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WID Final Report
March 2016 1
Assessment and Summary of the Member States'
Implementation Reports for the
IED, IPPCD, SED and WID
WID Final report
Prepared by
Amec Foster Wheeler Environment & Infrastructure UK Ltd
March 2016
WID Final Report
March 2016 3
Executive Summary
Introduction This report that has been produced for the purpose of understanding the status of
Member States’ implementation of the Waste Incineration Directive (WID)
(2000/76/EC). The findings are based on the information contained in the reports
submitted by Member States for the third and last reporting period under the WID which
covered the period 2012-2013. In view of the information already obtained for the
previous reporting periods, this report focusses on the changes and progress made by Member States in the period 2012-2013.
Background The Waste Incineration Directive (WID) aims to prevent and control pollution from
installations incinerating and co-incinerating waste. Amongst the key elements of the
WID are the requirements to issue permits with defined conditions, including emission
limit values (ELVs) for the main pollutants and related monitoring obligations. For waste
incineration and co-incineration plants, which were also regulated under the IPPC
Directive 2008/1/EC (integrated pollution prevention and control), the WID set the EU-wide “minimum requirements”.
The WID has been repealed and replaced as of 7 January 2014 by Directive 2010/75/EU on industrial emissions (IED).
Permit status Member States reported a total of 1,673 plants falling within the scope of the WID during
the reporting period, of which 939 (56%) were identified as incineration plants and 688
(41%) as co-incineration plants. The remaining 46 plants were not categorised. The
number of plants covered by the WID in 2012-2013 fell by 2%, down from 1,714 plants
in 2009-2011. There was a decrease of 6% in the number of incinerators (55 plants
less), while the number of co-incinerators remained almost the same (increased from 687 to 688).
Administrative details (name of plant and address) were provided for 1,382 plants (83%
of the reported total), comprising 680 incineration plants and 576 co-incineration plants.
Of the co-incineration plants, 176 were reported to be cement kilns, 305 combustion plants and 95 other industrial facilities.
The number of plants recovering heat has declined in absolute terms since 2009-2011
(from 1,392 to 1,322); however, as a proportion of the total number of plants, the
number of plants recovering heat has increased (accounting for 96% in the 2012-2013
reporting period compared 81% in the previous reporting period).
WID Final Report
March 2016 4
Figure 1: Number and type of plants and permits in EU-27 (2012-2013)
Thirteen Member States responded to the optional question on total permitted capacities
of waste throughputs. Capacities reported amounted to a total of 46 million tonnes of
waste treated per year with respect to 964 plants. There was no indication of how capacity varies in scale between the different plants.
Lastly, no mobile plants received permits under the WID during the reporting period.
Permitting procedures The level of detail provided by Member States with regard to permitting procedures
varied, and in most cases at least a part of the information requested was found to be missing.
Provisions for plants incinerating hazardous waste: There is a lack information
reported by Member States for such plants, in particular with respect to the
minimum and maximum flows of hazardous wastes to be treated and the range of
calorific values of hazardous wastes permitted.
Provisions to protect soil, surface and groundwater: The most frequently reported
measures were facilities for separate collection of polluted waters (reported by 12
Member States) and the use of impermeable and covered areas where wastes are
stored (reported by ten and eight Member States each).
Criteria to ensure sufficient storage capacity for water to be tested and treated:
The most frequently reported criterion (five Member States) was to undertake
calculation for storage capacity on the basis of hydraulic calculations.
Minimisation of residues in both quantity and harmfulness: Responses covered only
some requirements, with the most frequently reported being the minimisation in
amount and harmfulness, and recycling of residues (mentioned by 12 and 9
Member States respectively).
Control of emissions and operational conditions The WID allows for several derogations with regards control of emissions and operational conditions, and the following information was provided in this respect.
In accordance with the WID, ten Member States have granted a total of 133
authorisations to differ from the operating conditions stipulated in Article 6(1) and
Article 6(2) during the reporting period. The majority of these authorisations (67%)
WID Final Report
March 2016 5
were located in Germany. Based on the information provided for some representative
cases (41), these were generally granted to existing plants and laid down different
temperature conditions.
Derogations for monitoring requirements of emissions to air, as permitted under Article
11 of the Directive, have been applied in 16 Member States. The most commonly
reported pollutant for which derogations are applied is HF, both under Article 11(6) (14 Member States) and under Article 11(4) (13 Member States).
Monitoring requirements of emissions to water have been applied as laid down in Article
11(14-15) in 20 Member States. In keeping with the derogations permitted by the
Directive, Denmark and Ireland reported different reporting requirements for metals,
and France reported that additional parameters must be monitored. Cyprus, Hungary, Latvia and Luxembourg reported that the question is not relevant for them.
Emission limit values – Exemptions for cement kilns co-incinerating
waste In accordance with Annex II.1 of the Directive, Member States can apply certain special
provisions (exemptions) for cement kilns co-incinerating waste. Some aspects in relation to these provisions are summarised below.
A total of 21 Member States reported application of these provisions concerning
emission limits. As illustrated in Figure 2, these apply to SO2, TOC, dust and NOx, with the greatest number reported by France and with respect to SO2 and TOC.
Figure 2: Total number of exemptions permitted in cement kiln plant co-incinerating
waste, by Member State and by pollutant
Note: Austria and Italy did not report the number of exemptions permitted.
Additional or differing Emission Limit Values for air In accordance with the Directive, Member States may choose to set Emission Limit
Values (ELVs) for releases to air from incineration and co-incineration plants that cover
additional pollutants to those stipulated in the Directive, or that are more stringent to
those specified. As illustrated in Figure 3, 13 Member States responded that ELVs are
the same as those determined in Annex II and V of the WID, while 11 have set ELVs for
additional pollutants to those specified by the Directive. The most common additional
pollutant is ammonia, as reported by eight Member States.
WID Final Report
March 2016 6
Figure 3: Additional or more stringent Emission Limit Values for releases to air
Additional or differing ELVs for water In accordance with the Directive, Member States may choose to set additional or more
stringent ELVs for discharges of waste water from flue gas cleaning equipment to the
aquatic environment. 14 Member States reported that the ELVs for discharges of waste
water are with the same as under Annex IV to the Directive while 10 Member States reported otherwise, as illustrated by Figure 4.
Figure 4: Number of Member States reporting the adoption of additional or more
stringent ELVs values to waste water discharges
WID Final Report
March 2016 7
Table of contents
1. Introduction ..................................................................................... 10 1.1 Purpose of this report ............................................................................10 1.2 Study context .......................................................................................10 1.3 Waste Incineration Directive ..................................................................10 1.4 Reporting by Member States ..................................................................10 1.5 Structure of this report ..........................................................................11
2. Analysis of Member States’ reports on the implementation of the
Waste Incineration Directive ............................................................ 12 2.1 Overview .............................................................................................12 2.2 Approach .............................................................................................12 2.3 Evaluation criteria .................................................................................12 2.3.1 Evaluation of the completeness .......................................................................... 12 2.3.2 Prioritisation of the information gaps ................................................................... 13 2.4 Completeness of Member States’ reports .................................................14
3. Analysis of Member States’ responses per question ......................... 18 3.1.1 Overview ......................................................................................................... 18 3.1.2 Question 1: Number of plants and permits ........................................................... 18 3.1.3 Question 2: Definitions ...................................................................................... 25 3.1.4 Question 3: Mobile plants .................................................................................. 26 3.1.5 Question 4: Categories of waste that have been co-incinerated .............................. 26 3.1.6 Question 5: Annex V ELVs applicable ................................................................... 26 3.1.7 Question 6: Permitting process ........................................................................... 27 3.1.8 Question 7: Waste inappropriate for representative sampling ................................. 30 3.1.9 Question 8: Derogations from operating conditions ............................................... 31 3.1.10 Question 9: Exemptions from ELVs in cement kilns ............................................... 32 3.1.11 Question 10: Differing ELVs for release to air ....................................................... 35 3.1.12 Questions 11 and 12: ELVs for discharges of wastewater from flue gas cleaning
equipment ....................................................................................................... 40 3.1.13 Question 13: Operational control parameters for wastewater discharges .................. 44 3.1.14 Question 14: Provisions to protect soil, surface and groundwater ............................ 46 3.1.15 Question 15: Provisions to ensure sufficient storage capacity for water to be tested and
treated ............................................................................................................ 47 3.1.16 Question 16: Residues ....................................................................................... 48 3.1.17 Question 17: Measurement of pollutants to air ..................................................... 50 3.1.18 Question 18: Measurement of pollutants to water ................................................. 51 3.1.19 Question 19: Compliance as regards air emissions ................................................ 52 3.1.20 Question 20: Compliance as regards water emissions ............................................ 54 3.1.21 Question 21: Guidance on producing validated daily average emission data ............. 55 3.1.22 Question 22: Procedures for informing competent authority of a breach of ELVs ....... 57 3.1.23 Question 23: Public participation in permitting process .......................................... 59 3.1.24 Question 24: Availability of information through permitting process ........................ 62 3.1.25 Questions 25 and 26: Annual report .................................................................... 63 3.1.26 Question 27: Identification of plants with a nominal capacity of less than 2 tonnes per
hour ................................................................................................................ 66 3.1.27 Question 28: Provisions to control the period of abnormal operation ....................... 68 3.1.28 Question 29: Maximum permissible periods of abnormal operation ......................... 69 3.1.29 Question 30: General remarks ............................................................................ 71 3.1.30 Croatia’s report on the implementation of the Waste Incineration Directive .............. 71
4. Implementation status ..................................................................... 73 4.1.1 Summary of implementation status ..................................................................... 73 4.1.2 Follow-up actions .............................................................................................. 88 4.1.3 Main conclusions on implementation status .......................................................... 89
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March 2016 8
4.1.4 Conclusions on reporting ................................................................................... 90
Appendix A Member State summaries .......................................................... 91
Table 2.1 Key to completeness analysis ..........................................................13 Table 2.2 Overview of the responses to WID implementation questionnaire from
Member States .................................................................................................16 Table 3.1 EU-27 data set on number of plants, permits issued and plants recovering
heat (question 1.1) ...........................................................................................19 Table 3.2 Overview of reported issues with the definitions given in Article 3 ........25 Table 3.3 Co-incineration plants subject to the emission limits in WID Annex V ....27 Table 3.4 Particular issues identified in Member States’ responses on Article 4(5) 29 Table 3.5 Types of wastes reported as inappropriate for representative sampling .30 Table 3.6 Application of Article 6.4 .................................................................32 Table 3.7 Different ELVs to those specified in Annex IV of the WID set by Member
States ....................................................................................................41 Table 3.8 ELVs set for additional parameters to those specified in Annex IV to the
WID by Member States .....................................................................................43 Table 3.9 Operational parameters for the discharge of waste waters reported per
Member State ................................................................................................45 Table 3.10 Summary of MS responses which described measures or quoted relevant
parts of the legislation .......................................................................................49 Table 3.11 More stringent or additional requirements for air emission
measurements reported by Member States ..........................................................51 Table 3.12 Different wastewater monitoring requirements to those set out in Article
11(14) and 11(15) ............................................................................................52 Table 3.13 Summary of responses provided to question 19 ..............................53 Table 3.14 Summary of responses provided in reply to question 20 ...................55 Table 3.16 Website links where annual reports are available on the internet
(optional question) ...........................................................................................66 Table 4.1 Summary of implementation status (2012-2013) ...............................74 Table 4.2 Remaining gaps to follow-up ............................................................88
Figure 3.1 Question 1.1. Number and type of plants and permits in EU-27 ............18 Figure 3.2 Total number and type of plants by Member State (2012-2013) ...........20 Figure 3.3 Number of permits issued compared to number of plants by Member State
(2012-2013) ....................................................................................................22 Figure 3.4 Number of plants with heat recovery (HR) by Member State (2012-2013)
....................................................................................................23 Figure 3.5 Number and type of installations for which details have been provided
(2012-2013) ....................................................................................................24 Figure 3.6 Type of co-incineration plants by Member States (2012-2013) .............24 Figure 3.7 Specification of aspects prescribed in Article 4(5) based on Member States’
responses ....................................................................................................28 Figure 3.8 Total number of exemptions granted in accordance with Annex II.1 as
reported by Member States................................................................................33 Figure 3.9 Total number of exemptions by pollutant granted in accordance with Annex
II.1 ....................................................................................................34 Figure 3.10 Additional or more stringent Emission Limit Values for releases to air 36 Figure 3.11 Parameters for which more stringent ELVs for pollutants to air are
specified (by number of cases reported) ..............................................................37 Figure 3.12 Additional air pollutants to those specified in the WID for which ELVs
have been specified ..........................................................................................39
WID Final Report
March 2016 9
Figure 3.13 Reported derogations for the requirements for air pollutant
measurements and process operation parameters set in Article 11(2) of the Directive
50 Figure 3.14 Reported time within which authorities must be informed about the
breach of ELVs (% of MS) ..................................................................................58 Figure 3.15 Method of communication that be used (number of Member States) ..58 Figure 3.16 Means by which information concerning the permit application, and the
final decision for new and updated permits is made available to the public 3 ............60 Figure 3.17 The number of authorities across Member States responsible for making
new permit applications and the final decision available to the public ......................60 Figure 3.18 Period of time allowed to the public for commenting on permit
applications ................................................................................................62 Figure 3.19 Minimum requirements for the content of annual reports .................65 Figure 3.20 Reported forms to identify plants with capacity below 2 tonnes per hour
................................................................................................67 Figure 3.21 Provisions to control the period of abnormal operation .....................69 Figure 3.22 Time limit for the consecutive period of time of abnormal operation ..70 Figure 3.23 Time limit for the cumulative period of time of abnormal operation....70
WID Final Report
March 2016 10
1. Introduction
1.1 Purpose of this report
This report has been prepared under a contract (070201/2014/693416/ENV.C3) between
the European Commission and Amec Foster Wheeler Environment & Infrastructure UK
Limited (‘Amec Foster Wheeler’) related to the assessment and summary of Member
States’ implementation reports for the IED, IPPCD, SED and WID. The work is being delivered in partnership with Milieu Ltd.
This report has been produced for the purpose of understanding the status of Member
States’ implementation of the Waste Incineration Directive (WID) (2000/76/EC). The
findings in this report are based on the information contained in the reports submitted
by Member States for the third and last reporting period under the WID which covered
the period 2012-2013. In view of the information already obtained through the previous
reporting periods, this report focuses on the changes and progress made by Member States in the actual implementation of the Directive in the period 2012-2013.
1.2 Study context
1.3 Waste Incineration Directive
The Waste Incineration Directive (WID hereafter) aims to prevent and control pollution
from installations incinerating and co-incinerating waste. Amongst the key elements of
this Directive are the requirements to issue permits with defined permit conditions,
including emission limit values (ELVs) for the main pollutants and related monitoring obligations.
For large waste incineration and co-incineration plants, which were also regulated under
Directive 2008/1/EC (integrated pollution prevention and control), the WID set the
“minimum requirements”.
The WID has been repealed and replaced as of 7 January 2014 by Directive 2010/75/EU
on industrial emissions, which has absorbed seven previous directives relating to industrial installations.
1.4 Reporting by Member States
Article 15 requires Member States (in accordance with Article 5 of Council Directive
91/692/EEC) to submit reports on the status of implementation in respect of the main
elements of the Directive and to provide representative information on installations
falling within its scope.
There have been three separate Commission Decisions relating to the submission of
information1; the first one covering the period 2006-08, the second one covering the
period 2009-11 and the third one covering the period 2012-2013. The third Decision
follows a similar structure and pattern of questions to that of the previous Decision in
order to ensure continuity and enable direct comparisons to be made. The Decision also
acknowledges that Member States need not repeat information where there are no
material changes since the 2009-2011 report. This study is concerned with the
examination of those responses made in 2014 for the period 2012-2013. It is noted
that there is no date specified in the questionnaire beyond the year and there may be variation in the timeframe against which Member States have reported.
1 2006/329/EC, 2010/731/EU and 2011/632/EU
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March 2016 11
1.5 Structure of this report
The report is structured as follows:
Section 2 provides an analysis of the Member States’ reports on the
implementation of the WID;
Section 3 analyses the responses provided by Member States by question;
Section 4 presents the conclusions of the study; and
Appendix A includes the WID Member States summaries developed from responses
received by Member States.
WID Final Report
March 2016 12
2. Analysis of Member States’ reports on the implementation of the Waste Incineration Directive
2.1 Overview
This section presents the analysis of the completeness of Member State reports and an
overall analysis of each question across the EU-27 as reported for the period in 2012-
2013. Croatia also submitted a report regarding the implementation of the WID,
although it was not formally obliged to do so. A short summary has been included in
the report (see section 4) about the information provided by Croatia without going into specific details.
2.2 Approach
The analysis of the reports submitted by Member States for the period 2012-2013 was
carried out systematically with reference to the questionnaire (Decision 2011/632/EU) and to the WID itself.
The implementation of the Directive for each Member State has been assessed in a
series of stages:
1. An analysis of the ‘completeness’ of the reports (section 2.3.1).
2. An assessment of the information gaps to prioritise their criticality (section 2.3.2).
3. A detailed analysis of the status of implementation of the Directive (section 3).
The information included in this report is based solely on the data reported by Member
States, and any subsequent clarifications. Reports were translated into English by the
Commission where necessary and the analysis is based on the English translations, rather than the original language versions.
2.3 Evaluation criteria
2.3.1 Evaluation of the completeness
For each of the 30 questions analysed, an assessment was made as to the extent to
which the Member State had provided an adequate answer, or provided sufficient data
in relation to the reporting requirements under the Directive and the Commission’s questionnaire.
The results of this completeness assessment have been presented for each Member
State in Table 2.1 and Annex I contains further commentary on the nature of the gaps
within individual Member State assessments. The definitions attributed to the different colours are set out in the table below.
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March 2016 13
Table 2.1 Key to completeness analysis
Evaluation criteria for completeness
Green The information provided by the Member State addresses the requirements of the question, i.e. the response to the question is complete, and the information is sufficient to understand how a specific aspect of the Directive has been implemented.
Orange
The information provided by the Member State only partially addresses the requirements of the question, i.e. the information may only address part of the question, certain indents or provides limited detail. The information therefore does not give sufficient information to understand the status of implementation.
Red
Information provided by the Member State may not be relevant or present at all; it may not
address in any way the key requirements of the question, i.e. the question is incomplete and raises uncertainties surrounding the status of implementation of that aspect of the Directive.
No
colour/ White
When responses are made to questions, or part of the questions, that were not required by
the questionnaire, for example because information submitted in an earlier part of a question meant that the second part was not required (e.g. when information only had to be provided when Member State responded “yes” to the question) only colours green or orange will be utilised. If no responses are provided, then no colour will be used.
Black Use of the colour black indicates that there seems to be an IT problem with the question,
which is not visible in the report provided (neither the Word nor the Excel document), and therefore it has not been possible to do an assessment.
In addition the following assumptions have been applied:
Some questions, whilst not explicitly optional, requested information ‘if available’
or ‘if known’. When Member States did not provided all the requested fields,
stated that no information was available, or that particular information was not
known, this has not been considered a gap;
Considering that the questionnaire focuses on ‘changes and progress made by
Member States’ when a Member State comments that there has been no change in
last reporting period and do not bring any further details, this has not been
considered as a gap; and
Where there are particular issues regarding a Member State’s report, such as
omission of information or incomplete provision of information, notes have been
provided in the Member State specific analyses (see Appendix A) to give an
explanation as to why an orange or red colour has been applied. Where the
question is deemed to have been answered completely, no further comments have
been provided, unless further clarification was considered to be required.
2.3.2 Prioritisation of the information gaps
The analysis of the Member State reports started with a systematic review of the
information provided by the Member States. In order to draw conclusions on the
implementation status based on the information contained in the reports, criteria were
used to make a judgement about the degree to which the WID questionnaire has been
answered.
For quantitative information, provided in response to Questions 1, 5, 8 and 9, the criteria used to establish the status of implementation included:
whether any data had been provided by the Member State;
where data was not provided, whether an explanation has been given or why this
information was not available or what measures were in place to ensure data is
being collected; and
WID Final Report
March 2016 14
whether the data included provided an understanding of the status of
implementation.
For qualitative information, provided in response to the remaining questions the
evaluation required a judgement-based approach. While prescriptive criteria were not
developed, the analysis of each Member State’s report was undertaken with reference
to both the Directive and the questionnaire. For example, for questions 19 and 20 which
require an overview of the provisions in place to ensure compliance with Article 11, a
judgement was made based on the degree of information provided by Member States,
and whether sufficient detail was provided in order to understand what provisions are made within the permitting process in order to ensure compliance with the Directive.
2.4 Completeness of Member States’ reports
This section provides a summary of the assessment undertaken on the completeness of
Member State reports for each of the questions. This assessment is presented in Table
2.2 and has been conducted to give an overall picture on the quality of the information
reported by Member States during the considered reporting period and identify if there
are any significant gaps that may impact on the ability to assess implementation in accordance with the contract’s terms of reference.
All Member States provided an answer to the WID questionnaire. The following is noted with regards to the submissions:
Detail for a number of questions was sometimes lacking, particularly the questions
requesting details of the provisions made within the permitting process.
All of the Member States except from Italy and Luxembourg used the electronic
reporting tool (ERT) to submit their reports. Furthermore, Italy used the template
for the previous reporting period which has resulted in their reporting on two
additional questions (with respect to the measures in place to ensure that plants
are designed and equipped appropriately). This has not been flagged as an issue
because all the relevant information for the current reporting period has been
reported.
Hungary submitted two documents (one Excel file and one Word file) and the
responses do not always correspond with each other. Where gaps were identified
in the Excel file, we have used the Word document for the analysis.
Sweden and Cyprus provided additional files (Excel) with supportive data informing
their answers to the questionnaire2.
Belgium, Spain and the UK submitted a single report, but with information under
specific questions provided for individual regions.
Additionally, it is noted that there seems to be a technical problem with question 4,
which is not visible in the Word or Excel files provided for Hungary, Bulgaria,
Lithuania and Portugal. Technical problems when responding to this question were
also reported by Romania.
Despite the gaps and issues identified above, analysis of the completeness of reports
shows that, overall, the majority of Member States provided largely complete answers,
with very few unanswered questions. However, as illustrated in Table 2.2 answers to
the following questions showed a lower rate of incompleteness than responses for other
questions:
Question 1.1 (total number of plants falling under the scope of the WID, as well as
those that are permitted and recovering heat):
2 Providing additional files was not a requirement of the questionnaire.
WID Final Report
March 2016 15
In some Member States (UK, Finland, Netherlands, Portugal) it is unclear how
many plants were falling within the scope of the Directive at the end of the
reporting period. Other issues identified include gaps regarding the number of
plants that recover heat (Latvia), no distinction between incineration and co-
incineration (Belgium, Flanders), and inconsistencies between the information
provided under question 1.1 and question 1.2 with respect to the total number of
incineration and co-incineration plants (Germany and Spain).
Question 1.2 (list of plants falling under the scope of the WID, with further data on
type, location and energy efficiency for those where the capacity exceeds 2 tonnes
per hour).
Only Hungary has not responded to this question.
This question appears to be interpreted differently by Member States as regards
the plant with a capacity of 2 t/h or less:
o A significant number of Member States seem to have interpreted that
this question only requested the listing and description of those plants
with a capacity above 2 tonnes per hour, and consequently the number
of plants listed is lower than that reported in question 1.1. This has
been highlighted as a gap (amber) in Table 2.2.
o In other cases, the reports provided details for all plants reported under
question 1.1, which could mean that either all plants in that country
have a capacity above 2 tonnes per hour or that additional information
has been provided covering also smaller plants.
Only a few Member States (Cyprus, Czech Republic, Estonia, Greece, Netherlands
and Romania) have provided information on the latitude and longitude of the
plants for which details have been provided. The non-inclusion of this data has not
been highlighted as a gap in the completeness assessment table as although the
information is requested in the template provided by the Commission, it is not
explicitly requested by the questionnaire (2011/632/EU).
For some qualitative questions (notably 6, 15, 19, 20), several Member States
have answered by providing a reference to the relevant national legislation but no
details on the actual provisions contained in the legislation.
Detailed analysis of the completeness of each Member State’s report can be found in Appendix A.
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Table 2.2 Overview of the responses to WID implementation questionnaire from Member States
Question
AT BE BG CY CZ DE DK EE EL ES FR FI HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
1.1.a
1.1.b
1.1.c
1.1.d
1.2
2
3
4
5
6
7
8
8.1
8.2
9.1
9.2
10
11
12
13
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March 2016 17
Question
AT BE BG CY CZ DE DK EE EL ES FR FI HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
WID Final Report
March 2016 18
3. Analysis of Member States’ responses per question
3.1.1 Overview
This section provides an overview of the status of implementation of the WID across
the EU-27 in the period 2012-2013, following the order of questions in the
questionnaire. The overview is based on the Member State specific analyses
(presented in Appendix A), which were developed from the detailed question-by-
question analysis and completeness assessment. It draws conclusions on the common themes regarding implementation status as well as exceptions.
The text of each question in the Decision is presented at the start of each sub-section, in order to aid understanding.
It is noted that Croatia also submitted a report regarding the implementation of the
WID (while not yet being a Member State at that time). A short summary has been
included at the end of this section about the information provided by Croatia but their responses have not been considered in the question by question analysis.
3.1.2 Question 1: Number of plants and permits
1.1. Please give information on number of (a) plants, (b) permits issued in
accordance with Article 4(1), (c) plants that recover heat generated by the
incineration process heat recovery, and (d) the total permitted capacities of waste
throughput (tonnes/year) (broken down between incineration and co-incineration plants). Responding to 1(d) was optional for Member States.
Figure 3.1 provides an overview of the total number of plants within the scope of the
WID, the permits issued and the number of plants recovering heat as reported by
Member States, broken down by type of installation. The complete data set provided
by Member States on the four indents of question 1.1 is summarised in Table 3.1. A
more detailed and comparative analysis of the information provided by each Member State to these indents is provided in the following sections.
Figure 3.1 Question 1.1. Number and type of plants and permits in EU-27
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March 2016 19
Table 3.1 EU-27 data set on number of plants, permits issued and plants
recovering heat (question 1.1)
MS 1.1.a Number of plants 1.1.b Permits issued 1.1.c Plants recovering heat
To
tal
In
cin
era
tio
n
Co
-
incin
erati
on
No
n-
cate
go
ris
ed
To
tal
In
cin
era
tio
n
Co
-
incin
erati
on
No
n-
cate
go
ris
ed
To
tal
In
cin
era
tio
n
Co
-
incin
erati
on
No
n-
cate
go
ris
ed
AT 67 17 50 0 67 17 50 0 67 17 50 0
BE* 72 10 16 46 72 10 16 46 63 1 0 62
BG 10 3 7 0 10 3 7 0 7 0 7 0
CY 1 0 1 0 3 0 3 0 0 0 0 0
CZ 42 37 5 0 38 33 5 0 35 30 5 0
DE* 365 176 186 0 348 162 112 74 294 142 105 47
DK* 37 34 3 0 88 81 7 0 36 33 3 0
EE 4 3 1 0 4 3 1 0 4 3 1 0
EL 5 2 3 0 5 2 3 0 3 0 3 0
ES* 78 27 51 0 78 27 52 0 39 -- -- 39
FI* 24 10 14 0 24 10 14 0 24 10 14 0
FR 249 210 39 0 249 210 39 0 129 112 17 0
HU* 28 22 6 0 22 18 4 0 20 15 5 0
IE 20 15 5 0 16 11 5 0 15 10 5 0
IT 123 68 55 0 123 68 55 0 123 68 55 0
LT 3 2 1 0 3 2 1 0 3 2 1 0
LU 3 2 1 0 3 2 1 0 3 2 1 0
LV 11 6 5 0 11 6 5 0 1 1 0 0
MT 1 1 0 0 1 1 0 0 0 0 0 0
NL* 41 36 5 0 41 36 5 0 38 34 4 0
PL 119 51 68 0 119 51 68 0 73 43 30 0
PT* 14 6 8 0 3 1 2 0 17 8 9 0
RO 29 20 9 0 29 20 9 0 18 9 9 0
SE 138 2 136 0 82 1 81 0 138 2 136 0
SI 6 3 3 0 6 3 3 0 6 3 3 0
SK 23 17 6 0 23 17 6 0 23 17 6 0
UK* 159 116 43 0 159 116 43 0 143 -- -- 143
EU 1,673 939 688 46 1,628 911 597 120 1,322 562 469 291
Notes: I) ‘--‘Member State has not provided a response or reported that this information is not available;
‘*’ Inconsistencies or gaps were noted in the information provided by BE, DE, DK, ES, FI, HU, NL, PT, UK – please see below for further details.
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March 2016 20
Number and type of plants
Between 2012 and 2013 Member States reported a total of 1,673 plants under the
WID, of which 939 (56% of the total) were identified as incineration plants and 688
(41%) as co-incineration plants. The remaining 46 were not categorised. The
highest number of plants were located in Germany (22%), France (15%), the UK
(10%), Sweden (8%), Italy (7%) and Poland (7%). Together, these countries accounted for almost 70% of the total number of plants.
Belgium (Flanders) submitted data for the total number of plants but did not
distinguish between incineration and co-incineration plants due to some confusion on
datasets when merging responses from the three regions in Belgium. It remarked
that this issue will be addressed for future reporting. For the UK and Finland it was
unclear how many plants were falling within the scope of the Directive. Finland only
reported plants that incinerated more than 2 tonnes of waste per hour during the
reporting period, and the UK reported figures which are significantly lower than the
previous period and not consistent with the remarks provided. In view of this, the
analysis of this question refers to the response given for the previous reporting period
2009-2011 for the UK. All three issues were identified as a gap in section 2 of this report, but no follow up was made with the Member State.
The share of incineration and co-incineration plants varies between Member States, as illustrated by Figure 3.2. In sum:
Incineration plants: accounted for 56% of total plants and were present in all
Member States except Cyprus. Germany and France together accounted for
almost 46% of the total. Apart from Malta (one plant in total), Member States
with the highest share of incineration plants were Denmark (92%), the Czech
Republic (88%), the Netherlands (88%) and France (87%); and
Co-incineration plants: accounted for 41% of total plants, with Germany and
Sweden together accounting for 41% of the total. Apart from Cyprus (one plant
in total), co-incineration plants form the majority of plants reported in Sweden
(99% of the total), as well as Austria (75%).
Figure 3.2 Total number and type of plants by Member State (2012-2013)
Permits
The majority of Member States responded that the total number of permits issued in
accordance with Article 4(1) is equal to the total number of plants as reported under
question 1.1(a). Member States reported a total of 1,628 permits issued compared
to a total of 1,673 plants. The following reasons have been identified by Member States to explain why the figures do not always correlate:
WID Final Report
March 2016 21
1) The permits cover more than one plant or just the parts of a single plant
according to the definition of ‘permit’ in Article 3(12);
2) The Member State only reported the number permits that were issued during the reporting period; or
3) A permit had not been issued yet for certain plants.
Figure 3.3 shows that in all but eight Member States the total number of plants equals
the number of permits issued. Six Member States reported more plants than permits
(the Czech Republic, Germany, Ireland, Hungary, Portugal and Sweden), while
Cyprus and Denmark reported more permits than plants:
For Denmark, Ireland, Sweden and Cyprus this seems related to the fact that
Article 3(12) allows for a permit to “cover one or more plants or parts of a plant
on the same site operated by the same operator”. In Cyprus the only co-
incineration plant was covered by three permits. Denmark explained that some
plants were covered by more than one permit. Sweden reports that plants
within the same site are covered by a single permit. Ireland indicated in the
previous reporting period that there were two permits which covered four
plants. It is probable that this situation persisted during the current reporting
period although Ireland has not specified this.
The Czech Republic reported that four plants did not have a valid permit.
According to the Member State, these plants were no longer operational due to
the fact that they could not comply with technical operating conditions;
Portugal and Germany did not provide additional information to explain why the
total number of permits issued differs from the total number of plants (they
were not requested to do so in the questionnaire).The fact that Portugal
reported only three permits (compared to 14 plants) could be due to Portugal
interpreting that this question only requested the number of new permits that
had been issued in the reporting period 2012-2013 and not the total number of
permits.
WID Final Report
March 2016 22
Figure 3.3 Number of permits issued compared to number of plants by Member
State (2012-2013)
Heat recovery
Regarding question 1.1(c), heat was reported to be recovered in 1,322 plants, which
represents 79% of the total plants reported. Article 6 (6) stipulates that any heat
generated by the (co)-incineration process shall be recovered as far as is practical.
54% (191) of the 351 plants without heat recovery were located in two Member States: France (34%) and Germany (20%).
Of note, Portugal reported a greater number of plants recovering heat than the total
number of plants reported under sub-question 1.1a (i.e. 17 compared to 14). This
was identified as a gap in section 2 of this report, but no follow up was made with the Member State.
WID Final Report
March 2016 23
Figure 3.4 Number of plants with heat recovery (HR) by Member State (2012-
2013)
The proportion of plants recovering the heat generated is generally high across
Member States. Ten Member States (Austria, Estonia, Finland, Italy, Luxembourg,
Portugal, Sweden, Slovakia and Slovenia) reported that all plants within their
territories recovered the heat generated, and in Belgium, Denmark, the Netherlands,
and the UK, the proportion of these plants was above 85%. However, in three
Member States (France, Spain and especially Latvia), plants not recovering heat
represented more than 40% of the total number of plants reported. There was no
requirement for Member States to provide an explanation, but it would be useful to
obtain further insights as to the reasons for these high numbers.
Waste throughputs
13 Member States responded to the optional question 1.1d) on total permitted
capacities of waste throughputs, with some of them disclosing this information for
each category of plant and others noting that this information was only available for
some plants. Capacities reported amounted to a total of around 46 million tonnes of
waste treated per year with respect to 964 plants. There is no indication of how
capacity varies in scale between the different plants. More detail on waste capacities
is available in the Member State summaries in Appendix A.
List of plants
1.2. Please provide a list of all plants falling within the scope of Directive 2000/76/EC,
indicating the following information for each of those plants with a capacity of more than 2 tonnes per hour:
(a) whether it is an incineration or co-incineration plant and, for the latter, the
type of plant (cement kiln, combustion plant, other industrial facilities not covered by Annex II.1 or II.2 to Directive 2000/76/EC);
(b) for municipal solid waste incineration plants that carry out recovery operations
falling in Annex II, R1 to Directive 2008/98/EC of the European Parliament and of
the Council: the energy efficiency of the plant, calculated using the formula
provided in the footnote to Annex II, R1, of Directive 2008/98/EC.
In 17 cases, Member States only listed plants with a capacity above 2 tonnes per
hour, and consequently the number of plants listed is lower than that reported in
question 1.1. There are eight Member States that provided details for all plants
covered by the WID (as reported under question 1.1), which suggests that either all
plants in that country have a capacity above 2 tonnes per hour or that additional
information has been provided covering also smaller plants. Lastly, there were a few
WID Final Report
March 2016 24
cases where data reported under question 1.2 were not consistent with question 1.1
(Portugal, the Netherlands, Germany) or where no response was provided (Hungary).
As summarised in the figure below, Member States listed a total of 1,382 plants, representing 83% of the total number of plants reported under question 1.1.
As illustrated in Figure 3.5, 1,279 plants (93% of the total) were identified as either
incineration plants (680 accounting for 49% of the total) or co-incineration plants
(599 accounting for 43% of the total). Additional details were provided for most of
the co-incineration plants concerning the type of plant, as set out in Figure 3.5. A
detailed analysis on this question is presented in the Member State summaries in the Appendix to this report.
Figure 3.5 Number and type of installations for which details have been provided
(2012-2013)
Figure 3.6 Type of co-incineration plants by Member States (2012-2013)
WID Final Report
March 2016 25
Cement kilns co-incinerating waste (176 in total) were present in the majority of
Member States, with Germany and France accounting for most (33 and 29,
respectively). In Luxembourg, the Czech Republic, Bulgaria, Cyprus, Greece and Estonia all co-incineration plants were reported to be cement kilns.
Combustion plants co-incinerating waste (305) were only reported by 14 Member States, with 110 situated in Germany and 120 situated in Sweden.
12 Member States categorised 95 plants co-incinerating waste as other industrial
facilities not covered by Annex II.1 or II.2 to the WID. Most of these plants were
located in Germany (45% of the total). No further detail concerning these types of
plants was requested by the questionnaire and no further information was provided
by Member States.
3.1.3 Question 2: Definitions
2. Please describe any problems with the definitions in Article 3 identified when
implementing Directive 2000/76/EC. Provide specific information for each definition for which problems are identified.
Eight Member States reported issues with regards to the definitions given in Article
3 when implementing the Directive. Seven of these reported the same issues as in
the previous reporting period and only Hungary has raised new problems. These
problems are summarised below in Table 3.2; for more detail please refer to the Member States summaries in Appendix A.
Table 3.2 Overview of reported issues with the definitions given in Article 3
Definition Reported issues with definition
Waste As reported by the Member State in the previous reporting period, Sweden reported that some operators suggest "moving the borders of what is waste" - in order to enable combustion of material in plants not fulfilling the requirements of the WID. Sweden recommended reviewing the definitions of by-products and end-of-waste status under the Waste Framework Directive, and particularly suggested the determination of end-of-waste status criteria for "waste fuels".
Hazardous
waste
Spain reported that the definition only includes liquid and solid waste, therefore
excluding gaseous waste.
Mixed municipal waste
Romania suggested that it is necessary to clarify the term “untreated mixed municipal waste” used in Art. 7(4) but no further information was provided.
Spain indicated that there is a problem but no further details were provided on the nature of difficulties encountered with this definition.
In the Netherlands a distinction is made between waste from households and commercial waste
Incineration and co-incineration plant
Difficulties were encountered by Spain and Ireland in distinguishing between the two types of plants, specifically in ascertaining the main purpose of the facility (e.g. waste elimination, energy production, materials production).
Until now Swedish authorities were not required to decide whether a plant is an incineration or co-incineration plant based on the definitions of the Directive – although there were reported to be plans to make this mandatory by January 2013. The permitting authority has only made decisions on the type of plant regarding some plants that were using untreated mixed municipal waste as fuel and that should have been actually classified as co-incineration plants (instead of incineration plants).
Hungary reported that as pyrolysis plants are classified as incinerators they have experienced an issue with the burning of pyrogases resulting from the thermal treatment of waste at these plants whereby the process requires low reactor temperatures (compared to the legislation) and therefore the temperature related criteria cannot be met. Clarification was requested by the Member State as to whether or not this process should be regarded as part of the incineration process or not.
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March 2016 26
Definition Reported issues with definition
Romania also reported difficulties with regard to the inclusion of gasification and pyrolysis processes, and requested clarification of the condition “in so far as the substances resulting from the treatments are subsequently incinerated”.
Existing incineration or co-incineration plant
Bulgaria reported that existing incineration or co-incineration plants are interpreted as plants which started operating before the national legislation came into force.
Hungary found that if a permit is more than 5 years old, it will have already been reviewed in accordance with the integrated environmental permit rules. It is unclear how this relates to the definitions in Article 3 and what the problem is.
Nominal
capacity
Slovenia reported that it was unclear when and how confirmation by the operator of the
incineration capacities of the furnaces should take place. It also reported confusion regarding the fact that the calorific value is expressed as the quantity of waste incinerated in one hour. According to Slovenia it would probably “make sense to determine the lower and upper calorific value depending on the amount of individual waste material (e.g. waste oils, waste plastic, etc.)”.
3.1.4 Question 3: Mobile plants
3. Have any mobile plants received permits under Directive 2000/76/EC?
No mobile plants received permits under the WID during the reporting period.
3.1.5 Question 4: Categories of waste that have been co-incinerated
4. Please indicate the categories of waste that have been co-incinerated, broken down
by the type of co-incineration plant (cement kilns, combustion plants, other industrial
facilities not covered by Annex II.1 or II.2). For each co-incineration plant, indicate
the European Waste Catalogue codes (optional) as well as the permitted capacity granted for co-incineration (optional).
The electronic reporting tool enabled Member States to provide information on the
types of wastes co-incinerated in each of their co-incineration plants (as reported
under question 1.2). However, there seems to be a technical problem in some of the
reports provided, as the question is not visible in the Word or Excel files provided for
Hungary, Bulgaria, Lithuania and Portugal. Technical problems when responding to
this question were also reported by France and Romania, who noted that they could
only input information for a few plants.
Two Member States (Austria and Finland) did not provided a response and a few
Member States (Italy, Sweden and Luxembourg) did not respond to this question in
accordance with the electronic reporting tool and thus their responses cannot be
comprehensively summarised by the pre-defined categories of the questionnaire due
to the large amount of information provided.
For the remaining Member States with co-incineration plants in their territories,
wastes were generally identified using the European Waste Catalogue codes and in a
few cases total permitted capacities of waste co-incinerated were also reported (this
was optional). Where this information was available, information on the types of
wastes co-incinerated has been summarised in the Member State summaries in the Appendix.
3.1.6 Question 5: Annex V ELVs applicable
5. How many co-incineration plants do the emission limits provided in Annex V to
Directive 2000/76/EC apply to (i.e. where co-incineration of untreated municipal
waste is undertaken or more than 40 % of the heat release results from the combustion of hazardous waste)?
WID Final Report
March 2016 27
Only six Member States reported co-incineration plants subject to the emission limits
provided in Annex V in accordance with Article 7, with the rest indicating that such cases do not exist within their territories.
The provisions of Annex V applied to a total of 132 plants, a majority of which are
located in Sweden (72% of the total). For 67 plants Annex V applies due to co-
incineration of untreated municipal waste, whereas for 56 plants this is due to the
fact that more than 40% of the resulting heat release comes from the combustion of
hazardous waste. Member States were not requested to provide further information
about the type of co-incineration plant in question and as such this was not provided
in their responses.
Table 3.3 summarises the data received from Member States.
Table 3.3 Co-incineration plants subject to the emission limits in WID Annex V
MS Co-incineration plants subject to the emission limits
provided in Annex V of the Directive (% of total co-
incineration plants)
Due to co-incineration of untreated municipal
waste
Due to more than 40% of the heat release resulting from the combustion of
hazardous waste
DE 25 (17%) 3 22
ES 2 (4%) 0 2
IT 8 (15%) Not reported Not reported
LU 1 (100%) Not reported Not reported
SE 95 (70%) 64 31
SI 1 (33%) 0 1
Total 132 (19%) 67 56
Note: Italy and Luxembourg did not indicate why Annex V applied to these co-incineration plants.
3.1.7 Question 6: Permitting process
6. What provisions are made within the permitting process for:
(a) identifying the quantities and categories of hazardous waste that may be treated?
(b) the minimum and maximum flows of hazardous wastes to be treated?
(c) the range of calorific values of hazardous wastes permitted?
d) the restrictions on the content of pollutants, e.g. PCB, PCP, chlorine, fluorine, sulphur, or heavy metals?
All Member States responded to this question and it is noted that there is almost no
change to what was reported in the previous reporting period. Most Member States
have reported that aspects listed in Article 4 (5) of the Directive are specified in
permits in accordance to their national provisions. Almost all reports describe
national requirements regarding the content of permits granted to (co)-incineration
plants using hazardous wastes, but only some have indicated how these aspects are
determined in practice within the permitting process.
In addition, there are a few cases (Lithuania, Latvia, Estonia and Luxembourg) where,
instead of providing information on the applicable legal provisions, Member States
reported the actual conditions specified in permits granted to individual plants within
their territories. Greece and Sweden (on some aspects) responded by referring to
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March 2016 28
relevant parts of the national legislation, but without describing the provisions or
providing further details on what is specified in permits.
There are a number of instances where Member States reported issues concerning
the permitting process. Such issues are presented quantitatively in Figure 3.7 with details summarised in Table 3.4.
Figure 3.7 Specification of aspects prescribed in Article 4(5) based on Member
States’ responses
WID Final Report
March 2016 29
Table 3.4 Particular issues identified in Member States’ responses on Article
4(5)
Provision Issues identified
Quantities and categories of hazardous waste
Particular issues/derogations
Belgium (Flanders) indicated that if the waste categories are not specifically mentioned in the permit, the permit is restricted to the waste categories mentioned in the request for the environmental permit. Belgium (Wallonia) reported that quantities of waste are only specified “if required”.
Spain reported that in many cases the category or type of hazardous waste is specified, unless there is a viable re-use or recycling solution, or a list of types of waste which cannot be incinerated is compiled. According to the Member State, in most cases however, no amounts are specified.
Minimum and maximum flows of hazardous waste
Germany indicated that, depending on the type of plant, restrictions on minimum and maximum values are not imposed in some permits.
In Estonia and Spain mass flows have not been specified for all plants. Belgium (Flanders) indicated that if the mass flows are not specifically mentioned in
the permit, the permit is restricted to the mass flows mentioned in the request for the environmental permit.
The UK and the Netherlands explicitly indicated that minimum flows are not specified in the permit although in the case of the UK they have to be described in the permit application.
Unclear if provision is specified in the permits
Lithuania, France, Ireland and Italy appear to only mention the maximum mass flow value in the response.
In Cyprus and Poland, it appears from the responses given that this information has to be included in the permit application, but it is unclear if it is also specified in the permit.
Range of
calorific values of hazardous waste
Estonia provided information with regard to the range of calorific values of
hazardous waste for one incineration plant, rather that for all three plants operating in the Member State. See Appendix A for the detail.
Spain reported that in most cases, there are no special provisions in the authorisation process for determining the range of calorific values of authorised hazardous waste.
Belgium (Flanders) indicated that if the mass flows are not specifically mentioned in the permit, the permit is restricted to what is mentioned in the permit application.
Unclear if the provision is specified in the permits
France and Slovakia mentioned the minimum calorific value only. Germany reported the actual range of calorific values, rather than specifying the
permitting provisions. Finland did not explicitly report whether calorific values are specified in permits but
stated that the calorific value of the hazardous waste must be high enough for the ELVs not to be exceeded
In Cyprus and Poland, it appears from the responses given that this information has to be included in the permit application, but it is not reported whether it is also specified in the permit.
Restrictions on the content of pollutants
Estonia reported that permits do not lay down any restrictions on the content of pollutants but it is indicated that limit values have been specified for the amounts of pollutants emitted annually.
The Czech Republic indicated that in some cases permits specify the maximum allowable concentration of pollutants in waste (most commonly done for PCBs, thallium, mercury, chlorine and sulphur).
Belgium (Flanders) indicated that if the mass flows are not specifically mentioned in the permit, the permit is restricted to what is mentioned in the permit application.
Spain reported that, in most cases, there are no special provisions in the authorisation process for determining restrictions on pollutant content.
Unclear if the provision is specified in the permits
Finland did not explicitly report whether pollutant content restrictions are specified in permits but reported that the content of halogenated organic substances is limited to 1% when expressed as chlorine.
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March 2016 30
Provision Issues identified
The Netherlands reported that the Decree on the Incineration of Waste details (in Article 9.c) the restrictions on the content of pollutants but it is unclear if these are also specified in the permit.
In Cyprus and Poland, it appears from the responses given that this information has to be included in the permit application, but it is unclear if it is also specified in the permit.
Based on the responses provided it appears that all aspects required by Article 4(5)
are specified in permits in only nine Member States (Austria, Bulgaria, Denmark,
Hungary, Latvia, Luxembourg, Malta, Portugal and Romania).
The fact that some Member States explicitly stated or suggested that certain
information is not (always) required merits further investigation, as this does not
seem to be in accordance with the WID (and the Industrial Emissions Directive) which
requires that permits for plants that (co-)incinerate hazardous wastes “shall” contain all aspects listed in Article 4(5).
3.1.8 Question 7: Waste inappropriate for representative sampling
7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
19 Member States reported that some wastes have been found inappropriate for
representative sampling as summarised in the table below. The most frequently
reported types of waste (16 Member States) were medical, healthcare, clinical and
veterinary wastes that may have infectious or hazardous properties.
Seven Member States (Cyprus, Estonia, Finland, Ireland, Netherlands, Latvia and
Portugal) reported that no wastes inappropriate for representative sampling have been identified. Italy did not respond to this question.
The reasons provided by Member States were either that the waste in question posed
too significant a health & safety risk to operators to be used for representative
sampling, or that it was classified as infectious waste, making it inappropriate.
Table 3.5 Types of wastes reported as inappropriate for representative
sampling
Waste types Member States reporting
Medical, healthcare, clinical and veterinary waste that may be infectious or hazardous
AT, BE, BG, CZ, DE, DK, EL, FR, HU, LT, MT, PL, RO, SL, SK, UK
Rubber waste LU, LT
Peroxide DE
Carcinogenic, toxic and reactive wastes SE
Polyurethane foam, CFC-containing process air, creosote-treated
wood
DK
Other: tyres, wooden, textile and paper and cardboard packaging, waste concrete and concrete sludge, waste linings and refractories
LT
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March 2016 31
3.1.9 Question 8: Derogations from operating conditions
8. With regard to conditions for the furnace gas residence times and temperatures
as provided for in Article 6(1) and (2) of Directive 2000/76/EC, have any
authorisations to differ from those operating conditions been granted in accordance
with Article 6(4)? If the answer is ‘yes’, please indicate:
(a) How many authorisations have been granted?
(b) Where these data are available, please describe the reasoning for granting the
derogation(s) for a number of representative cases, as well as the following information:
(i) identification of the capacity of the plant;
(ii) whether it concerns an ‘existing’ plant as defined in Article 3(6) or a new plant;
(iii) the type of waste incinerated;
(iv) how it is ensured that no more residues are produced compared to a non-
exempted plant, and that the content of organic pollutants in those residues is
no more than expected from a non-exempted plant;
(v) the operating conditions laid down in the permit;
(vi) the emission limit values to be met by the plant (report only ELVs that
deviate from the ones set out in the Directive and indicate: Parameter, Limit
value (a range of ELVs may be provided), Unit, Averaging period, O2 % (if
different from WID) and the requirement to ensure that no more residues are
produced compared to, and that the content of organic pollutants in those residues is no more than expected from, a non-exempted plant).
Ten Member States (Austria, Belgium, Germany, Denmark, Hungary, Ireland, the
Netherlands, Sweden, Slovakia and the UK) indicated that competent authorities in
a number of cases applied derogations with respect to conditions for the furnace gas
residence times and temperatures. In total, 133 authorisations (8% of the total
number of plants reported) have been granted in accordance with Article 6(4). The
majority of authorisations (67%) were granted in Germany as shown in the table below.
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March 2016 32
Table 3.6 Application of Article 6.4
MS Number of authorisations granted in line
with Article 6(4)
Percentage that these
authorisations represent of the total number of
plants
Plants for which details has been provided (under
question 8b)
AT 5 7% 0
BE 4 6% 2
DE 89 24% 22
DK 17 46% 2
HU 2 7% 1
IE 1 5% 2
NL 2 5% 2
SE 6 6% 5
SK 2 9% 2
UK 3 2% 3
Total 133 8% 41
Note: Only Member States reporting cases have been included.
With the exception of Austria, all Member States concerned have provided
information on the derogations granted for some representative cases (including 31
derogations applied to existing plants and 10 to new plants). However, the level of
information provided by Member States varies, which prevents trends from being
identified or robust conclusions being drawn on the reasoning for such derogations,
and in many cases (16) the response provided is unclear as to what the derogation
is. The derogations specified relate to either the temperature permitted during the
start up or operating phases, the residence time for incineration, or a combination of
both (25). In addition, Denmark reported that an (unspecified) number of older
furnace lines in incineration plants are not required to have an auxiliary burner due
to technical difficulties and that biomass waste is used instead for start-up and shut-
down operations.
Due to the varying level of detail provided by Member States it is not possible to
assess whether these exemptions are in line with the WID as the detailed permit conditions per plant would be required for such an assessment.
Some Member States reported a number of methods to ensure that residues are not
produced in higher quantities or with higher content of organic pollutants compared
to non-exempt plants. These include the undertaking of trials and testing (UK), appropriate treatment before incineration (Slovakia) or slag analysis (Germany).
Details of the authorisations granted by each Member State in accordance with Article
6(4) and of the specific conditions imposed are presented in the individual summaries in the Appendix to this report.
3.1.10 Question 9: Exemptions from ELVs in cement kilns
9. For cement kilns co-incinerating waste, have any exemptions from the Emission
Limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?? If the answer is ‘yes’, please indicate the following:
WID Final Report
March 2016 33
(a) how many exemptions have been granted;
(b) where these data are available, please describe the reasoning for granting the
derogation(s) for a number of representative cases, as well as the following information:
(i) the capacity of the plant;
(ii) whether it concerns an existing or a new plant (taking into account Article 20(3) of Directive 2000/76/EC);
(iii) the type of waste co-incinerated;
(iv) the other operating conditions laid down in the permit
(v) the emission limits values to be met by the plants (Parameter, Limit value, Unit, Related Time Period);
All Member States replied to this question. A total of 21 Member States granted
exemptions from emission limits for cement kilns in accordance with Annex II.1
during the reporting period. However, it has not been possible to conclude on the
total number of cement kilns that apply different ELVs due to different interpretation
of this question by Member States (see Figure 3.8). Some Member States reported
the number of exemptions at pollutant level while others only reported the number
of exempted plants, independent of the number of pollutants for which derogations
were granted. In some cases (Austria, Germany, Italy and Poland) information
provided has been insufficient to determine which of the two interpretations has been
adopted and thus it has not been possible to provide uniform horizontal analysis across all Member States.
