MEETING REPORT INTRODUCTION - The European …eippcb.jrc.ec.europa.eu/reference/BREF/cak_kom_3009.pdfFS/EIPPCB/CAK KOM report September 2009 3 Table of Contents 1 INTRODUCTION TO THE

Edificio Expo, C/ Inca Garcilaso,3 ES-41092 Seville, - Spain Telephone: +34-95 44 88 284. Fax: +34-95 44 88 426. E.mail: [email protected], Internet: http://eippcb.jrc.ec.europa.eu/

EUROPEAN COMMISSION DIRECTORATE-GENERAL JRC JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production and Consumption Unit European IPPC Bureau

Seville, 18 November 2009 J06-SPC/FS/ARES(2010)37828

KICK-OFF MEETING

FOR THE REVIEW OF THE

REFERENCE DOCUMENT ON BEST AVAILABLE TECHNIQUES IN THE

CHLOR-ALKALI MANUFACTURING INDUSTRY

SEVILLE, 30 September – 2 October 2009

MEETING REPORT

INTRODUCTION The technical working group (TWG) on the review of the Reference Documents on Best Available Techniques for the Chlor-Alkali Manufacturing Industry (CAK BREF), met for its plenary meeting from 30 September to 2 October 2009 at the European IPPC Bureau (EIPPCB) of the Institute for Prospective Technological Studies (IPTS) of the Joint Research Centre (JRC) of the European Commission (EC). This record represents a summary of this first plenary meeting. Technical Working Groups are set up according to the work programme ratified by the Information Exchange Forum (IEF) to facilitate the exchange of information on best available techniques (BAT), associated monitoring and developments in them under Article 17 (2) of Directive 2008/01/EC of the European Parliament and of the Council concerning Integrated Pollution Prevention and Control (IPPC). The IPPC Directive (2008/1/EC) lays down a framework requiring Member States to issue operating permits for certain installations carrying out industrial activities described in its Annex I (energy industries, production and processing of metals, mineral industry, chemical industry, waste management, and other activities). The Directive stipulates that permits must contain conditions based on BAT as defined in Article 2(12) of the Directive, to achieve a high level of protection of the environment as a whole. BAT reference documents (BREFs), such as the Chlor-Alkali (CAK) BREF, represent one of the considerations to be taken into account when determining BAT according to Annex IV to the IPPC Directive. The BREFs serve as information and guidance for regulators within the procedure of issuing permits to installations. BREFs are also used by the industry concerned in preparing applications for operating permits. BREFs are also a source of information for other interested parties on ways to minimise the environmental impacts of industry.

http://eippcb.jrc.ec.europa.eu/


FS/EIPPCB/CAK KOM report September 2009 2

BAT is a dynamic concept because new measures/techniques may emerge, science and technologies are continuously developing, or new environmental processes are being successfully introduced into the industry. Since the elements of BAT change over time and the industry develops, BREFs have to be reviewed and updated as appropriate. The work on the original CAK BREF was conducted between 1997 and 2000 and it was formally adopted by the European Commission in December 2001 (available on the European IPPC Bureau website at http://eippcb.jrc.ec.europa.eu/). The CAK BREF serves as information and guidance for regulators within the procedure of issuing permits to chlor-alkali plants. The CAK BREF is also used by other stakeholders such as the industry concerned in preparation for operating permits. The task of this TWG is to carry out a detailed exchange of information between Member States and the industry concerned on BAT and associated monitoring in order to review the BAT Reference Document for the Chlor-Alkali Manufacturing Industry, which will assist Member States in writing IPPC permits for industrial installations. The purpose of reviewing a BREF is not to rewrite the whole document, but to improve and update it. This means keeping as much of the document as possible, however, new or updated information provided may create new sections or may alter sections in the BREF. Furthermore, this means, in particular, reflecting developments in techniques/technology or in the way they are applied that might have an impact on BAT. This particularly implies investigating whether the ‘emerging techniques’ quoted in the original BREF are now available. It also implies, now that the first series of BREFs is finished, that the TWG try to take advantage of the exchange of information for the whole series of BREFs; techniques used in other sectors may be available in the sector under review. During the review of a BREF, any necessary corrections should be made and the readability and user-friendliness of the document should be improved (with streamlining or restructuring if necessary), through cross-referencing to other BREFs, for example. Missing information, e.g. identified in the concluding remarks of the original CAK BREF document should be looked for and provided by the TWG members. The first plenary TWG meeting, also called kick-off meeting, officially started the aforementioned work. This record does not strictly follow the chronological order of the meeting discussion but rather is structured according to issues that will help in the development of the review of the CAK BREF.



Table of Contents

1 INTRODUCTION TO THE MEETING ......................................................................................... 4 2 MEETING STRUCTURE AND STRUCTURE OF THE MEETING REPORT ........................ 6 3 CONCLUSIONS ................................................................................................................................ 8

3.1 General Issues ............................................................................................................................ 8 3.1.1 Interface between the CAK BREF and other BREF documents and links to EU

legislation......................................................................................................................... 8 3.1.2 Consistency within the series of BREFs........................................................................... 8 3.1.3 Basic structure of the CAK BREF ................................................................................... 9 3.1.4 General updating ............................................................................................................ 10 3.1.5 Glossary of terms and abbreviations .............................................................................. 11

3.2 Environmental management ..................................................................................................... 13 3.2.1 Environmental relevance of the CAK industry (Chapter 1) ........................................... 13 3.2.2 Environmental management systems (EMS).................................................................. 13

3.3 Issues regarding the mercury cell process ................................................................................ 15 3.3.1 Historical contamination ................................................................................................ 15 3.3.2 Specific issues regarding Mercury cell plants ................................................................ 15 3.3.3 The phasing out of mercury and interim conditions ....................................................... 17 3.3.4 Conversion of mercury cell plants into membrane technology....................................... 18 3.3.5 Decommissioning of mercury cell plants ....................................................................... 19

3.4 Issues regarding diaphragm cell plants..................................................................................... 20 3.5 Issues regarding the membrane cell plants ............................................................................... 21 3.6 Other issues .............................................................................................................................. 22

3.6.1 Auxiliary processes (Chapter 2) ..................................................................................... 22 3.6.1.1 BREF Section 2.4.1 Salt unloading and storage..................................................... 22 3.6.1.2 BREF Section 2.4.2 Brine purification and resaturation ........................................ 22 3.6.1.3 BREF Section 2.4.3 Chlorine production, storage and handling............................ 23 3.6.1.4 BREF Section 2.4.5 Hydrogen production, storage and handling.......................... 24

3.6.2 Specific issues regarding BREF Section 4.1 All cell plants ........................................... 25 3.6.3 Chlorine transport .......................................................................................................... 26 3.6.4 Monitoring of emissions................................................................................................. 26 3.6.5 Energy consumption/energy efficiency .......................................................................... 28 3.6.6 Safety aspects ................................................................................................................. 29 3.6.7 Differences between soda process and potash process................................................... 30 3.6.8 Waste water and waste gas treatment ............................................................................. 31

3.7 Current consumption and emission levels ................................................................................ 32 3.7.1 Emissions and consumption levels update ..................................................................... 32 3.7.2 Diffuse emissions from cell rooms................................................................................. 33 3.7.3 Emissions to water ......................................................................................................... 33

3.8 Issues regarding emerging techniques ...................................................................................... 35 3.9 Information exchange and data collection................................................................................ 36

3.9.1 Member States reports on the implementation of the IPPC Directive............................ 37 3.9.2 General principles for providing information for the review of the BREF – general

update............................................................................................................................. 37 3.9.3 Exchange of information communication....................................................................... 39 3.9.4 TWG personal data on the EIPPCB web page ............................................................... 40

4 ANNEX I: STANDARD STRUCTURE FOR CHAPTER 4 ........................................................ 41 4.1 Type of information needed to fill in the chapter(s) on 'Techniques to consider in the

determination of BAT' and to derive useful BAT conclusions................................................. 42 5 ANNEX II: TEMPLATE FOR THE PROVISION OF INFORMATION FOR THE REVIEW

OF THE CAK BREF (QUESTIONNAIRE).................................................................................. 44

4 September 2009 FS/EIPPCB/CAK KOM report

1 INTRODUCTION TO THE MEETING The meeting was chaired by the European Commission and was attended by 27 representatives from 10 Member States (the United Kingdom, Ireland, France, Spain, Germany, Austria, Portugal, Italy, Finland, Romania and the Czech Republic), from industrial non-governmental organisations (nine representatives of Euro Chlor and individual companies), from environmental non-governmental associations (one representative from EEB) and European Commission Service, i.e. DG Environment (DG ENV) and the Joint Research Centre (JRC/EIPPCB). In order to facilitate the meeting, a background paper highlighting the subjects and issues proposed for discussion at the meeting along with a draft questionnaire for data collection was prepared by the European IPPC Bureau and was sent to the TWG members in advance of the meeting (by email dated 4 September 2009). The agenda of the kick-off meeting involved introductory presentations as well as presentations and discussions on the exchange of information process, the definition of the scope of the work and the outline of the BREF. Those discussions were covered during the first two days of the meeting. The third day covered the information exchange tools as well as the conclusion of the meeting. The Chairman Luis Delgado, acting head of the European IPPC Bureau, welcomed the TWG members and introduced the EIPPCB staff and subsequently allowed the participants at the meeting to introduce themselves. The representative of DG ENV, Alexandre Paquot, informed the TWG about the recent debate along with the state of play of the discussions and decisions on the recast of the IPPC Directive, in the framework of the IED (Industrial Emissions Directive). The Chairman addressed the group on the BREF review and the exchange of information that underpins the work. BREFs are the published results of an information exchange on BAT. They equip competent authorities, companies, the public, the Commission, etc. with information needed for their decision making. They are informative rather than prescriptive. They are a tool to drive and improve environmental performance. BREFs do not do the following: interpret the directive, define or alter legal obligations, suggest emission limit values, attempt to be exhaustive or contain detailed local considerations. Ms Frauke Schorcht from the European IPPC Bureau led the technical discussion. It was clarified that the aims of the kick-off meeting are as follows: 1. to get to know one another as members of the review of the CAK BREF; 2. to discuss the wishes expressed by the TWG members in May 2009; 3. to conclude on the main issues that the review of the CAK BREF will focus on;4. to agree on the type and format of the data/information which are needed for the review;5. to set a deadline for the provision of new information; 6. to agree on a forward plan for the whole project. The aims of the kick-off meeting were not to discuss techniques/measures in detail, specific data or information from the original CAK BREF, specific new or updated data or information, BAT and BAT-AELs. This would be done later in the review process. As a result of this kick-off meeting, the review process for the CAK BREF should be clarified so that the TWG and the European IPPC Bureau can be assigned clear tasks.


