Paul R James, AEA Technology Energy & Environment

Transcription

1 A comparison between the European Commission Best Available Techniques (BAT) Reference Document on Waste Incineration and the Waste Incineration Directive Paul R James, AEA Technology Energy & Environment Paul R James BSc MSc Principal Consultant AEA Technology Environment The Gemini Building Fermi Avenue Harwell International Business Centre Didcot, Oxfordshire. UK OX11 0QR Tel: +44 (0) Mob: +44 (0) Fax: +44 (0) paul.r.james@aeat.co.uk EXECUTIVE SUMMARY The Integrated Pollution Prevention and Control (IPPC) Directive, the concept of Best Available Techniques (BAT), the new EC BAT Reference (BREF) document and the Waste Incineration Directive are all introduced, and a comparison of BAT in the BREF and the requirements of WID is presented. Conclusions are presented regarding some key differences between the BREF and the WID. In particular an assessment is provided of: Conceptual differences between the BREF and WID approaches The BREF contribution on reducing emissions to air The BREF contribution on improving energy efficiency The BREF contribution on enhancing residue management In addition, comments are provided regarding the technological response to policy developments relevant to these key areas. 1

2 THE INTEGRATED POLLUTION PREVENTION AND CONTROL (IPPC) DIRECTIVE (EC/96/61) The Integrated Pollution Prevention and Control (IPPC) Directive (EC/96/61) requires that EU Member States ensure that industries falling within its scope are issued with a permit based on the concept of Best Available Techniques (BAT). The requirement to use BAT applies to a very broad range of industries, including many in the waste management sector (see box 1 below). Box 1: Waste management activities included in the IPPC Directive 96/61/EC 5.1. Installations for the disposal or recovery of hazardous waste as defined in the list referred to in Article 1 (4) of Directive 91/689/EEC, as defined in Annexes II A and II B (operations R1, R5, R6, R8 and R9) to Directive 75/442/EEC and in Council Directive 75/439/EEC of 16 June 1975 on the disposal of waste oils, with a capacity exceeding 10 tonnes per day 5.2. Installations for the incineration of municipal waste as defined in Council Directive 89/369/EEC of 8 June 1989 on the prevention of air pollution from new municipal waste incineration plants and Council Directive 89/429/EEC of 21 June 1989 on the reduction of air pollution from existing municipal waste-incineration plants with a capacity exceeding 3 tonnes per hour 5.3. Installations for the disposal of non-hazardous waste as defined in Annex II A to Directive 75/442/EEC under headings D8 and D9, with a capacity exceeding 50 tonnes per day 5.4. Landfills receiving more than 10 tonnes per day or with a total capacity exceeding tonnes, excluding landfills of inert waste THE EUROPEAN BEST AVAILABLE TECHNIQUES (BAT) GUIDANCE: In order to facilitate the implementation of the IPPC Directive (96/61/EC) the European Commission organises an exchange of information on the subject of Best Available Techniques (BAT) between experts from the EU Member States, industry and environmental organisations. This work is co-ordinated by the European IPPC Bureau, based in Seville, Spain. The main outputs from this information exchange are the BAT Reference Documents (BREFs). All European Member States and competent authorities are expected to take this guidance in to account when issuing permits for installations under the IPPC Directive. The BREF projects on Waste Treatment and on Waste Incineration commenced in Final drafts of both documents were presented to the European Commission in June The full EC adoption procedure is expected to be complete during The IPPC Directive requires the issue of permits based on BAT by October

3 THE WASTE INCINERATION DIRECTIVE (WID) EC/2000/76: The WI Directive entered in to force on 28 December It repeals former directives on the incineration of hazardous (Directive 94/67/EC) and non-hazardous (Directives 89/369/EEC and 89/429/EEC) waste and replaces them with a single text. The WI Directive sets controls on releases to water and to air, by setting emission limit values and establishes certain operating standards in relation to combustion conditions and residue quality. Most types of waste incineration plants fall within the scope of the WI Directive, with some exceptions, such as those treating only biomass (e.g. non-treated agriculture and forestry residues). Experimental plants with a limited capacity used for research and development of improved incineration processes are also excluded. Transposition into the national legislation of EU Member States was necessary by 28 December From this date on all new incinerators have had to comply with the provisions of the WI Directive. The deadline to bring existing plants into compliance was 28 December A COMPARISON OF THE WID AND BREF FOR INCINERATION PLANTS: It is important to note that recital 13 of WID states: Compliance with the emission limit values laid down by this Directive should be regarded as a necessary but not sufficient condition for compliance with the requirements of Directive 96/61/EC. Such compliance may involve more stringent emissions limit values for the pollutants envisaged by this Directive, emission limit values for other substances and other media, and other appropriate conditions. Achieving WID standards does not therefore automatically mean that the requirements to use the Best Available Techniques (under IPPC) have been fulfilled. In legal terms it is the WID that provides the minimum performance standards. However, it is anticipated that by the application of BAT and the integrated approach this will result in further improvements in operational standards, beyond that provided for by the WID, that will result in benefit to the environment as a whole The tables below provides a description of some of the key issues arising from a comparison of the requirements of the WID in respect of waste incineration plants and the BAT listed in the final draft of the waste incineration BREF: 3

