Seville Process from an Industrial Viewpoint

Seville Process from an Industrial Viewpoint
Dr. Wolfgang Volkhausen
05 November 2014
ThyssenKrupp Steel Europe
ThyssenKrupp Steel Europe
Importance of Seville Process
„What does not come from Seville, will never come“
Harald Schoenberger, former Head of EIPPCB , Oct 2013
Mistakes or errors in the BREF process cannot be corrected any
more by national implementration
Or positively speaking:
All issues relevant to national implementation of BAT have already
to be defined in the BREF conclusion
Industry and Authorities together have to put all their efforts into
the Seville process for a high quality BREF document
ThyssenKrupp Steel Europe
Why should companies be actively involved in the
BREF process?
Drivers for engagement
 Since IED came in force BREF conclusions are binding for
Member States
 BREF conclusions will unavoidably be implemented into
national regulations and/or permits
 Implementation of BREF conclusions can cause significant
investments for companies
ThyssenKrupp Steel Europe
Business Area Steel
Europe
Overview of ThyssenKrupp Steel Europe
ThyssenKrupp Steel
Europe
ThyssenKrupp Steel Europe AG
 covers 32 % of flat steel
demand in Germany
 and 11 % of flat steel
demand in Europe,
 has a workforce of
27,000,
 has invested more than
220 M€ for environment
protection over the last
10 years
Niche products
Heavy plate
HoeschHohenlimburg
Rasselstein
Industry// customer groups
Machine&
plant
construction
Special
vehicle
construction
Energy
Automotive
industry
Trucks
ThyssenKrupp Steel Europe
Packing
industry
Building
industry
Household
appliances
Within Europe expenditure for environment protection
is a competition factor
Drivers for engagement
Noise abatement
Recycling
o Environmental costs can be a
relevant factor for the
profitability of a company
Total:
approx.
€361 Mio
Air pollution
Water pollution
o In Europe environmental
standards are still not uniform
o Harmonized environmental
standards can help to
improve a fair competition
control
control
ThyssenKrupp Steel Europe operating expenditure
for environmental protection
ThyssenKrupp Steel Europe
Relevant BREF Documents for ThyssenKrupp Steel
1st Priority (highly concerned = potential of significant investments)
o
o
o
o
Iron and steel production
Ferrous metal processing
Large combustion plants
Surface treatment using organic solvents
(IS)
(FMP)
(LCP)
(STS)
Direct participation
in TWG, European
Steel Federation +
MS level
(WT)
(ICS)
(EFS)
(ENE)
Monitored by
European Steel
Federation
2nd Priority (moderately concerned)
o
o
o
o
Waste treatment
Industrial Cooling Systems
Emissions from storage
Energy Efficiency
ThyssenKrupp Steel Europe
ThyssenKrupp Steel involvement in the BREF process
EIPPCB
Technical Working
Group
• Collects data and technical
information within and beyond
the questionnaire
• Communicates with EIPPCB via
TWG
Shadow working
group at Eurofer*)
• Collects data and
technical information on national level
within the questionnaire
• Communicates with
EIPPCB
German Subgroup
(Federal Env. Agency)
•
•
Collects data on national level
Ensures that national subgroup
has same level of information as
SWG of Eurofer
WG in German Steel
Federation
*) European Steel Federation
ThyssenKrupp Steel Europe
ThyssenKrupp Steel involvement in the BREF process
o Provision of all necessary information and data beyond the
questionnaire which often does not reflect technical reality
o Considering of feedback from National Industry Federations or
companies
o Proposals for Chapter 1-4
o Proposal for Conclusions and BATAEL
o Direct Communication with EIPPC
Shadow working
group at Eurofer*)
*) European Steel Federation
ThyssenKrupp Steel Europe
ThyssenKrupp Steel involvement in the BREF process
EIPPCB
Technical Working
Group
German Subgroup
(Federal Env. Agency)
Shadow working
group at Eurofer*)
German Steel
Federation
Lessons learned:
 Provision of data and information can be better managed by Europ. Industry Federation
but
 for addressing other than technical aspects EIPPCB only pays attention to MS
A good collaboration between industry and national authority in the national
Subgroup is essential for a high quality document
*) European Steel Federation
ThyssenKrupp Steel Europe
Influencing Potentials on the BREF Document in the
Seville Process
High potential
to influence
Low potential to
influence
Kick-off
Meeting
Preparation
of BAT
Document
Final Draft +
BAT
Conclusion
Publication
National
Implementation
ThyssenKrupp Steel Europe
Influencing Potentials on the BREF Document in the Seville
Process
High potential
to influence
Potential to influence is high at an early stage of the process
After meeting of Art 75 Committee and publication of the BREF in
Low potential to
the official EU journal, changes in the document no longer possible
influence
Kick-off
Meeting
Preparation
of BAT
Document
Final Draft +
BAT
Conclusion
Publication
National
Implementation
ThyssenKrupp Steel Europe
Revision of the Best Avaliable Technique Reference
Document for Iron and Steel
Start:
Publication in offical journal:
2006
March 2012
Time needed:
6 Years
Authors:
2
No of pages:
619
Conclusions:
96
ThyssenKrupp Steel Europe
Different Expectations of BREF Document
in Member States
Some MS expect
o high flexibilty at local level +
o definition of emission limit values (ELV) in individual permits only .
o BATAEL in wide ranges.
o BREF as a blue print for permits
Other MS (e.g Germany and Austria)
o implement BAT conclusions directly into national legislation.
o support small rages of BATAEL
o transform BATAEL 1:1 in ELV.
