Revision of BREF documents in light of the Industrial .... Events/2014.11.04_Abrys_Bydgoszcz... ·...
Transcript of Revision of BREF documents in light of the Industrial .... Events/2014.11.04_Abrys_Bydgoszcz... ·...
European Suppliers of Waste to Energy Technology
Revision of BREF documents in light of the Industrial Emissions Directive
11th International Conference Thermal treatment of waste – from plans to implementation
Bydgoszcz, 4./6.11.2014
Edmund Fleck
ESWET President
European Suppliers of Waste to Energy Technology
Contents
1. ESWET
2. Introduction
3. BREF documents under IPPC
4. BREF documents under IED
5. Planning for the revision of BREF documents
6. ESWET planning
7. Summary
11th International Conference, Bydgoszcz 4./6.11.2014 2
European Suppliers of Waste to Energy Technology
• ESWET is the association of European suppliers of waste to energy technology
• Main aim is the development and dissemination of technologies for waste incineration
• Consciousness for the positive aspects of waste incineration for the environment, energy production, recovery of resources shall be initiated and furthered
• Focus of the activities is the law making process in Brussels
1. ESWET: Who is ESWET
3 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
1. ESWET members
11th International Conference, Bydgoszcz 4./6.11.2014 4
European Suppliers of Waste to Energy Technology
2. Introduction
1996: IPPC - Integrated Pollution Prevention and Control Directive
• Introduction of an integrated approach to avoid and control harmful implications to the environment
2000: WID - Waste Incineration Directive
• Determination of emission limits and other conditions for waste incineration plants
2010: IED - Industrial Emissions Directive
• New formulation and integration of: IPPC, WID + other directives
5 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
3. BREF documents under IPPC
• With the IPPC, the elaboration of BREF documents was introduced
• These should determine what is ‚state of the art‘ for various sectors ('vertical BREF')
• They are 'technical handbooks' that should assist permitting authorities; they are not legally binding though
• For the elaboration, the EIPPCB in Seville was founded
• EIPPCB reports to JRC and thus the Commission
• Authors for the BREF documents are mostly seconded from authorities in Member States
• A TWG is formed, consisting of experts from: Member States, Commission, Industry, NGO's
6 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
TWG kick-off meeting
Draft 1 (D1)
Final TWG meeting
Final draft
Draft 2 (D2) (revised) draft
BAT conclusions
Activation call of TWG (new BREF)
or
TWG reactivation and
call for ‘wishes’ (BREF review)
2 – 3 months
3 – 5 months
3 months (new BREF)
5 months (BREF review)
Information
6 months
6 months (new BREF)
4 – 6 months (BREF review)
5 – 7 months
2 – 3 months
3 months
Total: 30 – 38 months
TWG comments
TWG comments
RAI
RAI
RAI
Chap. 3, 4, 5
RAI
BREF - New BREF or BREF
revision with ‘major scope
expansion’
7
3. BREF documents under IPPC
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
TWG reactivation
and call for ‘wishes’
5 months
Draft 1 (D1)
Final TWG meeting
Final draft
Draft 2 (D2)
revised draft
BAT conclusions
2 – 3 months
TWG comments
3 – 5 months
Information
6 months
4 – 6 months
2 – 3 months
3 months
Total: 28 – 38 months (with D2)
23 – 28 months (without D2)
kick-off meeting
Draft 2?
