Refuse Derived Fuel: Is it Time for Minimum Treatment Standards?

While Solid Recovered Fuel (SRF) is required to meet strict quality requirements, Refuse Derived Fuel (RDF) is not. WMW asked a number of sector leaders for their thoughts on whether the introduction of minimum treatment standards for RDF would benefit the industry? Standards not Necessary but Waste Derived Fuels Must Continue to be a 'Waste' The need for quality criteria for waste derived fuels, be it SRF or RDF, depends on where they are to be used. If the destination is a dedicated Waste-to-Energy plant, a pre-treatment or input criteria for the waste is not necessary, as the plants are equipped with sophisticated flue gas cleaning systems. This enables WtE plants to accept heterogeneous waste while achieving the strict emissions requirements set in the Industrial Emissions Directive and the appropriate Best Available Techniques. However, if the waste is to be used at co-incinerating industrial facilities, for example cement kilns, then it is in the plant's own interest for certain input criteria be met to avoid technical problems such as corrosion or negative impacts on their product. This is because RDF is made of mixed waste materials including residual municipal waste, and is therefore quite heterogenous. For this reason, the industry has developed its own requirements on the use of SRF within the European Standardisation Committee (EN15359). However, this does not necessarily set environmental criteria, but provides fitness-for-use criteria setting out under which conditions a waste can be accepted without damaging the plant. Therefore, the European Standardisation Committee (CEN) sets limits for the chlorine content. It also establishes a net calorific value, which is an economic factor. The only environmental criterion is regarding Mercury (Hg). In general, heterogeneous waste such as RDF should be treated in dedicated waste-to-energy plants which are equipped with specific flue gas cleaning systems, whereas SRF can be suitable for co-incineration in industrial plants. Must Remain 'Waste' I cannot underline enough that both SRF and RDF must remain under the waste legislation in order to ensure a high level of environmental protection. The application of waste law guarantees that the burning of SRF and RDF comply with air pollution control legislation and Best Available Techniques, as set for waste incineration and co-incineration. This will prevent damage to health and the environment from the burning of heterogeneous material in poorly designed boilers and unregulated facilities lacking proper flue gas treatment or in facilities which do not comply with Best Available Techniques. It is also central to the application of the EU Waste Shipment Regulation with its necessary controls over its destination and where SRF or RDF might end up. For reasons of traceability, tracking and control of this material, SRF and RDF should also never become 'Green List' waste, as in this case prior notification is not requested for transboundary shipments. Ferdinand Kleppmann president of the Confederation of European Waste-to-Energy Plants Standards Should be Demand Led but Food Waste Needs Sorting The distinction between SRF and RDF might not be so large in terms of quality, not least given the characteristics of the lowest class of SRF. In principle, if quality standards were able to ensure an improvement in beneficial outcomes commensurate with their cost, then this might be a sensible idea. In practice, however, requiring exported RDF to meet standards which do not have to be met by waste generated within the receiving country, and which enters the very same facility, may simply increase costs for no benefit, and might be considered a form of trade barrier. Many receiving facilities have their own preparation processes, and preparation prior to export may actually pose more problems than it solves. The key is to prevent illegal exports and waste crime: to ensure that waste is not causing problems while being stored or transported. This suggests a focus on matters such as moisture content, and perhaps, rough shred size, and bale density. Over and above basic standards designed to protect health, standards to commodify waste as an energy source ought to be (is) demand-led by receiving industries. The designation of incineration as 'recovery' was explicitly sought by the European incinerator lobby. It flows from this that waste can cross borders where destined for such facilities. Current (not legally binding) European Guidance on this allows for the heat used within the plant to be counted when assessing whether a plant qualifies as recovery or disposal. This makes it feasible to achieve the R1 criterion through only generating electricity. A more challenging threshold based on the amount of heat and power exported and utilised would give greater confidence that where residual waste was exported for recovery, in whatever form, the efficiency of the energy recovery and use would be high. Much has been made of the fact that export of waste for incineration undermines the development of domestic incineration capacity. Our concern is that it risks undermining prevention, reuse and recycling also, because of the potential to suppress the costs of dealing with residual waste. Some countries, such as Sweden, are continuing to build capacity to satisfy the export market. One way to address this would be through an incineration tax. Complementary measures are requirements to sort waste. Given the relatively finely balanced economics at present, and the desirability of giving greater certainty in the market, it seems a sensible time to push forward