Figure 3.8 Total number of exemptions granted in accordance with Annex II.1
as reported by Member States
Note: I) Denmark has reported that exemptions from the SO2 ELV have been granted to 5 cement kilns but information provided under question 1 suggests that there is one cement kiln.
Based on information captured under question 9(b), and excluding those countries
where it has not been possible to interpret the reply, 79 cement kilns have been
granted exemptions out of a total of 176 cement kilns (44%) reported in question
1.2. Most of the total EU wide exempted plants (33%) were reported by France (26
out of a total of 29 kilns). In several Member States (Belgium, the Czech Republic,
WID Final Report
March 2016 34
Estonia, Greece, Luxembourg, Latvia, Slovenia and Romania) the number of plants
exempted equals the total number of cement kilns reported under question 1.2.
Under question 9(b), the majority of the reported exemptions referred to TOC (49% of the total number of derogations reported) followed by SO2 (47%) (see Figure 3.9).
Figure 3.9 Total number of exemptions by pollutant granted in accordance with
Annex II.1
Note: Austria and Italy did not report on any representative cases under question 9(b).
For seven plants in Romania, exemptions were granted with regards to NOx and dust
ELVs, even though the WID required these exemptions to end by January 2008.
Romania explained that the exemptions had been granted to an existing plant subject
to a transition period until 31 December 2013 for main activity 3.1 for the purpose
of complying with the IPPC Directive 96/61/EC as granted under the Accession Treaty
(2005)3. Upgrade measures to reduce dust and NOx emissions were implemented
before the deadline of December 2013 and consequently, under the new permit
issued in 2013 these exemptions were no longer applicable. Moreover, in Latvia,
exemptions were granted for SO2, TOC, dust and NOx for an existing plant on the
premise that emissions of TOC and SO2 are produced by raw materials and not as a
result of waste incineration. Although no explanation was provided by the Member
State as to how this relates to dust and NOx, Latvia reported that the ELV for NOx is 2,847 tonnes per year and that for dust it is 113.8 tonnes per year.
Regarding exemptions from the TOC and SO2 ELVs:
SO2 exemptions were reported by 15 Member States. The limit values reported
for SO2 range from 100 to a maximum of 2,500 mg/Nm³ as reported by
Belgium (Wallonia) for one plant that needs to add sulphur as a fluxing agent to
the white cement. The ELV that appeared most frequently in Member State
reports is 400 mg/Nm³, which is eight times greater than the ELV stated in the
WID (50 mg/Nm³); and
TOC exemptions were reported by 17 Member States. Emission limit values
between 12 and 140 mg/Nm³ are mentioned. The limit values most frequently
reported were around 50-100 mg/Nm³ which is 5-10 times higher than the WID
ELV (10 mg/Nm³). Sweden reports that no limit values have been set for TOC.
3 Protocol concerning the conditions and arrangements for admission of the republic of
Bulgaria and Romania to the European Union: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2005:157:FULL:EN:PDF
WID Final Report
March 2016 35
Belgium, Bulgaria, the Czech Republic, Ireland, Romania, and Slovenia have
explained that authorisations have been granted in cases where TOC and SO2
emissions do not result from the incineration of the waste fraction but instead
originate from the raw materials used for cement clinker manufacture (e.g.
limestone), due to their high content of organic matter and/or sulphur.
The questionnaire did not request Member States to provide information on how it
has been proven or documented that emissions result from other sources and not
from the waste incineration. Only a few Member States (e.g. Luxembourg, France, Greece) have provided details on how this is ensured.
Further details on the exceptions granted by each Member State and of the specific
conditions imposed are presented in the individual summaries in the Appendix to this report.
3.1.11 Question 10: Differing ELVs for release to air
10. For releases to air from incineration and co-incineration plants, have emission
limit values different to those given in Annex II or Annex V, as appropriate, been set? If the answer is ‘yes’ and where these data are available, please identify:
(a) the plants to which they apply, i.e. incineration or co-incineration plants, and for the latter indicating the type of plant;
(b) which of these plants are ‘new’ or ‘existing’;
(c) the pollutants to which the limit values apply and the limit values set;
(d) why these limit values are applied;
(e) the emission monitoring regime for these pollutants (continuously or
discontinuously, and for the latter indicating the frequency).
All Member States responded to these questions and the responses provided are quite
similar to the previous reporting period. Note that although the question only refers
to the total Emission Limit Values (ELVs) set in Annex II and Annex V, Member States
responded also with respect to additional ELVs (i.e. including the mixing rule). All
information provided by Member States has been incorporated within the analysis here.
In accordance with the Directive, Member States may choose to set ELVs for releases
to air from incineration and co-incineration plants that cover additional pollutants to
those stipulated in the Directive, or that are more stringent to those specified. As
illustrated by Figure 3.10, 13 Member States responded that ELVs are the same as
those determined in Annex II and V of the WID. A total of 14 Member States indicated
that different or additional air emission limit values (ELVs) have been set. Additional information on the application of such limits, was provided by all Member States.
WID Final Report
March 2016 36
Figure 3.10 Additional or more stringent Emission Limit Values for releases to air
More stringent ELVs set to those listed in Annex V or Annex II to the WID
Annex II sets out total ELVs that have to be complied with by cement kilns (II.1),
combustion plants (II.2) and other industries (II.3) not covered under II.1 and II.2.
Annex V sets the ELVs for incineration plants.
Figure 3.11 presents an overview of the parameters for which ELVs set are more
stringent to those specified in Annexes II and V to the WID. The information
presented in Figure 3.11 excludes the different ELVs used in Italy, the Netherlands
and Sweden due to incomplete or incomprehensible data reported. The issues with
the information provided are summarised as follows:
Sweden referred to the response provided in the last reporting period where it
provided an additional file with detailed information on the ELVs applied to 108
plants, all of which were more stringent. Information contained in this file has
not been summarised here due to the difficulty in extracting the data and the
fact that this file is not translated.
The Netherlands noted that more stringent ELVs for several pollutants are
contained in several permits for incinerators and that further information can be
requested at the Ministry of Infrastructure and the Environment on such values.
Italy indicated that different ELVs have been applied in 2 incinerators and one
co-incineration plant with regards to the following pollutants: total dust, TOC,
NOx, SO2, HCl but further detail was not provided.
Further details on the ELVs specified by each Member State and of the specific
conditions imposed (i.e. averaging periods) are presented in the individual summaries in the Appendix to this report.
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March 2016 37
Figure 3.11 Parameters for which more stringent ELVs for pollutants to air are
specified (by number of cases reported)
Note: (I) the chart shows in brackets the Member States that have reported different ELVs; (II) Information reported by Italy, the Netherlands and Sweden has not been included (see text for explanation).
In total, more stringent ELVs to those set in the WID have been reported for
incineration plants by seven Member States (Austria, Belgium, Denmark, Germany,
Slovenia, Spain, and the UK). For co-incineration plants, seven Member States
(Austria, Belgium, Denmark, Germany, Ireland, Slovakia and Spain) reported
differing ELVs. NOx is the parameter for which ELVs most commonly differ from the
ELVs specified in the WID with significantly more cases reported by Member States
compared to other parameters (a total of 23 cases reported compared to 9 for dust
as the second most common parameter with more stringent ELVs).
The above ELVs are set as plant specific ELVs (commonly applying to existing plants)
which take into account the techniques employed by the plant (e.g. where techniques
have been adopted that enable more stringent ELVs to be met) or the existence due
to local environmental conditions or quality standards that require the adoption of
stricter limits. As an example, Austria reported that, on the basis of best available
techniques, stricter NOx ELVs have been established for two incineration plants, as follows:
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March 2016 38
A stricter ELV of 100 mg/m3 (daily average value) for an existing installation on
the basis that the design for new installations with a capacity exceeding 6
tonnes/ hour emit 70 mg/m3. This compares to the ELV set in Annex V of 200
mg/m3 (daily average value) for installations with a capacity exceeding 6
tonnes/ hour.
A stricter ELV of 100 mg/m3 (half-hourly average values) for an existing
installation. This compares to the ELV set in Annex V of 200 mg/m3 (half-
hourly average values) for 97% of the measurements taken and 400 mg/m3
(half-hourly average values) for 100% of the measurements taken. The
response provided does not specify whether or not the ELV applies to 100% or
97% of the measurements taken.
Although the reported ELVs appear to be more stringent than those specified in the
WID, additional information on the plants concerned (e.g. capacity) or on permit
conditions would be required to accurately determine this, especially regarding co-
incineration plants as there might be cases where Annex V would apply for such plants.
A more detailed assessment is included in the Member State summaries in the
Appendix.
ELVs set for pollutants not listed in Annex V or Annex II to the WID
Annex II to the Directive provides a formula to enable the determination of ELVs
where the pollutant has not been specified in the Annex – this is referred to as the
mixing rule. Member States were not requested to submit information concerning
their application of the mixing rule, and thus where ELVs for additional pollutants
have been set, no detail concerning the application of the mixing rule have been provided.
ELVs for additional pollutants were reported by nine Member States (Austria,
Belgium, the Czech Republic, Denmark, Germany, France, Ireland, Slovakia, and
the UK), as shown in Figure 3.12. Information received from the Netherlands and
Sweden has not been incorporated here, as explained in relation to Figure 11. Italy
only indicated that air limit values have been set for additional pollutants in two
incinerators and one co-incineration plant with regard to PAH, PCB and NH3, but
further detail was not provided and so this information is not included in Figure
3.12.
WID Final Report
March 2016 39
Figure 3.12 Additional air pollutants to those specified in the WID for which ELVs
have been specified
Note: (I) the chart shows in brackets the Member States that have imposed such ELVs; (II) Information reported by Italy, the Netherlands and Sweden has not been included (see text for explanation) (IV)
As shown in Figure 3.12, the additional pollutants most frequently reported are
ammonia (NH3), polychlorinated biphenyls (PCBs) and polycyclic aromatic
hydrocarbons (PAHs). Ammonia ELVs were reported for plants equipped with
selective (non-)catalytic reduction (SCR/SNCR). For plants burning certain types of
waste (e.g. PCB-containing oil or creosote-treated wood) limits for PCBs and PAHs were reported by some Member States (Denmark, Czech Republic).
It is not possible to conclude on the total number of plants to which these ELVs have
been applied as the question required to provide this information stipulates that the
information is only required ‘if available’ and Member States have only reported on a
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March 2016 40
number of representative cases. While in some Member States the ELVs seem to be
applied to individual plants, in other Member States (e.g. Germany and France) limits
for certain pollutants are prescribed by national legislation and thus apply for all
plants or for all plants of a certain type. For example, France reported that the
national emission limit value for ammonia emitted at both co-incineration and
incineration plants is 30 mg/m3, although cement kilns may exceed this value up to
a maximum of 100 mg/m3 provided that the operator justifies use of BAT and that
any excess ammonia in the emissions is linked to ammonia content in the raw
materials used (limestone, clay, etc.).
Detailed information on the application of the above ELVs is presented in the summaries of Member States’ responses in the Appendix.
3.1.12 Questions 11 and 12: ELVs for discharges of wastewater from flue
gas cleaning equipment
ELVs for pollutants in Annex IV for discharges of wastewater from flue gas cleaning
equipment to the aquatic environment
11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission
limit values for discharges of wastewater from flue gas cleaning equipment to the
aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
All Member States responded to this question, showing a situation which is similar to
what was reported in the previous reporting period. In most cases, Member States
reported that the ELVs for the pollutants listed in Annex IV are identical to those
specified (18: Belgium, Bulgaria, Cyprus, the Czech Republic, Estonia, Finland,
France, Greece, Hungary, Malta, the Netherlands, Poland, Portugal, Romania,
Slovenia, Slovakia, Spain, and the UK).
Note that although Hungary reported that the ELVs for the pollutants listed in Annex
IV are identical, it specified a different ELV for total suspended solids in response to
question 12. Hungary reported under question 12 that an ELV for suspended solids
(1,000-1,500 mg/l) applies to an existing incineration plant. This is much higher
than the ELV specified in Annex IV. Hungary explained in its response that the value
for total suspended solids set in the appendix to the permit was determined on the
basis of 2010 self-monitoring results available at the Inspectorate, taking account of
the emission levels achievable by the permit holder. This response indicates that the
Directive has not been appropriately implemented in Hungary and should be
investigated further, as flagged later in the report. This inconsistency in reporting
was noted in the completeness assessment but not followed up by the European
Commission with the Member State.
In response to this question, three Member States indicated that there are no facilities
operating in their Member States in which waste water is produced by flue gas
cleaning and discharged to the aquatic environment (Latvia, Lithuania and
Luxembourg). Moreover, it is expected that no such facilities operate in Estonia in light of the Member States response to question 13.
An inconsistency in the reporting by Luxembourg has been noted in that a different
ELV for suspended solids is specified in response to question 12. Luxembourg
reported additional ELVs laid down for two plants, including an incineration plant (due
to the discharge from the waste water treatment plant treating plant water), and a
co-incineration plant (due to regenerated water from ion exchangers and rain water).
Among other parameters, the incinerator has to comply with an ELV for suspended
solids (30 mg/l), and the co-incinerator has to comply with and ELV for suspended
solids (50 mg/l) and arsenic (0.1 mg/l). While the ELV for arsenic and its compounds
is more stringent than Annex IV, the ELV for suspended solids is higher in the case
of the co-incinerator, and potentially higher in the case of the incinerator depending
WID Final Report
March 2016 41
on the frequency of measurements (not specified in the Member State response).
This response indicates that the Directive has not been appropriately implemented in
Luxembourg and should be investigated further, as flagged later in the report. This
inconsistency in reporting was noted in the completeness assessment but not
followed up by the European Commission with the Member State.
Six Member States (Austria, Germany, Denmark, Italy, Ireland and Sweden) reported
that ELVs that are determined differently to Annex IV of the Directive. As shown in
Table 3.7, stricter ELVs have been set in all cases except for Ireland. In Ireland, the
difference with the ELVs set out in the WID is not clear as the values reported are
the same as those set out in Annex IV. Ireland reported that in the plant concerned
emissions from flue gas cleaning are mixed with other effluents and treated
collectively prior to discharge, but it is not clear what this implies in terms of the
ELVs. Lastly, Italy reported that ELVs for emissions to the aquatic environment are
determined differently by taking measurements at the points of discharge of waste
water, but no further information is provided on how the ELVs are different from those in Annex IV.
An overview of the parameters and limit values reported in response to question 11
is presented in table below alongside the ELVs specified in Annex IV. Where
information on the averaging period is available it has been summarised in the notes
to the table.
Table 3.7 Different ELVs to those specified in Annex IV of the WID set by
Member States
Polluting Substances ELV in
Annex IV WID
Reported ELV (mg/l [ng/l for dioxins and furans])
AT DEI DKII IEIII SEIV
Total suspended solids 30 mg/l (95%)
45 mg/l (100%) 30 30
30-45
2-40
Hg 0.03 mg/l 0.01 0.03 0.003- 0.01 0.0001-0.015
Cadmium and its compounds (Cd)
0.05 mg/l 0.01 0.025- 0.01 0.0001-0.015
Thallium and its compounds (Tl)
0.05 mg/l 0.040- 0.01 0.001-0.03
Arsenic and its compounds (As)
0.15 mg/l 0.1 0.1 0.040- 0.1 0.002-0.1
Lead and its compounds (Pb)
0.2 mg/l 0.1
0.01- 0.02
0.056- 0.02 0.005-0.1
Chromium and its compounds (Cr)
0.5 mg/l 0.2 0.01- 0.01 0.005-0.3
Copper and its compounds (Cu)
0.5 mg/l 0.2 0.029- 0.02 0.5 0.02-0.2
Nickel and its compounds (Ni)
0.5 mg/l 0.1 0.083- 0.1 0.02-0.1
Zinc and its compounds (Zn)
1.5 mg/l 1 1 0.86- 0.1 1.5 0.03-0.7
Dioxins and furans 0.3 ng/l 0.1 0.3 0.1
Note: I) Germany reported that stringent limits apply in some federal states to meet their stricter water quality requirements. These apply for 24h (mixed) samples for all pollutants
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March 2016 42
II) ELVs in Denmark apply as yearly averages for all pollutants; III) See comment in text. ELVs in Ireland apply as daily averages for suspended solids, monthly averages for Cu and Zn and in relation to bi-annual sampling for dioxins and furans IV) Sweden reported the ranges of stricter ELVs that have been set in the individual permit conditions
for a number of plants. These apply as monthly averages for total suspended solids, for every measurement for dioxins/furans and as quarterly, monthly and yearly averages for the rest.
The questionnaire did not request Member States to report the number of plants to
which such ELVs have been applied. Therefore, it has not been possible to conclude
in most cases whether the ELVs reported have been set by national legislation for all
plants or on a case-by-case basis in the permits for a number of plants. It has only
been possible to determine the number of plants concerned for Ireland (one plant),
Sweden, which indicates for each pollutant the number of plants subject to stricter
ELVs (e.g. 62 plants have stricter cadmium ELVs) and Denmark, which indicates that
the stricter ELVs apply to all plants.
The lowest ELVs for all pollutants have been established in Sweden due to the
consideration of BAT-associated emission levels and the fact that the receiving
environment is particularly sensitive or vulnerable to eutrophication. BAT-associated
emission levels were also mentioned by Austria as a reason for such values.
ELVs for pollutants not listed in Annex IV
12. If emission limit values have been set for pollutants discharged to water, in addition to the pollutants specified in Annex IV:
(a) to which pollutants do these apply and what are the limit values set?
(b) to which plants do they apply (i.e. incineration or co-incineration, ‘new’ or ‘existing’)?
(c) why are these limit values applied?
All Member States responded to this question, showing a situation which is quite similar to what was reported in the previous reporting period.
In addition to the substances in Annex IV of the Directive (as listed above in Table
3.7), ELVs for additional pollutants have been reported by Austria, Germany,
Denmark, Italy, Sweden, Hungary, Luxembourg, Poland, France and Slovenia, as
presented in Table 3.8. Note that the pollutants in bold highlight those mentioned
by at least three Member States. Also note that Austria, Hungary, Spain and
Luxembourg have not provided information on the averaging period, which limits
comparability across Member States. Where this information is available it has been summarised in the notes to the table.
Italy stated that additional pollutants to those listed in Annex IV have been assigned
ELVs by operators for existing incinerators releasing discharge to sewers after
chemical and physical treatment. The reason given for their inclusion is that they
require a more restrictive limit value. However, no detail concerning the pollutants
or their respective ELVs has been provided by the Member State and so this is not
included in the summary table below. In addition, the information reported by Poland
is not included in the analysis below, rather it has been incorporated within the
analysis for question 13 as it was found to relate to operational parameters and not pollutants.
Moreover, it was noted that Spain reported that no additional pollutants to those
listed in Annex IV have been assigned ELVs. However, under remarks, the Member
State referred to the answer provided in the last reporting period, in which
information for two incineration facilities was provided where ELVs to additional
pollutants were applied for BOD5, COD, pH, and settleable solids (see section 2.5.11
of previous report). It is therefore unclear whether these continue to be applicable.
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March 2016 43
Table 3.8 ELVs set for additional parameters to those specified in Annex IV to
the WID by Member States
Parameter ELVs for additional pollutants (mg/l, unless otherwise indicated)
AT DE1 DKII FR HU LUIII SEIV SIV
Ammonium (NH4-N) 10 10VI 8VI 10-120 200VI
Antimony (Sb) 0.2
Biological Oxygen Demand (BOD5)
25 (24h) 30 (2h)
CaCl2 7000
Chemical Oxygen Demand (COD)
90 80-150 125 150 100 (24h) 140 (2h)
1600
Chloride (CL-) 25000 0.1
Cobalt (Co) 0.5 0.005-
0,01
Cyanide (CN-) 0.1
Fluoride (F) 20 30 15 20
Free Cyanide 0.1 0.1 0.1
Manganese (Mn) 1
Oil 10
Oil index 10
Organically bound halogens (AOX)
0.1 0.2 - 0.3 5 0.1 0.2 0.5
PAHs 0.0
3 0.1
Phenol index 0.3
Phenols 0.1 10
Settleable solids 0.3 ml/l
(after 2h)
Silver (Ag) 0.005 0.01
Sulphate (SO42−) 2500 2000 300
Sulphide (S2−) 0.2
Sulphite (SO32−) 20 20
Tin (Sn) 0.5
Total bound nitrogen 50
Total hydrocarbons 10 5 5
Total nitrogen 19 15-120
Total Organic Carbon (TOC)
30 40 75
Total Phosphorus 2 0.1 – 1.5
Toxicity inhibition of nitrification
20%
Toxicity to fish 2 dilution
factor
Vanadium (V) 0.5
Notes: I) Germany reported the daily average value and a 2 hour average value for total hydrocarbons; COD, F, SO4
2-, SO32−, total phosphorus; 1 weekly 2 h mixed sample for total nitrogen, Cl-, COD, SO4
2-, SO32−, total
phosphorus; For toxicity to fish it is reported as unit “dilution factor” but it is not clear what this means; II) Denmark reported yearly averaging for all pollutants.
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III) Luxembourg reported daily averaging for settleable solids, suspended solids, BOD5 and COD. IV) Sweden reported yearly averaging for Ag and Total nitrogen; monthly averaging for TOC, oil index, phenols, COD; maximum value for toxicity inhibition of nitrification and free cyanide and monthly or yearly averaging for the rest.
V) Slovenia reported daily averaging for all pollutants. VI) Member States reported the ELV in relation to ammoniacal nitrogen (NH3-N) but this has been incorporated here as it can be used interchangeably with NH4-N in this context.
As shown in Table 3.7, parameters reported by three or more Member States include,
in decreasing order of frequency: COD, AOX, NH4-N, SO42-, TOC, and total
hydrocarbons. However it is not possible to conclude on the total number of plants
to which these applied based on the information submitted by Member States.
Some of the above ELVs seem to be applied in individual cases depending on the
characteristics of the plant and the receiving environment. In this respect,
minimisation of eutrophication problems was mentioned as a reason for limiting
emissions of phosphorus and nitrogen compounds by Sweden and Denmark. In other
Member States (e.g. Austria, Germany and France) it appears that limits on emissions
of certain pollutants are prescribed by national waste water legislation in force for all plants or certain types of plants.
The reasons why these additional parameters have been established are not made clear in the information reported by Member States.
Detailed information on the application of the above ELVs has been compiled in the
Member States summaries in the Appendix.
3.1.13 Question 13: Operational control parameters for wastewater
discharges
13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for wastewater discharges?
Mandatory parameters as mentioned Article 8(6)(b) (pH, temperature and flow)
All Member States responded to this question, with the majority of Member States
reporting the same as in the previous reporting period.
As shown in Table 3.9, most Member States (17) confirmed the inclusion of the three
mandatory parameters in permits, with Member States highlighted in red referring to those that do not confirm the inclusion of the three mandatory parameters.
Three Member States (Estonia, Lithuania and Latvia) did not report any of the
required operational parameters and specified that this is because there are no waste
water discharges from the flue gas cleaning equipment in these Member States.
Of note, although Luxembourg previously reported that there are no facilities
operating in its Member State in which waste water is produced by flue gas cleaning
and discharged to the aquatic environment (in response to question 11), operational parameters were reported in response to this question.
WID Final Report
March 2016 45
Table 3.9 Operational parameters for the discharge of waste waters reported
per Member State
MS pH Temperature Flow
AT
BE
BG
CY
CZ
DE
DK
EE n/a n/a n/a
EL
ES
FI
FR
HU
IE
IT
LT n/a n/a n/a
LU
LV n/a n/a n/a
MT
NL
PL
PT
RO
SE Not all plants Not all plants Not all plants
SI
SK
UK
EU-27 21 19 19
There are five Member States (the Netherlands, Poland, Luxembourg, Cyprus and
Greece) where one or two of the required parameters have not been reported (cell
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March 2016 46
left blank in electronic reporting tool or parameter was not mentioned in report
submitted otherwise). In most of these cases the Member State did not indicate
whether such parameters are included in the permitting process. Cyprus mentioned
that although no wastewater is discharged, temperature and pH have been to be
monitored in cooling water discharged into the sea. This indicates that the Directive
has not been appropriately implemented in these Member States and should be investigated further, as flagged later in the report.
In addition, it is unclear from the response provided by Sweden whether or not the
Directive has been appropriately implemented. Sweden reported that the situation
has not changed compared to the previous period and that national legislation
stipulates that the supervisory authority is authorised to decide on the parameters
specified in permits, which had been regulated in individual permits in the following
way: pH in 72 plants; temperature in 14 plants and flow in 11 plants. Thus, although
the WID stipulates that such parameters should be set in all permits, it appears that this is not the case for all Swedish plants.
Poland did not indicate “flow” as a mandatory parameter for the permitting in their
response to question 13, but indicated under question 20 that the flow, together with temperature and pH, should be measured at the point of discharge of waste waters.
The fact that there are still some Member States that explicitly stated or suggested
that some parameters are not (always) set in permits should be further investigated as this does not seem to be in accordance with the WID’s requirements.
3.1.14 Question 14: Provisions to protect soil, surface and groundwater
14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
All Member States responded to this question and only six of them (Belgium, Bulgaria,
Estonia, Greece, Hungary and Slovenia) reported changes compared to the previous
reporting period (2009-2011). Note that Portugal did not provide any details concerning the provisions.
While four Member States merely provided additional detail concerning these
provisions (see section 2.5.14 of the previous report), substantive legislative changes
have only been reported by Belgium (Wallonia) and Slovenia, though in the latter
case no further information on the applicable provisions is provided.
The provisions reported by Member States to protect soil, surface and groundwater
are as follows (note that it is unclear from the responses given how many plants have applied these provisions):
Separate collection of pollution waters (10: AT, BE, CY, DE, EE, FI, FR, IT, MT,
NL);
Impermeable waste storage or handling areas (12: BE, CY, CZ, DE, DK, EE, EL,
ES, FI, FR, RO, SE);
Coverage of waste storage and handling areas (8: AT, BE, DK, EE, ES, IE, RO,
SE);
Internal inspections and leak tests (6: CZ, DK, ES, MT, RO, SK)
Specific regulations on handling of harmful substances (6: BG, CY, CZ, EL, SE,
SK);
Specific provisions regulating acceptance and storage of waste (4: BE, CY, RO,
SE);
Discharge limits (4: BE, HU, MT, SE);
Monitoring of wastewaters, groundwater, and soil quality (3: DE, EE, RO);
WID Final Report
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External inspections by authorities or other officials (2: ES, MT);
Requirement for an emergency plan (2: CZ, SK);
Plants designed in such a way as to complete avoid waste spreading (2: EL,
RO);
Requirement for a secondary storage tank (2: CY, DK);
Protocols in case of spills or accidents (2: HU, SK);
Easy access to wastewater reservoirs and drainage systems (MT);
Waste storage capacity dimensioned in such a way that storage periods are
limited (BE);
Areas designed in such a way that cleaning is facilitated (BE);
Application of technical rules and guidelines (ES);
Use of Best Available Techniques (EL);
Appropriate sanctions (IT);
Qualified staff with responsibility over water contamination (DE); and
Provisions of flammable liquids storage (DE).
3.1.15 Question 15: Provisions to ensure sufficient storage capacity for
water to be tested and treated
15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
All Member States responded to this question. Only four Member States (Greece,
Hungary, the UK and Slovakia) provided a different response compared to the
reporting period 2009-2011 and thus the analysis from the previous reporting period is still much applicable.
Overall, responses provided by Member States were very varied, with only 14
Member States (Belgium, Bulgaria, Cyprus, Germany, Denmark, Finland, Spain,
France, Hungary, Ireland, Luxembourg Slovakia, Romania and the UK) describing
criteria in place. Responses provided by the remaining Member States referred either
to national legislation, permit conditions or were insufficient to determine what
criteria are in place (for example by providing information not relevant to storage
capacity). Estonia, Greece and Latvia stated that storage capacity for water is not
applicable, and Latvia and Estonia reported that this is due to the fact that there were
no water discharges from flue gas cleaning. In particular, Estonia further clarifies that this is due to the use of a semi-dry scrubbing system.
The following information on provisions in place to ensure sufficient water storage
capacity was reported by Member States:
Calculation of the storage capacity on a basis of standard NF – EN 752-2 or
other equivalent standard (Belgium). The reported standard concerns Drain and
Sewage Systems Outside Buildings4;
Calculation of the storage capacity on the basis of hydraulic calculations
(Luxembourg, Bulgaria, Spain, Romania, UK). The following specific parameters
have been reported: maximum rainfall in the region of the facility (Bulgaria,
Spain), modelled rainfall predictions (Ireland), water consumption and
wastewater generated per type of waste (Romania, UK) and required for fire-
fighting operations (Bulgaria);
Requirements for the size of the storage area specified in the national legislation
(Spain, France);
4 http://infostore.saiglobal.com/EMEA/Details.aspx?ProductID=1024802
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Requirements for secondary storage (Cyprus);
Requirement for the operator to undertake a risk assessment in the permit
application to determine the maximum volume that would be held under a worst
case scenario (UK);
Design of the plant in order to ensure sufficient water storage capacity
(Denmark);
Installation of a storm sewer so that in the event of contamination, automated
pumping is shut down and the water is then treated (Slovakia);
Requirement for the documentation of the plant to include a clear procedure for
determining adequate storage capacity for testing or treatment of contaminated
water (Slovakia); and
An obligation on the operator to ensure specific measures are in place (Finland).
3.1.16 Question 16: Residues
16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
All Member States responded to this question but only three Member States
(Germany, Slovenia and Bulgaria) reported changes compared to the last reporting period 2009-2011.
A summary of those responses which described measures or quoted relevant
legislation is presented in Table 3.10 (for more detail see the individual Member States summaries in Appendix A as well as section 2.5.16 of the previous report).
Answers have been assessed against the following provisions of Article 9:
minimisation in amount and harmfulness, recycling, safe transport of dry residues
and appropriate testing of residues. It should be noted that it was not a requirement
of the questionnaire to report against each of these provisions.
Responses by Bulgaria, Hungary, Italy, Poland, Austria, Belgium and Malta mentioned
all requirements of Article 9. The remaining responses covered only some
requirements of Article 9, with the most frequently reported being the minimisation
in amount and harmfulness, and recycling of residues (mentioned by 12 and 9
Member States respectively). Safe transport of dry residues was reported by three Member States, and testing by four Member States.
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Table 3.10 Summary of MS responses which described measures or quoted
relevant parts of the legislation
MS
Provisions made within the permitting process
Remarks
Min
imis
ation
in
am
ount
and h
arm
fuln
ess
Recycling
Safe
tr
ansport
of
dry
resid
ues
Appro
priate
te
sting
of
the r
esid
ues
CZ Yes Yes Yes In these Member States the responses did not cover all provisions of Article 9.
DE Yes Yes
DK Yes Yes
EL Yes
ES Yes Yes
FI Yes Yes
SK Yes Yes Yes
RO Yes Yes Yes
LV Yes
LT Yes Yes
FR Yes Yes
NL Yes Yes Yes The quoted text of the national legislation does not contain
reference to the recycling of residues.
CY Yes Cyprus reported that all residues are recycled within the process which may mean that other provisions of the Article are not applicable.
SI Yes Based on the text of national legislation quoted, it appears that
recycling, safe transport of residues and testing are not covered.
HU Yes Yes Yes Yes Based on the descriptions provided, all provisions of Article 9 are covered in these Member States.
BG Yes Yes Yes Yes
IT Yes Yes Yes Yes
PL Yes Yes Yes Yes
AT Yes Yes Yes Yes Based on the text of national legislation quoted in the response,
all provisions of Article 9 are covered.
MT Yes Yes Yes Yes
BE Yes Yes Yes Yes Not all provisions of Article 9 have been reported by all regions
of Belgium.
Note: Yes – The MS describes provisions related to that aspect in line with Art. 9 or refers to national legislation
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3.1.17 Question 17: Measurement of pollutants to air
17. Are the requirements of the permit for the measurement of pollutants to air and
process operation parameters identical to those set out in Article 11(2)? If not, please provide information detailing the following:
(a) reason for deviating from Article 11(2), referring to the derogation possibilities mentioned in Article 11(4) to (7);
(b) the pollutant or parameter concerned and the measurement requirement
imposed.
All Member States responded to this question. Derogations from the requirements
under Article 11(2) apply in 15 Member States (Austria, Belgium (Flanders and
Wallonia), Cyprus, Denmark, Estonia, France, Germany, Hungary, Ireland, the
Netherlands, Slovakia, Slovenia, Spain, Sweden, and the UK) – as presented in Figure
3.13.
Of these Member States, only Germany and Sweden responded that all derogations
(under Article 11((4-)(7)) are applied in their Member States). France also indicated
that where the derogation to not continuously monitor hydrogen fluoride (HF) has
been applied (i.e. where hydrogen chloride (HCI) is treated so as to ensure that the
established emission limit value is not exceeded), HF emissions must still be measured at least twice a year.
More stringent monitoring requirements apply in Austria, Belgium, Germany and
Spain. With the exception of Spain, these are summarised by air pollutant in Table
3.11. The response provided by Spain has been excluded from Table 3.11 because
it is unclear in which sense the measurement requirements are stricter. Spain
reported that more stringent monitoring requirements apply to F emissions in a plant
in the region of Murcia. The equipment installed cannot monitor emissions from
substances that contain F continuously due to the temperature at which it operates, and therefore no fluoride emissions are permitted.
Figure 3.13 Reported derogations for the requirements for air pollutant
measurements and process operation parameters set in Article 11(2) of the
Directive
Notes: Belgium submitted three responses (Brussels, Flanders and Wallonia), which are considered individually in the analysis above.
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Table 3.11 More stringent or additional requirements for air emission
measurements reported by Member States
Parameter More stringent or additional requirements
Mercury (Hg) Austria introduced a requirement for continuous monitoring of Hg emissions
to air, unless it can be established that the content of Hg in burned waste does not exceed 0.02mg/MJ. The continuous measurement may also be omitted if the emission values can be demonstrated not to exceed 0.01 mg/m3.
Germany introduced a requirement for the continuous measurement of
mercury.
Dioxins and Furans
Belgium (Flanders) reported that in waste incineration plants (both for municipal and hazardous waste), dioxins and furans must be sampled
continuously with samples analysed every two weeks. Belgium (Wallonia) reported such requirement for municipal waste incineration plants as well
as cement kilns co-incinerating hazardous waste, although no reporting frequency was specified by the Member State.
In both cases this is in addition to the requirement for biannual measurement of dioxins and furans in Article 11(2).
3.1.18 Question 18: Measurement of pollutants to water
18. Are the requirements of the permit for the measurement of pollutants to water
identical to those set out in Article 11(14) and (15)? If not, please provide information
detailing the following:
(a) reason for deviating from Article 11(14) and (15);
(b) pollutant/parameter concerned and measurement requirement.
All Member States responded to this question. The majority of Member States
responded that the measurement requirements under Article 11(14) and 11(15) have
been transposed exactly in national legislation (20: Austria, Belgium, Bulgaria, the
Czech Republic, Germany, Estonia, Greece, Spain, Finland, Italy, Lithuania, Malta,
the Netherlands, Poland, Portugal, Romania, Sweden, Slovenia, Slovakia and the UK).
Deviations from these requirements are set out in Table 3.12.
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Table 3.12 Different wastewater monitoring requirements to those set out in
Article 11(14) and 11(15)
MS Measurement requirement
DK According to the response provided the conditions laid down for one plant for
the monitoring of heavy metals (Hg, Cd, Tl, As, Pb, Cr, Cu, Ni and Zn) are different to those set out in Article 11(14) and 11(15) of the Directive. In order to meet the requirements of the Directive, statistical discharge checks are conducted which involve a statistical verification of discharge data based on discharge data collected by random sampling with samples taken over a 24-hour period.
FR Additional parameters (TOC, fluorides, free CN, total hydrocarbons, AOX and
biochemical oxygen demand), which are subject to emission limit values, have
to be monitored.
IE The frequency of periodic measurements for heavy metals is reduced from
twice a year to once every 2 years. This deviation continues to be applied in the case of 5 permits, as per the previous reporting period.
HU No conditions apply at one plant in Hungary because the waste water is pre-treated and then drained off indirectly via a waste water treatment plant for class 3 waste water (~2-4 times per year), and the measurement results show
that the emission limit values are complied with.
CY, LU, LV
No conditions apply because no incineration plant produces waste water in these Member States. Note that this claim has been inconsistently reported by Cyprus and Luxembourg in response to questions 11, 12 and 13. It is unclear
therefore whether or not facilities producing waste water operate in these
Member States or not.
3.1.19 Question 19: Compliance as regards air emissions
19. What provisions are made within the permitting process to ensure compliance
with the following provisions as regards air emissions:
(a) Article 11(8);
(b) Article 11(9);
(c) Article 11(11);
(d) Article 11(12);
(e) the compliance regime set out in Article 11(10).
All Member States responded to this question, albeit with a varying degree of detail,
often referring only to the transposition into the national legislation, or the inclusion of the requirements in permit conditions.
Some Member States provided more elaborate descriptions of the provisions as
presented in Table 3.13. Estonia stated that automatic monitoring systems are in
place to ensure that compliance checks are well carried out, and that no other
requirements apply.
Seven Member States (Austria, Belgium, Bulgaria, Cyprus, the Czech Republic,
Estonia and Hungary) reported changes to the previous reporting period, but for five
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of them the reported changes only consisted of additional detail compared to the
previous reporting period. Thus, legislative changes have only been reported by Belgium (Wallonia) and Cyprus.
Table 3.13 Summary of responses provided to question 19
Item Summary of responses
11(8) with regards to standardisation of measurement results (reference
conditions to express ELVs and
assess compliance)
16 Member States merely referred to transposing legislation (BE, BG, DE, DK, EL, ES, IE, IT, LT, LU, NL, PL, PT, SE, SI, UK)
AT, CY, CZ, FR, HU, LV, NL, RO report the applicable the conditions (temperature, pressure, oxygen content, dry gas) in their response).
MT and SK report that the conditions are met through independent review by experts but do not provide further details.
AT allows an exemption for NOx from the standardisation requirement for emissions of pollutants which are reduced by exhaust gas treatment.
11(9) with regards
to recording and processing results, requiring all measurement results to be recorded,
processed and presented in such a way that allows the competent
authorities to check compliance
8 Member States did not specify the provisions, rather they referred
to the transposing legislation (BE, EL, ES, FR, LU, PT, SI, UK)
8 Member States reported that operators must submit annual reports (BG, CY, CZ, DE, HU, MT, SI, SK). In addition, CZ outlined instructions for evaluating monitoring data. DE and SI refer back to
the previous reporting period.
5 Member States reported that results should be submitted periodically (AT, BE (Brussels), LV, MT, NL). In addition, MT responded that results must be regularly made available online.
4 Member States reported that automatic monitoring systems are in
place that automatically record and process the results (AT, EE, LV, NL).
4 Member States reported that operators must keep log books (AT, HU, IE, SE).
Poland and Romania provided only general information about what should be recorded and processed.
11(11) with regards to calculating average values
13 Member States responded that the requirements have been fully transposed to national legislation or have been incorporated within permit conditions (AT, BE, BG, CY, CZ, DE, HU, IE, LT, LU, NL, PL, RO). Only 3 of those (AT, CZ, RO) have set out the provisions for how the average for monitoring should be calculated according to
the intervals between each measurement and depending on the emission source, stipulating that continuous measurements must be taken throughout the day, start and shut-down of operations must
be recorded, no more than 5 half hourly mean values can be discarded in a day, and no more than 10 daily mean values per year. CZ has also included detail on the evaluation of continuous
measurements.
SK reported that automatic emission measurement systems have been installed that meet the requirements of the legislation, but no detail has been provided.
13 Member States did not specify how the provisions have been implemented (DK, EE, EL, ES, FI, FR, IT, LV, MT, PT, SE, SI, UK).
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Item Summary of responses
11(12) with
regards to periodical measurements of HF, HCl and SO2
7 Member States provided detail as to how the provisions have been
transposed (AT, CZ, EE, FI, NL, RO, SE). In some of these cases, it is unclear if the provisions have been transposed in full or not (EE, FI, SE). EE reported that measurements are carried out automatically and that as such there is no need to set provisions in national legislation. FI and SE reported that the requirements are specified in the national monitoring programmes and that in practice
the parameters are monitored continuously.
18 Member States did not specify the provisions set (BE, BG, DE, DK, EL, ES, FI, FR, HU, IT, LT, LU, LV, MT, PL, PT, SI, UK). In these cases, Member States either provided the relevant article number in
national legislation (10) or referred to the previous reporting period (8).
It is unclear how the response provided by CY relates to the question and so it has not been included in the analysis here.
11(10) with
regards to compliance with ELVs for air
7 Member States responded with details concerning the procedure in
place (AT, (BE (Brussels), CZ, DE, NL, MT, RO). The evaluation is typically based on a calculated average value for the period of a year in all cases except CZ. In accordance with the Directive, CZ reports that for stationary sources thermally treating waste, during sampling of heavy metals, PCDD and PCDF no pollutant
concentration value exceeds the value of specific emission limits. DE and NL refer to the previous reporting period.
18 Member States did not specify the provisions, rather they referred to the legislation title and article to which the provisions
have been transposed (BE (Flanders and Wallonia), BG, CY, DK, EL, ES, FI, HU, IE, IT, LT, LU, LV, PL, PT, SE, SI, UK).
3.1.20 Question 20: Compliance as regards water emissions
20. What provisions are made within the permitting process to ensure compliance with the following provisions as regards water emissions:
(a) Article 11(9);
(b) The compliance regime set out in Article 11(16).
All Member States responded to this question, albeit with a varying degree of detail,
often referring only to the transposition into the national legislation, or the inclusion in permit conditions.
Some Member States provided more elaborate descriptions of the provisions as
presented in Table 3.14. Only three Member States (Belgium (except for Wallonia),
Germany and Hungary) reported changes compared to the previous reporting period.
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Table 3.14 Summary of responses provided in reply to question 20
Item Summary of responses
11(9) with regards to recording and processing results
requiring all measurement results to be recorded, processed and presented in such a way that allows the
competent authorities to check
compliance
4 Member States specified that annual reports are required (often with information on each pollutant for all point sources) (AT, RO, SI, SK) (this marks no change since the previous repo–t - see
section 2.5.19 of the previous report).
Malta indicated that reports must be submitted every 3 months, while Poland and Spain responded that reports must be submitted without specifying the interval.
14 Member States did not specify the provisions, rather they referred to the transposing legislation (BE, BG, DE, DK, EL, FR, HU, IE, IT, LU, NL, PT, SE, UK).
11(16) with regards to
compliance with ELVs for water
A total of 15 Member States provided no detail with respect to the provisions (BE, BG, DE, DK, EL, ES, FR, HU, IT, LU, MT, NL, PL, PT,
UK).
Of the remaining Member States, a handful indicated that the provisions have been applied as stipulated in the WID, as follows:
Total suspended solids: AT, IE, RO, SE, SK;
Heavy metals: RO, SE (note: only the second condition is applied, i.e. where more than 20 samples p.a. have been
carried out, no more than 5% exceed the ELV), SK and
Dioxins and furans: IE, RO, SE, SK.
The following Member States reported that more stringent/ different
conditions are applied:
CZ reported that for TSS, 95% of the daily measured values must not exceed the ELV and no value can exceed 45 mg/l; for heavy metals and As at most one of the monthly measured
values for the year may exceed the limit value; and dioxins and furans must be measured every six months (for the first year every three months) and no measured value may exceed the limit value.
SI referred to additional parameters that must be checked to ensure compliance, as outlined in response to question 13.
AT reported that the individual emission limit values for arsenic, lead, cadmium and chromium, manganese, nickel, thallium and zinc, are considered complied with if 95% of the values of all
the measurements carried out in the course of a single year do not exceed the emissions limit and no measurement value exceeds the limits by more than 50%.
IE reported that exceedances are permitted for heavy metals
under 4 permits. No further detail was provided.
3.1.21 Question 21: Guidance on producing validated daily average
emission data
21. Please describe any official guidance that has been developed on producing
validated daily average emission data (Article 11(11)). If available, please provide a web link.
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March 2016 56
A total of 26 Member States responded to this question. No response was provided
by Italy (in the previous reporting period, Italy responded that no guidance was available).
The most common responses indicate that the guidance has been incorporated within
national legislation (12), or that official guidance documents that have been produced (9).
The majority of Member States reported no change compared to the previous
reporting period (19: Austria, Bulgaria, Cyprus, Denmark, Finland, France, Germany,
Greece, Hungary, Ireland, Latvia, Luxembourg, Malta, Poland, Portugal, Romania,
Slovenia, Sweden and the UK) but in three cases either additional or updated web
links were provided. Changes were reported by six Member States, (Belgium, the Czech Republic, Estonia, the Netherlands, Slovakia and Spain).
An overview is set out in Table 3.15.
Table 3.15 Overview of official guidance documents on producing validated daily average emission data reported with web links
MS Guidance Link as reported Comments (on accessibility and content)
BG Guidance published in 2003. http://www3.moew.government.bg/?show=top&cid=116
The links provided allow access to instruction on producing daily averages (in Bulgarian).
CZ Guidance published in 2013. http://www.mzp.cz/cz/overovani_spravnosti_mereni_metodika
Guidance for verifying the accuracy of continuous measurement results for pollutants released to atmosphere by stationary air pollution sources.
DE Germany published guidelines on the basis of requirements set out in the national emissions monitoring practice, VDI measurement instructions (VDI 3950 sheet 1) and DIN standards (DIN EN 14181).
http://www.umweltbundesamt.de/luft/messeinrichtungen/mg-bestimmung.htm
http://www.umweltbundesamt.de/publikationen/luftreinhaltung-leitfaden-zur-emissionsueberwachung-0
https://www.umweltbundesamt.de/sites/default/files/medien/1/dokumente/auswerterichtlinie-gmbl_version_13-6-2005_0.pdf
http://www.gaa.baden-wuerttemberg.de/servlet/is/16507/4_3_4.pdf
http://www.umweltbundesamt.de/themen/luft/messenbeobachtenueberwachen/messgeraete-messverfahren/bekanntgabe-eignungsgepruefter-messeinrichtungen
The links provide access to a number of guidance and best practice documents related to emission monitoring. Additional website links were provided by the Member State in the current reporting period; however, it noted that no changes have been made to the either document.
DK Method sheet and draft report with recommendations on the application of standards were published.
www.ref-lab.dk The link provided opens a website of the Environmental Protection Agency Reference Laboratory.
IE 2 guidance documents are available: Guidance on cross checking continuous analysers and Guidance which applies to the
http://www.epa.ie/air/airenforcement/guidanceinrelationtoqualityofairemissionsdata/guidanceont
IE provided up to date links but also noted that no changes have been made to either document.
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MS Guidance Link as reported Comments (on accessibility and content)
application of 95% confidence intervals as required in WID & LCPD licences (published in 2012)
hequalityofairemissionmonitoringdata/#.Vc3kkjZwazc
http://www.epa.ie/pubs/advice/air/emissions/guidanceonagencyrequirementsunderwidandlcpd.html
NL Guidance on measurement obligations, the conversion, testing and uncertainty of measurement results, recording and reporting are included in the manual for the application of the Decree on the Incineration of Waste Substances (BVA).
http://www.infomil.nl/onderwerpen/klimaat-lucht/stookinstallaties/sitemap/
NL reported that the guidance has been updated to be interactive.
PT Guidance quoted in the response referred to producing daily average data for cement kilns
No link provided It is unclear if the guidance is also applicable to other types of plants or only to cement kilns.
RO Guidance on producing daily averages has been published. Romania also reports that other types of guidelines have been issued.
http://www.anpm.ro/files2/twinning_2004/5400/09_5404_RO.pdf
The link opens the guidance (published in Romanian)
SE More than one guidance document has been issued. The response provides details of the guidelines.
http://www.avfallsverige.se/fileadmin/uploads/Rapporter/F%C3%B6rbr%C3%A4nning/F2007_02.pdf
The link opens a manual based on standard EN14181
3.1.22 Question 22: Procedures for informing competent authority of a
breach of ELVs
22. What are the procedures for informing the competent authority in the event of a
breach of an emission limit value?
All 27 Member States responded that no changes have occurred since the previous
reporting period (see question 24 from the previous report). In addition, three Member States provided updates, as follows:
Bulgaria reported additional conditions that are imposed in permits in the event
of breach of an emission limit value, including to maintain a logbook to record
details of the event, and record the actions taken at the time of the event.
Spain provided additional information for a region (Asturias) – although no
detail is recorded here as it does not change the overall analysis for Spain as a
whole.
Belgium reported that there have been changes to the legislation setting out the
procedures in Wallonia (although the procedure remains unchanged).
Of note, the updates provided by Member States referred only to the procedures and
thus the time within which operators must notify their respective competent
authority, and the method of communication that must be used have not changed
since the previous reporting. Overviews are set out in Figure 3.14 and Figure 3.15
below. Please refer back to question 24 of the previous report for a more detailed account.
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Figure 3.14 Reported time within which authorities must be informed about the
breach of ELVs (% of MS)
Figure 3.15 Method of communication that be used (number of Member States)
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March 2016 59
3.1.23 Question 23: Public participation in permitting process
23. What arrangements are made to ensure public participation in the permitting
process (new and/or updated permits)? Please provide details, at least, on the following aspects:
(a) by which authority the permit application is made publicly available;
(b) period during which the public is allowed to comment;
(c) by which authority the final decision is made available.
All Member States responded to this question, with the majority of Member States
reporting the same as the previous reporting period (23, including Austria, Belgium,
Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Greece,
Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, Poland, Romania, Slovakia, Slovenia, Sweden and the UK).
Member States were requested to provide information concerning public participation
in the permitting process for both new permit applications and updating permit
applications. Details concerning public participation in the process for issuing new
permits were provided for 34 cases (across 23 Member States: Austria, Belgium
Cyprus, the Czech Republic, Denmark, Estonia, Finland, Germany, Greece, Hungary,
Ireland, Italy, Latvia, the Netherlands, Malta, Poland, Portugal, Romania, Slovenia,
Slovakia, Spain, Sweden the UK). For permit updates 27 cases were detailed (across
17 Member States including, Austria, Belgium, Cyprus, Denmark, Estonia, Germany,
Greece, Finland, Ireland, Italy, Latvia, the Netherlands, Poland, Romania, Slovakia,
Slovenia and the UK). In the case of Belgium (Flanders), France, Lithuania and
Luxembourg the type of process (new permit or update) is not specified in the
response given. Belgium, Germany and the UK provided multiple responses to this question to reflect the different arrangements in place at regional level.
Authority by which permit applications and final decisions are made available
Only Malta reported a change compared to the previous reporting period, whereby
information concerning the permit application and the final decision is now available
in more locations for the public to view. In addition to being at the national authority
office, the permit applications can now also be viewed at local authority offices, as
well as local council offices and the internet. An overview of all responses is presented in Figure 3.16 (see section 2.5.22 of the previous report for more detail).
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Figure 3.16 Means by which information concerning the permit application, and
the final decision for new and updated permits is made available to the public 3
Nine Member States reported differences between the ways in which information
concerning permit applications and the final decisions are made available to the public
(Belgium, Bulgaria, Cyprus, Germany, Greece, Ireland, Malta, Slovenia and the UK).
In all cases (except Cyprus and Germany), a lower number of authorities are reported
as publishing final decisions, compared to information concerning the applications,
which suggests that information on applications for new permits or changes to
existing permits are generally more widely disseminated compared to final decisions.
Of note, the final decision is not available at local authority offices for any of the
Member States (whereas seven Member States have reported that information
concerning the permit application is available at local authority offices). Also of note,
the internet is the most widely used means of making the final decision available to
the public. Lastly, one of the Länder in Germany reported that arrangements to make
the final decision publicly available have not been taken yet. An overview of the differences is presented in Figure 3.17 below.
Figure 3.17 The number of authorities across Member States responsible for
making new permit applications and the final decision available to the public
Notes: In some Member States multiple authorities are responsible at different administrative levels. Where information has been provided indicating such a split this is included in this Figure.
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Member States also reported other ways of notifying the public about the permitting
process. Austria, Denmark, Luxembourg, the Netherlands and Slovakia reported that
information on permit applications and/or final decisions are also published in
newspapers. In Romania it may also be publicised on the radio or television in
addition to press; public debates may also be organised. Cyprus highlighted in its
report that in case of IPPC plants, the public can also attend the meetings of the
technical committee evaluating permit applications. Slovenia stated that reported
provisions for public participation in the permitting process only apply to IPPC plants.
The UK (Scotland) reported that both the information concerning the permit and the final decisions must be made available via local libraries also.
