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 WID factsheets
Report to the European Commission
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Issue1
May 2010
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Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
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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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AEA Energy & Environment
iii
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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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BULGARIA
Overview of the answers
The table below presents the detailed analysis of Bulgaria’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.
AEA Group
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Table 1: Bulgaria – 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
2
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
Existing incineration or co-incineration
plant
This definition is hardly applicable to Bulgaria since the time limits set out in the
definition have expired prior to transposition of Directive into national law (Regulation
No. 6 of 28 July 2004 on the conditions and the requirements for construction and
operation of installations for incineration or co-incineration of waste). In this context, it is
assumed that an existing incineration and co-incineration plant is any incineration or coincineration plant put into operation prior to the date of entry into force of the
Regulation.
-
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
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
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
2.2
Have any mobile plants received permits under
this Directive
Please specify.
No
2.3
Please give information on the waste that has
been co-incinerated
For cement kilns
-
-
-
-
waste oils:
plastics:
textiles:
RDF:
EU waste catalogue code:
130205*, 130503*
hazardous/non-hazardous:
hazardous
amount (tonnes/year):
14
EU waste catalogue code:
070213, 070299, 150102,191204, 200139
hazardous/non-hazardous:
hazardous and non-hazardous
amount(tonnes/year):
207
EU waste catalogue code:
040222, 150202, 150203
hazardous/non-hazardous:
hazardous and non-hazardous
amount:
18
EU waste catalogue code:
191210
hazardous/non-hazardous:
-
other (please specify):
amount(tonnes/year):
4520
EU waste catalogue code:
150101, 160103, 160306
Hazardous/non-hazardous not
specified.
hazardous/non-hazardous:
AEA Group
amount(tonnes/year):
11 662
remarks:
paper and cardboard (150101) - 4.5
tonnes/ year; tyres (160103) - 4592
tonnes/year; meat-and-bone meal from
rendering (160306) - 7070 tonnes/year
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
2.4
Question (Q)
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)?
Remarks:
3
Summary of MS response
Comments
0
In the integrated permits issued to the four co-incinerating cement plants specified in
3.6.2, co-incineration of untreated municipal waste is not permitted to take place, and
the heat generated from the combustion of hazardous waste should not be more than
40 % of the resulting total heat release.
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
set out in the permit are
delineated.
3.1.1
Identifying the quantities and categories of
hazardous waste that may be treated
3.1.2
The minimum and maximum flows of hazardous
wastes to be treated
3.1.3
The range of calorific values of hazardous wastes
permitted
-
their lowest and maximum calorific values;
3.1.4
Restrictions on the content of pollutants e.g; PCB,
PCP, chlorine, fluorine, sulphur, heavy metals
-
their maximum contents 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?
In national legislation (Chapter Four of Regulation No. 6 of 28 July 2004), the conditions
and the requirements for the design, construction and operation of waste incineration
and co-incineration plants are laid down.
3.4
In national legislation (Art. 5 of Regulation No. 6 of 28 July 2004) it is stated that
permits for waste-related activities and integrated permits for waste incineration and
co-incineration should specify the type and amounts of waste allowed for treatment
using the codes listed in national waste classification legislation (Annex 1 of Ordinance
No. 3 of 2004)
For each permitted type of hazardous waste, the following should be specified:
the minimum and maximum mass flows;
-
Procedures for environmental impact assessment as well as for the issuing of a
permit have been set up.
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
-
The plants have been assessed and conditions have been set to ensure that the
established emission limit values will not be exceeded when operating the plants.
The plant operators are responsible for making continuous and periodic
measurements of the emissions of polluting substances into the air, which are
periodically verified on site by the competent authorities.
In addition, the competent authorities carry out periodic control measurements of
these emissions.
See answer to question 3.4
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?
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
Remarks
The facilities specified in this report have no wet gas purification and therefore do not
generate waste water from the cleaning of exhaust gases.
