european federation of waste management and environmental services committee 5 hazardous waste...

European Federation of Waste Management and Environmental Services

Committee 5 Hazardous waste

Brussels, 14 September 2015


Agenda

1. Welcome2. Adoption of the agenda and of the minutes of the last

meeting3. News from the FEAD Secretariat4. Ongoing EC studies on hazardous waste5. Revision of the Waste Treatment BREF6. Revision of the Waste Incineration BREF7. Any other business8. Date of the next meeting


3. News from the FEAD Secretariat


Adopted work programme for Committee 5

(2015-2016)


Committee 5Hazardous Waste

(Chair: Luis Palomino, ASEGRE – Vice-Chair: Sarah Moseley, ESA)

PRIORITY ISSUES Waste Incineration BREF revision – hazardous waste incineration

(municipal waste incineration: Committee 3 leading) Waste Treatment BREF – physico-chemical treatment (Task Force

BREF leading) List of Waste revision – hazardous properties (Annex III Waste

Framework Directive) – Ongoing impact assessment HP14

MONITORING ISSUES Continuous revision EU POPs Regulation (annexes) / Adoption of

guidelines for POPs-containing waste at international level (Basel Convention)

Ongoing EC studies: Hazardous waste management in the EU-28 EU waste classification guidance Derogation for PVC waste in the List of Waste

FINAL FEAD WORK PROGRAMME 2015-2016


Update on the Circular Economy Package


Resolution of the European Parliament (9

July 2015)


Provisions on hazardous waste

• 27. Recalls that the availability of standardised and modular components, disassembly planning, long-duration product design and efficient production processes have an important role to play in a successful circular economy; urges the Commission to take relevant actions to ensure that products are durable and easy to upgrade, reuse, refit, repair, recycle and dismantle for new resources, and that parts containing hazardous substances are clearly identified in product manuals to facilitate separation of those parts prior to recycling;



• 31. […] stresses in accordance with the waste hierarchy that prevention takes priority over recycling and that, accordingly, recycling should not justify the perpetuation of the use of hazardous legacy substances;

• 32. Calls on the Commission and the Member States to step up their efforts to substitute hazardous substances in the context of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment with a view to establishing non-toxic material cycles;



• 35. a binding, gradual reduction of all landfilling, implemented in coherence with the requirements for recycling, in three stages (2020, 2025 and 2030), leading to a ban on all landfilling, except for certain hazardous waste and residual waste for which landfilling is the most environmentally sound option;


4. Ongoing EC studies on hazardous waste


HW management performance in the EU-28


Background

• This study is part of a broader set of “compliance promotion initiatives” of the European Commission.

• Objective: to identify implementation gaps in the Member States, find best practices and issue recommendations.

• In the recent past, studies have been carried out on:

• Municipal waste focusing on 10 Member States with a significant implementation gap (a follow-up study on 8 additional Member States is o be launched soon);

• Separate collection;• Landfilling;• Construction and demolition waste (on-going).


Timeline

• …


FEAD input• FEAD commented on the draft screening methodology

(written remarks submitted on 9 January 2015).

• FEAD organised a conference call with Bipro (5 February 2015) on the screening of implementation in the EU-28, after which several members submitted additional information for their country.

• FEAD’s members (of the 10 countries selected for further assessment) were contacted by Bipro for in-depth interviews.

• FEAD supported ASEGRE’s (unsuccessful) request for Spain to be included as 11th MS.

• FEAD participated in the stakeholder workshop organised by Bipro and the European Commission on 30 June 2015 (input prepared during FEAD conference call on 15 June).


Main results* screening EU-28

• Planning/prevention: HW management planning in conformity with WFD for most Member States.

• HW labelling and mixing ban are implemented.• Record keeping: 16 MS require systematic reporting,

almost all countries have a register in place but large differences in terms of record keeping system and reporting obligations.

• Classification: 12 MS provide additional support.• Collection and treatment: large potential for

improvement in terms of implementing the waste hierarchy in practice.

