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Gossman Consulting, Inc

Cement Resource Recovery in Developing Countries

A Sustainable Development Option

Bert L. Schipholt

 ERAtech Group LLC

 45W962 Plank Rd., Hampshire, IL  60140

Phone #: (847) 683-4188

 Fax #: (847) 683-4212

  mailto:bschipholt@eratech.com

ERAtech Group LLC is a strategic alliance of ERAtech and GCI

ABSTRACT

At no time in history have developing countries faced environmental and business concerns of today's magnitude. The preservation of irreplaceable fossil fuels, global warming,  greenhouse gases, an overwhelming volume of industrial waste, and health and safety concerns are in the forefront of ecological issues.  Cost competitiveness, global competition and profitability are concerns for the business side.

Cement resource recovery is regarded as one of the most cost-effective and viable waste treatment technologies available to developing countries and represents the Best Practical Environmental Option for many industrial liquid and solid wastes today. 

Developing countries may be able to forego the need to invest in costly, and controversial, hazardous waste rotary kiln incinerators, because of the ability to safely use  recycled fuels made from industrial wastes in cement kilns. 

In many developing countries the cement resource recovery business is largely market driven, versus mostly regulatory driven in the developed countries.  Strengthening of environmental laws and enforcement thereof is a critical success factor for viable, sustainable alternate fuels programs. Environmental agencies in developing countries have good intentions to regulate the use of alternate fuels in cement kilns but often lack financial resources and qualified personnel. 

This difficult environment creates an opportunity for the Cement Industry to demonstrate stewardship in shaping the legislative and PR future for cement resource recovery in developing countries. In doing so, the Cement Industry may develop recommendations for regulations of Management of Alternative Fuels and Raw Materials and encourage and assist the environmental agencies to develop and enforce rules that allow facilities reasonable operating flexibility while protecting human health and the environment.

INTRODUCTION

Cement resource recovery is regarded as one of the most cost-effective and viable waste treatment technologies available to developing countries and represents the Best Practical Environmental Option for many industrial liquid and solid wastes today. 

In this presentation let us will touch on a few points that are important to promote  the subject of cement resource recovery in developing countries and why it represents an excellent win-win  option for the governments in support of their efforts to develop improved waste management infrastructures.

The following aspects of the business will impact cement resource recovery in developing countries:

We start with the regulatory environment and how it affects the waste market and the viability and sustainability of alternative fuels programs in developing countries.

THE REGULATORY ENVIRONMENT

The development of a proper hazardous waste management infrastructure in developing countries is not only required to protect human health and the environment but it is also necessary to sustain further development of their economies. Continued poor management of hazardous waste will eventually destroy not only the environment but also the economy of a developing country.

The key word in this phrase is “proper”.  We have seen countries that have attempted to generate their own regulations through their internal staff or through  the use of outside consultants that have little experience in waste management.  They simply copy the rules of the US or the European Community and promulgate a carbon copy.  We have also seen countries that took the lowest numbers from the US, Japan and Swiss regulations and have simply adopted these with no further technical thought or justification.  In other words, if a low number is good, then the lowest numbers of all in existence must be even better or safer.

The degree to which developing countries have proper rules and regulations in place varies widely from country to country. As a rule, those developing countries that have put good infrastructures in place and who’s economies on balance show strong growth tend to be more advanced. Typically in these more advanced developing countries, the populations primary needs are taken care of and the desire for a better environment and concerns for health and safety are more prominent. The poorer countries tend to focus on eradicating poverty and improving the living standards of their population as their first priority.

In many of the developing countries, even when rules and regulations are in place, enforcement of such regulations is weak. Also the quality of transportation, storage and treatment and disposal of hazardous wastes leaves much room for improvement.  Liquid hazardous wastes including waste oils and bunker sludges are often used as fuel in small boilers and furnaces and such wastes might even generate income for the waste producer.  We have seen countries where the oil producers put their storage tank clean outs to bid.  They award the work to the highest bidder who covers his labor cost and makes his money through the sale of the oily sludges to other developing nations.

Few developing countries have proper rules and regulations for the combustion of hazardous wastes in cement kilns incorporated in their waste management master plan.

THE WASTE MARKET

Many of the developing countries do not have a proper hazardous waste management infrastructure in place. They lack proper TDS facilities often due to unclear standards and lack of enforcement, creating uncertainties regarding the prospects of the TDS facility business. Permitted transportation companies and recyclers have limited skills and often low standards. Only easily recyclable hazardous wastes are processed. More difficult materials are often dumped.  Some generators export their hazardous wastes to developed countries for treatment and disposal.  Many generators of hazardous waste either store such waste on site or transfer it to permitted collectors.  These collectors sometimes recycle these wastes or dispose of them illegally.

Often the industries generating substantial quantities of hazardous wastes have limited options available to them to dispose of such wastes in a cost-effective and an environmental sound manner. They are reluctant to discuss waste generation and disposal practices and often report unusually low quantities of wastes generated. 

Liquid organic hazardous wastes including oil wastes and bunker sludges frequently find their way into small furnaces and boilers.

