Purpose, design and structure of reference documents on BAT

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1 For our Environment Workshop chemical industry 23/04/2015 Purpose, design and structure of reference documents on BAT Brigitte Zietlow Federal Environment Agency Germany Section III 2.1 General Aspects of Pollution Control, Chemical Industry and Combustion Plants

2 Outline Legal framework of BAT Reference Dokuments (BREF) Definition of BAT Structure of BREFs 2

3 The European Industrial Emissions Directive (IED) from 2010 Objective to prevent, to reduce and as far as possible to eliminate pollution arising from industrial activities based on the polluter pays and the precautionary principle taking into account, when necessary, specific local circumstances to avoid shifting of pollution from one environmental medium to another high level of protection for the environment as a whole to achieve a level playing field in the EU by aligning the environmental standards for industrial installations 23/04/2015 3

4 Main provisions of the IED (I) Each relevant industrial installation in the EU needs an environmental permit (in total: installations) The permits shall include: Emission limit values (ELVs) or equivalent parameters or technical measures ensuring an equivalent level of environmental protection Suitable emission monitoring requirements, including the obligation to report emission monitoring results to the CA requirements for regular maintenance as well as for other than normal operating conditions conditions for assessing compliance with the emission limit values 4

5 Main provisions of the IED (II) The emission limit values shall be based on the best available techniques, without prescribing the use of any technique or specific technology: The competent authority shall set emission limit values that ensure that, under normal operating conditions, emissions do not exceed the emission levels associated with the best available techniques as laid down in the decisions on BAT conclusions (IED Art. 15 para. 3) BAT conclusions do not prescribe the use of specific techniques, but a level of environmental protection that shall be achieved by the application of BAT! 5

6 Purpose of BAT reference documents (BREFs) BREFs should provide information to the competent authorities, industrial operators and the public at large on what BAT are Result of information exchange between authorities, the industry concerned and non-governmental organisations promoting environmental protection The process of determining BAT should be transparent and objective, based on sound technical and economic information. A BREF should also serve as a driver towards improved environmental performance across India. EU Member EU States Industry Installation data (technical descriptions, emission values ) BREFs with BAT conclusions Commission Environmenta l NGOs 6

7 Content of BAT reference documents Describes applied techniques, present emission and consumption levels, techniques considered for the determination of BAT as well as BAT conclusions and if applicable emerging techniques address the following: a. the performance of installations and techniques (emissions, and the associated reference conditions, consumption and nature of raw materials, water consumption, use of energy and generation of waste); b. with the techniques associated monitoring, cross-media effects, economic and technical viability; c. best available techniques and emerging techniques identified after considering the issues mentioned in points (a) and (b). 7

8 The definition and the determination of BAT Definition of BAT Best Available Technique = most effective with respect to the prevention and where that is not practicable the reduction of emissions and the impact on the environment as a whole = developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not it is used in the respective Member State = includes both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned 8

9 The EU- BREFs generally contain the following parts: Preface Scope Chapter 1: General Information Chapter 2: Applied Processes and Techniques Chapter 3: Current Emission and Consumption Levels Chapter 4: Techniques to Consider in the Determination of BAT Chapter 5: Best Available Techniques (BAT) Conclusions Chapter 6: Emerging techniques Concluding remarks and recommendations for future work References Glossary of terms and abbreviations Annexes (dependent upon relevance to the sector and availability of information) 9

10 Preface describes the structure of the document, and the way in which the document was drafted. Scope describes which activities are covered by the document. Chapter 1: General Information provides recent general information about the industry sector in terms of numbers and size of installations, geographical distribution, production capacity and economics. indicates the key environmental issues for the sector with some overall emission and consumption data as background information. 10

11 Chapter 2: Applied Processes and Techniques describes the production processes currently applied in the industrial sector along with an indication of the techniques used to prevent and reduce emissions. Describes relevant process variants, developing trends and alternative processes. reflects the sequential steps in a typical manufacturing unit (including raw materials and consumables (e.g. water and energy, auxiliary chemicals/materials); preparation, storage and handling of raw materials; material processing; product manufacture; techniques applied to prevent or reduce emissions; storage, handling and fate of by-products and residues/wastes). 11

