The IPPC Recast. New environmental requirements for explosives production sites. LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION DIRECTIVE 1996/61/EC
The IPPC Recast
for explosives production sites
LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION
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.
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:
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.
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:
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 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.