WGC Call for IP key issues - IKEMFileName=WGC+Call+for+IPs+...1.3.2 Production of sulphuric acid...

Edificio Expo – C/ Inca Garcilaso, 3 – ES-41092 Seville – Spain

Telephone: +34-95 44 88 284. Fax: +34-95 44 88 426

E.mail: [email protected]. Internet: http://eippcb.jrc.ec.europa.eu/

EUROPEAN COMMISSION DIRECTORATE-GENERAL JOINT RESEARCH CENTRE Directorate B – Growth and Innovation Circular Economy and Industrial Leadership Unit (DG JRC.B.5) European IPPC Bureau

Seville, 20 January 2017

Subject: Best Available Techniques Reference document for Common Waste Gas Treatment in the

Chemical Sector (the WGC BREF) - Call for initial positions, Document 2

Table of Contents

ACRONYMS ........................................................................................................................ 3

1 SCOPE OF THE WGC BREF..................................................................................... 5

1.1 OVERVIEW .......................................................................................................................... 5

1.2 BAT ON EMISSIONS TO AIR IN OTHER RELEVANT BREFS .................................................. 5

1.2.1 Overview ................................................................................................................... 5

1.2.2 CAK BREF ............................................................................................................... 6

1.2.3 CWW BREF ............................................................................................................. 6

1.2.4 LVOC BREF ............................................................................................................ 7

1.2.5 EFS BREF ................................................................................................................ 8

1.2.6 LCP BREF and MCP Directive ................................................................................ 9

1.2.7 WI BREF ................................................................................................................ 10

1.2.8 ICS BREF ............................................................................................................... 11

1.3 CONSIDERATION OF SPECIFIC PRODUCTS/PROCESSES ...................................................... 11

1.3.1 Overview ................................................................................................................. 11

1.3.2 Production of sulphuric acid ................................................................................... 14

1.4 SUMMARY OF THE EIPPCB PROPOSALS AND REQUESTS TO THE TWG ON THE SCOPE OF

THE WGC BREF .............................................................................................................. 15

2 STRUCTURE (AND CONTENTS) OF THE WGC BREF AND OF ITS BAT

CONCLUSIONS ......................................................................................................... 16

2.1 OVERVIEW ........................................................................................................................ 16

2.2 EIPPCB PROPOSAL FOR THE STRUCTURE (AND CONTENTS) OF THE WGC BREF AND

FOR ITS BAT CONCLUSIONS ............................................................................................. 16

3 KEY ENVIRONMENTAL ISSUES (KEIS) FOR THE WGC BREF ................... 18

3.1 OVERVIEW ........................................................................................................................ 18

3.2 INITIAL PROPOSALS FROM THE UNITED KINGDOM, CEFIC, GERMANY, AND VCI .......... 19

3.2.1 Overview ................................................................................................................. 19

3.2.2 Initial proposals from the United Kingdom ............................................................ 19

3.2.3 Initial proposals from CEFIC ................................................................................. 19

3.2.4 Information and initial proposals from Germany ................................................... 20

3.2.5 Information and initial proposals from VCI ........................................................... 21

Drawing up of the WGC BREF: Call for initial positions / Document 2

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3.2.6 EIPPCB proposal and TWG views on initial proposals from the United Kingdom,

CEFIC, Germany and VCI ...................................................................................... 21

3.3 IDENTIFICATION OF RELEVANT SUBSTANCES ................................................................... 22

3.3.1 Overview ................................................................................................................. 22

3.3.2 Substances referred to in the IED and the current chemical BREFs....................... 22

3.3.3 Substances with European Air Quality Standards .................................................. 23

3.3.4 Substances contained in the E-PRTR ..................................................................... 24

3.3.5 TWG views on substances included in the current chemical BREFs, European

ambient air quality standards and the E-PRTR ....................................................... 28

3.3.6 Substances for which industrial emissions are (partly) covered by legislation

other than the IED ................................................................................................... 29

3.4 IDENTIFICATION OF RELEVANT MASS FLOWS ................................................................... 30

3.5 SUMMARY OF THE EIPPCB PROPOSALS AND REQUESTS TO THE TWG ON THE

SELECTION OF KEIS FOR THE DRAWING UP OF THE WGC BREF ..................................... 31

4 DATA COLLECTION FOR THE WGC BREF ...................................................... 32

4.1 OVERVIEW ........................................................................................................................ 32

4.2 NOX EMISSION DATA COLLECTED DURING THE LVOC BREF REVIEW ........................... 33

4.3 ENVIRONMENTAL PERFORMANCE LEVELS ....................................................................... 33

4.3.1 Overview ................................................................................................................. 33

4.3.2 Units and averaging periods ................................................................................... 33

4.3.3 Grouping of substances and differentiation within groups of substances ............... 34

4.4 MONITORING OF EMISSIONS ............................................................................................. 35

4.5 QUESTIONNAIRE(S) FOR GATHERING PLANT-SPECIFIC DATA AND INFORMATION ........... 35

4.6 CONFIDENTIALITY ISSUES ................................................................................................ 37

4.7 SELECTION OF PLANTS/INSTALLATIONS FOR THE PLANT-SPECIFIC DATA COLLECTION ... 37

4.8 SUMMARY OF THE EIPPCB PROPOSALS AND REQUESTS TO THE TWG ON THE DATA

COLLECTION FOR THE DRAWING UP OF THE WGC BREF ................................................ 38

5 TECHNIQUES TO CONSIDER IN THE DETERMINATION OF BAT AND

EMERGING TECHNIQUES .................................................................................... 40


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ACRONYMS

Acronym Meaning

AOX Adsorbable organically bound halogens

BAT Best Available Techniques (as defined in Article 3(10) of the IED)

BAT-AEL Emission level associated with the BAT (as defined in Article 13(3) of the IED)

BAT-AEPL BAT-associated environmental performance level (as described in Section 3.3 of

Commission Implementing Decision 2012/119/EU). BAT-AEPLs include BAT-AELs

BATIS BAT Information System

BREF BAT reference document (as defined in Article 3(11) of the IED)

CAK BREF BAT reference document for the Production of Chlor-alkali

CEFIC European Chemical Industry Council

CFCs Chlorofluorocarbons

CMR Carcinogenic, mutagenic or toxic for reproduction

COD Chemical oxygen demand

CWW BREF BAT reference document for Common Waste Water and Waste Gas

Treatment/Management Systems in the Chemical Sector

EDC Ethylene dichloride

EFS BREF BAT reference document on Emissions from Storage

EIPPCB European IPPC Bureau

ELV Emission limit value

EN European Standard adopted by CEN (European Committee for Standardisation, from its

French name Comité Européen de Normalisation)

E-PRTR European Pollutant Release and Transfer Register

EU European Union

HCB Hexachlorobenzene

HCFCs Hydrochlorofluorocarbons

HFCs Hydrofluorocarbons

ICS BREF BAT reference document on Industrial Cooling Systems

IED Industrial Emissions Directive (2010/75/EU)

IPPC Integrated Pollution Prevention and Control

ISO International Organisation for Standardisation. Also international standard adopted by

this organisation

KEI Key environmental issue

LCP BREF BAT reference document for Large Combustion Plants

LVIC-AAF

BREF

BAT reference document for the Manufacture of Large Volume Inorganic Chemicals –

Ammonia, Acids and Fertilisers

LVIC-S BREF BAT reference document for the Manufacture of Large Volume Inorganic Chemicals –

Solids and Others Industry

LVOC BREF BAT reference document for the Large Volume Organic Chemical Industry

MDA Methylene diphenyl diamine

MDI Methylene diphenyl diisocyanate

Ninorg Total inorganic nitrogen

NMVOC Non-methane volatile organic compound

OFC BREF BAT reference document for the Manufacture of Organic Fine Chemicals

OTNOC Other than normal operating conditions

PAH Polycyclic aromatic hydrocarbon

PCDD/F Polychlorinated dibenzo-p-dioxin/furan

PER Perchloroethylene (tetrachloroethylene)

PFCs Perfluorocarbons

PM Particulate matter

PM2.5 Particulate matter which passes through a size-selective inlet with a 50 % efficiency cut-

off at 2.5 μm aerodynamic diameter as defined in Directive 2008/50/EC

PM10 Particulate matter which passes through a size-selective inlet with a 50 % efficiency cut-

off at 10 μm aerodynamic diameter as defined in Directive 2008/50/EC

POL BREF BAT reference document in the Production of Polymers

PVC Polyvinyl chloride

REACH Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation

and Restriction of Chemicals


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ROM REF JRC Reference Report on Monitoring of emissions to air and water from IED

installations

SCR Selective catalytic reduction

SNCR Selective non-catalytic reduction

SIC BREF BAT reference document for the Production of Speciality Inorganic Chemicals

SVHC Substance of very high concern

TDA Toluene diamine

TDI Toluene diisocyanate

TN Total nitrogen

TOC Total organic carbon

TVOC Total volatile organic carbon

TWG Technical Working Group

VCI Verband der Chemischen Industrie (German chemical industry association)

VCM Vinyl chloride monomer

VOC Volatile organic compound (as defined in Article 3(45) of the IED)

WI BREF BAT reference document on Waste Incineration

WGC BREF BAT reference document for Common Waste Gas Treatment in the Chemical Sector


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1 SCOPE OF THE WGC BREF

1.1 Overview

As laid out in the Commission's work programme for the exchange of information under the Industrial

Emissions Directive 2010/75/EU (IED)1, the drawing up of the WGC BREF will involve collecting

comprehensive and representative information and data on abatement techniques and emission levels across

the whole chemical industry of the EU.

Therefore, in principle, the WGC BREF concerns all chemical installations falling under the scope of the

IED, i.e. the activities specified in Section 4 of Annex I to the IED. However, the scope of the WGC BREF

may be restricted for the following reasons:

1. Coherence with other BREFs: Certain emissions to air might already be covered by, or be better

addressed in, other relevant BREFs (see Section 1.2).

2. Decisions that will be taken at the WGC kick-off meeting to focus the information and data

collection on Key Environmental Issues (KEIs): It is proposed to restrict the data collection to a

limited number of substances or groups of substances that are emitted in significant quantities (see

Sections 3 and 4).

3. Decisions that will be taken at a later stage of the drawing up the WGC BREF: For example, it could

be decided that there is insufficient information to derive sound BAT (-AEPLs) for a certain

product/process.

Proposal 1: The EIPPCB proposes to cover all chemical installations falling under the scope of the IED

in the scope of the WGC BREF (unless specifically excluded by other proposals). However, depending

on the decisions taken by the TWG on KEIs as well as on the quality and quantity of the data and

information collected, the scope coverage might end up being more restricted.

1.2 BAT on emissions to air in other relevant BREFs

1.2.1 Overview

Section 1.1.2 of the BREF Guidance2 foresees that 'horizontal' and 'vertical' BREFs should be developed so

as to be complementary and that this should not result in conflicting conclusions. 'Horizontal' BREFs shall

include information of a generic nature that can be used across many activities which fall under the IED

scope. In order to facilitate the use of both 'vertical' and 'horizontal' BREFs in a complementary way,

appropriate cross references need to be made.

Given that the WGC BREF only concerns activities listed in one section of Annex I to the IED (i.e. Section 4

'Chemical industry'), it is considered to be a 'vertical' BREF.

The other BREFs most relevant for emissions to air from the chemical sector are summarised in the

following sections.