• Availability of data: a majority of MS uses surveys and samples as a basis to report to Eurostat instead of data reported by operators.

• Enforcement: basis for carrying out inspections is present for the majority of MS.


Statistical gap between generation and treatment• A recent report* of the European Environment Agency

revealed that the waste, construction, mining and services sectors are the biggest generators of hazardous waste.

• It shows that in the EU overall, about 10% of HW is incinerated, 30-40% is recovered (other than energy recovery) and 35-40% is disposed of. These levels have not changed much over the past years.

• The report identifies a substantial gap between generation and treatment of HW. The “gap” is the biggest for chemical waste, ELVs and used oils.

• Reason for the gap: Pre-treatment? Illegal activities? Bad reporting/data?


Statistical gap between generation and treatment


Selection of 10 MS for in-depth analysis• The following countries were selected:

• Five countries with big gaps between reported generated and treated waste: Luxembourg, Ireland, Latvia, Italy and the United Kingdom

• Five countries with the smallest gap: Germany, Estonia, Bulgaria, Finland and the Netherlands

• Draft results for some of these countries were presented on 30 June*.

• Interviews continued in July, the final factsheets for each of the 10 MS will be presented in September.

• The study will be completed in October 2015, when the final report (including recommendations to improve HW management in the MS) will be published.


Impact assessment HP 14


Background

• At the TAC meeting in June 2014, MS agreed on the review of the legal framework on waste classification.

• Commission Regulation (EU) No. 1357/2014, replacing Annex III WFD, and Commission Decision 2014/955/EU amending the List of Waste have become applicable from 1 June 2015.

• The amendment of HP 14 (ecotoxicity) was postponed until an assessment of the impacts of different classification approaches is made.


Content of the study

• The ongoing study assesses 4 different calculation methods (based on chemical tests).

• 14 pairs of waste codes (“mirror entries”) which are likely to change classification depending on the calculation method used have been assessed to this effect.

• The study also contains a (preliminary) assessment of the environmental, social and economic impacts.

• The final report is due in August 2015.


First results

• At the stakeholder workshop on 20 April, the consultants presented the four calculation methods and possible consequences with regard to the classification of waste as ecotoxic.

• They indicated that methods 1 and 3 would lead to more waste types being classified as hazardous (on the ground that they are ecotoxic), compared to methods 2 and 4, and that methods 1 and 3 seem to be most in line with the current classification in the List of Waste.

• (These are preliminary results based on a limited number of samples. In the meantime, the consultants have analysed further samples.)


Discussion at TAC meeting• Member States discussed this study at the TAC meeting (Technical

Adaptation Committee) on 29 June.

• One MS said that it has conducted additional research and will send the results and its proposals to the Commission, possibly to be included as an annex to the final report.

• Two Nordic countries have also done work on the assessment of ecotoxicity and will send their conclusions to the Commission.

• The Commission clarified that the MS will be able to maintain their current approach for ecotoxicity (some undertake chemical analysis, some use bio tests and some a combined approach) until HP14 is modified.

• It also said that there is not a precise deadline for making a proposal on the amendment of HP14.


FEAD input

• FEAD participated in the stakeholder workshop organised by Bio by Deloitte and the European Commission on 20 April 2015.

• FEAD’s position was discussed during conference calls on 17 April and 15 June.

• Some members filled in the questionnaire issued by Bio by Deloitte after the workshop on 20 April.

• Industry was also asked for additional waste samples to be included in the study.

• FEAD expressed its disagreement with the consultant’s way of working and the short deadlines. An e-mail about this was sent to the consultant and the European Commission on 15 June.


EU guidance on the classification of HW


Background

• This study aims to assist the Commission in the development of a guidance document on the classification to be used by those involved in the production, assessment, management and regulation of HW.

• The final guidance document will be a non-binding document which aims to support national authorities and economic operators regarding the classification of hazardous waste. This should lead to a more harmonised implementation of the legislation throughout Europe.

