The EC Integrated Pollution Prevention and Control (IPPC) Directive ...

194THE COKE OVEN MANAGERS’ASSOCIATIONDRIVING FORCES FOR COKE OVEN GAS DESULPHURISATION -IPPC (BREFS, UK SECTOR GUIDANCE) & OTHER LEGISLATIONByDr Paul Brooks, Group Environmental Manager, CorusThe EC Integrated Pollution Prevention and Control (IPPC)Directive is one of the main, if not the main, legislative driving forcesfor environmental improvement across the European Union. TheDirective was implemented in the UK via the Pollution Prevention &Control (PPC) Regulations in 2000. The previous UK regulatoryregime of Integrated Pollution Control (IPC) is being replaced by IPPCin a sector-by-sector phased manner in the period up to 2007. IPPCintroduces the concept of BAT (Best Available Techniques), which isbroadly the equivalent of BATNEEC and BPEO (Best AvailableTechniques Not Entailing Excessive Cost and the Best PracticableEnvironmental Option), which are terms which those who were/areregulated under IPC will be familiar with. Whilst there is a requirementfor specified processes (including iron & steel and coke ovens) to useBAT, permits, emission limit values and operating conditions will,importantly, continue to be site specific. It is worth dwelling on thedefinition of BAT. ‘Best’ means the most effective for achieving a highlevel of protection for the environment as a whole and is the equivalentof BPEO. ‘Available’ means developed to sufficient scale for use inthe relevant sector, under economically and technically viableconditions, taking into account costs and advantages. This means thatthe technique must be affordable in general for the sector as a wholeand the benefits must at least be in balance with the costs.‘Techniques’ includes both the technology and the way the technologyis used.BAT is determined at EU level by sector. BAT reference documents(known as BREFs) are being developed by the European Commissionin Seville, Spain, in response to a requirement in the IPPC Directive forthe exchange of information by member states and other stakeholders.These BREFs are developed by working groups comprising

DRIVING FORCES FOR COKE OVEN GAS DESULPHURISATION - IPPC(BREFS, UK SECTOR GUIDANCE) & OTHER LEGISLATION195representatives from member states, industry, environmental NGOs(non-governmental organisations) and to a lesser extent equipmentsuppliers. It is important to note, however, that whilst the BREFs are auseful source of information, they have no legal status except asguidance to be taken into account by member states when determiningpermits at the local level. Whilst achievable emission levels are quoted,these are not emission limit values and are not absolute standards to beenforced.The iron and steel BREF, which includes coke making, waspublished in March 2000 and is due for revision in 2004/2005.Desulphurisation of coke oven gas was considered a high priority bythe BREF technical working group and, therefore, was defined as BATat a sector level for minimising SO 2 releases from coke making for bothnew and existing plants. Importantly, no particular techniques wereidentified as BAT as there are advantages and disadvantages for eachprocess, which have to be considered in the context of the localsituation.Process options can be generally divided into either wet oxidationprocesses (e.g. Stretford) or absorption processes (e.g. Still orSulfiban). There are numerous reference plants around the worldincluding Dofasco (Stretford), Coke Plant 2 Corus IJmuiden (Still) andCoke Plant 1 Corus IJmuiden (Sulfiban).In the UK, the Environment Agency has produced guidance for thecoke, iron and steel sector, although this is still in draft form, nearlytwo years after being issued for consultation. Whilst this guidance setsindicative standards which should be met unless there is justificationfor not doing so, it should be noted that BAT is, in fact, site specificand EA sector guidance is exactly that, i.e. guidance, not a series ofprescriptive requirements. The expectation of the Environment Agencyis, however, that operators who do not have coke oven gasdesulphurisation should install it by 2007.Irrespective of this though, BAT has to be determined locally, takinginto account for example local air quality and other factors. In thiscontext, SO 2 is less of an issue in South Wales, due to low background

196 THE COKE OVEN MANAGERS’ASSOCIATIONlevels, but more of an issue in Scunthorpe where the Trent Valley andother power stations have a significant influence. On Teesside there isalso a specific short-term problem, although this should be addressedby means other than coke oven gas desulphurisation.Whilst IPPC is an important legislative driver, other legislation willalso have an impact. The National Emissions Ceiling Directive placesabsolute limits on member states for a number of emissions, includingSO 2. The impact of this on the iron, steel and coke making industrydepends on how the directive is implemented in the UK, e.g. by burdensharing across all sectors or by lowest cost options. It will also becomplicated by related legislation such as the Large Combustion PlantDirective, which again depending on how it is implemented, couldintroduce very strict limits on SO 2 emissions from power plants(effectively requiring coke oven gas desulphurisation if coke oven gasis one of the fuels used in the power plant). The EU Emissions TradingDirective will also have an impact and through market forces, couldchange the way we look at emissions reductions and pollution controloptions.In conclusion, coke oven gas desulphurisation is BAT atsector/BREF level and at the UK sector guidance level. However,BREFs are not prescriptive and sector guidance is only guidance. PPCis site specific and there is scope to justify that coke oven gasdesulphurisation is not BAT at local level based on cost benefitanalysis. However, there is other legislation which may require cokeoven gas desulphurisation to be installed.