4 Subject WID BREF / BAT Comment / Implications taking into account the categories of suited to characteristics of the waste received waste to be incinerated (Art 4.2.(a)) (BAT 1) Installation design General design requirements are complimentary. The BREF also provides an indication of some critical factors, and information on design / waste suitability. Waste storage Pre-treatment Combustion conditions Energy recovery Residues Provides for compliance with the ELVs and other requirements of WID (e.g. Art 4.2) take all necessary precautions..to prevent or limit as far as practicable negative effects on the environment.. Art 5.1 Only mentioned in the context of improving ash burn out where required. (Art 6.1) Use of a FGT that..provides for the operational emission levels, given in a table (BAT 35) Provides FGT design selection criteria (BAT 36 & 37) Risk based. In general: sealed surfaces and controlled drainage (BAT 5). Manage storage times, provide for odour control (BAT 6 & 7). Segregate & label (BAT8, 9) Fire prevention and management plans (BAT 10) Mix, blend or shred to the degree required according to process design. Consider cross media impacts. Greater need if narrow design (e.g. of combustor or FGT) Need to consider safety aspects for HW 850 / 1100 C for 2 seconds etc (Art 6.1) WID requirements generally compatible with BAT, but..in general it is BAT to avoid excessive temperatures. And < 1100 C for HW has been shown to have overall benefit and can be BAT. as far as practicable (Art 4.2b & 6.6) residues will be minimised in their amount and harmfulness and recycled where appropriate (Art 4.2c) A combination of techniques and performance levels are suggested, and various local factors discussed. Installation energy recovery, exports and use are all considered. Some techniques are suggested, and a BAT guideline set of TOC value of less than 3 wt %, and typically between 1 and 2 %. Neither specifies precise design requirements, but both give performance requirements for releases. In the case of the WID these are ELVs, in the BREF they are operational levels. The BREF suggests a multi-media based approach to FGT design selection, and provides guidance on critical substances. BREF provides much more specific guidance in respect of the techniques that are applicable to fulfil the more general requirement in WID. BREF provides a much deeper assessment of the applicability of waste pre-treatments, their advantages and disadvantages. BREF suggests that the WID conditions provide a generally good guide but that there are circumstances when lower temperatures may of be greater overall environmental benefit. This compliments the WID derogation clause in Art 6.4 The information in the BREF provides much more information to allow an assessment of the performance of an individual installation, and whether the techniques it uses are BAT. The BREF confirms that BAT will achieve better burnout than WID, and provides information on how to improve overall performance. slag and bottom ashes Total Organic Carbon (TOC) content is less than 3 % or their loss on ignition is less than 5 % of the dry weight (Art 6.1) Ash segregation and testing are highlighted as BAT, along with a need consider downstream recycling and disposal when considering the extent of treatment of bottom ashes and FGT residues Both WID and BAT appear to compliment wider EC policy on waste and resources and promote techniques that may result in reduced disposal of the residues arising. 4

5 Subject WID BREF / BAT Daily average ELV Half hourly Daily average (100% / 97% ile) (operational BAT Emissions to air (mg/ Nm 3 unless stated) Half hour average (operational BAT range) Comment / Implications range) Dust / Suggests the use of BAT will generally result in routine emission levels significantly below the ELV set in WID. HCl / Suggests that BAT can result in routine emission levels SO / Suggests that BAT can result in routine emission levels NO x (as NO 2 ) < 200 to < 500 (size / new / existing dependant) 400 / (SCR) (SNCR) (SCR) (SNCR) Suggests the use of BAT will generally result in routine emissions below WID ELVs and that the lowest levels are generally achieved using SCR. VOC Suggests that BAT can result in routine emission levels CO (10 min avg) (some alternatives) Suggests that BAT can result in routine emission levels Hg 0.05 (non-continuous sample) Suggests the use of BAT will generally result in routine emission levels significantly below the ELV set in WID. Cd / Tl 0.05 (non-continuous sample) (non-continuous sample) Suggests that BAT can result in routine emission levels PCDD/F 0.1 ng/m 3 (non-continuous sample) ng/m 3 (non-continuous sample) Suggests that BAT can result in routine emission levels Ammonia < Limits / monitoring for ammonia is already included in some incinerator permits. N 2 0 Benz(a)pyrene PAHs PCBs Not included in WID Information about control techniques is provided. Indicates that monitoring of these substances may be required at some point? Note: The BREF working group agreed the ranges shown above, but not unanimously. Some members of the working group registered split views in respect of some of the ranges set. Some of these suggested higher, and some lower ranges than those given see the final version of the BREF for full details. Table 1: Some key issues arising from a comparison of the requirements of the WID and the BAT listed in the final draft of the BREF 5

