EPL Position on the Actions of the Lviv City Council regarding Solid Municipal Waste Management

One and a half year has passed since Hrybovychi tragedy. What exactly has changed in the field of waste management in Lviv? After the closure of the Hrybovychi landfill Lviv waste has travelled all over Ukraine, now – all over Lviv obalst to the landfills, none of which meets the requirements of environmental safety. And at the same time, Lviv City Council (LCC) has bought a press for pressing Lviv waste for about a million euros, which is now located in Shevchenko Street, 327 and which has not yet been applied according to its purpose.

LCC studied the experience of the European countries and decided to take a closer look at the experience of the Vilnius Mechanical and Biological Recycling Plant, that is, the production of refuse derived fuels (RDF) that can be used for combustion at cement plants. As it turned out, the Vilnius plant produces RDF¹ fuel. But cement plants do not need such fuel. Accordingly, Vilnius witnessed a waste collapse and RDF was buried in the landfill. A few tens of millions of euros have been spent on separate sorting, separation of energy-valuable waste, its shredding, and the outcome was hardly environmentally-friendly – RDF fuel buried in the landfill. LCC planned to take loans from the European Banks on construction of a mechanical and biological processing plant. Thus, LCC authorized Lviv City Utility Enterprise “Lvivteploenergo” (hereinafter – LCUE “Lvivteploenergo”) to prepare design documentation for plant construction.

On March 1 2017 LCUE “Lvivteploenergo” signed an agreement with PJSC “Vantazhpromavtomatyka” (Kharkiv) to develop a feasibility study on the project “Construction of a Waste Recycling Plant for LCUE “Lvivteploenergo” with a production capacity of 240,0 thousand tons/year”. The cost of developing the feasibility study was 490 thousand UAH. According to the design specification, the construction of the waste recycling plant for LCUE “Lvivteploenergo” was planned to be completed in two phases. In accordance with the agreement the first phase of construction included: the first sorting complex, installation of composting equipment, auxiliary equipment. The second phase included: the second sorting complex, the construction of the CHP for waste incineration, two steam boilers with the capacity of 30 tons a year, a steam condensing turbine with the capacity of 12 MW, auxiliary equipment. At the same time, according to the same contract, the budget for design works estimated construction of a mechanized processing plant for solid municipal waste with productivity from 60 to 120 thousand tons a year, with an estimated indicator being 240 thousand tons a year. Consequently, the information in the design technical specification and the cost estimate for the contract is different.

On June 20 2017 LCUE “Lvivteploenergo” concluded an agreement with PJSC “Kharkiv boiler-house enterprise “Kotloenergoproekt” for the development of design documentation “Construction of a Waste Recycling Complex for LCUE “Lvivteploenergo” with productivity of 240.0 thousand tons a year”. The cost of design works is 4,949 mln UAH. In the design specification construction of the plant is envisaged in one phase, in particular, the construction of a waste sorting module of 240,0 thousand tons a year and waste composting. Although the estimate for the contract provides for the construction of a mechanized processing plant for solid municipal waste with productivity from 60 to 120 thousand tons a year, the estimated figure is 240 thousand tons a year. And again, the design technical specifications and budget contain various objects, for which design is being carried out.
In the specifications and estimates under the agreements of March 1 and June 20, 2017, there is no information on the construction of a module or RDF-fuel production plant (refuse derived fuel). According to the specification for the feasibility study, a waste recycling complex for LCUE “Lvivteploenergo” with productivity of 240,0 thousand tons a year is planned to be built in two phases, and the second phase includes the construction of a CHP plant for waste incineration, while according to the technical specification for design documentation the plan is to build a one-phase waste recycling plant without the construction of a CHP plant for waste incineration:

https://prozorro.gov.ua/tender/UA-2017-03-01-001740-a

https://prozorro.gov.ua/tender/UA-2017-06-20-000810-b

The aforementioned documents show that LCC did not come up with a decision what would be built in Lviv to resolve the problem with solid municipal waste: a mechanical plant for solid municipal waste treatment, as indicated in the estimates to the feasibility study and design? The first and the second sorting facility, composting equipment and CHP for waste incineration in two phases – as is indicated in the technical specification for the feasibility study? Or the waste sorting module which is indicated in the technical specifications for the project and design documentation? But construction of a sorting facility and a plant for the mechanical processing of solid municipal waste are two different actions regarding waste treatment which produce different products. There is also significant difference in terms of cost. For instance, the sorting line is significantly cheaper than mechanical processing. However, is unknown what LCC meant under processing. Maybe, it was a mechanical and biological recycling plant which was supposed to produce RDF fuel.

