waste incineration bref - draft 1 · waste in large combustion plants which combust waste where 40...

Waste Incineration BREF - draft 1EURELECTRIC comments

September 2017

WG Environmental ProtectionContact:

Hélène LAVRAY, Advisor Renewables & Environment –[email protected]

Dépôt légal: D/2017/12.105/42

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helene.lavray 1 Selected Text 5 677 which combust mixedmunicipal waste

Major The term "mixed municipal waste" needs to be clarifiedand aligned with the scope of the BAT Conclusions forLarge Combustion Plants

Change text: "which combust mixedmunicipal waste as defined in Article3 (39) of Directive 2010/75/EU"

See scope of the LCP BREF

helene.lavray 2 Selected Text 5 677 These BAT conclusionsdo not address thefollowing

Major Include exemption from scope for disposal or recoveryof waste in large combustion plants covered by theBREF LCP and the corresponding BAT conclusions forlarge combustion plants.

Add text: "Disposal or recovery ofwaste in large combustion plantswhich combust waste where 40 % orless of the resulting heat releasecomes from hazardous waste orwhich combust waste except mixedmunicipal waste as defined in Article3(39) and except other waste listedin Article 42(2)(a)(ii) and (iii) ofDirective 2010/75/EU as this iscovered by the BAT conclusions forlarge combustion plants."

In general, co-incineration ofwaste in large combustion plantswith more than 50 MW of thermalrated capacity is covered by theBAT conclusions for largecombustion plants of the BREFLCP. However, in some cases,the BAT conclusions for LCPsdo not apply (e.g. for co-incineration plants combustingmixed municipal waste). Toavoid duplication and loopholesa clear exemption from scope ofplants covered exclusively by theBREF LCP should be included inthe BREF WI.

helene.lavray 3 Entire Chapter 5 677 Major Derivation of BAT-AELs should focus on KeyEnvironmental Indicators for the waste incinerationsector. For other IED pollutants that are not consideredto be KEI it is sufficient that the existing IEDrequirements continue to apply as safety network.According to the kick-off-meeting outcomes, pollutantsnot initially considered to be a priority in the context ofthis WI BREF review include among others HF, HCl,and CO. Results of the data collection confirm mostlythe appropriateness of the existing ELVs of IED AnnexVI for those pollutants.

Consider deleting the BAT-AELsconcerning HF (BAT 28), HCl (BAT28), and CO (BAT 29) for not beingKEI in the context of the BREF wasteincineration review.

See Kick-Off-Meeting chartsregarding KEI. Remind that IEDAnnex VI sets an appropriatesafety network including ELVsfor the non-key environmentalindicators such as HF, HCl andCO.

See also Joint contribution fromIED regulated industrial sectorson the crteria for identifying keyenvironmental issues for thereview of BREFs

http://www.eurelectric.org/media/293203/20161017_final_joint_contribution_on_kei-2016-oth-0085-01-e.pdf

helene.lavray 4 Entire Chapter 5 677 Major In some cases the BAT conclusions include tailoredBAT requirements for different waste types such asMSW/ONHW, sewage sludge and hazardous waste(e.g. In table 5.1). It is unclear which and to whatextent requirement(s) shall apply when several types ofwastes are used.

Include clarification on theapplication of BAT conclusions in thecase of different waste types beingincinerated.

Many waste incinerators can beclassified according to thepredominant waste type used(e.g MSW, SS, HW etc.).However, many plants are usingsmaller fractions of other wastetypes in combination with themain waste type or a predominntwaste type cannot be identified.

helene.lavray 5 Entire Chapter 5 677 Major For reasons of consistency with the IED, all BAT-AELsshould be expressed as daily averages only. In casesof waste co-incineration where the IED mixing ruleapplies, the mixing rule should be applied only for dailyaveraging periods using the corresponding relevantdaily values based on the BREF conclusions for Wasteincineration and from the BREF LCP, if applicable, orfrom the IED Annex, if necesary. The application of themixing rule shall not be based on BAT-AELs fordiffering averaging periods.

Express all BAT-AELs and indicativeemission levels for air emissions asdaily averages as far as continuousmeasurement applies. Do notinclude BAT-AELs or indicativeemission levels based on longterm(yearly, monthly) or short-term(houly, half-hourly) average. Clarifythat in case of co-incineration wherethe mixing rule applies, onlyemission values based on theavailable BREF conclusions or theIED expressed as daily averagesshall be used.

See Kick-Off-Meeting.Consistency with the IED AnnexVI that sets an appropriateframework for complianceassessment and ELVs based ondaily averages.

Chapter No. / Section No.

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helene.lavray 6 Entire Chapter 5 677 Major To enable compliance assessment, all BAT-AELs (andin particular the lower ranges) must take into accountthe applicable measurement uncertainty to allow formonitoring and compliance assessment. All valuesshall be based on the collected reference plant datawithout abstraction of measurement uncertainty. AllBAT-AELs should be assessed in line with the JRCreport on uncertainty management.

Check lower and upper ranges ofBAT-AELs against the relevantmeasurement uncertainty and raiselevels accordingly if necessary forcompliance assessment.

See JRC draft report andcorresponding Eurelectriccomments.

helene.lavray 7 Selected Text 5 678 Definitions Major Include definition for "wood waste" (WW) Add definition: Woody biomasswhich may contain halogenatedorganic compounds or heavy metalsas a result of treatment with woodpreservatives or coating and whichincludes, in particular, such woodwaste originating from constructionand demolition waste (see Article 3(31)b of Directive 2010/75/EU)

A definition of "wood waste" isneeded to enable, whereappropriate, the setting of woodwaste specific BAT requirementsthroughout chapter 5.

helene.lavray 8 Selected Text 5 678 Definitions Major Include definition for "Start-up and shut-down period" Add definition: The time period ofplant operation as determinedpursuant to the provisions ofCommission Implementing Decision2012/249/EU of 7 May 2012,concerning the determination of start-up and shut-down periods for thepurposes of Directive 2010/75/EU ofthe European Parliament and theCouncil on industrial emissions.

A concise and clear definition ofSUSD is needed for BAT 6 inparticular. See definition ofSUSD in BREF LCP / BATConclusions.

helene.lavray 9 Selected Text 5 678 Definitions Major Include definition for "Valid (half-hourly average)" A half-hourly average is consideredvalid when there is no maintenanceor malfunction of the automatedmeasuring system.

A concise and clear definition of"valid" half-hourly average isneeded for BAT-AEL monitoring.See definition of "Valid (houlyaverage)" in the BREF LCP /BAT Conclusions from 2017

helene.lavray 10 Selected Text 5 681 Average value over asampling period of 2 to 4weeks

Major General considerations (table averaging periods): Allowfor longer periods for "long-term sampling averages".

Change text in table for long-termsampling averages: "Average valueover a sampling period of at least 2weeks."

"Long-term sampling average" isdefined as "Average value overa sampling period of 2 to 4weeks". The used periods forPCDD/F samplings areremarkable longer (e.g. up to 8weeks).

helene.lavray 11 Selected Text 5 681 (1) For any parameterwhere, due to samplingor analytical limitations,a 30-minutemeasurement isinappropriate, a moresuitable sampling periodmay be employed. ForPCDD/F and dioxin-likePCBs, one samplingperiod of 6 to 8 hours isused in the case of short-term sampling.

Major Modify footnote 1 of the table concerning averagingperiods to allow for one longer measurement instead of3 shorter ones.

Modify footnote 1: "For anyparameter where, due to sampling oranalytical limitations, threeconsecutive 30-minutemeasurements are inappropriate , amore suitable sampling period maybe employed. For PCDD/F anddioxin-like PCBs, one samplingperiod of 6 to 8 hours is used in thecase of short-term sampling"

"Average over the samplingperiod" demands threeconsecutive measurements,which is not justified e.g. formetal analysis. One longermeasurement instead of 3shorter should be allowed also.

helene.lavray 12 Selected Text 5 682 Acronyms Major Add I-TEQ and WHO-TEQ to list of acronyms The list of acronyms should includethe terms I-TEQ and WHO-TEQaiming at clarifying the respectiveversions of TEQ.

The determination of PCDD/Fand PCB emissions should bebased either in accordance withIED Annex VI part 2 on I-TEQ-factors and methodology firstpublished in 1988 or on theWHO-TEQ-factors andmethodology published in 2005.

