European IPPC Bureau 1 Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 Review process for the Non-Ferrous Metals Industry BREF and effects on the draft guidance document V. Primary and secondary non-ferrous metal industry Rainer Remus European IPPC Bureau Sustainable Production and Consumption Unit Joint Research Centre Institute for Prospective Technological Studies 26 March 2012
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 2 Review process for the NFM BREF The original Non Ferrous Metals Industry BREF was adopted in December 2001 and was one of the first BREFs in a series of 33 documents. Consequently it was foreseen as one of the first BREFs to be reviewed. The review process started in 2006 under IPPC Directive 96/61/EC and will finalise under new Industrial Emissions Directive 2010/75/EU (IED) Strengthening of BAT and the role of the BAT reference documents (BREFs) ELVs in permits should be based on BAT to ensure that under normal operating conditions, emissions do not exceed the emission levels associated with BAT (BAT- AELs).
December 2006 September 2007 European IPPC Bureau Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 3 Steps in the review process for the NFM BREF Activation of the TWG for the review of the Iron and Steel BREF and submission of TWG wishes TWG kick off meeting November 2008 First draft of the review of the Iron and Steel BREF (2000 comments received) July 2009 Second draft of the review of the Iron and Steel BREF (1260 comments received) Beginning of 2010 November 2011 The draft NFM BREF document was considered by the EIPPCB to not be ready for a final meeting which was envisaged for 2010. Start of restructuring and rewriting of the Techniques to consider sections and a new data collection? Forum opinion on the full BREF including BAT conclusions? Adoption of the BAT conclusions by the Committee
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 4 Current status of the review process for the NFM BREF The whole document has to be overworked according to new rules laid down in the BREF Outline and Guide document as indicated in a decision recently adopted by the Commission (see http://eurlex.europa.eu/lexuriserv/lexuriserv.do?uri=oj:l:2012:063:0001:0039:en:p DF). Restructuring, disaggregating and rewriting of the Techniques to consider in the determination of BAT sections (BAT candidate sections)
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 5 Current status of the review process for the NFM BREF BAT conclusions and BAT-AELs proposed in the second draft are mainly based on expert judgement and are not sufficiently supported by the information included in the relevant sections of this document A new data collection of individual plant specific data according to the aforementioned decision considering the new BAT candidate structure was necessary
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 6 Non ferrous metals BREF review and effects on the draft guidance document V. Primary and secondary non-ferrous metal industry (annex II, categories 5 and 6) We do not see a need to give so much emphasize to mercury emissions in secondary aluminium and manganese production. Mercury is also emitted during the production of other refractory metals and during the production of ferro-alloys. The equivalent application of ceramic and fabric filters as BAT will be checked in the review of the NFM BREF. In many cases we doubt that ceramic filters are applied and/or show the same performance. HEPA filter are non regenerative filter for small off-gas volumes. Used for relevant applications?
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 7 Non ferrous metals BREF review and effects on the draft guidance document V. Primary and secondary non-ferrous metal industry (annex II, categories 5 and 6) The removal efficiencies for dust and mercury and the associated residual emission concentration values will be revised and may change. Additionally, the removal efficiencies for dust and mercury included and the associated residual emission concentration values in the draft guidance document seem to be not consistent in many cases.
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 8 Non ferrous metals BREF review and effects on the draft guidance document V. Primary and secondary non-ferrous metal industry (annex II, categories 5 and 6) The list of furnaces/processes in the NFM BREF for the production of copper, lead, zinc, precious metals, aluminium will not be used for the conclusions of BAT. The reason for this is that the information on energy consumption and cross media effects is considered not sufficient to exclude any furnace/process type The BAT-AEL will be mainly based on emissions to water and air.
Workshop of the Task Force on Heavy Metals Berlin, 12/13 April 2012 9 All BREFs can be downloaded free of charge from the EIPPCB website http://eippcb.jrc.es/reference/ Thank you for your attention Rainer Remus European IPPC Bureau rainer.remus@ec.europa.eu Tel.: +34 954 488 290 http://eippcb.jrc.es