IED, UK Pulp & Paper Sector Steve Freeman Director of Energy - - PowerPoint PPT Presentation

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IED, UK Pulp & Paper Sector Steve Freeman Director of Energy - - PowerPoint PPT Presentation

IED, UK Pulp & Paper Sector Steve Freeman Director of Energy & Environmental Affairs sfreeman@paper.org.uk IED Joint Seminar, Imperial College Sept 11 David Morgan, CPI, Presentation to xxxxxx, 28 March 2008 David Morgan, CPI,


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David Morgan, CPI, Presentation to xxxxxx, 28 March 2008 IED Joint Seminar, Imperial College Sept 11 David Morgan, CPI, Presentation to xxxxxx, 28 March 2008

IED, UK Pulp & Paper Sector

Steve Freeman

Director of Energy & Environmental Affairs

sfreeman@paper.org.uk

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IED Joint Seminar, Imperial College Sept 11

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UK Pulp & Paper sector in 2011

  • 2 integrated mechanical pulp mills
  • 70%+ feedstock recovered paper
  • Sulfite & kraft pulp 100% imported
  • Deployed CHP, most gas
  • Increasing use of biomass/waste
  • Smaller mills grid electricity & boilers
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IED Joint Seminar, Imperial College Sept 11

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UK Paper Mills

  • 42 mills in EU ETS (2010)
  • 5 associated CHP
  • 9 CCA only mills
  • Inc 2 new inward investments circa £700m
  • Annual production 4.3mt
  • Annual consumption 10.5mt
  • Collected for recycling 8mt
  • 2000 90 mills, 6.3 mt production
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IED Joint Seminar, Imperial College Sept 11

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EU ETS Emissions

2010 (tonnes CO2 as reported)

  • Direct by UK pulp & paper mills

1,279,299 (2008 1,534,404)

  • Associated CHP

1,040,926 (2008 1,660,482)

(Closed since 2008, 10 paper mills with 3 third party CHP)

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IED Joint Seminar, Imperial College Sept 11

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UK Pulp & Paper energy stats

  • Gas purchased 11,843,870 MWh

(inc all CHP & boilers)

  • CHP electricity 1,203,961 MWh
  • Exported electricity 438,321 MWh
  • Purchased electricity 2,349,274 MWh
  • Coal 584,507 MWh
  • Biomass/renewable waste 2,038,357 MWh

2010 figures as recorded by CPI

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IED Joint Seminar, Imperial College Sept 11

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Areas of concern - IED

  • LCPD – impact on a small number of large mills,

esp on third party CHP

  • WID – two waste combustors, but heat need

means interest in this area, potentially linked to biomass

  • IPPC – revised sector BREF
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IED Joint Seminar, Imperial College Sept 11

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Pulp & Paper BREF

Currently being revised – further delayed Chapter 1 – Introduction Chapter 2 – General (so cross cutting) Chapter 3 – Kraft pulping Chapter 4 – Sulfite pulping Chapter 5 – Mechanical pulping Chapter 6 – Processing of recovered paper

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BREF – key issues

  • BAT figures – and we still wait!
  • Requirement to include in permits within 4 yrs
  • New permit conditions; including non normal
  • peration, protection/monitoring of

soil/groundwater

  • Public participation strengthened
  • ELVs linked to BAT
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BREF - derogations

  • Derogations from BAT but only where;

“disproportionately higher costs compared to the environmental benefits due to geographic location or local environmental conditions, or technical characteristics of the installation” Questions – what will be BAT and how will this be interpreted in the UK? Required to document in a permit annex and report use to the Commission who may issue guidance and propose EU wide minimum standards

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BREF BAT Emission Levels

  • BAT AEL included in the Directive – under

“normal” conditions – potential for confusion

  • ver definition, but “not normal” is defined in

parts of the IED

  • Major issue for recovery boilers on pulp sites –

regulation via BREF, but consideration of minimum values during 2013

  • European Safety Net – 3 yr review of the

Directive - environmental impact/BAT implementation – EU wide minimum standards?

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BREF unresolved key issues

  • Definition of BAT

– at extreme could require a new mill; clear it is not BAU – where is the balance?

  • Local interpretation by regulators
  • Use and justification of derogation
  • When is an emerging technology emerged/failed?
  • Consultation opportunities – over 1,000 comments

lodged on first draft – slipped timetable limiting

  • pportunities
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Interactions with other initiatives

  • EU ETS – Phase III starts 2013
  • Global carbon targets – carbon leakage
  • UK rebalancing of the economy
  • Energy Efficiency Directive/Cogen policies
  • UK Climate Change Agreements
  • Waste initiatives
  • Biomass
  • Water
  • Marine shipping sulphur limits!