• The draft guidance was inspired by existing national guidance documents, in particular that of the UK.

• There is no precise timeframe for the publication of the final document (possibly end of 2015 or beginning of 2016).


Structure of the document*

• Introduction

• Legislative framework

• Procedure of classification

• Annex A: Annotated List of Waste

• Annex B: Data sources

• Annex C: Determining HP 1-15

• Annex D: Waste Sampling


Structure of the document


Particular issues discussed on 30 June• The consultant (Bipro) identified the following items*

for further discussion at the stakeholder workshop on 30 June 2015:

• Unknown waste composition• Classification of packaging waste• Concentration limits• Test methods• Interpretation of List of Waste entries• Exemption for metal alloys


FEAD input

• FEAD discussed the draft guidance document during its conference call on 25 June.

• FEAD participated in the stakeholder workshop organised by Bipro and the European Commission on 30 June.

• FEAD submitted its comments on the draft guidance document on 10 July – one item which could not be resolved was the classification of packaging waste.


Study on a derogation for PVC waste


Background

• The aim of this study is to assess whether certain waste types, which, in view of the threshold limits for the classification of waste, would be classified as hazardous should actually be classified as non-hazardous based on the fact that the substances they contain (and which are the reason for their classification as hazardous) are considered not biologically available.


Results

• Consultant Bipro came to the conclusion that several waste types cannot be considered relevant for a possible exemption from classification as hazardous waste. This concerns:• All types of rubber waste• Plastic waste from automotive applications• Polystyrene foam boards or broken parts from construction and

demolition waste• Plastic waste from EEE• Plastic waste from crates and pallets

• Specific waste types consisting of rigid or flexible PVC were considered relevant and assessed in detail.

• Bipro concluded that only specific rigid PVC waste types could be proposed for an exemption, more specifically waste from rigid PVC profiles and pipes.


Discussion TAC meeting

• One MS supported the view that rigid PVC should not be considered as HW as a measure to promote PVC recycling.

• Another MS replied that a classification as hazardous does not necessarily represent a breach to the circular economy. Art. 12 CLP should be interpreted that no availability should be present. Allowing an exemption would create an undesirable precedent.

• One MS expressed its doubts on the conclusion of the study, particularly on DEHP which is an ubiquitous pollutant, and considered the study incomplete given that M factors should also have been assessed.

• One MS said that the scope of the derogation should be transparent and science based and that economic considerations should be carefully weighed.


5. Revision of the Waste Treatment BREF


Update on the PCT subgroup work

Conclusions from the subgroup meeting in Seville, 17-18 June 2015:Specific plants: check if covered by IED, and threshold Pre-acceptance/acceptance: contribution to be consolidatedDecontamination: further elements needed to decide to

include or not in the WT BREF (IED) Storage/temporary storage: contribution to be consolidated

-No distinction between stand alone and other -No necessity of three categories -No need for definition for temporary storage -No systematic cross-references with EFS BREF



Solvents: contribution to be consolidatedWater-based liquid waste:-Specific section -Consolidate the contributions in one single document -Cross-references with techniques described in common section -Additional data for water-based liquid waste from DE and possibly UK (for plants having filled-in the questionnaires): emissions data Mid-July -Distinction between indirect and direct discharge -Treatment of liquid photographic waste kept in Chapter 2



Pre-treatment -Pre-treatment before landfilling/backfilling: consolidation of the contribution to be done -Treatment before backfilling to be addressed in Chapter 2 in a specific section (possibly in Chapter 4 if specific techniques) -Treatment before landfilling to be addressed in Chapter 2 in a specific section (possibly in Chapter 4 if specific techniques) -All obsolete Sections of current BREF to be removed Re-refining of waste oil-Specific chapter on re-refining of waste oil -Yield of 65% for defining re-refining -GEIR position paper to be shared with the subgroup