Current legislation defines waste processing as any technological operations on changing physical, chemical and biological waste properties to prepare waste for environmentally–friendly storage, transportation, recycling or disposal.

Waste sorting means mechanical separation of waste according to its physical and chemical properties, technical components, energy value, trade indicators, etc. to prepare waste for its recycling or disposal².

Below one can find information on the solutions to the solid municipal waste management problem in Lviv announced by the LCC representatives for the past months.

On 28 September 2017 at the session of the Lviv Press Club the Head of LUC ‘’Zelene Misto” (Lviv Utility Company “Green City”) announced that Lviv would build a mechanical and biological recycling plant that would produce RDF-fuel and stabilized organic fraction. Waste incineration was not mentioned at all, more details in the video: https://www.youtube.com/watch?v=81T06Ax0CN4.

On 25 October 2017 the journalists of Lviv Press Club presented for mass–media Vilnius Mechanical and Biological Recycling Plant built in 2016. After mechanical and biological processing there was no place to dispose of waste, the landfills were overloaded, there was only one incineration plant functioning and it did not accept waste. It means that even having a mechanical and biological recycling plant Vilnius had experienced a waste collapse. It was the experience of Vilnius plant that was studied by the LCC this year to implement it in Lviv. At the meeting the LCC representative stated that LCC conducts negotiations with two Ukrainian enterprises regarding their demand for RDF–fuel. In addition, the plant to be constructed in Lviv will have anaerobic composting of organic waste³. At the meeting the experts raised an issue about 90% of waste that would remain after mechanical and biological recycling, in particular, what LCC was going to do with it as technical compost would constitute only 10% of the general amount of waste. Technical compost cannot be used in agriculture as organic waste will not be separated but will go into the same container as heavy metals, medical packaging, pesticides, etc. However, at the meeting the LCC representative did not mention any specific plans for 90% of waste that would be produced at Lviv plant https://www.facebook.com/pressclublviv/videos/1696292103715850/.

On 10 November 2017 in the Lviv Press Club LCC representative spoke about two phases of plant construction. But currently only one phase will be implemented due to lack of funds. And Lviv opted for mechanicl and biological recycling plant and not the plant for producing RDF–fuel, as there is no confirmation from the Ukrainian cement plants regarding demand for such fuel. The plant will separate organic and non–organic fraction. Also it was stated that in the technical specification for feasibility study there were mistakes and these mistakes should be corrected https://www.youtube.com/watch?v=SeE6hAskrhQ&feature=youtu.be&t=3494. However, LCC still has not introduced any correction to the technical specifications for feasibility study https://prozorro.gov.ua/tender/UA-2017-03-01-001740-a.

At the same time, the letter of LCC as of 26.09.2017 states that the rationale of organizing tender on incineration plant construction will be established after the construction of the mechanical and biological recycling plant is completed⁴.

On 13 November 2017 the Lviv City Council denied potential construction of incineration plant for CHP and the very agreement on the development of feasibility study with the Kharkiv enterprise http://varta.com.ua/news/lviv/1144969, although the very technical specifications for feasibility study development is signed by the LCUE «Lvivteploenergo», which is a utility company of the Lviv City Council. Тherefore, the question is how is it possible that LCC does not know about the agreement signed by the enterprise affiliated to the LCC. Also, the technical specifications for feasibility study provided for the construction of CHP plant for waste incineration, while LCC denies the fact of such construction.

However, on 15 November 2017 the Mayor of Lviv made a statement for the journalists of «Vholos» (“Aloud”) that incineration plant to be built at CHP-2 would not affect the environment and it is the construction of the incineration plant that would be blocked by a group of people controlled by governmental officials from Kyiv: http://vgolos.com.ua/news/sadovyy_zayavyv_shcho_na_bankoviy_blokuvatymut_budivnytstvo_smittiespalyuvalnogo_zavodu_v_lvovi_290583.html.

What do the authorities plan to build in Lviv? At the beginning there was a variant of a mechanical and biological recycling plant to produce RDF–fuel, later — a mechanical and biological recycling plant without production of RDF–fuel, CHP to incinerate waste, incineration plant at CHP-2. Though the scheme of heat supply in the LCC plans envisaged incineration of solid waste at the CHP-2 as far back as 2008⁵. It is the indecisiveness and inconsistency of LCC that undermines public trust in the actions of local authorities.

At the meeting of the Lviv Press Club on the 10^th of November the Polish experts recommended LCC at first to build a polygon for municipal waste and organize a complex system of waste management in Lviv https://www.youtube.com/watch?v=SeE6hAskrhQ&feature=youtu.be&t=3494. However, the aforementioned LCC agreements and technical specifications do not envisage the construction of a landfill for municipal waste.

