Transcript 13, 03FEB2010, A Lecloux, ENVICAT.ppt

Industrial perspective of
source control options
Prof. André Lecloux (Envicat).
ScorePP Dissemination workshop
Lyngby (DK) February 3, 2010
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Scope of the presentation
• The Water Framework Directive
– Priority substances and EQS values
– Point sources: mixing zone concept
• The source control options
– Review of the options
– How to choose the “best” option
• The chemical industry point of view
• Conclusion
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The Water Framework Directive
• Objectives
 protection of all types of waters
 prevents further deterioration
 ensures the progressive reduction of pollution
 promotes sustainable water use
• The priority substances
 definition of EQS values
 priority hazardous substances
• River Basin Management Plan
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Priority substances and EQS Directive
• Definition of a priority list of chemicals
• Reduction of discharges, emissions and
losses of priority substances
• Cessation or phasing-out of discharges,
emissions and losses of priority hazardous
substances (with PBT characteristics)
• EQS values for annual average and
maximum acceptable concentrations
• Second priority list under review
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River Basin Management Plan
• MS should develop a plan to reduce the pollution
and to promote sustainable use of water
• These Management plans could foresee the
revision of the industrial permits.
• The permit generally defines ELV based on the
concentration measured in the plant effluent
• The WFD defines EQS, i.e. concentration
measured in the water body after some dilution in
the surface water
• Need to define a “mixing zone” to avoid the
confusion between EQS and ELV
• A guidance has been finalised
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The source control options
Review
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Substitution
IPPC Directive: the BAT approach
Process improvement
Specific Regulations
Voluntary initiatives
Waste water treatment
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The substitution (1)
• Phase out would imply substitution of PHS
• Substitution is a risk management option among
others and should be compared to others
• The need for substitution should be determined by
the risk of a particular chemical in a particular
application: fit to use
• Economical aspects should be considered not
only for producer but also for downstream users
• Successful substitution needs reliable long-term
perspective for economical reasons
• Difficulty to compare different types of risk
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The substitution (2)
• Impossible for unavoidable by-products like HCB,
HCBD or PAH without stopping huge parts of the
chemical industry (chlorine and coal tar industry)
• In the case of pesticides a toolbox of various
Modes of Action has to be maintained for each
crop, to avoid the development of pest resistance
• As the available toolbox could vary from country
to country, it is almost impossible to find
substitutes at European level.
• EU is currently reviewing the list of authorized
pesticides
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Substitution: a few examples (1)
• Substitution of 1,2-Dichloroethane (EDC) is
impossible when used as raw material for vinyl
chloride and PVC production but is possible when
used as solvent or as raw material for TRI and PER
production
• Di(2-ethylhexyl)phthalate (DEHP) can be
substituted as plasticizer for PVC by Di(isononyl)
phthalate (DINP) and Di(isodecyl) phthalate (DIDP).
This is a unique example where the same
producers are involved but this move requires
large investment
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Substitution: a few examples (2)
• The substitution of poly-bromodiphenyl ethers
leads to a huge number of products each of them
being specific for a given application. This implies
a complicated management of plastic processing.
• Substitution of cadmium as pigment, PVC
stabilizers, and in brazing and soldering alloys has
been accomplished
• The substitution of cadmium in batteries is
possible in consumer applications, but will be
based on market/performance/price attributes
rather than legislation.
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IPPC Directive: the BAT approach
• The IPPC Directive defines the Best Available
Techniques as well as the acceptable level of
emissions of pollutants (BREF document). It will
be revised to include the WFD priority substances
• Problem: relationship between ELV and EQS
• The Directive applies only to the large industrial
units but not to the smaller ones
• Up to now, the implementation of the IPPC
Directive is relatively limited. In principle the
permit renewal should force BAT application.
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Process improvement
• Independently of the very general BAT
approach, the industry could consider
specific process improvements by
– Modifying the process conditions ( temperature,
pressure, new catalysts,…) to increase the
selectivity and reduce the production o f byproducts
– Installing specific emission abatement unit
• This implies new investments
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Specific regulations
• For most of the priority substances, there are
already many EU regulations limiting their
use or controlling their specific emissions
• On top of that, many countries have added
their own national regulation to control
emissions and uses
• Examples: PAH, alkyl-phenols, mercury,
VOC,…
• The key question is how to effectively control
the application of these regulations
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Voluntary initiatives
• Well before the WFD, the industry implemented
voluntary initiatives to reduce its emissions.
