revised best available techniques (bat) reference document ... · 27.02.2019 · streams of plants...

WI BREF review – IED Art.13 Forum Meeting

Brussels, 27 February 2019European IPPC Bureau

Revised Best Available Techniques (BAT)

Reference Document for Waste Incineration

(WI BREF)

Final Draft for the opinion of the IED Article 13 forum



Outline of the presentation

Scope of the WI BREF

Summary of the WI BREF review process

Structure of the revised WI BREF

Main changes in the revised WI BREF

Key features of the BAT conclusions

Comments received from IED Article 13 forum

members on the Final Draft of the revised WI BREF

Issue proposed for discussion

Issues for clarification

2




The BREF covers:

Activity 5.2 of Annex I to the IED: subject to the

capacity thresholds set in Annex I,

waste incineration plants

waste co-incineration plants whose main purpose is not

the generation of material products and that combust

only waste, or

a high share of hazardous waste, or

mixed municipal waste.

3




The BREF also covers:

The treatment of slags and/or bottom ashes from the

incineration of waste covered by IED Annex I activities:

5.3 (a): disposal of non-hazardous waste with a capacity

threshold of > 50 tonnes/day

5.3 (b): recovery or recovery/disposal of non-hazardous

waste with a capacity threshold of > 75 tonnes/day

5.1: disposal or recovery of hazardous waste with a

capacity threshold of > 10 tonnes/day

4




The BREF does not cover:

Pre-treatment of waste prior to incineration;

Treatment of incineration fly ashes and other

residues resulting from flue-gas cleaning;

Incineration or co-incineration of exclusively

gaseous waste other than resulting from the

thermal treatment of waste;

Treatment of waste in plants covered by Article

42(2) of Directive 2010/75/EU.

5



6

Summary of the WI BREF review process (1/5)

Main steps Date

TWG reactivation May 2014

Call for wishes June 2014

Kick-off meeting January 2015

Activation of three subgroups March 2015

Collection of bulk information March – August 2015

Elaboration of questionnaires April – December 2015

Data collection through questionnaires January – April 2016



7


355 Main WI questionnaires submitted by 16 Member States



8


43 IBA treatment questionnaires submitted by 12 Member States



9


Main steps Date

Site visits Austria (4 WI plants; district cooling) April 2016

Site visits Sweden (2 WI & 1 IBA plants) April 2016

Webinar on data compilation November 2016

Draft 1 of revised WI BREF May 2017

Commenting period (~ 3 000 comments) May – September 2017

Site visits France (4 WI & 1 IBA plants; 1 AMS

manufacturer & 1 ILC test bench)June 2017

Site visits Germany (3 WI & 2 IBA plants) July 2017



10


Main steps Date

Assessment of comments and revision of the

draft BAT conclusions and of the BREF main text

September 2017 –

March 2018

Informal TWG meeting December 2017

Background Paper + revised draft BAT

conclusions for final TWG meetingFebruary 2018

Final WI TWG meeting 23 – 27 April 2018

Pre-final draft of the WI BREF 28 September 2018

Final draft of the WI BREF 14 December 2018

Forum meeting 27 February 2019



Structure of the revised WI BREF (1/2)

Preface

Scope

Chapter 1 – General information on WI

Chapter 2 – Processes and techniques applied for WI

Chapter 3 – Current emission and consumption levels

Chapter 4 – Techniques to consider in the

determination of BAT

Chapter 5 – BAT Conclusions

Chapter 6 – Emerging techniques

11



Structure of the revised WI BREF (2/2)

Chapter 7 – Concluding remarks and recommendations

for future work

Chapter 8 – Annexes, including:

Energy efficiency calculation examples

Detailed graphs for periodically and continuously monitored

emissions to air

Comparison of PCDD/F emission levels measured by long-term

and short-term sampling

Glossary

References

12



Main changes in the revised WI BREF

A general update.

A comprehensive restructuring of the document, e.g.

to more clearly distinguish information representative

of applied process and techniques from the BAT

candidates.

More consideration to resource efficiency.

Plant-specific data from WI questionnaires presented

in tables and graphs, in summary format in Chapter 3

and fully detailed in the Annexes.

BAT conclusions in line with IED requirements and

more focussed (37 BAT conclusions instead of 82).

