tyres

Environment Agency

CONSULTATION ON A TYRES PROTOCOLFOR USE ON CEMENT KILNS

A SUPPLEMENTARY NOTE TO THE SUBSTITUTE FUELS PROTOCOL

May 2001

CONSULTATION ON A TYRES PROTOCOL

A SUPPLEMENTARY NOTE TO THE SUBSTITUTE FUELS PROTOCOL

FOR USE ON CEMENT PROCESSES

SUBJECT TO REGULATION

UNDER THE POLLUTION PREVENTION AND CONTROL ACT 1999

Contact for Enquiries: Dr Neil DaviesPolicy ManagerRio HouseWaterside DriveAztec WestAlmondsburyBristolBS32 4UD

FORWORD

The UK produces nearly half a million tonnes of scrap tyres each year and there is a need to develop a robust,sustainable disposal and recovery capacity to deal effectively with existing and projected tyre arisings.

Sufficient capacity is needed to address the large quantity of tyres stored in stockpiles and the implications of thelandfill Directive, which will ban the disposal of whole tyres in 2003.

Currently over 70% of scrap tyres produced are recovered through a variety of markets. The bulk of tyres notrecovered are currently disposed of legally to landfill, but the final destination of a significant number of tyres isuncertain.

Unfortunately rising costs of tyre disposal has increased the financial incentive for illegal disposal, such as largescale dumping or localised fly tipping. Illegal activity has the potential to jeopardise the disposal and recoverynetwork if not addressed through robust enforcement.

The Agency has been aware of the environmental problems associated with the disposal of used tyres for many years,and has been involved in a number of initiatives, including the production of a report ‘tyres in the environment’ in 1998to influence the debate.

The Agency has recognised the magnitude of the problem and we are currently developing a Tyres Campaign inpartnership with the tyre industry. The aim of the campaign is:

‘to reduce the impact of tyres in the environment and encourage the sustainable recovery of waste tyres’.

We have set as our key objectives• Reduce the illegal disposal of tyres;• Reduce the risk of environmental damage from current tyre dumps;• Ensure there is a sustainable disposal/recovery system.

We will be developing a hierarchy of the best environmental options for the disposal/recovery of waste tyres. In themeantime, however, it must be recognised that one option for dealing with tyres is as a fuel. Tyres exhibit many ofthe qualities needed for a fuel and they have been used extensively throughout the world in cement kilns. As well ashelping to address the disposal problem, their use in cement kilns means that the amount of fossil fuels used isreduced. Also, tyres have a known and consistent composition, which means that the emissions from burning in kilnscan be reliably predicted and therefore controlled.

In view of the benefits of using tyres in cement kilns we are setting out a revised process for permitting companieswishing to use tyres in their kilns. This process, known as the Tyres Protocol, is designed to ensure that companiesare not discouraged from pursuing using tyres. At the same time, it offers a rigorous approach that companies musttake to demonstrate that using tyres has no detrimental effect on the environment. A prime feature of the Protocol isthe requirement for companies to consult and inform the local public about all aspects of tyre use in cement kilns.

Paul LeinsterDirector of Environmental Protection

TYRES PROTOCOL

CONTENTS LIST

1. INTRODUCTION AND PURPOSE..................................................................................................................1

2. PROCEDURAL REQUIREMENTS.................................................................................................................2

2.1 PROCEDURE 1: APPLICATIONS FOR TYRE TRIALS ON KILNS WHERE THE USE OF TYRES HAS NOTPREVIOUSLY BEEN PERMITTED......................................................................................................................2

2.2 PROCEDURE 2: APPLICATIONS FOR TYRE TRIALS ON KILNS WHERE THE USE OF TYRES HASPREVIOUSLY BEEN AUTHORISED FOR CONTINUOUS USE ................................................................................5

3. TECHNICAL REQUIREMENTS.....................................................................................................................6

3.1 PRE-TRIAL REQUIREMENTS ............................................................................................................................63.2 MONITORING REQUIREMENTS DURING TYRE TRIALS.....................................................................................83.3 REPORTING OF TYRE TRIALS .......................................................................................................................14

4. CONSULTATION ISSUES..............................................................................................................................15

5. REFERENCES..................................................................................................................................................16

ANNEX 1 - APPLICABLE STANDARDS .............................................................................................................17

ANNEX 2 GLOSSARY OF TERMS......................................................................................................................19

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1. INTRODUCTION AND PURPOSE

The European Commission's Landfill Directivea will ban the disposal of whole tyres to landfill byabout 2003, and shredded tyres by 2006. Some 450,000 tonnes of waste tyres are generated eachyear in the United Kingdom. Accordingly more reuse, material recycling and energy recoveryoptions are needed. To this end, the use of tyres as a fuel in cement kilns is an important outlet forwaste tyres.

It has been shown that burning tyres in cement kilns often has a net environmental benefit whencompared to conventional fuels, which are usually, coal and petroleum coke. The emissions ofnitrogen oxides (a major pollutant emitted from cement kilns) have been shown to be lower whenburning tyres. Also, because tyres contain iron, using them as a fuel reduces the amount of ironoxide that must be added to the process.

The purpose of this document is to set out for the benefit of Environment Agency (“Agency”)Officers, Industry and for the general public, Agency guidance on the procedures to be followed andthe considerations to be given to the use of tyres as a substitute fuel in cement manufacturingprocesses. The document builds upon the experiences gained by both the Agency and otherstakeholders in applying the Substitute Fuels Protocolb (SFP) to tyre burning trials in cement kilns.

