Sunday, 13 November 2016

Dont put it in the recovery position !

It was a simple innocent question that I put to Resource Recovery Solutions at a meeting of the Sinfin waste incineration plants Community Liaison Group (CLG) meeting back in early 2016.
We were part way though a presentation by a representative of RRS / SHANKS in relation to what they teach school children they visit at schools across Derby and Derbyshire or tours the construction site with and I was feeling somewhat uneasy that the councils were paying a company that was being employed to burn vast volumes of waste to then also educate school children what we should do with waste.
So at that point I thought hey ho lets just pop a question across to the the RRS / SHANKS  just to satisfy myself that they were in fact educating school children correctly and that I was being unfair to judge them. It was at this point that a representative of RRS / SHANKS (named in the meetings official minutes) told the meeting that they told children it was a recovery plant.
WOW THERE ! WOW THERE ! now hold on just a minute ! did they say it was a RECOVERY PLANT ? really ! a RECOVERY PLANT ?
Now burning waste is a funny old game because doing so can be considered to be one of two things when it comes to considering the process in the waste hierarchy it is considered a disposal process unless it can prove otherwise in which case it is a recovery process.

 The waste hierarchy just for clarity is a set of processes when dealing with the whole issue of waste that must be considered as it takes in best practices to deal with waste in the most sustainable way.
It starts with REDUCTION / PREVENTION where the aim is to reduce what waste we produce so managing materials in the best way - by not using them to start with ! Then we have RE-USE which is where whenever possible we take items that are now scrap and attempt to use them again in an innovative way to keep them out of landfill and incineration. Then comes RECYCLE which is when materials at the end of their life if not reused are reprocessed into new items by making use of the products raw material make up. As we head down the hierarchy we get closer to less sustainable methods of waste management such as incineration and landfill - neither of which are good methods of waste disposal. This brings us to RECOVERY which is when those handling waste start to use wastes for energy generation such as in incineration plants which meet an efficiency target called R1. These are plants which can show that their efficiency of energy generation meets a strict target and often requires such plants to export large volumes of heat or steam to customers to meet that efficiency rating. Finally we come to DISPOSAL which includes inefficient energy generation in incineration plants and also landfill.
In a twist to things a plant that meets R1 efficiency targets is STILL a disposal plant until it is granted recovery status.
Now rather conveniently for the UK government they use a waste hierarchy image as shown below which I consider to be incorrect as it blurs the lines between recovery and disposal in the waste hierarchy by using questionable wording.
The image shown below is the image in question and is used by DEFRA in their document
Energy from Waste a Guide to the Debate dated Feb 2014
Now reviewing the image it would be very easy to be misled into thinking that any incineration plant - including gasification is recovery in the waste hierarchy if it generates energy. The image appears to imply this is the case and as this image is commonly reproduced a gross misunderstanding takes place!
It is only when you take the chance to read other areas of the document that the issue of R1 and its application are considered and at that point you realise the difference between recovery and disposal. Obviously there are some who favour this blurring as it allows them to paint a picture of a project that makes it conveniently sound better than it is.
To aid you readers below is produced a series of statements from DEFRA from the document in relation to R1 and what is known as D10 disposal.
Recovery or disposal – the meaning of R1

47. As described above the Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula


So returning to what the RRS / SHANKS representative said they teach students the plant is. they stated they teach students that the plant is a RECOVERY plant - which raises the issue of R1 as noted above.
When we consider R1 and the claims of the RRS / SHANKS representative we know what they are teaching children is false because at the 2nd planning inquiry the developer had to admit that their plant fails the R1 test in its standard mode.
If you tell children something that is false then in general it is usually considered a lie.
It is a lie in this case because staff employed in waste disposal and waste management will know the requirements of the waste hierarchy



1 comment:

  1. Most important line: "All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1."