tio2 simplification report iss3

Analysis of the Simplification of the Titanium Dioxide Directives

Report to European Commission DG ENV.G.1

Restricted Commercial ED05640 AEAT/ENV/R/2506 Issue Number 3 December 2007

Restricted Commercial Analysis of the simplification AEAT/ENV/R/2506/Issue 3 of the TiO2 Directives

AEA Energy & Environment iii

Title Analysis of the Simplification of the Titanium Dioxide Directives

Customer European Commission DG Environment Sustainable Development and Economic Analysis Unit

Customer reference ENV.G.1/FRA/2006/0073

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This document has been prepared by AEA Technology plc in connection with a contract to supply goods and/or services and is submitted only on the basis of strict confidentiality. The contents must not be disclosed to third parties other than in accordance with the terms of the contract.

File reference ED05640

Reference number AEAT/ENV/R/2506/Issue 3

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Date December 2007

Analysis of the simplification Restricted Commercial of the TiO2 Directives AEA/ED05458/Issue 3

iv AEA Energy & Environment


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Executive Summary The overall objective of this contract is to support the Commission in the simplification and rationalisation of the Titanium Dioxide (TiO2) Directives, taking into consideration the review of Directive 96/61/EC on Integrated Pollution Prevention and Control (IPPC). The costs and benefits of different scenarios for setting emission limit values for the TiO2 manufacturing industry are assessed. In addition, consideration is given to the simplification of monitoring requirements for releases to water and air, bearing in mind that any simplification must meet the objective of ensuring no reduction of environmental protection.

The objective of this study required three linked tasks: 1. Data gathering 2. Emission limit analysis 3. Options for simplification of monitoring and changes in frequency

Two processes are used for TiO2 manufacture, the chloride and sulphate processes. Both take ore containing TiO2, convert it to other compounds enabling impurities to be removed, and then re-form TiO2. Naturally, each process has its own set of burdens to health and the environment via pollutants generated in the process.

Questionnaires designed to supplement information obtained through an earlier consultation led by the European Commission have been sent to all operators of TiO2 manufacturing plant and to regulators in all relevant Member States. Responses have been received from several Member States (Belgium, Czech Republic, Finland, Germany, the Netherlands, Slovenia and the UK).

Responses to the questionnaire indicate that there is a view in several Member States that much of the content of the TiO2 Directives is now redundant, largely because of the role of other Directives (the IPPC Directive in particular). The response of industry to the questionnaire has been low, but it has been indicated by the TDMA (Titanium Dioxide Manufacturers Association) that they are reluctant for the emission limit values specified in the 1992 TiO2 Directive to be removed.

The latest emissions data available show broad ranges for emissions per tonne of pollution. In some cases plant barely meet the Directive limits, whilst in others plant meet the lower range defined for BAT (Best Available Techniques) in the sectors BREF note1.

The costs and benefits of tightening the emission limit values given in the Directives to the ranges defined under the LVIC-S BREF for the TiO2 industry have been considered to the extent possible. Scenarios were defined as follows:

Table i. Emission limit values for each scenario

Scenario 1 Scenario 2 Scenario 3 Scenario 4 Scenario 5

Directive Upper BAT Lower BAT Between S1 and S2

Between S2 and S3

Sulphate process Dust to air 50 mg/m3 0.45 kg/t TiO2

20 mg/m3 0.004 kg/t TiO2

5 mg/m3 0.7 kg/t TiO2 0.25 kg/t TiO2

SO2 to air 10 kg/t TiO2 6 kg/t TiO2 1 kg/t TiO2 9 kg/t TiO2 4 kg/t TiO2 SO4 to water 800 kg/t TiO2 550 kg/t TiO2 100 kg/t TiO2 785 kg/t TiO2 300 kg/t TiO2 Chloride process Dust to air 50 mg/m3 0.2 kg/t TiO2 0.1 kg/t TiO2 0.4 kg/t TiO2 0.15 kg/t TiO2 SO2 to air Not given 1.7 kg/t TiO2 1.3 kg/t TiO2 No data No data Cl2 to air 5 mg/m3 (daily)

40 mg/m3 (instant) Not given Not given No data No data

Cl to water 130-450 kg/t TiO2 330 kg/t TiO2 38 kg/t TiO2 330 kg/t TiO2 150 kg/t TiO2

1 The Large Volume Solid Inorganic Chemicals (LVIC-S) BAT Refernce (BREF) note.


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The emissions data provided by the industry to the Commission earlier in 2007 enabled assessment of the extent to which these limit values were met on a plant by plant (though anonymous) basis. Where they were not met, estimates were made of the emission reductions required and associated costs and benefits, where possible.2 Results are summarised in Tables (ii) and (iii), the two tables representing the range of results arising from uncertainty in the way that emission limit values and emissions data are expressed (whether per tonne of pure TiO2 or per tonne TiO2 pigment). Table ii. Costs and benefits of moving to within the emission limit values defined for each scenario1

based on assumptions that minimise the number of plant exceeding limit values (emissions expressed against TiO2, ELVs against TiO2 pigment).

Scenario 2 Scenario 3 Scenario 4 Scenario 5 Additional abatement costs (M/year) Dust 1.3 6.4 0 2.2 SO2 6.4 17 0 9.6 Chlorine No data No data No data No data Sulphate 2.2 12 0 4.4 Chloride 0 No data 0 No data Quantified costs 4

9.9 34 0 16

Benefits from additional abatement (M/year) 2, 3 Dust 1.3 10 0 3.2 SO2 14 25 0 17 Other pollutants Not quantified Not quantified Not quantified Not quantified Quantified benefits 4

15 35 0 20

Notes: 1) So far as simplification of the TiO2 Directives is concerned, there are no costs or benefits relating to the attainment of the current Directive (i.e. the Scenario 1 limit values). 2) Damage cost data are available only for emissions of dust and SO2, but not for emissions of sulphate, chloride or chlorine. 3) Benefits shown are based on damage costs at the lower end of the range given in the BREF on Economics and Cross Media Effects. Use of the upper end of the range would make these benefits roughly three times larger. 4) The total quantified costs shown here omit the costs of any further abatement of chlorine (if it is necessary) and in some cases, further controls on chlorides. Quantified benefits are less complete still, with no benefits quantified for sulphates, chlorides or chlorine. This needs to be considered when comparing the totals shown for costs and benefits.

Table iii. Costs and benefits of moving to within the emission limit values defined for each scenario1 based on assumptions that maximise the number of plant exceeding limit values (emissions expressed against TiO2 pigment, ELVs against TiO2).

Scenario 2 Scenario 3 Scenario 4 Scenario 5 Additional abatement costs (M/year) Dust 1.8 6.4 1.3 3.9 SO2 9.6 19 4.8 16 Chlorine No data No data No data No data Sulphate 4.4 13 0 6.6 Chloride no data No data 0 No data Quantified costs 4

16 39 6.1 27

Benefits from additional abatement (M/year) 2, 3 Dust 2.5 11 0.5 4.5 SO2 17 25 11 20 Other pollutants Not quantified Not quantified Not quantified Not quantified Quantified benefits 4

20 36 12 25

Notes: See notes to Table (ii).

2 Updated emissions data were sent by the TDMA to the Commission at the end of the project, but unfortunately too late for inclusion in the full

analysis carried out under the contract. However, it has been concluded that they are unlikely to significantly change the conclusions reached in this report (see Section 6.4 and Appendix 5).


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The results shown in the two tables are subject to various uncertainties further to questions about how emission limit values and emissions data are expressed and the magnitude of benefits per unit emission of SO2 and dust (see note 3 to Table ii). The most significant include:

a) Changes in emissions through switching to alternative sources of ore and to different fuels. b) Uncertainties in the extent to which emissions can be reduced. This brings into question the

achievability of the Scenario 3 limits in particular. c) Uncertainties in the costs of reducing emissions. This contains biases in both directions

estimated costs are largely based on installation of new equipment rather than the upgrading of existing plant. This is unlikely to be necessary in all cases. On the other hand, some plant may require significant adaptation to fit in necessary equipment. Costs are most uncertain for attainment of the Scenario 3 (lower BAT-AEL) limits - there is little information in the LVIC-S BREF on how these are achieved.

d) Uncertainties in the response of industry to a tightening of emission levels. It is possible that cheaper solutions could be found than those proposed (e.g. changing the type of ore used). At the other extreme, operators could decide to close plant rather than upgrade them industry sources have said that 2 plant could close if dust emission limits were reduced to 5 mg/Nm3, though have provided no supporting evidence for this view.

e) There is potential to generate significant additional environmental burdens by moving to the lowest emission control scenarios. The effects of these burdens (greenhouse gas and other air emissions, solid wastes, etc.) are not accounted for here.