TWG comments
yes
no
3 – 5 months
3 – 7 months RAI
RAI
RAI
RAI
Chap. 3, 4, 5
BREF - 1st BREF revision
without ‘major scope
expansion’
8
3. BREF documents under IPPC
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
TWG reactivation
and call for ‘wishes’
5 months
Draft 1 (D1)
Final TWG meeting
Final draft
revised draft
BAT conclusions
2 – 3 months
Information
6 months
4 – 6 months
3 months
Total: 23 – 28 months
kick-off meeting
TWG comments
3 – 5 months
RAI: request for additional information from the EIPPCB to
the TWG (if this is considered necessary)
Chap. 3, 4, 5: Update of at least Chapters 3, 4 and 5
RAI
RAI
RAI
Chap. 3, 4, 5
BREF - following BREF
revision without ‘major
scope expansion’
9
3. BREF documents under IPPC
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
3. BREF documents under IPPC
For the current version of the BREF WI (Waste Incineration) the process proceeded like this, after installation of the TWG:
• Kick-off meeting in Seville
• Some countries (e.g. AT, DE, NL...) had worked out reports in advance and submitted these early on
• The author (Paul James/UK) mainly used these in his preparation of the 1st draft
• Several 1000 comments/remarks
• 2nd draft; again numerous comments
• 'Final' draft as basis for the 2nd TWG meeting in Seville
• 2nd meeting in Seville focused on: chapter 5; BATAOEL table; some 'split-views'
10 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
3. BREF documents under IPPC
• Short time after 2nd meeting for final comments
• Formal approval in IEF - Information Exchange Forum (Member States, Commission, Industry, NGO's)
• Publication in August 2006
• Entire BREF document only in English; some Member States had at least Chapter 5 translated into their mother language, on their own initiative (and cost)
11 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
4. BREF documents under IED
• Under IED, the BREF documents have a completely different status
• They are more legally binding
• BAT-Conclusions will be elaborated in a separate chapter
• These will be translated into all official languages in the EU and have legal status
• Within 4 years after formal adoption of new or revised BREF documents, permits have to be reviewed and adapted if needed
12 11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
EXISTING BREF (Best Available Technique) Reference Document
Based on IPPC (Existing BREFs), Chapters:
1. General Information
2. Applied Processes and Techniques
3. Current Consumption and Emission levels
4. Techniques to consider in the determination of BAT
5. Best Available Techniques
6. Emerging Techniques
7. Concluding remarks
13
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
NEW PROPOSED BREF Contents:
Preface
Scope
Chapter 1: General information
Chapter 2: Applied processes
Chapter 3: Current emission and consumption levels
Chapter 4: Techniques to consider in the determination of BAT
Chapter 5: BAT conclusions
Chapter 6: Emerging techniques
Chapter 7: Concluding remarks and recommendations for future work
14
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• EIPPCB (European IPPC Bureau): for each BREF, there will be 2 authors in parallel; this in order to guarantee continuity
• TWG (Technical Working Group): "Seville group"; composition in principle as before, but representatives from Industry have to be nominated through IED Article 13 Forum
• IED Article 13 Forum: group consisting of Member States, Commission, Industry, NGO's, led by the Commission. Gives comments/statements to the BAT-Conclusions
• IED Article 75 Committee: "Comitology", only Member States and Commission; final adoption of BREF document and BAT-Conclusions
15
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
IED Article 13
3. The Commission shall establish and regularly convene a forum composed of representatives of Member States, the industries concerned and non-governmental organisations promoting environmental protection.
The Commission shall obtain the opinion of the forum on the practical arrangements for the exchange of information and, in particular, on the following:
(a) the rules of procedure of the forum;
(b) the work programme for the exchange of information;
(c) guidance on the collection of data;
(d) guidance on the drawing up of BAT reference documents and on their quality assurance including the suitability of their content and format.
16
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
IED Article 13
5. Decisions on the BAT conclusions shall be adopted in accordance with the regulatory procedure referred to in Article 75(2).6.
6. After the adoption of a decision in accordance with paragraph 5, the Commission shall without delay make the BAT reference document publicly available and ensure that BAT conclusions are made available in all the official languages of theUnion.7.
7. Pending the adoption of a relevant decision in accordance with paragraph 5, the conclusions on best available techniques from BAT reference documents adopted by the Commission prior to the date referred to in Article 83 shall apply as BAT conclusions for the purposes of this Chapter except for Article 15(3)and (4).
