Review of the Chemical BREFs under the Industrial Emissions Directive (IED, 2010/75/EU)

Transcription

1 under the Industrial Emissions Directive (IED, 2010/75/EU) 7+7 European Chemical Industry Group Madrid, 10 June 2016 Serge Roudier Head of the European IP Bureau (EIPB) European Commission's Joint Research Centre 1 1

2 IPTS in the context of the Joint Research Centre (JRC) European IP Bureau (EIPB) ~20 staff within the Sustainable Production and Consumption (S) Unit of the Institute for Prospective Technological Studies (IPTS) 2 2

3 Outline 1 - The Industrial Emissions Directive (IED) 2 - The Sevilla process 3 3 3

4 1 - The Industrial Emissions Directive (2010/75/EU) 4 4

5 Industrial Emissions Directive 2010/75/EU (IED) Key instrument for minimising consumption and emissions of industrial activities in Europe General framework: prevent and, if not feasible, reduce pollution high level of protection for the environment as a whole permit based on Best Available Techniques (BAT) BAT are determined by a Technical Working Group steered by the JRC (EIPB) and documented in BREFs BAT conclusions are secondary legislation 5 5

6 Wide range of industrial activities listed: Energy industries Production and processing of metals Mineral industries Cement, lime, glass, ceramics Production of chemicals Waste management industries Several recovery or disposal operations Incineration Other industries: Pulp and paper, textile processing Tanning of hides and skins Annex I to the IED Intensive farming of pigs and poultry, slaughterhouses and animal by-product processing, food drink and milk processing, surface treatment using organic solvents ~ IP installations in Europe (~ 10 % chemical installations) 6 6

7 Chemical installations covered by the IED and chemicals sales EU chemicals sales Source: Cefic Chemdata International 5074 IED installations (estimation) Source: DG ENV 7 7

8 Environmental scope of the IED emissions to air prevention and control of accidents noise waste prevention and recovery vibration emissions to water heat energy & water use odour 8 8

9 Best Available Definition of BAT in the IED Most effective in achieving a high general level of protection of the environment as a whole Developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions Techniques Both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned Note: in determining BAT, special consideration should be given to the criteria listed in Annex III of the IED 9 9

10 Role of BAT conclusions in IED permitting a) BAT conclusions are the reference for setting permit conditions Art. 14(3) b) Permits to contain emission limit values (ELVs) to ensure that, under normal operating conditions, emissions do not exceed BAT-associated emission levels (BAT-AELs) Art. 15(3) a+b c) Derogation from BAT AELs is only possible in specific and justified cases: Art. 15(4) costs disproportionately higher than environmental benefits due to (a) geographical location or local environmental conditions; or (b) technical characteristics of the installation without jeopardy to Environmental Quality Standards (EQS) or IED ELVs public participation in their granting Art. 24 MS report to the public / Commission on use of derogations Art. 24(2)(f) / Art. 72 d) Monitoring conditions: based on BAT conclusions Art

11 Reconsidering / updating permit conditions (IED Article 21) 4 years BAT conclusions published in the OJ (a) all permit conditions reconsidered and updated (b) the installation complies with those conditions The reconsideration shall take into account all the new or updated BAT conclusions applicable to the installation and adopted since the permit was granted or last reconsidered IED permit 11 11

12 2 - The Sevilla process A complex consensus-building exchange of information with numerous stakeholders and underpinned by sound technoeconomic information that has been enshrined into law by: Commission Implementing Decision 2012/119/EU 12 12

13 Exchange of information on BAT: actors GLS (Glass) Industry Member States Env. NGOs Commission EU Member States Committee (IED Article 75) Forum (IED Article 13) led by the Commission: industry, Member States, environmental NGOs European IP Bureau (EIPB) WT (Waste Treatment) Industry Member States Env. NGOs Commission FMP (Ferrous Metals Processing) Industry Member States Env. NGOs Commission Members of the Committee: vote the BAT conclusions Forum members: guidance to COM nominate in TWGs formal opinion on BREFs BREF authors team: lead TWGs validate/check information draft BREFs present BREF to Forum 34 Technical Working Groups (TWGs) TWG members: research information peer review draft BREFs 13 13

14 Exchange of information on BAT: workflow Industry TWG kick-off meeting Member States + EFTA and Accession Countries Bulk of info. needed (incl. questionnaires) * optional Pre-final draft Draft 1 (D1) Draft 2 (D2)* Final TWG meeting Final draft BREF 14 TWG comments Forum opinion on BREF Adoption of BAT conclusions through the IED Article 75 Committee BAT conclusions 14 14

15 Data collection step is crucial for determining BAT The information on key environmental issues is obtained through plantspecific questionnaires covering: emissions to air and water generation of residues (i.e. by-products and wastes) use of resources (e.g. energy, water) techniques that are potential BAT candidates Importance of contextual information: details on the techniques used (characteristics, historical data) other than normal operating conditions link between the fuel characteristics and generated pollutants consumptions (e.g. raw water, energy, chemicals) 15 15

16 Ultraf Ultraf SF Filtr NI Filtr SF SF NI NI NI Flot NI NI NI Flot Flot SF Flot Flot Flot SF NI Flot SF SF NI TSS (mg/l) European Chemical Industry Group BAT is about real plant performance: Waste water treatment in the chemical sector (Zoom) Effluent values not shown in the graph: < LOD: #69 () < 5 mg/l: #36 () Abbreviation Filt Flot NI SF Ultraf Meaning logical treatment Filtration (includes MBR and sand filtration) Flotation No information provided Physico-chemical treatment only imentation Sand filtration Ultrafiltration BAT-AEL: 5 35 mg/l (yearly average) NI Flot NI Flot. NI Flot NT NINI NI NI Number of WWTP 16 16

