The IPPC Recast

New environmental requirements for explosives production sites

LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION DIRECTIVE 1996/61/EC Every chemical production site was in the scope of Directive 1996/61/EC (IIPC Directive). Transposition to Member States regulations was done before 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.

LEGAL REQUIREMENTS IN THE PREVIOUS LEGISLATION (2): DIRECTIVE 1996/61/EC 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 The most important BREFs related with our explosive production sector are: 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 The most important BREFs related with our explosive production sector are: 1.BREF-CWW (common aspects of waste gas and waste water treatment) 2.BREF-OFC (organic fine chemicals, related to DEGN production, MMAN production, etc). 3.BREF-SIC (specialty inorganic chemicals, related to primary explosives production).

A new COMMISSION IMPLEMENTING DECISION entered into force on 10 February 2012, laying down rules concerning guidance on the collection of data and on the drawing up of BAT reference documents and on their quality assurance referred to in Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions. The complete text is available under lex.europa.eu.

NEW REQUIREMENTS ACCORDING TO NEW IPPC DIRECTIVE Industrial Emission Directive - DIRECTIVE 2010/75/EU Industrial Emission Directive (IED) supersedes the previous IPPC Directive. Member States have to transpose it by the end of According to IED, the BAT (and the AEL) adopted by IPPC Bureau are mandatory (legally binding) for authorities when writing a permit. Nevertheless, only new BATs (included in new BREFs documents) will be mandatory. After IED, the first BREF that will be adopted will be: BREF-CWW (common aspects of waste gas and waste water treatment). A 2nd Draft of BREF has been uploaded to the Internet in July Final BREF is scheduled to be adopted by mid BAT Conclusions will be translated into every official European language in order to be the legally binding text.

Industrial Emission Directive - DIRECTIVE 2010/75/EU NEW REQUIREMENTS ACCORDING TO NEW IPPC DIRECTIVE (2) 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: OFC and SIC BREFs will be of special interest for our industry.

Manufactureof 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: Organic Explosives

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 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 Nowadays the contents of BAT conclusions are only recommendations for authorities. Manufactureof Specialty Inorganic Fine Chemicals (OFC)

The BREF SIC gives information on the manufacture of Specialty Inorganic Chemicals (SIC) in the EU: 1.general information 2.applied processes and techniques 3.current emission and consumption levels 4.techniques to consider in the determination of BAT 5.best available techniques (BAT) 6.emerging techniques.

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. The IPPC Recast