RecyclingLandfillIncinerators

Waste generators, waste segregators

Private or public waste collection and haulage

Pre-processing (platform)

Co-processing (kiln)

Waste collectionand transportsupervised by

cement company

uncontrolieddisposal


25/136


As cement kiln emissions are site-specific, depend-ing on production processes and the input material, acontrol and monitoring system for the incoming wastematerials and for the optimization of the feedingpoints is an important aspect to be considered.

Co-processing is not only the use of waste in placeof traditional fuels, but can also recover valuable rawmaterials.Y Table 3 above gives some examples on rawmaterial recovery from different wastes. For more infor-mation on waste selection Y see chapter 6.1.4 .

Compounds Waste material Industrial sources

Clay mineral / Al2O3YCoating residuesYAluminum recycling sludge

Y FoundriesYAluminum industry

Limestone / CaCO3Y Industrial limeY Lime sludge

YNeutralization processY Sewage treatment

Silicates / SiO2Y Foundry sandYContaminated soil

Y FoundriesY Soil remediation

Iron-oxide / Fe2O3Y Roasted pyriteYMechanical sludgeY Red sludge

YMetal surface treatmentYMetal industryY Industrial waste water treatment

Si-Al-Ca-FeY Fly ashesYCrushed sand

Y IncineratorY Foundries

Sulfur YGypsum from gas desulphurizationYChemical gypsum

Y IncinerationYNeutralization process

FluorineY

CaF2 filter sludgeY

Aluminum industryTable 3: Group classification of alternative raw materials (Source: VDZ)


26/136

Co-processingTransport

Pre-processingTransportCollection

Wastemarket /

Consumer

Sawdust

SludgyWaste

Premix

Pit

Pit Building

A.F.StorageBuilding

SolidWaste

FineSolid A.F.

CoarseSolid A.F.



5.2.3 Pre-processing: From waste to AFR

Wastes occur in different forms and qualities. The trans-formation of waste to AFR requires certain standards.Some types of waste cannot be used directly as AFR, butmust undergo a preparation process. This step producesa waste product with defined characteristics that com-plies with the technical specifications of cement pro-duction and guarantees that environmental standardsare met.

AFR pre-processing plants usually store incomingmaterials and contain grinding, mixing, and homogeni-zation processes. They must have all the required per-mits and monitoring systems, for example for dust,odor, VOC, water and noise.

[Y see Case Study 3: Pre-processing of waste material -

The example of Energis, Holcim Group, in Albox, Spain ]

Figure 5: From wasteto AFR: Pre-processing

operations

The polluter-pays principle must be the basis for theeconomical and financial analysis of co-processing. Thismeans that those who are producing waste (e.g. indus-try) or are responsible for its handling (e.g. municipality)have to take care for its best, environmentally sound

management. The costs for this duty depend on the dif-ferent treatment options available on the market, theenergy or material value of the waste itself, the requiredtechnical standards and the stipulated directives of acountry-specific environmental policy.

Co-processing means additional costs to the ce-ment company of the collection, pre-processing, storageand feeding of AFR to the kiln and of quality control andreporting. These costs are in general composed of run-ning costs (staff and equipment), amortization, interestsand business risk. As supply chain structures and moni-toring systems improve, costs decrease.

The market value of the waste material (positive ornegative) fluctuates and depends on the price for fossilfuel and primary raw materials, market competition andthe costs of alternative treatments. Normally the overallcosts for pre- and co-processing of waste are higher

than the energy and material savings so that a wastefee has to be levied. In only a few cases can the wastematerial reach a profitable market value. This occurswhen the sum of the production and investment costsfor AFR is lower than the market price for fossil energyand raw material.

Much environmental pollution and inadequatewaste handling comes from incorrect pricing of servicesand goods. In order to assure that waste disposal is notonly driven by financing criteria but also follows eco-logical concerns, market-based instruments (MBIs) suchas environmental taxes, incentives or compensation

schemes should be applied. The MBIs have to go hand inhand with strict enforcement and penalties.

5.2.4 Financing of waste services and the polluter-pays principle


27/136


5.3.1 Institutional challenges for co-processing

Co-processing AFR presents challenges for cementplant operators and regulators. The operators need tounderstand and control all impacts that co-processingwill have on the production process, on the final prod-uct, on the environment, and on the health and safetyof the workers. Regulators should understand all theseissues in order to fulfill their roles in controlling envi-ronmental impacts and impacts on health and safety.Both operators and regulators should understand theconcerns of the public over possible negative effects ofco-processing, and they should establish efficient com-munication processes in order to explain their activitiesand to avoid conflicts.

