1. IPPC application as seen by TOTAL Refining
12 years of practice, one recommendation
Workshop European Commission IPPC – EUROPIA - 4/07/08 - X Bontemps
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2. Total Refining in WE: 15 assets in 7 countries for the moment
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3. IPPC (international): 12 years later… There is no uniform practice.
France : Regulatory texts end Full refining emission footprints relating to main BATs reported from 2004 and completed mid BREFs and BATAELs handled by french authorities through a strict numerical reading.
UK: Emission footprint reported mid 2005, completed by recent HDS project. IPPC permit delivered end No BATAEL used for ELV setting.
Belgium : IPPC permit delivered mid This precedes the BREF documents. Ongoing negotiations since, in line with NECs and water emissions.
Germany : IPPC permit also delivered in Prescriptions reviewed mid 2005, then in december 2007.
Netherlands : BREF based comparison in 2004/5. IPPC permit delivered in June ELVs not modified as a function of BATAELs.
Italy : Full environmental footprint reported 4Q No further request to date from the regulators.
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4. IPPC (national): There is no uniform practice
IPPC (national): There is no uniform practice. The BREF concept and opportunity is not used.
Ref A : the regulators use BATAELs to impose ELVs on SOx and water emissions:
SOx : the bubble has been reduced to the theoretical sum of SOx BATAELs from each unit.
Water : consumption prescribed at 0,62 m3/t and waste water specs aligned to most BATAELs despite the refinery’s complexity and the absence of genuine environmental impact!
Ref B : Benzene waste water spec (5 µg/L) < river EQN (10 µg/L) and equal to the drinking water spec.
Ref C : Water BATAELs used to negotiate and intermediate position vs. current best practice.
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5. IPPC (local): The risk of damaging star industrial performance.
End 2004 : to satisfy FCC dust emission standards, Ref D commissioned an ESP early 2005
3Q 2008 : to comply with new SOx emission limits, the FCC will start a gas scrubber which makes economically redundant the prior investment.
As a consequence :
Regret expenditure
Higher water emissions: sulfates, metals, N (to be challenged next)
A borderline situation safetywise (project and operability)
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6. IPPC : Safety first?
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7. IPPC : financials IPPC1 equates to 10 €m/y/refinery over 2007-2011.
A burden followed by IPPC2 & ETS at a time when margins are predicted to drop and raw materials will remain on the rise.
It remains a competitive threat and accelerator.
Net cash
margin
Source: Solomon
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8. IPPC : one recommendation
For decades, refiners have successfully applied the « plan - do – check – correct » cycle as a fundamental improvement model. IPPC represents a huge opportunity to improve our environmental abatement effectiveness in a cost effective manner. To fully harvest this opportunity, it requires more implementation time, one common international regulatory lense and a BREF concept that is understood and cross referenced by all stakeholders. To move on to IPPC2 with a sense of great urgency will be counterproductive.
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