Common section for 'substance of high concern' including sub-section on mercury, PCBs and other POPs PCT of calorific value:-Subgroup to give the list of concerned questionnaires and detailed information about processes -If process is similar to water-based liquid waste, in same section -Remove carbonisation of contaminated wood Soil:-Generic title: treatment of excavated contaminated soils FGT -EIPPCB to check allocation of plants -Plasma furnace to be checked in Iron and Steel BREF


FEAD contribution

Comments on the text about “Pre-acceptance/ acceptance of waste”Luis Palomino (ASEGRE) drafted the chapter on “Temporary storage of HW”-Proposal not to have any BATAELs for temporary

storage of HW, as it is a ‘new activity’ which is not yet covered by the current BREF-Emissions:

*Air emissions: data hardly available*Water emissions: Differentiate between

discharges to surface water or to WWTP


Updated timeline WT revision

Subgroup PCTDeadline for contributions: 31 August Deadline of the subgroup mandate: 30 September Subgroup BTNext meeting: 14-15 September (to finalise KEI)Deadline of the subgroup mandate: 30 September

Subgroup MTAll the discussions have been held at EURIC-level !!Deadline of the subgroup mandate: 30 September Next FEAD TF BREF meeting to be held only after D1 (Q4 2015)


6. Revision of the Waste Incineration BREF


Eurits – Cefic – HWE – FEAD meeting, 29 June 2015:• Participants:

- FEAD: André JALLET

- HWE: Nicolas HUMEZ- CEFIC: Dr Bernd SOJKA - EURITS: Dr Ludwig RAMACHER- EURITS: Mike HALE - EURITS: Guido WAUTERS

• Points of discussion:• KEI• NOC/OTNOC• Questionnaire• Mercury and PCDD/F monitoring system• Energy efficiency• New techniques HW going to MWI + burn-out and destruction and removal

efficiency• Possible candidates for BAT


• Main outcome:• Discussions were aligned with FEAD on most of the

points; except on WtE receiving hazardous waste;• General agreement to accept Hg continuous monitoring

and PCDD/PCDF continuous sampling because it is necessary for Hazardous Waste incineration.

• Regarding energy efficiency the position is to try to stick to the 2006 first BREF: being exempted as far as possible as the first objective of HW incineration is safe destruction of waste and not optimised energy efficiency.

Eurits – Cefic – HWE – FEAD meeting, 29 June 2015:


Questionnaire and data collection subgroup


Questionnaire and data collection subgroup

FEAD, ESWET, CEWEP, EuLA and Austria expressed their support for Germany’s request to have a questionnaire workshop before the questionnaire is released EIPPC will organize the workshop at the end of September (date tbc)2nd draft questionnaire: Mid-September


Comments from stakeholders

• Common comments from various stakeholders:-To divide the ‘waste’ sheet into two separate sheets: one for hazardous waste and one for non-hazardous waste, in accordance with the BAT conclusions structure (KOM conclusion 77/78, 4.2).-To distinguish between MWI and HWI and adjust the questions accordingly

• DK:-There is general uncertainty on how to describe waste characteristics. DK asks for examples focused on the physical characteristics for non-hazardous waste and on chemical characteristics for hazardous waste.


HWE contribution on the questionnaire

The structure and the wording of the draft questionnaire are not adapted to hazardous waste incinerators and to hazardous waste management in general. Additional questions on the general description of the HW line and equipment are proposed.It is only possible for operators to deliver values referring to EOT and BATAELS should apply as well to EOT.A more complete description of waste is needed, including: the phase of the waste, for each phase whether it is hazardous or non-hazardous, the type of conditioning as well as the injection device.To include in the list of other waste types: solid non-hazardous waste, non-hazardous sludge, gaseous hazardous waste and hospital waste need to be included.To create a new sheet for “waste storage” (before and after the incineration line).


