Data gathering and impact assessment for a review and possible widening of

the scope of the IPPC Directive in relation to waste treatment activitiesFinal report

Fact sheet E2 – Pre-treatment of combustible waste for co-incineration

Potential amendment E2 – Pre-treatment of Combustible Waste for Co-incineration

1.Issue

Aim of the study: The present work intends to identify the issues related to the possible extension of the IPPC Directive to installations which pre-treat combustible waste for co-incineration. This analysis focuses on the problem and scope definition. It also provides estimates of the environmental impacts and size of sector.Options for including this sector within the scope of the IPPC Directive are then defined and their impact is assessed. The present study is based on background literature survey, waste workshop discussions, interviews with industries and associations and responses of the Member States to the questionnaire that was sent for the purpose of this study.It also takes into account the comments of the Advisory Group members on the draft final report.
Background: The overall objective is to have a better definition and a clearer outline of waste activities in the IPPC Directive, taking account of the dispositions of the Waste Framework Directive. The evaluation of a possible extension of the IPPC Directive to other waste treatment activities forms the basis for reaching this objective. The pre-treatment of combustible waste for co-incineration is a potential candidate for such an inclusion.
Issue summary: Until now, the installations for the pre-treatment of combustible waste for co-incineration are regulated under the IPPC Directive only if they are part of an installation covered by the directive. Currently, separate installations for the pre-treatment of waste for incineration are covered by the IPPCDirective whereas those for co-incineration are not. A preliminary study [EPEC 2005] classifies these installations as installations with significant environmental impact. The present study aims to focus on independent facilities dedicated to pre-treatment of waste to be used as fuel in co-incineration combustion processes.In EU-15, 9 million tonnes of waste derived fuels are produced in more than 250 installations. However, little information is available to determine whether these installations are stand-alone facilities.
The options considered for a potential inclusion of this sector within the IPPC Directive are to include installations that are above the thresholds already used in the IPPC Directive for waste treatment activities and which depend on whether the waste is hazardous or not.

2.Background Information

2.1Purpose of treating waste to recover a fuel

Under the current pressure due to European Directives and international conjuncture, there is a tendency toward alternatives to fossil fuel, which in turn, contributes to a decrease of the global CO2 emissions. The use of alternative fuels produced from waste in co-incineration processes in cement kilns started in the mid seventies when the petroleum crisis drastically increased the cost of fuel oil and when, in different countries, new regulations were issued on waste management [EUCOPRO].

2.2Understanding of the current legislation

Annex I-5 of IPPC Directive: “Waste management” activities

  • Paragraph 5.1

“Installations for the disposal or recovery of hazardous waste as defined in the list referred to in Article 1 (4) of Directive 91/689/EEC, as defined in Annexes II A and II B (operations R1, R5, R6, R8 and R9) to Directive 75/ 442/EEC and in Council Directive 75/439/EEC of 16 June 1975 on the disposal of waste oils, with a capacity exceeding 10 tonnes per day”.

  • Paragraph 5.3

“Installations for the disposal of non-hazardous waste as defined in Annex II-A to Directive 75/442/EEC under headings D8 and D9, with a capacity exceeding 50 tonnes per day”

Annex I of Waste Framework Directive 75/ 442/EEC

  • Annex II A – Disposal operations

“NB: This Annex is intended to list disposal operations such as they occur in practice. In accordance with Article 4 waste must be disposed of without endangering human health and without the use of processes or methods likely to harm the environment.

D 1 – Deposit into or onto land (e.g. landfill, etc.)

(…)

D 8 – Biological treatment not specified elsewhere in this Annex which results in final compounds or mixtures which are discarded by means of any of the operations numbered D 1 to D 12

D 9 – Physico-chemical treatment not specified elsewhere in this Annex which results in final compounds or mixtures which are discarded by means of any of the operations numbered D 1 to D 12 (e.g. evaporation, drying, calcination, etc.)

D 10 – Incineration on land

D 11 – Incineration at sea

D 12 – Permanent storage (e.g. emplacement of containers in a mine, etc.)

