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C.1 Infomation on current German legislation relevant to ferrous metals processing activities

C.1.1 German regulations concerning air quality

The basic law for air pollution control and noise abatement in Germany is the Federal Immission Control Act (Bundes-Immissionsschutzgesetz, BImSchG). It primarily aims towards the protection of the medium air, but it also applies to the media water and land in case pollution is introduced via the air. The BImSchG is complemented by 21 ordinances and the Technical Instructions on Air Quality (TA Luft). Especially the TA Luft specifies in more detail requirements to be met by installations subject to licensing. The next sections present important acts and ordinances of German air pollution prevention in more detail.

C.1.1.1 Federal Immission Control Act (Bundes-Immissionsschutzgesetz, BImSchG) The BImSchG is the legal instrument for monitoring air pollution. Immission as defined within the law comprises air pollutants, and also noise, vibration, light, heat, radiation and associated factors affecting humans as well as animals, plants or other things. This concept already implements the idea of cross-media effects to a certain extent. The BImSchG requires federal authorities to issue ordinances identifying the types of facilities, which are subject to licensing, set licensing requirements for these facilities, and impose emission limit values and technical control requirements for all facilities, whether licensed or not.

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Especially article 5(1)3 BImSchG aims at the avoidance and minimisation of wastes and residues. The paragraph emphasises the cross-media effects of industrial production.

The concept of "state of the art technology" defined in the BImSchG is similar to the one of BAT:

State of the art as used herein shall mean the state of development of advanced processes of facilities or modes of operation which is deemed to indicate the practical suitability of a particular technique for restricting emission levels. When determining the state of the art, special consideration shall be given to comparable processes, facilities or modes of operation that have been successfully proven in practical operation. (Article 3 paragraph 6 BImSchG)

In principle, "state of the art technology" is stated in terms of emission limits set by the licensing authority, the choice of technology to comply with the emission limit levels is left to industry. Necessary precautions against harmful effects on the environment are to be taken in particular by using control measures corresponding to the state of the art. Depending on the mass flow, some substances have to be measured continuously (eg. SOx, NOx, and particulates). Some relevant ordinances as well as selected requirements of the BImSchG are briefly presented in the following.

C.1.1.2 Ordinance on installations subject to licensing (4. BImSchV)

The 4. BImSchV (Ordinance on installations subject to licensing) lists all installations that are subject to licensing under the BImSchG. According to this ordinance (cf. Annex, row 1, N°

3.5 and 3.6) installations for the rolling of metals and for scarfing have to undergo a formal licensing procedure, regardless if they are new installations or substantial alterations to location, nature or operation of existing installations.

C.1.1.3 Technical Instructions on Air Quality (TA Luft)

The Technical Instructions on Air Quality (TA Luft) [1] have been set up as general administrative regulations related to §48 BImSchG [cf. 32]. The TA Luft further specifies the requirements to be met by installations subject to licensing. It prescribes limit values for most air pollutants as well as structural and operational requirements designed to limit diffuse emissions. Specific regulations for ferrous metals processing activities by the TA Luft, directing at the avoidance and minimisation of air pollution, are laid down in N° 3.3.3.6.1 (plants for rolling metals, heating and heat treatment furnaces) in N° 3.3.3.9.1. (galvanising installations), and in N° 3.3.3.10.1 (installation for surface treatment of metalls using HNO3).

Requirements set out are listed in Table 8-2.

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Table C.1-2: Special requirements by TA Luft applying to installations for the rolling of metals, for heating and heat treatment furnaces as well as for galvanising

N° in TA Luft Reference Specification

3.3.3.6.1 (rolling) Reference quantity Emissions values refer to a volume content of oxygen in waste gas of 5 out of 100

3.3.3.6.1 (rolling) Nitrogen oxides *) Emissions of nitrogen monoxide and nitrogen dioxide in the waste gas of plants operating air preheating of 200°C or more must not exceed the mass concentration given in the figure below (Fig. 8-1), given as nitrogen dioxide;

possibilities, to control emissions by fuel engineering and other state of the art measures are to be employed.

3.3.3.6.1 (rolling) Sulphur oxides If burnable gases are used in an interrelated production between an iron and steel works and a coking plant, sulphur oxide emissions may not exceed the emission value according to enclosure 1 to §16, 13th BImSchV.

3.3.3.9.1 (galvanising) Waste gas cleaning Installations for galvanising, using fluxes, are to be equipped with waste gas capturing devices like encapsulation or hoods; waste gases need to be ducted to a waste gas cleaning facility.

3.3.3.9.1 (galvanising) Dust Dustlike emissions in waste gases must not exceed 10mg/m3(STP).

3.3.3.9.1 (galvanising) Chlorine compounds Emissions of gaseous inorganic chlorine compounds in waste gas must not exceed 20mg/m3(STP), given as hydrogen chloride.

3.3.3.9.1 (galvanising) Emission measurements The result of a single measurement is to be determined by several dipping processes; measuring time

corresponds to the sum of single dipping times and shall cover usually ½ hour; dipping time is the period between the 1st and the last contact of the galvanised piece with the galvanising bath.

200 300 400 500 600 700

Air peheating in °C

Mass concentration of NO and NO2(stated as NO2)

Figure C.1-1: NOx emission limits TA Luft

*): The German Länderausschuß für Immissionsschutz (LAI) agreed on the 6th and 8th Mai of 1991 in Bayreuth to put in concrete terms the making dynamic of the TA Luft for heating and heat treatment furnaces and settled the following emission values for NOx: new plants - 500mg/m3

existing plants with combustion air preheating

- up to 450°C: 500mg/m3 - over 450°C: target value 500mg/m3

In case of using coke oven gas:

- investigation of the individual case with a target value of 500mg/m3

Since the TA Luft was enacted in 1986, local authorities sometimes demand stricter emission limit values.

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C.1.1.4 Technical Instruction on Noise Abatement (TA Lärm)

The Technical Instruction on Noise Abatement (TA Lärm) [5] sets limits for noise emissions by the operation of a facility, specified for various areas. The construction, operation or altering of a facility is granted only if the emission limits allowed for a specific area are not exceeded and if state-of-the-art noise protection measures are employed.