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National Implementation Plan – Stockholm Conventionen on Persistent Organic Pollutants

Annex 1
Action plan for reduction of emissions from unintentional production of dioxin, PCB and HCB

• 1 Introduction
• 2 Convention commitments
• 3 Evaluation of current releases
  • 3.1 Evaluation of current releases of dioxin
    • 3.1.1 Annex C, Part II source categories
    • 3.1.2 Annex C, Part III source categories
    • 3.1.3 Other source types not mentioned in Annex 3 of the Convention
  • 3.2 Release of unintentionally formed HCB and PCB
  • 3.3 Maintenance of release inventories
• 4 Evaluation of the effectiveness of existing legislation and policies
  • 4.1 Evaluation of existing legislation and policies in relation to individual source categories
    • 4.1.1 Annex C, part II
    • 4.1.2 Annex C, part III
• 5 Strategies to meet the commitments in the Convention
• 6 Measures to promote knowledge, teaching, education and information
  • 6.1 Promotion of knowledge on sources of production and degradation of dioxin and dioxin-like PCB
  • 6.2 Education and information
• 7 Update of the Action plan
• 8 Time Schedule

1 Introduction

This action plan deals specifically with measures to reduce releases of unintentionally formed dioxines/furanes, PCB and HCB.

Inventories of releases of PCB and HCB are not available in Denmark. Therefore, data presented in the plan cover only releases of dioxin.

The action plan is prepared in accordance with the Stockholm Convention, article 5 a), which specifies the following elements:

i)   An evaluation of current and projected releases, including the development and maintenance of source inventories and release estimates, taking into consideration the source categories identified in Annex C;

ii)   An evaluation of the efficacy of the laws and policies of the Party relating to the management of such releases;

iii)   Strategies to meet the obligations of this paragraph, taking into account the evaluations in (i) and (ii);

iv)   Steps to promote education and training with regard to, and awareness of, those strategies;

v)   A review every five years of those strategies and of their success in meeting the obligations of this paragraph; such reviews shall be included in reports submitted pursuant to Article 15 of the Convention on reporting;

vi)   A schedule for implementation of the action plan, including for the strategies and measures identified therein.

For dioxin, an action plan was carried out in Denmark in the period 2000-2004. This was done in cooperation between the Ministry of the Environment, the Ministry of Family and Consumer Affairs, and the Ministry of Food, Agriculture and Fisheries. The dioxin action plan focused broadly on dioxin, and aimed at dioxin in animal feed as well as foodstuffs as sources of dioxin pollution of the environment in general. The results of the action plan were presented by the three ministries in their report from 2005. Further, the results of the action plan are included in the relevant sections of the description of the country baseline, see chapter 2 of the national implementation plan.

2 Convention commitments

The parties to the Convention undertake to take steps to reduce – and if possible eliminate - releases from unintentional production of the substance groups polychlorinated dibenzo-p-dioxins and dibenzofurans (here referred to as dioxins), PCB and HCB. The specific requirements for a reduction of releases of dioxin are found in Article 5 and Annex C of the Stockholm Convention. In relation to the commitments, Annex C of the Convention contains two lists of source categories; Parts II and III respectively. The two lists are reproduced in table 1 below.

Part II source categories are indicated to have a potential for comparatively high production and release to the environment of unintentional POPs. The commitments in relation to these categories are more stringent than for source categories in Part III.

In the following review of the sources, the sources will be described in accordance with this categorisation.

Table 1
Source categories according to Annex C of the Stockholm Convention

The Convention commitments are summarised below. Please refer to the Convention text, primarily article 5 b) – g), for the precise formulation.

The parties must:

• Promote the application of measures that can expeditiously give a realistic and meaningful level of release reduction or source elimination;
• Promote the development and require the use of substitute or modified materials, products and processes to prevent production and release;
• Promote and require the use of best available techniques (BAT) and the best environmental practices (BEP); initially with special emphasis on new sources and source categories identified in Part II of Annex C;
• Possibly set release limit values or performance standards in order to fulfil commitments for the use of BAT;
• Promote the development and, where deemed appropriate, require the use of substitute or modified materials, products and processes to prevent the production and release of the chemicals listed in Annex C.

3 Evaluation of current releases

3.1 Evaluation of current releases of dioxin

The trend in releases of dioxin into the air from 1995 to 2000-2002 is shown in table 2. A comparison is complicated by the fact that the inventory from 1995 does not contain information about a number of sources and that the estimation methods in the two inventories are different. Therefore, an inventory with comparable figures is under preparation.

The inventory for 2000-2002 (in table 2) contains an attempt at an estimate of releases for all sources, even the sources for which there are no reliable measurements. As can be seen from the table, there are very wide uncertainty intervals for many of the source categories. This is because releases may vary substantially, even from the same source, and because it requires a very large number of measurements to determine total releases with great certainty. In addition, for some source categories, there are only very limited data available, both in Denmark and in other countries. For example, this applies to releases from accidental and intentional fires, which may potentially be significant sources.

