Relevant BAT phrase: The BAT-associated emission level for diffuse dust emissions is <5 15 g/t hot metal, determined as an annual mean value.

Transcription

1 IED Art. 13 Forum 13 September Deletion of BAT-AEL AEL Chapter 9.5 Blast Furnaces BAT 61 Relevant BAT phrase: The BAT-associated emission level for diffuse dust emissions is <5 15 g/t hot metal, determined as an annual mean value. Comments received: Either the method and the purpose of monitoring the diffuse dust emissions from the cast house should be clearly defined, or this BAT-AEL should be deleted. Remove such addition in BAT 61:..determined as an annual mean value. The information requested in comment one on monitoring has not been provided. The document also does not contain information on the averaging period. Delete the whole phrase about the diffuse emissions in this BAT /167

2 IED Art. 13 Forum 13 September Modification of BAT Chapter 9.6 Basic Oxygen Steelmaking and Casting BAT 80 Relevant BAT 80 BAT is to use dry basic oxygen furnace (BOF) gas cleaning where prerequisites are present. In order to avoid a contradiction with BATs 75 and 76, BAT 80 should only apply to new plants. Define and include prerequisites Remove this BAT As phrased in the conclusion the BAT 80 is inconsistent with BAT 75 and 76. In these BAT wet and dry dedusting are included as BAT. The document does not contain information on prerequisites. Therefore preference to dry dedusting should only be considered for new plants. 80. BAT for new plants is to use dry basic oxygen furnace (BOF) gas cleaning

3 IED Art. 13 Forum 13 September Different BAT-AEL AEL for Techniques for same activity/process and pollutant Chapter 9 BAT 22, 26, 48, 50, 51, 78 Example BAT 26 (same comment and general assessment for the other BAT) BAT for.. subsequently to reduce dust emissions by using a combination of the following techniques: I. hooding and/or enclosure II. an electrostatic precipitator or a bag filter. The BAT-associated emission level for dust is <10 mg/nm 3 for the bag filter and <30 mg/nm 3 for the electrostatic precipitator, both determined as a daily mean value. In order to clarify which BAT-AEL applies for BAT 26, only one BAT-AEL range should be specified, unless the applicability of the mentioned techniques is clearly restricted. For clarification, the applicability of the techniques mentioned in BAT 26 should be specified. Otherwise the wording of the BAT-AEL sentence in BAT 26 should be changed as follows: 'The BAT-AEL for dust is <10-30 mg/nm 3, determined as a daily mean value. The lower value refers to use of bag filters.' The given ranges reflects the outcome of the final TWG meeting. The data in the documents support to have these two ranges. Keep the BAT 22, 26, 48, 50, 51, 78 as they are. 92, 92, 112, 112, 146, 146, 155, 155, 157, 157,

4 IED Art. 13 Forum 13 September Different BAT-AEL AEL for Techniques for same activity/process and pollutant Chapter 9.4 Coke Oven Plants BAT 44 Relevant BAT 44 The BAT-associated emission level for dust from coal charging systems with land-based treatment of extracted gases is <5 g/t coke or <50 mg/nm 3, as the average over the sampling period (spot measurement, for at least half an hour). The relation between both BAT-AELs specified for dust emissions from coal charging with land-based gas treatment needs to be clarified: How to decide which value applies? Both values are defined as BAT-AEL and assumed to be equivalent (see Section p. 238) Little information has been provided for dust emission from charging. The BAT-AELs apply only if the gases are extracted and dedusted. They do not apply for diffuse emissions. Keep the BAT 44 as it is

5 IED Art. 13 Forum 13 September Adjustment of BAT-AELs AELs based on new data Chapter 9.3 Pelletisation Plant BAT 34 Relevant BAT 34 BAT is to reduce the sulphur oxides (SO X ), hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions from the induration strand waste gas by using one of the following techniques: I. wet scrubbing II. semi-dry absorption with a subsequent dedusting system The BAT-associated emission levels, determined as daily mean values, for these compounds are: sulphur oxides (SO X ), expressed as Sulphur dioxide (SO 2 ) <30 50 mg/nm 3 hydrogen fluoride (HF) <1 3 mg/nm 3 hydrogen chloride (HCl) <1 3 mg/nm 3. The level for HF should be increased from 3 mg/nm 3 to 4 mg/nm 3 Consideration of higher fluoride content of the ores extracted in Sweden Balance between environmental benefits and economic costs. From the data included in the BREF document values <1-3 mg HF/Nm 3 can be achieved with the included BAT. The discussion with Swedish pellet plant operator on one specific pellet plant revealed that relevant off-gas streams from this plant are not cleaned. Keep the BAT 34 as it is

6 IED Art. 13 Forum 13 September Adjustment of BAT-AELs AELs based on new data Chapter 9.3 Pelletisation Plant BAT 39 Relevant BAT BAT for pelletisation plants is to treat the effluent water prior to discharge by using a combination of the following techniques: I. neutralisation..v. heavy metal precipitation. The BAT-associated emission levels, based on a qualified random sample or a 24-hour composite sample, are: suspended solids <50 mg/l chemical oxygen demand (COD( 1 )) <100 mg/l Kjeldahl nitrogen <10 mg/l heavy metals <0.2 mg/l (sum of arsenic (As), cadmium (Cd), chromium (Cr), copper (Cu), mercury (Hg),nickel (Ni), lead (Pb), zinc (Zn)). In the TWG was agreed that new data will be used for the BREF Table 5.25 and the BAT-AEL. Please update with: suspended solids <50 mg/l chemical oxygen demand (COD( 1 )) <160 mg/l Kjeldahl nitrogen <45 mg/l heavy metals <0.55 mg/l (sum of arsenic (As), cadmium (Cd), chromium (Cr), copper (Cu), mercury (Hg),nickel (Ni), lead (Pb), zinc (Zn)). 126, 126, At the time of the final TWG meeting we had the meeting the competent authority told us that the new data were still considered provisional and that there was an ongoing discussion. The data have now been confirmed they could be included. Accepted

7 IED Art. 13 Forum 13 September Monitoring method that refers to an outdated method with impact on BAT- AEL Chapter 9.4 Coke Oven Plants BAT 51 Relevant BAT 51 BAT for coke quenching is to reduce dust emissions by using one of the following techniques: I. using coke dry quenching (CDQ) with the recovery of sensible heat and the removal of dust from charging, handling and screening operations by means of a bag filter II. using emission-minimised conventional wet quenching III. using coke stabilisation quenching (CSQ). The BAT-associated emission levels for dust, determined as the average over the sampling period are: <20 mg/nm 3 in case of coke dry quenching <25 g/t coke in case of emission minimised conventional wet quenching <10 g/t coke in case of coke stabilisation quenching. 158, 158, 159, 159, Add the measurement method used (VDI 2303=Mohrhauer Method) for BAT II and III (coke wet quenching) as described in this draft The guideline VDI 2303=Mohrhauer Method has been withdrawn. Nevertheless, it is the commonly applied method and the figures given for BAT II are based on it. BAT III is based on the isokinetic sampling according to VDI This has been discussed in the TWG meeting and the conclusion was not to insert the measurement methods. We support the idea of mentioning the Mohrhauer Method, perhaps without mentioning the VDI To be discussed