During the kick-off meeting, there was also time to discuss the wishes. However, the discussions were kept general. Thus, discussions did not enter into deep technical debates. For example, deciding on whether a certain technique is BAT was not discussed. Furthermore, the TWG was reminded on the guidance documents the Information Exchange Forum (IEF) has agreed upon at several IEF meetings. These documents are minimum requirements the TWG has to consider. The following IEF documents can be downloaded from the EIPPCB webpage hhttttpp::////eeiippppccbb..jjrrcc..eecc..eeuurrooppaa..eeuu//iieeff//

• BREF Outline and Guide provides an agreed upon basis for the work of the European IPPC Bureau and the TWGs (e.g. structure, standard text);

• Generic schedule for the reviews of BREFs presents the main steps that a TWG has to follow in order to review a BREF;

• Strategy to Review the Chemical BREFs presents the main elements to take into consideration to review the first series of chemical BREFs (‘Comparative Analysis’);

• IEF 20-4 Guidance Document on improving the collection and submission of data for the review of the BREFs;

• Vertical BREFs and horizontal BREFs, especially CWW, provide additional useful information.

ftp://ftp.jrc.es/pub/eippcb/doc/ief_20-4_guidan_on_data_collect_(final_after_ief).pdf

http://eippcb.jrc.ec.europa.eu/ief/


2 MEETING STRUCTURE AND STRUCTURE OF THE MEETING REPORT

The meeting discussion was structured according to the content of the background paper which was sent to the TWG in advance of this meeting by email dated 4 September 2009. A general reminder was given on the guidance documents agreed upon at the Information Exchange Forum (IEF) which set the minimum requirements for elaborating/reviewing a BREF document, e.g.: • BREF Outline and Guide

◦ provides an agreed-upon basis for the work of the European IPPC Bureau and the TWGs (e.g. structure, standard text);

• Generic schedule for the reviews of BREFs ◦ presents the main steps that a TWG has to follow in order to review a BREF;

• Strategy to review the chemical BREFs ◦ presents the main elements to take into consideration to review the first series of

chemical BREFs (‘Comparative Analysis’); • IEF 20-4 Guidance document

◦ on improving the collection and submission of data for the review of the BREFs; • Vertical BREFs and horizontal BREFs, especially CWW

◦ provide additional useful information. The discussion covered the following 10 general subject groups: 1. General issues; 2. Environmental management; 3. Issues regarding the mercury cell process; 4. Issues regarding the diaphragm cell process; 5. Issues regarding the membrane cell process; 6. Other issues; 7. Current consumption and emission levels; 8. Issues regarding emerging techniques; 9. Data collection; 10. Issues for information but considered not relevant for discussion at the kick-off meeting. Subject groups 1 to 8 were related to the question of what information and data should be provided and by whom.

Subject group 9 was related to the question on how and by using which format information and data should be provided. Additionally, a draft questionnaire for data collection was prepared by the EIPPCB and it was discussed during the meeting. Subject group 10 was not discussed at the meeting. Furthermore, the TWG did not consider issues other than the ones proposed in the above mentioned subject groups for discussion at the kick-off meeting. The subject groups and/or items were derived from about 210 wishes provided by the TWG. A wish in this context meant suggestions/comments provided by the members of the TWG to modify the existing BREF. Wishes regarding similar issues were grouped into items themselves and, additionally, grouped into subject groups. In most cases, the detailed individual wishes were listed.



In total, there was a discussion on 30 items. For each individual item, the following was presented by the leader of the technical discussion, Ms Frauke Schorcht: 1. Summary of wishes or individual wishes expressed by the TWG

◦ the wishes made and by whom; 2. EIPPCB proposals made by the EIPPCB to address the wishes

◦ proposals to develop or to resolve the issues/wishes; 3. New information identified by TWG members

◦ new information already identified and by whom; 4. TWG tasks to be carried out by the TWG to fulfil the wishes (basis: EU-27 information and

data) ◦ action to take in order to satisfy the wishes, comprehensive of what is needed from

the TWG members. Then the TWG members had the opportunity to discuss each individual subject and item. The discussion was related to the following: • Was the wish understood properly? • Was it allocated to the correct item? • Was it worth dealing with? • What information is available? • Who will provide the information? Regarding subject group 9, the draft questionnaire for data collection was discussed and was concluded on. For each individual item, the TWG agreed and concluded on TWG tasks, such as what will be done by the TWG and commitments. The record reflects the structure the meeting had, without relaying it exactly. For each subject group and/or item, a brief summary of the wishes and the proposals for the discussion is reported along with the summary of the discussion, if necessary. Furthermore, the conclusions reached during the meeting for each individual issue are also given, along with the information identified or promised by TWG members to be delivered to the EIPPC Bureau for the information exchange. The presentations given during the meeting are not repeated here; therefore, for the conclusions reached at the meeting, references have been made to the modified conclusions presentation which is uploaded onto BATIS. At the kick-off meeting, the discussion was very detailed, open and constructive. Regarding all topics which were proposed for discussion, conclusions were made by the TWG. Furthermore, the TWG identified a number of sources for new and/or updated information.


3 CONCLUSIONS 3.1 General Issues 3.1.1 Interface between the CAK BREF and other BREF documents

and links to EU legislation The wishes received from the TWG underlined the need for: • clarifying and improving the interrelationships between the CAK BREF and other

BREFs, e.g. CWW, ENE, ICS, EFS, MON, ECM by including cross-references to other BREF documents where useful information can be found regarding the respective task or measure/technique;

• dealing with interactions and links between the CAK BREF and the EU legislation by adding to the BREF EU legislation which is applicable to the CAK industry.

The following proposals of the EIPPCB were discussed: 1. Include cross-references to other BREF documents (IEF decision); 2. Add appropriate cross-references to the CWW, ENE, ICS, EFS, MON, ECM (IEF

decision); 3. Add to Annex D ‘EU legislation’ which is applicable to the CAK industry: IPPC

Directive, SEVESO II Directive, ATEX, REACH, Water Framework Directive, EC/1102/2008, etc.

Conclusions reached by the TWG after discussion (please also see the PowerPointConclusion Slide 4):

Information identified or promised to be provided by the TWG: • IEF documents and BREFs • EU legislation which is applicable to the CAK industry: IPPC Directive, SEVESO II

Directive, ATEX, REACH, Water Framework Directive, EC/1102/2008, etc. TWG tasks: 1. Identify appropriate, useful information from other vertical and horizontal BREFs which

can be referred to by cross-references; 2. Identify EU legislation which is applicable to the CAK industry.

3.1.2 Consistency within the series of BREFs The wishes received from the TWG underlined the need for: • including the standard text that appears in all BREF documents, e.g. regarding:

◦ Chapter 4 :Techniques to consider in the determination of BAT (nine headings); ◦ Chapter 5: BAT; ◦ PREFACE; ◦ SCOPE.

• including cross-references within the BREF text and set a precedent on terminology used.


The following proposals of the EIPPCB were discussed: 1. Follow the BREF Outline and Guide (BOAG) when describing techniques to consider in

the determination of BAT and include standard text and use the nine-headings standard structure (i.e. Description; Achieved environmental benefits; Operational data; Cross-media effects; Applicability; Economics; Driving force for implementation; Example plants; References to literature);

2. Improve the cross-references within the document, in particular between the BAT Chapter and the rest of the document;

3. Write the BAT conclusions in a way that is more in line with the current standard of writing BREFs (e.g. structure of BAT conclusions, numbering of BAT conclusions).

Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 5):

Information identified or promised to be provided by the TWG: • Comparative analysis of the first series of chemical BREFs prepared by the European

IPPC Bureau (dated December 2007); • IEF paper dated March 2007 on the ‘Strategy to revise the chemical BREFs’; • BREF Outline and Guide (updated in 2005) (BOAG); • IEF guidance document on improving data collection and submission of data for the

review of BREFs (IEF 20 – 4, dated June 2008); • information regarding data collection which can be used to provide missing data in order

to fill in the nine-heading standard structure. TWG tasks: 1. identify inconsistencies in the BREF; 2. include cross-references within the sections, where appropriate; 3. contribute ‘Techniques to consider in the determination of BAT’ according to the nine-

headings standard structure; 4. write BAT conclusions according to the IEF Guidance document, however, BAT will be

discussed later in the review process.

