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European Commission DG Environment

Assessment of the implementation of the IPPC Directive Task 1 report (specific contract no 070307/2009/545347/FRA/C4)

March 2011

Entec UK Limited and REC

C r e a t i n g t h e e n v i r o n m e n t f o r b u s i n e s s

Copyright and Non-Disclosure Notice The contents and layout of this report are subject to copyright owned by Entec (© Entec UK Limited 2010) save to the extent that copyright has been legally assigned by us to another party or is used by Entec under licence. To the extent that we own the copyright in this report, it may not be copied or used without our prior written agreement for any purpose other than the purpose indicated in this report. The methodology (if any) contained in this report is provided to you in confidence and must not be disclosed or copied to third parties without the prior written agreement of Entec. Disclosure of that information may constitute an actionable breach of confidence or may otherwise prejudice our commercial interests. Any third party who obtains access to this report by any means will, in any event, be subject to the Third Party Disclaimer set out below.

Third-Party Disclaimer Any disclosure of this report to a third-party is subject to this disclaimer. The report was prepared by Entec at the instruction of, and for use by, our client named on the front of the report. It does not in any way constitute advice to any third-party who is able to access it by any means. Entec excludes to the fullest extent lawfully permitted all liability whatsoever for any loss or damage howsoever arising from reliance on the contents of this report. We do not however exclude our liability (if any) for personal injury or death resulting from our negligence, for fraud or any other matter in relation to which we cannot legally exclude liability.

Document Revisions

No. Details Date

1 Draft Task 1 report for client comment

15th February 2010

2 Final Task 1 report taking client comments into account

27th April 2010

3 Final Task 1 report taking EIPPCB comments into account

25th January 2011

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Report for Kier-John McAndrew European Commission, DG Environment BU-5 03/49 BE-1049 Brussels Belgium

Main Contributors Marc-Henri Bouhier Ben Grebot Chris Green Keith Lawton Richard Noden Tim Scarbrough

Issued by ………………………………………………………… Ben Grebot

Approved by ………………………………………………………… Keith Lawton

Entec UK Limited Windsor House Gadbrook Business Centre Gadbrook Road Northwich Cheshire CW9 7TN Tel: +44 (0) 1606 354800 Fax: +44 (0) 1606 354810 Doc Reg No. 26697 h:\projects\em-260\26000 projects\26697 ppaq ippc implementation (subfile)\c -client\reports\task 1 report\26697 task 1 report 25jan2011.doc

European Commission DG Environment

Assessment of the implementation of the IPPC Directive Task 1 report (specific contract no 070307/2009/545347/FRA/C4)

March 2011

Entec UK Limited

In accordance with an environmentally responsible approach, this document is printed on recycled paper produced from 100% post-consumer waste, or on ECF (elemental chlorine free) paper

© Entec UK Limited

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© Entec UK Limited

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Contents

1. Introduction 1

1.1 This report 1

1.2 Aims and objectives 1

1.3 Structure of report 2

2. User guide to electronic tool 3

2.1 Overview 3

2.1.1 Scope 3

2.1.2 Structure 4

2.1.3 Colour coding of BAT-AEL records 7

2.1.4 Interpretation of data 8

2.2 Searching the tool 8

2.2.1 Multi-BREF search facility 8

2.2.2 Searching within the outputs of a search 11

2.2.3 Searching one sector only 12

2.2.4 Searching one BREF only 12

2.2.5 Saving / exporting the results of a search 12

2.2.6 Printing the results of a search 12

2.2.7 Beginning a new search 13

2.3 Glossary 13

2.4 Updating the tool 14

2.4.1 Inserting new BAT-AEL values 14

2.4.2 Updating existing BAT-AEL values 14

3. Issues discussed during tool development 15

3.1 Issues applicable to many or all BREFs 15

3.2 Issues specific to certain BREF sectors 15

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4. Future development 19

Table 2.1 List of BREFs and Draft BREFs included in scope of tool 3 Table 2.2 Fields in the tool 5 Table 5.2 Consumption and emission levels associated with the production of market milk from 1 litre of received milk 7 Table 2.3 Glossary and abbreviations used to record BAT-AELs in the tool. 13 Table 3.1 Particular notes recorded when extracting the BAT-AELs from BREFs into the tool. 16

Figure 2.1 Screenshot of SEARCH worksheet 9 Figure 2.2 Screenshot of OUTPUT worksheet. An autofilter menu on the ‘Product / sub-sector’ field has been selected. This

screenshot shows ten records are visible, with more to be viewed by scrolling down. The bottom of the screenshot shows the other worksheet tabs that can be viewed. 11

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1. Introduction

1.1 This report This Task 1 report provides an overview of the work that has been undertaken to review and extract information on Best Available Technique-Associated Emission Levels (BAT-AELs) and BAT from the BREFs and the development of a searchable electronic tool to present all of this information in a single consolidated format. This report also provides guidance on the use of the tool including the options for searching the information and the way in which it may be updated in the future as the BREFs are revised.

1.2 Aims and objectives The key aims and objectives of this task were two-fold:

1. To review and summarise the BAT-AELs and related BAT from all BREFs (both adopted and the latest available drafts) clearly specifying the averaging periods and reference conditions against which they apply as well as to which specific activities and types of installations they relate.

2. To present this information in an electronic tool so that the data can be queried and updated in the future with ease.

Although aspects of this task have been covered in previous implementation and related studies for specific sectors/activities/installation types, a comprehensive review and collation such as this has never been completed and a central reference source has not been prepared.

The task has provided an important reference source for Task 2 of the study, supporting the comparison of permit ELVs and current installation performance against the relevant BAT-AELs. From a wider perspective, it is anticipated that the tool will provide a valuable source of reference for the future, enabling users to check BAT-AELs without having to consult the BREF documents themselves, which are generally several hundred pages long and the conclusions on BAT-AELs sometimes difficult to interpret (especially for some of the older BREFs). For example, it is anticipated that such a tool would be useful for Member States when assessing and setting IPPC emission limit values within new permits or when reviewing existing permits. It is however acknowledged that BAT is more than just the BAT-AELs and therefore such a tool remains only a single part of a range of information that will need to be referenced when evaluating and determining BAT-based permit conditions.

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1.3 Structure of report The report is structured as follows:

• Section 2 provides a user guide to the tool including the ways in which the data in the tool should be interpreted as well as how it may be searched and updated in the future.

• Section 3 provides a list of key issues that have been identified from the review of each BREF.

• Section 4 provides a brief overview of how the tool may be further developed in the future.

A copy of the electronic tool is provided in Appendix A.


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2. User guide to electronic tool

2.1 Overview

2.1.1 Scope

This tool is a database of the BAT-AELs that are included in the BREFs and draft BREFs (current as at February 2010) listed below in Table 2.1. The AELs from draft BREFs have been retained in the tool in case BREFs are finalised and values can be confirmed. Those BREFs not listed in the table1 are not included because they do not contain any BAT-AELs.

Table 2.1 List of BREFs and Draft BREFs included in scope of tool

Sector code

Sector name Scope of inclusion

CLM Cement, lime, & magnesium oxide manufacturing industries Adopted BREF (2001)

Final Draft (May 2009)

CER Ceramic Manufacturing Industry Adopted BREF (2007)

CAK Chlor-alkali manufacturing industry Adopted BREF (2001)

CWW Common waste water & waste gas treatment / management systems in the chemical sector Adopted BREF (2003)

1st Draft (October 2009) (Note 1)

ESB Emissions from storage Adopted BREF (2006)

FMP Ferrous metals processing industry Adopted BREF (2001)

FDM Food, drink and milk industries Adopted BREF (2006)

GLS Glass manufacturing industry Adopted BREF (2001)

2nd Draft (July 2009)

ICS Industrial cooling systems Adopted BREF (2001)

1 BREFs without BAT-AELs and thus not included in the tool: Economics and Cross-Media Effects BREF (2006), Energy Efficiency BREF (2009), General Principles of Monitoring BREF (2003), Intensive Rearing of Poultry and Pigs BREF (2003), and Management of Tailings and Waste-Rock in Mining Activities BREF (2009).



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Sector code

Sector name Scope of inclusion

LCP Large combustion plants Adopted BREF (2006)

LVIC-AAF Large volume inorganic chemicals – ammonia, acids and fertilisers industries Adopted BREF (2007)

LVIC-S Large volume inorganic chemicals – solids and others industry Adopted BREF (2007)

LVOC Large volume organic chemical industry Adopted BREF(2003)

OFC Manufacture of organic fine chemicals Adopted BREF (2006)

REF Mineral oil & gas refineries Adopted BREF (2003)

NFM Non-ferrous metals industries Adopted BREF (2001)


I&S Production of iron & steel Adopted BREF (2001)


POL Production of polymers Adopted BREF (2007)

SIC Production of speciality inorganic chemicals Adopted BREF (2007)

PP Pulp & paper industry Adopted BREF (2001)

SA Slaughterhouses & animals by-products industries Adopted BREF (2005)

SF Smitheries and foundries industry Adopted BREF (May 2005)

STM Surface treatment of metals and plastics Adopted BREF (2006

STS Surface treatment using organic solvents Adopted BREF (2007)

TAN Tanning of hides & skins Adopted BREF (2003)

1st Draft (February 2009)

TXT Textiles industry Adopted BREF (2003)

WI Waste incineration Adopted BREF (2006)

WT Waste treatments industries Adopted BREF (2001)

Note 1: No BAT-AELs are listed in this first draft.

