Data gathering and impact assessment for a possible review of the IPPC Directive – Part II
European Commission – DG Environment
Framework contract No ENV.G.1/FRA/2004/0081
Assignment No 21
Final Report
25 September 2007
2007/IMS/R/290
Institute for Environmental StudiesVITO
Vrije Universiteit
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Data gathering and impact assessment for a possible review of IPPC Directive – Part IIfinal report
Citation and disclaimer
This report should be quoted as follows:
VITO, BIO and IEEP (2007) Data Gathering and Impact Assessment for a Possible Review of the IPPC Directive- Part II, Final Report
The contents and views contained in this report are those of the authors, and do not necessarily represent those of the European Commission
Contributing Authors:
Liesbet Goovaerts, Anne Jacobs, Peter Stouthuysen, Patricia Benito, Hélène Cruypenninck, Lea Turunen, Shailendra Mudgal, Patrick ten Brink and Karl Vrancken
Contacts.
- Overall responsible for the contractors VITO, BIO and IEEP: Karl Vrancken of VITO,
- For the European Commission – IPPC desk officers: Alexandre Paquot and Filip François. Overall responsible: Head of Unit: Marianne Wenning.
Contents
1.Introduction
2.Overview of the work
2.1Coverage of the work
2.2Project development stages
2.3Overview of methodology
3.Overview of the content and conclusion of the individual fact sheets
3.1 Potential amendment A.1: ‘foundries’
3.2 Potential amendment A.2: ‘ceramic products
3.3 Potential amendment A.3 : ‘chemical industry’
3.4 Potential amendment A.4: ‘food products
3.5 Potential amendment B.1: ‘gasification and liquefaction
3.6 Potential amendment B.2: ‘primary wood’
3.7 Potential amendment B.3: ‘coald fuel products’
3.8 Potential amendment B.4: ‘independent wastewater treatment plants’
3.9 Potential amendment B.5: ‘preservation of wood’
3.10 Potential amendment B.6: ‘shipyards’
3.11 Potential amendment C.1: ‘Site Restoration and Protection of soil’
3.12 Potential amendment C.2: ‘waste incineration’
ANNEXES
Annex I: Detailed Project methodology
Step 1: Problem definition
Step 2: Current situation
Step 3: Identification of options
Step 4: Options evaluation
Step 5: Summary
Annex II: Fact sheets
Annex III: Definition of environmental impact category indicators and characterisation factors
1.Introduction
This final report for the project‘Data gathering and impact assessment for a possible review of the IPPC Directive – Phase II’has been writtenby VITO, in association with BIO Intelligence Service, IEEPand IVM.
This work aimsto analyse the economic, environmental and social impacts relating to some potential “technical” amendments to the IPPC Directive. The work includes the collection of country specific data and insights on the current practices, the identification of different options to address these issues and the exploration of the pros and cons of the different options. The aim of the data analysis is to present the arguments for the different options in a clear and balanced manner so as to facilitate the European Commission’s task of deciding what policy options are the most appropriate to propose for each of the areas under consideration.
Advisory Group (AG) comments on the fact sheets were used as input to finalise this project. We would like to thank those who have responded to the questionnaire and/or sent their comments on the study. The questionnaire’s responses and comments can be found on the IPPCreview website[1].
This report contains a general overview of the content and conclusion of the individual fact sheets for the different potential amendments. The fact sheets show the results of the data gathering, the working insights, arguments and conclusions for every issue. Furthermore a global conclusion on the whole project is given.
2.Overview of the work
This phase II project evaluates two types of possible amendments to the IPPC Directive.
The first type aims to clarify some areas of possible misinterpretation. Specifically in Annex I some of the definitions seem to be not totally clear or are interpreted in different ways by the stakeholders. The fact sheets A1 to A4 and C1 deal with these clarification issues (see table 1).
The second type of possible amendments, or so-called B-amendments in table 1, consider possible additions to Annex 1 of the IPPCD. These additions were proposed on the basis of the E-PRTR list of sectors.
