ANNEX 8. Environment and Health

Transcription

1 ANNEX 8 Environment and Health Umweltbundesamt Vienna, July

2 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. CONTENT 1 GENERAL COMPARISON WID LCP EMISSIONS OF WDF INCINERATION TO AIR Incineration of WDFs as Waste Combustion Plants Co-incinerating Waste Incineration of WDFs as Non-Waste Combustion Plants Conclusions TRACEABILITY OF HAZARDOUS WASTE Umweltbundesamt Vienna, July 2011

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4 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. 1 GENERAL COMPARISON WID LCP If a waste ceases to be waste and is incinerated as a waste-derived fuel, a most powerful environmental and health impact originates from the fact that incineration then happens within another legal framework, i.e. under the scope of the LCP Directive (for plants of 50 MW rated thermal input) instead of the Waste Incineration Directive. The aim of the Waste Incineration Directive is to prevent or to limit as far as practicable negative effects on the environment, in particular pollution by emissions into air, soil, surface water and groundwater, and the resulting risks to human health, from the incineration and co-incineration of waste. Contrary to that, the LCP Directive regulates the incineration of conventional fuels, such as coal, oil, gas and biomass, and thus does not foresee any comparable requirements which take into consideration the co-incineration of waste. Requirements of WID and LCP Directive A summary of the most relevant differences between these two Directives with regard to WDF incineration as waste or non-waste is given in Table 1. Table 1: Summary of the most relevant differences between legal requirements for the WDF incineration as waste (WID) and non-waste (LCP) respectively Parameter Legal framework for incineration Air emission limit value Water emission limit value Legal requirements Incineration as waste Incineration as non-waste WID (2000/76/EC) Dust Gaseous and vaporous organic substances (VOC) HCl - HF - SOx NO x Cd + Tl - Hg - Sum of Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V Dioxins and furans (PCDD/F) - Total suspended solids - Hg - Cd - Tl - As - Pb - Cr - Cu - Ni - Zn - Dioxins and furans (PCDD/F) - LCP Directive (2001/80/EC) Dust - SOx NO x - 4 Umweltbundesamt Vienna, July 2011

5 Parameter Legal framework for incineration Operating condition Operating condition Legal requirements Incineration as waste Incineration as non-waste WID (2000/76/EC) In incineration plants, the slag and bottom ashes Total Organic Carbon (TOC) content has to be less than 3 % or their loss on ignition is less than 5 % of the dry weight of the material. With the aim to prohibit PCDD/F generation: The gas resulting from incineration has to be raised, after the last injection of combustion air, to a temperature of 850 C for two seconds*. Further requirements (e.g. auxiliary burners, automatic stop of waste feed in case of temperature drop, no waste feed during start-up and close-down operation) serve to keep the required flue gas temperatures. LCP Directive (2001/80/EC) *) Or to 1,100 C respectively, if hazardous waste with a content of more than 1% halogenated organic substances, expressed as chlorine, is incinerated. The scope of the LCP Directive covers only incineration plants of a rated thermal input of 50 MW. If a WDF that has ceased to be waste is incinerated in installations of smaller size, the LCP Directive does not apply, but the environmental requirements are subject to the respective national legislation of the Member States, and can vary significantly from one Member State to Member State. Consistent EU-wide minimum requirements for emission limit values also for smaller installations, which are not covered by the LCP Directive, are desirable. The Austrian transposition of the WFD, the Austrian Waste Incineration Ordinance (cf. Chapter 8.3 of the Report), specifies end-of-waste criteria for WDFs in general and for wood waste explicitly. Even when a WDF has ceased to be waste, incineration has to take place in an installation of 50 kw rated thermal input and complying with an dust emission limit to air of 20 mg/m³ (as half-hourly average limit value). By limiting dust emissions to air, the emissions of heavy metals (contained in the particulates) and of PCDD/F (which tend to get adsorbed to the particulates) can be controlled. Combustion plants < 50 MW: Consistent EUwide minimum requirements are desirable Austrian Waste Incineration Ordinance: Requirements for WDF incineration as non-waste Umweltbundesamt Vienna, July

6 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. 6 Umweltbundesamt Vienna, July 2011

