Potential amendment E11 – Preparation of scrap metal
Options and pros and cons
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- Analysis of options
Options and pros and consProblems to consider for the option definition The sector is already regulated by two sector specific Directives (ELV and WEEE) and by the Waste Framework Directive, bringing it under an additional directive (i.e. IPPC) may go against the Commission’s and some MSs’ simplification agendas. Shredder installations have a clear environmental impact (i.e. emissions of dust and dioxins), which is not covered by the ELV and WEEE Directives The sector contains a variety of installation types. Different installations perform different treatment methods. A threshold of 50 tonnes/day distinguishes small scale dismantling operations from large scale scrap processing installations. Option definition In this section, the 3 options under consideration are defined and a preliminary list of pros and cons is given. They will be further analysed in section 4. Considerations about the threshold definition are also given.
Analysis of optionsA qualitative approach is adopted for the analysis of the options proposed in section 3. For each of the issues, the relative advantages and disadvantages of the options are evaluated. The impact assessment matrix provided below summarises the results of the analysis. The process behind the rating is explained in the following sub-sections. In each cell a qualitative score of ‘+’, ‘0’ or ‘-‘ has been given. A ‘+’ signifies beneficial impact with respect to the criterion in question; ‘-‘ a negative impact; and ‘0’ no impact. Increased magnitude of the impacts will be indicated using the notation ++ or --. In some cases, when there are other external influencing factors, a range is used, for example 0 to – or even + to -.
‘++’: substantial beneficial effect; ‘+’: slight beneficial effect; ‘-‘: negative effect, ‘--‘: substantial negative effect; ‘0’ no effect; N/A: Not applicable; Y/N: yes/no General issues Legislative changes Bringing any additional activity into the Annex I of the IPPC Directive would lead to legislative changes at both the European and national levels. For options 2 and 3, changes to the provision of the IPPC Directive will be of the same order of magnitude (addition of one sector to the Annex I of the Directive). A BAT-based permitting system is only reported for one MS. So the inclusion of the sector into IPPC will require changes to national legislation in most MSs. Problem addressed The problem that needs addressing in this potential amendment is the control of emissions from scrap metal preparation. Option 1 does not address the problem. Options 2 and 3 address the problem. As the range of installations is wider, in Option 3 the problem is better addressed. Environmental issues Option 1, no action, does not improve environmental protection, compared to the present situation. The sector is already covered by the ELV and WEEE Directives. Large scale installations (> 50 tonnes/day) are mainly ELV processors. Annex I to the ELV Directive gives a limited number of requirements for the protection of soil and limitation of emissions to water. These are formulated in a very general way and provide no indication of the level of environmental protection to be reached. Bringing the sector under IPPC will only improve environmental protection for these compartments if BAT goes beyond the current requirements. Looking at a BAT-study performed in Belgium, BAT can provide more specific technical requirements and a limited number of techniques are available to go beyond the ELV-Directive protection level. The BREF on Emission from Storage does not mention techniques to reduce discharges to water. The requirements in the ELV-Directive do not consider emissions to air. Scrap metal preparation results in guided and diffuse emissions of dust and emissions of dioxins. Guided emission from shredders are typically controlled using a cyclone and a wet scrubber. It should be noted that even with the mentioned abatement measures, stack dust emissions can still be relevant when treating certain scraps that generate mainly fine dust. An estimation of the diffuse emissions shows that shredders produce a total of 4250 tonnes PM10 per year. For the total of the large scale scrap treatment installations this can be estimated at 8110 tonnes per year. Emission measurements of dioxins from 2 MSs allow to estimate the total dioxin emission at 0,0007 – 0,008 kg i-TEQ/year. Data from Flanders indicate that dioxin-like PCB emissions typically are an order of magnitude higher than dioxin emissions. Dust emissions are high as compared to disposal operations for hazardous and non-hazardous waste currently covered by the Directive. Dioxin emissions are relevant as compared to disposal operations for non-hazardous waste. A BAT-study in Belgium and the Storage BREF show that emission reduction techniques are available. Application of these techniques may result in a considerable reduction of the emissions, up to a factor of 10.