The inventory of the emissions of dioxin which is currently under preparation points towards total emissions of dioxin around 20 – 25 g for 2004.

Table 2
Releases of dioxin into the air, analysed by source categories, in 1995 and 2000-2002 ^[18].* See note.

*Please note that the figures are being revised. New figures for 1990 and 2004 will be available before the end of 2006.

Releases of dioxin into water and soil, analysed by source categories, are shown in table 3. A question mark next to a source category indicates that the releases may be significant, but that there is no basis for estimating the volume.

The most significant source of discharges to the aquatic environment is discharges from wastewater treatment plants and storm water discharges. Discharges into wastewater, which is subsequently treated in wastewater treatment plants, are not listed in the table. The most important sources of dioxin in wastewater, and thus sources of discharges from wastewater treatment plants, are estimated to be PCP-treated materials (0.2 g I-TEQ/yr), chlorine bleaching (<0.5 g I-TEQ/yr) and, not least, atmospheric deposition (0.4-4 g I-TEQ/yr).

Table 3
Releases of dioxin into the air and soil, analysed by source categories in 2000-2002 (same source as previous table).

3.1.1 Annex C, Part II source categories

a) Waste incineration plants
On the basis of the Danish EPA's first measuring programme for dioxin in flue gas from incineration plants in 1986-1989, the average release from the plants was estimated at 19.5 μg N-TEQ per tonne waste, and the total releases were calculated at 34 g N-TEQ per year (N-TEQ is an older unit, corresponding largely to I-TEQ). Since then, volumes of incinerated waste have increased significantly, but at the same time, better flue gas purification has been installed. As can be seen from table 2, total releases from incineration of municipal waste and medical waste in 1995 were estimated at 30 g I-TEQ.

In 2000-2002, total releases were calculated at 6.4 - 29 g I-TEQ/yr, of which the main part came from plants that did not already have dioxin removal equipment.

There are currently around 30 incineration plants in Denmark, and in 2004, they incinerated a total of 3.4 million tonnes of waste. From 28 December 2005, all plants have been required to stay within a limit value of 0.1 ng I-TEQ per Nm³ flue gas, corresponding to releases of about 0.65 μg I-TEQ per tonne of waste. Total releases can be calculated at a maximum of 2.2 g I-TEQ/yr if all plants stay within the limit value. Releases per tonne of waste have thus fallen to about 1/40 of the level at the end of the 1980s. These high levels of cleaning have been achieved by developing and applying filters to clean the flue gas, so that the dioxin created forms a bond to activated carbon, which is retained during the flue gas purification process.

b) Cement kilns firing hazardous waste

There is one cement factory in Denmark. The enterprise generally does not incinerate hazardous waste, but is licensed to incinerate oily sludges from cleaning up waste oil. Oily sludges only constitute a very modest part of the energy raw materials in the production of cement. The total release of dioxin from the production of 2.6 million tonnes of cement is estimated at 0.2 – 1.4 g I-TEQ/yr.

c) Production of pulp using chlorine or chemicals generating elemental chlorine for bleaching

Chlorine is not used for production of pulp in Denmark.

d) The following thermal processes in the metallurgical industry: i) secondary copper production; ii) sinter plants in the iron or steel industry; iv) secondary zinc production

These source types are not found in Denmark.

d, iii) Production of secondary aluminium

One enterprise carries out production of secondary aluminium from aluminium scrap. Measurements at the enterprise commenced at the beginning of 2000 showed very high releases of dioxin, and the enterprise has subsequently taken special measures to limit dioxin. In the most recent inventory, total releases have been calculated at <0.001 – 0.79 I-TEQ/yr, cf. table 2.

3.1.2 Annex C, Part III source categories

If nothing else is mentioned, the releases mentioned below are into the air.

a) Open burning of waste

According to the Statutory Order on Waste, burning of waste is only permitted in plants approved for the purpose. Approved plants are not necessarily waste incineration plants, but may be e.g. district heating plants that have achieved environmental approval to use specified waste types as fuel. Municipal councils are authorised to lay down regulations permitting burning of garden waste and certain similar types of waste.

Burning of painted or pressure-impregnated wood is regarded as waste incineration. Open burning of this type waste is thus prohibited. According to the mass-flow analysis, there may be a certain amount of waste wood in intentional fires, which has a significant influence on the generation of dioxin. Due to uncertainties as to emission factors as well as wood composition, the emissions in the most recent mass-flow analysis have been determined at 0.03-6.5 g I-TEQ/yr with a very large uncertainty factor. Thus, it is currently not possible to say whether intentional fires contribute significantly to total releases.

b) Thermal processes in the metallurgical industry not mentioned in Part II

Other thermal processes in the metallurgical industry comprise iron and metal foundries as well as hot-dip galvanising. Total dioxin releases from these processes have been calculated at 0.02-0.5 g I-TEQ/yr.