Overall, no evidence has been made available under the contract that demonstrates that the analysis presented here has a significant bias in any direction. At the same time, information that would allow more detailed analysis of the effects of these uncertainties on the cost-benefit analysis is not available. With this in mind, and irrespective of the way that a future directive might express ELVs, it is recommended that most attention be given to the results shown in Table (iii) where it is assumed that emissions data available for the analysis are expressed per unit TiO2 pigment and ELVs are expressed per unit pure TiO2,. This is the most pessimistic case of the three listed above so far as possible exceedance of limit values and hence additional costs of abatement are concerned. As the most pessimistic case, it is also the one that provides the most robust rationale for a reduction in emission limit values.

It has not been possible to assess compliance of chlorine emissions with the Directive through a lack of data in the format necessary. However, releases of chlorine to the environment should be tightly controlled as a result of the Seveso II directive, which applies to chloride process TiO2 plant. It is noted that emissions of chlorine from one plant seem significantly higher than from the other four chloride process plant.

The effects of pollutant releases to air and to water are dependent on the site of release. However, this is much more important for emissions to water, as pollutant movement is more constrained and receiving environments are extremely variable with respect to chemical composition, flow rates, ecology and so on. When setting emission limits for liquid discharges it is therefore much more important to take account of the site of release than it is when setting limits for aerial discharges. A further issue is that this variability means that generic estimates of damage per tonne emission are not available for releases to water in the same way that they are available via the BREF on Economics and Cross Media Effects for certain air pollutants, and hence for sulphate and chloride emissions no estimate of the benefits of additional control has been made (explaining the lack of information on their effects in Tables (ii) and (iii)).

The monitoring requirements of the TiO2 Directives have been reviewed and considered alongside other legislation (e.g. the Air and Water Framework Directives and the IPPC Directive). CEN, ISO and other monitoring standards have been identified and are listed in the report.

It is acknowledged that, historically, the requirement for environmental monitoring around TiO2 manufacturing sites made good sense, though given improvements in the performance of TiO2 plant in the last 30 years it is not clear that this remains the case. On this basis (and others detailed in the report, such as the requirements of the air quality and water framework Directives, agreed since the last of the current TiO2 came into force) there may be a rationale for abandoning much of the wider environmental monitoring required specifically in relation to the TiO2 industry. Associated costs are estimated, with a commentary on whether they are likely to be paid for by the operator or the


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regulator. However, it is noted that Directive 82/883/EEC already provides for simplification of monitoring to meet local conditions (via Article 4.3) once it is established that emissions from TiO2 manufacture are not causing significant environmental damage.

It would be possible to simplify the 1992 Directive by reference to the process discharge monitoring requirements of the IPPC Directive. However, given that the monitoring would need to be done anyway this simplification would have no effect, other than a minor easing of the regulatory burden for reporting on the TiO2 regulations to the European Commission.


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Table of contents 1 Introduction ...................................................................................................... 1

1.1 Objectives of this Report.................................................................................................... 1 1.2 Environmental Regulation of the TiO2 Industry ................................................................. 1 1.3 Consultation on Simplification of the TiO2 Directives ........................................................ 2 1.4 Overview of Study Methodology........................................................................................ 2

2 The TiO2 Industry in Europe............................................................................ 6 2.1 Overview ............................................................................................................................ 6 2.2 Chloride Process ............................................................................................................... 7 2.3 Sulphate Process............................................................................................................... 9 2.4 Pollution Control Techniques for Air Emissions............................................................... 11 2.5 Pollution Control Techniques for Liquid Effluents............................................................ 12 2.6 Control of Solid Wastes ................................................................................................... 13 2.7 TiO2 Content of Pigment as Sold..................................................................................... 14

3 Data Collection from the Industry and Regulators...................................... 16 3.1 Approach.......................................................................................................................... 16 3.2 Responses to Survey Sent to Plant Operators................................................................ 16 3.3 Responses to Surveys Sent to Member State Regulators .............................................. 16

4 Emission Scenario Analysis of Social, Economic and Environmental Impacts.................................................................................................................... 18

4.1 Impacts Associated with the Sector................................................................................. 18 4.2 Scenario Development .................................................................................................... 19 4.3 Analysis............................................................................................................................ 21 4.4 Effects on competitiveness and employment .................................................................. 33

5 Analysis on Monitoring of the Environment ................................................ 38 5.1 Introduction ...................................................................................................................... 38 5.2 Summary of monitoring requirements in the TiO2 Directives........................................... 38 5.3 Current monitoring in relation to TiO2 manufacture: ........................................................ 41 5.4 Monitoring Standards....................................................................................................... 44 5.5 Potential for simplification of monitoring .......................................................................... 46 5.6 Analysis of the impacts of simplifications of monitoring requirements ............................ 49

6 Conclusions and Recommendations ........................................................... 52 6.1 Emission limit values ....................................................................................................... 52 6.2 Monitoring ........................................................................................................................ 54 6.3 Definitions ........................................................................................................................ 55 6.4 Further analysis ............................................................................................................... 55


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Appendices Appendix 1: References Appendix 2: Questionnaire sent to Plant Operators Appendix 3: Questionnaire sent to Member States Appendix 4: Background information on impacts associated with pollutants emitted from TiO2 manufacture Appendix 5: Emissions data Appendix 6: Emission control methods and costs Appendix 7: Trends in Emissions According to EPER, 2001-2004 Appendix 8: Monitoring standards for relevant air pollutants


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1 Introduction

1.1 Objectives of this Report The overall objective of this contract is to support the Commission in the simplification and rationalisation of the Titanium Dioxide (TiO2) Directives, taking into consideration the review of Directive 96/61/EC on Integrated Pollution Prevention and Control (IPPC). The costs and benefits of different scenarios for setting emission limit values for the TiO2 manufacturing industry are assessed. In addition, consideration is given to the simplification of monitoring requirements for releases to water and air, bearing in mind that any simplification must meet the objective of ensuring no reduction of environmental protection.

1.2 Environmental Regulation of the TiO2 Industry At present there are three Directives in place which set out controls including monitoring requirements for TiO2 manufacture. The Directives are summarised in Table 1-1.

Table 1-1 : Summary of titanium dioxide Directives

Directive Title Main Provisions 78/176/EEC Council Directive on waste from the

Titanium Dioxide Industry Minimum permitting requirements, monitoring and requirement for Member State progress reports.

82/883/EEC Council Directive on procedures for the surveillance and monitoring of environments concerned by waste from the Titanium Dioxide industry

Defines the frequency, locations, and parameters to be monitored at and around TiO2 facilities

92/112/EEC Council directive on procedures for harmonising the programmes for the reduction and eventual elimination of pollution caused by waste from the Titanium Dioxide industry.

Specifies emission limit values for waste streams discharged to water and discharges to air.

The TiO2 Directives include requirements for Member States to provide reports to the Commission on progress towards objectives and the ongoing monitoring of the receiving environments. However, little information was available on this.

Other Community legislation is also relevant; in particular the Directive 96/61/EC (IPPC) and the Directive 2006/12/EC on waste, Directive 2000/60/EC (the Water Framework Directive) and Directive 96/62/EC on air quality.

The industry is also affected by the Euratom Directive (96/29/EEC) as a result of the presence of trace levels of NORMs (Naturally Occurring Radioactive Materials) in some ores and the Seveso II Directive from use of chlorine in plant that follow the chloride process for TiO2 manufacture.

Use of sector-specific Directives to control the environmental impact of industrial activities is not common (other directives include 2000/76/EC on incineration of waste and 2001/80/EC on large combustion plant), the main Community mechanism for control of industrial activities is the IPPC Directive, which requires consideration of releases to all media. However, the IPPC Directive was not in place when the need for a Community measure to control TiO2 manufacture was identified.


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1.3 Consultation on Simplification of the TiO2 Directives 1.3.1 Stakeholder consultation The Commission started to consult Member States in 2004, with a questionnaire relating to simplification of specific measures in the TiO2 Directives. A second stakeholder consultation was carried out in 2006 including a questionnaire and a paper showing potential simplifications to the TiO2 Directive3. The proposals for the simplified Directive essentially merged the requirements of the three existing TiO2 Directives into a single Directive. The questionnaire offered stakeholders the opportunity to comment on the proposed changes. Stakeholders were also invited to comment and provide suggestions for further potential simplification; in particular in those areas, such as permitting and monitoring, where other Community legislation (including IPPC, waste and water Directives) provides some overlap in controls.