Regarding funding that is planned by LCC to resolve the issue of solid municipal waste⁶:

• The loan of the European Bank for reconstruction and Development (EBRD):

25 mln EUR – is planned for the initial actions on remediation of Hrybovychi landfill, the first phase of construction of the mechanical and biological stabilization complex and general construction works.

• The loan from the European Investment Bank (EIB):

30 mln EUR – for remediation of Hrybovychi landfill;

45 mln EUR – for construction of waste processing facility and new landfill of solid municipal waste.

• Е5Р Fund (non-repayable financial aid):

10 mln EUR – for remediation of Hrybovychi landfill.

Thus, remediation of Hrybovychi landfill envisages 40 mln EUR (EIB, Е5Р) plus certain amount of money from the sum of 25 mln EUR from EBRD. All in all, funding from three aforementioned sources amounts to 110 mln EUR and from them 100 mln EUR is a loan that Lviv will have to return together with the interests on the loan.

In case LCC does not plan to produce RDF-fuel, what is the point of building a mechanical and biological processing plant which is supposed to produce RDF-fuel and stabilize waste organic fraction. If the idea is to spend twice more, then the loan to be paid off to the European banks by the residents of Lviv, is not a good economic idea.

As for RDF-fuel, such fuel can be incinerated at the cement plants under high temperature. The experience of Polish enterprises shows that cement plants set certain requirements to the components of RDF-fuel, which should not contain waste consisting of polyvinyl chloride. Polyvinyl chloride is one of the components of linoleum, plastic materials. Incineration of waste produced on the basis of polyvinyl chloride results in deterioration of cement plants technological equipment, clinker sticking. Another minus of RDF-fuel is the fact that in winter the operations of cement plants stop for about two months due to the absence of demand for cement and, consequently, there is a problem with RDF-storage⁷.

Requirements to RDF-fuel and its incineration are given in the European Commission Report as of 2003. A mandatory requirement for incineration of such fuel is high temperature that can be ensured at cement plants and which is necessary to split complex organic compounds, in particular, dioxins. This report indicates that these are the mechanical and biological processing plant that produce RDF-fuel, while separated organic waste is composted and undergoes anaerobic fermentation⁸.

It should be indicated that on 26 January 2017 the European Commission adopted a Recommendation «The Role of Installations «Waste–To–Energy» in a Circular Economy» which recommends to review waste incineration operations for the benefit of reuse and waste recycling. The document recommends sorting biodegradable waste and gives preference to anaerobic fermentation of such waste to increase biogas generation and its cogeneration, as well as fertilizers production. At the same time, the document stresses that by signing Paris Agreement the EU countries have taken obligations on decarbonizing their economies, that is why in future there is a risk of potential closing down waste incineration plants⁹. Ukraine was one of the first countries to ratify Paris agreement. 279 People’s Deputies of Ukraine voted for its ratification.

In the same way as before the European Commission endeavors to streamline EU funding and other activities of state financial support into actions of waste treatment according to waste hierarchy (waste management being of top priority). In particular, the European Commission primarily gives priority to waste prevention, preparation for reuse, recycling, utilization (for instance, energy recovery) and disposal of waste is the least preferable option. Moreover, on 8 November 2017 Ukraine adopted the National Strategy of Waste Management that ensures European methods to waste management and selected solution to the waste problem¹⁰.

Unfortunately, due to the LCC «consistency» and diversity of documents and statements described above, we do not know which option was chosen by LCC to resolve municipal waste problem in Lviv. Our organizations, residents of Lviv and neighboring villages are concerned about such a situation in Lviv. We all want to live here, breathe clean air, drink clean water and grow agricultural products on clean soils.

To Resolve the Problem of municipal waste in Lviv we over and over again suggest that LCC should:

1. Build a municipal waste landfill according to the construction and environmental norms.

2. Carry out remediation of Hrybovychi Landfill.

3. Build a municipal waste sorting line and fermentation station (anaerobic fermentation) for organic waste.

4. Organize separate collection of dry and organic waste fraction.

5. Install containers for organic waste fraction collection.

6. Establish in the city stations for collecting medical, construction waste, second–hand furniture, consumer electronics, clothes and other waste.

7. Organize logistics of waste collection, sorting and waste transfer for recycling.

8. Bury at the landfill the waste which cannot undergo reuse, recycling and anaerobic fermentation.

At the same time we require LCC to be open, transparent, to provide credible and full information at all the stages of resolving the municipal waste problem and to ensure public participation in the decision-making process.