3.1.3 Basic structure of the CAK BREF The wishes received from the TWG underlined the need for: • keeping the basic structure of the CAK BREF; • regarding Chapter 4, using the standard structure (nine headings); • reordering/restructuring topics for better comprehensibility. The following proposals of the EIPPCB were discussed: 1. keep the basic standard structure of the CAK BREF as indicated in the BREF Outline

and Guide (i.e. General information, Applied processes and techniques, Current consumption and emission levels, Techniques to consider in the determination of BAT, BAT) including data and information;

2. depending on the type and amount of information provided by the TWG, modify, alter, move, re-number sections and sub-sections from the original BREF;

3. keep data and information on mercury cell plants within the general basic structure ◦ The original BREF concluded that mercury cell plants are not BAT for new and

upgraded plants. However, because mercury cell plants are still alive and working


until a sunset date is defined, the environment and employees have to be protected and, e.g. emissions to air, water and soil have to be controlled, monitored, minimised and/or reduced.

The following figure shows the current structure of the CAK BREF.

Executive SummaryPrefaceScope

Chapters 1 – 7

Annexes A – E ReferencesGlossary

Chapter 1 General Information Chapter 2 Applied processes and techniquesChapter 3 Current consumption and emission

levelsChapter 4 Techniques to consider in the

determination of BATChapter 5 Best available techniques Chapter 6 Emerging techniques Chapter 7 Conclusions and recommendations

= Basic standard structure of a BREF= Basic standard structure of a BREF

Figure 1: Structure of the CAK BREF (adopted 2001)


Information identified or promised to be provided by the TWG: • BREF Outline and Guide (updated in 2005); • IEF guidance document on improving data collection and submission of data for the

review of BREFs (IEF 20 – 4, dated June 2008); • EU-27 data and information. TWG tasks: 1. keep the same structure of the CAK BREF along with the information on membrane cell

technology and also a BAT chapter for each of the following: mercury cell technique, diaphragm cell technique and membrane cell technique;

2. do not weaken BAT conclusions regarding technologies; 3. provide missing and updated information and data especially to describe techniques

according to the nine-headings standard structure; 4. collect information for mercury cell plants for the remaining lifetime; 5. re-order topics and avoid repetitions.

3.1.4 General updating The wishes received from the TWG underlined the need for: • In general, updating data and statistics for the EU-27. If old data is still valid, an

explanatory text should be included. Trademarks or patentee names should be excluded from the text.

• Updating figures, including data from the new EU Member States and updating data for the entire EU-27.


The following proposals of the EIPPCB were discussed: 1. collect or make available and provide information and data for the EU-27 (up-to-date

data, preferably for 2009, if available); 2. for still-valid old data and information, provide explanatory text, if necessary; 3. provide site-specific/plant-specific and best performance data and information in the

process of data collection.


Information identified or promised to be provided by the TWG: • EU-27 data and information. TWG tasks: 1. Update data, statistics and figures regarding the EU-27; 2. Provide explanatory text for old data that are still valid , if necessary; 3. Participate actively in the data collection process and provide generally applicable data

and site-specific/plant-specific data and best performance data. This was discussed in detail in BP Section 9 on data collection.

3.1.5 Glossary of terms and abbreviations The wishes received from the TWG underlined the need for: • significantly expanding the Glossary:

◦ The Glossary does not meet even minimum standards. Several used abbreviations are not included, occasionally not even explained in the BREF text. Other BREFs include explanations of not just abbreviations but also important keywords. This would also be the right place to add basic physicochemical data for the most important compounds.

• explaining/defining terms; • providing details and explanations of terms and abbreviations; • explaining ‘difference to balance’; • maintaining the consistency in the terms used in the whole series of chemical BREFs; • checking the Glossary of the revised horizontal CWW BREF and adding key technical

terms to the Glossary of the CAK BREF. The following proposals of the EIPPCB were discussed: 1. maintain consistency in the terms used across the whole series of chemical BREFs; 2. identify terms and abbreviations that would be worth defining in the Glossary and add

key technical terms to the Glossary; 3. propose definitions for terms and abbreviations identified in the CAK BREF.



Information identified or promised to be provided by the TWG: • horizontal CWW BREF; • comparative analysis of the first series of the chemical BREFs prepared by the European

IPPC Bureau (dated December 2007). TWG tasks: 1. expand the glossary significantly; 2. propose definitions for terms and abbreviations identified in the CAK BREF.


3.2 Environmental management 3.2.1 Environmental relevance of the CAK industry (Chapter 1) The wishes received from the TWG underlined the need for: • including correct background information with regard to mercury losses, especially the

explanation of ‘difference to balance’ (also for the Glossary); • updating and completing information regarding the environmental relevance of the CAK

industry; • adding information about the relevance of decommissioning measures/techniques and

monitoring; • updating and completing information. The following proposals of the EIPPCB were discussed: 1. provide updated information and data regarding the environmental relevance of CAK

plants along with information and data regarding historical contamination; 2. provide information and an explanation regarding the term ‘difference to balance’ which

will then be added to the Glossary. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 10):

Information identified or promised to be provided by the TWG: • EEB publication of October 2006: ‘Status report: Mercury cell chlor-alkali plants in

Europe; Lost and Found: Missing mercury from chemical plants pollutes air and water’; • EEB publication of October 2006: ‘Risky Business! No need for mercury in the Chlorine

Industry’; • Euro Chlor will provide information and data for 2008 relevant for the calculation of the

data used for OSPAR and other data; • EEB and Euro Chlor will provide additional documents explaining and defining

‘difference to balance’; • AT will provide the document: ‘Medienübergreifende Umweltkontrolle in ausgewählten

Gebieten’ (http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf).

TWG tasks: 1. provide updated information and data; 2. provide information and an explanation regarding the term ‘difference to balance’ and

propose a definition for adding to the Glossary.

3.2.2 Environmental management systems (EMS) The wishes received from the TWG underlined the need for: • Adding a section on Environmental Management Systems (EMS). Use the standard text

that appears in all of the BREF documents and add information and data specific to the CAK sector, if available.

http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf


The following proposal of the EIPPCB was discussed: 1. Add a section on Environmental Management Systems (EMS) by using the standard text

that appears in all of the BREF documents along with individual information provided by the TWG and data regarding the CAK industry and by using the standard structure (nine headings) from the guidance document on data collection, agreed upon by the IEF in April 2008 (Description, Achieved environmental benefits, Cross-media effects, Operational data, Applicability, Economics, Driving force for implementation, Example plants, Reference literature) and add information and data specific to the CAK sector, if available.


Information identified or promised to be provided by the TWG: • IEF documents, e.g. BREF Outline and Guide (updated in 2005). TWG tasks: 1. use standard text on ‘Environmental Management Tools’; 2. collect and provide chlor-alkali-specific information and data regarding ‘Environmental

Management Tools’ for each of the nine standard structure headings for the EU-27, if available.


3.3 Issues regarding the mercury cell process 3.3.1 Historical contamination The wishes received from the TWG underlined the need for: • updating information and adding further experiences and data regarding contaminated

sites resulting from chlor-alkali plants (e.g. level of PCDD/F compounds and/or mercury in soil) along with information on what has already been done up to 2009 and/or will be done further in order to improve the situation of contaminated sites.

The following proposals of the EIPPCB were discussed: 1. TWG to provide information regarding contaminated sites resulting from CAK plants

(e.g. level of PCDD/F compounds and/or mercury in soil) for the EU-27; 2. add information on what has already been done up to 2009 and/or what will be done

further in order to improve the situation of contaminated sites. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 12):

Information identified or promised to be provided by the TWG: • EEB publication of October 2006: ‘Status report: Mercury cell chlor-alkali plants in

Europe; Lost and Found: Missing mercury from chemical plants pollutes air and water’ • EEB publication of October 2006: ‘Risky Business! No need for mercury in the Chlorine

Industry’; • AT will provide the document: ‘Medienübergreifende Umweltkontrolle in ausgewählten

Gebieten’ (http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf); • Euro Chlor will provide a guideline for the management of mercury-contaminated sites. TWG tasks: 1. Update BREF section on historical contamination:

i. provide information, if available, on further experiences and data regarding contaminated sites resulting from chlor-alkali plants;

ii. provide information on what has already been done up to 2009 and/or will be done further in order to improve the situation of contaminated sites.

3.3.2 Specific issues regarding Mercury cell plants The wishes received from the TWG regarding this issue were divided into four groups: a. Emissions, consumptions and cost data; b. Waste; c. Hg contamination; d. Structure. Regarding group a) ‘Emissions, consumptions and cost data’, the wishes underlined the need for:



• checking and updating ‘Best case’ data (best performance data); • updating consumption and emission levels as well as costs data; • adding data for water treatment; • updating operational data regarding the EU-27. Regarding group b) ‘Waste’, the wishes underlined the need for: • adding detailed information on where mercury retorting takes place (on site or with an

external service provider); • discussing the issue on the following:

◦ All mercury wastes from the chlor-alkali industry should be retorted and the mercury recovered and stored according to Regulation EC/1102/2008 (Section 4.2.1.4). This is the only way to avoid arguments about determining the amount of mercury in wastes which is important for the mercury balance and an improved understanding of mercury releases.