The Titanium Dioxide Manufacturers Association (TDMA) provided a detailed response to the Commission, including specific suggestions for reduction of monitoring and comments on wastes and by-products. Two other organisations provided comments on the consultation.

Kronos (a TiO2 manufacturer) and, RIZA (the Netherlands Institute for Inland Water Management and Waste Water Treatment)

The RIZA response provided comments on waste definition, consistency with the BREF (Best Available Techniques Reference) note on the Large Volume Inorganic Chemical Solids (LVIC-S) IPPC sector and questioned whether there was still a need for a separate Directive for TiO2. However, Kronos recommended retention of the TiO2 Directives emission limit values and did not consider that regulation under the IPPC Directive alone was appropriate.

1.3.2 Further consultation with Member States Following the Stakeholder consultation the Commission sought additional information from Member States in early 2007. Seven Member States with TiO2 plant in their territories provided responses and these all considered that simplification of the monitoring requirements of the Directives was possible but only a few provided any detail of proposed simplifications and changes.

The suggestions included: Reducing monitoring frequency (to once every five years), Basing water monitoring on the requirements of the Water Framework Directive, Using CEN Standards where available, Monitoring effluent toxicity directly rather than monitoring the effect of emissions in the broader

environment, and Targeting monitoring to address the most important components.

1.4 Overview of Study Methodology The objective of this study required three linked tasks:

1. Data gathering 2. Emission limit analysis 3. Options for simplification of monitoring and changes in frequency

These tasks are described in the following sections.

3 Consultation document on a simplification of the Titanium Dioxide Directives available on the European Commission DG Environment website

at http://ec.europa.eu/environment/waste/titanium.htm



1.4.1 Data gathering Information from the Commissions consultation and information gathering exercise was reviewed with LVIC-S BREF note and selected IPPC permits for TiO2 installations. Questionnaires were developed for the environmental regulatory authorities in Member States responsible for the TiO2 industry. A separate questionnaire was developed for the operators of the TiO2 installations. The questionnaires are provided in Appendix 2 and Appendix 3 and were developed to address gaps (and potential changes) in data from the earlier stakeholder and Member State consultation and the BREF document for the sector.

The timescale for data collection was very short and a low response was anticipated. Initial contact with the manufacturers association (TDMA) had indicated that data for the manufacturing sites could be obtained from this organisation. Following a meeting with the TDMA however, it was agreed that the level of detail and timescale required contact with the individual manufacturers.

Although the time for response was very short several Member States (Belgium, Czech Republic, Finland, Germany, the Netherlands, Slovenia, Spain and the UK) provided responses. Of the manufacturers only Kemira Pigments has so far responded to the questionnaire, though some other information has been provided on behalf of the industry by the TDMA in response to some further questions raised in the course of this work.

1.4.2 Cost-benefit analysis A cost-benefit analysis has been carried out against different limit values, to the extent possible. The existing TiO2 Directives provide the baseline, with further scenarios based on the upper and lower ends of ranges specified in the relevant BREF note. Changes in emissions from reported data to the alternative limits were considered. Quantification through to monetised values of (primarily) health benefits was possible for dust and SO2 using reference data on costs per tonne emission from the BREF on Economics and Cross Media Effects. Similar analysis is not possible for pollutants discharged to water as such reference values do not yet exist, largely because of the complexity of exposure pathway characterisation. Data on the costs of further abatement were taken from sources including the LVIC-S BREF note, responses to the questionnaires and the US Environmental Protection Agency (USEPA).

1.4.3 Potential monitoring changes The monitoring requirements of the TiO2 Directives were reviewed. The TiO2 Directives include mandatory and optional monitoring with guidance on frequency and measurement technique. The purpose of the monitoring was assessed; in particular those parameters which provide a potential input to assessment of environmental deterioration and those parameters which have limit values identified.

The monitoring requirements of the TiO2 Directives were compared with monitoring requirements implemented by regulatory authorities in operating permits and additional monitoring by regulators and other agencies (where available).

The availability of EN, ISO and national standards for the monitoring parameters in the TiO2 Directives was assessed (the Directives provide little information on measurement standards).

The responses from earlier consultations were reviewed for potential simplifications in monitoring scope. In addition the monitoring requirements were assessed for coherence with BAT guidance on monitoring and the sector.



2 The TiO2 Industry in Europe

2.1 Overview At a European level the TiO2 industry is represented by the Titanium Dioxide Manufacturers Association (TDMA), part of CEFIC (the Council of the European Chemical Industry). TDMA membership is as follows:

Cinkarna Celje.d.d. (SI) Degussa (DE) Huntsman Tioxide Europe (GB, ES, FR, IT) Kemira Pigments Oy (FI) Kronos Worldwide Inc. (BE, DE, NO) Millennium Chemicals (GB, FR) Precheza AS (CZ) Sachtleben Chemie GmbH (DE) Tronox Pigments International GmbH (DE, NL) Zaklady Chemiczne POLICE S.A. (PL)

Associate members: DuPont de Nemours (USA) Ishihara Sangyo Kaisha, Ltd. (Japan)

Titanium dioxide (TiO2) pigments are used in a variety of products ranging from printing inks to plastics to food. Annual production in Europe is around 1.5 million tonnes, spread across 19 factories operating in 12 countries (Table 2-1). There are two processes used to manufacture TiO2, the chloride process and the sulphate process. Each leads to different environmental burdens with respect to the types and quantity of pollution released, as shown in the following sections. The plant at Leverkusen uses both processes, with a capacity of 100 kt for the chloride process and 30 kt for the sulphate process.

Table 2-1. Production capacity of TiO2 facilities in the European Union in 2002 (Source LVIC-S BREF).

Country Company Location Process Capacity (t) Belgium Kronos Europe Langerbrugge Chloride 60,000 Czech Rep Precheza Prerov Sulphate 41,000 Finland Kemira Pigments Pori Sulphate 130,000 France Tioxide Europe Calais Sulphate 100,000 France Millenium Chemicals Le Havre Sulphate 95,000 France Millenium Chemicals Thann Sulphate 30,000 Germany Sachtleben Duisburg-Homberg Sulphate 100,000 Germany Tronox Krefeld-Uerdingen Sulphate 107,000 Germany Kronos Titan Leverkusen Both 130,000 Germany Kronos Titan Nordenham Sulphate 62,000 Italy Huntsman Tioxide Scarlino Sulphate 80,000 Netherlands Tronox Rotterdam-Botlek Chloride 55,000 Poland Zaklady Cemiczne Police Sulphate 40,000 Slovenia Cinkarna Celje Sulphate 44,000 Spain Tioxide Europe Huelva Sulphate 80,000 UK Tioxide Europe Greatham Chloride 100,000 UK Tioxide Europe Grimsby Sulphate 80,000 UK Millennium Chemicals Grimsby/Stallingborough Chloride 150,000



As in other sectors, the TiO2 industry has made major investment (in excess of 1.4 billion) to reduce its burden on the environment since the early 1980s and emissions have undoubtedly fallen significantly as a result. However, there has as yet been no formal appraisal of costs and benefits to determine whether current emission levels are at a societal optimum. An important feature of both the chloride and sulphate processes is the extent to which waste materials are recycled within process, or sold as by-products, avoiding unnecessary releases and generating revenue or avoiding material costs for the companies involved.

2.2 Chloride Process The chloride process is shown in Figure 2-1, which is followed by a list of material inputs and, for each stage of the process a list of the main burdens arising to health and the environment, and brief details of how they are controlled (Table 2-2).

Figure 2-1. Outline process diagram for manufacture of TiO2 via the chloride process (Source: LVIC-S BREF)

The main inputs to the process, in addition to water and energy, are as follows, by process stage: Chlorination: Ore containing TiO2, chlorine and coke Solids separation and waste solid metal chlorides treatment: Lime and coal TiCl4 purification (removal of vanadium): Oil Oxidation: Oxygen, toluene Cooling and separation: Abrasive solids (e.g. silica sand, rock salt or granular TiO2)



Waste gas cleaning: Caustic soda Liquid effluent cleaning: Lime

Table 2-2. Main burdens and risks arising from each stage of the chloride process and their control.

Stage Main burdens Control Chlorination: Reaction of TiO2 with chlorine to form TiCl4.