This Tyres Protocol covers only the use of tyres for substitution of currently authorised fuels in kilns;it does not cover the use, or increased use, of other alternative fuels in the process of making cement,for which the existing SFP must be used. However, the SFP will not be used for applications for tyreuse. Furthermore, for any application requesting permission to trial more than one fuel (includingtyres) the Tyres Protocol can only be used for tyres.

This Tyres Protocol may also be used as guidance for Officers when assessing and decidingapplications from Operators for previously unauthorised (i.e. new) kilns, designed to burn tyres (i.e.tyres are burned at the base load condition).

Officers should note that the European Commission has replaced both the Hazardous WasteIncineration Directive c(HWID) and the Municipal Waste Incineration Directive d(MWID) with anew Waste Incineration Directivee, which covers most wastes not covered by the HWID. TheAgency is currently preparing guidance on implementation of this new Directive.

This supplementary note deals only in outline with procedural changes to the SFP. Officers mustrefer to the existing SFP for details on mechanisms for consultation as well as the legislative basis ofthe Agency’s approach to assessing applications for the use of tyres in cement kilns.

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2. PROCEDURAL REQUIREMENTS

There are two distinct procedures for permitting an application to burn tyres in cement kilns:

• Procedure 1, covering applications for tyre trials on kilns where the use of tyres as fuelhas not previously been permitted, and

• Procedure 2, covering applications for tyre trials on kilns where the use of tyres as fuelhas previously been permitted for continuous use and the Operator wishes to increasethe substitution rate.

The requirements of procedures 1 and 2 are described in sections 2.1 and 2.2 and are outlinedin Figures 1 and 2, respectively.

This Protocol may also be used as guidance for Officers when assessing and deciding applicationsfrom Operators for previously unauthorised (i.e. new) kilns, designed to burn tyres. Under thesecircumstances, the Operator must demonstrate within the application that the use of tyres as a fuelrepresents Best Available Techniques (BAT) for the new kiln(s). Also, the Officer must requirethe Operator to follow the technical requirements, as laid out in Section 3 of this Protocol, duringthe commissioning phase for the new kiln(s). A comprehensive commissioning report must besubmitted to the Agency to demonstrate compliance with the permitted limits. This report will bemade widely available.

2.1 Procedure 1: Applications for tyre trials on kilns where theuse of tyres has not previously been permitted

The procedure for permitting is outlined in Figure 1 and described through the following eightstages.

Stage 1: Consultation by Operator

Stage 2: Application for tyre burning

Stage 3: Consultation and assessment

Stage 4: Permit to burn tyres, subject to trial performance

Stage 5: Trial phase

Stage 6: Reporting

Stage 7: Assessment of report

Stage 8: Permission to recommence use of tyres

Figure 1 Procedure 1

Stage 1 ConsultationThe Agency considers that pre-application consultation is vital in order that the local public arebetter able to appreciate fully the issues surrounding the Operator’s proposals. Therefore, theOfficer should encourage the Operator to undertake extensive local consultation outlining itsintentions to use tyres as fuel. Within this consultation the Operator should present as muchinformation as is possible on the strategy for using all substitute fuels at that site. This

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consultation process should begin before an application for a permit is submitted to theAgency. As a result of doing this, the Operator should then address within the application theconcerns raised by the public. This consultation exercise should help the Operator to proposeCritical Success Factors (CSFs) - the specific factors or benchmarks by which the success of atyre burning trial can be judged - for tyre burning.

Stage 2 Application for tyre burningShould the Operator wish to continue pursuing using tyres then an application shall besubmitted to the Agency, detailing the proposals for tyre burning. However, permission to burntyres continuously will be subject to satisfactory completion of a trial. Only after the Officer issatisfied that the kiln can be operated satisfactorily using tyres should permission to burncontinuously be given.

The application should clearly address issues highlighted in the initial consultation exercise.Sufficient information should be supplied for Officers to determine the application in accordancewith the guidance provided in this Protocol.

The kiln to be used must be clearly identified and must be operating within the limits set out in itspermit. In some cases, where there is more than one kiln on the site, and the Operator is applyingto burn tyres also on other kilns, there would normally be a need for a trial on one kiln only. However, in deciding whether to allow this, Officers should compare the kilns on the basis of theraw materials used, the kiln and kiln-feed design, emissions data, operating regime andmanagement controls. However, should the Officer allow continuous tyre burning on other kilnson the site, it is important that permission is given conditional on adequate performance.Therefore, in these cases, the Officer should require, as a condition of the permit, the operator tosubmit a report within e.g. 3 months of commencing continuous tyre burning, detailing kilnperformance. This report must contain information on the level of emissions of those substancesin Table 1 in Section 3.2.4, as well as dioxins and metals. The Officer may also require othersubstances to be monitored depending on the outcome of the original trial.

The Operator should submit a proposed programme for the trial and the Officer willsubsequently determine if the programme is acceptable. This may involve agreeing a trialprogramme that allows setting up and optimisation as well as incremental increases insubstitution rates up to the maximum rate applied for. It may also be appropriate for theOperator to stage the tests e.g. trials at different substitution rates are interspersed with periodsof operation at baseline conditions. Whilst the trial programme should be completed within aperiod of six months the Officer may decide that an extension is acceptable in order to allowthe programme to be completed.

Stage 3 Consultation and AssessmentThe Officer will consider the application and define or accept draft CSFs, which would includeachievement of emission limits and may include considerations of issues raised in earlierconsultation and environmental assessments and relevant management procedures.

