Paula Webber HSE Manager BP Chemicals, Saltend, Hull.

Paula Webber HSE Manager BP Chemicals, Saltend, Hull

The industrial emissions Directive

Richard Vincent, Head of Industrial Pollution Control

Industrial emissions Directive

• Not a completely new Directive!

• Recasts existing Directives into one:– integrated pollution prevention and control (IPPC);– large combustion plants;– waste incineration;– solvent emissions; and– three on titanium dioxide production.

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Transposition (England and Wales)

• Transposed in England and Wales by the

Environmental Permitting (England and Wales)(Amendment) Regulations 2013 (SI 2013 No.390)

• Entered force 27 February 2013.

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Regulations and guidance

• Regulations at:

http://www.legislation.gov.uk/search?title=&year=2013&number=390&type=uksi

• Unofficial consolidation at:http://www.defra.gov.uk/industrial-emissions/eu-international/industrial-emissions-directive/

• Part A guidance at:http://www.defra.gov.uk/environment/quality/permitting/

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Schedules (I)

• Applies to existing Part A installations from 7 January 2014 so:

– Existing Schedule 7 remains until then;– New Schedule 7A applies now to new installations and

from 7 January 2014 to existing.

• New Schedule 14 (solvents) – applies from now.

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Schedules (II)

• Waste incineration:– Existing Schedule 13 remains until 7 January 2014;– New Schedule 13A applies now to new installations

and from 7 January 2014 to existing.– Covers all waste incineration and waste co-incineration

plants, irrespective of capacity.– Small waste incineration plants are those with

capacities below IPPC thresholds (10 t/d hazardous, 3 t/h non-hazardous).

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Schedules (III)

• Large combustion plants:– Existing Schedule 15 remains until 1 January 2016;– New Schedule 15A applies now to new installations

and from 1 January 2016 to existing.– All large combustion plants are also subject to

Schedule 7/7A.

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Main new “IPPC” activities

• More waste recovery activities, including:– anaerobic digestion above 100 tonnes/day;– metal shredders; and

• Wood preservation (>75 tonnes/day).

• Need permits by 7 July 2015.

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Implementation of BAT

• Tightens the implementation of best available techniques (BAT)

– In particular, through progressive adoption as Commission Implementing Decisions of the BAT Conclusions reached in the BREFs.

(BREF = Best available techniques Reference document.)

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BREFs

• BREFs produced/revised by Technical Working Groups drawn from throughout EU.

• Vital that industry contributes information and expertise.

• Commission guidance on BREF process at:http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:328:0027:0028:EN:PDF

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BAT Conclusions

• BAT Conclusions published for:– Glass (February 2012)– Iron & steel (February 2012)– Cement and lime (March 2013)– Tanneries (February 2013)

BAT Conclusions expected within next year for:- Chlor-alkali- Refineries- Pulp and Paper

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BREF work programme

• Programme “endorsed” on 6 June 2013.

• Available on European Commission “CIRCA” web site:

https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp?FormPrincipal:_idcl=FormPrincipal:_idJsp35&FormPrincipal_SUBMIT=1&id=06f33a94-9829-4eee-b187-21bb783a0fbf&javax.faces.ViewState=rO0ABXVyABNbTGphdmEubGFuZy5PYmplY3Q7kM5YnxBzKWwCAAB4cAAAAAN0AAExcHQAKy9qc3AvZXh0ZW5zaW9uL3dhaS9uYXZpZ2F0aW9uL2NvbnRhaW5lci5qc3A=

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Chemical BREFs work programme

• Common Waste Water and Waste Gas Treatment/Management Systems in the Chemical Sector (CWW) – To Article 13 Forum in 2013.

• Large Volume Organic Chemicals (LVOC) - To Article 13 Forum in 2014.

• Consideration by “Article 75” Committee and, subject to qualified majority vote, publication takes about one year thereafter.

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• ‘One inorganic chemical BREF’ – TWG 2015; to Article 13 Forum 2017

– Merging both the Solid and others and Ammonia, Acids and Fertilisers BREFs into

a single document is one option.

• Speciality Inorganic Chemicals (SIC) - TWG 2016; to Article 13 Forum 2018.