Regarding group c) ‘Hg contamination’, the wishes underlined the need for: • producing and publishing an independent estimate of site-specific mercury contamination

both on site and in its general area of operation (Section 4.2); ◦ It has recently been demonstrated that site perimeter mercury concentrations are

sometimes above acceptable limits, perhaps due to cell room emissions and perhaps due to site contamination (soil, waste air).

Regarding group d) ‘Structure’, the wishes underlined the need for: • restructuring Section 4.2.1 ‘Overview of mercury emission abatement’ and splitting the

section into detailed sub-sections (see tables of Section 4.2.1); • using the nine-headings standard structure and collecting information regarding the nine

headings; • updating operational data regarding the EU-27. The following proposals of the EIPPCB were discussed: 1. collect and provide information, developments and best performance data including:

i. emissions, consumptions and cost data; ii. data regarding mercury-containing waste;

iii. data regarding Hg contamination. 2. restructure Section 4.2.1 ‘Overview of mercury emission abatement’ and split the section

into detailed subsections by using the nine-heading standard structure. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 13):

Information identified or promised to be provided by the TWG: • BREF Outline and Guide (updated in 2005); • IEF guidance document on improving the data collection and submission of data for the

review of BREFs (IEF 20 – 4, dated June 2008); • EU-27 information and data; • EEB publication of December 2008: ‘The European Chlor-Alkali Industry: Is national

implementation of the IPPC Directive contributing to a mercury-free industry? Results of an Environmental NGO Survey’;

• EEB publication of October 2006: ‘Risky Business! No need for mercury in the Chlorine Industry’;


• EEB publication of October 2006: ‘Status report: Mercury cell chlor-alkali plants in Europe’;

• Euro Chlor will provide information on what type of waste is retorted. TWG tasks: • provide information, developments, emissions and consumption data and plant-specific

best performance data regarding the nine-heading standard structure; • provide information on which plants retort waste and which do not along with

information on whether waste retorting is carried out on-site or off-site; • provide information on mercury contamination; • restructure Section 4.2.1 ‘Overview of mercury emission abatement’.

3.3.3 The phasing out of mercury and interim conditions The wishes received from the TWG forced the discussion on the following proposals: • define a specific legally binding and near-term ‘sunset’ date for all mercury-cell chlor-

alkali plants, both sodium-based and potassium-based; • establish gradually decreasing requirements for mercury emissions; • reiterate that the mercury cell process is not BAT, therefore no level of emissions is

acceptable, and therefore emissions must be eliminated according to a fixed schedule over the shortest possible time frame;

• determine on what technical basis, if any, a plant may ignore BAT and continue to operate with mercury cells.

The following proposals of the EIPPCB were discussed: 1. it is not within the scope of the BREF to define a specific legally binding and near-term

‘sunset’ date for all mercury-cell chlor-alkali plants: i. a BREF does not interpret the IPPC Directive, does not define or alter legal

obligations, does not suggest emission limit values (ELVs), cannot be exhaustive or take local considerations into account in detail.

2. provide information regarding the phasing out of mercury; 3. BAT will be discussed later in the review process. The TWG was reminded on the fact that a BREF does not interpret the IPPC Directive, does not define or alter legal obligations, and does not suggest emission limit values (ELVs), cannot be exhaustive or take local considerations into account in detail. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 14):

Information identified or promised to be provided by the TWG: • EU-27 information and data; • Euro Chlor: Guideline on Decommissioning; • EEB: Publication of 2000 regarding decommissioning; • DE will try to provide information in order to establish tighten requirements; • EEB publication of December 2008: ‘The European Chlor-Alkali Industry’; • EEB publication of October 2006: ‘Risky Business! No need for mercury in the Chlorine

Industry’; • EEB publication of October 2006: ‘Status report: Mercury cell chlor-alkali plants in

Europe’.


TWG tasks: 1. provide information and experiences regarding the phasing out of mercury; 2. provide information and data in order to be able to define interim conditions.

3.3.4 Conversion of mercury cell plants into membrane technology The wishes received from the TWG underlined the need for: • updating information and data including conversion cost data; • defining the scope the conversion costs will refer to; • noting in the BREF that a written plan for decommissioning, conversion or closure, and

site remediation should be required; • including the results of a competent Sustainability Impact Assessment with regard to the

conversion or phasing out of mercury cells; • describing the process of conversion or the procedures after the closure of amalgam

electrolysis. The following proposals of the EIPPCB were discussed: 1. provide experiences, information and data on the conversion of mercury cell plants into

membrane technology including emissions data; 2. provide updated cost data along with specifications on what is included in the costs; 3. the TWG is asked to provide existing written conversion plans or documentations for

decommissioning, conversion or closure, and site remediation. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 15):

Information identified or promised to be provided by the TWG: • Euro Chlor will provide data and information regarding typical conversion cost ranges; • Euro Chlor will try to provide a break down of conversion costs; • ANE ES will provide data from recent conversion operations (ANE-Euro Chlor); • EU-27 information and data; • EEB publication of December 2008: ‘The European Chlor-Alkali Industry: Is national


• EEB publication of, October 2006: ‘Status report: Mercury cell chlor-alkali plants in Europe’;

• EEB publication of September 2000: ‘Decommissioning chlor-alkali facilities in Western Europe: Mercury options’.

TWG tasks: 1. provide experiences, information and data on the conversion of mercury cell plants into

membrane technology; 2. provide updated cost data along with specifications on what is included in the costs; 3. provide written conversion plans or documentations for decommissioning, conversion or

closure, and site remediation, if available.


3.3.5 Decommissioning of mercury cell plants The wishes received from the TWG underlined the need for: • updating the section on the decommissioning of mercury cell plants; • including detailed information and experiences (including costs) of decommissioning and

especially management, treatment, handling and the depositing of mercury and mercury-containing wastes;

• discussing measures/techniques for the control of mercury during the decommissioning of mercury cells;

• defining a specific, legally binding and near-term ‘sunset’ date for all mercury-cell chlor-alkali plants.

The following proposals of the EIPPCB were discussed: 1. provide information, experiences and plant-specific data on the decommissioning of

mercury cell plants in the EU-27; 2. provide written plans or documentation regarding the decommissioning of mercury cell

plants in the EU-27, if available. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 16):

Information identified or promised to be provided by the TWG: • Euro Chlor document on decommissioning; • French guidelines will be checked by FR for more recent information and for French

specifications (+ translation into English); • EU-27 information and data; • EEB publication of December 2008: ‘The European Chlor-Alkali Industry: Is national


• EEB publication of, October 2006: ‘Status report: Mercury cell chlor-alkali plants in Europe’;

• EEB publication of September 2000: ‘Decommissioning chlor-alkali facilities in Western Europe: Mercury options’;

• EEB publication of October 2006: ‘Risky Business! No need for mercury in the Chlorine Industry’.

TWG tasks: 1. provide documentation along with information, experiences and plant-specific data on the

decommissioning of mercury cell plants; 2. specify and describe techniques/measures for control mercury during the decommissioning

of mercury cells; 3. provide information and data regarding the treatment of mercury-containing wastes.


3.4 Issues regarding diaphragm cell plants The wishes received from the TWG underlined the need for: • updating data and information regarding the use of polymer modified asbestos (PMA)

diaphragm and regarding asbestos emissions; • checking for developments in non-asbestos diaphragms and providing information on

synthetic diaphragms; • updating state of conversion for mentioned reference plants; • updating cost/performance relation between asbestos and non-asbestos diaphragms; • adding examples for conversions of diaphragm to the membrane process; • taking into account the phase-out of the existing asbestos diaphragms in order to be

consistent with REACH (revision of the Annex 17 in progress). The following proposals of the EIPPCB were discussed: 1. update information, developments and plant-specific data; 2. provide information regarding:

i. the replacement of asbestos diaphragms; ii. synthetic diaphragms and non-asbestos diaphragm materials applied;

iii. energy consumption; iv. the achieved energy reduction rate compared to the asbestos diaphragm; v. the phasing out of existing asbestos diaphragms.


Information identified or promised to be provided by the TWG: • Legislation: REACH Annex 17 is published in an official journal on 26 June 2009, MS

have to provide a report to the Commission by June 2011. The Commission will decide on this issue on asbestos diaphragms;

• Euro Chlor: New info on synthetic diaphragm cells; • Euro Chlor will provide info on the specific production process as much as possible

(information on health, environmental and worker protection aspects as well as on alternative non-asbestos materials).

TWG tasks: 1. provide information, developments and plant-specific data (emissions and consumption

data, costs data); 2. provide information and data on energy consumption as well as regarding the achieved

energy reduction rate compared to the asbestos diaphragm; 3. provide information regarding the phasing out of existing asbestos diaphragms; 4. provide information and data for the specific production case (downstream chlorohydrin

processes).


3.5 Issues regarding the membrane cell plants The wishes received from the TWG underlined the need for: • updating information regarding membrane cell plants; • adding information on experiences with membrane cell technology; • updating information on emissions and consumption levels, especially regarding energy

consumption; • adding new information on monopolar/bipolar membrane techniques; • updating information and add developments/improvements on membrane materials. The following proposals of the EIPPCB were discussed: 1. provide information on monopolar/bipolar membrane technologies; 2. provide updated information regarding:

i. the development of membrane materials ii. plant-specific emissions and consumption data.


