With the end of 2015 the first six months of the Israel Ministry of Environmental Protection’s second Twinning project has come to an end. During this period, an important step was reached: Gap analysis reports in all components have been completed.
During the second quarter of the project, several missions took place, focused on many of the recommended environmental fields being addressed in all components of the project: development of an environmental regulatory framework, environmental management systems and resource efficiency. The sub-fields include wastewater treatment (end of pipe and investigation of special treatment processes), hazardous waste management, air quality (continuous stack monitoring), hazardous substances, and soil protection. The missions were aimed at identifying weaknesses, potentials, and the need for further action. At the end of each mission, a gap analysis was prepared by the experts. These gap analyses will serve as a basis for guidance documents for each of the aforementioned fields, including manuals, recommendations, and guidelines.
Altogether, 14 missions involving 25 experts from three countries took place within 130 working days. Participants included, in addition to MoEP units and Twinning experts also external parties, like certified labs, industry, consulting firms, from the MAI (Manufacturers Association of Israel), environmental NGOs and other ministries like Energy, Economy and Agriculture. This multi-stakeholder involvement can help create tailor-made solutions (manuals, recommendations, workshops) in the future. Organizing the missions and the follow-up activities was no small task; in this vein, the exceptional work of Ms. Ayelet Ben Ami must be recognized, as she was responsible for compiling over 10 working plans. Once that was done, the core Twinning team created a schedule for the 24-month Twinning period. This includes coming up with timetables and expected results for Component 1 (Environmental Regulation), Component 2 (implementation of an environmental management system) and Component 3 (enhancement of resource efficiency), where -following the missions on material streams -, it was decided to change the focus to municipal waste and data collection.
With these results, we are on an excellent way to achieve the project goals.
Preparation of a Mission to revised TA Luft and implementation of BREF documents
Germany‘s process of amending its air pollution control regulation, known as Technical Instructions on Air Quality Control, or TA Luft, is in full swing. The Twinning team is organizing a mission with two experts from the German Environmental Agency who are responsible for the implementation of the new TA Luft in Germany. This will give Israeli Twinning partners the opportunity to gain insight into the revision process, and to see first-hand what elements German lawmakers consider important enough to keep from the existing TA Luft.
One of the German experts, Rainer Remus, who is responsible for the TA Luft amendment, wants to inform interested people from the MoEP about general changes in: paragraph 1 (Scope of Application), paragraph 2 (Definitions of Terms and Units of Measurement), paragraph 3 (General Principles for Granting a Permit, Provisional decisions and Permissions for Early Start) and 6 (Subsequent Orders), as well as in 5.1 (General), 5.2 (General Requirements to Emission Limits) and 5.3 (Measurement and Monitoring of Emissions) of TA Luft and additional BAT-related issues of the new TA Luft.
The amendment will allow for a suitable procedure concerning the quick implementation of BREF documents and conclusions.
Mr Michael Suhr, the second German expert, will be on hand to answer existing cross-sector questions regarding BREF documents generally, and give an overview about interpretation and implementation of IED, new developments in Brussels and Sevilla, information exchange to BAT, key questions, and implementation of BAT with regards to the Water Law.
Both Misters Suhr and Remus will present and discuss overlapping issues between TA Luft and BREF. We plan to organise a least one or two round table discussions during the four day mission in June (13.06. until 16.06.2016)
To have a better understanding about amendments in the new TA Luft both RTA Twinning Assistants, Benjamin and Marc, will make an effort to translate the amended drafted text of the new TA Luft by June. Please note that the translated document will only be a draft (the amendment is currently being circulated in Germany).
In order to be prepared for the mission, the German experts would like MoEP professionals to send in questions or potential ad hoc advice, so that they can properly answer all inquiries.
We believe this mission will be interesting and fruitful for the Israeli Twinning team, and hope to organise a second, similar mission as a follow-up.