13



Structure of the BAT conclusions (1/2)

Scope

General considerations

5.1 BAT conclusions:

5.1.1 EMS

5.1.2 Monitoring

5.1.3 General environmental and combustion performance

• Waste stream management

• IBA output quality management

• Waste delivery monitoring

• Waste reception, handling and storage

• Optimisation of incineration, burnout and plant availability

• OTNOC management plan14



Structure of the BAT conclusions (2/2)

5.1.4 Energy efficiency

5.1.5 Emissions to air

• Diffuse emissions (WI and IBA treatment)

• Channelled emissions (WI and, for dust, IBA treatment with

air extraction)

• With special attention to peak emissions (in particular Hg)

5.1.6 Emissions to water

5.1.7 Material efficiency

5.1.8 Noise

5.2 Description of techniques

15



Key features of the BAT conclusions: Energy efficiency

For the incineration of municipal solid waste, other

non-hazardous waste, and hazardous wood waste:

BAT-AEELs for energy recovery expressed as gross

electrical efficiency or gross (total) energy efficiency

For the gross electrical efficiency, differentiated BAT-

AEELs for new and existing plants

For the incineration of sewage sludge and of hazardous

waste other than hazardous wood waste:

BAT-AEELs expressed as boiler efficiency

16



Key features of the BAT conclusions: Monitoring of

emissions to air

Continuous and periodic monitoring broadly following

IED Annex VI, with the following main advances:

Continuous measurement of Hg (general case)

Continuous sampling as well as periodic

measurements for PCDD/F (general case)

Monitoring of dioxin-like PCBs (general case)

Monitoring of PBDD/F for plants incinerating

brominated flame retardants or injecting bromide as

FGC technique

Determination of the POP content in the output

streams of plants incinerating hazardous waste

containing POPs 17



Key features of the BAT conclusions: BAT-AELs for

emissions to air

Differentiated and proportionate approach to different

pollutants based on relevance and availability of

effective techniques; key pollutants are: Hg and other

metals, NOX and NH3, HCl and SO2, Dust, PCDD/F,

PCBs

For continuously monitored pollutants, BAT-AELs set as

daily levels only

BAT-AELs underpinned by the analysis of year-long

emission series for >300 monitored points of emission

Differentiated levels for new and existing plants

18



Key features of the BAT conclusions: Other topics

Emissions to water:

BAT-AELs for emissions to water from wet flue-gas

cleaning processes and from the storage and treatment

of incineration slags and bottom ashes;

substances/parameters generally monitored as 24-h

composite samples with monthly frequency

Material efficiency:

BAT conclusions for the treatment of bottom ashes

and for the efficient recovery of valuable materials

from bottom ashes

19



Degree of consensus

High degree of consensus

16 split views fulfil the conditions set out in

Section 4.6.2.3.2 of the BREF Guidance and are

recorded in Chapter 7 of the BREF

20



Comments of the IED Article 13 forum on the Final Draft

TOTALConsidered consensual

Considered consensual subject to

certain amendments

Considered as representing the views of certain

members

Comment on the process -

considered not relevant for the forum opinion

64 14 8 40 2

21

64 comments

from 7 MS (AT, DE, DK, FR, IE, IT, UK), NO, 5

industrial associations (CEWEP-ESWET, FEAD,

Euroheat & Power, Eurometaux, European

Sustainable Phosphorus Platform), and EEB

31 comments on the BAT conclusions



22

Issue to discuss

Classification and comment number

Considered

consensual

Considered

consensual

subject to certain

amendments

Considered as

representing the

views of certain

members

Text of the Note in the

standard text on the EMSIT 1

Issues for discussion and clarification (1/3)



23

Issue to clarify


Considered

consensual

Considered

consensual subject

to certain

amendments

Considered as

representing the

views of certain

members

Measurement

uncertainty

FR 1, FEAD 3,

CEWEP-ESWET 3

Annex 8.2 examples of

energy efficiency

calculations

FEAD 7




24

Issue to clarify


Considered

consensual

Considered

consensual

subject to certain

amendments

Considered as

representing the

views of certain

members

Co-incineration plants in

the scope of the WI BREFUK 1

Monitoring frequency in

Table 5.8 (BAT-AELs for

indirect emissions to

water)

DE 3




Note of the EMS standard text

"Note" of the EMS standard text as circulated to the IEDF

in December 2018 and introduced in the Final Draft:

Regulation (EC) No 1221/2009 establishes the European

Union eco-management and audit scheme (EMAS), which

is an example of an EMS compliant with this BAT.