7 2 EMISSIONS OF WDF INCINERATION TO AIR For WDF incineration as waste (i.e. within WID plants) and WDF incineration as nonwaste (in an LCP plant), subsequently a comparison of the respective emission limit values according to WID, LCP Directive and IED is drawn. By way of concrete examples for the co-incineration of 5% or 10% respectively of WDF together with conventional fuel, the differences between emission limit values for air emissions in a co-incinerating LCP within the WID scope (i.e. WDF incineration as waste), in a LCP plant under the LCP Directive (i.e. WDF incineration as non-waste) and in a LCP plant under the IED (i.e. WDF incineration as non-waste) are presented. 2.1 Incineration of WDFs as Waste Combustion Plants Co-incinerating Waste In the case of combustion plants which are co-incinerating waste a mixing rule is applied to determine the emission limit values for pollutants released to air. The mixing rule is shown in Formula (2.1): (2.1) V waste : Waste gas volume resulting from the incineration of waste only determined from the waste with the lowest calorific value specified in the permit and at standardised conditions ( K, kpa, correction of water vapour content). C waste : VI). Emission limit values for waste incineration plants (WID: Annex V; IED: Annex V proc : Waste gas volume resulting from the plant process including the combustion of the authorised fuels normally used in the plant (wastes excluded) determined on the basis of oxygen contents at which the emissions must be standardised as set out in Union or national law. In the absence of legislation for this kind of plant, the real oxygen content in the waste gas without being thinned by addition of air unnecessary for the process must be used. C proc : Emission limit values as set out (WID: Annex II; IED: Annex VI) for certain industrial activities or in case of the absence of such values, mission limit values of plants which comply with the national laws, regulations and administrative provisions for such plants while burning the normally authorised fuels (wastes excluded). In the absence of such permit values the real mass concentrations are used. C: Total emission limit values at an oxygen content as set out for certain industrial activities and certain polluting substances or, in case of the absence of such values, total emission limit values replacing the emission limit values as set out in specific Annexes (WID Annex II; IED: Annex VI). The total oxygen content to replace the oxygen content for the standardisation is calculated on the basis of the content above respecting the partial volumes. In this report the co-incineration of waste in coal combustion plants will be discussed in detail since this is the most common case for co-incineration plants. Umweltbundesamt Vienna, July

8 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. On December 17 th 2010 the new directive on industrial emissions (2010/75/EU) was published and entered into force on January 6 th Within this directive seven different directives have been combined. Also the directives on the incineration of waste (2000/76/EC) and on the limitation of emissions of certain pollutants into the air from large combustion plants (2001/80/EC) became part of the new directive and were amended concomitantly. According to article 81 of the directive on industrial emissions (IED) the directive on the incineration of waste (WID) is repealed with effect from January 7 th 2014 and the directive on the limitation of emissions of certain pollutants into the air from large combustion plants (LCP directive) with effect from January 1 st Within this context the C proc values (EVL) for combustion plants co-incinerating waste and the emission limit vales for the incineration of waste of the current (WID) and the new (IED) directive are compared (Table 2 to Table 5). The compared values are the emission limit values for SO 2, NO X and dust for the combustion of coal (general cases). Special cases (e.g. fluidised bed combustion) are not discussed in this report. The IED differentiates between existing plants and new plants for the co-incineration of waste. According to article 30 (2) plants that have been granted a permit before January 7 th 2013 or the operators have submitted a complete application for a permit before that date, provided that such plants are put into operation no later than January 7 th 2014, will be considered as existing plants. Plants that are not covered by this paragraph of article 30 will be indicated as new plants. A further differentiation within the WID and the IED is applied between existing waste incineration plants and new waste incineration plants. An existing waste incineration plant is a plant that was in operation and had a permit before December 28 th 2002, which was authorized or registered for waste incineration and had a permit granted before December 28 th 2002, provided that the plant was put into operation no later than December 28 th 2003, or which in the view of the competent authority was the subject of a full request for authorisation before December 28 th 2002, provided that the plant was put into operation not later than December 28 th Transitional provisions as stated in article 82 (5) will not be considered in this context. Incineration as waste: ELVs for SO 2 - Comparison WID-IED Rated Thermal Input [MW th ] Table 2: Comparison of SO 2 emission limit values (C proc ) for solid fuels as daily averages (general case) WID Annex II IED Annex VI existing plants IED Annex VI new plants < (linear decrease) > Umweltbundesamt Vienna, July 2011

9 Rated Thermal Input [MW th ] Table 3: Comparison of NO x emission limit values (C proc ) for solid fuels as daily averages (general case) WID Annex II IED Annex VI existing plants IED Annex VI new plants Incineration as waste: ELVs for NOx - Comparison WID-IED < > Rated Thermal Input [MW th ] Table 4: Comparison of Dust Emission Limit Values (C proc ) for solid fuels as daily averages WID Annex II IED Annex VI existing plants IED Annex VI new plants Incineration as waste: ELVs for Dust - Comparison WID-IED < > Umweltbundesamt Vienna, July

