IMPEL Conference Malta Role of BAT and BREFs in new IED 3 October 2013 European IPPC Bureau 1 1 The...

IMPEL Conference MaltaRole of BAT and BREFs in new IED3 October 2013 European IPPC Bureau

1

1

The role of BAT conclusions and BREFs in the Industrial Emissions

Directive (IED)

Conference on Implementation and Enforcement of Environmental legislation

01 – 04 October 2013Floriana, Malta

Serge RoudierEuropean Commission, Joint Research Centre


2

2

European IPPC Bureau (EIPPCB)

~22 staff within the Sustainable Production and Consumption (SPC) Unit of the Institute for

Prospective Technological Studies (IPTS)

IPTS in the context of the Joint Research Centre (JRC)


3

3

Outline of this presentation

1 - The Industrial Emissions Directive (IED)

2 - The Sevilla process

3 - Challenges for the review of BREFs under the IED


4

4

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


5

5

Industrial Emissions Directive 2010/75/EU (IED)

Key instrument for minimising consumption and the 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

(EIPPCB) and documented in BREFs‘BAT conclusions’ are secondary

legislation


6

6

Annex I to IPPC and IED DirectiveWide 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 operationsIncineration

• ‘Other’ industries:Pulp and paper, textile processingTanning of hides and skinsIntensive farming of pigs and poultry, slaughterhouses and animal by-product processing, food drink and milk processing, surface treatment using solvents

~ 50 000 IPPC installations in Europe


7

7

Environmental scope of the IED

waste prevention and recovery energy &

water useprevention and control of accidents

noise

vibration

heat

emissions to water

odour

emissions to air


8

8

Definition of BAT in the IED

Best Most effective in achieving a high general level of protection of the environment as a whole

Available 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

Role of BAT conclusions in IED permitting

BAT conclusions are the reference for setting permit conditions

Permits to contain emission limit values (ELVs) to ensure that, under normal operating conditions, emissions do not exceed BAT-associated emission levels (BAT-AELs)

Derogation from BAT-AELs is only allowed in specific and justified cases

•Need to demonstrate that costs are disproportionately higher than benefits due to local/installation-specific situations

•Member States report to the public/Commission on use of derogations


10

10

Reconsidering / updating permit conditions (IED Article 21)

• "Within four years of publication of decisions on BAT conclusions in accordance with Article 13(5) relating to the main activity of an installation, the competent authority shall ensure that:(a) all the permit conditions for the installation

concerned are reconsidered and, if necessary, updated to ensure compliance with this Directive [the IED];

(b) the installation complies with those permit 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."

10


11

11

A complex consensus-building exchange of information with numerous stakeholders and underpinned by sound techno-economic

information that has been enshrined into law by:

2 - The Sevilla process

Commission Implementing Decision 2012/119/EU


12

12

The legal basis for the exchange of information on BAT

Article 13(1) of the Industrial Emissions Directive 2010/75/EC:

‘In order to draw up, review and, where necessary, update BAT reference documents, the Commission shall organise an exchange of information between Member States, the industries concerned, non-governmental organisations promoting environmental protection and the Commission’

The exchange of information should address:the performance of installations and techniques in terms of emissions and consumptions, etc.the techniques used, associated monitoring, economic and technical viability, etc.best available techniques and emerging techniques identified after considering all the issues concerned


13

13

Exchange of information on BAT: actors

Forum members:• guidance to COM• nominate in TWGs• formal opinion on BREFs

GLS(Glass)

• Industry• Member States

• NGOs• Commission

‘Forum’ (IED Article 13) lead by the Commission:industry, Member States, environmental NGOs

35 Technical Working Groups (TWGs)

BREF authors team:• lead TWGs• validate/check information• draft BREFs• present BREF to Forum

TWG members:• research information• peer review draft BREFs

I&S(Iron and Steel)



WT(Waste Treatment)



European IPPC Bureau (EIPPCB)

EU Member States Committee (IED Article 75)Members of the Committee:• vote the BAT conclusions


14

14

Industry EU Member States+ EFTA and Accession Countries

Environmental NGOs European Commission/

EIPPCB

TWGkick-off meeting

Draft 1 (D1)

Draft 2 (D2) *

Final TWG meeting

The ‘Sevilla process’

Final draft

Bulk of info. needed(incl. questionnaires)

Comments

BREFBREF

BATBATconclu-conclu-sionssions

• Forum opinion on BREF

• Adoption of BAT conclusions through the IED Art. 75 Committee

BATBATconclu-conclu-sionssions

* D2 optionalTotal duration:• 24 – 29 months (without D2)• 29 – 39 months (with D2)


15

15

200 to 1000 pages

Standard BREF structure:• Preface• General information about the sector …… Chapter 1• Process/techniques used……………………… Chapter 2• Consumption and emission levels………… Chapter 3• Candidate BAT …………………………………… Chapter 4• BAT conclusions ………………………………… Chapter 5• Emerging techniques…………………………… Chapter 6• Concluding remarks and recommendation

for future works (including suggestions for R&D)

Exchange of information on BAT: BREFs


16

16

The information on key environmental issues is obtained through plant-specific questionnaires covering:

emissions to air and water

generation of solid by-products, residues and wastes

efficient energy use

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)

Data collection step is crucial for determining BAT


17

17

TSS concentration in the influent and effluent of central WWTPs (detail)

34 01

0740

33 54 41 64 19

5362

60

30 37

29

48

51

04203 61 67 02

35

45

041 4327 63

44 39

49

17

59 32

09

65

38

46

Mec

a.+S

ed.