In some places the challenges are more complex.Environmental legislation does not exist in all countries.In others, the regulatory framework may exist, but there

is no enforcement because of lack of human capacity,awareness or resources. Most developing countries lackinformation on the methodology of emission analysisand on the evaluation of analytical data from continu-ous emissions monitoring. Waste statistics are more orless nonexistent, and documentation systems for trac-ing waste are not known. The lack of waste manage-ment plans does not allow for a financially and ecologi-cally optimized handling of waste streams. Thus capac-ity building is required for the regulatory body to ensureenvironmentally sound and efficient co-processing.

5.3.2 Areas for capacity building

The following are baseline questions when consideringa capacity-building process:Y Is the existing legislative and regulatory environmen-

tal framework appropriate for co-processing?Y Are regulations available for the safe pre-processing

of waste? Do the authorities have sufficient regula-tory capacities?

Y Does an integrated waste management plan existthat includes the optimized use of waste material for

the given local circumstances? Do national and localwaste management policies need further develop-ment or updating?

Y Do the industry and authorities understand and usethe concept of waste hierarchy?

Y Are the authorities qualified to authorize, control,and monitor co-processing? To what extent does theadministrative body need support regarding the per-mission and monitoring process?

Y Is there an effective, comprehensive quality controlsystem in place for waste sourcing, routine deliveries,AFR product shipments, and the co-processing sitesend product (clinker, cement)? Does systematic mon-itoring, in combination with periodic third party au-dits by independent institutions, ensure that the op-erations are in compliance with permits and otherinternal or external requirements?

Y Is the cement plant able to comply with the need formonitoring? Are the required equipment and trainedpersonnel available?

Y Are independent testing laboratories (national or re-gional service companies) available and experiencedin monitoring and controlling the quality of AFR andemissions?

Y Does the cement plant interested in processing AFRfulfill national environmental standards in using tra-ditional fuel and raw materials?

Y Are adequate transport, storage, and handling of thewaste material assured? Are there cooperation agree-

ments between the waste-producing industries andthe cement plants that allow for optimal delivery anduse of the waste material? Are the pre-treatmentoperators and haulage companies authorized andreliable?

Y Do adequate emergency response plans exist?Y Are occupational health and safety standards as-

sured? Are management and staff in cement indus-try and haulage companies sufficiently trained inhandling hazardous materials?

5.3 Requirements for the Implementation of co-processing


28/136



5.3.3 Implementation of capacity development

Capacity development is the process of strengtheningthe abilities of individuals, organizations, companies,and societies to make effective and efficient use of re-sources. In the context of these Guidelines, capacitydevelopment comprises first of all the transfer ofknowledge, experience, skills and values. It includes theimprovement of management systems and the exten-sion of networking. Change management and media-tion in conflicting situations are essential parts of insti-tutional development.

When national and local decision makers decide tointegrate co-processing into waste management sys-tems, the legal and institutional framework must beadapted, and those involved from both government andbusiness need profound knowledge of the implicationsof the decision. A comprehensive capacity-buildingstrategy should be designed and agreed on with therelevant stakeholders. Training could be done through or

in cooperation with bilateral and multilateral organiza-tions (i.e. the national focal points of international con-ventions like Basel or Stockholm). An additional partnerfor training could be the cement associations and spe-cialized research institutes and universities. YAnnex 4provides sources for contacts and information.

The objectives of the capacity-building strategycould include information on legal, technical, social,environmental and financial aspects of waste manage-ment in general and co-processing in particular. Thefollowing chapter gives an overview of the different

areas where capacity development and training mightbe required. Since conditions vary from country to coun-try, an individual and carefully designed capacity-build-ing strategy, including a comprehensive training con-cept, must be agreed on. The permitting and supervis-ing authorities must concentrate on their coordinatingand enforcement functions. Therefore the authoritiesdo not need to provide all relevant knowledge and ex-perience but can rely on external expertise. However,the officers directly responsible for the permitting, con-trol and enforcement procedures should have a pro-found understanding of co-processing. Training mightbe required regarding:Y formulation of waste management policiesY formulation and interpretation of waste statistics

Y authorization and controlling of co-processingY assessment of new materials for co-processing and

waste source qualificationY monitoring of operation and transportation (meth-

odologies of emission analysis and evaluation of ana-lytical data)

Y management of occupational health and safety ofthe workers within the cement plant and duringtransportation

Y enforcement of the national regulations and per-missions

Y systematic communication with stakeholders andthe public.