D 13 – Blending or mixing prior to submission to any of the operations numbered D 1 to D 12

D 14 – Repackaging prior to submission to any of the operations numbered D 1 to D 13

D 15 – Storage pending any of the operations numbered D 1 to D 14 (excluding temporary storage, pending collection, on the site where it is produced).”

  • Annex II B – Recovery operations

“NB: This Annex is intended to list recovery operations as they occur in practice. In accordance with Article 4, waste must be recovered without endangering human health and without the use of processes or methods likely to harm the environment.

R1 – Use principally as fuel or other means to generate energy

(…)

R5 – Recycling/reclamation of other inorganic materials

R6 – Regeneration of acids or bases

(…)

R8 – Recovery of components from catalysts

R9 – Oil re-refining or other reuses of oil.”

Conclusion on the activities covered under §5.1 and §5.3 of Annex I

The installations for the “biological treatment”, “physico-chemical treatment”, “blending” and “mixing” of “hazardous waste” prior to “incineration on land” are covered by the IPPC Directive when they treat “more than 10 tonnes/day of waste”.

In addition, the installations for the recovery option consisting in “using waste as fuel or other mean to generate energy” and in “oil re-refining or reusing of oil by other mean” from “hazardous waste” and that treat “more than 10 tonnes/day of waste” are covered by the IPPC Directive.

Further, the installations for the “biological treatment” and “physico-chemical treatment” of “non-hazardous waste” for the purpose of “incineration on land” and that treat more than “50 tonnes/day of waste” are covered by the IPPC Directive.

Several interpretations of the Annex I-5.1 of the IPPC Directive exist in practice:

  • According to a representative of EUCOPRO, the European Association for Co-Processing, the most common practice is that independent installations for the pre-treatment of hazardous waste with a capacity exceeding 10 tonnes per day are covered under the national transposition of the IPPC Directive.
  • The EPEC report states that “Preparation for recovery [of hazardous waste] is covered in Waste TreatmentBREF although it is not crystal clear that such activities are covered by the IPPC Directive” [EPEC 2005].

Regarding the pre-treatment of non-hazardous waste, pre-treatment by the mean of biological or physico-chemical treatment of waste is clearly covered by the Directive when the output of such treatments are disposed of or incinerated, but is clearly not covered when the output is co-incinerated.

The BREF document on Waste Treatment does not present an interpretation of the Directive. In order to be as complete as possible, the TWG chose to cover a broad range of activities.Therefore, the WT BREF presents a lot of pre-treatments of both hazardous and non-hazardous waste streams,for the production of a fuel that is suitable for both incineration and co-incineration.

During the waste workshop on 26 January 2007 inBrussels, it was noted that the pre-treatment of hazardous waste is not explicitly covered by the IPPC Directive.

There is also no clear reason why biological treatment for disposal has been included in IPPC, while biological treatment for recovery has not.

In addition, the interpretation of the current status of pre-treatment of waste for (co-) incineration was discussed and appears not to be clear. The following points were clarified:

  • The treatment of hazardous waste and waste oils for incineration is covered by Annex I-5.1.
  • Technically, the treatment of waste for the purpose of incineration and co-incineration do not differ. Therefore, it seems logical to cover the treatment of hazardous wastes for co-incineration under IPPC.
  • Mechanical-biological treatment of non-hazardous waste (municipal solid waste, commercial and industrial waste) for incineration seems to be covered by Annex I-5.3 (activity D8 and D9 in connection to operation D10). Therefore, it is argued that the treatment of non-hazardous wastes for co-incineration should fall as well under IPPC, as treatments are similar.
  • Treatment of specific non-hazardous waste fractions such as tyres, plastics, textile, sewage sludge, wood, can be excluded from further analysis by simple judgement based on the fact that identical operations have already been looked at as separate potential amendments.

Summary of key elements about the understanding of the current legislation useful for this exercise
Installations for the pre-treatment of combustible waste for incineration are currently covered by the IPPC Directive.
However, Annex I of the Directive refers to the R&D codes of the Waste Framework Directive, which raises interpretation issues.Thus, in some countries, installations for the pre-treatment of combustible waste for co-incineration, which are not covered by the IPPC Directive, are covered under its national transposition in several Member States, especially for hazardous waste. These installations are nevertheless within the scope of this study, as they are not listed in Annex I of the Directive.