Forum comment IT 1: the expression "compliant with"

might cause uncertainty regarding the responsibility of

the Competent Authority for assessing the effective

implementation of BAT 1. IT asks to replace "compliant"

with "consistent".

25

Issue for discussion (1/2)



Note of the EMS standard text

Assessment: The IT comment seems relevant taking also

into consideration that the "Note" refers not only to the

standard EMS text but also to the part of BAT 1 that lists

the sector-specific features (including e.g. OTNOC

management plan).

Proposal: to consider as consensual the amendment

proposed by IT 1: "Regulation (EC) No 1221/2009

establishes the European Union eco-management and

audit scheme (EMAS), which is an example of an EMS

compliant consistent with this BAT".

26

Issue for discussion (2/2)



Measurement Uncertainty

Forum comment FR 1: To add in Chapter 7 on concluding

remarks and recommendations for future work "To ask

CEN to work on the applicability and validation of existing

methods at the level of the BAT-AELs set in these BAT

conclusions and, if relevant, to work on new measurement

methods".

Forum comment FEAD 3: To add in the BAT conclusions a

reference to measurement uncertainty, factual and

concise, to be linked to the BAT on monitoring of

emissions to air from waste incineration plants.

27

Issues for clarification (1/18)



Measurement Uncertainty

Forum comment CEWEP-ESWET 3: To add in footnote (1)

to BAT 4 of the BAT conclusions that "As shown by

evidence emerged during the work of the TWG, it may be

necessary to assess the measurement uncertainty given

in the EN standards, because the relative measurement

uncertainty (i.e. percentage of the concentration) will

probably increase when concentration levels decrease".

28




Measurement Uncertainty (FR 1) assessment:

The issue has been recognised and is relevant for the

work programme of CEN. CEN/TC 264 is working on this

through the task force "Emissions".

It is unclear if such a recommendation would befit

Chapter 7 of the WI BREF.

The BREF Guidance states that "Recommendations will be

included for further research or information gathering in

view of the next review of the document".

This is however mainly relevant for implementation of the

current BREF, and does not point at an action for the WI

TWG to take. 29




Measurement Uncertainty (FEAD 3 and ESWET-CEWEP 3)

assessment:

Whilst the measurement uncertainty is relevant for

assessing compliance of installations with emission limit

values, the scope of the implementing acts that the

Commission is empowered to adopt does not include

conclusions on measurement uncertainty.

Rather, measurement uncertainty is an important

parameter to be taken into account in the implementation

phase when compliance with the permit conditions is

assessed.

30





assessment:

In accordance with Chapter II of the IED, Member States

are responsible for determining how to assess compliance

with the permit conditions and hence how to take

measurement uncertainty into account.

The Commission could thus exceed its delegated powers

should it include aspects of compliance assessment in the

implementing act.

31





assessment:

Measurement uncertainty is a horizontal issue across all

sectors; as such, it is primarily addressed in the ROM that

has been recently finalised.

The WI BREF recognises the relevance of measurement

uncertainty by including specific references to the ROM

and to other reports cited in the ROM, as well as by

including specific text in Chapter 7.

32





assessment:

DG Environment is actively engaging with Member States

and other stakeholders to support IED implementation.

Continued consideration can be anticipated of the

compliance assessment and measurement uncertainty

issues in the implementation phase of all BAT conclusions.

33





Annex 8.2 of the WI BREF includes detailed examples of

energy efficiency calculations for WI plants expressing

their energy efficiency either as gross electrical efficiency

or as gross energy efficiency

Forum comment FEAD 7: to also include the examples of

hybrid plants developed by the Energy Subgroup of the

WI TWG, even if those examples may be fictive examples

only.

34





Assessment:

The examples of hybrid plants that were initially drafted were

dropped from the Final Draft as they turned out to be cases that in

reality could be reduced to the cases already covered by the basic

configurations.

The Energy Subgroup has however collected additional data and

worked out further examples; a useful hybrid plant example has

been technically agreed between the Subgroup and the EIPPCB.

Proposal: to add in Annex 8.2 an example of a hybrid

plant with condensing turbine & partial steam extraction.