1 European Commission: Work programme for the exchange of information under Article 13(3)(b) of the IED for 2016 (and the outlook for the

following years), 29 January 2016, https://circabc.europa.eu/w/browse/33cff69c-bfd0-49e7-8f19-f75a9e062745. 2 Commission Implementing Decision 2012/119/EU laying down rules concerning guidance on the collection of data and on 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, Official Journal of the European Union, L 63, 3.3.2012, p. 1-39, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012D0119.

https://circabc.europa.eu/w/browse/33cff69c-bfd0-49e7-8f19-f75a9e062745

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012D0119

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012D0119


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1.2.2 CAK BREF

The review of the Production of Chlor-alkali (CAK) BREF was completed in 2013 and the published BREF

can be found on the EIPPCB website3. Except for monitoring, the CAK BREF contains five BAT

conclusions relevant for emissions to air (see Table 1.1).

Table 1.1: BAT conclusions relevant for emissions to air in the CAK BREF (except monitoring)

BAT Topic

BAT 1 Cell technique

BAT 2 Decommissioning of mercury cell plants

BAT 8 Use of an alkaline scrubber to reduce emissions of chlorine and chlorine dioxide

(linked to a BAT-AEL for chlorine and chlorine oxide)

BAT 9 Use of carbon tetrachloride as a process agent

BAT 10 Use of refrigerants for chlorine liquefaction

The relevant pollutants and sources in this specific chemical subsector were thoroughly assessed in the

BREF review process, and the EIPPCB believes there are no major gaps.

Proposal 2: The EIPPCB proposes to exclude CAK activities from the scope of the WGC BREF.

1.2.3 CWW BREF

The review of the Common Waste Water and Waste Gas Treatment/Management Systems in the Chemical

Sector (CWW) BREF was completed in 2015 and the published BREF can be found on the EIPPCB

website4. Except for monitoring, the CWW BREF contains 10 BAT conclusions relevant for emissions to air,

none of which are related to a BAT-AEL (see Table 1.2).

Table 1.2: BAT conclusions relevant for emissions to air in the CWW BREF (except monitoring)

BAT Topic

BAT 2 Inventory of waste gas streams

BAT 15 Enclosure of emission sources and treatment of emissions

BAT 16 Integrated waste gas management and treatment strategy

BAT 17 Prevention of flaring events

BAT 18 Reduction of emissions when using flares

BAT 19 Prevention/reduction of diffuse VOC emissions

BAT 20 Odour management plan

BAT 21 Reduction of odour emissions from waste water collection and treatment and from

sludge treatment

BAT 22 Noise management plan

BAT 23 Prevention/reduction of noise emissions

Hence, the CWW BREF provides a number of generic BAT conclusions concerning emissions to air that are

relevant for the whole chemical industry. However, channelled emissions to air are not covered by the CWW

BREF and these are considered major emission sources in the chemical industry.

Proposal 3: The EIPPCB proposes to include channelled emissions to air in the scope of the WGC

BREF except for those substances for which BAT-AELs have been set during the review of other

chemical BREFs under the IED. This includes covering in the WGC scope emissions from individual

and combined waste gas streams.

3 European Commission, Best Available Techniques (BAT) Reference Document for the Production of Chlor-alkali, 2014,

http://eippcb.jrc.ec.europa.eu/reference/BREF/CAK_BREF_102014.pdf. 4 European Commission, Best Available Techniques (BAT) Reference Document for Common Waste Water and Waste Gas

Treatment/Management Systems in the Chemical Sector, 2016, http://eippcb.jrc.ec.europa.eu/reference/BREF/CWW_Bref_2016_published.pdf.

http://eippcb.jrc.ec.europa.eu/reference/BREF/CAK_BREF_102014.pdf

http://eippcb.jrc.ec.europa.eu/reference/BREF/CWW_Bref_2016_published.pdf


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Moreover, the CWW BREF also does not cover diffuse emissions to air other than VOCs. These might be

important emissions (e.g. of dust) which could be included in the scope of the WGC BREF. However, it

might be more appropriate to address these diffuse emissions in the next CWW BREF review, as it already

covers diffuse VOC emissions, or in the next review of the EFS BREF, since such emissions are in many

cases related to the storage and handling of materials (see Section 1.2.5). The EIPPCB is of the opinion that

these should be covered in the next review of the CWW or EFS BREFs.

Proposal 4: The EIPPCB proposes to exclude the prevention/reduction of diffuse emissions to air from

the scope of the WGC BREF.

Finally, as summarised in Table 1.2, noise and odour emissions are already addressed in the CWW BREF.

Proposal 5: Moreover, the EIPPCB proposes to exclude emissions of noise and odour from the scope of

the WGC BREF.

1.2.4 LVOC BREF

The review of the Large Volume Organic Chemicals (LVOC) BREF is nearing completion5. Following the

final meeting of the Technical Working Group (TWG) in Seville in April 2016, the EIPPCB is working on

the final draft which should be published in early 2017. The scope of the revised LVOC BREF includes:

the production of organic chemicals as specified in Section 4.1(a) to (g) and (k) of Annex I to

Directive 2010/75/EU;

the production of hydrogen peroxide as specified in Section 4.2(e) of Annex I to Directive

2010/75/EU;

the combustion of fuels in process furnaces/heaters, where this is part of the aforementioned

activities.

The LVOC BREF covers the production of the aforementioned chemicals in continuous processes where

the total production capacity of those chemicals exceeds 20 000 tonnes/year.

While the LVOC BAT conclusions contain generic BAT conclusions for emissions of NOX, dust, SO2 and

CO to air for the whole LVOC sector, no generic BAT-AELs for emissions to air were concluded on at the

final TWG meeting. However, BAT and BAT-AELs were concluded on for some specific products and

processes which are described in the illustrative chapters of the BREF as indicated in Table 1.3 below.

5 European Commission, Conclusions of the Final Meeting of the Technical Working Group (TWG) for the review of the BAT reference document

for the Production of Large Volume Organic Chemicals (LVOC) BREF held in Seville, 25–29 April 2016, http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=118157.

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=118157


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Table 1.3: BAT-AELs for specific products and processes in the LVOC BREF

LVOC illustrative chapter BAT-AELs

Lower olefins (via steam cracking) None

Ethanolamines None

TDI/MDI (from toluene/aniline via TDA/MDA) TVOC, Cl2, CCl4, HCl and PCDD/Fs

Ethylene oxide / ethylene glycol TVOC (as specific emission load)

Aromatics, including cyclohexane (from the pygas by-

products of steam crackers and from

reformate/naphtha produced in catalytic reformers)

None

Formaldehyde TVOC and formaldehyde

Phenol (via cumene oxidation) TVOC and benzene

Ethylbenzene (from benzene) and styrene (via

ethylbenzene dehydrogenation or co-production with

propylene oxide)

None

Hydrogen peroxide TVOC

Ethylene dichloride / vinyl chloride monomer (via

oxychlorination of ethylene)

TVOC, sum of EDC and VCM, Cl2, HCl and

PCDD/Fs

Process furnaces/heaters: lower olefins and ethylene

dichloride crackers

NOX from the crackers and NH3 from the use of

SCR/SNCR

The LVOC BREF does not include BAT-AELs for emissions to air from:

shared waste gas treatment;

the production of large volume organic chemicals that are not described in the illustrative chapters

(e.g. the production of chemicals for which thumbnail descriptions are given in Chapter 2 of the

LVOC BREF including acetic acid, aniline, caprolactam, ethanol, fatty acid methyl esters

(biodiesel), methanol, etc.);

some illustrative processes (e.g. no BAT-AELs in four illustrative chapters (see Table 1.3), no BAT-

AEL for ethylene oxide from ethylene oxide production);

the production of the chemicals described in the illustrative chapters, but via different process routes

(e.g. vinyl chloride monomer production via direct chlorination of acetylene or propylene oxide by

routes other than via co-production with styrene);

batch processes or from continuous processes with a total production capacity below

20 000 tonnes/year (e.g. formaldehyde is sometimes produced in smaller stand-alone plants).

Therefore, the LVOC BREF does not include BAT-AELs for a number of relevant emissions to air from the

large volume production of organic chemicals.

Proposal 6: The EIPPCB proposes to include channelled emissions to air from the large volume

production of organic chemicals in the scope of the WGC BREF except for the substances produced in

those processes for which BAT-AELs have been set during the review of the LVOC BREF.

1.2.5 EFS BREF

The Emissions from Storage (EFS) BREF was published in 2006 under the IPPC Directive6 and a review

under the IED is not yet programmed. The EFS BREF is a 'horizontal' BREF that addresses the storage,

transfer and handling of liquids, liquefied gases and solids, regardless of the sector or industry. It addresses

emissions to air, soil and water, though most attention is given to emissions to air. The BAT conclusions in

the EFS BREF contain one BAT-AEL (for emissions of dust from enclosed storage) and a BAT-associated

emission reduction level for a large external floating roof tank (compared to a fixed roof tank without

abatement measures).

6 European Commission, Reference Document on Best Available Techniques on Emissions from Storage, 2006,

http://eippcb.jrc.ec.europa.eu/reference/BREF/esb_bref_0706.pdf.

http://eippcb.jrc.ec.europa.eu/reference/BREF/esb_bref_0706.pdf


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For the storage, transfer and handling of liquids and liquefied gases, the EFS BREF addresses tank types,

piping systems, material loading and unloading equipment. For the storage, transfer and handling of solids,

the EFS BREF describes mobile unloading devices, grabs, dump pits, fill pipes, thrower belts, conveyors and

feeders, and in each case the emission sources are identified.

Emissions from the storage, transfer and handling of materials are often diffuse emissions, although in some

cases they might be channelled to a (shared) treatment system (e.g. if exhausts from filling a solvent tank are

directed to a shared thermal oxidiser). For the chemical sector, diffuse VOC emissions are addressed by the

CWW BREF (see Section 1.2.3).

The final TWG meeting for the review of the LVOC BREF, held in April 2016, recommended that emissions

from storage related to LVOC production should be addressed in the future WGC BREF. However,

emissions from the storage, transfer and handling of materials are relevant for many industry sectors and

similar techniques are used. Therefore, it seems to make more sense to address these emissions in the

horizontal EFS BREF. However, if there is a shared waste gas treatment system for process emissions and

storage emissions where the storage emissions are only a small part of the load, then the storage emissions

will be included in the WGC BREF.

Proposal 7: The EIPPCB proposes to exclude emissions from the storage, transfer and handling of

materials from the scope of the WGC BREF.

1.2.6 LCP BREF and MCP Directive

The review of the Large Combustion Plants (LCP) BREF is nearing completion. The final draft was

published in June 20167. The LCP BREF concerns the following activities specified in Annex I to Directive

2010/75/EU:

Section 1.1: Combustion of fuels in installations with a total rated thermal input of 50 MW or more,

only when this activity takes place in combustion plants with a total rated thermal input of 50 MW or

more;

Section 1.4: Gasification of coal or other fuels in installations with a total rated thermal input

of 20 MW or more, only when this activity is directly associated with a combustion plant;

Section 5.2: Disposal or recovery of waste in waste co-incineration plants for non-hazardous waste

with a capacity exceeding 3 tonnes per hour or for hazardous waste with a capacity exceeding

10 tonnes per day, only when this activity takes place in combustion plants covered under 1.1 above.

The fuels considered in the LCP BREF are any solid, liquid and/or gaseous combustible material including

industry-specific fuels, e.g. by-products from chemical industries.