Economic issues Impact on firms: costs Under option 1, no additional cost are imposed on the industry. Options 2 and 3 will result in the implementation of additional emission reduction techniques in the sector. The basic (good-housekeeping) techniques for reduction of diffuse dust emissions are relatively easy to implement and do not generate high investment costs. Only if more far-reaching requirements on the housing of the installation and/or the storage are set, will the cost be high. The acceptability of the cost should be determined in defining BAT for the sector. Impact on firms: competitiveness within the sector All three options work for the sector (or the shredder sub-sector) as a whole. From the inventory of installations, it appeared that there is a difference in operations between large scale (> 50 tonnes/day) and small-scale installations. Therefore, a measure that affects all large scale installations, is not expected to lead to a distortion of competition within the sector. The option 3 has been supported by various national sector organisations and two large international scrap treatment groups, during the consultation of the draft version of this report. Impact on firms: competitiveness between sectors The scrap metal preparation sector is the only sector that can process scrap for the metal industry. Posing additional requirements on the sector is not expected to divert the waste scrap metal to other sectors. Therefore, none of the options will result in an impact on the competitiveness between sectors. Impact on public authorities (budget, resources) Not including the sector of scrap metal preparation in the scope of the IPPC Directive will not impose any additional cost (budget and/or resources) to public authorities. Bringing a new sector under IPPC will generate additional workload and cost. A limited survey showed that only very few MS use a BAT-based permitting regime for the scrap metal sector. On the other hand, the ELV Directive includes an authorisation system. Most of the ELV shredders already are included in this regime. As the number of shredder installation is relatively small (220 in EU-27), the additional workload for option 2 will be limited. For option 3 the number of installations is higher and the scope of the permits will be broader. The implementation of integrated permits in the scrap metal sector will therefore generate extra workload for the authorities, but can build on the existing authorisation system. Social issues Confidence of public on environmental control and pollution Scrap metal preparation is a sector with a generally low level of public confidence. Information concerning emission levels of dust and dioxins may negatively affect this public perception. The regulation of this activity under IPPC, according to the same system as other treatment methods for non-hazardous waste may strengthen the public image of the sector and generate higher public confidence. There is no difference in this respect between options 2 and 3. Number of jobs: public authorities The higher the number of installations covered by the Directive, the higher the number of workers is required to control the installations. As the number of shredder installations is relatively low, option 2 will not generate additional jobs. For option 3 there may be a limited effect. Number of jobs: scrap metal sector The large scale scrap treatment installations and shredders are medium-sized enterprises, with 5 - 70 employees. The inclusion of the sector in IPPC will not affect the economy of the enterprises in such a way that installations will be in danger. The competitiveness of the sector will not be affected and the costs for implementation of emission reduction techniques are judged to be moderate. Therefore the effect on employment in the sector will be minimal. Other issues Practicability: is it practical to implement? Option 1 (do nothing) is the most practical option. Option 2 may present some interpretation problems. Most shredder installations are integrated plants with a variety of other operations, ranging from depollution of ELVs to cutting and pressing of production scrap. While the depollution activities deliver their ‘product’ to the shredder, presses have no direct interaction with the shredder. Including only the shredder operation in Annex I of the Directive will cause difference in interpretation concerning the directly associated activities. Additionally, interpretation issues may arise concerning the calculation of the capacity of the shredder. This may be regarded as the capacity of the shredder itself or of the whole integrated installation. Option 3 overcomes all these issues and presents no implementation problem. Clarity and consistency None of the MS have indicated that the installations covered by this amendment are covered by IPPC. There does not seem to be a problem with clarity. The large scale scrap metal preparation installations are covered by the ELV Directive (and some installations by WEEE). The requirements of these directives concerning minimising the environmental impact of the operations is not in conflict with the BAT-principle or with an integrated permitting system. Both Directives do not set binding emission limit values, so there is no overlap. On the other hand, the IPPC Directive currently covers other waste treatment activities for non-hazardous waste with a similar environmental impact. It therefore is more consistent to include scrap metal preparation in IPPC as well. Besides the ELV and WEEE Directives, also the Waste Framework Directive applies. Introducing and additional directive may go against the Commission’s intention to simplify environmental legislation. Enforceability From enforcement point of view, options 2 would be more difficult to enforce as compared to option 3, as interpretation issues may arise. This has been discussed under the heading practicability. 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