Lighea holds a master’s degree in environmental engineering and works since 2012 with CEWEP, the confederation of European waste-to-energy plants, where she now external advisor for technology and environment. Her areas of expertise are emissions to air and water, monitoring techniques, life-cycle analysis, waste management systems and waste-related law. During the last years her main focus was the review of the Waste Incineration BAT Reference document (BREF), where she coordinated internally the work of more than 30 people, produced content and externally followed every aspect of it, from the technical exchange with the JRC to the preparation of workshops for helping the members on the upcoming implementation.
Thanks to its extensive experience with low emission levels, the WI sector was able to identify early on that compliance with requirements on uncertainty of measurements was becoming more and more a challenge. This aspect is especially important within the context of the implementation of WI BAT Conclusions, because BATAELs are derived from operational values that are associated with an unknown uncertainty. If, on the one hand, BATAELs are expressed without reference to an associated uncertainty, on the other, the future BATAEL‐based ELVs will have to be implemented with specific compliance rules, including the ones on uncertainty.
It should be stressed that the set of compliance rules is not defined in the WI BREF and it is considered as a task for competent authorities during the implementation phase. This work attempts to clarify the main aspects of this complex issue.
When defining BATAELs it was not taken into account the overall uncertainty of the reported emissions, nor the feasibility to perform, at BATAEL levels, measurements within a certain range of uncertainty. BATAELs are directly derived from operating values with a number of them below the LoQ of the methods, therefore with high and unknown level of uncertainty, and are expressed without information on how the measurement uncertainty should be taken into account for compliance assessment.
In other words, the Best Available Techniques for monitoring do not allow for the time being and foreseeable future to meet the requirements of the monitoring standards made mandatory by the IED and the WI BAT conclusions at the low concentrations encountered in Waste incineration BATAELs. BATAEL‐based ELVs have to be set considering the need of a margin for operating contingencies and uncertainty. One may consider that, to be on the safe side, it is appropriate to set ELVs at all BATAELs lower ends and at BATAEEL higher end. However, a number of crucial information must be taken into account when implementing the WI BAT conclusions. For example, it is necessary to make sure that a successful calibration with reference to the chosen ELV will be achievable. This is of the utmost importance, both for the operator and for the local authority that is to ensure compliance with the ELVs.