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helene.lavray 13 Selected Text 5 682 When waste is co-incinerated together withnon-waste fuels, theBAT-AELs for emissionsto air

Major The D1 does not take into account the currentrequirements of the IED for co-incineration. For plantsco-incinerating waste the mixing formular of Annex IVof the IED is applicable in certain cases.

Change text: "When waste is co-incinerated together with non-wastefuels, the BAT-AELs for emissions toair given in these BAT conclusionsapply to the entire flue-gas volumegenerated, except in cases wherethe mixing rule formula of Annex VI(part 4) to Directive 2010/75/EU isapplicable for the pollutant inquestion. In those cases, the BAT-AELs for emissions to air given inthese BAT conclusions apply only tothe entire flue-gas volume generatedfrom the waste."

For reasons of consistency andpropotionality, the specialprovisions concerning certainpollutants for combustion plantsco-incinerating waste containedin Annex VI (part 4) to Directive2010/75/EU and hereby inparticular the mixing rule formulaneed to be respected.

helene.lavray 14 Selected Text 5 682 The BAT-AELs foremissions to water applyat the point where theemission leaves theinstallation

Major General considerations: Clarify that emission levels foremissions to water refer to direct discharges toreceiving water bodies.

The BAT-AELs for emissions towater refer to direct discharges to areceiving water body and apply atthe point where the emission leavesthe installation.

See analogous provision in theBREF LCP BAT ConclusionChapter.

helene.lavray 15 Selected Text 5 682 Destruction efficiency Major The definition of the destruction efficiency for POPsshould be deleted.

Delete definition of "destructionefficiency".

Related to deletion of BAT 9.The analytical determination ofthe destruction efficiency basedon various randomly takenperiodic measurements in waste,slag/bottom ash, residues andflue gas are not enabling theplant operator to determine ascientifically sound andpractically relevant andreproducable destructionefficiency in light of the greatvariety of waste charges (withand without POPs) and timedelays between the differentsamplings. Also, it is not definedif mass is calculated as toxicityequivalents. There is a need toset common and suficientlyrobust methodology for asampling and calculations.

helene.lavray 16 Selected Text 5 682 The BAT-AELs refer todaily averages, i.e. 24-hour flow-proportionalcomposite samples

Major General considerations: Clarify that other methods thanthe 24-hour-flowproportional composite samples maybe used.

BAT-AEL for emissions to water:"The BAT-AELs refer to dailyaverages, i.e. 24-hour flow-proportional composite samples, oralternative on 4 of 5 measuringmethod. A Time-proportionalcomposite sampling can also beused alternatively provided thatsufficient flow stability isdemonstrated"

The flow-proportional collectionprocess is technically complexand is still subject to faults inoperation. Since there is nobetter results compared to thespot (random) sampleprocedure, for economic reasonsthe exemplary specification inBREF WI should be omitted. Inaddition, this method is anintegral feature, which leads tothe qualitative devaluation ofother suitable measuringmethods. The "time-proportionalcomposite sampling" enables toreduce the effort.

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helene.lavray 17 Selected Text 5 1 1 684 Specifically forincineration plants and,where relevant, bottomash treatment plants,BAT is

Major BAT 1 - EMS features not relevant for all plants Modify text as follows: "Specificallyfor incineration plants and, whererelevant, bottom ash treatmentplants, BAT is to also incorporateone or a combination of the followingfeatures in the EMS: "

With the specific requirementsfor the environmentalmanagement system, BREF WIis now calling for numerousconcepts / plans with specificspecifications that are rarelyfound in practise with thesespecifications. It is customary towork with specific requirementsand instructions tailored to thecompany's requirements. Inmany cases, they differ from thisdifferentiated presentation.It is now mistaken to see thatsuch a differentiated approachwith such management plans isdescribed as common.Thefeatures of an EMS identifiedspecifically for incinerationplants should not be generallyapplicable in all cases. It shouldbe up to operators andauthorities to select the requiredfeatures on a case-by-casebasis.

helene.lavray 18 Selected Text 5 1 1 684 BAT 2 Major BAT 2 - include applicability restriction for accidentmanagement plan

Include applicability restriction:"Applicability: Only applicable forplants subject to Directive2012/18/EU on the control of major-accident hazards involvingdangerous substances and for plantstreating or incinerating predominantlyhazardous wastes or for other plantswhere relevant accident hazardsinvolving dangerous substances areexpected and/or have beensubstantiated."

Accident management plansshould not be generallyapplicable for all installations.The accident management planshould only apply if largerquantities of hazardous wasteare used in the wasteincineration plant.

helene.lavray 19 Selected Text 5 1 2 685 BAT 3. Major BAT 3: Establish appropriate provisions for combinedheat and power plants regarding energy efficiency.

Replace footnote 1 to BAT 3 asfollows: "In the case of combinedheat and power (CHP) plants, onlyone of the two BAT-AEELs applies:either 'gross electrical efficiency' or'gross total heat efficiency',depending on the CHP unit design(i.e. either more oriented towardselectricity generation or towards heatgeneration).For CHP plants:• the gross total heat efficiency BAT-AEEL refers to the combustion unitoperated at full load and tuned tomaximise primarily the heat supplyand secondarily the remaining powerthat can be generated;• the gross electrical efficiency BAT-AEEL refers to the combustion unitgenerating only electricity at fullload."

Align provisions for CHP plantswith BAT Conclusions for LCPs.In light of the great differences inoperational designs andfunctionalities of CHP plants,allow for selecting the moreappropriate approach forassessing energy efficiencyperformance of the CHP plant inquestion: Either determination ofgross electrical efficiency or ofgross total heat efficiency.

helene.lavray 20 Selected Text 5 1 2 685 BAT 3. Major BAT 3 - Include derogation for performance test atCHP plants

Include further footnote (2): In thecase of CHP units, if for technicalreasons the performance test cannotbe carried out with the unit operatedat full load for the heat supply, thetest can be supplemented orsubstituted by a calculation using fullload parameters.

See analogous footnote in BREFLCP Bat Conclusion Chapter(BAT 2) applicable for CHPunits.

helene.lavray 21 Selected Text 5 1 2 685 BAT 4 Major BAT 4: Flow measurement at stack through CEMs don'tseem necessary, specifically in case of co-incinerationit's not required by LCP BREF.

Monitoring: Periodic or continuousdetermination

Flue-gas flow could be monitoredeffectively by stoichiometriccalculation using periodicanalysis of fuel.

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helene.lavray 22 Selected Text 5 1 2 686 BAT 5 Major BAT 5 - Include applicability restriction for minimummonitoring frequency

Include general footnote regardingminimum monitoring frequency: "Themonitoring frequency does not applywhere plant operation would be forthe sole purpose of performing anemission measurement."

Waste incinerator lines mayeventually not operated over thefull course of a year (e.g. due tomaintenance or repair). Quarterlyor monthly emission monitoringshould not lead to additionalemissions from start-up, shut-down etc. See analogousfootnote in BREF LCP BatConclusion Chapter (BAT 4)

helene.lavray 23 Selected Text 5 1 2 686 NH3 Major BAT 5 - Allow for exemption from continuousmeasurement for NH3 in small plants.

Include footnote for NH3: In the caseof use of SCR, the minimummonitoring frequency may be at leastonce every year, if the emissionlevels are proven to be sufficientlystable.

Ammonia emissions are usuallynot waste-specific, buttechnology specific (ammoniaslip when applying SCR/SNCR).For waste incinerators, the sameapplicability restrictions andderogations for NH3 shouldapply as for LCPs of comparablesize. See analogous footnote inBREF LCP Bat ConclusionChapter (BAT 4)

helene.lavray 24 Selected Text 5 1 2 686 SO2 Major BAT 5 - Allow for exemption from continuousmeasurement for SO2 in certain cases.

Include footnote for SO2: "Thecontinuous measurements for SO2may be replaced by periodicmeasurements with a minimumfrequency of once every year if theoperator can prove that theemissions of those pollutants canunder no circumstances be higherthan the prescribed emission limitvalues."