Production of secondary steel from scrap was previously an important source, but from April 2006, remelting of steel scrap is no longer being carried out in Denmark, because Dansteel A/S (formerly Danish Steel Works) now merely processes steel slabs imported from Russia.

c) Residential combustion sources

Wood-burning stoves contribute significantly to total dioxin releases. Total releases from wood-burning stoves in Denmark were calculated at 0.4-22 g I-TEQ/yr in 2000-2002. On the basis of further measurements, the uncertainty in the calculation has become less significant, and total emissions were most recently calculated at 2-4 g I-TEQ/yr.

The extent to which waste, including painted or treated wood, is burned in wood-burning stoves and wood furnaces in individual households is uncertain. This contributes to uncertainty as to the total releases from households. Burning of painted and impregnated wood in wood-burning stoves and furnaces is prohibited, as mentioned above, but probably takes place to a certain extent.

Since the first studies of dioxin releases from wood-burning stoves in 1990, a large number of studies have been carried out to understand the mechanisms behind generation of dioxin in wood-burning stoves and how this dioxin generation can be reduced. It is clear that burning of waste in wood-burning stoves increases dioxin generation. Therefore, the Danish EPA has carried out several campaigns to inform the general public of the problems of burning waste in wood-burning stoves.

Measurements have shown a clear connection between dioxin generation and the size of the installation. Burning of straw and wood in larger boilers generates very low dioxin emissions, while burning in smaller installations such as farm installations, small wood pellet boilers and wood-burning stoves generates emissions that are up to several hundred times larger. Dioxin concentrations in the flue gas from wood-burning stoves and smaller farm installations are typically around ten times the limit value of 0.1 ng I-TEQ/m³, which applies to incineration plants and industrial installations.

In connection with measurements of emissions from wood-burning stoves in a small village (Gundsømagle), we see a possible connection between the size of emissions and the type of chimney. Thus, emissions seem to be smaller from houses with steel chimneys. Currently, studies are being carried out to find out whether this is a general phenomenon and which mechanism lies behind it.

In the most recent study of emissions from wood-burning stoves, where simultaneous measurements have been made of particles, PAH and dioxin, no connection was found between emissions of dioxin and particles or between emissions of dioxin and PAH. There is a clear tendency towards newer wood-burning stoves having lower dioxin emissions; emissions from older wood-burning stoves vary from 5.1-17.7 ng I-TEQ/kg wood, while emissions from newer wood-burning stoves (< 3 years) lie at 0.2-3 ng I-TEQ/kg wood.

The concentration of dioxin in flue gas from wood-burning stoves and farm installations for burning straw generally lies above the concentrations seen in flue gas from incineration plants and industrial installations.

d) Fossil fuel-fired utility and industrial boilers

Total emissions from coal-fired power plants and other energy generation based on fossil fuels are calculated at 0.5-4.5 g I-TEQ/yr. Emissions from Danish coal-fired power plants were estimated with very large uncertainty in the most recent mass-flow analysis, but in any case, total emissions are relatively small, and the concentrations in flue gas are many times lower than the 0.1 ng I-TEQ/m³ that apply for incineration plants and industrial installations. Emissions from burning coal in industrial boilers have not been studied to the same extent, but emissions per tonne of coal are estimated to be higher than from coal-fired power plants.

e) Firing installations for wood and other biomass fuels

In Denmark, there are many small installations for burning wood chips, wood pellets, wood waste and straw. The installations are very different and so is the degree of releases of dioxin. Generally, small farm installations without flue gas purification have much higher emissions than for example combined heat and power plants with full flue gas purification. Total emissions from burning of biomass, excluding wood-burning stoves have been calculated at 0.3-19.4 g I-TEQ/yr in the mass-flow analysis, and the small installations represent the overall majority.

f) Specific chemical production processes releasing unintentionally formed POPs

This source type does not exist in Denmark.

g) Crematoria

Measurements from Danish crematoria show relatively low dioxin emissions, and total dioxin emissions have been calculated at 0.01-0.1 g I-TEQ/yr.

h) Motor vehicles, particularly those burning leaded gasoline

For many years, the use of leaded gasoline in motor vehicles has been banned in Denmark. Total emissions from motor vehicles have been calculated at <0.2 g I-TEQ/yr, while total emissions from other transport processes have been calculated at 1.3-1.5 g I-TEQ/yr which is mainly attributable to shipping and train transport.

i) Destruction of animal carcasses

Destruction of animal carcasses through incineration only takes place to a limited extent in Denmark and mainly constitutes animal carcasses from veterinary practices and residue from the normal destruction method. In the mass-flow analysis, emissions from treatment of animal carcasses are assessed to be marginal.

j) Textile and leather dyeing (with chlorine) and finishing (with alkaline extraction)