The LCP BREF defines a combustion plant as any technical apparatus in which fuels are oxidised in order to

use the heat thus generated. However, process furnaces/heaters are excluded from the scope of the LCP

BREF. Process furnaces/heaters are understood to be combustion plants whose flue-gases are used for the

thermal treatment of objects or feed material through a direct contact heating mechanism (e.g. a reactor used

in the (petro-)chemical industry), or whose radiant and/or conductive heat is transferred to objects or feed

material through a solid wall without using an intermediary heat transfer fluid (e.g. a furnace or reactor

heating a process stream used in the (petro-)chemical industry such as a steam cracker furnace).

Directive (EU) 2015/2193 on the limitation of emissions of certain pollutants into the air from Medium

Combustion Plants (the MCP Directive) applies to combustion plants with a total rated thermal input equal to

or greater than 1 MW and less than 50 MW, irrespective of the type of fuel they use. However, it does not

apply to combustion plants in which the gaseous products of combustion are used for the direct heating,

7 European Commission, Best Available Techniques (BAT) Reference Document for Large Combustion Plants, Final draft June 2016,

http://eippcb.jrc.ec.europa.eu/reference/BREF/LCP_FinalDraft_06_2016.pdf.

http://eippcb.jrc.ec.europa.eu/reference/BREF/LCP_FinalDraft_06_2016.pdf


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drying, or any other treatment of objects or materials, or to reactors used in the chemical industry (Articles

2(3)(d) and (k) of the MCP Directive)8.

In summary, emissions to air from combustion plants operating at chemical sites are largely addressed by the

LCP BREF and the MCP Directive. However, process furnaces and heaters are not covered and in some

cases these might constitute major emission sources.

Proposal 8: The EIPPCB proposes to exclude emissions from the combustion of fuels covered by the

LCP BREF or the MCP Directive from the scope of the WGC BREF.

Proposal 9: The EIPPCB proposes to include in the scope of the WGC BREF emissions from process

furnaces/heaters used in the chemical industry, with the exception of the process furnaces/heaters used

in lower olefins and ethylene dichloride crackers, which are covered by the LVOC BREF.

For the discussions at the WGC kick-off meeting and the preparation of the data collection, it also seems

useful to gather a list of processes/products which involve the use of process furnaces/heaters. Some

examples can be found in the existing chemical BREFs. For example, primary reformers for the production

of ammonia are described in the LVIC-AAF BREF9 and furnaces for the production of carbon black are

described in the LVIC-S BREF10.

Request 1: The TWG is asked to provide a list of processes/products which involve the use of process

furnaces/heaters.

1.2.7 WI BREF

The kick-off meeting for the review of the Waste Incineration (WI) BREF took place in January 201511. The

TWG reached the following conclusions:

to define the scope of the revised WI BREF based primarily on the capacity thresholds set for the

activities described in Section 5.2 of Annex I to the IED;

to exclude from the scope of the revised WI BREF those plants which only incinerate gaseous

effluents.

The treatment of gaseous effluents from chemical installations using thermal or catalytic oxidation is thus not

covered by the WI BREF. Thermal and catalytic oxidation are described in the CWW and LVOC BREFs,

and the LVOC BREF contains BAT-AELs in some illustrative chapters based on these techniques4, 5

.

Proposal 10: The EIPPCB proposes to exclude emissions from the incineration of waste covered by the

WI BREF from the scope of the WGC BREF.

Proposal 11: The EIPPCB proposes to include the thermal treatment of gaseous effluents in the scope

of the WGC BREF.

8 Directive (EU) 2015/2193 of the European Parliament and of the Council on the limitation of emissions of certain pollutants into the air from

medium combustion plants, Official Journal of the European Union, L 313, 28.11.2015, p. 1-19, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L2193.

9 European Commission, Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals -

Ammonia, Acids and Fertilisers, 2007, http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic_aaf.pdf. 10 European Commission, Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals - Solids

and Others industry, 2007, http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic-s_bref_0907.pdf. 11 European Commission, Meeting report for the Kick-off meeting for the review of the Reference Document on the Best Available Techniques for

Waste Incineration, Seville, 19–22 January 2015, http://eippcb.jrc.ec.europa.eu/reference/BREF/Meeting%20report%20KOM%20WI.pdf.

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L2193


http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic_aaf.pdf

http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic-s_bref_0907.pdf

http://eippcb.jrc.ec.europa.eu/reference/BREF/Meeting%20report%20KOM%20WI.pdf


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1.2.8 ICS BREF

The Industrial Cooling Systems (ICS) BREF was published in 2001 under the IPPC Directive12. A review of

this BREF under the IED is not yet programmed. The scope of the term 'cooling systems' in the ICS BREF is

confined to systems to remove waste heat from any medium, using heat exchange with water and/or air to

bring down the temperature of that medium towards ambient levels. This includes refrigeration systems, but

excludes the use of refrigerants such as ammonia and chlorofluorocarbons (CFCs).

Proposal 12: The EIPPCB proposes to exclude emissions from cooling systems from the scope of the

WGC BREF.

1.3 Consideration of specific products/processes

1.3.1 Overview

As laid out in the Commission's work programme for the exchange of information under the IED1, the

drawing up of the WGC BREF will involve collecting information and data from specific

products/processes that might require a dedicated approach when defining BAT and BAT-AELs for

emissions to air. This approach aims at addressing concerns raised by some members of the IED Article 13

forum that generic BAT-AEL ranges could become too wide or, conversely, not take into account the

peculiarities of some products/processes.

The Commission work programme indicated that the review of the remaining chemical BREFs will be

postponed. Once the WGC BREF is at a sufficiently advanced stage, decisions will be taken on which, if

any, chemical products/processes need to be addressed in other separate BREF(s), taking into consideration

factors such as the number of installations in the EU and the magnitude of their emissions to the

environment. At this stage, the aim of the Commission is to cover as many relevant sources for

emissions to air as possible and manageable in order to minimise the need to review the remaining

chemical BREFs13 (i.e. LVIC-AAF, LVIC-S, POL, OFC and SIC BREFs).

As a consequence of adopting such a generic approach, the WGC BREF will focus on recovery and

abatement techniques, rather than on process-integrated techniques. In principle, this approach should work

when the emission levels depend primarily on the abatement techniques used and their performance. There

may be cases where emission levels from specific products/processes are higher than in the generic case even

though the same abatement techniques with similar or even better performances are used, e.g. when the

untreated waste gas stream is characterised by high volumetric flows or pollutant loads. In such cases,

different BAT-AELs could be defined taking into account the characteristics of the untreated waste gas

stream, but it may not be necessary to enter into the details of the production process as such in order to

understand the emission levels.

On the other hand, the generic approach will face more difficulties when the emission levels significantly

depend on process-integrated techniques. The current series of chemical BREFs have included an increasing

number of specific products/processes within their scope and set product/process-specific BAT conclusions.

If the WGC BREF was to follow this approach and to describe how specific products are manufactured and

how specific processes work then the drawing up of the WGC BREF would become unmanageable.

However, the description and analysis of the manufacturing process of a very limited number of specific

products could exceptionally be included in the scope of the WGC BREF, provided that the process is

particularly relevant for emissions to air. One potential specific product, sulphuric acid, is addressed in

Section 0.

12 European Commission, Reference Document on the application of Best Available Techniques to Industrial Cooling Systems,

http://eippcb.jrc.ec.europa.eu/reference/BREF/cvs_bref_1201.pdf. 13 BATIS > Forums > Waste Gas Treatment in the Chemical Sector > 00 Emails sent to the TWG > 2016-12-19 TWG reactions to welcome email

and DG ENV answer, http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showPost&forumID=119183&postID=120520&readPost.

http://eippcb.jrc.ec.europa.eu/reference/BREF/cvs_bref_1201.pdf

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum



http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showPost&forumID=119183&postID=120520&readPost


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At this stage, little information is available on specific products/processes that might require a dedicated

approach and it is therefore difficult to assess if these could be comprehensively covered by the WGC BREF.

In this respect, the recent study of Ökopol for the German Environment Agency identified a number of

products/processes where emission levels and/or loads were found to be significantly higher than in the

generic case (see Table 1.4).

Table 1.4: Specific products/processes with high emission levels and/or loads as identified in the Ökopol study

for the German Environment Agency

Parameter Specific product/process

Ammonia (NH3)

PVC polymers (Point 4.1(h) of Annex I to the IED)

Fertilisers (Point 4.3 of Annex I to the IED)

Aromatic hydrocarbons containing fluorine (Point 4.1(f) of Annex I to the IED)

Flame retardants

Nitrogenous hydrocarbons (Point 4.1(d) of Annex I to the IED)

Hydrogen chloride (HCl) Non-metals, metal oxides or other inorganic compounds (Point 4.2(e) of Annex I to

the IED)

Nitrogen oxides (NOX) Fertilisers (Point 4.3 of Annex I to the IED)

Nitrogenous hydrocarbons (Point 4.1(d) of Annex I to the IED)

Sulphur oxides (SOX)

Sulphuric acid (Point 4.2(b) of Annex I to the IED)

Sodium hydrogen sulphate (Point 4.2(d) of Annex I to the IED)

Cement additives

TVOC

Plastic materials (polymers, synthetic fibres and cellulose-based fibres: slab stock or

moulded polyurethane foam production using hydrocarbons like pentane as blowing

agents (Point 4.1(h) of Annex I to the IED)

Surface-active agents and surfactants (Point 4.1(k) of Annex I to the IED)

Source: Ökopol, Definition of Best Available Techniques (BAT) in Europe: BAT for Air Emission Reduction in the Chemical

Industry Sector in Germany, October 2016,

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=120253.

As mentioned in the Commission's work programme for the exchange of information under the IED1,

another source of candidates for specific products/process that might require a dedicated approach could be

national legislation from EU Member States, i.e. when provisions for specific products/processes are set in

addition to general binding rules (see some examples in Table 1.5).



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Table 1.5: Examples from EU Member States' legislation where specific provisions for emissions to air from

chemical activities are defined in addition to general binding rules

Parameter Specific product/process

Member State with specific

provisions

France Germany Italy

Ammonia (NH3) Sodium carbonate - + -

Fertilisers - + +

Acrylonitrile Acrylonitrile - + -

Polymers based on acrylonitrile - + +

Benzene Carbon black - + -

Cyclohexane oxidation - + -

Carbon disulphide

(CS2)

Sulphur - + -

Viscose - + +

Chlorine (Cl2) Chlor-alkali - + +

Titanium dioxide + - -

Dust

Biocides - + +

Carbon black - - +

Fertiliser - + +

Titanium dioxide + - -

Dichloromethane

(CH2Cl2) Polycarbonate - - +

Hydrogen sulphide

(H2S)

Sulphur - + +

Viscose - + +

Mercury (Hg) Chlor-alkali - + +

Nitrogen oxides (NOX)

Carbon black - + +

Cellulose nitration - - +

Nitric acid + + -

Nitrosylsulphuric acid - - +

Nitrous oxide (N2O) Nitric acid - + -


Carbon black - + +

Nitrosylsulphuric acid - - +

Sulphur - + -

Sulphur dioxide/trioxide, sulphuric acid,

and oleum + + +

Titanium dioxide + - +

TVOC

Carbon black - + -

Polyester - - +

Polyethylene (high-pressure) - + -

Polystyrene (expandable) + - -

Polyurethane foams, when using pure

hydrocarbons as propellants - + -

PVC + - -

Vinyl chloride

monomer (VCM) PVC + + +

NB: + = legislation contains a specific provision; - = legislation does not contain a specific provision. The list is not

exhaustive. The German TA Luft is currently under revision and more specific provisions are likely to be added.

