The new SF Bref of the foundry sector is ready to go

With the implementation of the Committee procedure pursuant to art. 75 of the European Directive 2010/75/EU on industrial emissions (IED), held in Brussels on 17 September 2024, the new European document was approved that identifies the "Best Available Techniques (BAT)" applicable to ferrous and non-ferrous foundry activities and to the forge sector.

During the meeting indicated above, the Committee pursuant to art. 75 expressed its favourable opinion (political vote) on the proposal for the implementing act "Draft Commission Implementing Decision under Directive 2010/75/EU of the European Parliament and of the Council on BAT conclusions for the smitheries and foundries industry", for subsequent adoption by the European Commission in accordance with the examination procedure provided for by the specific EU legislation (Article 5 of Regulation (EU) No 182/2011).

The proposed BAT conclusions in question were derived from the relevant Final Draft BAT Reference Document (document in its final edition dated February 2024), on whose contents the Forum established pursuant to art. 13 of Directive 2010/75/EU expressed its favorable opinion at the meetings of 29 April 2024, in which Italy participated through an accredited delegation composed of experts designated by the Ministry of the Environment and Energy Security.

The forum, established to promote the exchange of information, is composed of representatives of the Member States, the industrial sectors concerned and non-governmental organizations promoting environmental protection (Commission Decision of 16 May 2011 establishing a forum for the exchange of information pursuant to Article 13 of Directive 2010/75/EU on industrial emissions).

The forum members appointed technical experts to form the Technical Working Group (TWG) which was the main source of information for the drafting of the document. The work of the TWG was led by the European IPPC Bureau.

In the TWG, composed of a total of 137 members, our country was represented by the delegation of the Ministry of the Environment, composed of Gianluca Cusano, Antonio Domenico Milillo, Guido Bernini, Adele Lo Monaco, Davide Laria, Simone Siciliani; the Italian delegation, as an industrial support expert, also included the head of Technical Services of Assofond Gualtiero Corelli.

In the large delegation of the CAEF (Committee of European Foundry Associations), as an industrial representation of the European foundry sector, was present the vice-president of Assofond Franco Vicentini.

Following the formal approval of the document, Chapter 4 "Best available techniques (BAT conclusions for the smitheries and foundries industry)" of the SF Bref for foundries, after translation into the various languages ​​of the Union, with the implementing decision of the Commission, will be published in the Official Journal of the EU.

The TWG work process in the SF Bref for foundries

The SF Bref update activity began with the formal activation of the TWG in July 2018 and with the kick-off meeting of 17-20 September 2019. It concluded, after a suspension of activities due to the Covid-19 pandemic, in September 2023. During this period, all the activities necessary for the collection of information, documentation and data required by the European provisions were carried out, for the drafting of the reference documents on the Best Available Techniques to eliminate or reduce the impacts of the activities subject to the aforementioned IED directive.

The TWG work was coordinated by a team of four technicians from the EIPPC Bureau of Seville: Eric Aries, Giorgios Chronomoulos, Jonas Ruiz Andersen, Frauke Schorcht, who also drafted the document.

The new SF Bref for the forges and foundries sector

The new reference document for the Best Available Techniques for companies in the forges and foundries sector, available in its final version, dated February 2024, on the Seville site of the EIPPC Bureau, is composed of six main chapters:

• Chapter 1 dedicated to forges
• Chapter 2 dedicated to foundries.Sections 1.1 and 2.1 provide general information on the industrial sectors concerned and their Key Environmental Issues (KEI). Sections 1.2 and 2.2 provide information on the industrial processes and techniques used within these sectors. Sections 1.3 and 2.3 provide data and information regarding the environmental performance of plants in the forges and foundries sectors, collected directly from European plants operating at the time of drafting the document (companies that voluntarily responded to the questionnaire prepared by the TWG); information and data that also concerned the consumption of raw materials, water and energy, emissions into the air and water, waste production.
• chapter 3 dedicated to techniques to prevent or, where this is not possible, to reduce the environmental impact of plants in the two sectors considered and to the determination of BAT.

This information includes, where relevant, the environmental performance levels (e.g. emission levels and specific consumption levels) that can be achieved using the techniques reported, the associated monitoring, costs and cross-media issues associated with the techniques.

Chapter 3 is structured as follows:

Section 3.1: Common techniques to be considered in the determination of BAT for forges and foundries;

Section 3.2: Techniques to be considered in the determination of BAT for foundries;

Section 3.3: Techniques to be considered in the determination of BAT for forges.

• Chapter 4 presents the "BAT conclusions" defined in Article 3(12) of the IED.
• Chapter 5 is dedicated to emerging techniques, identified for both forges and foundries.
• Chapter 6 with concluding remarks and recommendations for future work on forges and foundries.

The scope of the SF Bref in foundries

The document, as specified in the introductory part of Chapter 4 "Best Available Techniques (BAT conclusions For The Smitheries and Foundries Industry)", applies to the following IPPC activities:

• 2.3. Processing of ferrous metals: (b) operation of forges with hammers whose energy exceeds 50 kilojoules per hammer, where the heat output used exceeds 20 MW.
• 2.4. Operation of ferrous metal foundries with a production capacity exceeding 20 tonnes per day.
• 2.5. Processing of non-ferrous metals: (b) smelting, including alloying, of non-ferrous metals (including recovered ones) and operation of non-ferrous metal foundries, with a melting capacity exceeding 4 tonnes per day for lead and cadmium or 20 tonnes per day for all other metals.
• 6.11 Independent waste water treatment not covered by Directive 91/271/EEC, provided that the main polluting load comes from the activities covered by these BAT conclusions for foundries and the sectors considered.

