Some Freedom for Shredded Tyres in Landfill Engineering
Defra has allowed some shredded tyres to be used for “certain landfill engineering purposes” after the landfilling of tyres is officially banned in July. The news follows research conducted by the National Industrial Symbiosis Programme (NISP).
Initial interpretation of the Landfill Directive declared that from July this year only whole tyres would be permitted for this purpose and the use of shredded tyres was therefore precluded. However, according to the NISP this move would have had serious environmental consequences; because NISP had already identified replacement aggregate as a re-use option for up to a quarter of this year’s UK tyre waste.
After NISP was approached by a number of number of member companies (BIFFA, Cory Environmental and Credential Environmental) to alert Defra to the consequences of implementing such a ban, the programme prepared a detailed analysis of current engineering practices using shredded tyre products. The report concluded that a used tyre derived aggregate replacement (UTDAR) product provided a more sustainable alternative to virgin aggregates as a leachate drainage blanket in landfill. The report also highlighted the fact that in addition to the environmental consequences, the ban actually went against some of the fundamental aims of the European Commission (EC) Landfill Directive.
Peter Laybourn, NISP Director, commented: “In 2004, 17 per cent of the UK’s waste tyres were re-used in landfill engineering applications. This figure has increased to 25 per cent this year, with the further potential for growth year-on-year. Strict implementation of the regulations would have removed this major disposal avenue.”
As a result of NISP’s intervention, Defra, with support from the DTI and the Environment Agency, wrote to the EC to seek guidance. The EC response was in essence that the Landfill Directive is concerned with the disposal of waste and not the recovery of waste. It followed that recovery activities fell outside the ambit of the Landfill Directive disposal ban. On the basis that shredded tyres used in properly engineered landfill leachate drainage layers, as a replacement for other material, is a recovery activity, it should not therefore, fall within the disposal ban.
Richard Edy, National Tyre Distributors Association, adds: “Tyre retailers were very concerned about the impact of the ban and its potential to create significant environmental problems with industry currently experiencing a real shortage of treatment capacity.”
The figures quoted in NISP’s report were taken from the results of a pilot study that used UTDAR in place of virgin aggregates as a leachate drainage blanket in landfill. The product was developed by Credential Environmental, in conjunction with a local university knowledge base and several other NISP members, including BIFFA, and was carried out at BIFFA’s Roxby Landfill in Scunthorpe.
Nick Wyatt, managing director of Credential Environmental, says: “Using UTDAR at Roxby has made operator cost savings of more than £34,000 and offset 6,480 equivalent tonnes of virgin aggregate material that would have been used in its place to line the 6000 square-metre site. This is a great example of commercial development of an environmental synergy backed up with solid research and support from the Environment Agency.”
“Now the technology has been proven, and the economic and environmental benefits established, UTDAR is being used at landfill sites throughout the UK, with ourselves and NISP working hard with industry partners and Government to maximise its potential.”
Defra’s John Galvin observed: “It has always been the case that recovery operations fall outside the scope of the Landfill Directive and it remains the case that the directive bans the acceptance of shredded used tyres at landfill.
“We are, however, committed to encouraging the recovery of waste materials in an environmentally acceptable way. The clarification that we have received from the commission serves to demonstrate that when certain conditions are met, the use of shredded used tyres as landfill engineering material may amount to a recovery operation that replaces the use of aggregates.
“This clarification does not amount to a reversal of the legal position and whether the use of shredded used tyres at a particular landfill site amounts to a genuine recovery operation remains to be assessed on a case-by-case basis. It would now be beneficial to agree guidelines for the use of shredded tyres leachate drainage engineering, against which recovery may be assessed on a case-by-case basis.”