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10.7 EU Directive (2000/76/EC)

The EIA report in an attempt to allay the impacts on human health of gaseous emissions from the proposed WTE Plant, has adopted the emissions standards as stated in EU Directive (2000/76/EC) and proposed state of the art air pollution
control technologies.

The EIA report fails to recognise that proper control of air emissions requires more than the presence of state of the art air pollution control technologies. MSW incineration facilities must be well operated and well maintained to ensure that the objectives of lower emissions of pollutants are achieved. Combustion practices can control emission by ensuring that the temperature in the combustion chamber and the time the MSW remains in the combustion chamber are kept at optimal levels. Major variations in these or other incineration process operations, for example during start up, shut down and upset conditions, will lead to significant higher emission rates than under steady state conditions.

The EU Directive (2000/76/EC) on incineration of wastes covers both the incineration of hazardous wastes (formerly Directive 94/67/EC) and non-hazardous wastes (formerly Directives 89/369/EEC and 89/429/EEC).

Essentially EU Directive (2000/76/EC) introduces stricter provisions than those found in the former Directives, inter alia:

• It sets up new lower limit values for gaseous emissions and introduces Dioxins as a new parameter for discharges into water;
• It control releases not only to the atmosphere but also sets out emission standards and conditions for discharges of wastewater to the aquatic environment so as to minimise the impacts of incineration on marine and fresh water ecosystems;
• It stipulates that residues from the combustion process must be minimised in their amount of harmfulness and recycled where appropriate and if not possible disposed of only under certain conditions;
• It provides for public consultation, access to information and participation into the permitting procedure;
• It envisages procedures for the application and granting of operating permits and sets a series of operating conditions.

The EU legislators having recognised that strict lower emission standards for pollutants released during MSW incineration are necessary to reduce risks to the environment and human health went to the extent of specifying stringent operational conditions and technical requirements to ensure that these standards are achievable.

The distinction between hazardous and non-hazardous waste is based principally on the properties of the waste prior to incineration or co-incineration but not on the
differences in emissions. The same emission limit values should apply to the incineration or co-incineration of hazardous and non-hazardous wastes waste but different techniques and conditions of incineration or co-incineration and different monitoring measures upon reception of waste should be retained.55

• Operational Conditions and Technical Requirements for Incineration of MSW
With regard to incineration of MSW waste, the operational conditions and technical requirements are clearly spelt out and these include:

o The definition of municipal waste and fractions that are excluded;
o The delivery and reception of wastes;
o Operating conditions with specifications on the temperature of the combustion gases and how to maintain the temperature during start up and shut down;

o EU Directive clearly states that the incinerator shall have and operate an
automatic system to prevent waste feed (Article 6 (3)):

(a) at start up until the temperature of 850oC or 1100oC as the case may be or the temperature specified according to paragraph 4 has been reached;
(b) whenever the temperature of 850oC or 1100oC as the case may be or the temperature specified according to paragraph (4) is not maintained;
(c) whenever the continuous measurements required by this Directive show that any emission limit value is exceeded due to disturbances or failures of the purification devices.

o Management of residues;
o Control and monitoring and the measurement requirements among others.

The EIA Report seems to suggest that the maximum limits set out in the EU Directives are stringent enough whereas Clause 13 of the said Directive clearly spells out that “Compliance with the emission limit laid down by this Directive should be regarded as a necessary but not sufficient condition for compliance56 with the requirements of Directive 96/61/EC. The Directive further states that “such compliance may involve more stringent emissions limit values for the pollutants envisaged by this Directive, emission limit values for other substances and other media, and other appropriate conditions”.

Conclusion:
Although the EIA report has adopted the EU standards for gaseous emissions as stated in EU Directive (2000/EC/76), yet it fails to recognise that proper control of air emissions requires more than the presence of state of the art air pollution control technologies. Operational conditions and technical requirements are specified in the EU Directive so as to ascertain that the strict emission standards are achieved for waste incineration.

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55 EU Directive (2000/EC/76) (16) pL332/92
56 Bold and underline for emphasis.

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