By 2007/8, some 4500 installations regulated by the UK’s Environment Agency (EA) under the Integrated Pollution Prevention and Control (IPPC) regime brought in by the EU IPPC Directive should finally have completed the permitting process.
The activities listed in the directive include energy production, the processing of metals, minerals; chemicals; waste management; pulp and paper; textiles treatment; tanning; food production and intensive farming. The latest available figures show that approximately 450 permits had been issued for Part A(1) processes. Such installations are regulated by the EA, and usually relate to the largest, potentially most polluting operations.
For many companies seeking to get to grips with the permit regime and complying with the UK Regulations which implement the Directive (Pollution Prevention and Control (England and Wales) Regulations 2000), a visit to the EA website to seek further clarification is likely to be their first port of call. Yet many of them probably don’t then turn to the detailed and comprehensive EU guidance which underpins the UK IPPC regime.
Known as BREFs (BAT References), these documents have now been drawn up by the European Integrated Pollution Prevention and Control Bureau (EIPPCB) in order to create an EU-wide information exchange process between member states on Best Available Techniques (BAT).
Since 2001 over 30 of these sector-specific guides have been prepared, with over half of them formally adopted by the Commission. While the BREF notes do not constitute binding requirements, competent authorities in the member states are required to take account of them in their own determinations of BAT.
However, while the EA refers to the BREFs, its own guidance to UK manufacturing sectors in no way reflects the breadth and depth of information they contain. For example, its UK guidance for delivering the PPC (IPPC) regulations in the pulp and paper sector states briefly that “the quality, comprehensiveness and usefulness of the BREF is acknowledged. This guidance is designed to complement the BREF … The reader is advised to have access to the BREF.”
This doesn’t really do justice to the 500 plus page document available for free from the EIPPCB website. As a result, many potential users of the documents are probably failing to realise the scope of these comprehensive documents. The people responsible for day-to-day operations of their plant who would gain significant benefits from the guidance may simply not be aware of their existence.
So why should process engineers take a look at the BREFs? The short answer is that the BREF’s specific focus on maximising resource efficiency, consumption and use of raw materials – including water and energy inputs – all now play an increasingly central role in process optimisation and ultimately, the delivery of bottom-line business benefits.
No resource and energy-intensive industrial sector can afford to ignore these issues, or do the minimum possible to get by – the upward spiral of rising energy prices, the need to reduce carbon dioxide emissions and the constraints of the Emissions Trading Scheme have put paid to that.
Two sectors of interest
To take a short look at just two of the sectors covered by the BREFs where final documents or the latest drafts have recently been published will give some indication of the scope of this EU best practice guidance.
Firstly, the final draft of the Draft Reference on BAT for the Surface Treatment of Metals and Plastics (STM) which was published in May 2005. While STM in itself does not form a distinct vertical sector, it provides a service to a wide range of industries which treat metals and plastics to change their surface properties, for example for decoration and reflectivity, improved hardness and wear resistance, corrosion prevention and as a base to improve adhesion of other treatments.
The STM industry plays a major role in extending the life of metals – for example, in automotive bodies and construction materials. It is also used in equipment that increases safety or reduces consumption of other raw materials. The BREF addresses both process-integrated and end-of-pipe techniques, with over 200 techniques for pollution prevention and control discussed under 18 specific areas. These include, for example, general operational issues such as: utility inputs and their management to optimise electricity consumption, and the amount of energy and/or water used in cooling.
The BREF goes into considerable detail about a wide range of process techniques. For example, the retention of raw materials in process vats and minimisation of water use by controlling the drag-in and drag-out of process solutions.
The guidance describes how this can be achieved by jigging and barrelling workpieces to enable rapid draining, preventing overdosing of process solutions and using eco-rinse tanks and multiple rinsing with countercurrent flows.
A whole chapter is devoted to techniques necessary to increase process solution life, as well as preserving quality, by monitoring and maintaining solutions within specified limits. A separate chapter is also devoted to emerging techniques – for example, the possibility of integrating surface treatments into the manufacturing production process and the use of a trivalent chromium substitute process for hard chrome plating via modified pulse current which has already started pre-production verification in three typical applications.
Meanwhile, the 672-page draft BREF on the Large Volume Inorganic Chemicals (LVIC) – Solid and Others Industry published in June provides similarly detailed, technique and process-specific guidance for plant optimisation aimed at maximising resource use both in terms of energy and raw material input and improving process efficiency in the LVIC sector.
The BREF’s thorough analysis and description of production processes, together with techniques for process optimisation throughout the large inorganic chemicals sector (including soda ash, titanium dioxide, carbon black, synthetic amorphous silica and inorganic detergent, food and feed phosphates) should be required reading for any LVIC plant engineer professional.
The section on soda ash production alone, for example, runs to some 64 pages, covering a wealth of topics which range from applied processes and techniques, options for process optimisation and improvement, consumption of raw materials and utilities in the form of steam, process water, cooling water and electricity, energy management, energy conversion of primary fuels, energy saving in the process, heat recovery, energy minimisation and optimisation of the soda ash process to reduce carbon dioxide emissions, to mention just a very few.
Likewise, the section on titanium oxide includes comparison of a titanium oxide plant using the sulphate process route and the chloride process route, with a six-page analysis of life cycle assessment in the titanium oxide industry.
The BREF examines in detail a range of selected LVIC industry products, including silicon carbide, zeolites, calcium carbide, carbon disulphide, ferrous chloride, ferric sulphate, iron oxide pigment, lead oxide, sodium perborate and sodium percarbonate and thorough technical information of their individual production processes, applications, applied processes and techniques, and raw material and energy inputs and outputs.
Again the BREF also considers emerging technologies in the LVIC industry – ranging from innovations in the carbonation section of the soda ash plant, novel products and co-products in titanium oxide production, and future developments in carbon black, to potential new developments in furnace operation in silicon carbide production.
Elaine Coles is Head of Research at IMS Consulting (part of IMS Marketing Communications Group plc) and writes regularly on environmental and industrial issues.