Analysis of the reports submitted by Member States on the
implementation of directive 2008/1/EC, Directive
2000/76/EC, Directive 1999/13/EC and further development
of the web platform to publish the information
Draft report on subtask 3.1: Analysis of Member States
implementation of IPPC and WI Directives – Annex A:
Member States WI factsheets
Report to the European Commission
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Issue1
April 2010
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Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Title
Analysis of the reports submitted by the Member States and the further
development of the web platform to publish the information
Customer
European Commission
Customer reference
ANV.C.4/FRA/2007/0011
Confidentiality,
copyright and
reproduction
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File reference
Reference number
Marie Leverton
AEA
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t: 0870 190 2817
f: 0870 190 5545
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Author
Name
Approved by
Name
Liesbet Goovaerts (VITO)
Katrijn Alaerts (VITO
Ive Vanderreydt (VITO)
Signature
Date
AEA Energy & Environment
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Table of contents
Annex A
iv
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Annex A
Annex A sets out the detailed overviews of the Member States responses to the questionnaire.
For each Member State a individual fact sheet is drafted containing:
-
The main text given in the response to each qualitative question by means of a short
summary. This short summary presents the most relevant information provided by the MS in
relation to each question. The questions are structured using the 6 main categories, used in
the reporting tool. The qualitative questions are further split into subcategories providing an
overview of specific practical approach and experiences of the Member States for each of
the main categories.
-
Presentation of the Member States quantitative data in tables;
-
The completeness table, which indicates the degree to which the answers comply with the
requirements of the questionnaire. The method described in the main report is used;
-
A summary on the status of implementation. This summary describes whether or not all
requirements are implemented into a functional and effective practical systems.
These fact sheets were presented to the Member States for approval. All comments, clarifications
and additional information provided by the Member States were taken into account.
These fact sheets are used as the basis for the analysis made in previous chapters.
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FINLAND
Overview of the answers
The table below presents the detailed analysis of Finland’s responses to each question of the
questionnaire, by means of a short summary or standardised answer where appropriate. Comments
regarding the adequacy of the answers in relation to the requirements of the questionnaire are
added where necessary.
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Table 1: Finland – overview of the answers
Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
1
Category: DEFINITIONS
Subcategory: Specific Member States approach
NO related questions asked
Subcategory: Experiences of Member States
1.1
Please describe any problems with the definitions
given in Article 3 identified when transposing and
implementing the Directive?
-
Waste
Hazardous waste
Mixed municipal waste
Incineration plant
Co-incineration plant
The case of Lahti Energia's Kymijärvi plant concerning the gasification of waste
(incineration of purified product gas). The matter has already been heard in the
European Court of Justice and the hearing of the sequel (incineration of unpurified
product gas) is still pending.
-
Existing incineration or co-incineration
plant
Nominal capacity
Emission
Emission limit value
Dioxins and furans
Operator
Permit
Residue
-
-
2
-
Category: NUMBER OF INSTALLATIONS/PERMITS/WASTE (CO)-INCINERATED
Subcategory: Specific Member States approach
NO related questions asked
Subcategory: Experiences of Member States
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Main category
Question
number – sub
question
reporting tool
2.1
2.2
2.3
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Please give information on number of installations,
permits and permitted capacities that fall within the
scope of the Directive.
See Table 2 below
Have any mobile plants received permits under
this Directive?
Please specify.
Please give information on the waste that has
been co-incinerated
Comments
No
For cement kilns
-
waste oils:
hazardous
-
plastics:
non-hazardous
-
fluff from shedding:
non-hazardous
-
other (please specify):
non-hazardous
remarks:
meat-and-bone meal, crushed tyres.
For combustion plants
-
wood waste:
hazardous and non-hazardous
-
sludge:
hazardous and non-hazardous
-
other (please specify):
hazardous and non-hazardous
remarks:
2.4
3
How many co-incineration plants are subject to the
emission limits provided in Annex V of the
Directive (i.e. where co-incineration of untreated
municipal waste is undertaken or more than 40 %
of the heat release results from the combustion of
hazardous waste)?
meat-and-bone meal, oil, paper, cardboard waste,
plastics, crushed tyres, etc.
