The burning of imported waste in Bulgaria will continue full steam. This is the conclusion with which we concluded the first part of the investigation “Destination Waste”. It happened nearly 5 years ago. Our prediction came true.
The record year for the import of waste for incineration in Bulgaria is 2021, when nearly 1 million tonnes of garbage will be imported, of which 141 883 tonnes is so-called RDF or “combustible waste”. Half of it enters through Varna West port and goes to Devnya Cement for recovery. Compared to 2015, when the Public Centre for Environment and Sustainable Development started monitoring the process, this amount has increased 10 times. From the reports we have obtained under the Access to Public Information Act, it is clear that almost all of the imported “combustible” garbage enters through the Varna West port and comes mainly from Italy and, until two years ago, from England.
Last year a total of 12 ships with 71796 tonnes of RDF docked at the port. For 2022, 14 vessels carried 70 990 t. The figure represents a total of 90% of the amount of incineration waste imported into Bulgaria (based on comparable data presented during a parliamentary scrutiny this year).
Who supplies us with combustible waste?
One importer, Italy’s Refuel SRL, produces secondary solid fuel (SRF) by processing residual waste from the recycling industry. According to the plant’s technology, described on their website, it transforms waste from the separate collection of packaging – mainly paper and mixed non-recyclable plastics – into green energy that can be used by cement factories and power plants in Italy and abroad.
The other supplier, Italy’s SMOCO Srl, presents itself as an environmental consultancy that is able to supply alternative fuels to cement plants instead of traditional fossil fuels.
In fact, it is the PR campaign, which is also promoted by European legislation, that is linked to presenting waste incineration as a better alternative to coal. In this way, we are saving ourselves a huge problem caused by overconsumption, namely the generation of more and more waste, including non-recyclable waste, and its expensive disposal.
The so-called recycling of waste in cement plants is presented as an ‘after-use with the strategic aim of replacing the use of coal and therefore promoting CO2 reduction in production processes’.
With a slightly different portfolio in the list of suppliers is the Italian Metal Ferro SRL, which is supplying RDF in the country in 2022 and 2023. It is represented by 30 years of experience in industrial demolition, disposal of special hazardous and non-hazardous waste, and marketing of metallic and non-metallic scrap.
22 of the 28 deliveries in 2021 and 2022 of Varna West were made by the British PROBIO Energy International. It is touted to “maximise recycling and recovery rates by providing many types of alternative fuels that would otherwise go to landfill”. The products it produces and offers include – refuse derived fuel (RDF) and solid recoverable fuel (SRF).
What is RDF?
According to PROBIO Energy International’s website, it is a “low-energy product composed primarily of municipal waste”.
It is produced “by shredding and dehydrating solid waste. It consists mainly of combustible components of municipal waste such as plastics and biodegradable ones. “RDF is used in combined heat and power plants around the world, producing hot water and electricity,” the company added.
The only supplier other than PROBIO in 2021 is our well-known Italian Deco. Already in our first in-depth study of waste imports in 2019, we found that the suppliers are large multinationals operating in multiple markets. Deco S.p.A., for example, is part of a well-known company in Italy and abroad for building tanks and systems for the wine, food and chemical industries. However, the company is also the founder of the Italian-Tunisian Ecoti, which manages the landfills of Tunisia (North Africa).
Who are the recipients in our country?
In 2021 and 2022, it is the Sofia-based company Ludon Trans Ltd. Its sole owner, Nelly Mladjova, is the daughter of Nikolay Mladjov, the owner of Zet & Em Prawit Co, a representative of TysonCorp and Hitachi, supplying equipment to the largest mining companies in the country and in Central Asian markets. Majov was the winner of CRIB’s 2018 Grand Prize, presented personally by then Prime Minister Boyko Borissov.
In just three years from 2019, the turnover of Ludon Trans is about 69 million levs and jumps five times compared to the previous three. The company only carries out the transportation of RFD in the country by sea, arranging the accompanying documents.
As of the end of 2022 and throughout 2023, the recipient of the RFD bales is now Devnya Cement (Heidelberg Bulgaria) and Josaicle Bulgaria, which is owned by the cement plant in Beli Izvor, Vratsa region – Holsim Bulgaria. According to the website of “Josaicle Bulgaria”, almost 100,000 tonnes of waste were collected and pre-processed by the company in 2017 – mainly SRF. More than 90,000 tonnes of waste were in turn co-processed in the plant’s cement kiln then.