6 CONCLUSIONS: The BREF for the Waste Incineration sector provides information that shows that the actual performance of modern installations using BAT gives rise to in operation emissions levels that improve on the emission limit values (ELVs) that are included in WID. However, this is to be expected as the WID sets emission limit values, whereas the BREF provides performance levels based upon the use of BAT. Key conceptual differences between the BREF and the WID are: The BREF also provides information on how to improve performance, whereas the WID only provides what must be achieved The BREF uses an integrated approach and provides tools that support the assessment of the appropriateness of technological changes and advances in the local context The BREF has developed additional quantitative assessment criteria, including for energy recovery an area that was not described in any detail in the WID The most significant issues that arise from a comparison of BREF / BAT and the WID of appear to be: 1. REDUCING EMISSIONS TO AIR: In some cases the BAT based performance levels for emissions to air suggest that installations using BAT are generally capable of achieving emission levels that are well below the emission limit values prescribed by the WID. It should however be noted that this does not necessarily suggest that the emission limits set in permits need to be lowered. In many cases it would appear that the operational emission levels that are described in the BREF as BAT may be those derived as a consequence of designer and operator compliance with emission limit values set at the values contained in WID. The BREF itself, in its introduction to the BAT Chapter, includes a description of this relationship between emission limits on the one hand, and the derived performance on the other. To confirm this relationship requires comparison of the actual emission levels of installations with the levels suggested in the BREF. In some cases techniques already widely in use in the industry result in emission levels significantly below those described in WID. Particular examples include the use of bag filters and Selective Catalytic Reduction (SCR), which regularly provide for emissions of less than half of the WID limits for dust and NO 2 respectively. The economy of scale at larger plants is noted in the BREF as a factor that allows more economic adoption of SCR at larger installations. This would appear to compliment policies that aim to achieve the maximum cost / benefit for pollution control investments, and may offer particular advantages in respect of larger installations situated in cities with poor air quality in the vicinity. 6

7 2. ENERGY EFFICIENCY: The BREF provides far more detailed information with which to judge the energy efficiency performance of installations. The information provided in the BREF clearly shows that the range of energy efficiency performance is very wide, and that site specific factors and policies that impact on the availability of suitable users for heat generally have a great influence. It is noted in the BREF that, under favourable conditions the energy efficiency of CHP plants can quadruple the efficiency of energy recovery when compared with the recovery of electricity only. Improving the utilisation of the energy recoverable from the waste that will be treated in the waste incineration sector provides the greatest opportunity for the waste incineration sector to contribute to improved environmental performance. The BREF notes that that wider policy on energy plays a key role in providing the circumstances that allow greater exploitation of the energy value of residual waste. This is of particular significance for those EU MS`s that are in a position where they are today taking decisions on energy and waste policy that will influence infrastructure development for many years to come. Effectively exploiting high efficiency energy from waste development can contribute to current energy policy themes such as security of supply and addressing greenhouse gas emissions, whilst also providing a cost effective and environmentally sound means to address landfill diversion targets. It may be concluded that, in respect of energy recovery, it is not technological innovation that is required, but policy development and management, so that known and applied techniques can be applied on a wider basis. 3. RESIDUE PRODUCTION & USE: The BREF confirms that BAT will achieve better burnout than WID, and provides information on how to improve overall performance. Modern installations are already achieving ash burn out levels that are a significant improvement upon the 3% TOC level indicated in WID. However, noting the impact that variations in waste composition can have upon the possibility of guaranteeing lower levels, the working group on BAT concluded that a TOC value of less than 3 wt %, and typically between 1 and 2 % was appropriate. Technological development in this area is being driven by wider policies at the National and International level on waste and resource management, and the increasing cost of landfill. Key influences in this respect are the EC Landfill Directive (99/31/EC) and the EC thematic strategies on; the prevention and recycling of waste and, sustainable use of resources. In effect these policies are: Promoting greater prevention and recovery of wastes Increasing the cost of final disposal This results in greater interest in those techniques that reduce residue production, or result in the production of residues that may occupy a higher level on the waste hierarchy. 7

8 REFERENCES: 1. Directive 96/61/EC concerning integrated pollution prevention and control (the IPPC Directive) 2. Directive 2000/76/EC on the incineration of waste (the WI Directive) 3. Reference document on the best available techniques for waste incineration - final draft July Thematic Strategy on the prevention and recycling of waste (21 Dec 2005) 5. Thematic Strategy on the Sustainable Use of Natural Resources (21 Dec 2005) 6. Directive 99/31/EC on the landfill of waste 8