Whether or not the application is determined to be substantial as defined by the PPCRegulations, the Agency will determine that statutory consultation is still required, under itspowers in Schedule 7 of the Regulations. The officer will also consider whether, and to whatextent, extended public consultation should also be undertaken. If it is decided that extendedpublic consultation should also be undertaken then the Officer should refer to the consultationmechanisms outlined in the Substitute Fuels Protocol. However, the Officer should focus anyconsultation on the CSFs. In parallel to these activities, the Operator should be encouraged to

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continue consulting with a wider audience. Officers should take care in making clear that thismay be the only formal opportunity for the public to make representations over the application.

Stage 4 Permit to burn tyres, subject to trial performanceOnce the CSFs have been finalized, having taken account of representations made duringconsultation, the Officer may permit the Operator to burn tyres, conditional on satisfactoryperformance of a trial. The trial will be for a fixed duration specified in terms of operationalhours, with a tolerance of about 5% to ensure flexibility at each stage of the trial.

Irrespective of whether tyre burning is subsequently granted or refused, the Agency willproduce a clear explanation of the reasons for the decision and a response to all the relevantissues raised in the consultation process. If representations are made raising issues relevant tothe decision but outside the scope of the Agency's expertise or remit (e.g. issues regardingsafety), they should be referred to an appropriate organisation for comment. Comments fromthat organisation will be incorporated, as appropriate, in the Agency’s explanation of itsdecision. It may also be appropriate to demonstrate how each point has been dealt with byreference to conditions in the permit or variation notice.

It is important to ensure that the Agency's decision on the application is properly documentedand recorded. A decision document will be made widely available, with documents placed ataccessible points, such as the Agency's public registers, libraries and council offices. Thedecision document should be non-technical wherever possible, easy to read, and should relatethe Agency's decision to the key issues raised by the consultation.

Stage 5 Trial PhaseThroughout the duration of the trial the Operator should again be encouraged to keep the publicinformed on the progress of the trial e.g. newsletters, weekly reports etc. In addition, theOperator should gather evidence for reporting on the performance of the trial against the CSFs.The trial must stop if, at any stage, non-conformance with CSFs become apparent. Under suchcircumstances the Officer will have to decide whether the trial can recommence and whethermore consultation should be undertaken. In some cases the permit allowing the trials may needto be further varied.

Once the trial is complete the Operator must stop burning tyres and shall not recommence untiland unless written approval is given by the Officer. A decision would normally be made within8 weeks.

Stage 6 ReportingThe Operator must submit a report of the trial to the Agency. This report must contain anevaluation of performance against the CSFs. The Operator should be encouraged to make thisreport publicly available before submitting to the Agency. In this way, the Operator can addressin the report any concerns the public may have, prior to submission to the Agency. Allrepresentation made by the public and the action taken by the Operator to address them shouldbe clearly highlighted in the report. The Officer should consider rejecting the report if this isnot done.

Stage 7 Assessment of ReportOn receiving the report the Officer will ensure that it is placed on the public registers. At thisstage, the Officer should ensure that all CSFs have been achieved and be fully satisfied that theOperator is capable of operating the kiln using tyres. Consultees, including statutory

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consultees, should be given an opportunity to raise any concerns still outstanding and theOfficer should be satisfied that they have been addressed before allowing further tyre burning.

Stage 8 Permission to recommence use of tyresSubject to satisfactory performance against the CSFs, and providing all representations fromconsultation are adequately addressed, the Agency would then normally permit, in writing, thecontinuous use of tyres as fuel. The time from stopping the trial to permitting continuous useshould not normally exceed 8 weeks.

Key stakeholders should be notified, by letter, of the Agency’s decision in conjunction with asubsequent press release. Also, the Officer should produce a document explaining theAgency’s decision to allow the Operator to recommence tyre burning.

2.2 Procedure 2: Applications for tyre trials on kilns where theuse of tyres has previously been authorised for continuous use

The procedure for permitting is outlined in Figure 2 and described through the following threestages.

Stage 1: Application for increased substitution rate

Stage 2: Consultation and assessment

Stage 3: Continuous use of tyres as fuel

Figure 2 Procedure 2

Stage 1 Application for increased substitution rateFollowing authorisation to burn a particular tyre type at a given substitution rate, for example10%, an Operator may wish to increase the tyre feed rate. In this case, the Operator shouldsubmit an application for a variation to increase the substitution rate. The Officer should take aview on whether to pursue this Procedure or Procedure 1, depending on the incrementalincrease applied for. However, as a general rule the Officer should use this Procedure providedthe requested increase is less than, or equal to, a 10% increment (e.g. 10 to 20% or 15 to 25%).

Stage 2 Consultation and AssessmentOn receipt of an application the Officer will consider the application and define or acceptCSFs. For this type of trial, a lot of information will already be available on the performanceof tyres in the kiln.

Whether or not the application is determined to be substantial as defined by the PPCRegulations, the Agency will determine that statutory consultation is still required, under itspowers in Schedule 7 of the Regulations. Furthermore, the Officer should consider whether,and to what extent, to undertake wider public consultation. The mechanisms available forundertaking extended public consultation are outlined in the Substitute Fuels Protocol. TheOperator should be proactive in informing local residents of the request to increase thesubstitution rate.

