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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April 2010
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Analysis of the reports submitted by the Member States
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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
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reproduction
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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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SPAIN
Overview of the answers
The table below presents the detailed analysis of Spain’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: Spain – 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
General difficulty encountered in interpreting this definition for the two sections,
specifically 2.a.ii. This has led to difficulties in applying specific requirements for some
plants and hence in the application of emission ceilings as defined in Annexes II and V.
-
Mixed municipal waste
Difficulties encountered
-
Incineration plant
Difficulty encountered in interpreting this definition, especially with regard to gasification.
-
Co-incineration plant
Existing incineration or co-incineration
plant
Difficulty encountered in discerning between existing incineration or co-incineration
plants owing to the different time frames and situations described in this Article.
-
Nominal capacity
Emission
Emission limit value
Dioxins and furans
Operator
Permit
Residue
-
A description of these
problems is not provided.
Category: NUMBER OF INSTALLATIONS/PERMITS/WASTE (CO)-INCINERATED
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Subcategory: Specific Member States approach
NO related questions asked
Comments
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.
2.2
Have any mobile plants received permits under
this Directive
Please specify.
Please give information on the waste that has
been co-incinerated
No
2.3
For cement kilns
-
Remarks:
Capacity defined in terms of waste code is not available. Information on the total
capacity of the waste co-incineration at 25 cement manufacturing plants is provided: 1
569 044 t/year.
-
waste oils:
EU waste catalogue code:
08 03 19*, 08 04 17*, 12 01 06*, 12 01 07*, 12 01 10*, 12
01 19*, 13 01 09*, 13 01 10*, 13 01 11*, 13 01 12*, 13 01
13*, 13 02 03*, 13 02 04*, 13 02 05*, 13 02 06*, 13 02
07*, 13 02 08*, 13 03 06*, 13 03 07*, 13 03 08*, 13 03
09*, 13 03 10*, 13 04 01*, 13 04 02*, 13 04 03*, 13 05
06*, 19 02 07, 19 08 03*, 19 08 09, 19 08 10*, 20 01 25,
20 01 26*
hazardous and non-hazardous
solvents:
hazardous/nonhazardous:
EU waste catalogue code:
hazardous
filtercake:
hazardous/nonhazardous:
EU waste catalogue code:
-
-
AEA Group
07 01 03*, 07 01 04*, 07 02 03*, 07 02 04*, 07 03 03*, 07
03 04*, 07 04 03*, 07 04 04*, 07 05 03*, 07 05 04*, 07 06
03*, 07 06 04*, 07 07 03*, 07 07 04*, 08 01 11*, 08 01
13*, 08 01 15*, 08 01 17*, 08 01 19*, 08 04 09*, 08 04
11*, 08 04 13*, 08 04 15*, 09 01 03*, 14 06 02*, 14 06
03*, 14 06 05*, 20 01 13*
05 01 15*, 07 01 09*, 07 01 10*, 07 02 09*, 07 02 10*, 07
03 09*, 07 03 10*, 07 04 10*, 07 05 09*, 07 05 10*, 07 06
09*, 07 06 10*, 07 07 09*, 07 07 10*
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number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
-
-
-
-
-
-
hazardous
wood waste:
hazardous/nonhazardous:
EU waste catalogue code:
