IPPC BREF OUTLINE and GUIDE - December 2005
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IPPC BREF OUTLINE and GUIDE December 2005 http://eippcb.jrc.es/pages/FActivities.htm Purpose of guide and outline The purpose of this paper is to provide an agreed basis for the work to be carried out in the European IPPC Bureau with the Technical Working Groups (TWGs) set up according to the workplan of the Information Exchange Forum (IEF). The text of this paper is not intended to be included in the BREF documents as such but is meant to guide the BREF authors and the members of the TWGs in a harmonised manner across the whole series of BREFs. It refers to the standards texts of IEF paper 7-3 agreed in February 2000 and IEF paper 14-4 agreed in December 2005. Procedural expectations A BREF is the product of an exchange of information carried out with a dedicated TWG constituted for the purpose. After finalizing the first round of BREFs the focus of the information exchange will shift to review of early BREFs plus any new special requests. The review of BREFs is a continuing process which is a consequence of the dynamic concept of best available techniques. The decision to start reviewing a BREF is taken by the Commission based on the recommendation of the IEF on the work programme taking into account information in the emerging techniques and concluding remarks chapters of the BREF and factors such as the time that has elapsed since the BREF was initially published or reviewed, the indication that new techniques might be available, the need to expand the scope of the BREF, and the need to include products/substances or processes not covered in the BREF. The TWG remains the primary means through which all information required for BREFs is gathered and assessed. Information not submitted to the TWG within the requisite time period cannot be expected to be included in the final BREF. The European IPPC Bureau acts as a neutral, technically competent secretariat to all TWGs. The life span of a TWG and the time to prepare a final draft BREF will vary according to the detail of the subject. In the case of a totally new BREF, the expectation is to complete a final draft within about two to three years of starting the work. The procedure to create the final draft will normally include two plenary meetings of the TWG and submission of draft BREF or draft parts of BREF to the TWG for review and comment. In the case of a review of an existing BREF, the TWG will be reactivated by the European IPPC Bureau according to the work programme and will be asked to submit new or updated information to the European IPPC Bureau for consideration by the TWG in the review work. The expectation is to complete a final draft for a reviewed BREF within about one and an half year of the deadline set for receiving the new or updated information. The procedure to create the final draft will normally include three plenary meetings of the TWG and the preparation of one intermediate draft BREF for review and comment by the TWG. However in exceptional cases, based on the recommendation of the IEF, the Commission may decide that another full draft may be necessary. Most of the work for TWG members can be expected outside of the plenary meetings in submitting information and reviewing draft proposals. In particular, the successful development of a BREF requires the TWG to respond in detail to substantial draft documents within a limited time period. As a general rule a minimum of 8 weeks will be scheduled for a TWG to submit comments on full draft BREFs. To address specific issues within the whole scope of the work, sub groups may be constituted who should submit draft text or proposals to the whole TWG. For any information to be satisfactorily validated by the European IPPC
Bureau and reviewed by the TWG, it is necessary for the TWG members to submit
information early in the working life of a TWG, in general within the first 12 months for a new
BREF and within the first 6-8 months for a review after the kick-off meeting. Information
submitted later cannot be expected to be included in the final BREF. Information which is well
supported by evidence will be given more weight than unsupported views and opinions.
Whilst consensus of the TWG is sought throughout the work, it is not a pre-requisite and it is
the task of the European IPPC Bureau to reflect the available information in the draft BREF.
The role of the IEF is to generally oversee the information exchange process. Specifically this
includes recommending to DG Environment the rolling work programme and keeping it under
review, discussing the scope of upcoming BREFs (in particular horizontal BREFs) and
indicating to the Commission the degree of support for final draft BREFs. IEF members are
also expected to take responsibility for ensuring nomination of their members to TWGs and to
keep in contact with these throughout the drafting process. Final responsibility for publication
of BREFs rests with the Commission.
General boundaries of BREFs
A BREF should contain a number of elements leading up to the conclusions of what are
considered to be "best available techniques" (BAT) in a general sense for the sector
concerned. . The definition of BAT requires that the technique is developed on a scale that
allows implementation in the sector. The evidence to support a technique as BAT can come
from one or more plants applying the technique somewhere in the world. In some rare cases,
even pilot projects can provide a sufficient basis.