Use of chlorine

Some impurities such as silica and zirconium removed

Seveso II Directive requires enclosure and high integrity of process and detailed hazard assessment to minimise Cl emissions to environment Solid wastes either recycled or destined for appropriate landfill disposal

Solids separation Further removal of impurities, generating waste

Solid wastes either recycled or destined for appropriate landfill disposal

Neutralisation of waste solid metal chlorides using lime

Further removal of impurities, generating solid waste

Some sale of FeCl2, most metal chlorides sent to appropriate landfill

Condensation of TiCl4, jet scrubbing of gas stream with cold TiCl4

Further removal of impurities, generating waste

Gas stream passed for waste gas treatment (see below)

Distillation, further purification of TiCl4

Further removal of impurities, generating waste

See below

Vanadium oxychloride removal using oil

Generation of sludge containing complexed VOCl2

Sludge recycled back to solids separation where it is removed from the process stream and disposed of as appropriate

Oxidation at 900-2000C, converting back to TiO2 and controlling final crystal size

Use of oxygen Emissions associated with energy use Generation of chlorine

Energy efficiency measures

See next stage Cooling and separation Presence of chlorine Chlorine recycled to chlorination

stage Adsorption / desorption process, TiO2 slurried in water

Presence of chlorine Chlorine absorbed in liquid TiCl4 and recycled to chlorination stage, though some remains for waste gas treatment

Finishing via milling and coating with additives to improve pigment properties

Generation of dust Removal using bag filters

Waste gas treatment CO, COS

HCl

Cl2 Use of caustic reagents Generation of liquid effluent

May be removed by thermal oxidiser, generation of less hazardous CO2 and SO2, possibility of selling sulphur as a co-product Absorbed using aqueous scrubbers, may produce sale grade HCl acid Removed by caustic scrubbing Containment, safe handling, etc. See below

Treatment of solid wastes, via neutralisation using chalk or lime, precipitation and stabilisation of metals

Production of filter cake requiring disposal

Some generation of by-products. Residual solid wastes disposed of to appropriate landfill.

Treatment of liquid effluents Transfer of pollutants from liquid to solid media

Consent limits for effluent composition will reflect the nature of the receiving medium

The term main burdens as given in the above table needs some clarification. It refers to the main burdens of the process before control. Hence, although containment of chlorine gas is a major



consideration at plant using the chloride process, the process technology is designed to prevent significant emissions of chlorine to the wider environment.

2.3 Sulphate Process The sulphate process is shown in Figure 2-2, which is followed by a list of material inputs and, for each stage of the process a list of the main burdens arising to health and the environment, and brief details of how they are controlled (Table 2-3).

Figure 2-2. Outline process diagram for manufacture of TiO2 via the sulphate process (Source: LVIC-S BREF)

The main inputs to the process, in addition to water and energy, are as follows: Digestion: Ore containing TiO2, sulphuric acid Reduction: Scrap iron Clarification and crystallisation: Small amounts of filter aid and lime Hydrolysis, filtration and washing: No significant material usage Calcination: Small amounts of mineral salts such as KCl Finishing: Inorganic metal sulphates and caustic soda Waste gas cleaning: Caustic soda and peroxide



Liquid effluent cleaning: Lime and limestone, particularly if neutralisation is the chosen abatement system

Table 2-3. Burdens arising from each stage of the sulphate process, and their control. Stage Main burdens Control Digestion Use of concentrated (80-

95%) sulphuric acid Off-gases containing SOx, dust, H2S

Containment, safe handling, etc.

Normal or multi-stage scrubbing

Reduction (when primary ore is ilmenite)

Generation of hydrogen Discharged to air avoiding explosive hazard

Clarification and crystallisation using flocculation and filtration

Solid residue Limited re-use, most neutralised then sent for landfill

Hydrolysis Emissions associated with energy use Spent acid


Acid is recycled or neutralised with lime or limestone to form gypsum, which is sold or land filled

Filtration and washing Acidic filtrate

Residual solid metals (Fe, Cr, Mn, V)

Acid is recycled or neutralised with lime or limestone to form gypsum, which is sold or land filled

Calcination Emissions associated with energy use SO3 SO2

TiO2 dust


Removed by ESPs Scrubbed or oxidised to SO3 and absorbed to form sulphuric acid which can be recycled Removed by scrubbing, recycled

Finishing via milling and coating with additives to improve pigment properties

Generation of dust Removal using bag filters

Waste gas treatment Dust

H2S, SO2 Use of caustic reagents Generation of liquid effluent

Removed using bag filters and cyclones Removed by scrubbing Containment, safe handling, etc. See below

Treatment of solid wastes, via neutralisation using chalk or lime, precipitation and stabilisation of metals

Production of filter cake requiring disposal

Some generation of by-products. Residual solid wastes disposed of to appropriate landfill.

Abatement of aqueous emissions

Transfer of pollutants from liquid to solid media

Acid recycling Neutralisation Consent limits for effluent composition will reflect the nature of the receiving medium

An important feature of the sulphate process is that the digestion process is carried out batch wise rather than continually. One consequence of this is that the gas cleaning systems need to be able to handle large volumes of gas for relatively short periods in the order of minutes, followed by lower volumes during a bake period that lasts for several hours.



2.4 Pollution Control Techniques for Air Emissions4 2.4.1 Sulphate process The LVIC-S BREF indicates that the main emissions to air from the sulphate process arise from the digestion and calcination sections. The key emissions are oxides of sulphur (SO2 and SO3) and hydrogen sulphide (H2S). Other emissions from the process including particulate matter (PM) from materials handling, storage/packing and milling. Off-gas treatment from the digestion stage are simple scrubbing processes or, in common with the calcination process, are designed to suit opportunities for recovery of materials on site.

In some digestion plant (only plant dealing with natural ore rather than slag) the off-gases are scrubbed with waste water which then passes for treatment before discharge. In other processes, off-gases can be quenched and scrubbed with caustic soda; the resulting scrubber liquor can either be decomposed to SO2 and S for further use in an acid plant or, is passed for treatment before discharge. Alternatively; gases are quenched and passed through an electrostatic precipitator to remove acid mist. The SO2 fraction is then oxidised to SO3 and absorbed in dilute sulphuric acid and recovered.

The LVIC-S BREF provides the following summary of costs for digestion and calcination off-gas treatment.

Table 2-4 : LVIC-S Costs of acid gas abatement for digestion and calcination

Digestion (installations) Calcination (installations) Costs /tonne TiO2 produced

Slag (3) Ilmenite (8) std catalyst (6)

hp catalyst (1)

Scrubbing (3)

Capital 85 75 70 140 170 Operating 10 5 5 10 9

The average SO2 concentrations discharged to atmosphere in 1999 for digestion and calcination in the BREF were 87 and 713 mg/m3 respectively. The average SO2 emission concentration for digestion is comparatively low and the scope for improvement is limited. However, it is interesting to note the BAT range for AELs (as a daily average) for sulphuric acid manufacture from contact and absorption which is between 100 and 680 mg/m3. The BAT range for sulphuric acid plant suggests that there is scope for up to 85% reduction based on 1999 emission levels.

The LVIC-S BREF indicates that particulate emission controls are fabric filters or cyclones and these technologies are able to meet the ELVs specified in the TiO2 Directives. However the indicated average concentrations (12-39 mg/m3 for various activities in 1999) appear high for fabric filters which can achieve concentrations



2.5 Pollution Control Techniques for Liquid Effluents5 2.5.1 Wastewater composition Based on the information found in the LVIC-S BREF (2006) and the answers to questionnaires from Member States (including e.g. general and specific permit conditions) the wastewater of a titanium dioxide plant contains the following substances: For the chloride route: chlorides (hydrochloric acid (HCl)), suspended solids (SS), metals (Mn, Fe,

V, Cr, Zn, Ni, Pb, Cu, As, Cd, Hg), chlorinated organic compounds For the sulphate route: sulphate, suspended solids (SS), metals (Fe, Cd, Hg, others)

2.5.2 Effluent treatment techniques Based on the wastewater composition, it can be concluded that effluent treatment techniques should be considered for chlorides, sulphates, suspended solids and metals. In the following sections, a brief description is given for some techniques.

2.5.2.1 Chlorides

Inorganic chlorides contained in a waste water stream are generally not abated, but released into the environment [CEFIC, 2002 in LVIC-S BREF, 2006, BREF Common WWT and GT, 2003]. However, this is strongly dependent on the receiving environment and the compound emitted [85, EIPPCB, 2004-2005 in LVIC-S BREF, 2006].

2.5.2.2 Sulphates

Part of the sulphates can be removed by, e.g. precipitation with lime (or limestone to form gypsum which can be sold as a co-product). An excess of lime allows a reduction in the release of sulphates, but this obviously leads to an increased usage of lime [6, CEFIC, 2002 in LVIC-S BREF, 2006].