None
Under national legislation a plant that incinerates mixed municipal waste is a waste
incineration plant.
Category: PERMIT
Subcategory: Specific Member States
approach
3.1
What provisions are made within the permitting
process for:
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Question
number – sub
question
reporting tool
3.1.1
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Identifying the quantities and categories of
hazardous waste that may be treated
It has not been considered necessary to issue special provisions, because the matter is
dealt with in operators' quality systems or similar guidelines.
The permit regulations specify the maximum permissible incineration amounts by waste
fraction.
3.1.2
The minimum and maximum flows of hazardous
wastes to be treated
The calorific value of hazardous waste fractions going to incineration must be
sufficiently high and the incineration mass flow rate selected so as not to exceed the
emission limit values under the regulation.
3.1.3
The range of calorific values of hazardous wastes
permitted
See answer to question 3.1.2
3.1.4
Restrictions on the content of pollutants e.g; PCB,
PCP, chlorine, fluorine, sulphur, heavy metals
The concentrations of halogenated organic substances in the hazardous waste
incinerated in the waste treatment plant must not exceed 1% expressed as chlorine.
3.4
For incineration plants, what measures are in place
(in addition to the report requested under
Article12(2), if any) to ensure that plants are
designed, equipped, built and operated to so that
the emission limit values (as set out in Annex V of
the Directive) are not exceeded?
The permit stipulates that before starting productive activities the operator must explain
how he will comply with the emission limit values.
The permit application is examined to ensure that the operator orders the equipment
necessary to comply with the emission limit values.
The warranty conditions shall state that it must be possible to reach the emission limit
values with the equipment.
3.5
For co-incineration plants, what measures are in
place (in addition to the report requested under
Article12 (2), if any) to ensure that plants are
designed, equipped, built and operated to so that
the emission limit values (as set out in Annex II of
the Directive) are not exceeded?
See answer to question 3.4.
The same measures hold for incineration and co-incineration plants.
3.7
For releases to air from incineration and coincineration plants, have emission limit values
additional to those given in Annex II or Annex V, as
appropriate, been set?
No
3.8
How are emission limit values for discharges of
waste water from flue gas cleaning equipment to
the aquatic environment determined?
identical to Annex IV
3.9
Have emission limit values been set for pollutants
discharged to water, in addition to the pollutants
specified in Annex IV?
No
Comments
No information is provided on
how these quantities and
categories of hazardous
waste, as set out in the permit,
are determined.
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
What operational control parameters are set within
the permitting process for waste water discharges?
NH4-N
No operational control
parameters are specified (pH,
temperature, flow,...).
3.11
What provisions have been made to ensure
protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
There are no provisions.
The permit regulations lay down provisions on the storage of waste and on the
treatment of the resulting wastewater.
No further information is
provided on the provisions laid
down in the mentioned permit
regulations.
3.12
What criteria are used to ensure that storage
capacity is adequate for waters to be tested and
treated before discharge where necessary?
There are only general provisions.
It is the operator's obligation to see to the matter.
No further information is
provided on the general
provisions.
3.13
What provisions in general have been made to
minimize the quantities and harmfulness of
residues resulting from incineration or coincineration plants?
There are no provisions.
3.14
Are the requirements of the permit for the
measurement of pollutants to air and process
operation parameters identical to those set out in
Article 11(2)?
Yes
3.15
Are the requirements of the permit for the
measurement of pollutants to water identical to
those set out in Article 11(14-15)?
Yes
3.16
What provisions are made within the permitting
process, as regards to air emissions, to ensure
compliance with the provisions of
3.10
3.16.1
Article 11 paragraph 8?