10 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. The comparison of the emission limit values shows that the values given in the directive on the incineration of waste were significantly amended in the IED (without considering transitional provisions according to article 82 (5) in this context). Especially differences are present regarding SO 2 emissions for plants with a rated thermal input between 50 MW th and 300 MW th (Table 2 and Incineration as waste: ELVs for NOx - Comparison WID-IED Table 3). In comparison to existing plants (IED) the values given for new plants show additionally minor improvements for SO 2 and NO x (> 300 MW th ) and a further reduction of the dust emission limit values for plants with a rated thermal input larger than 50 MW th. Furthermore the emission limit values stated for the incineration of waste were compared (Table 5) since they are also an input parameter for the determination of the total emission limit values for plants co-incinerating waste (Formula (2.1)). 10 Umweltbundesamt Vienna, July 2011

11 Pollutant Table 5: Comparison of Emission Limit Values (C waste ) as daily averages WID Annex V IED Annex VI (11 % O 2 ) (11 % O 2 ) SO NO x 200 (1) /400 (2) 200 (1) /400 (2) Dust Incineration as waste: ELV Overview - Comparison WID-IED 1) existing waste incineration plants with more than 6 t/h nominal capacity or new waste incineration plants 2) existing waste incineration plants with less than 6 t/h nominal capacity In the case of SO 2, NO x and dust the emission limits are identical for the WID and IED. Due to the fact that the WID will be repealed in 2014 only the regulations of the IED will be taken into account for the further discussion. Emission Limit Values for Combustion Plants Co-incinerating Waste Within this chapter the emission limit values for the co-incineration of waste in combustion plants are discussed. In this context two different cases will be outlined: combustion of coal with 5 % (1) co-incineration of waste combustion of coal with 10 % (1) co-incineration of waste These two cases represent a typical and a maximum ratio for waste coincineration in coal combustion plants. A share of more than 10 % waste is rather uncommon. The emission limit values for SO 2, NO x and dust resulting from the different shares of waste were calculated by applying the mixing rule (Formula (2.1)) and are shown in Table 6 to Table 13. Table 6: SO 2 emission limit values for existing plants for the co-incineration of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > waste in Large ELVs for SO 2 according to WID (1) regarding the share of the waste gas volume resulting from the incineration of waste Umweltbundesamt Vienna, July

12 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. Table 7: SO 2 emission limit values for new plants for the co-incineration of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > waste in Large ELVs for NO x according to WID Table 8: NO x emission limit values for existing plants (in terms of coincineration and waste incineration) for the co-incineration of coal and waste as daily averages; maximum capacity of waste incineration < 6 t/h Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > Table 9: NO x emission limit values for existing plants (in terms of coincineration and waste incineration) for the co-incineration of coal and waste as daily averages; maximum capacity of waste incineration > 6 t/h Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < 50 1) 1) ) 300 1) ) 207 1) > ) rated thermal input to low to co-incinerate more than 6 t/h waste Table 10: NO x emission limit values for existing plants for the co-incineration (new in terms of waste incineration) of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > Umweltbundesamt Vienna, July 2011

13 Table 11: NO x emission limit values for new plants (in terms of coincineration and waste incineration) for the co-incineration of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > Table 12: Dust emission limit values for existing plants for the co-incineration of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration waste in Large ELVs for Dust according to WID < > Table 13: Dust emission limit values for new plants for the co-incineration of coal and waste as daily averages Rated Thermal Input 5 % Co-Incineration 10 % Co-Incineration < > The influence of the different shares between conventional fuel and waste has only a marginal effect on the resulting emission limit values. Since the linear dependence of the different emission limit values (C proc, C waste ) the value for conventional fuel is dominant. In the predominant cases where the emission limit values for waste incineration are lower the effect is mostly compensated by the different dilutions resulting from the reference oxygen content. An example for this effect would be the NO X value for new co-incineration plants with a rated thermal input of MW th (Table 11) where the values of 300 mg/nm³ at 6 % oxygen content (C proc ) and of 200 mg/nm³ at 11 % oxygen content result in the same mass flow of the pollutant. When both values are equal (at different Umweltbundesamt Vienna, July

14 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. oxygen content) the diluting effect results in values even higher than those for combustion of the regular fuel (e.g. NO X for new plants with a rated thermal input > 100 MW th ). In some cases the values for the conventional fuel are even below those for waste incineration (NO X for existing plants and NO X for new plants with a rated thermal input > 300 MW th ). A significant effect that determines the emission limit values is the age of the incineration plants. Table 15) have to be met. In contrast to SO 2, NO X and dust the emission limit values are independent of the waste share, age of the plant or the thermal input. Additional half-hourly emission limit values are stipulated for dust, TOC, HCl, HF, SO 2 and NO X (2). Table 14: Total emission limit values for heavy metals for plants co-incinerating waste (average values over the sampling period of a minimum of 30 minutes and a maximum of 8 hours) Pollutant Co-Incineration Cd + Tl 0.05 Hg 0.05 Sb + As + Pb + Cr + Co + Cu + Mn + Ni V When wastes are coincinerated in combustion plants additional emission limit values for total organic carbon (TOC), hydrogen Co-incineration chloride (HCl), as waste hydrogen in Large fluoride Combustion (HF), heavy Plants: metals ELVs (Table for 14), Heavy dioxins Metals according and furans to (Coincineration as WID waste in Large ELVs for PCDD/F according to WID Table 15: Total emission limit value for dioxins and furans for plants co-incinerating waste (average value over the sampling period of a minimum of 30 minutes and a maximum of 8 hours) Pollutant Co-Incineration [ng/nm³] Dioxins and furans 0.1 waste in Large ELVs for PCDD/F according to WID 2 for existing waste incineration plants with a nominal capacity exceeding 6 tonnes per hour or new waste incineration plants 14 Umweltbundesamt Vienna, July 2011

15 To determine the total concentration of dioxins and furans the mass concentrations of dibenzo-p-dioxins and dibenzofurans have to be multiplied by equivalence factors as stated in Part 2 of Annex VI of the directive on industrial emissions (2010/75/EU). 2.2 Incineration of WDFs as Non-Waste Combustion Plants In the case of exclusively co-incinerating WDF (where end of waste applies) in combustion plants only the conventional emissions limit values for large combustion plants would be relevant. The emission limit values for large combustion plants are stipulated in the directive on the limitation of emissions of certain pollutants into the air from large combustion plants (2001/80/EC, LCP directive) which will be replaced by the directive on industrial emission (2010/75/EC, IED). According to article 81 (2) of the IED the LCP directive will be repealed with effect from January 1 st Both the LCP directive and the IED differentiate between plants according to the time of their permit and the time they were put into operation. In the context of the LCP directive we will consider plants as existing plants if they were a subject of a full request for a licence (in the view of the competent authority) before November 27 th 2002, provided that they were put into operation no later than November 27 th 2003 (article 4 (1) and 4 (3)). Other plants will be considered as new plants (article 4 (2)). Regarding article 30 of the IED plants that have been granted a permit before January 7 th 2013 or the operators have submitted a complete application for a permit before that date, provided that such plants are put into operation no later than January 7 th 2014, will be considered as existing plants. Plants that are not covered by this paragraph of article 30 will be indicated as new plants. Although transitional provisions and derogation will not be discussed in this report it has to be mentioned that combustion plants with limited life time derogation may be exempted from compliance with emission limit values stated in the directive during the period from January 1 st 2016 to December 31 st 2023 (IED article 33). Regarding WDF a co-incineration would be possible in plants which do not have to comply with the emission limit values stated in the IED until the end of Table 21 the stipulated emission limit values for large combustion plants are shown. In Table 16 to Concineration as nonwaste in Large ELVs for Dust according to IED Umweltbundesamt Vienna, July

16 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. non-waste in Large ELVs for SO 2 according to LCP-D Rated Thermal Input Table 16: SO 2 Emission limit values for coal fired combustion plants as daily averages according to the LCP Directive existing plants new plants , , (linear decrease) , (linear decrease) 200 > non-waste in Large ELVs for SO 2 according to IED Table 17: SO 2 Emission limit values for coal fired combustion plants as daily averages according to the IED Rated Thermal Input existing plants new plants > non-waste in Large ELVs for NO x according to LCP-D Table 18: NO x Emission limit values for coal fired combustion plants as daily averages according the LCP Directive Rated Thermal Input existing plants new plants > non-waste in Large ELVs for NO x according to IED Table 19: NO X emission limit values for coal fired combustion plants as daily averages according the IED Rated Thermal Input existing plants new plants > Umweltbundesamt Vienna, July 2011

17 Table 20: Dust emission limit values for coal fired combustion plants as daily averages according the LCP Directive Rated Thermal Input existing plants new plants > non-waste in Large ELVs for Dust according to LCP-D Table 21: Dust emission limit values for coal fired combustion plants as daily averages according the IED Rated Thermal Input existing plants new plants > Co-ncineration as non-waste in Large ELVs for Dust according to IED The comparison shows that the emission limit values stipulated in the LCPdirective were significantly amended for new and existing plants (different in date than in the LCP directive) in the IED. Particularly the values for the emission of SO 2 were decreased significantly. In contrast to this the values stipulated for existing plants in the LCP directive may still be applied until 2023 if a limited lifetime derogation has been granted. This may results in emission values that are more than four to eight times higher than set out in the IED. The values shown for new and existing plants in terms of the IED are consistent with the values (C proc ) set out for plants co-incinerating waste. For coincineration additionally dust emission limit values for plants with a rated thermal input below 50 MW th are given. In comparison to the co-incineration of waste (non-wdf) and conventional fuels neither emission limit values for total organic carbon, hydrogen chloride, hydrogen fluoride, heavy metals, dioxins and furans nor half-hourly emission limit values are stipulated for conventional combustion plants Conclusions For combustion plants the case of co-incineration of waste in coal fired plants was assessed. For co-incineration a mixing rule has to be applied to determine the emission limit values. Due to the fact that rarely more than 10 % waste will be co-incinerated in coal fired plants the emission limit values are predominantly determined by the input values (C proc ) for conventional fuels. In the cases of Umweltbundesamt Vienna, July

18 Suitability of WDFs for End-of-waste Status Annex 8 Environment and Health Error! Style not defined. significant lower input values (C waste ) for waste incineration the effect is mostly compensated due to dilution effects since the values are standardised to different oxygen contents. For the exclusive co-incineration of WDF (where end of waste applies) in combustion plants the emission limit values for large combustion plants are seen as relevant. The values given for SO 2, NO X and dust are consistent with the input values for the mixing rule for co-incineration and the determined emission limit values are nearly equal. In contrast to co-incineration, where transitional provisions may apply at the latest until December 31 st 2015, derogations for large combustion plants may be applied until December 31 st These derogations can result in emission values that are more than four to eight times higher (SO 2 for plants with 50 MW th 300 MW th ). As a further example the influence of the limited lifetime derogation on dust emissions is shown in Table 22. non-waste: Dust ELVs are 3-5 times higher Rated Thermal Input Table 22: Comparison of dust emission limit values for coal fired coincineration/combustion plants as daily averages Dust ELVs for Co-incineration of 5% WDF in a Large Combustion Plant WID: Existing Plants As waste WID: New Plants IED: Existing Plants As non-waste IED: New Plants LCP Directive: Existing Plants* [MW th ] < > *) with limited lifetime derogation (possible until the year 2023) While the overall range of dust emissions is 30 mg/nm³ to 10 mg/nm³ for plants with a rated thermal input larger than 50 MW th the range for existing plants with respect to the provision of the LCP directive is 50 mg/nm³ to 100 mg/nm³. For plants with a rated thermal input below 50 MW th only limits for co-incineration plants are given. Furthermore for large combustion plants neither emission limit values for total organic carbon, hydrogen chloride, hydrogen fluoride, heavy metals, dioxins and furans nor half-hourly emission limit values are prescribed. Technical provision (e.g. minimum incineration temperature at a given residence time) are only stipulated for plants incinerating or co-incinerating waste (article 50 of the IED). 18 Umweltbundesamt Vienna, July 2011

19 3 TRACEABILITY OF HAZARDOUS WASTE Some of the WDFs within the scope of the study at hand i.e. waste oil and waste solvents - are always hazardous waste according to the List of Waste. Other WDFs, e.g. wood waste, waste plastic or waste paper, usually arise as non-hazardous waste, but can under certain circumstances also arise as hazardous waste fractions. According to Article 17 WFD, ( ) Member States shall take the necessary action ( ) to ensure traceability from production to final destination and control of hazardous waste ( ). In case a WDF ceases to be waste and is traded as a product within and over the borders of the European Union, the traceability stipulated by Article 17 WFD is not warranted any more. The following provisions regulate the incineration of WDFs as waste or nonwaste, respectively, on EU level. Article 17 WFD: Traceability of hazardous waste has to be ensured EoW for hazardous waste equals loss of traceability Umweltbundesamt Vienna, July