Source: France: Arrêté du 02/02/98 relatif aux prélèvements et à la consommation d'eau ainsi qu'aux émissions de toute

nature des installations classées pour la protection de l'environnement soumises à autorisation; Germany: First General

Administrative Regulation Pertaining the Federal Immission Control Act (Technical Instructions on Air Quality

Control – TA Luft) of 24 July 2002; Italy: Allegati al Decreto legislativo 3 aprile 2006, n. 152.

Request 2: The TWG is asked to provide a list of candidate products/processes that would require a

dedicated approach when defining BAT and BAT-AEPLs (which include BAT-AELs) for emissions to

air, including a sound justification.


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1.3.2 Production of sulphuric acid

The production of sulphuric acid represents a particular issue within the specific products/processes that

might require a dedicated approach, as it is also related to the production of non-ferrous metals.

During its final TWG meeting in March 2014, the TWG for the review of the Non-Ferrous Metals (NFM)

BREF considered that the production of sulphuric acid was within the scope of the LVIC-AAF BREF and

decided that it would therefore be removed from the scope of the NFM BREF in order to ensure consistency

and to avoid overlaps. Some NFM TWG members, however, would have preferred to include the production

of sulphuric acid within the scope of the NFM BREF.

At that time, the drawing up of the WGC BREF was not yet envisaged. In its letter dated 5 August 2016, the

Commission informed the members and observers of the Industrial Emissions Expert Group (IEEG) that the

drawing up of the WGC BREF would constitute the first opportunity to reassess the BAT-AELs set in the

LVIC-AAF BREF for the production of sulphuric acid14.

An initial assessment of the LVIC-AAF BREF and of some Member States' legislation (see Table 1.5)

suggests that emission levels for SOX from sulphuric acid production depend on the production process (e.g.

single or double contact, single or double absorption) and that they are (partially) expressed as sulphur

conversion levels. Moreover, Eurometaux argues that NFM plants operate under specific conditions (e.g.

high variability of SO2 inlet concentrations) that are different to those of plants using elemental sulphur as

raw material15.

This suggests that emissions of SOX from the production of sulphuric acid require a dedicated approach.

They could be addressed in the WGC BREF, which is likely to require a deeper analysis of the sulphuric acid

production process(es). Although specific production processes should in principle not be described in the

WGC BREF, a very limited number of exceptions could be acceptable provided that the specific process

used is particularly relevant for emissions to air (see Section 1.3.1). This could be the case here since the

annual production of sulphuric acid in Europe in 2013 was reported to be 19 Mt/year16, of which a significant

proportion was produced by NFM plants. In 2005, 39 % of the sulphur dioxide used for sulphuric acid

production originated from the production of non-ferrous metals9.

Proposal 13: The EIPPCB proposes to include the production of sulphuric acid in the scope of the

WGC BREF, including when sulphuric acid is produced in NFM plants.

14 BATIS Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 01 Chemical strategy and work programme > 12 COM -

Letter to IED Forum on sulphuric acid production,

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showPost&forumID=119185&postID=119319&readPost. 15 BATIS Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 05 Eurometaux - Background information on sulphuric

acid production. http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=120271. 16 The University of York, The Essential Chemical Industry online, last amended 20th December 2013,

http://www.essentialchemicalindustry.org/chemicals/sulfuric-acid.html.







http://www.essentialchemicalindustry.org/chemicals/sulfuric-acid.html


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1.4 Summary of the EIPPCB proposals and requests to the TWG on the scope of the WGC BREF

Based on the information given above, the EIPPCB proposes the following elements for the scope of the

WGC BREF:

Proposal 1: To cover all chemical installations falling under the scope of the IED (unless specifically

excluded by other proposals). However, depending on the decisions taken by the TWG on KEIs as

well as on the quality and quantity of the data and information collected, the scope coverage might

end up being more restricted (see Section 1.1).

Proposal 2: To exclude CAK activities (see Section 1.2.2).

Proposal 3: To include channelled emissions to air except for those substances for which BAT-AELs

have been set during the review of other chemical BREFs under the IED. This includes emissions

from individual and combined waste gas streams (see Section 1.2.3).

Proposal 4: To exclude the prevention/reduction of diffuse emissions to air (see Section 1.2.3).

Proposal 5: To exclude emissions of noise and odour (see Section 1.2.3).

Proposal 6: To include channelled emissions to air from the large volume production of organic

chemicals except for the substances produced in those processes for which BAT-AELs have been set

during the review of the LVOC BREF (see Section 1.2.4).

Proposal 7: To exclude emissions from the storage, transfer and handling of materials (see

Section 1.2.5).

Proposal 8: To exclude emissions from the combustion of fuels covered by the LCP BREF or the

MCP Directive (see Section 1.2.6).

Proposal 9: To include emissions from process furnaces/heaters used in the chemical industry, with

the exception of the process furnaces/heaters used in lower olefins and ethylene dichloride crackers,

which are covered by the LVOC BREF (see Section 1.2.6).

Proposal 10: To exclude emissions from the incineration of waste covered by the WI BREF (see

Section 1.2.7).

Proposal 11: To include the thermal treatment of gaseous effluents (see Section 1.2.7).

Proposal 12: To exclude emissions from cooling systems (see Section 1.2.8).

Proposal 13: To include the production of sulphuric acid, including when sulphuric acid is produced

in NFM plants (see Section 0).

TWG members are asked to provide their feedback on the proposed scope by filling in the

corresponding cells in Document 3.

Moreover, TWG members are asked to provide:

Request 1: A list of processes/products which involve the use of process furnaces/heaters (see

Proposal 9 and Section 1.2.6);

Request 2: A list of candidate products/processes that would require a dedicated approach when

defining BAT and BAT-AEPLs (which include BAT-AELs) for emissions to air, including a sound

justification (see Section 1.3.1).


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2 STRUCTURE (AND CONTENTS) OF THE WGC BREF AND OF ITS BAT CONCLUSIONS

2.1 Overview

The revised CWW BREF already addresses a number of generic issues related to emissions to air from

chemical installations (see Section 1.2.3). In particular, detailed descriptions of final abatement techniques

can be found in its Chapter 3 on 'Techniques to consider in the determination of BAT'.

However, no plant-specific, detailed data on emissions to air were collected for that BREF, and consequently

no BAT-AELs were set for emissions to air. As the new WGC BREF is intended to fill the gaps left

especially by the revised CWW BREF, a reasonable approach could be to use the structure and contents of

the air-related parts of the CWW BREF as the starting point. These parts would be reviewed and, if

necessary, updated based on the information exchanged by the WGC TWG. This approach would offer the

following advantages:

valuable and peer-reviewed existing information would be used without the need to draw up a

completely new document, thereby allowing a more efficient process;

end users would find it easier to understand the WGC BREF if it follows the same structure as the

CWW BREF;

when the CWW BREF is reviewed again, the contents of both BREFs could be incorporated into a

single BREF relevant for the whole chemical industry for both emissions to air and water and

thereby avoiding a review of the WGC BREF.

2.2 EIPPCB proposal for the structure (and contents) of the WGC BREF and for its BAT conclusions

Based on the current structure of the revised CWW BREF and considering the reflections on the scope

outlined in Section 1 above, the structure of the WGC BREF and the BAT conclusions contained therein

could be as follows:


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Preface

Scope

1. General information

1.1. The chemical industry in Europe

1.2. Environmental relevance of the chemical industry for emissions to air

1.3. Waste gas in the chemical industry

1.4. Waste gas treatment technology

2. Current emission levels

2.1. General information on the collection of plant-specific data via questionnaires

2.2. Main techniques used to reduce emissions to air

2.3. Analysis of emission levels

3. Techniques to consider in the determination of BAT

3.1. Monitoring of channelled emissions to air

3.2. Generic techniques to reduce channelled emissions to air

3.2.1. Selection of treatment techniques

3.2.2. Individual waste gas treatment techniques

3.2.2.1. Recovery/abatement techniques for both organic and inorganic compounds

3.2.2.2. Abatement techniques for both organic and inorganic compounds

3.2.2.3. Recovery/abatement techniques for dust

3.2.2.4. Recovery/abatement techniques for inorganic compounds

3.2.3. Combination of waste gas treatment techniques

3.3 Techniques to reduce channelled emissions to air for specific products/processes (if

needed, e.g. sulphuric acid production)

4. Best Available Techniques (BAT) conclusions for Common Waste Gas Treatment in the

Chemical Sector

Scope

General considerations

Definitions

4.1. Generic BAT conclusions

4.1.1. Monitoring

4.1.2. Emissions to air

4.2. Product/Process-specific BAT conclusions (if needed, e.g. sulphuric acid production)

4.3. Description of waste gas treatment techniques

5. Emerging techniques

6. Concluding remarks and recommendations for future work

References

Glossary

Annexes

Proposal 14: The EIPPCB proposes to use the structure (and contents) shown above for the drawing

up the WGC BREF.

TWG members are asked to provide their feedback on the proposed WGC BREF structure by filling

in the corresponding cells in Document 3.


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3 KEY ENVIRONMENTAL ISSUES (KEIs) FOR THE WGC BREF

3.1 Overview

The so-called focused approach and the front-loading of the information exchange were presented to

stakeholders by the Commission at the IED Article 13 forum meeting in June 201317. More specifically for

the chemical BREFs, the principles of 'targeted efforts', 'generic BAT if possible', 'fewer illustrative

processes', 'transparency' and 'efficiency' were discussed at the IED Article 13 forum meetings in 201418. The

Commission stressed the importance of adopting the front-loading of information to identify KEIs and to

define suitably targeted data collection priorities and procedures.

At the forum meeting in 201519, the Commission presented criteria for defining KEIs at the earliest possible

stage of the information exchange for drawing up/reviewing a BREF:

criterion 1: environmental relevance of pollution caused by the activity or process, i.e. whether it

may cause an environmental problem;

criterion 2: significance of activity (number of installations, geographical spread, contribution to

total (industrial) emissions in the EU);

criterion 3: potential of BREF review for identifying new or additional techniques that would

further significantly reduce pollution;

criterion 4: potential of BREF review to set BAT-AELs that would significantly improve the level

of environmental protection compared to current emission levels.

Based on the information currently available (see Sections 3.2, 3.3, and 3.4), it seems feasible to assess

criteria 1 and 2 before and during the WGC kick-off meeting, while the assessment of criteria 3 and 4 is

likely to be more difficult, as the necessary information might only become available during the information

collection.

The EIPPCB considers that two major issues need to be addressed when selecting the KEIs for emissions to

air from the chemical industry: The first one is of a qualitative nature and concerns the identification of

relevant substances (see Section 3.3), while the second one is of a quantitative nature and concerns the

question of when the emission mass flow rate is large enough to be considered relevant (see Section 3.4).

17 IED Article 13 forum meeting of 6 June 2013, https://circabc.europa.eu/w/browse/77c81228-4492-4348-9b3f-299ee5ecca93. 18 IED Article 13 forum meetings of 24 September 2014 and 4 December 2014, https://circabc.europa.eu/w/browse/aa59671e-9115-4eed-af1d-

3eab251befa8, https://circabc.europa.eu/w/browse/84b358a5-eda0-4812-8247-3a7eb02af577, and

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=119185. 19 IED Article 13 forum meeting of 19 October 2015, https://circabc.europa.eu/w/browse/33cff69c-bfd0-49e7-8f19-f75a9e062745 and


https://circabc.europa.eu/w/browse/77c81228-4492-4348-9b3f-299ee5ecca93

https://circabc.europa.eu/w/browse/aa59671e-9115-4eed-af1d-3eab251befa8

https://circabc.europa.eu/w/browse/aa59671e-9115-4eed-af1d-3eab251befa8

https://circabc.europa.eu/w/browse/84b358a5-eda0-4812-8247-3a7eb02af577


https://circabc.europa.eu/w/browse/33cff69c-bfd0-49e7-8f19-f75a9e062745



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3.2 Initial proposals from the United Kingdom, CEFIC, Germany, and VCI

3.2.1 Overview

During 2016, the EIPPCB received information and suggestions from the United Kingdom, CEFIC,

Germany, and VCI for the scope and the KEIs of the WGC BREF. They also made more general proposals

regarding the content and the process for the drawing up of the WGC BREF. The information received has

been useful in developing this call for initial positions and the EIPPCB is grateful for these contributions as

part of the 'front-loading' approach.