12 Chapter 3: Current Emission and Consumption Levels reports on the range of currently observed emission and consumption levels (inputs and outputs) for the overall process and sub-processes along with an indication of the techniques used. includes information regarding production levels. emissions of the key pollutants to air and water and the generation of residues/wastes. options for the recycling and reuse of materials within the whole process or beyond. 12

13 Chapter 4: Techniques to Consider in the Determination of BAT Crucial for decisions on BAT! provides a catalogue of techniques and associated monitoring used for: preventing emissions to air, water (including groundwater) and soil or, where this is not practicable, for reducing emissions preventing or reducing waste generation. includes both the technology used and the way in which the installations are designed, built, maintained, operated and decommissioned. Includes good operating practices, (preventive) maintenance systems, process control methods and contingency provisions. 13

14 Chapter 4: Techniques to Consider in the Determination of BAT Information on each technique should include all of the following elements: Technical description Achieved environmental benefits Environmental performance and operational data Cross-media effects Technical considerations relevant to applicability Economics Driving force for implementation Example plants Reference literature 14

15 Chapter 5: Best Available Techniques (BAT) Conclusions EU aproach: This chapter will set out the conclusions on what BAT are for the sector, based upon the information exchanged, as reflected in the previous chapters Proposal for Gujarat: Chapter 5 should support industry or other decision makers to decide on the most appropriate set of techniques with regards to the identified environmental problems Could include a check list of all techniques described in chapter 4 together with main environmental aspects and applicability issues Conclusions on consent conditions Proposal paper industry 15

16 Thankyouforyour attention! Almut Reichart Brigitte Zietlow 16

17 Chapter 4: Techniques to Consider in the Determination of BAT Technical description A detailed but concise technical description including chemical or other equations, pictures, diagrams and flow charts Achieved environmental benefits Includes the environmental benefits of the technique (including reduced consumption of energy; reduced emissions to water, air and land; raw material savings; as well as production yield increases, reduced waste, etc.). slide 10 17

18 Chapter 4: Techniques to Consider in the Determination of BAT Environmental performance and operational data Includes actual plant-specific performance data (including emission levels, consumption levels of raw materials, water, energy and amounts of residues/wastes generated) from wellperforming plants Information on how to design, operate, maintain, control and decommission the technique emission monitoring issues related to the use of the technique details of relevant operating conditions (e.g. percentage of full capacity, fuel composition,, inclusion or exclusion of other than normal operating conditions, reference conditions), sampling and analytical methods, and statistical presentations (e.g. short and long-term averages, maxima, ranges and distributions). Slide 10 18

19 Chapter 4: Techniques to Consider in the Determination of BAT Cross-media effects Relevant negative environmental effects due to implementing the technique, Technical considerations relevant to applicability general technical restrictions - including the reasons for the restrictions - on the use of the technique within the sector (e.g. if the technique is not applicable for certain types of plants (new existing, small large), processes or products) No list of possible local conditions that could affect the applicability of the technique for an individual plant. Slide 10 19

20 Chapter 4: Techniques to Consider in the Determination of BAT Economics Information on the costs of techniques (capital/investment, operating and maintenance) and any possible savings following from their application (e.g. reduced raw material or energy consumption, waste charges, reduced payback time compared to other techniques), revenues or other benefits Driving force for implementation Where applicable, specific local conditions, requirements (e.g. legislation, safety measures) or nonenvironmental triggers (e.g. increased yield, improved product quality, economic incentives e.g. subsidies, tax breaks) which have driven or stimulated the implementation of the technique to date will be included. Example plants Reference(s) to a plant(s) where the technique has been implemented will be listed, including an indication of the degree to which the technique is in use in the EU or worldwide. Slide 10 20

21 Criteria for determining best available techniques 1. the use of low-waste technology; 2. the use of less hazardous substances; 3. the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate; 4. comparable processes, facilities or methods of operation which have been tried with success on an industrial scale; 5. technological advances and changes in scientific knowledge and understanding; 6. the nature, effects and volume of the emissions concerned; 7. the commissioning dates for new or existing installations; 8. the length of time needed to introduce the best available technique; 9. the consumption and nature of raw materials (including water) used in the process and energy efficiency; 10. the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it; 11. the need to prevent accidents and to minimise the consequences for the environment; 12. information published by public international organisations. 21