Time period during which the public is allowed to comment
There has largely been no change compared to the previous reporting period
concerning the time period during which the public is allowed to comment on the
permit applications. Additional information and changes were reported by three Member States, as follows:
Germany reported the amount of time that the permit applications are available
to the public for comment varies amongst the Länder, and can be 10-30 days,
31-50 days, or 51-70 days. Of note, 51-70 days is the longest time provided to
the public for comment. Further, note that it is not clear from the response
provided whether or not this is a change, or additional information, as
previously the Member State reported that the arrangements were made at
Lander level without specifying the amount of time.
Spain provided a national overview in addition to the details provided previously
as a regional level. At a national level, the public is given between 31 and 50
days to comment on permit applications; however, the regional authorities may
choose to amend this.
Portugal has extended the length of time that the public can comment on permit
applications from 10-15 to 10-30 days.
An overview of the information reported (including where no change has been reported) is presented in Figure 23.
The Member State summaries in Appendix A of this report and question 24 of the previous report provide for a more detailed account.
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Figure 3.18 Period of time allowed to the public for commenting on permit
applications
3.1.24 Question 24: Availability of information through permitting process
24. With regard to the availability of information throughout the permitting process:
(a) Is there any information related to environmental aspects not publicly/partially
available on the application, decision process and subsequent permit? If yes, please
specify which information.
(b) ‘f ’No' specified: Where these data are available, please specify whether this information is available free of charge.
A total of 24 Member States provided a complete response to this question with Bulgaria, Italy and Portugal submitting unclear or incomplete responses.
Several Member States reported that all information related to environmental aspects
is publicly available (14, including Austria, Belgium, Cyprus, the Czech Republic,
Estonia, France, Greece, Ireland, Latvia, Lithuania, Malta, the Netherlands, Slovenia
and Spain), while 12 Member States (Bulgaria, Germany, Denmark, Finland,
Hungary, Luxembourg, Poland, Portugal, Romania, Sweden, Slovakia, and the UK)
reported that there are restrictions on the information that is made public. Only
Hungary has reported a change since the previous reporting period, whereby it
reported that certain information related to environmental aspects is not publically
available where there is an issue of commercial or technological secrets that are classified as intellectual property.
11 Member States (Bulgaria, Germany, Finland, Hungary, Luxembourg, Poland,
Portugal, Romania, Sweden and Slovakia) responded that some information related
to the permitting process may not be available to the public for personal, juridical,
industrial, commercial, professional or business confidentiality reasons. Five Member
States (Bulgaria, Luxembourg, Poland, Romania and the United Kingdom) responded
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there may be restrictions in accessing information that may have an impact on
national security. Seven Member States reported other instances when information may not be shared with the public:
Bulgaria, Luxembourg, Romania and Poland reported that access to information
may be restricted if there is a risk that publication of such information may have
an adverse impact on the environment;
Slovakia reported that information may not be made available unless there is a
significant change to the operation of IPPC plants;
Luxembourg stated that if information is provided on a voluntary basis, the
supplier of information can request that it remains confidential; and
Denmark reported that under the national legislation (the Public Administration
Act, the Public Access Act and the Act on public access to environmental
information) there might be some restrictions to access applications,
supplementary material as well as draft and final decisions; however it did not
provide further details.
16 Member States reported that all information is free of charge (Austria, Cyprus,
the Czech Republic, Estonia, France, Greece, Hungary, Ireland, Latvia, Lithuania,
Luxembourg, Malta, the Netherlands, Romania, Slovakia and Slovenia). Of the eight
(Belgium, Germany, Denmark, Spain, Finland, Poland, Sweden and the UK) that
reported that a charge can apply, this referred to charges for the cost of photocopying
or printing, rather than a charge to access the information. Of note, since the
previous reporting period, three Member States have introduced a charge for
photocopies etc. (including Belgium (Wallonia), Spain (Asturias, Cantabria, Galicia,
Madrid, and Murcia), and the UK (Northern Ireland)). This is likely to be indicative
of financial constraints in the respective authorities.
3.1.25 Questions 25 and 26: Annual report
25. For incineration plants and co-incineration plants with a nominal capacity of 2
tonnes or more per hour, what provisions are made to require an operator to submit
an annual report on the functioning and monitoring of a plant to the competent authority?
26. If an annual report is provided:
(a) what information does this contain?
(b) how may the public get access to this report?
Provisions to submit an annual report
All Member States provided a response to question 25, although details of the
provisions were missing in the responses given by Greece and Luxembourg. No
Member State reported any change compared to the previous reporting period to the provisions in place.
Overall, 16 Member States (Austria, Belgium (Wallonia and Flanders), Bulgaria,
Cyprus, France, Greece, Italy, Hungary, Lithuania, Luxembourg, Malta, Netherlands,
Poland, Sweden, Slovenia and Slovakia) have reported that the requirement for the
operators to submit an annual report has been introduced in their legislation. In 10
Member States (Belgium (Brussels), the Czech Republic, Germany, Denmark, Spain,
Finland, Ireland, Portugal, Romania and the United Kingdom) this requirement is
implemented through permit conditions.
Two Member States reported other information, as follows:
In Estonia there are two plants falling within the scope of the Directive. While
no information on where the requirement to submit an annual report is laid
down, it stated that the plants submit the report each year. Further, it is noted
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that this report is submitted in addition to the one that all plants submit every
quarter to the Competent Authority on emissions to water and air pursuant to
the Ambient Air Protection Act and the Water Act.
Latvia reported that no specific provisions have been introduced with regard to
requirement the for an annual report; however requirements for the content of
annual reports and for making it available to the public are laid down in national
legislation.
Only Italy indicated that failure to submit an annual report by incineration plants and
co-incineration plants with a nominal capacity of 2 tonnes or more per hour could
result in a fine for operators. According to the response given, anyone operating an
incineration or co-incineration plant who fails to comply with the requirements of the
legislation in force, or the conditions imposed by the competent authority when
issuing the permit, is punishable by an administrative fine of €1,000 to €35,000.
Bulgaria also noted that a penalty may be issued where an operator fails to submit an annual report – although no further details were provided.
Annual report content and public availability
All Member States provided a response to this question; however, two of the
responses indicated that the minimum requirements set by the Directive (i.e. to
report on the running of the process and the emissions into air and water compared
with the emission standards) might not have been met, and no further explanation as to why was given. In summary:
Portugal indicated that an annual report is required; however no detail of the
content was specified.
Slovakia reported that emissions into water are not required in the annual
report. It is not clear from the responses why. Although it is possible that this
omission is because emissions into water do not occur in the respective plants,
the Member State has not indicated this to be the case (in response to this
question or others in the questionnaire).
Of note, Estonia and Latvia indicated that emissions into water are not required
in the annual report. However this is not regarded as not meeting the
requirements of the Directive because as explained in response to questions 11
and 13, both Member States reported that there are no waste water discharges
from the flue gas cleaning equipment in their Member State, and thus it is likely
that this omission is because emissions into water do not occur in the respective
plants.
An overview of the required content for annual reports is presented in Figure 3.19 by
Member State. Article 12 of the Directive stipulates that the annual report ‘shall, as
a minimum requirement, give an account of the running of the process, and the
emissions into air and water compared with the emission standards in this Directive’,
as well as providing ‘a list of incineration or co-incineration plants with a nominal capacity of less than two tonnes per hour’.
Note that the following additional information was also specified by some Member States under ‘other’:
Belgium (Wallonia) and the Czech Republic also require information on energy
recovery.
Cyprus and Ireland specify that the data must be presented in a format that is
compatible with E-PRTR (European-Pollutant Register for Transfers and
Releases) reporting.
Additional data on waste consumption and production as a result of the
processes in place is required by Cyprus, France, Spain, Luxembourg and
Slovenia.
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Portugal also falls under the ‘other’ category on the basis that no minimum
reporting requirements are specified in the Member State’s response, as
referred to above.
Figure 3.19 Minimum requirements for the content of annual reports
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Member States have generally reported that annual reports are made available to
the public either via the internet, by the competent authority on request or by the
operator on request. The most common means is by the competent authority on
request, as reported by 19 Member States (BE, CY, CZ, DE, EL, ES, FI, FR, HU, IT,
LU, NL, PL, PT, RO, SE, SI, SK, UK). For the 12 Member States that reported that
annual reports are available on the internet (AT, BG, CZ, DE, DK, FI, HU, IE, LV, MT,
NL, SE, SK), the links provided are set out in Table 3.16. Note that Estonia reported
that emissions to air data is available online, but provided no indication as to how
the annual reports are made available to public. Estonia provided the website link
for the raw data (rather than the annual report), which can be located via the State
Environmental Register,
http://register.keskkonnainfo.ee/envreg/main#HTTPfgJx7CaOHSYnrTwOJA7w93AgF
1hJBT
Table 3.16 Website links where annual reports are available on the internet
(optional question)
MS Website link
AT www.bmlfuw.gv.at
BG http://eea.government.bg/bg/r-r/r-kpkz/godishni-dokladi/
IE www.epa.ie
LV http://parissrv.lvgmc.lv/#viewType=home_view
MT http://www.mepa.org.mt/ippc-applications-installations-incinerator
SE http://utslappisiffror.naturvardsverket.se/
3.1.26 Question 27: Identification of plants with a nominal capacity of less
than 2 tonnes per hour
27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
All Member States except for Hungary and UK (Northern Ireland and Wales)
responded to this question. Belgium (Brussels) and Lithuania reported that the
requirement does not apply to them as no plants with a nominal capacity of less than
2 tonnes per hour operate on their territory. The means used by Member States to
identify plants with a capacity below 2 tonnes per hour are presented in Figure 3.20.
No changes since the previous reporting period have been reported in terms of the
way in which these plants are publicly identified, although in a few cases the list or website has been updated and an updated link has been provided (Table 3.17).
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Figure 3.20 Reported forms to identify plants with capacity below 2 tonnes per
hour
Table 3.17 Website links reported by Member States where the list of plants with
capacity below 2 tonnes is available on the internet (optional question)
MS Website link
AT www.bmlfuw.gv.at
BE Flanders: Via the OVAM website http://ovam.be – no link provided
Wallonia: http://environnement.wallonie.be/owd/entagree/incin.pdf
BG http://eea.government.bg
CY http://www.mlsi.gov.cy/mlsi/dli/dli.nsf/All/3F693C6469DF096FC2256EB0003A567D?OpenDocument
CZ http://portal.chmi.cz/files/portal/docs/uoco/oez/emise/spalovny/index.html
http://portal.chmi.cz/files/portal/docs/uoco/web_generator/incinerators/index_CZ.html
http://portal.chmi.cz/files/portal/docs/uoco/oez/emise/spalovny/evidence/index.html
EE http://klis.envir.ee/klis
RO http://www.anpm.ro/articole/incinerare_deseuri-141
SI http://www.arso.gov.si/varstvo%20okolja/odpadki/podatki/OVD%20Se%c5%beig%20sose%c5%beig%2026082014.pdf
SK http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2013
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MS Website link
UK Scotland: http://www.sepa.org.uk/waste/waste_regulation/energy_from_waste/efw_sites_in_scotland.aspx
3.1.27 Question 28: Provisions to control the period of abnormal operation
28. What provisions are made within a permit to control the period of operation of
an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
All Member States except for Lithuania responded to this question. The majority of
Member States (18) indicated that the provisions are set in national legislation
(Austria, Belgium, Bulgaria, the Czech Republic, Denmark, Estonia, Finland,
Germany, Greece, Hungary, Latvia, Luxembourg, Malta, the Netherlands, Poland,
Slovakia, Slovenia and Sweden)5. A total of 11 Member States reported that the
provisions are laid down in permit conditions (Bulgaria, Cyprus, France, Ireland, Italy,
Poland, Portugal, Slovenia, Spain, Sweden and the UK). Four Member States have
reported that the provisions are laid down in both national legislation and permit
conditions (Bulgaria, Poland, Slovenia and Sweden). One possibility to explain this
overlap is that permit conditions are used to stipulate stricter conditions compared
to national legislation (as indicated by Sweden).
Seven Member States did not specify the provisions in place to control the period of
abnormal operation, rather they indicated only whether the provisions are laid down
by national legislation or by the permit conditions (Germany, Estonia, Greece, Malta,
the Netherlands, Sweden and the UK).
An overview of the types of provisions to control the period of abnormal operation
is presented in Figure 3.21 below. Note that the most common options in place are
reducing or stopping the waste feed to the installation, or stopping all activity (as
reported by 11 Member States respectively).
5 Lithuania responded in the previous reporting period that the provisions to control abnormal operation are set in national legislation, and that they stipulate that waste feed to the installation must be reduced or stopped as soon as possible. Although the Member State did not respond to this question, it is likely that the same applies to the current reporting period.
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Figure 3.21 Provisions to control the period of abnormal operation
3.1.28 Question 29: Maximum permissible periods of abnormal operation
29. For incineration and co-incineration processes what are the maximum permissible
periods of operation during abnormal operation before the plant must shut down:
(a) maximum permissible period with exceedance of emission limit values;
(b) maximum cumulative duration of periods exceeding emission limit values over 1.
All Member States responded to this question. All Member States reported that the requirements of the Directive have been met with the following exceptions:
Estonia did not specify a time limit for the maximum permissible period with
exceedance of emission limit values.
The Netherlands reported that the time limit for the consecutive period of time
of abnormal operation may exceed 4 hours (as also reported under the previous
reporting period). No further explanation was provided to justify this.
The Czech Republic and Estonia reported that the time limit for the cumulative
period of time of abnormal operation may exceed 60 hours.
o No further explanation was provided by the Czech Republic to justify
this. It reported that the maximum cumulative duration of periods
exceeding emission Limit Values for one year was 60 hours until 1
September 2012, and that there after the limit is 120 hours.
o In the case of Estonia, the exceedance applies to one plant only,
owing to the fact that the sudden discharge period for the three
rotary kilns are activated for no more than 135 hours per year. An
additional comment was made by Estonia with regards to the only
other plant operating in its Member State to report that operations
are automatically stopped in the case of any breach.
It is flagged later in the report that these issues should be further investigated as
this does not seem to be in accordance with the WID’s requirements.
The most commonly reported time limits are between 3 and 4 hours (for the
consecutive period of time allowed), and between 40 and 60 hours (for the
cumulative period of time allowed) – as illustrated by Figure 3.22 and Figure 3.23.
This shows that in most cases (19/27), the Member State has chosen to apply the
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Directive requirements exactly. Only a few Member States reported that more
stringent requirements apply; as shown in the figures below, this includes
Germany, Greece and Slovakia – see below for details.
Figure 3.22 Time limit for the consecutive period of time of abnormal operation
Figure 3.23 Time limit for the cumulative period of time of abnormal operation
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3.1.29 Question 30: General remarks
Member States were invited to provide any other remarks. Only Belgium (Flanders) and Bulgaria chose to respond, as follows:
Belgium reiterated comments that were already reported in the previous period.
Note that a few of these issues relate to definitions and therefore are reported
under question 2. In brief, it was remarked that:
o the difference between energy recovery and material recovery is
unclear where the waste material can be used for both purposes at
the same time;
o the approach that should be taken to continuous monitoring
requirements in the case of batch processes is unclear;
o the scope of the Directive in relation to diesel engines incinerating
waste (specifically in relation to temperature, continuous
measurement of certain emission parameters);
o the ELVs applying to water discharges from the cleaning of exhaust
gases (with regards to metallurgical processes) were established
taking into consideration primarily incinerators of household waste,
and these values cannot be reached in metallurgical processes, which
would imply that these plants will not be able to incinerate waste.
Bulgaria noted that Regulation No 6 of 28 July 2004, which transposed the
requirements of WID, was repealed with effect from 16 April 2013 (SG No 36 of
16 April 2013). Regulation No 4 of 5 April 2013 (SG No 36 of 16 April 2013),
which transposes the requirements laid down in Article 31(2), Chapter IV and
Annex VI of Directive 2010/75/EU on industrial emissions, came into force on 16
April 2014.
3.1.30 Croatia’s report on the implementation of the Waste Incineration
Directive
The information in the report submitted by Croatia covers almost all the requirements
of the questionnaire, providing data to demonstrate the status regarding implementation.
19 installations fell within the scope of the Directive during the reporting period and
all recovered the heat generated in the incineration process. All plants were
permitted. No permits were granted to mobile plants. 17 plants were identified as
co-incinerators and 2 as incinerators, although the latter ones stopped working during
2012. Under question 1.2 details are provided for 13 co-incinerators, of which five
are identified as cement kilns, 5 as combustion plants and 3 as other industrial facilities.
A range of hazardous and non-hazardous waste types are co-incinerated (as
identified by the EWC codes) and infectious or potentially infectious waste are exempted from representative sampling of wastes.
Croatia did not indicate if any of the co-incineration plants are subject to the
provisions of Annex V and whether any authorisations have been granted in accordance with Article 6(4).
Croatia did not made use of the possibility to grant exemptions and derogations from
certain provisions of the Directive regulating ELVs. Specifically, no exemptions
according to Annex II.1 have been made, no exemptions from the monitoring
requirements of emissions to air and water were applied in line with the provisions
of Article 11 of the Directive and no air limit values different to those given in Annex
II, Annex IV or Annex V have been set. However, Croatia highlighted that no effluent
is produced from flue gas cleaning at the existing incineration and co-incineration
plants. Given the lack of waste water discharges, Croatia did not report which specific
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operational parameters are set within the permitting process for waste water
discharges and on the provisions regulating monitoring of waste waters.
All aspects required by Article 4(5) are specified in permits granted to plants incinerating hazardous wastes in accordance with its national provisions.
Provisions have been made to ensure the protection of soil, surface water and
groundwater as well as the adequacy of storage capacity for waste waters. In
addition, Croatia quoted the national legislation which transposes the provisions of
Article 9 on residues, Article 11 on monitoring and Article 13 on abnormal operations of the WID.
In Croatia, the permit application is publicly available via the website of the Ministry
of Environmental and Nature Protection (MENP) and the public have a minimum of
30 days to review and comment on an application. The Croatian Environment Agency
(CEA) runs a Waste Management Permits Register database which contains
information and documents on waste management permits (for hazardous, non-
hazardous and municipal waste). Data on permits are available upon request to CEA,
which also prepares yearly annual reports publicly available based on data from the Permits Register.
The obligation to provide an annual report by the operator to the Environmental
Pollution Register (EPR) and its content is specified by national legislation. Part of
the information contained in these reports is publicly available online and the reports
are available to interested public upon request to competent authorities.
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4. Implementation status
This section provides a summary of the overall analysis and description of the
implementation of the Waste Incineration Directive in the EU for the reporting period
2012-2013, highlighting key issues and relevant conclusions.
The discussion on the status of implementation should be understood as an indication
of the point in the implementation process that each Member State had reached at
the end of the reporting period. The information presented here is based solely on
the information provided by Member States in their responses to the questionnaire.
4.1.1 Summary of implementation status
The main aspects of the implementation of the WID have been summarised in Table
4.1. Each aspect is compared to the main conclusions on similar aspects from the
2009-2011 reporting period. In addition, where possible, charts have been designed
to allow a graphic comparison of the evolution of the implementation of the WID.
The sources for this comparative analysis are the 2014 report on the status of the implementation of the WID within the EU-27 for the period 2009-20116.
6 AMEC, 2014, Assessment and Summary of Member States' Implementation Reports for the
IPPC Directive (2008/1/EC) covering the period 2009-11
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Table 4.1 Summary of implementation status (2012-2013)
Aspect Implementation status 2012-2013 Comparison with the previous reporting period (2009-2011)
Plants and permit coverage
Number of Plants (Q1, Q3)
Member States reported 1,673 plants falling within the scope of the WID during the reporting period. Six Member States (DE, FR, IT, the UK, SE and PL) accounted for 70% of the total.
939 (56% of the total) were identified as incineration plants and 688 (41%) as co-incineration plants. It was not possible to categorise 46
plants located in Belgium based on the information provided.
Plants with heat recovery represented 80% of the total (1,322 plants). The proportion of these plants was below 50% in Romania (22%), Latvia (8%) and Malta (1 plant). No data were provided by Greece.
A comparison shows that the number of plants covered by the WID in 2012-2013 fell by 2%, down from 1,714 plants in 2009-2011.
As the 2012-2013 reporting period is shorter than the previous reporting period, the number of permits issued during the two periods is not directly comparable (although it is noted that fewer permits were issued in the current reporting period
- see figure below).
A comparative analysis on the evolution of plants per type (incineration/co-incineration) shows a decrease of 6% in the number of incinerators (55 plants less). The number of co-incinerators remains almost the same, with one more plant reported for 2012-2013 (688 compared to 687). The number of plants recovering heat has declined since 2009-2011 (from 1,392, representing 81% of the total); however, as a proportion of the total number of plants, the number of plants recovering heat has increased (accounting for 96% in the 2012-2013 reporting period).
Permits (Q1) Member States reported a total of 1,628 permits issued compared to a total of 1,673 plants.
20 Member States reported the same number of plants as permits issued. The reasons provided by Member States to explain the differences include: all plants were permitted but permits cover more than one plant (IE, SE) or just the parts of a single plant (CY, DK), and plants without a valid permit were not operational (CZ). The remaining Member States reporting a difference did not provide an explanation in their responses (DE and PT).
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Aspect Implementation status 2012-2013 Comparison with the previous reporting period (2009-2011)
Permit requirements
Provisions for plants incinerating hazardous waste (Question 6)
The lack information provided for certain aspects remains an issue among a significant number of Member States.
In nine Member States (AT, BG, DK, HU, LV, LU, MT, PT and RO) all aspects required by Article 4(5) are specified in the permits. For the remaining Member States, there are cases where it is explicitly stated that certain information is not (always) included in the permit or it is unclear based on the information provided. In particular, specification of the maximum and/or minimum value of mass flows or calorific values is not mentioned by eight Member States.
In addition, information provided by some Member States on how the different aspects of Article 4(5) are determined within the permitting process, reveals that European Waste Catalogue (EWC) codes are commonly required for the identification in the permit of the types of hazardous wastes to be treated.
Only two Member States (CZ and PL) have reported changes with regards to the permitting provisions based on newly introduced legislation which suggest that some aspects are actually included in permits (i.e. previously it was unclear). In addition, other Member States (UK, EE, ES and DE) have also provided some additional information on the process.
Other permit provisions (Question 14, 15, 16)
Provisions to protect soil, surface and groundwater
26 Member States have introduced provisions to protect soil, surface and groundwater. The most frequently reported provisions were facilities for separate collection of polluted waters (reported by 12 Member States) and the use of impermeable and covered areas where wastes are stored (reported by ten and eight Member States each). For Portugal it was impossible to determine, based on the response, whether and what provisions were implemented.
Provisions to protect soil, surface and groundwater
The responses provided for 2009-2011 suggested that provisions to protect soil, surface and groundwater were implemented across 26 Member States and this continues to be the case in the most recent period with only Portugal providing insufficient information.
Criteria to ensure sufficient storage capacity for water to be tested and treated
Responses were very varied, with only 14 Member States describing criteria in place. The most frequently reported criterion (five Member States) was to undertake calculation for storage capacity on the basis of hydraulic calculations. Responses provided for the remaining Member States referred either to national legislation, permit conditions or were insufficient to determine what criteria are in place (for example by providing information not relevant to storage capacity). Estonia, Greece and Latvia stated that storage capacity for water is not applicable.
Criteria to ensure sufficient storage capacity for water to be tested and treated
Comparison with previous reporting periods shows an improvement as only 12 Member States provided information in the last period (2009-2011).
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Aspect Implementation status 2012-2013 Comparison with the previous reporting period (2009-2011)
Minimisation of residues in quantity and harmfulness
Seven Member States reported provisions relevant to all requirements of Article 9. The remaining responses covered only some requirements, with the most frequently reported being the minimisation in amount and harmfulness, and recycling of residues (mentioned by 12 and 9 Member States respectively). Safe transport of dry residues was reported by three Member States, and testing by four Member States.
Minimisation of residues in quantity and harmfulness
Based on the open nature of the question asked, it is not possible to draw conclusions on the change in level of implementation of these provisions between the periods.
Emission Limit Values (ELVs)
Co-
incineration plants to which ELVs from Annex V applied (Question 5)
The provisions of Annex V applied to a total of 132 plants located in
six Member States (DE, ES, IT, LU, SE, SI) with Sweden accounting for 72% of the total. Across the EU-27, for 67 plants it was reported that the application of Annex V ELVs is due to co-incineration of untreated municipal waste being undertaken at such plants, whereas for 56 it is due to the fact that more than 40% of the resulting heat released comes from the combustion of hazardous waste. For 9 plants (8 located in Italy and 1 in Luxembourg) it was not clear, based on the response, why Annex V ELVs were applied.
In total a net increase of 11 plants has been observed between the two reporting
periods (121 plants in 2009-2011), despite fewer Member States reporting the application of Annex V to co-incineration plants in the current reporting period compared to the previous one (8: AT, DE, ES, LT, LU, SE, SI and the UK).
Exemptions from ELVs in Annex II.1 for cement kilns (question 9)
Exemptions from ELVs in Annex II.1 for cement kilns (question 9)
21 Member States have granted exemptions from emission limits in accordance with Annex II.1 during the reporting period. Based on the information provided it has not been possible to determine the total number of cement kilns with exemptions. Nevertheless, it has been observed that there were eight Member States where all cement kilns reported had been granted exemptions.
Exemptions from the TOC (10 mg/m3) and SO2 (50 mg/m3) ELVs were granted by 17 and 15 Member States respectively, mostly in cases where emissions of these pollutants do not result from the incineration of the waste.
It is of note that Latvia and Romania each reported one plant exempted from the ELV set out for NOx and dust, despite the fact that the WID required these exemptions to end by January 2008. Explanations for both cases are outlined in the analysis for question 9.
Exemptions from ELVs in Annex II.1 for cement kilns (question 11)
In the previous reporting period, 21 Member States reported cement kilns with exemptions in accordance with Annex II.1 to the WID. The figure below shows the number of Member States reporting each type of exemption in both periods.
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Aspect Implementation status 2012-2013 Comparison with the previous reporting period (2009-2011)
It can be observed that the number of Member States reporting exemptions for SO2 and TOC ELVs has been quite similar. In both reporting periods, the values that appeared most frequently in Member States’ reports where 400 mg/Nm³ for SO2 and 50-100 mg/Nm³ for TOC.
ELVs for emissions to air and water (Questions 10,11,12)
Different ELVs for emissions to air (question 10)
In 13 Member States air ELVs are the same as those specified in the WID and without covering additional parameters.
12 Member States reported that different ELVs to those set out in Annex II and V to the WID have been set. Although the reported ELVs appear to be more stringent than those specified in the WID, additional information on the plants concerned (e.g. capacity) or on permit conditions would be required to accurately determine this, especially regarding co-incineration plants as there might be cases where Annex V would apply for such plants.
ELVs for additional pollutants have been reported by nine Member States. Member States were not requested to submit information concerning their application of the mixing rule, and thus where ELVs for additional pollutants have been set, no detail concerning the application of the mixing rule have been provided and it has not been possible to determine whether or not the requirements of the Directive have been met. With respect to the additional pollutants listed by Member States, Ammonia (NH3) was the most frequently reported (by nine Member States). Other commonly pollutants reported included PAHs and PCBs.
Different ELVs to water (question 11 and 12)
In 18 Member States water ELVs are the same as those in the WID and do not cover any additional parameters. Three Member States indicated that there are no facilities operating in their Member States in which waste water is produced by flue gas cleaning and discharged to the aquatic environment (Latvia, Lithuania and Luxembourg). Moreover, it is expected that no such facilities operate in Estonia in light of the Member States response to question 13.
Six Member States (Austria, Germany, Denmark, Italy, Ireland and
Sweden) have reported that ELVs that are determined differently to Annex IV of the Directive. Stricter ELVs have been set in all cases except for Ireland where the values reported are the same as those set out in Annex IV.
During the 2009-2011 period:
For air ELVs, 17 Member States reported that additional or different limit values have been set. The pollutants affected and reasons provided for adopting those ELVs were similar.
For water ELVs, 8 Member States laid down more stringent ELVs compared to those set out in Annex IV to the Directive and 12 Member States had set limit values for additional waste water pollutants. The pollutants affected and reasons provided for adopting those ELVs were similar.
Overall, the present reporting period shows that fewer Member States are going beyond what is required by the WID. However it is of relevance the fact that several Member States report that stricter ELVs have been set at national level on the basis of the state of the art.
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Aspect Implementation status 2012-2013 Comparison with the previous reporting period (2009-2011)
Inconsistencies in the information reported were observed in the responses provided by Hungary and Luxembourg – indicating that the Directive has not been appropriately implemented and should be investigated further.
ELVs for additional pollutants (to the substances in Annex IV of the Directive) have been reported by 10 Member States (Austria, Germany, Denmark, Italy, Sweden, Hungary, Luxembourg, Poland, France and Slovenia). The reasons why these additional parameters have been established are not clear from the information reported by Member States.
Control of emissions and operational conditions
Derogations from operating conditions according to Article 6(4)
(Question 8)
Ten Member States (AT, BE, DE, DK, HU, IE, NL, SE, SK and the UK)
have granted authorisations to differ from the operating conditions stipulated in Article 6(1) and Article 6(2) during the reporting period. In total, 133 derogations (which represent 8% of the total number of plants) have been granted in accordance with Article 6(4). The majority of derogations (67%) were located in Germany.
Based on the information provided for some representative cases (41), these were generally granted to existing plants and laid down different temperature conditions. Note that it is not possible to assess whether these derogations are in line with the WID as the detailed permit information per plant would be required for such an assessment.
During the 2009-2011 period, the same number of Member States reported the
application of derogations (131) in accordance with Art. 6(4). With the only exception of Spain, the rest continued to report derogations in the present period 2012-2013. The number has increased in Denmark and decreased in Germany and the UK. In the rest the same number has been reported. In total, a net increase of only 3 plants has been observed between the reporting periods.
Hungary was the only Member State which reported such derogations in the 2012-2013 period and not in 2009-2011. An increase in the number of plants with such derogations may imply practical problems and technical difficulties in complying with the WID requirements.
Monitoring
requirements of emissions to air (Q17) and provisions to ensure compliance (Q19)
Derogations from measurement requirements laid down in
Article 11(2)
Derogations apply in 16 Member States. The most commonly reported pollutant for which derogations are applied is HF, both under Article 11(6) (14 Member States) and Article 11(4) (13 Member States). Another commonly reported pollutant for which exemptions apply is HCl under Article 11(6) (13 Member States).
Only Germany and Sweden responded that all derogations are applied in their Member States – otherwise, the combination of derogations that apply vary considerably between Member States.
Derogations from the measurement requirements laid down in Article 11(2)
A comparison between the information reported by Member States in the 2009-2011 and the 2012-2013 reporting periods is illustrated in the figure below. In 2009-2011, the same number of Member States have reported that they allowed derogations from the requirements of Article 11(2) as the 2012-2013 reporting period.
However, there are variances between the two reporting periods in relation to the Member States that apply the derogations and the number of pollutants concerned – the latter is illustrated by the figure below. There has been a significant decline in the number of pollutants with derogations compared to the previous reporting
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period, particularly for dioxins and furans, and heavy metals. Declines in the number of derogations are also evident for SO2, HF, and HCl under Article 11(6).
More stringent monitoring requirements for emissions to air compared to requirements of the WID were implemented by five Member States in relation to Hg (Austria and Germany), dioxins and furans (Belgium), F (Spain), and HF (France). Note that fewer Member States have reported that stricter monitoring requirements apply compared to the previous reporting period (due to changes reported by the Netherlands), and that the parameters have also changed since the previous reporting period.
Provisions to ensure compliance with air emission values
The majority of Member States (18) reported that the provisions concerning air emission measurements are laid down in the national (or regional in the case of Belgium) legislation, while 11 reported that the requirements of the Article are set in permit conditions. Finland reported that an emission monitoring programme has been established in their Member State and that the provisions of this article have been transposed via this organisation. Estonia responded that
Provisions to ensure compliance with air emission values
Since the 2009-2011 reporting period more detail has been provided by 5 Member States, and 2 Member States (BE (Wallonia) and CY) reported legislative changes. Given the small number of changes between the two reporting periods, the conclusion from the previous reporting period is still much applicable. Member States have continued to respond with a varying degree of detail, often referring only to the transposition of Article 11 into the national legislation, or the inclusion of the Article requirements in permit conditions.
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it was not necessary to transpose the requirements in legislation or permit conditions as monitoring is automatic.
The level of detail varies by Article item and by Member State. Less detail has generally been provided where the provisions relate to technical matters (e.g. Article 11(12) with regards to periodical measurements of HF, HCl and SO2 to which 18 Member States did not provide details).
Monitoring and operational control parameters for water (Q13, 18) and provisions to ensure compliance (Q20)
Control parameters for waste water from flue gas cleaning
17 Member States have confirmed that they include the three mandatory control parameters (pH, temperature and flow) for the discharge of waste water from the cleaning of exhaust gases as required by Article 8(6).
Four Member States (Estonia, Lithuania, Latvia and Luxembourg) did not report any of the required operational parameters because there are no waste water discharges from the flue gas cleaning equipment in these Member States.
Six Member States state or suggest that some parameters are not (always) set in permits, which should be further investigated as this
does not seem to be in accordance with the WID’s requirements.
Control parameters for waste water from flue gas cleaning
In the period 2012-2013 a lower number of cases where Member States explicitly state or suggest that some parameters are not (always) set in permits has been observed. It is important to note that the omission of a parameter is not sufficient to conclude that a Member State in the report is not compliant with Article 8(6).
Deviations from measurement requirements of Article 11(14-15)
A majority of Member States (20) have established identical monitoring requirements for water emissions to those set out in Article 11(14-15).
Denmark and Ireland reported different reporting requirements for metals, and France reported that additional parameters must be monitored. Cyprus, Latvia and Luxembourg reported that no effluents are produced and therefore the requirements do not apply. Hungary specified that no conditions apply in the case of one plant due to the system of pre-treatment for wastewater that has been installed.
Deviations from measurement requirements of Article 11(14-15)
The number of Member States with no conditions in place has increased from three to four as Hungary reported that deviations apply to one plant due to the system of pre-treatment for wastewater that has been installed. Note that the deviations that previously applied in Spain are no longer in place.
Provisions to ensure compliance with water emission values
The majority of Member States responded that the relevant provisions from Article 11 with regard to water emissions have been transposed (13 of which responded that the provisions are set in national
Provisions to ensure compliance with water emission values
Given that only three Member States (BE (except for Wallonia), DE and HU) reported changes compared to the previous reporting period, the conclusion from the previous reporting period is still applicable.
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legislation - AT, BE, BG, CZ, EL, FR, IT, LU, NL, PL, PT, SE, SI, and 9 of which that the provisions are set in permit conditions (DE, DK, ES, HU, IE, MT, RO, SK, UK). Detail of the relevant provisions in place with regard to Article 11(9) were provided by 6 Member States. While details with regards to compliance with ELVs for water (Article 11(16)) were provided by 7 Member States. Lastly, 5 Member States reported that the provisions within the permitting process to ensure compliance
as regards water emissions are not relevant as no waste water is emitted in the respective Member States (CY, EE, FI, LT, LV)
Controlling periods of abnormal operation (Q28,29)
Provisions made to control the periods of abnormal operations
All Member States except for Lithuania responded to this question. There have been no changes to the provisions in place to control the periods of abnormal operation. These provisions have been set either through conditions in national legislation (18) or in permit conditions (11). Note that four Member States have reported that the provisions are laid down in both national legislation and permit conditions (BG, PL, SI and SE). One possibility to explain this overlap is that permit conditions are used to stipulate stricter conditions compared to
national legislation (as indicated by SE).
Seven Member States did not specify the provisions in place to control the period of abnormal operation, rather they indicated only whether the provisions are laid down by national legislation or by the permit conditions (Germany, Estonia, Greece, Malta, the Netherlands, Sweden and the UK). The most common options in place are reducing or stopping the waste feed to the installation, or stopping all activity (as reported by 11 Member States respectively).
Provisions made to control the periods of abnormal operations
A comparison between the 2009-2011 and the 2012-2013 reporting periods with regards to the provisions in place illustrates that a greater number of Member States have reported that operation is prohibited when ELVs or operational parameters are exceeded compared to previously. However, as there has been no change to the provisions reported by Member States, it is likely that reporting has improved rather than implementation.
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Periods with exceedance of emission limit values
All Member States responded to this question and 25 reported that the requirements of the Directive have been met.
The Czech Republic and Estonia reported that the time limit for the cumulative period of time of abnormal operation may exceed 60 hours, while the Netherlands reported that the time limit for the consecutive period of time of abnormal operation may exceed 4 hours.
Lastly, Estonia did not specify a time limit for the consecutive period of time of abnormal operation. Estonia provided further explanation for this, however the Czech Republic and the Netherlands did not which has been flagged as an issue requiring further investigation.
Periods with exceedance of emission limit values
Since the previous reporting period several Member States have introduced more stringent limits. Germany, Greece and Slovakia report that the consecutive time period exceeding ELVs in a single event is no more than an hour. Germany and Slovakia also report that the cumulative time period must be less than 20 hours in the case of certain plant types, and between 20 and 40 hours in another instance – as reported by Slovakia.
Of note, there has been one more incident in the current reporting period, compared to the previous one, where the Directive has not been transposed appropriately with regards to the cumulative time limit (as reported by CZ).
Guidance on
producing validated daily average emission data (Q21)
A total of 26 Member States responded to this question. The most
common responses indicate that guidance has been incorporated within national legislation (12), or that official guidance documents that have been produced (9). Other Member States indicated that guidance is incorporated within the permit conditions (2), or that other documents are available to explain relevant methods for producing daily average emission data (1). Five Member States responded that either no guidance is available, did not respond to the question, or
There has been no comparatively little change reported compared to the 2009-2011
reporting period with 19 Member States reporting that no changes have occurred, with additional guidance now available in the Czech Republic and regionally in Spain, as well as updates to the guidance in the Netherlands.
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provided an unclear answer (Belgium (Brussels), Italy, Lithuania and Malta).
Procedures for informing authorities about the breach of ELVs (Q22)
Procedures to inform the authorities
A majority of Member States (17) reported that procedures for informing authorities about breaches of ELVs are laid down in the
national legislation, and two that they are included in the permit conditions. Latvia reported that the procedures are set out in the emergency plan which operators are required to draw up as part of their permit conditions. Lastly, six Member States outlined the procedure in place without specifying how they have been implemented, and Italy responded that no procedure is in place.
Procedures to inform the authorities
All 27 Member States reported that there have been no changes to the procedures since the previous reporting period, but some more detail was provided in three
cases concerning the procedures in place.
Time for informing authorities about the breach of ELVs
Only 20 Member States provided a response to this question in terms of the time within which authorities must be informed about the breach of ELVs. The most common requirement reported (15 Member States) is that authorities must be informed without delay. In the case of five Member States, longer time to inform the authorities is
allowed (between 12 and 48 hours following detection of the fault).
Time for informing authorities about the breach of ELVs
All 27 Member States reported that there have been no changes since the previous reporting period.
Means to inform the authorities about the breach of ELVs
11 Member States also reported on the means of informing the authorities about a breach of ELVs. In many cases Member States reported that more than one means of communication is available to operators. In ten Member States authorities must be informed in writing. Other forms of communicating with authorities include email (5), phone (4) and fax (2).
Means to inform the authorities about the breach of ELVs
All 27 Member States reported that there have been no changes since the previous reporting period.
Annual report requirements (25,26)
Requirement to submit annual report to the authorities
16 Member States reported that the requirement for the operators to submit annual report has been introduced in national (or regional in the case of Wallonia and Flanders) legislation, and 10 Member States that this requirement is implemented through permit conditions. Note that there is double counting for Belgium to account for the regional variances.
Latvia reported that no specific provisions have been introduced with regard to the requirement for an annual report to be submitted.
Requirement to submit annual report to the authorities
All 27 Member States reported that there have been no changes since the previous reporting period.
Content requirement for annual reports
The figure below provides a comparison of requirements for the content of annual reports reported by Member States in the 2009-2011 and 2012-2013 reporting periods.
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Similarly, no provisions were specified by Estonia – although in both cases annual reports are submitted by operators.
Content requirement for annual reports
All Member States provided a response to this question. As a minimum, annual reports should give an account of the running of the process, and the emissions into air and water compared with the emission standards in the Directive. Two Member States indicated that the minimum requirements for the content of annual reports have not been transposed to the national legislation (Portugal and Slovakia).
Additional reporting requirements by Member State are presented in the figure to the right. Note that the following additional information was specified under ‘other’:
Information on energy recovery (2);
Compatible format with E-PRTR (European-Pollutant Register for Transfers and Releases) reporting (2);
Data on waste consumption and production (5).
As illustrated, the same number of Member States reported the requirement on operators to report on the running of the process (25) and emissions to water (25); while one more Member State reported that emissions to air has been included in the requirements (26).
Availability of annual reports to public
Member States have generally reported that annual reports are made available to the public in one or more of three ways, including via the internet (12), or either by the competent authority (19) or operator on request (5). Note that Estonia reported that emissions to air data is available online, but provided no indication as to how the annual reports are made available to public.
Availability of annual reports to public
A comparison of information between the 2009-2011 and 2012-2013 reporting periods is illustrated in the figure below.
There appears to be some fluctuation reported by Member States as to whether or not the annual reports can be obtained upon the request from the installation. It is unclear if this is an inconsistency in reporting, or if it reflects changes to the way in which the Directive has been implemented.
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Public participation and availability of information throughout the permitting process (Q24)
Public participation in the permitting process
A total of 24 Member States provided a complete response to this question with Bulgaria, Italy and Portugal submitting unclear or incomplete responses.
Public participation in the permitting process
In the 2009-2011 reporting period, 26 Member States responded that the requirements of the Directive had been met in relation to making information about new permits available to the public (only Luxembourg did not clarify whether the response given related to new permits or updates). However, according to the responses given for the 2012-2013 reporting period, only 23 Member States specified that the provisions of the Directive have been met. This is likely to be an inconsistency in reporting by the Member States in question whereby the type of permit application has simply not been specified, and the level of public participation in the permitting process is likely to be of the same or similar level to the previous reporting period.
Period for the public to comment on permit applications
The most commonly reported amount of time that a permit application (new or updated) is available to the public for comment is between 10 and 30 days (as reported in 38% of the responses for new permits applications – constituting 12 Member States, and 33% for updated permit applications – constituting 9 Member States), followed by between 31 and 50 days (as reported in 27% of the responses for new
Period for the public to comment on permit applications
A comparison between the 2009-2011 reporting periods shows that there has been relatively little change reported by Member States with only Portugal indicating that a change has occurred - the length of time that the public can comment on permit applications has been extended from 10-15 to 10-30 days. As such, the overall conclusion that the majority of Member States reports a 30 day period or shorter, is also valid for the 2012-2013 reporting period.
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permits applications amounting to six Member States, and 30% for updated permit applications amounting to four Member States).
Authority by which permit applications and final decisions are made available
In 19 Member States information on applications and final decisions
on new permits as well as updates to the permits is published by the same types of authorities. The internet is now used by 18 Member States to disseminate information and final decisions to the public in case of new and updated permits.
Authority by which permit applications and final decisions are made available
A total of 26 Member States responded that no changes have been made compared
to the previous reporting period and it can still be concluded that the majority of Member States reported that permits can be consulted at local authority offices, frequently combined with availability from regional and national level authorities, and the internet.
Public access to information (q.24)
A total of 24 Member States provided a complete response to this question with Bulgaria, Italy and Portugal submitting unclear or incomplete responses.
Several Member States reported that all information related to environmental aspects is publicly available (14), while 12 Member States reported that there are restrictions on the information that is made public. 16 Member States reported that all information is free of charge. Of the eight (Belgium, Germany, Denmark, Spain, Finland,
Poland, Sweden and the UK) that reported that a charge can apply, this referred to charges for the cost of photocopying or printing, rather than a charge to access the information.
With regards to public access, only Hungary has reported a change since the previous reporting period, whereby it reported that certain information related to environmental aspects is not publically available where there is an issue of commercial or technological secrets that are classified as intellectual property.
The number of Member States reporting that a charge may be applied for public access to this information has increased since the previous reporting period with three additional Member States introducing a charge for photocopies since the previous reporting period (including BE (Wallonia), ES (Asturias, Cantabria, Galicia,
Madrid, and Murcia), and the UK (Northern Ireland)). This is likely to be indicative of financial constraints in the respective authorities.
Information on plants with capacity less than 2 tonnes per hour (q.27)
All Member States except for Hungary and parts of the UK (Northern Ireland and Wales) responded to this question. Of these, Belgium (Brussels) and Lithuania reported that the requirement does not apply to them as no plants with a nominal capacity of less than 2 tonnes per hour operate in their respective Member States. An equal share of Member States have reported that the list is available online as those that have reported that the list is available from competent authorities by request (12).
No changes have been reported by Member States in terms of the way in which these plants are publicly identified, although in a few cases the list or website has been updated since the previous reporting period and an updated link has been provided. As such, it may be concluded that all Member States have made the information on plants with capacities less than 2 tonnes per hour available to the public.
Other issues related to the implementation of WID
Definitions (Q2)
Eight Member States (BG, HU, NL, IE, RO, SE, SI and ES) have reported difficulties or particular issues with the definitions given in
In the previous reporting period, problems with the definitions given in Article 3 were reported by 10 Member States (BG, BE, HU, NL, IE, LV, RO, SE, Slovenia and ES).
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Article 3 when implementing the WID. However, it is important to note the following:
Some Member States (e.g. the Netherlands, Bulgaria) have reported observations or technical issues that do not constitute problems with the wording or scope of the definition as such.
Some of the problems reported are no longer applicable with the adoption of the Industrial Emissions Directive (IED) 2010/75/EC which has clarified certain definitions (e.g. on gaseous wastes).
Some issues seem more connected with the definitions given by other legislative instruments such as the Waste Framework Directive or the Animal by-products Regulation.
Taking the above into account, problems or issues most frequently reported relate to the distinction between incineration and co-incineration plants (reported by five Member States) and the definition of waste (e.g. end of waste status criteria) and the different waste categories (reported by three Member States).
Two of the above Member States no longer reported difficulties in the present reporting period (Belgium and Latvia) and in the case of Hungary the issues are different to those raised in the present reporting period which implies that those previously identified have been addressed.
The remaining Member States continue to report the same issues.
Waste co-incinerated (Q4) and waste representative sampling(Q7)
Waste co-incinerated
A wide variety of non-hazardous and hazardous wastes have been co-incinerated across the EU-27 during the reporting period in the different types of co-incineration plants. However, it has not been possible to draw meaningful conclusions on the most common types of wastes co-incinerated at EU-27 level (due to technical problems with the reporting tool, large amount of information).
Waste inappropriate for representative sampling
19 Member States reported that some wastes have been found inappropriate for representative sampling, of which 16 Member States stated medical, healthcare, clinical and veterinary wastes that may have infectious or hazardous properties. Other types of waste were reported by six Member States. Italy did not respond to this question.
Waste co-incinerated
During the reporting period 2009-2011 refuse Derived Fuel (RDF), waste oils and plastics were the waste types most frequently reported as being co-incinerated in cement kilns. Waste wood was the most frequently reported type of waste burnt in combustion plants. Although a detailed analysis at EU-level has not been possible in the period 2012-2013 it is likely that these conclusions still remain valid.
Waste inappropriate for representative sampling
Compared to the 2009-2011 reporting period one more Member State (HU) reported waste inappropriate for representative sampling. Similarly to the previous reporting period, medical and healthcare wastes were the most commonly reported waste identified as inappropriate for representative sampling.
Other remarks provided by Member States (Q32)
Only Belgium (Flanders) and Bulgaria responded to this question. Flanders referred to the general remarks made in the 2009-2011 reporting period while Bulgaria remarked that the national legislation transposing the requirements of WID has been repealed with effect from 16 April 2013 (SG No 36 of 16 April 2013) to reflect the changes adopted under the industrial emissions directive, which came into force on 16 April 2014.
The general remarks made by Flanders in the previous reporting period include several issues in relation to definitions within the Directive and approaches for monitoring. The fact that Flanders referred to the previous reporting period suggests the same issues are ongoing and have not yet been resolved.
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4.1.2 Follow-up actions
The table below presents an overview of the remaining gaps and aspects from which the Commission would benefit to follow up.
Table 4.2 Remaining gaps to follow-up
Question number
Follow-up
1 A handful of data gaps have been identified relating to the number of plants which fall within the scope of the Directive, where there are inconsistencies between responses given for different questions, or a lack of detail. These gaps could indicate that Member States have experienced difficulties responding to the questionnaire.
4 It has been observed that there was a technical problem with question 4, which is not visible in the Word or Excel files provided for Hungary, Bulgaria, Lithuania and Portugal. Technical problems when responding to this question were also reported by Romania.
6 To clarify what provisions are in place in the permitting process and whether (or how) the aspects listed in Article 4(5) are specified in permits in the case of those Member States identified in Table 3.4.
9 Exemptions from the NOx and dust ELVs were no longer allowed since 2008. The fact that such derogations seemed to be still in place in Austria, Germany, Italy and Poland might need further investigation.
11 Hungary reported under question 12 that a much higher ELV for suspended solids than is permitted by the Directive is in place for an existing incineration plant. Hungary explains that the value for total suspended solids set in the appendix to the permit was determined on the basis of 2010 self-monitoring results available at the Inspectorate, taking account of the emission levels achievable by the permit holder.
11 Luxembourg reported under question 12 a higher ELV for suspended solids in an incineration plant (30 mg/l), and a co-incineration plant (50 mg/l). The ELV for suspended solids is higher in the case of the co-incinerator, and potentially higher in the case of the incinerator depending on the frequency of measurements (not specified in the response).
13 There are seven Member States (Cyprus, Greece, Finland, Luxembourg, the Netherlands, Poland and Sweden) where it is unclear if the operational parameters are in place or not. It could be further investigated as this does not seem to be in accordance with the WID’s requirements - see Table 3.9 for more detail concerning the operational parameters.
14 Portugal has not provided any details concerning the provisions to ensure the protection of soil, surface waters or groundwater.
19 To clarify what provisions are in place and whether (or how) the aspects listed in Article 11(12) have been implemented in Estonia, Finland, and Sweden.
20 Ireland reported that exceedances are permitted for heavy metals under 4 permits but no further detail was provided.
25 Responses from Portugal and Slovakia indicated that the minimum requirements set by the Directive (i.e. to report on the running of the process and the emissions into air and water compared with the emission standards) might not be met, and no further explanation as to why was given.
29 To clarify which provisions are in place concerning the consecutive and cumulative periods of time of abnormal operation in Estonia, the Netherlands, and the Czech Republic.
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4.1.3 Main conclusions on implementation status
For the 2012-2013 reporting period, all 27 Member States concerned have provided
responses to the Commission’s questionnaire on the implementation of the WID. In
general Member States covered most of the aspects of the questionnaire, providing sufficient data to allow a complete assessment on their implementation of the Directive.
Overall, the information provided by the majority of Member States gives no indications
that implementation of the WID was particularly problematic during the reporting
period. From the comparison with the previous reporting period 2009-2011, it appears
that there have been very few changes reported although some aspects of the
implementation have improved.
The total number of plants and permits reported has slightly decreased compared to the
previous reporting period:
In total, Member States reported 1,673 plants falling within the scope of the WID
during the reporting period, with six Member States accounting for 70% of the
total. This represents a 2% decrease over the previous reporting period (down
from 1,714 plants in 2009-2011). More than half (56%) of the 1,673 plants are
identified as incineration plants, 41% are co-incineration plants and a small
number could not be assigned to any category. Co-incineration takes place mainly
in combustion plants and cement kilns; and
Based on data provided, almost all plants were permitted during the reporting
period. A valid permit was reported to be missing for only 4 (non-operational)
plants, all located in Czech Republic. Information provided on the number of
permits issued was unclear in two other Member States (Germany and Portugal)
and concerned 28 plants.
As during the previous reporting period (2009-2011), an overall good level of practical
implementation of the WID has been observed, with Member States generally describing
processes undertaken to comply with the requirements of the WID in terms of control
of emissions, reporting and public access to information. Moreover, less Member States
have reported problems with definitions or implementation compared to the last reporting period.
The possibility of allowing exemptions from certain requirements has been applied in
several Member States in accordance with the WID, apart from a few cases, where further information is needed to assess whether this is effectively the case.
Some good practices were observed during this reporting period, with, for example,
separate guidance or instructions on producing validated daily average emission data reported as being available in 12 Member States.
In general, the present reporting period continues to show that a significant number of
Member States are going beyond what is at least required by the WID, drawing a similar situation to the previous period. This demonstrated by the fact that:
More than half of Member States (63%) reported permits that either contain
stricter air and water ELVs than those required by the WID and/or determine limit
values to cover additional pollutants not listed in Annexes II, IV and V to the WID
(e.g. NH3, PAHs). The information reported by Member States indicate that limits
for these pollutants are in some instances prescribed by the national legislation.
