Explanatory and Guidance document on Waste Incineration BREF and BAT conclusions
The Waste Incineration BAT conclusions, the basis to reassess and update the environmental permits of waste incineration plants in Europe, have been adopted by the European Commission and have been now published on the Official Journal of the European Union. The new requirements will have to be implemented in permits of all European plants within 4 years from the date of the publication.
Despite being part of a more comprehensive document, the Waste Incineration BREF (final draft here), BAT conclusions are meant to be a stand-alone document that serves as a reference for permits. However, a lot of practical information which will be necessary for their implementation is missing from the document and is not otherwise available to the main users of BAT conclusions – plant operators and competent authorities.
For this reason, CEWEP, ESWET, FEAD and Euroheat & Power, the organisations that participated in the Technical Working Group for the review of the Waste Incineration BREF, decided to publish this Guidance document. It consists of the main document, an executive summary, and 7 annexes, and aims to explain the most difficult issues which are left unaddressed, the needed contextual information and some proposals and forms to fill in that can be useful for the implementation and harmonisation of Waste Incineration BAT conclusions.
CONTENT of the Explanatory & Guidance document (E&G‐d):
ANNEXES 2 –NOC/OTNOC/EOT
ANNEXES 3 – Monitoring and uncertainties (air emissions)
ANNEX 5 – Comments on some BAT conclusions
ANNEXES 6 – Forms to assess the implementation of BATs in a plant
ANNEX 7 – Frequently Asked Questions
INERIS Report on accuracy of air emissions measurement - Update
This study prepared by INERIS for CEWEP, ESWET and FEAD addresses the question of performance of monitoring techniques for air emissions, in particular in the framework of the Industrial Emissions Directive (IED). Its focus is on the reliability and accuracy of measurements at very low concentrations, which has significant implications on the drawing up of Best available techniques REFerence documents (BREFs), the setting of IED-based BAT-Associated Emission Levels (BATAELs) and the relative BATAEL-based ELVs.
This updated version of the study was done to take into account the comments that were made on the original study, published in summer 2016, by national experts of different Member States and from experts of the European IPPC Bureau. It also includes additional results of measurement campaign obtained by INERIS during tests for certification confirmation where laboratories are compared, which illustrate the relative uncertainties as a function of concentrations.
The report concludes that for several substances high measurement uncertainty is observed at significantly lower concentrations than the IED’s ELVs, therefore it is desirable to maintain daily ELVs at levels necessary to keep a minimal risk when declaring whether an AMS is compliant or not in respect with standard requirements.
The full report is available here.
Explanatory note on INERIS report
ESWET together with CEWEP and FEAD prepared an explanatory note on the report 'Study on AMS and SRM performances and their impact on the feasibility of lowering ELVs for air emissions in the context of the BREFs and BATs revision and of BATAEL elaboration according to the IED' published in July 2016.
Our aim with the INERIS study is to raise awareness on the issue, to trigger discussion on this horizontal topic, and to work together with stakeholders in order to find a harmonised procedure or guidance at European level to deal with it: although compliance with current IED Annex V and VI ELVs is not questioned, for some pollutants the low values reported by plant operators cannot be used 1:1 to set emission limits, because the relative uncertainty connected to the measured values would be too high to comply with the current rules on uncertainty.
Considering the legally binding nature of ELVs (with severe legal consequences in case of noncompliance), we need to ensure that compliance with ELVs derived from BATAELs can be checked with the appropriate certainty.
For the full explanatory note, please click here.
INERIS report on accuracy of air emissions measurement
ESWET together with CEWEP and FEAD are pleased to publish a report prepared by INERIS Institute addressing the question of air emissions monitoring within the Industrial Emissions Directive. The report focuses on reliability and accuracy of monitoring at very low concentrations, which has significant implications on the drawing up of Best Available Techniques (BAT) Reference documents (BREFs) and the setting of BAT Associated Emission Levels.
We consider that the monitoring issue must be very seriously taken into account before going further in the review process of Waste Treatment BREF and Waste Incineration BREF and before official validation of Large Combustion Plants BREF and Reference Report on Monitoring.