Above all the aim of a BREF should be to offer information to the competent authorities of
Member States, industrial operators, the Commission and the public at large to guide the
determination of BAT-based permit conditions or general binding rules by providing
information relevant to the permitting of installations according to the IPPC Directive
96/61/EC. A BREF should serve as a driver towards improved environmental performance
across the European Union. A BREF does not interpret the Directive itself, nor does it remove
the obligations on operators and Member States under the Directive to make decisions at
national, regional or local level including the necessary balanced decisions required by the
Directive. BREFs do not prescribe techniques or emission limit values.
All BREFs should follow the general principles of this outline, but the order of chapters given
here is illustrative and any BREF may be structured differently in detail where that is more
appropriate to the subject of the BREF. Documents dealing with horizontal issues may depart
substantially from this outline and some chapters may not be relevant at all. For horizontal
subjects the TWG, and therefore the reference document, should try to conclude on BAT as
far as relevant and possible, even if this means identifying practices not considered to be
compatible with BAT. Information can only be included where it is made available to the
European IPPC Bureau, but gaps in knowledge may be identified to be addressed at later
dates. In the case of a review of an existing BREF, the revised document will be a
consolidated version integrating the previously adopted text and highlighting the amendments
and corrections brought by the review process. This consolidated document could contain an
index of the changes made. A TWG may decide that a separate addendum is necessary in
addition to the consolidated document.
A BREF should remain a fundamentally technical document and where a TWG identifies
issues outside the scope of the BREF and IPPC they should not be discussed in the BREF
(but could be raised at IEF level). Similarly, political opinions and views should not be
introduced into a BREF. If it serves a specific purpose of assisting the reader to seek further
information on an issue, companies (i.e. installations or suppliers), trade names, contributors
or TWG members should be named in a BREF.
2Executive Summary
The main findings from all chapters of the document will be presented, without background
information but with references to details within the body of the BREF, in such a way that the
summary can be read and understood as a “stand-alone” document. It should include the
principal conclusions on BAT, the emission and consumption levels associated with the use of
BAT and should describe any split views of the respective Technical Working Group in
respect of those BAT conclusions. Emission and consumption levels should be qualified with
reference conditions and averaging periods. As a stand-alone document, however, the
executive summary should not attempt to replace the main text within the BREF or to
encourage decision-making on BAT in specific cases without reference to the full text.
Preface
This standard section (for vertical / industry sector BREFs) will describe the structure of the
document, the legislative context, the way in which the document was generated (e.g. how
information was collected and assessed) and how it can be used. This standard text will be
tailored to reflect the individual structure of each BREF.
General Information
This brief introductory chapter will provide general information about the industry addressed
by the BREF in terms of numbers of installations, size, geographical distribution, production
capacity and economics. It will describe the structure and nature of the sector and will give an
indication of the key environmental issues for the sector with some sector-relevant emission
and consumption data as background information for the process of determining BAT and as
useful information for a regulator writing a permit.
Applied Processes and Techniques
This chapter will briefly describe the production processes and techniques currently applied in
the industrial sector covered by the BREF. The activities covered will include the activities
described in Annex I to the Directive and directly associated activities while noting the
relevance of other BREFs to certain aspects of some associated activities. There will be
descriptions of process variants, developing trends and alternative processes. The description
may be aided by diagrams or flow sheets and will reflect the sequential steps in a typical
manufacturing unit. Some or all of the following stages and information will be included:
• raw material used (including secondary/recycled) and consumables, including energy;
• auxiliary chemicals/materials used;
• raw material preparation (including storage and handling);
• material processing;
• product manufacture;
• product finishing;
• intermediate and final product storage and handling;
• handling of by-products and residues.
The actual or possible relationships between various activities within the BREF and between
BREFs should be described, giving a first indication of issues affecting overall environmental
performance (for example where wastes from one activity could act as feedstock to another).
