Suitability of WDFs for End-of-Waste Status Annex 8 “Environment and Health”” Error! Style not defined.
ANNEX 8 “Environment and Health”
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CONTENT
2
1
GENERAL COMPARISON WID – LCP ...................................... 4
2
EMISSIONS OF WDF INCINERATION TO AIR.......................... 7
2.1 2.1.1
Incineration of WDFs as Waste ...........................................................7 Combustion Plants Co-incinerating Waste .............................................7
2.2 2.2.1 2.2.2
Incineration of WDFs as Non-Waste .................................................14 Combustion Plants................................................................................14 Conclusions...........................................................................................16
3
TRACEABILITY OF HAZARDOUS WASTE............................. 18
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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
Incineration as waste
Incineration as non-waste
Legal framework for incineration
WID (2000/76/EC)
LCP Directive (2001/80/EC)
Air emission limit value
Dust
Dust
Gaseous and vaporous organic substances (VOC)
-
HCl
-
HF
-
Water emission limit value
4
Legal requirements
SOx
SOx
NOx
NOx
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)
-
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Parameter
Legal requirements Incineration as waste
Incineration as non-waste
Legal framework for incineration
WID (2000/76/EC)
LCP Directive (2001/80/EC)
Operating condition
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.
-
Operating condition
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.
-
-
*) 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.
Combustion plants < 50 MW: Consistent EUwide minimum requirements 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.
Austrian Waste Incineration Ordinance: Requirements for WDF incineration as non-waste
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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 z
in a co-incinerating LCP within the WID scope (i.e. WDF incineration as waste),
z
in a LCP plant under the LCP Directive (i.e. WDF incineration as non-waste) and
z
in a LCP plant under the IED (i.e. WDF incineration as non-waste)
are presented.
2.1
Incineration of WDFs as Waste
2.1.1 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)
Vwaste:
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 (273.15 K, 101.3 kPa, correction of water vapour content). Cwaste:
Emission limit values for waste incineration plants (WID: Annex V; IED: Annex
VI). Vproc:
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. Cproc:
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.
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On December 17th 2010 the new directive on industrial emissions (2010/75/EU) was published and entered into force on January 6th 2011. 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 7th 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 1st 2016. Within this context the Cproc 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 SO2, NOX 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 7th 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 7th 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 28th 2002, which was authorized or registered for waste incineration and had a permit granted before December 28th 2002, provided that the plant was put into operation no later than December 28th 2003, or which – in the view of the competent authority – was the subject of a full request for authorisation before December 28th 2002, provided that the plant was put into operation not later than December 28th 2004. Transitional provisions as stated in article 82 (5) will not be considered in this context. Incineration as waste: ELVs for SO2 Comparison WID-IED
Table 2: Comparison of SO2 emission limit values (Cproc) for solid fuels as daily averages (general case) Rated Thermal Input
WID Annex II
IED Annex VI existing plants
IED Annex VI new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
–
–
–
50–100
850
400
400
100–300
850–200 (linear decrease)
200
200
200
200
150
< 50
> 300
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Table 3: Comparison of NOx emission limit values (Cproc) for solid fuels as daily averages (general case) Rated Thermal Input
WID Annex II
IED Annex VI existing plants
IED Annex VI new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
–
–
–
50–100
400
300
300
100–300
300
200
200
> 300
200
200
150
< 50
Table 4: Comparison of Dust Emission Limit Values (Cproc) for solid fuels as daily averages Rated Thermal Input
WID Annex II
IED Annex VI existing plants
IED Annex VI new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
< 50
50
50
50
50–100
50
30
20
100–300
30
25
20
> 300
30
20
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Umweltbundesamt Vienna, July 2011
Incineration as waste: ELVs for NOx Comparison WID-IED
Incineration as waste: ELVs for Dust Comparison WID-IED
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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 SO2 emissions for plants with a rated thermal input between 50 MWth and 300 MWth (Table 2 and Incineration as waste: ELVs for NOx Comparison WID-IED
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Table 3). In comparison to existing plants (IED) the values given for new plants show additionally minor improvements for SO2 and NOx (> 300 MWth) and a further reduction of the dust emission limit values for plants with a rated thermal input larger than 50 MWth. 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)).
