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Gossman Consulting, Inc.

Burning Waste in Kilns in the United Kingdom
A Comparison of Regulations in the United Kingdom
versus the United States EPA Regulations

David Constans

Gossman Consulting, Inc.

Presented at the AWMA International Specialty Conference on Waste Combustion in Boilers and Industrial Furnaces April, 1994


The paper discusses the general format of environmental regulations in the United Kingdom and how these regulations are being applied to kilns burning hazardous waste fuel. This includes a comparison to the application of the USEPA BIF regulations.

Such topics as facility design requirements, insurance reviews and requirements, overlapping regulatory authorities, environmental testing and methods, baseline emissions versus waste fuel burning emissions restrictions, other operating restrictions, environmental authorities' concerns, and public involvements are discussed. An assessment of the level of environmental regulations for burning hazardous waste fuel in cement kilns in the United Kingdom is provided in comparison with the current BIF regulations.


It is not the intent of this paper to present a guidance document on how to acquire a permit to use hazardous waste fuel (HWF) in cement kilns in the United Kingdom, but rather to illustrate the approach the U.K. has taken in regulating this activity in comparison to current U.S. regulations.

At the present time there are only two cement kilns in the United Kingdom that are utilizing hazardous waste fuel (HWF). Castle cement began using HWF in 1992, and Rugby cement commenced HWF use at one facility in late 1993.

Although using HWF in kilns is fairly new to the United Kingdom, the industry and the regulators were certainly aware of it from successful HWF programs in other countries. Norway, France, Belgium and the United States are just a few of the countries now using HWF.

The current method of disposal of flammable liquid waste in the U.K. is by incineration in purpose-built incinerators. There are about 60 "in-house" incinerators and four commercial incinerators. The commercial incinerators currently dispose of approximately 100,000 metric tons per year, or about two and one-half million U.S. gallons. There is also a large amount of hazardous material, including flammable liquids, that are disposed of in land fills, the U.K. does not currently have a "land ban" standard.


Table 1 is a list of the regulatory authorities that are involved in regulating HWF use in cement kilns in England and Wales. There are minor differences in names and responsibilities for similar agencies in Scotland and Northern Ireland, for the most part, however this is a representative overview. These groups are already involved in the regulation of cement production facilities, so the various aspects of HWF use is regulated by the same agencies. The list starts with the most local to the least local, although submittal of forms or information may not be executed in this order.

Based on this overview comparison, it would be expected that acquiring permission to burn HWF in the United Kingdom would be as difficult as it is in the United States. This, however, is not the case.

Gossman Consulting, Inc. (GCI) assisted Rugby Cement and Organic Technologies, Ltd. in acquiring permission to burn HWF in a cement kiln. It took only five months from the first meeting with the authorities to actual consumption of HWF in the kiln. The differences in approach are telling. The current policy views the use of HWF, provided it is compounded and delivered to the cement kiln facility in conformance to a "product specification", as a secondary fuel not as a waste. The authorities are much less confrontational. Discussions are held without legal council present. The standards are technology based, rather than health based. Consequently, there is less discussion about what is and is not satisfactory compliance. The regulatory personnel are experienced and professional. This is reflected in their understanding of the current and proposed activities and in the questions they ask. Local resistance was minimal - mainly concerned with restricting the transportation of HWF to daylight hours. In all, the process proceeded quickly, dealing with real issues in a realistic manner.


Table 2 is a comparison of current new facility incinerator emission standards in the U.K. (based on the draft EEC directive on Hazardous Waste Incineration) versus the current U.S. BIF and Incinerator standards. Since the British standard is technology based and uses different standard conditions and correction factors than those used in the United States it is difficult to make direct comparisons of the two standards. There are a number of differences that are readily apparent in an examination of Table 2. The most notable of these is the choice of metals and how the metals limits are determined, and the use of the 11% oxygen correction. The 11% oxygen correction will yield a lower emission concentration (by about one third) than the 7% oxygen concentration. When applied to an emission limit, the limit would allow about one third greater emissions than the same value at 7% oxygen.

These emission standards are for "in-house" and "merchant " incinerators built or "substantially changed" after April 1, 1991. At the present time there are no specific emission standards for cement kilns. However kilns are covered under the present regulation as an "Alternative Disposal Route" with the Chief Inspector's Guidance to Inspectors stating: "If chemical wastes were incinerated in such plants, the release limits in this Note should apply to the portion of the exhaust gases attributable to the burning of the waste." Under such a concept using HWF for 30% of the fuel to the kiln would require that 30% of the exhaust gases meet the emission standard. Based on experiences in the U.S. during the BIF Testing it is obvious that the source of fuel for a cement kiln has little impact on cement kiln emissions. Consequently, although there is an emission standard, it is accepted that it is not applicable in its present form. In its letter of authorization the HMIP acknowledged that the draft EEC Directive on Hazardous Waste complicated the issue. The issue was left open, however, by viewing the operation as "merely the use of an alternative fuel" that "will no doubt be resolving this on a national level". The HMIP's focus has become an examination of whether or not the use of this alternative fuel increases stack emissions. To that end baseline and alternate fuel use emission tests were required and subsequently conducted.


The HMIP's testing requirements are straight forward. Compare an analysis of stack emissions from an alternate fuel test, at 20 - 25% heat replacement, with emissions from a primary fuel test and demonstrate that there are no increases in emissions due to the use of the alternate fuel. This was to be done without "spiking" additional metals into the kiln and at normal operating conditions. There were no requirements to establish operating limits such as minimum or maximum temperatures, a maximum gas velocity or raw feed rate as is required by the BIF regulation. Basically the tests were to confirm that the concept of using HWF as an alternate fuel in a specific kiln did not adversely impact the environment.

