The impact of revised BREFs (Best Available

Techniques Reference Documents) on AELs

(Achievable Emission Limits) in the Metals Industries

William Averdieck william@pcme.co.uk

Contents

• Motivation and status for IED

• Role and status of BREFS

• Metals industry BREF notes and limits• Metals industry BREF notes and limits

• Monitoring requirements

– Industry specific requirements

– Monitoring BREF Notes

– Changes in relevant CEN standard

Where are we coming from?

• IPPC (Integrated Pollution

Prevention and Control)

– Started 1996, revised in

2008

– Objective: Prevent or

• WID (Waste Incineration

Plant)

• LCPD (Large Combustion

Plant Directive)

– Started 1988, replaced – Objective: Prevent or

minimise emissions to air

land and water from major

industrial plant

– Status at revision

• Uptake by 27 member

states is inconsistent

• Only 26,000 of 50,000 sites

have permits

– Started 1988, replaced

in 2001

IED (2010/75/EU)

• Published in Jan 2011

• Replaces IPPC, LCPD,

WID

• Same objectives as IPPC

and other Directives

• Improve quality and

consistency of

implementation

Implement Best Available

technology (BAT) on a more

prescriptive basis through

revision of BREFS (BAT

reference documents)

Timescales

• Jan 2011 IED into force

• Jan 2013 Transpose into national legislation

• Jan 2013 Applies to all new installations

• Jan 2014 Applies to existing installations on • Jan 2014 Applies to existing installations on

permit renewal (every 5 years)

• Jan 2015: applies to newly prescribed processes

(eg waste recovery, wood preservation)

• Jan 2016 LCP must meet new requirements

Increasing importance of BREFS

• More prescriptive approach in BREFS (Best

available techniques REFerence documents)

• Emission limits (Average Emission Limits: AELs

and other BREF condition shall be the reference and other BREF condition shall be the reference

for setting permit conditions

• Expectation that permits will be revised as new

or updated

• Critical role of BREF from now on

• Less strict emission limits have to be justified to

the commission

Timetable for ‘more prescriptive’

BREFS

• Metals industries

– Iron and Steel Production

– Ferrous Metals Processing Industries

– Non–Ferrous Metals Industries– Non–Ferrous Metals Industries

– Smitheries and Foundries

• Some other industries

– Large Volume Organic Chemical

– Large Combustion Plant

– Waste Incineration

Number of plant

BAT: Best Available Technology rather

than Lowest Common Denominator

Consistent with Emission Limits

falling for Power Plant

Pollutant Coal

Plant size

IED limit Historical

LCPD limit

Implication

for control

technology

Comment

Particulate 50 -500MW

>500MW

30mg/m3

20mg/m3

100mg/m3 (50 new plant)

50mg/m3 (50 new plant)

Bagfilters/

FGD>500MW 20mg/m3 50mg/m3 (50 new plant) FGD

SO2 50 -100MW

100 – 500MW

>500MW

400mg/m3

400 -150

150mg/m3

2000mg/m3 (850 new)

2000- 400 mg/m3

400mg/m3

FGD plant

NOX Up to 500MW

>500MW

300mg/m3

200mg/m3

600mg/m3

500mg/m3 (200mg/m3 in

2016)

Need SCR to

meet new

limits

Monitoring as specified in

Directive

• Article 14: Monitoring details need to be in the

permit

• Article 16: Monitoring should be BAT (therefore

must be covered in BREFS)must be covered in BREFS)

– Industry specific BREFS

– Monitoring guidance document

• Article 15: Emission limit values should be BAT

(again a focus of revised BREFS)

Example direction of NEW BREFs

• Non–ferrous industry BREF July 2009– 1-5mg/m3: associated emission limit value

– A bag burst detection system is needed with an instrument which can measure either

12

instrument which can measure either

• Trend in PM

• Peak heights during cleaning

– Dust should be monitored continuously

BAT: Best Available Technology rather

than Lowest Common Denominator

Reference Report on Monitoring

(ROM)

• Monitoring guidance rather than requirement

(replace Monitoring BREF 2003)

• To be used in conjunction with industry specific

BREFS which now are more prescriptive on BREFS which now are more prescriptive on

monitoring requirements

• Scope: air and water

• ROM anticipated to be published in Autumn 2014

– Comments received on draft

Monitoring BREF content

• 4.2 Monitoring of emissions to air

– 4.2.1 Definitions of air pollutants

– 4.2.2 Continuous/periodic measurements

– 4.2.2.1 When to measure continuously or periodically?

