Foreword

Download the BLA code of practice for the use of waste-derived fuels in lime kilns - here.

The British Lime Association (BLA) Members are committed to improve continuously the sustainability of lime operations and to operate to a standard that complies with the Environmental and Socially responsible objectives of the Association.

Using waste-derived fuels in lime manufacture improves the sustainability of lime operations by reducing the use of fossil fuel and helping to solve society’s waste problem. Opportunities for widespread use of waste-derived fuels in the Lime Industry are limited by the requirement from many customers for high purity lime products (particularly in the pharmaceutical and drinking water purification sectors). Clearly the very cleanest fuels must be used to drive the calcination process for these markets to ensure that there is no contaminant in the final product. However, waste-derived fuels have been used successfully by the UK lime industry since the 1990’s and have been demonstrated to deliver clear environmental benefits. The use of waste-derived fuels is subject to strict regulatory controls and this Code of Practice has been developed by the BLA with its Members to set out the minimum standards to which members will adhere.

The BLA commitment to up-front stakeholder consultation prior to making a formal application to the Environment Agency goes over and above regulatory obligations, and seeks to involve the local community and interested parties at an earlier stage in the process.

Introduction

1. Members of the BLA using waste-derived fuels will abide by the requirements of this Code and all relevant UK legislation.
2. Alleged breaches of the Code will be investigated by the BLA and Members will be required to explain the reasons for any proven infringement. Relevant actions to ensure compliance with the Code will be taken by the BLA.
3. Members will comply with the regulatory requirements imposed by the Environment Agency, the Health and Safety Executive and other relevant regulatory bodies at all times. This Code goes beyond these statutory legal requirements and is designed to ensure that employees and the public appreciate the strict conditions under which waste-derived fuels are used.

Categories of fuel

4. The categories of fuel employed will follow …..(equivalent of BCAs WBCSD CSI) Guidelines
5. This Code applies to all waste derived fuels, including:
   
   

   Chipped tyres

   Liquid Fuels (e.g. waste oil, mixed solvents)

   Solid fuels (e.g. plastic, paper)

   Animal derived fuel (e.g. tallow, meat and bone meal)

   Sewage sludge

   Other combustible waste streams

6. Member companies will not use any of the following in their kilns as fuel, or in our waste recovery and disposal operations.

   Nuclear waste

   Infectious medical waste

   Chemical or biological weapons destined for destruction

   Entire batteries

   Unknown or non-specified waste

New fuels

7. The first time a particular waste-derived fuel is used within a lime works, will be considered as a ‘new-fuel’.

Consultation

8. Under the Provisions of the Waste Incineration Directive, a change from burning a non-hazardous waste to burning a hazardous waste would be classified as a substantial change.
9. On the basis of widespread experience in the use of substitute fuels, and in view of the legal and technical requirements applicable to their use, most other applications would not be regarded as a substantial change.
10. Members will inform the Environment Agency of its intention to burn a ‘new fuel’ at one of its works and advise the Agency of the nature of the consultation process.
11. Members will consult those identified in the PPC Regulations and succeeding legislation relevant to this area, and will inform them of the company’s intention to burn a ‘new fuel’, regardless of whether it is deemed a substantial change or not.

Consultation format

12. Members will discuss the proposal for a ‘new fuel’ with local stakeholders prior to submitting the formal application for a variation: using the established site liaison committee; through local publications (such as newspaper or website); and other means as appropriate. Stakeholders will be encouraged to comment throughout the process.
13. Where appropriate, the company may additionally communicate its intent through community newsletters.

Community relations

14. Communications are a primary concern of lime manufacturers and Members are committed to developing effective and constructive liaisons with their local communities. They undertake to liaise with local councils and meet periodically to ensure that the information regarding environmental effects is in the public domain.

Fuel evaluation

15. Members shall abide by the requirements of the …..(equivalent to WBCSD VSI Guidelines) for the Selection and Use of Fuels and Raw Materials.

Legal compliance

16. Members shall submit an application to vary their permit issued under PPC or succeeding legislation to the Environment Agency to allow the use of the ‘new fuel’.
17. Members shall abide by the requirements of the Waste Incineration Directive and their varied permit issued under the PPC or succeeding legislation whilst using waste-derived fuels.
18. A technical evaluation of each ‘new fuel’ will take place for a set period, typically 4 weeks following commencement of use followed by continuous monitoring evaluation during normal operation. During the evaluation, continuous emissions monitors will be used along with periodic extractive monitoring as required by the WID. The technical evaluation will be agreed in advance with the Environment Agency.

Nuisance

19. The storage and control of waste-derived fuels will be addressed in the application for a permit variation under PPC or succeeding legislation. Potential nuisance issues, such as litter or odour, relating to a ‘new fuel’ will be addressed during the evaluation period. Members will ensure that the handling and storage of ‘new fuel’ does not impact beyond the site boundary or pose a nuisance issue to the environment or local communities.

Management system

20. All lime plants in the UK are covered by one or more accredited environmental management systems. Members will ensure that any additional operational and other requirements associated with the handling of the ‘new fuel’ will be incorporated within the management system. With regard to the use of a waste-derived fuel, the management system will include consideration of: organisational control, assessment of risk, operational control, training, data collection, review/audit, document control and records.

Reporting

21. At the end of the evaluation, the member will submit a report to the Environment Agency. Copies of the report will be provided by the member for interested parties upon request. The results of the trial will be communicated to local groups through the site liaison meetings, via web sites etc.
22. The member will submit an annual performance report to the Agency and make it available to other interested parties on request on the functioning and monitoring of the burning of the waste-derived fuel. This will include the following areas: annual consumption of waste-derived fuels, time plant is operational and reasons for significant outages, amount and fate of residues from burning the waste-derived fuel, any electricity or other energy produced/exported and the emissions measured (both continually and periodically).