To :

General Technical Guideline for Environmentally Sound Management of Wastes
Consisting of, Containing or Contaminated with Polychlorinated Dibenzo-p-dioxins
(PCDDs) and Polychlorinated Dibenzofurans (PCDFs)
Response to the March 2004 Draft
Comments on the Comments of the World Chlorine Council (WCC)
and Canada
On behalf of CEWEP, the European representation of 200 incineration plants from
13 countries, treating annually around 30 million tons of municipal solid waste in an
environmentally sound way, we would like respond to some of the comments made
on the above mentioned guidelines.
1. Incineration temperature (paragraph 90)
We do not agree with the proposals from Canada and the WCC to rise the low
incineration temperature to 950 or 1 000 °C. These figures seem to be quite arbitrary.
Incineration is the most widely used method for the destruction of POPs. It is highly
regulated demanding very low levels of emissions, e.g. in the European Waste
Incineration Directive (WID) 2000/76/EC, which prescribes emission < 0.1 ng/Nm3
for dioxins/furans.
According to this directive incineration plants shall operate with a temperature of 850
°C for two seconds. Only if hazardous wastes with a content of more than 1 % of
halogenated organic substances, expressed as chlorine, are incinerated, the
temperature has to be raised to 1 100 °C for at least two seconds.
These figures are coherent with the Best Available Technique for Waste Incineration,
the BREF WI, and they are based on long experience with destruction of PCDD/F by
incineration. The requirement of 2 seconds guarantees a long (and sufficient) burn
A higher temperature does not automatically mean lower PCDD/F emissions. The
dioxins/furans emission limits of 0.1 ng/Nm3 requirement by the WID is achieved by
incineration plants operating according to the WID, i.e. 850 °C for 2 seconds. In
practice, the incineration plants represented by CEWEP achieve much lower dioxin
emissions with 850 °C for 2 seconds.
However, if hazardous wastes with a content of more than 1 % chlorine are
incinerated, the temperature has to be raised to at least 1 100 °C for at least two
seconds, according to the WID.
The technical guidelines should be consistent with the WID, the BREF WI and
practical experience.
Not at least due to the climate protection (Kyoto protocol), the energy efficiency and
the sustainable use of resources (energy), it is not advisable to operate with higher
temperatures than necessary as this always consumes additional energy.
2. Further comments:
Paragraph 123
Incinerators destroy waste containing POPs on the one hand and have to treat their
residues (bottom ash, boiler ash and fly ash) in an environmentally sound way on the
other hand.
Paragraph 123 says:
The following PCDDs and PCDFs wastes are suitable for hazardous waste landfills:
solid matrices with a bulk concentration and leachate concentration below
regulatory limits;
semi-solid form that are suitable for and have undergone immobilisation prior to
solid residues (fly ash, bottom ash, slag, scrubber sludge, treated soil, treated
metals, etc.);
The third bullet mentions bottom ash and slag. These residues are considered non
hazardous and they are often used in road construction. Therefore, they are not
suitable for hazardous waste landfills.
Paragraph 41:
First bullet, the term ‘auto-shredder fluff’ should either be excluded or it should be defined
clearly what is to be understood under this term. As to our understanding, auto-shredder fluff
can be destroyed through waste incineration.
Paragraph 95:
The term ‘proper treatment of by-products’ needs definition. It should be ensured that byproducts of mobile incinerators, such as fly ash, have to be treated in the same way as those of
fixed incinerators.
Include a sentence: “The by-products of a mobile incinerator must be treated in the same
manner as the by-products of a fixed incinerator”.
If you have any queries please do not hesitate to contact us. CEWEP will try to
provide you with any information available.
With kind regards,
Dr. Ella Stengler
Managing Director
Confederation of European Waste-to-Energy Plants
12A, Boulevard Clovis
B-1000 Brussels
Tel. : +32.2.770 63 11
mailto : [email protected]