on a requirement to sort food waste. Other materials could also be included in such requirements, as per the Scottish approach. Dr Dominic Hogg chairman and founder of environmental consultancy, Eunomia research & Consulting Minimum Standards Could Drive Recycling and Boost Public Perception of WtE While SRF is manufactured to a defined quality specification, RDF is much cruder. This is not because we don't have the technology to produce a more refined substance. On the contrary, innovative processing equipment exists to enable us to achieve a homogenous and highly segregated material. However, RDF customers have not dictated a strict specification like SRF users have, because they are happy with the quality of fuel being supplied. It's not surprising really. After all, there is wealth in waste. So, at present, RDF importers seek volume and the ability to charge higher gate fees. They are also undoubtedly happy with high levels of valuable revenue-generating recyclates such as metals and plastics, being shipped with the fuel. However it could be argued that this commercially-driven interest is perhaps to the detriment of environmental gain. As the EU strives to achieve its resource efficiency goals, we should all be working harder to recover more recyclates during the RDF production process. A quality specification would also give greater peace of mind regarding RDF utilisation. What's more, a quality grading would go some way to improving public perceptions surrounding alternate fuels, certainly in countries such as the UK where waste to energy is less warmly embraced by the public. It is important to consider the apparent growth of the RDF market too. UK export levels alone reportedly rose from just under 900,000 tonnes in 2012, to 1.5 million tonnes in 2013. More and more countries will undoubtedly increase RDF production in acknowledgement of this high level of trade. However, if a quality standard is not in place, how will the market protect itself from spurious imports? A minimum quality grade would act as a barrier to entry for less scrupulous manufacturers who perhaps want to make a 'quick buck'. The 'walk before we can run' phrase is potentially relevant here. To introduce a complex grading system overnight may cause too much market disruption. However, a minimum standard would drive some initial improvements and the subsequent phased implementation of a quality framework could help to achieve even more of the above benefits. It's great the UK government is consulting industry to define what a realistic specification could be. Criteria such as particle size, calorific value and metallurgical content should be considered. Admittedly, policing this will not be easy, especially when organisations such as the Environment Agency face continued cut-backs. However, perhaps TFS regulations could be adapted to help monitor quality. Plus, if governments better acknowledged the long-term economic and renewable energy benefits of waste to energy, maybe more resource would be allocated to safeguarding this area of industry. Chris Oldfield managing director of waste shredding specialist UNTHA UK RDF is A Commercial Opportunity but Recyclables Must be Separated Market demand for fuel derived from waste is driven by the need for sustainable solutions to low-cost energy and unavoidable non-recyclable waste. While some users require SRF, there exists ample demand for RDF, which can be cheaper to produce. Arguments about recyclable material remaining in RDF can be quashed by introducing requirements to extract what is practicable from the waste stream. Quality standards certainly have their place, and it is important that waste processors can achieve certification to provide the market with the assurances it requires. But since not all facilities have such specific requirements, it would perhaps be unnecessarily and burdensome on the industry to insist that all residual waste is processed to SRF standards. That said, it is important to ensure that valuable recyclable materials are not being exported in RDF, and RDF processors worth their salt are already extracting whatever value is practicable from the waste stream. It is simple economics: why pay for a material to be recovered when you can generate an income stream? Extracting the value of materials domestically is always going to be beneficial. An important consideration with tightening regulations around SRF/RDF is the increasing amount of material that is rejected, which then ultimately ends up back in landfill. It's an important balance to strike, and the European Recovered Fuel Organisation is making great strides in strengthening this side of the industry. So there is an argument for introducing quality standards in terms of the process and limiting the amount of recyclables left in the material. That would certainly benefit both waste producers and waste processors. But since SRF and RDF are two distinct products, it is important not to take a hammer to crack a nut, and respect the role in the market for both types/standards of material. The UK may harm itself if it introduces a single-tier quality standard, meaning that all residual waste destined for energy recovery needs to meet SRF requirements. That could price the country's RDF producers out of the market for lower grade fuels, and potentially result in stockpiles of waste with no destination. Particularly since much of the UK's SRF/RDF is currently exported to Europe, it makes sense to provide what is needed. It's always good to make sure that all parts of industry are served, and that includes low-cost waste disposal and affordable energy. Gavin Williams director for Recycling & IRM at Biffa