HWE contribution on the questionnaire

To create a new sheet for “Flue Gas Treatment” in order to record information on the equipment in place and specifically for each equipment: pollutant(s) abated, reagent type and reagent annual consumption.“continuous” and “spot” should collect data on half-hour averages exceeding ELVs.The following information is needed for “Emission limit values prescribed by competent authority” (Endnote 73): measurement method, measuring range of each apparatus used and detection limit.The possibilities of selling electricity from HWI may be quite different and the prices quite lower than in the case of non-hazardous waste incineration, and may also be quite different among member states. These data should be somehow taken on board of the questionnaire.


Energy issues subgroup


HWE contribution on energy issues

Maximizing the energy recovery of hazardous waste incineration is not necessarily the main criterion in all cases and at all timesEnergy recovery is hardly feasible in plants dedicated to the incineration of waste with high concentration of halogens or POPs. for this type of plants.Boilers main use is primarily to reduce the temperature of the combustion gases and their design/operation conditions aim as well at avoiding dust accumulation or sticking and at resisting to the corrosion due to ambient gaseous HCl. Again, the main design criterion is not the maximization of energy recovery.HWI process many different HW showing a large variety of characteristics. This extreme variety, specific to hazardous waste, makes it difficult and imprecise to determine the energy flow entering the kiln.HWE wishes to point out that it would not be possible to apply to hazardous waste incineration the formula and BATAEPL that might be derived for the energy efficiency of non-hazardous waste incineration.


Other stakeholders’ comments

Several other stakeholders also agreed on the need o distinguish between MWI and HWI and adjust the questions regarding energy efficiency accordingly within the questionnaire for data collection.


Residues subgroup


Feedback from meeting Berlin July 2015

BAT Conclusions should be drawn from collected data but only as qualitative BATC;Waste wood, if not considered biomass (as specified in IED), lies within the scope of WI BREF and has to be tackled in the review;The data collection scheme was changed according to the results from the discussion ;Flow sheet (compare revised version in the background paper):• Remove riddlings and alternative boiler ash streams• Instead of the data collection for riddlings (amount, influence on TOC of

the bottom ash) possible data on riddlings will be delivered by Germany.• Instead of alternative boiler ash streams studies will be delivered by UK,

NL and ES.The structure and content of “old” chapter 4 BREF will be discussed after data collection.

So far EURITS and HWE have shown their disagreement with the conclusions!


- EURITS. Disagreement on two grounds:•During the meeting it was decided to collect all the data and to gather all information available concerning the DE, POPs, etc. for all incinerators treating hazardous waste irrespective of the amount of hazardous waste incinerated. (and not based on the main input of the incineration plant)•Secondly the meeting conclusions refer to: "a list of parameters asked for in the permits is added to the three parameters above mentioned" – it was not agreed to limit data collection to parameters asked for in permits.Furthermore we can not agree that there is "an ongoing discussion on about additional parameters if hazardous waste is incinerated" - as mentioned we spent a lot of time discussing this and from our understanding we reached firm conclusions.




- HWEConclusions don't reflect what was decided all together:•Discussion upon « revised » documents and not « partially-revised » as stated by the subgroup coordinator after the meeting;•During the meeting it was decided to collect all the data and to gather all information available concerning the DE, POPs, etc. for all incinerators treating hazardous waste irrespective of the amount of hazardous waste incinerated. (and not based on the main input of the incineration plant)•Never talked about “parameters asked for in permits”.


Other stakeholders’ comments

Comments from various stakeholders on the solid residues:As agreed in KOM conclusion 30 to add the

possibility to collect data and/or information on the destruction efficiency and burn-out quality in case of incineration of HW


Discussion of next steps


Updated timeline WI BREF revision • Questionnaire subgroup:

2nd draft questionnaire: Mid-September Workshop on data collection: Late-SeptemberTest questionnaire with volunteers: End October

• Energy issues subgroup:Comments by early-SeptemberPre-meeting before the data collection workshop: Late-September

• Residues subgroupComments by mid September

• Deadline for techniques to consider for BAT: 31 August• Deadline for the list of well performing plants: 30 September• Launch of data collection exercise: Mid/end November

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