Several Member States report more stringent monitoring requirements for
emissions to air and/or water compared to requirements of the WID. As such 17
Member States reported that additional operational control parameters are set
within the permitting process for waste water discharges from flue gas cleaning
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equipment and five reported more stringent monitoring requirements to those laid
down in Article 11.
In addition, follow up actions have been identified and are summarised in Table 4.2.
4.1.4 Conclusions on reporting
A lot of the responses provided are similar to those reported in the previous reporting
period, particularly with regards to qualitative questions (i.e. regarding legislative
provisions in place) with several Member States’ responses referring to their responses
to the previous questionnaire.
Nevertheless for some Member States further improvements in the reported information
have been observed. In some instances these improvements addressed gaps or
problematic aspects identified in the previous reporting period (2009-2011), with
Member States providing further clarifications or even adopting measures to correct
issues.
However, there still remain issues to be clarified or corrected in a few Member States,
for example some responses are unclear on the information to be included in permits (e.g. specification of maximum, minimum value of mass flows or calorific values).
The level of information provided on derogations granted varied across Member States,
some of which were not detailed enough to assess whether they are in line with the
WID. Finally, some numerical responses questions on number of plants and number of
permits were interpreted differently which seems to indicate that instructions for reporting could be added to facilitate next reporting.
The next reporting for waste incineration and co-incineration plants will be conducted
under the IED. The questionnaire has already been adopted and is located in Module 4
of Annex II to Commission Implementing Decision 2012/795/EU. Question 11.2 of this
module requires several quantitative information for which current reporting has
observed an inconsistent level of details across Member States. In order to facilitate
reporting and increase the quality of the information reported by Member States,
guidance and practical examples of the types of information expected should be
included. The Electronic Reporting Tool should also allow for flexibility for installations
with multiple processes or derogations being used (e.g. for the reporting of information
on the change of operating conditions as allowed by Article 51(2)).
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Appendix A Member States summaries on implementation
Summaries of the implementation of the Directives in each Member States are presented below.
A.1 Austria
A.1.1 Analysis of the completeness
Table 1: Completeness assessment of answers reported by Austria – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 (a-b)
Whilst in question 1 Austria reports a total of 67 plants (17 incinerators and 50 co-incinerators), in question 1.2 only lists 35 plants. In addition, no details on the latitude and longitude of the plants have been provided in question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Technical difficulty with the reporting tool. No response available.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.a
8.b
Emission limit exemptions for
cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
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Question Completeness Comment
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-
e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water
and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity
for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation
28
29
Other remarks 30
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Austria provided an almost complete response to the questionnaire. The following
omissions were identified: lack of information on the waste co-incinerated (question 4),
and some data missing in question 1.2. In question 8.2 and 9.2, Austria has not
provided further details; however this information was only to be provided “if these data are available” and therefore is not seen as a gap.
A.1.2 Analysis of Austria´s responses
The table below contains detailed analysis of the responses provided by Austria to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Austria under each question. The table contains
a summary of the response, as well as further comments and descriptive analysis of the
answers given. In cases where text has been quoted directly from the English translation of the report, it is presented in italics.
Table 2: Austria – Response analysis table
AUSTRIA
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total, 67 plants fell within the scope of the Directive, of which 50 were co-incineration plants.
67 permits were issued in Austria and all plants recovered the heat from the process.
Austria reported that the total permitted capacity of waste throughput was not available (this was an optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
In contrast to the response provided under question 1.1 Austria listed 35 plants, of which 21 were co-
incineration and 14 incineration plants.
Of the reported co-incineration plants, 11 were combustion plants, 9 were cement kilns and the other one was identified as “other industrial facility” not covered by Annex II.1 or II.2 to the WID.
Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for 10 of the plants described in question 1.2. The efficiency figures were equal to or above 60% and therefore in line with the requirements of the Waste Framework Directive (ranging between 0.66 and 1.20).
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Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with definitions were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to Directive 2000/76/EC during the reporting period. In remarks Austria stated that it is questionable whether mobile plants are state of the art.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
Austria has not responded to this question
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
Austria reported no co-incineration plants to which emission limits set out in Annex V applied, as per the previous period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There has been no change in the response to this question compared to the last reporting period
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
5 exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4). Austria did not report any details of the exemptions in response to question 8.2.
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Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Austria reported that 14 exemptions have been granted in accordance with Annex II.1. No details of the plants or the pollutants for which exemptions have been granted has been provided by Austria.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those given in Annex II or Annex V have been set as follows:
Parameter WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
Hg 0.05 (30 min to 8-hour)
Existing incinerator: ELV = 0.03 (DAV)
State of the art (seems to be applied in general to all existing incineration plants)
HF 1 (DAV) 4(HHAV100%A) 2 (HHAV 97%B)
Existing incinerator: ELV = 0.5 (DAV) - 0.7 (HHAV)
NOx 200 (DAV > 6t/h or new) 400 (DAV=< 6t/h) 400(HHAV100%A) 200(HHAV 97%B)
Existing Plants > 6t/h: 100 (DAV + HHAV)
New plants: 70 (DAV)
Plants 2-6 t/h: 150 (DAV) – 200 (HHAV)
Plants < = 2t/h: 200 (DAV) - 300 (HHAV)
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
Dust 30 (II.1 –cement) Cement plants: ELV = 20 (HHAV) Austria reports that these ELVs apply to all cement manufacturing plants on the basis of state of the art.
NOx 800 existing - 500 new (II.1 –cement)
Cement plants: ELV = 500 (HHAV)
HF 1 (II.1 –cement) Cement plants: ELV = 0.7 (HHAV)
Hg 0.05 (II.1.2.3) Cement plants: ELV = 0.03 (DAV)
Co-incineration and Incineration plants- ELVs set for pollutants not listed in Annex II or Annex V to the WID
PAH (Benzo(a)pyrene)
1 incineration plant; ELV = 0.01 (maximum average value)
No comments provided
NH3 1 co-incineration plant (cement) ; ELV = 30 -60 (HHAV)
1 incineration plant ; ELV = 5 (30 min -8h)
The reason in the cement kiln is the use of selective non-catalytic reduction at the plant.
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PCB 1 incineration plant; ELV = 0.1 No comments provided
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours; II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
There has been no change in the response to this question compared to the last reporting period. Stricter limit values were specified for As, Pb, Hg and Zn.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Austria has defined ELVs for a number of additional pollutants not listed in Annex IV to the WID as follows:
Polluting substance ELV reported (mg/l) Comments
Ammonium 10 All additional ELVs listed apply to existing incineration and co-incineration plants Antimony 0.2
Cobalt 0.5
Chemical Oxygen Demand (COD) 90
Cyanide, easily released 0.1
Organically bound halogens (AOX) 0.1
Fluoride 20
Manganese 1.0
Phenol index 0.3
Phosphorus 2
Sulphate 2500
Sulphides 0.2
Sulphites 20
Tin 0.5
Total Organic Carbon (TOC) 30
totally bound nitrogen 50
Vanadium 0.5
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in Austria compared to the last reporting period.
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Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in Austria compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change in Austria compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Austria reported that permit conditions relating to measurement of pollutants to air are different to those set out in Article 11(2) as follows:
Deviation Comments (Pollutant or parameter concerned
and measurement requirement)
More stringent requirements Yes
In Austria, continuous monitoring of mercury emissions to air is required, unless it can be established that the content of mercury in burned waste does not exceed 0.02mg/MJ or if the assessment values can be demonstrated not to exceed 0.01 mg/m3.
Exemptions for HF under Art. 11(4) Yes No further information provided.
Exemptions for water vapour under Art. 11(5)
Exemptions for HCl under Art. 11(6): Yes No further information provided.
Exemptions for HF under Art. 11(6): Yes No further information provided.
Exemptions for SO2 under Art. 11(6):
Exemptions for heavy metals under Art. 11(7):
Yes Except for mercury
Exemptions for Dioxins and furans
under Art. 11(7): Yes No further information provided.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Austria compared to the last reporting period. These are identical to those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
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There has been no change in Austria compared to the last reporting period with regards to the provisions in place covering items 8, 9, 10 and 11 of Article 11. With regards to item 12, Austria adds the following:
Article Comment
11(12) Austria quotes the text of Article 10(4) Ordinance on the Incineration of Waste, indicating that
emissions measurement recorders and assessment systems must be calibrated in the acceptance test and thereafter every three years. Calibration must be carried out in accordance with ÖNORM EN 14181, issued on 1 September 2004. Measurement uncertainties are determined through calibration, whereby the 95% confidence interval value must not exceed the emissions limits percentages indicated in the norm and which mirror those established in Annex III of the WID plus one for mercury (40%). Every year, a performance test must be carried out in accordance with Standard EN 14181 on the emissions measurement recorders
In its report, Austria refers further to the Waste Incineration Regulations, specifically Article 12(1) which states that in case of continuous measurements, the evaluation values must consist of the half-hourly average values obtained during the actual operating hours of the plant and therefore should exclude the measurements done during the start-up or shut down of the plant. In case of periodic / discontinuous measurements, the mean of at least 3 last individual measurements should be provided.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in Austria compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
In response to this question, Austria quotes the text of Articles 3(26), 3(42), 8(1), 9(9), 10(4) and 12(1) of the Waste Incineration Ordinance as well as Article 3 of the Ordinance on the Limitation of Wastewater Emissions from cleaning incineration gas, which contain requirements on producing validated daily average emission data. Austria refers to the method EN 14181 on quality assurance of automated measuring systems from stationary emission sources. Based on the response provided it appears that Austria has not produced a separate guidance document, but introduced guidance on the producing validated daily averages in their national legislation governing waste incineration and co-incineration operations in the country, in accordance with the method EN14181.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in Austria compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The application and final decision on a new permit are publicly available at the national and local
authorities, on the internet and must also be notified in daily newspapers. The public has between 31 and 50 days to comment on the application.
The applications for updated permits are open for public comment for 31 to 50 days. Austria highlights that there must be significant changes to the permit for public consultation to take place (which is in line with the requirements of the IPPC Directive). The application and final decision on updated permits are publicly available at the national and local authorities and on the internet.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in Austria compared to the last reporting period.
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Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the information provided by Austria compared to the last reporting period. Only the website mentioned to host the annual report prepared by the Federal Minister for agriculture and forestry, the environment and water resources, which summarises the functioning and results of monitoring of co-incineration plants has changed: www.bmlfuw.gv.at.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
The list of incineration/co-incineration plants with a nominal capacity of less than 2 tonnes per hour is published on the internet at www.bmlfuw.gv.at.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in Austria compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in Austria compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Austria.
SUMMARY OF CHANGES
The information in the report submitted by Austria covers all the requirements of the questionnaire, providing data to demonstrate the status regarding implementation. The changes that have been reported in comparison with the previous reporting period, relate to questions 1, 5, 9, 10, 12, 17, 19 and 23.
Installations
In Austria, 67 plants fell within the scope of the Directive, of which 50 were co-incineration plants and 17 incineration plants. All were permitted and recovered heat. No information was available on the total permitted waste throughput. Further details were provided for 35 plants in question 1.2. No mobile plants received permits. Austria has not reported any problems with the definitions in the Directive. Austria has not provided information on the types of waste co-incinerated.
ELVs, operational parameters and monitoring requirements
The following derogations and exemptions have been granted in Austria:
• 5 exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4); however details of these exemptions were not provided.
• 14 exemptions have been granted in accordance with Annex II.1; however details of these exemptions were not provided.
• Permit conditions relating to measurement of pollutants to air are different to those set out in Article 11(2), with a more stringent monitoring requirement introduced for mercury emissions. However measurements of pollutant emissions to water are identical to those set out in Article 11(14) and 11(15).
With regards to emission limit values, Austria introduced the following different limits:
• Different air limit values to those given in Annex II or Annex V have been set by Austria regarding HF, NOx, Hg and dust on the basis of the state of the art. In addition, for certain plants, ELVs have been set for polycyclic aromatic hydrocarbons (PAHs), PCBs and Ammonia (NH3) which are not listed in Annex II or Annex V to the WID. Different and additional ELVs for discharges of wastewater from flue gas cleaning equipment compared to Annex IV of the Directive have also been introduced in Austria.
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General legislative provisions and procedures
With regards to sufficient storage capacity for water to be tested and treated, information provided by Austria is the same as in the last reporting period and did not include sufficient information to conclude how this is ensured.
The public is able to participate in the permitting process, with all information throughout the permitting process being available to the public free of charge. The public has between 31 to 50 days to comment on new and updated permits.
Austria has not published dedicated guidance on producing daily average values; however some general information and requirements are included in the national legislation, in accordance with the method EN14181. The list of plants with capacities lower than 2 tonnes per hour is published on the internet.
A.2 Belgium
A.2.1 Analysis of the completeness of the report
Table 3: Completeness assessment of answers reported by Belgium – WID Directive
Question Completeness Comment
Numbers of plants and
permits
1.1.a In Flanders no distinction has been made
between incineration and co-incineration plants.
1.1.b In Flanders no distinction has been made
between incineration and co-incineration plants.
1.1.c
In Flanders no distinction has been made between incineration and co-incineration plants.
Wallonia reported that 16 plants recover heat however based on the information provided it is unclear if this refers to the 16 co-incinerators or if it includes both incinerators and co-incinerators.
1.1.d No responses were provided by Flanders or
Wallonia but as the question is optional it is not a gap.
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated
4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6 (a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
8
8.1
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Question Completeness Comment
Authorisations containing conditions in accordance with Article 6(4)
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b No response provided by Brussels but the
question is optional and therefore not a gap.
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits
values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for
additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control
parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface
water and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Only Wallonia has reported changes compared to the previous reporting period; however, no details concerning the changes was provided by the Member State.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Only Wallonia has reported changes compared to the previous reporting period; however, no details concerning the changes was provided by the Member State.
Guidance on producing validated daily average emission data (Article11(11))
21
Only Wallonia has reported changes compared to the previous reporting period; however, no details concerning the changes was provided by the Member State.
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
No responses were provided by Brussels or
Wallonia but the question is optional and therefore not a gap.
Belgium has submitted a partially complete response to the WID questionnaire as per
the Commission Decision 2011/632/EU using the electronic reporting tool. Several
issues have been identified with regards to question 1.1, 1.2 as well as for 19, 20 and 21 for the region of Wallonia, as summarised in the table above.
A.2.2 Analysis of the response by Belgium
The table below contains detailed analysis of the responses provided by Belgium to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Belgium under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 4: Belgium – Response analysis table
Belgium
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down
between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 72 plants fell within the scope of the Directive, of which 56 are incineration plants and 16 are co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
88% of the total plants listed recover heat generated by the incineration process.
The total permitted capacities of waste throughput in Brussels is 450,000 tonnes/year (optional question). No response was provided for Wallonia, and the question is not relevant to Flanders.
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Belgium
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Belgium listed all 72 plants by name and type of plant, however the address details was only provided
for one plant. Of these, 29 were co-incineration and 40 incineration plants, and in three cases the type of plant was not specified.
Of the reported co-incineration plants, 11 were combustion plants, five were cement kilns, and 13 were in other industrial facilities.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out
recovery operations falling in Annex II, R1 to Directive 2008/98/EC was provided for one incineration plant located in Brussels. The response provided includes the calculation according to the formula provided in the Directive, as well as the calculation according to the formula provided in the regional legislation (Annex 4). In 2012 the energy efficiency figures are 0.777 and 0.816 (Annex II, R1) for inside and outside the heater system; and in 2013, the energy efficiency figures are 0.781 and 0.828 (Annex II, R1) for inside and outside the heater system, respectively. The calculation according to the formula provided in the regional legislation results in a slightly higher energy efficiency figure compared to the one resulting from the Annex II, R1 formula (not repeated here). In addition, the energy efficiency figures are provided for four other incineration plants; however, it is unclear where the plants are located, and the figures are provided as a percentage and so it is unclear how the values have been derived from the Annex II, R1 formula – as such, these figures are not included in the analysis here.
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Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems were reported concerning the definitions in Article 3.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The types of waste co-incinerated were reported for 33 co-incineration plant – for 15 were combustion plants, five were cement kilns, and 13 were in other industrial facilities. This number is greater than the total reported by the Member State for question 1.2 (29 co-incineration plants were listed). The difference is in the number of combustion plants reported. No explanation was provided by the Member State as to why this difference appears.
The types of waste co-incinerated are presented below.
Type of plant
Category of waste
Co-incinerated?
Remarks
Cement kilns
Waste oils
Yes Includes waste solids, liquids or slurries, consisting mainly of mineral components of clinker, moist or not, as a substitute for natural raw materials (e.g. sludge from the production of drinking water or from the preparation of industrial water), and waste solids or slurries, composed mainly of organic materials, used as a substitute for conventional fuels (e.g. paper and cardboard waste and waste from recycling or production of paper/cardboard; plastic waste; textile and carpet waste; waste wood; rubber waste, tyres; vehicle shredder residue; frying fats; animal flours from the processing of animal waste; carbon black waste; char from pyrolysis or thermolysis of waste; non-hazardous waste from the agri-foodstuffs industry; solid substitute fuels prepared by impregnation and fixation of various types of waste on sawdust or any other absorbent medium; combustible liquid waste (e.g. waste from frying oils, vegetable emulsions; animal fats; solvents; combustible component of waste liquids from waste oils; mineral/organic mixed waste: soils and dredging spoils; sludge from the treatment of urban or industrial wastewater; non-hazardous waste from the agri-foodstuffs industry; mineral waste used as mill additions or as substitute for clinker; waste from the extraction or preparation of fossil fuels; wastewater and residual liquids; waste oils).
Combustion Wood waste
Includes waste from the co-incineration of sludge, wood waste and residues from production of paper.
Other Yes Includes sawdust, shavings, etc. from wood processing and the production of panels and furniture, wooden packaging, fractions of wood collected separately, primary wooden packaging intended for normal household activity, collected separately, wood from non-hazardous waste management facilities, waste from forestry, sawdust, shavings, cuttings, wood, particle board and veneer other than those containing dangerous substances, construction and demolition wood waste (including excavated soil from contaminated sites), wood waste from waste management facilities, off-site wastewater treatment plants and the preparation of water intended for human consumption and water for industrial use other than that containing dangerous substances.
Other industrial facilities
Other Yes Waste solids or slurries, composed mainly of organic materials and used as a substitute for conventional fuels (such as paper and cardboard waste and waste from recycling or production of paper/cardboard; plastic waste; textile and carpet waste; wood waste; rubber waste, tyres; vehicle shredder residue not containing dangerous substances; frying fats; non-putrescible
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natural organic materials (e.g. straw, solid substitute fuels prepared by impregnation and fixation of various types of waste on sawdust or any other absorbent medium); combustible liquid or viscous waste; combustible liquid or viscous waste (waste oils)).
Animal fats (categories I, II and III) in specific facilities
Pyrolysis of activated carbon containing contaminating components
Co-incineration of waste materials containing chlorine, with a view to ensuring the recovery of Cl
Co-incineration of waste materials containing sulphur, with a view to ensuring the recovery of S
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Only Wallonia has classified certain wastes (from hospital and health care activities) as inappropriate for sampling (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
Belgium reported that four plants are exempt from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). Three of these plants are situated in Wallonia, and the details are the same as the previous reporting period. The authorisations have been issued at 3 existing plants, with capacities of 2,160t; 33,580t and 25,000t per year. Wallonia explains that derogations have been granted as engines are involved. Wastes incinerated at the plants are vegetable oil and animal fat. Belgium has also reported that a new derogation was granted in accordance with Article 6(4) (compared to the previous reporting period). The authorisation was issued to a new plant with capacity of 25,000 tonnes per year, incinerating hazardous waste. No further details of the authorisation were reported – among other things therefore it is unclear where the plant is situated.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Belgium reported that ten exemptions were granted from emission limits in accordance with Annex II.1. These exemptions apply to plants in Wallonia and refer to TOC and SO2. However details are only provided for the exemptions on SO2:
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Pollutant Details
SO2 Applied at five existing plants.
SO2 limit values reported were 250 mg/m3, 400 mg/m3 (two plants), 1000 mg/m3 , 2500 mg/m3 (daily average values),
The reasoning provided in case of 4 plants was the presence of sulphur in deposits. For one plant (ELV of 2,500 mg/m3), the sulphur has to be added to the cement production process as flux.
Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] expressed as daily average value, may be authorised in cases where SO2 do not result from the incineration of waste. This seems to be the reason provided by Wallonia which states that exemptions have been granted due to the composition of the raw material used, due to their high content of organic matter and/or sulphur. In addition, one of the SO2 exemptions was granted due to the need of to add sulphur as a fluxing agent to the white cement.
In addition Wallonia reported that additional monitoring requirements have been set for the plants granted exemptions. Plants are required to measure the following pollutants: free cyanides, Cr VI, benzene, benzo(a)pyrene, total of 7 phthalates, ‘total’ PCBs and hexachlorobenzene. They must also undertake a health and environment risk analysis if results of measurements exceed certain thresholds (not reported).
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
The air emission limit values are different to those given in Annex II and Annex V for 15 plants – as set out below:
Parameter WID Value (mg/m3) (averaging period)
Plants and ELV reported (mg/m3) (averaging period- see note)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
NOx 200 (DAV > 6t/h or new) 400 (DAV=< 6t/h)
For three existing plants: ELV= 100 mg/Nm3 (averaging period not specified); Continuous monitoring In one existing plant (multiple kilns): ELV= 140-180 mg/Nm3 (averaging period not specified) In one existing plant: ELV= 120 mg/Nm3 (DAV)
The ELV has been specified as a result
of recommendations made in the relevant BREF.
Dioxins and furans
0.1 ng/m3 (HHAV) 0.1 ng/Nm³ (target value) More intensive monitoring of these parameters.
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
NOx 400-200 (II.2) (DAV)
150 mg/Nm3 DAV Applies to an existing fluid bed combustion type plant.
ELVs set for pollutants not listed in Annex II or Annex V to the WID
NH3
For seven plants (of which two are new): ELV = 5-10 mg/Nm³ (DAV); Continuous monitoring
In four cases the ELV has been specified as a result of recommendations made in the BREF for waste incineration. Additional reasons include following the installation of a catalytic DENOX, and following findings from an EIA. Note that in five of the installations the ELVs set for NH3 are set at the same time as different ELVs for NOx (see above for details).
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8
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hours; II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
The operational control parameters of pH, temperature and flow for the discharge of wastewater need to be monitored across Belgium. Note that in the previous reporting period the region of Brussels did not list flow as one of the parameters controlled whereas pH was not reported as being measured in Flanders.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period in the regions
of Brussels and Flanders. The Member State has however reported that new legislation entered into force in Wallonia detailing provisions to ensure the protection of soil, surface waters, and groundwater (Article 7 of the Walloon Government Decree of 21 February 2013 determining the sectoral conditions relating to incineration and co-incineration of waste). According to the provisions listed, operators are required to conduct a document check prior to accepting hazardous waste at the waste incineration plant or waste co-incineration plan, as well as taking a representative sampling to establish the nature of the waste being treated. These provisions are similar to those described by the Member State for the previous reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period in the regions of Flanders and Wallonia. The Member State has however reported that since the previous reporting period, the criteria developed in Brussels is no longer applicable as the only household waste incinerator that previously fell within the scope of the criteria no longer generates waste water due to evapo-crystalliser and water cycling technologies.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period in the regions of Brussels and Flanders. The Member State has however reported that new legislation entered into force in Wallonia detailing provisions to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants (Article 13 of the Walloon Government Decree of 21 February 2013 determining the sectoral conditions relating to incineration and co-incineration of waste). Note that there are no changes to the provisions since the previous reporting period (the new legislation refers to provisions stipulated by the Decree on waste, 27 June 1996).
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Belgium has reported changes in Brussels and Flanders since the previous reporting period, and no changes in Wallonia. The requirements are set out below:
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In Brussels permit conditions relating to measurement of pollutants to air are now the same as those set out in Article 11(2).
In Flanders Belgium reported fewer derogations compared to the previous reporting period as set out below:
Deviation Comments (Pollutant or parameter concerned
and measurement requirement)
More stringent requirements Yes
In addition to periodic measurements for dioxins
and furans (twice a year), there is the continuous sampling of the flue gases for dioxins and furans with analyses every two or four weeks.
Exemptions for HF under Art. 11(4) Yes
Measurements indicate compliance with emission
limit conditions, thus measurements do not need to be carried out on a continuous basis, but twice a year and every three months during the first year.
Exemptions for water vapour under Art. 11(5)
Exemptions for HCl under Art. 11(6):
Exemptions for HF under Art. 11(6):
Exemptions for SO2 under Art. 11(6):
Exemptions for heavy metals under Art. 11(7):
Exemptions for Dioxins and furans
under Art. 11(7):
Note that although not a change to previous reporting period, stricter requirements (with regards to polychlorinated dioxins and furans) and derogations (with regard to exemptions for HCl, HF and SO2 under Article 11(6)) apply in certain cases in Wallonia.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Belgium reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15) in all three reporting regions.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period in Brussels and Flanders. However, Belgium has reported that new legislation entered into force in Wallonia – the relevant articles in the new legislation are set out below. Note that the Member State has provided no detail of the provisions in its response.
Article Comment
11(8) Covered by Article 5, part 5, point 2.7 of the Walloon Government Decree of 21 February 2013.
11(9) Covered by Article 15 of the Walloon Government Decree of 21 February 2013.
11(11) Covered by part 7, point 1.2 of the Walloon Government Decree of 21 February 2013.
11(12)* Covered by part 7, point 1.3 of the Walloon Government Decree of 21 February 2013.
11(10) Covered by part 7, point 1.1 of the Walloon Government Decree of 21 February 2013.
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*Note that although there has been no change since the previous reporting period for Brussels, the article with the relevant provisions is Article 11(11) (rather than Article 11(10) as reported in the previous reporting period).
Although no changes have taken place in Brussels since the previous reporting period, additional information has been provided with regards to Article 11(10) outlining the provisions made within the permitting process. The Member State reported that the results of measurements are sent systematically to the competent authority which is responsible for verifying them, and that the competent authority also occasionally conducts its own tests in authorised laboratories.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period concerning Article 11(9) and 11 (16) in Brussels and Flanders. However, Belgium has reported that new legislation entered into force in Wallonia with the provisions set out in Article 11(9) transposed to Article 15 of the Walloon Government Decree of 21 February 2013, and those set out in Article 11(16) transposed to part 7, point 2 of the same decree. Note that the Member State has provided no detail of the provisions in its response.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
There has been no change since the previous reporting period in Brussels and Flanders. However, Belgium has
reported that new guidance was published in Wallonia under Part 7, point 1.2 of the Annex to the Walloon Government Decree of 21 February 2013. No details outlining the guidance was provided by the Member State but a link to the document was included in the response - http://environnement.wallonie.be/legis/pe/pesect065.html.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change to the procedures in place compared to the last reporting period; however, the Member State has reported that since 2013 the provisions for Wallonia are set out in the Walloon Government
Decree of 21 February 2013. No article or page reference was provided by the Member State to locate the relevant provisions in the decree.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change to the arrangements in place compared to the last reporting period in Flanders and Wallonia. In addition to what was reported in the previous reporting period for Brussels, Belgium reported that new permit applications and final decisions are publicly available at the regional authority offices (as well as the local authority offices).
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in response to part (a) of this question compared to the last reporting period. The Member State has provided more detail in response to (b), as follows:
Brussels: Consultation is free of charge but photocopies must be paid for. Flanders: Access to public documents is free of charge and photocopies can be made for a charge.
Wallonia: Access to the information is free of charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to question 25 compared to the last reporting period in Brussels and Flanders. However, Belgium has reported that new legislation applies in Wallonia, although the provisions
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specified have not changed (the provisions are stipulated in Article 17(1) of the Walloon Government Decree of 21 February 2013). There has been no change in the response to question 26 compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period in Flanders and Wallonia. However, since the previous reporting period Belgium has reported that no incineration or co-incineration plants with a nominal capacity of less than 2 tonnes per hour now operate in Brussels – thus there is no longer a need for public identification.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period in Brussels and Flanders. The following changes are reported by Belgium concerning provisions in Wallonia (Articles 5 and 6 of the Walloon Government Decree of 21 February 2013, http://environnement.wallonie.be/legis/pe/pesect065.html):
The operator cannot incinerate waste for more than 4 consecutive hours.
The cumulative duration of operation in such conditions over one year shall not exceed 60 hours.
In the case of a breakdown, the operator shall reduce or close down operations as soon as practicable until normal operations can be restored.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No new general remarks were provided by Belgium. The Member State referred to an observation made in the
previous reporting period in relation to definitions in Flanders – see previous report for detail.
SUMMARY OF CHANGES
Belgium submitted a partially complete answer to the WID questionnaire as per the Commission Decision
2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
72 installations (56 incinerators and 16 co-incinerators) fall within the scope of the Directive, 88% of which recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. The total permitted capacities of waste throughput in Brussels is 450,000 tonnes/year and no response was provided for Wallonia, and the question is not relevant to Flanders (optional question).
ELVs, operational parameters and monitoring requirements
Belgium reported that four plants are exempt from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4) one of which Belgium has reported is a new derogation. It was granted to a new plant with capacity of 25,000 tonnes per year, incinerating hazardous waste. No further details of the authorisation were reported.
The air emission limit values are different to those given in Annex II and Annex V for two existing parameters in eight plants (NOx for incinerators and co-incinerators, and dioxins and furans for incinerators). A new parameter has also been established for seven incinerator plants for NH3.
The requirements of the permit for the measurement of pollutants to air and process operation parameters are different to those set out in Article 11(2) in all three regions. Changes compared to the previous reporting period were reported only in Belgium and Flanders. The requirements for Brussels and Flanders are as follows:
In Brussels permit conditions relating to measurement of pollutants to air are now the same as those set out in Article 11(2).
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In Flanders, Belgium reported more stringent requirements for measuring dioxins and furan (there is the continuous sampling of the flue gases for dioxins and furans with analyses every two or four weeks) and exemptions for HF under Article 11(4) of the Directive (reporting is only required twice a year and every 3 months in the first year)
General legislative provisions and procedures
There have been no changes in the responses provided on legislative provisions and related procedures since the previous reporting period in Brussels and Flanders.
However, Belgium has reported that new provisions were introduced in Wallonia under the Walloon Government Decree of 21 February 2013 determining the sectoral conditions relating to incineration and co-incineration of waste. In most cases the provisions transposing the Directive requirements have not changed under the new legislation, and in others the detail has not been provided by the Member State to make the comparison (e.g. the transposition of Article 11 concerning the provisions within the permitting process that are in place to ensure compliance as regards air emissions provisions). Only in one instance has a change been noted and this concerns the provisions within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation. Under Articles 5 and 6 of the Walloon Government Decree of 21 February 2013 the operator cannot incinerate waste for more than 4 consecutive hours, and the cumulative duration of operation in such conditions over one year shall not exceed 60 hours. Further (as reported in the previous reporting period) in the case of a breakdown, the operator shall reduce or close down operations as soon as practicable until normal operations can be restored.
A.3 Bulgaria
A.3.1 Analysis of the completeness
Table 5: Completeness assessment of answers reported by Bulgaria – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
(a-b)
Whilst in question 1 Bulgaria reports a total of 10 plants (3 incinerators and 7 co-incinerators), the response to question 1.2 only lists 5 plants. In addition, no details on the latitude and longitude of the plants have been provided in question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Technical difficulty with the reporting
tool. No response available.
Co-incineration plants subject to
the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
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Question Completeness Comment
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.a
8.b
Emission limit exemptions for
cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air
and water (Article 11)
17
18
Handling the results of measurements and determining
compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
23
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Question Completeness Comment
Access to information and public participation (Article 12)
24 No information is provided on whether
environmental information is provided free of charge.
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Bulgaria provided an almost complete response to the questionnaire. Only the response
to questions 1.2 and 24 are partially incomplete. In addition, there seems to be a
technical problem with question 4, which is not included in the Word or Excel files provided for Bulgaria.
A.3.2 Analysis of Bulgaria responses
The table below contains detailed analysis of the responses provided by Bulgaria to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Bulgaria under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given. In cases where text has been quoted directly from the English
translation of the report, it is presented in italics.
Table 6: Bulgaria – Response analysis table
BULGARIA
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 10 plants fell within the scope of the Directive, of which 7 were co-incineration plants.
7 permits were issued in Bulgaria and all co-incineration plants recovered the heat from the process.
Bulgaria has not reported the total permitted capacity of waste throughput (this was an optional question).
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Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Bulgaria listed 5 plants, of which 4 were cement kilns and one was not identified.
Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
There has been no change since the previous reporting period. In Bulgaria existing incineration or co-incineration plants are interpreted as plants which started operating before the national legislation came into force.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to Directive 2000/76/EC during the reporting period. In remarks Bulgaria stated that it is questionable whether mobile plants are state of the art.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There seems to be a technical problem with question 4, which is not included in the Word or Excel files provided for Bulgaria. In the previous reporting period the main types of wastes co-incinerated are: waste oils, plastics, textiles, RDF and tyres.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
Bulgaria reported no co-incineration plants to which emission limits set out in Annex V applied
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There has been no change in the response to this question compared to the last reporting period. Biowaste and infectious waste continue to be considered inappropriate for sampling.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-
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incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Bulgaria reported that 3 exemptions have been granted in accordance with Annex II.1 for SO2 and TOC.
Pollutant Details
SO2 Granted to 1 plant.
SO2 limit value of 400 mg/Nm³ (averaging period is not stated).
TOC Granted to 2 plants
TOC limit values reported range between 100 and 50 mg/Nm³ (averaging period is not stated)
Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³], expressed as daily average values, may be authorised in cases where TOC and SO2 do not result from the incineration of waste. Emission limit values reported by Bulgaria are between 8 to 15 times higher compared to Annex II.1.2 of the Directive. Bulgaria explains that the exemptions were granted because it was demonstrated that these emissions result from incineration of raw materials used for cement production, rather than from incineration of waste. Furthermore Bulgaria reports that these emission limit values comply with the national law for cement kilns using conventional fuels.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (as per the previous reporting period).
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
According to the provisions set out in Regulation No 6 of 28 July 2004 and Regulation No 4 of 5 April 2013, the operational control parameters of pH, temperature and flow (as well as any additional plant specific operational parameters) for the discharge of wastewater need to be monitored continuously.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
Provisions to ensuring protection of soil, surface waters or groundwater when operating waste incineration
plants are defined in the national legislation (Article 31(1) of Regulation No 6 of 28 July 2004). Bulgaria further indicates that these namely require that the sites of incineration or co-incineration plants, including their yards for intermediate storage of waste, must be designed and/or operated in such a way as to ensure the prevention of accidental and unauthorized releases of harmful or hazardous substances.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in Bulgaria compared to the last reporting period.
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Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
In addition to what was indicated in the last reporting period, Bulgaria adds that non-preventable residues are
recovered at or outside the relevant incineration or co-incineration facility. The methods for recovery and/or disposal of the particular residues from the operation of the incineration or co-incineration plant are determined on the basis of an analysis of their physical and chemical properties and of the risks for human health and pollution of the environment.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Bulgaria compared to the last reporting period. These are identical to those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Bulgaria compared to the last reporting period. These are identical to those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in Bulgaria compared to the last reporting period with regards to the provisions in place covering items 8, 11 and 12 of Article 11. With regards to items 9 and 10, Bulgaria adds the following:
Article Comment
11(9) Bulgaria indicated that the results from all measurements are recorded, processed and presented to the competent authority in the form of a report which allows the competent authority to verify compliance with the conditions laid down in the permits or integrated permits as well as compliance with the operating conditions, emission limit values and emission standards established by the Regulations.
11(10) The permit for waste related activities (or an integrated permit) sets the necessary conditions for the construction and operation of the waste incineration and co-incineration plants.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change since the previous reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
Bulgaria provides additional detail to what was reported in the previous reporting by indicating the conditions imposed in permits in the event of breach of an emission limit value. Permit holders are obliged to
• Maintain a Logbook providing details of the spill (e.g. the date and time of identification of the spill, causes, the polluted area and the scale of pollution, the pollutants, information on the containment in which the spilled fluid is collected or of the sorbent used, the consequences of the spill and the remedial measures undertaken to eliminate the factors that had caused the spill).
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• Record and keep at their sites the results from the implementation of the instructions and make these records available to the competent authorities upon request.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the
final decision available.
The application on a new permit is publicly available at the national and local authorities and on the internet. The public has between 10 and 30 days to comment on the application. The final decisions are made available on the internet only.
Bulgaria does not provide information regarding updated permits.
24. With regard to the availability of information throughout the permitting process is there any information
related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit?
There has been no change compared to the last reporting period
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
Bulgaria requires operators that have been granted integrated permits to submit an annual report in order for
the authority to verify compliance with the permit conditions. Penal provisions might be applied in case the operator fails to submit the report.
• The report must contain information on (i) emissions to air, (ii) emissions to water, (iii) capacity of the plant, (iv) type of plant, (v) type of waste incinerated an (vi) type of installation.
• Every year the Executive Environment Agency (IAOS) publishes on its website the annual reports on
compliance with the conditions laid down in the integrated permits as prepared by operators. These are available here: http://eea.government.bg/bg/r-r/r-kpkz/godishni-dokladi/
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change compared to the last reporting period
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change compared to the last reporting period
Question 30. Any other remarks.
Bulgaria notes that Regulation No 6 of 28 July 2004, which transposed the requirements of WID, was
repealed with effect from 16 April 2013 (SG No 36 of 16 April 2013). Regulation No 4 of 5 April 2013 (SG No 36 of 16 April 2013), which transposes the requirements laid down in Article 31(2), Chapter IV and Annex VI of Directive 2010/75/EU on industrial emissions, came into force on 16 April 2014.
SUMMARY OF CHANGES
The information in the report submitted by Bulgaria covers almost all the requirements of the questionnaire, providing data to demonstrate the status regarding implementation. Changes or additional information in comparison with the previous reporting period, relate to questions 1, 9, 13, 14, 16, 19, 22 and 23. These are summarised below:
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Installations
A total of 10 plants fall within the scope of the Directive (3 incineration plants and 7 co-incineration cement kilns). In total 10 permits were issued. 7 plants recovered heat from the process. Bulgaria has no plants to which the provisions of Annex V applied; there are also no relevant mobile plants in the country. Bulgaria reported that definition of “existing incineration or co-incineration plant” is interpreted differently in the country because the transposition of the Directive to national legislation happened in 2004, after the dates in the definitions expired.
ELVs, operational parameters and monitoring requirements
3 plants have been granted exemptions from the requirements for SO2 and TOC in accordance with Annex II.1; the exemptions were issued because emissions of these pollutants originate from the incineration of raw materials used for cement production rather than from the incineration of waste. As per the previous period, Bulgaria has not set more stringent ELVs to air or water under Annexes II, IV or V.
General legislative provisions and procedures
In addition to what was reported in the previous period, Bulgaria provides further details of the provisions to ensure the protection of soil, surface water and groundwater as well as the minimisation of residues.
It also further describes the conditions imposed in permits in the event of breach of an emission limit value, which include the requirement to maintain a Logbook providing details of any spill.
In order to verify compliance of the plant with permit requirements and legislation, operators need to submit an annual report to the competent authorities. The national legislation and instructions specify the content of the report. Operators failing to report may be subject to penalties.
The public has access to information; however under Bulgarian environmental law there a number of instances in which such access can be restricted and details of those have been provided (e.g. on the grounds of official, commercial and trade secrets). It is unclear if access to information for the public is free of charge, as no answer has been provided to the respective part of the question.
A.4 Cyprus
A.4.1 Analysis of the completeness of the report
Table 7: Completeness assessment of answers reported by Cyprus – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
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Question Completeness Comment
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and
harmfulness of residues (Article 9) 16
Measurement of pollutants to air and
water (Article 11)
17
(a- b)
18
(a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
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Question Completeness Comment
27
Abnormal operation 28
29
Other remarks 30
Cyprus provided a complete response to the questionnaire.
A.4.2 Analysis of Cyprus’s responses
The table below contains detailed analysis of the responses provided by Cyprus to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Cyprus under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 8: Cyprus – Response analysis table
CYPRUS
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down
between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 1 plant fell within the scope of the Directive - a co-incineration plant which is not reported as recovering heat generated by the incineration process.
3 permits were issued, including: an air pollutant release permit; a discharge permit for discharges to soil and water; and a waste management permit.
No response was provided for the total permitted capacity of waste throughput (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Cyprus listed 1 co-incineration cement kiln plant.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
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Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with definitions were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were co-incinerated in cement kilns (EWC codes of each of the wastes co-incinerated are set out under remarks, where they were provided by the Member State):
Type of plant Category of waste Co-incinerated? Remarks
Cement kilns Waste oils
Solvents
Filter cakes
Wood waste
Plastics
Textiles
RDF Yes 191210
Fluff from shredding
Other Yes Meat and bone meal; partially stabilised wastes which contain hazardous substances; fly ash and boiler dust from power plants; waste from mechanical treatments of waste which contain hazardous substances; and waste from gaseous waste treatment plants (020202,190304,100104,191211,190899)
The permitted capacity of different waste types was not provided (optional question).
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change since the previous reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There is no category of waste considered inappropriate for sampling in Cyprus (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type
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of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
No exemptions have been granted in accordance with Annex II.1.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No exemptions have been granted in relation to the air limit values given in Annex II or Annex V.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
There has been no change with regards to the ELVs for discharges of wastewater from flue gas cleaning equipment established in Cyprus compared to the last reporting period. The ELVs apply exactly, and it is specified that wastewater is not produced from flue gas cleaning equipment in the co-incineration plant.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period). The Member State notes that under the discharge permit, a plant may only discharge cooling water into the sea and so no wastewater discharges are made.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
No wastewater discharges are made into the water, but since the previous reporting period pH and temperature operational control parameters have been determined for monitoring the cooling water discharged into the sea.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change since the previous reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change since the previous reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change since the previous reporting period.
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Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Cyprus reported that permit conditions relating to measurement of pollutants to air are different to those set out in Article 11(2), as follows:
Deviation Comments (Pollutant or parameter concerned and measurement requirement)
More stringent requirements
Not mentioned in the response by Cyprus.
Exemptions for HF under Article 11(4)
Yes Although no exemption is currently in place, the Air Pollutant Release Permit stipulates that the continuous measurement of HF may be omitted if HCI treatment stages are used which ensure that the ELV for HCI is complied with. In this case, the emissions of HF shall be subject to periodic measurements (at least 2 measurements annually).
Exemptions for water vapour under Article 11(5)
Yes Although no exemption is currently in place, the Air Pollutant Release Permit stipulates that the continuous measurement of the water vapour content shall not be required if the sampled exhaust gas is dried before the emissions are analysed.
Exemptions for HCl under Article 11 (6)
Exemptions for HF under Article 11(6)
Exemptions for SO2 under Article 11(6)
Exemptions for heavy metals under Article 11(7)
Exemptions for dioxins and furans under Article 11(7)
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Cyprus since the last reporting period. The conditions set out in Article 11(14) and 11(15) do not apply because the plant does not produce waste water.
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
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The provisions concerning air emissions are set under the Air Pollutant Release Permit (previously set under the Waste Gas Emission Permit in the last reporting period). There have been no changes with regards to the provisions in place covering items 8, 9 and 10 of Article 11 of the Directive. With regards to item 11 and 12, the following now applies:
Article Comment
11 (11) The Air Pollutant Release Permit contains a condition concerning the co-incineration plant
(cement kiln) reflecting the requirements of the Directive.
11 (12) The Air Pollutant Release Permit contains a condition according to which the operator must
construct appropriate sampling boxes and platforms in the stack of the gaseous waste treatment system of the co-incineration process, in accordance with the technical specifications included in an annex to the permit. The annex refers to the location where boxes must be constructed, the requisite number of boxes, their dimensions, as well as the characteristics which the platform of access to the stack must have. Finally, it refers to the supplies which are necessary for sampling, such as the supply of water and electricity. The operator of the co-incineration plant has constructed appropriate sampling boxes and platforms which are adequately accessed.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
The report from Cyprus does not provide information on any separate guidance issued with regards to
validated daily average emission data and no link to further information is provided.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
In the case of an emergency or other operational issues which may lead to exceeding the ELVs, the operator has to inform the authorities without delay, and submit a report with details of the incident as well as informing the authority if the measuring equipment is out of operation for more than 24 hours. In addition to the procedure established under the Waste Gas Emission Permit, under the Air Pollutant Release Permit the operator is required to keep a file with the date and duration of each exceedance of ELV recorded, with the
total annual duration of operation outside the ELV calculated each year. This file must be available for inspection at any time and included in the annual report.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change since the previous reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period – all information is publically available at no charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
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There has been no change in the information provided by Cyprus compared to the last reporting period and the provisions outlining content of the annual reports required by operators of all plants with a capacity over 2 tonnes/hour continue to be set out in the conditions of the Waste Gas Emission Permit. The reports are also still available upon request from the competent authorities.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
Information on all licensed plants is available to the public via the internet. The online catalogue contains
details of waste incineration plants with capacity lower than 10 tonnes per day and is available at: http://www.mlsi.gov.cy/mlsi/dli/dli.nsf/All/3F693C6469DF096FC2256EB0003A567D?OpenDocument.
It is unclear why Cyprus refers to plants with capacity of 10 tonnes per day rather than 2 tonnes per hour, and whether these thresholds are seen as equivalent. However this is not considered as a major issue, given that no such plants operated in Cyprus between 2009 and 2010.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
The Air Pollutant Release Permit specifies that cement kilns, during co-incineration and incineration, must have and operate an automatic system to prevent waste feed:
i. At start-up, until the temperature of 850 °C or 1,100 °C, as the case may be, has been reached;
ii. Whenever the temperature of 850 °C or 1,100°C, as the case may be, is not maintained;
iii. Whenever the continuous measurements show that any Emission Limit Value is exceeded, due to disturbances or failures of the purification devices.
In the case of a breakdown, the operator of the plant shall close down the operations as soon as practicable until normal operation can be restored.
In order to obtain a valid daily average value as regards the continuous measurement systems for emissions of gaseous pollutants, no more than 5 half-hourly values in any day, or 10 daily average values per year shall be discarded due to malfunction or maintenance of the continuous measurement systems.
The Air Pollutant Release Permit also requires the operator to develop a programme of actions if failure of the gaseous waste treatment system is observed. The programme must include the actions of the operator and of the maintenance experts as well as emergency plans.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The Air Pollutant Release Permit establishes:
a maximum permissible period of abnormal operation with exceedance of ELVs of between 3 and 4 hours (Article 13 specifies a limit of 4 hours)
a maximum cumulative duration of periods exceeding ELVs over one year of 120 hours (less stringent than the 60 hour limit set by Article 13 of the Directive)
Question 30. Any other remarks.
No general remarks are provided by Cyprus.
SUMMARY OF CHANGES
Cyprus submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
1 plant fell within the scope of the Directive in Cyprus, which is a cement kiln co-incineration plant – not reported as recovering heat generated by the incineration process. In total 3 permits were issued for the plant in question, including: an air pollutant release permit; a discharge permit for discharges to soil and water; and a waste management permit. No response was provided for the total permitted capacity of waste throughput (this was an optional question), or for the energy efficiency figures for municipal solid waste incineration plants that carry out recovery operations.
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ELVs, operational parameters and monitoring requirements
The following information on exemptions and derogations has been provided by Cyprus:
There were no co-incineration plants to which the provisions of Annex V applied.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
No exemptions from the emission limits for NOx, dust, SO2 or TOC for cement kilns co-incinerating waste have been granted in accordance with Annex II.1.
No exemptions have been granted in relation to the air limit values given in Annex II or Annex V.
Although no wastewater discharges are made into the water, since the previous reporting period pH and temperature operational control parameters have been determined for monitoring the cooling water discharged into the sea. Further, Cyprus reported that permit conditions relating to measurement of pollutants to air are different to those set out in Article 11(2) allowing exemptions for HF and water vapour, although no exemption for either is currently in place.
General legislative provisions and procedures
The provisions concerning air emissions are set under the Air Pollutant Release Permit (previously set under the Waste Gas Emission Permit in the last reporting period). There have mostly been no changes with regards to the provisions in place, except for the following additions:
The Air Pollutant Release Permit contains a condition concerning the co-incineration plant (cement kiln) reflecting the requirements of the Directive (Article 11 (11)).
The Air Pollutant Release Permit contains a condition according to which the operator must construct appropriate sampling boxes and platforms in the stack of the gaseous waste treatment system of the co-incineration process, in accordance with the technical specifications included in an annex to the permit (Article 11 (12)).
In addition to the procedure established under the Waste Gas Emission Permit, under the Air Pollutant Release Permit the operator is required to keep a file with the date and duration of each exceedance of ELV recorded, with the total annual duration of operation outside the ELV calculated each year. This file must be available for inspection at any time and included in the annual report.
In addition to the provisions controlling the abnormal operating conditions for incineration or co-incineration plants from the previous reporting period, further conditions have been introduced. In brief, the Air Pollutant Release Permit specifies that:
Cement kilns, during co-incineration and incineration, must have and operate an automatic system to prevent waste feed.
In the case of a breakdown, the operator of the plant shall close down the operations as soon as practicable until normal operation can be restored.
In order to obtain a valid daily average value as regards the continuous measurement systems for emissions of gaseous pollutants, no more than 5 half-hourly values in any day, or 10 daily average values per year shall be discarded due to malfunction or maintenance of the continuous measurement systems.
The operator must develop a programme of actions if failure of the gaseous waste treatment system is observed. The programme must include the actions of the operator and of the maintenance experts as well as emergency plans.
The maximum admissible operations duration for incineration and co-incineration under abnormal conditions is between 3 and 4 hours, and the maximum cumulative duration of periods exceeding ELVs for one year is now 120 hours.
A.5 Czech Republic
A.5.1 Analysis of the completeness of the report
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Table 9: Completeness assessment of answers reported by the Czech Republic – WID
Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex
II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity
for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and
harmfulness of residues (Article 9) 16
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Question Completeness Comment
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements
and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of
breaches of emission limit values 22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
The Czech Republic provided a complete response to the questionnaire.
A.5.2 Analysis of the Czech Republic’s responses
The table below contains detailed analysis of the responses provided by the Czech
Republic to the WID questionnaire covering the period 2012-2013. The information
presented is based solely on the information reported by the Czech Republic under each
question. The table contains a summary of the response, as well as further comments
and descriptive analysis of the answers given.
Table 10: Czech Republic – Response analysis table
CZECH REPUBLIC
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 42 plants fell within the scope of the Directive, of which 5 were co-incineration plants.
38 permits were issued in the Czech Republic. Those plants without a permit are out of commission at the time of reporting as they do not comply with the necessary technical operating conditions.
35 plants recover heat generated by the incineration process. No explanation is provided as to why the remaining plants do not recover heat.
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The total permitted capacity of waste throughput is 1,205,463 tonnes/year, of which 35% is allocated to co-incineration plants.
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with
a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
The Czech Republic listed 42 plants, of which 5 were co-incineration and 37 incineration plants.
Of the reported co-incineration plants, all were cement kilns.
Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for 3 of the plants described in question 1.2 (all of which are incineration plants). The energy efficiency figures for the respective incineration plants are 0.70, 0.75, and 0.98. No explanation was provided by the Member State as to why energy efficiency figures were not provided for the other plants.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with definitions were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to Directive 2000/76/EC during the reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were co-incinerated in cement kilns (EWC codes of each of the wastes co-incinerated are set out below as provided by the Member State):
Type of plant Category of waste Co-incinerated? Remarks
Cement kilns Waste oils Yes 130205; 130701
Solvents Yes 140603
Wood waste Yes 030101
Plastics Yes 070213
RDF Yes 191210
Other Yes Tyres (160103); Other waste (including waste mixtures) from mechanical processing of
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waste containing dangerous materials (191211)
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in
Annex V to the Directive?
As with the previous reporting period, the emission limits set out in Annex V do not apply to any co-incineration plants in the Czech Republic.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
Since the last reporting period the Act on Atmospheric Protection entered into force on 01/09/2012 (No 201/2012), repealing earlier legislation (Decrees No 2005/2009 and No 356/2002). This act includes new provisions for permit conditions specifying the types, quantities and properties of waste to be incinerated (Section 12).
The Directive requirements for permit conditions to specify the minimum and maximum flows of hazardous waste are set out in Section 12 (4) – with particular reference made to the flows for polychlorinated biphenols, pentachlorphenol, chlorides, fluorides, sulphur and heavy metals. The content requirements for permit applications and permit conditions are set out in Appendix 7 of the Act, which stipulates that permit applications must include the range of calorific values for hazardous waste from a stationary source (especially fuels and waste).
At the time of reporting, 10 permit conditions specify the maximum allowable concentration of pollutants (principally in relation to PCBs, chlorides, fluorides, heavy metals, sulphur, PCP and PAH).