hazardous and non-hazardous
plastics:
hazardous/nonhazardous:
EU waste catalogue code:
non-hazardous
textiles:
hazardous/nonhazardous:
EU waste catalogue code:
RDF:
hazardous/nonhazardous:
EU waste catalogue code:
non-hazardous
fluff from shedding:
hazardous/nonhazardous:
EU waste catalogue code:
non-hazardous
other (please specify):
hazardous/nonhazardous:
EU waste catalogue code:
03 01 01, 03 01 04*, 03 01 05
02 01 04, 07 02 13, 12 01 05, 15 01 02, 16 01 19, 17 02
03, 19 12 04, 20 01 39
04 02 09, 04 02 21, 04 02 22, 15 01 09, 19 12 08, 20 01
10, 20 01 11
non-hazardous
19 02 08*, 19 02 09*, 19 02 10 , 19 12 10
19 10 04
01 05 05*, 01 05 06*, 02 01 02, 02 01 03, 02 01 07, 02 01
09, 02 01 99, 02 02 02, 02 02 03, 02 02 99, 02 03 99, 02
07 02, 02 07 03, 03 02 01, 03 02 02, 03 03 01, 03 03 02,
03 03 07, 03 03 08, 03 03 09, 03 03 10, 03 03 11, 04 01
03*, 04 01 05, 04 01 07, 04 01 08, 04 01 09, 04 01 99, 04
02 10, 04 02 14*, 04 02 15, 04 02 16*, 04 02 17, 04 02
19*, 04 02 20, 05 01 03*, 05 01 04*, 05 01 05*, 05 01 06*,
05 01 07*, 05 01 08*, 05 01 09*, 05 01 10, 05 01 11*, 05
01 13, 05 01 14, 05 01 17, 05 06 03*, 06 02 03*, 06 13
02*, 06 13 03, 07 01 01*, 07 01 07*, 07 01 08*, 07 01 11*,
07 01 12, 07 01 99, 07 02 01*, 07 02 07*, 07 02 08*, 07
02 11*, 07 02 12, 07 02 99, 07 03 01*, 07 03 07*, 07 03
08*, 07 03 11*, 07 03 12, 07 04 01*, 07 04 07*, 07 04 08,
07 04 11*, 07 04 12, 07 05 01*, 07 05 07*, 07 05 08, 07
05 11*, 07 05 12, 07 05 13*, 07 05 14, 07 06 01*, 07 06
07*, 07 06 08*, 07 06 11*, 07 06 12, 07 07 01*, 07 07 07*,
07 07 08*, 07 07 11*, 07 07 12, 07 07 99, 08 01 12, 08 01
14, 08 01 16, 08 01 18, 08 01 20, 08 01 21*, 08 02 02, 08
03 07, 08 03 08, 08 03 12*, 08 03 13, 08 03 14*, 08 03
15, 08 03 17*, 08 03 18, 08 04 10, 08 04 12, 08 04 14, 08
04 16, 09 01 01*, 09 01 02*, 09 01 04*, 09 01 05*, 09 01
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Comments
Question (Q)
06*, 09 01 13*, 10 01 01, 10 01 02, 10 01 25, 10 02 11*,
10 03 27*, 10 04 09*, 10 05 08*, 10 06 09*, 10 07 07*, 10
08 19*, 10 11 03, 11 01 13*, 12 01 08*, 12 01 09*, 12 01
12*, 12 01 14*, 12 01 15, 12 01 18*, 12 03 01*, 12 03 02*,
13 01 04*, 13 01 05*, 13 05 02*, 13 05 03*, 13 05 07*, 13
05 08*, 13 07 01*, 13 07 02*, 13 07 03*, 13 08 01*, 13 08
02*, 13 08 99*, 15 01 01, 15 01 03, 15 01 05, 15 01 06,
15 01 10*, 15 02 02*, 15 02 03, 16 01 03, 16 01 06, 16 01
07*, 16 01 13*, 16 01 14*, 16 01 15, 16 01 17, 16 01 18,
16 01 20, 16 01 99, 16 02 14, 16 02 15*, 16 03 05*, 16 03
06, 16 05 06, 16 05 07, 16 05 08, 16 05 09, 16 07 08*, 16
07 09*, 17 02 01, 17 02 04*, 17 03 01*, 17 03 02, 17 03
03*, 18 01 03, 18 01 06*, 18 01 07, 18 01 08, 18 01 09,
18 02 05*, 18 02 06, 18 02 08, 19 01 04, 19 01 06*, 19 01
10*, 19 02 04*, 19 02 05, 19 03 04*, 19 03 05, 19 03 06*,
19 03 07, 19 05 01, 19 05 02, 19 05 03, 19 06 04, 19 06
06, 19 08 01, 19 08 05, 19 08 11*, 19 08 12, 19 08 13*,
19 08 14, 19 09 01, 19 09 02, 19 09 03, 19 09 04, 19 11
01*, 19 11 02*, 19 11 03*, 19 11 04, 19 12 01, 19 12 06*,
19 12 07, 19 13 01*, 19 13 02, 19 13 03*, 19 13 04, 20 01
01, 20 01 17*, 20 01 27*, 20 01 28, 20 01 29*, 20 01 30,
20 01 32, 20 01 37*, 20 01 38, 20 01 99
hazardous/nonhazardous:
hazardous and non-hazardous
For combustion plants
-
Remarks
Capacity defined in terms of waste code is not available. Information on the total
capacity of the waste co-incineration at 3 plants is provided (data from one plant still
pending):31 236 tonnes/year.