In Denmark, there is no ban against the use of chloranil, but the substance is classified as carcinogenic, toxic and environmentally dangerous. The Product Register for chemicals has recently been updated, and it shows that there is currently no registered use of chloranil in Denmark.

k) Shredder plants for the treatment of end-of-life vehicles

In the most recent mass-flow analysis, dioxin emissions from car breakers in Denmark are assessed to be marginal. Since PCB-containing capacitors have not been used for the last 20 years, not many of the white goods scrapped today will contain these capacitors. According to the WEEE Order, PCB-containing capacitors must be removed before the equipment is treated further.

l) Smouldering of copper cables

Thermal smouldering of certain types of cables containing oil was previously carried out by a single enterprise. One measurement referred to in the most recent mass-flow analysis is below the limit value of 0.1 ng I-TEQ/Nm³ in the Guidelines for industrial air pollution control, and total emissions in 2000 were estimated at <0.00002 g I-TEQ/yr. Subsequently, the enterprise has stopped its thermal treatment of cables, which are now exported for treatment abroad.

Private burning of cables is prohibited, and is not assessed to take place to any noticeable extent.

m) Waste oil refineries

Refining of waste oil is carried out at one enterprise in Denmark. Discharges from this process are, however, assessed to be marginal in relation to discharges from burning waste oil, and in recent years, measurements have been taken for dioxin emissions from a number of installations that burn either unrefined or re-refined waste oil. The most recent mass-flow analysis estimates dioxin emissions from burning of waste oil in Denmark at <0.17 g I-TEQ/yr.

3.1.3 Other source types not mentioned in Annex C of the Convention

Other industrial high-temperature processes

In recent years, measurements have been made in Denmark for a number of other high-temperature processes such as production of tiles, lime burning and production of insulation materials. Analyses confirm that these processes only contribute modestly to total emissions. Total emissions from other industrial high-temperature processes have been calculated at 0.04 – 0.1 g I-TEQ/yr.

Fires

Among the remaining dioxin sources, accidental and intentional fires may be significant sources, but it is, however, very difficult to determine their extent. In order to be better able to assess the risk of dioxin pollution from fires, the Danish EPA published a manual on the assessment of spreading of dioxin and other environmentally harmful substances from uncontrolled fires (”Håndbog om vurdering af spredning af dioxin og andre miljøskadelige stoffer fra ukontrollerede brande”) in 2004.

Studies of dioxin contents in soil and fallen soot around fire sites have shown slightly increased values of dioxin, but it has not been possible to determine the amount of dioxin generated from the incidents on the basis of the studies. Studies of dioxin in the proximity of large fires, where large amounts of PVC have been burned, show that substances emitted from a fire spread over a large area and will only very rarely lead to pollution of the surrounding areas to an extent that can affect the health of the local population. Releases from fires can primarily be reduced by limiting the use of substances and materials that are particularly prone to developing dioxin. Bans against the use of substances like PCB and PCP have thus largely been intended to limit the risk of generation of dioxin in fires. A general reduction in the use of materials containing chlorine, including PVC, is also expected to lead to a reduction in the generation of dioxin from fires.

Total emissions from fires have been calculated at 0.5-20 g I-TEQ/yr, which indicates that fires, despite uncertainties, should be regarded as a significant source of releases of dioxin into the air.

Dioxin in wood treated with pentachlorophenol (PCP)

In Denmark, pentachlorophenol contaminated with small amounts of dioxin was used for impregnation of wood in the period 1950-1978. Some of this wood is still in use. Moreover, PCP may still be in disposable pallets from southern Europe. When the treated wood is used, part of the dioxin may be released into the air. A recent study by the Danish EPA showed that wood treated with PCP still contains dioxin, and that disposable pallets from southern Europe contain PCP, albeit in concentrations below the 5 mg/kg set in the "bekendtgørelse nr. 420 af 21. april 1996 om begrænsning af salg og anvendelse af pentachlorphenol" (statutory order no. 420 of 21 April 1996 on limiting the sale and use of pentachlorophenol). On the basis of these studies, total releases of dioxin into the air have been estimated at 0.03-5 g I-TEQ/yr, i.e. releases from PCP-treated wood may be significant, but it is doubtful.

3.2 Release of unintentionally formed HCB and PCB

As mentioned in the introduction, there is no inventory of releases of unintentionally formed PCB and HCB into soil, air or water for Denmark. Industrial processes known to be particularly prone to forming HCB do not occur in Denmark.

The source categories are assumed the same as for dioxin. Measures to reduce releases of dioxin are therefore also expected to reduce releases of the other substances.

On the basis of the results from an EU study that is expected to be completed in mid-2006, a study will be made to evaluate if there are hitherto overlooked sources in Denmark that may form unintentional POPs, focusing on HCB and PCB. The study will cover emissions to air, water and soil. If this appears to be the case, an estimation will be attempted, taking into account the need for comparable data In the EU and internationally. Also, it will be considered whether there is a need for further measures.