2.1.2 Structure

The tool has been developed in a macro-enabled Microsoft Excel 2007 spreadsheet. Microsoft Excel has been chosen as the software to develop the tool in because it provides the functionality that is required in a format that is familiar to the tool designers and more generally to potential audiences. Whilst the data in the tool itself may be viewed in older versions of Excel, the functionality of the search and filter aspects of the tool will be impaired.

The database is broken down into sub-databases, one sub-database for each BREF, and all sub-databases are also collated into one master database which is used for searching. The workbook is structured as follows:


• One worksheet, titled ‘SEARCH’, which is the title screen for the user upon opening the tool. This screen provides (a) hyperlinks to each BREF worksheet, and (b) a set of search criteria using drop-down lists. The search is carried out by the user clicking on a ‘Search and view output’ button.

• One worksheet, titled ‘OUTPUT’, which shows the results of the BAT-AEL search that follow the criteria entered in the SEARCH worksheet (if the ‘Search and view output’ button has been pressed).

• There is one worksheet per BREF. These worksheets are named using the BREF codes listed in Table 2.1. All the BAT-AELs from a particular BREF (and draft BREF if applicable) are listed in that worksheet. All these BREF worksheets follow a common format.

• One worksheet, titled ‘All’, collates all BAT-AELs from all BREFs, again following the same common format. It is from within this worksheet that the SEARCH function searches for BAT-AELs using an Advanced Filter (which filters according to multiple criteria in multiple columns where all criteria must be true).

• Two [hidden] worksheets: a first titled ‘Entry lists’, which provides data validation rules for both the SEARCH screen and for each BREF worksheet; and a second titled ‘Deleted records’, which includes records that have been removed from the main searchable tool following EC and EIPPCB comments, particularly in relation to records identified as achievable emission levels (see section 2.1.3).

The information that has been extracted from the BREFs on the BAT-AELs and to which sectors / plants / fuels etc they apply to have been categorised into the fields listed below in Table 2.2. These fields are common to all BREFs worksheets. However, as can be expected with such a broad range of sectors from all the BREFs covered, some fields cover slightly different scope between sectors. Furthermore, some of the fields are not applicable to some BREFs, and in these instances, those fields are filled with ‘Unspecified’ or similar.

Table 2.2 Fields in the tool

Field name Searchable Notes

ID No Unique ID field

IPPC Activity Category

Yes I.e. 1, 2, 3, 4, 5 or 6. Cross-sectoral BREFs are included as ‘All’

IPPC Activity Yes Included for every BAT-AEL. E.g. 1.2 or 2.3(b). Cross-sectoral BREFs are included as ‘All’, except the CWW BREF which applies to all chemical sector activities; this has been included as additional activity ‘4.X’. Where one BREF covers multiple activities, records are duplicated but with IPPC Activity differentiating between multiple activities.

Sub-sector / Product

Yes Optional field. Varies for each BREF.

• E.g. for the Polymers BREF this field has the options: ESBR / polyolefines / polystyrene / PVC / unsaturated polyester / viscose staple fibres

• E.g. for the Iron & steel BREF this field has the options: basic oxygen steelmaking and casting / blast furnace / coke oven / electric steelmaking and casting / pelletisation plant / sinter plant.


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Sub-sub-sector / Sub-product

Yes Optional field. Varies for each BREF. Is used to further refine sub-sector / product field.

• E.g. for the Polymers BREF and for the sub-sector/product of polystyrene, this field has the options EPS / GPPS / HIPS.

• E.g. for the Pulp and paper BREF and for the sub-sector/product of kraft pulping, this field has the options bleached and unbleached kraft / bleached kraft / Integrated bleached Kraft pulp and uncoated fine paper / Integrated kraftliner, unbleached / Integrated sackpaper, unbleached / Integrated unbleached Kraft.

Plant type Yes Optional field. Varies for each BREF.

• E.g. for the LCP BREF, this field is utilised for differentiating AELs by combustion technique, i.e. it includes boiler types (e.g. PC, CFBC, grate firing), gas turbines, gas engines.

• E.g. for the CLM BREF, this field is used to differentiate by kiln type, i.e. pre-heater kilns, lepol and long rotary kilns, parallel flow regenerative kilns.

Plant age Yes New or existing (where specified)

Plant capacity Yes Optional field. Varies for each BREF. E.g. different BAT-AELs for different plant sizes

Fuel type Yes Optional field. Varies for each BREF.

• E.g. for the LCP BREF, this field has the options biomass / coal / gas / HFO / LFO,diesel / lignite / liquid / peat / refinery fuel gas.

• E.g. for the REF BREF, this field has the options All / Gas / Liquid / efinery fuel gas.

Emission source Yes Optional field. Varies for each BREF.

• E.g. for the CER BREF, this field includes the options dusty operations / drying processes / firing processes / kiln firing process [and others].

• E.g. for the CAK BREF, this field includes the options caustic soda / cell room / hydrogen gas / process emissions / process exhausts / Untreated cooling air from Hg distillation unit.

Release type Yes Emission to Air, Emission to water. Also covers other levels associated with BAT: Consumption (see example below in Box 1), Input, Noise or Waste

Pollutant Yes Different pollutants for each release type. This can be either as individual pollutants, or in groups, for example the sum of certain specified heavy metals.

BAT No The BAT(s) to which the emission level is associated.

Units of BAT-AEL No Units of measurement

BAT-AEL (lower bound)

No If single numerical figure given, entered in both lower and upper BAT-AEL. Note not all are numerical e.g. “<5-200”.

If an AEL is given as e.g. <20, it is entered as lower bound 0 and upper bound 20

BAT-AEL (upper bound)

No If single numerical figure given, entered in both lower and upper BAT-AEL. Note not all are numerical e.g. “<5-200”.

‘Colour’ No Green, Amber or Red. See section 2.1.3.

Monitoring No Description of applicable monitoring conditions (if stated).

Reference condition: oxygen content of flue gas

No Only applicable to emissions to air. In %, as dry gas.

Averaging period No Description of averaging period to which the BAT AELs are referring.



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Notes No Allows for any additional points to be made, e.g. applicability, split views, expansion of BAT description etc.

Source: BREF No BREF title and version

Source: BREF section reference

No BREF section reference

Source: BREF page reference

No Page reference to paper copy of BREF

Source: BREF pdf page reference

No Page reference to pdf file of BREF

As an example of consumption levels associated with BAT, which have been included in the tool, see Box 1.

Box 1 Extract from the Food, Drink and Milk Industries BREF (2006), p.604

5.2.5.1 Additional BAT for the production of market milk

In addition to the BAT in Sections 5.1 - 5.1.7 and 5.2.5, for the production of market milk, BAT is to do the following:

1 achieve the consumption and emission levels shown in Table 5.2 (see Sections 3.3.5.1.1, 3.3.5.1.2, 3.3.5.4 and 5.2.5 paragraph 9)

Energy consumption (kWh/l) Water consumption (l/l) Waste water (l/l)

0.07 – 0.2 0.6 – 1.8 0.8 – 1.7

Table 5.2 Consumption and emission levels associated with the production of market milk from 1 litre of received milk

2.1.3 Colour coding of BAT-AEL records

The BAT-AEL records are colour coded through the use of ‘traffic light’ shading to differentiate between the robustness of the BAT conclusion as follows:

Green BREF clearly indicates that the BAT-AEL is an emission level associated with BAT.

Amber Indicates that a split view within the TWG was recorded in the BREF (note that these are still BAT-AELs).

Red Red is used to indicate that the BREF does not clearly indicate that the emission level is associated with BAT. In most cases, the terminology used in such instances is ‘achievable emission level’.



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Following comments from the European IPPC Bureau (EIPPCB) the records shaded red have been removed from the main searchable tool and are listed on a separate (hidden) worksheet within the tool called ‘Deleted records’.2

2.1.4 Interpretation of data

When searching for data it is worth bearing in mind the following points:

• No BAT conclusions are recorded in the tool if there is no emission level also recorded.

• Where one BAT-AEL is applicable to more than one IPPC activity, then it is duplicated for each activity.

• If a BAT-AEL specifically states that it applies to both new and existing plant, then it is duplicated as one record for each of new and existing.

2.2 Searching the tool There are multiple ways in which the tool can be searched. It is recommended that Microsoft Excel 2007 is used for searching – this is due to its improved auto-filter support.

2.2.1 Multi-BREF search facility

As described in section 2.1.2, upon opening the tool the user is presented with the main search screen (worksheet: ‘SEARCH’). This worksheet presents two options (a screenshot of this is displayed below in Figure 2.1):

i. On the left hand side, there are hyperlinks for the user to jump straight to the worksheet for specific BREFs. See below for more detail on this.

ii. On the right hand side is the multi-BREF search facility which includes a number of dropdown boxes.

2 Due to both the removal of records shaded red – representing achievable emission levels – out of the main searchable tool and into a separate list, and the addition of select records following EIPPCB comments, the ID field (that ensures each entry in the database is unique) is not a numerically sequential list in the main searchable tool.