Current Emission and Consumption Levels
This chapter will report on the range of currently observed emission and consumption levels
for the overall process and its sub-processes. Information will include currently observed
usage of energy, water and raw materials as well as an indication of issues such as noise or
odour. As far as available, data will include emissions to air, water and solid residues arising
3from the activities as well as inputs to and outputs from sub-processes, thus highlighting the
more environmentally significant sub-processes and addressing options for recycling and re-
use of output streams within the whole process.
The extent of multi-media complexity will be indicated where interdependency exists between
various inputs and outputs, for example where different parameters are dealt with together or
where some trade-off has been made such that certain levels cannot be achieved at the same
time.
Performance data will be qualified as far as possible with details on operating conditions (e.g.
percentage of full capacity), sampling and analytical methods, and statistical presentation
(e.g. averages, maxima, ranges). Actual performance data may be compared to relevant
standards set in national or international legislation.
Techniques to Consider in the Determination of BAT
This chapter will provide a catalogue of emission reduction or other environmentally beneficial
techniques that are considered to be most relevant in the determination of BAT (both
generally and in specific cases). This pool of possible techniques will include both process
integrated and “end-of-pipe” techniques, thus covering pollution prevention and pollution
control measures. Good operating practices will be addressed and consideration given to
inspection routines, maintenance systems, process control methods and contingency
provisions. Techniques that are generally seen as obsolete will not be included. Techniques
which are emerging in practice within the sector and are established techniques in other
sectors will be included where relevant.
The technical description of each technique will include the environmental benefits to be
gained by implementation. Any cross-media effects will be mentioned, together with the costs
of implementation, practical applicability, technical problems and the overall economic impact.
This chapter aims to include as much information as may be needed in order to assess the
applicability of a certain technique in general or specific cases. Each technique will be
discussed without pre-judging whether it meets all the BAT criteria of IPPC (cf. Article 2(11)
and Annex IV of the IPPC Directive).
Techniques presented may apply to the improvement of existing installations, or to new
installations or a combination of both. The range of techniques presented shall span various
cost/benefit situations including both lower and higher cost techniques.
Information on each technique should preferably include the following elements :
• Description: Brief technical description using, as appropriate, pictures, diagrams and
flow sheets;
• Achieved environmental benefits: the potential environmental advantages to be
gained through implementing this technique including emission and consumption data
where available, including any qualification of those data in terms of how they are
measured and expressed;
• Operational data: Actual performance data (including reference conditions and
monitoring periods) on emissions / wastes and consumption (raw materials, water
and energy). Any other useful information on how to operate, maintain, control etc the
technique;
• Cross-media effects: Potential effects due to implementing the technique (advantages
and disadvantages supported by data if available) in various environmental
compartments (whole environment) such as:
§ energy consumption and contributions to global warming
§ stratospheric ozone depletion and photochemical ozone creation
potential
§ acidification resulting from emissions to air
§ particulate matter (including micro-particles and metals)
4§ eutrophication of land and waters resulting from emissions to air or
water
§ oxygen depletion potential in water
§ persistent / toxic / bioaccumulable components in water or to land
(incl metals)
§ creation or reduction in (waste) residues
§ ability to re-use or recycle (waste) residues
§ noise and/or odour
§ risk of accidents
§ consumption of raw materials and water.
• Applicability: Consideration of plant age (new or existing) and factors involved in
retrofitting (e.g. space availability). Consideration of plant size (large or small).
Thereby highlighting where the technique can and cannot be implemented and noting
constraints to implementation in certain cases;
• Economics: Information on costs (investment and operating) and any savings (e.g.
reduced raw material consumption, waste charges) where appropriate. Economic
information relevant to new build and retrofit to existing installations will be included;
• Driving force for implementation: Specific conditions or requirements which have
driven implementation of the technique to date. For example, legislation or other
reasons such as increased yield or improvement in product quality. By inference this
information leads to the extent to which the technique might be appropriate to the
sector as a whole within the framework of IPPC.
• Example plants: examples of plants where the technique has been implemented. The
degree to which the technique is in use in Europe or world-wide may be useful
information.
