A push for cleaner industrial production - EEB

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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 12
BAT-based binding ELVs will deliver an additional push for environmental innovation, and will ensure that the Directive is consistent in the signals sent to operators. Derogations to standards below these levels will not be possible and a bottom line of environmental performance will be assured. The following mechanisms will help to ensure that the sectoral ELVs contribute to achieving the long term objectives of the Thematic Strategy on Air Pollution and the Water Framework Directive: • The binding sectoral ELVs should be based on BAT and set within the range of the BATAELs in the BREF. This approach will ensure a coherent and consistent BAT-based framework for controlling industrial emissions to the environment. • Following the updating of a BREF, the minimum requirements should be adjusted to reflect scientific and technical progress within a 12-month period. This is essential to ensure that the minimum requirements reflect what is technically and economically feasible in commercially operating installations. • The safety net should be extended to cover all IPPC sectors. In extending the binding minimal requirements to cover all sectors, emission limit values may be supplemented by equivalent parameters of technical measures provided that an equivalent or higher level of environmental protection can be achieved. To deliver a baseline of protection to the environment and European citizens. • Measures designed to update or establish the binding minimum requirements should be adopted through comitology with scrutiny. The comitology procedure is much faster than co-decision, geared towards technical decision-making, and more able to rapidly respond to technological progress. • Stakeholders representing the public interests should be consulted by the Commission before the final decision regarding such measures is made. In order to make the decision making process open, transparent and increase the confidence of European citizens. 13
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Page 5 and 6: Contents Background to the Revision
Page 7 and 8: The Goalposts The proposed Directiv
Page 9 and 10: WATER The Water Framework Directive
Page 11 and 12: The Solutions The recast of the IPP
Page 13: The Solution: Playing Fair Accordin
Page 17 and 18: The Solution: Applying BAT(Example
Page 19 and 20: Potential Benefits The benefits of
Page 21 and 22: Co-Incinerating Waste The Problem:
Page 23 and 24: Potential Benefits Implementing SCR
Page 25 and 26: Sevilla Process and BREFs: The BREF
Page 27 and 28: The Solution: Baseline Reports The
Page 29 and 30: Source: Commission, 2007, “Report
Page 31 and 32: The Solution: A Differentiated Thre
Page 33 and 34: References AEAT, 2004, “Costs and
Page 35 and 36: Leibacher, U., Bellin, C., Linero,
Page 37 and 38: ENTEC 2008, Table 4.15 The five hig
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