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Medical and veterinary wastes sealed in protective packaging are excluded from the representative sampling requirement under Act No 201/2012.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
As with the previous reporting period, no exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust,
SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
The Czech Republic reported that exemptions have been granted for existing cement kiln co-incinerators in relation to SO2 and TOC emissions. The exemptions are as follows:
Pollutant Details
SO2 Four exemptions applied at existing plants co-incinerating the following wastes: 191210, 070213, 160103, 050106 and 191210.
SO2 limit values reported were 260 mg/m3, 400 mg/m3 (for two exemptions), and 300 mg/m3 (daily average values),
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The exemptions were granted because emissions did not originate from the waste fraction of incinerated material.
TOC Five exemptions applied existing plants co-incinerating the following wastes: 191210, 070213, 160103, 050106, 191211 and 191210.
TOC values of 50 mg/m3 (for two exemptions), 25 mg/m3, 100 mg/m3 and 40 mg/m3 (daily average values).
The exemptions were granted because emissions did not originate from the waste fraction of incinerated material.
Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³], expressed as daily average value, may be authorised in cases where TOC and SO2 do not result from the incineration of waste.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
As in the case of the previous reporting period, different air limit values for incinerators have been set for three new parameters, as follows:
Parameter WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
NH3 n/a 2 incineration plants; ELV = 50 mg/Nm3 (DAV); Periodic monitoring
The plants utilised Selective Catalytic Reduction
PCBs n/a 2 incineration plants; ELV = 0.2 mgTEQ/m3; Periodic monitoring
The ELVs were set in order to reduce emissions of PCBs given the types of waste incinerated at the plants.
Hexachlorobenzene (HCB) n/a
1 incineration plant; ELV = 0.2 mgTEQ/m3 (DAV); Periodic monitoring
It appears from the response provided that the composition of waste incinerated could have resulted in elevated HCB emissions
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours; II)
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
There has been no change with regards to the ELVs for discharges of wastewater from flue gas cleaning equipment established in the Czech Republic compared to the last reporting period. The limit values in Annex IV apply exactly.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to
the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
The Member State has not defined ELVs for any additional pollutants to those listed in Annex IV of the WID.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting
process for waste water discharges?
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There has been no change since the previous reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change since the previous reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change since the previous reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change since the previous reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period (the permit conditions relating to measurement of pollutants to air are identical to those set out in Article 11(2)).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period (the permit conditions relating to the measurement of pollutants to water are identical to those set out in Article 11(14) and 11(15)).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
In addition to the provisions in place at the time of the previous reporting period for items 8, 9, 10, 11 and 12 of Article 11, the following now also applies since the entry into force of Act 201/2012 and Decree 415/2012:
Article Comment
11(8) Additional operating conditions for stationary sources that thermally process waste are
established under Annex 4 of Act 201/2012 and Decree 415/2012 along with emission limits related to established reference oxygen content levels for waste incinerators, other stationary sources, and cement kilns. The reference oxygen content levels are determined in accordance with Annex II of the Directive.
11(9) Provisions for evaluating single and continuous measurements for operating records are set in
Decree 415/2012 (section 5 and 8) to enable the comparison of data on mass concentration of pollutants and flow, and emissions. Further to the Directive, it is specified that continuous measurements should be recorded electronically and printed where the emission limit is exceeded.
11(11) The technical procedure for evaluating continuous measurement is specified under Decree
415/2012 (section 8). Further to the Directive, the provisions specify how the average for monitoring should be calculated according to the intervals between each measurement and depending on the emission source.
11(12) The method and conditions for determining pollution levels by single measurement are set out
in Decree 415/2012 (section 4) which, in keeping with the Directive, must be carried out according to relevant CEN-standards (as listed in Part I of Annex 1 to this Decree). The conditions also specify that for a single measurement one may only use those measurement methods which allow establishing pollutant concentrations in a range from 10% to 200% of the specific emission limit.
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11(10) Whereas the Directive specifies that an emission limit is regarded as being complied with if 97% of the daily average value over the year does not exceed the emission limit value, the Decree 415/2012 (section 6) specifies that the emission limit is regarded as compliant up to 120% pf the emission limit value. However, for stationary sources thermally treating waste, during sampling of heavy metals, PCDD and PCDF no pollutant concentration value can exceed the value of specific emission limits.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with
(a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average
emission data (Article 11(11)).
In 2013 additional guidance for verifying the accuracy of continuous measurement results for pollutants released to atmosphere by stationary air pollution sources was published, following the new requirements (based on the binding ČSN 141 81 standard) that were established in 2012 for the annual verification of result accuracy for continuous measurement (section 6 (5) of Act 201/2012). The guidance is available here, http://www.mzp.cz/cz/overovani_spravnosti_mereni_metodika.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change since the previous reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change to the provisions since the previous reporting period. However, there have been changes to the legislation and the provisions are now stipulated under Act 201/2012, section 30.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period – all information is publically available at no charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change since the previous reporting period concerning the requirements, content and availability for annual reports submitted by incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change since the previous reporting period – plants are identified on the website of the Czech
Hydrometeorological Institute, http://portal.chmi.cz/files/portal/docs/uoco/web_generator/incinerators/index_CZ.html.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-
incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
In addition to the provisions controlling the abnormal operating conditions for incineration or co-incineration plants
from the previous reporting period, further conditions have been introduced which apply to operators of stationary sources (as stipulated in Act 201/2012, section 17).
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In summary, operators of stationary sources are required to curtail or shut down without delay the stationary source at times of abnormal operation which cannot be remedied within 24 hours of their occurrence. These requirements do not apply where the shutdown would lead to higher levels of pollution than that caused by its continued operation or, if as a result of interruption of heat supplies human health were to be endangered. The operator is obliged to inform the Regional Office and Inspection of any period of abnormal operation within 48 hours of its occurrence.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation
during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The maximum admissible operations duration for incineration and co-incineration under abnormal conditions is 4 hours. The maximum cumulative duration of periods exceeding ELVs for one year was 60 hours, however since 1 September 2012 it is 120 hours (less stringent than the 60 hour limit set by Article 13 of the Directive). No
explanation is provided as to why this period is less stringent than the Directive.
Question 30. Any other remarks.
No general remarks are provided.
SUMMARY OF CHANGES
The Czech Republic submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
42 plants fell within the scope of the Directive in the Czech Republic, of which 37 are incineration plants and 5 co-incineration plants. In total 38 permits were issued. Those plants without a permit were out of commission at the time of reporting for not complying with the necessary technical operating conditions. The total permitted capacity of waste throughput is 1,205,463 tonnes/year, of which 35% is allocated to co-incineration plants. Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for 3 of the plants.
ELVs, operational parameters and monitoring requirements
The following information on exemptions and derogations has been provided by the Czech Republic:
There were no co-incineration plants to which the provisions of Annex V applied.
Medical and veterinary wastes sealed in protective packaging are excluded from the representative sampling requirement under Act No 201/2012.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
With regards to ELVs, the Czech Republic reported different limit values for pollutants to air compared to those in Annex II or Annex V of the Directive. As in the case of the previous reporting period, different air limit values for incinerators have been set for three new parameters (NH3, PCBs, and HCB). In addition, it is reported that exemptions have been granted for existing cement kiln co-incinerators in relation to SO2 and TOC emissions. The exemptions were granted because emissions did not originate from the waste fraction of incinerated material.
General legislative provisions and procedures
Several changes to the provisions for air emissions measurements within the permitting process have been made since the previous reporting period under Act 201/2012. In summary the changes are as follows (with reference to the relevant Directive article in parenthesis):
Operating conditions apply to stationary sources that thermally process waste, establishing reference oxygen content levels for waste incinerators, other stationary sources, and cement kilns (Article 11 (8)).
Continuous measurements should be recorded electronically and printed where the emission limit is exceeded (Article 11 (9)).
Criteria specifying how the average for monitoring should be calculated according to the intervals between each measurement and depending on the emission source (Article 11 (11)).
The method and conditions for determining pollution levels by single measurement must be carried out according to relevant CEN-standards (Article 11 (12)). The conditions also specify that for a single measurement one may only use those measurement methods which allow establishing pollutant concentrations in a range from 10% to 200% of the specific emission limit.
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The emission limit is regarded as compliant up to 120% pf the emission limit value. However, for stationary sources thermally treating waste, during sampling of heavy metals, PCDD and PCDF no pollutant concentration value can exceed the value of specific emission limits (Article 11 (10)).
In 2013 additional guidance for verifying the accuracy of continuous measurement results for pollutants released to atmosphere by stationary air pollution sources was published.
In addition to the provisions controlling the abnormal operating conditions for incineration or co-incineration plants from the previous reporting period, further conditions have been introduced which apply to operators of stationary sources (as stipulated in Act 201/2012, section 17). In brief, the maximum admissible operations duration for incineration and co-incineration under abnormal conditions is 4 hours, and the maximum cumulative duration of periods exceeding ELVs for one year is now 120 hours (less stringent than the 60 hour limit set by Article 13 of the Directive). No explanation is provided as to why this period is less stringent than the Directive.
A.6 Denmark
A.6.1 Analysis of the completeness of the report
Table 11: Completeness assessment of answers reported by Denmark – WID
Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
Total throughput was only provided
for one plant; however this is an optional question and was not considered a gap.
1.2
Whilst in question 1 Denmark reports
a total of 37 plants, in question 1.2 only lists 34 plants (it appears that 3 incinerators are not included). In addition, no details on the latitude and longitude of the plants have been provided in question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
8
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Question Completeness Comment
Authorisations containing conditions
in accordance with Article 6(4)
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit
values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for
waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional
pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18
(a-b)
Handling the results of measurements
and determining compliance for emissions to air (Article 11)
19 Denmark refers to the specific
articles and annexes of national legislation but no further description of provisions is provided.
Handling the results of measurements
and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
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Question Completeness Comment
Other remarks 30
Denmark provided an almost complete response to the questionnaire. Only the response to questions 1.2, 19 and 20 are partially incomplete.
A.6.2 Analysis of Denmark’s responses
The table below contains detailed analysis of the responses provided by Denmark to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Denmark under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 12: Denmark – Response analysis table
Denmark
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 37 plants fell within the scope of the Directive, of which 34 are incineration plants and 3 are co-incineration plants.
In total 88 permits were issued – 81 for incineration and 7 for co-incineration plants. It is of note that
in the last reporting period Denmark reported that all plants had been issued with at least one permit.
36 plants recover the heat from the incineration process.
The total waste throughput was provided for the following: 1 co-incineration plant (25,250 tonnes per year); 35,950 tonnes of dry matter for three sludge incineration plants; 3,591,500 tonnes of waste in 2012 and 3,676,500 tonnes in 2013 for 30 of the 34 incineration plants.
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Denmark listed 34 plants and details were provided for all of them. Of these, 3 were co-incineration plants and 31 incineration plants. It seems that Denmark understood that this question only requested to list plants with capacity above 2 tonnes per hour.
Of the reported co-incineration plant 1 was a cement kiln and 2 were classified as other industrial facilities.
Where applicable Denmark reports for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant.
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Denmark
This was provided for 21 plants. The efficiency figures were equal to or above 60% ranging between 0.71 and 1.40.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
There were no problems reported with the definitions, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were co-incinerated in the co-incineration plants:
Type of plant Category of waste
Co-incinerated?
Remarks
Cement kiln
Waste Oils Yes Bitumen
Solvents Yes Glycerol
Filtercakes No
Wood waste No
Plastics No
Textiles No
RDF No
Fluff from shredding
No
Sludge Yes Dried sewage sludge
Other Yes Tyre chips. Meat and bone meal. Non-hazardous combustible waste.
Other industrial facilities
Other Yes
Insulating or heat transmission oils containing PCBs (13 03 01) in one plant. In the other it is indicated that around 80 types of wastes are permitted to be co-incinerated, as long as the authority has accepted the documentation for the waste type and supplier.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
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Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Some wastes are considered inappropriate for sampling in Denmark (as reported in the previous reporting period). These include polyurethane foam, CFC containing process air, creosote treated wood, infectious clinical waste, inhomogeneous waste and other types of hazardous waste packaged in small units.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
17 authorisations have been granted allowing an exemption from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). The following details are provided by Denmark:
1 authorisation has been granted to an existing incinerator with capacity of 4.5 tonnes per hour. The exemption approved a residence time of 1.5 seconds for which the kiln line was designed.
A number of older kiln lines in incineration plants (Denmark does not specify how many) are not required to have an auxiliary burner due to the fact that typically it is not technically possible to integrate such burners. Instead biomass waste is used for start-up and shut-down operations. The supervisory authority considers start-up and shut-down using biomass waste (pure wood waste) to be environmentally sound.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
5 exemptions in accordance with Annex II.1 have been granted, though it is noted that only one cement kiln was reported in question 1.2 above. Because all exemptions have been granted for a single pollutant (SO2), the table format utilised in analysis of this questions in other Member States is not used in the case of Denmark. The exemptions granted are for:
SO2 limit values range between 250 and 425 mg/Nm³. Information on the averaging time period was not provided.
Annex II.1 of the Directive, specifies that exemptions from the ELV set out for SO2 [50 mg/Nm³], expressed as daily average value, may be authorised in cases where SO2 emissions do not result from the incineration of waste. This seems to be the reason provided by Denmark which states that exemptions have been granted due to SO2 emissions not resulting from the incineration of waste (meat and bone meal).
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those given in Annex II or Annex V, as well air ELVs for new pollutants (those not listed in the Directive) have been set in Denmark - summarised in table below. Note that in all cases except for NH3 (where continuous monitoring was required), the measurement method was periodic.
Parameter WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
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CO Not specified (II.1.2.–cement)
Existing co-incineration plant (other industry); ELV = 100 (HAV), discontinuous monitoring (twice per year).
Not provided
NOx DAV
200 (Ex>6t/h and new)
400 (Ex=<6t/h) HHAV 400 (100%A) 200 (97%B)
Existing incineration plant: ELV = 275 (DAV) / 400 (HHAV); continuous monitoring
For one plant limit applies to operation of up to 1 000 hours per year.
Existing incineration plant: ELV = 190 (DAV) / 380 (HHAV); continuous monitoring
Limit applies to the total discharges from two kiln lines and until 31 December 2013.
Co-incineration and Incineration plants- ELVs set for pollutants not listed in Annex II or Annex V to the WID
PAH 3 plants (2 incineration and 1 co-incineration) ELV = 0.005 (HAV); discontinuous monitoring (twice per year).
Incineration plants incinerates creosote treated wood, whereas the co-incineration burns oil containing PCBs.
NH3 3 existing incinerator plants
ELVs = 10 (DAV), 10 (HAV) or 30 (HHAV). For two plants monitoring is continuous and for the other is periodic (twice and four times per year)
Monitoring and limitation of ammonia slip from DeNOx plants.
PCB 1 co-incineration plant (other industry); ELV = 0.0001 (DAV)
The plant co-incinerates PCB containing oil
AS 1 existing incineration plant; ELV = 0.02 (HAV); discontinuous monitoring (twice per year).
Compliance with “C value” (contribution value calculated on release of the substance into the environment)
Cr 1 existing incineration plant; ELV = 0.2 (HAV); discontinuous monitoring (twice per year).
Compliance with “C value”
Ni 1 existing incineration plant; ELV = 0.2 (HAV); discontinuous monitoring (twice per year).
Compliance with “C value”
Sum of Cd, Ni, Cr and As
3 existing incineration plants; ELVs = 0.2, 0.06 or 0.075 (HAV); discontinuous monitoring (twice per year).
Compliance with “C value”
Sum of Ni, Cr and As
1 existing incineration plant; ELVs = 0.05 (HAV); discontinuous monitoring (twice per year).
Compliance with “C value”
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours II). When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply. However Denmark reports under question 5 no co-incineration plants to which the provisions of Annex V applied.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
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ELVs for discharges of wastewater from flue gas cleaning equipment are different from the values in Annex IV. Whereas Denmark reported in the previous period that the ELVs presented corresponded to one plant, this reporting period it has provided the ranges applied in the country as shown in table below:
Denmark reports yearly averaging for all pollutants.
Polluting substance Annex IV WID ELV reported (mg/l) Comments
Total suspended solids 95%/30 mg/l 100%/45 mg/l 30 No reasoning is provided.
Mercury (Hg) 0.03 mg/l 0.003; 0.01
Cadmium (Cd) 0.05 mg/l 0.025; 0.01
Thallium (Tl) 0.05 mg/l 0.040; 0.01
Arsenic (As) 0.15 mg/l 0.040; 0.1
Lead (Pb) 0.2 mg/l 0.056; 0.02
Chromium (Cr) 0.5 mg/l 0.01; 0.01
Copper (Cu) 0.5 mg/l 0.029; 0.02
Nickel (Ni) 0.5 mg/l 0.083; 0.1
Zinc (Zn) 1.5 mg/l 0.86; 0.1
Dioxins and furans 0.3 ng/l 0.1 ng/l
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Additional pollutants to those listed in Annex IV of the WID have been assigned ELVs as shown in table below.
The previous reporting period stricter limits were reported for one incineration plant: “Vejen Bæk”, which appear to be no longer applicable.
Denmark reports yearly averaging for all pollutants.
Polluting substance ELV reported (mg/l) Comments
Ammoniac nitrogen (NH3-N) 8 Existing incinerator plant. Limitation of discharges of nitrogen to the Limfjord.
Oil 10 Existing incinerator plant. In accordance with Directive 76/464/EEC
Silver (Ag) 0.005 Existing incinerator plant. In accordance with Directive 76/464/EEC
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
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Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Denmark reports that for HF (under Article 11(4) and 11(6)) only biannual performance checks are required (3 x 1-hour measurement). In addition it is noted that continuous measurements of the water vapour are not required.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
As per the previous reporting period, Denmark indicates that the conditions laid down in one plant for the monitoring of heavy metals (Hg, Cd, Tl, As, Pb, Cr, Cu, Ni and Zn) are not identical to those set out in Article 11(14) and 11(15) of the Directive.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
The following documents are available:
Method sheet MEL 16, Quality assurance of automatic measuring systems with recommendations for practical application of DS/EN 14181.
The guidelines are available online at www.ref-lab.dk
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The new and updated permit applications as well as the final decisions are available to the public from local authorities and on the internet.
The public is invited to comment on the application for a permit for a period between 10-30 days.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
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Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to questions 25 and 26 (a) compared to the last reporting period.
With regards to question 26 (b) it is noted that the reports are available on the internet and that annual reports can be submitted as part of the publicly accessible green accounts.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
The list of plants with a nominal capacity of less than 2 tonnes per hour is published by the competent authority on the internet. No further references to the relevant authority or links to the list were provided in the report.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The permit establishes:
• a maximum permissible period of abnormal operation with ELVs exceeded of 4 hours
• a maximum cumulative duration of periods exceeding ELVs over one year of less than 60 hours
Unlike the previous reporting period, no plants exempted from these values have been reported.
Question 30. Any other remarks.
No general remarks are provided by Denmark.
SUMMARY OF CHANGES
Denmark submitted an almost complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. Changes since the previous reporting period are summarised below.
Installations
37 installations (34 incinerators and 3 co-incinerators) fall within the scope of the Directive, of which 36 recover the heat generated in the incineration process. All plants have been issued with at least one permit (88 permits issued in total), and so far no permits have been granted to mobile plants, as per the previous reporting period. The total permitted waste throughput for 30 of the 34 incineration plants in the reporting period was 3,591,500 tonnes of waste in 2012 and 3,676,500 tonnes in 2013. A range of wastes were reported to be co-incinerated in co-incineration plants.
ELVs, operational parameters and monitoring requirements
The following changes have been reported by DK:
• 17 authorisations have been granted allowing an exemption from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). Further details provided for some plants indicate that these relate to the application of a different residence time in an incinerator and the installation of auxiliary burners which are not required in a number of older kilns.
• 5 exemptions from the emission limits in accordance with Annex II.1 have been granted for a single pollutant (SO2).
• Different air limit values to those given in Annex II or Annex V, as well air ELVs for new pollutants have been set in Denmark. This relate to NOx, dust, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), CO, heavy metals and ammonia (NH3).
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• Different ELVs for discharges of wastewater from flue gas cleaning equipment compared to Annex IV, as well air ELVs for new pollutants have been set.
• Exemptions from continuous measurements of emissions of HF, in line with provisions of Articles 11(4) and 11(6) of WID are reported.
General legislative provisions and procedures
Further detail on the official guidance that has been developed on producing validated daily average emission data is provided. These are available online at www.ref-lab.dk.
In addition, it is specified that the public is invited to comment on the application for a permit for a period between 10-30 days. Denmark further adds that the annual reports provided by operators are available on the internet and that these can be submitted as part of the publicly accessible green accounts. Moreover, the list of plants with a nominal capacity of less than 2 tonnes per hour is published by the competent authority on the internet.
Unlike the previous reporting period, no plants exempted from the maximum permissible periods of operation during abnormal operation have been reported.
A.7 Estonia
A.7.1 Analysis of the completeness of the report
Table 13: Completeness assessment of answers reported by Estonia – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Whilst in question 1 Estonia reports a total of 4 plants (4 incinerators and 3 co-incinerators), in question 1.2 only lists 3 plants (it appears that one incinerator is not included).
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
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Question Completeness Comment
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10
(a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional
pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water and
groundwater protection (Article 8(7)) 14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of
breaches of emission limit values 22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
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Estonia provided an almost complete response to the questionnaire. Only the response to question 1.2 is partially incomplete.
A.7.2 Analysis of Estonia’s responses
The table below contains detailed analysis of the responses provided by Estonia to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Estonia under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 14: Estonia – Response analysis table
Estonia
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down
between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 4 plants fell within the scope of the Directive, of which 3 are incineration plants and 1 is a co-
incineration plant.
Permits were issued for all plants that fall within the scope of the Directive and all recover heat generated by the incineration process.
A total of 402,000 tonnes of waste throughput are permitted per year
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Estonia listed 3 plants and details were provided for all of them. Of these, 1 was a co-incineration and
2 incineration plants.
The reported co-incineration plant was a cement kiln.
Estonia reports for the one incineration plant processing municipal waste an energy efficiency of 35.5 in summer 2013 (the waste incineration plant was operating under a condensation regime). In autumn it is 78.1 (co-generation regime).
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Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
There were no problems reported with the definitions, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types
of waste were co-incinerated in the cement kiln. EWC codes of each of the wastes co-incinerated are set out under remarks where they were provided by the Member State: Type of plant
Category of waste
Co-incinerated?
Remarks
Cement kiln
Waste Oils Yes 130507*
Solvents No
Filtercakes No
Wood waste No
Plastics No
Textiles No
RDF Yes 191210
Fluff from shredding
Other Yes Sorting residues, industrial sewage sludge, chemical sludge and chemical residues (191211)
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
The last reporting period Estonia indicated that integrated permits specify the quantities and categories of hazardous waste and specified the permit conditions established for the co-incineration plant - Kunda Nordic Tsement AS – regarding the flow and calorific values. This reporting period Estonia also specifies the permit conditions laid down for the incineration plant Epler & Lorenz AS: minimum and maximum flow of hazardous
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wastes (min. 0.038t/h; max. 0.3t/h) and a range of calorific values of waste permitted (min. <1MJ/kg; max. 46.7 MJ/kg). For the remaining two plants Estonia reports no information with regard to flow or calorific values.
Estonia reports that permits do not lay down any restrictions on the content of pollutants but it is indicated that limit values have been specified for the amounts of pollutants emitted annually. Operators take into account the pollutant content of the waste in the industrial specifications on the preparation of fuel mixes.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
No wastes are considered inappropriate for sampling in Estonia (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
There has been no change in the response to this question compared to the last reporting period. 2 exemptions continue to be granted in accordance with Annex II.1 for the existing cement kiln with regards to SO2 and TOC ELVs, although the exact level at which the ELVs have been set is not specified.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (as per the previous reporting period).
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period). Estonia further clarifies that no waste water is produced in incineration plants and co-incineration plants when cleaning flue gases, as a semi-dry scrubbing system is used.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous
reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
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Estonia clarifies that no waste water is produced, so permits for waste incineration plants and co-incineration plants do not prescribe monitoring the discharge of waste water from the cleaning of exhaust gases.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
Estonia provides further detail on what measures have been introduced at individual plants:
- AS Epler & Lorenz: monitoring of storm water for a number of parameters: pH, BOD, COD, total nitrogen, total phosphorus, petroleum products, DDT, PAH (total), Hg, Cd, Ni and Pb.
- AS Kunda Nordic Tsement and Eestia Energia AS Iru power station: Water is used only for cooling and therefore does not require cleaning and is discharged into the environment (into the Kunda River and Kroodi Stream respectively) via an oil trap. However, the following parameters are monitored: pH, BOD, COD, total nitrogen, total phosphorus, petroleum products and mono- and bi-phenols.
It is unclear what specific provisions have been applied at the fourth plant falling within the scope of the Directive, however, Estonia notes the following for all incineration plants:
Soil is not monitored, as soil and groundwater protection is applied in all incineration plants when operating equipment, with containers being installed on site.
Waste storage areas in covered warehouses and depots have cement floors. Furthermore the sites have been with equipped with rainwater collection systems and relevant purifiers.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
As per the previous period Estonia does not report specific provisions to ensure sufficient storage capacity and notes that no effluent is discharged from Estonian plants when cleaning flue gases. This reporting period Estonia further clarifies that this is due to the use of a semi-dry scrubbing system.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Estonia answers this question by referring to permit conditions of individual plants. The situation is the same as the one reported in the previous reporting period except for the plant “Kunda Nordic Tsement AS”, whose permit conditions relating to measurement of pollutants to air are now the same as those set out in Article 11(2), as it is also the case of the plants Eesti Energia AS Iru power station, Epler & Lorenz AS.
Only for Hansa Biodiesel OÜ’s Estonia indicates that the permit conditions do not reflect all of the stated requirements, but no further details are provided.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Estonia reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance
regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been almost no change in the response to this question compared to the last reporting period. Only with regards to Article 11(11) Estonia adds that compliance with the provisions is ensured by installing the required measuring equipment, carrying out measurements, verifying the figures thoroughly and recording them. Control measurements are taken regularly, and reference measurements are taken.
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Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
Estonia indicates that from 26 June 2013, the calculation of daily average emission values is based on
Regulation No 39 of the Minister for the Environment of 20 June 2013 laying down rules for the regular measurement of the level of contaminants in gases and waste water discharged from waste incineration and co-incineration plants. Furthermore, any specific conditions relating to the calculations of daily average emission values are included in the permits. Estonia provide the following link to the Regulation: https://www.riigiteataja.ee/akt/126062013016
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The new and updated permit applications as well as the final decisions are available to the public from local, regional and national authorities and on the internet.
The public is invited to comment on the application for a permit at any point in the application process. No further detail, for example on the duration of the application process, has been reported.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
As per the previous year, all environmental information is publicly available and free of charge. Estonia further adds that information on all incineration and co-incineration plants is publicly available via the environment permit information system: http://klis.envir.ee/klis.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
In the response to question 25, Estonia indicates that in addition to Kunda Nordic Tsement AS (as reported last period), the waste-to-energy block of Eesti Energia AS Iru power plant also prepares an environmental report for the general public, which includes data on plant operations and monitoring. This report is submitted in addition to the one that all plants submit every quarter to the Competent Authority on emissions to water and air pursuant to the Ambient Air Protection Act and the Water Act.
Regarding question 26(a) Estonia indicates that the report contains information on emissions to air, capacity, type of installation and types of wastes incinerated. Regarding question 26 (b) Estonia indicates that the public is able to obtain data on emissions of certain pollutants into ambient air from the State Environmental Register: http://register.keskkonnainfo.ee/envreg/main#HTTPfgJx7CaOHSYnrTwOJA7w93AgF1hJB. However it is unclear how the public gets access to the annual report provided.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
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There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Estonia.
SUMMARY OF CHANGES
Estonia submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. Changes since the previous reporting period are summarised below.
Installations
4 installations (3 incinerators and 1 cement kiln) fall within the scope of the Directive, all of which recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. The total permitted waste throughput in the reporting period was 402,000 tonnes per annum.
ELVs, operational parameters and monitoring requirements
Estonia further clarifies that no waste water is produced in incineration plants and co-incineration plants when cleaning flue gases, as a semi-dry scrubbing system is used. Therefore, permits for waste incineration plants and co-incineration plants do not prescribe operational control monitoring.
Unlike the previous reporting period, the permit conditions relating to measurement of pollutants to air are the same as those set out in Article 11(2) for the plant “Kunda Nordic Tsement AS”. Only for Hansa Biodiesel OÜ’s Estonia indicates that the permit conditions do not reflect all of the stated requirements, but no further details are provided.
General legislative provisions and procedures
Further detail on the permitting conditions established for individual plants are provided regarding specified flow and calorific values (Epler & Lorenz AS), specific measures for the protection of soil and water (all plants) and the preparation of an annual report (Eesti Energia AS Iru power plant).
Estonia indicates that from 26 June 2013, the calculation of daily average emission values is based on Regulation No 39 of the Minister for the Environment of 20 June 2013.
The new and updated permit applications as well as the final decisions are available to the public from local, regional and national authorities and on the internet. Estonia further adds that information on all incineration and co-incineration plants is publicly available via the environment permit information system.
A.8 Finland
A.8.1 Analysis of the completeness
Table 15: Completeness assessment of answers reported by Finland – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a Finland indicates that the number of
plants reported in question 1.1 only comprise those plants that incinerated 1.1.b
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Question Completeness Comment
1.1.c
more than 2 t of waste or waste fuels per hour within the reporting period. However, these questions request the total number and a complete list of all plants falling within the scope of the WID.
1.1.d
1.2 (a-b)
The number of plants reported in
question 1.1 and listed in 1.2 only comprise those plants that incinerated more than 2 t of waste or waste fuels per hour within the reporting period. However, these questions request the total number and a complete list of all plants falling within the scope of the WID. Additionally, no details on the latitude and longitude of the plants have been provided in question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Technical difficulty with the reporting tool. No response available.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.a
8.b
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit
values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits
values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for
additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
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Question Completeness Comment
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air
and water (Article 11)
17
18
Handling the results of
measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24 No information is provided on whether
environmental information is provided free of charge.
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Finland provided an almost complete response to the questionnaire. Only the responses
to questions 1.2 and 4 have gaps.
A.8.2 Analysis of Finland responses
The table below contains detailed analysis of the responses provided by Finland to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Finland under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given. In cases where text has been quoted directly from the English translation of the report, it is presented in italics.
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Table 16: Finland – Response analysis table
FINLAND
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
Finland indicates that the number of plants reported in question 1.1 and listed in 1.2 only comprise those plants that incinerated more than 2 t of waste or waste fuels per hour within the reporting period. However, these questions request the total number and a complete list of all plants falling within the scope of the WID.
In total 24 plants (which incinerated more than 2 t of waste or waste fuels per hour) fell within the
scope of the Directive, of which 14 were co-incineration plants.
24 permits were issued in Finland and all co-incineration plants recovered the heat from the process.
Finland has not reported the total permitted capacity of waste throughput (this was an optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for
plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Finland listed 24 plants, of which 14 were co-incineration and 10 incineration plants.
Of the reported co-incineration plants, 10 were combustion plants, 2 were cement kilns and the other 2 were identified as “other industrial facility” not covered by Annex II.1 or II.2 to the WID.
Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
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There has been no change since the previous reporting period. No problems with definitions were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to Directive 2000/76/EC during the reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
Finland has not responded to this question.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
Finland reported no co-incineration plants to which emission limits set out in Annex V applied.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There has been no change in the response to this question compared to the last reporting period. No wastes were considered inappropriate.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4) (as per the previous reporting period).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Finland reported no exemptions in accordance with Annex II.1 (as per the previous reporting period).
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (as per the previous reporting period).
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please
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indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period). Finland adds that wastewater from the flue gas scrubbers of a waste co-incineration plant must be channelled to a wastewater treatment plant. It is not discharged directly into a water body.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Finland compared to the last reporting period. These are identical to those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Finland compared to the last reporting period. These are identical to those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
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There has been no change since the previous reporting period. Guidance can be accessed here: http://energia.fi/sites/default/files/yhteinen_menettelytapa_en14181_0.pdf
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The application on a new and updated permit and the final decisions are publicly available at the national and local authorities and on the internet.
The public has between 10 and 30 days to comment on the application.
24. With regard to the availability of information throughout the permitting process is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit?
In Finland, information classified as a business secret in the permit application is not available. Access to the remaining information appears to be not available free of charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to questions 25 and 26 compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
Finland reports that there is no list available of such plants.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
None
SUMMARY OF CHANGES
The information in the report submitted by Finland covers almost all the requirements of the questionnaire, providing data to demonstrate the status regarding implementation. Changes or additional information in comparison with the previous reporting period, relate to questions 1, 11, 23, 24 and 27. These are summarised below:
Installations
A total of 24 plants fell within the scope of the Directive, of which 10 were incineration plants and 14 co-incineration plants. All 24 plants were permitted and recovered the heat generated by the incineration process. No mobile plants received permits under the Directive and no problems with the definitions have been reported by Finland.
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FINLAND
Due to lack of response to question 4 the types of waste co-incinerated in Finland are unknown. No wastes have been found inappropriate for representative sampling.
ELVs, operational parameters and monitoring requirements
As per the previous reporting period Finland has not made use of the possibility to grant exemptions and derogations from certain provisions of the Directive and no ELVs different or additional to those from Annex II, IV and V have been set. Only with regards to emissions to the aquatic environment, Finland adds that wastewater from the flue gas scrubbers of a waste co-incineration plant must be channelled to a wastewater treatment plant. It is not discharged directly into a water body.
General legislative provisions and procedures
The public can participate in the permitting process and has between 10 and 30 days to comment on the new or updated permit applications published by the authorities. However, information classified as a business secret in the permit application is not available. Access to the remaining information appears to be not available free of charge.
Finland further clarifies that there is no list available of plants with a nominal capacity of less than 2 tonnes per hour.
A.9 France
Analysis of the completeness of the report
Table 17: Completeness assessment of answers reported by France – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 Details were not provided for one plant.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-
incinerated 4
Co-incineration plants subject
to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing
conditions in accordance with Article 6(4)
8
8.1
8.2
9.a
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Question Completeness Comment
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-
e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for
additional pollutants discharged to water beyond those in Annex IV
12 (a-
c)
Operational control parameters
for water discharges (Article 8(6)(b))
13
Provisions for soil, surface
water and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
The provisions were not provided for Article 11(10)
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and
public participation (Article 12)
23
24
25
26.1
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Question Completeness Comment
26.2
27
Abnormal operation 28
29
Other remarks 30
France has submitted a partially complete response to the WID questionnaire as per the
Commission Decision 2011/632/EU using the electronic reporting tool. Several issues
were identified for questions 1.2, 4, 9(b), and 19 – as outlined in the table above.
Analysis of the response by France
The table below contains detailed analysis of the responses provided by France to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by France under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given.
Table 18: France – Response analysis table
France
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
A total of 249 plants fell within the scope of the Directive, of which 210 were incineration plants and
39 were co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
In total, 129 plants (52% of the total) recovered the heat generated by the incineration process.
The total permitted capacities of waste throughput was not provided (this was an optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
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France
France listed 248 plants and details were provided for all of them. Of these, 39 were co-incinerators and 209 incinerators. No explanation was provided by the Member State as to why the details are missing for one of the incineration plants that falls within the scope of the Directive (as reported under question 1.1). A likely explanation is that the Member State has not accounted for updates since the previous reporting period.
Of the reported co-incineration plants, 29 were cement kilns, 4 were combustion plants and 6 were other industrial facilities.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for 127 plants. In summary the following can be noted:
o The majority of plants (91) reported that their energy efficiency is ~0.6 (mostly reported as <0.6 and 0.65 with only 12 plants reporting energy efficiency rates between 0.66 and 0.69);
o 18 plants reported that their energy efficiency is ~0.7 (ranging from 0.71 to 0.79);
o 10 plants reported that their energy efficiency is ~0.8 (ranging from 0.80 to 0.85);
o 3 plants reported that their energy efficiency is ~0.9 (ranging from 0.92 to 0.95);
o 3 plants reported that no energy recovery took place in the 2012-2013 reporting period; and
o 2 plants reported that their energy efficiency is 1.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with the definitions in Article 3 were identified by the Member State, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
France provides an annex document with an extensive list of the wastes that are co-incinerated along with the EWC code; however these have not been categorised due to technical difficulties with the reporting tool.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
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Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
The Member State reports no changes to the provisions within the permitting process compared to the previous reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Infectious clinical waste continue to be considered inappropriate for sampling in France (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
France reports that no plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per the previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Exemptions from emission limits in accordance with Annex II.1 have been granted in 44 cases for 2 pollutants. The Member State specifies details for 2 examples of existing plants with exemptions in place that have been granted owing to the large quantities of sulphur and hydrocarbons in the raw materials used by the plant to produce cement. The details are as follows:
Pollutant Details
SO2 Granted to two existing plants, one with a capacity of 6,000 tonnes/ day for cement production and 1,900 tonnes/ day for clinker production, and the other with a capacity of 4,100 tonnes/ day.
SO2 limit values are 1,500 mg/Nm³ (DAV) and 1,100 mg/Nm³ (DAV) respectively.
TOC Granted to two existing plants, one with a capacity of 6,000 tonnes/ day for cement production and 1,900 tonnes/ day for clinker production, and the other with a capacity of 4,100 tonnes/ day.
TOC limit value are 100 mg/Nm³ (DAV) and 80 mg/Nm³ (DAV) respectively.
Annex II of the WID, specifies that exemptions from the ELVs for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³] may be authorised in cases where TOC and SO2 do not result from the incineration of waste.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air emission limit values to those given in Annex II or Annex V have been set in keeping with what was reported in the previous reporting period.
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Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (whereas different ELVs were previously specified for arsenic).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
An additional six pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the
previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
The requirements for the measurement of pollutant to air and the process operation parameters are different to those set out in Article 11(2), as follows:
Deviation Comments (Pollutant or parameter concerned and measurement requirement)
More stringent requirements
Exemptions for HF under Art. 11(4) Yes
France notes that continuous measurement of HCl, HF and SO2 is unnecessary when the permit conditions only authorise the incineration of waste which does not cause the average values for these polluting substances to exceed 10% of the emission limit values established for them.
Exemptions for water vapour under Art. 11(5)
Yes No further information provided.
Exemptions for HCl under Art. 11(6): Yes France notes that continuous measurement of HCl, HF and SO2 is unnecessary when the permit conditions only authorise the incineration of waste which does not cause the average values for these polluting substances to exceed 10% of the emission limit values established for them.
Exemptions for HF under Art. 11(6): Yes
Exemptions for SO2 under Art. 11(6): Yes
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Exemptions for heavy metals under Art. 11(7):
Exemptions for Dioxins and furans
under Art. 11(7): Yes
France notes that dioxins and furans must be measured twice a year on a semi-continuous basis at incineration plants. At co-incineration plants, the operator must measure the parameters four times a year.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
France reports no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are different to those set out in Article 11(14) and 11(15). France reports that additional parameters (TOC, fluorides, free CN, total hydrocarbons, AOX and biochemical oxygen demand) are subject to emission limit values and are monitored.
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided any detail beyond that the provisions are specified in the permit for Article 11(10).
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The permit application and final decision are publicly available at the level of the regional public administrations.
The public is given a period of between 31 days to comment on the application for a permit, and this time can be extended by another 15 days if the investigating commissioner decides so.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
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There has been no change in the response to this question compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period, however he Member State has provided additional detail.
• France specifies that the maximum permissible period with exceedance of emission limit values is 4 hours when the measurements show that a limit value for discharge into the air has been exceeded. In addition, it remarks that the maximum permissible period with exceedance of emission limit values from continuous measurement of effluents in the water and in the air is 10 hours.
• The Member State reports that the maximum cumulative duration of periods exceeding emission limit
values over 1 year is 60 hours.
Question 30. Any other remarks.
No general remarks are provided by France.
SUMMARY OF CHANGES
France submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes and additional information provided are summarised below.
Installations
A total of 249 plants (210 incinerators and 39 co-incinerators) fall within the scope of the Directive. All plants were permitted and no permits were granted to mobile plants. 52% of the plants recover the heat generated in the incineration process.
France provides details for 248 plants (209 incinerators and 39 co-incinerators – the latter including 29 cement kilns, 4 combustion plants and 6 other industrial facilities). The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for 127 plants.
ELVs, operational parameters and monitoring requirements
The following changes have been reported by France:
• Additional exemptions from emission limits for cement kilns co-incinerating waste have been granted since the previous reporting period, now totalling 44 cases for 2 pollutants (SO2 and TOC). The Member State specifies details for 2 examples of existing plants with exemptions in place that have been granted owing to the large quantities of sulphur and hydrocarbons in the raw materials used by
the plant to produce cement. The specified limit values are 1,100 and 1,500 mg/Nm³ (DAV) for SO2 and 100 and 80 mg/Nm³ (DAV) for TOC.
• The requirements for the measurement of pollutant to air and the process operation parameters are different to those set out in Article 11(2) for exemptions for HF under Article 11(4), water vapour under Article 11(5), HCl, HF, and SO2 under Article 11(6), and dioxins and furans under Article (7).
General legislative provisions and procedures
There have no changes in the responses provided on legislative provisions and related procedures since the previous reporting period, although some additional detail has been provided, as follows.
• The period time provided to the public to ensure their participation in the permitting process is 31 days, and this time can be extended by another 15 days if the investigating commissioner decides so.
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• In addition to specifying the maximum permissible period with exceedance of emission limit values, it remarks that the maximum permissible period with exceedance of emission limit values from continuous measurement of effluents in the water and in the air is 10 hours.
A.10 Germany
A.10.1 Analysis of the completeness of the report
Table 19: Completeness assessment of answers reported by Germany – WID
Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Whilst in question 1 Germany reports a total of 365 plants (219 incinerators and 146 co-incinerators), in question 1.2 Germany lists 362 plants. It is also noted that no details on the latitude and longitude of the plants have been provided in response to question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
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Question Completeness Comment
Setting of different emission limit values to those specified in Annex II or Annex V
10
(a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water and
groundwater protection (Article 8(7)) 14
Ensuring adequate storage capacity
for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of
breaches of emission limit values 22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Germany provided an almost complete response to the questionnaire. Only the
response to question 1.2 is partially incomplete. In addition it is noticed that not all plants falling within the scope of the Directive are reported to be permitted.
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A.10.2 Analysis of Germany’s responses
The table below contains detailed analysis of the responses provided by Germany to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Germany under each question. The table contains
a summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 20: Germany – Response analysis table
Germany
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 365 plants fell within the scope of the Directive, of which 219 are incineration plants and 146
are co-incineration plants.
A total of 348 permits have been issued in accordance with Article 4(1). Of these 162 are for incineration plants and 112 are for co-incineration plants. In addition, there are 74 permits for which the type of plant has not been specified by two federal states providing data. Germany did not provide additional information to explain why the total number of permits issued differs from the number of plants within the scope of the Directive (but they were not requested to do so in the questionnaire).
294 plants recovered the heat from the incineration process.
Germany is not able to provide the total waste throughput permitted per year based on data available, but reports that a portion of this equals 2,007,0246 tonnes of waste.
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Germany listed 362 plants (out of 365 falling within the scope of the Directive) and details were provided for all of them. Of these, 186 were co-incineration and 176 incineration plants. It is of note that there is an inconsistency with the number of incineration and co-incineration plants provided between question 1.1(a) and question 1.2 (219/146 versus 186/176). However no explanation is provided to justify why there is such difference in the reported figures.
For the 186 co-incineration plants, the report specified the type of the plant as shown in the pie chart below.
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For 75 plants energy efficiency figures have been provided. The efficiency figures were equal to or above 60% and therefore in line with the requirements of the Waste Framework Directive, except for 1 plant for which the values were less than 60%. For this plant it is only indicated that efficiency was less than 0.60 but the actual value is not provided. For the rest efficiency values reported ranged between 0.60 and 1.08.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the
Directive. Provide specific information for each definition for which problems are identified.
There were no problems reported with the definitions, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were co-incinerated in co-incineration plants. Germany reported a large list of EWC codes for these wastes but it has not been possible to summarise here. Moreover, under “other” it lists a number of wastes (by specifying their EWC code) of which only a selection are presented here.
Type of plant Category of waste
Co-incinerated? Remarks
Cement kilns
Waste Oils Yes
Solvents Yes
Filtercakes Yes
Wood waste Yes
Plastics Yes
Textiles Yes
RDF Yes
Fluff from shredding
Yes
Sludge Yes Other wastes (including mixtures of materials) from mechanical treatment of wastes
Other Yes Such as sludge from treatment of urban waste water
Combustion plant
Wood waste Yes
Sludge Yes
Other Yes Such as combustible waste (fuel from waste), coal fly ash, filler and coating sludge from mechanical separation
Other industrial facilities Other Yes
Such as animal-tissue waste, mineral-based chlorinated hydraulic oils
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Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
25 co-incineration plants are subject to ELVs specified in Annex V of the Directive. Germany reports that for 22 plants this is because more than 40% of the heat released at these plants results from combustion of hazardous wastes. In the remaining 3 this is because co-incineration of untreated municipal waste is undertaken.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to indents (a), (b) and (d) of this question compared to the last reporting period.
For indent (c) Germany clarifies that the calorific values are between 1 and 45 MJ/kg, for liquid waste between 15 and 45 MJ/m³ and for gaseous waste between 15 and 80 MJ/m³.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
As reported in the previous reporting period, some wastes (peroxide and infectious waste) continue to be considered inappropriate for sampling in Germany.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
89 authorisations have been granted in accordance with Article 6(4) (24% of the total number of plants).
In question 8(b), details have been provided for 19 existing plants and 3 new plants. Based on information provided most of these authorisations (15) lay down different temperature and residence time conditions to those specified in Art. 6(1) and 6(2). However, for 6 plants no details on the operating conditions are provided and it is only indicated that these are in accordance with Federal Emissions Regulation. Additionally, information on ELVs stipulated in the permit (for dust, TOC and NOx) is provided for some plants. Other remarks regarding the measurement and determination of certain parameters (e.g. dioxins) are also established for some plants.
In addition, Germany reports a number of methods to ensure that residues are not produced in higher quantities or with higher content of organic pollutants from the plants compared to non-exempt plants. These include the undertaking of incineration trials or slag analysis.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
19 exemptions from emission limit values have been granted in Germany in accordance with Annex II.1 (it is unclear whether this refers to the total number of plants, or number of exemptions granted for individual pollutants). Details of the exemptions were provided for 7 existing plants and are summarised below.
Pollutant Details
SO2 Granted at 3 plants.
SO2 limit values reported range between 140 and 400mg/Nm3 daily average value.
TOC Granted at 2 plants.
TOC values between 25 and 100 mg/Nm³ (daily average value) are reported.
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Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³], expressed as daily average values, may be authorised in cases where TOC and SO2 emissions do not result from the incineration of waste. This seems to be the reason provided by Germany which states that exemptions have been granted due to the composition of the raw material used.
In addition, Germany reports NOx ELVs set for 2 existing plants. The limit values quoted is 350 mg/Nm³ (daily average value). This is stricter compared to Annex II.1, in which ELVs for NOx emissions in existing plants are 800 mg/Nm3. Therefore, it is not considered an exemption.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
More stringent ELVs, as well air ELVs for new pollutants (those not listed in Annex II or Annex V of the Directive) have been set in Germany - these are summarised in the table below. It appears that information provided applies to a minimum of 41 plants, but it is not possible to state the total quantity of plants at which these ELVs have been set based on the information reported. The related time periods were not reported by Germany for some of the ELVs; where data were provided, the ELVs are specified as either half-hourly average or daily average values and this information is indicated in the table below.
Parameter WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
Mercury (Hg) 0.05 (30 min -8h) 2 plants ELVs = 0.03 (DAV) or 0.0084 (HHAV)
Dust 10 (DAV) 3 plants: ELVs= 5 (DAV), 8 (DAV) and 25 (HHAV)
HCL 5 (DAV) 1 plant : ELV= 8 (DAV)
SO2 50 (DAV) 1 plant : ELV= 30 (DAV)
Dioxins and furans
0.1 ng/m3 (DAV)Error! Not a valid link.
2 plants ELVs = 0.1 ng/m3 (DAV) and 0.08 ng/m3 (DAV)
One plant (0.1 value) is due to start normal operation on 2015, and the permit requires additional measurements for the group of halogenated dioxins and furans, plus mixed halogenated PCDD/PCDF congeners and PCBs.
CO 50 (DAV) 1 plant : ELV= 50 (HHAV),
NOx 200 (DAV > 6t/h or new) 400 (DAV=< 6t/h)
4 plants: ELVs= 100 (DAV), 150 (DAV) and 300 (HHAV)
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
Dust 50-30 DAV (II.2) 2 combustion plant: ELV = 15 (DAV)
NO/NO2 Annex V applies to this plant: 200 (DAV > 6t/h or new) 400 (DAV=< 6t/h)
1 combustion plant : ELV= 200 (DAV)
According to Annex V it should be 400; but set at 200.
SO2 850-200 DAV (II.2) 2 combustion plant: ELVs = 160-179 (DAV)
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HCL 10 DAV (II.1) 1 combustion plant: ELV = 20 (DAV),
Cd+Tl 0.05 DAV (II.1.2.3) 1 combustion plant: ELV = 0.0045,
Ni Annex V applies to this plant:
0.5 (30 min -8h)
1 combustion plant; ELV = 0.15 (DAV)
Cd Annex V applies to this plant:
0.05 (30 min -8h)
1 combustion plant; ELV = 0.04 (DAV)
Dioxins and furans
0.1 ng/m3 (II.1.2.3)
1 combustion plant; ELV = 0.008 - 0.05
Co-incineration and Incineration plants- ELVs set for pollutants not listed in Annex II or Annex V to the WID
PAH 1 co-incineration plant ; ELV = 5.5 (DAV)
NH3 11 plants (8 incinerators and 3 co-incinerators). ELVs = between 2-30 (DAV) and 5 (HHAV)
Operation of an SNCR plant with ammonia water
Benzo (a) pyrene
4 plants (2 incinerators and 2 co-incinerators). ELVs = between 0.008-0.05 (DAV) and 0.005 (HAV)
Requirements in accordance with national legislation on air pollution
Benzene 3 existing plants (1 incinerator and 2 co-incinerators); ELVs = 1 (DAV) and 5 (DAV)
Requirements in accordance with national legislation on air pollution
HBr 1 existing incineration plant; ELV = 3 Monitoring cycle each 3 years
PCB 1 co-incineration plant; ELV = 1 ug/N29m³ Requirements in accordance with national legislation on air pollution
PCP 1 incineration plant; ELVs = 0.05 µg/m3 Plant due to start normal operation on 2015, with permit requiring PCP measurements in the 2015-2017 program.
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply. Germany reports under question five 25 co-incineration plants to which the provisions of Annex V applied.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Different ELVs to those in Annex IV for discharges of waste water from flue gas cleaning equipment have been specified for the following substances: total suspended solids, Hg, Cd, As, Pb, Cr, Cu, Ni and Zn. Germany reports that for 95% of plants incinerating municipal wastes, the flue gas scrubbing is undertaken without generating wastewater. The other plants in this area of application comply with the requirements of Annex 33 to the Waste Water Regulation (Abwv) which directly transposes the waste water values in the WID. More stringent limits apply in some federal states to meet their stricter water quality requirements.
Note that Germany reports 24 h (mixed) sampling for all pollutants. It is noted that for Mercury the same value as that in Annex IV of the WID is reported.
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Polluting substance Annex IV WID ELV reported (mg/l)
Total suspended solids 95 % (30 mg/l) 100 % (45 mg/l)
30
Mercury (Hg) 0.03 mg/l 0.03
Cadmium (Cd) 0.05 mg/l 0.01
Arsenic (As) 0.15 mg/l 0.1
Lead (Pb) 0.2 mg/l 0.01 / 0.02
Chromium (Cr) 0.5 mg/l 0.2
Copper (Cu) 0.5 mg/l 0.2
Nickel (Ni) 0.5 mg/l 0.1
Zinc (Zn) 1.5 mg/l 1
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
The following additional ELVs to those specified in Annex IV have been set in Germany for pollutants discharged to water. These are in line with the requirements for discharge points set under the Waste Water Regulation – Annex 33.
Substance ELV reported (mg/l)
Comments
Chemical Oxygen Demand (COD)
80 -150 As per Annex 33/47 of the Wastewater regulation (AbwV) - (when using quicklime)
Chloride (CL-) 25000 Chlorine-containing liquid residues and flue gases
Fluoride (F) 30 As per Annex 33/47 of the Wastewater regulation (AbwV)
Sulphate (SO42−) 2000 As per Annex 33/47 of the Wastewater regulation (AbwV)
Sulphite (SO32−) 20 As per Annex 33/47 of the Wastewater regulation (AbwV)
Total hydrocarbons 10
Total Nitrogen 19 Pre-polluted process water
Total Phosphorus 0.1-1.5 Pre-polluted process water
Toxicity to fish eggs 2 (dilution factor)
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
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Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
In addition to what was reported in the last reporting period, Germany further adds that mercury and mercury
compounds are determined and measured as mercury (Hg) | 0,03 mg/l.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Requirements for measurement of pollutants are different to those set out in Article 11(2). According to the report, they correspond to the provisions of Article 11(2) but are derived from the national legislation (17. BImSchV Article 11).
