The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau The review of the BREF on refineries : First findings and next challenges after the Call for wishes Michel Chaugny European IPPC Bureau 4 th July 2008 Assessment of implementation of the IPPC Directive Workshop for the Refineries sector Brussels - 4 th July 2008 The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Outline The Sevilla Process (brief recall) Purpose Actors The review of BAT Reference Documents (BREFs) Purpose Generic schedule REF BREF : which difficulties, which areas for improvement? General areas of concern Particular areas of concern The challenge of data collection The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau IPTS 180 staff 15 M/year budget + 5 M revenues European IPPC Bureau 18 staff Within the Competitiveness and Sustainability (C&S) Unit The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau The Sevilla Process A complex consensus building exercise with all main stakeholders based on sound techno-economic information The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Purpose Article 17(2) of the IPPC Directive (2008/1/EC) Exchange of information: The Commission shall organise an exchange of information between Member States and the industries concerned on best available techniques, associated monitoring, and developments in them. Every three years the Commission shall publish the results of the exchanges of information The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Actors (1) TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission Information Exchange Forum (IEF) 33 Technical Working Groups (TWGs) so far TWG Industry Member States NGOs Commission European IPPC Bureau (EIPPCB) The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission Actors (2) Information Exchange Forum (IEF) 33 Technical Working Groups (TWGs) European IPPC Bureau (EIPPCB) IEF members: oversee exchange of info. nominate experts to TWGs indicate degree of support on BREFs to DG ENV advise on BREF review programme decide on fundamental issues The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission Actors (3) Information Exchange Forum (IEF) 33 Technical Working Groups (TWGs) European IPPC Bureau (EIPPCB) BREF authors: permanent secretary to TWG steer work of TWG analyse info. from TWG seek for additional information propose texts for BREF present BREF at IEF The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission TWG Industry Member States NGOs Commission Actors (4) Information Exchange Forum (IEF) 33 Technical Working Groups (TWGs) European IPPC Bureau (EIPPCB) TWG members: collect and provide info. provide expert opinions contribute to discussions participate in TWG meetings comment on BREF drafts The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau The review of BAT Reference Documents (BREFs) A necessary and challenging task as an integral part of the Sevilla Process The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Why reviewing BREFs ? BAT is intrinsically a dynamic concept : New techniques emerge permanently New environmental processes are being successfully introduced into the industry Costs of techniques change New Member States in the playing field New products and new processes may enter in the scope (e.g. biofuels) Purpose of a BREF review : Not to rewrite the whole BREF Review new information which may affect BATs Correct errors and inconsistencies with other BREFs Improve user friendliness and fill possible gaps The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau 1 st TWG meeting 1 st Draft Final TWG meeting Technical Working Group (TWG) Analysis/validation of information Consultation Analysis/validation of information + drafting of the document Comments Site visits Final draft IEF Collection and submission of information Presentation Acceptation DG ENV BREF 2 nd TWG meeting Wish list for the review Review of a BREF Site visits Collection and submission of information Analysis/validation of information + drafting of the document Analysis/validation of information + drafting of the document Generic process for BREF reviews Site visits Adoption by the Commission Inter-service consultation If strictly needed The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Generic schedule for BREF reviews 1TWG reactivation11 Step No. BREF review step Expected step time (months) Accumulated time (months) 2Call for wishes1 22 3 3Kick-off meeting13 4 4New information (deadline)6 89 12 5Consultation and 2 nd meeting2 311 15 6Draft415 19 7TWG comments217 21 8Final meeting3 420 25 9Final draft323 28 10Presentation at an IEF meeting Subject to schedule of IEF meetings REF BREF Feb 08 May 08 Sep 08 Apr 09 Jun 09 End 09 Along 2010 The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Where are we in the process of BREF reviews? First series (33 docs) finished - Last one : Energy efficiency April 08) Reviews have started: Cement and lime (2005) Iron and steel, pulp and paper, glass (2006) Non-ferrous metals, common waste water/gas, tanneries (2007) Refineries, intensive rearing of poultry and pigs, ferrous metals (2008) Work programme : At least 3 reviews to launch every year 2008 : chlor-alkali, large volume organic chemicals 2009 : textile, cooling systems, monitoring 2010 : waste treatment, large combustion plants (tentative) The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau BREF on refineries : First findings after the call for wishes What do we have on the table ? The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Wishes Around 370 wishes from : 12 MS, among which only 2 Eastern new comers 3 industrial NGOs + 1 isolated company 1 environmental NGO EIPPCB The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau General areas of concern / improvement (1) Clarify position with / facilitate links to other BREFs Articulation with other vertical BREFs LCP (e.g. scope of application