2.5.2.3 Suspended solids

There are many ways, used individually or in combination, to eliminate suspended matters from waste water streams: Flocculation Natural or mechanical-aided decantation Air-flotation Filtration Etc. are the most widely used techniques [CEFIC, 2002 in LVIC-S BREF, 2006, BREF Common WWT and GT, 2003].

2.5.2.4 Metals

Metals are usually contaminants (such as Fe(II) to Fe(III)) of the feedstock and they end up with the product, as solid waste, or dissolved in waste water streams. In this latter case, and when it is necessary to avoid rejecting them into the water body, the conventional process consists of precipitating and separating insoluble metal hydroxides, sulphides or phosphates. The metal release depends on many factors, such as the metal itself; the nature of the precipitating agent and the presence of other metals or organics. Also an excess of reactant allows the reduction in the release of metal, but this then leads to an increased release of the reactant itself [CEFIC, 2002 in LVIC-S BREF, 2006].

5 Further information relevant to this section is given in Appendix 6, particularly with respect to the costs of abatement.



2.5.3 Description of most relevant techniques

2.5.3.1 Primary treatment

2.5.3.1.1 Oxidation Oxidation of contaminants can be achieved by the addition of a variety of reagents. For example, ozone, hydrogen peroxide, and sodium hypochlorite can be used. Other schemes involve pure oxygen, and proprietary catalyst systems. 2.5.3.1.2 Neutralisation If possible, the first step of neutralisation should be to merge the acidic and alkaline waste water streams, in order to avoid additional salt load. Effluents should be dosed with an appropriate acid or alkali to achieve a neutral solution. As dosing systems cannot cope with effluents of extreme pH, an intermediate facility capable of storing strongly acidic or alkaline effluents should be installed with automatic control. 2.5.3.1.3 Solids removal The removal of particulate matter from effluents can be hindered by flow fluctuations. The removal of finely divided suspended solids can be enhanced by the addition of chemical coagulants/flocculants. These substances can also aid the removal of emulsions and grease. Techniques for the removal of solids include: settlement, flotation, precipitation, dewatering and filtration. Precipitation can be described as the altering of dissolved compounds to insoluble or badly soluble compounds, in order to be able to remove the compounds by means of filtration. Filtration is the separation of a solid and a liquid by using a porous substance that only lets the liquid pass through.

2.5.3.2 Secondary/tertiary systems

2.5.3.2.1 Ion exchange resins Ion exchange can be employed for the removal of undesirable anions and cations from waste water. Cations are exchanged for hydrogen or sodium, and anions for hydroxyl ions. Removal of the fine particles containing metal prior to ion exchange may be necessary. Special selective ion exchange resins are used to selectively remove trace amounts of e.g. metals from the other ions in the solution. 2.5.3.2.2 Membrane processes Membrane processes include: ultrafiltration, reverse osmosis, and membrane filtration. These systems concentrate solutions by selective filtration and usually produce a purified filtrate stream and a concentrate stream. These types of processes can be used either to clean up the waste water for re-use, or to recover material for recycling. 2.5.3.2.3 Biological treatment In specific conditions, biological treatment can be used to remove the compounds of nitrogen, phosphorus and sulphur from waste waters. 2.5.3.2.4 Electromechanical techniques Metals can be extracted from aqueous streams by sacrificial exchange. This process would result in the release of another metal into the aqueous stream.

2.6 Control of Solid Wastes To the extent considered possible by the industry, waste streams associated with the industry, whether gaseous, liquid or solid are processed to remove materials that can be extracted with sufficient quality for use elsewhere. Residual solid wastes (filter cake, etc.) will be sent to landfill. Controlled disposal at landfill sites requires that account be taken of the hazard posed by waste materials. In the case that hazardous wastes are disposed of the landfill concerned must have adequate leachate collection, etc., to prevent the escape of hazardous substances.



2.7 TiO2 Content of Pigment as Sold The Titanium Dioxide Directives do not define titanium dioxide, presumably because there seemed at the time that they were written not to be any need to define beyond the chemical formulation. In contrast, the BREF gives AELs per unit TiO2 pigment produced. This leads to some uncertainty in how emissions, normalised per unit of production (i.e. expressed as kg per tonne TiO2) have been calculated, whether against the actual quantity of TiO2 produced, or the quantity of pigment labelled as TiO2 leaving the factory. The issue arises chiefly as a result of the finishing stage where additives are used to improve the properties of the TiO2. Information provided on the internet gives the following data on TiO2 content of the marketed product for six of the European producers, with figures ranging from 80 to 99%. This suggests that any bias introduced by different assumptions to the meaning of a tonne of TiO2 is at most 25%, and typically less (possibly much less). Table 2-5. Titanium dioxide content of pigments as sold

Manufacturer Product name or brand Product applications

Pigment TiO2 content (%)

Huntsman Pigments TIOXIDE Decorative and industrial coatings, plastics, inks, paper and ceramics 80 97.5

Millennium Chemicals Ltd Tiona Surface coatings, plastics, paper 80 99

Kemira Pigments Oy Kemira Paints and coatings, packaging inks, paper and plastics 82 99

Kronos KRONOS Coatings, plastics and paper laminates 82 99 Tronox Pigments International GmbH TRONOX

Coatings, paper, plastics and printing inks 86 99

Zakady Chemiczne POLICE S.A TYTANPOL Paints, plastics, rubber, textile, ceramic and paper 88 98.5

Note: No data were found on the internet for the products of Degussa, Cinkarna, Precheza and Sachtleben

The TDMAs interpretation is that the directive expresses sulphate and chloride discharge limits as per tonne of 100% TiO2 which is typically equivalent to the uncoated product that arises either from calcination (sulphate process) or oxidation (chloride process). The ecolabel criteria for paints refer to the directive so it is necessary to back calculate from the coated product to the limits based on pure TiO2. So far as the BREF was concerned it was felt that it would be simpler to express limits related to the actual product sold (i.e. per tonne pigment), to avoid the need for additional calculation.

However, there remains uncertainty concerning the emissions data used below, and on which discussions relating to the development of the BREF were based. Whilst labeled as being per tonne TiO2 the figures provided in several cases match those given per tonne pigment in the BREF. One option for addressing this issue whilst the question remains open is to run sensitivity analysis in the assessment of possible changes to emission limit values, considering reported emissions to be per tonne TiO2 and per tonne TiO2 pigment. A value of 85% TiO2 content looks a suitable lower bound from the information given in Table 2-5. Lower values are given in the table, but the analysis is concerned not with products at the extremes of ranges, but with likely average values for any plant.



3 Data Collection from the Industry and Regulators

3.1 Approach Questionnaires were developed for the environmental regulatory authorities in Member States responsible for the TiO2 industry. A separate questionnaire was developed for the operators of the TiO2 installations. The questionnaires were developed to address gaps (and potential changes) in data from the earlier stakeholder and Member State consultation and the BREF document for the sector.

3.2 Responses to Survey Sent to Plant Operators Only limited response was received during the contract period from operators. These provided some useful information for the analysis, but a more complete response would have enabled the analysis to be performed with a higher level of confidence. However, response was received from the TDMA on a series of specific questions raised during the course of the contract in relation to:

1. How industry defines TiO2 for the purpose of the Directive (i.e. as 100% pure TiO2, or following coating etc. to make the marketed pigment). For the purpose of the Directive the industry seems to consider the weight of uncoated TiO2, in other words, the material at the end of the calcinations step (for the sulphate process) or the oxidation step (for the chloride process). It was felt to be simpler in the BREF to define limits against the amount of material sold.

2. Performance of gas cleaning equipment. It is noted below that the emitted concentration of dust for TiO2 plant is higher than that achieved using similar technologies for gas control elsewhere. The TDMA respond that Although values below 50mg/m3 are obtainable 5mg/m3 is not realistic. One of the TDMA member companies has indicated that the required increase in filter area to get near this would result in the need for new buildings and closure of 2 plants.

3. Performance of liquid effluent cleaning equipment. Again, questions have been raised as to whether the existing TDMA plant are operating optimally with respect to chloride and sulphate emissions. TDMAs response is that emissions are site specific reflecting the sensitivity of the receiving environment and also reflect the ore used for input.

Emissions data were submitted by the TDMA to the European Commission for European operators prior to the start of the contract (the data on which analysis presented in the BREF was based, with some updates to fill in gaps)6.

3.3 Responses to Surveys Sent to Member State Regulators

Responses were received from the Regulatory Authorities in 8 Member States. Several commented that the European Commission had requested similar information in its questionnaire of March 2007 and were unable to go far beyond that on the short timescale of this contract. However, it was noted that some Regulatory Authorities were able to provide much more detailed information than others, for example, permits were made available for only about half of the plant in the countries covered by respondents.