Stage 3 Continuous use of tyres as fuelSubject to the Officer being satisfied with the application and, where appropriate, providing allrepresentations from consultation are adequately addressed, the Officer may permit the

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continuous use of tyres as fuel at the new substitution rate. The Officer should, however,require, as a condition of the permit, the Operator to submit a report after a period of tyreburning (e.g. 3 months) outlining the kiln performance. This report must be made available tothe public in order that they can comment on the outcome of the trial. Therefore, in addition toplacing it on the public registers, key stakeholders should also be notified about the availabilityof the report. The Operator should also be encouraged to engage with the local community onthe findings of this report.

At the time of permitting continuous use of tyres a decision document will be made widelyavailable, with documents placed at accessible points, such as the Agency's public registers,libraries and council offices. The decision document should be non-technical whereverpossible, easy to read, and should relate the Agency's decision to the key issues raised by theconsultation.

3. TECHNICAL REQUIREMENTSThis section outlines the information that the operator must include in any application and/orreport concerning the use of tyres.

3.1 Pre-trial requirements

3.1.1 Specification of Tyres

Good generic analytical data are already available on the composition of tyres and it may beappropriate to estimate pollutant inlet burdens from the generic analysis and the measuredinput tyre feed rate. However, Officers should be aware that commercial vehicle tyres exhibitsignificantly different compositions to those of car tyres for some important components (e.g.iron and zinc content). Only tyres that can meet a specification agreed in advance with theAgency will be permitted to be trialed. Consequently, Officers should require Operators tonotify the Agency concerning the mix of tyres to be trialed.

3.1.2 Storage, Handling and Control of Tyres

Operators should demonstrate in the application that they will put in place measures for suitablestorage of tyres. Details of how the thermal substitution rate is to be determined and monitoredshould be provided. The Operator will also need to confirm the circumstances which will lead tothe cessation of tyre feed, e.g. duration of electrostatic precipitator outage.

3.1.3 Specific Requirements

The Operator should demonstrate to the satisfaction of the Officer that the operation of the kiln isproperly controlled and that there are safeguards against potential environmentally damagingupsets. This should include assurances that the management controls are adequate. Evidence ofcompliance with the existing permit should be supported by adequate established emissions data.Furthermore, data must be provided on the operation of the process to demonstrate that theprocess is capable of sufficiently stable operation. For example, in relation to ‘mean time betweenstoppages’, number, duration and cause (e.g. high carbon monoxide) of Electrostatic Precipitatortrips per year. Operators should provide data demonstrating that the number and duration ofcarbon monoxide trips has been minimised. This will enable meaningful test results to beobtained during the trial period, Officers will then need to consider if each of the currentpermitted limits is appropriate for the trials.

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It is vital that most sampling is undertaken at the maximum rate of substitution. This will allowcomparison with a similar number of valid results obtained over a comparable operationalperiod under baseline conditions (see Section 3.2).

If sufficient historic data exist the Officer may permit less testing under baseline conditions,which should be defined as either the design fuel mix for the kiln or the previously tested andpermitted substitution rate. The Officer should only use the latter provided the kiln has beenrecently operating at, or close to, the permitted substitution rate. However, in determining if lessmonitoring than would normally be required for a baseline is justified, the Officer must besatisfied that for the period over which the Operator wishes to use as baseline monitoring nosignificant changes to the process have been made. Criteria to be used in determining if lessmonitoring is justified include:

• no significant changes being made to the process plant (e.g. change of abatement plant or

design fuel);• no significant changes being made to process control (e.g. installation of an expert

management system);• no significant changes to the sampling methods or protocols and the monitoring and

analytical methods meet current standards; and• no significant changes to the installed plant continuous emission monitors.

In view of this, it is important that the Operator notifies the Officer at the earliest opportunitywhenever changes to the process control and monitoring systems are proposed. This willenable the Officer to make a judgement on the comparability with the existing controls.

It is important that all testing is carried out under comparable operating conditions (e.g. similarcoal/coke quality and mesh size, kiln and abatement operation including % Cement Kiln Dust(CKD) recycle, back end temperature, sulphur/alkali ratio etc). It is also important that kilnsshould be allowed to stabilise before attempting any testing. It should be noted that whilststabilisation from cold start may take 2 or 3 days, stabilisation periods from one trial conditionto another may be considerably shorter. In general, 24 hours should be allowed forstabilisation between different trial conditions.

3.1.4 Monitoring Arrangements

Operators must provide details of continuous monitoring instrumentation and monitoringmethods to be used to monitor inputs and outputs from the process as detailed in Section 3.2. The Operator must monitor all significant inputs (including fuels, raw materials, recycledmaterial) and significant outputs (including releases to all media, CKD and products) usingapproved sampling and analysis contractors e.g. accredited under the United KingdomAccreditation Scheme (UKAS).

The general testing and monitoring regime is detailed in Section 3.2, but the actual monitoringprogramme must be agreed with the Officer. Operator monitoring will be audited by theAgency on an unannounced basis.

Operators will propose a method for estimating or calculating gas dispersion, acceptable to theAgency, to be used in their assessment of environmental impact of emissions from the process. Where concerns are raised about ambient levels of pollutants, the Officer will need to consider if

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ambient monitoring is appropriate and, if so, should be carried out to national network standards(see DETR guidance1).

3.2 Monitoring Requirements during Tyre Trials

Wherever possible, and in accordance with the relevant articles of EU Directives, the followingrequirements will be specified in any permit authorising trials and will be enforced accordingly.

3.2.1 The Trials Programme

The Operator should keep to the agreed trials programme as much as possible but if there areunavoidable disruptions the Agency must be informed, and agreement sought to extend theprogramme.