Only authorized and regularychecked wastes may be used ina WtE Plant.The waste isincinerated under stableoperating conditions. Reduceadministrative cost and avoidunnecessary administrativeburden. See also analogousexemption in IED Annex VI part2.5

helene.lavray 25 Selected Text 5 1 2 686 HCl Major BAT 5: Continous measurement of HCl should be anoption (as for HF) in cases where emission levels areproven to be stable.

Minimum monitoring frequency forHCl and HF: insert note (2)reference:"(2) The continuous measurement ofHF and HCl may be replaced byperiodic measurements if theemission levels are proven to besufficiently stable. Periodicmeasurements may be carried outeach time that a change of the fueland/or waste characteristics mayhave an impact on the emissions,but in any case at least once everysix months. No EN standard isavailable for the periodicmeasurement of HF."

CEMs is not useful in case af lowand stable emission levels,considering measurement LOD,uncertainty and no additionalinformation provided. Theproposal is consistent with anequivalent footnote in the LCPBREF for plants co-incineratingwaste (LCP BREF - BAT 4,footnote 13).

helene.lavray 26 Selected Text 5 1 2 686 HF Major BAT 5: Continous measurement of HF should be anoption (as for HCl) in cases where emission levels areproven to be stable.

Minimum monitoring frequency forHCl and HF: insert note (2)reference:"(2) The continuous measurement ofHF and HCl may be replaced byperiodic measurements if theemission levels are proven to besufficiently stable. Periodicmeasurements may be carried outeach time that a change of the fueland/or waste characteristics mayhave an impact on the emissions,but in any case at least once everysix months. No EN standard isavailable for the periodicmeasurement of HF."

CEMs is not useful in case af lowand stable emission levels,considering measurement LOD,uncertainty and no additionalinformation provided. Theproposal is consistent with anequivalent footnote in the LCPBREF for plants co-incineratingwaste (LCP BREF - BAT 4,footnote 13).

helene.lavray 27 Selected Text 5 1 2 686 Dioxin-like PCBs Major BAT 5: Restrict minimum monitoring frequency tocases when a BAT-AEL is actually set based on WHO-TEQ-methodology.

Modify Minimum monitoringfrequency: "Once every month if ELVis set based on WHO-TEQmethodolgy".

The requirement to monitordioxin-like PCBs should berestricted in line with appliedBAT-AELs.

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helene.lavray 28 Selected Text 5 1 2 686 Hg Major BAT 5 - allow explicitly for the use of continuoussampling methods

BAT 5: Add footnote to continuousmeasurement of Hg which reads:"Continuous sampling combined withfrequent analysis of time-integratedsamples, e.g. by a standardisedsorbent trap monitoring method, maybe used as an alternative tocontinuous measurements uponrequest by the operator."

Continuous sampling representsa viable alternative method tofulfill obligations for continuousmeasurement of Hg in anefficient way from environmental,economical and technicalpespective.

helene.lavray 29 Selected Text 5 1 2 686 Dioxin-like PCBs Major BAT 5: Reduce monitoring frequency in certain cases BAT 5: Add footnotes to once everymonth measurement frequency ofPCDD/F and Dioxin-like PCBs whichreads: "If the emission levels areproven to be sufficiently stable,periodic measurements may becarried out each time that a changeof the fuel and/or wastecharacteristics may have an impacton the emissions, but in any case atleast once every six months."

Once every month measurementfrequency of PCDD/F iseconomically unfustifiable incases where emission levels areproven to be sufficiently stableand well below the BAT-AELs.

helene.lavray 30 Selected Text 5 1 2 686 N2O Major BAT 5: Delete monitoring requirement for N2O BAT 5: Delete row concerning N2O.If not deleted, change "standard" to:Generic EN standards or EN 21258.

Information on N2O emissionsare not commonly available. Noinformation concerning N2Oemissions was gathered via thequestionnaire on BAT referenceplants, and, hence, no BAT-AELhas been derived. In theabsence of specific provisionsand BAT technologies to reduceN2O emissions, the monitoringrequirement for N2O should beremoved to reduce adminstrativeand monitoring cost. Ifmonitoring requirement is notdeleted, change entry in"standards column: There isgiven the specific standard tomeasure parameter (periodicly).N2O could also easily bemeasured by same AMS device(e.g. FTIR) as many otherparameters and thus periodicmeasurements may not beneeded in all cases.

helene.lavray 31 Selected Text 5 1 2 686 Metals and metalloidsexcept mercury (As, Cd,Co, Cr, Cu, Mn, Ni, Pb,Sb, Tl, V)

Major BAT 5 - Allow for reduction of monitoring frequency formetals and metalloids.

BAT 5 - Include new footnote formetals and metalloids: “The bi-annual sampling of metals andmetalloids except mercury can bereplaced by a monitoring frequencyof once every year in the case thatthe operator can prove on the basisof information on the quality of thewaste concerned and the monitoringof the emissions that the emissionsare under all circumstancessignificantly below the emission limitvalues for heavy metals.”

Reduce administrative cost andavoid unnecessaryadministrative burden. See alsoanalogous exemption in IEDAnnex VI part 2.6

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helene.lavray 32 Selected Text 5 1 2 686 Hg Major BAT 5 - allow for further exemptions from continuousmonitoring of Hg emissions for small emitters

Adapt and extend footnote 3concerning Hg: "For incinerationplants with a capacity of < 100.000tonnes/year incineratingpredominantly non-hazardous waste,and for plants incinerating wasteswith intrinsically low and stablemercury content (e.g. sewagesludge, mono-streams of waste ofcontrolled composition), and forplants proving that mercury emissionlevels are significantly lower than theapplicable limit value andpredominantly close to the lower endof the applicable BAT-AEL (5 µg/m³),the continuous monitoring ofemissions can be replaced by long-term sampling or periodic monitoringwith a minimum frequency of onceevery six months. In the latter casethe relevant standard is EN 13211."

Only authorized and regularychecked wastes may be used ina WtE Plant.The waste isincinerated under stableoperating conditions. BAT 5should allow for an exemptionfrom continuous monitoring ofHg emissions for small emittersto avoid the disproportionallyhigh installation and monitoringcost for continuousmeasurement of mercuryemissions.

helene.lavray 33 Selected Text 5 1 2 686 PCDD/F Major BAT 5: Enable application of footnotes 4 and 5 forplants using small amounts of hazardous waste

In footnotes 4 and 5, the term"exclusively non-hazardous waste"should be replaced with"predominantly non-hazardouswaste"

Many MSW, SS and other Non-HW incinerators co-incineratesmaller fractions of hazardouswaste. In light of thediscontinuous incineration ofsmaller quantities of HW in suchinstallations, a monthlymonitoring frequency is notnecessary. The possibility toreduce the monitoring frequencyshould be enabled forincinerators using only smallerquantities of HW.

helene.lavray 34 Selected Text 5 1 2 686 Dioxin-like PCBs Major BAT 5: Enable application of footnotes 4 and 5 forplants using small amounts of hazardous waste

In footnotes 4 and 5, the term"exclusively non-hazardous waste"should be replaced with"predominantly non-hazardouswaste"

Many MSW, SS and other Non-HW incinerators co-incineratesmaller fractions of hazardouswaste. In light of thediscontinuous incineration ofsmaller quantities of HW in suchinstallations, a monthlymonitoring frequency is notnecessary. The possibility toreduce the monitoring frequencyshould be enabled forincinerators using only smallerquantities of HW.

helene.lavray 35 Selected Text 5 1 2 686 Benzo[a]pyrene Major BAT 5: Delete monitoring requirement forBenzo(a)pyrene.

BAT 5: Delete row concerning N2O.If not deleted, change "standard" to:Generic EN standards or EN 21258.

No individual BAT-AEL is set forBenzo(a)pyrene and there is noEN Standard avaialble. Hence,delete requirement for individualmeasurement of this pollutant.

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helene.lavray 36 Selected Text 5 1 2 687 The monitoring can becarried out by directemission measurementsor by monitoring of

Major BAT 6 - OTHNOC: Restrict applicability of BAT 6 tocontinuously measured air pollutants according to BAT5.

