European IPPC Bureau

Industrial Emissions Directive (IED)

Drawing up of the WPC BREF document

WEI Annual Meeting

Utrecht 11-12 September 2014

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 European IPPC Bureau

Outline of this presentation

1 - The Industrial Emissions Directive (IED)

2 - The 'Sevilla process' / Challenges for the elaboration of BREFs under IED

3 - Starting the WPC BREF document elaboration

4 Useful information and links

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 European IPPC Bureau

1 - The Industrial Emissions

Directive (2010/75/EU)

IPPC Directive 2008/1/EC

Large Combustion Plants

(LCP) Directive 2001/80/EC

Waste Incineration
Directive 2000/76/EC

Directive on the limitation

of emissions of VOC from
solvents 1999/13/EC

Directives related to the

titanium dioxide industry Industrial Emissions Directive (IED)
78/176, 82/883 and 92/112 2010/75/EU
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 European IPPC Bureau

Industrial Emissions Directive 2010/75/EU (IED)

Key instrument for minimising consumption and the emissions of
industrial activities in Europe
'Successor' of IPPC Directive (merging 7 existing Directives)
Extended scope and provisions on soil and groundwater protection
Strengthened provisions on inspections, review of permit
conditions and reporting on compliance
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)
Strengthened role of BREFs and BAT
'BAT conclusions are secondary legislation
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 European IPPC Bureau

BAT-based
Structure of IED permit
conditions
Ch. I: Common provisions
Ch. II: Provisions for all activities listed in Annex I

Ch. III: Special provisions for combustion plants [> 50 MW]

Ch. IV: Special provisions for waste (co-)incineration plants
Ch. V: Special provisions for installations and activities using
organic solvents
Ch. VI: Special provisions for installations producing TiO2

Ch. VII: Committee, transitional and final provisions

Annexes
Sectoral minimum requirements
incl. emission limit values
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 European IPPC Bureau

Scope of IED - Annex I

Wide range of industrial/agro-industrial activities listed

in Annex I, of special interest for WPC sector:

6.10. (new activity) Preservation of wood and wood

products with chemicals with a production capacity
exceeding 75 m per day other than exclusively
treating against sap stain.

6.7. Surface treatment of substances, objects or

products using organic solvents, in particular for
dressing, printing, coating, degreasing, waterproofing,
sizing, painting, cleaning or impregnating, with an
organic solvent consumption capacity of more than
150 kg per hour or more than 200 tonnes per year.

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 European IPPC Bureau

Environmental scope of the IED

emissions
emissions
to water
to air
waste prevention
prevention energy &
and recovery
and control water use
of accidents
vibration
odour
noise heat

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 European IPPC Bureau

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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 European IPPC Bureau

'BAT Conclusions'
Part of BREF laying down conclusions on:

BATs, their description, information to assess their

applicability, emission levels associated with BAT,
monitoring, consumption levels, and, where appropriate,
relevant site remediation measures

new Adoption of BAT conclusions by Commission

=>Commission Implementing Decision
after Committee (Art.75) vote
taking into account opinion of stakeholder forum on BREF

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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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 European IPPC Bureau

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."

* New installations: BAT conclusions to be used as reference when issuing permit

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2 - The Sevilla process

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 European IPPC Bureau

What is the 'Sevilla process'?

A complex consensus-building exchange of information with
numerous stakeholders and underpinned by sound techno-
economic information that has been enshrined into law by:

Commission Implementing Decision 2012/119/EU

Legal basis for the exchange of information on BAT is

Article 13(1) of the Industrial Emissions Directive
the Commission shall organise an exchange of information
between Member States, industries concerned, non-governmental
organisations and the Commission; addressing:
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

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

Forum (IED Article 13) lead by the Commission: Forum members:

guidance to COM
industry, Member States, environmental NGOs
nominate in TWGs

European IPPC Bureau (EIPPCB) formal opinion on

BREFs

GLS WPC SA
(Glass) (Slaughterhouses BREF authors team:
(Wood Preservation )
and
lead TWGs
Animal by-products)
Industry Industry validate/check information
Industry
Member States Member States draft BREFs
Member States
NGOs NGOs present BREF to Forum
NGOs
Commission Commission
Commission
TWG members:
research information
35 Technical Working Groups (TWGs) peer review draft BREFs
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 European IPPC Bureau

The Sevilla process

Commission
TWG Activation Implementing Decision
Initial positions

TWG
Total duration

kick-off meeting
Bulk of info. needed
(incl. questionnaires)
Draft 1 (D1)
TWG Comments
Draft 2 (D2) Adoption of BAT
optional conclusions
Art 13 Forum through the IED
opinion Art. 75 Committee
Final TWG meeting

Final draft BREF

BAT
conclusions
24 29 months (without D2) BAT

29 39 months (with D2) conclu-

sions
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 European IPPC Bureau

Challenges of BREF elaboration under IED

Timing
BAT conclusions are prerequisite for the updating of IPPC permits
Crucial for implementation of the IED, need to speed up

Resources of stakeholders

Limited resources / personnel (incl. EIPPCB)

Data quality

Increased importance of BATc / BAT-AEL requires the acquisition

of better and more data (contextual information, applicability,
monitoring, costs), which may not be readily available

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 European IPPC Bureau

General strategy to shorten the time to delivery

Adopt a more focused approach

shorter BREFs
focus on BAT conclusions and target key environmental issues
Anticipate and prepare input
anticipation of the structure of the BAT and identification of the
data needs are crucial to devise appropriate questionnaires
Increased participation of TWG Members (shadow groups,
industry)
readiness to provide input (especially plant specific data) in
format and quality as required

