review of the waste incineration bref under the industrial ...challenges and constraints of a bref...

ISWA 8th Beacon Conference Malmö Review of Waste Incineration BREFs 27 November 2013

European IPPC Bureau

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Review of the Waste Incineration BREF

under the Industrial Emissions Directive (IED)

Conference on Waste to Energy 27 – 28 November 2013

Malmö, Sweden

Simon Holbrook European Commission, Joint Research Centre



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European IPPC Bureau (EIPPCB)

~22 staff within the Sustainable Production and Consumption (SPC) Unit of the Institute for

Prospective Technological Studies (IPTS)

IPTS in the context of the Joint Research Centre (JRC)



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Outline of this presentation

 1 - The Industrial Emissions Directive (IED)

 2 - The Sevilla process

 3 - Challenges for the review of BREFs under the IED

 4 – Review of the Waste Incineration BREF



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1 - The Industrial Emissions Directive (2010/75/EU)



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Industrial Emissions Directive 2010/75/EU (IED)

Key instrument for minimising consumption and the emissions of industrial activities in Europe

General framework:

prevent and, if not feasible, reduce pollution

high level of protection for the environment as a whole

permit based on Best Available Techniques (BAT)

BAT are determined by a Technical Working Group steered by the JRC

(EIPPCB) and documented in BREFs ‘BAT conclusions’ are secondary legislation



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Annex I to IPPC and IED Directive Wide range of industrial activities listed:

•  Energy industries •  Production and processing of metals •  Mineral industries

cement, lime, glass, ceramics

•  Production of chemicals •  Waste management industries

Several recovery or disposal operations Incineration

•  ‘Other’ industries: Pulp and paper, textile processing Tanning of hides and skins Intensive farming of pigs and poultry, slaughterhouses and animal by-product processing, food drink and milk processing, surface treatment using solvents

~ 50 000 IPPC installations in Europe



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Environmental scope of the IED

waste prevention and recovery energy &

water use prevention and control of accidents

noise vibration

heat

emissions to water

odour

emissions to air



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Definition of BAT in the IED

Best Most effective in achieving a high general level of protection of the environment as a whole

Available Developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions

Techniques Both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned

Note: in determining BAT, special consideration should be given to the criteria listed in Annex III of the IED



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Role of BAT conclusions in IED permitting

BAT conclusions are the reference for setting permit conditions

Permits to contain emission limit values (ELVs) to ensure that, under normal operating conditions, emissions do not exceed BAT-associated emission levels (BAT-AELs)

Derogation from BAT-AELs is only allowed in specific and justified cases

•  Need to demonstrate that costs are disproportionately higher than benefits due to local/installation-specific situations

•  Member States report to the public/Commission on use of derogations



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Reconsidering / updating permit conditions (IED Article 21)

•  "Within four years of publication of decisions on BAT conclusions in accordance with Article 13(5) relating to the main activity of an installation, the competent authority shall ensure that: (a) all the permit conditions for the installation

concerned are reconsidered and, if necessary, updated to ensure compliance with this Directive [the IED];

(b) the installation complies with those permit conditions.

•  The reconsideration shall take into account all the new or updated BAT conclusions applicable to the installation and adopted since the permit was granted or last reconsidered."



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A complex consensus-building exchange of information with numerous stakeholders and underpinned by sound techno-economic

information that has been enshrined into law by:

2 - The Sevilla process

Commission Implementing Decision 2012/119/EU



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The legal basis for the exchange of information on BAT

Article 13(1) of the Industrial Emissions Directive 2010/75/EC:

‘In order to draw up, review and, where necessary, update BAT reference documents, the Commission shall organise an exchange of information between Member States, the industries concerned, non-governmental organisations promoting environmental protection and the Commission’

The exchange of information should address: the performance of installations and techniques in terms of emissions and consumptions, etc. the techniques used, associated monitoring, economic and technical viability, etc. best available techniques and emerging techniques identified after considering all the issues concerned



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Exchange of information on BAT: actors

Forum members: •  guidance to COM •  nominate in TWGs •  formal opinion on BREFs

GLS (Glass)

•  Industry

•  Member States •  NGOs

•  Commission

‘Forum’ (IED Article 13) lead by the Commission: industry, Member States, environmental NGOs

35 Technical Working Groups (TWGs)

BREF authors team: •  lead TWGs •  validate/check information •  draft BREFs •  present BREF to Forum

TWG members: •  research information •  peer review draft BREFs

I&S (Iron and Steel)

•  Industry


•  Commission

WT (Waste Treatment)

•  Industry


•  Commission

European IPPC Bureau (EIPPCB)

EU Member States Committee (IED Article 75) Members of the Committee: •  vote the BAT conclusions



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Industry EU Member States + EFTA and Accession Countries

Environmental NGOs European Commission/

EIPPCB

TWG kick-off meeting

Draft 1 (D1)

Draft 2 (D2) *

Final TWG meeting

The ‘Sevilla process’

Final draft

Bulk of info. needed (incl. questionnaires)

Comments

BREF

BAT conclusions

•  Forum opinion on BREF

•  Adoption of BAT conclusions through the IED Art. 75 Committee

BAT conclusions

* D2 optional Total duration: •  24 – 29 months (without D2) •  29 – 39 months (with D2)



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200 to 1000 pages

Standard BREF structure: •  Preface •  General information about the sector …… Chapter 1 •  Process/techniques used……………………… Chapter 2 •  Consumption and emission levels………… Chapter 3 •  Candidate BAT …………………………………… Chapter 4 •  BAT conclusions ………………………………… Chapter 5 •  Emerging techniques…………………………… Chapter 6 •  Concluding remarks and recommendation

for future works (including suggestions for R&D)

Exchange of information on BAT: BREFs



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  The information on key environmental issues is obtained through plant-specific questionnaires covering:   emissions to air and water

  generation of solid by-products, residues and wastes

  efficient energy use

  techniques that are potential BAT candidates

  Importance of contextual information:   details on the techniques used (characteristics, historical data)

  other than normal operating conditions

  link between waste characteristics and generated pollutants

  consumptions (e.g. raw water, energy, chemicals)

Data collection step is crucial for determining BAT



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TSS concentration in the influent and effluent of central WWTPs (detail)

34 0107

4033 54 41 64 19

5362

60

30 3729

48

51

04203 61 67 02

35

45041 43

27 6344 39

49

17

59 32

09

65

38

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ir_flo

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OW

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0

10

20

30

40

50

60

70

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90

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0 40

Number of central WWTPs

TSS

(mg/

l)

<5

influent 20-430

#36: MBR: <detection limit for TSS #08: MBR: 1.1 mg/l (average of 150 measurements)

#40:

OFC

+PO

L, D

irect

Pr

etre

atm

ent:

floc+

filtr

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#48:

LVO

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atm

ent:

Settl

ing+

bio.

trea

t.

Only part of the effluent passes through the MBR - Data from 2007, in 2009 <10 mg/l

BAT is about real plant performance

BAT-AEL: 10 – 20 mg/l (monthly average)



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http://eippcb.jrc.ec.europa.eu/reference/

BREFs are available to the world



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  4 BAT conclusions already adopted:   Iron and Steel; Glass; Tanning of Hides and Skins; Cement, Lime and Magnesium Oxide

  3 BAT conclusions soon to be adopted: Chlor-Alkali; Pulp, Paper and Board; Refining of Mineral Oil and Gas

  8 (B)REFs being worked upon:   Common Waste Water/Waste Gas; Non-Ferrous Metals; Intensive Rearing of Poultry and Pigs; Large Volume Organic Chemicals; Large Combustion Plants; Wood-Based Panels; Waste Treatments; Monitoring

  Work on 4 more BREFs to start in 2014:   Food, Drink and Milk; Waste Incineration; Surface Treatment using Organic Solvents; Wood-Preservation with Chemicals

Progress on the review of BREFs under the IED



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3 - Challenges for the review of BREFs under the IED



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35 BREFs

8-year review cycle



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Challenges and constraints of a BREF review

 The delivery of BREFs and BAT conclusions is a prerequisite for the updating of IPPC permits time is a critical factor in the implementation of the IED, there is now the need to speed up the Sevilla process

 The time allowed for a BREF review is 2-3 years maximum

 Resources are scarce among stakeholders involved in the Sevilla process, including the EIPPCB

 Increased importance of BREFs/BATC requires the acquisition of better and more data (contextual information, applicability, monitoring, costs), which may not be readily available



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General strategy to shorten the time to delivery

 Adopt a more focused approach (shorter BREFs, focus on BAT conclusions, target key environmental issues)

 Anticipate further and prepare input before the BREF review starts: anticipation of the structure of the BAT and identification of the data needs are crucial to devise appropriate questionnaires

  ‘single draft’ route is the standard for BREF reviews not involving major changes in the scope

  Possibilities for e.g. extending commenting periods and holding additional TWG or subgroup meetings are necessarily limited

 Deliver the best quality with (limited) available time and resources



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Conditions to reach useful BAT conclusions

 All stakeholders should contribute to the exchange of information, including representatives from institutions/associations who are not directly represented in the TWG (e.g. competent authorities, equipment suppliers, representatives of industrial installations)

 The applicability of the identified BAT and any potential restrictions need to be carefully assessed

 A transparent exchange of information needs to be ensured

 BAT conclusions are based on clear facts and sound techno-economic information



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4 – Review of the Waste Incineration BREF



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Industry EU Member States + EFTA and Accession Countries

Environmental NGOs European Commission/

EIPPCB

TWG kick-off meeting

Draft 1 (D1)

Draft 2 (D2) *

Final TWG meeting

The ‘Sevilla process’

Final draft

Bulk of info. needed (incl. questionnaires)

Comments

BREF

BAT conclusions

•  Forum opinion on BREF

•  Adoption of BAT conclusions through the IED Art. 75 Committee

BAT conclusions

* D2 optional Total duration: •  24 – 29 months (without D2) •  29 – 39 months (with D2)



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Some Specific Challenges of WI

•  IED Directive incorporated both former IPPC and WI Directives.

•  Some (max) ELVs already enshrined in Directive Annex VI.

•  Large amount of data available. >500 installations

•  Significant growth in sector and in types of incineration plant since 2006.

•  High level of public interest in many Member States.



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Some things you can do now  Carefully get aware with the Guidance (2012/119/EU) to get acquainted with the procedures and timing

 Networking among all the industrial organisations involved: shadow groups are an option that can help the review

 Contact operators and create an EU-wide list of WI plants that will be available for the data collection exercise

 Prepare the operators to the task of filling a detailed questionnaire on the topics indicated in previous slides, including contextual information (operating conditions, monitoring, inputs)

 Collect examples of IPPC permits of operating WI plants and share them with the EIPPCB



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Early Activities in WI BREF Review

  The EIPPCB will soon start to work on the existing WI BAT conclusions to turn them into IED-fit BAT conclusions for discussion.

•  WI TWG wake-up call early 2014 with kick-off meeting around mid-2014.

•  Kick off meeting will determine the scope of the review, based on review of existing conclusions and wishes of TWG members.



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Thank you for your attention

Simon Holbrook Seconded National Expert to the European IPPC Bureau

[email protected] +34 954 488 560

http://eippcb.jrc.ec.europa.eu/

review of the waste incineration bref under the industrial ...challenges and constraints of a bref...

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