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Implementation of BAT approach

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Experience of Poland

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Implementation of BAT approach

  1. 1. Towards the BAT based permitting in Poland Marcin Wiśniewski Department of Environmental Instruments Ministry of Climate and Environment Regional meeting with Eastern Partnership countries 16 November 2020
  2. 2. Institutions Supervising Authority  Ministry of Climate and Environment Permitting Authority  Voivodship Marshal  Starost Inspection Authority  Environmental Protection Inspectorate (Voivodship Inspectorates) Appeals Authority  Minister of Climate and Environment (for decisions issued by voivodship marshals) and appeals boards (for decisions issued by starosts)
  3. 3. 3 Administrative Division
  4. 4. Number of the IED installations in PL 403 426 332 540 890 1804 0 200 400 600 800 1000 1200 1400 1600 1800 2000 BAT conclusions published BAT conclusions not published
  5. 5. Number of the IED installations in the EU 5 ≈ 4300
  6. 6. History of the integrated approach Single media permits (air, water, noise) IPPCD IED Since 1970 2001/2004 20142010 End of compliance programs implementation • Integrated permits had to be issued until 2007 • Deadlines differentiated according to the activity types Revised IED ? 2022/2023
  7. 7. Challenges under the IPPCD  Shift from the „command and control” approach into a BAT approach  Significant size of documentation to be prepared (operator) and assessed (CA)  Required high level of expertise regarding technological processes (CA)  Proper understanding of the role of BAT • BREFs being a guidance documents • Neither prescriptive nor exhaustive character of BATs  Financing • Activities in the field of collecting and sharing information about BAT  Interpretation issues e.g.: • Determination of the installation boundaries (facility > installation > unit), • How to determine production/processing capacity • Differences between activities e.g.: 2.3c: application of protective fused metal coats with an input exceeding 2 t of crude steel per hour, and 2.6: Surface treatment of metals or plastic materials using an electrolytic or chemical process where the volume of the treatment vats exceeds 30 m 3
  8. 8. Applied measures and activities • Pilot projects, • Trainings for administration and industry, • Guidelines and folders concerning integrated permits, • Translation of reference documents (BREFs), • Establishing of Polish Technical Working Groups • Polish IPPC website, • Registration fee Registration fee = B x Wr / Wp however not higher than 12 000 EUR Where B – base-fee rate for each activity type (defined in the Regulation) Wr - parameter chractreising maximum scale of the activity (deifined by the opertors) Wp - parameter charcterising average scale of the activity (defined in the Regulation)
  9. 9. Industrial emissions Directive (IED) Changes introduced by the IED:  New activities e.g. WBP or IWWTP  Improved identification of BAT  BAT conclusions on the key environmental issues  Quantification of BAT performance, especially via BAT-AELs  Also address prevention of emissions at source by using process- integrated techniques  Stricter ELVs for LCP, WI, VOC and TiO2, since 2016  Additional elements of the permit e.g. baseline reports
  10. 10. Challenges under the IED  Active involvement into the BREFs revision/elaboration process  Activation of the industry and competent authorities  Data collection  Meaningful contribution to Sevilla Process
  11. 11. Challenges with permitting under the IED  Implementation of the BAT conclusions,  How to translate the BATc into the permit conditions,  How to properly set the ELVs (based on BAT),  How to asses if the art. 15.4 derogation is sufficiently justified,  Compliance check criteria for the ELVs,  Measurement uncertainty.
  12. 12. Implementation of the BAT conclusions  No transposition of the BATc into national law  No general binding rules  The BATc applies directly using a framework given in the national legislation Instead  National guidance documents produced to almost each Implementing Decision  Meetings with the competent authorities (usually the most relevant for a given sector)
  13. 13. How to translate the BATc into the permit conditions Publication of decision on BAT Conclusions Start up of the analysis Results of the analysis Full compliance Permit needs to be updated Announcement RAI Reconsideration of previously granted derogations Information for the operator Request to submit an application for updating the permit conditions 6m 4years Competentauthorities
  14. 14. Elaboration of application Submission of an application Is 15.4 needed ? Request to submit an application for updating the permit conditions For how long ? Granting a permit Compliance with the BAT Conclusions Lack of an application Limitation of the permit by law 12m 4yearsafterpublicationofBATConclusions
  15. 15. How to properly set the ELVs (based on BAT)  In national legislation the BAT AELs are defined as the highest value from the AELs range - what doesn’t mean that upper end of the range needs to be applied because:  The obligation that permit needs to be always based on BAT  The emission limit set out in the permit results from the techniques installed – but cannot be higher than the upper end of the BAT AELs  Still one of the biggest challenges – which value from the range fits best  In addition the environmental quality standards can not be breached
  16. 16. How to assess if derogation is sufficiently justified  Derogation from BAT-AELs is only allowed in specific and justified cases:  costs are disproportionately higher than benefits due to local / installation-specific situation – IED Article 15(4)  without jeopardy to Environmental Quality Standards  not exceed the ELVs in the IED Annexes Guidance document available at: https://ekoportal.gov.pl/pozwolenia- zintegrowane/poradniki-branzowe 16 𝑵𝑷𝑽 = 𝒕=𝟎 𝒏 𝑶𝒕 𝟏 + 𝒓 𝒕 − 𝒕=𝟎 𝒏 𝑰𝒕 𝟏 + 𝒓 𝒕 Sum of discounted financial expenditures (CAPEX+OPEX) Sum of discounted environmental benefits
  17. 17. 17 Compliance check criteria Basic assumption that BAT AELs will replace IED Annex V ELVs was not accurate because:  The BAT AELs (where CEMS is used) refer usually to daily and yearly averages  No directly defined averaging periods for the Annex V ELVs  Compliance check based on specific rules from the IED (Annex V Part 4):  no validated monthly average value exceeds the relevant emission limit values set out in Parts 1 and 2;  no validated daily average value exceeds 110 % of the relevant emission limit values set out in Parts 1 and 2;  95 % of all the validated hour average values over the year do not exceed 200 % of the relevant emission limit values set out in Parts 1 and 2.  Therefore compliance with the BAT AELs is verified differently than with the IED Annex V ELVs - without paying attention to hourly averages;
  18. 18. Mv 90 110 120 Rv Sv Rv Sv Rv Sv Max A 20% MV 72 18 88 22 96 24 125 B 20% ELV 70 20 90 20 100 20 120 C 20% MV lub 20% ELV gdy niższy od MV 72 18 90 20 100 20 120 D SD 85,5 4,5 104,5 5,5 114 6 105, 26 NOx – ELV = 100 mg/Nm3 Mv – measured value, Rv – reported value, ELV – Subtracted value, SD – Standard deviation Measurement uncertainty
  19. 19. Thank you

Experience of Poland

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