Still, the emission limit values for dangerous and hazardous substances in waste water
from gas purification are specified in national legislation (Chapter Six of Regulation No.
6 of 28 July 2004 ).
Have emission limit values been set for pollutants
discharged to water, in addition to the pollutants
specified in Annex IV?
No
What operational control parameters are set within
the permitting process for waste water discharges?
pH
Temperature
Flow
Remarks
National legislation (Art. 28 and 29 of Regulation No. 6 of 28 July 2004) determines
the points for which the relevant individual emission limit values apply. In these points
the analyses of the waste water from the cleaning of exhaust gases are carried out,
inter alia continuous measurements of:
pH, temperature and flow
other operational parameters necessary in view of the specific technical
3.9
3.10
AEA Group
All analyses to be carried out
on the waste water from the
cleaning of exhaust gases are
specified in the original
answer.
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question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
conditions in the treatment facility.
3.11
What provisions have been made to ensure
protection of soil, surface waters or groundwater in
accordance with Article 8(7)?
The provisions of national legislation (Art. 31(1) of Regulation No. 6 of 28 July 2004)
lay down the requirements for ensuring adequate protection of soil, surface waters or
groundwater.
3.12
What criteria are used to ensure that storage
capacity is adequate for waters to be tested and
treated before discharge where necessary?
National legislation (Art. 31(2) and (3) of Regulation No. 6 of 28 July 2004) states that:
storage capacity must be provided for contaminated rainwater run-off or
contaminated water arising from spillage or fire-fighting operations.
the storage capacity and the residence time of waste water in the tanks
should be adequate to ensure that such water can be tested and treated
before discharge where necessary.
For determining storage capacity and the residence time account is taken of:
o
the best practices
o
the capacity of the waste water treatment facility
o
the quantities of water intended for fire-fighting purposes in
accordance with the emergency plan of the facility
o
the maximum rainfalls in the region of the facility site.
3.13
What provisions in general have been made to
minimize the quantities and harmfulness of
residues resulting from incineration or coincineration plants?
National legislation (Chapter Seven of Regulation No. 6 of 28 July 2004) sets out the
general measures for management of the residues resulting from incineration and coincineration plants.
The operators of incineration and co-incineration plants are required to
maintain the incineration process within optimal limits in order to ensure that
the slag and bottom ashes total organic carbon content is less than 3 %.
Transport and intermediate storage of residues in the form of dust resulting
from the operation of incineration plants, as takes place in closed containers
or polyethylene big-bags to avoid spreading.
Harmful residues from incineration are pre-treated prior to disposal to a
landfill to meet the criteria for the relevant landfill class. This pre-treatment
includes solidifying of the residue by its mixing with cement to minimize the
mobility of dangerous substances in the residues.
In the case of the co-incineration plants the generated residues are recovered
as an inseparable part of the cement clinker produced.
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
No information is provided on
recycling of the residues from
incineration plants.
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Question
number – sub
question
reporting tool
3.15
3.16
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Are the requirements of the permit for the
measurement of pollutants to water identical to
those set out in Article 11(14-15)?
Yes
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?
National legislation (Chapter Nine of Regulation No. 6 of 28 July 2004) specifies the
conditions and the requirements for construction and operation of installations for
incineration or co-incineration of waste.
Within the procedure for the issuance of permits, the relevant conditions are set, which
oblige the operator to carry out the measurements to comply with this legislation.
3.16.2
Article 11 paragraph 9?
National legislation (Chapter Nine of Regulation No. 6 of 28 July 2004) specifies the
conditions and the requirements for construction and operation of installations for
incineration or co-incineration of waste.
Within the procedure for the issuance of permits, the relevant conditions are set, which
oblige the operator to carry out the measurements to comply with this legislation.
-
-
-
All measurement results are recorded, processed and presented to the
competent authority in the form of a report in order to enable the competent
authority to verify compliance with the permitted operating conditions and the
emission limit values established by this legislation.