Non-hazardous wastes with energy value such as paper, cardboard, wood, sawdust, plastic and aluminum wastes are often collected and re-used or disposed of to land at little or no cost to the generator.  Therefore such wastes are often not economical as coal substitutes.

MARKET DRIVEN VS. REGULATORY DRIVEN

In the developed countries like the US or Europe, the alternative fuels and raw materials (AFR) market is largely regulatory driven.  A proper hazardous waste management infrastructure is in place and treatment and disposal fees are significant.  This applies equally to conventional treatment and destruction of hazardous organic wastes in incinerators or selectively recycling such wastes for energy and material recovery in cement kilns.

In developing countries, the alternative fuels and raw materials business is largely market driven. For the cement industry this means that the wastes tend to flow towards the cement kiln that is proposing the lowest disposal fees. And with more cement kilns enter the AFR market in a developing country, disposal fees tend to spiral down further.

For this reason, the cement industry in developing countries needs a hazardous waste management infrastructure and proper regulations for the Management of Alternative Fuels and Raw Materials in cement kilns in place and enforced in order to be able to develop viable and sustainable AFR projects.

CEMENT RESOURCE RECOVERY STEWARDSHIP

As I mentioned before, strengthening of environmental laws and enforcement thereof in general and specifically for the management of hazardous waste derived fuels in cement kilns is the key to promoting a viable, sustainable environment for cement resource recovery in developing countries. Environmental agencies in developing countries have good intentions to regulate the use of alternate fuels in cement kilns but often  lack financial resources and qualified personnel.

This difficult environment creates an opportunity for the Cement Industry to demonstrate stewardship in shaping the legislative and PR future for cement resource recovery in developing countries. In doing so, the Cement Industry may develop recommendations for regulations of Management of Alternative Fuels and Raw Materials and encourage and assist the environmental agencies to develop and enforce rules that allow facilities reasonable operating flexibility while protecting human health and the environment.

However, the task to shape the legislative and PR future for cement resource recovery and to promote viable, sustainable AFR projects in many developing countries may be too large for any individual cement company.

We at ERAtech believes that a joint effort to promote cement resource recovery between leading cement companies in selective developing countries may be a more appropriate path forward to achieve sustainable AFR projects.  France, as a country, is a good historic example where several cement companies took ownership and jointly developed the AFR market to the benefit of all parties involved by the formation of a central waste management company to collect, process and supply the hazardous waste derived fuels to the cement manufactures.  We firmly believe that such a concept may work well in developing countries. Such a proposed strategic business relationship involving selective cement groups and a waste management company provides the opportunity for all of the parties to create a situation where the product is greater than the sum of it’s parts.  The business principals of such a partnership are the formations of a long-term relationship and the creation of a win-win situation for all of the parties involved. 

RECOMMENDATION FOR REGULATIONS FOR THE MANAGEMENT OF HAZARDOUS WASTE FUELS

In an environment without rules and regulations governing the use of recycled fuels made from industrial hazardous wastes in cement kilns it will be difficult to develop viable, sustainable AFR programs. Especially if several cement companies enter the waste market simultaneously, they tend to depress the disposal fees to a point where such waste fuels are not economical as coal substitutes any longer.

It is in these circumstances that the Cement Industry will benefit from demonstrating leadership in shaping the legislative and PR future for cement resource recovery.

In assisting environmental agencies to develop and enforce rules that allow facilities reasonable operating flexibility while protecting human health and the environment we suggest to consider the following outline of regulations for use  of recycled fuels derived from hazardous wastes in cement kilns:

1.         Storage and Management of Wastes (minimum criteria)

                        a.         Liquid Storage and Ancillary Systems

                        b.         Solids Storage and Ancillary Systems

2.         Shipment Manifesting and Receipt procedures

3.         Waste Analysis Requirements

4.         Emissions Testing Requirements

5.         Determinations of Permitted Emissions Limits and Operating Parameters

6.         Monitoring Requirements

7.         Record keeping Requirements


  1.    Minimum criteria for Storage and Management of Wastes should include:
  1. Shipment Manifesting and Receipt Procedure:
  1. Waste Analysis Requirements
  1. Emission Testing Requirements

This outline would not be adequate to meet USEPA or State permit requirements. It is however, sufficient to provide information to a facility for making decisions regarding compliance with proposed regulations.

The emission testing requirements provide the minimum needed information to plan and execute a test burn. It specifies the sampling and analytical methods, when and where the samples are collected and the operating condition that the plant is to achieve during the sampling. This is sufficient information for an agency to review and determine if the plan addresses their concerns. It is also sufficient for a stack sampling contractor or an analytical laboratory to provide a cost estimate. We propose that there are three runs for each operating condition. This is considered a minimum.

Obviously, additional test parameters such as PCB or metals emissions testing increases the cost of testing as would additional test days at different test conditions (such as higher or lower fuel substitution rates). However, if the testing is going to be done, it should be done correctly and

thoroughly enough to provide useful information. If the testing is not done properly the data generated is useless or may even be damaging to the project.

