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Industrial Emissions Directive: European Chlor-Alkali Industry pleads in favour of justified flexibility

04/10

Euro Chlor, representing the European Chlor-Alkali Industry, welcomes the efforts of the European bodies to simplify and strengthen the Industrial Emission Directive (IED) with the aim of sustainable environmental protection. This would also solve a major problem encountered in the application of the existing IPPC-regulation: uneven implementation in the Member States.

However, in a balanced approach, the IED should still take into account the different local conditions and the different technical characteristics of the plants and processes. This means that justified flexibility and local adaptation must be better secured.

For the Chlor-Alkali Industry the Best Available Techniques (BAT) have been described in the BREF-document that was adopted in December 2001. Some specific emission ranges have been set in this document.

In the proposed IED (Art. 14.4)  and without prejudice to Art. 18, the competent authority may set stricter permit conditions than those achievable by the BAT. Provided these measures are justified by a cost-benefit analysis, Euro Chlor could support this article.

Article 15.4 specifies that the competent authority may define less strict emission limit values, provided that an assessment demonstrates that the implementation of the BAT as described in the BREF document is affected by the geographical location and the local environmental conditions, the technical characteristics of the installation or an obvious disparity between the economic costs and the environmental advantages. Euro Chlor supports the European Chemical Industry Council's (Cefic) view that this could occur on specific cases (not exceptional cases).

These three concrete examples illustrate Euro Chlor's view:

• Some chlor-alkali plants use highly purified salt as a raw material for their electrolysis, leaving virtually no impurities and solid waste on the production site. Those production units working with non-purified salt will have to discharge certain amounts of waste water and sludge (picture).
• The Chlor-Alkali Industry has emissions of chloride into its waste water flows. This is of virtually no importance if the water flows are conducted to the sea. If the waste water flows are released into a small river or brook, however, the chloride content could affect the water quality.
  NB: high releases reduce the total energy consumption.
• The newest "membrane" technology available can reduce electricity consumption by an average of 4 to 10%, but the adaptation needs large investments and therefore the change to the newest technology needs to be done at an economically feasible pace (life expectancy of an installation = 30 to 40 years).

As a conclusion, Euro Chlor requires justified flexibility as part of the IED.

Download here a visualised synthesis of this Euro Chlor position.

Contact:
Véronique Garny, Regulatory Affairs Director, tel. +32 2 676 7232
eurochlor@cefic.be