(BAT) Reference Document for the Production of Chlor-alkali ...

Environmental performance and operational data
{Please TWG provide information.}
Economics
{Please TWG provide information.}
Chapter 4
Example plants
In Germany, regulatory measurements of halogenated organic compounds in chlor-alkali plants
are carried out by using the AOX method according to EN ISO 9562 when chloride
concentrations are below 5 g/l, and by using the modified AOX method according to the
informative Annex A of EN ISO 9562 when chloride concentrations are above 5 g/l [ 161,
Germany 2004 ]. In Austria, the AOX method according to EN ISO 9562 is used [ 160, Austria
1996 ] but due to the aforementioned difficulties the EOX method according to OENORM M
6614 is frequently used.
{Please TWG provide more information if AOX/EOX is measured in EU Member States and
which methods are used.}
Reference literature
[ 70, COM 2003 ], [ 157, CEN 2004 ], [ 158, DIN 1984 ], [ 159, ASI 2001 ], [ 160, Austria
1996 ], [ 161, Germany 2004 ]
4.3.5 Techniques to reduce emissions to air
4.3.5.1 Techniques to reduce emissions of chlorine
4.3.5.1.1 Techniques to prevent accidents and incidents or to limit their
environmental consequences Safety measures
{This section has not yet been updated. The EIPPCB has launched a discussion to which extent
techniques to prevent accidents and incidents or to limit their einvironmental consequences
should be included in the chlor-alkali BREF. While some TWG members were of the opinion
that such techniques should be included, other TWG members were not. The EIPPCB has
therefore invited those TWG members who would like to see a revision of this section to provide
the TWG with a targeted proposal. The proposal should be drafted with the standard
10-heading-structure of techniques to consider in the determination of BAT as set out in Table
4.1.
Regarding the contents, the EIPPCB is of the opinion that the general principles of safety
management which are laid out in the Seveso Directive should not be repeated in the BREF. In
addition, the EFS BREF (Emissions From Storage) has a dedicated section on this (4.1.6.1) and
concludes in 5.1.1.3 "BAT in preventing incidents and accidents is to apply a safety
management system as described in Section 4.1.6.1." Other issues on the storage and handling
of chlor-alkali products are also covered by the EFS BREF. Consequently, only techniques
specific to the chlor-alkali industry should be mentioned in this section.}
WORKING DRAFT IN PROGRESS
Description
In hazard and risk assessment studies, the design of chlor-alkali installations and equipment and
the operating and maintenance routines are examined in detail to reduce the risks for people and
the environment at source as much as possible. The most important substance to consider is
chlorine. Preventative measures are the most important, although corrective and emergency
measures are also of importance. The design principles of the plant, scheduled maintenance and
inspection, procedures and instrumentation (control systems) for operating the unit are covered,
as well as hardware. An overview is given, below, of measures that can be applied to reduce the
risks in operating a chlor-alkali plant, including storage and loading of products. The measures
TB/EIPPCB/CAK_Draft_1 December 2011 217