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Figure 2.1 Screenshot of SEARCH worksheet

The multi-BREF search facility is a multiple criteria search across multiple fields, where all criteria must be true. For each field that is searchable (these are listed in Table 2.2) there is a box to enter the search term in. By selecting the box, a drop down menu appears; a value from the drop down menu may be selected (i.e. it is not a free-text search).3 If the user leaves the field blank, as shown in the screenshot above, then no criterion is placed on that field (i.e. the field can contain any value). If all field search boxes are left blank, the entire database presented.

is

The search is carried out by the user first entering as many or as few search criteria in the search boxes as required, then, second, by clicking the ‘SEARCH AND VIEW OUTPUT’ button at the bottom of the screen. There may be a short pause before the results of the search are presented. If no results are found, a message box is used to inform the user of this, and to suggest that fewer search criteria are specified.

3 For the field ‘Pollutant’, the validation rules have been relaxed, to enable the user to enter a search string that may capture multiple variants of a single pollutant (see section 3.1).


To quickly delete all the entered search terms, press the button marked ‘Delete all search terms’ which is towards the top right of the screen. To delete one criterion, select the criterion box and clear its contents by pressing delete.

Two of the search boxes use drop-down menus that are dependant on the criterion entered in other boxes. This means that the first search box must be completed first before a criterion is selected in the second box. These are:

• IPPC Activity – this input is dependant on the ‘IPPC Activity Category’ search box. I.e. if ‘1. Energy Industries’ is selected in the ‘IPPC Activity Category’ search box then only the activities 1.1, 1.2, 1.3 and 1.4 will be visible in the ‘IPPC Activity’ search box.

• Pollutant – this input is dependant on the ‘Release type’ search box. This is because a different set of pollutants are associated with each release type.

Upon clicking the ‘SEARCH AND VIEW OUTPUT’ button, the user is taken to the ‘OUTPUT’ worksheet. An example of what this worksheet looks like if no search terms are entered (i.e. as per Figure 2.1) is shown below in Figure 2.2. Due to the number of fields, the user must scroll to the right to see all of the fields (refer to Table 2.2 for the list of fields); note that the screenshot only displays the fields from ‘ID’ to ‘Emission Source’. Scrolling down will display further results of the search (if any).


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Figure 2.2 Screenshot of OUTPUT worksheet. An autofilter menu on the ‘Product / sub-sector’ field has been selected. This screenshot shows ten records are visible, with more to be viewed by scrolling down. The bottom of the screenshot shows the other worksheet tabs that can be viewed.

2.2.2 Searching within the outputs of a search

The OUTPUT worksheet has the built-in autofilter function already enabled (but not applied). This allows the user to continue searching within the outputs of the main search, using the autofilter4. To apply a filter, simply select a drop down arrow by the field title. This presents a small menu (as shown in Figure 2.2 for the field ‘Product / Sub-sector’) from which the user can:

• Select individual entries by first un-checking the box next to ‘(Select All)’, and individually selecting the items of interest; or

4 Online help on Microsoft Excel 2007 filtering is available at http://office.microsoft.com/en-us/excel/HP100739411033.aspx


• Choose ‘Text Filter’ from the autofilter menu and then for example the method ‘Contains’ for a free text search; or

• Filter by colour (see section 2.1.3).

2.2.3 Searching one sector only

This may be useful for browsing the BAT-AELs for one particular sector, e.g. viewing both those listed in an adopted BREF and those listed in a draft BREF. From the main SEARCH worksheet, the user should click on the relevant hyperlink next to the sector of interest. This will jump then to the worksheet for that sector, which can then be searched using the same autofilter functionality described above in section 2.2.2. To return to the main SEARCH screen, simply click on the SEARCH tab on the bottom left of the screen.

2.2.4 Searching one BREF only

The best method to search for the AELs in one BREF only is to use the multi-BREF search facility (see section 2.2.1) and to only place one criterion: in the Source (BREF) search box. Alternatively the user can search directly within the worksheet for a particular BREF using the autofilter options.

2.2.5 Saving / exporting the results of a search

The easiest method to save the OUTPUT is to copy the worksheet to a new blank workbook. To do this, right click on the OUTPUT tab at the bottom of the screen, select ‘Move or Copy…’, then in the ‘To book:’ drop-down menu select ‘(new book)’, and then ensure that the ‘Create a copy’ checkbox is checked before pressing OK. This process will provide the search OUTPUT in a new blank workbook, which you can now save.

Chose the Save As dialog to choose the format you require for exporting.

2.2.6 Printing the results of a search

It is important to note that due to the size of the database, printing the search output may run to hundreds of pages.

From Microsoft Excel 2007, the best method to print the output is to first select the output (including the field headings), ensuring that blank rows are not included, click Print, then ensure that in the ‘Print what’ section the button ‘Selection’ is ticked rather than ‘Active sheet(s)’.


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2.2.7 Beginning a new search

Part of the SEARCH macro automatically clears the OUTPUT of the previous search, so there is no need for the user to do this (see Section 2.2.1 for further details).

2.3 Glossary Some terminology has been abbreviated for clarity in the tool. These abbreviations are explained below in Table 2.3.

Table 2.3 Glossary and abbreviations used to record BAT-AELs in the tool.

Abbreviation Meaning Abbreviation Meaning

API American Petroleum Institute HIPS High impact polystyrene

BFBC Bubbling fluidised bed combustion HRSG Heat recovery steam generator

CCGT Combined cycle gas turbine LDPE Low density polyethylene

CFBC Circulating fluidised bed combustion LLDPE Linear low density polyethylene

CHP Combined heat and power MF Microfiltration

CPI Corrugated Plate Interceptor PC Pulverised Combustion

DLN Dry Low NOx pre-mix burners (for gas turbines) PEMS Parametric Emission Monitoring Systems

DSI Dry sorbent injection PFBC Pressurised fluidised bed combustion

DWI Draw and wall iron: a production method for producing cans

PPI Parallel Plate Interceptor

EPS Expandable polystyrene ppm parts per million

ESBR Emulsion polymerised styrene butadiene rubber PVC Polyvinyl chloride

ESP Electrostatic Precipitator SCR Selective catalytic reduction

FBC Fluidised bed combustion SDS Spray Dry Scrubbing

FF Fabric Filter SNCR Selective non-catalytic reduction

FGD Flue Gas Desulphurisation UF Ultrafiltration

GPPS General Purpose Polystyrene VCM Vinyl chloride monomer

HDPE High density polyethylene WWTP Waste water treatment plant


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2.4 Updating the tool The tool can be updated with additional records from additional drafts/adopted BREFs as the review process continues. Two copies of the tool will be provided to the Commission: one will be for the end-user and will not be as easily updateable; the second will be a ‘Master’ copy for the Commission. The end-user copy is smaller in size to make it easier to distribute. The master copy is larger but retains some functionality to ease the updating process. The master copy has in the ‘All’ worksheet links (rather than values) to the BAT-AEL records listed in each BREF-sector worksheet such that if changes are made in the BREF-sector worksheet these are reflected in the ‘All’ worksheet. This retention of links to cells makes it easier to update the ‘All’ worksheet when additional BAT-AEL records are put into each worksheet.

2.4.1 Inserting new BAT-AEL values

Updating the tool can be done easily by a person competent in the use of Microsoft Excel by following the procedure below:

i. Insert additional rows in the BREF-sector worksheet. Due to the conditional formatting and data validation employed in this spreadsheet, additional rows must be inserted by first highlighting the row immediately below the last recorded BAT-AEL record, then inserting sheet rows. Note the ID number of the last recorded BAT-AEL record.

ii. Fill in the BAT-AEL record for each row inserted.

iii. Adjust the ‘All’ worksheet to reflect updates from individual BREF sector worksheet. This is done by scrolling down to the ID field in the ‘All’ worksheet until the ID number is reached which was noted under point (i) above. Then, select the row beneath this record and insert the number of rows that were added in point (i) above.

iv. Update drop-down menus for SEARCH worksheet. If entries for particular fields have not previously been used in the tool before, then the data validation lists used for the drop-down menus in the SEARCH worksheet will need to be updated. These are included in the hidden worksheet ‘Entry lists’. As these are referred to using named ranges, cells should be inserted in these lists, rather than additional entries made below the lists.

2.4.2 Updating existing BAT-AEL values

Modifications to entries already contained within the tool can be made manually in the relevant cells of a particular BREF worksheet. If a new field is required which has not been used in the tool before then the instructions in the last bullet point above (iv) should be followed.


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3. Issues discussed during tool development

During the development of the tool, various issues arose, some of which are applicable to many or all BREFs, and those which are only relevant to specific BREFs. This section discusses both.

3.1 Issues applicable to many or all BREFs As discussed in section 2.1.3, a number of instances have been identified where BREFs have not referred to emission levels as ‘associated emission levels’ but as ‘achievable emission levels’, or other text. Such emission levels have been highlighted in the tool by red shading. Similarly, split views recorded in BREFs have been shaded amber in the tool.

Each BREF may refer to a pollutant in a slightly different way than other BREFs. To illustrate this variability, sulphur emissions to air have been variously referred to as the following:

• Sulphur (S)

• Sulphur dioxide (SO2)

• Sulphur dioxide, expressed as S

• Sulphur oxides (SOx)

• Sulphur oxides, expressed as SO2

Many other examples exist in the tool. In order to faithfully reproduce the BAT-AELs as written in the BREFs, the tool on the whole retains these variations (particularly where, as in the above example, all variations are technically different). Where variations in pollutants (or other fields) have been deemed to be written differently but are ultimately the same, we have sought to amalgamate these into single variants.