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 European IPPC Bureau

Exchange of information on BAT: BREFs

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
200 to 1000
for future works (including suggestions for R&D) pages
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 European IPPC Bureau

Chapter 3/Current emission and consumption levels

Range of currently observed emission and consumption

levels for the overall process and sub-processes

Data presenting the whole sector

Qualified as far as possible with details on operating

conditions (e.g. percentage of full capacity, inclusion or
exclusion of other than normal operating conditions,
reference conditions)

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 European IPPC Bureau

Chapter 4 / Candidate BAT

10 heading structure
Description
Technical description
Achieved environmental benefits
Environmental performance and operational data
Cross-media effects
Technical considerations relevant to applicability
Economics
Driving force for implementation
Example plants
Reference literature
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Environmental performance and operational data

Actual plant-specific performance data from well-

performing plants

Emission levels, consumption levels of raw materials, water,

energy and amounts of residues/wastes generated

Accompanied by the relevant contextual information

Details of relevant operating conditions

Emission monitoring issues related to the use of technique

Key for deriving environmental performance levels

associated with BAT
Data collection step is crucial for determining BAT
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 European IPPC Bureau

Data collection for determining BAT

The information on key environmental issues is obtained
through sector-specific questionnaires

representative, reliable, real-life data, relevant contextual/

operational information on installation level
Pre-selection of well-performing plants/installations
willing to participate
Member State representatives sending/
collecting questionnaires from operators
(providing preliminary quality check)

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 European IPPC Bureau

Individual BAT conclusion (standard format)

x. In order to reduce VOC emissions from process AA, BAT is
to use one or a combination of the techniques given below.

Technique Description Applicability

a aa [description] new plants
b bb existing plants
c cc
The BAT-AELs for VOCs are:
- For new installations: 10 20 mg C/Nm3 as a daily average
under reference conditions xx, yy,
- For existing installations: 20 30 mg C/Nm3 as a daily average
under reference conditions xx, yy,

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 European IPPC Bureau

BAT conclusion (real example with AEPL)

8.1.3 Water and waste water management

4. In order to reduce the generation and the pollution load of waste water from wood storage and
preparation, BAT is to use a combination of the techniques given below.
Technique Applicability
Restricted applicability when high purity and brightness is
a Dry debarking (description see Section 8.7.2.1)
required with TCF bleaching
Handling of wood logs in such a way as to avoid the
b Generally applicable
contamination of bark and wood with sand and stones
Paving of the wood yard area and particularly the surfaces Applicability may be restricted due to the size of the wood
c
used for the storage of chips yard and storage area
Controlling the flow of sprinkling water and minimising
d Generally applicable
surface run-off water from the wood yard
Collecting of contaminated run-off water from the wood Applicability may be restricted by the degree of
e yard and separating out suspended solids effluent before contamination of run-off water (low concentration) and/or
biological treatment the size of the waste water treatment plant (large volumes)

The BAT-associated effluent flow from dry debarking is 0.5 2.5 m3/ADt.
This performance level is not an emission level associated with the Best Available Techniques in
the sense of Article 3(13) of the Industrial Emissions Directive (2010/75/EU).

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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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 European IPPC Bureau

3 Starting the Wood and Wood

Products Preservation with
Chemicals (WPC) BREF document
elaboration

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 European IPPC Bureau

The steps completed so far

Step BREF review WPC BREF drafting

milestones time frame
EIPPCB letter dated
0.1 Activation of the TWG
4/07/2014

Nominations of Deadline was 1/09/2014

0.2
TWG members (64 TWG members)

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the next major steps

Step BREF review milestones WPC BREF drafting
time frame
Call for expression of initial
0.3
positions
Est. 1st quarter
1. Kick-off meeting (KoM)
2015
1.1 Data collection

2. Draft BREF document (D1)

3. Final TWG meeting Around mid-2017

Adoption and publication in
2018
the OJ
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 European IPPC Bureau

What can TWG members/WPC industry do to

prepare for the elaboration of the WPC BREF?
Become familiar with the BREF 'Guidance' (2012/119/EU)
Look at recently adopted BAT conclusions (e.g. Refining of Mineral Oil
and Gas; Pulp, Paper and Board; Chlor-Alkali; Cement, Lime and MgO)
Identify key environmental issues for WPC/WPC sub-sectors and the
techniques (candidate BAT) most relevant to address these
Be prepared to provide the necessary information on the candidates
(following '10 heading' concept)
Identify well-performing plants that will participate in the collection of
plant-specific information/data (questionnaires)
Have potential BAT conclusions for WPC sector in mind and ensure the
necessary information is submitted, to fulfil content/format
requirements and ensure clear, precise, complete and consistent BATc
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4 Useful information and links

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 European IPPC Bureau

Useful information and links

European IPPC Bureau (EIPPCB)

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

Industrial Emissions Directive(IED)

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:334:0017:0119:en:PDF

"Guidance" - Commission Implementing Decision 2012/119/EU

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:063:0001:0039:EN:PDF

Guidance on Interpretation and Implementation of the

IPPC Directive (DG ENV)
http://ec.europa.eu/environment/industry/stationary/ippc/general_guidance.htm

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 European IPPC Bureau

Thank you for your attention

Contact:
European Commission
Joint Research Centre, Institute for Prospective Technological Studies
Sustainable Production and Consumption Unit, European IPPC Bureau

Edificio EXPO, C/ Inca Garcilaso, 3, E-41092 Sevilla/Spain

WPC functional mailbox address: JRC-IPTS-EIPPCB-WPC@ec.europa.eu

Tel: +34 954 488 391 (Gabriela) gabriele.klein@ec.europa.eu

+34 954 488 467 (Georgios) georgios.chronopoulos@ec.europa.eu

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

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