Results of last mission in the field of hazardous waste management
Work on hazardous waste management continued in April 2016, with a third mission focusing on the issue. It was led by two waste management experts, Brigitte Karigl of Austria and Ellen Gerlach of Germany. This mission came after two previous missions, during which a gap analysis was drafted and work began on a hazardous waste classification manual. The manual describes the general procedure for waste classification and details the hazardous properties of waste and methods for testing for those properties. It includes also a list of Austrian Standards for waste analysis. During the mission, Ellen Gerlach provided insight into the German approach to the management of hazardous waste. In addition, the first draft of the manual was in the spotlight. There were discussions about adding detailed descriptions of special classification criteria of waste and hazardous properties. The Twinning team also decided to create a broader manual concerning classification of waste treatment installations. After intense discussions with waste experts from Austria, Northern Ireland, and Germany, Israeli MoEP professionals have decided to conduct case-by-case examinations to determine the allocation of recovery or disposal (R/D) operations of waste treatment installations. While the hazardous waste mission was taking place, two UK experts were in Israel for a second mission in the area of municipal waste management as a source of resource efficiency. As such, a round table discussion was organised with all the European waste management experts about the classification of waste treatment installations in R/D installations. These discussions should result in a manual that will help MoEP professionals understand how to best classify R/D installations. During the final meeting of the mission, the next steps concerning hazardous waste management were reviewed. A study tour in Austria will be arranged, aimed at furthering discussions on hazardous waste classification. Ultimately, the different European approaches being studied will help Israel’s Ministry of Environmental Protection determine their optimal approach to hazardous waste management. The next mission with experts from Austria and Germany will take place from 19.06.2016 until 23.06.2016.
Twinning Experts Help Calm Concerns about Planned Plant in North
(By Twinning team with the cooperation of Dorit Zis and Ram Greenwald, MoEP Northern District)
In late November 2016, two German environmental government regulators arrived in northern Israel for a mission focused on the potential environmental effects of a facility that was being planned by a flavor-enhancing company in northern Israel. The regulators, who had served as experts in previous Twinning projects, came in to give their expert opinions and recommendations regarding how to prevent or mitigate odor nuisances for residents within close proximity to the facility.
The expert visit followed large-scale public concern about an odor nuisance from the future plant; that concern resulted in a public campaign aimed at preventing construction of the plant in that location. After submitting relevant documents and organizing a round-table discussion in October, the Ministry of Environmental Protection’s Northern District office invited the experts, through the Twinning project, to review the documents, visit the site of the planned installation, and present their conclusions during a round-table discussion with all stakeholders. These include company representatives, ministry officials (represented by northern district manager Dorit Zis and industrial coordinator Ram Greenwald), representatives of the citizens' initiative, and the municipality.
The Twinning experts noted that the planned site of the new facility is not a chemical installation (i.e.: no changed processes would take place there), and therefore, would not have required an Integrated Pollution Prevention and Control (IPPC) permit in Germany. However, because odor was a potential problem, they recommended using technical means to prevent it, such as selling all production activities and discharging the concentrated air flows through RTO (regenerative thermal oxidizer).
The objective and professional opinions of the Twinning experts was particularly helpful to the MoEP’s Northern District office, which was in communication with the local municipality about building permit conditions for the plant. In short, the Twinning's expertise and knowledge proved to be a most efficient and helpful decision-making tool.
Emissions Inventory Mission
2 experts from Germany took part in an expert mission from October 18-22 (2016), focused on how to best integrate Israel's inventory of all pollutants emitted into the air with the country's PRTR database. The PRTR, or Pollution Release and Transfer Register, details which pollutants factories release to air, water, and soil, and/or transfer off-site for treatment or disposal. The information is taken from reports submitted by the factories themselves.
The European experts and Ministry of Environmental Protection officials responsible for Israel's PRTR analyzed possible ways to bring together the emissions inventory and the PRTR, since both databases contain, in essence, the same information. Israel's Ministry of Environmental Protection published its first PRTR in December 2013; the inventory was published January 2015.
Workshop: Thermal treatment of waste
The yearly so-called "waste forum", organized by the Israeli Ministry of Environmental Protection and the environmental NGO "Adam Teva V'Din", with participation of industry, a number of ministries and consultants took place this year On January 25th, 2017. Two Twinning experts gave presentations in the framework of this event.