-
wood waste:
EU waste catalogue code:
03 01 01, 03 01 05
non-hazardous
other (please specify):
hazardous/nonhazardous:
EU waste catalogue code:
hazardous/nonhazardous:
hazardous and non-hazardous
-
02 01 03, 02 01 07, 02 03 99, 03 03 01, 03 03 08, 07 02
08*, 07 05 04*, 17 02 01
Other industrial sector not covered under Annex
II.1 or II.2 co-incinerating waste
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Main category
Question
number – sub
question
reporting tool
2.4
3
Subcategory: approach or experiences
Summary of MS response
Question (Q)
other (please specify):
EU waste catalogue code:
1 03 07*, 02 01 08*, 02 02 02, 02 02 03, 02 02 99, 03 02
01*, 04 02 14*, 05 01 05*, 07 01 01*, 07 01 08*, 07 01 12,
07 02 08*, 07 07 99, 08 01 11*, 08 04 09*, 09 01 01*, 10
02 11*, 10 03 29*, 11 01 11*, 12 01 07*, 12 01 09*, 12 01
10*, 13 01 04*, 13 01 05*, 13 01 10*, 13 01 11*, 13 01
13*, 13 02 05*, 13 02 06*, 13 02 08*, 13 03 07*, 13 03
08*, 13 04 01*, 13 07 01*, 16 01 13*, 16 07 08*, 18 01
08*, 19 07 02*, 20 01 29*
hazardous/nonhazardous:
remarks:
hazardous and non-hazardous
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)?
Comments
In addition to the codes indicated, one plant is authorised
for chapter 02 waste. 121 906 tonnes per year of waste
can be co-incinerated in 10 industrial sector plants not
included in points 1 or 2 of Annex II. Information from two
plants is pending.
3, one of which applies these limits when using glycerine and tyre waste as fuel.
Category: PERMIT
Subcategory: Specific Member States
approach
3.1
3.1.1
What provisions are made within the permitting
process for:
Identifying the quantities and categories of
hazardous waste that may be treated
Article 4(5) of the WID has been transposed into national legislation (Article 6(3) of
Royal Decree 653/2003 on waste incineration).
The authorization process itself adheres to different national regulations (Royal Decree
653/2003, Law 16/2002 on integrated pollution prevention and control and regulations
concerning hazardous waste).
Amounts and categories of waste that can be treated, as well as maximum and/or
minimum flows, are based on regional criteria.
In many cases the category or type of hazardous waste is specified, unless there is a
viable re-use or recycling solution, or a list of types of waste which cannot be
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Comments
Question (Q)
incinerated is compiled. In most cases however, no amounts are specified
If amounts are established, they are based on:
the percentage of energy substitution
the calorific value of the waste, the total heat released from the hazardous waste,
which must not exceed 30-40% depending on the process and according to the
project submitted and plant characteristics
Best Available Technology
the National Inventory of Dioxins and Furans in the cement sector
sectoral studies
control of the resulting emissions by means of prior tests (in one case).
Waste products belonging to any of the authorised categories are subject to prior
characterization and analysis to verify if their physicochemical properties are within
acceptable limits.
3.1.2
The minimum and maximum flows of hazardous
wastes to be treated
See answer to question 3.1.1
3.1.3
The range of calorific values of hazardous wastes
permitted
In most cases, there are no special provisions in the authorisation process for
determining the range of calorific values of authorised hazardous waste or restrictions
on pollutant content.
In cases where these ranges or restrictions were established, they were based on:
information available from several studies (Mods documents, National Inventory of
Dioxins and Furans in the cement sector, sectoral studies), establishing the
minimum LHV and maximum halogen, chlorine and phenol levels of the waste
allowed in the process
a limit for PCB and PCP and for Cl based on emissions found in previous tests in
accordance with the project submitted.
3.1.4
3.4
Restrictions on the content of pollutants e.g; PCB,
PCP, chlorine, fluorine, sulphur, heavy metals
See answer to question 3.1.3
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?
-
-
AEA Group
National legislation:
o
specifies that incineration plants be designed, equipped, built and used
in such a way that escaping gases do not exceed the ELVs laid down in
Annex V of the Directive and in other air quality regulations. (Art. 11(1)
of Royal Decree 653/2003)
o
establishes the application of CEN standards for emission
measurements and the use of calibration standards for automated
systems. (Art. 14, 15 and 16 of Royal Decree 653/2003)
Permits generally provide for:
o
technical specifications (e.g. gas purging, redundant control systems,
preventive maintenance measures, etc), in accordance with the BAT
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reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
-
-
-
3.5
3.7
Comments
o
control of the continuous or quarterly emission data
o
measurements in accordance with national legislation
The monitoring plans included in the Integrated Environmental Authorisations or
the environmental plans approved by the competent authority must be complied
with.
Visits (initial and periodic) may be carried out and reports may be requested from
the owner regarding certain parameters (operating times, gas temperature,
emissions, types and amounts of waste being incinerated)
in one region an air quality control campaign has also been conducted to study
the possible impact of the plant.
