Workshop on Directive 96/61/EC Ankara November 5th

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Workshop on Directive 96/61/ECAnkaraNovember
5th 6th 2009

• Frank Clinton, EPA Ireland

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BREFs (BAT Reference Documents) in setting BAT
for SMEs in Turkey

• November 6th 2009

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Where did BREF come from?

• IPPC Directive 96/61/EC
• Article 16 Exchange of Information
• Article 16(2)
• The Commission shall organise an exchange of
  information between Member states, and the
  industries concerned on the best available
  techniques, associated monitoring, and
  developments in them
• Note when I mention BAT, I mean best
  available techniques

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Where did BREF come from?

• IPPC Directive 96/61/EC
• Article 16 Exchange of Information
• Article 16(2)
• The Commission shall organise an exchange of
  information between Member states, and the
  industries concerned on the best available
  techniques, associated monitoring, and
  developments in them
• Note when I mention BAT, I mean best
  available techniques

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So, what is BAT ? (1)

• The Directive 96/61/EC defines it
• 'best available techniques shall mean the most
  effective and advanced stage in the development
  of activities and their methods of operation
  which indicate the practical suitability of
  particular techniques for providing in principle
  the basis for emission limit values designed to
  prevent and, where that is not practicable,
  generally to reduce emissions and the impact on
  the environment as a whole.

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So, what is BAT ? (1)

• The Directive 96/61/EC defines it
• 'best available techniques shall mean the most
  effective and advanced stage in the development
  of activities and their methods of operation
  which indicate the practical suitability of
  particular techniques for providing in principle
  the basis for emission limit values designed to
  prevent and, where that is not practicable,
  generally to reduce emissions and the impact on
  the environment as a whole.

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So, what is BAT ? (2)

• In plain English -
• BAT describes the practical techniques that can
  be used to set emission limit values
  (ELVs).and through the achievement of these
  ELVs we can successfully reduce emissions and
  consequently minimise the impact on the
  environment.

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So, what is BAT ? (3)

• 'best shall mean most effective in achieving a
  high general level of protection of the
  environment as a whole.
• 'available techniques shall mean those developed
  on a scale which allows implementation in the
  relevant industrial sector, under economically
  and technically viable conditions, taking into
  consideration 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 shall include both the technology
  used and the way in which the installation is
  designed, built, maintained, operated and
  decommissioned.

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So, what is BAT ? (3)

• 'best shall mean most effective in achieving a
  high general level of protection of the
  environment as a whole.
• 'available techniques shall mean those developed
  on a scale which allows implementation in the
  relevant industrial sector, under economically
  and technically viable conditions, taking into
  consideration 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 shall include both the technology
  used and the way in which the installation is
  designed, built, maintained, operated and
  decommissioned.

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So, what is BAT ? (3)

• 'best shall mean most effective in achieving a
  high general level of protection of the
  environment as a whole.
• 'available techniques shall mean those developed
  on a scale which allows implementation in the
  relevant industrial sector, under economically
  and technically viable conditions, taking into
  consideration 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 shall include both the technology
  used and the way in which the installation is
  designed, built, maintained, operated and
  decommissioned.

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What is a BREF?

• Before we elborate on what a BREF is ,
• .lets clarify what its not !

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What a BREF is not!!!

• Its not a standard which has to be met
• Its not a set of Rules
• Its not a prescription of costly obligations
  which the SME has to conform to.

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What is a BREF?

• A BREF is a BAT reference document
• A BREF is simply a documentary output from an
  information exchange
• A compilation of information that may be useful
  within the Member State in the process of setting
  or determining a National or site specific BAT
• A BREF is the product of 2 3 three year process
  involving up to 100 experts (including industry
  experts, equipment suppliers, regulators NGOs)
• The life time of a BREF is between 5 and 7 years.
  

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Who orgainses the BREF process?

• The Integrated Pollution Prevention Control
  Bureau (IPPCB), Seville, Spain.
• The Sevilla Process

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BREF so far..

• So far, in its 12 years of existence, the Bureau
  has produced 35 BREFs covering a broad
  cross-section of IPPC sectors, cross media issues
  and there is 1 further BREF on a non-IPPC sector
  mining.
• The Bureau is currently engaged in the new
  process of revision of these Community reference
  documents.

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How might BREFs be useful in Turkey?

• In setting targets to be aimed at in Turkey
• As an aid to the consultation process leading up
  to BAT
• In defining BAT for Turkey
• In discussions between regulators and industry
• In discussions between regulators, industry and
  all other interested parties
• In making comparisons with other countries
• In making the Turkish case in Europe

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SMEs and BREF

• Which SMEs will be affected by BREFs?
• If an SME in Turkey is carrying on an activity
  which is specified on Annex I of the Directive
  96/61/EC, then the relevant BREF will apply to
  that operation.
• How that BREF assists in defining National BAT
  in Turkey is a matter for the authorities in
  Turkey to decide.
• Usually, the SME representative body, the
  regulator, suppliers of abatement equipment and
  NGOs work together to decide what is possible
  within the definition of BAT.

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Annex I

• Sectors specifically identified in Annex I are
• Energy industries
• Production processing of metals
• Mineral industry
• Chemical industry
• Waste management
• Others (including paper board, textiles,
  tanning, food processing, rendering, poultry
  production, surface treatments using solvents,
  graphite).