Information identified or promised to be provided by the TWG: • Euro Chlor will provide new information on monopolar/bipolar membrane technologies; • ES will provide information on the inventory of existing membrane technologies

currently under operation in ES; • EU-27 information and data; • IR will provide information on bipolar technology for specific Irish plants; • Euro Chlor will provide a document on energy issues for all three types of plants; • Euro Chlor will provide a list of suppliers. TWG tasks: 1. provide information, developments and plant-specific data; 2. provide information on monopolar/bipolar membrane technologies; 3. provide information and data on energy consumption; 4. contact suppliers for performance data (EIPPCB).


3.6 Other issues 3.6.1 Auxiliary processes (Chapter 2) 3.6.1.1 BREF Section 2.4.1 Salt unloading and storage The wishes received from the TWG underlined the need for: • updating information concerning the potential sources of salt including:

◦ acknowledging possible sources and qualities of salt/brine, given the existing diversity and the overall environmental benefit of some practices, e.g. recovery of waste from KCl mining;

◦ modifying this paragraph concerning the potential sources of salt. The following proposals of the EIPPCB were discussed: 1. provide updated information concerning:

i. the potential sources of salt along with information regarding qualities of salt/brine;

ii. its existing diversity; iii. the overall environmental benefit of some practices, e.g. the recovery of waste

from KCl mining. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 19):

Information identified or promised to be provided by the TWG: • ES will provide information regarding the inventory of sources, consumption and

qualities of salt/brine; • PT will check whether information is available regarding sources and brine quality; • AT will try to get new information; • CZ can provide information regarding KCl; • UK will try to get information on this issue. TWG task: 1. provide information regarding sources, consumption and qualities of salt/brine.

3.6.1.2 BREF Section 2.4.2 Brine purification and resaturation The wishes received from the TWG underlined the need to: • revise available techniques for waste brine treatment plants to control/minimise chloride

and mercury discharges to water; • consider the reduction of effluent volume considering:

◦ waste brine treatment plants have high effluent discharge rates; ◦ the effluent has a high-chloride load and if associated with mercury cell, is a

significant contributor to the mercury releases to water. • check energy consumption:

◦ the energy consumption for a cell with waste brine treatment is likely to be higher, as the fresh brine requires preheating.


The following proposals of the EIPPCB were discussed: 1. provide information and data regarding available techniques for waste brine treatment

plants in order to: i. control/minimise chloride and mercury discharges to water;

ii. reduce effluent volume; iii. reduce/minimise energy consumption.


Information identified or promised to be provided by the TWG: • Euro Chlor will provide information regarding all waste brine plants; • UK can provide information regarding UK plants. TWG tasks: 1. provide information and data regarding available techniques for waste brine treatment

plants in order to: i. control/minimise chloride and mercury discharges to water;

ii. reduce effluent volume; iii. reduce/minimise energy consumption.

3.6.1.3 BREF Section 2.4.3 Chlorine production, storage and handling The wishes received from the TWG underlined the need for: • adding information about possibilities (techniques, methods) to replace cooling agents

such as CFCs, HCFCs, HFCs etc., as the use of those agents will be prohibited in 2015; • adding technical details about packings used in the dryers; • sorting out if there are new developments in chlorine liquefaction (especially without use

of carbon tetrachloride. The following proposals of the EIPPCB were discussed: 1. identify techniques/measures and/or methodologies which allow for replacing cooling

agents (e.g. CFCs, HCFCs, HFCs) and provide information; 2. provide information on technical details about packings used in the dryers; 3. provide information on new developments in chlorine liquefaction Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 21):

Information identified or promised to be provided by the TWG: • Euro Chlor will provide information on the use of CCl4 in the CAK industry; • Euro Chlor will provide basic information regarding packings used in dryers; • FR will provide information for the use of CCl4.


TWG tasks: 1. Identify techniques/measures and/or methodologies which allow for replacing cooling

agents (e.g. CFCs, HCFCs, HFCs) and provide information. Add cross-reference to the BREF on Industrial Cooling Systems.

2. Provide information on technical details about packings used in the dryers. 3. Provide information on new developments in chlorine liquefaction. 4. Identify developments regarding chlorine liquefaction and provide information. 5. Collect and provide data and information regarding available techniques and details for

chlorine production, storage and handling.

3.6.1.4 BREF Section 2.4.5 Hydrogen production, storage and handling The wishes received from the TWG underlined the need for: • placing stronger emphasis on efficient use of the produced hydrogen (too valuable to just

be burned). The following proposal of the EIPPCB was discussed: 1. identify and provide information on efficient use of the produced hydrogen. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 22):

Information identified or promised to be provided by the TWG: • Euro Chlor will provide information on how hydrogen is used and not lost; • PT will provide information how hydrogen is used directly in other chemical processes; • AT will provide information on this issue (it is included in the document

‘Medienübergreifende Umweltkontrolle in ausgewählten Gebieten’; http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf).

TWG task: 1. identify and provide information on the efficient use of the produced hydrogen.



3.6.2 Specific issues regarding BREF Section 4.1 All cell plants The wishes received from the TWG were related to the following sections of the CAK BREF: • BREF Section 4.1.2; • BREF Section 4.1.4; • BREF Section 4.1.5; • BREF Section 4.1.6; • BREF Section 4.1, in general. These wishes underlined the need for: • updating information and emissions data • updating and improving data on chlorine absorption units along with information on

safety measures/techniques, e.g. regarding the following issue: ◦ in the case of an emergency, the chlorine production is stopped immediately and

thus the chlorine absorption unit needs only two minutes to treat the complete cell room content (and not 15 – 30 minutes as stated in Section 2.4.3.2).

• taking into account that an analytical procedure for the control of the process (brine system) and of the raw material (salt) can avoid/prevent the production and accumulation of the dangerous impurity;

• discussing the issue that every site should be required to produce and publish an independent estimate of mercury contamination both on-site and in its general area of operation.

The following proposals of the EIPPCB were discussed: 1. provide information, developments and plant-specific performance data regarding

Section 4.1; 2. provide information regarding available analytical procedures for the control of the

process (brine system) and of the raw material (salt); 3. identify and provide available information regarding the estimate of mercury

contamination both on-site and in its general area of operation; 4. provide information regarding the chlorine absorption unit along with safety

measures/techniques (NL). Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 23):

Information identified or promised to be provided by the TWG: • NL: plant-specific data regarding chlorine dioxide resulting from chlorine absorption

units (plants in Delfzijl and Rotterdam); • EEB publications; • FI can provide information; • IT will provide information regarding the quality control of the procedure; • Euro Chlor will provide information on safety requirements for the chlorine absorption

unit.


TWG tasks: 1. provide information, developments and plant-specific performance data regarding

Section 4.1; 2. provide information regarding available analytical procedures for the control of the

process (brine system) and of the raw material (salt); 3. identify and provide available information regarding the estimate of mercury

contamination both on-site and in its general area of operation; 4. provide information regarding the chlorine absorption unit along with safety

measures/techniques (NL).

3.6.3 Chlorine transport The wishes received from the TWG underlined the need for: • collecting and adding information on the transport of chlorine with regard to the scope of

the BREF; • considering the following: In addition to the basic activities for CAK production, the

document should cover the associated activities (e.g. regarding chlorine transport) which could have an effect on emissions or pollution.

The following proposal of the EIPPCB was discussed: 1. provide information regarding the transport of chlorine within the production site or the

industrial area along with safety measures/techniques applied. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 24):

Information identified or promised to be provided by the TWG: • UK will provide guidance notes related to safety aspects of chlorine transport; • Euro Chlor will provide documents for transportation of chlorine inside of the plant

(recommendation of best practice). TWG tasks: 1. provide information regarding the chlorine transport within the production site (please

remember the scope of the BREF); 2. specify the transportation system used; 3. provide information regarding safety measures/techniques applied.

3.6.4 Monitoring of emissions The wishes received from the TWG were related to the following specific issues: • monitoring in general; • monitoring water emissions; • monitoring mercury emissions. Regarding monitoring in general, these wishes underlined the need for:


• establishing requirements for data transmission: ◦ e.g. oxygen content, half-hourly average, daily average, concentration unit,

emission factor. • establishing a standardised and realistic level of monitoring and reporting emissions on

the plant site, at the plant perimeter and in surrounding areas (more comprehensive, more frequent and continuous in pre-defined critical areas), from the cell room, as well as reporting energy consumption;

• adding information on the monitoring of emissions along with monitoring frequencies: ◦ e.g. periodic or continuous measurements, safety reasons and the use of safety

measurements. Regarding monitoring water emissions, these wishes underlined the need for: • allowing monitoring and control of emissions into water at the boundary of the site (not

at the electrolysis unit level); • adding information on the monitoring of hazardous substances released into waters. Regarding monitoring mercury emissions, these wishes underlined the need for: • adding more guidance information on how to accurately calculate or estimate mercury

releases. The following proposals of the EIPPCB were discussed: 1. provide information regarding the monitoring and control of emissions to water; 2. provide as much information as possible about monitoring issues. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slides 25 – 26):

Information identified or promised to be provided by the TWG: • Euro Chlor will provide information regarding monitoring and the control of emissions to

water at the boundary of the site (not at the electrolysis unit level); • FR contribution to the revision of the CWW BREF; • EEB publication of December 2008. ‘The European Chlor-Alkali Industry’; • EEB publication of October 2006: ‘Status report: Mercury cell chlor-alkali plants in

Europe’; • Current report of Member States; • UK will provide a report on the monitoring certification scheme (methods used

specifically for monitoring of emissions to air and water; • EEB will provide research papers regarding a plant in Georgia (US); • Euro Chlor will provide a document on recommendations for Hg emissions from cell

rooms and Hg balance and a document on methods for emission analysis; • AT will provide information regarding emissions to air and water (document

‘Medienübergreifende Umweltkontrolle in ausgewählten Gebieten’; http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf) and will try to get new data.



TWG tasks: 1. provide information regarding the monitoring and control of emissions to water along

with the monitoring and control points (where monitoring points are located and/or where it is measured and which parameters are monitored and/or measured);

2. provide information about monitoring issues, including types of emissions along with details regarding emissions monitoring, e.g.:

i. monitoring frequencies, e.g. for periodic, continuous measurements; ii. how the data were generated or measured, i.e. as half-hourly, daily, monthly,

yearly average or estimated by calculation; iii. unit and emissions ranges time period related to this; iv. standard conditions of air emissions (e.g. volume flow, oxygen content,

concentrations, standard state). 3. provide information regarding monitoring and calculation of the balance of Hg in

products (from the questionnaire discussion).

3.6.5 Energy consumption/energy efficiency The wishes received from the TWG underlined the need for: • updating information on energy consumption levels; • establishing energy efficiency targets that will be gradually reduced over time; • Table 3.2 on energy use should be expanded in order to describe all the steps in which

energy use is important (brine preparation, for instance); • data concerning energy should refer to the (process) steps taken into account; • providing information and data on gas diffusion technology generating chlorine (with

energy consumption at 1500 kWh) (see MITI Japan). The following proposal of the EIPPCB was discussed: 1. provide general applicable data and plant-specific information and data regarding energy

consumption. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slides 27 – 28):

Information identified or promised to be provided by the TWG: • Euro Chlor will provide information regarding energy consumption; • Euro Chlor will provide recent information on gas diffusion technology; • Euro Chlor will provide information on energy efficiency in general but not plant-

specific; • Euro Chlor will provide information on energy according to process steps; • Euro Chlor will provide a document including more specific elements on energy tasks; • DE will try to provide data on energy consumption (not site-specific) , provided

confidentiality issues can be resolved; • EEB publication of December 2008: ‘The European Chlor-Alkali Industry: Is national

implementation of the IPPC Directive contributing to a mercury-free industry? Results of an Environmental NGO Survey’.


TWG tasks: 1. provide information and EU-27 data (up-to-date data up to 2009 including the year of

data collection/measurement) in a uniform format regarding: i. energy consumption and energy efficiency in general and related to process steps;

ii. plant-specific energy consumption data; iii. energy data and further information and data on gas diffusion technology

generating chlorine.

3.6.6 Safety aspects The wishes received from the TWG underlined the need for: • updating and improving data on safety aspects; • providing data for adding a new topic ‘Alarm management in case of

accidents/incidents’; • completing Section 4.1.1 ‘Safety measures’ with statistics or indicators of accidents

occurred in chlor-alkali sites; • adding information and safety experiences regarding liquid chlorine storage; • adding information on updated guidelines for the safe handling and use of chlorine

(including storage); • updating and improving data on chlorine absorption units (Section 4.1.2). The following proposals of the EIPPCB were discussed: 1. identify and provide further and updated information regarding safety aspects along with

industry standards regarding this issue of alarm and risk management; 2. update, improve and add information and data on safety aspects; 3. provide information and data for chlorine storage. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slides 29 – 30):

Information identified or promised to be provided by the TWG: • ANE ES will provide information on safety statistics from the sector companies and/or

consolidated at the sectoral association level; • DE will try to gather information regarding a new topic ‘Alarm management in the case

of accidents/severe irregularities/incidents’; • IT will provide information regarding safety measures in the storage area; • NL will provide improved information and data regarding the chlorine absorption unit; • Euro Chlor will provide guidelines for the safe handling and use of chlorine; • UK will provide information resulting from the ‘Chlorine covenant’ regarding the safe

storage and use of chlorine; • DOW will provide the TUIS standards (‘Technische Hilfe bei Transport- und

Lagerunfällen mit chemischen Produkten’/‘Transport, accident, information and emergency response system’, VCI Germany).


TWG tasks: 1. provide further and updated information regarding safety aspects along with industry

standards regarding this issue of alarm and risk management; 2. provide information on safety statistics from the sector companies and/or consolidated at

the sectoral association level (ANE-ES); 3. try to provide information regarding a new topic ‘Alarm management in case of

accidents/severe irregularities/incidents’ (DE); 4. provide information regarding safety measures in the storage area (IT); 5. provide improved information and data regarding the chlorine absorption unit (NL); 6. provide up-to-date ‘Guidelines for the safety handling and use of chlorine’

(Euro Chlor).

3.6.7 Differences between soda process and potash process The wishes received from the TWG underlined the need for: • emphasising in the BREF the differences between soda process and potash process.

These processes are different, for instance in terms of energy use or temperature (which has an important impact on air emissions).

The following proposal of the EIPPCB was discussed: 1. collect and provide information regarding the differences between soda process and

potash process, e.g. energy use, temperature and emissions. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 31):

Information identified or promised to be provided by the TWG: • FR will try to obtain data and best practices from example sites as references; • Euro Chlor will provide information on this issue; • ES will provide information regarding the conversion from Hg cell technology to

membrane technology for the production of potash; • IT will check whether info is available regarding the conversion from Hg cell technology

to membrane technology for the production of potash. TWG tasks: 1. identify, obtain and provide plant-specific data and information along with

measures/techniques applied from example sites (FR); 2. provide information regarding the conversion from Hg cell technology to membrane

technology for the production of potash.


3.6.8 Waste water and waste gas treatment The wishes received from the TWG underlined the need for: • adding to Chapter 4 (Techniques to consider in the determination of BAT) of the BREF

techniques for waste water and waste gas treatment. See also document ‘Comparative analysis’, especially Section 3.3.2.

The following proposals of the EIPPCB were discussed: 1. provide information and plant-specific performance data regarding techniques for waste

water and waste gas treatment by using the nine-heading standard structure for Chapter 4 2. add information to Chapter 4 Techniques for waste water and waste gas treatment. See

also IEF document ‘Strategy to review the chemical BREFs’ (‘Comparative analysis’), especially Section 3.3.2.


Information identified or promised to be provided by the TWG: • IR will provide information on a fully automated waste water treatment plant working

continuously before discharge to the sewer; • UK will try to provide information regarding brine purge treatment; • PT will sent information regarding a waste water pretreatment pant; • DE will provide information regarding a technique for Hg treatment; • Euro Chlor will provide a document for waste water treatment for mercury and updated

data for asbestos and chlorate (specific to membrane technology). TWG tasks: 1. provide information and plant-specific performance data regarding techniques for waste

water and waste gas treatment regarding the nine-heading standard structure; 2. provide information regarding brine purge treatment techniques


3.7 Current consumption and emission levels 3.7.1 Emissions and consumption levels update The wishes received from the TWG underlined the need for: • updating data on emissions to air and water as well as energy and raw material

consumption; • establishing requirements for data transmission (e.g. oxygen content, half-hourly average,

daily average, concentration unit, emissions factors) and the use of a consistent data collection format;

• considering that emissions to air and water should also be given in concentration units and not only in emission factors (specific emissions);

• obtaining and providing site-specific information concerning the real performances of measures/techniques.

The following proposal of the EIPPCB was discussed: 1. provide up-to-date information and plant-specific consumption and emissions data for

both emission concentrations and emission factors in a consistent format. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slides 33 – 34):

Information identified or promised to be provided by the TWG: • Euro Chlor documents; • ‘Good Mercury Housekeeping’ guide by Euro Chlor; • Euro Chlor will provide information about mercury mass balances; • FR will try to obtain data and best practices from example sites as references; • Data from reports of Member States; • AT will provide plant-specific data (also from the Austrian report ‘Medienübergreifende

Umweltkontrolle in ausgewählten Gebieten’; http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf) and will try to get new data.

TWG tasks: 1. provide updated information and plant-specific consumption and emissions data; 2. obtain and provide consumption and emissions data from example plants (FR); 3. provide data by using a consistent data format and by addressing monitoring issues:

i. type of emissions and how the data were generated or measured, i.e. as a half hourly, daily, monthly, yearly average or estimated by calculation;

ii. unit and emissions ranges time period related to this; iii. monitoring frequencies, e.g. for periodic, continuous measurements; iv. standard conditions of emissions (e.g. volume flow, oxygen content,

concentrations, standard state).



3.7.2 Diffuse emissions from cell rooms The wishes received from the TWG underlined the need for: • regarding cell-room ventilation, updating data for mercury emissions; • requiring a better, more standardised and more realistic level of monitoring and reporting

of emissions from the cell room; • considering that air flow determination has to be detailed, as it is an important parameter

for the evaluation of diffuse emissions from cell rooms; • including general measures/techniques to prevent and to reduce diffuse/fugitive

emissions. The following proposals of the EIPPCB were discussed: 1. provide information on diffuse emissions from cell rooms by:

i. obtaining data and information on best measures/techniques from example plants; ii. identifying the main/best criteria for air flow calculation.

2. provide information regarding the monitoring and reporting of emissions from the cell room;

3. provide information regarding general measures/techniques to prevent and to reduce diffuse/fugitive emissions.


