4 December 2019
Treatment and recovery of waste
On 3rd December 2019, after a 5-year review process, the Best Available Techniques (BAT) Conclusions for Waste Incineration (WI) were published in the Official Journal of the EU (OJEU).
CNIM is proud of the environmental performances of Waste-to-Energy plants in Europe, which continue to act as a sink for pollution in an integrated waste management, treating the waste that cannot be recycled in an environmentally sound way, while using robust technology and long-term experience. Waste-to-Energy provides the perfect bridge to support the efforts of our society to become more circular by using the energy contained in waste while avoiding that substances of concern re-enter the cycle. At the same time it helps to achieve the objectives on air and water quality, soil protection as well as health and environmental preservation as a whole.
The newly adopted WI BAT Conclusions are the reference for setting permit conditions of the Waste-to-Energy (WtE) plants. This means that within 4 years from today, all permit conditions of European WtE plants will be reconsidered and, if necessary, updated to ensure compliance with the new requirements. These new BAT Conclusions set even more demanding standards than the already very strict previous legal requirements of Annex VI of the Industrial Emission Directive (IED), regarding emission limits. They also add a number of controlled substances and monitoring requirements.
The WtE sector is used to strict regulations. Already the Waste Incineration Directives of 1989 then 2000 made WtE incineration the most stringently regulated and controlled industrial activity. The directive of 2000 was merged with others within the Industrial Emission Directive (IED) in 2010 and set the legally binding emission limits in its Annex VI. The efforts put in place by WtE designers, suppliers and operators to achieve the ambitious standards can be clearly seen from the sector‘s extremely low contribution to the overall industrial emissions collected for the European Pollutant Register (EPRTR). WtE incineration contributes only 1.8% of NOx and less than 1% of dioxins and mercury emissions to the overall European industrial emissions. In which transports, agriculture etc. are not taken into account.
The new WI BAT Conclusions result in an ambitious package, not only for the concentration ranges (BATAELs) that are the basis for emission limit values in the new permits, but also for other requirements such as continuous monitoring of mercury emissions to air. Moreover, BAT conclusions are not only about emissions, they include the references to the most advanced techniques for combustion performance, energy efficiency, material efficiency, noise control and for implementing an environmental management system.
It should be noted that the detection of possible waste radioactivity as well as the continuous sampling of emissions of dioxins and furans, installed for years by CNIM in France and other countries but which was not requested in many other Member States are now recognised as Best Available Techniques.
As part of the BREF review process, emission data was collected from existing plants which due to previous legislation, already presented very low emission values. When emissions are at such low levels, the uncertainty of the measurement becomes a very important topic. No measurement is exact, and for a given monitoring device the lower the measured value is, the less reliable the result of the measurement becomes. The measurement uncertainty needs to be tackled to avoid that monitoring requirements become inconsistent with future Emission Limit Values. CNIM expected to see a mention of this issue and how this is taken into account in the BAT Conclusions but considers it a starting point that the reference to this has been made in Chapter 7 of the published WI BREF, which should be published in a few months.
WI BAT Conclusions tackle many aspects of how the BAT principle can be considered when writing permits for the installation but does not cover every last detail. For those issues that are left unsaid, CEWEP, ESWET, FEAD and Euroheat and Power published an Explanatory and Guidance document (E&G-d) in English identifying the gaps in the BAT conclusions and proposing solutions to remedy, as well as forms to help preparing the re-examination application.
« CNIM, who very actively contributed to the drawing up of the WI BREF and to the writing of these documents, says Hubert de Chefdebien, Public Affairs Director of CNIM Environment & Energy, made a list accessible here of the sites where to find the documents necessary for a good understanding of the WI BAT conclusions including the official documents, the Explanatory & Guidance document, conferences in English and French (.ppt and videos) as well as studies, articles, notes. »