3.2.2 Monitoring Requirements - General Considerations

All Operator monitoring must be carried out at the maximum substitution rate and, whereappropriate, at baseline conditions. The Officer should also consider requiring the Operator tomove from baseline to maximum substitution rates in stages. The Operator should not move tohigher substitution rates until the Officer is satisfied with the overall kiln performance. Theminimum frequency of testing for each determinand is shown in Figure 3, but actual frequencieswill be set by the Agency dependent upon the characteristics of tyres to be trialed. If there areseveral tests within the trials programme each test should be long enough to stabilise operatingconditions for sufficient time to ensure that test results are as representative as possible. Also,tests should be spread evenly over the duration of the trials programme.

Examples of approved standard methods, which must be used by Operators, are provided inAnnex 1. The Agency also requires that UKAS (or equivalent) accredited sampling and analysiscontractors are employed and all sampling and analysis must be representative.

The Officer should audit the Operators monitoring arrangements and facilities before a trialcommences using the Agency’s Operator Monitoring Assessment. Based on this the Officer maydecide that Agency check monitoring should also be undertaken during the trial.

All monitoring data gathered by the Operator and Agency monitoring programmes will be placedon the Public Register.

3.2.3 Testing and Monitoring Facilities

Sampling locations (for releases into air and water, wastes or products and raw materials/fuels)and procedures to ensure representative sampling should take account of the appropriate samplingstandards and must be agreed with the Officer.

Facilities for the sampling of emissions to air should at least meet the standards stipulated inAgency Technical Guidance Note M1(f). It should be noted that M1 is restricted to the applicationof compact total particulate monitoring equipment. However, platform design and railings mustalso be suitable to accommodate other more bulky sampling systems as well as there beingadequate lifting facilities and power supplies. Additional guidance can be found in the SourceTesting Association’s booklet “Hazards, Risks and Risk Control in Stack Test Operations”.

1 Local Authority Air Quality Management Technical Guidance Notes, LAQM TG1.

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If there has been no previous assessment of background surface levels of dioxins and metals itmay be prudent to undertake such a study before trials commence. In these cases, soil andvegetation samples should, as a minimum, be taken downwind of the stack, and at least in thearea calculated to have the maximum ground level concentration, where practicable. Thesampling sites and the pollutants to be monitored must be agreed with the Officer.

3.2.4 The Operator’s Permanently Installed Continuous Emission Monitoring Systems (CEMs)

The minimum requirement for continuous monitoring of emissions at baseline conditions andmaximum substitution rate, using the Operator’s installed continuous emission monitoringsystems (CEMs) are given in Table 1. However, Officers must take account of therequirements set within the Waste Incineration Directive.

Table 1 Determinands to be monitored using continuous emissions monitors

Determinands

Particulate matterOxides of nitrogen (as nitrogen dioxide)Sulphur dioxideHydrogen chlorideCarbon monoxideOxygen, moisture, temperature and pressureTotal organic carbon (TOC)

Continuous stack monitoring should take place over a period of at least 6 weeks (in terms ofoperational hours) at each of the baseline (if appropriate) and maximum substitution conditions.Test periods should be of comparable duration. Data must be recorded/logged as one-minutemeans but instruments must also be capable of providing data for comparison with ambient airquality standards. In addition, maxima, minima, means, and standard deviations are to be reportedfor the various averaging periods.

Continuous emission monitoring systems for gases must be calibrated immediately before andafter each trial and at three monthly intervals if trials continue beyond this period of time.Calibration for gas monitors should follow CEN or British/international standards. The Agencymust be notified in advance and given the option of witnessing such calibrations. Where possiblethe CEMs for gases should also be subject to daily zero and span checks using, for example,certified gas standards.

An Agency audit of the Operator's continuous monitoring should also be undertaken, and includea comparison of Operator's continuous monitoring data with extractive data, and an evaluation ofthe Operator's data logging facility.

Continuous particulate monitors must be calibrated against a standard extractive gravimetricmethod calibrated, before and after each trial, and at least every 6 months.

3.2.5 Periodic Extractive Sampling of Stack Emissions

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To give greater confidence in the results from CEMs periodic extractive sampling will berequired. This could be undertaken using temporary installed extractive instrumental monitoringsystems or by employing manual extractive monitoring methods. The determinands, which mustbe sampled, by the Operator, and the minimum sampling periods, are summarised in Table 2.

Table 2 Periodic extractive sampling requirements for stack emissions

Determinand Minimum sampling period per sample

Particulate matter In accordance with approved standard but likely to be around1 hour per sample

PM10 As per particulate matter

Oxides of nitrogen (as NO2) Continuously for at least 12 hours

Sulphur dioxide Continuously for at least 12 hours

Carbon monoxide Continuously for at least 12 hours

Oxygen Continuously for at least 12 hours

Hydrogen chloride 1 hour

Hydrogen fluoride 1 hour

Total Organic Carbon) Continuously for at least 12 hours

Heavy metals(1) 1 hr

Dioxins and furans 6 hours

Polychlorinated biphenyls (PCB's)(2) 6 hours

Polycyclic aromatic hydrocarbons 6 hours

Stack moisture 1 hour

Stack gas flow rate and temperature In accordance with approved standard

Note (1) Arsenic, lead, chromium, copper, cobalt, vanadium, mercury, cadmium, thallium, nickel, manganese,antimony and zinc

Note (2) In the absence of a recognised sampling standard, determination of PCB concentration should beundertaken in accordance with the principles and procedures in BS EN1948

Periodic extractive testing for each determinand must be undertaken for the duration shown inTable 3 and should be spread out evenly over each of the baseline (where appropriate) andmaximum tyre feed rate trial periods. All periodic manual sampling must be undertaken duringsteady state operation of the kiln. Where periodic extractive instrumental monitoring systems areemployed, these must be fully calibrated immediately before and after each trial. Also, as aminimum, these systems must be spanned and zeroed immediately before and after each sampleperiod using certified standard gas mixtures.

