Information on procedures of pre consent and approval for Refuse Derived Fuel
(RDF) international transboundary movement for Non OECD member states, but accessible for member states of the Basel Convention.
Refuse derived fuel (RDF) is produced by the mechanical processing of solid waste. For use in a kiln, a typical processing scheme for production of RDF might include shredding, screening, and air classification of the wastes. The fuel properties of RDF vary somewhat among plants and processing schemes but in comparison with typical coal properties, refuse derived fuels are generally lower in calorific value and sulphur content but higher in chlorine content. The low sulphur content of RDF is a desirable feature because sulphur dioxide emissions from kilns are subject to air pollution regulations and the use of a low sulphur fuel facilitates meeting these regulations. Also, sulphur is considered a contaminant of some products made in kilns (e.g., lime) and kiln operators prefer to minimize the addition of sulphur to their kilns. In addition to the chemical composition of the RDF itself, the chemical composition of the ash resulting from combustion of RDF is also important. RDF and coal ash are similar in silica (Si02) and alumina (Ah03) content. RDF ash is generally lower in sulphur (S03) and iron oxide (Fe203) but higher in the alkaline oxides (Na20, K20) than coal ash. Refuse Derived Fuel (combustible fuel waste) is classified as non-hazardous waste, not to be confused with municipal solid waste (MSW). The correct codes must be allocated for the correct export. According to the European Waste List (EWL), Refuse Derived fuel is listed as 19 12 10 (Fuel like combustible Waste). For international waste shipments outside the EU, RDF would require HS Code 3825100000 – Municipal Waste. These codes are and will be used as codes for the RDF export.
The ideal use of RDF is in the form of “Recovery”. Recovery by means of generating heat and /or energy by incineration. R1 recovery plants are best suited for the use of RDF. The users of RDF most suited are cement producing facilities, who can use RDF as a cost effective alternate to fossil fuels. Where coal would be used to generate heat in the manufacturing process, RDF can be used by co firing or as a replacement and achieve the same results. Facilities using fossil fuels for heat generation can use RDF as base fuel, as fuel mixture with fossil fuel or as a fossil fuel replacement. The RDF having low moisture and sulphur contents can be an attractive incentive to users. RDF can also be used by facilities using fossil fuel for generating electricity. By using RDF as a secondary fuel with coal and / or gas in power generation, the user can achieve the same results required but being more cost effective.
It is deemed as non-dangerous combustible waste, subject to export license specifically addressed to destination plant and inclusive of destination Country's authority’s approval (procedure known as "prior written notification and consent"). Destination Country must be signatory of Basel Convention on wastes. Please provide the following documents for pre-approval and qualification:•
End User Pre Approval LOI; this letter must be accompanied by: • Documentation and technical reports on the facility and its operation. • Plans of the facility, operating procedures, description of the material flows, fume extractions etc. • photographic documentation•
Local Country's Competent Authority (EPA, Ministry of Environment); Consent Addressed to Importer / End User. This document must also be accompanied by: • a copy of the operating licence; and • Written confirmation from the competent authority in the importing state stating that the applicable environmental regulations.•
Local Country’s Competent Authority (EPA, Environment Agency) Consent Addressed to Exporter
After documents have been received, due diligence will be carried out on the information provided. This process can take up to 3 weeks. If the buyer qualifies a contract will be forwarded to the buyers. The contract once approved and terms accepted, signed contracts will be exchanged. The contracts will be presented to the Environment Agencies involved and the buyer will put up the financial guarantee or equivalent insurance. The Exporters will put up the Notification and Movement of Waste Document with the UK Environment Agency. The Notification document process can take up to 16 weeks. Once Notification is received, the buyers will activate the financial guarantee. Loading is carried out and shipping commences. The buyer will arrange all off loading, transport at the destination port. The buyer will confirm the complete recovery of the RDF with a Certificate of Recovery in the allotted time. When contract is completed the financial guarantee is returned to the named issuer by the Environment Agency UK. Once the completed documents (Appendix A, B, C and D) are received, we will confirm receipt via written acknowledgment, this will initiate the process of RDF sale and purchase.
The buyer and/or the end plant is required, and must financially guarantee (by a financial guarantee or equivalent insurance) the recovery of delivered waste or its sound return to origin Country, if the end user fails to recover the notified waste. Guarantee's amount will be computed based on quantity to be delivered every month and shall stay in place for the entire contract's duration. The established financial guarantee or equivalent insurance for The Environment Agency (UK) (International Waste Shipment) in accordance with Articles 6 of the Ordinance (EC) No. 1013/2006. This is to provide the competent authorities with guaranteed money to take action if things go wrong with a notified shipment, including: • Arranging and paying for recovery or disposal of the Refuse Derived Fuel at the importing country. • Arranging for the return of the waste to the country of origin. The arranging for the storage, recovery or disposal of the Refuse Derived Fuel. Any financial guarantee or equivalent insurance policy set up in relation to an export from England or Wales must be in English and subject to and in accordance with English law. The financial guarantee or equivalent insurance will be valid for 1 year and will be cover for value of 2 (two) active shipments revolving. E.g. monthly order for 2,500 tonnes a financial guarantee covering 2 monthly shipments i.e. 5,000 tonnes @ GB£ 100 / tonne = GB£ 500,000.00 financial guarantee / equivalent insurances valid for 1 year. On successful completion of the delivery and recovery of the Refuse Derived Fuel the Financial Guarantee or equivalent insurance will role on to cover the next shipment. On expiration of the contract the Financial Guarantee is released to issuer(s) by the Environment Agency UK.