Process and current status
The “Large Volume Inorganic Chemicals” (LVIC BREF) will be a review of a merger of two inorganic chemicals production BREFs,:
- BAT Reference Document for the Manufacture of Large Volume Inorganic Chemicals – Ammonia, Acids and Fertilisers (2007, adopted under the IPPC Directive) – LVIC-AAF
- BAT Reference Document for the Manufacture of Large Volume Inorganic Chemicals – Solids and Others Industry (2007, adopted under the IPPC Directive – LVIC-S
The LVIC -AAF BREF was reviewed between October 2001 and was published in August 2007,it took 6 years to write it from scratch.
The LVIC-S BREF was reviewed between May 2003 and published in August 2007, it took 4 years to write it from scratch.
The process and status of the revision of the merged LVIC BREF and tentative schedule is as follows:
- Kick off meeting took place on 24-28 October 2022 (see KoM report)
- Draft 1: Q2 2024 (not complied with)
- Final Meeting Q3 2025
- Comitology Vote: Q4 2026
- Publication date OJEU: Q1 2027
- Maximum Compliance date: Q1 2031
Status (mid May 2025): A data assessment workshop took place from 9-11 April 2025, pointing to a delay of about 1 year, pointing to D1 rather being available in Q2 2025.
Main Environmental issues and discussion points on BAT / BATAE(P)Ls
The main issues identified by the EEB for the LVIC BREF review relate to the following:
The revised standards will set the pollution prevention standards for energy intensive industries such as ammonia, acids and fertiliser production, the majority of which also have a very high climate impact (and mitigation potential) in particular for Soda Ash, carbon black and titanium dioxide.
The production of ammonia for fertilisers is CO2-intensive, currently relying on fossil-derived (hydrogen). The EU ETS log data indicate 2019 emissions reported at 40,1 Million tonnes CO2eq, of which the highest share comes from Ammonia production (20,7Mtons) followed by Hydrogen and synthesis gas production (9,2Mtons). The EU ETS median benchmark for ammonia indicates an average GHG pollution intensity at 1,972tCO2e/t of product (which is very significant), whilst the 10% ‘most efficient installations’ would still be in the order of 1,604tCO2e/t of product (still very significant). 30.6Mtonnes are marked as attributes to be covered by the benchmark.
For hydrogen the EU ETS benchmark indicates an average GHG pollution intensity at 10,78tCO2e/t of product, whilst the 10% ‘most efficient installations’ would achieve a level of 4,09tCO2e/t of product, indicating that there is significant room for progress. Irrespective the current hydrogen route is not based on the electrolysis-based hydrogen production route.
The following priorities have been identified for the EEB:
- Setting decarbonisation BAT for the sector, notably techniques and measures aimed at
- Electrification of energy using processes
- Substitution of fossil feedstock and fuel use as
- Carbon Capture of GHG emissions at the site
- Dedicated BAT-AELs on GHG emissions (this may also be relevant for H2, which may act as a greenhouse gas with a GWP of 11 (i.e. roughly like methane), by quenching hydroxyl radicals in the high atmosphere and thereby slowing down breakdown of e.g. methane and of course N2O
- Alternative process routes e.g. Soda Ash production based on Trona rock showing a better GHG footprint per equivalent output product.
- Preventing diffuse emissions / addressing leakage, in particular linked to storage, transfer or handling (of raw materials, products or waste) through state-of-the-art autonomous real-time leak warning and LDAR leak mapping systems/detection monitoring systems
- Developing dedicated BAT for hydrogen production, notably the electrolysis route with likely increasing importance of H2. The EEB believes it is irrelevant if its use is limited to where it is associated with ammonia production. The main production processes are the same, whether H2 is used to produce nitrogen, to hydrogenate unsaturated fats, in hydroformylation, as a fuel or an energy carrier. H2 being an inorganic substance, its production deserves to be considered as a whole. Annex I point 4.2. of the IED lists hydrogen as an inorganic chemical on its own, irrespective of its subsequent use. See a dedicated briefing by the EEB on the inclusion of H2 in the LVIC BREF;
- Preventing air pollution: notably dust, ammonia, SO2, PAH, SO2, H2S, gaseous chlorine / HCl , and NOx.
- Preventing water emissions: focus would be on metals and other substances of concern including the need to prevent PFAS pollution at the source (see further EEB material “additional data 3b KEI water”)
- Robust resource consumption BAT-AEPLs (water, resources and energy), as required by the IED.
- The production of phosphoric acid (generally not regarded as an inorganic phosphate) generates phosphor gypsum waste, which is highly relevant due to its quantities, heavy metal content and radioactivity issues.
Further information from the EEB / the European Commission is available in the following documents:
- Background Paper for the Kick Off Meeting, summarising the main points made
- EEB input to the KoM, such as the initial position and the backup documents
How can you make a difference?
Our main focus will be on accelerating the decarbonisation of the inorganic chemicals production, so far there is a total absence of dedicated BAT ensuring climate protection from those activities.
Air pollution will also be relevant as well as water protection and resource consumption requirements.
We expect the LVIC BREF to set state of the art for hydrogen production via electrolysis, powered by renewable electricity.
The following information would thus be appreciated:
Air pollution / GHG emissions:
- Techniques enabling the monitoring of diffuse emissions on the site
- Techniques not yet listed in the current BREFs, achieving performance levels below the mid-range of the current IPPC LVIC BREF BAT-AELs
- Decarbonisation techniques applied in inorganic chemicals production, including with GHG avoidance performance data, notably for:
- electrification of processes (heat pumps, steam generation alternative thermal process substitution away from fossil fuels)
- installations with GHG performance data better than the relevant EU ETS benchmark values
- Carbon Capture techniques showcasing abatement efficiencies above 95%
- Techniques delivering significant energy efficiency gains
- Techniques / current practice of substitution of fossil feedstock / fuel use.
Note: an EEB research paper is in finalisation stage and should be available by latest 6 June 2025.
Water protection
- Performance data on substitution of / PFAS abatement in chemicals input / waste water stage including effluent characterisation (see STM BREF)
- best performers data in relation to phase out of other Priority Hazardous Substances (at least below mid-point range below relevant BAT-AEPLs)
Other:
- Techniques enabling circular use of materials / preventing waste and/or increasing resource efficiency (see section 4.5 of the KoM);
- other supplementary information backing up need for fast-track review and improving ambition level of protection of human health and the environment.
Contacts
Please add “LVIC BREF review” in subject line.