The IPPC RecastThe IPPC Recast

New environmental requirements

for explosives production sites

LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATIONDIRECTIVE 1996/61/EC

Every chemical production site was in the scope of Directive 1996/61/EC (IIPC Directive). Transposition to Member States regulations was done before 2002.

Chemical production of explosives (Annex 1, reference 4.6, IPPC Directive) is included in chemical installations section.

A new (codified) text was published in 2008 (Directive 2008/1/EC) having basically the same kind of requirements: new permit for existing installations, new allowable emission levels (AEL) as decided by authorities, etc. AEL were selected by taking into account the list of Best Available Techniques (BAT).

Therefore, BATs were voluntary (not mandatory) for the industry.

LEGAL REQUIREMENTS IN THE PREVIOUS LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION (2): DIRECTIVE 1996/61/EC LEGISLATION (2): DIRECTIVE 1996/61/EC

BATs have been derived by European Commission BATs have been derived by European Commission IPPC Bureau at Seville, Spain. BAT documents IPPC Bureau at Seville, Spain. BAT documents are called BREF (BAT Reference Documents). are called BREF (BAT Reference Documents). BREFs are prepared by means of the BREFs are prepared by means of the “Seville “Seville process”process” through information exchange between through information exchange between industry, authorities from Member States and any industry, authorities from Member States and any other interested parties (universities, NGOs etc). other interested parties (universities, NGOs etc). Several BREF have been prepared at Seville from Several BREF have been prepared at Seville from 2000 to 2007. The most important BREFs related 2000 to 2007. The most important BREFs related with our explosive production sector are:with our explosive production sector are:

1.1.BREF-CWW (common aspects of waste gas and BREF-CWW (common aspects of waste gas and waste water treatment)waste water treatment)

2.2.BREF-OFC (organic fine chemicals, related to BREF-OFC (organic fine chemicals, related to DEGN production, MMAN production, etc).DEGN production, MMAN production, etc).

3.3.BREF-SIC (specialty inorganic chemicals, BREF-SIC (specialty inorganic chemicals, related to primary explosives production).related to primary explosives production).

A new COMMISSION A new COMMISSION

IMPLEMENTING DECISIONIMPLEMENTING DECISION entered into force on 10 February entered into force on 10 February 2012, laying down rules 2012, laying down rules concerning guidance on the concerning guidance on the collection of data and on the collection of data and on the drawing up of BAT reference drawing up of BAT reference documents and on their quality documents and on their quality assurance referred to in Directive assurance referred to in Directive 2010/75/EU of the European 2010/75/EU of the European Parliament and of the Council on Parliament and of the Council on industrial emissions. The industrial emissions. The complete text is available under complete text is available under www.eur-lex.europa.eu.www.eur-lex.europa.eu.

NEW REQUIREMENTS ACCORDING TO NEW IPPC NEW REQUIREMENTS ACCORDING TO NEW IPPC DIRECTIVE Industrial Emission DIRECTIVE Industrial Emission

Directive - Directive - DIRECTIVE 2010/75/EUDIRECTIVE 2010/75/EU

Industrial Emission Directive (IED)Industrial Emission Directive (IED) supersedes the supersedes the previous IPPC Directive. Member States have to previous IPPC Directive. Member States have to transpose it by the transpose it by the end of 2012end of 2012. According to IED, the . According to IED, the BAT (and the AEL) adopted by IPPC Bureau are BAT (and the AEL) adopted by IPPC Bureau are mandatory (legally binding)mandatory (legally binding) for authorities when writing for authorities when writing a permit. Nevertheless, only new BATs (included in a permit. Nevertheless, only new BATs (included in new BREFs documents) will be mandatory. After new BREFs documents) will be mandatory. After IED, the first BREF that will be adopted will be: IED, the first BREF that will be adopted will be: BREF-CWW (common aspects of waste gas and BREF-CWW (common aspects of waste gas and waste water treatmentwaste water treatment). A 2nd Draft of BREF has ). A 2nd Draft of BREF has been uploaded to the Internet in July 2011. Final been uploaded to the Internet in July 2011. Final BREF is scheduled to be adopted by mid-2012.BREF is scheduled to be adopted by mid-2012.