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?
National legislation includes a transposition of Art. 7(2) of the WID(Art. 11(2) of Royal
Decree 653/2003).
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?
Yes
Remarks
In general no new ELVs were established except for an existing co-incineration plant in
one region.
The answer to question 3.4 also hold for co-incineration plants.
ELVs below those resulting from applying the general co-incineration formula of Annex
II of the WID were applied to the following parameters: Particles, CO, HCl, SO2,
Sb+AS+Pb+Cr+Co+Cu+Mn+Ni+V.
In some cases these ELVs were based on the BREF, while in others they were based
on technical criteria deriving from the measurement history.
In one region periodic measurements of PAH have been established for certain
incineration plants, but for assessment purposes only.
3.7.2
3.8
If yes, where these data are available, please
identify (optional).
See Table 3 below
How are emission limit values for discharges of
waste water from flue gas cleaning equipment to
the aquatic environment determined?
Identical to Annex IV
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Main category
Subcategory: approach or experiences
Question (Q)
Remarks
Summary of MS response
Art. 8(2, 3, 4, 5) of the WID is covered in national legislation (Art. 12 of Royal Decree
653/2003).
In most cases, these ELVs do not apply because:
there is no waste water from flue gas cleaning given that dry cleaning systems
are employed
the discharge of waste water from any part of the process is prohibited.
Comments
Reference to the applicable
national regulations is
provided for in the original
answer.
In cases where the ELVs laid down in Annex IV of the Directive apply, also national
and regional regulations concerning discharge into aquatic environments, the state of
the receiving environment and the quality objectives established for the latter are taken
into account in the environmental permit.
Environmental authorisations must include the sampling and measurement procedures
used, mentioning any specific regulations or methods that may be applicable.
3.9
3.10
3.11
Have emission limit values been set for pollutants
discharged to water, in addition to the pollutants
specified in Annex IV?
Yes
Remarks
In general, no ELVs have been set for pollutants other than those specified in Annex IV,
although the applicable sectoral regulation must also be applied, in this case the
general water regulation.
There is only one case in which additional ELVs have been set.
If Yes, please specify
See Table 4 below.
What operational control parameters are set within
the permitting process for waste water discharges?
pH
Temperature
Flow
Other (see remarks)
Remarks
Weekly flow volume, peak weekly flow.
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 covered in national legislation (Art. 12(6) of Royal Decree
653/2003).
A series of measures contained in the permit aim for ensuring protection of soil, surface
waters and ground water:
In most cases preventive measures in waste storage and handling and water
treatment are applied, such as:
o
an impermeabilisation and watertightness maintenance programme
o
preventing direct contact of waste with soil
o
basins and collection systems with sufficient storage capacity, designed
AEA Group
All pollutants to be measured
are listed in the original
answer.
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Comments
Question (Q)
to prevent and/or collect spills
periodic inspections and tests of storage tanks and safety basins
action protocols in the event of spills
protection of work areas from precipitation
compliance with national regulations governing the storage of chemical
and inflammable products
o
control and monitoring programme for lavatory and rain water and for
ground water by means of wells and bore holes
o
independent watertight systems for: the storage of chemical products
and hazardous waste, the distribution of chemical products to processes
and rain and waste water networks.
Some regions include the filing of reports on soil and ground water quality and
prohibit measures facilitating ground absorption of waste water.
o
o
o
o
-
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. 12(6) of Royal Decree 653/2003) provides that the storage
capacity of sites for contaminated precipitation runoff or for waters from spills or firefighting operations must be adequate so that the said waters can be tested and treated
before discharge as when necessary.
Some regions also take into account the applicable sectoral regulation and general
water regulation.
All these regulations are taken into consideration for adequate plant design and
dimensioning of water treatment plants.
Criteria used 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 covered in national legislation (Art. 13 of Royal Decree 653/2003).
No information is provided on
measures for transport and
physical and chemical testing.
-
-
In general, plant operation must ensure the proper incineration and co-incineration
of treated waste and proper management of waste generated.
In most regions, specific measures have been introduced and are laid down in
regional waste schemes or best practice manuals.
In one region, regional legislation provides that waste incineration plants must
reduce the amount and hazardousness of the ash produced in the incineration
process as far as possible. This must be assessed, in accordance with technical
and economic conditions, national and regional waste legislation. Specific
measures have been adopted regarding the selective collection of organic matter
and a charge has been introduced for the incineration of municipal waste at public
and private incineration plants.