Calibration gases shall be certified in conformance with BS 4559 Part 4 (ISO 6141). Operatorsand monitoring contractors shall procure calibration gases from suppliers having UKAS (orequivalent) accreditation for the analysis of gases.

In accordance with BS 4559, each calibration gas cylinder shall have a full certificate ofanalysis, and a certificate of minimum requirements (extracted from the full certificate of

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analysis) which shall be attached to the container of calibration gas. These minimumrequirements are listed in Table 4.

Table 4 Minimum requirements for calibration gas certificates, as attached tocalibration gas cylinders.

Item Requirement1 Unique certificate identification2 Container identification3 Specified components4 Composition5 Expanded uncertainty6 Filling pressure7 Valve outlet connection8 Minimum utilisation pressure9 Storage/utilisation pressure10 Expiry date

Stack gas testing should meet the following minimum requirements and each of the parametersdetailed below must be monitored under baseline conditions (where appropriate) and atmaximum substitution rate.

To determine the various monitoring options and the minimum number of samples to be takenand the sampling frequency, determinands indicated in Table 2 should be inserted (in turn) inthe flow chart given below.

Officers should note that Figure 3 represents the required number of samples that must betaken in order to provide the minimum number of valid results.

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YES

Operator collectsdata continuouslyduring trials andvalidates CEMs

YES

Installedstack CEMs fordeterminand

?

Contractor collectsdata for 12 hrs overeach of 6 test days

YES

2 consecutivemanual samples oneach of 6 test days ①②

YES

2 consecutivemanual samples on 1test day

NO Is thecontractor usingcontinuous

instr ?

NO Dioxins,

PM10, Particulatematter or

metals

NO

PCBs ?

Monitor for 12 hrs onone test day

YES Independent

continuousinstruments

used ? .

6 manual extractivesamples ①

NO

START

Measure flow, Oxygen,temperature, moisture andpressure at least twice oneach test day

Key

Action(s) to be taken Question

① For particulate matter, if BS3405 is to be satisfied at least two consecutive samples will be required toobtain one valid result.② In accordance with BS EN1948, a field blank will additionally be required.

Figure 3 Flow chart for determining minimum stack sampling requirements for anindividual test

3.2.6 Testing of Inputs, Products and Material Collected in Abatement Equipment

Testing of feeds, all fuels (excluding tyres), material collected in abatement equipment andproducts is required under baseline and substitution conditions. The collected samples must beanalysed for the following parameters as given in Table 3.

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Table 3 Periodic monitoring requirements for kiln inputs and outputs

Parameter Feeds(a)

Fuels (a)(b)

CKD(a)(d)

Clinker(a)

Heavy metals ✔ (c) ✔ (c) ✔ (c) ✔ (c)

Total of each S, F, Cl, Br, I ✔ ✔ ✔ ✔

Dioxins and furans ✔ ✔

Flow (kg/hr) ✔ ✔ ✔ ✔

Calorific value (gross) ✔

Free lime content, alkalinity,and pH of leachate

✔

PCBs content ✔ ✔

NOTES✔ Denotes that a parameter is to be periodically monitored(a) At least two samples to be taken over each test period (Officers have discretion as to how samples

are to be bulked for analysis)(b) Each fuel to be tested separately(c) Arsenic, lead, chromium, copper, cobalt, vanadium, mercury, cadmium, thallium, nickel,

manganese, antimony and zinc(d) Sampling not required if 100% of the cement kiln dust is recycled during normal operation.

Representative sample increments (using a method(g) agreed with the Officer) should be takenonce per hour during the test periods and accumulated to provide a bulk aggregated sample. Where practicable, sample increments should be taken from falling or flowing streams. Forsolids, any material above 5 cm in size in the bulk aggregate sample should be crushed, thenthe sample should be mixed and progressively sub-divided (e.g. by cone and quartering) toprovide a single representative sub-sample (around 5 kg) for each test period.

3.2.7 Environmental Monitoring

Where there are specific justifiable concerns, a programme of ambient air monitoring may berequired to back up the Operator’s assessment of environmental impacts from dispersionmodelling, and to demonstrate that releases are rendered harmless consistent with BAT. Account should be taken of the Agency’s guidance on the monitoring of ambient conditions setout in Technical Guidance Notes M8(h) and M9(i).

3.2.8 Recording of Process Parameters

Plant process conditions shall be recorded during the baseline and tyre burning periods of alltrials, and must be included in all monitoring reports. As a typical minimum requirement, thismay include readings of the following parameters (example for dry cement kilns):

• cyclone pre-heater temperatures;• primary and secondary air temperatures;• clinker cooler temperatures;• kiln exit temperatures;• kiln throughput;• fuel quality and input rates (including tyres when being burned);

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• abatement operation (including details of abnormal operation and times);• kiln exit carbon monoxide and oxygen concentrations;• CKD recycle rate; and• alkali/sulphur ratios.