2.3Useful definitions

The purpose of this document is not to provide any interpretation of the Directive itself regarding the R and D codes of the WFD.

Moreover, no consideration on the waste status or not of materials will be provided. In addition, this document is not intended to provide any classification of waste regarding their hazardous characteristics.

In order to avoid any misunderstanding, useful definitions are provided hereafter.

Waste derived fuel: fuel resulting from the pre-treatment.

Pre-treatment:process to produce a waste derived fuel through the treatment of waste.

Substitution or alternative fuel: waste derived fuel that is used in combustion process in addition or substitution to traditional fuels such as oil and gas.

Incineration of waste:thermal treatment of wastes with or without recovery of the combustion heat generated

Co-incineration of waste:use of wastes as a regular or additional fuel or thermal treatment of waste for the purpose of disposal in installation whose main purpose is the generation of energy or production of material products.

3.Current practice

3.1Scope of the sector

Structure of the waste pre-treatment sector

There are many types of waste and many existing treatments to recover a fuel. The technique applied to pre-treat waste streams determines the fuel property (e.g. its calorific value) and thus the possible end-users.

The key parameters that determine the quality of the (waste) fuel are [Juniper 2005]:

-Calorific (or heating) value;

-Moisture content;

-Ash content;

-Chemical composition;

-Heavy metal content.

The present study focuses on independent facilities dedicated to the pre-treatment of waste to produce a waste derived fuel suitable to be used as alternative fuel in co-incineration processes.

The following figure provides the existing routes for the management of combustible waste.

Figure 1: Management of combustible waste

Among the possible routes for combustible waste (see Figure 1), only the ones leading to co-incineration are of interest (orange routes in Figure 1).

On-site pre-treatment plants (black dashed box in Figure 1) are out of the present scope and may already be covered by the IPPC Directive if the co-incineration installation (e.g. cement kiln) is covered. The preparation of waste derived fuel intended to be used in installations dedicated to the incineration of waste (blue dashed box in Figure 1) is also out of the scope.

This study will focus on installations dealing with pre-treatment plants upstream the co-incineration facilities (orange dashed circle in Figure 1).

Scope of the sector

The sector of the pre-treatment of combustible waste for co-incineration appears to be largely diversified. There is nearly one treatment process for each type of combustible waste.

-Type of waste to consider for the production of fuel

There are several types of waste that can be treated in order to produce a fuel, namely:

Municipal Solid Waste (MSW);

Construction and Demolition Waste (C&DW);

Commercial waste (including waste oil from restaurants);

Industrial waste (including waste oil, sewage sludge, adsorbent, solvents, paint and ink, oil sludge, saw dust);

Others (including waste wood, tyre, textiles, animals meals and fat);

Etc...

-Type of treatments to consider for the production of fuel

There are several types of treatment that can be involved in the production of fuel from waste, namely:

Gasification;

Mild re-processing;

Severe reprocessing;

Thermal cracking;

Hydrogenation;

Preparation of biodiesel;

Blending;

Fluidification;

Preparation of emulsion;

Mechanical treatment (MT);

Shredding;

Grinding;

Mechanical Biological Treatment (MBT);

Carbonisation;

Drying;

Etc...

Treatments that can be used for each type of waste are provided in Annex B.

-Scope reduction

As explained above, the sector of the pre-treatment of combustible waste for co-incineration covers a lot of waste streams and a lot of processes. However, some of these processes are already clearly covered by the Directive as Annex I activity or they are already considered by other potential amendments in the review of the Directive.

In addition, some treatments are applied to small quantities of waste. They will be excluded from the present work.

Table 1below provides the list of treatments that will not be considered under this study (either because the activity is already covered or to be studied in other IPPC review studies or because no data have been identified, suggesting that the quantities are quite small compared to other treatments).

