Reviewing the Large Combustion Plant BREF
BATs need to be updated once in a while. Photo: Trey Ratcliff/Creative Commons
The references documents for best available technique (BAT) for large combustion plants are under review. New issues like oil shale, firing of high-sulphur coal and greenhouse gases such as nitrous oxide and sulphur hexafluoride will be considered.
2011 has seen the start of the review process for the Large Combustion Plant (LCP) BREF. BREFs (BAT Reference Documents) are large technical documents, originally produced under the Integrated Pollution Prevention and Control (IPPC) Directive to assist the writing of industrial permits for individual installations. This legislation has now been replaced by the Industrial Emissions Directive (IED), and the LCP BREF review is the first to take place wholly under this new legislation.
BREFs set out the EU benchmark standards for Best Available Techniques (BAT) for each industrial sector or cross-sector issue, and under the IPPC Directive they were provided as guidance for permit writers. However, under the IED, their status has been upgraded to provide the reference for regulators, with derogations from the BREF BAT standards only being allowed if a public justification is made on the basis of particular local factors specified in the legislation.
The LCP BREF review has attracted a lot of attention, resulting in an abnormally large Technical Working Group (TWG) of nearly 140 representatives of member states, industry and environmental NGOs. This large representation produced nearly 2400 proposals for revision during the submission of wish lists from TWG members earlier this year.
These wishes were integrated into a background paper for discussion at the Kick-off Meeting of the TWG that took place in Seville at the end of October. Over a three-day period, the meeting reached conclusions on a range of issues, including the scope and structure of the BREF. Here, for example, it was decided to keep co-incineration of waste within the BREF, but to add a new chapter on gasification/pyrolysis/liquefaction. This will appear alongside chapters for each of solid, liquid and gaseous fuels, within which multi-fuel combustion will be included. Carbon capture will also be formally covered, possibly as part of a wider section on emerging techniques.
The revised BREF will also lay greater emphasis on cross-reference to other relevant BREFs, both to avoid duplication and to increase the legibility of the series of BREFs taken as a whole.
The revision process only addresses those parts of the existing BREF where modification and/or updating are judged necessary. These include not only revisiting the sections on mercury, biomass, etc., to take account of recent technical developments, but also considering new issues as appropriate e.g. oil shale, firing of high-sulphur coal and greenhouse gases such as nitrous oxide and sulphur hexafluoride. Data is also to be collected to determine whether there is a case for setting BREF BAT standards for modes of operation other than base load e.g. for mid-merit, peak and emergency loads.
Given the new guidance currently being developed to assist the BREF process1, the design of a plant data collection questionnaire and the methodology for processing the data are important parts of the review process. A sub-group is to be formed to finalise the draft questionnaire, and member states are to nominate reference plants with good environmental performance within each sub-category to receive the questionnaire, together with a rationale for their selection.
This data collection process is scheduled until the end of May 2012, after which the first draft of the revised BREF is expected by the autumn of 2012, with comments to be received by January 2013. This will be followed by a second draft and a further round of comments by the autumn of 2013. A final meeting of the TWG is scheduled to take place in Seville in the spring of 2014, with the revised BREF being available for presentation to a Forum meeting in the autumn. The formal process of adopting the BAT conclusions determined in the review process will follow that.
Lesley James, representing the European Environmental Bureau in the review of the LCP BREF.
1 GUIDANCE DOCUMENT on the practical arrangements for the exchange of information under the Industrial Emissions Directive (2010/75/EU), including the collection of data, the drawing up of best available techniques reference documents and their quality assurance as referred to in Article 13(3)(c) and (d) of the Directive