for fuel mixtures) Storages : cross references to avoid duplication Use of horizontal BREFs (e.g. cooling systems, monitoring, cross media) Stand-alone document or cross references ? User friendliness General lay out Internal automatic links Separate techniques and processes BAT/BAT-AELs summary tables Accessibility to all users Language More practical and operational executive summary The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau General areas of concern / improvement (2) Address the overall context evolution Sulphur Increase of input sulphur in crudes Decrease of output sulphur in products EU enlargement Full update of chapter 1 and others How to motivate new comers ? Scope Biofuels stored/mixed/processed in refineries (hydro treatment) Off shore refining of natural gas LNG storage and distribution The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau General areas of concern / improvement (3) BAT/BAT-AELs Specification/justification Averaging period Operating conditions Sampling and measuring references and standards Pertinent way of expressing performance Split views Clarify justification Methodology for solving ? New/existing installation Retrofitting cost Theoretical/real performance of BAT (Low NOx burners) Local conditions (safety, congestion) The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau General areas of concern / improvement (4) BUBBLE In principle : why not, but What in ? What about LCP, gas turbines, flares? What for ? What about dust and fine particulates, VOC? Need of flexibility for internal optimization: to which extent ? How to take into account the site complexity level ? In practise : NOx and SOx : simply not applicable with : ranges width as provided in the current BREF data justification as provided in the current BREF Set up the flexibility frame : from the strict sum of all unit-specific BAT-AELs ? to a fixed packaged bubble level ? The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Particular areas of concern / improvement (1) Hazardous substances in air PCDD/F More data on emission (catalytic reforming, FCC) Specific BAT and BAT-AEL required ? PM 10 and PM 2.5 Introduce BAT-AELs (FCC, combustion plants) Avoid confusion (secondary aerosols) CMR : heavy metals, toxic organic compounds More data Specific BAT-AELs in line with other EC regulations (LCP) Hazardous substances in water CMR : heavy metals, toxic organic compounds Specific BAT-AEL for each individual metal Specific BAT-AELs in line with other EC regulations (Water Framework) The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Particular areas of concern / improvement (2) Energy consumption and efficiency Find a common methodology for evaluation/comparison Collect and share homogeneous data Consider the complexity level (Nelson and Salomon indexes ?) Better use of the tools given in the ENE BREF Address energy monitoring Best ways to evaluate activity data for CO2 calculation (MRG) Continuous monitoring of CO2 concentration in key flue gases Consider flares Consider cross media effects Optimize energy consumption of additional SRU capacities Every BAT should be evaluated regarding their added CO2 More examples/data on internal/external reuse of heat Air pre-heating versus NOx performance The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Particular areas of concern / improvement (3) For some specific units (1/2) Boilers, heaters, furnaces Low NOx burners retrofitting : BAT-AELs to be reviewed ESP filtering for heavy fuel oil firing : technical adaptation FCC Review BATAEL ranges due to real performances observed : Non Pt - Low NOx oxidation promoters NOx and SOX-reducing catalysts SNCR performance achieved after real retrofitting Dust + PM using best 3 rd stage filters operated (Australia) Reconsider economics / cross media effects for : Scrubbing SCR (operability due to pressure drops) SOx-reducing catalysts The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Particular areas of concern / improvement (4) For some specific units (2/2) Flares No data available on flare emissions Report experience from recent flare reduction programmes Sulphur recovery units (SRU) Review recovery efficiency for all existing techniques Application to stand-alone lubricant refineries Handing and storages VOC monitoring, measurement, reduction : new techniques Impermeable bunds (Groundwater Directive) The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau A major challenge : data collection (1) Essential to the information exchange process IEF Guideline (IEF 20-4 Final) of June 2008 : Main gaps in the data provided so far to the EIPPCB Quantity and representativeness Data at installation level Key data for BAT determination (particular techniques, best performing installations, cross media effects, economic data) Data on particular topics (e.g. energy, residues/waste, fugitive emissions, monitoring, non standard pollutants or processes) Comparability of data (background and context information The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Data collection (2) BAT conclusions are useful when associated with good figures defining the environmental performance: Clear and appropriate units Reference conditions (e.g. flue gas oxygen level) Averaging period (daily/monthly/yearly ) Several ways of expression (concentration + mass flow + specific flow) General principles for the type, format and quality of data Complete data sets at the level of single installations Clear references to the applied techniques Information from best performing plants Specific issues under the remit of each TWG Sector-specific template for collecting information Time schedule for collecting and submitting data The REF BREF review : first findings and next challenges after the call for wishes Brussels 4/07/ European IPPC Bureau Thank you for your attention Michel Chaugny European IPPC Bureau Tel.: European IPPC Bureau