The emissions monitoring programme lays down how to monitor emissions, how to use
the data to calculate the concentrations comparable to the limit value and how to save
and store the data. It also specifies that the control authorities must be notified
immediately if the values are exceeded.
3.16.2
Article 11 paragraph 9?
See 3.16.1.
3.16.3
Article 11 paragraph 11 ?
See 3.16.1.
AEA Group
Comments
Unclearness remains with
respect to the relation
between the emissions
monitoring programme and
the permitting process (Is it
part of the permit or a section
of national legislation?).
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Question
number – sub
question
reporting tool
3.16.4
Main category
Subcategory: approach or experiences
Question (Q)
Article 11 paragraph 12?
Summary of MS response
Comments
See 3.16.1.
In practice the measurements are continuous.
3.17
What provisions are made within the permitting
process, as regards to water emissions, to ensure
compliance with the provisions of Article 11
paragraph 9?
See 3.16.1.
3.18
What compliance regime is applied for emissions
to air and water according to Article 11 paragraphs
10 and 16, respectively?
See 3.16.1.
For air:
Option box: Identical to Article
11(10)/More stringent compliance
regime
Identical
For water:
Option box: Identical to Article
11(16)/More stringent compliance
regime
Identical
3.19
Please describe any official guidance that has
been developed to determine average emission
data in accordance with article 11, paragraph 11?
There is no official guidance, but a report on the application of emission monitoring
standard EN 14181 has been drawn up in cooperation with industry and energy
companies.
3.20
What are the procedures for informing the
competent authority in the event of breach of an
emission limit?
Immediate electronic reporting in the VAHTI system. The system is also used to verify
that the controllers respond to the report within the period prescribed.
Subcategory: Experiences of Member States
3.2
What wastes have been considered to be
‘inappropriate’ for representative sampling?
None
3.3
With regard to the furnace gas residence times
and temperatures laid out in Article 6(1) and Article
6 (2): have any exemptions from the operating
conditions been granted in accordance with Article
6(4)?
No
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
3.6
4
Question (Q)
For cement kilns co-incinerating waste, have any
exemptions from the emission limits for NOx, dust,
SO2 or TOC been granted in accordance with
Annex II.1?
Summary of MS response
Comments
No
Category: Public participation
Subcategory: Specific Member States
approach
4.1
4.2
4.2.1
4.2.2
What arrangements are made to ensure public
participation in the permitting process?
-
type of permit
new
-
public availability of the permit
application
At local authority office
At regional authority office
-
period that the public is enable to
comment
During the official period of public notice (30 days), although an effort is made to take
into account all remarks made before the permit decision.
-
public availability of the final decision on
the permit application
At local authority office
At regional authority office
Through the internet
With regard to the availability of information
throughout the permitting process:
Is there any information related to environmental
aspects not publicly available on the application,
decision process and subsequent permit?
Yes
If yes please specify:
Business and professional secrets (rare).
Where these data are available, please specify
whether this information is available free of charge
(optional)
Yes
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
4.3
4.4
Question (Q)
For incineration plants and co-incineration plants
with a nominal capacity of two tonnes or more per
hour, what provisions are made to require an
operator to submit an annual report on the
functioning and monitoring of the plant to the
competent authority?
Summary of MS response
The permit provides for monthly and annual reporting and for the reporting of breaches
of emission limit values.
What information are these Annual Reports
required to contain?
-
Remarks
The obligation is provided for by decree.
4.5
How are the annual reports made available to the
public?
All annual reports are available through the internet
All annual reports are available from the competent authority upon request
4.6
For incineration or co-incineration plants with a
nominal capacity of less than two tonnes per hour,
how are these plants publicly identified?
All plants requiring a permit are listed on the internet.
