Approval of incineration and coincineration plants Lázár MÁRTON, DVM National Food Chain Safety Office Hungary 28 February – 1 March 2013 TAIEX ABP Event in Belgrade Relevant legislations New ABP legislation is in force and directly applicable in every Member State as from 4 March 2011. 1774/2002/EC „the old ABP legislation" 1. 1069/2009/EC Regulation EU Control Regulation (basic principles) 2. 142/2011/EU Regulation EU implementing Regulation (detailed rules) 4. 2000/76/EC Directive Waste Incineration Directive (WID) 3. National implementing (enforcement) regulation Definitions ‘co-incineration’ means the recovery or disposal of animal by-products or derived products, if they are waste, in a co-incineration plant; ‘incineration’ means the disposal of animal by-products or derived products as waste, in an incineration plant, as defined in point 4 of Article 3 of Directive 2000/76/EC; ‘combustion’ means a process involving the oxidisation of fuel in order to use the energy value of the animal byproducts or derived products, if they are not waste; Combustion • The combustion of material of animal origin other than animal fat must not be permitted • Processed fat or tallow, produced as a part of rendering process, can be used as a boiler fuel provided if requirements in Annex IV Chapter IV Section 2 F of 142/2011/EU Regulation are fulfilled. • • Production of fat to be used as fuel is not subject to specific approval but it must be produced in a plant approved to process animal by-products. For this process, a fat fraction derived from ABPs of all categories may be used. Approval 1 • Incineration of ABPs must take place at an approved plant. • This may be approved under the rules of Waste Incineration Directive (WID) EC 2000/76 and/or in accordance with ABP legislation. • For ABP incineration the detailed rules can be found in Annex III of 142/2011/EU regulation • (Low capacity ) incineration plants which are incinerating only dead bodies of animals, do not require an environmental permit in addition to their Veterinary approval. They are exempt from the more onerous controls of the Waste Incineration Directive. Approval 2 • However, plants which burn other animal byproducts (such as former foodstuffs, catering waste, manure etc.), derived products (meat and bone meal), or other materials considered as waste must be authorised under the Waste Incineration Directive as well. • Plants which burn animal by-products or derived products for the purpose of energy generation must be also approved for co-incineration under the Waste Incineration Directive. Application • Application may be made for approval as low capacity (less than 50kg/hour) or high capacity (more than 50kg/hour). • The plant operator must provide the veterinary inspector with evidence, written or visual, of the working of this device. • The manufacturer’s manual has to be also attached to the application, which confirms that the model of the incinerator will meet either the 850 C for two seconds or the new 1100 C for 0.2 seconds standard. Low capacity incineration plants 1 Careful with the applications: in the manufacturer ‘s manuals, often not the kg/hour capacity is written down, for example: 100 kg Capacity (0.18 m³) 200 kg Capacity (0.36 m³) 300 kg Capacity (0.56 m³) This means the loading capacity! Low capacity incineration plants 2 Often used: • Poultry farms • Pig farms • Dead pet animal cremation • Kennel / Stable waste • Small ruminant farms • Butcher’s ABP When only fallen animals are disposed with such low capacity incineration plant near an animal holding (on-site, static, NOT MOBILE) then the only approval is needed from Veterinary Services. Where ABPs other than fallen animals are incinerated, or veterinary medicine waste or kennel/stable waste is also incinerated, then environmental approval needed as well. Low capacity incineration plants 3 • When used to incinerate category 1 specified risk material (SRM) a low capacity incinerator must be equipped with an auxiliary burner (a secondary chamber). • When used to incinerate other by-products a secondary chamber (auxiliary burner) is not required however a manufacturer’s declaration must be available to ensure the time and temperature requirements are being achieved. • Dead bodies of animals containing specified risk material must be incinerated in whole unless cutting up has taken place at a plant approved for that purpose. Low capacity incineration plants 4 What about two low capacity incineration plants on one site? Interpretation 1 It can be permitted provided if the overall capacity of the site above does not exceed the 50kg/hour threshold. Only one incinerator operating at a time. Interpretation 2 If there is more than one incinerator such that the potential throughoutput is greater than 50kg/hr the plant will be considered automatically high capacity. High capacity incineration devices 1 Incineration or co-incineration plants treating animal by-products and derived products with a capacity of more than 50 kg per hour (high-capacity plants) High capacity incinerator (150 kg/hour) with loading 750 kg Capacity (1.18 m³) durable refractory cement lining (up to 10 cm width) High capacity incineration devices 2 • All high capacity incinerators must be equipped with an auxiliary burner which switches on automatically if the temperature of the gas falls below 850 C or 1100 C as appropriate. • There must be an automatic system which prevents introduction of material to be incinerated into the primary chamber at any time when the temperature is below 850 C or 1100 C (as appropriate) in the secondary chamber Mobile incineration plants 1 • It is said to be suited for rapid deployment to areas with sudden outbreaks of diseases • Can be high and low capacity equipments as well. Mobile incineration plants 2 • In Hungary, for the time being it can be only used for the cremation of dead pet animals • No requirements are laid down in the ABP legislation on mobile incineration devices • It seems to be very problematic, for there are public oppositions and protests against operating such devices amongst residential buildings. Location of the incinerator 1 • If the incinerator will be used to burn animal by-products from several premises it must be located on a site which has no livestock. • For the location to be considered a separate premise, it must as a minimum have a defined secure boundary (fence) and dedicated entrance. • It may also be possible to approve the use of a mobile incinerators at specified