International Review of Waste Management Policy - Department of ...

might be argued that no threshold applies, and the issue is whether or not a process
is, on assessment, established to be a net emitter of dioxins and furans. The effects
would most likely be quite significant for Ireland in terms of both recycling, and the
consideration of alternatives to incineration. This matter has been discussed in more
detail within a Strategic Environmental Assessment of a proposed Section 60 Policy
Direction. 1091
As discussed in Annex 1.0, the UNECE POPs Protocol obliges Parties to reduce their
emissions of dioxins, furans, polycyclic aromatic hydrocarbons (PAHs) and HCB below
their levels in 1990 (or an alternative year between 1985 and 1995). The dioxin
emissions in Ireland are low – and this is reflected in the most recent results of the
ongoing national dioxin surveys. 1092 The 2002 dioxin inventory, however, suggests
that Ireland plans to increase dioxin emissions over the period from 2000 to 2010
and that the main increase would be in incinerator residues. 1093 It is difficult to
reconcile this with the obligations of the UNECE POPs protocol.
The addition of nine new POPs to the Convention at the fourth Conference of the
Parties seems likely, within Europe, to lead to a revision of Regulation 850/2004, and
this will have knock-on implications for Ireland. In this context, it would seem to make
sense to avoid making commitments that prejudice future compliance with what is a
predictable change in regulation. The Annex A listings of c-Octa BDE and c-Penta BDE
significantly increase the likelihood that brominated dioxins and furans (‘PBDD/DFs’)
will soon be proposed for similar listing because PBDD/DFs are both contaminants of
the newly listed flame retardants and are also by products from their combustion. It
is notable that the EPA has already started testing for these compounds in the annual
dioxin surveys. 1094
Releases of unintentionally produced by-products (chlorinated dioxins, chlorinated
furans, PCBs and HCB) are subject to continuous minimisation and ultimate
elimination where feasible. The main tool for this is an action plan which should
cover source inventories and release estimates, as well as plans for release
reductions.
The EPA is currently working on the preparation of a draft national implementation
plan (NIP). 1095 Once completed this draft will be made available for public
consultation. In June 2008 the EPA prepared a short consultation paper to provide
interested parties with more information on the proposed NIP. Written
1091 Eunomia (2009) Section 60 Policy Direction Capping Incineration of Municipal Waste and Other
Matters, Environmental Report for DoEHLG, June 2009.
1092 C. Concannon (2008) Dioxin Levels in the Irish Environment 2007 Fifth Assessment Based on
Levels in Cow's Milk November 2008. 2008: Dublin, Ireland
1093 F. Hayes and I. Marnane (2002) Inventory of Dioxin and Furan emissions to air, land and water in
Ireland for 2000 and 2010 Final Report, Prepared for the Environmental Protection Agency By URS
Dames & Moore: Dublin.
1094 C. Concannon (2008) Dioxin Levels in the Irish Environment 2007 Fifth Assessment Based on
Levels in Cow's Milk November, Environmental Protection Agency, Ireland.
1095 http://www.epa.ie/whatwedo/resource/hazardous/pops/
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