3.2.2 Initial proposals from the United Kingdom

In May 2016, the United Kingdom wrote to the IED Article 13 forum with some suggestions for KEIs to be

included in the scope of the WGC BREF20. Six priority pollutants / pollutant groups were proposed for

inclusion:

(i) SOX – oxides of sulphur;

(ii) NOX – oxides of nitrogen;

(iii) Dust – particulate matter;

(iv) Halogens and their compounds;

(v) NH3 – ammonia;

(vi) VOCs – volatile organic compounds.

From the paper, it was not entirely clear whether 'halogens and their compounds' included organohalogen

compounds and whether 'VOCs – volatile organic compounds' exclusively referred to the sum parameter

TVOC or whether it would also encompass individual organic compounds. Nevertheless, the information

'Halogens and VOCs are key pollutants listed under the Stockholm Convention and are reported to

competent authorities as carcinogenic and/or teratogenic substances released from chemical installations'

included in a footnote of the UK paper suggested that some individual organic compounds are also regarded

as priority pollutants by the UK.

In addition, the United Kingdom suggested that:

for SOX, NOX and dust, the information exchange should differentiate between 'combustion' and

'process' sources;

the BAT-AELs should only apply when a threshold emission is reached, e.g. 'The BAT-AEL only

applies if the emission exceeds x t/yr.'

3.2.3 Initial proposals from CEFIC

In July 2016, a delegation from CEFIC met the EIPPCB in Seville for a brainstorming session to discuss the

possible approaches for the scope of the WGC BREF and the selection of KEIs21. During that meeting,

CEFIC provided information on:

the top ten pollutants of the chemical industry – compared with all industrial sectors in Europe;

pollutants for which BAT-AELs have been already set in five of the chemical BREFs;

20 BATIS Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 01 Chemical strategy and work programme > 11 UK -

Non-paper on WGC BREF 2016-05-25

http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showPost&forumID=119185&postID=119194&readPost. 21 BATIS Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 02 Brainstorming meeting EIPPCB - CEFIC on 6/7 July

2016 > 03 CEFIC presentation. http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showPost&forumID=119195&postID=119279&readPost.












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the responses to an internal CEFIC questionnaire on which compounds are abated in the chemical

sector.

On this basis, CEFIC proposed that the WGC BREF should cover six pollutants / pollutant groups:

(i) SOX;

(ii) NOX;

(iii) Dust;

(iv) Halogen (compounds);

(v) NH3;

(vi) (T)VOCs.

CEFIC also proposed that other substances (e.g. SVHCs, CMR substances) should not be included in the

scope of the WGC BREF because:

in many cases they are only relevant for specific sectors of the chemical industry;

they will need very specific abatement techniques (based on physical and chemical properties);

they are covered by national regulations; and

they are covered by other regulations (e.g. REACH).

Finally, CEFIC also suggested focusing the drawing up of the WGC BREF on key abatement techniques and

on relevant emission sources (i.e. where the load exceeds a certain threshold).

3.2.4 Information and initial proposals from Germany

In October 2016, Ökopol produced a report for the German Federal Environment Agency (UBA) entitled

'Definition of best available techniques (BAT) in Europe: BAT for air emission reduction in the chemical

industry sector in Germany'22. It is based on 550 monitoring reports – corresponding to approximately one in

four of the approximately 2 000 chemical installations in Germany. The report analyses 2 972 measurements

from 1 209 emission sources in the German chemical industry that were mostly carried out in the period from

2012 to 2015. The focus of the project was on periodic monitoring of emissions to air because these

monitoring reports include contextual information, such as on the process and the waste gas treatment system

used, and major substances involved. No information from continuous measurements was compiled and

assessed as part of this project.

The project revealed the following potential KEIs for the chemical sector.

Parameters

Groups of

substances

Dust, TOC, NOX, SO2, PCDD/Fs, other CMR substances, non-CMR halogenated organic

compounds, more harmful organic substances and metals (as three classes of metals, based

on volatility and toxicity - 'PM Class I' (mercury, thallium), 'PM Class II' (lead, cobalt,

nickel, selenium, tellurium) and 'PM Class III' (antimony, chromium, copper, manganese,

vanadium, tin))

Single

substances

NH3, methanol, acetic acid, ethylene oxide, propylene oxide, formaldehyde, HCl, HF, HBr,

Cl2, chloromethane, toluene, benzene, VCM, phenol, dichloromethane

The report includes a table of the substances or groups of substances most frequently measured. It shows that

the number of installations measuring a specific pollutant is much greater than the number of installations

reporting that pollutant to the E-PRTR. For example, the report included hydrogen chloride measurements

for 177 installations whereas only 15 installations in Germany reported it to the E-PRTR. This is probably

due to the reporting thresholds of the E-PRTR regulation.

22 BATIS Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 04 UBA study on definition of best available techniques

(BAT) for WGC, http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=120253.








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The report suggests that emission concentration values should always be linked with the mass flow of the

emission. Elevated emission concentrations may have a negligible environmental impact if they are linked

with small waste gas volumes, resulting in low mass flows.

Finally, the report presents many graphs on emission levels that can generally be achieved when using

certain abatement techniques (e.g. for dust in the case of fabric filters and wet scrubbers or for TVOC in the

case of thermal oxidisers and wet scrubbers).

3.2.5 Information and initial proposals from VCI

In December 2016, the German chemical industry association VCI presented the summary of a study similar

to the Ökopol study (see Section 3.2.4). The VCI study23 was based on the mandatory emission declaration

data of the German chemical industry from 2008 to 2012, whereas the Ökopol study had used periodic

monitoring data from inspection reports. The VCI study dataset covered emissions from 500 to 600 plants

which represent about 35 % of the German chemical plants and nearly 7 300 emission sources.

The VCI study shows that, for some substances, most of the annual emissions come from a small number of

emission points that have large volume flow rates. It also shows that a significant proportion of emission

points have a low volume flow rate and that in total these contribute only marginally to the overall annual

emissions. Therefore, VCI suggests limiting the data collection by setting emission thresholds.

The VCI study also shows that installations that were operated less than 500 hours per year tend to show

higher emission concentrations and higher mass flows. However, their contribution to the total annual

releases is relatively minor because they only operate for a short period of time. Therefore, VCI suggests that

operation time should be taken into account.

3.2.6 EIPPCB proposal and TWG views on initial proposals from the United Kingdom, CEFIC, Germany and VCI

The United Kingdom, CEFIC, Germany and VCI have each provided initial proposals on the substances that

should, and should not, be selected as KEIs in the WGC BREF.

Proposal 15: The EIPPCB proposes to include as KEIs five of the substances/groups of substances that

were commonly proposed by the United Kingdom, CEFIC, Germany and VCI, namely: SOX, NOX,

dust, NH3 and TVOC. As halogen compounds were not clearly defined in the proposals from the

United Kingdom and CEFIC (see Sections 3.2.2 and 3.2.3), no proposal is made at this stage.

Request 3: TWG members are asked to provide their views on the KEIs proposed by the United

Kingdom, CEFIC, Germany and VCI, by filling in the corresponding cells in Document 3.

23 BATIS > Forums > Waste Gas Treatment in the Chemical Sector > 01 Preparatory work > 06 CEFIC/VCI - Data assessment of the current

emission situation in Germany, http://eippcb.jrc.ec.europa.eu/batis/console/forumIndex.jsp?fuseAction=forum_showForum&forumID=120604.








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3.3 Identification of relevant substances

3.3.1 Overview

Criterion 1 for identifying KEIs (i.e. environmental relevance of the pollution as described in Section 3.1)

could be assessed by reviewing the pollutants that are listed or addressed in existing legislation including the

IED and the current chemical BREFs. Moreover, the European Pollutant Release and Transfer Register (E-

PRTR) provides quantitative information on the number of chemical installations and their annual emissions

of certain substances. These data could be used to assess criterion 2 for identifying KEIs (i.e. significance of

the activity as described in Section 3.1).

3.3.2 Substances referred to in the IED and the current chemical BREFs

The list of polluting substances in Annex II to the IED is largely a list of groups of substances rather than

single substances. These are considered here as potential KEIs for emissions to air:

1. Sulphur dioxide and other sulphur compounds

2. Oxides of nitrogen and other nitrogen compounds

3. Carbon monoxide

4. Volatile organic compounds

5. Metals and their compounds

6. Dust including fine particulate matter

7. Asbestos (suspended particulates, fibres)

8. Chlorine and its compounds

9. Fluorine and its compounds

10. Arsenic and its compounds

11. Cyanides

12. Substances and mixtures which have been proved to possess carcinogenic or mutagenic properties or

properties which may affect reproduction via the air

13. Polychlorinated dibenzodioxins and polychlorinated dibenzofurans.

The main air pollutants from chemical processes and energy supply that are summarised in Chapter 1.4.3 of

the CWW BREF are also based on groups of substances that are considered here as potential KEIs4:

carbon dioxide (CO2);

sulphur oxides (SO2, SO3) and other sulphur compounds (hydrogen sulphide (H2S), carbon

disulphide (CS2), carbonyl sulphide (COS));

nitrogen oxides (NOX, N2O) and other nitrogen compounds (NH3, HCN);

halogens and their compounds (Cl2, Br2, HF, HCl, HBr);

incomplete combustion compounds, such as CO and CXHY;

volatile organic compounds (VOCs) and organosilicon compounds;

particulate matter (such as dust, soot, alkali metals and heavy metals).

Table 3.1 gives an overview of the pollutants for which one or more BAT-AELs for emissions to air have

been set in the chemical BREFs.


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Table 3.1: BAT-AELs for emissions to air in the chemical BREFs

Pollutant Chemical BREFs

CAK LVIC-AAF LVIC-S LVOC OFC POL SIC

Ammonia (NH3) X X X X

Benzene

X

Carbon dioxide (CO2) X

X

Carbon disulphide (CS2)

X

X (1)

Carbon monoxide (CO) X X

Carbon tetrachloride (CCl4) X

Chlorine (Cl2) X X X X

Dust

X X

X X X

EDC

X

Formaldehyde (CH2O) X

Hydrogen bromide (HBr)

X

Hydrogen chloride (HCl)

X X X X

X

Hydrogen cyanide (HCN)

X

X

Hydrogen fluoride (HF)

X (2) X

Hydrogen sulphide (H2S) X X (

1)

Nitrous oxide (N2O)

X

Nitrogen oxides (NOX)

X X X X X X

PCDD/Fs

X

Phosphate X


X X

X X

TVOC

X X X X

VCM

X

X

(1) The BAT-AEL is expressed as sulphur.

(2) For the production of inorganic phosphates, the BAT-AELs are expressed as fluorine.

Source: Chemical BREFs as of December 2016 (including the BAT conclusions of the revised LVOC BREF as agreed at the final

TWG meeting in April 2016).