Deviation Comments (Pollutant or parameter concerned and measurement requirement)
More stringent requirements than those of Article 11(2) are applied
Yes Hg must be measured continuously. Article 11(2) of the Directive does not require continuous measurement of mercury emissions. Therefore this requirement is stricter compared to the provisions of the Directive.
Exemptions for HF under Art. 11(4)
Yes Individual measurement yearly/ individual measurements on three days in the year.
Exemptions for water vapour under Art 11(5)
Yes Calculation from saturation temperature.
Exemptions for HCl under Art 11 (6)
Yes Individual measurement yearly/ individual measurements on three days in the year
Exemptions for HF under Art. 11(6)
Yes Annual individual measurement
Exemptions for SO2 under Art. 11(6)
Yes Individual measurement yearly. However Germany adds that SO2 is always measured continuously.
Exemptions for heavy metals under Art. 11(7)
Yes Individual measurements yearly
Three individual measurements annually are to be undertaken for antimony, arsenic, lead, chromium, cobalt, copper, manganese, nickel, vanadium and tin.
Exemptions for dioxins and furans under Art. 11(7)
Yes Dioxins and furans - individual measurements yearly
Dioxins - individual measurements on three days in the year
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15), except in one federal state regarding heavy metals, dioxins and furans, although the specific measurements applied are not reported.
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Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been almost no change in the response to this question compared to the last reporting period. Only with regards to Article 11(16) Germany adds that a more stringent compliance regime applies in one federal state: compliance with the best available techniques, with one monthly check on a qualified sample or 2 h composite sample.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period. Only more actualised links are provided:
http://www.umweltbundesamt.de/luft/messeinrichtungen/mg-bestimmung.htm http://www.umweltbundesamt.de/publikationen/luftreinhaltung-leitfaden-zur-emissionsueberwachung-0 https://www.umweltbundesamt.de/sites/default/files/medien/1/dokumente/auswerterichtlinie gmbl_version_13-6-2005_0.pdf
http://www.gaa.baden-wuerttemberg.de/servlet/is/16507/4_3_4.pdf http://www.umweltbundesamt.de/themen/luft/messenbeobachtenueberwachen/messgeraete-messverfahren/bekanntgabe-eignungsgepruefter-messeinrichtungen
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
It appears that Germany has reported the different arrangements made by the regional authorities, which differ greatly across them. Depending on the region, the public can access the new and updated permit applications and final decisions from local authorities, regional authorities as well as over the internet. In some instances information on the decisions adopted is published in their official gazettes and in the daily press.
Periods for commenting on the application vary, the most common ones being: 10-30days, 31-50days, 51-70days.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to these questions compared to the last reporting period. Germany only notes that the same provisions are laid down in the new version of the Federal Regulation 17th BImchV of 2.5.2013, but under a different Article.
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Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
In addition to what was reported the previous period, Germany adds that with the Regulation17th BImSchV in
the event of a disruption of operation, operators are required to take the necessary action to restore normal operation without delay. The authority is required to ensure, by means of supervisory measures, that operators meet this requirement or that the plant is shut down. Points 21(3) and (4) of the 17th BImSchV lay down emission limit values and maximum operating times in the event of a breakdown of the flue gas cleaning equipment.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
For incineration and co-incineration plants the following permissible periods of abnormal operations apply:
A maximum permissible period of abnormal operation with exceedance of ELVs between 3 and 4 consecutive hours.
A maximum cumulative duration of periods exceeding ELVs over one year of between 40 and 60 hours.
These requirements are laid down in point §21 of the 17th BImSchV (of 2.5.2013). There is one exception for cement plants: when the brown coal dust infeed breaks down, the rotary kiln must be shut down if the malfunction cannot be rectified within 2 hours.
Special permissible periods of abnormal operations have been set out for plants incinerating sewage sludge:
Technically unavoidable breakdowns – max. of 1 hour with exceedance of ELVs.
Operation with broken-down flue gas treatment within one calendar year cannot exceed 12 hours in total.
A maximum cumulative duration of periods when ELVs at sewage treatment plants are exceeded must be less than 20 hours per year.
It is also noted that in the event of a breakdown the plant must be shut down immediately.
Question 30. Any other remarks.
No general remarks are provided by Germany.
SUMMARY OF CHANGES
Germany submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU.
Changes since the previous reporting period are summarised below.
Installations
365 installations (219 incinerators and 162 co-incinerator plants) fall within the scope of the Directive, of which 81% recover the heat generated in the incineration process. A total of 348 permits have been issued in accordance with Article 4(1), but it is unclear why the total number of permits issued differs from the number of plants within the scope of the Directive.
ELVs, operational parameters and monitoring requirements
Changes have been reported with regards to these aspects, which are summarised below:
25 co-incineration plants were subject to ELVs specified in Annex V of the Directive.
Derogations with regard to the operating conditions of Art. 6(1) and art 6 (2) have been granted to 89 plants (24% of the total number of plants) under Art. 6(4).
19 exemptions from emission limit values have been granted in accordance with Annex II.1 for SO2 and TOC.
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New and more stringent air limit values to those given in Annex II or Annex V have been set for co-incineration and incineration plants. New ELVs have been developed for the following parameters: NH3, benzene, HBr, PCB, PAH, PCP and benzo (a) pyrene.
Different ELVs to those in Annex IV for discharges of waste water from flue gas cleaning equipment have been specified for the following substances: total suspended solids, Hg, Cd, As, Pb, Cr, Cu, Ni and Zn. Additional ELVs to those specified in Annex IV has been set for pollutants discharged to water.
Requirements for measurement of air pollutants are different to those set out in Article 11(2). According to the report, they correspond to Article 11(2) but are derived from the national legislation. However the requirements of the permit for the measurement of pollutant emissions to water are identical to those set out in Article 11(14) and (15), with the only exception of one federal state which applies stricter requirements for heavy metals, dioxins and furans.
General legislative provisions and procedures
There is a new version from February 2013 of the national legislation (17. BImSchV) implementing the provisions of the Directive. However, most of the provisions appear to remain the same and are only located under different Articles. Nevertheless Germany provides some additional information or details concerning the following:
With regards to Article 11(16) of the Directive, Germany adds that a more stringent compliance regime applies in one federal state.
Links to guidance on producing validated daily average emission data have been provided.
This reporting exercise, Germany has reported the different arrangements made by several regional authorities to ensure public participation in the permitting process.
Germany provides further detail on the provisions made within a permit to control the period of operation during abnormal operation. The authority is required to ensure, by means of supervisory measures, that operators take the necessary action to restore normal operation without delay or that the plant is shut down.
There is a change concerning the permissible periods of abnormal operations (between 3 and 4 consecutive hours and between 40 and 60 hours cumulative over a year). There is an exception for cement plants when the brown coal dust infeed breaks down (2 consecutive hours).
A.11 Greece
A.11.1 Analysis of the completeness of the report
Table 21: Completeness assessment of answers reported by Greece – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
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Question Completeness Comment
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
Greece reports that there has been no change compared to what was reported in the last reporting period. The response provided then referred to relevant parts of the national legislation, but without describing the provisions or providing further details on what is specified in permits.
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II
or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15 Greece indicates that this question is
not applicable but it does not indicate why.
Minimising quantities and
harmfulness of residues (Article 9) 16
Measurement of pollutants to air and
water (Article 11)
17
(a- b)
18
(a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19 Greece reports that there has been no
change compared to what was reported in the last reporting period.
The responses provided then referred to relevant parts of the national legislation, but without describing the provisions or providing further details.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
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Question Completeness Comment
Access to information and public participation (Article 12)
23
24
25
Greece reports that there has been no
change compared to what was reported in the last reporting period. The response provided then referred to relevant parts of the national legislation, but without describing the provisions or providing further details.
26.1
26.2
27
Abnormal operation 28
Greece reports that there has been no change compared to what was reported in the last reporting period. The response provided then referred to relevant parts of the national legislation, but without describing the provisions or providing further details.
29
Other remarks 30
Greece provided an almost complete response to the questionnaire. However it should
be noted that, for a number of questions, Greece reported by referring to relevant parts
of the national legislation, but not describing the relevant provisions or providing further
details (see the section on response analysis). Such responses provide very limited
detail on the specific aspects of the implementation of the Directive.
A.11.2 Analysis of Greece’s responses
The table below contains detailed analysis of the responses provided by Greece to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Greece under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given.
Table 22: Greece – Response analysis table
Greece
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 5 plants fell within the scope of the Directive, of which 2 are incineration plants and 3 are co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
All the co-incineration plants recover heat generated by the incineration process, but none of the incineration plants.
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Greece has not reported the total permitted capacity of waste throughput (this was an optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial
facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Greece listed all the 5 plants and details were provided for the 3 co-incineration plants.
All the reported co-incineration plants were cement kilns.
Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the
Directive. Provide specific information for each definition for which problems are identified.
There were no problems reported with the definitions, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
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The following types of waste were co-incinerated in cement kilns. EWC codes of each of the wastes co-incinerated are set out under remarks where they were provided by the Member State.
Type of plant Category of
waste
Co-
incinerated? Remarks
Cement kilns
Waste Oils No
Solvents No
Filtercakes No
Wood waste No
Plastics Yes 70213
Textiles No
RDF Yes 191210
Fluff from shredding
No
Other Yes
End-of-life tyres (160103), ASF (191211*), ALF (190204*), Shredder light fraction (SLF) and dust – car fluff (191004), spent activated carbon (190904), waste from mechanical treatment of waste – plastic and rubber (191204)
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period. Greece answered then by providing a reference to the relevant national legislation but no further details.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Medical wastes are considered inappropriate for sampling in Greece (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
The 3 cement kilns were granted exemptions according to Annex II.1 – these were issued for SO2 and TOC. All plants had a capacity higher than 2 tonnes per hour. The exemptions for SO2 and TOC emissions are summarised in the table below.
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Pollutant Details
SO2 Granted at one new plant with capacity of 40 t/h and at one existing with capacity of 24 t/h.
SO2 limit value of 400 mg/Nm3 (DAV) was set.
TOC Granted at the above two plants and to another existing plant with capacity of 10t/h.
TOC limit values were set at 35 and 100 mg/Nm³.
Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10mg/m3], expressed as daily average values, may be authorised in cases where emissions do not result from the incineration of waste. This seems to be the reason provided by Greece which states that exemptions have been granted because the operators demonstrated that the emissions do not originate from incineration of waste.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the
emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive. Greece further specifies that limit values are set in Joint Ministerial Decision No 22912/1117/05.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
As per the previous reporting period, Greece only reports pH as the operational control parameter set within the permitting process.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
In addition to what was reported in the previous reporting period, Greece indicates that conditions for handling and storing materials and for managing possible leakages and contaminated rainwater, where applicable, are laid down in the Decisions Approving Environmental Conditions.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
Greece indicates that this question is not applicable but no further details are provided. Based on the review of other answers provided during the present and last reporting it is unclear why this requirement is not applicable.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
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If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Greece continues to report that exemptions from monitoring requirements for emissions to air are applied to heavy metals, dioxins and furans and HF in line with the provisions of Article 11(7) and (6) of the Directive.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Greece reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
Greece refers to the response provided in the last reporting period. Greece responded then by providing a reference to the legislation transposing Article 11 to national legislation, but without providing further detail.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
Greece refers to the response provided in the last reporting period. Greece responded then by providing a reference to the legislation transposing Article 11 to national legislation, but without providing further detail.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The new and updated permit applications are available to the public from regional authorities and on the internet. The final decision is only available on the internet.
The public has between 31 and 50 days to comment on the application.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
As per the previous year, all environmental information is publicly available. Greece further clarifies that information is free of charge. Pursuant to Joint Ministerial Decision No 11764/653/06 (Government Gazette, Series II, No 327) the data may be examined by the public on the spot free of charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to questions 25 and 26 (b) compared to the last reporting period.
With regards to question 26(a) Greece indicates that the annual report must include information on the
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account of the running of the process; emissions into air and water compared to standards set in the Directive; the type of installation and the types of waste that are incinerated.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
Greece indicates that the list of plants can be obtained from the competent authority upon request. In addition, it notes that the environmental permit procedure includes a uniform public information procedure, irrespective of plant capacity.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The maximum permissible period with exceedance of emission limit values is less than 1 hour for incineration plants, and between 3 and 4 hours for co-incineration plants.
The maximum cumulative duration of periods exceeding emission limit values over one year is between 40- 60 hours. With regards to maximum cumulative duration of the periods, Greece does not distinguish between incineration and co-incineration plants.
Question 30. Any other remarks.
No general remarks are provided by Greece.
SUMMARY OF CHANGES
Greece submitted an almost complete answer to the WID questionnaire as per the Commission Decision
2011/632/EU. In several questions it referred to the response provided in the last reporting period. However it should be noted that for a number of these questions (6, 19, 20, 21, 25 and 28), Greece reported by referring to relevant parts of the national legislation, but without describing the relevant provisions. The response to the questionnaire continues therefore to be insufficient to assess the following provisions of the Directive:
if aspects outlined in Article 4(5) are specified in permits issued to plants (co)-incinerating hazardous wastes;
what provisions have been made within the permitting process to ensure compliance with the provisions of Article 11 for air and water emissions;
what provisions are in place for the submission of an annual report by operators of plants with capacity greater than 2 tonnes per hour;
what provisions are in place to control periods of abnormal operations.
Installations
5 installations (2 incinerators and 3 cement kilns) fall within the scope of the Directive, 3 of which (the 3 cement kilns) recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. Different types of wastes were co-incinerated in cement kilns including plastics, RDF, tyres and mixtures of waste containing hazardous substances.
ELVs, operational parameters and monitoring requirements
The following new information was reported:
The 3 cement kilns were granted exemptions according to Annex II.1– these were issued for SO2 (at 2 plants) and TOC (at 3 plants).
Greece clarifies that the ELVs for water discharges set out in the national legislation are identical to those in Annex IV and that no ELVs for additional pollutants to those in Annex IV were set.
General legislative provisions and procedures
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Further detail on the provisions to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7) has been provided. As such the decisions approving environmental conditions must include measures to store materials, manage leakages and possible rainwater contamination.
Greece indicates that question 15 on ensuring adequate storage capacity for water testing and treatment prior to discharge is not applicable.
The new and updated permit applications are available to the public from regional authorities and on the internet whereas the final decision is only available on the internet. Greece further adds that the public has between 31 and 50 days to comment on the application.
Greece clarifies that related environmental information is free of charge and describes further the content of the annual reports. In addition, it notes that a list of incineration or co-incineration plants with a nominal capacity of less than 2 tonnes per hour can be obtained from the competent authority upon request.
Greece has also reported that the maximum permissible period with exceedance of emission limit values is less than 1 hour for incineration plants, and between 3 and 4 hours for co-incineration plants. For both types of plants the maximum cumulative duration of periods exceeding emission limit values over one year is between 40- 60 hours.
A.12 Hungary
Analysis of the completeness of the report
Table 23: Completeness assessment of answers reported by Hungary – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a Two documents were submitted by the Member State and the responses do not correspond one with the other. 1.1.b
1.1.c
1.1.d
1.2 No response was provided.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated
4 Technical difficulty with the reporting tool.
No response available.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6 (a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
8
8.1
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Question Completeness Comment
Authorisations containing conditions in accordance with Article 6(4)
8.2
Two documents were submitted by the Member State and the responses do not correspond one with the other. The Member State reports that two authorisations are permitted, but only provides details for one. No explanation is given as to why the details are not provided.
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a Two documents were submitted by the Member State and the responses do not correspond one with the other. 9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for
additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Two documents were submitted by the
Member State and the responses do not correspond one with the other.
Operational control
parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface
water and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
Two documents were submitted by the
Member State and the responses do not correspond one with the other.
Minimising quantities and harmfulness of residues
(Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b) Two documents were submitted by the
Member State and the responses do not correspond one with the other.
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
The provisions were not provided for Articles (11(10-12).
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23 The length of time that the public can
respond to permit applications is not specified.
24 Two documents were submitted by the Member State and the responses do not correspond one with the other. 25
26.1
26.2
27 No response was provided.
Abnormal operation 28 Two documents were submitted by the
Member State and the responses do not correspond one with the other. 29
Other remarks 30
Hungary has submitted a partially complete response to the WID questionnaire as per
the Commission Decision 2011/632/EU using the electronic reporting tool. Several issues have been identified in relation to questions 1.2, 8.2, 19, 23 and 27.
Note there were several gaps in the Excel response which were not gaps in the Word
document affecting questions 1.1(b)(c), 8.2, 9(a-b), 10(a-e), 12 (a-c), 15, 18 (a-b),
24, 25, 26 (1-2), 28 and 29. We have used the Word document for the analysis here.
Lastly, there are many differences between the responses provided for the current
reporting period compared to the previous one, and it is unclear from the response
given whether or not the differences refer to changes in the legislation or differences
in reporting. All the differences reported have been captured here.
Analysis of the response by Hungary
The table below contains detailed analysis of the responses provided by Hungary to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Hungary under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 24: Hungary – Response analysis table
Hungary
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between
incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 28 plants fell within the scope of the Directive, of which 22 are incineration plants and 6 are co-
incineration plants.22 permits were issued in accordance with Article 4(1) (18 to incinerators and 4 to co-incinerators). Hungary did not provide additional information to explain why the total number of permits issued differs from the number of plants within the scope of the Directive (but they were not requested to do so in the questionnaire).
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Of the plants listed, 20 recover heat generated by the incineration process (including 15 incinerators and 5 co-incinerators).
The Member State did not provide the total permitted capacities of waste throughput (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Hungary provided no response to this question.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
Hungary identifies one problem with the definitions in Article 3 in relation to hazardous waste under the definition of incineration plants. It finds that as pyrolysis plants are classified as incinerators there is an issue with the burning of pyrogases resulting from the thermal treatment of waste at these plants whereby the process requires low reactor temperatures (compared to the legislation) and therefore the temperature related criteria cannot be met. The Member State reports that clarification is needed as to whether or not this process should be regarded as part of the incineration process or not.
The Member State makes an additional comment concerning the permit renewal process for waste incinerators, whereby it finds that if a permit is more than 5 years old, it will have already been reviewed in accordance with the integrated environmental permit rules. It is unclear how this relates to the definitions in Article 3 and what the problem is.
Note that these issues are different to those raised in the previous reporting period which implies that those previously identified have been addressed.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There seems to be a technical problem with question 4, which is not included in the Word or Excel files provided for Hungary. In the previous reporting period the main types of wastes co-incinerated were: filtercakes, wood waste, plastics, textiles, RDF, fluff from shredding, agricultural by-products, and combustible non-hazardous waste from paper, wood and plastic components.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in
Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
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Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Infectious hospital waste from packaging is considered inappropriate for sampling in Hungary because it is regarded as bulky and non-homogeneous (previously no wastes were considered inappropriate for representative sampling).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
Two plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4) (previously no exemptions were permitted). Details are provided for one authorisation, as set out below. No explanation is given as to why the details are not provided for the second authorisation referred to.
• 1 authorisation has been granted to a new plant for non-hazardous industrial waste that operates at intermittent intervals (whereby the amount of waste that can be fed into the incinerator is determined by the reactor volume and the treatment time – no plant capacity is specified in the response given). The exemption approved sets a 1% limit for the total organic halogen content of the rubber chippings that will be recovered. The plant must install an automatic system to prevent waste being fed in whenever the emission limit values are being exceeded (determined according to continuous measurements taken every two half-hour).
Lastly, note that this response is taken from the Word document that was submitted rather than the Excel. The two include different responses to this question and no explanation is offered as to why.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Two exemptions from the emission limits for TOC have been granted in accordance with Annex II.1 for two new plants co-incinerating non-hazardous waste (the capacity for the respective plants has not been specified). Note that these exemptions are different to those permitted previously. The details are as follows:
Pollutant Details
TOC Granted due to the fact that clinker production technology has been installed in the respective plants.
The emission limit values permitted are 25mg/Nm3 (DAV) and 18.2mg/Nm3 (DAV).
Annex II of the Directive specifies that exemptions from the ELVs set out for TOC [10 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste and so it is assumed that this is the reason why the exemption has been granted.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-
incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (note that in the previous reporting period different values were set and that these no longer apply).
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Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
The emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment are identical to those set in Annex IV of the Directive (note that different values were previously reported and that these no longer apply).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to
the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Additional pollutants to those listed in Annex IV of the WID have been assigned ELVs in Hungary (note that different
values were previously reported and that these no longer apply).
Polluting substance ELV reported (mg/Nm3) Comments
Total suspended solids 1,000-1,500 All additional ELVs listed apply to existing incineration plants Chemical oxygen demand (COD) 150
pH 5.5-12
Polycyclic aromatic hydrocarbons (PAH)
0.03
Absorbable organic halogen (AOX) compounds expressed as chlorine.
0.1
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
The Member State reports that pH, temperature and flow rate are all used as operational control parameters.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
The provisions to ensure the protection of soil, surface waters and groundwater are specified in the permit
conditions and include emission limit values (in accordance with Decree No 28/2004 governing water pollutant discharge limits and the rules governing their application), in addition to a damage remediation plan specifying how contaminated water will be contained.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
The criteria used to ensure that storage capacity is adequate for waters to be tested and treated before discharge is
specified in the permit conditions. The criteria specifies that storage capacity is regularly emptied so as to prevent overflow, and that continuous measurements of pollutant levels must be carried out.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Permit conditions relating to the measurement of pollutants to air are different to those set out in Article 11(2) (previously these were reported as being the same as the Directive). The deviations that apply, as reported by the Member State, are set out below:
Deviation Comments (Pollutant or parameter concerned and measurement requirement)
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More stringent requirements
No
Exemptions for HF under Article 11(4)
Yes During trial operations, the following must be measured monthly: NOx, CO, total solids, TOC, HCl and SO2, heavy metals, HF, dioxins and furans, and 3.4-Benzo(a)pyrene. During normal operations, the following must be continuously measured and recorded: NOx, CO, total solids, TOC, HCl and SO2. The following must be measured periodically (once in the first quarter and once in the second quarter following trial operation; thereafter at least two measurements per year must be taken): heavy metals, HF, dioxins and furans.
Exemptions for water vapour under Article 11(5)
Yes Measurement required at least twice a year.
Exemptions for HCl under Article 11 (6)
Yes Once per quarter during the 12 months following the commissioning of a plant and thereafter at least once every 6 months.
Exemptions for HF under Article 11(6)
Yes Continuous measurement of HF may be omitted if the technology used to capture HCl is such as to ensure compliance with ELVs for HCl. In this case, HF emissions must be verified by means of periodic measurements (once per quarter during the 12 months following the commissioning of a plant and thereafter at least once every 6 months).
Exemptions for SO2 under Article 11(6)
Yes Once per quarter during the 12 months following the commissioning of a plant and thereafter at least once every 6 months.
Exemptions for heavy metals under Article 11(7)
No
Exemptions for dioxins and furans under Article 11(7)
No
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
The Member State reports that the conditions for the measurement of pollutants emitted to water as set out in Article 11(14) and (15) are different in the case of the permit conditions for one incineration plant.
For the case in question the measurement frequency is different to those set out in the Article because pre-treated waste water is drained off indirectly via a waste water treatment plant for class 3 waste water (~2-4 times per year), and the measurement results show that the emission limit values are complied with.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
The Member State makes the following comments with regard to the provisions made within the permitting process to ensure compliance with air emission requirements:
Article Comment
11(8) The requirements relating to the evaluation of emission limit values and measurement results are specified in the permit conditions. It is unclear from the Member State response whether or not this is compliant with the conditions stipulated by the Directive.
11(9) The requirements relating to the archiving of measurement results and accessibility of these
results are specified in the permit conditions. These are compliant with the provisions stipulated by the Directive. Additional permit requirements apply to emissions from fixed sources of pollution to air under section 18 of Decree 6/2011 laying down the rules for the examination, monitoring and assessment of air load levels and emissions from fixed sources of air pollution. Operators are required to keep an operations logbook providing a continuous record of air pollution sources and the functioning of the associated technological equipment.
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11(11) The Member State reports that the provisions of the Directive are transposed exactly to national legislation. It does not provide any detail concerning the legislation or the provisions.
11(12) The Member State reports that the provisions of the Directive are transposed exactly to national legislation. It does not provide any detail concerning the legislation or the provisions.
11(10) The Member State reports that the provisions of the Directive are transposed exactly to
national legislation. It does not provide any detail concerning the legislation or the provisions.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
Hungary reports the following provisions with regard to requirements for water emission measurements laid down in Article 11 of the Directive:
Article Comment
11(9) These are covered by national legislation. No details are provided.
11(16) The technological emission limit values for waste water discharges from flue gas treatment units, and the measurement and data reporting obligations relating to compliance therewith are laid down in the permits. The conditions specify that the emission limit values must be complied with, and typically specify that a report should be written up as part of the self-monitoring requirements (in accordance with section 30 of Decree 220/2004 regarding self-monitoring).
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
Hungary reports that there is no official guidance available on producing validated daily average emission data. The Member State indicates that earlier official measurement records may be referred to and that some technical requirements are set out under Decree 3/2002 on the technical requirements and operating conditions for waste incineration and Decree 6/2011 on the examination, monitoring and assessment of air load levels and emission from fixed sources of air pollution.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
The procedures are specified in the permit conditions. In broad terms, the operator is required to cease activity until the breach is rectified, and the inspectorate must be informed of the breach immediately.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
Hungary reports that new permit applications are made available to the public through the internet, and the local and regional authority offices. The Member State does not specify the amount of time that the public has to comment on new permit applications. No comment is made concerning public participation of existing permit applications.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
Hungary reports that certain information related to environmental aspects is not publically available where there is
an issue of commercial or technological secrets that are classified as intellectual property. In general however the public does have access to information pertaining to the permit application, free of charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
The Member State reports that the permit conditions require operators to submit an annual report. No further detail
concerning the provisions is provided by the Member State.
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It is reported that the annual report should include: an account of the running of the process; emissions into air, and water compared to standards set in the Directive; capacity of the installation; type of installation; and the types of waste that are incinerated. The operator is required to publish the report on its website, or the public can put in a request to the competent authority for a copy of the report.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how
are these plants publicly identified?
The Member State does not provide a response to this question.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
The Member State reports that the provisions to control plant activity during abnormal operation are specified in the permit conditions. The conditions include:
• The waste feed must be stopped in the case of equipment breakdown or malfunction until operating
conditions have been restored.
• Processes must be limited in the event of a malfunction until normal operating conditions have been restored, and they must be stopped if the risks are deemed to pose a serious threat to the surrounding population.
• The operator must draw up a remediation plan that should be updated every 5 years and approved by the inspectorate under Section 9 of Decree 90/2007 on the prevention and remediation of environmental damage.
• The inspectorate must be informed of the abnormal conditions within 12 hours, and the operator must specify the type of abnormal operation affecting the environment, the environmental media at risk, the extent of contamination, and the measures taken and the results achieved according to an external environmental officer (the operator is required to cover the costs of the site inspection). Further, the inspectorate must be present when any site inspection is made.
• The operator is required to maintain a record of abnormal operations in a logbook in keeping with the
requirements set under section 14 of Decree 3/2002 which lays down requirements relating to abnormal operation.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation
during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
Hungary reports that the maximum permissible period exceeding emission limit values is between 3 and 4 hours,
and that in cumulative terms this must not exceed between 40 and 60 hours. These provisions are set under section 14(4) of Decree 3/2002.
Question 30. Any other remarks.
No general remarks are provided by Hungary.
SUMMARY OF CHANGES
Hungary submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. There are many differences between the responses provided for the current reporting period compared to the previous one, and it is unclear from the response given whether or not the differences refer to changes in the legislation or differences in reporting.
Installations
28 plants (22 incinerators and 6 co-incinerators) fall within the scope of the Directive, 20 of which recover the heat generated in the incineration process (including 15 incinerators and 5 co-incinerators). Of the total plants listed, 22 were permitted (including 18 incinerators and 4 co-incinerators) and, so far, no permits have been granted to mobile plants, as per the previous reporting period.
The Member State did not provide the total permitted capacities of waste throughput (optional question), nor did it provide a list of all the plants within the scope of the Directive.
ELVs, operational parameters and monitoring requirements
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The Member State reports the following exemptions to ELVs and monitoring requirements, and other operational parameters:
Infectious hospital waste from packaging is considered inappropriate for sampling in Hungary because it is regarded as bulky and non-homogeneous.
Two plants have been exempted from the operating conditions with regard to the conditions for the furnace gas residence times and temperatures as specified in articles 6(1) and 6(2) in accordance with Article 6(4). The exemption approved sets a 1% limit for the total organic halogen content of the rubber chippings that will be recovered at new plant for non-hazardous industrial waste that operate at intermittent intervals.
Two exemptions from the emission limits for TOC have been granted in accordance with Annex II.1 for two new plants co-incinerating non-hazardous waste due to the fact that clinker production technology has been installed in the respective plants. The emission limit values permitted are 25mg/Nm3 (DAV) and 18.2mg/Nm3 (DAV).
The air emission limit values given in Annex II or Annex V of the Directive and the emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment set in Annex IV of the Directive are applied exactly.
The following parameters have been assigned ELVs which are additional to those listed in Annex IV of the WID: total suspended solids (1,000-1,500 mg/Nm3); Chemical oxygen demand (COD) (150 mg/Nm3); pH (5.5-12 mg/Nm3); Polycyclic aromatic hydrocarbons (PAH) (0.03 mg/Nm3); Absorbable organic halogen (AOX) compounds expressed as chlorine (0.1 mg/Nm3).
The Member State reports that pH, temperature and flow rate are all used as operational control parameters. In addition, it reports that total suspended solids are used in the continuous monitoring of metals, and dioxins and furans, which are carried out every 24 hours in the case of metals and every 3 months in the case of dioxins and furans.
Permit conditions relating to the measurement of pollutants to air are different to those set out in Article 11(2). The deviations that apply, as reported by the Member State, are for: HF under Article 11(4); water vapour under Article 11(5); and, HCl, HF and SO2 under Article 11 (6).
The Member State reports that the conditions for the measurement of pollutants emitted to water as set out in Article 11(14) and (15) are different in the case of the permit conditions for one incineration plant. For the case in question the measurement frequency is different to those set out in the Article because pre-treated waste water is drained off indirectly via a waste water treatment plant for class 3 waste water (~2-4 times per year), and the measurement results show that the emission limit values are complied with.
General legislative provisions and procedures
Hungary reports that the requirements of the Directive are transposed fully within national legislation. The relevant provisions are included in the following pieces of legislation:
Decree 3/2002 on the technical requirements and operating conditions for waste incineration.
Decree No 28/2004 governing water pollutant discharge limits and the rules governing their application.
Decree 220/2004 regarding self-monitoring.
Decree 90/2007 on the prevention and remediation of environmental damage.
Decree 6/2011 laying down the rules for the examination, monitoring and assessment of air load levels and emissions from fixed sources of air pollution.
Hungary identifies one problem with the definitions in Article 3 in relation to hazardous waste under the definition of incineration plants. It finds that as pyrolysis plants are classified as incinerators there is an issue with the burning of pyrogases resulting from the thermal treatment of waste at these plants whereby the process requires low reactor temperatures (compared to the legislation) and therefore the temperature related criteria cannot be met. The Member State reports that clarification is needed as to whether or not this process should be regarded as part of the incineration process or not.
A.13 Ireland
A.13.1 Analysis of the completeness of the report
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Table 25: Completeness assessment of answers reported by Ireland – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10
(a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water and
groundwater protection (Article 8(7)) 14
Ensuring adequate storage capacity
for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
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Question Completeness Comment
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of
breaches of emission limit values 22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Ireland provided a complete response to the questionnaire.
A.13.2 Analysis of Ireland’s responses
The table below contains detailed analysis of the responses provided by Ireland to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Ireland under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
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Table 26: Ireland – Response analysis table
IRELAND
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 20 plants fell within the scope of the Directive, of which 5 are co-incineration plants.
16 permits were issued in Ireland. In the previous reporting period Ireland indicated that all plants were permitted and that there were two permits which covered four plants. It is probable that the same has occurred in the current reporting period although the Member State has not specified this.
10 incineration plants and all 5 co-incineration plants recover heat generated by the incineration process.
No response was provided concerning the total permitted capacities of waste throughput (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Ireland listed 16 plants, of which 11 are incineration plants, 3 are co-incineration in cement kilns, and 2
are co-incineration plants in other industrial facilities.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
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Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
Ireland reported no problems concerning the definitions in Article 3, except for those relating to hazardous waste and mixed municipal waste. In both cases the problem reported is the difficulty of distinguishing between an incineration and co-incineration plant – particularly if the generation of energy is reported as the main purpose of the plant and dependent on the tariffs from the sale of energy.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The types of waste that have been co-incinerated were reported for 4 plants, including in cement kilns as well as other industrial facilities, as listed below (EWC codes of each of the wastes co-incinerated are set out in the table below, where provided by the Member State):
Type of plant Category of waste
Co-incinerated?
Remarks
Cement kilns Waste oils Yes Not specified
Solvents
Filter cakes
Wood waste
Plastics
Textiles
RDF Yes 191210
Fluff from shredding
Other
Other industrial facilities
Other Yes Still bottoms and reaction residues (070708), organic solvents (070104), washing liquids and mother liquors (070504).
The permitted capacity of different waste types was provided for co-incineration in cement kilns in relation to waste oils and RDF (95,000 tonnes p.a. and 127,875 tonnes p.a., respectively). For co-incineration in other industrial facilities, the amounts varied between 5,000 and 5,600 tonnes p.a.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change since the previous reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There is no category of waste considered inappropriate for sampling in Ireland (as reported in the previous reporting period).
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Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
1 new plant has been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). Ireland does not indicate the type of plant but reports that it has capacity of 1,250kg of waste per hour and that process solvent distillates are permitted for co-incineration: EWC codes 07 01 04* and 07 05 04* . Distillates reportedly do not contain dissolved solids. The permit operating conditions have not changed since the previous reporting period and the same information has been reported by Ireland.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available
please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
One exemption in accordance with Annex II.1 has been granted to a cement kiln with regards to the ELV for SO2:
Pollutant Details
SO2 Granted to existing plants with a capacity of 80 tonnes per hour co-incinerating solid recovered fuel and low carbon fuel, tyres, biomass sludge from industrial waste water treatment, solvents* due to the fact that emissions do not result from the incineration of waste
SO2 limit value reported is 400 mg/Nm³, daily average value
*Note that those wastes underlined were not reported previously.
Annex II of the Directive, specifies that exemptions from the ELV set out for SO2 [50 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste. In line with this requirement Ireland indicates that SO2 emissions do not originate from waste incineration.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those given in Annex II or Annex V have been set - these are summarised in the table below. The different values are the same as the previous reporting period however the number of plants is different. Application of different ELVs has been described for 7 plants but based on the information submitted it is unclear if there are other plants with different ELVs (the questionnaire only requested information on ELVs applied “if available)”.
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IRELAND
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours; II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply.
Parameter
WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
Arsenic (As) 0.5 (30 min -8h)
1 new plant listed (not previously reported)
ELV= 0.2 (30 minute to 8-hour averaging period, discontinuously)
More stringent requirement based on air dispersion modelling for As emission
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
Dust 30 DAV (II.1 –cement)
1 existing co-incineration plant (other industry)
ELV = 40 (continuous monitoring, averaging period not specified in permit)
Annex II mixing rule
NOx 800 existing - 500 new DAV (II.1 –cement)
400-200 DAV (II.2.1)
1 existing co-incineration plant (other industry)
ELV = 635 (continuous monitoring, Ireland reports that averaging period is not specified in permit)
Annex II mixing rule
SO2 50 DAV (II.1 –cement)
850-200 DAV (II.2.1)
2 existing co-incinerators and one new co-incinerator
ELV (cement kiln) = 400 (DAV, continuously)
ELV (other industry) = 625 (continuously)
ELV (new plant) = 200 (HHAV, periodic)
Cement kiln: Annex II.1: SO2 emissions do not result from the co-incineration of waste
Other industrial sector: Annex II mixing rule
New plant: Article 11(6)
Sb+As+Pb+Cr+Co+Cu+Mn+Ni+V
0.5 DAV (II.1.2)
1 new co-incinerator
ELV= 0.2 (30 minute to 8-hour averaging period, discontinuously)
More stringent requirement based on air dispersion modelling for As emission
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Ireland reports no change since the previous reporting period. Limit values for emissions to the aquatic environment differ from those in Annex IV of the Directive in the case of one permitted facility (P0009-03) where emissions from flue gas cleaning are mixed with other effluents and treated collectively prior to discharge. It reports that emission limit values for flue gas treatment emissions are set for total suspended solids (30-45 mg/la), Cu (0.5 mg/l), Zn (1.5 mg/l) and dioxins/furans (0.3 mg/l). However any difference with the WID is not clear, as these ELVs are the same as those stipulated in Annex IV of the WID. Monthly monitoring is required for all parameters in Annex IV, except for total suspended solids (daily) and dioxins and furans (biannual).
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Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous
reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
All permits require continuous monitoring of temperature and flow of waste water discharges from flue gas cleaning while only some require monitoring of pH as well. For the permits that don't require continuous pH monitoring on waste water discharges from flue gas cleaning, the waste water discharge from flue gas cleaning is combined with general plant waste waters for collective treatment in on-site waste water treatment plants and there is a requirement in each case for continuous pH monitoring on the combined waste water treatment plant discharge.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change since the previous reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change since the previous reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change since the previous reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Ireland reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to air are different to those set out in Article 11(2), as follows:
Deviation Comments (Pollutant or parameter concerned and measurement
requirement)
More stringent requirements
Exemptions for HF under Article 11(4)
Yes HF, twice yearly, quarterly.
Exemptions for water vapour under Article 11(5)
Yes
Exemptions for HCl under Article 11 (6)
Yes HCl, twice yearly.
Exemptions for HF under Article 11(6)
Yes HF, quarterly monitoring required in one permit when fluorinated compounds are utilised or manufactured. Twice yearly.
Exemptions for SO2 under Article 11(6)
Yes SO2, twice yearly.
Exemptions for heavy metals under Article 11(7)
Yes In one permit for a liquid-vapour incinerator, monitoring is "as required" by the regulatory authority.
Exemptions for dioxins and furans under Article 11(7)
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Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Ireland since the last reporting period. There has been a deviation to the conditions set out in Article 11(14) and 11(15) whereby the frequency of periodic measurements for heavy metals is reduced from twice a year to once every 2 years. This deviation continues to be applied in the case of 5 permits, as per the previous reporting period.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change since the previous reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change since the previous reporting period to the following guidance has been published by the Environmental Protection Agency, however the web links have been updated:
Guidance on cross checking continuous analysers under requirements of Quality Assurance Levels (QAL) 2 (calibration of the installed automated monitoring systems (AMS) using a standard reference method (SRM))and QAL 3 (assessment of ongoing performance using zero / span gas) and again annually under annual surveillance testing: http://www.epa.ie/air/airenforcement/guidanceinrelationtoqualityofairemissionsdata/guidanceonthequalityofairemissionmonitoringdata/#.Vc3kkjZwazc
Guidance which applies to the application of 95% confidence intervals as required in WID & LCPD licences: http://www.epa.ie/pubs/advice/air/emissions/guidanceonagencyrequirementsunderwidandlcpd.html
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change since the previous reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change since the previous reporting period – arrangements are as follows:
The permit application and final decision are publicly available at the office of the national authority and can be consulted on the internet.
The public can comment during the period of assessment of an application of a new permit or its review (from the date of receipt up until a proposed decision (draft permit) is issued) and for a period of 28 days after the date of publication of a proposed decision. An oral hearing can also be requested
during this latter 28-day period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period – all information is publically available at no charge.
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Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change compared to the last reporting period and all permits, regardless of the scale of activity, require the submission of annual environmental report to the competent authority. The reports include information concerning: the running of the process; emissions into air compared to standards set in the Directive; emissions into water compared to standards set in the Directive; capacity of the installation; type of the installation (incineration or co-incinerations); and types of waste that are incinerated.
The reports are available online at the website of the Environmental Protection Agency: www.epa.ie
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change compared to the last reporting period - all incineration and co-incineration plants are permitted, regardless of capacity.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change compared to the last reporting period - relevant permits generally prohibit waste feed by means of an automated system.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change compared to the last reporting period - the maximum permissible period of abnormal operation with exceedance of ELVs of 3 to 4 hours (in line with article 13), and the maximum cumulative duration of periods exceeding ELVs over one year is 40- 60 hours (in line with article 13).
These periods are explicitly expressed in two incineration permits although generally the permit requirement is to either cease waste feed or cease operation in the event of abnormal operation.
At cement kilns co-incinerating waste, plant associated with an electrostatic precipitator is to be taken off-line in the event of a loss of operation of an electrostatic precipitator for more than 30 minutes. Waste feed and/or operation is to cease as soon as practicable in the event of abnormal operation, including continuous monitors indicating that emission limit values are being exceeded.
Question 30. Any other remarks.
No general remarks are provided by Ireland.
SUMMARY OF CHANGES
Ireland submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
20 plants fell within the scope of the Directive in Ireland, of which 5 are co-incineration plants. In total 16 permits were issued, of which all were for incineration plants. No response was provided for the total permitted capacity of waste throughput (this was an optional question). Details were provided for 16 plants, of
which 11 are incineration plants, 3 are co-incineration in cement kilns, and 2 are co-incineration plants in other industrial facilities. The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations were not provided.
ELVs, operational parameters and monitoring requirements
The information provided on exemptions has not changed since the previous reporting period with the exception of the derogation in place for cement kilns co-incinerating waste in accordance with Annex II.1. Tyres, biomass sludge from industrial waste water treatment and solvents have been included in the list of relevant waste types not emitting SO2.
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General legislative provisions and procedures
Ireland reported problems concerning the definitions in Article 3, for those relating to hazardous waste and mixed municipal waste due to the difficulty of distinguishing between an incineration and co-incineration plant.
The types of waste that have been co-incinerated were reported for 4 plants (in cement kilns as well as other industrial facilities), and include waste oil, RDF, and Still bottoms and reaction residues, organic solvents, washing liquids and mother liquors. The permitted capacity of different waste types and amounts was provided for co-incineration in cement kilns in relation to waste oils and RDF (95,000 tonnes p.a. and 127,875 tonnes p.a., respectively). For co-incineration in other industrial facilities, the amounts varied between 5,000 and 5,600 tonnes p.a.
A.14 Italy
A.14.1 Analysis of the completeness of the report
Table 27: Completeness assessment of answers reported by Italy – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Whilst in question 1 Italy reports a total of 123 plants (68 incinerators and 55 co-incinerators), in question 1.2 Italy only lists 73 plants. In addition, no details on the name, latitude and longitude of the plants have been provided in question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Italy only reports a long list of co-incinerated wastes identified by their EWC code
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Italy states the total number of co-incineration plants to which the emission limits provided in Annex V to the Directive apply to. However, it does not indicate the reason that justifies this.
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
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Question Completeness Comment
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Italy has not provided details of exemptions from certain emission limit values provided for the cement kilns; however this information was only to be provided “if these data are available” and therefore is not seen as a gap.
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for
waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional
pollutants discharged to water beyond those in Annex IV
12 (a-c)
The different reporting template used
by the Member State has meant that less details have been provided.
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water and
groundwater protection (Article 8(7)) 14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19 Italy refers to the specific articles and
annexes of national legislation but no further description of provisions is provided.
Handling the results of measurements
and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of
breaches of emission limit values 22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
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Question Completeness Comment
29
Other remarks 30
Italy provided a response to the questionnaire with several gaps. The response to
questions 1.2, 4 and 5 are partially incomplete, whereas no answer has been provided
to questions 2, 7, 21 and 24. In addition, Italy’s answer does not use the template
that has been provided by the Commission, rather it has responded using the
template for the previous reporting period. As such, Italy’s response includes information for two additional questions.
A.14.2 Analysis of Italy’s responses
The table below contains detailed analysis of the responses provided by Italy to the WID
questionnaire covering the period 2012-2013. The information presented is based solely
on the information reported by Italy under each question. The table contains a summary
of the response, as well as further comments and descriptive analysis of the answers given.
Table 28: Italy – Response analysis table
Italy
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 123 plants fell within the scope of the Directive, of which 68 are incineration plants and 55 are co-incineration plants.
123 permits have been issued in accordance with Article 4(1)
All plants recover the heat from the incineration process.
The total annual waste throughput was provided for the following: 5.189.184 tonnes in incinerators and 3.561.335 tonnes in co-incinerators.
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
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A total of 73 installations are listed in question 1.2, of which 36 are incinerators. The remaining 37 are co-incinerators, of which 14 are identified as cement kilns and 2 electrical power plants.
Italy reports that municipal waste treatment plants, including those with an R1 permit, are not required to report energy efficiency calculated according to the formula provided in the footnote to point R1 of Annex II to Directive 2008/98/EC.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No answer has been provided to question 2. This may indicate that there are no problems with the definitions of article 3 of the WID.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
Italy does not follow the format of the Electronic Reporting Tool and instead reports a long list of co-incinerated wastes identified by their EWC code. Due to the length of this list wastes reported are not summarised here.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are 8 co-incineration plants to which the emission limits set out in Annex V have been applied. However, the Italian response does not indicate the type of reason that justifies this.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
No answer has been provided to question 7. Perhaps no wastes were considered inappropriate for representative sampling.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No authorisations have been granted allowing an exemption from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4) have been granted, as per the previous period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
11 exemptions in accordance with Annex II.1 have been granted to cement kilns. However no further details are provided by Italy under question 9 (b) on the type of pollutants.
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Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those given in Annex II or Annex V, as well air ELVs for new pollutants (those not listed in the Directive) have been set in Italy. It is only reported that these have been applied in one new incinerator and in existing incineration/co-incineration plants with regards to the following pollutants: Total dust, TOC, NOx, NO2, SO2, HCI, PAH, PCB, NH3.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Italy only reports that ELVs are determined by taking measurements at waste water discharge points. However it is unclear based on this response whether those emission limit values differ from the ones in Annex IV.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Additional pollutants to those listed in Annex IV of the WID have been assigned ELVs for existing incinerators.
These limits are set out in table 3, Annex 5 (part 3) to Legislative Decree No 152/2006, in addition to some parameters laid down by Legislative Decree No 133/2005. However no detail on the parameters regulated are provided.
Nevertheless, the response provided to question 13 shows that, in addition to the parameters specified in Annex IV, permits lay down emission limit values for polycyclic aromatic hydrocarbons (PAHs), which have to be measured every three months for the first 12 months of operation and after that at least twice a year.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Italy reports that the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2), with the exception of 5 plants, for which periodic HF measurements are planned. No further detail is provided.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
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If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
As per the previous reporting period, Italy indicates that the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
No answer has been provided. Perhaps this means that no guidance had been produced (as reported the
previous period).
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change in the response to this question compared to the last reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
Italy refers to question 23 above. However, from the response provided under that question it is unclear if there is any information related to environmental aspects not publicly available and if the information is free of charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to questions 25 and 26 compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible
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period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Italy.
SUMMARY OF CHANGES
Italy submitted an almost complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. Changes since the previous reporting period are summarised below.
Installations
123 installations (68 incinerators and 55 co-incinerators) fall within the scope of the Directive, of which all recover the heat generated in the incineration process. All plants have been permitted, and so far no permits have been granted to mobile plants, as per the previous reporting period. The total permitted waste throughput was 8,750,519 tonnes per year. A range of wastes were reported to be co-incinerated in co-incineration plants.
ELVs, operational parameters and monitoring requirements
The following changes have been reported:
• There are 8 co-incineration plants to which the emission limits set out in Annex V have been applied.
• 11 exemptions from the emission limits in accordance with Annex II.1 have been granted.
• Different air limit values to those given in Annex II or Annex V, as well air ELVs for new pollutants have been set in Italy in one new incinerator and in existing incineration/co-incineration plants with regards to
the following: Total dust, TOC, NOx, NO2, SO2, HCL, PAH, PCB, NH3.
• Additional pollutants to those listed in Annex IV of the WID have been assigned ELVs for existing incinerators. In particular, national legislation requires the permit to lay down ELVs for polycyclic aromatic hydrocarbons (PAHs), in addition to the parameters of Annex IV.
• The permit requirements for the measurement of pollutants to air are identical to those set out in Article 11(2), with the exception of 5 plants, for which periodic HF measurements are planned.
General legislative provisions and procedures
There has been no change in the information provided by Italy with regards to general legislative procedures and provisions.
A.15 Latvia
Analysis of the completeness of the report
Table 29: Completeness assessment of answers reported by Latvia – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c The number of co-incinerators that
recover heat was not specified.
1.1.d
1.2 Only two plants were listed.
Definitions (Article 3) 2
Mobile plants 3
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Question Completeness Comment
Categories of waste co-incinerated 4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6 (a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with
Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters
for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water
and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7)) 15
Latvia has reported that the question
is not applicable, and yet Article 8(7) refers to storage capacity for contaminated rainwater run-off therefore a criteria should have been developed and should have been reported here.
Minimising quantities and
harmfulness of residues (Article 9) 16
Measurement of pollutants to air
and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
The provisions for Article 11(10), (11), and (12) have not been specified by the Member State.
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Question Completeness Comment
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Latvia has submitted a partially complete response to the WID questionnaire as per the
Commission Decision 2011/632/EU using the electronic reporting tool. Several issues
have been identified in relation to questions 1.1(c), 1.2, 4, 15 and 19 (as presented in the table above).
Analysis of the response by Latvia
The table below contains detailed analysis of the responses provided by Latvia to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Latvia under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 30: Latvia – Response analysis table
Latvia
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 11 plants fell within the scope of the Directive, of which six are incineration plants and five are co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
Only one of the plants listed recovers heat generated by the incineration process.
The total permitted capacities of waste throughput is 322,106 tonnes/year (optional question).
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Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Latvia only listed two co-incineration plants. The details were provided for both of them.
Of the reported co-incineration plants, one was in a cement kiln and the other was in other industrial facilities.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with the definitions in Article 3 have been identified. This suggests that the problems reported in the previous reporting period have been resolved.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
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The following types of waste were co-incinerated (EWC codes of each of the wastes co-incinerated are set out below, as provided by the Member State):
Type of plant Category of waste
Co-incinerated?
Remarks
Cement kilns Waste oils Yes 770 t/a Includes: Waste engine, gear and lubricating oils (130204, 130205, 130206, 130207, 130208); Bilge oils (130401, 130402, 130403); Waste hydraulic oils (130105, 130110, 130111,130112); and, End-of-life tyres (160103)
Solvents
Filtercakes
Wood waste
Yes 15000 t/a
Includes: wood containing dangerous substances (191206)
Plastics
Textiles
RDF Yes 252000 t/a
Includes: packaging waste (including separately collected municipal packaging waste) (150101); plastic (170203); unsorted municipal waste not containing hazardous components (190203); wastes from the mechanical treatment of wastes (including mixtures of materials) (191212); paper and cardboard (200101); clothes (200110); textiles (200111); plastics (200139); unsorted municipal waste (200301); composite materials (040209); and textile waste (191208).
Fluff from shredding
Other Yes 24000 t/a
Premixed wastes composed of at least one hazardous waste (190204)
Other industrial facilities Other Yes 35.66 t/a
Paper and cardboard (200101); Wastes whose collection and disposal is not subject to measures to prevent infection (for example linen, disposable clothing, diapers) (180104); textiles (200111); and, sawdust, shavings, cuttings, spoiled timber or particles (030105)
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Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
No waste is considered inappropriate for sampling in Latvia (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted
plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
As reported in the previous reporting period, one cement kiln has been granted exemptions from the emission limit values in accordance with Annex II.1. It is an existing plant with capacity to incinerate 166.7 tonnes of used tyres, waste-derived fuel (ecofuel), wood production residues, natural wood residues, polluted soil and bottom sludge. Latvia notes the following:
Pollutant Details
TOC Granted due to the fact that TOC emissions do not result from the incineration of waste
TOC limit value is 284.77 tonnes per year.
SO2 Granted due to the fact that SO2 emissions do not result from the incineration of waste
TOC limit value is 1138.76 tonnes per year.
Dust Dust limit value is 113.88 tonnes per year
No further information is provided
NOx NOx limit value is 2847.0 tonnes per year.
No further information is provided
Annex II of the Directive specifies that exemptions from the ELVs set out for TOC [10 mg/Nm³] and SO2 [50 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste. In line with this requirement Latvia indicates that a study conducted by the German Cement Institute in 2011 on the chemical composition of raw materials and fuel showed that emissions of TOC and SO2 are produced by raw materials and not as a result of waste incineration.