Change text: "The monitoring of airemissions of pollutants continuouslymeasured in accordance with BAT 5can be carried out by direct emissionmeasurements or by monitoring ofsurrogate parameters if this provesto be of equivalent or better scientificquality than direct emissionmeasurements. "

This BAT does not apply to (orrepresent) the operationalpractise and monitoringprocedures . It should be madeclear that:1. the emissions of a WI-plant ismonitored often in EOT - fromthe start-up to shut-down.2. Compliance with prescribedlimit values of IED shall only bedemonstrated during the wasteincineration incl. start-up andshut-down with waste on thegrate/in the combustion chamberWater emissions from FGC andbottom ashtreatment are notsubject of start-up and shut-down considerations regardingthe waste incinerator. Themonitoring should focus oncontinuously monitoredpollutants.

helene.lavray 37 Selected Text 5 1 2 687 Emissions during start-up and shutdown whileno waste is beingincinerated

Major BAT 6 - OTHNOC: Restrict applicability of BAT 6 toincineration of waste.

Delete sentence: "Emissions duringstart-up and shutdown while nowaste is being incinerated…" orrewrite: "Emissions during start-up and shutdown while no waste is being incinerated are not a commonpart of the monitoring. They may beestimated based on at least onemeasurement campaign per yearcarried out during a planned start-up/shutdown operation."

The BREF WI should focus onthe incineration of waste. If thesentence is not deleted, theapplicability should be limited towaste incinerators and not beapplicable for plants co-incinerating wastes as for thoseplants start-up and shut-downprovisions should be closelyaligned with the BATconclusions for BREF LCP.

helene.lavray 38 Selected Text 5 1 2 687 Total organic carbon(TOC)

Major BAT 7 - Limit TOC measurement to bottom ashtreatment

Delete reference to FGC, requiremeasurement of TOC only forbottom ash treatment (proposalrelated to proposal for BAT 34 tolimit applicability of TOC BAT-AEL tobottom ash treatment).

Consistency with IED Annex VI.TOC measurement is notrequired for waste water fromflue gas cleaning (FGC).

helene.lavray 39 Selected Text 5 1 2 687 Once every month Major BAT 7 - clarify that minimum montoring frequency ofonce every month is only applicable for directdischarges to receiving water bodies

BAT-AELs should only be applicablefor direct discharges to receivingwater bodies. Include footnote tominimum monitoring frequency of"once every month": "Monitoringfrequency of once every months onlyapplicable for direct discharges toreceiving water bodies. As analternative, the '4 out of 5 method'may be used."

Reduce administrative cost formonitoring of water emissions incases where the waste water istransfered to an external wastewater treatment plants or othernot direct discharges to areceiving water body. Themonitoring requirements shouldallow for other well establisheddetection methods alreadyintroduced in the EU, inparticular the '4 out of 5 method'.

helene.lavray 40 Selected Text 5 1 2 687 BAT 7 Major BAT 7: Reconsider which metals to monitor in relationto the metals listed in Table 5.8 to BAT34.

BAT 7: Require monitoring of metalsonly for metals listed in Table 5.8 toBAT 34.

Mn and Sb is not in BAT7 whileMo is included. Mn and Sb areincluded in the metals in table5.4 on BAT-AEL while Mo is not.Monitoring of metal emissionsshold only be required for metalswith BAT-AEL requirements inline with Table 5.8 of BAT 34.

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helene.lavray 41 Selected Text 5 1 2 687 BAT 7. Major BAT 7: Respect the limitations of proposed standards BAT 7: Introduce a general footnoteto the table indicating that thestandards has limits. When usedoutside the limits of application, theresults should be interpreted withcaution.

The methods described instandard has limitations andinterferences might result inincorrect results. Especially forsuspended solids.

The filtering normally is completewithin less than 1 minute.However, some types of waterscontain materials that block thefilter pores or reduce their width(eg salts). This increases thefiltering time and the results canbe a function of the samplevolume. If such blocking of thefilter is observed, thedetermination should berepeated with smaller volumes.The results should be interpretedwith caution.

helene.lavray 42 Selected Text 5 1 2 688 BAT 9. Major BAT 9: Delete BAT 9 converning the incineration ofhazardous waste containing POPs.

Delete BAT 9 Section BAT 9 regarding thedetermination of the POPdestruction efficiency is notbased on established practicesand should be deleted. It is notdemonstrated that measuring ofinput and output of POPs in themedia demanded (waste, slags,bottom ash, fly ash, otherresidues, waste water and fluegas) is a feasible, available, andestablished technique todetermine a meaningful andrepresentative destructionefficiency of POPs in plants. Noexample of a plant using suchtechnique is presented. To ourunderstanding is it not possibleto determine the destructionefficiency of a specific POP in aplant where the "POP-waste",with concentrations exceedingvalues in annex IV of the EUPOP-regulation, only is a fractionof the total waste input. The bulkof incinerated waste consist of alarge number of inhomogeneouswastes with low averageconcentrations of commonlyoccurring POPs (for exampledioxins and furans in mostwastes, PFOS in textiles andhelene.lavray 43 Selected Text 5 1 2 688 BAT 8.BAT is to monitor

the total organic carboncontent of bottomashes/slags and/or theirloss on ignition inaccordance withEN 13137 and/orEN 15169. Theminimum monitoringfrequency is once everythree months.

Major BAT 8: Change wording to "or" instead of "and/or". BAT 8: Modify text: "BAT is tomonitor the total organic carboncontent of bottom ashes/slags ortheir loss on ignition in accordancewith EN 13137 or EN 15169 (...)"

BAT conclusions should beclearly and precisely formulated.Avoid ambigious expressionssuch as "and/or". Here, it issufficient to conduct one of thetwo options, either monitoringTOC of bottom ashes and slagsor monitoring of LOI. A provisionshould be inserted allowing foran extension of the minimummonitoring frequency if themeasured levels are proven tobe sufficiently table.

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helene.lavray 44 Selected Text 5 1 3 688 BAT 10.In order toimprove the overallenvironmentalperformance of theincineration plant, aspart of the waste streammanagement plan (seeBAT 1), BAT is to use allof the techniques (a) to(d) given below, and,where relevant, alsotechniques (e) and (f).

Major BAT 10 would, in its current formulation, require awaste-stream-based management system that is notintroduced in common practice, but which must alwaysbe adapted to the specific requirements of theoperation. This has to be considered in the BAT 10. Itis up to the operator to decide to what extentmanagement plans are actually applied.

BAT 10. In order to improve theoverall environmental performance of the incinerationplant, as part of the waste streammanagement plan (see BAT 1), BATis to use one or an appropriatecombination of the techniques (a) to(f)

The waste-stream-basedmanagement system has closelyto be adjusted considering thewaste input characteristics andthe local requirements.

helene.lavray 45 Selected Text 5 1 2 688 BAT 8.BAT is to monitorthe total organic carboncontent of bottomashes/slags and/or theirloss on ignition inaccordance withEN 13137 and/orEN 15169. Theminimum monitoringfrequency is once everythree months

Major BAT 8 - reduce monitoring frequency for TOC and LOIof bottom ashes/slags

BAT 8: "(...) The minimum monitoringfrequency is once every year."

The introduction of a measuringinterval of 3 months obviouslyaims at improving knowledgeabout pollutant emissions from astatistical point of view.However, from the operator'sperspective, they are causingsignificant addionaladministrative burden withoutimproving plant performance. Toreduce administrative cost, theminimum monitoring frequencyshould be changed from "onceevery three months" to "onceevery year". It should also beclarified that monitoringrequirements refer to either TOCor LOI as alternative options.

helene.lavray 46 Selected Text 5 1 3 690 Visual inspection Major BAT 12 - delete requirement of visual inspection forsewage sludge

Line "Sewage sludge": delete "visualinspection" or restrict applicability.

Visual inspection of sewagesludge is usually not applicablein cases where the sewagesludge is directly discharged orpumped from the enclosedtransport container into thestorage deposit.

helene.lavray 47 Selected Text 5 1 3 690 In order to improve theoverall environmentalperformance, BAT is tomonitor the wastedeliveries as part of thewaste acceptanceprocedures (seeBAT 10) including theelements given below

Major BAT 12 - do not require all features of waste monitoringin all cases

Rewrite introduction to BAT 12: "Inorder to improve the overallenvironmental performance, BAT isto monitor the waste deliveries aspart of the waste acceptanceprocedure (see BAT 10) using anappropriate combination of theelements given below for particularwaste fractions."