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a working example in a growing sector in
Turkey
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Layout of a BREF (e.g. cement)

• Executive Summary Preface the background
• Main Chapter - Cement industry explained in
  detail
• Process types
• Raw materials used
• Unit operations
• Energy issues
• Typical emisssions
• Techniques to consider in setting BAT
• For resource efficiencies
• For process selections
• For NOx control
• For SOx control
• For dust control, and so on.
• Emerging techniques, e.g., SNCR for NOx
  reductions

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How will BREF work in the Cement sector?

• How is cement produced in Turkey ?
• Look at the methods used across the EU (BREF
  Note)
• How do these compare to the methods used in
  Turkey?
• Are cement production methods in Turkey
• As effective in protecting the environment as in
  EU MS?
• As energy or resources efficient as those in EU?
• Likely to produce similar amounts of waste as in
  plants in EU?
• What could change in the Turkish industry to
  bring production methods into line with the EU
  cement plants in the respect of adequately
  protecting the environment?

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Emissions to air from the Turkish cement sector

• For emissions to atmosphere in Turkey-
• SOx, NOx, Particulates (dust),
• Typically what concentration (mg/Nm3) or mass
  emission (kg/hr) for each pollutant arises at
  Turkish cement plants?
• ---------THE TEST-----------
• How do these numbers compare to the ranges in the
  BREF?

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After the Test

• The regulator, the industry / representative body
  must determine what must change in order to meet
  the ranges set out in the BREF to protect the
  environment.
• Select the most appropriate
• Best available manufacturing process
• Best available abatement equipment
• Least wasteful processing technique
• ..taking cross media factors and the BAT
  definition into account.

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remembering

• 'best shall mean most effective in achieving a
  high general level of protection of the
  environment as a whole.
• 'available techniques shall mean those developed
  on a scale which allows implementation in the
  relevant industrial sector, under economically
  and technically viable conditions, taking into
  consideration 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 shall include both the technology
  used and the way in which the installation is
  designed, built, maintained, operated and
  decommissioned.

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remembering

• 'best shall mean most effective in achieving a
  high general level of protection of the
  environment as a whole.
• 'available techniques shall mean those developed
  on a scale which allows implementation in the
  relevant industrial sector, under economically
  and technically viable conditions, taking into
  consideration 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 shall include both the technology
  used and the way in which the installation is
  designed, built, maintained, operated and
  decommissioned.

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for NOx

• What techniques must be employed to ensure that
  the emission of NOx is brought within the BREF
  range of
• 500-2000 mg/Nm3
• (for example in the case of a Cyclone preheater
  without heat recovery)
• or within the BREF range of
• 300-1400 mg/Nm3
• (for example in the case of a Cyclone preheater
  with heat recovery)
• When you have identified the techniques. You
  have defined BAT!

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. For dust

• What techniques must be employed to ensure that
  the emission of dust is brought within the BREF
  range of
• 5 to 200 mg/Nm3
• the BREF recognises that dust abatement equipment
  is now so advanced that emission of 10 mg/Nm3 are
  easily achieved in kilns and mills at modern
  cement plants in the EU
• When you have identified the techniques. You
  have defined BAT!

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example of a smaller SME

• 26 of SME output in Turkey is in metallic
  goods (OECD, 2004)
• We will look at an example of a small SME
  involved in galvanising (lt20 workers involved)
• It would be covered by Annex I - Category 2.3(c)
• application of protective fused metal coats with
  an input exceeding 2 tonnes of crude steel per
  hour.

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Galvanising SME BREF

• The relevant BREF is
• Reference Document on Best Available Techniques
  in the Ferrous Metals Processing Industry (Dec
  2001)
• The relevant part is Part C
• (page 367 of 538 (!))
• Batch Galvanizing
• The relevant paragraph in part C is C.5.
• (page 387 of 538)
• Best Available Techniques for Batch Galvanizing

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Galvanising SME BREF (2)

• This BREF relies less on emission limits / AEL
  ranges and more on methods to achieve reduction
  of pollutant releases.
• Advice is given on methods for degreasing
• Advice is given for cleaning away other
  contaminants on the metal to be galvanized
• Advice is given on HCl pickling
• (including an associated HCl emission
  level of 2 30 mg/Nm3).
• Select the method to reduce emisison and / or to
  achieve the AEL range and you have defined BAT

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General comments on the BREfs

• They are very comprehensive
• They are very technical
• They are carefully written and the EIPPC Bureau
  tries, as far as possible, to make them
  readable.
• May not be available in Turkish, so this is a big
  challenge for workers in Turkey.

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General comments on the BREFs

• They are available on the EIPPCB website
• http//eippcb.jrc.ec.europa.eu
• or
• http//www.epa.ie
• if you look them up on the Irish EPA website,
  you can also see the Irish BAT Notes and you
  can see how BAT has been defined for Ireland

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In summary

• BREFs are the result of an information exchange
• They are not binding
• but pay attention to developments in the new
  IED!!!
• They were intended (by the IPPC Directive) to be
  used as an aid to defining BAT
• In using BREFs to define BAT you should consider
  also
• Economic factors
• Practical issues
• Specific Turkish issues such as climate, water
  availability, availability of equipment suppliers
  etc
• Reasonableness

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Thank you to the interpretorsThank you for
listenting

• f.clinton_at_epa.ie