3.3 Maintenance of release inventories

In Article 5, the parties undertake to develop and maintain source inventories and release estimates.

This obligation was implemented via Article 6(1) of the POP Regulation, which directs Denmark and the other EU Member States to develop and update inventories of releases of dioxin, furan, PCB, HCB and PAH into air, water and soil respectively.

The Danish EPER register, which is managed by the Danish EPA, will be extended due to the implementation of the PRTR Protocol. The register contains information on releases into the air and water from point sources and will also, in time, contain information on releases to soil as well as information on diffuse sources. However, this information is not expected to be sufficiently complete in the near future to allow overall inventories of releases of POPs from Danish sources to be drawn from the register.

NERI prepares annual inventories of dioxin releases into the air, which are reported to UNECE and the European Environment Agency. Inventories of releases into soil and water have been made in connection with mass flow analyses. So far, no inventories have been made for releases of HCB and PCB.

4 Evaluation of the effectiveness of existing legislation and policies

A number of instruments in EU legislation and Danish environmental protection legislation help bring down releases of POPs formed unintentionally.

The following section evaluates the existing legislation and strategies for each source category in relation to the Stockholm Convention commitments.

The main strategies in the Convention to reduce releases of unintentionally formed POPs are the requirements to use best available techniques (BAT) and best environmental practices (BEP) as well as the requirement to promote the development and, where it is deemed appropriate, require the use of substitute or modified materials, products and processes.

In Denmark, the main initiatives giving rise to significant reductions in releases of dioxin have been:

• Establishment of systems to remove specifically dioxin from flue gases at incineration plants and industrial installations with high emissions of dioxin;
• Establishment of improved flue-gas cleaning systems at large installations for combustion of fossil fuels and biofuels (not specifically aimed at dioxin);
• The ban on using PCPs;
• The ban on private burning of waste;
• The strategy to limit burning of PVC at incineration plants.

Requirement to use BAT for large sources

The Danish Environmental Protection Act is based on the fundamental principle that overall pollution of the surroundings should be prevented or limited as much as possible. On this basis, the Environmental Protection Act, in accordance with the principles in the Stockholm Convention, requires individual enterprises to use BAT, so that overall pollution is minimised. In order to assess what actually is the best available techniques, priority should be primarily on preventing pollution by using cleaner technology. In addition to this, unavoidable pollution should be limited as far as possible using pollution mitigation measures, including best possible decontamination/remediation.

The Guidelines for industrial air pollution control, which are applied in the administration of the Environmental Protection Act, contain a description of how air pollution from enterprises is to be regulated. The Guidelines stipulate that emissions should be limited in order to reduce releases of dioxin if the annual mass flow of dioxin is greater than 0.01 g I-TEQ, and that releases of dioxin should be minimised. According to the Guidelines, the limit value for emissions should be set at 0.1 ng I-TEQ/Nm³. However, for technical or financial reasons, it may be necessary to accept a limit value of 0.2 ng I-TEQ/Nm³ for some types of enterprise. The Guidelines also set a limit value for emissions of PCB at 0.0001 mg/Nm³, but no limits have been set for HCB.

The Danish EPA reference laboratory for measurement of emissions into the air has prepared a report (in Danish) “Måling af dioxinemissionen fra industrielle anlæg” (measurement of dioxin emissions from industrial installations). The report is helping the supervisory authorities assess and determine whether and how measurements of dioxin emissions at industrial installations are to be carried out, and it is helping them establish a framework so that control measurements are conducted correctly and the results are correctly assessed.

For the majority of the industrial processes in Denmark, the requirements on use of BAT will result in dioxin emissions below the recommended limit value in the Guidelines. At many types of source, for example power stations, releases of POPs are limited as a result of flue gas purification, the primary objective of which has been to reduce emissions of particles and acidic flue gases.

The requirement to use BAT is a core element in the IPPC Directive, which covers the largest stationary sources of POPs formed unintentionally. The IPPC Directive has been implemented in Denmark via the Danish Environmental Protection Act and the Statutory Order on Approval of Listed Activities. In association with the IPPC Directive, EU-level work is being conducted on BREF notes, which describe the techniques considered as BAT. These notes are part of the foundation for supervision authorities’ administration of the Environmental Protection Act.

The techniques considered as BAT will change over time as a result of technological development, and the Danish EPA is continuously assessing whether the specific requirements placed on heavily polluting enterprises are in line with developments in BAT.

The Environmental Protection Act and the statutory orders issued pursuant to the Act (e.g. Statutory Order on Approval of Listed Activities (the Approval Order)) form the legislative foundation for meeting the obligations in the Stockholm Convention commitments for large stationary sources. Preparation of guidelines for the supervisory authorities ensures that they have the required knowledge to implement the provisions effectively.

