Final chlor-alkali BAT Reference (BREF) documents update and consequences – Definitive document available online
Assisted by Euro Chlor’s Technical Working Groups, the final version of the revised BAT Reference documents (BREF) for the production of chlor-alkali, as required by the Industrial Emissions Directive (IED), is available on the E.U. website. Check and download it here.
Compared to the version posted on this website in July 2014, only the cover pages were modified (i.e. pages 1-5 and 342-344). This definitive version also carries an ISBN and is also available via the EU Bookshop.
Some important comments
The BAT conclusions (chapter 5 of the CAK BREF document) were published in the Official Journal of the EU.
Under the IED, the BAT (best available techniques) conclusions have become legally binding whilst other chapters of the BREF are considered as guidance or recommendations.
The fact that the BAT conclusions have been published now triggers the competent authorities, i.e. the national authorities who may mandate local permitting authorities, to ‘reconsider permit conditions’ and ‘they shall take into account the BAT conclusions and shall ensure that the installation complies with the permit conditions within 4 years after publication of the BAT conclusions in the OJ’, this means before 11 December 2017 (IED, Art. 21).
In terms of production techniques, only monopolar/bipolar membrane and asbestos-free diaphragm techniques are considered BAT. This means other techniques cannot be used under the renewed permits (which enter into force 4 years from now at the latest), according to the published BAT conclusions.
The published BAT conclusions under the IED also mean that the mercury cell technology should no longer be used in chlor-alkali units beyond 11 December 2017. There is limited scope in the IED to obtain exemptions concerning the time for compliance (e.g preamble 22) but these are up to local/ national permitting authorities to assess. Click on the Mercury page to read more.