A push for cleaner industrial production - EEB

A PUSH FOR CLEANER INDUSTRIAL PRODUCTION
The Environmental Safety Net
The Problem
Annexes V, VI, VII and VIII of the Industrial Emissions Directive integrate binding minimal emission
limit values (ELVs) for large combustion plants, waste incineration and co-incineration plants,
installations and activities using organic solvents and installations producing titanium dioxide.
Regulatory authorities can draw on the BATAEL in the BREF to set emission standards in the permit
that are stricter than these binding ELV, but they cannot be less strict 8 . These standards act as a
safety net to ensure that emission levels do not exceed a certain level.
Practice in permitting these types of installations has shown that the permit conditions are often
based directly on the binding ELVs, with no reference to the BATAEL in the BREF.
In some of the new Member States, authorities rely on the binding standards to guide their
permitting practice, as the case-by-case BAT-based permitting approach demands additional time,
expertise and a philosophy with which they are unfamiliar.
The Solution: A Safety Net extended to all IPPC sectors
The sectoral ELVs therefore represent a critical safety net, requiring a bottom line of environmental
performance below which standards cannot slip. It is therefore essential that the level at which ELVs
are set is strict enough to deliver a baseline of environmental protection.
Current practice, where standards in permits
often drawn directly from the binding
sectoral ELVs with no reference to BATAEL
in the BREF, have led to a disconnection
between levels of emissions and those
achievable using BAT.
Setting sectoral ELVs within the BAT range
will serve to ensure that permits deliver a
level of pollution control that is achievable
using techniques that are readily available
on the European market and that have
been successfully applied in commercially
operating installations.
The sectoral ELVs have been instrumental in driving
improvements in UK industry‘s environmental
performance, after the implementation of IPPC.
• Implementation of the Waste Incineration
Directive NOx ELV of 800 mg/Nm 3 drove
uptake of SNCR at Lafarge’s Hope Aberthaw
and Cauldron cement works and at Castle
Cement’s Ketton works
• Rugby cement replaced upgraded dust control
techniques to comply with Waste Incineration
Directive ELVs
• Implementation of the Large Combustion Plant
Directive forced UK power plants to retrofit
flue gas desulphurisation techniques or operate
at low loads to meet SO 2
emissions ELVs
8
the Dutch administrative court has made clear that sectoral ELVs are only a bottom line, competent authorities
have to refer to BATAEL in the BREF and take them into account. e.g. AB RvS 25 January 2006, 200409; AB
RvS 20 April 2005,200405315/1233/1
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