3.3 Reporting of Tyre Trials

3.3.1 Content of Report

To enable an Officer to evaluate the results of tyre trials it will be necessary to submit acomprehensive report, which is complete in its own right. Officers should not have to makereference to documents elsewhere or to ones that have been submitted to the Agency on someearlier occasion. Therefore, the report should include the following: a) Covering letter explaining what has been submitted and a synopsis of the company's

findings;

b) Performance and degree of achievement against the CSFs; c) Comparative data for both baseline testing and trials testing at the maximum substitution

rate, comprising results from all process measurements and analysis, measurements andanalyses for all inputs and outputs from the process, and mass balances where possible;

d) All other relevant testing and monitoring including environmental sampling and analyses;

e) Information regarding issues raised during consultation and how they have been addressed; f) Conclusions and recommendations including justification; and g) Non-technical summary of the application.

3.3.2 Reporting of Monitoring Data

Monitoring results must be reported on Environment Agency standard report forms (whereavailable) for monitoring of emissions to atmosphere. All reports shall include the followingfeatures, as a minimum requirement:

• Details of all methods employed for sampling and analysis, including reference to standard

methodologies;• Details of plant layout, sampling ports and planes with diagrams;• Limits of detection, accuracy and precision on an individual basis for all samples;• How the limits of detection, accuracy and precision of measurements have been determined;• Plant operating conditions - any abnormalities should be highlighted (with timings) for the

period of the trials;• Summary tables of all monitoring results;• Start and end times of all sampling;• Full presentation of pitot and temperature traverses taken before, during and after sampling,

along with gas flow rate results;• Full raw monitoring data in appendices, including all laboratory measurements and test

variables;• Presentation of calculations of concentrations, flows and mass emissions;

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• Details of any non-compliance with standards employed;• Dioxin test reports should include determined levels of all congeners and full tabulation of

spike recoveries by congener;• Metals test reports for stack emissions should tabulate each metal measured in both particle

and vapour phases. The combined emission should be reported for each metal. The mass ofeach determinand collected in the particle phase, the bulked impinger solutions (excluding thefinal impinger solution) and the final impinger solution must be measured and reportedseparately; and

• Derivation of monitoring results used for dispersion, dioxin trail and BPEO assessments.

4. CONSULTATION ISSUES

4.1 The Agency welcomes your comments on the proposals we have set out in this Tyres Protocoland, in particular, your responses to the following questions.

1. Do you agree with the concept of using well-defined success criteria as a basis foraiding the Agency’s decision making process?

2. What sort of performance measures do you consider should be success criteria?3. Are you broadly supportive of the proposal to encourage the industry to play a greater

role in the consultation process?4. How would you assess the effectiveness of this Protocol?

The Agency will review this Protocol following the external consultation process.

Responding to the consultation

4.2 The closing date for the consultation is 31 July 2001. Please send your response to:

Dr N H DaviesEnvironment AgencyRio HouseWaterside DriveAztec WestAlmondsburyBristolBS32 4UD

Phone: 01454 624478Fax: 01454 624374E-mail: {TyresProtocol@environment-agency.gov.uk}

This consultation document can also be viewed on our website (http://www.environment-agency.gov.uk) from where consultation responses can be sent directly.

This consultation is being carried out in accordance with the principles of the “Code of practiceon written consultation” issued by the Cabinet Office in November 2000. This is available on(http://www.cabinet-office.gov.uk/servicefirst/2000/consult/code/ConsultationCode.htm).

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5. REFERENCES

(a) Directive 1999/31/EC of The European Parliament and of The Council of April 26 1999 onthe Landfill of Waste. Official Journal of the European Communities L 182, 16/07/1999p.0001-0019

(b) Substitute Fuels Protocol for Use on Cement and Lime Kilns. Environment Agency 1999. Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol. BS32 4UD

(c) Directive 94/67/EC of The European Parliament and of The Council of 16 December 1994on the incineration of hazardous waste. Official Journal L 365 31.12.1994 p.34

(d) Council Directive of 8 June 1989 on the prevention of air pollution from municipal waste

incineration plants (89/369/EEC).

(e) Directive 2000/76/EC of The European Parliament and of The Council of 4 December 2000on the incineration of waste. Official Journal L 332/91 11.3.1997, p.1.

(f) Technical Guidance Note M1 Sampling facility requirements for the monitoring ofparticulates in gaseous releases to atmosphere, March 1993, ISBN 0-11-752777-7.

(g) Environment Agency – Guidelines for Ash Sampling

(h) Environment Agency Technical Guidance Note M8 - Monitoring Methods for Ambient Air(in preparation).

(i) Environment Agency Technical Guidance Note M9 - Environmental Monitoring Strategy:

Ambient Air (in preparation).

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ANNEX 1 - APPLICABLE STANDARDS

Table A1 - Reference Test Methods1

Pollutant Standard Reference TitleHydrogen chloride BS EN1911: 1998, Parts 1 to 3 Air Quality - Stationary source emissions - Manual method of determination of HClHydrogen halides2 US EPA Method 26A Determination of Hydrogen halide and halogens from stationary sourcesDioxins and furans BS EN1948: 1997, Parts 1 to 3 Stationary source emissions - Determination of mass concentration of PCDDs/PCDFs PCDDs/PCDF’S - Part 1:

Sampling, Part 2 Extraction and clean-up, Part 3: Identification and quantificationParticulate matter3 BS3405 : 1983 British Standard Method for Measurement of particulate emission including grit and dust (simplified method)Particulate matter BS 6069-4.3 : 1992 (ISO 9096) Stationary Source emissions - Determination of concentration and mass flow rate of particulate material in gas

carrying ducts - Manual gravimetric methodGas velocity4 BS 1042 Part 2.1:1977 (ISO 3966) Measurement of fluid flow in closed conduits - Velocity area method using Pitot static tubes.Gas velocity ISO 10780 Stationary source emissions - Measurement of velocity and volume flowrate of gas streams in ductsSulphur dioxide5 BS 6069-4.1: 1989/Corr1998 (ISO

7934)Stationary Source emissions - Determination of the mass concentration of sulphur dioxide - Hydrogenperoxide/barium perchlorate/Thorin method.