Annex II also indicates that exemptions from the NOx ELV [800 mg/Nm³ for existing plants] and dust ELV [30 mg/Nm³] could be authorised until January 2008 for existing wet process cement kilns or cement kilns which burn less than three tonnes of waste per hour, provided that the ELV is not more than 1200 mg/Nm³. Latvia
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seems to report that these derogations are still in place which is potentially contradictory to the requirements of the directive.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
There has been no wet scrubbing of flue gases with water at any of the waste incineration plants issued with a permit and thus the emission limit values for emissions to the aquatic environment are not applicable.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period. Note that this response is considered to be incomplete as Latvia has reported that the question is not applicable, and yet Article 8(7) refers to storage capacity for contaminated rainwater run-off therefore a criteria should have been developed and should have been reported here.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Latvia reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to air are the same as those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
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Latvia reported no changes since the previous reporting period. No conditions for the measurement of pollutants emitted to water as set out in Article 11(14) and (15) have been established in a permit because no incineration plant produces waste water.
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that the provisions for Article 11(10), (11), and (12) have not been specified by the Member State.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance
with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period. The question is not relevant due to the fact that no incineration plants produce waste water from the cleaning of the exhaust gases in Latvia.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or
updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change in the response to this question compared to the last reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to this question compared to the last reporting period. Additional
information has been provided by the Member State relating to public access to the annual reports, with a link to a website where annual reports on substances emitted into the atmosphere and on waste and waste management are available (http://parissrv.lvgmc.lv/#viewType=home_view).
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
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Latvia
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Latvia.
SUMMARY OF CHANGES
Latvia submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
A total of 11 installations (six incinerators and five co-incinerators) fall within the scope of the Directive, one of which recovers the heat generated in the incineration process. The total permitted capacities of waste throughput is 322,106 tonnes/year. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. Latvia only provided the details for two co-incineration plants.
The following types of waste were co-incinerated: Waste oils, wood waste, textiles, RDF, and other (premixed wastes composed of at least one hazardous waste, paper and cardboard and wastes whose collection and disposal is not subject to measures to prevent infection).
ELVs, operational parameters and monitoring requirements
The Member State has reported the following changes:
No plants have been exempted from the operating conditions with regard to conditions for the furnace gas residence times and temperatures.
The air emission limit values for releases to air from incineration and co-incineration plants are the same as those given in Annex II or Annex V.
The emission limit values for emissions to the aquatic environment are not applicable because there has been no wet scrubbing of flue gases with water at any of the waste incineration plants issued with a permit.
General legislative provisions and procedures
There have been no changes in the responses provided on legislative provisions and related procedures since the previous reporting period, though some additional detail has been provided in relation to public access to the annual reports that incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour are required to submit. The Member State has included a link to a website where annual reports on substances emitted into the atmosphere and on waste and waste management are available (http://parissrv.lvgmc.lv/#viewType=home_view).
A.16 Lithuania
Analysis of the completeness of the report
Table 31: Completeness assessment of answers reported by Lithuania – WID
Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 No details on the latitude and longitude of
the plants were provided.
Definitions (Article 3) 2
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Question Completeness Comment
Mobile plants 3
Categories of waste co-incinerated
4 Technical difficulty with the reporting tool.
No response available.
Co-incineration plants subject
to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation
to hazardous waste (Article 4(5))
6
(a–d)
No information is actually provided on the
provisions made within the permitting process
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for
additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control
parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface
water and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues
(Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
The Member State has not provided any detail concerning the provisions.
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Question Completeness Comment
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and
public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28 No response was given.
29
Other remarks 30
Lithuania has submitted a partially complete response to the WID questionnaire as per
the Commission Decision 2011/632/EU using the electronic reporting tool. A few gaps
have been identified in the report with regards to questions 6, 19 and 28 (as outlined in the table above).
Analysis of the response by Lithuania
The table below contains detailed analysis of the responses provided by Lithuania to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Lithuania under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 32: Lithuania – Response analysis table
Lithuania
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total three plants fell within the scope of the Directive, of which two are incineration plants and one is a co-incineration plant.
Permits were issued for all plants that fall within the scope of the Directive.
All of the plants listed recover heat generated by the incineration process.
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Lithuania
The total permitted capacities of waste throughput was reported to be 180,000 tonnes/year (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Lithuania listed three plants and details were provided for all of them. Of these, one was a co-incineration and two were incineration plants.
The one co-incineration plants listed is a combustion plant.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems have been reported with the definitions in Article 3, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
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Lithuania
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There was a technical problem with the reporting tool for question 4. No response was logged.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied. The Member State previously reported that the emission limits applied to two co-incineration plants.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
Additional information has been provided compared to the last reporting period. As reported previously, Lithuania has listed the yearly quantities of the different categories of hazardous wastes that can be treated and specifies the conditions to be set regarding maximum mass flow (1.1 tonnes/hour, 26.4 tonnes/day or 8 000 tonnes/year) and the range of calorific values (10,000 – 40,000 KJ/kg). In addition, the Member State has specified that waste compatibility is determined according to the results of hazardous waste analyses and on the basis of information provided by the operator. If waste with a content of more than 1% of halogenated organic substances, expressed as chlorine, is used when composing mixtures, the whole mixture must be incinerated in such a way that the gas resulting from the process is raised, after the last injection of air, in a controlled and homogeneous fashion and even under the most unfavourable conditions, to a temperature of 1 100 °C, as measured near the inner wall of the incineration chamber, for 2 seconds.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There has been no change since the previous reporting period. Several wastes are reported to be inappropriate for representative sampling, including: end-of-life tyres, wooden packaging, textile packaging, plastic and rubber, textiles, paper and cardboard, paper and cardboard packaging, waste linings and refractories (residues from fire-proof bricks), waste concrete and concrete sludge, and hazardous medical waste.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
No exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1, as per the previous reporting period.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the
emission monitoring regime for these pollutants.
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Lithuania
No air emission limit values different to those given in Annex II or Annex V have been set (as per the previous reporting period).
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
As reported in the previous reporting period, Lithuania has stated that requirements have not been set up because no waste water is generated from flue gas cleaning equipment. It is unclear what requirements would apply in the event that these discharges were produced by plants in the future.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period. No operational control parameters have been set within the permitting process for waste water discharges because no waste water is generated from flue gas cleaning equipment.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Lithuania reported that permit conditions relating to the measurement of pollutants to air are the same as those set out in Article 11(2) (the exemptions previously reported no longer apply).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Lithuania reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. The Member State has not provided any detail concerning the provisions.
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Lithuania
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
The Member State has reported that no water discharges are performed and so there has been no change since the previous reporting period concerning Article 11(9) and Article 11(16).
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
The Member State has reported that no official guidance is available.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change in the response to this question compared to the last reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to this question compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
The Member State has responded that no such plants operate in Lithuania.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
No response was provided by the Member State.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The Member State has reported that the maximum permissible period exceeding Emission Limit Values is between 3 and 4 hours, and that the maximum cumulative duration of periods exceeding Emission Limit Values is between 40 and 60 hours.
Question 30. Any other remarks.
No general remarks are provided by Lithuania.
SUMMARY OF CHANGES
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Lithuania
Lithuania submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
Three installations (two incinerators and one co-incinerator in a combustion plant) fall within the scope of the Directive, all of which recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. The total permitted capacities of waste throughput was reported to be 180,000 tonnes/year.
ELVs, operational parameters and monitoring requirements
There have been no changes since the previous reporting period.
General legislative provisions and procedures
There have been mostly no changes in the responses provided on legislative provisions and related procedures since the previous reporting period, though some additional detail has been provided on the following issues.
With regards to the permitting process, additional information has been provided concerning the restrictions that apply. The Member State has specified that waste compatibility is determined according to the results of hazardous waste analyses and on the basis of information provided by the operator. If waste with a content of more than 1% of halogenated organic substances, expressed as chlorine, is used when composing mixtures, the whole mixture must be incinerated in such a way that the gas resulting from the process is raised, after the last injection of air, in a controlled and homogeneous fashion and even under the most unfavourable conditions, to a temperature of 1 100 °C, as measured near the inner wall of the incineration chamber, for 2 seconds.
Further, the Member State has reported that the maximum permissible period exceeding Emission Limit Values is between 3 and 4 hours, and that the maximum cumulative duration of periods exceeding Emission Limit Values is between 40 and 60 hours.
A.17 Luxembourg
Analysis of the completeness of the report
Table 33: Completeness assessment of answers reported by Luxembourg – WID
Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 The plant name and addresses were not
provided.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
The standard categories of waste have
not been used.
Co-incineration plants subject to
the emission limits applicable to incineration plants (Article 7(2) and (4))
5
It is unclear if the co-incineration plant
listed is because co-incineration of untreated municipal waste is undertaken or because more than 40 % of the heat released results from the combustion of hazardous waste.
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Question Completeness Comment
Permitting process in relation to hazardous waste (Article 4(5)) 6
(a–d)
The provisions in the national legislation have not been provided, rather the Member State has set out the permit conditions as granted to the co-incineration plant.
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing
conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for
cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and
harmfulness of residues (Article 9) 16
Measurement of pollutants to air
and water (Article 11)
17
(a- b)
18
(a-b)
Handling the results of measurements and determining compliance for emissions to air
(Article 11)
19
No provisions have been provided.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
No provisions have been provided.
Guidance on producing validated daily average emission data (Article11(11))
21
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25 No provisions have been provided
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Luxembourg has submitted a partially complete response to the WID questionnaire as
per the Commission Decision 2011/632/EU. The response does not use the template
that has been provided by the Commission as a result it does not include some of the
standardised answer that were included in the electronic reporting tool (ERT). Several
gaps have been identified with regards to questions 1.2, 4, 5, 6, 9, 19 and 20 (as
presented in the table above).
Analysis of the response by Luxembourg
The table below contains detailed analysis of the responses provided by Luxembourg to
the WID questionnaire covering the period 2012-2013. The information presented is
based solely on the information reported by Luxembourg under each question. The
table contains summary of the response, as well as further comments and descriptive
analysis of the answers given.
Table 34: Luxembourg – Response analysis table
Luxembourg
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total three plants fell within the scope of the Directive, of which two are incineration plants and one is co-incineration plant.
Permits were issued for all plants that fall within the scope of the Directive.
All of the plants listed recover heat generated by the incineration process.
The total permitted capacities of waste throughput 208,548 tonnes/year (optional question).
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Luxembourg
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula
provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Luxembourg listed three plants but did not provide the plant names or addresses.
The one reported co-incineration plant was a cement kiln.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the
Directive. Provide specific information for each definition for which problems are identified.
No problems with the definitions in Article 3 were reported, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There has been no change since the previous reporting period. Note that as the Member State has not used the template provided by the Commission, the types of waste reported are different to the categories of waste pre-defined in the questionnaire and are not summarised in a table as in the case of other Member States.
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Luxembourg
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
The emission limits set out in Annex V have been applied to the one co-incineration plant listed. As per the previous reporting period it is unclear if it is because co-incineration of untreated municipal waste is undertaken or because more than 40 % of the heat released results from the combustion of hazardous waste.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided the national requirements regarding the content of permits, rather it has set out the provisions within the permit granted to the co-incineration plant.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Rubber waste was considered inappropriate for sampling in Luxembourg (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted
plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
As reported previously, the cement kiln has been granted exemptions from the emission limit values in accordance with Annex II.1. It is an existing plant with capacity for 1,000,000 tonnes per year of clinker.
Pollutant Details
TOC TOC limit value is 30 mg/Nm3
SO2 Exceptionally, emissions of SO2 may exceed 50 mg/Nm3 but should not exceed 200 mg/Nm3. Should this occur operators must submit a certificate as soon as possible proving that the higher emissions do not result from waste incineration. This certificate must be renewed at least once every two years and any time there is a significant change in the load composition. If the higher emissions are generated from waste incineration they must be stopped immediately.
Annex II of the Directive, specifies that exemptions from the ELVs set out for TOC [10 mg/Nm³] and SO2 [50 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste. In line with this requirement Luxembourg indicates that SO2 emissions can only exceed the ELV when waste incineration is not the source. No specific information is provided on TOC but it is assumed to be the same case.
In addition, it is indicated that emissions of nitrogen oxides may exceed the ELV of 500 mg/Nm3 but may not exceed 800 mg/Nm3 (which is the ELV stipulated in the WID for existing cement kilns).
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Luxembourg
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
No emission limit values for emissions to the aquatic environment have been reported by the Member State as neither the waste incineration plants nor the clinker production plant (co-incineration) produce waste water discharges resulting from waste gas scrubbing to the aquatic environment.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
As reported in the previous reporting period, Luxembourg has reported that additional pollutants discharged to
water to those specified in Annex IV are applied to ELVs, as follows:
The existing incineration plant concerning the discharge from the wastewater treatment plant. The following ELVs are to be applied: Settleable solids after two hours [0.3 ml/l], suspended solids [30 mg/l], BOD5 [25 mg/l O2 (24 hours); 30 mg/l O2 (2 hours)] and COD [100 mg/l O2 (24 hours); 140 mg/l O2 (2 hours)].
The existing co-incineration plant concerning regenerated water from ion exchangers and rain water.
The following ELVs are to be applied: Suspended solids [50 mg/l], arsenic [0.1 mg/l], absorbable organic halogens (AOX) [0.2 mg/l], CaCl2 [7 g/l] and hydrocarbons [5 mg/l].
Among these parameters, the water stream from the incinerator has to comply with an ELV for suspended solids (30 mg/l), whereas the water stream from the co-incinerator has to comply with and ELV for suspended solids (50 mg/l) and Arsenic (0.1 mg/l). These parameters are listed in Annex IV to the WID: Suspended solids (95%/30 mg/l-100% 45mg/l) and Arsenic (0.15 mg/l).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Luxembourg reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to air are the same as those set out in Article 11(2).
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Luxembourg
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There is no discharge of industrial water from the plants covered by the WID, as reported previously.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that the provisions have not been specified by the Member State.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period. Note that the provisions have not been specified by the Member State.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change in the response to this question compared to the last reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to this question compared to the last reporting period. Note that the provisions to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority have not been specified by the Member State.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period. Information
to identify these plants is available on request.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
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Luxembourg
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Luxembourg.
SUMMARY OF CHANGES
Luxembourg submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
Three installations (two incinerators and one co-incinerator in a cement kiln plant) fall within the scope of the Directive, all of which recover the heat generated in the incineration process. The total permitted capacities of waste throughput 208,548 tonnes/year. The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period.
ELVs, operational parameters and monitoring requirements
For releases to air from incineration and co-incineration plants, the air emission limit values are identical to those given in Annex II or Annex V of the Directive.
General legislative provisions and procedures
There have been no changes in the responses provided on legislative provisions and related procedures since the previous reporting period.
A.18 Malta
A.18.1 Analysis of the completeness
Table 35: Completeness assessment of answers reported by Malta – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
(a-b)
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
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Question Completeness Comment
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.a
8.b
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional
pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for
water discharges (Article 8(6)(b)) 13
Provisions for soil, surface water
and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Based on the response it is impossible to determine how sufficient storage capacity for waters to be tested and treated is ensured.
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
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Question Completeness Comment
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Malta submitted almost a complete answer to the WID questionnaire as per Commission
Decision 2010/731/EC. The only gap has been identified in the response to question 15.
A.18.2 Analysis of Malta responses
The table below contains detailed analysis of the responses provided by Malta to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Malta under each question. The table contains a
summary of the response, as well as further comments and descriptive analysis of the
answers given. In cases where text has been quoted directly from the English translation of the report, it is presented in italics.
Table 36: Malta – Response analysis table
MALTA
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
1 incineration plant, with capacity above 2 tonnes per hour fell within the scope of the Directive.
The plant is permitted but did not recover the heat generated by the incineration process.
The total permitted capacity of waste throughput was 12,910 tonnes per year (this was an optional question).
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with definitions were reported.
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MALTA
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to Directive 2000/76/EC during the reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There were no co-incineration plants in Malta during the reporting period and so this question is not applicable.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There were no co-incineration plants in Malta during the reporting period and so this question is not applicable.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
There has been no change in the response to this question compared to the last reporting period. Infectious clinical waste continues to be considered inappropriate for sampling.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No exemptions from the operating conditions in Article 6(1) or 6(2) have been granted in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Malta reports that there were no cement kilns in operation during the reporting period and so this question is not applicable.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No different air limit values to those given in Annex II or Annex V have been set, as per the previous period.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
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MALTA
Malta only reports that emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive, as per the previous period.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Malta reports that no ELVs covering additional pollutants to the ones specified in Annex IV have been set for
waste water discharges.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in Malta compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in Malta compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change in Malta compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Malta compared to the last reporting period. These are identical to those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change in Malta compared to the last reporting period, These are identical to those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in Malta compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in Malta compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
No official guidance on producing validated daily average data has been developed.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
There has been no change in Malta compared to the last reporting period.
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MALTA
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The application for a new permit is publicly available at national and local authorities at several public
locations and can be consulted on the internet as well. Several public locations refer to the nearest local council offices.
The final decision on a new permit is publicly available at the national competent authority and can be consulted on the internet as well.
The public is eligible to comment on the application for a period of 10- 30 days before the decision.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is
available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in Malta compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in Malta compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in Malta compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in Malta compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in Malta compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Malta.
SUMMARY OF CHANGES
The information in the report submitted by Malta covers all the requirements of the questionnaire, providing data to demonstrate the status regarding implementation. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
There was only 1 incinerator plant with capacity above 2 tonnes per hour falling within the scope of the Directive during the reporting period. The plant is permitted but did not recover the heat generated by the incineration process. No co-incineration plants exist in Malta.
ELVs, operational parameters and monitoring requirements
No exemptions or additional requirements have been adopted with regards to ELVs and measurement requirements in accordance with the corresponding provisions of the Directive, as per the previous reporting period.
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MALTA
General legislative provisions and procedures
The only change that has been reported in comparison with the previous reporting period relates to question 23 on public participation. For new installations, the public is eligible to comment on the application for a period of 10- 30 days and has access to all permitting information free of charge. This is available at the premises of the National and Local Competent Authority (nearest local council offices) and through the internet.
The operator is required to submit an annual report in accordance with the content specified in national legislation. The reports are available on the Internet and upon request from the competent authorities.
A.19 Netherlands
Analysis of the completeness of the report
Table 37: Completeness assessment of answers reported by the Netherlands – WID
Directive
Question Completeness Comment
Numbers of plants and
permits
1.1.a There is an inconsistency with the number of
plants provided by the Member State between question 1.1 and question 1.2. 1.1.b
1.1.c
1.1.d
1.2 There is an inconsistency with the number of
plants provided by the Member State between question 1.1 and question 1.2.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated
4
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
No provisions have been provided.
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
9.a
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Question Completeness Comment
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
It is not clear from the Member State response which pollutant the ELV provided applies to. However, it could be for CO given that the same ELV was reported previously for CO.
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control
parameters for water discharges (Article 8(6)(b))
13
Provisions for soil,
surface water and groundwater protection (Article 8(7))
14
No provisions concerning the design of the plant
site and associated storage areas is provided.
Ensuring adequate
storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
No criteria is specified.
Minimising quantities
and harmfulness of residues (Article 9)
16 No provisions are provided.
Measurement of
pollutants to air and water (Article 11)
17 (a-
b)
No detail has been provided as to how these are
not identical to the Directive.
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
No provisions for Article 11(8), (10), and (11) have been provided.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
No provisions have been provided.
Guidance on producing validated daily average emission data (Article11(11))
21
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28 No provisions have been provided.
29
Other remarks 30
The Netherlands has submitted a partially complete response to the WID questionnaire
as per the Commission Decision 2011/632/EU using the electronic reporting tool. A few
gaps have been identified in the report with regards to questions 1.1, 1.2, 4, 6, 10, 14,
15, 16, 17, 19, 20 and 28 (as outlined in the table above).
Analysis of the response by the Netherlands
The table below contains detailed analysis of the responses provided by the Netherlands
to the WID questionnaire covering the period 2012-2013. The information presented is
based solely on the information reported by the Netherlands under each question. The
table contains summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 38: The Netherlands – Response analysis table
The Netherlands
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down
between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 40 plants fell within the scope of the Directive, of which 36 are incineration plants and four are
co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
95% of the total plants listed recover heat generated by the incineration process.
No response was provided concerning the total permitted capacities of waste throughput (optional question).
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The Netherlands
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula
provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
The Netherlands listed 19 plants and details were provided for all of them. Of these, five were co-incineration and 14 incineration plants.
Of the reported co-incineration plants, one was a combustion plant and four were cement kilns.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC are applicable in the Netherlands for the 19 incinerator plants listed. The energy efficiency figures provided range between 0.60 and 1.04.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the
Directive. Provide specific information for each definition for which problems are identified.
Only one problem was reported by the Netherlands concerning the definitions in Article 3 with regards to mixed municipal waste. According to the Member State, a distinction is made between waste from households and commercial waste in the Netherlands.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The Member State has provided the categories of waste that are co-incinerated for all four co-incinerator plants, as follows (no EWC codes were provided by the Member State):
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The Netherlands
Type of plant Category of waste
Co-incinerated?
Remarks
Cement kilns
Waste Oils
Solvents
Filtercakes Yes Hazardous waste
Wood waste
Plastics
Textiles
RDF Yes Non-hazardous waste
Fluff from shredding
Sludge Yes
Other Yes
Non-hazardous anode material, bedcokes and animal waste. Sludge (hazardous and non-hazardous) is also incinerated.
Other industrial plants
Other Yes
Solvents, wood and waste oil are also incinerated as hazardous waste. Sludge (hazardous and non-hazardous) is also incinerated.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period. Note that the provisions have not been specified by the Member State.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
No waste is considered inappropriate for sampling in the Netherlands (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in
accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
Two existing co-incinerator plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
No exemptions from emission limits for cement kilns in accordance with Annex II.1 have been reported, as reported in the previous reporting period.
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Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
The air emission limit values are different to those given in Annex V in the case of one existing incinerator plant, as follows:
Parameter WID Value (mg/m3) (averaging period)
Plants and ELV reported (mg/m3) (averaging period- see note)
Reasoning / comments
Incineration plants- Different ELVs to those specified in Annex V to the WID
Not specified
For one existing plant: ELV= 15 mg/Nm3 (YAV); 11% O2; Continuous monitoring
It is not clear from the Member State response which pollutant this ELV applies to. However, it could be for CO given that the same ELV was reported previously for CO.
More stringent air limit values to those given in Annex II or Annex V or covering additional pollutants have been set for the following substances: CO, Cd and Ti, CxHy, dioxins/furans, HCl, HF, Hg, NH3, NOx, PAKS, SO2, dust, TOC and heavy metals. The Member State has reported that detailed information on these values can be provided on request.
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours; II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous
reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
The Member State has referred to the response provided for the previous reporting period. Note that the provisions concerning the design of the plant site and associated storage areas is provided have not been specified by the Member State.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
The Member State has referred to the response provided for the previous reporting period. Note that for both
the current and previous reporting periods, the criteria has not been specified by the Member State.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
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The Member State has referred to the response provided for the previous reporting period. Note that the provisions have not been specified by the Member State.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
As reported in the previous reporting period, the requirements of the permit for the measurement of pollutants to air and process operation parameters are different to those set out in Article 11(2) in the Netherlands.
Reported reasons under question 19 for deviating from Article 11(2) are:
Deviation Comments (Pollutant or parameter concerned
and measurement requirement)
More stringent requirements
Exemptions for HF under Art. 11(4) Yes No further information provided.
Exemptions for water vapour under Art. 11(5)
Yes No further information provided.
Exemptions for HCl under Art. 11(6): Yes No further information provided.
Exemptions for HF under Art. 11(6): Yes No further information provided.
Exemptions for SO2 under Art. 11(6): Yes No further information provided.
Exemptions for heavy metals under Art. 11(7):
Exemptions for Dioxins and furans
under Art. 11(7): Yes No further information provided.
Based on the reported information, it seems that exemptions concerning the continuous measurements of water vapour, HCl, HF and SO2 may be laid down in the permit, allowing for periodic measurements to be carried out. The Netherlands does not provide further information on the application of these exemptions and on the periodic measurement requirements imposed in permits.
In addition, the exemption laid down under Article 11(7) to reduce the frequency measurement for Dioxins and Furans from twice a year to once a year is indicated in their response to question 19. However this seems to be inconsistent with the response provided under question 10 where it reports a more stringent measurement regime for dioxins and furans, with continuous measurement and fortnightly sampling (once every two weeks) as opposed to two periodic measurements per year.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
The Netherlands has reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that no provisions for Article 11(8), (10), and (11) have been provided.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period. Note that no provisions have been provided for either the current or previous reporting period.
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Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
Guidance on measurement obligations, the conversion, testing and uncertainty of measurement results,
recording and reporting has been incorporated within an interactive web-based user guide, available here, http://www.infomil.nl/onderwerpen/klimaat-lucht/stookinstallaties/sitemap/.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an
emission limit value?
The Netherlands has reported that in the case of a breach of an emission limit value, the installation must take
immediate action to limit the consequences and inform the competent authority as quickly as possible. A derogation can be applied where the adverse effects on the environment are not significant. The provisions are set out in Article 17 of the Environmental Management Act. Note that it is unclear if the provisions have changed
or if more detail has been provided.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or
updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change since the previous reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change since the previous reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided any details concerning the provisions.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by the Netherlands.
SUMMARY OF CHANGES
The Netherlands has submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
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In total, 40 installations (36 incinerators and four co-incinerators) fall within the scope of the Directive, 38 of which recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. Details were provided for 19 plants (five co-incinerators and 14 incinerators). Of the reported co-incineration plants, one was a combustion plant and seven were cement kilns. The energy efficiency figures provided range between 0.60 and 1.04.
ELVs, operational parameters and monitoring requirements
The Member State has provided the categories of waste that are co-incinerated for all four co-incinerator plants.
In cement kilns this includes filtercakes, RDF and other (non hazardous anode material, bedcokes, animal waste and sludge). In other industrial plants this include solvents, wood, waste oil, and sludge (under the waste category of other). The EWC and the permitted capacity granted for these plants were not provided by the Member State.
The air emission limit values are different to those given in Annex V in the case of one existing incinerator plant (ELV= 15 mg/Nm3 (YAV); 11% O2; Continuous monitoring). It is not clear from the Member State response which pollutant this ELV applies to. However, it could be for CO given that the same ELV was reported previously for CO. More stringent air limit values to those given in Annex II or Annex V have been set for the following substances: CO, Cd and Ti, CxHy, dioxins/furans, HCl, HF, Hg, NH3, NOx, PAKS, SO2, dust, TOC and heavy metals. The Member State has reported that detailed information on these values can be provided on request.
General legislative provisions and procedures
There have been mostly no changes in the responses provided on legislative provisions and related procedures since the previous reporting period, though new guidance has been published and some additional detail has been provided, as follows.
New guidance has been developed on measurement obligations, the conversion, testing and uncertainty of measurement results, recording and reporting. Although the content is much the same as reported in the previous reporting period, it has now been incorporated within an interactive web-based user guide, available here, http://www.infomil.nl/onderwerpen/klimaat-lucht/stookinstallaties/sitemap/.
Additional information has been provided with regards to the procedures in place in the case of a breach of an emission limit value. It is unclear if the provisions have changed or if more detail has been provided. The Member State has reported that in the case of a breach, the installation must take immediate action to limit the consequences and inform the competent authority as quickly as possible. A derogation can be applied where the adverse effects on the environment are not significant. The provisions are set out in Article 17 of the Environmental Management Act.
Lastly, fewer problems have been reported by the Netherlands in this reporting period concerning the definitions in Article 3. The problem identified concerns mixed municipal waste, for which a distinction has to be made between waste from households and commercial waste.
A.20 Poland
A.20.1 Analysis of the completeness of the report
Table 39: Completeness assessment of answers reported by Poland – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 No details concerning location of the
plants are provided.
Definitions (Article 3) 2
Mobile plants 3
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Question Completeness Comment
Categories of waste co-incinerated 4
Poland has only listed the plant names but not the waste.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II
or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and
harmfulness of residues (Article 9) 16
Measurement of pollutants to air and
water (Article 11)
17
(a- b)
18
(a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Poland has submitted a partially complete response to the WID questionnaire as per the
Commission Decision 2011/632/EU using the electronic reporting tool. A few gaps have
been identified in the report with regards to question 1.2 (as outlined in the table above).
A.20.2 Analysis of Poland’s responses
The table below contains detailed analysis of the responses provided by Poland to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Poland under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 40: Poland – Response analysis table
Poland
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued
in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 119 plants fell within the scope of the Directive, of which 51 are incineration plants and 68 are co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
61% of the total plants listed recover heat generated by the incineration process.
No response was provided concerning the total permitted capacities of waste throughput (optional
question).
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Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Poland listed all plants, however, beyond the name of the installation, details were only provided for 31
plants.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems concerning the definitions in Article 3 were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
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The types of waste that have been co-incinerated were reported for 9 co-incinerating plants in cement kilns and 8 in combustion plants. It is unclear from the information available which categories are co-incinerated as no details are provided beyond the name of the installation and the type of plant.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
Since 23 January 2013, the provisions made within the permitting process for the above mentioned factors fall under the Waste Act of 14 December 2012 (Journal of Laws 2013, item 21, as amended).
During the procedure for issuing administrative decisions for the operation of thermal waste treatment installations, pursuant to Article 42 of the Waste Act of 14 December 2012 (Journal of Laws 2013, item 21, as amended), the application for a permit for thermal waste treatment shall specify (regardless of the properties of the waste) the types of waste to be processed. If the specification of the type is not sufficient to establish the threats that the waste can cause to human life and health and to the environment, the competent authority may request the applicant to specify the basic chemical composition and properties of the waste. The application shall also specify the mass of the various types of waste (including hazardous waste) treated and formed in the treatment process over a one year period. Further, it shall also specify technical and organisational capabilities that allow for the appropriate operation of the waste treatment installation, with a particular regard to professional qualifications or training of personnel, as well as to the quantity and quality of installations and appliances complying with environmental protection requirements. The application shall also specify the minimum and maximum quantities of hazardous waste, its highest and lowest calorific value and the maximum content of pollutants, in particular PCB, pentachlorophenol (PCP), chlorine, fluorine, sulphur and heavy metals. Furthermore, pursuant to Article 188(2) of the Act of 27 April 2001 – Environmental Protection Law (Journal of Laws 2013, item 1232, as amended), the permit shall determine the type and parameters of the installation relevant to preventing pollution.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Medical and veterinary waste are considered inappropriate for sampling in Poland due to their potentially contagious properties (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4).
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
As reported previously, 9 exemptions in accordance with Annex II.1 have been granted to cement kilns; however details are only provided for 3 plants with regards to two types of pollutants – specifically SO2 and TOC.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
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If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
As reported previously, the air limit values are the same as those set in Annex II and Annex V.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Poland reports no change since the previous reporting period. Limit values for emissions to the aquatic environment are identical to those in Annex IV of the Directive.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
As reported previously, in addition to the ELVs specified in Annex IV for pollutants discharged to water, temperature and pH are used as additional parameters for monitoring.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
As reported previously, all permits require continuous monitoring of temperature and pH of waste water discharges from flue gas cleaning.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change since the previous reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change since the previous reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
Since the previous reporting period, additional provisions have been introduced to establish appropriate procedures for handling waste formed as a result of thermal waste treatment under the Waste Act of 14 December 2012 (Journal of Laws 2013, item 21, as amended). Accordingly, operators must now test the physical and chemical properties of waste formed in the thermal waste treatment process, including in particular the soluble fractions of heavy metals; transport and store waste in dust form, created in the thermal waste treatment process, in closed containers; and determine a safe route for the transport of hazardous waste formed in the thermal waste treatment process if their recovery or disposal in the place of origin was unsuccessful.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Poland reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to air are the same as those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Poland reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
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Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change since the previous reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period – provisions are reported for both articles although no detail is provided concerning Article 11(16).
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change since the previous reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change since the previous reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change since the previous reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
There has been no change compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Poland.
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SUMMARY OF CHANGES
Poland submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU.
In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
119 plants fell within the scope of the Directive in Poland, of which 51 are incineration plants and 68 co-
incineration plants. Permits were issued for all 119 plants. 73 plants (61%) recover heat generated by the incineration process. No information was provided regarding the total annual permitted capacity of waste throughput. Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
ELVs, operational parameters and monitoring requirements
No changes are reported concerning ELVs, operational parameters and monitoring requirements.
General legislative provisions and procedures
No problems concerning the definitions in Article 3 were reported.
New provisions concerning the operation of thermal waste treatment installations within the permitting process were introduced under the Waste Act of 14 December 2012 (Journal of Laws 2013, item 21, as amended). Under the new provisions, the permit must outline the types and mass of waste processed, and where necessary must specify the chemical composition and properties of the waste. The permit must also specify technical and organisational capabilities of operating staff, as well as the minimum and maximum quantities of hazardous waste, its highest and lowest calorific value and the maximum content of pollutants, in particular PCB, pentachlorophenol (PCP), chlorine, fluorine, sulphur and heavy metals. In addition, operators must now test the
physical and chemical properties of waste formed in the thermal waste treatment process, including in particular the soluble fractions of heavy metals; transport and store waste in dust form, created in the thermal waste treatment process, in closed containers; and determine a safe route for the transport of hazardous waste formed in the thermal waste treatment process if their recovery or disposal in the place of origin was unsuccessful.
A.21 Portugal
Analysis of the completeness of the report
Table 41: Completeness assessment of answers reported by Portugal – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
The number of co-incinerators and
incinerators for details have been provided does not correlate to the number provided in response to question 1.2.
1.1.b
1.1.c The number of plants recovering heat is
greater than the total number of plants that fall within the scope of the Directive.
1.1.d
1.2
The number of co-incinerators and incinerators for details have been provided does not correlate to the number provided in response to question 1.1.a. The latitude and longitude was not provided for the plants.
Definitions (Article 3) 2
Mobile plants 3
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Question Completeness Comment
Categories of waste co-incinerated
4 Technical difficulty with the reporting tool.
No response available.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing
conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14 No provisions have been provided.
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
No provisions have been provided.
Minimising quantities and
harmfulness of residues (Article 9)
16 No provisions have been provided.
Measurement of pollutants to
air and water (Article 11)
17 (a- b)
18 (a-b)
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Question Completeness Comment
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
No details for the provisions have been provided.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
No details for the provisions have been provided.
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and
public participation (Article 12)
23
24
No response was given to part (b) of this
question (as to whether or not the information is available free of charge or not)
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Portugal has provided a partially complete response to the questionnaire as per the
Commission Decision 2011/632/EU. Several issues were identified in relation to
questions 1.1(a)(c), 1.2, 14, 15, 16, 19, 20 and 24.
Analysis of the response by Portugal
The table below contains detailed analysis of the responses provided by Portugal to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Portugal under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given.
Table 42: Portugal – Response analysis table
Portugal
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
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Portugal
In total 14 plants fell within the scope of the Directive, of which seven are incineration plants and seven are co-incineration plants.
Permits were issued for three plants that fall within the scope of the Directive.
121% of the total plants listed recover heat generated by the incineration process. It is unclear why more plants have been listed as recovering heat generated by the incineration process to the total number of plants within the scope of the Directive.
No response was provided concerning the total permitted capacities of waste throughput (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula
provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Portugal listed 14 plants and details were provided for all of them. Of these, eight were co-incineration and six incineration plants.
Of the reported co-incineration plants, six were in cement kilns and two were in other industrial facilities.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation.
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Portugal
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with the definitions in Article 3 have been identified, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There is a technical problem with the reporting tool with regards to question 4. No response is available from Portugal.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that
may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
No wastes are considered inappropriate for sampling in Portugal (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available
please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
No exemptions from emission limits in accordance with Annex II.1 have been granted (previously, exemptions were granted to five existing plants in cement kilns).
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (previously, stricter limit values were applied for dust).
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Portugal
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
No emission limit values different to those given in Annex IV have been set (previously, stricter emission limit values to the aquatic environment were applied for lead and dioxins and furans).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (previously, additional
limits were set in Portugal).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided any details concerning the provisions.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period. Note that
the Member State has not provided any details concerning the provisions.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period. Note that
the Member State has not provided any details concerning the provisions.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Portugal has reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to air are the same as those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Portugal reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that in the previous reporting period’s response no detail has been provided for any of the provisions.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
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Portugal
There has been no change in the response to this question compared to the last reporting period. Note that no detail has been provided for any of the provisions.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
Applications for new permits are publicly available at the office of the regional and national authority, and can also be consulted on the internet. The final decision is available at the premises of the national authority and also on the Internet.
To comment on the application for a new permit, the public is given a period of 10-30 days (it is unclear when this period starts).
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period. Note that no response was given to part (b) of this question (as to whether or not the information is available free of charge or not).
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to this question compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Portugal.
SUMMARY OF CHANGES
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Portugal
Portugal submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
A total of 14 installations (seven incinerators and seven co-incinerators) fall within the scope of the Directive. Three plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. No response was provided concerning the total permitted capacities of waste throughput.
Note that there are two inconsistencies in the reporting of plant numbers concerning the number of plants that recover heat generated by the incineration process (which is greater than the total number of plants that fall within the scope of the Directive), and the number of incinerators and co-incinerators for which details have been provided. These inconsistencies were also apparent in the previous reporting period.
ELVs, operational parameters and monitoring requirements
The following changes have been reported by the Member State:
No exemptions to the emission limits for cement kilns co-incinerating waste apply.
The emission limit values in Annex II and Annex V have been applied exactly (for releases to air).
The emission limit values in Annex IV have been applied exactly (for discharge of wastewater).
No additional pollutants to those listed in Annex IV have been assigned ELVs (for discharges to water).
General legislative provisions and procedures
Portugal has reported only one change concerning the legislative provisions and related procedures since the previous reporting period with regards to the arrangements in place to ensure public participation in the permitting process. The amended provisions are as follows:
Applications for new permits are publicly available at the office of the regional and national authority, and can also be consulted on the internet. The final decision is available at the premises of the national authority and also on the Internet.
To comment on the application for a new permit, the public is given a period of 10-30 days (it is unclear when this period starts).
A.22 Romania
A.22.1 Analysis of the completeness of the report
Table 43: Completeness assessment of answers reported by Romania – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Whilst in question 1 RO reports a total of 29 plants (20 incinerators and 9 co-incinerators), in question 1.2 RO lists 12 plants
Definitions (Article 3) 2
Mobile plants 3
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Question Completeness Comment
Categories of waste co-incinerated
4
There seems to be a technical problem with question 4. Romania indicates that the software application has drawn out from the answer to question 1.2 only one co-incineration plant from a list of eight plants and, therefore, it was not possible to provide the required information for those plants.
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions
in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit
values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for
waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18
(a-b)
Handling the results of measurements
and determining compliance for emissions to air (Article 11)
19
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Question Completeness Comment
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public
participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Romania provided an almost complete response to the questionnaire. Only the response
to question 1.2 is partially incomplete. In addition there seems to be a technical problem
with question 4.
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A.22.2 Analysis of Romania’s responses
The table below contains detailed analysis of the responses provided by Romania to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Romania under each question. The table contains
a summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 44: Romania – Response analysis table
Romania
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 29 plants fell within the scope of the Directive, of which 20 are incineration plants and 9 are co-
incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
62% of the total plants listed recover heat generated by the incineration process.
No response was provided concerning the total permitted capacities of waste throughput (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Romania listed 11 plants and details were provided for all of them. Of these, 8 were co-incineration and 3 incineration plants.
Of the reported co-incineration plants, 1 was a combustion plant and 7 were cement kilns.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was not applicable to any installation.
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Romania
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
There has been no change since the previous reporting period. In Romania clarification continues to be needed with regards to the terms “untreated mixed municipal waste” and the classification of incineration plants.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
There seems to be a technical problem with question 4. Romania indicates that the software application has drawn out from the answer to question 1.2 only one co-incineration plant from a list of eight plants and, therefore, it was not possible to provide the required information.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Medical and veterinary waste continue to be considered inappropriate for sampling in Romania (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per previous reporting period.
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Romania
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
All cement kilns (7) have been granted exemptions from emission limits in accordance with Annex II.1, as follows:
Pollutant Details
SO2 Granted to all 7 plants.
SO2 limit values reported range between 400 and 1500 mg/Nm³, with the values of 400-450 mg/Nm³ being the most frequent (applied in 6 plants).
TOC Granted to 5 plants.
TOC values between 50 and 100 mg/Nm³ are mentioned, with 100 mg/Nm³ being the most frequent limit value (applied in 3 plants).
NOx Set for 1 plant with a capacity with a production capacity above 23 t/h, which was subject to a transition and upgrade which ended in December 2013.
The limit value for NOX is 2000 mg/Nm³.
Dust Set for the same plant as NOx exemption.
The limit value for dust is set at 50 mg/Nm³.
Annex II of the Directive specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste. In line with this requirement Romania indicates that this is the case for SO2 and TOC emissions. In addition, it should be noted that plant with an ELV of 1500 mg/Nm³ is subject to a transition and upgrade to reduce emissions which was reported as due to end in December 2013.
Annex II also indicates that until 1 January 2008, exemptions from ELVs for NOx [800-500 mg/Nm³] and dust [10 mg/Nm³] may be authorised for existing wet process cement kilns (only for NOx) or cement kilns which burn less than three tonnes of waste per hour, provided that the ELV is not more than 1200 mg/m3 for NOx and 50 mg/Nm³ for dust. Romania has informed that abatement measures for this pollutants were implemented before the end of the transition period. Consequently, under the Integrated Environmental Permit No 5/20.10.2013, valid until 20.12.2023, this installation has no longer been granted exemptions from the emission limit values in 2013.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
No air emission limit values different to those given in Annex II or Annex V have been set (as per the previous reporting period).
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for
discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
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Romania
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Romania reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to air are the same as those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Romania reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period concerning Article 11(9). With regards to the compliance regime set out in Article 11(16) Romania specifies that environmental permits establish all the emission limit values provided for in the Annex IV to Directive 2000/76/EC as mandatory conditions.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
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Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The permit application and final decision of new and updated permits are publicly available at all levels of the public administration (local, regional, national and other) and can be consulted on the internet as well.
The public is given an opportunity to comment from the moment of submission of the application, to granting of the permit.
In addition Romania notes that the place where information is published varies according to the competences to issue the environmental agreement:
o Public display in a certain territorial area, organisation of exhibitions with plans, drawings, tables, graphs, designs relating to the project in question and others.
o Public access to documentation in electronic format; in cases where server capacity is insufficient, the competent authority communicates where information should be published.
o Publications from national and/or local press.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to questions 25 and 26(a) compared to the last reporting period. Regarding question 26 (b) Romania adds that all annual reports are available from the Competent Authority
upon request. In addition, the operator must maintain a file for public information on the site, available to the public upon request. However, they do not need to disclose the full report.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Romania.
SUMMARY OF CHANGES
Romania submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
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Installations
29 installations (20 incinerators and 9 co-incinerators) fall within the scope of the Directive, 18 of which recover the heat generated in the incineration process. All plants were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period.
ELVs, operational parameters and monitoring requirements
Exemptions to the ELVs for NOx, SO2, TOC and dust set out in the Directive have been reported again for the 7 existing cement kilns. However the exemption granted to one of these plant for the NOx and dust ELVs seems to deviate from the requirements of the Directive as these exemptions could only be granted until 1 January 2008 and the plant had a transition period until December 2013. However, Romania has reported that abatement measures for these pollutants were implemented before the end of the transition period and consequently the plant was no longer granted an exemption during 2013 under the Integrated Environmental Permit No 5/20.10.2013, valid until 20.12.2023.
General legislative provisions and procedures
There have been mostly no changes in the responses provided on legislative provisions and related procedures since the previous reporting period, though some additional detail has been provided on the following issues.
With regards to the compliance regime set out in Article 11(16) Romania further specifies that environmental permits establish all the emission limit values provided for in the Annex IV to Directive 2000/76/EC as mandatory conditions.
For new and updated permits, Romania details further that different channels that are available to the public to participate in the permitting process during the entire period between the submission of the application and the final granting of the permit.
An annual reporting requirement is laid down in the integrated environmental permits. The operator must maintain a file for public information on the site, available to the public upon request. In addition, Romania indicates that annual reports are also available from the Competent Authority upon request.
According to Romania clarifications to some of the definitions of Article 3 to the Directive are still needed. A problem with the definition of “untreated mixed municipal waste” and “incineration plants‟ was reported, specifically on the inclusion of waste pyrolysis and gasification plants as falling under the scope of the Directive.
A.23 Slovakia
A.23.1 Analysis of the completeness of the report
Table 45: Completeness assessment of answers reported by Slovakia – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 Details are only provided for 9 of the
total 23 permitted plants.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
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Question Completeness Comment
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement
kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit
values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values
for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and
water (Article 11)
17
(a- b)
18
(a-b)
Handling the results of
measurements and determining compliance for emissions to air (Article 11)
19
Handling the results of
measurements and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
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Question Completeness Comment
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Slovakia has provided an almost complete response to the questionnaire. A few
issues were identified with respect to questions 1 and 1.2.
A.23.2 Analysis of Slovakia’s responses
The table below contains detailed analysis of the responses provided by Slovakia to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Slovakia under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given.
Table 46: Slovakia – Response analysis table
Slovakia
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 23 plants fell within the scope of the Directive, of which 17 are incineration plants and 6 are co-incineration plants. Slovakia also reports that 2 of these plants are non-operational (unclear which type of plant this refers to).
Permits were issued for all plants that fall within the scope of the Directive.
All of the plants listed recover heat generated by the incineration process.
The total permitted capacities of waste throughput (optional question) was not provided as the data is not available according to the Member State.
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Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula
provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Slovakia listed the details for 9 plants.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were only provided for one of the incineration plants listed (R1 – 0.73).
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems concerning the definitions in Article 3 were reported.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period. Slovakia also indicates that no applications were submitted for operation of such plants.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The types of waste that have been co-incinerated were reported for 5 co-incinerating plants in cement kilns and 1 in combustion plants. The information available is presented below:
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Type of plant Category of waste
Co-incinerated?
Remarks
Cement kilns Solvents
Filter cakes
Plastics
RDF Yes The permitted capacity for RDF was reported in all 6 cases, up to 90,000 tonnes/year in the highest example given. No EWC code was provided by the Member State.
Fluff from shredding
Sludge
Other
Combustion plants
Wood waste
Sludge
Other Yes Other sludge from biological treatment of industrial waste water (190812) – the permitted capacity is 28,502 tonnes/year.
The permitted capacity of different waste types was provided for the co-incineration of RDF in cement kilns, and sludge from biological treatment of industrial waste water, as reported in the table above.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
The emission limits set out in Annex V have not been applied to any plants, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
Regarding the provisions within the permitting process for identifying hazardous waste that may be treated, in addition to the provisions previously reported, Slovakia notes that if no requirements are laid down in the permit, the operator is obliged to comply with the requirements under general legislation. Regarding the minimum and maximum flows, the provisions no longer require a certificate of the waste by an accredited facility. There has been no change since the previous reporting period regarding the provisions for the range of calorific values of hazardous waste permitted, and any restrictions on the content of pollutants.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Infectious and non-infectious waste from veterinary activities are considered inappropriate for sampling in Slovakia due to their health risks (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
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2 authorisations have been granted in accordance with Article 6(4) (9% of the total number of plants), as reported in the previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
1 exemption in accordance with Annex II.1 has been granted to an existing cement kilns (note that in the previous reporting period no exemptions were granted):
Pollutant Details
TOC Granted to 1 existing plant that co-incinerates solid conditioned waste due to the fact that TOC emissions do not result from the incineration of this waste. The plant capacity is 7 tonne/hour-1 of waste per year.
TOC limit value is 30 mg/Nm3 DAV for the existing plant.
Annex II of the Directive, specifies that exemptions from the ELVs set out for TOC [10 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those set in Annex II have been set for 1 existing co-incineration combustion plant (previously no differences were reported). These are summarised below:
Parameter Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Co-incineration combustion plants - Additional ELVs to those specified in Annex II.2 to the WID
HF 1 existing co-incineration combustion plant
ELV = 5 mg/Nm³ (DAV), discontinuous monitoring (every 3 months during testing)
ELV as proposed by
operator
TOC 1 existing co-incineration combustion plant
ELV = 25 mg/Nm³ (DAV), continuous monitoring
CO 1 existing co-incineration combustion plant
ELV = 235 mg/Nm³ (DAV), continuous monitoring
HCl 1 existing co-incineration combustion plant
ELV = 20 mg/Nm³ (DAV), discontinuous monitoring (every 3 months during testing)
H2S 1 existing co-incineration combustion plant
ELV = 10 mg/Nm³ (DAV), 10% O2, continuous monitoring
NH3 1 existing co-incineration combustion plant
ELV = 20 mg/Nm³ (DAV), discontinuous monitoring (every 3 months during testing)
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours; II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply.
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Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Slovakia reports no change since the previous reporting period. Limit values for emissions to the aquatic environment are identical to those in Annex IV of the Directive.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Slovakia reports no change since the previous reporting period. No additional limit values for pollutants
discharged to water to those specified in Annex IV have been set. Slovakia notes that the cleaning of waste of waste gases does not give rise to waste water.
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
Operational control parameters of pH, temperature and flow for the discharge of wastewater are established in the permit, in accordance with Art. 8(6), as reported in the previous reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
There has been no change since the previous reporting period. Requirements are provided pertaining to the handling of harmful substances, internal inspections and leak tests, emergency action plans in the event of a spill, and storage of run-off water.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
Slovakia provides further detail compared to the previous reporting period on the applicable criteria. In
particular, Slovakia does note that in addition to the requirement for the design documentation of the plant to include a procedure to determine sufficient storage capacity for water, a storm sewer is in place so that in the event of contamination, automated pumping is shut down and the water is then treated.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
There has been no change since the previous reporting period. Plant documentation must include a procedure
for determining adequate storage capacity for testing or treatment of contaminated water. No further information is provided on specific criteria.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period. Slovakia responds that the requirements of the permit for the measurement of pollutants to air and process operation parameters are different to those set out in Article 11(2) for exemptions for HF under Article 11(4), HCl, HF and SO2 under Article 11(6), and heavy metals and dioxins and furans under Article 11(7).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
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There has been no change since the previous reporting period. Details are provided for implementation with the exception of Article 11(12) for which only details concerning its transposition to national law are provided.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period – provisions are reported for both articles.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
Guidance on the incineration of waste is provided by Decree 411/2012 on monitoring of emissions from stationary air pollution sources and air quality jointly for WID and other LCP and IPPC (IED) plants. This include guidance on the acquisition of daily average emission values (as laid down in points 1, 2, 4 to 7, and 15 of Annex 4 of the guidance document). The guidance is available here, http://www.zbierka.sk/sk/ciastky/ciastka-100-2012.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change since the previous reporting period. The operator shall notify the competent authority immediately of any breach. No further detail is provided.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change since the previous reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
National legislation lays down the requirement for operators incinerating or co-incinerating more than 2 t/hr to submit a report on the operation and monitoring of the plant to the competent authorising authority once a year; – reports are published on the website:
2012: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2012
2013: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2013
Annual reports include: Account of the running of the process; Emissions into air compared to standards set in the Directive; Capacity of the installation; information on the type of the installation (incineration or co-incinerations); types of waste that are incinerated; operation of the atmospheric pollution source for the previous calendar year; quantity of waste incinerated; a record of repairs made to the plant; and, a list of raw materials and fuels
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
These plants are publically identified via the internet here:
2013: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2013
2012: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2012
2011: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2011
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Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change since the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Slovakia.
SUMMARY OF CHANGES
Slovakia submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
23 plants fell within the scope of the Directive in Slovenia, of which 17 are incineration plants and 6 co-incineration plants. Permits were issued for all 23 plants, and all recover heat generated by the incineration process. The total permitted capacities of waste throughput (optional question) was not provided. Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC was provided for 1 plant (R1 – 0.73).
The category of waste that has been co-incinerated in cement kilns is typically RDF, with a permitted capacity up to 90,000 tonnes/year in the highest example given. In the case of combustion plants, the category of waste co-incinerated is sludge from biological treatment of waste water, with a permitted capacity up to 28,502 tonnes/year.
ELVs, operational parameters and monitoring requirements
Regarding the provisions within the permitting process for identifying hazardous waste that may be treated, in addition to the provisions previously reported, Slovakia notes that if no requirements are laid down in the permit, the operator is obliged to comply with the requirements under general legislation (previously not specified in the response given). Regarding the minimum and maximum flows, the provisions no longer require a certificate of the waste by an accredited facility.
1 exemption in accordance with Annex II.1 has been granted to an existing cement kilns for TOC emissions on the basis that none are emitted as a result of the incineration of the solid conditioned waste that the plant co-incinerates. The TOC limit value is 30 mg/Nm3 DAV (compared to 10 mg/Nm3 DAV as stipulated in the Directive).
Different air limit values are reported for co-incineration combustion plants for HF, TOC, CO and HCl as well as additional ELVs to those specified in Annex II.2 to the WID for H2S and NH3.
General legislative provisions and procedures
No problems concerning the definitions in Article 3 were reported.
