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The analysis of the available records of the continuous measurements of atmospheric emissions at the Zubieta waste plant in the years 2020 and 2021, together with other available information, points to serious non-compliance with IPPC regulations on integrated pollution prevention and control.
The data confirms that during the first half of 2020 the Zubieta waste incineration plant was operating under the legal umbrella of a “test period”, although it did not comply with the technical or legal conditions for it.
During 2020 and 2021, the plant’s two incineration lines operated at approximately 50% of their capacity, with abundant shutdowns. This operating regime presented an average of more than one shutdown per week on each line, and an average of one monthly shutdown covering at least one full calendar day. This operating regime is a far cry from that advocated by European regulations.
From February to June 2020, before the Integrated Environmental Authorization (Autorización Ambiental Integrada, AAI) of the facility became effective, the plant was already incinerating waste in anomalous conditions, as it did not comply with the prior conditions required by law for the effective exercise of the activity, such as having all the corrective measures for pollutant emissions foreseen in the AAI. Therefore, in this period the facility presented 532 exceedances of ELV (Emission Limit Value) in line 1, and 1390 exceedances in line 2. As of June 16, 2020 (with the AAI already in force) there were 45 exceedances in line 1 and 21 in line 2. In 2021 there were 24 exceedances at line 1 and 11 exceedances at line 2. There were also 3 exceedances of daily emissions contract ELVs, one of which was also an exceedance of an AAI ELV.
The data confirms that the facility does not have the automatic control system required by the regulations, that must shut down the waste feed when there is an exceedance of any ELV. Since June 2020, the facility has 23 exceedances of ELVs that are not followed by immediate closure of the waste feed, in violation of the regulations. The latest non-compliances are from July 2021, in the two lines. Given that the facility could have incinerated waste during shutdowns, as it does not have automatic feed shutdown control, some exceedances in those periods should also be counted. In that case, total exceedances could amount, on line 1, to 65 in 2020 and 33 in 2021. More information is needed to confirm this data, which has been requested from the competent body, but access has been denied.
The incineration plant also did not have -at least in February and March 2020- the interlock system included in the project and required by the regulations, which must stop the incineration if 4 consecutive hours of operation with exceedances of ELVs happen. According to the records, line 1 began incinerating waste on February 7, with a particulate matter ELV exceedance. On February 9, it had a series of 14 consecutive ELV exceedances. The longest series of exceedances on record began on February 22, and lasted 26 hours. Line 2 began incinerating residues on February 14, concatenating 12 consecutive exceedances over 6 hours. The longest series of exceedances on record began on February 4 and lasted 4 days and 10.5 consecutive hours with no stoppage of the waste feed.
The records show that pollutant emissions during line startup and shutdown periods are substantial. For carbon monoxide (CO), they accounted in 2020 (as of June 16) for 24% (line 1) and 29% (line 2) of total emissions without stops. Emissions during shutdowns would be even higher for other substances (TOC, HCl, SO2). These data would be a clear indication that the abundant stops and starts of the facility have been an important source of emissions of polluting substances, although a reasonable doubt also arises as to whether during these periods of supposed “stoppage” waste was being incinerated, due to the absence of automatic control of waste feed to the furnaces.
Emissions, measured in terms per ton of waste incinerated, are always higher before the effectiveness of the AAI (June 16, 2020), than after. This could be another indicator that during the previous period the facility was incinerating waste without the necessary implementation of some corrective measures for atmospheric emissions.
This work is the result of collaboration between ekopol and the legal team of the citizens’ association guraSOS.
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