Information identified or promised to be provided by the TWG: • revised draft of the CWW BREF, specifically the section on diffuse dust emissions; • FR will try to obtain data and best practices from example sites and will try to identify

main/best criteria for air flow calculation; • French general guidelines written by the ‘Halogens and Derivates Association’ for the

determination of diffuse emissions; • Euro Chlor will provide guidelines on measuring diffuse emissions from cell rooms. TWG tasks: 1. provide information regarding the monitoring and reporting of emissions from cell

rooms; 2. provide data and measures/techniques from example sites and identify main/best criteria

for air flow calculation (FR); 3. check French general guidelines for the determination of diffuse emissions; 4. check revised draft of the CWW BREF, specifically the section on diffuse dust

emissions; 5. regarding cell-room ventilation, provide updated data for mercury emissions and

occupational exposure levels.

3.7.3 Emissions to water The wishes received from the TWG underlined the need for: • in general, updating data on water emissions; • adding data on water emissions regarding waste brine treatment plants:

◦ the effluent has a high chloride load and if associated with mercury cell, is a significant contributor to the mercury releases to water.


• updating data on mercury in waste water streams; • regarding the membrane cell process:

◦ investigating and add data on water emissions (i.e. chlorinated substances, free oxidants to water);

◦ updating data on chlorate in waste water. The following proposals of the EIPPCB were discussed: 1. collect and provide information and data regarding emissions to water by using a

consistent/uniform data format; 2. information and plant-specific data regarding hazardous substances in waste water from

CAK plants along with existing abatement or purification techniques. Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slide 36):

Information identified or promised to be provided by the TWG: • AT will provide data regarding the membrane process from the Austrian report

‘Medienübergreifende Umweltkontrolle in ausgewählten Gebieten’, http://www.umweltbundesamt.at/fileadmin/site/publikationen/M168.pdf) and will try to get new data;

• Euro Chlor will provide information regarding the waste brine plants (also for recycled brine).

TWG tasks: 1. provide updated information and plant-specific data regarding emissions to water for all

three chlor-alkali processes, especially regarding: i. hazardous substances in waste water along with existing abatement or

purification techniques; ii. waste brine treatment plants;

iii. mercury in waste water streams; iv. the membrane cell process, i.e. chlorinated substances, free oxidants to water,

chlorate.



3.8 Issues regarding emerging techniques The wishes received from the TWG underlined the need for: • in general, updating information on the emerging techniques mentioned in the CAK

BREF and provide developments on them; • checking whether emerging techniques mentioned in the CAK BREF are still emerging

or are already in use; • providing information regarding the gas diffusion technology (generating chlorine) which

may cut the power consumption further by 30 – 40 % (energy consumption at 1500 kWh) and add it to the BREF;

• checking whether further emerging techniques are available and provide information. The following proposals of the EIPPCB were discussed: 1. provide information and data regarding emerging techniques and further developments; 2. provide information regarding the issue of whether the emerging techniques mentioned in

the CAK BREF are still considered emerging; 3. provide information regarding the gas diffusion technology (generating chlorine) which

may cut the power consumption further by 30 – 40 % (energy consumption at 1500 kWh).


Information identified or promised to be provided by the TWG: • Euro Chlor will provide updated information on the gas diffusion technology and other

potential developments; • Euro Chlor will provide info on abandoned/discontinued techniques TWG tasks: 1. provide information and data regarding emerging techniques and further developments; 2. provide information regarding the issue of whether the emerging techniques mentioned in

the CAK BREF are still considered emerging; 3. provide information regarding the gas diffusion technology (generating chlorine) which

may cut the power consumption further by 30 – 40 % (energy consumption at 1500 kWh);

4. provide information regarding further emerging techniques which are available.


3.9 Information exchange and data collection The provision of text and data during the exchange of information is a vital part of reviewing a BREF. The consumption and emissions data in particular are important for identifying the best performers and to identify a range of performance data that is associated with the use of BAT. The performance data supplied to the European IPPC Bureau in the past were often aggregated from several installations and were not always accompanied by the necessary supporting operational information. Therefore, these performance data were of limited use in the process of determining BAT and BAT Associated Emission Levels (AELs). In order to perform a clear classification of techniques for BAT determination, it is necessary to obtain information in such a way that techniques can be compared with one another. The provision of data and descriptive information during the exchange of information is a vital part of reviewing a BREF. Consumption and emissions data in particular are important for identifying the best performing installations and to identify a range of performance data that can be associated with the use of BAT. As this has been identified in many of the wishes, the original CAK BREF contains limited data and information on the current consumption and emission levels and on the performance of techniques to be considered in the determination of BAT, especially on the achievable emission and consumption levels (AELs). Performance data supplied to the European IPPC Bureau in the past were often aggregated from several installations and were rarely accompanied by the necessary supporting operational information. Therefore, performance data had limited use in the process of determining BAT. The CAK BREF needs to be updated and improved with respect to economics information, such as conversion cost information as well as the costs of techniques. Furthermore, the BREF needs major improvements on energy consumption and energy efficiency information. The recommendations for future work in the original BREF include the wish to scrutinise the membrane cell process and to collect more data and information on this issue. Furthermore, information regarding the decommissioning of mercury cell plants in the EU-27 should be included. Information should be submitted to the European IPPC Bureau preferably using a common template. Templates are particularly useful for gathering a great deal of information, for enabling the comparison of data and for identifying gaps and anomalies through the possibility of obtaining standardised data. A questionnaire for the collection of information and data was prepared by the European IPPC Bureau which was discussed, developed further and agreed upon at the kick-off meeting.


3.9.1 Member States reports on the implementation of the IPPC Directive

The wishes received from the TWG underlined the need for: • Using information and data from the IPPC Member States’ reports on the chlor-alkali

manufacturing industry which was provided to the Commission (DG ENV) in 2009. The following proposals of the EIPPCB were discussed: 1. use actual monitored emissions at the permitted level (plant-specific data) along with

information on monitoring frequency and duration requirements from the Member States’ reports (reporting period 2005 – 2007, EU-25), if provided and available;

2. the collected emission limit values (ELVs) from IPPC permits could be useful only for basic discussions of the CAK BREF review process.

a. Please remember that the BREF concludes on BAT along with BAT associated emission levels but not on ELVs.


Information identified or promised to be provided by the TWG: • Member States’ reports on the implementation of the IPPC Directive (reporting period

2005 – 2007 for EU-25 chlor-alkali installations) which will be provided to the European Commission (DG ENV) in 2009.

TWG tasks: 1. Provide the EIPPCB with information and data on Member States’ reports on the

implementation of the IPPC Directive (reporting period 2005 – 2007 for EU-25 chlor-alkali installations) � EIPPCB will get the reports from DG ENV.

3.9.2 General principles for providing information for the review of the BREF – general update

The wishes received from the TWG underlined the need for: • updating data for the EU-27 in general; • providing missing information for the techniques regarding performances, cross-media

effects, consumption, economics, applicability, operational data, example plants and driving forces for implementation;

• providing plant-specific information in a non-aggregated form; • providing emissions performance data both in emissions concentrations (e.g. mg/Nm3)

and emissions factors (e.g. g/t); • providing information from best performers; • considering that emissions levels should be accompanied by the appropriate averaging

period (e.g. hourly average, daily average, yearly average), reference conditions (e.g. oxygen content) and any other relevant information to enable a comparison with sets of data from other installations.


The following proposals of the EIPPCB were discussed: 1. data on techniques to consider in the determination of BAT should be provided with all

of the information shown in IEF 20-4 Guidance document on improving the collection and submission of data for the review of the BREFs (nine-headings structure);

2. a draft template for the reporting of information and data on CAK plants was attached as Annex II to the background paper of the kick-off meeting and should be used for providing plant-specific information and data;

3. provide plant-specific information and data about the environmental performances of chlor-alkali plants, essentially from good performers, using the templates attached as Annexes to the background paper of the kick-off meeting.

Regarding the minimum requirements given by the IEF 20-4 Guidance document on improving the collection and submission of data for the review of the BREFs, the standard structure (nine-heading structure) for describing the ‘Techniques to consider in the determination of BAT’ was explained and examples on types of information to be included were given for information and for data collection and report. The discussion covered the issue on providing information and plant-specific data about the environmental performance of CAK plants by using a consistent data collection format. It was emphasised that monitoring issues should be addressed, such as: • the types of emissions and how the data were generated or measured, i.e. as a half-hourly,

daily, monthly or yearly average or estimated by calculation; • the time period related to the units and emissions ranges; • monitoring frequencies, e.g. for periodic, continuous measurements; • standard conditions of emissions (e.g. volume flow, oxygen content, concentrations,

standard state). It was also underlined to take care when determining the reference conditions for emission values to air and water and to relate data to specific products and production rates, if applicable. Furthermore, it was stressed to preferably submit information at the site level to the European IPPC Bureau by using a common template. Templates are particularly useful for gathering a great deal of information, for enabling the comparison of data as well as for identifying gaps and anomalies. The questionnaire for data collection prepared by the EIPPCB was discussed, developed further during the kick-off meeting and it was agreed upon and concluded on page by page at the kick-off meeting. The comments and remarks the TWG made both at the kick-off meeting and after a short commenting period after the kick-off meeting were included. It was concluded on to collect information at the site level in a coordinated way between the Euro Chlor secretariat and members of the TWG to avoid the duplication of efforts Conclusions reached by the TWG after discussion (please also see the PowerPoint Conclusion Slides 39 – 40):

Information identified or promised to be provided by the TWG: • IEF 20-4 guidance document on improving the collection and submission of data for the

review of the BREFs (http://eippcb.jrc.ec.europa.eu/ief/) attached to this document (Annex I);

http://eippcb.jrc.ec.europa.eu/ief/




• Member States’ reports on the implementation of the IPPC Directive (reporting period 2005 – 2007 for the EU-25.