– 4.2.2.2 Continuous measurements

– 4.2.2.2.1 EN standards

– 4.2.2.2.2 Quality assurance system

– 4.2.2.2.3 Certified measuring systems according to

EN15267:2009

– 4.2.2.2.4 Measurement point, sampling and analysis

– 4.2.2.2.5 Reference conditions - Standard conditions

– 4.2.2.2.6 Data treatment

– 4.2.2.2.7 Reporting of measurement results

– 4.2.2.2.8 Elaboration of BREFs

ROM contents (cont)

• 4.2.2.3 Periodic measurements

• 4.2.2.3.1 EN standards

• 4.2.2.3.2 General remarks

• 4.2.2.3.3 Measurement sites and sections

• 4.2.2.3.4 Measurement objective and measurement plan • 4.2.2.3.4 Measurement objective and measurement plan

• 4.2.2.3.5 Measurement frequency

• 4.2.2.3.6 Analysis of the collected samples

• 4.2.2.3.7 Reference conditions - standard conditions

• 4.2.2.3.8 Data treatment

Further ROM contents

(Chapter 4: air monitoring)

– 4.2.3 Indirect monitoring of emissions using surrogate

parameters (PEMS and filter leak )

– 4.2.4 Monitoring of diffuse diffusive and fugitive emissions

– 4.2.5 Odour measurements

– 4.2.6 Indirect monitoring of emissions using biological monitoring

with plants

– 4.2.7 Monitoring costs aspects of emissions to air connected

with monitoring

Amendment: EN-14181:

Quality Assurance of AMS

• Used in major plant

• Document for Technical Enquiry early in 2012,

soon to be published

– Some clarification on– Some clarification on

• Calibration at low levels

• Visibility to QAL3 results (even if internal to instrument)

• Openness to different types of QAL3 charts

• Period between QAL3

– Maintenance interval!

PS-11 and EN-14181 compared

Linearity check

Calibration check

with SRM

7 day drift

test

Initial correlation

audit (ICA)Zero and

upscale

Relative response

Audit (RRA)

Time

Customer

purchase

QAL 1

Instrument

certification

QAL 2

Calibration

QAL 3

On going QA

Zero and Span

AST

1 year

QAL 3

Absolute correlation audit (ACA) with

3 reference materials

Revision: EN-13284: Dust

Standards

• EN-13284-1: (SRM) revision in process

– Important for low dust levels

• EN-13284-2 (AMS) revision in process• EN-13284-2 (AMS) revision in process

– Calibration at low dust levels

– Dealing with practical problems

– Appendix for filter leak monitors

Relevant for mass reporting and velocity profiles

New standards for

– Part 1: Manual methods for velocity and flow

• S,P 3D pitot (flow and velocity)

New: EN-16911: Flow

• S,P 3D pitot (flow and velocity)

• including tracer methods (flow)

– Part 2: AMS

• Not restrictive on technology (QAL1 specified)

• Incentive for flow profiling to encourage use of AMS

with appropriate measurement path

• New statistical approach for calibration

New: Data Acquisition standard

• CEN TC-264 WG-9 drafting standard (nearing

completion)

• Scope includes industrial emissions reporting

• Basis for software certification and QA• Basis for software certification and QA

• Consistent approach

– Calculations of averages

– Rules for valid and substitute date

– Minimum reporting requirements

– Data security

Summary

• IED in implementation phase

• BREFs for metals industry confirming lower

emission limits as BAT

• Monitoring approach specified in BREFS

• Guidance on monitoring supported in ROM

• ROM refers to relevant CEN standards, some of

which are new and others being updated due to

parallel activities