The required features of wastemonitoring should not begenerally applicable in all cases,but should follow a risk-basedapproach. It should be up tooperators and authorities toselect the required features on acase-by-case basis. For somewastes such as certainhazardous waste the “visualinspection” and “unpacking andvisual inspection” is not feasibleto protect the employees. Someof the hazardous waste streamsare very toxic and thereforestored in closeddrums/containers.

helene.lavray 48 Selected Text 5 1 3 690 Radioactivity detection Major BAT 12: Do not require radioactivity detection for non-hazardous waste

Delete "radioactivity detection" in line2 of table to BAT 12.

Radioactivity detection is notnecessary for MSW or other non-hazardous waste. Monitoringwould require to implement ameasurement system withoutsignificant benefits.

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helene.lavray 49 Selected Text 5 1 3 690 BAT 12 Major BAT 12 - Include tailored requirements for wood wasteanalogously to MSW.

Include additional row for woodwaste in table to BAT 12: Wastetype: "wood waste"; Monitoring: "•Weighing of the waste deliveries• Visual inspection• Periodic sampling of keyproperties/substances for differenttypes of wood waste fractions (e.g.calorific value, content of halogensand metals/metalloids)"

For wood waste includinghazardous wood waste fractionstailored requirements for themonitoring of waste deliveries aspart of the waste acceptanceprocedures should beestablished. Wood wastedeliveries are commonlyclassified into different woodwaste fractions of typicalcharacteristics andcorresponding acceptancecriteria. Detailed analysis ofeach individual waste delivery isnot required.

helene.lavray 50 Selected Text 5 1 3 690 BAT 12 Major BAT 12 - include tailored requirements for hazardouswaste fractions used in MSW and other Non-hazardouswaste incinerators

Include footnote for "hazardouswaste": "For hazardous wastefraction fractions stemming frommunicipal solid waste or comparablecommercial waste of controlledcomposition delivered to plantsincinerating predominantly non-hazardous waste the applicablemonitoring is the one for municipalsolid waste"

Reduce administrative cost forhazardous waste fractions co-incinerated in MSW or other non-HW incinerators.

helene.lavray 51 Selected Text 5 1 3 690 Municipal solid wasteand other non-hazardous waste

Major BAT 12 - do not require periodic sampling of individualdeliveries for MSW and other non-hazardous waste inall cases

Monitoring of MSW and other non-hazardous waste: Periodic samplingof individual deliveries or bulksamples and analysis of keyproperties/substances

It is unreasonable to monitorindividual waste deliveries in allcases; caloric value could bemonitored from bulk samplesgathered from deliveries from asingle supplier or via heatbalance of the unit. Halogensand metals/metalloids could bemonitored from bulk samplesgathered during long period.

helene.lavray 52 Selected Text 5 1 3 691 BAT 13.In order toreduce theenvironmental risksassociated with thereception, handling andstorage of waste, BAT isto use both of thetechniques given below

Major BAT 13: allow for the application of differenttechniques.

Reword introductory sentence: "BAT13. In order to reduce theenvironmental risks associated withthe reception, handling and storageof waste, BAT is to use one or anappropriate combination of thetechniques given below." Split BAT13a in two techniques: 'impermeablesurfaces' and 'segregated drainage'.

Depending on the waste to beused, specific measures areused to isolate possibleenvironmental risks. Therefore,the reference to the tabledescribing the techniques shouldnot be exhaustive orprescriptive, but rather describedifferent techniques ofexemplary character. Thetechnique BAT 13a should besplit in two techniques:'impermeable surfaces' and'segregated drainage'. Theapplication of segregateddrainage is not commonpractice in waste storagebunkers. Instead of applyingsegregated drainage, a possibledrainage could also beconnected to a commondrainage system, becausedrainage is closed during normaloperation and used only duringmaintenance or in other specificcases.

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helene.lavray 53 Selected Text 5 1 3 692 BAT 16.In order toimprove the overallenvironmentalperformance of theincineration plant and toreduce emissions to air,BAT is to set up andimplement proceduresfor the adjustment of theplant’s settings, e.g.though the advancedcontrol system (seedescription inSection 5.2.1), as andwhen needed andpracticable, based onthe characterisation andcontrol of the inputwaste (see BAT 12).

Major BAT 16: Delete BAT 16 Delete BAT 16 BAT 16 basically describesmechanisms which have beenintroduced in principle. Since thisgeneric requirement does notpermit any further clarificationdue to the different waste used,the installed boiler and flue gascleaning technology as well asthe existing control technology,this BAT should be deleted.Otherwise, plant operators facecould face considerablediscussions with authoritiesduring subsequentimplementation, but withoutactually being able to achieveimprovements.

helene.lavray 54 Selected Text 5 1 3 692 BAT 17.In order toimprove the overallenvironmentalperformance of theincineration plant, BATis to set up andimplement operationalprocedures (e.g.organisation of thesupply chain, continuousrather than batchoperation, preventivemaintenance) to limit asfar as practicableshutdown and start-upoperations.

Major BAT 17: Delete BAT 17 Delete BAT 17 BAT 17 is not necessary and it isunclear how it would beimplemented. The BAT shouldbe removed. In principle,operational procedures arealready covered by BAT 1 andother BAT conclusions.

helene.lavray 55 Selected Text 5 1 3 692 identification of potentialOTNOC, of their rootcauses (e.g. failure ofemission abatementsystems, includingidentification ofequipment critical to theprotection of theenvironment ('criticalequipment')) and of theirpotential consequences,and regular review andupdate of the list ofidentified OTNOCfollowing the periodicassessmentbelow;appropriatedesign of criticalequipment (e.g.compartmentalisation ofthe bag filter,supplementary burnersto heat up the flue-gasand obviate the need tobypass the bag filter onstart-up, etc.);set-up andimplementation of apreventive maintenanceplan for criticalequipment;monitoringand recording ofemissions during

Major BAT 19 - Merge with BAT 6 concerning OTNOC Merge BAT 6 and 19 into one BAT. BAT 6 and 19 both targetOTNOCs.

helene.lavray 56 Selected Text 5 1 3 692 supplementary burnersto heat up the flue-gasand obviate the need tobypass the bag filter onstart-up

Major BAT 19: restrict general applicability of supplementaryburners

Include restriction of applicabilty tonew plants: "in case of new plantssupplementary burners to heat upthe flue-gas and obviate the need tobypass the bag filter on start-up"

It is not possible to fulfill thiscondition in existing plants whichwere designed with bypass todeal with dangerous operationalsituations (for example in casesof unintended pressureincreases)

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helene.lavray 57 Selected Text 5 1 4 693 oxygen-enrichedcombustion air.

Major BAT 21b: Delete the oxygen enrichement example inthe description.

BAT 21b: Delete the oxygenenrichement example in thedescription. Restrict Applicabilty ofBAT 21b to new plants.

From a system perspective,enriching combustion air withoxygen consumes more energythan gained through thereduction of flue gas. Thismeasure should not consideredto be a BAT measure forincreasing energy efficiency. Theexamples listed in BAT 21 bcannot be consired to be generally applicable for existingplants because the measurescannot be implemented withoutmajor changes to the plantand/or can cause excessivecosts. Hence, applicability ofBAT 21 b should be limited tonew plants.

That could not be a general BATfor existing plants.

helene.lavray 58 Selected Text 5 1 4 693 In the case of plantsdedicated to theincineration ofhazardous waste, theapplicability may belimited by

Major BAT 20: Extend limitation of applicability to all wastetypes.

Extend limitation of applicability to allwaste types: "Applicability: [..] TheApplicability may be limited by:.."

Applicability is not limited tohazardous waste. MSW, SS andother non-HW may also containcorrosive substances such aschlorine in the flue gas or havephysical fly ash propertiescomparable to hazardous wasteincinerators.

helene.lavray 59 Selected Text 5 1 4 693 Applicable within theconstraints associatedwith the availability oflow-grade heat

Major BAT 21 a. Thermal drying of sewage sludge: Extendapplicability restriction

Applicable within the constraintsassociated with the availability of low-grade heat and the requiredcombustion conditions with a view tomaintaining an optimal performanceof the boiler.

The applicability may be limitedby insufficient recoverable heatfrom the process, by the requiredcombustion conditions, or by thewaste moisture content.

helene.lavray 60 Selected Text 5 1 4 693 Applicable to new plantsand to major retrofits ofexisting plants

Major BAT 21 d: limit optimisation of the boiler design to newplants

Delete applicability to existing plants:"Applicable to new plants."

