Industrial perspective of source control options

1. Industrial perspective of source control options Prof. André Lecloux (Envicat). ScorePP Dissemination workshop Lyngby (DK) February 3, 2010

2. Scope of the presentation • The Water Framework Directive • Priority substances and EQS values • Point sources: mixing zone concept • The source control options • Review of the options • How to choose the “best” option • The chemical industry point of view • Conclusion

3. The Water Framework Directive • Objectives • protection of all types of waters • prevents further deterioration • ensures the progressive reduction of pollution • promotes sustainable water use • The priority substances • definition of EQS values • priority hazardous substances • River Basin Management Plan

4. Priority substances and EQS Directive • Definition of a priority list of chemicals • Reduction of discharges, emissions and losses of priority substances • Cessation or phasing-out of discharges, emissions and losses of priority hazardous substances (with PBT characteristics) • EQS values for annual average and maximum acceptable concentrations • Second priority list under review

5. River Basin Management Plan • MS should develop a plan to reduce the pollution and to promote sustainable use of water • These Management plans could foresee the revision of the industrial permits. • The permit generally defines ELV based on the concentration measured in the plant effluent • The WFD defines EQS, i.e. concentration measured in the water body after some dilution in the surface water • Need to define a “mixing zone” to avoid the confusion between EQS and ELV • A guidance has been finalised

6. The source control optionsReview • Substitution • IPPC Directive: the BAT approach • Process improvement • Specific Regulations • Voluntary initiatives • Waste water treatment

7. The substitution (1) • Phase out would imply substitution of PHS • Substitution is a risk management option among others and should be compared to others • The need for substitution should be determined by the risk of a particular chemical in a particular application: fit to use • Economical aspects should be considered not only for producer but also for downstream users • Successful substitution needs reliable long-term perspective for economical reasons • Difficulty to compare different types of risk

8. The substitution (2) • Impossible for unavoidable by-products like HCB, HCBD or PAH without stopping huge parts of the chemical industry (chlorine and coal tar industry) • In the case of pesticides a toolbox of various Modes of Action has to be maintained for each crop, to avoid the development of pest resistance • As the available toolbox could vary from country to country, it is almost impossible to find substitutes at European level. • EU is currently reviewing the list of authorized pesticides

9. Substitution: a few examples (1) • Substitution of 1,2-Dichloroethane (EDC) is impossible when used as raw material for vinyl chloride and PVC production but is possible when used as solvent or as raw material for TRI and PER production • Di(2-ethylhexyl)phthalate (DEHP) can be substituted as plasticizer for PVCby Di(isononyl) phthalate (DINP) and Di(isodecyl) phthalate (DIDP). This is a unique example where the same producers are involved but this move requires large investment

10. Substitution: a few examples (2) • The substitution of poly-bromodiphenyl ethers leads to a huge number of products each of them being specific for a given application. This implies a complicated management of plastic processing. • Substitution of cadmium as pigment, PVC stabilizers, and in brazing and soldering alloys has been accomplished • The substitution of cadmium inbatteries is possible in consumer applications, but will be based on market/performance/price attributes rather than legislation.

11. IPPC Directive: the BAT approach • The IPPC Directive defines the Best Available Techniques as well as the acceptable level of emissions of pollutants (BREF document). It will be revised to include the WFD priority substances • Problem: relationship between ELV and EQS • The Directive applies only to the large industrial units but not to the smaller ones • Up to now, the implementation of the IPPC Directive is relatively limited. In principle the permit renewal should force BAT application.

12. Process improvement • Independently of the very general BAT approach, the industry could consider specific process improvements by • Modifying the process conditions ( temperature, pressure, new catalysts,…) to increase the selectivity and reduce the production o f by-products • Installing specific emission abatement unit • This implies new investments

13. Specific regulations • For most of the priority substances, there are already many EU regulations limiting their use or controlling their specific emissions • On top of that, many countries have added their own national regulation to control emissions and uses • Examples: PAH, alkyl-phenols, mercury, VOC,… • The key question is how to effectively control the application of these regulations

14. Voluntary initiatives • Well before the WFD, the industry implemented voluntary initiatives to reduce its emissions. • Efficient approach: realistic, economically acceptable, technically feasible, improved image. • In terms of positive image, much higher benefit of voluntary agreements compared to legally binding approach. • Legally binding instruments: often politically driven with blue sky goals (for example: beyond the BAT, zero level, complete phase out) • Difficulty: poor confidence of authorities, public and NGOs in industry willingness to really reduce emissions. Necessity of an external audit • Several examples are given here after

15. Euro Chlor voluntary program (1) • Include environmental, social and economic factors in all strategic business decisions; • Optimise energy efficiency in chlorine production; • Reduce water usage through recycling; • Continuously reduce polluting emissions to water, air and land; • Use performance indicators with moving targets, like energy consumption, COC and mercury emission and eco-toxicological knowledge

16. Euro Chlor voluntary program (2)COC emissions to air

17. Euro Chlor voluntary program (3)Mercury emissions: g / t chlorine capacity

18. PVC Producers Vinyl 2010 initiative • Bisphenol A phased out of PVC production in 2001 • Phthalate risk assessments completed (2005) and published (2006). DEHP replaced • Stabilizers: • Cadmium stabilisers phased-out in EU-15 (2001) and in EU-27 in 2007 • 50% reduction in lead stabiliser foreseen for 2010 in EU-27 and phase-out in 2015. • Recycling: Several technologies available • exponential increase from 18kT in 2004 to 200kT in 2008 • recycling of pipes, windows, flooring, roofing and waterproofing membranes, coated fabrics • Recognition of Vinyl 2010 as a partner by UN Commission for Sustainable Development (2004)

19. Waste water treatment Plants (WWTP) • The Task 5.6 of the project critically reviewed all the types of WWTP • Their efficiency in removing various priority pollutants was measured or estimated • This “end of pipe” option should also be considered to reduce releases to the aquatic environment

20. How to choose the “best” option • For each given use or type of source, criteria are needed to assess each option • Technical feasibility • Technical efficiency • Probability to reach WFD target • Operational costs • Investment costs • Impact on the supply chain • Impact on employment • Impact on the drinking water production • Delay of implementation • Use of three level scores for each criteria

22. The scoring process • If we note the score Sijk • the index “i” is related to the use, • the index “j” is related to the measure and • the index “k” is linked to the criteria. • The total score of a measure x for a given use y is given by sum on k of Syxk . • The total score of a measure x for all uses/sources of a pollutant is given by sum on i and k of Sixk .

23. Estimation of the scores • It is important to point out that the scores will strongly depend on the local conditions, the type of stakeholders involved, the way the costs are shared, the budget available, the existing facilities, … • As a function of these conditions, the stakeholders could give a increased weight to one or two criteria, giving more importance to one or two aspects of higher relevance for the specific situation. • There is no universal best option, but only option that solve a local or regional problem

24. Conclusion • If the chemical industry is committed to reduce emissions and to protect the aquatic environment, it is important that the various options could be reviewed by the various stakeholders involved • The right balance should be found between environmental, social and economic aspects, the three pillars of the sustainable development. • Ideological position like zero emission of complete phase out should be avoided and pragmatic solutions favoured. • The down stream users should be involved when a substitution is considered.

25. Thank you for your attentionQuestion timeenvicat@skynet.be