In some BREFs, BAT-AELs are provided for a sum of heavy metals, whereas in other cases, BAT-AELs are provided for each metal. Where an AEL has been recorded as a sum of heavy metals, this has been recorded in the tool as that sum (e.g. ‘Heavy metals (Cr, Cu, Ni, Pb, Zn)’) as it is not possible to produce a figure for one specific metal. As such the user must bear in mind that they may need to search for heavy metals as an alternative to a specific metal.

3.2 Issues specific to certain BREF sectors Particular notes have been made regarding issues specific to certain BREF sectors. These relate to:


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• How BAT-AELs from a BREF have been recorded in the tool;

• Contentious issues; or

• Levels that have not been included in the tool.

These notes are included below in Table 3.1. The table is not a complete list of all emission levels that are not clearly denoted as associated emission levels; it is suggested to check the tool for, for example, a complete list of all emission levels marked up as red.

Table 3.1 Particular notes recorded when extracting the BAT-AELs from BREFs into the tool.

BREF code

Notes

CWW This is a horizontal BREF, applicable to the entire chemicals sector. Therefore, an additional IPPC activity has been created: ‘4.X’.

This BREF states that “The refinery industry also sees this BREF as relevant to the refinery sector”. Therefore BAT-AEL records have been duplicated with IPPC Activity set as 1.2, and the field ‘Emission source’ records “Combustion Exhaust Gas Treatment in the chemical sector”, with notes applied to this effect under the field ‘Notes’. These are recorded as in the tool.

This BREF gives AELs for waste gases from combustion plants [in the chemical sector], so these are doubled up to IPPC activity 1.1, and the field ‘Emission source’ records “Combustion Exhaust Gas Treatment in the chemical sector”, with notes provided to this effect under the field ‘Notes’. These are recorded as in the tool.

ESB Only associated and achievable emission reduction levels that are stated in the BAT section (5) of the BREF have been included in the tool.

This is a horizontal BREF, so IPPC activity category and activity have been entered as ‘All’ The field ‘emission source’ records such records as “Storage of bulk or dangerous liquids and liquefied gases“.

GLS Some of the BAT conclusions have associated AELs which are accompanied by text such as “This statement is not a firm conclusion, rather a balanced judgement based on the information available at the time of writing.” These have been recorded in the tool as and with the statement recorded in the notes field.

Section 5.11 on emissions to water includes a set of emission levels with accompanying text “The emission levels (…) are indicative of the emission levels that would be achieved with those techniques generally considered to represent BAT. They do not necessarily represent levels currently achieved within the industry but are based on the expert judgement of the TWG.” These have been recorded in the tool as and with the statement recorded in the notes field.

ICS This is a horizontal BREF so ‘All’ is entered as the IPPC activity.

A noise reduction associated with BAT has been included – but these are not levels as such but reductions in dB(A) e.g. BAT is to reduce by at least 5dB has been entered as >=5 for both lower and upper BAT-AEL.

LCP Thermal efficiencies associated with BAT have not been included in the tool.

LVIC-AAF

For phosphoric acid, the emission levels generally use the wording “BAT is to achieve emissions levels of […]”.These are recorded as in the tool.

For HF, consumption/emission levels are described as "achievable consumption/emission level associated with BAT". These are recorded as in the tool, except one instance which is both achievable and a split view which has been recorded as .

For urea and UAN, none of the ‘AELs’ in section 8.5 explicitly say they’re associated with BAT, the wording is generally “BAT is to achieve emissions levels of […]” or “BAT levels”. These are recorded as in the tool.

amber

green

green

green

green

green

green

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BREF code

Notes

LVIC-S For TiO2, BAT conclusion #17, the overall energy efficiency in the sulphate process has both a range which has been interpreted as a BAT-AEL (23-41 GJ/t TiO2 pigment) and as such included under the BAT-AEL field, and additional energy efficiency ranges for specific TiO2 plants which are referred to as “extreme ranges [that] apply only as indicative levels”, which have been recorded in the same record but under the Notes field. The single record has been included as in the tool.

LVOC For Generic BAT, section 6.4 p139 (p185 of the pdf document), the threshold mass flows in the last column are included in the Notes field.

On page 140 it is stated that “BAT for process furnaces is gas firing and low-NOx burner configuration. This can achieve NOx reduction down to 50 - 100 mg/Nm3 (as an hourly average) for new and existing situations.” This is recorded as in the tool.

The BAT associated levels for gas-fired furnaces given in Table 7.19 on page 190 are recorded in the tool whilst those written descriptively for the same plants in final four paragraphs on page 189 are not recorded.