17 Section 5.7 Example of one individual BAT conclusion (standard format) CAK BREF (Commission Implementing Decision 2013/732/EU) Emissions to water BAT 13. In order to reduce emissions of free chlorine to water from the chlor-alkali plant, BAT is to treat waste water streams containing free chlorine as close as possible to the source, to prevent stripping of chlorine and/or the formation of halogenated organic compounds, by using one or a combination of the techniques given below. a b Technique Chemical reduction Description The free chlorine is destroyed by reaction with reducing agents, such as sulphite and hydrogen peroxide, in stirred tanks. The BAT-associated emission level for free chlorine, expressed as Cl 2, is mg/l in spot samples taken at least once every month at the point where the emission leaves the installation. The associated monitoring is in BAT

18 BREFs are available to the world

19 BREFs are used throughout the world 60,000 56,403 BREF downloads 2015 TOP 10 countries 50,000 40,000 30,000 20,000 27,599 22,710 19,725 17,391 10,000 9,674 9,385 8,398 8,251 8,166 0 China Great Britain Germany Italy United States Spain France India Thailand United Arab Emirates 19 19

20 Achievements since entry into force of the IED 9 BAT conclusions already adopted: Iron and Steel; Glass; Tanning of Hides and Skins; Cement, Lime and Magnesium Oxide; Chlor-Alkali; Pulp, Paper and Board; Refining of Mineral Oil and Gas; Wood-Based Panels; Common Waste Water and Waste Gas Treatment/Management Systems in the Chemical Sector 2 BAT conclusions soon to be adopted: Non-Ferrous Metals; Intensive Rearing of Poultry and Pigs 8 (B)REFs being worked upon: Large Volume Organic Chemicals; Monitoring of Emissions; Large Combustion Plants; Waste Treatment; Food, Drink and Milk; Waste Incineration; Surface Treatment using Organic Solvents (including Wood and Wood Products Preservation with Chemicals); Ferrous Metal Processing Work on 3 more BREF reviews to start in 2016/2017: Common Waste Gas Treatment in the Chemical Sector; Textiles; Slaughterhouses and Animal byproducts 20 20

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22 BREF coverage of the chemical sector in 'organic' + 4 'inorganic' chemical BREFs LVOC (Large Volume Organic Chemicals) POL (Polymers) OFC (Organic Fine Chemicals) Chemical sector CWW (Common Waste Water and Waste Gas Treatment/Management Systems in the Chemical Sector) CAK (Chlor-Alkali) LVIC AAF (Large Volume Inorganic Chemicals Ammonia, Acids and Fertilisers) LVIC S (Large Volume Inorganic Chemicals Solids and others) SIC (Speciality Inorganic Chemicals) 1 generic + 7 specific chemical BREFs Cross-cutting issues: EFS, ENE, ICS, LCP, WT BREFs 22 22

23 Approach to review the Chemicals BREF? We haven't got time to change the wheels keep pushing 23 23

24 Main problems encountered in the review of the chemical BREFs Major gaps in BAT-AELs for emissions to air - No BAT-AELs in the revised CWW BREF - Major gaps in the revised LVOC BREF Potential lack of consistency between the chemical BREFs - Risk of scope gaps or overlaps - Risk of incoherent or contradictory BAT conclusions Transparency issues (review of the LVOC BREF) Late finalisation of the review of the chemical BREF series Duplication of efforts Need for higher effectiveness and efficiency 24 24

25 Principles for reviewing (the chemical) BREFs Targeted effort: Ensure that inputs match outputs and focus efforts on BAT/BAT-AELs for key environmental issues Generic BAT if possible: Define BAT/BAT-AELs at the most generic level possible and describe specific products/processes only if key environmental issues cannot adequately be covered by generic BAT Transparency: Enhance transparency Efficiency: Ensure that efforts made so far are not wasted and avoid further delays 25 25

26 Way forward for reviewing the chemical BREFs CAK BREF: Review finalised in 2014 CWW BREF: Review expected to be finalised in 2016 LVOC BREF: Finalise the LVOC BREF review as soon as possible, applying the principles of 'generic BAT if possible' and 'efficiency' WGC BREF: Develop a new BREF on Common Waste Gas Treatment in the Chemical Sector (WGC), starting in 2016, as the best possible solution to apply the principles of 'targeted efforts' and 'generic BAT if possible' Other chemical BREFs: Postpone the review of other chemical BREFs until the drawing up of the WGC BREF is at a sufficiently advanced stage. At that moment, decide which products/process/subsectors would still need to be addressed 26 26

27 Drawing up of the WGC BREF Collect comprehensive and representative information and data on abatement techniques and emission levels across the whole chemical industry Collect information and data from specific products/processes that might require a dedicated approach Thoroughly analyse the information and data collected Define generic BAT and BAT-AELs for emissions to air for the whole chemical industry, while identifying processes requiring further specific consideration 27 27

28 Conditions to reach useful BAT conclusions All stakeholders should contribute to the exchange of information, including representatives from institutions/associations who are not directly represented in the TWG (e.g. competent authorities, equipment suppliers, operators of installations) The applicability of the identified BAT and any potential restrictions need to be carefully assessed A transparent exchange of information needs to be ensured BAT conclusions are based on clear facts and sound technoeconomic information 28 28

29 Useful information and links European IP Bureau (EIPB) Industrial Emissions Directive (IED) "BREF Guidance" Commission Implementing Decision 2012/119/EU Guidance on Interpretation and Implementation of the IED (DG ENV)