The EU chemical industry is connected to a wide field of processing and manufacturing activities. Its output covers a wide range of chemical products and supplies virtually all sectors of the economy.
The character and scale of emissions from chemical plants are highly variable. Emissions may depend on factors such as raw material composition, product type, nature of intermediates, use of auxiliary materials, process operating conditions, type of process-integrated techniques to prevent or reduce emissions and type of end-of-pipe treatment.
The EU BREF on common waste gas treatment in the chemical sector (WGC BREF) is setting binding minimum performance standards for these plants, aiming to prevent or minimise the negative impact that these operations can have on the environment.
Process and current status
The development of the WGC BREF is on-going.
The development of the BREF started in 2016 and the first draft was published in November 2019. Following a stakeholders commenting period until end February 2020, the European Commission is currently working on a revised draft that would be again discussed and finally concluded upon at the Final meeting (to be held in the first half of 2021, to be confirmed).
The BREF in a nutshell
The new WGC BREF will apply to all chemical installations falling under the scope of the IED, and will focus on BAT for the prevention and reduction of pollutant emissions to air / on BAT for the treatment of waste gas. It will aim at closing the regulatory gap, linked to the absence of BAT-Associated Emission Levels (BAT-AELs) for pollutant emissions to air, left by the CWW BREF which includes narrative BAT for the prevention / reduction of emissions to air / BAT for waste gas treatment (outlining the techniques) but not BAT-AELs.
Apart from the CWW BREF, there are seven more (outdated) BREFs linked to specific sectors of the industry, e.g. the production of organic chemicals. Another positive aspect is that the adoption of the horizontal WGC BREF will mean that the updated requirements to reduce the environmental impact of the industry will be in place much earlier than through separate reviews.
On the other hand, the sectors employing process-integrated techniques will not be adequately covered in a horizontal BREF mainly focusing on end-of-pipe pollution abatement. The existing draft section of the WGC BREF on process-integrated techniques needs further development. One of the main demands of the EEB is that a another BREF focusing on such sectors and BAT follows the development of the WGC BREF, or that the European Commission and member states consider altering the legal status of the existing series of chemical BREFs.
Further points of concern are:
- GHG emissions are outside of the scope of the draft.
- When a mass flow thresholds is indicated, the BAT-AELs only apply if the mass flow of the given substance or parameter emitted from the emission point is above the associated mass flow threshold. We fear that this flexibility (whose purpose rightly is that operators are primarily focused on abating large flows of polluting emissions) may be abused, e.g. in cases when mass flow thresholds would be applied on sites which currently abate emissions of CMR-substances: installations being below the proposed thresholds (due to their pollution abatement efforts) would not have to abate in future.
- Pollution prevention techniques have been overlooked.
- There is hardly anything on ‘Integrated waste gas prevention strategy’.
- On CBI considerations (production volumes etc.), the process has to be more transparent.
For more information about the WGC BREF, the EEB’s positions during the negotiation and ahead of implementation, check out the Download section.
Aliki Kriekouki, Senior Technical Officer for Industrial Production: email@example.com