6 As noted elsewhere, further data (specific to 2006) were provided by TDMA at the end of the contract, too late for inclusion in the main analysis.

These data are presented in Appendix 5.



3.3.1 Releases to Air and Water Responses to these questions varied considerably in depth, ranging from no response, to a simple reference to compliance with the Directives, to more detailed description of emissions and their monitoring and how plant specific limits were derived. Most respondents confirmed whether discharges to water were released to rivers, estuaries or the sea.

3.3.2 Discharges to Land Five Member States provided information on this topic, confirming that solid wastes were being sent to landfills of appropriate design for the materials concerned, and that monitoring was done to guard against environmental harm.

3.3.3 Environmental Monitoring An overview of the answers given in relation to monitoring can be found under section 5.

3.3.4 Monitoring Organisations and Costs A summary of the monitoring practice in the different Member States, based on the answers received from the different authorities, is given in Table 3-1.

Table 3-1 Monitoring practice

Member State Monitoring Estimated yearly cost () Payer Belgium Surface water quality (Ti) 2,400 Authority Wastewater (emissions) 1,500-2,000 (+ 1 man-day) Authority Czech Republic NR NR NR Spain Plant emission monitoring NR Operator Any additional monitoring

carried out by authority NR Authority

Germany NR NR NR The Netherlands NR NR NR Slovenia National monitoring NR Authority Emission monitoring 75,000 Operators UK Emission monitoring NR Operator Environmental monitoring In excess of 21,000 Authority

NR = No Response received

3.3.5 TiO2 Directives Reporting Costs Three responses indicated that the preparation of centralised reports took about 1 week per year. However, additional regional reporting costs equivalent to 5,000/plant were reported by one Member State.

3.3.6 Costs for Emissions Control Only 2 Member States responded with any information on the costs for emissions control, though this was far from complete. Most usefully, one regulator stated that for one plant, reduction of sulphate (from current level) to 550kg/t TiO2 would cost in the region of 735,000 capital plus an additional 15/te operating cost.

3.3.7 Issues from Removal of TiO2 Directives The environmental authorities in Member States considered that removal of the TiO2 Directives would not lead to environmental harm. This was partly a result of the fact that the plant concerned are covered in any case by the IPPC Directive, and that the BAT-AELs indicate tighter emission limits than the Directive.

However, it was recognised that the Titanium Dioxide directives specify particular requirements that might not be covered by IPPC e.g. monitoring of receiving environments. Concern was expressed, for example, over groundwater monitoring. To maintain continuity of these controls, one regulator saw benefit in transcribing appropriate monitoring requirements into a TiO2 Technical Annex in a revised IPPC Directive. It was also said that such monitoring would be useful in confirming the effectiveness of IPPC in protecting the environment.



4 Emission Scenario Analysis of Social, Economic and Environmental Impacts

4.1 Impacts Associated with the Sector 4.1.1 Environmental and Health Impacts Impacts on environment and health are considered together, as many of the pollutants with which this assessment is concerned are capable, at sufficient concentration, of having effects on both. This section provides a summary with more detail being given in Appendix 4.

Titanium Dioxide is considered sufficiently non-toxic that it is used in products including some foods and toothpaste, as well as plastics and paints. Indeed, it has largely replaced the use of white lead in paints, and hence, as a product, has had a significant benefit to health. Evidence for health effects of TiO2 dust in air have been reviewed by the National Institute of Occupational Safety and Health (NIOSH) in the US7. The review concluded that TiO2 poses a negligible risk of lung cancer through workplace exposures. The review, did, however, also find that TiO2 was capable of causing inflammation of the lung, and of causing cancer in rats when exposure levels were high. Effects appear to be unrelated to the chemical nature of TiO2. Given that this establishes that TiO2 particles can affect health, and given the sub-micron size of TiO2 particles it seems appropriate to treat TiO2 as falling in the PM2.5 fraction. Health impacts of non-specific PM2.5 have been reviewed by WHO for the ECs Clean Air For Europe (CAFE) Programme. Whilst WHO did not identify specific causes of death linked to fine particle exposure they did recommend quantification of various impacts, including mortality.

CAFE also considered it appropriate to treat sulphate aerosols generated in the atmosphere following emissions of SO2 as PM2.5 for the purposes of health impact assessment. SO2 emission also has significant effects on ecosystems in acid-sensitive areas, particularly in NW Europe.

Chlorine is well known as a poisonous gas. However, its use for the chloride process for TiO2 manufacture is controlled through the Seveso II Directive. Automatic monitoring for chlorine, with shut down should significant levels of the gas be detected, is now a standard part of process control at chloride process plants.

Pollutants in liquid effluents, such as chlorides, HCl, iron compounds, sulphate and suspended solids are mainly a risk factor for the health of aquatic organisms. Effects will differ significantly with the type and quality of the receiving environment, with risks much higher for freshwaters than marine or systems. Acidity (when input at sufficiently high levels) can interact with other pollutants, for example increasing the solubility of harmful metals

Various carcinogenic elements are also present in liquid effluents from TiO2 plant (e.g. arsenic, lead, nickel). However, to damage health with any degree of certainty, these pollutants need to enter a pathway where human exposure will occur, at a sufficiently high concentration.

4.1.2 Social Impacts The main social impacts of the sector are likely to be through the effects of pollutant emissions on health (covered above under environmental impacts) and on employment (covered below under economic impacts).

4.1.3 Economic Impacts The economic impacts of the sector, and hence of any changes to its regulation that have an economic impact, exist at various scales, ranging from the local economy (e.g. employment effects and the competitiveness of specific installations) to the competitiveness of the national and European economies.

7 http://0-www.cdc.gov.mill1.sjlibrary.org/niosh/review/public/TIo2/pdfs/TIO2Draft.pdf



4.2 Scenario Development Specification of required levels of emission controls needs to account for several factors: Protection of health and the environment, accounting for the nature of the receiving media. Composition of input materials, noting in particular variability between TiO2 ores Process characteristics (e.g. whether the chloride or sulphate process is used) Cost of improvement Time scales for emission control, accounting for costs and damage done to the environment

A strength of the IPPC process is that it is sufficiently flexible to take such factors into account. This flexibility can, however, also be a weakness, as it is difficult to define what exactly constitutes Best Available Techniques at any site.

The specification for this contract stated that the following scenarios should be considered: Scenario 1: Directive 92/112/EEC (S1) Scenario 2: Upper limits8 for emissions for TiO2 production according to the LVIC-S BREF (S2) Scenario 3: Lower limits8 for emissions for TiO2 production according to the LVIC-S BREF (S3) Scenario 4: An otherwise undefined position between S1 and S2 (S4) Scenario 5: The likely position following implementation of the IPPC Directive for the sector (S5)

Emission limits for the first three scenarios are shown in Table 4-1. It is assumed that all plant already meet the limit values of the TiO2 Directives. As well as being a legal requirement this is also a requirement of membership of the TDMA (all producers in the EU are members of the association). Any costs incurred to meet the TiO2 directive limits are not relevant here as they are a function of previous legislation.

The baseline emission scenario for this analysis is based on the latest set of emissions data provided to the European Commission by Peter Thompson, on behalf of the TDMA. This is based on the information that was used in the development of the section of the LVIC-S BREF that deals with TiO2 manufacture, supplemented with additional information to fill in some of the gaps in that dataset. Much of the data therefore dates back to 19999. It is also anonymised so that emissions data cannot be linked to specific plant, preventing integration of more recent information that has been obtained for a small number of cases. The fact that the analysis is based on rather old information may not be too problematic for the results, as it post-dates the most recent Directive by 7 years. It is therefore quite possible that plant will have been adapted to meet the requirements of the Directive before 1999, and in most cases may not have been altered since, given the lack of further legislative pressure specific to the sector as a whole10.

Consideration was given to applying two versions of Scenario 1. One version would be based on available emissions data, representing business as usual. With all plant meeting the Directive limits, costs and benefits for this scenario are both zero. The second version would take the view that emissions at all plant could increase up to the limits specified in the 1992 Directive. However, this is not realistic and so was not applied in the analysis. Scenario 1 was therefore based on current emissions, which reflect not just the limit values specified in the Directive but also the concerns of local regulators. A similar logic has been applied to the other scenarios also, with performance of plant that currently meet the limit values assumed to remain constant rather than increase up to the emission limit value. Scenarios 2 and 3 are based on the upper and lower BAT-AELs from the BREF. It is assumed that these scenarios only affect those plant whose emissions for any pollutant are not already at or below the appropriate BAT-AEL.

Scenario 4 takes limit values based on the plant with highest emissions that meet the limit values of the Directive. This is very similar to scenario 1, but would avoid the potential for the highest emitting plant in the future producing more pollution than they currently do.