3.3.3 Substances with European Air Quality Standards

In order to protect human health and the environment, Directives 2004/107/EC24 and 2008/50/EC25 set

ambient air quality standards (e.g. as limit values, target values, or long-term objectives) for a number of

substances:

arsenic (As);

benzene;

cadmium (Cd);

carbon monoxide (CO);

lead (Pb);

nickel (Ni);

nitrogen oxides (NOX);

24 Directive 2004/107/EC of the European Parliament and of the Council of 15 December 2004 relating to arsenic, cadmium, mercury, nickel and

polycyclic aromatic hydrocarbons in ambient air, Official Journal of the European Union, L 23, 26.1.2005, p. 3-16, http://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX%3A32004L0107. 25 Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe, Official

Journal of the European Union, L 152, 11.6.2008, p. 1-44, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008L0050.





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ozone;

PM2.5;

PM10;

polycyclic aromatic hydrocarbons;

sulphur dioxide (SO2).

All of the aforementioned substances are emitted by the chemical industry, except for ozone which is a

secondary pollutant formed by the sunlight-induced reaction of hydrocarbons and nitrogen oxides in air.

3.3.4 Substances contained in the E-PRTR

The European Pollutant Release and Transfer Register (E-PRTR)26

is the Europe-wide register that provides

easily accessible environmental emission data from industrial facilities in European Union Member States

(except Croatia) as well as in Iceland, Liechtenstein, Norway, Serbia and Switzerland. The EPRTR data can

be used to assess criterion 1 (environmental relevance) and criterion 2 (significance of the activity) to

identify KEIs for the WGC BREF. The emissions of individual substances and groups of substances are

presented in seven different categories: chlorinated organic substances, greenhouse gases, heavy metals,

inorganic substances, other gases, other organic substances, and pesticides. Article 5 in combination with

Annex II to the E-PRTR regulation27 sets thresholds for the reporting of each pollutant or group of pollutants

(see Table 3.2).

Table 3.2: A selection of the reporting thresholds set in the E-PRTR

Pollutant

Threshold for reporting annual

releases to air

(kg/year)

Ammonia (NH3) 10 000

Dichloromethane (CH2Cl2) 1 000

Lead and compounds (as Pb) 200

Nitrogen oxides (NOX/NO2) 100 000

Non-methane volatile organic

compounds (NMVOC) 100 000

Sulphur oxides (SOX/SO2) 150 000

Tetrachloromethane (CCl4) 100

The EIPPCB has collected data from the E-PRTR28. In 2014, 2 777 chemical installations reported data on a

total of 41 pollutants for releases to air. The number of pollutants reported in the E-PRTR is higher than the

number of pollutants for which BAT-AELs have been set in the chemical BREFs (see Section 3.3.2).

In order to assess the significance of the activity, the following criteria could be used:

absolute number of chemical installations reporting emissions of a certain pollutant (see Figure 3.1);

absolute quantity of the pollutant emitted by all chemical installations (see Figure 3.2);

share of the chemical installations reporting emissions of a certain pollutant in the total number of

industrial installations reporting emissions of that pollutant (see Figure 3.3);

share of the pollutant emitted by all chemical installations in the total quantity emitted by all

industrial installations (see Figure 3.4).

26 http://prtr.ec.europa.eu/#/home. 27 Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the establishment of a European

Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC, Official Journal of the European Union, L

33, 4.2.2006, p. 1–17, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32006R0166. 28 E-PRTR search parameters: EU-27; releases to air; all pollutant groups and pollutants; chemical Installations and all industry sectors.

http://prtr.ec.europa.eu/#/home

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32006R0166


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NB: Data refer to the EU-27 and 2014. Due to space restrictions, only the first 30 out of the 41 reported pollutants that are emitted

from chemical installations are shown.

Source: EIPPCB based on data from E-PRTR.

Figure 3.1: Absolute number of chemical installations reporting emissions of a certain pollutant in the E-PRTR

Substances could be considered candidate KEIs if there are chemical installations reporting those substances

in the E-PRTR. Figure 3.1 shows that there are 16 substances for which there are more than 20 chemical

installations reporting emissions to the E-PRTR. The number of installations identified by this approach

needs to be treated with caution because it is strongly influenced by the E-PRTR emission reporting

thresholds. For example, there may be substances which are emitted by a large number of chemical

installations but the emissions are just below the E-PRTR reporting threshold so those installations will not

appear in the E-PRTR data.


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Figure 3.2: Absolute quantity of the pollutant emitted by all chemical installations in the E-PRTR

Substances could be considered candidate KEIs if there are chemical installations reporting those substances

in the E-PRTR. Figure 3.2 shows a wide variation in the quantities of different substances emitted by

chemical installations that are reported in the E-PRTR. This is a reflection of the wide variation in the E-

PRTR reporting thresholds for different substances (see Table 3.2).


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Figure 3.3: Share of the chemical installations reporting emissions of a certain pollutant in the total number of

industrial installations reporting emissions of that pollutant in the E-PRTR

Substances could be considered candidate KEIs when there is a high share of chemical installations reporting

that substance in the E-PRTR compared to all other industrial installations. The left-hand side of Figure 3.3

shows that there are 7 substances for which more than 50 % of the installations reporting to the E-PRTR

were chemical installations and 18 substances for which more than 10 % of the installations reporting to the

E-PRTR were chemical installations.


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Figure 3.4: Share of the pollutant emitted by all chemical installations in the total quantity emitted by all

industrial installations in the E-PRTR

Substances could be considered candidate KEIs when a high share of emissions reported in the E-PRTR

originate from chemical installations compared to all other industrial installations. The left-hand side of

Figure 3.4 shows that there are 13 substances for which more than 35 % of the emissions reported in the E-

PRTR originate from chemical installations and 20 substances for which more than 10 % of the emissions

reported in the E-PRTR originate from chemical installations.

The right-hand side of Figure 3.4 shows the substances whose emissions from chemical installations

represent only a small percentage of the total industrial emissions. The EIPPCB is of the view that this need

not be a reason for automatically rejecting those substances as KEIs in the WGC BREF because they may

qualify as KEIs for other reasons. For example, dust, SOX and NOX might be included as KEIs based on the

total mass of substance emitted (as shown in Figure 3.2), or because they are substances that are subject to

European ambient air quality standards.

The EIPPCB is of the view that the relevance and significance of pollutants for their consideration as KEIs

could be assessed using the E-PRTR, but it should not be exclusively based on these data because the E-

PRTR only covers a limited number of substances and only contains data from installations whose emissions

of a substance exceed an annual threshold.

3.3.5 TWG views on substances included in the current chemical BREFs, European ambient air quality standards and the E-PRTR

Request 4: TWG members are asked to provide their views on which of the substances included in the

current chemical BREFs, European ambient air quality standards and the E-PRTR should be selected

as KEIs for the WGC BREF, by filling in the corresponding cells in Document 3. A rationale should be

provided to support each proposed substance.


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3.3.6 Substances for which industrial emissions are (partly) covered by legislation other than the IED

The IED is not the only European legislation that aims to reduce the emissions of substances from industrial

installations. Each candidate KEI substance can be assessed by considering the effectiveness of other

legislation which may be sufficiently effective that setting BAT-AELs under the IED will not result in a

significant reduction of emissions. Consequently, there would be little or no benefit in selecting that

substance as a KEI for the WGC BREF.

Such other legislation often applies to only a few specific substances and in some cases it aims to prevent

emissions by completely phasing out the use of those substances. Examples of other legislation and the

substances they cover include the following:

The EU emissions trading system29 which covers emissions of the greenhouse gases carbon dioxide

and nitrous oxide (N2O). (Note: the EU ETS does not cover all emissions of these substances from

IED chemical installations).

Regulation (EU) No 517/201430 which covers emissions to air and the placing on the market of

fluorinated greenhouse gases such as hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and

sulphur hexafluoride.

Regulation (EC) No 1005/200931 which covers the production, placing on the market, and use of

substances that deplete the ozone layer: chlorofluorocarbons (CFCs), halons, carbon tetrachloride

(CCl4), 1,1,1-trichloroethane and hydrochlorofluorocarbons (HCFCs). (Note: When ozone-depleting

substances are used as feedstock or are generated as side products, they are not covered by this

regulation).

Proposal 16: The EIPPCB proposes to exclude as KEIs the substances/groups of substances whose

emissions are regulated by the EU emissions trading system, Regulation (EU) No 517/2014 on

fluorinated greenhouse gases and Regulation (EC) No 1005/2009 on ozone-depleting substances.

Request 5: TWG members are asked to provide their views on which substances' emissions are

controlled by other legislation and so should not be selected as KEIs in the WGC BREF, by filling in

the corresponding cells in Document 3. A rationale should be provided to support each proposed

substance.

29 Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission

allowance trading within the Community and amending Council Directive 96/61/EC, Official Journal of the European Union, L 275, 25.10.2003, p. 32–46, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32003L0087.

30 Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing

Regulation (EC) No 842/2006, Official Journal of the European Union, L 150, 20.5.2014, p. 195–230, http://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=celex%3A32014R0517. 31 Regulation (EC) No 1005/2009 of the European Parliament and the European Council of 16 September 2009 on substances that deplete the ozone

layer, Official Journal of the European Union, L 286, 31.10.2009, p. 1–30, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1005.


http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014R0517

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014R0517

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1005

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1005


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3.4 Identification of relevant mass flows

The chemical industry is covered by Section 4 of Annex I to the IED. The list presented in Section 4 refers to

the production of chemicals which it defines as '… the production on an industrial scale by chemical or

biological processing of substances or groups of substances …'. This definition captures all chemical

manufacturing installations irrespective of size, except for those carrying out research and development

activities that are excluded from the scope of the IED by virtue of Article 2 of the IED (which will usually be

very small-scale activities). In this respect, the chemical industry descriptions are significantly different from

other IED industry sectors where the activity descriptions only cover large installations. In some cases, the

other sector descriptions have a numerical capacity threshold (e.g. combustion plants with a total rated

thermal input of 50 MW or more; or surface treatment of metals and plastic where the volume of the

treatment vats exceeds 30 m3). In other cases, the IED description itself covers per se only large installations

that have significant emissions, e.g. integrated steelworks or oil refineries.

There are many installations in the chemical sector that are likely to have small emissions of substances to

air, particularly in the small-scale production of speciality chemicals. Excluding minor sources of channelled

emissions to air from the data collection would be in line with applying criterion 2 for identifying KEIs. The

task of data collection and analysis for the WGC BREF could be reduced by setting a numerical limit (e.g. in

kg/year or g/hr) below which emissions of a substance, or group of substances, would not be considered

relevant for the purpose of drawing up the WGC BREF. A similar approach is already widely used in

environmental legislation, for example in the general binding rules for industrial emissions in France,

Germany, and Italy which specify emission limit values that only apply when the emissions exceed certain

hourly thresholds and also in the E-PRTR which only requires the reporting of emissions that exceed a

certain annual threshold.

Proposal 17: The EIPPCB proposes to specify emission thresholds for each KEI to avoid collecting

data from minor emission sources.

The emission thresholds used for the data collection should be:

for unabated emissions and for single emission sources, not for the installation as a whole;

high enough to exclude trivial emissions that have little or no environmental impact; however, they

should be low enough to ensure that possible emission thresholds used in the BAT

conclusions/BAT-AELs can be set that are within the range of the data that are collected.

Request 6: TWG members are asked to provide their views on the emission thresholds that should be

used for the data collection, for each substance proposed as a KEI. A rationale should be provided to

support each proposed emission threshold.


