With a number of EU states developing their own end-of-waste criteria for waste derived fuels, European associations with a stake in waste management, including the Confederation of European Waste-to-Energy Plants (CEWEP), have urged the European Commission to ensure that Refuse Derived Fuel (RDF) and Solid Recovered Fuel (SRF) from waste remain under the control of waste legislation.
According to the associations this is an essential requirement for the application of the strict emissions and monitoring rules set in EU air policy and Best Available Techniques for waste incineration and waste co-incineration.
It was also said to be central to the application of the EU Waste Shipment Regulation, as are the necessary controls over the destination and where waste might end up as a feedstock.
This issue is being raised in light of the increasing number of Member States that are developing their own national criteria for the End-of-Waste status of SRF and RDF which means that strict waste legislation would thereby not apply.
The organisations consist of CEWEP, European Suppliers of Waste-to-Energy Technology (ESWET), Municipal Waste Europe (MWE) and CEMBUREAU – The European Cement Association.
The associations said that strict EU air laws must also apply to waste derived fuels .
Waste incineration and waste co-incineration must comply with emission control and abatement techniques set in the EU Industrial Emissions Directive for waste incineration and co-incineration, as well as the relevant Best Available Techniques.
The organisations warned that if SRF/RDF were to no longer be viewed as a waste it could be burned in facilities that do not need to comply with the specific, strict requirements applied to installations using waste.
“The application of waste legislation will prevent damage to health and the environment from the burning of heterogeneous material in poorly designed boilers and unregulated facilities lacking proper flue gas treatment or in plants not complying with Best Available Techniques for waste incineration and waste co-incineration,” CEWEP said in a statement.
It was therefore said to be essential that SRF/RDF continues to be burned in facilities that comply with the requirements for waste incineration and waste co-incineration, providing a high level of environmental protection as required by the Waste Framework Directive for End-of-Waste criteria (Recital 22), and ensuring that this will not lead to overall adverse environmental or human health impacts (Article 6(1)(d) Waste Framework Directive).
Further, the organisations said that EU Waste Shipment Regulation must apply to trace waste derived fuels.
The EU Waste Shipment Regulation ensures that transboundary shipments of waste are notified and controlled by the competent authorities. The organisations said that industry is concerned about the impact that national initiatives, classifying SRF or RDF as End-of-Waste (therefore a “product”) can have on the traceability and control of transboundary shipments.
Dilution of the classification of SRF/RDF to “Green Listed” waste, which does not require prior notification, would also make tracking and control of this material more difficult and could potentially be exploited by unscrupulous operators.
Letter to the Commission
A letter sent by the organisations can be read below.
SUBJECT: Requirement for consistent application of pollution prevention by ensuring that Waste Derived Fuels (SRF and RDF) comply with strict waste rules and are NOT a candidate for End-of-Waste (EoW).
Over the last three decades, the European Union has created and adopted environmental legislation on waste handling and treatment, with the specific purpose of protecting health and the environment. National decisions by Member States which allow the circumvention of this legislation could grow uncontrollably, with the potential for negative environmental impacts if this important topic is not comprehensively addressed.
Signatories to this letter raise the issue that an increasing number of Member States are developing their own national criteria for the End-of-Waste (EoW) status of Solid Recovered Fuels (SRF) and Refuse Derived Fuels (RDF). We are keen to ensure that these national initiatives comply with the conditions that are set out in Article 6(1) of the Waste Framework Directive (WFD) as well as the emission limit values encompassed in the Waste Incineration Directive 2000/76/EC (now part of the Industrial Emissions Directive 2010/75/EU) and the techniques described in the respective Best Available Technique Reference documents as well as the Waste Shipment Regulation EC (No) 1013/2006.
Our particular concerns regarding this issue are set out below.
Incineration and co-incineration of SRF and RDF help to replace fossil fuels and divert waste from landfills. The Industrial Emissions Directive (chapter IV in connection with Annex VI) sets strict environmental requirements, that have to be applied by dedicated Waste-to-Energy incineration plants and industrial plants (e.g. cement kilns) that co-incinerate waste.
The Waste Shipment Regulation makes sure that transboundary shipments of waste are notified and controlled by the competent authorities. We are concerned about the impact that national initiatives, classifying SRF or RDF as EoW (therefore a “product”) can have on the traceability and control of transboundary waste shipments set in the Waste Shipment Regulation. Dilution of the classification of SRF/RDF to become “Green List” waste, not requiring prior notification, would also make tracking and control of this material more difficult and could potentially be exploited by unscrupulous operators.
In addition, incineration and co-incineration of SRF/RDF as EoW (i.e. as a “product”), would NOT fall under the scope of the Industrial Emissions Directive’s provisions for waste incineration and waste co-incineration plants. Therefore operators of other facilities would not have to meet the same strict emission limit values and monitoring requirements set in this Directive.
Waste incineration and waste co-incineration need to comply with emission control and abatement techniques according to European air pollution legislation and Best Available Techniques.
No-longer-waste SRF/RDF however can be burnt in facilities that do not need to comply with the specific, strict requirements for installations using waste. They could be used as fuel in any facility, or even in homes, which could thereby generate the high levels of harmful emissions that the Industrial Emissions Directive seeks to prevent through its strict controls and emission limits.
We cannot underline enough the enormous importance that waste status is not lifted for SRF/RDF. Although modern pre-treatment techniques in combination with reliable quality surveillance systems can change the characteristics (e.g. the calorific value) of RDF and especially SRF, these materials should nevertheless remain in the waste regime. Only a treatment conforming to Best Available Techniques set for waste incineration and waste co-incineration, ensuring pollutant emissions can be controlled and minimised, can safeguard an environmentally safe recovery process.
Laboratory analyses by the Austrian Environmental Protection Agency indicated “that sufficiently good qualities [of waste derived fuels] cannot be produced from mixed non-haz[ardous] waste that is able to fulfil standards and specifications for EoW. If incinerated as non-waste [i.e. EoW] in plants outside the Waste Incineration Directive scope, higher air emissions have to be expected”.
It is essential therefore, that SRF/RDF continues to be burnt in facilities that comply with the requirements of the Industrial Emission Directive for waste incineration and waste co-incineration, providing a high level of environmental protection as required by the Waste Framework Directive for End-of-Waste criteria (Recital 22 WFD), ensuring that this would not lead to overall adverse environmental or human health impacts (Article 6(1)(d) WFD).
The application of waste legislation will prevent damage to health and the environment from the burning of heterogeneous material in poorly designed boilers and unregulated facilities lacking proper flue gas treatment or in non-Best Available Techniques (for waste incineration and waste co-incineration) plants which are unable to control and minimise pollutant emissions.
Any classification of SRF/RDF should include necessary controls over its destination and where it might end up as a feedstock. This is ensured by the application of the Waste Shipment Regulation and its provision for notification of transboundary waste shipments.
Therefore, we urge the European decision makers to ensure that SRF and RDF meet the requirements in relation to traceability, control of transboundary waste shipments and comply with air pollution control legislation and Best Available Techniques as set for waste incineration and co-incineration. This would avoid an overall adverse human health or environmental impact which Article 6(1)(d) of the WFD has been constructed to protect.
We urge the European the European Commission to ensure that SRF/RDF always remains under the control of waste legislation.
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