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Table 5: Comparison of Emission Limit Values (Cwaste) as daily averages Pollutant
WID Annex V
IED Annex VI
[mg/Nm³] (11 % O2)
[mg/Nm³] (11 % O2)
SO2
50
NOx
200
Dust
(1)
/400
50 (2)
200
10 1)
Incineration as waste: ELV Overview Comparison WID-IED
(1)
/400 (2)
10
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 SO2, NOx 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: z
combustion of coal with 5 %(1) co-incineration of waste
z
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 SO2, NOx 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: SO2 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
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
–
–
50–100
389
378
100–300
196
191
> 300
196
191
[MWth] < 50
(1)
Co-incineration as waste in Large Combustion Plants: ELVs for SO2 according to WID
regarding the share of the waste gas volume resulting from the incineration of waste
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Table 7: SO2 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
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
–
–
50–100
389
378
100–300
196
191
> 300
147
144
[MWth] < 50
Co-incineration as waste in Large Combustion Plants: ELVs for NOx according to WID
Table 8: NOx 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
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
–
–
50–100
310
320
100–300
214
228
> 300
214
228
[MWth] < 50
Table 9: NOx 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
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[MWth] < 50
–
1)
– 1)
50–100
300 1)
300 1)
100–300
203 1)
207 1)
203
207
> 300 1)
rated thermal input to low to co-incinerate more than 6 t/h waste
Table 10: NOx emission limit values for existing plants for the co-incineration (new in terms of waste incineration) of coal and waste as daily averages
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Rated Thermal Input
5 % Co-Incineration
10 % Co-Incineration
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
< 50
–
–
50–100
397
393
100–300
203
207
> 300
203
207
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Table 11: NOx 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
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
< 50
–
–
50–100
300
300
100–300
203
207
> 300
155
160
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
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
< 50
49
48
50–100
29
29
100–300
25
24
> 300
20
20
Co-incineration as waste in Large Combustion Plants: 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
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
< 50
49
48
50–100
20
20
100–300
20
20
> 300
10
10
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 (Cproc, Cwaste) 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 NOX value for new co-incineration plants with a rated thermal input of 50–100 MWth (Table 11) where the values of 300 mg/Nm³ at 6 % oxygen content (Cproc) 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
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oxygen content) the diluting effect results in values even higher than those for combustion of the regular fuel (e.g. NOX for new plants with a rated thermal input > 100 MWth). In some cases the values for the conventional fuel are even below those for waste incineration (NOX for existing plants and NOX for new plants with a rated thermal input > 300 MWth). 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 SO2, NOX 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, SO2 and NOX(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)
When wastes are coincinerated in combustion plants additional emission limit values for total organic carbon (TOC), hydrogen Co-incineration chloride (HCl), as waste in Large hydrogen fluoride Combustion (HF), heavy Plants: metals ELVs for Heavy Metals (Table 14), dioxins according to WID and furans (Coincineration as waste in Large Combustion Plants: ELVs for PCDD/F according to WID
Co-Incineration
Pollutant
[mg/Nm³] (6 % O2) Cd + Tl
0.05
Hg
0.05
Sb + As + Pb + Cr + Co + Cu + Mn + Ni + V
0.5
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 as waste in Large Combustion Plants: ELVs for PCDD/F according to WID
Co-Incineration [ng/Nm³] (6 % O2)
Dioxins and furans
2
14
0.1
for existing waste incineration plants with a nominal capacity exceeding 6 tonnes per hour or new waste incineration plants
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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
2.2.1 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 1st 2016. 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 27th 2002, provided that they were put into operation no later than November 27th 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 7th 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 7th 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 1st 2016 to December 31st 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 2023. Table 21 the stipulated emission limit values for large combustion plants are shown.
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In Table 16 to Concineration as nonwaste in Large Combustion Plants: ELVs for Dust according to IED
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Co-incineration as non-waste in Large Combustion Plants: ELVs for SO2 according to LCP-D
Table 16: SO2 Emission limit values for coal fired combustion plants as daily averages according to the LCP Directive Rated Thermal Input
existing plants
new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
1,700
850
100–300
1,700
400–200 (linear decrease)
300–500
1,700–400 (linear decrease)
200
400
200
> 500
Co-incineration as non-waste in Large Combustion Plants: ELVs for SO2 according to IED
Co-incineration as non-waste in Large Combustion Plants: ELVs for NOx according to LCP-D
Co-incineration as non-waste in Large Combustion Plants: ELVs for NOx according to IED
16
Table 17: SO2 Emission limit values for coal fired combustion plants as daily averages according to the IED Rated Thermal Input
existing plants
new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
400
400
100–300
200
200
> 300
200
150
Table 18: NOx Emission limit values for coal fired combustion plants as daily averages according the LCP Directive Rated Thermal Input [MWth]
existing plants
new plants
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
600
400
100–300
600
200
300–500
600
200
> 500
500
200
Table 19: NOX emission limit values for coal fired combustion plants as daily averages according the IED Rated Thermal Input
existing plants
new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
300
300
100–300
200
200
> 300
200
150
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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
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
100
50
100–300
100
30
300–500
100
30
> 500
50
30
Table 21: Dust emission limit values for coal fired combustion plants as daily averages according the IED Rated Thermal Input
existing plants
new plants
[MWth]
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
50–100
30
20
100–300
25
20
> 300
20
10
Co-incineration as non-waste in Large Combustion Plants: ELVs for Dust according to LCP-D
Co-ncineration as non-waste in Large Combustion Plants: 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 SO2 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 (Cproc) set out for plants co-incinerating waste. For coincineration additionally dust emission limit values for plants with a rated thermal input below 50 MWth 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.
2.2.2 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 (Cproc) for conventional fuels. In the cases of
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significant lower input values (Cwaste) 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 SO2, NOX 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 31st 2015, derogations for large combustion plants may be applied until December 31st 2023. These derogations can result in emission values that are more than four to eight times higher (SO2 for plants with 50 MWth – ≈ 300 MWth). As a further example the influence of the limited lifetime derogation on dust emissions is shown in Table 22.
Co-incineration as non-waste: Dust ELVs are 3-5 times higher
Table 22: Comparison of dust emission limit values for coal fired coincineration/combustion plants as daily averages Rated Thermal Input
[MWth] < 50
Dust ELVs for Co-incineration of 5% WDF in a Large Combustion Plant As waste
As non-waste
WID: Existing Plants
WID: New Plants
IED: Existing Plants
IED: New Plants
LCP Directive: Existing Plants*
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
[mg/Nm³] (6 % O2)
49
49
–
–
–
50–100
29
20
30
20
100
100–300
25
20
25
20
100
300–500
20
10
20
10
100
> 500
20
10
20
10
50
*) 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 MWth 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 MWth 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).
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Umweltbundesamt Vienna, July 2011
Suitability of WDFs for End-of-Waste Status Annex 8 “Environment and Health”” Error! Style not defined.
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.
Article 17 WFD: Traceability of hazardous waste has to be ensured
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.
EoW for hazardous waste equals loss of traceability
The following provisions regulate the incineration of WDFs as waste or nonwaste, respectively, on EU level.
Umweltbundesamt Vienna, July 2011
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