The definition of new plants (seepage 678) includes completereplacements of a plant. Inaddition, the term "majorretrofits" can not be preciselydefined. BAT 21 d should not beapplicable for "major retrofits ofexisting plants"

helene.lavray 61 Selected Text 5 1 4 694 Applicable within theconstraints associatedwith the local heat andpower demand

Major BAT 21g: Modify applicablity restriction. BAT 21g: Change applicabilityrestriction to "Applicable within theconstraints associated with the local heat and power demand as well asthe availability of distributionnetworks for power, heat andcooling."

The applicability of BAT 21g alsodepends on the availability ofdistrict heating and districtcooling networks.

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helene.lavray 62 Selected Text 5 1 4 694 Table 5.1:BAT-associated energyefficiency levels (BAT-AEELs) for incineration

Major BAT 21 - Table 5.1: Include separate BAT-AEELs forwood waste incinerators

Include new line in Table 5.1: woodwaste (WW): 25 - 35 for new plants;20 - 35 for existing plants. Changehigher end of the BAT-AEELs forexisting HW (excluding WW) from 32to 25. Change BAT-AELs for existingMSW and other non-HW (excl. WW)to 17 - 32.

Energy efficiency of dedicatedwood waste incinerators cannotbe compared with the complexityand plant layouts of otherhazardous waste incinerators orMSW incinerators. Wood wasteincinerators (WWI) use apermanently varying mix ofdifferent wood qualities, butcomparable LHV. In the datacollection, WWI should betreated equally regardless ofwood waste quality input(hazardous or non-hazardouscharacter). In particular,reference plants BE-11, DE-1,DE-2, DE-4, DE-5, DE-31, DE-32, DE-33, UK17, and UK19 aretypical WWI that should beexcluded from the derivation ofBAT-AEELs for MSW or HW.However, they should be usedfor deriving a specific BAT-AEELfor wood waste.

helene.lavray 63 Selected Text 5 1 4 694 Table 5.1:BAT-associated energyefficiency levels (BAT-AEELs) for incineration

Major BAT 21 - Table 5.1: BAT-AEELs for SS only indicative Extend footnote 5 to existing plantsusing sewage sludge; add statementthat gross electrical efficiency notonly depends on the water content,but also on the pretreatment of thesewage sludge (e.g. raw/untreated orrotted/digested) and the nature andshare of auxiliary fuel and othercomplimentary waste fuels used;include clarification in footnote 5 thatthe BAT-AEELs are only indicativefor sewage sludge.

The proposed BAT-AEELs forSS are only based on referenceplants applying FBC technology.In practice, a broad variety ofplant sizes and firingtechnologies are applied usingse-wage sludges of very differentwater content and LHV. Inparticular, reference plant DE-16(setting the higher range of theBAT-AEEPL) is an alonestanding large SS incineratorusing a broad range of publicand industrial sewage sludgesas well as sludges and otherresidues from the chemicalindustry. DE-16 is supplyingelectricity to the grid and is notassociated with a public wastewater treatment facility with itsown peculiarities and electricityand heat demand profiles.Hence, due to the limitedavailability of reference plantdata for SS incineration and thefact that gross electricity ishighly dependent on the watercontent and the pre-treatment ofthe sludge as well as thecomplimentary auxiliary fuel andother waste fuel input (seefootnote 5 to Table 5.1 of BAThelene.lavray 65 Selected Text 5 1 5 1 695 BAT 22 Major BAT 22 - include applicability restriction for wood waste Include restriction of applicability: not

generally applicable for storage ofwood waste

Sorted wood waste is notassociated with significant odouremissions and is often notstored in enclosed buildings.Waste wood incinerators forelectricity generation areincreasingly operated in line withthe electricity grid requirements.The provision minimising theamount of waste in storageduring shutdown periods shouldnot be applicable for waste woodincineration.

helene.lavray 66 Selected Text 5 1 5 1 695 BAT 23 Major BAT 23 - include applicability restriction concerningdirect injection of liquid sewage sludge

It should be clarified that BAT 23 isnot generally applicable for sewagesludge.

Allow for pre-mixing with otherwaste and/or pre-drying ofsewage sludge prior toincineration.

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helene.lavray 67 Selected Text 5 1 5 1 695 BAT 22. Major BAT 22: Adjust BAT 22 to the requirements for similarstorage and pre-treatment of waste in the BATC of WT-BREF for bulk waste storage and pre-treatment ofwaste.

BAT 22: Introduce the samerequirements for bulk storage andpre-treatmen of waste as proposedin the WT-BREF preFD (Seeproposed BAT23 and BAT24 in WT-BREF).

Avoid duplicative and potentiallyconflicting BREF requirementsfor alone-standing waste storageand waste treatment areas.

The proposed BAT 22 is notfeasible for plants where thestorage and pre treatmentresembles WT-plants withstorage and treatment at the site.It is not reasonable that BAT forstorage is not the same for WI-plant and WT-plants.

helene.lavray 68 Selected Text 5 1 5 1 695 BAT 22 Major BAT 22: Add further BAT techniques BAT 22: "BAT is to minimise theamount of waste in storage and/or touse an alternative abatementtechnique (e.g. a wet scrubber orchemical odour filter or biologicalodour filter) and/or to conduct theextracted air to stack."

Add further exemplary commontechniques to reduce diffuseand/or odour emissions oth thanwet scrubber.

helene.lavray 69 Selected Text 5 1 5 2 695 Generally applicable tonew plants and to majorretrofits of existingplants

Major BAT 24 should not be considered to be generallyapplicable for major retrofits of existing plants.

Restrict applicability of BAT 24:"Generally applicable to new plants"

The definition of new plants (seepage 678) includes completereplacements of a plant. Thelisted measures can only beused optimally in the design ofnew power stations. In existingpower plants, it is much moredifficult or even impossible toimplement these measures. Inaddition, the term "majorretrofits" can not be preciselydefined. BAT 24 should not beapplicable for "major retrofits ofexisting plants"

helene.lavray 70 Selected Text 5 1 5 2 695 BAT 24. Major BAT 24: Delete BAT 24 BAT 24: Delete BAT 24 Flow modelling is one out ofmany other techniques for plantdesign and optimisation. Ifintroduced as a specific BAT it isgiven too much attention inrelation to other methods andtechniques used in plant design.Flow modelling is not anappropriate method during theoperation of the plant; so itshould be clearly said that thisconcerns only the plant designand commissioning phases.Flow modelling in the designphase is not always necessary,but could be useful whendesigning e.g. an SNCR systemwith reagent injection.

helene.lavray 71 Selected Text 5 1 5 2 1 697 Table 5.2:BAT-associated emissionlevels (BAT-AELs) foremissions to air of dust,metals and metalloidsfrom incineration

Major BAT 26 - Table 5.2 (dust): Do not prescribe only bagfilter as BAT. Formulate BAT-AELs in a technology-neutral manner.

Change BAT-AEL-range for dust forall existing plants to 2 - 7 mg/m³. Forthis purpose modify footnote 1 toTable 5.2 as follows: The higher endof the BAT-AEL range is 7 mg/m³ forexisting plants."

According to BAT 26, bothtechnologies for reduction ofdust emissions, bag filter andESP, are BAT. BAT conclusionsshould not be prescriptive and,hence, not exclude certain BATtechnologies. The footnote 1 toTable 5.2 should be applicablefor all existing plantsdisregardless of technologyapplied.


Major BAT 26 - Table 5.2 (dust): Include derogation for smallexisting incinerators.

Extend footnote 7 for dust emissionsto existing plants (excluding HWother than WW) with a nominalcapacity of 12 tonnes per hour orless.

Footnote 7 should be extendedto accomodate all small wasteincinerators with a nominalcapacity of 12 tonnes per hour orless.

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Major BAT 26: Values at lower end of dust range cannot beproperly measured using available measurementequipment (AMS and SRM), systems and methodscompliant with CEN Standards, currently installed inorder to cover continuous monitoring and periodicmeasurements.

Insert additonal footnote for dust-BAT-AEL: "Lower end of the rangeshould be assessed considering ENstandard for measurement."

