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
Unrestricted Commercial
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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Reference number
Marie Leverton
AEA
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Name
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Katrijn Alaerts (VITO
Ive Vanderreydt (VITO)
Signature
Date
AEA Energy & Environment
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Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Table of contents
Annex A
iv
5
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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.
AEA Group
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LATVIA
Overview of the answers
The table below presents the detailed analysis of Latvia’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: Latvia– 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?
-
2
Waste
Hazardous waste
Mixed municipal waste
Incineration plant
Co-incineration plant
Existing incineration or co-incineration
plant
Nominal capacity
Emission
Emission limit value
Dioxins and furans
Operator
Permit
Residue
-
Category: NUMBER OF INSTALLATIONS/PERMITS/WASTE (CO)-INCINERATED
Subcategory: Specific Member States approach
NO related questions asked
Subcategory: Experiences of Member States
2.1
Please give information on number of installations,
permits and permitted capacities that fall within the
scope of the Directive.
See Table 2 below.
Data inconsistency: the
reported number of permits
issued for new installations is
3, while only 2 new
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
installations fall within the
scope of the Directive. For
existing installations no
permits were issued or remain
to be issued, while 1 existing
installation is reported to fall
within the scope of the
Directive.
2.2
Have any mobile plants received permits under
this Directive?
Please specify.
2.3
Please give information on the waste that has
been co-incinerated
No
For cement kilns
-
-
-
-
waste oils:
wood waste:
RDF:
other (please specify):
EU waste catalogue code:
130208
hazardous/non-hazardous:
hazardous
amount (tonnes/year):
3863
EU waste catalogue code:
hazardous/non-hazardous:
hazardous
amount (tonnes/year):
7500
EU waste catalogue code:
191210
hazardous/non-hazardous:
non-hazardous
amount (tonnes/year):
7215
remarks:
Incineration of this type of waste began in 2008.
EU waste catalogue code:
160103
hazardous/non-hazardous:
non-hazardous
amount (tonnes/year):
3693
remarks:
For combustion plants
-
AEA Group
other (please specify):
EU waste catalogue code:
070703,070504,080111,130205 , 130208,
It is not clear if the remark
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
150110,150202,160107,160303, 160305, 160506,
180103,180106, 200113, 200119
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)?
hazardous/non-hazardous:
hazardous
amount (tonnes/year):
2598
remarks:
Information on waste incinerated at hazardous waste
incineration installations is included here. The total
quantity of incinerated waste has been specified.
There are no co-incineration plants in Latvia.
refers to hazardous waste coincinerating combustion plants
or incineration installations,
fully dedicated to the thermal
treatment of hazardous waste.
Conflicts with the answer to
the previous question. Does
this mean that there are no coincineration plants with the
conditions specified in this
question or no co-incineration
plants at all? If the latter is
true, it is unclear what kind of
plants the answers to question
2.3 are referring to.
Category: PERMIT
Subcategory: Specific Member States
approach
3.1
What provisions are made within the permitting
process for:
No information is provided on
how these quantities,
categories, flows, ranges of
calorific values and restrictions
are determined within the
permitting process.
3.1.1
Identifying the quantities and categories of
hazardous waste that may be treated
National legislation (Cabinet Regulation No 294 of 9 July 2002) provides that the
categories and quantities of hazardous waste that may be processed must be specified
in the permit.
3.1.2
The minimum and maximum flows of hazardous
wastes to be treated
National legislation (Cabinet Regulation No 294 of 9 July 2002) provides that the
minimum and maximum flows for incinerating waste must be specified in the permit.
3.1.3
The range of calorific values of hazardous wastes
permitted
National legislation (Cabinet Regulation No 323 of 17 July 2001) provides that the
heating capacity of hazardous waste must not be below 30 MJ/kg.
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Question
number – sub
question
reporting tool
3.1.4
3.4
Main category
Subcategory: approach or experiences
Question (Q)
Restrictions on the content of pollutants e.g. PCB,
PCP, chlorine, fluorine, sulphur, heavy metals
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?
Summary of MS response
Comments
National legislation (Cabinet Regulation No 323 of 17 July 2001) specifies restrictions
on the concentrations of the following polluting substances: for polychlorinated aromatic
hydrocarbons the concentration must not be greater than 50 ppm.
The furnace gas residence time and temperature requirements of Art. 6(1) of the WID
have been transposed into national legislation (Cabinet Regulation No 323 of 17 July
2001) in similar wordings.
No English translation was
provided for this answer, so
the interpretation is dependent
on the quality of the machine
translation.
Full citation of the relevant
part of national legislation can
be found in the original answer
(in Latvian).
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?
Art 6(2) of the WID has been transposed into national legislation (Cabinet Regulation
No 323 of 17 July 2001) in similar wordings.
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
3.10
What operational control parameters are set within
the permitting process for waste water discharges?
pH
Temperature
Flow
All measurement requirements
for waste water pollutants are
specified in the original
answer.