17
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
Article 75
Committee procedure
1. The Commission shall be assisted by a committee.
2. Where reference is made to this paragraph, Articles 5 and 7 of Decision 1999/468/EC shall apply, having regard to the provisions of Article 8 thereof. [Comitology definition]
The period laid down in Article 5(6) of Decision 1999/468/EC shall be set at 3 months.
18
4. BREF documents under IED
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
Review Preparation
TWG Reactivation / Call for wishes
Kick-Off Meeting Preparation
Kick-Off Meeting
New Information
Drafting
Draft Formal
TWG Comments
Final TWG Meeting
Drafting
Prepare final draft
Consideration by Forum
Forum
Preparation
Committee
Preparation
BATC
Publication
Working Period
Specific Date /
Meeting
19
5. Planning for the revision of BREF documents
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• Work under IED has started with the revision of the BREF 'Glass and Steel'
• In parallel a so-called 'Guidance Document' has been elaborated in the Art. 13 Forum and published on 2.3. 2012: "Commission implementing decision 2012/119/EU of 10 February 2012 laying down concerning guidance on collection of data and of the drawing up of BAT reference documents and on their quality assurance referred to in Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions"
• As always, documents like this are a compromise; but our assessment is that we can live with it
• Revision of the BREF LCP is the first governed by IED from the very beginning
20
5. Planning for the revision of BREF documents
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
21
5. Planning for the revision of BREF documents
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
22
5. Planning for the revision of BREF documents
BREF WT
• Reactivation of the TWG: 24.6.2013
• Submission of 'wish list': 20.9.2013
• Kick-off meeting: 25.-28.11.2013
• Questionnaire send: 27.6.2014
• Reply to questionnaire: 31.10.2014
BREF WI
• Reactivation of the TWG: 12.5.2014
• Submission of 'wish list': 12.9.2014
• Kick-off meeting (planned): 19.-22.1.2015
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• After reactivation of the TWG, a so-called 'wish list' can be submitted (also called 'frontloading')
• Under IED, preferably complete data sets/information from various plants shall be provided
• A 'Questionnaire' has to be elaborated specifically
• This should request not only technical data, emissions, consumption etc. but also cost
• Data should be collected over a longer period, e.g. one year
• In principle, data could be declared as 'confidential'; then only EIPPCB will have access, not the TWG
23
5. Planning for the revision of BREF documents
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• ESWET has started with a dedicated working group more than 2 years ago
• Most important are the revision of the BREF WT and the BREF WI
• In a first step, the existing documents have been analysed; identifying missing/wrong/outdated information
• The implications of the new 'rules' on the data reported has been analysed in great detail
• A detailed 'wish list' has been prepared and submitted
First for the BREF WI, but then also for the BREF WT, ESWET and CEWEP have formed joint working groups
24
6. ESWET planning
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
Some questions
How many plants and which plants should provide data; how many will answer
Short- or long-term averages
How to deal with data/information declared as 'confidential'
How will BATAEL's (ranges or single values) be derived
25
6. ESWET planning
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• The role of BREF documents has changed significantly under IED
• From a 'technical handbook' to a legally binding document, that is mandatory in permitting
• This will play a role when submitting data/information
• How and what data will be collected, will be quite different
• All stakeholders will start much earlier and more intense with their preparation
26
7. Summary
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
• All participants are on a 'learning curve'
• EIPPCB is struggling with resources; envisioned time for revisions of BREF cannot be kept
• Has led to focusing more and more on BAT-Conclusions and what is leading to them
• Commission and EIPPCB are in general very transparent and cooperative
Will be a time-consuming, interesting and challenging process
But will be worth the effort
BREF documents are being looked at worldwide
27
7. Summary
11th International Conference, Bydgoszcz 4./6.11.2014
European Suppliers of Waste to Energy Technology
Thank you very much for your attention
www.eswet.eu
28 11th International Conference, Bydgoszcz 4./6.11.2014