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3.5 Summary of the EIPPCB proposals and requests to the TWG on the selection of KEIs for the drawing up of the WGC BREF

Based on the information given above, and to ensure that the data collection is manageable, the EIPPCB

proposes the following elements for the selection of KEIs for the WGC BREF:

Proposal 15: The EIPPCB proposes to include as KEIs five of the substances/groups of substances

that were commonly proposed by the United Kingdom, CEFIC, Germany and VCI, namely: SOX,

NOX, dust, NH3 and TVOC (see Section 3.2.6).

Proposal 16: The EIPPCB proposes to exclude as KEIs the substances/groups of substances whose

emissions are regulated by the EU emissions trading system, Regulation (EU) No 517/2014 on

fluorinated greenhouse gases and Regulation (EC) No 1005/2009 on ozone-depleting substances (see

Section 3.3.6).

Proposal 17: The EIPPCB proposes to specify emission thresholds for each KEI to avoid collecting

data from minor emission sources (see Section 3.4).

Requests 4, 5, and 6: TWG members are asked to provide their views on the substances that should and

should not be selected as KEIs, based on the following information:

Request 3: The KEIs proposed by the United Kingdom, CEFIC, Germany and VCI (see Proposal 15

and Section 3.2.6).

Request 4: The substances included in the current chemical BREFs, European ambient air quality

standards and the E-PRTR (see Section 3.3.5).

Request 5: The substances whose emissions are regulated by other legislation (see Proposal 16 and

Section 3.3.6).

Request 6: TWG members are asked to provide their views on the emission thresholds that should be used

for the data collection, for each substance proposed as a KEI.

TWG members are asked to provide their feedback on the proposals 15 to 17 and the requests 4 to 7,

including a supporting rationale, by filling in the corresponding cells in Document 3 (note that this is

to be done via a single table on the worksheet '3. KEI').


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4 DATA COLLECTION FOR THE WGC BREF

4.1 Overview

As for any other BREF, the data and information collection for the drawing up of the WGC BREF will

follow the provisions of Section 5 of the BREF Guidance2.

The EU chemical industry is one of the biggest industrial sectors in Europe32. A report produced by Amec

Foster Wheeler in 2016 shows the breakdown of IED installations in the chemical sector according to

Sections 4.1 to 4.6 of Annex I to the IED.

Source: Amec Foster Wheeler Environment & Infrastructure UK Ltd March 2016, Assessment and Summary of the

Member States' Implementation Reports for the IED, IPPC Directive, SED and WID - IPPC Directive Final Report,

https://circabc.europa.eu/w/browse/7976d5b7-c037-43e6-9406-e898006396d0.

Figure 4.1: Breakdown of IED installations in the chemical sector

Due to the size and heterogeneity of this industrial sector, the EIPPCB proposes to focus the data and

information collection on relevant emissions to air and on techniques to consider in the determination of

BAT (i.e. 'BAT candidates'). In order to assess the reported emission levels, contextual information will be

collected on the following (see Section 5.4.4 of the BREF Guidance2):

the origin of the waste gas stream (i.e. sources);

the characteristics of the untreated waste gas stream (e.g. flow rate, load, presence of substances that

may interfere with the abatement technique);

the waste gas treatment technologies and the way they are designed, maintained, and operated;

the abatement efficiency of those waste gas treatment technologies;

the relevant reference conditions (e.g. oxygen content, humidity, temperature, flow rate);

the monitoring (e.g. analytical methods, frequency, sampling period, averaging period; see

Section 4.4);

32 Eurostat Statistical books – Environmental statistics and accounts in Europe – 2010 Edition,

http://ec.europa.eu/eurostat/documents/3217494/5723037/KS-32-10-283-EN.PDF/22a4889d-e6c9-4583-8d17-fb5104e7eec0.

3140 1056

151 116

540

82

Production of organic chemicals

Production of inorganic chemicals

Production of phosphorous-, nitrogen- or potassium-based fertilisers [simple or compound fertilisers]

Production of plant protection products or of biocides

Production of pharmaceutical products including intermediates

Production of explosives

https://circabc.europa.eu/w/browse/7976d5b7-c037-43e6-9406-e898006396d0

http://ec.europa.eu/eurostat/documents/3217494/5723037/KS-32-10-283-EN.PDF/22a4889d-e6c9-4583-8d17-fb5104e7eec0


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the plant conditions (e.g. normal or other than normal operating conditions, percentage of capacity at

which plant is operating, number of operating hours per year).

In general, all data and information submitted by TWG members will be directly posted into BATIS. General

information can be provided in whatever format it is available. For information on 'BAT candidates' and

emerging techniques, in particular when these are not yet described in the CWW BREF, TWG members

should use the standard 10-heading format laid down in the BREF Guidance2. For plant-specific information,

a dedicated questionnaire template will be developed involving the whole WGC TWG (see Section 4.5).

4.2 NOX emission data collected during the LVOC BREF review

The final TWG meeting on the review of the LVOC BREF, held in April 2016, recommended that the

information on NOX emissions to air from the use of thermal oxidisers, which was collected for the review of

the LVOC BREF, should be used when drawing up the WGC BREF5.

The EIPPCB is of the view that the information collected for the LVOC BREF was not always complete,

especially regarding reference conditions (e.g. O2 content). Moreover, since the information was collected

for the years 2010 to 2012, there may be more up-to-date information available. Therefore, the information

from the LVOC plants concerned should be collected again to ensure that the TWG has a consistent set of

recent data.

Proposal 18: The EIPPCB proposes not to use the data on NOX emissions from thermal oxidisers that

were collected during the LVOC BREF review and instead to collect a new set of data.

4.3 Environmental performance levels

4.3.1 Overview

According to the BREF Guidance, the collected data will be used to derive 'environmental performance

levels associated with BAT' (i.e. the so-called BAT-AEPLs, which include BAT-AELs), where there is a

sound basis for doing so (see Section 3.3. of the BREF Guidance2). The TWG should therefore decide at an

early stage of the BREF process for which KEIs information should be collected (see Section 3) and which

units and averaging periods should be used. This will enable the questionnaire template(s) (see Section 4.5 to

be tailored to provide the necessary data for the assessment of techniques (i.e. 'BAT candidates') and for the

appropriate derivation of BAT conclusions including the relevant BAT-AEPLs (including BAT-AELs).

4.3.2 Units and averaging periods

As a consequence of adopting a generic approach, the WGC BREF will focus on recovery and abatement

techniques, rather than on process-integrated techniques (see Section 1.3.1). Therefore, BAT-AELs will

necessarily need to be expressed in concentrations, and not in specific loads. Alternatively, the performance

of abatement techniques could be described by defining abatement efficiencies (which would be BAT-

AEPLs). Combinations of BAT-AELs expressed in concentrations and BAT-AEPLs expressed as abatement

efficiencies also seem possible, as was decided for the parameters COD/TOC and TN/Ninorg when setting

BAT-AELs for emissions to water in the CWW BREF4.

However, in the case of sulphuric acid production, BAT-AEPLs might need to refer to conversion

efficiencies, potentially in combination with BAT-AELs expressed in concentrations (see Section 0).

Deviations from the general approach to express BAT-AEPLs in concentrations and/or abatement

efficiencies might also be appropriate in the case of other specific products/processes, if the emissions

depend significantly on process-integrated techniques.


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Proposal 19: The EIPPCB proposes to generally express BAT-AEPLs for emissions to air in

concentrations, abatement efficiencies, or in combinations thereof.

The monitoring of emissions from chemical installations is often carried out on a periodic basis and ELVs

often refer to short-term averages. Therefore, the BAT-AELs for emissions to air in the CAK and LVOC

BREFs which are expressed in concentrations refer to short-term averages (i.e. as an average over the

sampling period in the case of periodic measurements or as a daily average in the case of continuous

measurement).

Proposal 20: The EIPPCB proposes to express BAT-AEPLs for emissions to air as short-term averages

(i.e. as an average over the sampling period in the case of periodic measurements or as a daily average

in the case of continuous measurement).

4.3.3 Grouping of substances and differentiation within groups of substances

The emissions to air from the chemical industry contain a significant number of individual inorganic

substances and a very large number of individual organic substances. In many cases, these can be considered

as groups of substances which present a similar environmental risk and require similar abatement techniques,

because they have similar toxicological, physical and/or chemical properties. The grouping of some

substances is a widespread practice and can be carried out in two ways:

A BAT-AEPL (or an ELV) is expressed for the sum of the concentrations of the individual

substances. Examples include NOX, SOX, and PCDD/Fs. Often this implies the use of factors that

take into account the properties of the individual substances (e.g. the molar mass in the case of NOX

and SOX, or the toxicity in the case of PCDD/Fs). In some cases, no factors are used (e.g. a BAT-

AEL for the sum of EDC and VCM was set in the LVOC BREF for the production of EDC/VCM,

see Section 1.2.4).

A BAT-AEL (or an ELV) is expressed as a surrogate parameter (i.e. sum parameter). Examples

include the parameters TVOC and dust.

The task of collecting data and setting BAT-AEPLs for the WGC BREF could be simplified by dealing with

groups of substances, rather than individual substances. This approach will be particularly appropriate when

an abatement technique is applicable to all of the individual substances in the group.

Proposal 21: The EIPPCB proposes to collect data and set BAT-AEPLs for groups of substances,

rather than individual substances, when it is possible and practicable to do so (e.g. for dust, NOX, SOX,

and TVOC).

In addition to the aforementioned examples, further groupings of individual substances could be

contemplated. For example, the United Kingdom and CEFIC proposed to consider halogens and their

compounds as KEIs (see Sections 3.2.2 and 3.2.3) while Germany suggested further groups including other

CMR substances, non-CMR halogenated organic compounds, more harmful organic substances and metals

(see Section 3.2.4). The proposals, however, did not specify if the data collection and setting of BAT-AEPLs

for these categories of substances could be simplified by grouping individual substances, either by summing

up the concentrations of the individual substances or by using surrogate parameters.

Request 7: TWG members are asked to provide their views on which substances, if any, could be

grouped together to simplify the data collection and the setting of BAT-AEPLs and how this could be

done. A rationale should be provided to support each proposed group of substances.


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On the other hand, some differentiation might be needed for certain groups of substances depending on their

toxicity. For example, more stringent BAT-AEPLs could be set for the surrogate parameters dust and TVOC,

if very toxic substances such as CMR substances are present in the waste gas. This has been the case for dust

emissions from lead oxide production, where a BAT-AEL of < 0.1–0.2 mg/Nm3 has been set in the LVIC-S

BREF10

. In this sense, Germany proposed to distinguish between three groups of particulate metal emissions

(see Section 3.2.4). A differentiation of dust emissions by particle size could also be contemplated. Other

examples can be found in the LVOC BREF, where the BAT-AELs for TVOC emissions to air from the

production of TDI/MDI and EDC/VCM are considerably lower than those set in other illustrative chapters.

Request 8: TWG members are asked to provide their views on whether and how BAT-AEPLs should

be differentiated for certain groups of substances due to their toxicity (e.g. for dust and TVOC). A

rationale should be provided to support each proposed differentiation.