According to the reference of the Regional Inspectorate of Environmental Protection – Vratsa, obtained under the Access to Public Information Act, for the period 2021 – 2023, waste from Ludon Trans, originating in England, and Giosicle Bulgaria, imported from Italy, was imported to Holsim Bulgaria. The total amount of waste is based on the decisions issued by the Ministry of Environment and Water for granting consents to notifications for transboundary shipments of waste, in accordance with the requirements of Regulation (EC) No 1013/2006.
What is happening with so-called RDF in our country?
The RDF imported through the Varna West port goes for recovery to Devnya Cement (Heidelberg Matiriles Devnya) and to the Holsim Bulgaria cement plant in Beli Izvor. For the last three years, the Devnya plant has taken in about 210 000 tonnes of so-called alternative fuel, according to reports of the Regional Inspectorate for Environment and Water in Varna, while the Vratsa cement plant – 7 times less. Both enterprises are active in the production of cement and cement
clinker. In connection with compliance with and implementation of environmental legislation on environmental components and factors by the Executive Environmental Agency for the activities of the companies have been issued complex permits, updated last year.
In 2021-2022, a total of four companies on the territory of the Municipality have permits for waste treatment with code 19 12 10 – Metarex Ltd, Ecoseif Ltd, Pencomers Ltd and Devnya Cement JSC. Last year only Devnya Cement had such a permit, according to the information provided by the Regional Inspectorate for Environmental Protection – Varna.
In the complex permit of “Devnya Cement” a daily capacity for kiln line No. 7 of 6280 t of cement clinker, 868 t of hazardous waste and 550 t of slag and ash was determined. There is a permit for equipment for shredding of production and pre-treated waste fractions permitted for recovery in kiln 7, as well as for commissioning of kiln line 8 with a 24-h capacity of 7792 t of cement clinker, 868 t of hazardous waste and 550 t of slag and ash.
Carbon neutral cement
“The cement industry is one of the largest polluters and generators of carbon emissions. We are aware that we need to take action. The process started more than 20 years ago. The first step on the road to decarbonisation is the replacement of so-called fossil fuels – gas, petcoke, coal – with alternative fuels,” says Konstantin Bozhinov, ANRAV project manager and alternative fuels manager at Heidelberg Matirials Devnya AD (Devnya Cement). He does not speak directly about the use of garbage, but about “waste which, after primary separation, separation of all the valuable fraction and subsequent treatment, is converted into RDF alternative fuel. This, according to Bozhinov, is one way to reduce landfilling. Recycling should always be a priority, he says, but unfortunately no more than 7-8 to 10% of household waste becomes recyclable.
Cement factories do not recycle waste, Konstantin Bozhinov specifies. In his words, the cement kiln has been proven globally as the only zero-waste technology when it comes to end-of-waste, not targeted incineration of garbage.
“The so-called residual ash, the mineral content of any type of waste, has it in incinerators. At a temperature of more than 1,500 degrees in a cement kiln, the metal lattice breaks down and all the minerals contained in the waste go into the contents of our clinker,” explained the manager at Heidelberg Matirials Devnya. In other words, the ash goes directly into the production process and is not landfilled.
The plant management explained that they carry out an “extremely detailed inspection of the waste” before putting it into the kiln. “The Ministry of Environment and Water has 24-hour access to our control room and sees what we mix and what we feed to the furnace,” Konstantin Bozhinov said. The controls were put in place after the big scandal a few years ago over the import of unregulated plastics and waste from Italy. “We wanted to differentiate ourselves because we don’t import such waste. Our RDF is not waste, we bring in fuel,” Bozhinov said.
And Varna’s garbage goes into a cement kiln
According to the company’s management, the priority is to work with local waste. Currently, Devnya Cement uses 100% of the available alternative fuel produced from waste from the Varna region. It is close to 50 000 tons/year according to the company.
However, the Municipality of Varna does not have a contract with the cement plant. Instead, they use the intermediary of Ecoinvest Assets, where the waste is delivered for pre-treatment at the plant in the village of Ezerovo. According to the response received from the Directorate for Ecology and Environmental Protection under the Access to Public Information Act, Varna Municipality handed over 114 662 tonnes of waste to Ecoinvest Assets last year. For this, the company received 14.844 million BGN, i.e. nearly 130 BGN per tonne. The price of garbage has jumped by 50% in just two years. More than 40% of the amount handed over to Eco Invest for processing has subsequently gone for recycling at the Devnya cement plant.
