Council Directive 9661 concerning integrated pollution prevention and control IPPC Don Litten, Envir

1
Council Directive 96/61 concerning integrated
pollution prevention and control (IPPC)Don
Litten, Environment Strategy Adviser
(SIET)Institute for Prospective Technological
Studies (IPTS) Seville, Spain
2
Invited expert to IPPC training workshop in
Vilnius,31 May 1 June 2006.Duncan Mitchell
3
Disclaimer

• Nothing presented or discussed during this
  workshop constitutes an opinion of the European
  Commission. It is for the courts of law to
  ultimately interpret legislation.

4
General Introduction
5
European Commission
Directorate GeneralEnvironment
Directorate GeneralEnterprise
Directorates General TREN, SANCO, AGRI RELEX,
Research, etc
Directorate GeneralJoint Research Centre
IES, IPSC, IHCP IRMM, IE, ITU
IPTS Institute for Prospective Technological
Studies
6
European Council Directive 96/61/EC
of 24 September 1996 concerning integrated
pollution prevention and control (IPPC)

• a framework directive aiming at a high level of
  protection for the environment as a whole - all
  environmental media
• operating permits for industry with conditions to
  be based on best available techniques (BAT) -
  NB also to meet EQS
• provides for an exchange of information on BAT -
  Article 16(2)

7
European Council Directive 96/61/EC
of 24 September 1996 concerning integrated
pollution prevention and control (IPPC)

• As amended by
• Directive 2003/35 (dealing with public
  participation and access to information adding
  that operator includes in application what
  alternatives have been considered)
• Directive 2003/87 (specifying that IPPC permit
  shall not include emission limit values for
  greenhouse gases specified in emission trading
  scheme)
• Regulation 1882/2003 (changing detail of
  committee procedure)

8
IPPC and environmental responsibility

• Whereas, in order to tackle pollution problems
  more effectively and efficiently, environmental
  aspects should be taken into consideration by the
  operator whereas those aspects should be
  communicated to the competent authority or
  authorities so that they can satisfy themselves,
  before granting a permit, that all appropriate
  preventive or pollution-control measures have
  been laid down .

9
IPPC Implementation

• Member States expected to have their own
  environmental priorities and policies.
• First step in IPPC implementation is
  transposition to national law.
• Next step is for operator to make application for
  permit.
• Finally, authority determines appropriate permit
  conditions.

10
IPPC Implementation

• National law transposing Directive may go further
  than Directive in terms of scope of application
  to industry.
• Member States observed to be phasing in sectors
  in advance of 2007 deadline.
• Some cause for concern over number of
  installations yet to be permitted in 2006/7.
• All BREFs well advanced by end 2005.

11
Obligations of the operator

• Refer to national law transposing IPPC Directive
• Application to competent authority for permit
  must contain
• a description of the installation
• materials and energy used and generated
• sources and nature of foreseeable emissions
• proposed technology and techniques for preventing
  or reducing emissions
• and .

12
Obligations of the operator

• measures planned to prevent or recover wastes
  generated
• description of the main alternatives (if any)
  studied by the applicant
• measures planned to monitor emissions
• amongst other things.
• a non-technical summary

13
Obligations of the operator

• Operation so that waste is
• avoided
• recovered
• disposed of while avoiding or reducing impact on
  environment
• On cessation of activities
• measures to avoid pollution risk
• site is returned to satisfactory state

14
(No Transcript)
15
Boundaries of Installations
16
Boundaries of Installations

• Article 2(3)
• installation shall mean a stationary technical
  unit where one or more activities listed in Annex
  I are carried out, and any other directly
  associated activities which have a technical
  connection with the activities carried out on
  that site and which could have an effect on
  emissions and pollution

17
Boundaries of Installations

• In Article 2(3), what is meant by directly
  associated activities which have a technical
  connection with the activities carried out on
  that site?

18
Boundaries of Installations

• To be a directly associated activity it is
  expected that somehow there is an influence or
  dependence on the way in which Annex I activity
  is carried out in.
• A directly associated activity would probably not
  take place at that particular location if the
  Annex I activity were not there.

19
Boundaries of Installations

• Consider an example of cold rolling or drawing at
  an iron or aluminium works, where offcuts from
  the rolling or drawing are recycled to the
  melting process and may carry with them oils used
  in the rolling or drawing process.
• The cold rolling or drawing is not in itself an
  Annex I activity.

