Is it time to come clean on SRF?
Should solid recovered fuel be reclassified as a product or a fuel? Marcus Brew considers the arguments for and against
Solid recovered fuel (SRF) is still classified as a waste material, not a product, despite the fact it is manufactured to a quality specification and is a resource from which energy can be recovered. It has been widely reported that SRF has the potential to satisfy approximately 5% of the country's energy requirement.
When considering this, plus impending landfill targets, the increasing depletion of fossil fuels and the need to improve the UK's waste agenda, everything seems to point towards SRF being an area of great potential. If this is the case, why don't we better embrace this sustainable resource? When used in replacement of traditional fuels, SRF is carbon neutral, so what is holding us back?
In truth this is a multifaceted subject from which extensive debate stems. Industry leaders have talked at great length about the challenges we face and the opportunities that we are ignoring, and still the discussions continue.
Education and awareness is a clear issue. Confusion still exists within the waste-to-energy industry as to the difference between SRF and refuse derived fuel (RDF), but the two are not the same. SRF is manufactured to a specification, whereas RDF is comparatively cruder.
The specification is likely to vary depending on end-user requirements, but typically SRF facilities will rigorously process pre-sorted commercial and industrial waste to a homogenous shredded particle size of less than 30mm, with a moisture content < 15% and calorific value of 18-22MJ/kg.
The European Committee for Standardisation has set out classes of SRF specification under document CEN/TS 15359. Drawn up with the assistance of waste experts and SRF users such as cement kiln operators, this document is designed to provide an efficient method for trading SRF. But this alone is not enough.
Currently there is no regulatory body to monitor and control marketplace quality for SRF so whilst SRF sounds like the perfect refined fuel, it is still considered a modified waste. Consequently every company that handles SRF needs a waste transfer license in order to comply with the Waste Incineration Directive, and as a result they can charge SRF suppliers relatively high gate fees.
These are effectively handling charges which are passed on to the SRF producers due to the lack of classification and material uncertainty. This is not to say some producers do not manufacture SRF to an incredibly high quality, but unfortunately the risk of inconsistency for energy firms is currently too great.
It seems unbelievable that waste-to-energy plants do not have a regulatory body that closely controls and monitors their feedstock, when their operations are so stringently scrutinised. This is the difference between SRF being considered a waste which brings with it added complexities, or a commodity such as cardboard which can be traded in wire-tied, mill-size bales of over 400kg, and can be bought anywhere because customers have confidence that the product will meet the defined criteria.
SRF producers need to invest in sophisticated technologies in order to manufacture a higher quality fuel to a consistent specification. But whilst costly gate fees are imposed, this investment is just not commercially viable for many organisations. It is very much a 'chicken and egg' scenario.
SRF also has to compete with other waste-derived fuels such as biomass; a great example of a mature, self-regulated market with clear-cut material classes. This is perhaps because wood, in comparison to SRF, is a much simpler material.
So could we reach the point where SRF is classified as a product? Yes, possibly, but only with significant investment. The Government is not unresponsive to the notion of a change, but there are currently no plans for progress to be made here. It certainly will not be possible until a detailed, well-tested specification is agreed and consistently reached.
Perhaps the industry should therefore turn its attention to working with the Environment Agency to develop a licensing body or accreditation scheme for high quality, responsible SRF producers. These producers could then be assessed and endorsed with a standard of excellence akin to an ISO certification, according to the procedures and quality control mechanisms that they have in place to manufacture a consistently clean product.
This may ultimately remove the need for a waste transfer license. Although some may be concerned that this could impact negatively upon industry standards, if carefully introduced and well regulated it should have the opposite effect. This approach could help to heighten the level of trust amongst reputable organisations, drive standards within our lucrative industry and encourage the free movement of SRF between quality-registered companies.
If the demand for SRF increases then the number of manufacturers will also rise, marketplace competitiveness will be greater and quality considerations will become even more paramount. This would hopefully drive down the gate fee, opening the market up even further and making this fuel an affordable, beneficial and readily available energy source for the UK.
Industry leaders in the sector are already apparent but as the market grows more SRF and waste-to-energy pioneers will emerge. The Government should make better use of this specialist knowledge and form a carefully-assembled steering committee to work with the industry on a long-term, centralised and party-neutral SRF strategy.
This may go some way to addressing public resistance to alternative fuel production, which is in a large part due to being ill-informed. We need to increase community confidence so that SRF can become a valuable and clean resource.
Marcus Brew is alternative fuels expert at UNTHA UK