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Application of BAT in IPPC/EIA Experience in EU Member States

Application of BAT in IPPC/EIA Experience in EU Member States. Per Ponsaing COWI. EIA and BAT applications. EIA application. IPPC application. BAT assessment. BAT assessment. Are the roles of BAT different in EIA and BAT?. What is BAT?. BAT = Best Available Techniques

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Application of BAT in IPPC/EIA Experience in EU Member States

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  1. Application of BAT in IPPC/EIA Experience in EU Member States Per Ponsaing COWI

  2. EIA and BAT applications EIA application IPPC application BAT assessment BAT assessment Are the roles of BAT different in EIA and BAT?

  3. What is BAT? • BAT = Best Available Techniques • Available: Developed to allow implementation in the relevant industrial sector under economically and technically viable conditions, taking into account the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they arereasonably accessible to the operator; • Techniques: Technology used + the way the installation is designed, built, maintained, operated and decommissioned.

  4. The BAT hierarchy • Process design/redesign to eliminate or reduce emissions to air, water, land, reduce formation of waste and energy consumption; • Substitution of fuel, chemicals, raw materials etc. by environmentally less harmful ones; • Minimisation and reduction by means of process control, maintenance, end-of-pipe technologies etc.

  5. Views on what BAT limits for a sector should represent • The highest emission levels allowed for any plant in the sector new or existing; • The highest emission levels allowed for new plants; • The emission levels achieved by the best handful of plants in the world; • The emission levels achieved by the very best performing plant in the world.

  6. Simplifying the permitting system in Denmark 1974 - 1991 1991 - 2004 2004 - Integrated permits Integrated permits Integrated permits Simplified integrated permits Branch regulations Branch regulations Single media permits or by order Single media permits or by order Single media permits or by order

  7. Integrated IPPC and EIA procedure

  8. Economy of BAT in EU • Are BAT plants viable? Do they suffer disadvantages in the face of international competition? • How will the adoption of BAT impact on the medium to long term survival of plants which have not already adopted BAT? • What does the analysis imply for “sectoral viability”

  9. Cement plants investigated in Europe

  10. Cement: 3 most important competitive disadvantages

  11. However... • Nevertheless plant investment is higher in Germany (per tonne average) than at counterpart plants in other EU countries sampled. German plants still find it worth investing. • Profitability at German plants owned by 3 major cement companies was reported to be similar to plants owned by the same company in other EU countries despite low capacity utilisation and strong environmental regulation in Germany.

  12. Non- ferrous metal plants investigated in Europe

  13. Secondary aluminium – strength of BAT vs. yield

  14. Profitability in the non-ferrous metal industry • It is argued that labour productivity, metal yield and energy reduction are all closely related to improvements in profitability; • Capital costs as measured by technical age are achieved at low expense provided that improvements are undertaken progressively; • IPPC drives to improve efficiency e.g. in terms of use of raw materials and energy, hence is consistent with improved profitability.

  15. Pulp & paper plants investigated

  16. Pulp & paper economy vs. environment

  17. General conclusions • No evidence that BAT companies were hindered from remaining competitive both nationally and internationally • It is important to prioritise environmental initiatives and time these initiatives carefully. Special consideration is recommended for those initiatives expected to yield a positive economic return

  18. How to determine BAT when there is no BAT documentation? • Most often the relevant sector will be covered by BREFs or other BAT documents. • Example: A producer of chemicals falling between • Large Volume Organic Chemicals (final BREF) • Organic Fine Chemicals (no BREF yet) • Polymers (if this is the kind of product – no BREF yet) • We suggest to start with LVOC BREF and supplement with other BAT information

  19. Example: Organic chemicals production • Other BAT information to consult: • UK guidance for the large volume organic chemicals sector (however not very different from BREF LVOC) • UK guidance for specialty organic chemicals • US EPA: Profile of the plastic resins and man-made fibres industry (if this is the kind of product) • HELCOM recommendation 23/11: Requirements for discharging of waste water from the chemical industry

  20. Example: Organic chemicals production • “Horizontal” BREFs: • BREF Emissions from storage of bulk or dangerous materials (2nd draft) • BREF Common waste water and waste gas treatment and management systems in the chemical sector (final BREF) • Energy efficiency (no BREF yet)

  21. Example: Organic chemicals production • General principles: • UK EPA: General Sector Guidance (to be used where there is no IPPC sector-specific guidance) • BREF Economic and cross media issues under IPPC (2nd draft)

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