A push for cleaner industrial production - EEB

A PUSH FOR CLEANER INDUSTRIAL PRODUCTION
The Problem: Indiscriminate application of the Inherent Flexibility
Even as these key mechanisms will work to generate a level playing field for industrial operators, a
number of elements remain that serve to retain much of the flexibility inherent in IPPC.
Range:
The standards in the BREF, the BATAELs, are presented not as a single value
but as a range. In all cases, the range of BATAELs presented in the BREF accounts
for the variation expected from commercially operating installations that install
and operate BAT within different technological and environmental contexts. As
shown by the figures below, installations with different performances can be
accommodated by the BAT range.
Selection of BAT and ELV: Plant A (Spain)
Cost
BAT range
Selection of BAT and ELV: Plant B (Italy)
Cost
BAT range
Investment
Needed
Investment
Needed
Plant A
Plant B
Emission Reduction
Required
ELV
Current
Emission
Emission
Emission Reduction
Required
ELV
Current
Emission
Emission
Excerpt from case study of two aluminium plants operating according to BAT; ALCOA (Aluminium
Industry) EP Lunch Debate May 14th, 2008
Peaks:
Compliance:
Derogations:
BATAELs are presented as emission levels averaged over specific time periods
and are drawn from commercial installations operating under normal conditions.
Normal conditions inevitably include fluctuations in process factors such as input
quality, and as such the BATAELs already account for short term peaks in emissions
and are directly transferable to emission limit values in the permits.
Member States have full freedom to determine the regime under which an installation’s
compliance with permit conditions is assessed. Compliance regimes
frequently allow actual emissions to exceed the emission limit values in the
permit under certain circumstances and for specific time limits. These regimes
allow for some peaks, for instance under abnormal operating conditions, and so
provide flexibility to the operator.
Member States retain the flexibility to set permit standards that exceed the
standards in the BREF in exceptional cases based on an assessment of the
environmental and economic costs and benefits, and taking into account the
technical characteristics of the installation, its geographical location and the
local environmental conditions (Article 16.3).
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