International Review of Waste Management Policy - Department of ...

tonnes early in 2010, and as much as 280,000 tonnes per annum later in the year.
The SRF would be displacing coal at Lagan cement and Quinn Cement, and petcoke
at the Irish Cement facilities. Studies suggest that this will make the overall
environmental effect
Given the fuel specification is of the order 16MJ/kg and above, with defined limits on
ash content, chlorine, moisture and heavy metals, mixed residual MSW is likely to
require pre-treatment so that the 280,000 tonnes capacity is likely to be derived from
a larger quantity of residual MSW. The exact quantity depends upon the waste
stream, but the quantity might be expected to be no less than 300,000 tonnes, and
as much as 600,000 tonnes.
The degree to which cement kilns might deal with biodegradable material might
appear, at first glance, to have been compromised by the EPA’s specification of pertreatment
in that this tends to suggest that SRF should be derived principally from
non-biodegradable waste streams. The Guidance document appears to push MBT
suppliers towards a ‘splitting approach’ since landfill site operators would, in
principle, not be allowed to accept waste at landfills without it having been dealt with
in such a way. 861 However, we are informed by the EPA that this arises from a too
literal interpretation of the document, and that in principle, the approach to
generating SRF is not constrained.
51.3.3 Mechanical Biological Treatment
Regarding mechanical biological treatment (MBT) facilities, this is rightly described in
a STRIVE report as being in its infancy in Ireland. 862 The report states that at least two
facilities export a refuse-derived fuel (RDF) for thermal treatment abroad. There are
also some facilities which have potential to be deployed as MBT facilities, some of
these described in a 2008 report. 863 These may be capable of delivering reductions in
the biodegradability of waste which they handle, so contributing to meeting targets in
due course.
It remains to be seen how the EPA’s Guidance on Pre-treatment and Residuals
Management will affect the development of MBT in Ireland. Discussions with EPA
officials suggest that the Guidance Document is not a full reflection of the way in
which the Pre-treatment requirement will be implemented. 864
861 EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Johnstown Castle Estate: EPA.
862 Fehily Timoney & Company / Veolia Environmental Services / Ramboll (2008) Critical Analysis of
the Potential for Mechanical Biological Treatment for Irish Waste Management: Volume 2, Report for
the Environmental Protection Agency, September 2008.
863 Eunomia with Tobin (2008) Meeting Ireland’s Waste Targets: The Role of MBT, Final Report to
Greenstar.
864 If one takes the Guidance at face value, then it would difficult to understand why the EPA made the
decisions which it appeared to have made. In addition, the Guidance document does not give sufficient
detail concerning how the Guidance is to be operationalised, and there are several decisions made
where the justification is through appeal to the need to demonstrate BAT, though this is not clearly
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International Review of Waste Policy: Annexes