The LoQ and uncertaintyassociated with themeasurement have to be takenin account when setting the BAT-AEL range: identify theperformances of the monitoringtechniques available on themarket in accordance withcurrent EN Standard so to reviewlower end of the range asminimum achievable ELVs/BATAELs. The purpose of theBAT-AELs are to serve as marksfor ELVs in environmentalpermits. It must therefore bepossible for the operators toprove that they comply with theELVs set according to BAT-AELsin this document. For this reasonBAT-AELs must not be set onlevels that prevent successfullcalibration according toprescribed standards, given thelimitations of the methodsdescribed in these standards.(see JRC Reference Report onMonitoring of emissions to airand water from IED installations -Revised final draft July 2016)

helene.lavray 74 Selected Text 5 1 5 2 1 697 BAT 27 Major BAT 27: This BAT conclusion requires a majoroverhaul to make it feasible and relevant for both dryand wet treatment plants. Include a list of optional BATtechniques for dry ad wet treatment of slags andbottom ashes

BAT 27: Rewrite introductorysentence "In order to reduce dustemissions to air from the treatmentof slags and bottom ashes, BAT is touse one or an appropriatecombination of the techniques givenbelow". Include table with commonBAT techniques and applicabilityconsiderations dealing with thespecific characteristics of wet anddry treatments. Techniques: a. enclosed equipment at relevantpoints of dust emissions (e.g.crushing, sieving) b. keep enclosedequipment under negative pressure(not applicable for wet bottom ashtreatment facilities) c. treatment ofthe extracted air with a bag filter (notapplicable for sticky dust) d.treatment of the extracted air with acyclone e. ... etc.

The techniques described inBAT 27 are based on specifictypes of (dry) treatment ofbottom ash. Enclosement ofequipment as well as dustcapture and removal should onlybe required if relevant dustemissions occur. It should beclarified that BAT 27 is in thepresent form not applicable to storage and loading of materialon site or storage fieldsassociated with the slag andbottom ash treatment plant.Change the applicabilityaccordingly and/or introduceother techniques to reducediffuse emissions. Introduceother techniques that do notrequire enclosed equipment andchannelled emissions for othertreatment methods than the typeof plants listed in table 3.55.Introduce suitable applicabilityrestrictions for the requirement ofenclosed equipment bag-filtersfor treatment methods in the typeof plants listed in table 3.55.Theplant used as a bases for theproposed BAT is specific and notgenerally applicable to alltreatment of slags. Thehelene.lavray 75 Selected Text 5 1 5 2 2 697 Boiler sorbent injection Major BAT 28 e: include applicability restriction for boiler

sorbent injectionBAT 28 e: Boiler sorbent injection:"Only applicable to fluidised bedboilers"

Applicability of boiler injection isusually limited to fluidised bedboilers.

helene.lavray 76 Selected Text 5 1 5 2 2 698 Table 5.4:BAT-associated emissionlevels (BAT-AELs) foremissions to air of HCl,HF and SO2 fromincineration

Major BAT 28 - Averaging period: include clarification forperiodic measurement of HCl, HF and SO2

HCl, HF, SO2: Daily average oraverage over the sampling period

Clarify averaging period in casesof periodic measurement of HCl,HF or SO2.

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Major BAT 28 - BAT-AEL for HCl for existing plants Include additional footnote for HCl:"The higher end of the BAT-AELrange is 10 mg/m³ for existing plantsapplying dry abatement techniquesfor desulfurisation such as directdesulfurisation (in boiler), boilersorbent injection or dry sorbentinjection."

See reference plant n° DE 68and emission performance ofother FBC plants or otherincinerators applying drydesulfurisation techniques.WI Kick-off-meeting conclusions identified HCl as non-KEI.


Major BAT 28: Values at lower end of the HCl and HF rangecannot be propely measured using available equipment(AMS and SRM), systems and methods compliant with CEN Standards, currently installed in order to covercontinuous monitoring and periodic measurements.

remove footnote 1Insert additional footnote: "Lowerend of the range should be assessedconsidering EN standard formeasurement."

The LoQ and uncertaintyassociated with themeasurement have to be takenin account when setting BAT-AEL range: identify theperformances of the monitoringtechniques available on themarket in accordance withcurrent EN Standard so to reviewlower end of the range asminimum achievable ELVs/BATAELs. The purpose of theBAT-AELs are to serve as marksfor ELVs in environmentalpermits. It must therefore bepossible for the operators toprove that they comply with theELVs set according to BAT-AELsin this document. For this reasonBAT-AELs must not be set onlevels that prevent successfullcalibration according toprescribed standards, given thelimitations of the methodsdescribed in these standards.(see JRC Reference Report onMonitoring of emissions to airand water from IED installations -Revised final draft July 2016)


Major BAT 28: include footnote for HF in case of certain co-incineration plants fitted with wet FGD with adownstream gas-gas-heater

Insert additional footnote for HF: Inthe case of co-incineration plantsfitted with wet FGD with adownstream gas-gas heater, thehigher end of the BAT-AEL range is7 mg/Nm3

Consistency with LCP BREF.See LCP BREF BAT ConclusionBAT 21 - Table 5, footnote 3.WI Kick-off-meeting conclusions identified HF as non-KEI.

helene.lavray 80 Selected Text 5 1 5 2 3 698 Table 5.5:BAT-associated emissionlevels (BAT-AELs) forNOX and CO emissionsto air from incinerationand for NH3 emissionsfrom the use of SNCRand/or SCR

Major BAT 29 - Table 5.5 (NOx): Include derogation for smallincinerators.

Include further footnote for NOx insmall incinerators: The higher end ofthe BAT-AEL range is 150 mg/m³ fornew plants and 180 mg/m³ forexisting plants with a nominalcapacity of 12 tonnes per hour orless.

The application of SCR cannotconsidered to be generallyapplicable for small installationsdue to the excessive capitalcost.


Major BAT 29: CO emission levels should be considered asindicative emission values for existing co-incinerationplants.

Insert additional footnote concerningCO-BAT-AELs: "For existing co-incinerations plants, these levels areindicative."

Consistency with LCP BREF:see LCP BREF BAT Conclusion -BAT 20, CO indicative emissionlevel.WI Kick-off-meeting conclusions identified CO as non-KEI.

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Major BAT 29: Amend footnote concerning the lower end ofthe BAT-AEL range for NOx and increase the lowerend of the range for existing plants from 50 to 65mg/m³ in line with reference plant data collection.

Modify footnote (1): "The lower endof the BAT-AEL range can beachieved when using most advancedSCR systems design." For existingplants the lower end of the rangeshould be increased from 50 to 65mg/m³.

Footnote (1) to Table 5.5 shouldbe amended considering thecase of existing plants alreadyapplying SCR that cannotachieve so high performances inall operating conditions, andconsidering limitations for furtherretrofitting due to techno-economic reasons. Only a smallnumber of reference plantsreported NOx emissions at alevel below 65 mg/m3. Best-performing smaller plantsreported somewhat highervalues. Such plants are eitherrecent and newly commissionedplants (after 2000) in somecases applying SNCR and SCRin combination (e.g. IT 05). Insome cases, operators ofreference lines that reported verylow NOx emissions in the yearof data collection reportedsignificantly higher emissions ofother reference lines at the samesite applying the sametechnology for NOx reduction (e.DE 66-1 and 66-2). As a matterof principle, it can be expectedthat the lower BAT-AEL range ofexisting plants should besomewhat higher than the one ofhelene.lavray 83 Selected Text 5 1 5 2 3 698 Table 5.5:BAT-

associated emissionlevels (BAT-AELs) forNOX and CO emissionsto air from incinerationand for NH3 emissionsfrom the use of SNCRand/or SCR

Major BAT 29: Change averaging period for NH3 Change averaging period for NH3 to:"Daily average or average over thesampling period."

See comment to BAT 5concerning period measurementof NH3 in certain cases in linewith IED provisions.

helene.lavray 84 Selected Text 5 1 5 2 3 699 Selective catalyticreduction (SCR)

Major BAT 29 e: extend applicability restriction to technicaland economic restrictions

BAT 29 e: Change text ofapplicability restriction: "There maybe technical and economicrestrictions for retrofitting existingcombustion plants. Retrofittingexisting combustion plants may beconstrained by the availability ofsufficient space."