Sulphur dioxide6 ISO 11632 : 1992 Stationary source emissions - Determination of the mass concentration of sulphur dioxide - Ion chromatographymethod

Nitrogen oxides7 BS ISO 11564 : 1998/Corr2000 ISO 11564:1998 Stationary source emissions -- Determination of the mass concentration of nitrogen oxides -- Naphthylethylenediamine photometric method

Heavy metals US EPA Method 29 Determination of metals emissions from stationary sourcesTotal OrganicCarbon

BS EN12619 : 1999 Stationary source emissions - Determination of the mass concentration of total gaseous organic carbon at lowconcentrations in flue gases - Continuous flame ionization method

Moisture US EPA Method 4 Determination of moisture in stack gases Notes:

1 This table should be used for guidance purposes only and should not be regarded as an authoritative summary. Sampling of all pollutants as well as reference measurements to calibrate automated measurement systems or toprovide correction of data to reference conditions shall be carried out as given by CEN standards. If CEN standards are not available, ISO standards, national or international standards which will ensure the provision of data of anequivalent scientific quality shall apply, subject to approval from the Agency. (Last updated 1 March 2001). If instrumental methods are to be used for reference testing, then refer to the standards in Table A2 for the applicableperformance standards.

2 This method is used for determining the concentration of fluoride in the stack gas emissions.

3 BS 6069 Part 4.3 is recommended, unless there is a sound reason to justify the use of BS 3405.

4 ISO 10780 is recommended, unless there is a sound reason to justify the use of BS 1042-2.1

5 The correction from 1998 must be applied.

6 This method is not recommended if sulphur trioxide is present, or if ammonia and/or volatile sulphates are present at a concentration more than 5% by volume.

7 The correction from 2000 must be applied.

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Table A2 - Standards for continuous emissions monitoring systems1

Pollutant Standard Reference Title

Particulate matter BS ISO 10155:1995 Stationary source emissions - Automated monitoring of mass concentrations of particles – Performance characteristics, testmethods and specifications

Gas flow BS ISO 14164: 1999 Stationary source emissions - Determination of the volume flowrate of gas streams in ducts - Automated methodSulphur dioxide BS 6069-4.4:1992 (ISO

7935)Stationary source emissions - Determination of the mass concentration of sulphur dioxide -– performance characteristics ofautomated measuring systems

Nitrogen oxides2 ISO 10849: 1996 Stationary source emissions - Determination of the mass concentration of nitrogen oxides -– Performance characteristics forautomated measuring systems

Carbon monoxide,carbon dioxide andoxygen3

ISO/DIS 12039:2001 Stationary Source Emissions - Determination of the volumetric concentration of CO, CO2 and oxygen - Performancecharacteristics and calibration of an automated measuring method

Total Organic Carbon BS EN12619:1999 Stationary source emissions - Determination of the mass concentration of total gaseous organic carbon at low concentrationsin flue gases - Continuous flame ionization method

General requirements ISO 10396 Stationary source emissions - Sampling for the automated determination of gas concentrationsNotes:

1 These standards contain performance specifications for continuous emissions monitoring systems.

2 ISO 10849 is to be adopted by the British Standards Institution as BS ISO 18049

3 Although ISO/DIS 12039 was still technically a draft standard at the time of writing, the formal process of voting was scheduled for April 2001.

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ANNEX 2 GLOSSARY OF TERMS

BPEO Best Practicable Environmental Option

Br Bromide as bromine

CEN Committee European de Normalisation (European standards committee)

CKD Cement Kiln Dust (dust collected in air pollution control equipment)

Cl Chloride as chlorine

DETR Department of Environment Transport and the Regions

Dioxins A series of polychlorinated dioxin and furan ring compounds numbering over 200. TEQ refers to a toxic equivalent rating which is usually applied to the seventeen2,3,7,8 chloro-substituted congeners.

EIA Environmental Impact Assessment

EP Electrostatic Precipitator

EU European Union

F Fluorine

HCl Hydrogen chloride

HF Hydrogen fluoride

HWD Hazardous Waste Directive

I Iodide as iodine

MWID Municipal Waste Incineration Directive

NO Nitrogen monoxide (nitric oxide)

NO2 Nitrogen dioxide

NOx Total oxides of nitrogen (NO + NO2)

O2 Oxygen

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PCBs Polychlorinated Biphenyls

PPC Pollution Prevention And Control Regulations

Sample A small representative part of a material flow taken during a test period

S Sulphur

SO2 Sulphur Dioxide

Test A period during which burning is carried out at a single condition(eg tyre substitution rate) and a number of samples are taken

TOC Total Organic Carbon

Trial A series of tests undertaken at different conditions (eg tyre feed rate varies) with aspecific objective

UKAS United Kingdom Accreditation Service (now replaces NAMAS)

USEPA United States Environmental Protection Agency

Valid result A monitoring result that is considered by the Agency to be acceptable for monitoringmethod applied and representative of the measured process parameter

VOC Volatile Organic Compounds

WID Waste Incineration Directive