For the period 2021 – 2023, residents of Varna have paid EcoInvest Assets BGN 35.286 million for processing their waste. In the same time, just over 70,000 tonnes of garbage have gone to the landfill in the village of Vahlen. For this purpose, BGN 2.022 million came out of the municipal budget.
According to the report of the municipal eco-directorate, it turns out that waste treatment costs us 4 times more than the more harmful process – landfilling. For the last year, Varna has been paying BGN 35 per tonne of waste to the Aksakov landfill, and about 15% of the total municipal garbage generated in the sea capital goes there.
Landfill or incineration?
“Usually, when a waste cannot be recycled, it has two routes – landfill or incineration. Neither of these options is good. Both are equally harmful. The good option is to generate as little waste as possible, and waste that has its way in the circular economy, either through recycling or other forms of use,” said Ilian Iliev from the Public Centre for Environment and Sustainable Development. According to him, no matter the type of plastic or other product, if it is incinerated at the end of its life cycle, the environmental consequences will be the same in the end.
“Incineration is one form of recycling, which is the name given to the whole process of treating a product to change its characteristic and make it harmless. Utilization can be by incineration, by plasma, to be treated by steam. Different types of recycling lead to different transformation of the product,” the ecologist said.
Iliev has been following the waste import process in Bulgaria for nearly 10 years. “In 2015, importers had nothing to worry about. They unloaded the waste at Odessos port, loaded it into wagons without hiding. Now this process has been moved as far away as possible – to the port of Varna West, the cargo in the wagons is turned, not to be seen and not to annoy people,” says the ecologist. According to him, almost nothing has changed in terms of legislation. Rather, the “chewing gum” for political use has changed.
“Every time there is an election this is a topic that is raised and commented on,” says Devnya Mayor Svilen Shitov. Apart from RDF waste recycling, there is also an incinerator on the territory of the municipality, and for more than 2 years it has taken actions to increase its capacity, i.e. install a new incinerator. In this regard, there have been repeated complaints and grievances from residents living in the vicinity, according to the mayor. According to him, the issue of pollution is sensitive and so it should be. Requests have been made by the municipality to the Ministry of Environment for the installation of a second monitoring station near the industrial complex. We have been repeatedly refused on the grounds that given our territory there is no need for a second measuring station, Shitov says.
Between 5 and 7 million tonnes of RDF are transferred annually in Europe. In order to ensure that it does not go only to developing countries, there are various restrictions, such as a ban on exporting hazardous waste from Organisation for Economic Co-operation and Development countries to those outside the rich club, a ban on exports for landfill, etc.
The country’s Waste Management Act imposes a limit on the import of waste destined for incineration to quantities not exceeding half of the annual capacity of installations.
Under the Waste Directive and the Waste Shipment Regulation, the government can restrict and suspend imports for landfill, including incineration, on the basis of a notification. However, this requires not only a clear and enforceable waste management strategy, but a host of other concrete and simple measures, such as a deposit system in place to encourage citizens to recycle.
Are the figures correct
In trying to get to the actual combustible waste imported and recovered in the country, we used several sources – the registered imports from the Ministry of Ecology and the regional inspectorates in Varna and Vratsa respectively, a response to a parliamentary question to the Minister of Environment in the previous National Assembly, and a conversation with some of the management of Devnya Cement. We have also collated our observations of the ships that deliver the waste. In some cases, their tonnage differs, but it is quite possible that they are carrying other types of waste than RDF. We had to cross-check the data with Customs. However, from their reply it was clear that there was no correspondence between the codes that are under the waste classification and the codes under which the import is made, i.e. under the customs classification. This means that without knowing the exact customs code, we cannot draw a conclusion about the import of waste. There is a possibility that they have been imported under a completely different code which has no relation to the waste codes. It could be classified as a product, a commodity, including fuel, said lawyer Alexander Asenov. However, as far as the application of the procedures under Regulation No. 1013/2006 is concerned, there the notification and documentary security procedures are followed (at least formally). Therefore, the data from the Ministry of Environment and its structures – the Regional Inspectorate for Environmental Protection – must correctly reflect the quantities and movements of waste, even more so for non-EU countries such as the UK. However, they do not include imports of SRF – waste, some of which also goes to the cement industry for recovery.
The equation is becoming more and more uncertain, but the result is clear – combustible waste continues to be imported into Bulgaria, and citizens are left in doubt about the quality of controls on pollutants. Because of the dynamics of the process, we are starting to work on “Destination Waste 3″. And there the numbers will no longer be what they are…