• Polymers (POL) and Organic Fine Chemicals (OFC) - TWG 2017; to Article 13 Forum 2019.

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Part A permit updates

• Permits have to be reconsidered and if necessary updated within four years of publication of relevant BAT Conclusions.

• So by: – 2019 for large volume organics?– 2024 for organic fine chemicals?

• However, permits can be reconsidered at any time if the regulator considers there is a need.

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BAT-AELs, ELVs and derogations (i)

• Set emission limit values that ensure that, under normal operating conditions, emissions do not exceed the emission levels associated with the best available techniques as laid down in the decisions on BAT conclusions.

• Only where BAT-associated emission levels are given in adopted BAT Conclusions.

• Derogations possibly needed only in that situation – operator to make the case to the regulator.

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BAT-AELs, ELVs and derogations (ii)

Derogation may apply only where an assessment shows that the achievement of BAT-associated emission levels in adopted BAT Conclusions would lead to disproportionately higher costs compared to the environmental benefits due to:

(a) the geographical location or the local environmental conditions of the installation concerned; or

(b) the technical characteristics of the installation concerned.

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BAT-AELs, ELVs and derogations (iii)

• Reasons to be documented in an annex to the permit conditions (with public participation in the decision).

 • ELVs to not exceed the emission limit values set

out in the LCP, waste incineration or solvents Annexes where applicable.

• In any case ensure that no significant pollution is caused and that a high level of protection of the environment as a whole is achieved.

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Inspections

• Minimum requirements set in Chapter II (Article 23), so apply to “IPPC” installations.

• Site visits at least triennially, and annually for high risk installations.

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Large combustion plants

• Significantly tightened emission limit values - Apply now to new plants and from 1 January 2016 for existing.

• Provision for “limited life” opt-out (17,500 hours from 1 January 2016 or 31 December 2013, whichever come sooner).

• Transitional National Plan – option for existing plants to cover the period 1 January 2016 to 30 June 2020.

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Waste incineration

• Waste incineration requirements are virtually unchanged.

• LAs to regulate only waste incineration/co-incineration installations below the IPPC thresholds:

– 10 tonnes/day hazardous waste; or– 3 tonnes/hour non-hazardous waste.

• Defined in the Regs as small waste incineration plants.

• BAT does not apply in England.

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Solvent emissions

• Solvent emission requirements virtually unchanged.

• Solvent emission Directive activities no longer Part B - covered by new Schedule 14.

• BAT no longer applies in England.

• But Section 6.4 remains unchanged, so many activities using solvents will be Part B even so.

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Outcome of reviews

• Report from the Commission on the reviews undertaken under Article 30(9) and Article 73 of Directive 2010/75/EU on industrial emissions addressing emissions from intensive livestock rearing and combustion plants

• At http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2013:0286:FIN:EN:PDF.

•  No changes in respect of livestock.

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Outcome of reviews (II)

• “For the combustion of fuels in plants with a rated thermal input less than 50 MW, a clear potential for cost-effective abatement of air emissions was demonstrated and in a next step options for potential regulatory action will be further assessed in an impact assessment which will support the on-going review of the Thematic Strategy on Air Pollution.”

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Outcome of reviews (III)

• No need to amend existing or establish new EU-wide emission limit values at this stage for:

– diesel engines and recovery boilers within installations for the production of pulp;

– combustion plants within refineries firing the distillation and conversion residues from the refining of crude-oil;

– combustion plants firing gases other than natural gas; and

– combustion plants in chemical installations using liquid production residues as non-commercial fuel.

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Reporting

• Member State reports to European Commission:– On 2013, by September 2013;– On 2013-2016, by September 2017.

• Questionnaires in Commission Implementing Decision, December 2012, at

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:349:0057:0065:EN:PDF

• 2017 report to include details of every Part A installation.

• PRTR will show outcomes! See http://prtr.defra.gov.uk/

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Timeseries showing emissions of nitrogen oxides from the glass sector

Year Total Release Accidental Release No. of Facility2007 6,867,000 kg 0 kg 142008 10,178,000 kg 0 kg 132009 8,067,000 kg 0 kg 152010 8,515,000 kg 0 kg 162011 8,787,000 kg 0 kg 15