8 BAT upper limit = the upper end of the range specified for emissions from the TiO2 industry in the LVIC-S BREF (least restrictive case). BAT

lower limit = the lower end of the range specified for emissions from the TiO2 industry in the LVIC-S BREF (most restrictive case). 9 The TDMA is collecting more up to date information in response to the questionnaire sent to operators in August 2007. However, no new

information had been received by the deadline required for this report. 10

As noted elsewhere in this report, emissions data for 2006 for all plant was supplied by the TDMA at the end of the contract (see Appendix 5), too late for full inclusion in the analysis presented here.



Table 4-1. Emission limit values from Directive 92/112/EEC and the BREF

Emission Directive

92/112/EEC 1 BAT upper limit 1 BAT lower limit 1 Sulphate process

Weak Acid / neutralised waste 800 kg tot SO4 /

t TiO2 SO4 total to water 550 kg / t TiO2 100 kg / t TiO2 Suspended solids to water 40 kg / t TiO2 1 kg / t TiO2 Iron compounds to water 125 kg / t TiO2 0.3 kg / t TiO2 Mercury to water 1.5 g / t TiO2 0.32 mg / t TiO2 Cadmium to water 2 g / t TiO2 1 mg / t TiO2 V, Zn, Cr, Pb, Ni, Cu, As, Ti, Mn No techniques identified - lack of data Dust to air, major sources 50 mg/Nm3 Dust to air, other sources 150 mg/Nm3 Dust to air, total 0.45 kg / t TiO2 0.004 kg / t TiO2 Dust to air, emission rate 20 mg / Nm3



Emission limit values for each scenario are summarised for the pollutants of most concern in Table 4-2. In all cases the Scenario 4 limits are close to the existing Directive limits, and the Scenario 5 limits are roughly midway between the upper and lower BAT-AELs.

Table 4-2. Emission limit values for each scenario

Scenario 1 Scenario 2 Scenario 3 Scenario 4 Scenario 5 Sulphate process Dust to air 50 mg/m3 0.45 kg/t TiO2

20 mg/m3 0.004 kg/t TiO2

5 mg/m3 0.7 kg/t TiO2 0.25 kg/t TiO2

SO2 to air 10 kg/t TiO2 6 kg/t TiO2 1 kg/t TiO2 9 kg/t TiO2 4 kg/t TiO2 SO4 to water 800 kg/t TiO2 550 kg/t TiO2 100 kg/t TiO2 785 kg/t TiO2 300 kg/t TiO2 Chloride process Dust to air 50 mg/m3 0.2 kg/t TiO2 0.1 kg/t TiO2 0.4 kg/t TiO2 0.15 kg/t TiO2 SO2 to air Not given 1.7 kg/t TiO2 1.3 kg/t TiO2 No data No data Cl2 to air 5 mg/m3 (daily)

40 mg/m3 (instant) Not given Not given No data No data

Cl to water 130-450 kg/t TiO2 330 kg/t TiO2 38 kg/t TiO2 330 kg/t TiO2 150 kg/t TiO2

Questions arise as to whether emission limits are best described in terms of: Emission rates per unit of flow (mg/Nm3) or per unit of production (kg/t product), and if the latter Against production of pure TiO2 or TiO2 pigment. These are addressed in the analysis that follows.

4.3 Analysis This section describes the costs and benefits for the sector of moving to different possible emission limit values. It proceeds through the following stages: Definition of boundaries for quantification of emissions and consideration of abatement

technologies. Quantification of emissions and a preliminary assessment of performance against the scenario

emission limit values. Quantification of the costs of damage caused by pollutants emitted from the sector. For those

pollutants of main interest these costs can be quantified for SO2 and dust only. Identification of pollution abatement techniques and associated costs. Comparison of the costs and benefits of meeting scenario emission limit values. Discussion of uncertainties in the results. Consideration of trends since the late 1990s in other pollutants emitted by the sector.

4.3.1 Boundaries The operational boundary considered for the impacts of the sector relevant to this analysis is restricted to operations at the European TiO2 manufacturing plant, in line with the boundary set under the TiO2 Directives. It therefore excludes impacts from ore extraction, manufacture of certain reagents and additives manufactured off-site, transport and use of materials.

Geographical boundaries are set to the EU level, in terms of the plants considered and the effects of air pollutants. Effects of liquid effluents and solid wastes are considered at a local to regional level, depending on the specific pollutant concerned.

The temporal boundary for environmental impacts is set to the period over which the emissions (for pollutants for which ELVs exist under the Directives) from one years operation by the sector will be active in the environment and on health. 4.3.2 Emissions data Emissions data for individual plant (referred to by number rather than name) are presented in Appendix 5 to the extent that they are available.11 It is not clear whether the data are reported as pure

11 Appendix 5 contains the original dataset supplied by TDMA to the European Commission prior to the start of this contract, on which analysis in

this chapter is based. It also includes more up to date information (specific to 2006 and referred to as the new dataset), though this was received too late to be included in the main assessment.



TiO2 or TiO2 pigment, or whether this is reported consistently between locations. Recognition of this is given in sensitivity analysis in the CBA that follows.

A broad indication of performance against the ELVs of each scenario is given in Table 4-3. Most appear to have met the requirements not just of the TiO2 Directives but also the upper end of the BAT AELs (as shown by the figures S2 upper BAT-AEL, S3 lower BAT-AEL and S5 intermediate position between the AELs, in the table). In these cases there will be no costs or benefits of meeting the upper BREF limits.

Table 4-3. Scenario targets met by each plant, based on the BREF data, supplemented with additional information supplied by TDMA. It is assumed that the emissions data available for the analysis that follows are directly comparable with emission limit values (i.e. that both are expressed as kg/t TiO2, or kg/t TiO2 pigment).

Plant1 Dust SO2 Sulphate Cl2 3 Chloride Sulphate process

1 S2 2 S5 S4 2 S2 S5 S5 3 S4 S4 S3 4 S4 S4 S5 5 S3 S2 S5 6 S5 S3 S5 7 S5 S5 S5 8 S5 S5 S5 9 S5 X S5 10 S5 S5 S5 11 S5 S3 S3 12 S2+? S4 S4 13 S2+? S4 S5

Chloride process 1 S2 ? S3 2 S3 ? S5 3 S4 ? S5 4 S5 ? ? 5 S3 ? S2

Notes: 1) These data were not available with the specific plant identified, other than by number. 2) The numbers in the table show which scenarios emissions used for the development of the BREF agree with. Hence S1 means that a plant meets the limit values set for Scenario 1 (the baseline as specified in the TiO2 Directives), whilst S2 or S3 correspond to the limit values under scenarios 2 and 3 respectively. X signifies that a plant did not meet the requirements of the baseline. ? means that data were either absent or unavailable in a form that permitted direct comparison with the scenario limits. 3) Data supplied for chlorine emissions were not given in the same format as the Directive limit. The BREF does not give limit values for chlorine.

4.3.3 Monetised damage factors for pollutant emissions Figures presented in the BREF on Economics and Cross Media Effects12 give monetary values for national average damage linked to emissions to air of SO2 and fine particles (PM2.5), accounting for trans-boundary impacts. The methods of calculation were subject to extensive debate and independent peer review under the ECs CAFE Programme13. Accounting for different methodological assumptions, chiefly linked to the approach for quantifying and monetising mortality effects gives roughly a factor 3 range in unit damage costs. Damage factors for dust and SO2 from chloride and sulphate process plant (averaged across the countries that contain chloride or sulphate plant) are shown in Table 4-4. Further information on the calculation of the averaged damage factors is given in Appendix 4.14

12

http://www.jrc.es/pub/english.cgi/d1254319/18%20Reference%20Document%20on%20Economic%20and%20Cross%20Media%20Effects%20%28adopted%20July%202006%29%20-%201.8%20Mb 13

http://cafe-cba.aeat.com/html/reports.htm 14

The BREF provides country specific damage factors. However, the emissions data supplied for this contract were anonymised, and so it is not possible to apply country-specific data to them.



Table 4-4. Averaged damage factors for estimating the costs of PM2.5 and SO2 emissions from chloride and sulphate plant on health

Process Pollutant /t low /t high Chloride plant PM2.5 1 46,000 134,000 Sulphate plant PM2.5 1 35,500 104,000 SO2 7,500 21,700 Note 1) The difference in the damage factors for dust between chloride and sulphate process plant arises because analysis accounts for variation in location. Higher damages are quantified for countries towards the centre of Europe than for those at the fringes because of differences in the extent to which people will be exposed.