Cement industry staff from various departments(production, quality, AFR, legal, OH&S etc.) may needtraining in:Y control of wastes and AFRY operation of facilities for pre-processing and

co-processing according to internal regulationsY occupational health and safetyY communicationsY internal monitoring of environmental (emission)

aspectsY auditing techniques and audit protocolsY periodic re-certification for employees and sub-

contractors.

Reliable and well-trained external auditors, servicecompany personnel, and experts from the public andprivate sector working in the field of waste manage-

ment are needed to make co-processing work. To ensurequality and to simplify the work of administrative bod-ies, the certification of recycling and haulage compa-nies, of laboratories for internal and external controlling,as well as of individual experts, is most important.

Waste producers and pre-treatment and haulagecompanies will be involved in pre-organization and pre-treatment before delivery to the cement plant. Effi-ciency requires the optimization of material flow, wasteseparation, preparations for safe handling of the mate-rials already at the source, and adequate installationsfor transportation and storage. Management and staff

should be trained accordingly.


29/136


5.3.4 Implementation of the Guidelines

These Guidelines recommend environmental and socialstandards as well as technical and legal requirements.They shall not be regarded as binding law (see impo-rant notice on page B). Their application enhancesbroad acceptance of co-processing waste material incement plants. For the implementation of the proposedambitious but realistic principles a stepwise approachis required depending on the framework conditions inthe different countries.

We have to understand that the level of economi-cal development, environmental consciousness, politicalpriorities, good governance or cultural habits influencethe dynamics and timeframe of the modernization ofwaste management in a country. The implementationof co-processing must be seen as a part of this changeprocess and will progress differently from country tocountry.

The Guidelines should be implemented on thebasis of a spirit of cooperation between the public andprivate sector. As this will not happen from one day toanother, a gradual phasing-in is needed, which is fixedon the given political, social and legal circumstancesand based on achievable and realistic milestones.

The driving force for the introduction of co-pro-cessing in accordance with these Guidelines can be anational cement association, an individual cementcompany or the public sector. Whoever promotes thisactivity should do it in a transparent manner andwithin a defined and binding time horizon.


30/136


31/136

Principle 1

An appropriate legislative and regulatory framework shall be set up:YCo-processing shall be integrated into the overall legislation concerning environmental protection

and waste management before it can be accepted as a viable waste management alternative.

Y Legally-binding regulations and standards are necessary to guarantee legal security and toassure a high level of environmental protection.

Y Law enforcement is the key to successful AFR implementation and marketing.

Principle 2

Baselines for traditional fuels and raw materials shall be defined:YControl and monitor inputs, outputs, and emissions during the operation of the cement plant

with virgin fuel and primary raw materials.Y Evaluate the given environmental situation prior to starting waste co-processing.YUse this baseline data to define potential impacts of AFR on the environment based on stand-

ardized Environmental Impact Assessments (EIA).

Principle 3

All relevant authorities should be involved during the permitting process:Y

Build credibility with open, consistent, and continuous communications with the authorities.YConsider and strive to apply Best Available Technology (BAT).Y The cement plant operator shall provide necessary information to enable authorities to evalu-

ate the option of co-processing.Y Install community advisory panels early, including the authorities, to facilitate the exchange ofininformation, opinion and know-how.


6.0 Requirements for co-processing in Cement Kilns

6.1 Legal Aspects

6.1.1 Principles

6.1.2 The legal framework

National laws should define the basic principles underwhich co-processing takes place. They should then de-fine the concrete requirements and standards for co-processing. Without legally binding rules, the authori-

ties will not be able to control compliance or to enforceenvironmental protection.

The regulatory framework should reflect the realcapacities of environmental authorities. Complexstandards are difficult for regulators to handle, particu-larly in developing countries. Clearly defined criteriathat are easy to evaluate and to apply are more appro-priate.To integrate co-processing into the nationalwaste policies and laws, the regulatory bodies, the ce-

ment industry and other stakeholders should provide acountry and sector specific input for the national insti-tutions formulating laws and regulations.