It is understood that the above outline merely represents recommendations and encouragement to the environmental agencies in developing countries. These agencies themselves will determine to what extend these recommendations for regulations for the management of hazardous waste fuels conform to their requirements. It will probably be a slow process but once accomplished it will make AFR programs more viable and sustainable in the long run.

In the absence of rules and regulations around the use of recycled fuels derived from hazardous wastes, the cement industry in developing countries are setting themselves up for failure.  When this occurs, there will be no long-term successful AFR project, and the politics will overwhelm the science.

We strongly recommend that from the very beginning, an AFR program must be correctly designed and well planned.  Attempting to “just get by” by cutting corners or by not performing test burns nor providing documentation to the local regulatory agencies is a recipe for the destruction of a project.

PUBLIC RELATIONS AND RISK COMMUNICATION

We must be prepared to discuss and disclose information on the possible risks and benefits associated with the use of alternative fuels, in particular those recycled fuels derived of hazardous wastes at our operations to workers, to community’s, government agencies and to the public at large. This will increasingly be the norm also in developing countries, whether the result of government action, media probing, or the pressures of activist groups. The days when it was possible for industry to run its business and ignore the outside world are gone.

Industry is perceived to a great extent as responsible for creating much of the pollution and for the damage to the environment, which is believed to be under immediate threat.

In this climate of mistrust, a corporation will need to rely on the skillful use of risk communications, to minimize potential criticism and develop a rational public acceptance of risks in a complex society.

The dynamics of risk perception are extremely complex and public perceptions about risk do not follow logical patterns. And facts are not always successful in easing concerns.

The implication is that we must not assume, therefore, that facts will carry the day. The emotional aspects of risk communications are powerful and often overwhelming.

On the other hand, one thing that you must assume is that the general public is well educated and has access to a huge amount of information through the use of the Internet.  Trying to simply down play the use of the alternative fuels will inevitably backfire and has destroyed many a potential project.

The primary objective of risk communications is not to change public opinion about the size of the risk but rather to build trust about the corporate commitment to contain and control it. To tell the public why the risk of an unfamiliar hazard is small is likely to fail or may even backfire. But efforts to educate about systems, which control and reduce risk and work to contain it, can give an outsider confidence.  When risk information is presented by or on behalf of self-interested parties (e.g., the corporation), the public will respond with caution. But corporate credibility can only go so far. Third party allies – trusted medical, community and political leaders – are essential to risk communication.

 Two primary factors tend to be the driving forces of how the public categorizes and perceives various risks.  The first key element is control. The public will almost always underestimate risks where they feel that they are in charge and can make the decision whether to take the risk and how to handle it. The second element is the ability to understand the risk with some clarity and familiarity. If a risk is perceived as unknown, unseen, and unfamiliar, it is far more likely to create dread and therefore become unacceptable.  It is essential, therefore, in our community relations program that we try to use techniques, which create a sense of both control and familiarity.

The overriding objective of an effective risk communications efforts associated with the use of waste derived fuels in cement kilns is to create a level of public comfort. This objective is best achieved, not by attempting to create greater public understanding of the small size of the risk, but by creating greater confidence that a corporation can be trusted to manage the risk.  Finally the best risk communications will not come from words but from deeds, from the actions, which we are seen to take which add value for customers, employees and communities, the winning of public confidence through such deeds will help us to be effective communicators when risk issues arise.

CONCLUSION

At no time in history have developing countries faced environmental and business concerns of today's magnitude. The preservation of irreplaceable fossil fuels, global warming, greenhouse gases, an overwhelming volume of industrial waste, and health and safety concerns are in the forefront of ecological issues.  Cost competitiveness, global competition and profitability are concerns for the business side.

Cement resource recovery is regarded as one of the most cost-effective and viable waste treatment technologies available to developing countries and represents the Best Practical Environmental Option for many industrial liquid and solid wastes today. 

Developing countries may be able to forego the need to invest in costly, hazardous waste rotary kiln incinerators, because of the ability to safely use  recycled fuels made from industrial wastes in cement kilns. 

In many developing countries the cement resource recovery business is largely market driven, versus mostly regulatory driven in the developed countries.  Strengthening of environmental laws and enforcement thereof is a critical success factor for viable, sustainable alternate fuels programs. Environmental agencies in developing countries have good intentions to regulate the use of alternate fuels in cement kilns but often lack financial resources and qualified personnel. 

This difficult environment creates an opportunity for the Cement Industry to demonstrate stewardship in shaping the legislative and PR future for cement resource recovery in developing countries. In doing so, the Cement Industry may develop recommendations for regulations of Management of Alternative Fuels and Raw Materials and encourage and assist the environmental agencies to develop and enforce rules that allow facilities reasonable operating flexibility while protecting human health and the environment.

The cement industry and its recycled fuel suppliers must be prepared to discuss and disclose information on the possible risks and benefits associated with the use of alternative fuels, in particular those recycled fuels derived of hazardous wastes at our operations to workers, to community’s, government agencies and to the public at large. This will increasingly be the norm also in developing countries, whether the result of government action, media probing, or the pressures of activist groups. The days when it was possible for industry to run its business and ignore the outside world are gone.