The BAT for TOC emissions to water in section 11.5.4 use the term “The application of BAT allows an emission level of 0.4 kg Total Organic Carbon /t acrylonitrile to be achieved (based on an organics destruction rate of 90 %).” This has been recorded in the tool as and has been removed from the main searchable tool.

REF The following split view in the introduction to the BAT chapter (from page 393 of the BREF) applies to all the AELs recorded in the tool, but has not been reproduced in every record: “In the determination of the upper value of the associated emission range in this chapter, a split view has been expressed by industry and two Member States. The split view is that they consider that the upper value in Chapter 5 should correspond with the upper value found in Chapter 4. Their rationale is that if a technique considered BAT is already applied in an installation and achieves a certain value, that value should be considered in the range of associated emission values.”

I&S In some cases, where associated emission levels are not stated in the BAT conclusion, but achievable emission levels for individual techniques mentioned to meet BAT are stated, these have been included in the tool, recorded as (e.g. BAT conclusion #3 on page 86) and have been removed from the main searchable tool.

POL There are generic BAT which apply to many types of emissions. BAT specific to the product has been recorded in the ‘BAT’ field, and generic BAT measures in the ‘Notes’ field.

For dust minimisation, despite BAT-AELs there were no specific BAT for Polyolefines LDPE. This is recorded in the BAT field.

For PVC the BAT conclusions are quite lengthy (especially for VCM emissions to air). These BAT have been split between the BAT and Notes fields. Thus the generic BAT conclusions for VCM emission to air for PVC have been omitted (IDs 3298 and 3304).

BREF section 13.5: we have been unable to identify either generic or specific BAT for some of the pollutants in the BREF’s table 13.11.

BREF section 13.10 lists three emission levels for Zinc emitted to water – one is associated emission level (from the table), another is “BAT is to achieve …”, but in different units, and the third is a more stringent one for sensitive water bodies. The first two have been recorded (as ) in separate records; the third has been recorded in the Notes field of the second AEL.

PP Records with ID numbers 3547 to 3553, which refer to emission levels of single emission sources or points in kraft pulping, have been recorded with colour code rather than red. This is following comment from the EIPPCB that the values should be interpreted as an approximate range of what can be expected for BAT-AELs, and that revision of the PP BREF is expected to present new values to supersede quoted values.

Records with ID numbers 3734 to 3740, which refer to emission levels of special paper mills, have been recorded with colour code amber rather than red. This is following comment from the EIPPCB that the values can be considered as BAT-AELs but it should be borne in mind that there may exist some exceptions from the rule. The values are realistic and cover most speciality paper mills.

TAN One AEL from the adopted BREF has been included, with the rest from the 1st draft of the revision.

amber

green

green

green

red

red



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BREF code

Notes

TXT The urea consumption rate (from page 454 of the BREF) has not been included. It is not a consumption level associated with BAT. Also, it is not applicable to many plant types.

Page 456 of the BREF lists that it is BAT to reduce water & energy consumption in continuous processes by installing high-efficiency washing machinery according to the principle described in Section 4.9.2. It states that (emphasis added) “The associated values for high-efficiency continuous washing of cellulosic and synthetic fabric in open-width are reported in table 4.38”. This table is on p.398, but it states (emphasis added) that it is “Achievable specific water consumption levels for continuous washing processes during finishing of open width woven fabric consisting of cotton or viscose and their blends with synthetic fibres”. These have not been included.

WT The BREF states that it covers IPPC activities 5.1 and 5.3. Although the BAT conclusions chapter 5 indicates textually (italic for hazardous; normal for non-hazardous) which activity the conclusion applies to, there doesn’t seem to be many BAT-AELs for hazardous waste activities. Therefore all the AELs have been duplicated for activities 5.1 and for 5.3.

The BAT conclusions 42 to 55 are too lengthy to include in the notes field – the notes field thus includes a link to them.

There is an AEL for total “Heavy metals (Cr, CU, Ni, Pb, Zn)”; this is how the tool has recorded it. Thus if the user wants to search for lead (Pb) release to water from WTs, they must be aware that there may be no AEL just for lead but for lead combined with other pollutants.


4. Future development

This tool could be developed further into, for example, a web-based searchable database. This may have the advantage that it is available to more users, and may further simplify the user interface and search functionality. In order to do this, further consideration would need to be given as to the optimal way to integrate it into existing Commission online services e.g. the online Industrial emissions Reporting Information System (IRIS). Given that the tool has been developed as an Excel database and some on-line tools, such as the E-PRTR, are in an Access format, we recommend that this be a discussion point between the Commission, Entec and one of the Commission’s software development representatives.


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Appendix A Electronic tool

Two copies of the Microsoft Excel tool are provided:

i. For the end-user (smaller file size, but less easily updateable);

ii. A ‘master’ copy for the Commission (larger file size, more easily updateable).


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