In several co-incineration authorisations, waste minimising measures are included,
based on the re-introduction as far as possible of waste from process cleaning
systems. Otherwise waste is managed externally.
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3.14
Main category
Subcategory: approach or experiences
Question (Q)
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)?
Remarks
Summary of MS response
Comments
No
National legislation (Art. 15(2) of Royal Decree 653/2003) includes the same
requirements as Article 11(2) a) and b) of the Directive, but is more stringent than 11(2)
c).
If No is selected, please specify:
3.15
-
reason for deviation from Article 11(2)
More stringent requirements than those of Article 11(2) are applied
-
pollutant/parameter concerned and
measurement requirement
National legislation (Art. 15(2) c) of Royal Decree 653/2003) lays down a minimum of
four annual measurements of heavy metals, dioxins and furans. During the initial 12
months of operation, measurements are taken at least every two months.
Are the requirements of the permit for the
measurement of pollutants to water identical to
those set out in Article 11(14-15)?
No
Remarks
National legislation (Art. 18(1) of Royal Decree 653/2003) lays down the same
requirements as Directive Article 11(14) a), b) and c) but is more stringent than 11(14)
d).
If No is selected, please specify:
3.16
-
reason for deviation from Article 11(1415)
More stringent measurement requirements than those of Article 11(14-15) are applied
-
specify pollutant/parameter concerned
and measurement requirement
National legislation (Art. 18(1) d) of Royal Decree 253/2003) requires measurements of
dioxins and furans at least quarterly. During the first 12 months of operation
measurements are to be taken at least every two months.
What provisions are made within the permitting
process, as regards to air emissions, to ensure
compliance with the provisions of
National legislation (Art. 14, 15, 16,17,18 of Royal Decree 653/2003 of 30 May 2003) on
waste incineration:
provides that measurement requirements are to be stipulated in the
authorisations
establishes the frequency and conditions of the measurements
lays down the conditions for compliance with limits for emissions into the
atmosphere and water
Sectoral regulations applicable to the atmosphere and waters must also be considered.
Therefore, it is the environmental permit that includes the obligations envisaged in
Article 11 of the Directive. Obligations relating to the atmosphere are always laid down,
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Question (Q)
while those relating to water emissions are included only when applicable.
In cases where water emissions are included, environmental surveillance and control
programmes have been established in accordance with Directive provisions
(parameters, measurement frequency, remittal of reports to competent authorities,
external checks by collaborating bodies, etc.).
3.16.1
Article 11 paragraph 8?
Art. 11(8) of the WID is covered by Article 16(1) of Royal Decree 253/2003.
3.16.2
Article 11 paragraph 9?
Article 11 paragraph 9 of the Directive is covered by Article 16(2) of Royal Decree
253/2003.
Requirements for measurement and monitoring of parameters, conditions and mass
concentrations related to the incineration process are included in the plant's
authorisation and are conducted with the frequency, techniques and conditions laid
down in national legislation (Art. 14, 15, 16 and Annex III of Royal Decree 653/2003).
In many regions, environmental monitoring and control programmes are described in
the authorisation, stipulating, with respect to emission and immission levels:
measurement techniques in accordance with CEN standards
quality assurance for the continuous control equipment in accordance with
standards UNE 14181, UNE 13284-2,
frequencies and pollutant record books
In most regions the competent authorities must be informed of the results of the
measurements, including real time transmission of continuous measurements in some
cases.
In many regions audits are conducted (initial and follow-up) by authorised control
bodies or organisations collaborating with the authority, in accordance with the
provisions of the environmental monitoring and control plans, including the taking of
emission and immission air samples.
3.16.3
Article 11 paragraph 11 ?
Art.11( 11) of the WID is covered by Art. 17(2) of Royal Decree 253/2003
3.16.4
Article 11 paragraph 12?
Art. 11( 12) of the WID is covered by Art. 17(3) of Royal Decree 253/2003.
What provisions are made within the permitting
process, as regards to water emissions, to ensure
compliance with the provisions of Article 11
paragraph 9
Art. 11 ( 9) of the WID is covered by Art. 16(2) of Royal Decree 253/2003.
3.17
No further information is
provided on the guidance
concerning the location of the
measurement points.
In cases where water emissions are included in the permit, environmental surveillance
and control programmes have been established in accordance with Directive provisions
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
(parameters, measurement frequency, remittal of reports to competent authorities,
external checks by collaborating bodies, etc.).
3.18
What compliance regime is applied for emissions
to air and water according to Article 11 paragraphs
10 and 16, respectively?
Art.11( 10) and (16) of the WID are covered by national legislation (Art. 17(1) resp.
