Understanding BAT in the context of IPPC

1
Understanding BAT in the context of IPPC

• Hans-Roland Lindgren
• Director, Swedish EPA

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What is BAT?
BAT stands for Best Available Techniques
and is defined as the most effective and
advanced stage in development
Why techniques and not technology?
Techniques include both the technology
used and the way an installation is designed,
built, maintained, operated and decommissioned
Hans-Roland Lindgren
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Definition of BAT in the IPPC-directive
best available techniques shall mean the most
effective and advanced stage in the development
of activities and their methods of operation
which indicate the practical suitability of
particular techniques for providing in principal
the basis for emission limit values designed to
prevent and, where this is not practicable,
generally to reduce emissions and the impact on
the environment as a whole
Hans-Roland Lindgren
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Definition of BAT in the IPPC-directive
techniques shall include both technology used
and the way in which the installation is
designed, built, maintained, operated and
decommissioned
available techniques shall mean those developed
on scale which allows implementation in the
relevant industrial sector, under economically
and technically viable conditions, taking into
consideration the costs and advantages, whether
or not the techniques are used or produced inside
the Member State in question, as long as they are
reasonably accessible to the operator
best shall mean most effective in achieving a
high general level of protection of the
environment as a whole
Hans-Roland Lindgren
5
Views on what BAT limits for a sector should
represent

• The highest emission levels allowed for any plant
  in the sector new or existing
• The highest emission levels allowed for new
  plants
• The emission levels achieved by the best handful
  of plants in the world
• The emission levels achieved by the very best
  performing plant in the world

Hans-Roland Lindgren
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How should BAT be adopted to cross media
considerations?
This is not a relevant question BAT is about
protecting the environment as a whole
Hans-Roland Lindgren
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The BAT hierarchy

• Process design/redesign to eliminate or reduce
  emissions to air, water, land, reduce formation
  of waste and energy consumption
• Substitution of fuel, chemicals, raw materials
  etc. by environmentally less harmful ones
• Minimisation and reduction by means of process
  control, maintenance, end-of-pipe technologies
  etc.

Hans-Roland Lindgren
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Can general binding rules on BAT-levels be a tool
when implementing the IPPC?
Yes, but only under the following
conditions limited to certain requirements
for certain categories of installations an
equivalent high level of of environmental
protection as a whole are ensured
An approach based on general binding rules in the
form of emission standards could never be the
main tool for implementation of the
IPPC-directive
Hans-Roland Lindgren
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Is BAT for a sector different in different
countries because of differences in economy?
No, No!
BAT considers economical factors only on a
general level. It should be economically viable
in a sector as such. If the techniques are used
or produced in the member state is irrelevant.
But it should be reasonably accessible to the
operator
Hans-Roland Lindgren
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Sector BAT versus BAT for a specific plant
BAT for a sector is not necessarily the same as
BAT for a specific plant
The following can be taken into account in a
specific case

• Technical characteristics of an installation
• The geographical location
• The local environmental conditions

Hans-Roland Lindgren
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Are BREF recommendations representing BAT?
The steel working group conclusion was that BAT
dust emission level from existing electric arc
furnaces was 15 mg dust/Nm3
More then 30 of 45 existing furnaces in the EU
meet that limit already 1994 and three of four
German furnaces had levels below 2 mg/Nm3
The conclusion is obvious, BREF recommendations
are not necessarily representing BAT as defined
in the IPPC
Hans-Roland Lindgren
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BAT recommendations in the cement BREF
The working group for the cement BREF had split
views on NOx limits and three different views
were expressed
View 1 BAT is 200- 500 mg NOx/Nm3 (equivalent
to 0,4-1,0 kg/tonne of clinker)
View 2 BAT is 500-800 m NOx/Nm3 (equivalent
to1,0-1,6 kg/tonne of clinker)
View 3 BAT is 100-200 mg NOx/Nm3 (equivalent to
0,2-0,4 kg/tonne of clinker)
Hans-Roland Lindgren