Every BREF is written with the national backgound
of the individual author
ThyssenKrupp Steel Europe
Authors
Actually only 7 Member State and 1 Non-Member State have
delegated experts to Seville
more challenges:
o Change of authors in
the running process
o Skills
not all authors are experts
in the field of the
document they write
ThyssenKrupp Steel Europe
Importance of Data Quality for BAT Conclusion
For derivation of BAT AEL, emission data are requested as annual
averages plus 5°and 95%; BUT
o BAT AEL are generally defined as daily averages
o Discontinuous processes cannot be described correctly by only 3 data
emission ranges of a real plant
Highest emission value in period
Annual average reported to Seville
Lowest emission value in period
ThyssenKrupp Steel Europe
Timespan of BREF Iron and Steel
EU
D
Time from kick-off to publication: 6 years
National implementation:
4 years
26.09.2006
2006
02.2008
2008
Deadline for national
implementation
If major investments have to be made, an
implementation phase of 4 years is much
too short.
Industry needs an indication of new
requirements at an earlier stage
10.2010
2010
2012
ThyssenKrupp Steel Europe
2014
2016
Timespan of BREF Iron and Steel
EU
D
Deadline for national
implementation
At latest, the most relevant conclusions must be fixed
after the final TWG meeting
Precondition: Conclusions must be well defined and
BATAEL must be kept in small ranges
26.09.2006
2006
02.2008
2008
10.2010
2010
2012
ThyssenKrupp Steel Europe
2014
2016
Position of German State Enviromenment Agency
(excerpt)
ThyssenKrupp Steel Europe
German Industry Proposals for Improvements to the
Seville Process
Improve capacity and skills in the Sevilla office
o The Sevilla office should be staffed by people who have sufficient
capacity and skills.
o Authors should bring in professional expertise and be thoroughly
familiar with the relevant sector. Authors should be assigned to a
theme which mirrors their professional qualifications.
o An author should flank the process of drafting a BREF from
beginning to end. If this is not the case, there will be interruptions in
the continuity of drafting.
ThyssenKrupp Steel Europe
German Industry Proposals for Improvements to the
Seville Process
Reduce data collection to the essential
o The aim should be that only emission data which is relevant for
emission limit values is collected.
o Interfaces between horizontal and vertical BREFs must be clearly
defined.
o Before data is collected, there should be clear indications of how it
is to be used (nature of averages (annual or daily averages, etc).
There should also be an obligation for data to be specified.
Furthermore, the essential problem arises if the data basis (annual
average value) is described as daily average values in the BATAEL and these are to be implemented as limit values in national
law. In the case of non-continuous processes, annual and
maximum daily average values can vary by a factor of ten.
ThyssenKrupp Steel Europe
German Industry Proposals for Improvements to the
Seville Process
Improve data processing
o It must be obligatory to take account of data sets supplied. Deficient
data sets should be rejected with corresponding justification.
o Transparency with respect to data processing needs to be
improved. Input of aggregate data is of little help to companies.
o Data should be evaluated in liaison with the TWG’s subgroups
which have the necessary expertise.
o Uniform requirements for drafting BATs must be met. When a
rapporteur changes, existing drafts should not be reworked to
reflect individual preferences.
o In the case of substantial revisions to BREFs (e.g. LCP), the
general rule should be that there are two drafts.
ThyssenKrupp Steel Europe
German Industry Proposals for Improvements to the
Seville Process
Involve all EU Member States
o An effort should be made to ensure that all EU Member States are
involved in the drafting of BREFs. At the present time, many
Member States are not represented.
ThyssenKrupp Steel Europe
German Industry Proposals for Improvements to the
Seville Process
Make an impact assessment obligatory
o An impact assessment should be obligatory. It is important to
assess the implications of a BREF not only for individual Member
States but also for industry in terms of the timetable and with regard
to the expected costs.
Improve timekeeping
o Timetables should be adhered to. It is necessary to define the
period within which a BREF is to be processed.
o Deadlines should be more realistic and oriented toward the number
of working days available. It is important not to set deadlines which
take account of only holiday periods observed by the Seville office.
ThyssenKrupp Steel Europe
European Industry Proposal to IED Joint Workshop
Berlin Oct 16 and 17 (Excerpt)
ThyssenKrupp Steel Europe
European Industry Proposal to IED Joint Workshop
Berlin Oct 16 and 17 (Excerpt)
ThyssenKrupp Steel Europe
Thank you
ThyssenKrupp Steel Europe

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