Diffuse sources

With regard to diffuse sources, the most important instrument is the Statutory Order on Waste. The requirements in the Statutory Order on waste collection systems and that waste should be collected and treated at approved installations, prevent almost all uncontrolled burning and the resulting releases. The Statutory Order also stipulates that waste may only be incinerated at approved installations.

The existing legislation and the associated strategies for limiting releases of unintentionally formed POPs are summarised in table 4.

Table 4
Existing legislation and strategies for limiting releases of unintentionally formed POPs

4.1 Evaluation of existing legislation and policies in relation to individual source categories

4.1.1 Annex C, part II

a) Incineration plants

The Statutory Order on incineration plants sets a limit value for emissions of dioxin from incineration plants of 0.1 ng I-TEQ/ Nm³. The limit value has applied to new installations since 24 March 2003. The limit value has applied since 28 December 2005 for existing installations. The limit value corresponds to emissions of about 0.65 μg I-TEQ per kg waste for incineration of domestic waste. If all installations comply with the limit value, the total emissions will be a maximum of 2.2 g
I-Teq/yr, corresponding to about 7 per cent of the total emissions from incineration plants in 1990.

The existing limit value is deemed to correspond to the currently attainable value using best available techniques (BAT) and therefore it meets the requirements of article 5 of the Stockholm Convention regarding use of BAT for new sources within annex C, part 2 categories of sources, when applying article 5(g) of the Convention on use of limit values.

In order to ensure that incineration plants comply with the limit values, they make regular control measurements. The inspection authorities as well as the Danish EPA will regularly assess the need for tighter supervision and control.

Over the past decade, waste arisings discarded through incineration have risen from 2.2 million tonnes to 3.4 million tonnes; a trend which, if it continues, could also result in increasing amounts of dioxin emissions. The increase in the amount of waste is particularly a result of increased economic activity in society. Decoupling the growth in waste from economic growth is therefore one of the three fundamental principles in the Government’s waste policy for 2005-2008.

All waste suitable for incineration in Denmark must be incinerated at incineration plants with energy recovery. This practice minimises the risk of dioxin being formed by unintentional fires at waste sites. However, there is a ban on burning impregnated wood at waste incineration plants, except for wood treated with creosote. This is primarily to avoid additions of heavy metals to incineration plants.

Most of the dioxin formed in incineration processes ends in waste products. The composition of the input waste has a significant impact on the volume and quality of residues. As a result of the previous waste plan, Waste 21, requirements have been introduced stipulating that a number of waste fractions containing environmental contaminants must, as far as possible, be prevented from reaching waste incineration plants. Examples of these fractions include impregnated wood, electronic equipment, and PVC. Reduction of the production of POPs has not been the main reason for separating these waste fractions, but a side benefit will probably be reduction of unintentional production of dioxin and other POPs in the incineration process.

The Danish EPA will regularly assess the effectiveness of the various measures in order to ensure that, as far as possible, waste fractions containing environmental contaminants do not end in incineration plants.

b) Cement kilns firing hazardous waste

Emissions from the only Danish cement factory are estimated at 0.2-1.4 g I-Teq/yr, based on measurements which show concentrations in flue gas varying between <0.0006 and 0.15 ng I-TEQ/Nm³. Oil sludge constitutes a very small fraction of the energy raw material for cement production, and it is not considered a significant source of chlorine. It is deemed that the flue-gas cleaning technology applied corresponds to BAT, and there are no plans to place requirements for specific dioxin cleaning.

d, iii) Secondary aluminium production

Three measurements in 2000 of dioxin emissions from the only Danish company manufacturing secondary aluminium showed concentrations in flue gas of 183, 113 and 14 ng I-TEQ/Nm³ respectively. A concentration of 183 ng I-TEQ/Nm³ corresponds to annual releases of about 60 g I-Teq/yr. In 2001 the company was therefore ordered to reduce the releases and has subsequently established dioxin cleaning equipment using activated carbon.

In the most recent inventory from 2000-2002, total releases were calculated at
<0.001-0.79 I-TEQ/yr. The most recent measurements are in accordance with the recommended limit value in the Guidelines for industrial air pollution control of 0.1 ng I-TEQ/Nm^3, and the total releases will be 0.03 g I-Teq/yr. The requirements of the Environmental Protection Act have thus been an effective instrument in reducing dioxin releases.

At EU level an assessment is being carried out of the possibilities of setting limit values for releases of POPs from metallurgical processes, and Denmark is awaiting the results of this work.

4.1.2 Annex C, part III

a) Open burning of waste

According to the Statutory Order on Waste, burning waste is only permitted in approved plants. Open burning of waste and burning waste in stoves and boilers is banned under all circumstances. Burning painted or impregnated wood is also considered waste incineration.

Burning painted and impregnated wood in stoves and boilers does seem to happen to a not inconsiderable extent, despite the ban, but no studies of the scope of the problem have been made. There are well-developed waste schemes throughout Denmark, and with the existing schemes there is no general financial incentive for private citizens to burn waste, except for using the calorific value of the waste. Private burning is probably more attributable to some people considering this method of disposal as the easiest for some types of waste.