If no specific legislative framework covers co-pro-cessing, the cement company interested in the use ofAFR should prepare all the necessary documentationbefore starting any waste co-processing or pre-process-ing activities, and apply for a permit under the generalenvironmental law in force, in close cooperation withthe authorities, basing the application on existing goodpractices. International and regional experiences andinformation exchange about best practices should beconsidered.


32/136



6.1.3 The institutional framework

Experience from countries that allow co-processing ofwaste clearly shows that it is best if the permittingprocess, supervision and controlling functions are allconcentrated in one single administrative body.

Poor enforcement often stems from a lack ofawareness or of resources in terms of control andmonitoring. Thus capacity building for the regulatoryand administrative bodies may be needed [Y see chap-ter 5.3 ]to ensure the environmentally sound treatmentof all the waste generated and efficient co-processing.

The civil servants responsible for permitting, con-trol and supervision should have an adequate technicalbackground and legal knowledge. However, the au-thorities do not need to provide all relevant knowledgeand experience, but can make use of external expertise.A basic requirement for the process is the availability ofqualified, reliable companies and experts.

6.1.4 Emission control and selection of waste:

Enforceable standards are needed

The regulatory framework must provide rules that areeasy to enforce. National emissions standards must beapplied by the concerned authorities and implementedby permits in each case. Within the given standards, thetechnical specifications for co-processing and the wasteto be used may vary from country to country or evenfrom one cement plant to another.

Special attention must be given to reliable emis-sions control and monitoring, as this is one of the mostsensitive areas of the co-processing activity. In manycountries, industrial emissions standards already existbut do not cover emissions from cement factories usingAFR. Y chapter 6.2.2 provides a detailed overview of en-vironmental impacts and emission control.

Derived from the EU waste catalogue, a list ofwastes suitable for co-processing has been prepared [YseeAnnex 5 ]. This list indicates that co-processing isapplicable for a wide range of waste and not limited toa certain type of waste. However, the decision on what

type of waste can be finally used in a certain plant can-not be answered uniformly; it must be based on the

clinker production process, the raw material and fuelcompositions, the feeding points, the gas-cleaning proc-ess, the current existing local regulations, if any, and thegiven waste management problems [Y see also chapter6.3.2 ]. The Accept-Refuse Chart in YAnnex 6 could beused by plant operators to help them in consideringwhich type of waste is suitable for co-processing. As abasic rule, wastes accepted as AFR must give an added-value for the cement kiln:Y calorific value from the organic partYmaterial value from the mineral part.

In some cases kilns can be used for the safe dis-posal of special wastes such as obsolete pesticides,PCBs, or outdated pharmaceutical products. However,for this type of treatment, regulatory authorities andcement plant operators must come to individual agree-ments and standards on a case-by-case basis. Suchdisposal activity should be done as a joint effort be-

tween the public and the private sector.

As documented in YAnnexes 2 and 5, a wide rangeof waste materials may be used as AFR. The most com-mon ones are mixed dirty paper, cartons, plastics, tex-tiles, packaging material, tires, wood, and sorted wastesfrom households, commerce, or production and serviceindustries. There are liquid waste products such as usedoil, solvents or coal slurries as end-of-line products fromthe transport sector or derivates from industrial activi-ties. Some waste materials can be delivered as singlebatches directly to the cement plant while others must

be pre-processed to meet the required conditions. Insome cases (e.g. municipal garbage, hospital waste),co-processing can only be applied after pre-processingphases such as segregation, sorting, making inert, neu-tralization, or thermal treatment. Regular quality con-trol of the collected and delivered waste will help toensure a smooth use of the AFR in the kiln.

The quality of what goes in determines the qualityof what comes out. Therefore attention must be paid tothe selection of raw materials and fuels, whether theycome from primary or secondary sources. All naturalresources used in cement production (raw material and

fuels) contain pollutants such as heavy metals; so a pre-AFR baseline emissions study is recommended. Data


33/136


from this study helps operators to understand the pol-lution content of traditional inputs and to demonstratelater whether the use of AFR offers environmental im-provements.

