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

Per Ponsaing COWI

Consultant: CMDC Joint Venture

EIA and BAT applications

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

Consultant: CMDC Joint Venture

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 are reasonably accessible to the operator; Techniques: Technology used + the way the installation is designed, built, maintained, operated and decommissioned.

Consultant: CMDC Joint Venture

The BAT hierarchy 1. Process design/redesign to eliminate or reduce emissions to air, water, land, reduce formation of waste and energy consumption; 2. Substitution of fuel, chemicals, raw materials etc. by environmentally less harmful ones; 3. Minimisation and reduction by means of process control, maintenance, end-of-pipe technologies etc.

Consultant: CMDC Joint Venture

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.

Consultant: CMDC Joint Venture

Simplifying the permitting system in Denmark

1974 - 1991 1991 - 2004 Integrated permits Integrated permits Single media permits or by order

Consultant: CMDC Joint Venture

Branch regulations Single media permits or by order 2004 Integrated permits Simplified integrated permits Branch regulations Single media permits or by order

Integrated IPPC and EIA procedure

Activity/Month

Screening for EIA

1 2 3 4 5 6 7 8 9 10 11 12 13 14

Call-in of ideas and alternatives IPPC application and EIA report + public announcement of the application IPPC permit and addendum to physical plan Hearing of stakeholders including the applicant Revision of permit and plan Public hearing Revision of permit and plan Political decisions Complaining period

Consultant: CMDC Joint Venture

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”

Consultant: CMDC Joint Venture

Cement plants investigated in Europe Countries BAT Middle Poor Germany Italy Spain UK 2 1 Poland Total

Consultant: CMDC Joint Venture

3 5 6 1 1 13 1 1 4 4 3 13 5 5 4 29 All plants 8 7

Cement: 3 most important competitive disadvantages Importance Germany Italy Spain UK Poland First Labour costs Second Thrid Environ mental regulation Environ mental costs

Consultant: CMDC Joint Venture

Environ mental costs Age of plant Labour costs Labour quality Location Location Age of plant Quality of raw material Size of plant Age of plant Size of plant Manufac turing costs

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.

Consultant: CMDC Joint Venture

Non- ferrous metal plants investigated in Europe Metal produced Primary copper No of plants in EU 4 Secondary copper 6 Secondary aluminium 50 Secondary lead Salt slag Waelz oxide 30 10 7 11 7 4 No of plants visited 4 5 17

Consultant: CMDC Joint Venture

Secondary aluminium – strength of BAT vs. yield

Consultant: CMDC Joint Venture

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.

Consultant: CMDC Joint Venture

Pulp & paper plants investigated Location → Environmental performance ↓ A mills B mills C mills Total no of mills Pulp 5 5 1 11 3 2 EU Paper 5 WLC 5 5 10

Consultant: CMDC Joint Venture

1 3 3 7 Canada Pulp Brazil Pulp 1 2 3

Pulp & paper economy vs. environment Perfor mance → Kraft pulp White Line Chipboard Copy paper 30 45 Economic: Good Environmental: Good 60 Economic: Poor Environmental: Good 25 Economic: Good Environmental: Poor 5 Economic: Poor Environmental: Poor 10 10 35 45 10 15 10

Consultant: CMDC Joint Venture

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

Consultant: CMDC Joint Venture

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

Consultant: CMDC Joint Venture

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

Consultant: CMDC Joint Venture

Example: Organic chemicals production “Horizontal” BREFs:

• BREF Emissions from storage of bulk or dangerous

materials (2 nd draft)

• BREF Common waste water and waste gas treatment and

management systems in the chemical sector (final BREF)

• Energy efficiency (no BREF yet)

Consultant: CMDC Joint Venture

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 (2

nd draft)

Consultant: CMDC Joint Venture