The main EU requirements for co-incineration

The relevant waste treatment processes have to fulfil requirements set by European and national legislation. With a focus on incineration and co-incineration of waste, the technical requirements are mainly set by the European Waste Incineration Directive and its amendment by the European Industrial Emission Directive (2010/75/EU - IED). The scope of the directive covers all installations for the incineration and co-incineration of waste.

Exempted from the scope are incineration and co-incineration plants only treating the following wastes:

Vegetable waste from agriculture and forestry;

Vegetable waste from the food processing industry, if the heat generated is recovered;

Fibrous vegetable waste from virgin pulp production and from production of paper from pulp, if it is co-incinerated at the place of production and the heat generated is recovered;

Cork waste;

Wood waste with the exception of wood waste which may contain halogenated organic compounds or heavy metals as a result of treatment with wood preservatives or coating and which includes, in particular, such wood waste originating from construction and demolition waste;

Radioactive waste;

Animal carcasses as regulated by regulation (EC) No 1774/2002 of the European Parliament and of the Council on 03.10.2002 establishing health rules concerning animal by-products not intended for human consumption

Waste resulting from the exploration for, and the exploitation of, oil and gas resources from off-shore installations and incinerated on board the installations;

Experimental plants used for research, development and testing in order to improve the incineration process and which treat less than 50 tons of waste per year.

Another approach to the scope, derived from the definitions, is shown as an example in a summarised version of the terms “waste incineration and co-incineration plants”:

Waste incineration plant means any stationary or mobile technical unit and equipment dedicated to the thermal treatment of waste, with or without recovery of the combustion heat generated, through the incineration by oxidation of waste as well as other thermal treatment processes, such as pyrolysis, gasification or plasma process, if the substances resulting from the treatment are subsequently incinerated.

Waste co-incineration plant’ means any stationary or mobile technical unit whose main purpose is the generation of energy or production of material products and which uses waste as a regular or additional fuel or in which waste is thermally treated for the purpose of disposal through the incineration by oxidation of waste as well as other thermal treatment processes, such as pyrolysis, gasification or plasma process, if the substances resulting from the treatment are subsequently incinerated*.

If processes other than oxidation, such as pyrolysis, gasification or plasma process, are applied for the thermal treatment of waste, the waste incineration plant or waste co-incineration plant shall include both the thermal treatment process and the subsequent incineration process.

If co-incineration takes place in such a way that the main purpose of the plant is not the generation of energy or the production of material products, but rather the thermal treatment of waste, the plant shall be deemed an incineration plant as defined above.

In order to ensure a high level of environmental and human health protection and to avoid trans-boundary shipment of waste to plants operating at lower environmental standards, it is necessary to set and maintain stringent operating conditions, technical requirements and emission limits for plants incinerating or co-incinerating waste within the European Union.

The air emission limits for both of the thermal waste treatment technologies are defined in the Industrial Emission Directive (IED).

The air emission limits for specialized waste incineration techniques (e.g. grate fired plants, rotary kilns etc.) are a bit more stringent than for co-incineration waste derived fuels in a process. The determination of air emission limits for the co-incineration of waste derived fuels takes the special situation of a production plant or a power plant into account.

For this reason, the directive defines different solutions for the determination of air emission limits. One is the use of a formula (“mixing rule”) as defined in the attachment of the directive and shall be applied whenever a specific total emission limit value ‘C’ has not been included in a table in that attachment. The emission limits for each relevant air polluting substance and CO in the flue gas resulting from the co-incineration shall be calculated as defined in the “mixing rule”. This attachment also includes special provisions for cement kilns using waste derived fuels to determine the specific total emission limits.

Besides these minimum requirements, the description of waste treatment activities has to take into account the Best Available Techniques Reference Documents (BAT-Reference or BREF). In the future, the national transposition of the BREF caused by the Directive 2010/75/EU on industrial emissions (IED) of 24.11.2010 are influence national requirements much more. Main aspects of the process are the higher compulsion of the BAT documents, exchange of information on BAT in Europe as a continuous and dynamic process and the national transition and control of BAT conclusions.

The IED is more than simply a recast of the IPPC directive because several European directives were put together and the compulsion of the BAT documents was strengthened.

The BAT process is a central way to achieve more uniformity between the European member states and to become more important to the EU 28 member states.

In order to determine the best available techniques and to limit imbalances in the European Union with regards to the level of emissions from industrial activities, reference documents for BAT reference documents’ should be drawn up, reviewed and, where necessary, updated through an exchange of information with stakeholders and the key elements of BAT reference documents (conclusions) adopted through committee procedure.

In this respect, the Commission should, through committee procedure, establish guidance on the collection of data, on the elaboration of BAT reference documents and on their quality assurance. BAT conclusions should be the reference for setting permit conditions. They can be supplemented by other sources. The Commission should aim to update BAT reference documents not later than 8 years after the publication of the previous version.

Two BAT Reference Documents (BREFs) for the waste sector have been prepared as part of a process referred to as the Seville process:

BREF for waste incineration (does not cover specific techniques and co-incineration of waste derived fuels, and particularities related to the co-incineration; these are dealt with in the BREFs for the relevant sectors (e.g. cement kilns or similar processes);

BREF for waste treatment (all non-thermal waste treatment processes, e.g. physico-chemical treatment, biological treatment, refining of waste oil, production of alternative waste derived fuels, and wastewater treatment).

With reference to the community standards as defined in the EU Directive on landfill, there will be no BREF for sanitary landfilling.

Work on the revision of the Waste Treatment BREF started in November 2013 (kickoff meeting in Seville). The scope of the Waste Treatment BREF covers the biological-mechanical treatment where national standards are set by the 30^th Ordinance on the Immission Control Act.

The start of the revision of the Waste Incineration BREF is expected at the end of 2014.

The waste treatment activities are also influenced by the European Waste Framework Directive and their national implementation.

Energy recovery assumes the use of preprocessed waste as an alternative fuel in industrial processes (co-incineration) or its use in a municipal waste incineration plants (MSW-incinerators) if the R1-criteria is met as defined in the European framework. Meaning, the combustion of waste must generate more energy than the consumption of energy by the incineration plant itself, the greater part of the waste must be consumed during the operation and the generated energy must be recovered and used either as heat or as electricity and has therefore to replace the use of primary energy.