35




Co-incineration plants in the scope of the WI BREF

Text of the Scope in the Final Draft:

Disposal or recovery of waste in waste co-incineration plants:

(a) for non-hazardous waste with a capacity exceeding 3 tonnes per hour;

(b) for hazardous waste with a capacity exceeding 10 tonnes per day.

whose main purpose is not the production of material products and where

at least one of the following conditions is fulfilled:

• only waste, other than waste defined in Article 3(31)(b) of Directive

2010/75/EU is combusted;

• > 40 % of the resulting heat release comes from hazardous waste;

• mixed municipal waste is combusted.

36





Forum comment UK 1: To avoid confusion, the wording of

the scope should be clarified by:

matching the equivalent wording used in the LCP BREF;

making clear that relevant plants will still be included under the

scope of the WI BREF if their rated thermal input is below 50 MW.

UK 1 proposal: amend the first bullet to:

• only wastes are combusted, other than except if those wastes are at

least partially comprised of biomass as defined in Article 3(31)(b) of

Directive 2010/75/EU and are combusted in a plant with a total rated

thermal input of 50 MW or more is combusted;

37





Assessment:

A better alignment of the text with the laguage used in the scope of

the LCP BREF could represent a useful clarification

However, the inclusion of a 50 MW threshold would amount to a

substantive change of scope.

The WI BREF includes in its scope the types of co-incinerators that

combust the categories of waste considered to be more concerning.

Other types of waste would be excluded, irrespective of whether

those plants would be covered by the LCP BREF.

This aspect was clarified in 2015 ahead of the WI data collection.

38





Proposal: to align the text of the WI BREF and BAT

conclusions scope to the language used for LCP, but not to

mention the 50 MW threshold:

• only wastes are combusted, other than except if those wastes

are at least partially composed of biomass as defined in Article

3(31)(b) of Directive 2010/75/EU is combusted;

39




Monitoring frequency for emissions to water

40


Parameter Process Unit BAT-AEL (1)

Total suspended solids (TSS)FGC

Bottom ash treatmentmg/l 10–30

… … … …

… … … …

Sulphate (SO42-) Bottom ash treatment mg/l 400–1 000

PCDD/F FGC ng I-TEQ/l 0.01–0.05

(1) The averaging periods are defined in the General considerations.

Table 5.79: BAT-AELs for direct emissions to a receiving water body




41


Parameter Process UnitBAT-AEL (1)

(daily average)

As FGC mg/l 0.01–0.05

… … … …

PbFGC

Bottom ash treatment… 0.02–0.06

… … … …


(1) The BAT-AELs may not apply if the downstream waste water treatment plant is

designed and equipped appropriately to abate the pollutants concerned, provided this does

not lead to a higher level of pollution in the environment.

Table 5.810: BAT-AELs for indirect emissions to a receiving water body



Monitoring frequency for indirect emissions to water

Forum comment DE 3: waste water from bottom ash

treatment, two cases are given in the "General

considerations". Daily averages for continuous discharges,

and average values over the release duration (or spot

samples) for batch discharges.

DE 3 proposes to add a footnote to cover the case of Pb

emissions in waste water from bottom ash treatment:

"(2) The averaging period for Pb in the case of bottom ash

treatment is defined in the General considerations"

42




Monitoring frequency for indirect emissions to water

Assessment: The issue raised by DE 3 seems relevant, as

in the case of bottom ash treatment the BAT-AEL for Pb

emissions may be associated with a batch discharge.

Proposal: While the DE 3 proposal would sufficiently cover

the relevant case, it seems simpler to replicate the

approach of table 5.7 9: remove "daily average" from the

last column´s heading in Table 5.8 10, and reinstate in

Table 5.8 10 the footnote appearing as footnote (1) in

Table 5.7 9.

43





44


Parameter Process UnitBAT-AEL (1) (2)

(daily average)

As FGC mg/l 0.01–0.05

… … … …

PbFGC

Bottom ash treatment… 0.02–0.06

… … … …


(1) The BAT-AELs may not apply if the downstream waste water treatment plant is

designed and equipped appropriately to abate the pollutants concerned, provided this does

not lead to a higher level of pollution in the environment.

(2) The averaging periods are defined in the General considerations.

Table 5.810: BAT-AELs for indirect emissions to a receiving water body



Thank you for your attention!

45

revised best available techniques (bat) reference document ... · 27.02.2019 · streams of plants...

Documents