• References to literature: literature for more detailed information on the technique.
To be able to compare and assess the performance of the various techniques, data will be
explained, as far as information is available, in terms of methods used for sampling, analysis
and data processing (averaging etc.).
Data on emissions may be expressed as absolute or concentration values, and relative to
actual production or production capacity. The most relevant economic aspects of each of the
techniques will be described to identify, where possible, the overall economic impact of any
given technique. Various expressions may be used for costs and consumption, referring to
units of production or time.
Best Available Techniques (BAT)
This chapter, with standard explanatory introduction, will conclude on what is considered to
be BAT in a general sense for the sector based upon the information in the previous chapter,
but taking account of the Article 2(11) definition and the considerations listed in Annex IV to
the Directive. Here the overarching criteria of costs of techniques and their environmental
performance, including cross-media implications, are considered in relation to the industry
sector. This chapter will not set emission limit values but will suggest emission and/or
consumption levels that are associated with the use of BAT and it will explain the basis for the
conclusions. When the best of the achieved levels as described in the previous chapter are
excluded, the reason for this should be explained. Reference conditions and measurement
periods will be included so that these conclusions on BAT in a general sense could act as an
input to the determination of BAT in specific cases.
BAT and emission or consumption levels associated with BAT will generally be proposed by
the EIPPCB on the basis of information available at the time of drafting. Such information may
include any specific proposals for BAT or associated levels received from the TWG. TWG
members are expected to provide sound technical, cross media and economic arguments as
relevant to their case when they do not agree with the BAT proposals. Such arguments
should be submitted initially as comments to the draft BREF within the consultation period set.
If the TWG finally reaches no consensus on this issue, the dissenting views and their
rationale will be reported in the BREF only if the following conditions are observed:
5• The dissenting view is based on information already made available to the EIPPCB at the
time of drafting the BAT conclusions for the BREF or has been provided within the
commenting period corresponding to such draft;
• A valid rationale supporting the split view is provided by the TWG member(s) concerned. A
rationale is considered valid if it is supported by technical, cross media and economic data
and information relevant to the Directive definition of BAT;
The Member States (MS) or industry associations that bring or support the split view will not
be named in the document. Nevertheless, the degree to which the split view is supported
among TWG members will be indicated using statements such as: one MS, two MS, few MS,
some MS and (part of) industry.
Emerging Techniques
This chapter will identify any novel pollution prevention and control techniques that are
reported to be under development and may provide future cost or environmental benefits.
Information will include the potential efficiency of the technique, a preliminary cost estimate,
and an indication of the time scale before the techniques might be commercially “available“.
This section can also include techniques to address environmental issues that have only
recently gained interest in relation to the sector at hand. Established techniques in other
sectors that are emerging in practice within the sector concerned will not be included in this
chapter.
Concluding Remarks
In particular, this section will conclude on the information exchange exercise for the sector. To
indicate how contemporary the document is, the start date and duration of the information
exchange exercise will be given. Mention will be made of the various sources of information
on which the BREF was based highlighting any particularly noteworthy reports or submissions
which contribute to the confidence in the results. The degree of consensus reached amongst
parties in the information exchange will be reported without making reference to any specific
Member State expressing a dissenting view. Any gap or weakness in knowledge will be
identified. Recommendations will be included for further research or information gathering and
for the time scale for updating the reference document, in the light of ongoing technical and/or
economic developments.
Annexes (dependent upon relevance to sector and availability of information)
1. Glossary – to define abbreviations and terms used in the document; 2. Supporting
Literature and/or Case studies; 3. Summaries of existing legislation - primarily Community
legislation which is considered to be particularly relevant in arriving at BAT conclusions.
National or local legislation will not be summarised nor repeated within the BREF document
other than a brief mention where relevant as a driving force in case studies. Where available,
URL links to web sites where national or other legislation can be found will be listed in the
Annex. Where summaries of national or other legislation are submitted by the TWG, they will
be incorporated into a separate document and made available as additional information from
the web site of the EIPPCB; 4. Monitoring of emissions (specific to sector)
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