4.4 Monitoring of emissions

The JRC Reference Report on Monitoring of Emissions to Air and Water from IED installations (ROM)33

summarises information on the monitoring of emissions to air and water from IED installations. It provides

practical guidance for the application of the BAT conclusions on monitoring in order to help competent

authorities to define monitoring requirements in the permits of IED installations. Moreover, the information

and recommendations provided by this document are intended to help the TWG to derive BAT conclusions

during the drawing up and review of BREFs. Chapter 3 of the ROM describes the use of standardised

monitoring methods, while Chapter 4 is dedicated to the monitoring of emissions to air including the

description of air pollutants and continuous/periodic measurement methods. Finally, Annex A.1 lists

European (EN) and international (ISO) standards as well as methods for the measurement of emissions to air

for parameters or substances, where these are available.

The hierarchy of standards in many adopted BAT conclusions on monitoring (including in the CAK and

CWW BAT conclusions) is: 'BAT is to monitor emissions to […] in accordance with EN standards. If EN

standards are not available, BAT is to use ISO, national or other international standards which ensure the

provision of data of an equivalent scientific quality.' This format was agreed on at the final TWG meeting for

the LVOC BREF as well.

During the plant-specific data collection via questionnaires, information on monitoring will be collected

including on:

the parameters monitored;

the monitoring standards used (EN, ISO, other standards);

the purpose of monitoring (e.g. compliance monitoring, operational control);

who carried out the monitoring (e.g. operator self-monitoring, regulatory authority);

monitoring frequencies (continuous, once every year, once every day, etc.);

units and averaging periods;

issues regulated by permit conditions, e.g. emission limit values (ELVs).

4.5 Questionnaire(s) for gathering plant-specific data and information

In order to be able to derive BAT-AEPLs (including BAT-AELs), it will be necessary to collect new and

updated, representative, reliable and plant-specific real-life data.

33 European Commission, JRC Reference Report on Monitoring of emissions to air and water from IED installations, Revised final draft, July 2016,




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Usually, a general questionnaire will be used. As the WGC BREF will focus on recovery and abatement

techniques, the general questionnaire will relate to individual emission sources and not to the installations as

a whole. This implies that several questionnaires could be submitted by the same installation, if it has several

relevant emissions sources.

Depending on the decisions taken by the TWG at the kick-off meeting, it might also be necessary to

exceptionally develop tailor-made questionnaires for a few specific products/process (e.g. for the production

of sulphuric acid, see Section 1.3.2).

The format and extent of the questionnaire(s) should ensure that the data and information submitted are

relevant to the determination of BAT and that all relevant contextual information necessary to evaluate and

compare the data is collected (see Section 4.1).

In order to ensure data comparability, the following criteria should be fulfilled:

Data should be obtained using a common methodology/approach.

Data should be clearly related to units, relevant reference conditions (e.g. O2 content in the case of

combustion), and averaging periods.

Data should be clearly related to applied sampling and monitoring standards. Information on the use

of EN/ISO or (other) monitoring standards will be part of the information requested and will be

further used in the determination of BAT, especially with respect to monitoring aspects.

Data should be expressed in a manner that fully relates the performance to the operating context,

distinguishing in particular normal operating conditions from other than normal operating conditions

(e.g. start-ups, shutdowns, malfunctions, incidents).

The TWG will contribute to the development of the questionnaire templates by providing proposals for

issues to cover and formats, as well as by commenting on draft templates using the BATIS platform.

The draft questionnaire templates may be tested on a small number of plants to provide a quality check

before the distribution of the final versions. To do this, it will be necessary to prepare in advance a list of

plants willing to participate in the plant-specific data collection via questionnaires (see Section 4.7).

The final questionnaire will be sent to and collected from operators, followed by a first quality check by the

TWG Member State representatives. This quality check by Member States (foreseen in Section 4.4.2 of

the BREF Guidance) is of paramount importance and we take this opportunity to stress it.

For each completed questionnaire from a plant located in his/her country, the corresponding TWG

Member State representative will specifically be asked to:

ensure the completeness, quality and consistency of the data;

check the validity of any confidentiality claims, (noting that data should only be considered

confidential in exceptional circumstances, see Section 4.6): if some data/information is claimed to be

confidential, the Member State representative extracts the confidential part of the questionnaire and

sends this separately to the EIPPCB by email together with a justification as to why the information

is indeed to be considered confidential;

upload non-confidential questionnaires directly onto BATIS.

A further quality check of the submitted data and information is the responsibility of all TWG members,

including the EIPPCB.

All TWG members will be encouraged to participate in the assessment of the submitted data and

information.


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Request 9: TWG members are asked to provide their views on the collection of data and information

via plant-specific questionnaires by filling in the corresponding cells in Document 3. The views

expressed should address:

the process for developing the questionnaire(s);

the content and format of the questionnaire(s);

the process for collecting data via the questionnaire(s);

the quality assurance of the collected data.

4.6 Confidentiality issues

BAT-AELs must be based on information that is available to the whole TWG. The review of the LVOC

BREF was complicated by the fact that many operators claimed that some of the provided data was

commercially confidential, in particular data on the process conditions and the production volumes, as well

as the consumption of energy and raw materials. The EIPPCB expects that confidential business information

and sensitive information under competition law will generally not be an issue for the WGC BREF because

the information exchange will focus on emission data that are in the public domain according to the Aarhus

Convention (see Section 5.3 of the BREF Guidance2). Some of the relevant contextual information (see

Section 4.1) might not necessarily be in the public domain, but experience from previous BREF reviews

shows that confidentiality should not be a major issue for the drawing up of the WGC BREF, as the focus is

on abatement techniques and emission levels.

Information on the actual production volumes, capital costs and running costs of the chemical production

processes should generally be excluded from the data collection, so that operators do not have to supply any

confidential data. This will allow all questionnaire responses to be posted directly onto BATIS, including the

names of the plants (though plant names will generally be anonymised in the BREF, except for example

plants in the chapter on 'Techniques to consider in the determination of BAT'). However, there may be some

confidential business information and sensitive information under competition law that is needed and useful

for drawing up the WGC BREF.

It is important to identify and discuss the type of potentially confidential data in advance of launching the

data collection, so that the questionnaire can be designed to minimise the collection of confidential data.

Proposal 22: The EIPPCB proposes to design the questionnaire(s) in a way that avoids requesting

confidential data so that all data provided by operators can be posted directly onto BATIS.

Request 10: TWG members are asked to provide examples of information that might be necessary for

the drawing up of the WGC BREF and that might also be considered confidential/sensitive

information.

4.7 Selection of plants/installations for the plant-specific data collection

The experience from other BREF reviews has shown that the drawing up of a list of plants that could take

part in the data collection via a questionnaire takes time, e.g. due to the need to send requests to operators,

waiting for responses, and finally selecting the most suitable plants. For this reason, and in the spirit of front-

loading the work, it is therefore recommended that TWG members start the process of selecting plants for

the data collection as early as possible with the aim of having a draft list available in time for the kick-off

meeting.

Each TWG member's organisation is therefore invited to propose a list of plants operating well-performing

waste gas treatment systems (including best performers) for the data collection via questionnaires. While


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there is no formal definition of a 'well-performing plant' in the work on BREFs, it is clear that this refers to

plants that are considered to reflect good environmental performances in one or more environmental aspects,

e.g. low pollutant emissions, low usage or high recovery/recycling of energy/water/material.

Due to the size of the chemical sector and the number of emission sources, it will not be feasible to collect

and analyse data from all sources. The challenge will thus be to select a representative sample of well-

performing plants.

Criteria for selecting plants for the plant-specific data collection include:

environmental performance – well performing waste gas treatment systems (including best

performers);

the use of 'BAT candidates';

production capacity – both small and large;

age – both newer and older;

processes – single and multi-product, continuous and batch;

geographical distribution – representative for all Member States that have plants in a given

subsector, especially when climatic conditions are relevant;

products/processes that might require a dedicated approach;

availability of data (including on data confidentiality considerations).

Request 11: TWG members are asked to propose plants/installations operating well-performing waste

gas treatment systems for the data collection by filling in the corresponding cells in Document 3.

4.8 Summary of the EIPPCB proposals and requests to the TWG on the data collection for the drawing up of the WGC BREF

Based on the information given above, the EIPPCB proposes the following elements for the data collection

for the WGC BREF:

Proposal 18: Not to use the data on NOX emissions from thermal oxidisers that were collected during

the LVOC BREF review and instead to collect a new set of data (see Section 4.2).

Proposal 19: To generally express BAT-AEPLs for emissions to air in concentrations, abatement

efficiencies, or in combinations thereof (see Section 4.3.2).

Proposal 20: To express BAT-AEPLs for emissions to air as short-term averages (i.e. as an average

over the sampling period in the case of periodic measurements or as a daily average in the case of

continuous measurement; see Section 4.3.2).

Proposal 21: To collect data and set BAT-AEPLs for groups of substances, rather than individual

substances, when it is possible and practicable to do so (e.g. for dust, NOX, SOX, and TVOC) (see

Section 4.3.3).

Proposal 22: To design the questionnaire(s) in a way that avoids requesting confidential data so that all

data provided by operators can be posted directly onto BATIS (see Section 4.6).

TWG members are asked to provide their feedback on the proposals for the data collection in the


Moreover, TWG members are asked to provide:

Request 7: Their views on which substances, if any, could be grouped together to simplify the data

collection and the setting of BAT-AEPLs and how this could be done. A rationale should be

provided to support each proposed group of substances (see Section 4.3.3).


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Request 8: Their views on whether and how BAT-AEPLs should be differentiated for certain groups

of substances due to their toxicity (e.g. for dust and TVOC). A rationale should be provided to

support each proposed differentiation (see Section 4.3.3).

Request 9: Their views on the collection of data and information via plant-specific questionnaires

including on the process for developing the questionnaire(s), the content and format of the

questionnaire(s), the process for collecting data via the questionnaire(s) and the quality assurance of

the data collected (see Section 4.5).

Request 10: Examples of information that might be necessary for the drawing up of the WGC BREF

and that at the same time might be considered confidential/sensitive information (see Section 4.6).

Request 11: Proposals for plants/installations operating well-performing waste gas treatment systems

for the data collection by filling in the corresponding cells in Document 3 (see Section 4.7).


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5 TECHNIQUES TO CONSIDER IN THE DETERMINATION OF BAT AND EMERGING TECHNIQUES

As a starting point, the EIPPCB proposes to review the information in Chapter 3 of the CWW BREF on

'Techniques to consider in the determination of BAT' (i.e. 'BAT candidates') and more particularly the

information in Section 3.5.1 on 'Individual waste gas treatment techniques'. Moreover, the information in

Section 5.2 of the CWW BREF on emerging techniques for waste gas treatment should also be reviewed.

The CWW BREF provides detailed information on individual waste gas treatment techniques, including:

technical descriptions;

abatement efficiencies and emission levels;

consumption levels;

applicability issues;

economics.

CEFIC has offered to provide information on the most relevant abatement techniques used within the

chemical industry (see Section 3.2.3). The German report referred to in Section 3.2.4 summarises the most

frequent types of waste gas treatment systems installed in chemical installations in Germany.

Request 12: TWG members are asked to evaluate the 'Techniques to consider in the determination of

BAT' and the 'Emerging techniques' in the current CWW BREF and to indicate:

any obsolete techniques, i.e. that are not (or no longer) used in the chemical sector;

which techniques are considered to be the most important;

which techniques require updating (and which part of the information e.g. description,

emission/consumption levels, applicability, economics);

what information can be provided;

any relevant technique that is missing ('BAT candidate' or emerging technique).

In order to facilitate the evaluation by the TWG, Table 3.149 'Overview of the waste gas treatment

techniques with respect to the pollutants to be abated' from page 335 of the CWW BREF has been copied

into Document 3.

TWG members are asked to provide their feedback by filling in the corresponding cells in the


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