Jürgen Kühn from the German Ministry of Environment (BMUB) talked about air emission aspects of thermal waste treatment in Europe: He pointed out that in Germany alone, 48 million ton of municipal waste in Germany are produced, with the legislation allowing to landfill only 5%. This, then makes thermal treatment a necessity, and so it is not surprising that there are over 100 thermal waste treatment facilities in Germany treating ca. 20 million ton of otherwise non-recyclable waste. Due to the economic potential of energy production by waste incineration, the largest part of the funding – over 70% - comes from the private sector. However, Kühn stressed, that the main concern of waste incineration shall always be removal of waste, and not energy production, which is a by-product.
Afterwards, Markus Gleis from the German Environmental Agency (UBA) focused on waste management in thermal treatment of waste in Europe. Gleis gave arguments for both RDF and thermal treatment of waste (RDF is especially useful in commercial waste, since it is more homogenous), and gave an overview of the thermal treatment sector in Germany, both in terms of quantity (24-25 million tons of waste is incinerated in ca. 69 so-called "mass-burning" facilities) and in terms of quality: In his words – "no one is smarter than he who has experience", and experience shows that the transition from landfill to thermal treatment can only be done gradually, in small steps, and not at once. Finally, Gleis also mentioned the upcoming update of the thermal waste treatment BREF, with which he is involved with.
In summary can be said that the Twinning contribution to the waste forum helped the Israeli colleagues get a better understanding of the situation in Europe, and to implement the transition from landfill to thermal treatment in a way paved by the European experience.
Workshop: Classification of Waste
On February 22nd, 2017, a large training workshop of two key Twinning experts, one from Austria and one from Germany, took place. Preceding it, in their last missions in April, June and November 2016, the experts had developed two manuals “Manual of Classification of Waste” and „Classifiction of waste treatment installations“. After internal discussion with the Israeli Colleagues, the manuals had been finished and are now translated into Hebrew.
The workshop, which took place in collaboration of the Twinning project and the MoEP with participation of industry, environmental NGOs, served as a training for the waste producing industries, other waste owners and operators of waste disposal and recovery facilities. Its foci were waste classification and waste assessment.
During the workshop the participants from industry and enterprises got an introduction of the content of the “Manual for Waste Classification”. Subsequently they were familiarized with the examples and the way to assess a waste. The manuals were presented and discussed. For better understanding of the European Waste Catalogue (EWC), the key document for classification of waste, a presentation about this issue was prepared by the Twinning experts. In addition to the manual, case studies of waste classification and assessment were prepared and presented in the workshop.
In order to supply the participants with written information, a quick guide for waste classification was developed. The flyer "Quick Guide for Waste Classification” was distributed to the participants of the workshop. The remaining time was dedicated to discussing the following questions concerning the classification of waste treatment operations as R or D operations: calorific value of RDF or other alternative fuels (recommended: > 11,000 kJ/kg), minimum content of mineral oil in emulsions for classification of R/D of the emulsion splitting.
In summary can be said that the products of this mission ,the last one on hazardous waste in this Twinning project, will form the base of a better understanding of the waste sector in general, and hazardous waste in particular, which will lead to a more successful cooperation between waste-producing industry and waste-regulator.
Workshop: Training on finalized manual on wastewater stream inventory
On March 1st, 2017, a large training workshop of a key Twinning expert, BREF-author Dr. Bernd Serr took place on waste water stream inventories and the related manual. This workshop, whose participants included representatives of the MoEP, industry and consultants, was very successful and reflected the increasing acceptance of industry stakeholders of the new tool of waste water stream inventory over the duration of the Twinning project.
After Danniel Sharon from the MoEP wastewater department introduced the BREF documents and use of stream inventory, Dr. Serr presented the stream inventory database as well as a sample case, and summarized the situation of chemical installations in Israel. A major milestone discussed was the use of Zahn-Wellens test by an Israeli lab (Bactochem), a representative of which also gave a short presentation. As the Zahn-Wellens Test is the key into a transparent management of waste water from organic chemical installations, this development marks the real start-up of the stream inventory tool.
The Twinning manual on wastewater stream inventory, originally written in English, had been translated into Hebrew and sent out for comments and question, which formed, together with the workshop itself, the basis of a lively professional discussion. BAT compliance and threshold of load sources were some of the issues debated.
In summary can be said that the products of this mission ,the last one on wastewater in this Twinning project, and of the previous ones, will form the base of a successful cooperation between industry and regulator, and of a more streamlined process.
The presentation of the German key expert which was presented during the workshop is available under Project related Downloads and Documents.