Operators are obliged to ensure a periodic calibration of the measurement
equipment. This calibration is carried out by a specialised external company,
and the results are submitted to the competent control authorities.
The operators are obliged to present to the competent control authorities
monthly and annual reports on the measurements carried out by them.
3.16.3
Article 11 paragraph 11 ?
See answer to question 3.16.1
3.16.4
Article 11 paragraph 12?
See answer to question 3.16.1
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 answer to question 3.16.2
3.17
Comments
AEA Group
No further information is
provided on the guidance
concerning the location of the
measurement points.
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Question
number – sub
question
reporting tool
3.18
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
What compliance regime is applied for emissions
to air and water according to Article 11 paragraphs
10 and 16, respectively?
A full compliance regime is applied.
Comments
For air:
3.19
Option box: Identical to Article
11(10)/More stringent compliance
regime
For water:
identical
Option box: Identical to Article
11(16)/More stringent compliance
regime
identical
Please describe any official guidance that has
been developed to determine average emission
data in accordance with article 11, paragraph 11?
National legislation (Instruction No. 1 of 3 July 2003) describes the procedures for
producing validated daily average emission data.
If available, provide the reference or weblink.
3.20
What are the procedures for informing the
competent authority in the event of breach of an
emission limit?
National legislation (Art. 53 of Regulation No. 6 of 28 July 2004) requires that when the
results of the measurements indicate that the emission limit values have been
exceeded, the operators inform the competent authorities in writing of the recorded
exceeding values without delay.
Subcategory: Experiences of Member States
3.2
What wastes have been considered to be
‘inappropriate’ for representative sampling?
Type:
biological waste, infectious waste
Reasoning:
National legislation (Art. 9(6) of Regulation No. 6 of 28 July 2004) states that the
requirements for taking representative samples do not apply to biological waste and
waste classified as infectious.
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
3.3
Question (Q)
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)?
Summary of MS response
No
3.6
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?
Yes
3.6.1
If yes, how many exemptions have been granted?
4
3.6.2
If yes, where these data are available, please
describe the reasoning for granting the
derogation(s) for each case (optional)
See Table 3 below
4
Comments
Category: Public participation
Subcategory: Specific Member States
approach
4.1
What arrangements are made to ensure public
participation in the permitting process?
Remarks:
-
type of permit
No information provided
-
public availability of the permit
application
period that the public is enable to
comment
public availability of the final decision on
the permit application
No information provided
-
AEA Group
Within the procedure for the issuance of integrated permits (Article 122a(5) of the
Environmental protection Act), the competent authority acting jointly with the
municipalities concerned :
announce the application
ensure equal access to the application for the persons concerned, incl. the
persons in the States affected by the operation of the facility in case of
transboundary impact, during the course of one month.
take into consideration the opinions submitted throughout the period of public
access in the process of issuance of the permits.
No information provided
No information provided
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Question
number – sub
question
reporting tool
4.2
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
With regard to the availability of information
throughout the permitting process:
4.2.1
Is there any information related to environmental
aspects not publicly available on the application,
decision process and subsequent permit?
No
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 (Art. 46 of Regulation No. 6 of 28 July 2004, Art.125(1)of the
Environmental Protection Act) requires that:
all measurement results are recorded, processed and presented to the competent
authority in the form of a report.
the plant operator prepares and submits an annual report on the implementation
of the activities for which an integrated permit has been granted
In the legislative framework regulating the environment, penal provisions are provided
for operators failing to submit an annual report.
4.4
What information are these Annual Reports
required to contain?
Remarks
-
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 annual report contains :
An introductory part with data about the operator and the plant
An environmental management system
Information on meeting the requirements for efficient use of resources
Use of water
Use of energy
Use of raw materials, auxiliary materials and fuels
Storage of raw materials, auxiliary materials and products
Results of self-monitoring as:
o
A report under the E-PRTR
o
Emissions of harmful substances into the air
o
Emissions of harmful and dangerous substances in waste water
o
Waste management
o
Implementation of specific permit conditions relating to noise
o
Protection of soil and groundwater from pollution
o
A report on an investment programme for enforcement of
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Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
o
o
4.5
4.6
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.