Subcategory: Experiences of Member States
NO related questions asked
5
Comments
Account of the running of the process
Emissions into air compared to standards set in the Directive
Emissions into water compared to standards set in the Directive
Capacity of the installation
Type of the installation (incineration or co-incineration)
Types of waste that are incinerated
The amount of incinerated waste
Category: Abnormal operation of
installations
Subcategory: Specific Member States
approach
5.1
What provisions are made within a permit to
control the period of operation of an incineration or
co-incineration plant during abnormal operation
(i.e. stoppages, disturbances or failure of
abatement or monitoring equipment)?
5.2
For incineration and co-incineration processes
what are the maximum permissible periods of
operation during abnormal operation (i.e. before
the plant must shut down)?
The obligations of the WID are followed.
Limit value exceedances must be reported electronically to the controlling authority
without delay.
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
6
Remarks
See question 5.1.
Maximum permissible period with exceedence of
emission limit values
4 hours
Maximum cumulative duration of periods
exceeding ELV over one year
60 hours
Subcategory: Experiences of Member States
NO related questions asked
Category: Other
Subcategory: Specific Member States
approach
NO related questions asked
Subcategory: Experiences of Member States
6.1
What information, if any, do you have to suggest
that the Directive should be amended with regards
to
6.1.1
Articles 10
-
6.1.2
Articles 11
-
6.1.3
Articles 13
-
6.1.4
Annex I
-
6.1.5
Annex III
-
6.1.6
Other (optional)
It is proposed to exclude faecal (manure) matter and other natural non-hazardous
agricultural or forestry material used for the production of energy through processes or
methods which do not harm the environment or endanger human health, from the scope
of waste incineration and co-incineration requirements in the IPPC Directive.
Faecal matter (manure) should however, be incinerated as waste under requirements of
WID if it is required in Regulation No 1774/2002 (Animal by-product Regulation).
AEA Group
A suggestion for adaptation of
Art. 38.2 of the proposal for an
industrial emissions Directive
can be found in the original
answer.
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Member State quantitative data
Table 2: answer to question 2
Requested information
1
existing1
new
total
Number of installations within the scope of the Directive
20
4
24
Number of permits issued
12
3
15
Number of permits to be issued
0
12
12
Total permitted capacities of waste throughput, if available
(optional) (tonnes/year)
Number of plants that recover heat generated by the
incineration process
0
0
0
20
4
24
Existing plants are as defined in article 3 paragraph 6, new plants are all others
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Analysis of completeness
Table 3 presents the level of completeness of the report of Finland
Table 3: Finland – Completeness analysis table
Question
number,
subquestion
Level of
completeness
Comments
1.1
2.1
2.2
2.3
2.4
3.1
No information is provided on how the waste reception parameters, set out in the
permit, are determined.
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
No operational control parameters are specified (pH, temperature, flow,...).
No further information is provided on the provisions laid down in the mentioned
permit regulations.
No further information is provided on the general provisions mentioned.
3.13
3.14
3.15
3.16
3.17
3.18
3.19
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3.20
4.1
4.2
4.3
4.4
4.5
4.6
5.1
5.2
6.1
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Analysis of implementation status
Finland provides a concise overview of the national legislation and legal provisions in place to
ensure compliance with the WI Directive.
A problem is reported with the interpretation the Directive’s definition of ‘co-incineration plant’ with
respect of the incineration of syngas from a gasification unit.
24 installations (including 20 new installations) fall within the scope of the Directive, of which 15
were permitted so far, all of them recovering the heat generated in the incineration process.
Various types of waste, covering both hazardous and non-hazardous waste categories, are coincinerated in cement kilns and combustion plants.
For some issues Finland provides sufficient and appropriate information to check compliance with
the WID. However, for several issues (such as control parameters for waste water discharge,
provisions to ensure protection of soil, surface waters or groundwater, provisions relating to residue
handling and measurement requirements) adequate information is lacking to prove full compliance
with the provisions of the WI Directive.
Public participation is ensured throughout the permitting process, through various information
channels.
No provisions to control abnormal operation of installations are foreseen, nor in the permit nor in the
national legislation (only refererence is made to the relating obligations of the WID).
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