The project started with a general assessment of the possible amendments. This provided a survey of the size and activity of the different sectors, as well as their environmental impact. This first screening has led to a selection of the most relevant sectors (see table 1).For these sectors options to clarify the implementation of the IPPC Directive and/or extend its coverage to improve the environmental impact have been provided. To evaluate these options arguments for and against the various options were developed.
The information used is based on interviews with sector organisations and experts, sector and literaturedata as well as the responses to the project questionnaire sent out in March 2007 and consultation on the draft final report in June 2007.
The work across the amendments is presented in issue-specific fact sheets. An overview of the content and conclusions of the specific fact sheets can be found in Annex II of this report.
2.1Coverage of the work
The potential “technical” amendments to the IPPC Directive considered in this study are presented in the table below.
For the amendments B.1, B.3 and B.4, the first analysis of the information has led to the conclusion that very few plants would be affected. In consultation with DG ENV, it was decided not to develop a full assessment of these activities.
Table 1: Potential Amendments to be considered in the Study
Amendments to be considered / ReferenceA / Possible changes to the current provisions of Annex I of the IPPC Directive
1 / A.1 / Foundries – Production capacity / Annex I, Section 2.4
2 / A.2 / Ceramics – “and/or” / Annex I, Section 3.5
3 / A.3 / Chemical industry – biological processing and pharmaceutical intermediates / Annex I, Section 4
4 / A.4 / Production of Food products / Annex I, Section 6.4(b)
B / Possible additions to Annex I activities (based on Part I)
5 / B.1 / Any gasification and liquefaction * / Part I, C.2.a
6 / B.2 / Production of any primary wood products / Part I, C.2.b
7 / B.3 / Manufacture of coal fuel products and solid smokeless fuel* / Part I, C.2.d
8 / B.4 / Independently operated industrial wastewater treatment plants* / Part I, C.2.e
9 / B.5 / Industrial plants for the preservation of wood and wood products / Part I, C.2.f
10 / B.6 / Installations for the building of, and painting of or removal of paint from ships / Part I, C.2.h
C / Other possible changes
11 / C.1 / Site restoration and protection of soil / Art. 3(f)
12 / C.2 / Waste incineration
*not fullyassessed
2.2Project development stages
The project started on the 13th of November 2006. The aims and objectives of the work were presented at the Advisory group meeting held on the 8th of December 2006.
The initial data gathering started in January 2007. On this basis the possible amendments were refined and focused and some data gaps were identified.Aquestionnaire was prepared and sent to the Advisory Group in March 2007. The questionnaire covered 7 of the possible amendments.
Based on the discussions with DG ENV and DG ENTR, the responses on the questionnaire and comments from the AG and further data collection,an impact assessment has been carried out. A draft final report was presented to the Advisory Group for consultation in June 2007. The text was revised on the basis of the comments made. The resultsand conclusions of the project are presented in this final report.
2.3Overview of methodology
The methodology was based on five key steps, as illustrated in the table below,to conduct the six tasks identified by the Terms of Reference (ToR) in an interactive and coherent manner.
Table 2:Overview of the 6 tasksand related project steps
In the methodology: / In the ToR:Step 1- Problem definition / Task 1- Problem definition and objectives
Step 2- Current situation / Task 3,4 - Data gathering
Step 3- Identification of options / Task 2- Option definition
Step 4- Option evaluation / Task 5- Assessment of the impacts of different options for action
Task 6- Comparison of impacts and …
Step 5- Conclusions / Task 6- … and justification of preferences
The content of each step and the amount of steps followed differ from one amendment to another.
Some amendments stopped at defining the problem and evaluating the current situation (B.1, B.3 and B.4), as this first screening resulted in the conclusion that very few plants would be affected.
For other issues options for amendment were identified and evaluated using an impact assessment matrix (see table 1 in Annex I of this report). The manner and detail of this evaluation depended on the amount of data that was available. For some amendments a detailed environmental impact assessment could be carried out. The intention of the project was to focus on the impact on air and water emissions. The impact categories used in this project were derived from LCA studies. Based on these impact categories the magnitude of the environmental impact can be compared.