Remarks:
The Executive Environmental Agency maintains a public register of the results of the
emissions monitoring provided for in the integrated permits. These results are published
on the web page of the Executive Environmental Agency: http://nfpbg.eionet.eu.int/ncesd/bul/IPPC/ip-kom/ip-doc.html
The list of these plants is officially published by the competent authority(according to
Art. 59 of Regulation No. 6 of 28 July 2004)
For incineration or co-incineration plants with a
nominal capacity of less than two tonnes per hour,
how are these plants publicly identified?
Subcategory: Experiences of Member States
5
compliance with the conditions of the integrated permit
Cessation of the operation of installations or parts of installations
Accidents, complaints and objections relating to the environment.
NO related questions asked
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)?
Remarks
AEA Group
In the integrated permits conditions relating to intermediate and abnormal operation are
laid down, in which it is specified how to control the plant operation in the event of a
deviation from the normal operating conditions.
The operator of the plants is obliged to apply a monitoring plan in abnormal operating
conditions, which should include, as a minimum:
the nature
quantities
duration in time of the abnormal operation emissions
the method for their measurement and control.
Summarized results of the monitoring in abnormal operation of the plants are submitted
as a part of the Annual Environmental Report.
Information provided allows
not to check if the conditions
laid down in the permit cover
all periods of abnormal
operation.
The provisions in case of deviations from the normal operating conditions of the
incineration and co-incineration plants are laid down in national legislation (Chapter Ten
of Regulation 6 of 28 July 2004). In the integrated permits conditions are laid down,
which oblige the operators of the plants to stop incinerating waste when for a period of
more than 4 hours uninterrupted the emission limit values set in the integrated permit
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Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
are exceeded.
After eliminating the causes for exceeding the emission limit values, a resumption of
this activity is allowable.
The cumulative duration of the periods of operation of the plant in abnormal operating
conditions should be less than 60 hours/year, irrespective of the number of periods of
excessive emission limit values. The 60-hour restriction applies to all kilns of the entire
plant which are linked to one single flue gas cleaning device.
6
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
6.1.1
What information, if any, do you have to suggest
that the Directive should be amended with regards
to
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
existing1
new
total
Number of installations within the scope of the Directive
0
7
0
Number of permits issued
0
7
0
Number of permits to be issued
0
0
0
-
-
-
0
7
0
Total permitted capacities of waste throughput, if available
(optional) (tonnes/year)
Number of plants that recover heat generated by the
incineration process
1
Existing plants are as defined in article 3 paragraph 6, new plants are all others
AEA Group
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Table 3: Answer to question 3.6.2
New/Existing
Parameter
Limit value
NOx
- 1200 mg/Nm3 from 1 January 2007 to 31 December 2007, in case of incineration of
less than 3 tonnes of waste per hour for each kiln
- 800 mg/Nm3 from 1 January 2007 to 31 December 2007, in case of incineration of
more than 3 tonnes of waste per hour for each kiln
- 800 mg/Nm3 from 1 January 2008
Existing
Dust
SO2
TOC
NOx
Existing
Dust
SO2
NOx
- 50 mg/Nm3 from 1 January 2007 to 31 December 2007, in case of incineration of less
than 3 tonnes of waste per hour for each kiln
- 30 mg/Nm3 from 1 January 2007 to 31 December 2007, in case of incineration of more
than 3 tonnes of waste per hour for each kiln
- 30 mg/Nm3 from 1 January 2008.