Table 1: Reasons for excluding some processes from the present study

Waste / Treatment / IPPC relation / Other
Animal meals and fat, bone meal / Rendering / Annex I-6.5[1] if > 10 tonnes/day
Tyres and rubber / Shredding / IPPC review: shredding of tyres has little impact[2]
MBT / no data identified
Plastics / Shredding / IPPC review: shredding of plastics has little impact[3]
MBT / no data identified
Textiles / MBT / no data identified
Waste wood / MT / IPPC review: recycling of wood has little impact
Contaminated waste wood / Carbonisation / no data identified
C&DW, commercial and industrial waste / - MBT
- MT / no data identified
Waste oils / Preparation of biodiesel / IPPC review phase II–Biofuels
Sewage sludge / Drying / IPPC review: sewage sludge treatment has little impact[4]

Scope of the present study

Consequently, the remaining treatments of waste to produce fuel are provided inTable 2.

Table 2: Treatments to consider in this study

Waste / Treatments / Output
MSW / - Mechanical Biological Treatment (MBT)
- Mechanical Treatment (MT) / Solid waste derived fuel
waste oils / - gasification
- thermal cracking
- hydrogenation / Gaseous waste derived fuel
- mild re-processing
- severe reprocessing
- thermal cracking / Liquid waste derived fuel
saw dust / MT / Solid waste derived fuel
Adsorbent
waste oil / - blending
- fluidification
- preparation of emulsion / Liquid waste derived fuel
solvents and others
oil sludge
paint/ink sludge
  • MBT of MSW

Mechanical-Biological-Treatment consists in the partial processing of municipal solid waste by mechanically removing some parts of the waste and by biologically treating others. The residual fraction is smaller, more stable, and more suitable for a number of possible uses, compared to the input waste.

MBT is thus a two-stage process:

  1. Mechanical treatment: this consists in sorting, separation, size reduction and sieving technologies in varying configurations to achieve a mechanical separation of waste fractions into potentially useful products and/or streams suitable for biological processing.
  2. Biological treatment: it consists in aerobic or anaerobic biological processing in order to convert the biodegradable waste fraction into a compost-like output and (in case of anaerobic digestion) biogas. Biological digestion is intended to reduce the weight of organic material and to inactivate any biologically active organic material.

Some of the practical advantages of MBT include the reduction of the volumes of waste and the reduction of the organic matter content of the waste (that is sent to final disposal such as landfill or incineration) [EC 2006] [Juniper 2005].

Depending upon the type of the biological treatment, the outputs from the MBT vary. The main MBT and the associated output are provided in Annex C.

Figure 2 below provides the possible uses of the outputs of the treatments of municipal solid waste by mechanical biological treatment.

Figure 2: Outputs of the MBT of MSW

Source: adapted from [EC 2006] and [Juniper 2005]

Annex Dprovides several examples of applications of the outputs from MBT (applications for biogas, compost, solid fuel and landfill). The key issues limiting the applicability of the outputs are also provided in this annex.

  • MT of municipal solid waste

Mechanical treatments of waste are similar to the mechanical treatment stages in MBT processes.

  • Treatments of waste oils

Figure 3 below present the treatments of waste oils that are considered within the scope of this study.

Figure 3: Treatments of waste oils to produce fuel considered in this study

Source: adapted from [EC 2006] and [Juniper 2005]

Note: the re-refining of waste oils is excluded from the present study, as this process is intended to recover oil from waste. The output of such a process is oil rather than waste derived fuel.

-Thermal cracking

The principle of thermal cracking is to use heat to break down long-chain hydrocarbon molecules constituting waste oils. The shorter chains generate lighter liquid fuels, which are more valuables. Several types of hydrocarbons can be subject to thermal cracking. The process operates at very high temperatures that allow all the water contained in the waste oils to evaporate. Then, a large part of the heavy metal content is removed as sludge or via an acid treatment prior to the cracking step. The waste is generally cracked at 420°C and at low pressure. The outputs of the following distillation and stabilizing steps are marketable fuels. Depending on the intensity of the cracking, the material may either be a fuel oil, a fuel suitable for blending with diesel or materials used as light lube oil and for other uses.