The European Union’s Circular Economy Package has a number of clear targets linked to discourage landfill and increase recycling. Whether this package is adopted in any form by the UK government will depend on how its relationship with the EU is defined and the strategy developed as part of the Brexit negotiations. However, whatever the final approach refuse derived fuel (RDF) in its broadest definition and energy from waste (EfW) - the thermal treatment of waste coupled with energy recovery – must be included and should play a central role to the development of the Circular Economy.
RDF coupled with EfW is a key method for taking the residual element of both municipal and commercial waste and converting it for further beneficial use as a form of energy – either electricity and/or heat. In addition this approach also helps to provide low cost, sustainable and secure energy. Finally, with Brexit this may represent a further opportunity to develop the infrastructure within the UK rather than exporting RDF to Europe or beyond.
The export of RDF from the UK has grown from 0.8 million tonnes in 2012 to 1.6 million tonnes in 2013 to over three million tonnes by the end of 2015, based on information from the Environment Agency. This does not reflect the true growth of the RDF market as there are also quantities of RDF that are in storage, but not destined for an end-user – the grey market which is causing a rise in concern over the RDF market.
It had been widely expected that the export market would continue to grow beyond 2016 and until additional EfW capacity in the UK commenced operation.
The failure of a number of new projects to reach operation has placed further pressure on the export market.
However, the single largest impact on the market has been the vote by the UK in June 2016 to leave the European Union. The immediate impact is not through any change in relations with receiving European countries, but through the resulting devaluation of the pound which places significant pressure on those exporting RDF into the European market. A number of organisations are now struggling to viably export RDF with a number already going into administration and more expected to follow.
A drive for quality and best practice
Quality requirements for RDF are generally set by the end-user. For example, if the final destination is a dedicated EfW the input criteria may be low with the waste not requiring pre-treatment as the plant will be operated under strict regulations and be equipped with equipment for removing and cleaning emissions before release to atmosphere. This approach enables the plant to accept waste with more varied compositions while still achieving the strict emissions criteria as set out in the Industrial Emissions Directive.
However, if the RDF is to be used for co-incineration or as part of an industrial process such as cement production then it is in the best interests of that plant to ensure that certain criteria are met to avoid technical problems such as corrosion, negative impacts on product or unwanted emissions to atmosphere.
It is these higher quality fuels that typically fall under the SRF banner and are likely to be produced under the European EN 15359 standard. However, this does not necessarily address the environmental, storage and transportation criteria, but provides fit-for-use criteria under which the waste can be accepted. And even though this standard may be achieved the SRF is still classified as a waste and moved under waste regulations.
It is even more highly unlikely now that any form of Europe-wide standard for RDF will be developed and implemented meaning that it will be down to end-users to determine input criteria in conjunction with limited and specific definitions such as that for SRF. Many EfWs within Europe are designed and set up to receive municipal and/or commercial waste with little or no pre-treatment and are willing to accept RDF that has undergone minimal treatment and so have no interest in implementing stricter acceptance standards.
The lack of standards and willingness to accept waste that has received minimal treatment has meant that it is relatively easy both technically and financially for operators to start up and enter the market to ‘treat’ waste and produce an RDF. The Department for Environment, Food & Rural Affairs (Defra) has developed an updated definition for RDF that clarifies what is expected of waste described as RDF.
The new definition follows a process that began in March 2014 when Defra issued a call for evidence into the market challenges faced by the RDF sector. It then announced in December 2015 that it would introduce an RDF treatment standard to address concerns from within the industry regarding RDF production processes, the improper or illegal storage and stockpiling of RDF, and the lack of strict legal enforcement on behalf of government authorities.
Defra stated that the introduction of a clearer definition alongside a regulatory treatment standard would help ‘provide clarity’ within the industry and ensure that the waste hierarchy is followed.
The new definition, released by Defra in November 2015, reads: “RDF consists of residual waste that is subject to a contract with an end-user for use as a fuel in an energy from waste facility. The contract must include the end-user’s technical specifications relating as a minimum to the calorific value, the moisture content, the form and quantity of the RDF”.
The definition has been composed to ensure that any waste described as RDF is legitimate and has a definite end-user. This will help address cases where waste is described as RDF, but has been abandoned or is causing problems, such as leaching, after being stockpiled for long periods. Defra says it has been configured so that legitimate businesses in the RDF sector are unaffected.
Look at the supply chain
Perhaps a more successful way of tackling poor quality is to look at the whole supply chain and include production, storage and transportation. This would then provide a focus on other existing regulations such as waste crime under which storage and transportation is covered.
Requiring more stringent permitting or some form of financial guarantee/bond would also assist in improving the standards within the whole supply chain, reduce impact on the environment from issues such as odour and may help to prevent the rogue operators from entering the market and reduce the associated ‘grey market’.
The designation of incineration as ‘recovery’ means that waste can cross borders where destined for such plants and current, although not legally binding European Guidance on this allows for the heat used within the plant to be counted when assessing whether a plant qualifies for recovery or disposal meaning that R1 status can be achieved through electricity generation.
Perhaps an alternative more challenging threshold based on the amount of heat and power exported and utilised would give greater confidence that where residual waste as RDF is exported for recovery the efficiency of the energy recovery and used would be higher.
The treatment of municipal and commercial waste to produce RDF is here to stay. However, we are likely to see in the long-term more RDF used within the UK market as additional EfW capacity becomes available.
Including EfW as part of the CE, and not as an afterthought or bolt-on, will ensure that the correct focus is placed on generating quality recycling while ensuring the most effective use of the residual as a fuel for energy generation. It can act as a driver for quality recycling by providing a valuable method for the treatment of contaminated or non-suitable waste and by keeping harmful materials out of the recycling supply chain.
Where RDF has been manufactured to a high quality we have already seen its use exploited within the cement industry within the UK, Europe and beyond as a more sustainable alternative to fossil fuel. RDF and EfW provide an opportunity to enhance energy security. Considering that in 2012 EU countries imported 106 billion m3 of natural gas from Russia (Eurostat), it is worth noting that the energy content of the waste treated by EfW plants in the EU equalled 19% of Russian gas imports that year. Given the stories that regularly appear about lights going out and shortage of generation capacity within the network, EfW provides a valuable source of consistent energy.
The RDF sector must look to identify, embrace and maximise these types of opportunities where RDF can become a more sustainable fuel source to support manufacturing and power generation.
While there may be little appetite for more prescriptive standards which would also be difficult to implement, it may be time to ensure that a joined-up approach is used to develop and implement best practice across the RDF supply chain to protect the environment, increase standards and assist in preventing rogue operators from entering the market.