18(3) of Royal Decree 253/2003)
For air:
Option box: Identical to Article
11(10)/More stringent compliance
regime
Identical
For water:
3.19
Option box: Identical to Article
11(16)/More stringent compliance
regime
A more stringent compliance regime is applied.
If More stringent compliance regime is
selected, please specify:___
National legislation (Art. 18(3) c) of Royal Decree 253/2003) provides that in the case
of dioxins and furans, compliance with ELVs is assumed when measurements taken
four times per year do not exceed the ELV laid down in Annex IV.
Please describe any official guidance that has
been developed to determine average emission
data in accordance with article 11, paragraph 11?
Art.11 (11) of the WID has been transposed into national legislation.
In some regions, continuous data transmission is established, accompanied by a data
validation protocol.
One region has drawn up technical instructions stipulating data processing based on
the values obtained by an automatic measurement system. These instructions specify
among other things:
calibration requirements
the calculation of the confidence intervals to be used
the calculation of the daily average data as in Art 11 (11) of the WID.
In other regions, a sampling and measurement scheme is used, identifying sampling
points and recognised measuring techniques. One control test per year is
programmed.
Calibration protocols of the measurement devices must adhere to CEN standards or, if
unavailable, ISO standards.
Measurements are made during operating time, excluding down time, operational
AEA Group
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
failures or plant maintenance.
3.20
What are the procedures for informing the
competent authority in the event of breach of an
emission limit?
In some regions the competent authority receives validated data on a daily basis which
is then reviewed daily.
In most regions, the competent regional ministry is contacted by means of fax, post,
electronic or direct communication and sometimes the local authority is contacted as
well.
In some regions the procedures are laid down in the civil protection legislation.
Subcategory: Experiences of Member States
3.2
3.3
What wastes have been considered to be
‘inappropriate’ for representative sampling?
some
Type:
Explosive and radioactive waste or waste liable to react and form toxic mixtures or
vapours.
Meat and bone meal.
Waste received in sealed containers (e.g. bio-health, infectious or cytostatic materials).
Vehicle tyres.
Reasoning:
In some cases these were considered inappropriate for sampling purposes.
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 exemptions were granted in 2006-2008
3.3.1
If yes, how many exemptions have been granted?
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?
9
3.6.2
If yes, where these data are available, please
describe the reasoning for granting the
derogation(s) for each case (optional)
No real reasoning provided.
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Question (Q)
Remarks:
Summary of MS response
Comments
Detailed information on all exemptions is unavailable. The following information is
available:
one exemption was due to the high SO2 content of the limestone as a raw material:
installation capacity: 33 000 t/year
types of co-incinerated waste: tyres and rubber, biomass (wood chips),
glycerine
ELVs for each plant: 1 200 mg/m3N (average daily value) of SO2
one exemption concerns SO2 and TOC:
installation capacity: 730 000 t/year cement, 576 000 t/year clinker,
types of co-incinerated waste: biomass and used mineral oil
conditions of use provided in the permit
plant ELVs: SO2: 200 mg/Nm3, TOC: 50 mg/m3
two exemptions for SO2 and TOC
4
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
-
public availability of the permit
application
period that the public is enabled to
comment
public availability of the final decision on
the permit application
-
AEA Group
In accordance with national legislation (Art. 19 of Royal Decree 653/2003), the
processing procedure for new authorisations for incineration and co-incineration plants
includes a public information process whereby observations may be submitted prior to
the competent authority's decision on the granting of authorisation.
Moreover other national provisions (and regional if applicable) concerning public
participation must be respected.
These public information procedures are typically carried out through the Official
Journal of the Autonomous Community and occasionally through web page
announcements.
Reference to all relevant
legislation is provided for in
the original answer.
No information provided.
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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
Comments
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?
No
Remarks:
Information related to environmental aspects of permit applications, the decision-making
process and the ensuing permit is publicly available (in many cases via a web page) in
compliance with basic legal provisions on access to environmental information, except
information that is considered confidential.
If yes please specify:
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. 19(2) of Royal Decree 653/2003) states that operators must
draw up and submit to the competent authority an annual report on the operation and
monitoring of the plant which at least covers the running of the process and emissions
into the air or water compared to the emission levels regulated by this legislation.
For incineration plants:
The duty to submit this report is stipulated in the incineration plant permit.
Depending on the region, the following is requested, in addition to the annual report:
submission of data on a daily basis
submission of periodic reports (monthly, quarterly, half-yearly and even annual) on
different aspects (emissions, measures, waste generation, etc.)
submission of a triennial certificate issued by the organisation collaborating with
the authority
submission of a report drawn up by an authorised control body on compliance with
the environmental monitoring and control plan laid down in the permit.
