The applicant proposes to put in place procedures to ensure that C & D waste contaminated
with halogenated organics or heavy metals is not brought on site. These procedures would
address education, monitoring and auditing of suppliers, modification of purchasing
specifications, visual inspection and chemical testing of incoming loads of recycled timber,
product testing in accordance with European Panel Federation (EPF) procedures, and the
training of purchasing and production staff. It is also stated that previous testing of products
for metals found no significant differences between virgin timber, final product, process dust
and MDF.
Submission(s) on Objection: None.
Technical Committee’s Evaluation: Construction & Demolition (C &D) waste wood
was excluded from use as a fuel or raw material on the basis that the burning of this
waste came within the scope of the Waste Incineration Directive (WID). The wording
of Article 2(a)(iv) of the Directive is as follows, and exempts: “wood waste with the
exception of wood waste which may contain halogenated organic compounds or heavy
metals as a result of treatment with wood preservatives or coatings, and which includes
in particular such wood waste originating from construction and demolition waste,”.
The phrase “may contain” in the wording appears to suggest that a precautionary
approach should be applied, with the remainder of the Article stating that this
precautionary approach should prevail in particular for C & D waste.
It follows that the combustion of any C & D waste in the absence of WID compliance
at Finsa can only be permitted if there is a very high level of assurance that no wood
treated as described in the Article is present. The applicant has submitted details of the
sampling, analysis and inspection procedures that would be used for C & D wastes, as
well as procedures on supplier education, monitoring and auditing, staff training and
other quality assurance measures. A lorryload of chipped waste timber arriving on site,
from which samples would be taken for analysis for contaminants, would not be
expected to have the homogeneity required to provide the necessary assurance of the
absence of these contaminants. The licensee also has a poor compliance record which
does not inspire confidence in its ability to ensure that no treated wastes would
ultimately be used as fuel. Furthermore, any conditions in the licence requiring
demonstration of the absence of such contaminants in the waste would not be a
practical solution and would be very difficult to enforce.
With regard to the use of MDF as a raw material, an investigation conducted by the
licensee showed that elevated formaldehyde emissions occur in these circumstances.
The licensee’s compliance record indicates that this prohibition is necessary to assist in
compliance with formaldehyde ELVs.
Recommendation: No change.
A.2. Schedule B.1 Emission Limit Values (ELVs) for particulates.
The licensee objects to the particulate ELVs specified for bag filters, stating that the relevant
BATNEEC guidance note and equivalent UK guidance specifies 50 mg/m3, and another plant
within this sector has an ELV of 20 mg/m3, whereas the PD has specified various limits all
under 10 mg/m3. These limits are far below manufacturers guarantees and are unachievable
in the long term. The licensee wishes to retain ELVs of 10 mg/m3 for the bag filters, and 50
mg/m3 for cyclones.
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