3.11
What provisions have been made to ensure
protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
Art 8(7) of the WID is transposed into national legislation (Cabinet Regulation No 323 of
17 July 2001) in similar wordings.
Full citation of the relevant
part of national legislation can
be found in the original
AEA Group
Full citation of the relevant
part of national legislation can
be found in the original
answer.
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
answer.
3.12
What criteria are used to ensure that storage
capacity is adequate for waters to be tested and
treated before discharge where necessary?
See answer to question 3.11.
Criteria for ensuring adequate
storage capacity are not
specified.
3.13
What provisions in general have been made to
minimize the quantities and harmfulness of
residues resulting from incineration or coincineration plants?
Art. 9 of the WID is transposed into national legislation (Cabinet Regulation No 323 of
17 July 2001) in similar wordings.
Full citation of the relevant
part of national legislation can
be found in the original
answer.
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
3.16.1
Article 11 paragraph 8?
Art. 11(8) is transposed into national legislation (Cabinet Regulation No 323 of 17 July
2001) in similar wordings.
Full citation of the relevant
part of national legislation can
be found in the original
answer.
3.16.2
Article 11 paragraph 9?
In accordance with the requirements of national legislation (Cabinet Regulation No 323
of 17 July 2001) the results of all the measurements and the permit conditions are
documented to allow environmental inspectors to check the conformity of the
installation's operation with the permit conditions and requirements set out in laws and
regulations.
No further information is
provided on the procedures for
data recording, processing
and presentation.
3.16.3
Article 11 paragraph 11 ?
Art 11(11) of the WID is transposed into national legislation (Cabinet Regulation No 323
of 17 July 2001) in similar wordings.
Full citation of the relevant
part of national legislation can
be found in the original
answer.
3.16.4
Article 11 paragraph 12?
National legislation (Cabinet Regulation No 323 of 17 July 2001) provides that the
average HF, HCl and SO2 values are determined in accordance with the permit
conditions and in conformity with Annex 1 of this legislation in the case of periodical
No information is provided on
the content of Annex 1 and on
guidance concerning the
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
measurements.
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?
3.18
What compliance regime is applied for emissions
to air and water according to Article 11 paragraphs
10 and 16, respectively?
location of the sampling and
measurement points.
See answer to question 3.16.2.
Full citation of the relevant
parts of national legislation
can be found in the original
answer.
For air:
3.19
Option box: Identical to Article
11(10)/More stringent compliance
regime
For water:
Option box: Identical to Article
11(16)/More stringent compliance
regime
Identical
Please describe any official guidance that has
been developed on producing validated daily
average emission data (Article 11, paragraph 11)?
Art 11(11) of the WID is transposed into national legislation (Cabinet Regulation No 323
of 17 July 2001) in similar wordings.
Identical
No further official guidance is
reported.
Full citation of the relevant
part of national legislation can
be found in the original
answer.
3.20
If available, provide the reference or weblink.
http://www.vidm.gov.lv/lat/likumdosana/normativie_akti/?doc=3132
What are the procedures for informing the
competent authority in the event of breach of an
emission limit?
National legislation (Cabinet Regulation No 323 of 17 July 2001) states that, if the
measurements show that the ELVs have been exceeded the operator must inform the
relevant regional environmental board immediately.
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
No
AEA Group
Full citation of the relevant
parts of national legislation
can be found in the original
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Question (Q)
conditions been granted in accordance with Article
6(4)?
3.6
4
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?
Comments
answer.
No
Category: Public participation
Subcategory: Specific Member States
approach
4.1
What arrangements are made to ensure public
participation in the permitting process?
National legislation (Cabinet Regulation No 294 of 9 July 2002) states that the
information included in a permit application, including supplementary documents
submitted, are to be publically available.
If an operator considers that part of the information is restricted access information,
such information is submitted separately, an a reasoning is added.
The regional environmental board, publishes a notice on the State Environmental
Service website, which comprises among other things the place and time the
application can be consulted. Information on the decision is added afterwards.
The full public participation
procedure and all information
to be provided by the regional
environmental board and by
the operator can be found in
the original answer.
The operator must publish a notice in a local newspaper, providing information on,
among other things the place where the public may receive a summary of the
application and the submission and documents attached, the place and time of a public
consultation and the date by which the public may submit written proposals to the
board. The public may submit proposals or an opinion in writing within 40 days following
the day on which the notice is published.
-
type of permit
new
-
public availability of the permit
application
At local authority office
At national authority office
Through the internet
-
period that the public is enable to
comment
public availability of the final decision on
the permit application
31-50 days
-
At local authority office
At national authority office
At several public locations
Through the internet
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Question
number – sub
question
reporting tool
4.2
4.2.1
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
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:
National legislation (Cabinet Regulation No 294 of 9 July 2002) states that the
information included in a permit application, including supplementary documents
submitted, are to be publically available.
If an operator considers that part of the information is restricted access information,
such information is submitted separately. A reasoning has to be provided.
4.2.2
Where these data are available, please specify
whether this information is available free of charge
(optional)
Yes
4.3
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?