Guidance on the incineration of waste is provided by Decree 411/2012 on monitoring of emissions from stationary air pollution sources and air quality jointly for WID and other LCP and IPPC (IED) plants. This include guidance on the acquisition of daily average emission values (as laid down in points 1, 2, 4 to 7, and 15 of Annex 4 of the guidance document). The guidance is available here, http://www.zbierka.sk/sk/ciastky/ciastka-100-2012.
National legislation lays down the requirement for operators incinerating or co-incinerating more than 2 t/hr to submit a report on the operation and monitoring of the plant to the competent authorising authority once a year; – reports are published on the website and are available for the reporting period here:
2012: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2012
2013: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2013
Incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour are publically identified via the internet and the annual lists for the reporting period are available here:
2013: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2013
2012: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2012
2011: http://enviroportal.sk/ovzdusie/spalovne-a-spoluspalovanie-r-2011
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A.24 Slovenia
A.24.1 Analysis of the completeness of the report
Table 47: Completeness assessment of answers reported by Slovenia – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2 Details are not provided for all of the
permitted plants.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for
representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10
(a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and
groundwater protection (Article 8(7)) 14
Ensuring adequate storage capacity
for water testing and treatment prior to discharge (Article 8(7))
15
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Question Completeness Comment
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements
and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements
and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily
average emission data (Article11(11)) 21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Slovenia has provided an almost complete response to the questionnaire. A few issues were identified with respect to questions 1.1 and 1.2.
A.24.2 Analysis of Slovenia’s responses
The table below contains detailed analysis of the responses provided by Slovenia to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Slovenia under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
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Table 48: Slovenia – Response analysis table
Slovenia
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 6 plants fell within the scope of the Directive, of which 3 are incineration plants and 3 are co-incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
All of the plants listed recover heat generated by the incineration process.
The total permitted capacities of waste throughput (optional question) is 61,337 tonnes/year for incineration plants and 114,010 tonnes/year for co-incineration plants.
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula
provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Slovenia listed the details for 5 plants.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
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Slovenia
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
The same problems concerning the definitions in Article 3 as reported previously were raised again by the Member State. Slovenia notes that it is unclear when and how confirmation by the operator of the incineration capacities should take place to calculate “nominal capacity”. The Member State also finds that it would be better to determine the lower and upper calorific value depending on the amount of individual waste material (e.g. waste oils, waste plastic, etc.), rather than as the quantity of waste incinerated hourly.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The types of waste that have been co-incinerated were reported for 1 co-incinerating plants in cement kilns and 1 in combustion plants. The information available is presented below:
Type of plant Category of waste
Co-incinerated? Remarks
Cement kilns Waste oils Yes Waste oils with no more than 15% water, more than 10 mgPCB per kg of oil, if it contains no hazardous substances, a flash point of 63 STC, calorific value greater than 30 MJ / kg (130205)
Solvents
Filter cakes
Plastics Yes 070213
RDF Yes 191210
Fluff from shredding
Sludge Yes 160103, 150203, 150101, 150102, 020203 (meat and bone meal), 191212, 200101, 150202, 120112, and some types of non-hazardous waste not specified here.
Other Yes Sludge from treating urban waste water (190805)
Combustion plants
Wood waste
Sludge
Other Yes Other organic solvents (070504) – this refers to co-incineration of their own waste, and waste with a lower calorific value of 19 MJ / kg, zg, or a calorific value of 30 MJ / kg, 100 mg / kg of Cl, up to 500 mg / kg of S
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
The emission limits set out in Annex V have been applied to 1 plant where more than 40% of the heat release results from the combustion of the combustion of hazardous waste, as per the previous reporting period.
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Slovenia
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change since the previous reporting period. The provisions are set under Article 4 of the Decree on waste incineration (UL RS 68/08 and 41/09); this does not specify the maximum and minimum flows of waste to be treated, as required by Article 4.5 of the WID (rather it indicates that the permit shall determine the annual quantities of processed waste and the nominal waste incineration capacity).
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Infectious waste from healthcare activities are considered inappropriate for sampling in Slovenia due to their health risks (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4), as per the previous reporting period.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx,
dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
1 exemption in accordance with Annex II.1 has been granted to cement kilns (note that in the previous reporting period an additional exemption was granted to a new cement kiln):
Pollutant Details
TOC Granted to 1 existing plant due to the fact that TOC emissions do not result from the incineration of waste. The type of waste co-incinerated is typically non-chlorinated waste oils, waste tyres, RDF, plastic, textiles and sludge. The plant has a clinker production capacity of 112.5 tonne/hour, and 108,960 tonnes of waste per year.
TOC limit value is 50 mg/Nm3 for the existing plant.
Annex II of the Directive, specifies that exemptions from the ELVs set out for TOC [10 mg/Nm³] may be authorised in cases where emissions do not result from the incineration of waste. In line with this requirement Slovenia indicates that this is the case for TOC emissions, which are a consequence of the organic substance content of the input raw materials rather than from the incineration of waste.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
As reported previously, different air limit values to those set in Annex II and Annex V have been set for HF, NOx, dust, CO, HCl, SO2, and Hg.
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Slovenia
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Slovenia reports no change since the previous reporting period. Limit values for emissions to the aquatic environment are identical to those in Annex IV of the Directive.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison
to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
As reported previously, in addition to the ELVs specified in Annex IV for pollutants discharged to water,
additional parameters were laid down on the issuing of the environmental permit with respect to an existing incineration plant on the basis of the results of multi-year measurements of operational monitoring for ammoniac nitrogen (NH3-N), fluoride (F), free cyanide, organically bound halogens (AOX), PAHs, phenols and sulphate (SO42−).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
All permits require continuous monitoring of temperature, flow rate and pH of waste water discharges from flue gas cleaning.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in accordance with Article 8(7)?
The national legislation to which these provisions has been transposed has changed since the previous reporting period and is now regulated by the Decree on Waste Incineration (Article 13, UL RS 68/08 and 41/09) and the Decree on Waste (Article 10, UL RS 103/2011). No detail of the provisions has been provided by the Member State in its response.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change to the national legislation since the previous reporting period. Criteria to determine the adequate storage capacity of such reservoirs has not been provided by the Member State in its response.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of
residues resulting from incineration or co-incineration plants?
An operator is required to generate the lowest possible level of harmful residues from incineration or co-
incineration, as stipulated in Article 21 of the Decree on Waste Incineration (UL RS 68/08 and 41/09). The article specifies that incineration residues must be processed at the site of the co-incineration or incineration plant, or outside that site in accordance with the regulations governing the landfill of waste, if this is possible through the use of BAT. Moreover, under Article 27 of this decree, where more than 150 tonnes of waste or more than 200 kg of hazardous waste is produced in a calendar year, the operator must draw up a waste management plan. At a minimum, waste management plans must contain: information on the quantities, sources and site of generation of waste by classification number and the anticipated waste generation trends; a description of existing and planned technical, organisational and other measures for preventing and minimising waste generation and the harmful impacts of waste on the environment and human health; a table indicating the deadlines for implementation of the planned measures; a description of existing and planned methods of managing waste, with details concerning the temporary storage of waste, the separate collection of waste, the delivery or surrender of waste, the processing of waste carried out or intended to be carried out by the producer itself, and the producer’s own existing or planned waste processing plants. The waste management plan must be drawn up for a four-year period and must be reviewed and, where appropriate, amended by the waste producer on an annual basis. It must be submitted to the ministry or the competent inspector upon request.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
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Slovenia
Slovenia reported no changes since the previous reporting period. Permit conditions relating to measurement of pollutants to air may be different to those set out in Article 11(2) for HCl, HF and SO2 exemptions (Article 11(6)), although no information on the application of these exemptions is provided by the Member State.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period. Permit conditions relating to measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change since the previous reporting period to the national legislation transposing the Directive requirements; no details are provided on how this is implemented in practice.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change since the previous reporting period – provisions are reported for both articles, although no detail is provided concerning Article 11(16).
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change since the previous reporting period – guidance has been developed in the national legislation and no web link is provided.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change since the previous reporting period. The operator shall notify the inspectorate where measurements taken show an excessive environmental impact, and waste feeding must be stopped or limited until the prescribed operating conditions to manage the environmental impact have been carried out.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
Permit applications for new and existing plants are publically available at the national authority office and the
public has 10 to 30 days to comments on the permit application. Additional information was submitted by the Member State concerning the arrangements to ensure public participation in the permitting process for IPPC which are not included here.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any
information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change since the previous reporting period, information on the permit application is publically
available at no charge.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and
monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change since the previous reporting period.
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Slovenia
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
These plants are publically identified via the Slovenian Environment Agency and the list is available through
the internet here, http://www.arso.gov.si/varstvo%20okolja/odpadki/podatki/OVD%20Se%c5%beig%20sose%c5%beig%2026082014.pdf (as reported in the previous reporting period).
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change since the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods
exceeding emission limit values over 1 year?
There has been no change compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Slovenia.
SUMMARY OF CHANGES
Slovenia submitted a complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU.
In many cases there has been no change since the previous reporting period. Changes are summarised below.
Installations
6 plants fell within the scope of the Directive in Slovenia, of which 3 are incineration plants and 3 co-incineration plants. Permits were issued for all 6 plants, and all recover heat generated by the incineration process. The total permitted capacities of waste throughput (optional question) is 61,337 tonnes/year for incineration plants and 114,010 tonnes/year for co-incineration plants. Energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were not provided.
ELVs, operational parameters and monitoring requirements
One exemption from the emission limits for TOC has been granted to an existing cement kiln plant on the basis that TOC emissions do not result from the incineration of waste at the plant. The TOC limit value is 50 mg/Nm3
(compared to the ELV in the Directive [10 mg/Nm³]). The type of waste co-incinerated is typically non-chlorinated waste oils, waste tyres, RDF, plastic, textiles and sludge.
General legislative provisions and procedures
The same problems concerning the definitions in Article 3 as reported previously were raised again by the Member State. It notes that it is unclear when and how confirmation by the operator of the incineration capacities should take place to calculate “nominal capacity”. It also finds that it would be better to determine the lower and upper calorific value depending on the amount of individual waste material (e.g. waste oils, waste plastic, etc.), rather than as the quantity of waste incinerated hourly.
The national legislation to ensure the protection of soil, surface waters or groundwater in accordance with Article 8(7) has been transposed has changed since the previous reporting period and is now regulated by the Decree on Waste Incineration (Article 13, UL RS 68/08 and 41/09) and the Decree on Waste (Article 10, UL RS 103/2011). No detail of the provisions has been provided by the Member State in its response.
A.25 Spain
A.25.1 Analysis of the completeness of the report
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Table 49: Completeness assessment of answers reported by Spain – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c The data on number of installations
recovering heat cannot be
disaggregated by type of installations
1.1.d
1.2
Whilst in question 1 Spain reports a total of 78 plants (27 incinerators and 51 co-incinerators), in question 1.2 the response lists 77 plants. In addition, no details on the latitude and longitude of the plants have been provided in question 1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated 4
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to
hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10
(a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12
(a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
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Question Completeness Comment
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and harmfulness of residues (Article 9)
16
Measurement of pollutants to air and water (Article 11)
17 (a- b)
18
(a-b)
Handling the results of measurements
and determining compliance for emissions to air (Article 11)
19
Handling the results of measurements
and determining compliance for emissions to water (Article 11)
20
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Spain provided an almost complete response to the questionnaire. Only the response
to questions 1.1(c) and 1.2 are partially incomplete. In addition, to questions 13 and
23 Spain responds with information for some of the individual facilities or for individual
regions, without presenting consolidated answers for whole of Spain. It is understood
that this is the way the information for the purposes of the questionnaire was collected
by Spain and that this represents all information available. It is therefore not considered a gap.
However it is noted that the translated Excel file seems to be corrupted. The
completeness assessment and question analysis has been made on the basis of the
review of the original submission by a native language speaker.
A.25.2 Analysis of Spain’s responses
The table below contains detailed analysis of the responses provided by Spain to the
WID questionnaire covering the period 2012-2013. The information presented is based
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solely on the information reported by Spain under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the
answers given.
Table 50: Spain – Response analysis table
Spain
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 78 plants fell within the scope of the Directive, of which 27 are incineration plants and 51 are co-incineration plants.
In total 78 permits were issued – 27 for incineration and 51 for co-incineration plants.
39 plants (50% of the total) recover the heat from the incineration process.
The total annual waste throughput was not provided (this question was optional).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
• Spain listed 77 plants and details were provided for all of them. Of these, 52 were co-incineration
plants and 25 incineration plants. There seems to be an inconsistency with the information reported under question 1.1 as both total number of co-incineration plants do not match (i.e. 52 compared to 51). Spain notes that there is new cement plant in Madrid authorized in April 2013 under Directive 2010/75 / EU, and not under Directive 2000/76 / EU.
For the 52 co-incineration plants, the report specified the type of the plant as shown in the pie chart below.
Where applicable Spain reports for municipal solid waste incineration plants that carry out recovery
operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant. This was provided for 9 plants. The efficiency figures were equal to or above 60% and therefore in line with the requirements of the Waste Framework Directive, except for 2 plants for which the values were less than 60%.
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Spain
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
Spain refers to the response provided in the last reporting period, where it stated problems with the following definitions: mixed municipal waste, hazardous waste and incineration and co-incineration facilities.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were co-incinerated in the co-incineration plants. Wastes are identified using EWC codes, in some cases total capacities of waste incinerated are also reported. However, it has not been possible to summarise this information here due to the length and format used. Moreover, under “other” it lists a number of wastes (by specifying their EWC code) of which only a selection are presented here.
Type of plant Category of waste
Co-incinerated? Remarks
Cement kilns
Waste Oils Yes
Solvents Yes
Filtercakes
Wood waste Yes
Plastics Yes
Textiles Yes
RDF Yes Combustible waste (refuse derived fuel)
Fluff from shredding
Yes
Sludge Yes Sewage sludge, plant biomass
Other Yes Such as end-of-life tyres
Combustion plant
Wood waste
Sludge
Other Yes Such as animal-tissue waste, polystyrene,
Other industrial facilities Other Yes Such as waste oils, wastes from forestry, etc.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
2 co-incineration plants are subject to ELVs specified in Annex V of the Directive. Spain reports that this is because more than 40% of the heat released at these plants results from combustion of hazardous wastes.
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Spain
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
Spain refers to the response provided in the last reporting period to describe the permitting process.
This period it adds that in some Autonomous Communities, in addition to the provisions set out in national legislation (Royal Decree 653/2003) the general guidelines established in the National Integrated Waste Plan 2008-2015 are also considered. In the case of Castilla La Mancha, it required an average calorific value greater than 3500 Kcal / Kg and restrictions on some pollutants: total halogens: 1%; mercury: 10 ppm; Thallium+ Cadmium: 15 ppm; Lead + Zinc: 3%; Other heavy metals: 0.5% (Sb + As + Cu + Ni + Co + Mn + Sn + V + Cr); PCB + PCT's: 30 ppm.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Some wastes are considered inappropriate for sampling in Spain (as reported in the previous reporting period). These included explosive and radioactive waste, tyres, meat and bone meal and waste received in sealed containers.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
No authorisations have been granted allowing an exemption from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). Note that during the last period one authorisation was reported.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
In total 12 plants have been granted exemptions according to Annex II.1 regarding the ELVS of SO2 and TOC.
Pollutant Details
SO2 Granted to 7 plants.
SO2 limit values were set in the range 30-1200mg/Nm3.
The lower ELV in the range is more strict compared to Annex II.1. On the other hand the higher ELV in the range is significantly higher than stated in Annex II. This has been granted due to the high content of sulphur in the raw materials used by the plant in the cement manufacturing process).
TOC Granted to 8 plants.
TOC limit values were set in the range 12-120 mg/Nm³.
The exemptions have been granted due to the high content of organic matter in the raw materials and, in the case of one plant, because the facility reuses foam from sugar mill carbonation as a secondary raw material to replace quarry-derived calcium carbonate, preventing its build-up in the waste disposal plant.
Annex II.1 of the Directive, specifies that exemptions from the ELVs set out for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³], expressed as daily average values, may be authorised in cases where TOC and SO2 emissions do not result from the incineration of waste. This appears to be the reason provided by Spain.
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Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air limit values to those given in Annex II or Annex V have been set by Spain for some plants. In the second part of this question Spain reports four examples, concerning 4 plants:
For one cement plant and one incinerator Spain reports a higher ELV for TOC emissions (60 mg/m3) than what it is established in the Directive. This has been already stated in question 9 above and is not replicated here.
For one combustion plant co-incinerating waste, Spain only reports that the ELVs for some parameters (TOC, HCL, SO2, NOx and CO3) have been updated as a consequence of the technical characteristics of the installation and in accordance with national legislation regulating IPPC activities. However no detail on the ELVs implemented are provided.
For the remaining cement kiln, stricter ELVs have been set to those established in Annex II as reported in table below:
Parameter WID Value (mg/m3) (averaging period)
Number of plants and ELV (mg/m3) (averaging period- see note for abbreviations)
Reasoning / comments
Co-incineration plants- Different ELVs to those specified in Annex II to the WID
SO2 50 DAV (II.1 –cement)
One cement plant: ELV = 20 (averaging period not specified); measured continuously.
Best available technologies and techniques, location and business environment, characteristics of the production process. Dioxins and
furans 0.1 ng/m3 (DAV) (II.1.2.3)
One cement plant: ELV = 0.03 mg/m3 (averaging period not specified); measured discontinuously.
Sb + As + Pb + Cr + Co + Cu + Mn + Ni + V
0.5 (II.1.2)
One cement plant: ELV = 0.3 mg/m3 (averaging period not specified); measured discontinuously.
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply. Spain reports under question 5 two co-incineration plants to which the provisions of Annex V applied.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex
IV.
Spain indicates that these are identical to the ones in Annex IV and refers to the answer provided in the last reporting period. It is noted that the in the last report a few installations were identified to have different ELVs (in some cases even less strict) than the Directive. It is unclear whether these continue to be applicable.
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
Spain reports that no additional pollutants to those listed in Annex IV of the WID have been assigned ELVs.
However in their response they also refer to the answer provided in the last reporting period, where it was stated that national and autonomous regulations regarding water and dumping sites must be considered where
applicable. Spain reported information for two incineration facilities, where limit values to additional were applied: BOD5, COD, pH, and settleable solids. It is unclear whether these continue to be applicable.
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Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
Spain indicates that the operational control parameters of pH, temperature and flow for the discharge of wastewater are established in the permit.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
Spain reports that, for the majority of permits, the measurement requirements are the same as set out in Article 11(2). For some plants, the following requirements different to those in Article 11(2) are set out in the permits:
Deviation Comments (Pollutant or parameter concerned and measurement requirement)
More stringent requirements than those of Article 11(2) are applied
Yes In an installation in Murcia due to technical limitations the temperature of the oxidizer equipment does not allow the continuous measurement of particles and substances or preparations containing fluoride in any form are not handled, transported or produced.
It is unclear in which sense the measurement requirements are stricter.
Exemptions for HF under Art. 11(4)
Yes Applied to plants in Cantabria, Galicia, Baleares, Catalonia and Murcia. In these cases the HF is measured periodically, generally on a quarterly basis.
Exemptions for water vapour under Art 11(5)
Exemptions for HCl under Art 11 (6)
Yes In Catalonia the replacement of continuous measurement for quarterly measurements is allowed for HCl, HF and SO2 pollutants when the company has demonstrated the impossibility of exceeding the emission limit values. Exemptions for HF under
Art. 11(6) Yes
Exemptions for SO2 under Art. 11(6)
Yes
Exemptions for heavy metals under Art. 11(7)
Yes In Murcia heavy metals and dioxins and furans to be measured manually on a quarterly basis. However this appears to be stricter than what it is specified in the Directive.
Exemptions for dioxins and furans under Art. 11(7)
Yes
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Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
As per the previous reporting period, Spain indicates that the requirements for measurement of pollutant emissions to water are identical to those set out in Article 11(14) and 11(15) of the Directive.
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
Spain refers to the response provided in the last reporting period and only adds that one the plant also falls under the IPPC Directive the provisions of Article 11 are included in the integrated environmental authorization.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been almost no change in the response to this question compared to the last reporting period. As it was indicated in the previous period, Spain has provided details on the additional guidance produced by some Autonomous Communities. Apart from the ones mentioned previously, the response includes the case of Asturias, for which it describes some of the actual content of the guidelines which is not summarised here due to the length of the information provided and the fact that it has not been translated.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
Spain refers to the response provided in the last reporting period and only provides further details on the procedures in place in the Autonomous Community of Asturias (which are not summarised here).
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The general case is that the new permit applications as well as the final decisions are available to the public from regional authorities. The public is invited to comment on the application for a permit for a period between 31-50 days.
Nevertheless, the specific arrangements will depend on the specific Autonomous Community. These were detailed in the response to the previous reporting period and are still valid, with the only exception of Castilla y León which has extended the period during which the public can comment on the application from 20 days to 30 days plus 10 days of public information hearing to interested parties before drafting the proposed resolution concerned.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to question 24 (a) compared to the last reporting period.
Regarding 24(b) it is noted that generally such information is accessible free of charge. However, 5 autonomous communities (compared to 2 in the last reporting period) introduced fees for obtaining copies of the documentation:
Galicia – there is a minimum fee of €2.96.
Madrid – information provided on a CD is free of charge. Hard copies of the documents are charged at
€0.09 per page (size DIN A4 and B/N). A digital copy (pdf) is charged at €0.05 per page.
Asturias: for copying the requested information rules of Asturias on rates applied.
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Cantabria - only when copies of documents are requested a fee is charged.
Murcia - the consultation of information is available for free, only when copies a charge is applied (39.05
and 78.13 euros) in accordance with the Order of 29 January 2014.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response to these questions compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour,
how are these plants publicly identified?
There has been no change in the response to these questions compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
The permit establishes:
• a maximum permissible period of abnormal operation with ELVs exceeded between 3- 4 hours.
• a maximum cumulative duration of periods exceeding ELVs over one year between 40 - 60 hours.
However, in Castilla-La Mancha, the permits for co-incineration plants specify additional periods of operations in abnormal conditions:
• ELVs for solid particles may be exceeded by 50% for a maximum of 4 hours, providing that dust emission limits are not exceeded, in situations resulting from malfunctioning of purification measures.
• The ELVs for SOx may be exceeded for a period of up to 2 hours during the start-up of clinckerisation furnaces which emit up to 100mg/Nm3.
• The total cumulative time of such exceedances is 20 hours per year.
Question 30. Any other remarks.
No general remarks are provided by Spain.
SUMMARY OF CHANGES
Spain submitted an almost complete answer to the WID questionnaire as per the Commission Decision
2011/632/EU. Changes since the previous reporting period are summarised below.
Installations
78 installations (27 incinerators and 51 co-incinerators) fall within the scope of the Directive, of which 39 recover the heat generated in the incineration process. All plants have been permitted, and so far no permits
have been granted to mobile plants. A range of wastes were reported to be co-incinerated in co-incineration plants.
ELVs, operational parameters and monitoring requirements
The following changes have been reported by Spain:
• 2 co-incineration plants are subject to ELVs specified in Annex V of the Directive.
• Unlike the previous reporting period, no authorisations have been granted allowing an exemption from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4).
• 12 plants have been granted exemptions according to Annex II.1 regarding the ELVS of SO2 and TOC.
• Different air limit values to those given in Annex II or Annex V have been set in Spain for 4 plants.
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• Different ELVs for discharges of wastewater from flue gas cleaning equipment compared to Annex IV, as well air ELVs for new pollutants have not been set.
• Exemptions from continuous measurements of air emissions in accordance with Article 11 of the WID are reported for some Autonomous Communities.
General legislative provisions and procedures
In most cases, Spain refers to the response provided in the last reporting period to describe the general legislative provisions and procedures applied at national level. However in some instances Spain adds further detail on the specific arrangements applied in certain Autonomous Communities where there has been a change or additional information has been made available by the regions (e.g. in question 6 on the permitting process, question 23).
General changes applicable to the whole territory include:
• Spain continues to report the same problems with the definitions in Article 3 as per the previous period.
• Spain indicates that the operational control parameters of pH, temperature and flow for the discharge of wastewater are established in the permit.
• The general case is that the new permit applications as well as the final decisions are available to the public from regional authorities. The public is invited to comment on the application for a permit for a period between 31-50 days.
A.26 Sweden
A.26.1 Analysis of the completeness of the report
Table 51: Completeness assessment of answers reported by Sweden – WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a
1.1.b
1.1.c
1.1.d
1.2
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-incinerated
4
The Member State has provided
a response to this question in a separate document and has not made use of the reporting tool. Due to the presentation of the data, it is not clear which categories of waste have been co-incinerated in Sweden.
Co-incineration plants subject to the
emission limits applicable to incineration plants (Article 7(2) and (4))
5
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Question Completeness Comment
Permitting process in relation to hazardous waste (Article 4(5)) 6
(a–d)
Provisions have not been specified for certain aspects of the permitting process in relation to hazardous waste.
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex
II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Different emission limit values apply but the reporting format in which the Member State has presented them is unclear. Further, it is unclear if the emission limit values specified
are in addition to or instead of those previously reported.
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage capacity for water testing and treatment prior to discharge (Article 8(7))
15 No criteria have been specified.
Minimising quantities and harmfulness of residues (Article 9)
16 No provisions have been
specified.
Measurement of pollutants to air and
water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
In certain sections, Sweden refers to specific sections of the national legislation where Article 11 has been transposed, without
providing any further commentary.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
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Question Completeness Comment
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
Sweden has submitted a partially complete response to the questionnaire as per the
Commission Decision 2011/632/EU. Sweden has provided an Excel file to accompany
the questionnaire with data on installations covered by the Directive for questions 1, 4,
5 and 10. This file completes the one provided for the last reporting period 2009-2012,
which remains unchanged and still valid for the present period 2012-2013. This
accompanying document does not make use of the standard reporting tool concerning
the changes which has led to some difficulties interpreting the information provided for
questions 1.2, 4 and 10 (as presented in the table above). Several additional issues were identified in relation to questions 6, 15, 16 and 19. .
A.26.2 Analysis of the response by Sweden
The table below contains detailed analysis of the responses provided by Sweden to the
WID questionnaire covering the period 2012-2013. The information presented is based
solely on the information reported by Sweden under each question. The table contains
summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 52: Sweden – Response analysis table
Sweden
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down
between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
In total 138 plants fell within the scope of the Directive, of which two are incineration plants and 136
are co-incineration plants.
82 permits were issued in accordance with Article 4(1) Sweden reports that all plants are permitted but that there are sites covered by several permits, with individual permits regulating only a part of a site or one aspect of the operation at the site (for example noise emissions from all co-incineration plants at that site).
All plants listed recover heat generated by the incineration process.
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The total permitted capacities of waste throughput is 11,200,000 tonnes/year (optional question).
Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants
with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
Sweden listed 138 plants and details were provided for all of them. Of these, 136 were co-incineration
and two were incineration plants.
Of the reported co-incineration plants, 120 were combustion plants, 12 were in other industrial facilities, and four were cement kilns.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out
recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for the plants listed. The figures relate to 2 incineration plants at the Sakab (Örebro) site. It is indicated by the Member State that the R1 formula is not meant to be used in this case due to the incineration of hazardous waste Sweden has calculated that the values for the two individual plants are 79% (rotary kiln) and 109% (grate firing) respectively.
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
There has been no change since the previous reporting period. In Sweden clarification continues to be needed with regards to the terms “waste” and the classification of co-incineration plants.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
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Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
Sweden has reported that the same categories of waste were co-incinerated in the co-incinerators listed in the previous reporting period. Further, the Member State has provided information concerning the additional four plants that fall within the scope of the Directive this reporting period. However, as the response to this question was provided in a separate document, not using the reporting tool, it is not clear which additional categories of waste have been co-incinerated in Sweden and therefore these changes are not summarised here.
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set
out in Annex V to the Directive?
The provisions of Annex V applied to 63 plants where co-incineration of untreated municipal waste is undertaken and to 31 co-incineration plants where more than 40% of the resulting heat released comes from the combustion of hazardous waste, as per the previous reporting period.
Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided the provisions for certain aspects of the permitting process.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Many different wastes have been identified as inappropriate, as per the previous reporting period.
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in
Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be met by the plant.
A total of six plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). There has been no change to what was reported previously.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Two existing plants have been granted exemptions from emission limits in accordance with Annex II.1 with regards to the emission limits for TOC (no limit applies). There has been no change to what was reported previously.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the
emission monitoring regime for these pollutants.
Different air emission limit values to those given in Annex II or Annex V have been set. In addition to those reported previously, Sweden has reported a further two emission limit values which differ from those in Annex II and V. These are not summarised here due to difficulties arising from the fact that the Member State has
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not used the standard reporting tool to submit these emission limit values, and the information submitted was not translated.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are different to those set out in Annex IV of the Directive in the case of 11 pollutants (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
An additional ten pollutants to those listed in Annex IV of the WID have been assigned ELVs across 58 plants (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not specified the criteria used.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period. Note that no provisions have been specified by the Member State.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period. Permit conditions relating to the measurement of pollutants to air are different to those set out in Article 11(2).
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those
set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
There has been no change since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are different to those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following
provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that the provisions for Article 11(8), (10) and (11) have not been specified by the Member State.
Question 20. What provisions are made within the permitting process for water emissions to ensure compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
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There has been no change since the previous reporting period.
Question 21. Please describe any official guidance that has been developed on producing validated daily
average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
There has been no change in the response to this question compared to the last reporting period.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question compared to the last reporting period.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per
hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
The provisions for operators to submit an annual report on the functioning and monitoring of a plant to the competent authority are the same as provided in the previous reporting period, however the website that the report must be uploaded to has changed to: https://smp.lansstyrelsen.se/Default.aspx?Cause=9. With regard to the information in the annual report and public access, there have been no changes in the response since the previous reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
There has been no change in the response to this question compared to the last reporting period.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or
co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
There has been no change in the response to this question compared to the last reporting period.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of
operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by Sweden.
SUMMARY OF CHANGES
Sweden submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes are summarised below.
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Installations
A total of 138 plants (two incinerators and 136 co-incinerators) fall within the scope of the Directive, 18 of which recover the heat generated in the incineration process. The total permitted capacities of waste throughput is 11,200,000 tonnes/year. Of the total plants, 82 were permitted and, so far, no permits have been granted to mobile plants, as per the previous reporting period. Details have been provided for two incinerators and 136 co-incinerators (120 combustion plants, 12 other industrial facilities, and four cement kilns), as well as the energy efficiency figures where applicable.
ELVs, operational parameters and monitoring requirements
Different air emission limit values to those given in Annex II or Annex V have been set. In addition to those reported previously, Sweden has reported a further two emission limit values which differ from those in Annex II and V. These are not summarised here due to difficulties arising from the fact that the Member State has not used the standard reporting tool to submit these emission limit values, and the information submitted was not translated.
General legislative provisions and procedures
The Member State has reported only one change to the legislative provisions and related procedures since the previous reporting period. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, operators are required to submit an annual report on the functioning and monitoring of a plant to the competent authority and the website that the report must be uploaded to has changed to: https://smp.lansstyrelsen.se/Default.aspx?Cause=9.
A.27 United Kingdom
A.27.1 Analysis of the completeness of the report
Table 53: Completeness assessment of answers reported by the United Kingdom –
WID Directive
Question Completeness Comment
Numbers of plants and permits
1.1.a The numbers of plants that fall within the scope of the Directive and that are permitted are significantly smaller than previously reported, and do not correlate to the remarks made in the current reporting period. It is likely that the Member State has made a typo in reporting.
1.1.b
1.1.c
The number of plants that recover heat from the incineration process has not been provided for England and Northern Ireland.
1.1.d
1.2
The number of plants listed does not correlate to the expected number of plants that fall within the scope of the Directive.
Definitions (Article 3) 2
Mobile plants 3
Categories of waste co-
incinerated 4
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Question Completeness Comment
Co-incineration plants subject to the emission limits applicable to incineration plants (Article 7(2) and (4))
5
Permitting process in relation to hazardous waste (Article 4(5))
6
(a–d)
“Inappropriate” waste for representative sampling (Article 5(4)(b))
7
Authorisations containing
conditions in accordance with Article 6(4)
8
8.1
8.2
Emission limit exemptions for cement kilns co-incinerating waste (Annex II.1)
9.a
9.b
Setting of different emission limit values to those specified in Annex II or Annex V
10 (a-e)
Determining emission limits values for waste water discharges from flue gas cleaning equipment (Article 8)
11
Emission limits values for additional pollutants discharged to water beyond those in Annex IV
12 (a-c)
Operational control parameters for water discharges (Article 8(6)(b))
13
Provisions for soil, surface water and groundwater protection (Article 8(7))
14
Ensuring adequate storage
capacity for water testing and treatment prior to discharge (Article 8(7))
15
Minimising quantities and
harmfulness of residues (Article 9)
16
Measurement of pollutants to
air and water (Article 11)
17 (a- b)
18 (a-b)
Handling the results of measurements and determining compliance for emissions to air (Article 11)
19
No details are provided beyond that the provisions are specified in the permit.
Handling the results of measurements and determining compliance for emissions to water (Article 11)
20
No details are provided beyond that the provisions are specified in the permit.
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Question Completeness Comment
Guidance on producing validated daily average emission data (Article11(11))
21
Informing the competent authority of breaches of emission limit values
22
Access to information and public participation (Article 12)
23
24
25
26.1
26.2
27
Abnormal operation 28
29
Other remarks 30
The UK has provided a partially complete response to the questionnaire. Several issues
were identified in relation to questions 1, 19 and 20 (as presented in the table above).
A.27.2 Analysis of the response by the United Kingdom
The table below contains detailed analysis of the responses provided by the United
Kingdom to the WID questionnaire covering the period 2012-2013. The information
presented is based solely on the information reported by the United Kingdom under
each question. The table contains summary of the response, as well as further comments and descriptive analysis of the answers given.
Table 54: United Kingdom – Response analysis table
United Kingdom
Question 1.1. For plants that fall within the scope of the Directive please give information (broken down between incineration and co-incineration plants) on (a) the number of plants (b) the number of permits issued in accordance with Article 4(1), (c) the number of plants that recover heat generated by the incineration process and, optionally (d) the total permitted capacities of waste throughput (tonnes/year).
There is an inconsistency between the number of installations provided and the comments made in the response given by the UK. It is likely that there has been a typo; however as we have been unable to confirm this, it has not been possible to give an accurate summary of the plants that fall within the scope of the Directive for this reporting period. Rather, we refer to the response given for the previous reporting period, as follows:
A total of 159 plants fell within the scope of the Directive, of which 116 (73% of the total) were incineration plants.
Permits were issued for all plants that fall within the scope of the Directive.
In total, 143 plants (90% of the total) recovered the heat generated by the incineration process.
Information with regards to total permitted capacities of waste throughput is only available for Scotland and Northern Ireland (895,000 tonnes per year) (this was an optional question).
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Question 1.2. Please provide a list of all plants falling within the scope of the Directive. Additionally, for plants with a capacity of more than 2 tonnes per hour indicate (a) whether the plant is an incineration or co-incineration plant and, for co-incinerators, the type of plant (cement kiln, combustion plant, other industrial facilities), and (b) for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC on waste, the energy efficiency of the plant calculated using the formula provided in the footnote to Annex II, R1 to Directive 2008/98/EC.
The UK listed 61 plants and details were provided for all of them. Of these, 12 were co-incineration and 48 incineration plants. Due to the inconsistency in reporting for question 1.1 it is unclear how many plants should have been listed, but it is likely that many plants are missing from this list. No explanation was provided by the Member State as to why.
Of the reported co-incineration plants, eight were combustion plants and four were cement kilns.
The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for four plants (ranging between 0.71 and 0.75).
Question 2. Please describe any problems with the definitions in Article 3 identified when implementing the Directive. Provide specific information for each definition for which problems are identified.
No problems with the definitions in Article 3 were identified by the Member State, as per the previous reporting period.
Question 3. Have any mobile plants received permits under the Directive?
No mobile plants received permits pursuant to the Directive, as per the previous reporting period.
Question 4. Please indicate the categories of waste that have been co-incinerated, broken down by the type of co-incineration plant. Optionally, please indicate the European Waste Catalogues code and the permitted capacity granted for co-incineration in these plants.
The following types of waste were reported as co-incinerated (EWC codes of each of the wastes co-incinerated are provided in the response but are not summarised here):
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Type of plant
Category of waste Co-incinerated?
Remarks
Cement kilns Waste oils Yes
Solvents
Filtercakes
Wood waste
Plastics
Textiles
RDF
Fluff from shredding
Sludge Yes 160103
Other Yes End of life tyre (190208), recycled liquefied fuel (200301), mixed MSW (190805), Meat and Bone Meal (202003), and Solid Recovered Fuel (020107, 030101, 030105, 150101, 150102, 150105, 150109, 190210, 190208, 191208, 191210, 200101, 200110, 200111, 200138, 200139).
Combustion plants
Wood waste Yes 170201
Sludge Yes
Other Yes Poultry litter (020107), wood chips/sawdust from agricultural and forestry waste (020202), meat & bone meal, feathers and feather meal, combustible waste (191210), and other wood (020304, 020704, 030307, 030310, 030199, 170201, 010505, 020101, 020103, 020107, 020301, 020305, 020403, 020502, 020603, 020701, 020705, 030101, 030105, 030301, 030311, 040209, 040210, 040220, 040221, 040222, 050102, 050103, 050104, 050105, 050106, 050109, 050110, 050111, 050113, 050114, 050115, 070111, 070112, 070312, 070512, 070612, 100215, 120112, 120115, 120118, 120119, 120121, 130105, 130110, 130111, 130112, 130113, 130204, 130205, 130206, 130207, 130208, 130306, 130307, 130308, 130309, 130310, 130401, 130402, 130403, 130501, 130502, 130503, 130506, 130508, 130701, 150101, 150102, 150103, 150105, 150106, 150109, 160708, 170201, 170203, 170503, 170505, 170506, 170507, 170508, 190501, 190502, 190503, 190606, 190801, 190802, 190805, 190809, 190810, 190811, 190812, 190813, 190814, 190902, 190903, 190906, 191101, 191105, 191106, 191201, 191206, 191207, 191208, 191210, 191211, 191212, 191301, 191302, 191303, 191304, 191305, 191306, 200101, 200125, 200126, 200137, 200138, 200139).
Question 5. How many co-incineration plants are subject to the emission limits for incineration plants as set out in Annex V to the Directive?
There are no co-incineration plants to which the emission limits set out in Annex V have been applied.
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Question 6. What provisions are made within the permitting process for (a) identifying hazardous waste that may be treated, (b) the minimum and maximum flows of hazardous waste to be treated, (c) the range of calorific values of hazardous waste permitted, and (d) any restrictions on the content of pollutants.
The UK reported that the quantities and categories of hazardous wastes that may be treated, the range of calorific values and the restrictions on the content of pollutants must be detailed in the application and included in the permit. The EWC number (where available) or other specifications related to the wastes are included in the permit. Only wastes listed in the permit can be (co-)incinerated.
Although the Directive requires permits for plants that (co-)incinerate hazardous wastes to contain the minimum and maximum mass flow, the UK responded that minimum flows are not specified in the permit, rather that they have to be described in the permit application. However the maximum flow rates are specified in the permit.
In addition, the UK also reported that maximum thermal substitution rates are included in permits for co-incineration plants burning hazardous waste and not subject to Annex V of the WID.
Question 7. What wastes have been considered to be ‘inappropriate’ for representative sampling?
Hazardous clinical waste continue to be considered inappropriate for sampling in the UK (as reported in the previous reporting period).
Question 8. With regard to conditions for the furnace gas residence times and temperatures as provided for in Article 6(1) and (2), have any authorisations to differ from those operating conditions been granted in accordance with Article 6(4)?
If the answer is yes, indicate (a) how many authorisations have been granted and (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) identification of the capacity of the plant, (ii) whether it concerns an existing plant or a new plant, (iii) the type of waste incinerated, (iv) how it is ensured that no more residues are produced compared to a non-exempted plant and that the content of organic pollutants in those residues is no more than expected from a non-exempted plant, (v) the operating conditions laid down in the permit, and (vi) the emission limit values to be
met by the plant.
The UK has reported that three plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4). The exemptions apply to new plants, all of which are situated in Scotland and incinerate wood waste and tannery waste.
The capacity of the respective plants are as follows:
750,000 tonnes/ year
97,000 tonnes/ year
30,000 tonnes/ year
In two cases the permits include provisions to ensure that no more residues are produced, and in the other the Member State has reported that trials were conducted to ensure that no more residues would be produced before the permit was granted. The UK has reported that all of the permits granted set different temperature conditions to those specified in Art. 6(1) and 6(2) and that the rest of the operating conditions remain the same as indicated in the WID.
Question 9. For cement kilns co-incinerating waste, have any exemptions from the emission limits for NOx, dust, SO2 or TOC been granted in accordance with Annex II.1?
If the answer is yes, please indicate (a) how many exemptions have been granted (b) where data is available please describe the reasoning for granting the derogation(s) for a number of representative cases as well as (i) the capacity of the plant (ii) whether it concerns an existing or a new plant (iii) the type of waste co-incinerated (iv) the emission limit values to be met by the plant and (v) the other operating conditions laid down in the permit.
Exemptions from emission limits in accordance with Annex II.1 have been granted for three pollutants in four plants, as follows:
Pollutant Details
SO2 Granted to two existing plants, one with a capacity of 12 tonnes/ hour co-incinerating solvents and solvent mixtures and the other with a capacity of 23 tonnes/ hour co-incinerating meat and bone meal.
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SO2 limit value reported is 4,000 mg/Nm³ (DAV) and 200 mg/Nm³ (DAV), respectively.
TOC Granted to one existing plant with a capacity of 12 tonnes/ hour co-incinerating solvents and solvent mixtures (as reported above).
TOC limit value reported is 140 mg/Nm³ (DAV).
Annex II of the WID, specifies that exemptions from the ELVs for SO2 [50 mg/Nm³] and TOC [10 mg/Nm³] may be authorised in cases where TOC and SO2 do not result from the incineration of waste. The UK remarked that “in the case of both TOC and SO2 the presence of organic matter and pyritic sulphur in the raw materials for cement clinker manufacture result in emissions higher than the limits imposed by WID”.
In addition, the UK reports a NOx ELV set for one existing plant. The limit values quoted is 800 mg/Nm³ (daily average value). This is the same value required by Annex II.1, in which ELVs for NOx emissions in existing plants are 800 mg/Nm3. Therefore, it is not considered an exemption.
Question 10. For releases to air from incineration and co-incineration plants, have emission limit values
different to those given in Annex II or Annex V, as appropriate, been set?
If the answer is yes, and where data are available, please identify (a) the plants to which they apply, and for co-incineration plants the type of plant, (b) which of these plants are ’new’ or ‘existing’, (c) the pollutants to which the limit value apply and the limit values set, (d) why these limit values are applied, and (e) the emission monitoring regime for these pollutants.
Different air emission limit values to those given in Annex II or Annex V have been set, as summarised below:
Parameter WID Value (mg/m3) (averaging period)
Plants and ELV reported (mg/m3) (averaging period- see note)
Reasoning / comments
Incineration and co-incineration plants- ELVs set for pollutants not specified in Annex II or V to the WID
NOx 200 (DAV > 6t/h or new) 400 (DAV=< 6t/h)
For one new plant: ELV= 60 mg/Nm3 (DAV); Continuous monitoring
The ELV has been specified to ensure that the Air Quality Standards are met despite the fact that the plant has a final chimney with a height lower than recommended in guidance (due to local circumstances).
NH3
For one new plant: ELV= 10 mg/Nm3 (DAV); Discontinuous monitoring (quarterly for first year then twice per year)
As a control mechanism for pollutant abatement system (SNCR)
NH3
For one new plant: ELV= 10 mg/Nm3 (DAV); Discontinuous monitoring (quarterly for first year then twice per year)
As a control mechanism for pollutant abatement system (SNCR)
Note: I) Abbreviations: DAV- Daily average value/ HAV- Hourly average value/ HHAV- Half-hourly average value/ YAV- Yearly average value/ 30 min -8h – all average values over a sampling period of 30 minutes to 8 hours II) When comparing ELVs set for co-incineration plants against the values specified in Annex II to the WID it is important to note that there might be cases where Annex V would apply. Spain reports under question 5 two co-incineration plants to which the provisions of Annex V applied.
Question 11. For the pollutants listed in Annex IV to Directive 2000/76/EC, how are emission limit values for discharges of wastewater from flue gas cleaning equipment to the aquatic environment determined? Please indicate those cases where emission limit values for those polluting substances differ from the ones in Annex IV.
Emission limit values for emissions to the aquatic environment are determined in line with Annex IV of the Directive (as per the previous reporting period).
Question 12. If emission limit values have been set for additional pollutants discharged to water in comparison to the pollutants specified in Annex IV (a) to which plants do they apply, (b) to which pollutants do they apply and what are the limit values set, and (c) why are the limit values applied?
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No additional pollutants to those listed in Annex IV of the WID have been assigned ELVs (as per the previous reporting period).
Question 13. What operational control parameters (pH, temperature, flow rate, etc.) are set within the
permitting process for waste water discharges?
There has been no change in the response to this question compared to the last reporting period.
Question 14. What provisions have been made to ensure protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There has been no change in the response to this question compared to the last reporting period.
Question 15. What criteria are used to ensure that storage capacity is adequate for waters to be tested and treated before discharge where necessary?
The criteria to ensure that that storage capacity is adequate for waters to be tested and treated before discharge is determined on a case-by-case basis according to the capacity, treatment techniques, and volume of waste water being produced. The Member State has reported that the operator is expected to undertake a risk assessment when applying for a permit to determine the maximum volume that would be held in a worst case scenario.
Question 16. What provisions in general have been made to minimise the quantities and harmfulness of residues resulting from incineration or co-incineration plants?
There has been no change in the response to this question compared to the last reporting period.
Question 17. Are the requirements of the permit for the measurement of pollutants to air and process
operation parameters identical to those set out in Article 11(2)?
If not, please provide information detailing (a) the reason for deviating from Article 11(3), referring to the derogation possibilities mentioned in Articles 11(4) to (7) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
The UK reported no changes since the previous reporting period. Permit conditions relating to the measurement of HF, HCl, and SO2 pollutants to air are periodic.
Question 18. Are the requirements of the permit for the measurement of pollutants to water identical to those set out in Article 11(14) and (15)?
If not, please provide information detailing (a) the reason for deviating from Article 11(14) and (15) and (b) the pollutant or parameter concerned and the measurement requirement imposed.
The UK reported no changes since the previous reporting period. Permit conditions relating to the measurement of pollutants to water are the same as those set out in Article 11(14) and 11(15).
Question 19. What provisions are made within the permitting process to ensure compliance with the following provisions as regards air emissions? Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10). Article 11(8); Article 11(9); Article 11(11); Article 11(12); the compliance regime set out in Article 11(10).
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided any detail beyond that the provisions are specified in the permit.
Question 20. What provisions are made within the permitting process for water emissions to ensure
compliance with (a) Article 11(9) and (b) the compliance regime set out in Article 11(16)?
There has been no change in the response to this question compared to the last reporting period. Note that the Member State has not provided any detail beyond that the provisions are specified in the permit.
Question 21. Please describe any official guidance that has been developed on producing validated daily average emission data (Article 11(11)).
There has been no change in the response to this question compared to the last reporting period.
Question 22. What are the procedures for informing the competent authority in the event of a breach of an emission limit value?
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There has been no change in the response to this question compared to the last reporting period.
Question 23. What arrangements are made to ensure public participation in the permitting process (new
and/or updated permits)? Please provide details on (a) the authority that makes the permit publicly available, (b) the period during which the public is able to comment, and (c) the authority that makes the final decision available.
The permit application and final decision are publicly available at the level of the regional and local public administrations and can also be consulted on the internet.
The public is given a period of between 31 and 50 days to comment on the application for a permit.
Particularities of the process are described for Scotland only. In accordance with the online Public Participation Directive, the time period in Scotland is two 28 day consultation periods, one at the start of the process and one at draft decision stage. Permit applications are also distributed to local libraries.
Question 24. With regard to the availability of information throughout the permitting process (a) is there any information related to environmental aspects not publicly/partially available on the application, decision process and subsequent permit? and (b) where these data are available, specify whether this information is available free of charge and, if not, the level of charges made and in what circumstances these charges are applied.
There has been no change in the response to this question with regard to part (a) compared to the last reporting period. With regards to part (b), data is available free of charge on public registers for the whole of the UK. However, a charge now applies in Northern Ireland for hard copies (£0.10 per sheet), and charges continue to be applied in England and Scotland if excessive photocopying is required. The public may also now have free access to the information on a CD in England and Scotland.
Question 25. For incineration plants and co-incineration plants with a nominal capacity of 2 tonnes or more per hour, what provisions are made to require an operator to submit an annual report on the functioning and monitoring of a plant to the Competent Authority? and
Question 26. If an annual report is provided (a) what information does this contain and (b) how may the public get access to this report?
There has been no change in the response compared to the last reporting period.
Question 27. For incineration or co-incineration plant with a nominal capacity of less than 2 tonnes per hour, how are these plants publicly identified?
The list of plants with a nominal capacity of less than 2 tonnes per hour are available via the competent authority's website for Scotland (http://www.sepa.org.uk/waste/waste_regulation/energy_from_waste/efw_sites_in_scotland.aspx), and by request at the competent authority's local offices for England. No responses were provided for Northern Ireland and Wales.
Question 28. What provisions are made within a permit to control the period of operation of an incineration or co-incineration plant during abnormal operation (i.e. stoppages, disturbances or failure of abatement or monitoring equipment)?
The UK has reported that standard conditions regarding the control of abnormal operations are contained in permit conditions, which allow for a maximum of 4 hours of operation with exceedance of ELVs due to technically unavoidable abnormal operating conditions with a cumulative duration of such operation to be no more than 60 hours annually.
Question 29. For incineration and co-incineration processes what are the maximum permissible periods of operation during abnormal operation before the plant must shut down in terms of (a) maximum permissible period with exceedance of emission limit values and (b) the maximum cumulative duration of periods exceeding emission limit values over 1 year?
There has been no change in the response to this question compared to the last reporting period.
Question 30. Any other remarks.
No general remarks are provided by the UK.
SUMMARY OF CHANGES
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The UK submitted a partially complete answer to the WID questionnaire as per the Commission Decision 2011/632/EU. In most cases there has been no change since the previous reporting period. Changes and additional information provided are summarised below.
Installations
The number of installations that fall within the scope of the Directive has been taken from the 2009-2011 reporting period due to reporting inconsistencies for the current reporting period. A total of 159 installations (116 incinerators and 43 co-incinerators) fall within the scope of the Directive. All plants were permitted and no permits were granted to mobile plants. 90% of the plants recover the heat generated in the incineration process.
For the current reporting period, the UK has provided details for 61 plants (48 incinerators and 12 co-incinerators – the latter including 8 combustion plants and 4 cement kilns). The energy efficiency figures requested for municipal solid waste incineration plants that carry out recovery operations falling in Annex II, R1 to Directive 2008/98/EC were provided for four plants. A range of hazardous and non-hazardous waste are reported as being co-incinerated in cement kilns and combustion plants. There are no co-incineration plants subject to the provisions of Annex V.
ELVs, operational parameters and monitoring requirements
The following changes have been reported by the UK:
Three plants have been exempted from the operating conditions specified in articles 6(1) and 6(2) in accordance with Article 6(4) with regards to the temperature conditions only. The exemptions apply to new plants, all of which are situated in Scotland and incinerate wood waste and tannery waste.
Exemptions from emission limits in accordance with Annex II.1 have been granted for three pollutants (SO2, TOC, and NOx) in four existing plants.
Different air emission limit values to those given in Annex II or Annex V have been set for NOx (in a new incineration plant to ensure that air quality standards are met despite the short chimney in place), and for NH3 (in two new plants, one incinerator and one co-incinerator, as a control mechanism for pollutant abatement system).
General legislative provisions and procedures
There have been a few changes in the responses provided on legislative provisions and related procedures since the previous reporting period, as well as some additional detail that has been provided, as follows.
The maximum flow rates are now required among the provisions within the permitting process. It is unclear if this is additional information that has been provided by the Member State or a new requirement.
The criteria to ensure that that storage capacity is adequate for waters to be tested and treated before
discharge is determined on a case-by-case basis according to the capacity, treatment techniques, and volume of waste water being produced. The Member State has reported that the operator is expected to undertake a risk assessment when applying for a permit to determine the maximum volume that would be held in a worst case scenario. It is unclear if this is additional information that has been provided by the Member State or a new requirement.
In addition to the provisions previously reported, the UK has reported that standard conditions regarding the control of abnormal operations contained in permit conditions now specify that an annual cumulative duration of abnormal operation can be no more than 60 hours. It is unclear if this is additional information that has been provided by the Member State or a new requirement.