BAT Conclusions will be translated into every BAT Conclusions will be translated into every official European language in order to be the official European language in order to be the legally binding text.legally binding text.

Industrial Emission Directive - DIRECTIVE 2010/75/EU

NEW REQUIREMENTS ACCORDING TO NEW IPPC DIRECTIVE (2)

Up to now, there is no specific BAT concerning explosive waste management. Therefore, open burning and open detonation (OB/OD) methods can be authorized (or forbidden) at Member State level.

BREF-CWW (2nd draft) pays especial attention to VOC (Volatile organic compounds) and odour emissions and AEL for central waste water treatment plants. More information in: http://eippcb.jrc.es/

OFC and SIC BREFs will be of special interest for our industry.

Manufacture Manufacture of of

Organic Fine Chemicals (OFC)Organic Fine Chemicals (OFC)

This BREF focuses on the batch manufacture of This BREF focuses on the batch manufacture of organic chemicals in multipurpose plants and organic chemicals in multipurpose plants and addresses the manufacture of a wide range of addresses the manufacture of a wide range of organic chemicals. Some production sites may also organic chemicals. Some production sites may also include dedicated production lines for larger include dedicated production lines for larger volume products with batch, semi-batch or volume products with batch, semi-batch or continuous operation. The list includes amongst continuous operation. The list includes amongst other OFC: other OFC:

Organic ExplosivesOrganic Explosives

BREF on Production of Specialty Inorganic BREF on Production of Specialty Inorganic Chemicals (BREF-SIC). Final BREF (August 2007). Chemicals (BREF-SIC). Final BREF (August 2007). Chapter 6 (paragraph 6.4) deals with production of Chapter 6 (paragraph 6.4) deals with production of primary explosivesprimary explosives (Lead Azide, Lead Styphnate, Lead (Lead Azide, Lead Styphnate, Lead Picrate). This BREF will be updated by the Picrate). This BREF will be updated by the European Commission European Commission after 2013after 2013. Management of . Management of waste explosives by open burning/detonation is not waste explosives by open burning/detonation is not included in BAT conclusions. Nowadays the included in BAT conclusions. Nowadays the contents of BAT conclusions are only contents of BAT conclusions are only recommendations for authorities.recommendations for authorities.  BREF on Waste incineration. Final BREF (August BREF on Waste incineration. Final BREF (August 2006). No chapter is devoted to explosive waste 2006). No chapter is devoted to explosive waste management. The relevant management. The relevant explosives’ waste BREFexplosives’ waste BREF will will be updated by European Commission be updated by European Commission after 2013after 2013. . Nowadays the contents of BAT conclusions are only Nowadays the contents of BAT conclusions are only recommendations for authorities.recommendations for authorities.

Manufacture Manufacture of of

Specialty Inorganic Fine Chemicals (OFC)Specialty Inorganic Fine Chemicals (OFC)

The BREF SIC gives information on the The BREF SIC gives information on the manufacture of Specialty Inorganic manufacture of Specialty Inorganic

Chemicals (SIC) in the EU: Chemicals (SIC) in the EU:

1.1.general information general information 2.2.applied processes and techniques applied processes and techniques 3.3.current emission and consumption levels current emission and consumption levels 4.4.techniques to consider in the techniques to consider in the

determination of BAT determination of BAT 5.5.best available techniques (BAT) best available techniques (BAT) 6.6.emerging techniques. emerging techniques.

This topic has been included in the agenda This topic has been included in the agenda of the FEEM Health and Safety Working of the FEEM Health and Safety Working Group as it will possibly impact across a Group as it will possibly impact across a large number of businesses and members large number of businesses and members should be aware that it has the potential should be aware that it has the potential to cause problems. to cause problems.

The Working Group found it valuable to The Working Group found it valuable to review the BAT system for explosive review the BAT system for explosive manufacturing technology and the manufacturing technology and the handling of explosives wastes at their next handling of explosives wastes at their next meeting in September 2012 in Prague. meeting in September 2012 in Prague.

The IPPC RecastThe IPPC Recast