The details for each of the modules in the 5 steps are described in Annex I.
Figure 1: The 5-step methodology to analyse an amendment
3.Overview of the content and conclusion of the individual fact sheets
3.1 Potential amendment A.1: Possible changes to the current provisions of Annex I of the IPPC Directive for Foundries in the thresholds for ferrous and non-ferrous metal foundries
Aim of the study:
The present work identifies the issues related to the possible change of the threshold for foundries and to clarify the determination and the use of melting and production capacity for ferrous and non-ferrous metal foundries.
The current work is based on a background literature survey, interviews with sector organisations and experts and inputs from other stakeholders. It also takes into account the comments of the Advisory Group members on the draft final report
Background:
The current definition of Annex I § 2.4 mentions as the threshold for ferrous metal foundries ‘a production capacity of 20 tonnes per day’ and § 2.5 (b) mentions as the threshold for non-ferrous metal foundries ‘a melting capacity of …20 tonnes per day for all other metals’.
MS interpret and implement both thresholds in different ways. There is confusion whether the production capacity refers to raw castings (i.e. before finishing) or good castings (i.e. the sold product). Additionally, MS apply a variable approach to determine production on a daily basis, as some casting processes take more than a day.
Non-ferrous foundries are not mentioned as a separate activitybut fall under smelters. For this activity, a different criterion is used to define the threshold, namely the melting capacity. Interpretation issues exist on how to determine the melting capacity. Additionally, there is no technical reason to use a different criterion for both foundry sub-sectors (ferrous vs. non-ferrous).
Issue summary:
In order to avoid misinterpretation and to facilitate administrative decisions two issues are to be considered: (1) how to define ‘capacity’ and (2) should the difference in approach between ferrous and non-ferrous metal foundries be maintained.
Analysis:
The foundry industry is a relatively small industry, primarily made up of SMEs. The total number of production units is estimated to be over 3000, with a total annual production of 15 Mt castings produced in the year 2002. Foundries can be found across Europe. Germany, France and Italy are the top three production countries with a total annual production of over two million tonnes of castings each and representing about 60-70% of the total production in Europe
Based on country specific data from Germany, UK and Italy, which represent 55 % of the total production, it is estimated that about 25% of all EU foundries are currently not covered by IPPC - with the exception for the UK, where 203 out of 230 foundries are outside the scope because of the specific structure of the foundry sector in this country.
The emission factors indicate that the main environmental impacts from foundry processes arise from the pouring and cooling of the metal and the core and mould making operations. Because of the various types of foundries and the specific structure of the foundry sector across Europe, it is not possible to give a general indication on the total environmental impact.
The current definition in Annex I is subject to interpretation and has provoked some law suits. The interpretation of ‘capacity’ differs significantly across Europe. Hence, the clarification of this definition is desirable.
However the effect of clarification is difficult to calculate in numbers. The impact assessment is therefore made on a qualitative basis. Four different options are considered:
- clarification of what is meant by ‘production capacity’ for the foundry sector by adding guidance to the existing guidance document on capacity from the Commission
- clarification of the determination of the ‘capacity per day’ by adding guidance to the existing guidance document on capacity from the Commission
- to redefine production capacity in activity 2.4 as the weight of good castings per year for ferrous metal foundries
- to define a separate article 2.5 c) for non-ferrous metal foundries with the threshold referring to the production capacity as the weight of good castings per year
Conclusions:
The term ‘production capacity’ should be understood as the production of good castings. ‘Good castings’ are the castings after removal of feeders and gate system, finishing and quality control. These castings are the finished products of a foundry. The raw castings are ‘half products’ and their amount is more difficult to calculate. The use of ‘good castings’ will also simplify inspection as the amount of finished products is well known in every foundry.