Applicability restrictions for SCRretrofitting are describedinsufficiently. Technicalconstraints may include amongothers space restrictions andwaste characteristics. See alsoapplicability restrictions for SCRretrofitting in BREF LCP BAT-conclusions for solid and liquidfuels. In general, SCR retrofittingis not proportionate for existingplants fitted with SNCRtechnology.


Major BAT 29 - Table 5.5: Extend footnote 4 concerning NH3to plants fitted with SCR but not with wet abatementtechnique

Footnote (4): For existing plantsfitted with SNCR or SCR without wetabatement techniques, the higherend of the BAT-AEL range is 15mg/Nm3.

helene.lavray 86 Selected Text 5 1 5 2 4 699 BAT 30 Major BAT 30: allow for selection of techniques for reductionof PCDD/F and PCBs

Rewrite introduction to BAT 30: "Inorder to reduce emissions of organiccompounds including PCDD/F andDioxin-like PCBs from theincineration of waste, BAT is to usean appropriate combination oftechniques (a) to (i) given below."

The BAT conclusion should notbe too prescriptive, but leaveflexibility to the operator to findthe appropriate combination oftechniques associated with BAT.

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helene.lavray 87 Selected Text 5 1 5 2 4 699 Knowledge and controlof the specifications ofthe waste being fed intothe incinerationchamber, including theircombustioncharacteristics, toensure homogeneous,stable and optimalincineration conditions

Major BAT 30 b: Reword description BAT 30 b: Reword description:"Knowledge and control of thewastes being fed into the incinerationchamber, including their combustioncharcteristics, to ensure stable andoptimal incineration conditions."

Many waste incineration plantsare designed to incinerateinhomogeneous residual wastethat remains after separation torecycling and as a reject fromindustries.

helene.lavray 88 Selected Text 5 1 5 2 4 699 Flue-gas quenching Major BAT 30 d: restrict applicability to new plants and allowfor other techniques with similiar effect

Restrict applicability of "flue-gasquenching" to new plants. Allow forother techniques serving a similiarpurpose: "Use a design that certifiesa quick passage through the criticaltemperature window." without naminga specific technical design.

Flue-gas quenching is notpossible in existing plants, andgenerally ruins the energyefficiency of the plant. There areother ways to obtain the intendedgoal of this measure. Quenchingwill also result in higher flue gasflows and counteracts targets onhigh energy and resourceefficiency.

helene.lavray 89 Selected Text 5 1 5 2 5 700 A wet scrubber operatedat a pH value below 1.

Major BAT 31 a: Change text regarding pH value. Change BAT 31 a to: "A wetscrubber operated at a pH value ofapproximately 1."

Although some wet scrubbersmay be operated with pH<1,others do fine with values slightlyabove 1. Low pH increases thehealth risk for staff and shouldbe avoided when possible.

helene.lavray 90 Selected Text 5 1 5 2 5 700 Boiler bromine addition Major BAT 31 b: restrict applicabilty of bromine addition. Limit applicability to the types ofincineration plants and wastes wherethe technique has successfully betested (i.e. rotary kilns and fluizedbed combustion of sewage sludge).Also take into consideration theknown and potential cros-mediaeffects and technical limitationswhen describing the applicability. Forexample is the technique notrelevant for plants burning waste witha high chlorine content. Update thecross-media effects section ofChapter 4.5.6.7 (p. 619), accordingly.

Br is well known for damagingthe filter bags in bag filters.Moreover, the risk of forming Br-dioxins is poorly studied. It alsocause an increase in chemicalconsumption and may causeproblems for processes aimingat utilising the fly ash. Also, theemission of Br2, a highlypoisonous gas may occur due todifferent oxidative equilibriumthan what is found in some coalor waste combustion plants. Thetechnique is not generally usedin waste incineration plants andthus not a general BAT. Onlytested on rotary and FB. Theprecautionary principle shoud betaken into concideration. Thesientific bases to determineenvironmental benefits and down-sides of the technique isinsufficient, as well as theknowledge of the technical andeconomical limitations of thetechnique. Taking the above inconsideration, there is no soundbase to classify the technique asa generally applicable BAT.

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helene.lavray 91 Selected Text 5 1 5 2 5 701 Table 5.7:BAT-associated emissionlevels (BAT-AELs) foremissions of mercury toair from incineration

Major BAT 31: Remove the indicative half-houly values formercury from Chapter 5.

Delete or move this information onindicative values to Chapter 3.

It has been agreed by the TWGnot to provide half-houlyemission values (BAT-AELs)and this was also mentioned inthe background documentsprovided by EIPPCB with WIBREF D1. Even if the emissionlevels are supposed to be onlyindicative, this provision it thusmisleading in Chapter 5including the binding BATconclusions and should bemoved to Chapter 3. Thedetermined emission ranges forHg must take into account thatincreased Hg emissions mayoccasionally occurr due tounrecognized Hg-containinginputs in the waste. The eventsare rarely classified, but theimpact of such events must bereflected in the BAT-AEL rangedetermination.helene.lavray 92 Selected Text 5 1 6 703 Table 5.8:BAT-AELs for

direct emissions to areceiving water body

Major BAT 34: Include '4 of 5 measuring method' Table 5.8: Change heading of thefourth column: "BAT-AEL (dailyaverage or 4 out of 5 measuringmethod)"

According to BAT 34, for wastewater flows from flue gascleaning the sample duration hasto be based on a daily meanvalue. However, otherapproaches commonly used inEurope should be enabled. Inparticular, the '4 out of 5measuring method should bementioned.

helene.lavray 93 Selected Text 5 1 6 702 BAT 33. Major BAT 33: Include common practice to deliver wastewater to an external waste water treatment plant

Include letter d (new): "d. supply ofwaste water to an external wastewater treatment plant, equipped withappropriate techniques"

BAT 33 should take into accountthat some plant operators do nottreat their waste water within theinstallation boundaries, butdeliver them to an external wastewater treatment plant. The extentof the treatment of wastewaterfrom wet flue gasdesulphurisation is specificallydependent on the local boundaryconditions at the site of thewaste incineration plant andextends from the proceduredescribed under c up to theaddition of wastewater to anexternal sewage treatment plant.

helene.lavray 94 Selected Text 5 1 6 702 BAT 33.In order toreduce water usage andto prevent or reduce thegeneration of wastewater from theincineration plant, BATis to use one or acombination of thetechniques given below

Major BAT 33: Allow for other measures achieving acomparable level of environmental protection.

Change wording of the title: "In orderto reduce water usage and toprevent or reduce the generation ofwaste water form the incinerationplant, BAT is e.g. to use one or a acombination of the techniques givenbelow or other equivalenttechniques."

The given technique options (a,band c) represent a number of notexhaustive examples of thetechniques that might be used toreduce water usage and toprevent waste water generation.Other equivalent techniquesshould also be allowed insteadof those 3 mentioned in BAT 33.

helene.lavray 95 Selected Text 5 1 6 703 Table 5.8:BAT-AELs fordirect emissions to areceiving water body

Major BAT 34: Limit TOC BAT-AEL to bottom ash treatment Delete reference to FGC, establishBAT-AEL for TOC only for bottomash treatment

Consistency with IED Annex VI.TOC measurement is notrequired for waste water fromFGC.

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TWG coments

helene.lavray 96 Selected Text 5 1 7 703 BAT 35.In order toincrease resourceefficiency and improvethe recovery of usefulmaterials from theincineration residues,BAT is to handle andtreat bottom ashesseparately from flyashes and from otherFGC residues, and touse a combination of thetechniques given below.

Major BAT 35: Do not require seperate handling of bottomashes in all cases

Change introductory sentence ofBAT 35: "In order to increaseresource efficiency and improve therecovery of useful materials from theincineration residues, BAT is to useone or an appropriate combination ofthe techniques given below."Add new BAT technique: "Handleand treat bottom ashes separatelyfrom fly ashes and from other FGCresidues with applicability: Generallyapplicable for new plants, applicablefor existing plants subject to techno-economic restrictions and flue-gascleaning system configuration."

To handle and treat bottomashes separately from fly ashesand from other FGC residues isproblematic from techno-economic perspective forexisting plants designed for jointmanagement of these materials.This BAT technique should notbe mandatory but rather one ofthe listed possibilities.

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