Experts Converge on London to Discuss Waste to Energy’s New Emission Regulations : A BREF Discussion at the Energy from Waste Conference
On day one of the Energy from Waste Conference taking place in London this week, the complex issue of the Best Available Techniques Reference Document (BREF), and its significant implications for both new and existing waste to energy facilities, was discussed.
Moderating the session, Paul James, independent consultant and moderator for the session, also leader of the EU technical working group, project manager and lead author for production of the original BREF on Waste Incineration, asked:
“I was involved with writing the first BREF, we’ve now got a new one. I’m aware that some NOx levels have come down and that there are potential requirements for dioxin and mercury, continuous emission sampling and adjusted emission levels in those. There are also some new energy efficiency levels, which for new plants talk about gross electrical generation efficiency of 25% to 35% and about 5% lower than that for existing plants. But what does it mean?”
Dr Kai Lieball, operations leader at Hitachi Zosan Inova and a representative on the European Suppliers of Waste European Suppliers of Waste-to-Energy Technology’s (ESWET) Technical Committee noted that the biggest change is that the new BREF is legally binding.
“What’s changed is that now it’s become law, so the impact if you don’t comply, is very much different,” he tells the audience. "We have to guarantee the values and have a certified measurement that we achieve those values over the whole year. If it only reaches it for 90% then it {the plant} might be returned to the EPC contractor and need to be rebuilt.”
Anita Lloyd, a lawyer at Squire Patton Boggs specialising in environmental and sustainability matters, including waste, environmental permits, producer responsibility, product compliance and labelling, chemical regulation, asbestos and contaminated land, and climate change law, confirmed this.
“The limits for the main types of emissions have all come down,” she says. “They’re all stringent. There are also requirements to continuously monitor things which didn’t need to be monitored before.
“The other more general thing is a requirement for more enhanced environmental management systems – the running of the whole facility, which is going to require investment in new systems and training and skills for members of staff,” continued Lloyd.
In terms of implementing the BREF, Member States are responsible for issuing guidelines.
“I remember when we finished the first BREF document and we put it out into the world and a lot of time was spent on the interpretation of that,” recalls James. “There was an explanation in it which said that it’s not really appropriate to take the lowest end of all the ranges, the best performance for all of the aspects, and put them together - because that’s frankly not possible.”
With its considerably beefed up requirements, industry stalwart Edmund Fleck, managing director of Martin GmbH and President of ESWET noted some of the merits of the German approach.
“The German way might not be a bad one because we changed the law, which everyone has to stick with, but at least they know what they have to do,” he concluded.
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