For co-incineration plants:
In some regions the duty to submit this report is stipulated in the environmental permit.
Depending on the region, the following is requested, in addition to the elements
enumerated above for incineration plants:
submission of a surveillance plan which must include measurement of immisions
an annual report on the latter for submission to the environmental body.
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Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
4.4
4.5
4.6
What information are these Annual Reports
required to contain?
-
Remarks
Following is a general overview of the information that may be included in the annual
reports (typically stipulated in the authorisation):
operating time, incidents, failures and invalid emissions data
data on annual consumption of raw materials (water, energy, fuel, etc.), list of
chemical products and amounts used (attaching safety specifications)
annual summary of continuous and periodic emission measurement parameters
(emissions report to be filed with the PRTR). In some cases these data are to be
compared with the emission levels of national legislation/the E-PRTR.
annual report of the results of immission levels or air quality checks
discharges
monitoring of surface and ground water, soil and vegetation quality
noise
waste production and/or management, waste description
environmental audit report on waste management and production (biennial).
How are the annual reports made available to the
public?
All annual reports are available from the competent authority upon request.
Other (see remarks)
Remarks:
An individual citizen/the public at large may see that report upon request to the
competent public authority. Also, E-PRTR data are public and can be viewed via the
web page of the Spanish Ministry of the Environment and Rural and Marine Affairs.
In one region an ad hoc participation committee has been created.
For incineration or co-incineration plants with a
nominal capacity of less than two tonnes per hour,
how are these plants publicly identified?
This varies from region to region:
in some regions these plants are subject to the integrated environmental
authorisation, being published in the Official Journal of the Province.
in other regions these plants can be found on the authority web page in the list of
waste managers.
in some regions a public list is drawn up based on the incineration or coincineration capacity declared by the different plants.
plant capacity is also determined through the E-PRTR.
NO related questions asked
Subcategory: Experiences of Member States
5
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
Types of waste that are incinerated
Other (see remarks)
Category: Abnormal operation of
installations
AEA Group
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Draft Report
Main category
Question
number – sub
question
reporting tool
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Subcategory: Specific Member States
approach
5.1
5.2
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)?
A few specific provisions:
immediate reporting of failures to the competent authority with full documentation
development of a safety plan and action to be taken in emergency situations or
action protocols for failures, accidents or over-limit ELVs
power shut-off to the waste burning oven through a control loop based on: air
pollution emission levels, a fall in temperature below the established threshold or
in some cases breakdown/maintenance of the continuous measurement devices
ensuring ideal combustion conditions
maximum mitigation of effects due to discharge and accidental leaks
implementation of preventive measures (calibrations, maintenance)
prevention and repair of environmental damage
compliance with a self-protection plan as required by national legislation
identification of possible modes of abnormal operation
requirements on minimum availability of measurement equipment
limits on maximum abnormal operating periods
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
Maximum periods of operation under the abnormal conditions are laid down in the
permit in accordance with national legislation (Art. 20 of Royal Decree 653/2003),
specifying the cases where plant operation must be interrupted.
Some regions specify additional requirements.
Maximum permissible period with exceedence of
emission limit values
No answer provided.
Maximum permissible period with exceedence of
emission limit values
No answer provided.
Subcategory: Experiences of Member States
6
The permit must comply with the provisions of Art. 13 of the WID
NO related questions asked
Category: Other
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Question
number – sub
question
reporting tool
Main category
Subcategory: approach or experiences
Summary of MS response
Question (Q)
Subcategory: Specific Member States
approach
NO related questions asked
Comments
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)
-
AEA Group
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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
50
32
82
Number of permits issued
42
32
74
0
8
8
1529201
2717163
4246364
33
26
59
Number of permits to be issued
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
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Table 3: Answer to question 3.7
New/
existing
Parameter
Limit
value
Unit
Averaging Monitoring
period
method
coincinerator
coincinerator
coincinerator
coincinerator
existing
particles
45
mg/Nm3
hhav
continuous
existing
particles
20
mg/Nm3
dav
continuous
existing
CO
1445
mg/Nm3
dav
continuous
existing
CO
1470
mg/Nm3
other
continuous
Measurement period: average
value of ten minutes (95% of
measurements).
coincinerator
existing
CO
1438
mg/Nm3
hhav
continuous
Measurement period: average
half-hourly value (100% of
measurements).
coincinerator
coincinerator
coincinerator
coincinerator
coincinerator
existing
HCI
100
mg/Nm3
hhav
continuous
existing
HCI
30
mg/Nm3
dav
continuous
existing
SO2
1200
mg/Nm3
hhav
continuous
existing
SO2
1100
mg/Nm3
dav
continuous
existing
Sb+As+Pb+Cr+Co+Cu+Mn+Ni+V 4
mg/Nm3
other
discontinuous
Type
AEA Group
Remarks
Average period: average value
during a sampling period
lasting at least 30 minutes and
a maximum of 8 hours.