Reasoning for granting the derogation (only
for TOC and SO2)
The authorised exemptions for SO2 and TOC are on the
basis of the main raw materials (marl and limestone) used in
the production of cement clinker. In the process of the
issuance of an integrated permit, the competent authority has
requested the operator to provide evidence that the SO2 and
TOC emissions are not as a result of incineration of waste but
of the raw materials used. The measurement results during
waste incineration and during the conventional process are
one and the same. Moreover, it should be taken in
consideration that the emission limit values set for SO2 and
TOC are in compliance with the national legislation on
existing cement kilns which use conventional fuels.
30 mg/Nm3 from 1 January 2008
The same reasoning applies for all exempted kilns.
100 mg/Nm3
- 1200 mg/Nm3 to 31 December 2007
- 800 mg/Nm3 from 1 January 2008
- 50 mg/Nm3 from 1 January 2007 to 31 December 2007
- 30 mg/Nm3 from 1 January 2008
750 mg/Nm3
- 1200 mg/Nm3 to 31 December 2007, in case of incineration of less than three tons of
waste per hour
- 800 mg/Nm3 from 1 January 2008
Existing
Dust
SO2
NOx
Existing
SO2
TOC
- 50 mg/Nm3 from 1 January 2007 to 31 December 2007
- 30 mg/Nm3 from 1 January 2008
750 mg/Nm3
- 1200 mg/Nm3 to 31 October 2007
- 800 mg/Nm3 from 1 November 2007
750 mg/Nm3
100 mg/Nm3
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Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Analysis of completeness
Table 4 presents the level of completeness of the report of Bulgaria
Table 4: Bulgaria – 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 waste quantities, categories, flows, ranges of
calorific values and restrictions set out in the permit are delineated.
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
3.13
No information is provided on recycling of the residues from incineration plants.
3.14
3.15
3.16
3.17
3.18
3.19
20
Q 3.16.4: no further information is provided on the guidance concerning the location
of the measurement points.
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
3.20
4.1
No information is provided for the requested fields, except for the remarks-field.
4.2
4.3
4.4
4.5
4.6
5.1
5.2
6.1
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Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Analysis of implementation status
Bulgaria has demonstrated that the key administrative provisions and practices are in place to
ensure compliance with the requirements of the Directive. The report shows no indications of
important shortcomings in the reporting or a lack of implementation.
Bulgaria has 7 existing installations falling within the scope of the Directive, which all apply heat
recovery.
Only in cement kilns, a limited amount of waste (mainly meat-and-bone from rendering) is coincinerated. Bulgaria has no co-incineration plants that is subject to the emission limits of Annex
V of the WID.
Both national legislation and the permits issued specify necessary requirements and measures
related to reception of waste, operating conditions and emissions to ensure compliance with WID.
National legislation lays down the minimum requirements for waste reception.
information is provided on how these requirements are delineated.
However, no
National legislation also states that incineration and co-incineration plants must be designed,
equipped and built so that ELVs are not exceeded, without explicitly mentioning the actual
measures.
None of the Bulgarian installations generates waste water from flue gas cleaning equipment.
Several provisions have been made to minimize the impact of residues from incineration plants.
However, no provision concerning the recycling of the residues is reported.
Bulgarian national legislation classifies both biological and infectious waste as inappropriate for
representative sampling. No clarification is given why biological waste is classified this way.
The measurement requirements relating to emissions to air and water laid down in national
legislation are identical to the requirements stated in the WID and ensure compliance with the
WID.
On the arrangements to ensure public participation in the permitting process, insufficient
information is reported as to check whether Bulgaria complies completely with the WID.
The annual reporting requirement is laid down in national legislation, specifying the content of this
report, according to the requirements of the WID. For operators failing to submit an annual report,
penal provisions are provided in the legislation.
A list identifying plants with a capacity of less than 2 tonnes/h is published by the competent
authority, as foreseen in national legislation.
For control of abnormal operating conditions are laid down in the integrated permits The
information provided allows not to check if the conditions laid down in the permit cover all periods
of abnormal operation.
22
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
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