Over the past five years, a number of campaigns have been completed to urge people to stop burning painted wood and other waste, including in private stoves.

The Danish EPA considers that there is still a need to tell the public not to burn waste and is planning to continue the use of the campaign materials.

b) Thermic processes in the metallurgical industry not mentioned in part 2

The requirements in the Environmental Protection Act that individual enterprises use best available techniques (BAT) is deemed effective in reducing releases from other thermal processes in the metallurgical industry.

As stated in table 2, releases from manufacturing secondary steel amounted to 7.5 g I-Teq/yr in 1995. The enterprise has subsequently stopped production from smelting scrap steel, and this was the only part of the enterprise’s activities causing releases of dioxin.

c) Residential combustion sources

As mentioned above, a number of studies have demonstrated that dioxin releases from stoves and farm installations which burn straw can be considerable, and they are related to the size of the installation.

There are no requirements at present for flue gas purification from stoves, but a labelling system has been introduced for new stoves, which is intended to promote the use of clean-burning stoves with high energy efficiency.

In recent years the Danish EPA has conducted a number of studies in order to achieve a better understanding of the mechanisms around production of dioxin in stoves and boilers in order to prescribe methods which can reduce production and releases of dioxin.

As mentioned earlier, recent studies indicate that modern stoves lead to less dioxin production than old stoves, and that the type of chimney may have an effect. A follow-up study of dioxin pollution from stoves is underway.

Total emissions could be reduced with a ban on burning biomass in small installations without flue gas purification, but such an initiative could have undesirable effects in the context of the goals to reduce total CO₂ emissions, and it would be hard to enforce. The area will be closely monitored and there will be regular considerations of what can be done as better knowledge comes to light.

d) Fossil-fuel-fired utility and industrial boilers

The most recent mass-flow analysis estimates emissions from Danish coal-fired power plants with great uncertainty, but at all events total emissions are relatively small. The concentrations in flue gas are many times lower than the 0.1 ng I-TEQ/Nm³ applying to incineration plants and industrial installations. The emissions from burning coal in industrial boilers have not been studied to the same extent and are thought to be higher than from coal-fired power plants, although still less than the 0.1 ng I-TEQ/Nm³. Limiting atmospheric pollution from coal-fired power plants has primarily been based on a desire to reduce emissions of dust and sulphur and nitrogen compounds, while limiting dioxin emissions has been a welcome side effect. Danish coal-fired installations are considered to meet BAT with regard to dioxin emission, and there are no plans for further initiatives to limit dioxin releases from this type of source.

e) Installations burning wood and other biomass fuels

In Denmark there are a number of small installations burning wood chips, wood pellets, wood residues and straw. There are great differences between the installations and the degree of dioxin emissions. Large installations, for example district heating plants, are regulated by the Environmental Protection Act and equipped with well developed flue-gas cleaning systems. These live up to the BAT requirement.

The problem is primarily the small farm installations without flue gas purification, which have far higher emissions than for example combined heat and power stations. The total releases from burning biomass, of which the small installations account for the majority, are considered to comprise a considerable proportion of Denmark’s total releases of dioxin.

As for private sources, the area will be monitored closely and there will be regular considerations of what can be done as better knowledge comes to light.

f) Crematoria

As mentioned above, measurements from Danish crematoria show relatively low dioxin emissions, with dioxin emissions below the recommended limit value in the Guidelines. The low emissions are attributable to good incineration at high temperatures, as required in the Danish EPA environmental guidelines ”Begrænsning af forurening fra forbrændingsanlæg. Vejledning nr. 60.273 af 01/01/1993 ("Limitation of pollution by incinerator plant. Guideline No. 60.273, of 1st January, 1993"). The Danish EPA is preparing a sector annex for crematoria, to be finished in mid-2006, in which there will be requirements that crematoria take measures to limit emissions of mercury. The measures aimed at reducing mercury will also reduce releases of unintentionally formed POPs as a positive side effect, as has been documented in measurements at two Danish crematoria. There are no plans for further requirements to limit dioxin releases from crematoria.

g) Motor vehicles, particularly those burning leaded gasoline

For many years, the use of leaded gasoline in motor vehicles has been banned in Denmark, except for a modest use by propeller aircraft, where bromine-containing additives are also used. The Danish EPA is currently considering whether there are possibilities for further reductions in the use of leaded gasoline for this purpose.

Much work is going on to reduce particle pollution from diesel motors, and a side effect of this will probably be reductions in dioxin emissions from diesel-powered motor vehicles.

The Danish EPA does not consider that there is a need to take further steps to reduce releases of dioxin from transport processes.

h) Shredder plants for the treatment of end-of-life vehicles

The requirement to remove capacitors containing PCB from white goods and other electronic equipment before dismantling means that a significant source of production of dioxin in the process has been removed. Today, Danish car-breaking installations are also fitted with equipment to decontaminate exhaust air from the installation. The Danish EPA has no plans for further initiatives to limit dioxin releases from this source.