Filt

.

Mec

a.+F

lot.1

+Filt

.

Sed

.1+S

ed.2

+Filt

.

Sed

.1+S

ed.2 S

ed.1

Sed

.+A

ir_flo

t.

Mec

a.+O

WS

+Sed

.1+F

lot.2

OW

S+A

ir+flo

t.+F

lot.1

OW

S+S

ed.1

+Sed

.2+F

ilt.

Sed

.1+S

ed.2

Sed

.2

Mec

a.

Flo

t.1

Sed

.1+S

ed.2

Lag.

+Sed

.2

Sed

.2

Flo

t.2

50

69

OW

S+A

ir+flo

t.

Sed

.2

Air+

flot.

Mec

a.+S

ed.2

Sed

.2+F

ilt.

Sed

.1+F

ilt.

CM

AS

_MB

R

Sed

.1+S

ed.2

Air_

flot.

Air_

flot.

Filt

.+P

ond/

lag.

Sed

.1+S

ed.2

Sed

.1

Sed

.2+P

ond/

lag.

Sed

.2+F

lot.2

Mec

a.+O

WS

+Sed

.1+S

ed.2

Mec

a.+O

WS

+Sed

.1+S

ed.2

0

10

20

30

40

50

60

70

80

90

100

0 40

Number of central WWTPs

TS

S (

mg

/l)

<5

influent 20-430

#36: MBR: <detection limit for TSS #08: MBR: 1.1 mg/l (average of 150 measurements)

#4

0: O

FC

+P

OL

, D

ire

ct

Pre

tre

atm

en

t: f

loc

+fi

ltra

tio

n

#4

8: L

VO

C, D

ire

ctP

retr

eat

me

nt:

Set

tlin

g+

bio

. tr

ea

t.

Only part of the effluent passes through the MBR - Data from 2007, in 2009 <10 mg/l

BAT is about real plant performance

BAT-AEL: 10 – 20 mg/l (monthly average)


18

18

http://eippcb.jrc.ec.europa.eu/reference/

BREFs are available to the world


19

19

4 BAT conclusions already adopted:

Iron and Steel; Glass; Tanning of Hides and Skins; Cement, Lime and Magnesium Oxide

3 BAT conclusions soon to be adopted:

Chlor-Alkali; Pulp, Paper and Board; Refining of Mineral Oil and Gas

9 (B)REFs being worked upon:

Common Waste Water/Waste Gas; Non-Ferrous Metals; Intensive Rearing of Poultry and Pigs; Large Volume Organic Chemicals; Large Combustion Plants; Wood-Based Panels; Waste Treatments; Food, Drink and Milk; Monitoring

Work on 3 more BREFs to start in 2014:

Waste Incineration; Surface Treatment using Organic Solvents; Wood-Preservation with Chemicals

Progress on the review of BREFs under the IED


20

20

3 - Challenges for the review of BREFs under the IED


21

21

35 BREFs

8-year review cycle


22

22

Challenges and constraints of a BREF review

The delivery of BREFs and BAT conclusions is a prerequisite for the updating of IPPC permits time is a critical factor in the implementation of the IED, there is now the need to speed up the Sevilla process

The time allowed for a BREF review is 2-3 years maximumResources are scarce among stakeholders involved in the

Sevilla process, including the EIPPCB Increased importance of BREFs/BATC requires the

acquisition of better and more data (contextual information, applicability, monitoring, costs), which may not be readily available


23

23

General strategy to shorten the time to delivery

Adopt a more focused approach (shorter BREFs, focus on BAT conclusions, target key environmental issues)

Anticipate further and prepare input before the BREF review starts: anticipation of the structure of the BAT and identification of the data needs are crucial to devise appropriate questionnaires

‘single draft’ route is the standard for BREF reviews not involving major changes in the scope

Possibilities for e.g. extending commenting periods and holding additional TWG or subgroup meetings are necessarily limited

Deliver the best quality with (limited) available time and resources


24

24

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, representatives of industrial 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 techno-economic information


25

25

Thank you for your attention

Serge RoudierHead of the European IPPC Bureau

[email protected]+34 954 488 308

http://eippcb.jrc.ec.europa.eu/

IMPEL Conference Malta Role of BAT and BREFs in new IED 3 October 2013 European IPPC Bureau 1 1 The...

Documents

Transcript of IMPEL Conference Malta Role of BAT and BREFs in new IED 3 October 2013 European IPPC Bureau 1 1 The...