National legislation (Cabinet Regulation No 323 of 17 July 2001) states that if the
nominal capacity of the installation exceeds two tonnes per hour the operator has to
submit a report each year.
4.4
What information are these Annual Reports
required to contain?
-
4.5
How are the annual reports made available to the
public?
All annual reports are available from the competent authority upon request.
Remarks:
No information as to how may people look at the annual report.
For incineration or co-incineration plants with a
nominal capacity of less than two tonnes per hour,
how are these plants publicly identified?
A list of these plants is available to the competent authority on request.
4.6
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
Information received from other operators (such as complaints)
Answer not very clear.
Remarks:
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Main category
Question
number – sub
question
reporting tool
5
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Subcategory: Experiences of Member States
NO related questions asked
Comments
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
An operator must immediately inform the relevant regional environmental board of:
o
all emergencies which have resulted or which are likely to result in
unauthorised environmental pollution
o
urgent measures for the prevention of a possible accident or for the
elimination of consequences of an accident.
If the installation is damaged, the operator shall restrict or close down the
installation until normal operations can be resumed.
The total dust content of emissions into the air may not exceed 150 mg/m3,
expressed as a half-hourly average and air emission values for CO and total
organic carbon shall not be exceeded.
If the company is closed down, all types of waste and chemical residues must be
removed and transferred to a licensed organisation. The territory must be
guarded until these measures have been implemented.
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)?
Remarks
National legislation (Cabinet Regulation No 323 of 17 July 2001) states that the
operator of an incineration or a co-incineration installation must not continue
incineration of hazardous waste if the emission limit values have been exceeded for a
period of more than 4 hours without interruption. The emission limit values within one
year must not be exceeded for more than 60 hours. The 60-hour duration shall also
apply to several lines of incineration jointly that are connected to a common exhaust
gas cleaning system.
Maximum permissible period with exceedence of
emission limit values
3-4 hours
Maximum cumulative duration of periods
exceeding ELV over one year
40-60 hours
Subcategory: Experiences of Member States
NO related questions asked
Only restrictions for hazardous
waste incineration are
reported.
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
6
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)
-
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Member State quantitative data
Table 2: Answer to question 2.1
Requested information
total
Number of installations within the scope of the Directive
2
1
3
Number of permits issued
3
0
3
Number of permits to be issued
0
0
0
2100
26607
28707
0
0
0
Total permitted capacities of waste throughput, if available
(optional) (tonnes/year)
Number of plants that recover heat generated by the
incineration process
1
existing1
new
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 Latvia
Table 3: Latvia – Completeness analysis table
Question
number, subquestion
Level of
completeness
Comments
1.1
2.1
The reported numbers are inconsistent.
2.2
2.3
Some unclearness remains regarding the remark on the combustion plant data.
2.4
The answer conflicts with the answer to Q 2.3
3.1
The answer is incomplete: some information on the permitting process is missing.
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
The question is not answered: the criteria for ensuring adequate storage capacity
are not specified
3.13
3.14
3.15
3.16
Q 3.16.2: Some information on the provisions of Art. 11(9) is missing.
Q3.16.4: Some information on the provisions of Art. 11(12) is missing.
3.17
3.18
3.19
3.20
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4.1
4.2
4.3
4.4
4.5
The answer provided in the remarks section is not entirely clear.
4.6
5.1
5.2
The answer might be incomplete: only restrictions for hazardous waste incineration
are reported.
6.1
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Analysis of implementation status
Latvia provides a generally clear and quite complete overview of the national legislation and legal
provisions in place to ensure compliance with the WI Directive. However, some questions remain
incompletely or unclearly answered, which complicates a straightforward interpretation in those
cases.
No problems were encountered in interpreting the Directive’s definitions and no amendments are
suggested.
3 installations are reported to fall within the scope of the Directive and were permitted, none of them
recovering the heat generated in the incineration process. So far, no permits were granted to mobile
plants.
Various waste types, covering both hazardous and non-hazardous waste categories, are coincinerated in cement kilns and combustion plants. None of the co-incineration plants is subject to
the emission limits of Annex V of the WID.
Latvia has demonstrated that the key administrative provisions and practices are in place to ensure
compliance with the Directive’s requirements regarding the normal and abnormal operating
conditions, ELVs for emissions to air and water, residues, monitoring, control and measurement and
public participation procedures.
No exemptions to the Directive’s provisions have been granted whatsoever, although some
unclearness remains regarding the maximum permissible periods of operation during abnormal
operating conditions. The report makes notice of such maximum periods laid down by national
legislation, but only hazardous wastes are mentioned.
Clear procedures for ensuring public participation in the permitting process are provided for. Permitrelated details are made available through various information channels and opinions may be
submitted in writing for a period of 40 days. If operators provide an adequate reasoning for
considering a part of the submitted information confidential, public access to those parts of the
application could be denied.
Annual reporting is required for plants with a nominal capacity of two tonnes or more per hour.
The information to be contained in these reports exceeds the Directive’s provisions on the matter.
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