The impact of the new Bref and the BAT conclusions on foundries

The update of the 2005 Bref document led to the definition of BAT and the related environmental performances with a substantially different approach from the previous one. The BAT conclusions defined in chapter 4 of the Bref do not only define emission levels associated with BAT (BATAEL), but also levels of "environmental performance" (BATAEPL):

• Some BAT_AEPL are "binding": specific energy consumption; percentages of sand reuse; quantities of waste sent for disposal; specific water consumption.
• Other BAT_AEPL are "indicative": operational efficiency of materials (process yield).

The development and implementation of an Environmental Management System (EMS) is made mandatory with specific indications of its general characteristics (20 requirements), substantially attributable to the requirements defined by the UNI EN ISO 14.001 standard, and "specific" ones for the foundry sector (9 requirements), each referred to by a specific BAT that details its purpose and content.

In order to improve overall environmental performance, the EMS of foundry companies must include:

• An inventory of the process INPUTs and OUTPUTS (BAT 2);
• A chemical management system (BAT 3);
• A plan for the prevention and control of leaks and spills (BAT 4a);
• A plan for the management of conditions other than normal (BAT 5);
• An energy efficiency plan and Audit (BAT 7a);
• A water management plan and Audit (BAT 35a);
• A noise and/or vibration management plan (BAT 8);
• A waste management plan (BAT 10);
• An odor management plan for foundries (BAT 32).

The challenges posed by new environmental regulations for the foundry sector

The implementation of BAT in foundries and compliance with the new environmental objectives defined in the Bref will require careful evaluation by companies in the sector. Evaluation that could, in many situations, make it necessary to update the technical-production structure of the foundry, in relation to the new limits and the expansion of environmental issues to be managed. In addition to having significantly reduced the values ​​of the emission levels associated with the BAT (BAT_AEL) of all the pollutants considered, the new document takes into consideration gaseous pollutants, such as emissions of volatile compounds (organic and inorganic) whose control requires technologies different from the traditional suction and abatement systems based on fabric filters, universally widespread in companies in the sector.

Even the approaches to the problems of capturing polluting emissions, based on the "dilution" of pollutants within suction flows that are generally oversized, will have to be reviewed by addressing issues such as emissions of volatile compounds, particularly if they are substances with a low olfactory threshold. Furthermore, new investments will have to be evaluated to achieve regulatory compliance, also analyzing the sustainability of the investment and, above all, the management costs of the necessary environmental measures.

The positive aspects of the SF Bref and BAT in foundries

For the Italian experience related to the implementation of the IPPC regulation in our country, also in relation to what happens in other countries, a non-secondary element linked to the new document should be noted in light of its legal value.

The Bref in its BAT conclusions establishes precise indications about the relevant aspects of the production phases and processes, with respect to which the various BAT and the related BAT_AEL and/or BAT_AEPL apply; binding references, based on the IED directive, for the competent Authorities.

This will in fact lead to greater homogeneity in the application of the SF Bref at European level and beyond, eliminating the important disparities that are currently recorded in the requirements between one AIA and another; disparities in application linked to the various interpretations of the rule and the current Bref, by the Competent Authorities (also found at Italian level between the different regions), which have been possible up to now.

The hope is that the new AIA will lead, on the one hand, to a reduction in costs related to monitoring and control plans and, on the other, to an equalization of such management costs for monitoring and controls, with positive repercussions in terms of competition between companies in the sector.

The legal value of Bref (BAT conclusion)

There are many references to the BAT documents present in the IPPC legislation and in the transposition provisions that have modified Title III-bis of Legislative Decree 152/06 relating to the Integrated Environmental Authorization.

Paragraph 1 of art. 29-bis establishes that: «The integrated environmental authorization is issued taking into account what is indicated in Annex XI to Part Two and the related conditions are defined with reference to the Conclusions on BAT, …».

References to BAT are included in various articles, in particular in relation to the definition of the reference limit values ​​(Art. 29-sexies, paragraph 4-bis) and the emission control requirements (Art. 29-sexies, paragraph 6), included in the Integrated Environmental Authorizations.

The BAT Conclusions are also the reference for the review activities (Art. 29-octies, paragraphs 2 and 3) of the Integrated Environmental Authorizations. The review must be carried out in any case within four years of the publication of the BAT Conclusions (Art. 29-sexies, paragraph 6) in the Official Journal of the European Union.

The achievement of the new environmental objectives defined by the approved BAT conclusions will, in many respects, require careful analysis and in-depth analysis by companies in the sector. It is therefore advisable to immediately analyze the document with the emission limits (BATAEL) and environmental performance (BATAEPL) associated with the application of the defined BAT, to be prepared when the BAT conclusions become operational and the foundries will be called upon to review the integrated environmental authorizations of their plants.

Source: G. Corelli for In Fonderia – Il magazine dell’industria fusoria italiana