The ESA POSITION on BATS INCLUDED IN IED 2010/75/EU and IPPC 1996/61/EC DIRECTIVES
The ESA published a large reference document of Best Available Techniques (BATs) in 2009 which detailed the IPPC 1996/61/EC directive and the BATs for each type of Sealing Device available.
The relevant regulation has now changed to IED 2010/75/EU, and the technologies available within sealing devices has improved over the intervening years, hence the issuing of an updated BAT for sealing Devices.
The key point is that IED 2010/75 combines and merges 7 existing directives. (IPPC (1996/61/EC and 2008/1/EC); Large Combustion Plants (2001/76/EC); Waste Incineration (2000/76/EC); Solvent Emissions (1999/13/EC); and 3 existing TiO2 directives).
The MAJOR change is that the IED now strengthens the role of BREFs and BATs recommendations and includes the issuing of Permits to allow plants to operate, and the Permit Conditions which include emission limit values for ALL POULTANTS which are to be determined in BATs. IPPCs did not include permit conditions, so IED 2010/75 is MUCH tougher, and BATs are MUCH more important documents.
The types of installations covered by IED 2010/75 are much the same (Energy Industries; Metal Industries; Mineral Industries; Chemical Industries; Waste Management; and the “Other” industries including: Tanneries; Pulp and Paper; Wood based panels; Textiles; Slaughterhouses; Food and Drink; Surface treatment with organic solvents; and the ubiquitous Intensive Livestock Farming. All these documents focus on the process BREFs and general BATs.
The BATs conclusions are the reference for setting permit conditions and permits must contain the Emission Limit Values (ELVs) detailed in the BAT.
By their very nature BATs are dynamic and are required to be updated frequently and an 8 year minimum cycle is recommended.
The scope of the IED is heavily focused on the environment, with particular attention to:
· Emissions to air;
· Emissions to water;
· Emissions to land;
· Prevention and control of accidents;
· Waste prevention and recovery;
· Energy and water use;
· And now, noise; vibration; heat; and odour.
IED INDUSTRIAL EMISSIONS ARTICLE 13 FORUM.
This effectively is the working group, chaired by DG Environment in Brussels, which decides, via the expert working group (similar to the IPPC Information Exchange Forum), on the technical issues for all the new BREFs that are to be issued as part of IED. BAT conclusions are agreed by qualified majority, adopted via the implementing acts. This is similar to the Seville process of the IPPCs.
Mark Neal is a member of Article 13 forum on behalf of ESA.
There is a published list of active BREFs, and the programme of new and reviews of BREFs available from DG Environment. Recent work includes the recent draft on Large Volume Organic Chemicals (LVOC) and the Large Combustion Plant (LCP), and there has been a call for participation in the Waste Gas in Chemical Sector BREF.
ESA POSITION ON BREF AND BAT DOCUMENTS
ESA fully supports the concept of industry BREFs and BATs and the concept of operating permits, with emission limits set by BATs.
ESA wants to be an active member of Article 13 forum and ensure the very best sealing devices are used within the industries covered by BREFs, and to help set realist emissions targets for operating permits, based on the best Sealing Techniques being used.
ESA is committed to reducing emissions to the atmosphere, water sources and land. ESA fully supports efforts to reduce accidents, waste, energy use, water use, noise and odour.
IPPC Directive 2010/75/EU Reference documents are available at:
BAT reference Documents are available at: