The Chlor-Alkali BREF

Chlor-alkali BREF update

The Industrial Emissions Directive came into force in March 2011, requiring some adaptations to the revision of the BREF - Best Available Techniques (BAT) Reference Document for the chlor-alkali industry. Euro Chlor, with the help of member companies, was intensively involved in the process of updating this document, the first draft of which was published in December 2011.

In December 2012, the technical working group met at the European Integrated Pollution Prevention and Control (IPPC) Bureau (EIPPCB offices) in Seville to finalise the draft of the chlor-alkali BREF. The Euro Chlor delegation included three company members and was supported by the Cefic specialist, to defend a pragmatic approach and obtain a workable BREF document.

Nine countries and the European Environmental Bureau (EEB) took an active part in the sometimes very intense discussions that were efficiently managed by the EIPPCB.

Of course we could not obtain everything we wanted, and we had to face unforeseen last minute proposals from some countries. But most of our positions were accepted, thanks to the good arguments provided by the Euro Chlor members.

Results

• In general, we can be happy with the results obtained except for some issues concerning a very limited number of plants (use of asbestos or carbon tetrachloride) which will require more work, probably at local level, using the possibilities of derogation offered by the Industrial Emissions Directive.
• The BAT conclusions are mainly descriptive and several of the values mentioned are not prescriptive.
• For some of the emissions it was not possible to agree on emission limits ranges (BATAEL) and only monitoring would be required (chloride, chlorate, halogenated organic compounds and heavy metals, usually once a year at the outlet of the site).
• Only the free chlorine in water has a BATAEL, proposed at the site outlet.
• We nevertheless had to accept a lower limit than our actual guideline recommends for the chlorine emission at the chimney of the absorption unit and we will update our document accordingly.

There is still some work to do requiring comments on one additional BAT proposal for the chapter 5 (BAT conclusions) that was put on the table:  safety provisions (Austria and Germany)

There are also two "split views", one presented by Austria and EEB, not agreeing with the conclusion to not include associated emissions limits (BATAEL) for chlorate in liquid effluents, and one by the UK and Spain proposing to include mercury emissions reduction techniques and levels in the chapter 5..

Next steps

The final draft BREF document incorporating the results of the discussions will be available soon for a last review, before being presented to the Article 13 Forum for opinion - probably in June this year. The Commission should then endorse the BREF document.

After this step, the BAT Conclusions (chapter 5) will be extracted from the document, submitted to the Article 75 Committee for a vote at the end of 2013, with subsequent adoption by the Commission as an Implementing Decision.

Translation and publication in the Official Journal are foreseen early 2014; the 4 years period to update the permits of the plants will then start.

This updating work started for Euro Chlor in the summer of 2009 and involved a very intensive collaboration of different company and national association delegates to provide accurate information to the technical working group. We prepared many documents, contributed to gathering consumption and emission data, commented significantly on the draft and working documents produced by the Commission and answered the many questions we received from the EIPPCB.

Contact:

Jean-Pol Debelle, tel. +32-2-676 73 36
Dolf van Wijk, tel. +32-2-676 73 73

Updated 01/13