The BREF on Economics and Cross Media Effects takes the position followed in the CAFE Programme and does not assign preference to any point in the range of PM2.5 damage costs. The authors of this report have a preference for the lower end of the range for the following reasons: A belief that mortality associated with air pollution exposure should be quantified against loss of life

expectancy and valued in terms of the value of a lost life year rather than deaths valued in terms of the value of statistical life, partly because it is unlikely that deaths from exposure to particles generally (rather than, e.g. known carcinogens) could ever be ascribed to air pollution from a specific source within the current regulatory framework.

The coastal location of many of the plant will limit particle impacts to some degree. The effect of this is, however, more limited than may at first sight appear to be the case as a result of the extended distances over which particles and SO2 are carried on the air, and the no-threshold position recommended by WHO and expert groups elsewhere.

Whilst our own preference is for the lower end of the range, we recognise that others have a different view, and so include here the full range given from the data in the BREF on Economics and Cross Media Effects.

The LVIC-S BREF provides average figures for emissions of SO2 and dust from each stage of production of TiO2 for chloride and sulphate process plant. These emissions data can be combined with the damage/tonne estimates from Table 4-4 to estimate total damage attributable to emissions of the two pollutants from TiO2 manufacture

Table 4-5. Total dust and SO2 related damage from European TiO2 manufacture.

Process Pollutant Average emission Total emission Lower bound damage

Upper bound damage

Chloride PM2.5 0.159 kg/t TiO2 120 t/year 5.5 M/year 16 M/year Sulphate PM2.5 0.28 kg/t TiO2 289 t/year 10 M/year 30 M/year Sulphate SO2 4.97 kg/t TiO2 5,130 t/year 38M/year 111 M/year

It is clear for dust and for SO2 that emissions from TiO2 plant cause an appreciable level of damage (in total estimated at between 54 and 157 million/year), and so it is reasonable to consider whether further emission reductions should be sought.

Monetised damage factors are not available for any of the other pollutants of principal interest to this report. However, it should be noted that the impact of the discharge of (e.g.) sulphate or chloride rich waste water depends not only on the discharge rate and concentration, but also on the characteristics of the receiving water with respect to factors such as: Flow rate in the receiving environment Nature and state of the receiving environment Use of waters in the receiving environment It may therefore be appropriate to vary the level of control according to the site of emission and the likely harm caused to the environment for aquatic discharges.

4.3.4 Costs of pollution abatement measures for the sector The estimated costs of abating emissions of dust, SO2 and chlorine to air and sulphate and chloride to water are presented in Table 4-6. A more complete discussion of the derivation of the data in the table is provided in Appendix 6.

Table 4-6. Techniques and annualised costs for various pollutant abatement techniques.

Pollutant Process Technique 1 Annualised 1

Performance Source of data



cost/plant 1 Dust Chloride Fabric filter 483k/year 2 See note 3 USEPA Sulphate Fabric filter 412k/year 2 See note 3 USEPA SO2 Sulphate Standard catalyst 0.8M/year 8 kg/t TiO2 LVIC-S BREF Sulphate High performance catalyst 1.6M/year 2 kg/t TiO2 LVIC-S BREF Sulphate Scrubber 1.7M/year 1 kg/t TiO2 LVIC-S BREF Chlorine Chloride No data - - - Sulphate Sulphate Not specified, presumed

upgrade 4 1.1M/year 550 kg/t TiO2 UK Environment

Agency Chloride Chloride No data - - - Notes: 1) The costs cited for dust and SO2 control are for new facilities. The costs for sulphate control are considered to be for plant upgrade. 2) The cost difference reflects variation in the average size of chloride and sulphate process plants. 3) The potential performance of dust abatement equipment at TiO2 plant is open to question. Fabric filters in other applications routinely attain



For SO2, however, a series of abatement measures (standard catalyst, high performance catalyst and scrubbers) were given in Table 3.53 of the LVIC-S BREF (reproduced in this report as Table A6.2 in Appendix 6). The BREF specifies different levels of abatement for each of these measures. For SO2 it is therefore assumed that where these technologies are fitted the plant concerned would operate to the levels defined in the BREF. However, it is assumed that only emissions of SO2 from the calcination stage are treated, where necessary, as this is the stage that emits most SO2 and for which the LVIC-S BREF states that the cost-effectiveness data reported therein apply.

The costs of further abatement of emissions are quantified by application of the data provided in Section 4.3.4 for each pollutant.

The benefits of emission controls are quantified for dust and SO2 abatement by multiplying emission reductions by the damage per tonne data provided in Section 4.3.3. This is applied for dust and SO2 only as unit damage costs are not available for other pollutants.

Uncertainties

Scenario emission limit values were defined in Table 4-2. Those specified in the Directive are given as emissions per unit TiO2 production, whereas limit values from the BREF are defined per unit TiO2 pigment production. Turning to emissions, the discussion in Section 4.3.2 noted uncertainty as to whether reported data per unit of production are expressed: per unit of pure TiO2, per unit of TiO2 pigment, or a mix of the two, varying from plant to plant.

Taking a pragmatic approach to these issues, this report investigates the balance of costs and benefits under all possible combinations, with numerical values for ELVs in each scenario held constant whether or not they are expressed per unit pure TiO2 or per unit TiO2 pigment:

1. Emissions per unit pure TiO2, ELVs per unit pure TiO2. So far as results are concerned this of course gives the same result as when both emissions and ELVs are expressed per unit TiO2 pigment.

2. Emissions per unit pure TiO2, ELVs per unit TiO2 pigment. 3. Emissions per unit TiO2 pigment, ELVs per unit pure TiO2.

From an industry perspective, option [2] gives the most optimistic result in terms of the number of plant exceeding possible limit values and option [3] the most pessimistic.

Further uncertainties are as follows: f) Changes in emissions as a result of significant changes to plant or process since the

data provided were originally collected. Whilst some of the data are recent, others are older and changes may have occurred in the intervening years. However, the fact that the TiO2 Directives were last revised in 1992 suggests that there may have been little drive more recently to reduce emissions below levels achieved in the early 1990s, with the result that the figures provided are reasonably reliable for current use.

g) Changes in emissions through switching to alternative sources of ore and to different fuels. These could push emissions either up or down.

h) Uncertainties in the benefits of reducing emissions. These are addressed using ranges taken from the BREF on Economics and Cross Media Effects (see Section 4.3.3). There will also be uncertainty resulting from the fact that the figures taken are national average damages per tonne emission, rather than figures specific to the location and dispersion parameters of individual TiO2 plant. However, assessment of variation in damage per tonne figures between neighbouring countries suggests that associated uncertainty is relatively small for SO2, largely because health damage associated with SO2 emissions is quantified via exposure to one of its reaction products in the atmosphere, sulphate aerosol. The time taken for aerosol formation to take place reduces the dependence of damage on the exact location of a plant. There is greater potential for uncertainty in damages associated with PM emissions, though it should be noted that these total only about half of the damage associated with releases of SO2 (Table 4-5). The fact that results are generated for groups of plant, rather than individual facilities, means that location-specific errors should to some extent cancel out.



i) Uncertainties in the extent to which emissions can be reduced. This problem has been identified elsewhere in this report, particularly with respect to the abatement of dust emissions, where industry sources have said that there are (unspecified) problems for achieving similar levels of abatement using bag filters to those seen in other sectors. Given a lack of evidence for this view, however, it is simply raised here as a possible problem.

j) Uncertainties in the costs of reducing emissions. This uncertainty, like several others, could go either way. If for example, it is possible to upgrade dust controls rather than replace them with new equipment, costs could be overestimated. Some options not considered in this report, such as changing raw materials, may also provide the required improvement but at lower cost. However, if it is necessary to significantly alter the layout of a plant to allow incorporation of new emission control equipment the costs given here may be underestimated.

k) Uncertainties in the response of industry to a tightening of emission levels. Companies could decide to act differently, e.g. close plant rather than upgrade them. This is discussed below in Section 4.4.

Overall, no evidence has been made available under the contract that demonstrates that the analysis presented below has a significant bias in any direction. At the same time, information that would allow more detailed analysis of the effects of some of these uncertainties (a, b, d, e) on the cost-benefit analysis is not available. With this in mind it is recommended that most attention be given to the case where it is assumed that emissions data available for the analysis are expressed per unit TiO2 pigment and ELVs are expressed per unit pure TiO2, irrespective of the way that a future directive might express ELVs. This is the most pessimistic case of the three listed above so far as possible exceedance of limit values and hence additional costs of abatement are concerned. As the most pessimistic case, it is also the one that could demonstrate the most robust ratio

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