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Table 4: Answer to question 3.9
Pollutant
Type
New/
existing
Limit
value
pH
incinerator
existing
5,5-9,5
COD
incinerator
existing
160
mgl
BOD5
incinerator
existing
40
mgl
Total
phosphorous
incinerator
existing
10
mgl
Ammoniacal
nitrogen
incinerator
existing
15
mgl
Residual free
chlorine
incinerator
existing
0,05
mgl
Total coliform
bacteria
incinerator
existing
1500
ufc/100ml
Faecal
coliform
bacteria
incinerator
existing
300
ufc/100ml
Faecal
streptococci
incinerator
existing
100
ufc/100ml
Suspended
solids
incinerator
existing
0,5
mgl
Sulphides
incinerator
existing
1
mgl
Sulphites
incinerator
existing
1
mgl
Unit
Reasoning for
applying this
additional limit value
For all cases: determined
by the inter-community
basin body on the basis of
legislation currently in
force.
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Analysis of completeness
Table 5 presents the level of completeness of the report of Spain
Table 5: Spain – Completeness analysis table
Question
number,
subquestion
1.1
Level of
completeness
Comments
A description of the problems concerning the interpretation of ‘mixed municipal
waste’ and ‘incineration plant’ is not provided.
2.1
2.2
2.3
2.4
3.1
3.2
No real reasoning provided.
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
Criteria used for ensuring adequate storage capacity are not specified.
3.13
No information is provided on measures for transport and physical and chemical
testing.
3.14
3.15
3.16
3.17
3.18
3.19
28
Q 3.16.4: No further information is provided on the guidance concerning the location
of the measurement points.
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3.20
4.1
No information provided for the sub questions.
4.2
4.3
4.4
4.5
4.6
5.1
5.2
Maximum permissible periods are not specified.
6.1
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Analysis of implementation status
Spain has provided an extensive, clear and complete overview of the national legislation and
legal provisions in place to ensure compliance with the WI Directive.
Spain has 82 installations (including 50 new installations) falling within the scope of the Directive,
of which 59 apply heat recovery (33 new and 26 existing installations). The total permitted
capacities of waste throughput is 4 246 ktonnes/year.
25 cement kilns co-incinerate in total 1 569 ktonnes/year, both waste oils, solvents, wood waste,
textiles, fluff, plastics, RDF and other waste. Combustion plants co-incinerate in total 31
ktonnes/year wood waste and other waste. Additionally 10 industrial sector plants (not covered
under Annex II.1 or II.2) can co-incinerate 122 ktonnes/year.
3 of these co-incineration plants are subject to the emission limits of Annex V of the WID.
Spain ensures full compliance with the provisions of the WI Directive regarding the normal and
abnormal operating conditions, ELVs for emissions to air and water, residues, monitoring, control
and measurement requirements and public participation procedures is ensured by means of the
requirements laid down in national legislation.
For some aspects however, exemptions are applied or more stringent requirements are adopted.
For one installation, in addition to the pollutants as specified in Annex IV, ELVs for water
discharge have been set for several parameters (including phosphorous, sulphides, sulphites and
several biological parameters).
For emissions to air the measurement frequency is specified as minimum four annual
measurements for dioxins and heavy metals. For emissions to water the minimal measurement
frequency for dioxins is quarterly. For new installations, for these parameters the measurement
frequency is raised to at least every two months.
In addition to the more stringent measurement frequency, for dioxin emissions to water the
compliance with the ELV is assumed when measurements taken four times per year do not
exceed the ELV laid down in Annex IV.
Public participation in the permitting process is ensured by national legislation.
The annual reporting requirement is laid down in the permit and in national legislation for
incineration plants. National legislation specifies the content of this report, according to the
requirements of the WID. For co-incineration plants however, the submittance of an annual report
is not applicable in all Spanish regions.
Information on plants with a capacity of less than 2 tonnes/h is always available, although it
depends on the specific region in which form or format. A specific listing is not drawn up.
Control and duration of abnormal operating conditions is regulated as specified by the WID, and
laid down in both national legislation and the permit.
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Tel: 0845 345 3302
Fax: 0870 190 6138
E-mail: info@aeat.co,uk
www.aeat-env.com
31