The IPPC Recast
New environmental
requirements
for explosives production sites
LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION
DIRECTIVE 1996/61/EC
Every chemical production site was in the scope of Directive
1996/61/EC (IIPC Directive). Transposition to Member States
regulations was done before 2002.
Chemical production of explosives (Annex 1, reference 4.6, IPPC
Directive) is included in chemical installations section.
A new (codified) text was published in 2008 (Directive 2008/1/EC)
having basically the same kind of requirements: new permit for
existing installations, new allowable emission levels (AEL) as
decided by authorities, etc. AEL were selected by taking into
account the list of Best Available Techniques (BAT).
Therefore, BATs were voluntary (not mandatory) for the industry.
LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION
(2): DIRECTIVE 1996/61/EC
BATs have been derived by European Commission IPPC Bureau
at Seville, Spain. BAT documents are called BREF (BAT
Reference Documents). BREFs are prepared by means of the
“Seville process” through information exchange between
industry, authorities from Member States and any other interested
parties (universities, NGOs etc). Several BREF have been
prepared at Seville from 2000 to 2007. The most important BREFs
related with our explosive production sector are:
1. BREF-CWW (common aspects of waste gas and waste water
treatment)
2. BREF-OFC (organic fine chemicals, related to DEGN
production, MMAN production, etc).
3. BREF-SIC (specialty inorganic chemicals, related to primary
explosives production).
A new COMMISSION IMPLEMENTING
DECISION
entered into force on 10 February 2012, laying
down rules concerning guidance on the
collection of data and on the drawing up of
BAT reference documents and on their
quality assurance referred to in Directive
2010/75/EU of the European Parliament and
of the Council on industrial emissions. The
complete text is available under www.eurlex.europa.eu.
NEW REQUIREMENTS ACCORDING TO NEW IPPC
DIRECTIVE
Industrial Emission Directive DIRECTIVE 2010/75/EU
Industrial Emission Directive (IED) supersedes the previous IPPC
Directive. Member States have to transpose it by the end of 2012.
According to IED, the BAT (and the AEL) adopted by IPPC Bureau
are mandatory (legally binding) for authorities when writing a
permit. Nevertheless, only new BATs (included in new BREFs
documents) will be mandatory. After IED, the first BREF that will be
adopted will be: BREF-CWW (common aspects of waste gas and
waste water treatment). A 2nd Draft of BREF has been uploaded to
the Internet in July 2011. Final BREF is scheduled to be adopted by
mid-2012.
BAT Conclusions will be translated into every official European
language in order to be the legally binding text.
NEW REQUIREMENTS ACCORDING TO NEW IPPC DIRECTIVE (2)
Industrial Emission Directive - DIRECTIVE 2010/75/EU
Up to now, there is no specific BAT concerning explosive
waste management. Therefore, open burning and open
detonation (OB/OD) methods can be authorized (or
forbidden) at Member State level.
BREF-CWW (2nd draft) pays especial attention to VOC
(Volatile organic compounds) and odour emissions and AEL for
central waste water treatment plants. More information in:
http://eippcb.jrc.es/
OFC and SIC BREFs will be of special interest for our
industry.
Manufacture
of
Organic Fine Chemicals (OFC)
This BREF focuses on the batch manufacture of organic chemicals
in multipurpose plants and addresses the manufacture of a wide
range of organic chemicals. Some production sites may also include
dedicated production lines for larger volume products with batch,
semi-batch or continuous operation. The list includes amongst other
OFC:
Organic Explosives
Manufacture
of
Specialty Inorganic Fine Chemicals (OFC)
BREF on Production of Specialty Inorganic Chemicals (BREF-SIC).
Final BREF (August 2007). Chapter 6 (paragraph 6.4) deals with
production of primary explosives (Lead Azide, Lead Styphnate,
Lead Picrate). This BREF will be updated by the European
Commission after 2013. Management of waste explosives by open
burning/detonation is not included in BAT conclusions. Nowadays
the contents of BAT conclusions are only recommendations for
authorities.
BREF on Waste incineration. Final BREF (August 2006). No chapter
is devoted to explosive waste management. The relevant explosives’
waste BREF will be updated by European Commission after 2013.
Nowadays the contents of BAT conclusions are only
recommendations for authorities.
The BREF SIC gives information on the manufacture
of Specialty Inorganic Chemicals (SIC) in the EU:
1. general information
2. applied processes and techniques
3. current emission and consumption levels
4. techniques to consider in the determination of BAT
5. best available techniques (BAT)
6. emerging techniques.
The IPPC Recast
This topic has been included in the agenda of the
FEEM Health and Safety Working Group as it will
possibly impact across a large number of businesses and
members should be aware that it has the potential to
cause problems.
The Working Group found it valuable to review the BAT
system for explosive manufacturing technology and the
handling of explosives wastes at their next meeting in
September 2012 in Prague.