• Efficient approach: realistic, economically
acceptable, technically feasible, improved image.
• In terms of positive image, much higher benefit of
voluntary agreements compared to legally binding
approach.
• Legally binding instruments: often politically
driven with blue sky goals (for example: beyond
the BAT, zero level, complete phase out)
• Difficulty: poor confidence of authorities, public
and NGOs in industry willingness to really reduce
emissions. Necessity of an external audit
• Several examples are given here after
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Euro Chlor voluntary program (1)
• Include environmental, social and economic
factors in all strategic business decisions;
• Optimise energy efficiency in chlorine
production;
• Reduce water usage through recycling;
• Continuously reduce polluting emissions to
water, air and land;
• Use performance indicators with moving
targets, like energy consumption, COC and
mercury emission and eco-toxicological
knowledge
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Euro Chlor voluntary program (2)
COC emissions to air
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Euro Chlor voluntary program (3)
Mercury emissions: g / t chlorine capacity
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PVC Producers Vinyl 2010 initiative
• Bisphenol A phased out of PVC production in 2001
• Phthalate risk assessments completed (2005) and
published (2006). DEHP replaced
• Stabilizers:
– Cadmium stabilisers phased-out in EU-15 (2001) and in
EU-27 in 2007
– 50% reduction in lead stabiliser foreseen for 2010 in
EU-27 and phase-out in 2015.
• Recycling: Several technologies available
– exponential increase from 18kT in 2004 to 200kT in 2008
– recycling of pipes, windows, flooring, roofing and
waterproofing membranes, coated fabrics
• Recognition of Vinyl 2010 as a partner by UN 18
Commission for Sustainable Development (2004)
Waste water treatment Plants (WWTP)
• The Task 5.6 of the project critically
reviewed all the types of WWTP
• Their efficiency in removing various
priority pollutants was measured or
estimated
• This “end of pipe” option should also
be considered to reduce releases to the
aquatic environment
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How to choose the “best” option
• For each given use or type of source, criteria
are needed to assess each option
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Technical feasibility
Technical efficiency
Probability to reach WFD target
Operational costs
Investment costs
Impact on the supply chain
Impact on employment
Impact on the drinking water production
Delay of implementation
• Use of three level scores for each criteria
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USE 1
USE 2
………
USE u
Pollutant 1
Criteria 1 Criteria 2 ……….
Measure 1 Score 111 Score 112 ……….
Measure 2 Score 121 Score 122 ……….
………….
…………
Measure m Score 1m1 Score 1m2 …………
Measure 1 Score 211 Score 212 ……….
Measure 2 Score 221 Score 222 ………..
…………
…………
Measure m Score 2m1 Score 2m2 ………..
……… Criteria n Total score
……….. Score 11n
………. Score 12n
………. Score 1mn
………. Score 21n
……….. Score 22n
……….. Score 2mn
Measure 1 Score u11 Score u12 ………. ………. Score u1n
Measure 2 Score u21 Score u22 ……….. ………. Score u2n
……
…………
Measure m Score um1 Score um2 ………… .........
Score umn
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The scoring process
• If we note the score Sijk
– the index “i” is related to the use,
– the index “j” is related to the measure and
– the index “k” is linked to the criteria.
• The total score of a measure x for a
given use y is given by sum on k of
Syxk .
• The total score of a measure x for all
uses/sources of a pollutant is given by
sum on i and k of Sixk .
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Estimation of the scores
• It is important to point out that the scores
will strongly depend on the local conditions,
the type of stakeholders involved, the way
the costs are shared, the budget available,
the existing facilities, …
• As a function of these conditions, the
stakeholders could give a increased weight
to one or two criteria, giving more
importance to one or two aspects of higher
relevance for the specific situation.
• There is no universal best option, but only
option that solve a local or regional problem
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Conclusion
• If the chemical industry is committed to reduce
emissions and to protect the aquatic environment,
it is important that the various options could be
reviewed by the various stakeholders involved
• The right balance should be found between
environmental, social and economic aspects, the
three pillars of the sustainable development.
• Ideological position like zero emission of complete
phase out should be avoided and pragmatic
solutions favoured.
• The down stream users should be involved when a
substitution is considered.
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Thank you for your attention
Question time
[email protected]
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