Supporting materials: • Annex I of this meeting report indicates the type of information that is needed to describe

in the CAK BREF the techniques to consider in the determination of BAT (see also 3.1 of the IEF 20-4 guidance document);

• Annex II to this meeting report indicates the questionnaire for gathering and providing data concerning the environmental performance of CAK plants. The questionnaire has been developed further during the kick-off meeting, was modified as it was discussed and concluded on.

TWG tasks: 1. provide data on techniques to consider in the determination of BAT with all of the

information shown in Annex I to this meeting report (nine-heading structure); 2. provide plant-specific information and data about the environmental performances of

chlor-alkali plants, essentially from good performers, using the templates attached to the BP meeting report (Annexes I and II);

3. provide data and information in accordance with the updated and modified questionnaire (Annex II);

4. collect information at the site level in a coordinated way between the Euro Chlor secretariat and members of the TWG to avoid the duplication of efforts.

3.9.3 Exchange of information communication An effective information exchange is dependent on the active involvement of all TWG members. The TWG is expected to collaborate fully and to use objective scientific communication to support the views expressed. The organisation of data collection within the TWG was discussed and it was concluded that information would be collected at the site level in a coordinated way between the Euro Chlor secretariat and members of the TWG to avoid the duplication of efforts (please also see conclusion slide 41). Information submissions may take the form of quantitative data or qualitative descriptions, but they have to be provided on time, on target and in the appropriate and consistent format. In accordance with the updated generic schedule for the review of BREFs (agreed upon at IEF 1 April 2009), the deadline for the provision of information was concluded to be 15 April 2010 (please also see conclusion slide 43). Early submissions are obviously welcome. Any data referring to installations, techniques, equipment, etc. should be exchanged through the BAT information system (BATIS). BATIS is a web-based software application set up to facilitate the exchange of information on BAT as well as the internal process carried out within the EIPPCB in order to produce or review BREFs. BATIS helps to maintain transparency in the BREF elaboration process. Furthermore, it helps to organise and to manage BREF-related information. The information management system should be considered a tool for the elaboration of BREFs, for the collecting, publishing and sharing of initial information and data, and for drafting, approving and publishing the BREF. An introductory presentation on the basic use of the system was provided by the EIPPCB.


The members of the CAK TWG have access to the CAK forum within BATIS for exchanging information. The forum is accessible by members of the CAK TWG and EIPPCB staff only. A personal invitation to join BATIS was sent by e-mail to all TWG members after the kick-off meeting. IEF members have access to BATIS to read only. Registering, logging into the system, posting and reading documents need to be followed by each TWG member and cannot be carried out by the EIPPCB. Should any member request assistance in the use of BATIS, they should not hesitate to contact the EIPPCB secretariat (email: [email protected]; tel.: +34 954 48 8284; fax: +34 954 488426) Both the email and the EIPPCB forum within BATIS play an important role in the information exchange. Any short communication or any minor information should be transmitted vial email. Site visits constitute a good method for understanding the sector, identifying specific issues and gathering and validating information. Some TWG members (Euro Chlor) have already offered their help to organise site visits for the BREF author. TWG members may also be invited to participate in visits if possible. Brief reports on such visits will be made available through the BATIS system.

3.9.4 TWG personal data on the EIPPCB web page The European IPPC Bureau informed TWG members that their personal data, which consists of the addressee’s name and contact details, have been collected from their appointment as a TWG member with the exclusive purpose of allowing the Institute for Prospective Technological Studies (IPTS) of the Joint Research Centre (JRC) of the European Commission to manage TWG member's participation in the review of the CWW BREF and to allow TWG members to access the contents management tools for the editing and reviewing of BREFs and other documents. Additionally, and in order to facilitate the work of the TWG, the IPTS publishes TWG contact details on its website: http://eippcb.jrc.ec.europa.eu.

The European Commission is committed to user privacy. The policy on ‘protection of individuals with regard to the processing of personal data by the Community institutions’ is based on Regulation (EC) N° 45/2001 of the European Parliament and of the Council of 18 December 2000. The European Commission, responsible for the treatment of the personal data mentioned above, will retain the data. At any time, TWG members may exercise their right to access and modify the data by contacting the European IPPC Bureau Secretariat: email: [email protected] Tel: +34 954 488 284 Fax: +34 954 488 426

mailto:[email protected]

mailto:[email protected]


4 ANNEX I: STANDARD STRUCTURE FOR CHAPTER 4 When providing information on 'Techniques to consider in the determination of BAT', the use of a standard structure is required in order to enable comparisons of techniques and so that an objective assessment against the definition of BAT given in the IPPC Directive can be made. This standard structure is stipulated in the BREF Outline and Guide and is as shown in Section 4.1 of this meeting report. It is necessary to use this standard structure for the provision of information for specific techniques.


4.1 Type of information needed to fill in the chapter(s) on 'Techniques to consider in the determination ofBAT' and to derive useful BAT conclusions

In order to determine BAT, all techniques to be considered in the BAT decision-making process will be presented in the BREF according to a standard structure,shown in the first two columns of the following table. The third column gives more details on the specific data which are needed from the TWG members in orderto draft 'Techniques to consider in the determination of BAT' and to derive useful BAT conclusions from them.

Name of the typeof information Type of information to be included in the BREF Important information to collect and to report1

Description Technical description of the technique (includingdrawings, schematics if necessary)

The description can include both prevention and control measures (in-process and end-of-pipe)

Achievedenvironmental benefits

The main environmental impacts (including energy,water, raw material savings, as well as productionyield increases), addressed by the technique

Cross-mediaeffects

Any side effects and disadvantages to other environmentalmedia (e.g. air, water, land) caused by implementation.Environmental effects of the technique in comparisonwith others

The Reference Document on Economics and Cross-media Effects (ECM) is a documentthat should be taken into account with regard to cross-media aspects as far as there aresignificant cross-media effects. This document is available from the European IPPCBureau website at http://eippcb.jrc.ec.europa.eu

OperationalData

Data on consumption and emission levels fromoperational plants using the technique (includingreference conditions – e.g. O2 level – and monitoringmethods used). Any other information on how tooperate, maintain and control the technique

Emissions data (see also Sections 3.7.1 and 3.9 of this background paper):• both the concentration and (specific) load of pollutant(s) (if available) or the data

needed to derive this information. For specific load data, the product referred toshould be clearly defined

• the quantity of pollutant before and after the abatement system in order to determinethe abatement efficiency

• the Reference Document on General Principles of Monitoring (MON) is a documentthat should be taken into account with respect to the expression of monitoring resultsand how to deal with uncertainties, emission factors, direct measurements andmonitoring requirements

Consumption data:• the type and amount of fuel, energy (heat, electricity), water and raw

materials/chemicals consumed/used by the techniqueWaste:• the type and quantities of waste generated and treatment/disposal methods and/or

techniques to prevent waste

1 based on the main gaps identified during the elaboration of the first series of BREFs


FS/EIPPCB/CAK KOM report September 43

Name of the typeof information Type of information to be included in the BREF Important information to collect and to report1

Operationaldata

Others:• sensitivity and durability of the technique• operation/control/maintenance issues

ApplicabilityIndication of the type of plants in which the technique may beapplied, considering, e.g. plant age (new or existing), plant size(large or small), techniques already installed and type of product

Examples:• information on retrofitting of parts of the installation

EconomicsInformation on costs (both investment and operational) andpossible savings, including details on how these costs have beencalculated

• capital/investment, operating and maintenance costs including details on how thesecosts/savings have been calculated/estimated

• possible savings (including payback time), including details on how thesecosts/savings have been calculated/estimated

• cost data will preferably be given in Euros (EUR). If a conversion is made fromanother currency, the data in the original currency and the year when the data werecollected will be indicated. This is important as conversion rates vary over time

• price/cost of equipment or service will be accompanied with the year it waspurchased

• information on the market for the sector to put costs of techniques into context

The Reference Document on Economics and Cross-media Effects (ECM) and theReference Document on the General Principles of Monitoring (MON) should be takeninto account with regard to economic aspects and monitoring costs, respectively. Bothdocuments are available from the European IPPC Bureau website athttp://eippcb.jrc.ec.europa.eu

Driving force forimplementation

Local conditions or requirements which lead to or may stimulateimplementation. Information on reasons other thanenvironmental ones for implementation (e.g. increase inproductivity, safety)

Examples:• information on type/quality of receiving waters (e.g. temperature, salinity)• information on environmental quality standards• information on the increase of production or productivity

Example plants Reference to plants in which the technique is applied and fromwhich information has been collected

Reference literature Literature that was used in writing the section and that containsmore details


44 September FS/EIPPCB/CAK KOM report

5 ANNEX II: TEMPLATE FOR THE PROVISION OF INFORMATION FOR THE REVIEW OF THE CAK BREF (QUESTIONNAIRE)

The questionnaire was developed further by the TWG during the kick-off meeting. Furthermore, it was modified because of the comments received from the TWG after the kick-off meeting. Please note that the questionnaire for data collection is available on BATIS. The working platform is accessible to CAK TWG members.