Process requirements, product quality targets, andemissions regulations all have a bearing on the choiceof the chemical and physical parameters of the poten-tial waste material considered for use. In selecting andusing AFR, the aims areY to fulfill any legal requirements about pollution,

health, safety, and technical standardsY to assure that the waste used as AFR undergoes its

most favorable treatment compared to possible othertechnologies

Y to exclude damaging effects to the product or theproduction process

Y to minimize the net financial and economic costs ofwaste management.

In many countries regulators have produced listsof maximum pollutant values allowed for selectedwaste to be transferred into AFR and for the pre-proc-essed AFR itself. Y Annex 7gives an overview of suchvalues from different countries. No agreed thresholdlimit values exist, as different criteria are applied, de-pending on the local situation. Such criteria include:Ynational environmental policiesY significance of the impact of the cement industry in

the context of regional industrial developmentY efforts to harmonize supra regional environmental

laws and standardsYpollutants in traditional raw materialsY treatment alternatives for the available wasteY fixed minimum calorific valueY toxicity level of pollutants in wasteY requirements for cement quality.

In all countries where co-processing will be used,such lists should be prepared and regularly reviewed bynational or local authorities in cooperation with the ce-

ment associations. The aim is to define standard valuesappropriate for the local circumstances and require-ments (on a country-wide basis or on a plant-by-plantapproach). This sensitive task should be given specialattention during any capacity development activity.

Permits for co-processing should define the wastethat is licensed for co-processing. EU Directive 2000/76/EC9, for example, provides explicitly in Art. 4, paragraph 4that the permit granted by the competent authorityfor an incineration or co-incineration plant shall ... listexplicitly the categories of waste which may be treat-ed. Kiln operators should respect these provisions.

The main objective of the permission and control-ling process is to assure that only suitable wastes willbe used and the AFR operations run properly. Regulatorsand kiln operators should be able to track the progressof the waste through the waste treatment path, either

directly from a waste generator or through collecting/pre-treatment companies. The quality of the materialdesignated for co-processing is crucial. Quality data andemissions monitoring data form the basis for scientificdiscussions with external stakeholders. They are alsohelpful tools for reducing local concern and the notionthat cement plants are misused as trash bins for uncon-trolled disposal of wastes.

To avoid an overload of case-by-case decisions,permitting should be done for types of wastes; thoughthere are exceptions to this [Ysee Table 4 next page ].

Co-processing should only be applied if not justone but all tangible pre-conditions and requirements ofenvironmental, health and safety, socio-economic andoperational criteria are fulfilled. As a consequence, notall waste materials are suitable for co-processing.Y Table 4 on the nextpage gives an overview for the

justification of waste not being recommended for co-processing in cement plants. Further explanations onthe exclusion criteria are given in YAnnex 8.

9 The EC directive can be found under: http://europa.eu.int/comm/environment/wasteinc/newdir/2000-76_en.pdf


34/136

Enrichment of

pollutants in

the clinker

Emission

valuesOH&S

Potential for

recycling

Landfilling as

better option

Negative im-

pact on kiln

operation

Electronic waste X X X

Entire Batteries X X X X

Infectious & biol.

active medical

waste

X

Mineral acids and

corrosivesX X X

Explosives X X X

Asbestos X X

Radioactive waste X X

Unsorted

municipal wasteX X X X


Table 4: List of waste material not suited for co-processing and the main reasons for the exclusion from co-processing


Cement plant operators must know the quantityand characteristics of the available wastes before ap-plying for a permit for co-processing. However, anopen communication channel and regular consulta-tions between the public and the private sector willhelp to reduce possible friction and misunderstand-ings and to develop a permit process most suitablefor all involved.

6.1.5 Permitting process for co-processing

Generic permits for heterogeneous waste groups shouldnot be issued because it is hard to track these wastesfrom the generator to the kiln. And it is difficult to as-sess their environmental impact. It is important toknow the origin of each type of waste and its composi-tion in order to ensure safe co-processing. Agreementsmust be signed with the collectors or haulage compa-nies in order to ensure these requirements.

Generic permits shall only be issued for homoge-neous waste including waste coming from pre-process-ing facilities, for example:Y solid substitute fuels (impregnated sawdust,

refuse derived fuels, fluff)Y liquid substitute fuels

and for waste types with a defined characteristic anda successful long-term application in cement plants(e.g. tires).

Pre-processing facilities accept different wastematerials suitable for co-processing that due to theirphysical states cannot always be fed directly to theplant. It is therefore necessary to prepare from thesewastes a single waste stream in the form of a liquid orsolid substitute fuel that complies with the administra-tive and technical specifications of the cement plants.

In this case the traceability is ensured.

Cement plant operators who co-process wasteshave the main responsibility for the whole procedure,including permitting and quality assurance. Their ap-plications must include detailed descriptions of all rel-evant processes within the plant, comprehensive dataabout all materials designated for co-processing and adetailed self-monitoring plan. These documents givethe authorities an overview of the quality of the wasteand the expected emissions. The authorities should notaccept incomplete application documents.


35/136


Operators should apply for a permit only afterconsidering the following elements:Y the cement process (raw material, fossil fuels,

type of kiln etc.)Y the characteristics of the waste marketYnearby waste markets, for possible trans-boundary

shipments.

A well-documented permitting process shouldprovide detailed information on the plant specifica-tions [ Y see the attached permit procedure as modelcase inAnnex 9]and give information on:Y raw materials, fuels, co-processed wastes and fuels,

handling and preparationY expected volumes per waste streamY feeding point into the process for each waste streamY chemical/physical criteria of each waste streamYmain items of equipment including plant capacity

and operating conditions (i.e. temperature and pres-sure), where relevant to pollution potential

Ypollutant abatement equipment: scrubbers, filters,absorbers, precipitators, etc

Y release pointsY intermediary products, waste handling, conditioning,

and storageY inspection plan for incoming waste and pre-proc-

essed AFRY sources of water and treatment used for process cool-

ing water, effluent water etc, where relevant to pollu-tion potential or release

Ydescription of the emission situation: technology forpreventing pollution, contents and quantities of

emissionsYdescription of secondary fuels, generation, processing,

using installation, supply and quality assurance systemY investigation of the future harmful effects of pollut-

ants in the plants sphere of influence (sphere of in-fluence is an assessment area within a radius of 50times the stack height) chemical/ physical reactions of emitted substances potential dangers, toxicological and environmental

relevance loads and protection factors in the plants sphere of

influence emission load of relevant components

pathways, periods of time, and circumferences ofeffects that require protection

suitable measures for avoiding pollutants environ-mental effects

the emission values ascertained in the assessmentareas are compared with various references, limit-ing values, and guide numbers for the background;pollutants to be considered in relation to the pro-duction of cement are dust, NOx, SO2, VOC, heavymetals, and PCDDs/PCDFs

Ymaintenance of industrial and occupational healthand safety standards

Ydescription of methods of informing the public.

When the application is completed (an examplefor an application form is attached as YAnnex 10), theauthorities should be asked for review and instruction.However, continuous communications with the au-thorities can avoid delays in the permit process

[Y for a flow chart of the permit process, seeAnnex 11]

The roles and responsibility of the cement com-pany making the application include:Ymaking first contact with the competent authority

and statutory consulting authorityYpreparing application forms, application for modifica-

tions in fuels and raw materials with major changesin the process

Y organizing discussions about the procedure and pub-lic participation

Y a written identification, description, and assessmentof the effects of the planned activity.

The roles and responsibilities of the permit issuingauthority are:Y considering the application and all the formsY involving other authorities in the consultation proc-

ess (health, transportation, economy)Ypublic participation: public information, public in-

spection of an application, public hearingY environmental assessmentY risk assessment evaluation with interdisciplinary teamsY final decision on approval by the competent authority

(with additional stipulations i.e. imposition, condi-tion, time limitation, reservation as to revocation).

[ Y see Case Study 4: Aspects on permitting -

The example of North Rhine Westfalia, Germany ]


36/136



6.1.6 Baseline testing - trial burn testing

Kiln emissions (with the exception of NOx and someheavy metals) are produced by volatile components inthe raw materials that volatilize during preheating ofthese materials (i.e. in the cyclone preheater of a precal-ciner kiln). Volatile components are hardly ever homo-geneously distributed in a deposit (quarry) and thustheir amounts fluctuate over days and years dependingon the part of the quarry being exploited. Dynamicprocesses of formation and reduction during internalcirculation, as well as the kiln operation modes, also af-fect emissions.

An emission change forecast based on expertknow-how and, if required, expulsion testing and che

Guidelines COPROCEM Low

Documents

Transcript of Guidelines COPROCEM Low