locations which otherwise meet the requirements of approval for a static incinerator. In such cases an agreed procedure for the cleansing and disinfection of all mobile equipment prior to movement to a new location will be a condition of any approval issued. Location of the incinerator 2 • In a premises which has livestock on it but disposing only animal by-products arising on that premises, the incineration plant can be established on the same site, provided if… • …there is a physical and operational separation such that the livestock cannot gain access to the incinerator and there is no risk of passive transfer of by-products to livestock by personnel or equipment. • This will require dedicated equipment and clothing for use when operating the incinerator or cleansing and disinfection prior to use associated with livestock. General conditions 1 • If incineration is not undertaken immediately upon receipt of animal by-products at the plant they must be stored in identified leak proof and covered containers. • After arrival at the plant animal by-products must be disposed of without undue delay. No timescale is specified within the legislation and factors such as quantity and weather conditions may be relevant in determining this period however it is expected that they would not be stored for longer than one or two days. General conditions 2 • The incinerator must be placed on a hard standing which may be sloped to drain. In a bunded area fluid may be absorbed and incinerated. • The drained area must provide sufficient space for the cleansing and disinfection of containers or vehicles as appropriate to the plant in question. General conditions 3 • Waste water arising at a plant which handles category 1 specified risk material must pass preliminary treatment through a 6mm trap before leaving the site. Solid material recovered from the trap must be incinerated. • Cleaning and pest control procedures must be in place and documented. Staff must have access to a wash basin, toilet and changing area. • A contingency plan must be in place for disposal of by-products in the event of breakdown. • Incompletely incinerated by-products must be re-incinerated or otherwise disposed of in accordance with ABP Regulations. • Completely incinerated by-products of which only ash remains may be disposed of to landfill. The ash may be applied to land for agricultural benefit, or in case of cremation of dead pet animal it can given back to owners. Operation • Incineration of by-products must not take place if the exhaust gas is not held at a minimum of 850 C for two seconds or 1100 C for 0.2 seconds. With 850 C/2 seconds incinerators this is often achieved using a secondary chamber to retain the gas for the requisite two seconds. It is therefore necessary that the gas in this chamber is at the required temperature before animal by-product incineration begins. Monitoring and recording During operation the chamber temperatures (either single chamber or secondary chamber) must be recorded either automatically throughout the burn cycle or manually (e.g. every two hours for 10% of incinerations.) Cement plant in Hungary (High capacity co-incineration) Co-incineration: the recovery of animal by-products or derived products in a co-incineration plant, where the main purpose is generating energy for the production of material products The final material product is cement. The most important use of cement is the production of mortar and concrete. Category 1 material meat-and-bone meal (Solt, Category 1 processing plant) The route of Cat 1 MBM from cat 1 processing plant in Solt (B) to the cement plant in Beremend (A) Cement plant (High capacity co-incineration) • Cement is made by heating limestone (calcium carbonate) with small quantities of other materials (such as clay) to 1450 C in a rotary kiln (the process is calcination) The resulting hard substance, called 'clinker', is then ground with a small amount of gypsum into a powder to make cement. • Clinker will be grinded in order to get the final product, the cement. Cement is a well known and mostly widespread binding susbstance in the building industry. The rotary kiln Cat 1 MBM Checklist 1 Material for incineration • What materials are incinerated in the plant? • Is the plant approved under WID or not? Location • Where does the incineration plant located in relation to other premises or livestock in the vicinity? Incinerator capacity • At what capacity does the incinerator operate? (manufacturer’s data sheet) • Is high capacity the result of a combination of more than one low capacity incinerators? • Is a secondary chamber (auxiliary burner) in place? Checklist 2 Type and category of ABPs (SRM or non SRM) • What species and category of ABPs are incinerated? • Does the plant incinerate SRM? • What is their origin (farms, slaughterhouses, renderers, food businesses, other)? • Incinerating own material or material from other premises? • Incinerating cat 2 and 3 ABPs (no SRM or not fallen animals containing SRM)? • What species of ABPs are to be incinerated? Reception area of premises • The incineration plant to be located on premises with livestock? • Will the incinerator be used to incinerate only whole dead bodies of animals? • Will the incinerator plant receive ABPs not arising on the same premises? • How will ABPs be stored when awaiting incineration? Checklist 3 Drainage • Is the incinerator sited on a drained or contained hard standing? • How will fluids and waste water be disposed of? • All incineration plant must have controlled drainage which mitigates any risk to animal or public health. Ash • Storage and transport of ash must be in covered, leak proof containers • Will the ash be disposed by landfilling? • Will the ash be spread to land? • Will the ash be returned to owners? Checklist 4 Monitoring and recording of operational temperatures • Is the system manual or automatic? • If manual are operational temperatures recorded regularly? (e.g. every 2 hours or at least 10% of burns) Operation and maintenance • In the event of inefficient operation ABPs that have not been fully reduced to ash must not disposed of to landfill • State the company which carries out the regular (annual) maintenance service • In the event of a breakdown or inefficient operation to where will ABPs be consigned? • Are there the required operational procedures in place (waste water management, cleansing and pest control etc.)? Thank you for your attention!
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