Table 3 tabulates the results of these tests for Castle Cement. Not surprisingly the kiln did not achieve the particulate standard. The HCL standard was also exceeded, however the method used to determine the chloride concentration in the flue gas does not account for volatile salts such as ammonium chloride. In all, the values are similar to values from kilns in the U.S. The comparison BIF Test values were taken from a kiln of similar capacity and process type. These values have been expressed in the same units and standard conditions at 11% oxygen as the British standard. Additionally the BIF Test values, though averages of three runs, are the result of the extreme conditions required by BIF. The metals listed were "spiked" to achieve the maximum allowed input levels. The remaining 5 BIF metals were Tier IA metals and their emission rates were not reported in the BIF Test results. The NOX, SO2 and the PCDD/PCDF values were taken from a state air permit test report on the same kiln operated at similar conditions.


The British regulatory authorities have approached the burning of hazardous materials in cement kilns from a very practical view point. They have not viewed this only as an activity that must be regulated but also as the use of an alternate fuel that must be investigated. There are no specific regulations that cover the use of hazardous waste as fuel at the present time. It is hoped that the regulation when enacted will be as intelligently thought out and implemented as the recent experience has indicated is possible.


"Chief Inspector's Guidance to Inspectors", Waste Disposal & Recycling Merchant & In House Chemical Waste Incineration, Process Guidance Note IPR 5/1, HMSO, London, 1990.

Table 1. Overview of Regulating Authorities and Their U.S. Equivalents

Fire Brigade

(Review basic fire response plan.)

City/County/State Laws

Subpart D of 264, RCRA

County Council

(Issues license for certain activities such as fuel handling and landfills. Is the lead waste regulation authority. Local involvement through Council members.)

State Laws
Health and Safety Executive

(Requests Hazop Study. Reviews safety procedures.)

National Rivers Authority

(Siting and discharge to waters.)

EPA, State programs, NPDES, Coast Guard
Her Majesty's Inspectorate of Pollution

(Sets emission standards, advises other agencies. Administrates Integrated Pollution Control program.)

EPA and State Air Permits.
EEC Emission Standards for Incinerators

(as a draft EEC directive)

Federal BIF and Incinerator Standards

Table 2. Comparison of EEC Incineration Emission Standards Versus USEPA Standards





Standard conditions

0C, 101.3kPa, dry, 11% O2

Standard conditions

68F, 29.92" Hg, dry, 7% O2

Standard conditions

68F, 29.92" Hg, dry,7% O2


Daily Average - 50 mg/m3

HRAvg.- 100 mg/m3

CO Based on Tier Level and Testing CO

HRAvg - 100ppm

VOC (as TOC) - 20 mg/m3 VOC Based on Tier Level and Testing VOC - N/A
Particulate - 20 mg/m3 Particulate - 0.08 g/dscf

(167 mg/m3)

Particulate - 0.08 g/dscf

(167 mg/m3)

HCl - 10 mg/m3 HCl and Cl2 - Emission limits are based on MEI ground level impact. HCl and Cl2 - 99% SRE or 4#/Hr., which ever is less stringent.
HF - 2 mg/m3 HF - N/A HF - N/A
SO2 - 50 mg/m3 SO2 - N/A SO2 - N/A
NOX (as NO2) - 350 mg/m3 NOX - N/A NOX - N/A
Dioxins (TEQ by EEC method) - 1 ng/m3 Dioxins (TEQ)* - Emission limits are based on MEI ground level impact. Dioxins - N/A
Cd + Tl = < 0.1 mg/m3 Metals - As, Sb, Ba, Be, Cd, Cr, Hg, Pb, Ag, and Tl. Emission limits are based on MEI ground level impact. Metals - N/A
Hg - <0.1 mg/m3
Sb + As + Cr + Co + Cu + Pb + Mn + Ni + Sn + V = <1.0 mg/m3

* Dioxin testing is only required for kilns that exhibit certain conditions. See 40CFR266.104(e).

Table 3. Castle Cement Stack Emission Results


(all values - mg/m3)

100% Coal 75% Coal

25% HWF

British Incinerator Emission


Comparable Values

From BIF


Particulate 85.1 56.3 20 42
Sulfur Dioxide 1879 5330 50 205 (2)
Nitrogen Oxides 275 43.7 350 475 (2)
Chlorine 50.6 37.27 10 (as HCl) HCl + Cl as HCL


Fluorine 21.6 16.06 2 (as HF) N/A
Bromine 5.55 2.11 n/a N/A
Cd + Tl <0.0259 0.00508 <0.1 As 0.0012

Be 0.0002

Cd 0.011

Cr 0.015

Pb 0.185

Hg <0.0043 <0.00002 <0.1
Sb + As + Cr + Co + Cu + Pb + Mn + Ni + Sn + V <0.0734 <0.13807 <1.0
Organic Compounds
Dioxins/Furans TEQ(ng/m3) 0.131 0.2005 <1.0 .015 (2)
TOC 19.5 19.3 20 As THC in ppmv


CO -- -- D. Avg. - 50

HRA - 100

HRA in ppmv


(1) Average COC test values from a kiln of similar capacity corrected to British standard conditions and 11% oxygen.

(2) Average run values taken during state air permit test on the same kiln operated at the same



Cement Kiln


Permit Standards


United Kingdom