Not mentioned in the annexes to the Convention

Accidental fires

There remains great uncertainty as to the extent fires add to the total releases of dioxin in Denmark. Formation of dioxin requires the presence of chlorine, but it is still uncertain how much building materials and fittings containing chlorine, e.g. in PVC, increase the amount of dioxin formed in fires.

Dioxin in wood treated with pentachlorophenol (PCP)

The size of releases from wood treated with pentachlorophenol is uncertain. As mentioned above, pentachlorophenol seems mainly to appear in disposable pallets from southern Europe.

5 Strategies to meet the obligations of the Convention

Large point sources

The assessment is that with existing legislation and strategies for large point sources, Denmark meets the obligations under the Stockholm Convention for these categories of source.

Today, the challenge for incineration plants is to prevent increasing amounts of waste, in so doing reducing the risk of increasing releases, and the amount of residues which must be deposited.

Further initiatives will therefore involve decoupling the increases in the amounts of waste from economic growth and further efforts to limit additions of PVC to waste incineration plants. PVC leads to the production of large quantities of residues. It is not clear the extent to which less PVC will result in less production of dioxin, but it is likely to be a positive side benefit.

As mentioned above, the new requirements for crematoria on reducing releases of mercury will also result in side benefit of reducing releases of dioxin.

Wood-burning stoves and boilers burning biomass

Once emissions from waste incineration plant and industrial installations have been reduced, it is clear from table 1 that burning biomass potentially represents the largest source of releases of dioxin in Denmark. There is still great uncertainty regarding the size of the total releases.

In addition to releases of dioxin, these sources also make considerable contributions to Denmark’s total releases of PAH and particles. There is no immediate simple solution to this problem, which Denmark is likely to share with a large number of other countries burning biomass at smaller installations. Therefore, there is a need to study further how the releases of pollutants from these installations can be reduced.

The Danish EPA will continue examining the mechanisms behind production of dioxin in stoves and small boilers.

The Danish EPA considers that there remains a need to urge the public not to burn waste and about good stove practice, and it plans to continue using the campaign material already developed and available on the Internet.

The new initiatives to meet Denmark’s commitments under the Convention are summarised in table 5.

Table 5
New initiatives to reduce releases of unintentionally formed POPs

6 Measures to promote knowledge, teaching, education and information

6.1 Promotion of knowledge on sources of production and degradation of dioxin and dioxin-like PCB

In future years, and further to the activities already implemented, the Danish EPA will promote knowledge about sources of production and degradation of dioxin and dioxin-like PCB.

The activities in the study, as mentioned above, will include:

• A study of the degradation of dioxin in the Baltic Sea with a view to determining the extent to which dioxin, which is currently accumulating in fish, arises either from current atmospheric deposition or from remobilisation of dioxin bound to the seabed. The study will elucidate how much of the dioxin in fish is the result of ”sins of the past”.
• A study of the sources of dioxin in organic agriculture.
• Continued studies of the emissions of dioxin and other pollutants from wood-burning stoves and small boilers and the measures to be initiated to reduce emissions from these sources.
• On the basis of the results of an EU study, expected completed in mid-2006, the extent of overlooked sources in Denmark of unintentionally formed dioxin, PCB and HCB will be assessed. If it appears that there are overlooked sources, an assessment of the emissions will be made to the extent possible, and the need for further measures will be considered.

6.2 Education and information

Authorities and enterprises

In 2003 the Danish EPA issued a report on measurement of dioxin emissions from industrial installations, which helps the supervisory authorities assess and determine whether emissions measurements must be carried out, and it helps place the right requirements so that control measurements are performed correctly and the results are interpreted correctly. The report also acts as information for the enterprises involved.

The public

The public contribute primarily to unintentional production of POPs through burning waste and using problematic burning practices.

The campaign materials already prepared to limit private waste combustion and promote use of proper heating techniques in wood-burning stoves and small boilers are being distributed effectively by the relevant enterprises and organisations.

Teaching at schools

In connection with updating of relevant teaching materials for young people on chemicals, there will be more focus on POPs, and the need for targeted materials will be examined.

7 Update of the action plan

In accordance with the provisions in the Convention, the existing strategies and new initiatives in this action plan shall be evaluated five years after the adoption of this action plan, and every five years thereafter. The results of the evaluations will be included in the reports to be submitted in accordance with article 15 of the Convention.

8 Time Schedule

The action plan will be implemented in accordance with the time schedule below.

Table 6
Time schedule for the action plan

Footnotes

^[18] Source: Based on Hansen et al. 2003. Substance Flow Analysis for Dioxin 2002. Environmental Project no. 811. Danish EPA, Copenhagen.

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Version 1.0 June 2006, © Danish Environmental Protection Agency