Monitoring and controlling emissions in Europe
Implementing the EU’s Industrial Emissions Directive calls for quality and consistency in technologies for monitoring and controlling emissions.
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The European Commission’s Industrial Emissions Directive (IED) will standardise the maximum emission levels across a very broad range of industries throughout the European Union (EU). The IED reorganised seven existing overlapping directives related to industrial emissions into a single, clear and coherent legislative instrument and its implications will be cascaded through national governments into local or provincial legislation of EU member countries and enforced by inspectors in their local authorities.
The seven existing directives that will coalesce into the IED are the Large Combustion Plant directive (LCPD); the Integrated Pollution Prevention and Control directive (IPPCD); the Waste Incineration directive (WID); the Solvent Emissions directive (SED) and the three existing directives on titanium dioxide on disposal (78/176/EEC), monitoring and surveillance (82/883/EEC) and programmes for the reduction of pollution (92/112/EEC).
Best available techniques
One of the main reasons for the recast of the directive was the inadequate and incoherent implementation of the application of best available techniques (BAT) to optimise all-round environmental performance across the EU. In addition, the fact that relevant provisions were spread across seven different legal instruments was deemed to place unnecessary administrative burdens on companies, particularly those with operations spanning several member states.
Many of the primary industrial sectors in the EU are already well regulated in terms of emissions, but the aim of the IED is to harmonise and standardise how they are regulated and how BAT is utilised across the entire region by setting minimum emissions benchmarks and improving the quality and consistency of implementation.
For companies already operating above and beyond this benchmark, there will be no change required to their operating protocols. For instance, Sweden and Denmark, where a tax on nitrous oxide (NOx) and sulphur oxides (SOx) is in place, very little additional impact is likely. In these countries industrial companies have already invested heavily in emissions reduction technologies to minimise paying these taxes. It is also predicted that there will be similar low impact in the Netherlands, a leading EU member state in terms of environmental policy, where very low legislated emissions levels are already in effect.
The impact of the IED is therefore more likely to be felt in countries like France, the UK and in certain member states in Eastern Europe, which have lagged behind the leading environmental legislation in Europe. It will address shortcomings in the newer member states, such as the Czech Republic, Bulgaria, Romania and Poland, as well as Turkey, a candidate member state, which has never before operated in this sphere of environmental regulation.
The IED will describe how measuring and monitoring should take place and will be driven by an increase in the use of BATs via revised BAT Reference (BREF) documents in order to obtain better consistency of implementation across the EU member states. The BAT approach is aimed at identifying and applying the best technology available worldwide and applying it as cost effectively as possible on an industrial scale to reduce emissions and achieve a high level of environmental protection. The BREF documents contain the maximum emissions values for industries outside of power generation, such as iron and steel, refining, glass, cement and chemicals.
The IED principally covers control of pollution to the air, land and water and focuses on 13 specific pollutants or polluting substances to air: sulphur dioxide (SO2) and other sulphur compounds; NOx and other nitrogen compounds; carbon monoxide (CO); volatile organic compounds (VOCs); metals and their compounds; dust, including fine particulate matter; asbestos; chlorine (Cl) and its compounds; fluorine (F) and its compounds; arsenic (As) and its compounds; cyanides; substances and mixtures that have been proved to possess carcinogenic or mutagenic properties, or properties that may affect reproduction via the air and polychlorinated dibenzodioxins and polychlorinated dibenzofurans. For many industries, much of the impact for emissions to air will be focused on four pollutants: SO2, NOx, CO and VOCs.
The LCPD, one of the seven existing EU directives related to industrial emissions, has required member states to legislatively limit emissions from combustion plants with a thermal capacity of 50 MW or greater. The directive applies to large thermal plants, many of which are fossil-fuel power stations. IED will repeal and replace LCD as of 1 January 2016 and, through BREF notes, is set to strengthen and extend those provisions across a very broad range of industries, covering the operation of combustion plants beyond the power generation industry. Examples include the ferrometals (iron and steel) industry and coke production, since coke is an essential ingredient in the manufacture of iron and steel. Non-ferrous metal production, such as aluminium processing, will also come into scope, as will the chemical, glass and cement industries where huge kilns are needed.
The link between this legislation and technology is very clear. The roll-out of regional directives like the IED will serve to drive the development and raise the profile of new pollution control technologies around the world by defining and referring to BAT. The BREF documents which record these BATs will herald new, lower emissions limit values (ELV) that will necessitate investment in more advanced pollution control measures. This will require investment in advanced pollution control unit operations with new process control instrumentation and, very likely, will need new instrumentation, specialty gases and calibration gas mixtures. In some cases, like continuous emission monitoring (CEM), the composition and quality of these gases and calibration mixtures will be independently regulated and controlled by external auditors and is likely to be regulated through accredited schemes for measurement such as ISO17025. Some of these new pollution mitigation unit operations, such as selective catalytic reduction (SCR), will also require chemical additives like ammonia (NH3), which would need to be measured as a potential pollutant if SCR does not work properly.
As often happens when legislation is updated in a specific country or region, other countries outside its range adopt certain principles as a blueprint or starting point for their own local legislation. This is why many of the changes taking place in environmental legislation in the EU reflect developments in the United States, where authorities like the Environmental Protection Agency (EPA) are also striving to level the playing fields across industries.
For example, a trend that is likely to be taken up in the EU in the future is the move towards speciation analysis in the VOC arena. Speciation analysis is defined as the separation and quantification of different chemical forms of a particular element. Until recently, determining total element concentrations was thought to be sufficient for environmental considerations, but now it has been recognised that it is important to understand the toxicological properties of the sample’s various components in order to manage environment risk more accurately.
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