Related to the definition of ‘production capacity’ one has also to hold in mind that the production of a casting is a process that - depending on the circumstances - may take several days. Therefore it is difficult to determine the daily capacity. Nowadays foundries already calculate the daily capacity based on the yearly capacity divided by the number of working days. A general and fixed amount of working days for the calculation of the daily capacity, viz. 300 working days per year could be used.
For a sensible definition of the capacity of a foundry, the period of observation could also be extended to a yearly based production capacity, resulting in a threshold capacity value of 6000tonnes/year for ferrous metal castings.
Regarding the definition for the non-ferrous metal foundries, this could also be based on the production capacity. One of the optionsis to set up a separate article (category) in Annex I for non-ferrous foundries, distinguishing them from non-ferrous smelters. The latter melt non-ferrous scrap, while most non-ferrous foundries melt pre-alloyed blocks. Therefore the determining factor from the technical and ecological point of view is not the melting operation, but the moulding process.
For the conversion of the melting capacity to the production capacity a factor of 60% metal yield can be used, beingthe average metal yield given in the BREF. This would lead to a threshold of 2.4 tonnes per day (or 720 tonnes per year) for lead and cadmium and 12 tonnes per day (or 3600 tonnes/year) production capacity for other metal castings.
The foundry associations report that the suggested thresholds will not significantly influence the number of IPPC foundries. The results of the assessment reinforce that the proposed options will mainly clarify the definition. Guidance on the interpretation of production capacity and calculation of the daily capacity will harmonise the implementation in the different member states. It may also prevent that court cases arise again in the future. The application procedure will be simplified as such. Therefore the proposed changes will lead to better regulation, with minimal changes to the existing legislation.
3.2 Potentialamendment A.2: Possible changes to the current provisions of Annex I of the IPPC Directive on the wordings of the definition of the manufacture of ceramic products
Aim of the study:
The present work identifies the issues related to the possible changing of the wording of the definition for the manufacture of ceramic products. The current work is based on a background literature survey, interviews with sector organisations and experts and inputs from other stakeholders.It also takes into account the comments of the Advisory Group members on the draft final report.
Background:
The current definition of Annex I, §3.5 states: “Installations for the manufacture of ceramic products by firing, in particular roofing tiles, bricks, refractory bricks, tiles, stoneware or porcelain, with a production capacity exceeding 75 tonnes per day, and/or with a kiln capacity exceeding 4 m³ and with a setting density per kiln exceeding 300 kg/m³”. This definition leaves room for MS to use both parts of the definition alternatively or cumulatively and thus for differences in interpretation between the MS.
Issue summary:
The major problem addressed by this potential amendment is the clarification and harmonization of the wording of the definition of point 3.5 of the Annex 1 of IPPCD.
Analysis:
The ceramic industry is a small industry, primarily made up of SMEs. The total number of producing companies is estimated to be over 2000 with a total annual production of 101 Mt products in the year 2000. Production of ceramic products is carried out across Europe, but not all products are manufactured in every MemberState.
The most important sub-sectors in production capacity are the manufacture of brick and roof tiles and wall and floor tiles, with respectively 55 Mt (54% of total) and 25 (25% of total) Mt output in 2000.
The typical kiln size used in the manufacture of ceramics exceeds 4 m³. Typical installation capacity of brick and roof tiles, vitrified clay pipes, refractory product and wall and floor tiles exceeds the 75 tonnes per day. Only for brick and roof tiles, wall and floor tiles and refractory products the setting density typically exceeds 300 kg/m³.
Because of the lack of emission data of the European ceramic industry the estimates and calculations of the environmental impact are based on rough figures, generated from basic emission factors and estimates from the BREF document and the Corinair database.
The contribution of the ceramic industry to the air pollution impacts is estimated to be relatively small compared to overall emissions of certain pollutants. However, local impacts from the emissions of the installations concerned can be significant and need to be regulated. These rough emission estimates however show that the most important sub-sector of this industry is the brick and roof tile sector, covering 50-90% of the emissions of the total ceramic industry.