20
Boundaries of Installations

• When both activities are considered in an
  integrated manner, the better environmental
  option may be to have a melting furnace designed
  to accept this contamination from the offcuts,
  whereas if the melting process was considered
  separately it may be better to insist on
  uncontaminated input.
• Similarly, considering the downstream process
  together with the melting and casting activity
  may offer better overall energy efficiency
  through less reheating as a result of integrated
  management.

21
Boundaries of Installations

• UK Case Law 13/01/2006
• United Utilities Water Plc
• and
• The Environment Agency for England and Wales
• . waste water treatment plants chosen as test
  cases designed to determine the main issues of
  principle .

22
Boundaries of Installations

• I come to the unsatisfactory conclusion that the
  wording of 'directly associated activity' and
  'installation are so obscure that it is not
  possible for me to provide any clear
  interpretation of them on the information before
  me.
• Appeal in progress! BUT

23
Boundaries of Installations

• Some conclusions seem to be clear
• Sewage sludge is waste (in liquid form or in cake
  form). Wastewaters as such are not.
• Wastewater treatment is covered by IPPC if it is
  directly associated to and on the same site as a
  core IPPC industrial activity. Generically,
  sewage / wastewater treatment is not an IPPC
  activity.

24
Boundaries of Installations

• From which
• Treatment of (process) wastewaters from a core
  IPPC activity on the same site is part of the
  installation.
• Treatment of (process) wastewaters from a core
  IPPC activity on a different site (for example in
  a municipal / urban wastewater treatment plant,
  is not part of the installation. (see also
  direct and indirect emissions to water)

25
Boundaries of Installations

• Other infrastructural parts of installation
  could include
• Receipt, handling and storage of raw materials,
  intermediates and products
• On-site production of steam, heat or electricity
• On-site treatment of process waste streams
  (examples ash from incinerators residue
  treatment prior to recycling of material, water
  or solvent)

26
Boundaries of Installations

• Generally accepted
• A site or installation can be crossed by a road,
  river, canal etc (different land owner).
• Some MS issue permits only to one operator, one
  installation, in other cases permits are issued
  to parts of installations or multiple operators.
• Directive does provide flexibility for MS.

27
(No Transcript)
28
Understanding the text of Annex 1 to the IPPC
Directive

• Guidance on some of these issues is under
  development and is not yet finalised.

29
Annex 1 to IPPC Directive

• Wide range of industrial activities listed.
• Energy industries - LCP, refineries
• Production and processing of metals
• Mineral industries - cement, lime, glass,
  ceramics
• Production of chemicals production on an
  industrial scale of basic chemicals
• Waste management industries incineration and
  some recovery or disposal operations
• Others

30
Examples from Annex 1 to IPPC Directive

• Coke ovens
• Metal ore roasting or sintering
• Production of pig iron or steel incl. continuous
  casting, with capacity gt 2.5 tph
• Processing of ferrous metals
• hot-rolling mills with a capacity exceeding 20
  tph of crude steel
• application of protective fused metal coats with
  an input exceeding 2 tph of crude steel
• Ferrous metal foundries with a production
  capacity exceeding 20 tpd

31
Examples from Annex 1 to IPPC Directive

• Production of non-ferrous crude metals from ore,
  concentrates or secondary raw materials by
  metallurgical, chemical or electrolytic processes
• Smelting, including the alloyage, of non-ferrous
  metals, including recovered products, (refining,
  foundry casting, etc.) with a melting capacity
  exceeding 4 tpd for lead and cadmium or 20 tpd
  for all other metals
• Surface treatment of metals and plastic materials
  using an electrolytic or chemical process where
  the volume of the treatment vats exceeds 30 m3

32
Annex 1 to IPPC Directive

• Other industries
• Pulp and paper
• Textile processing
• Tanning of hides and skins
• Intensive farming of pigs and poultry
• Slaughterhouses animal by product processing
• Food drink and milk processing
• Surface treatment using solvents

33
Annex 1 to IPPC Directive

• Should the introductory paragraph 1 of Annex I be
  understood to be restricted to installations or
  parts of installations solely used for research,
  development or testing?
• 1. Installations or parts of installations used
  for research, development and testing of new
  products and processes are not covered by this
  Directive.

34
Annex 1 to IPPC Directive

• It seems highly unlikely that the intention could
  have been to exclude from the scope of the
  Directive installations or parts of installations
  normally used for industrial production simply
  because they are occasionally used for research,
  development or testing.

35
Annex 1 to IPPC Directive

• Add-up rule of Annex I
• Note There is an identical provision in Annex I
  to Directive 2003/87/EC establishing a scheme for
  greenhouse gas emission allowance trading within
  the Community.
• 2. The threshold values given below generally
  refer to production capacities or outputs. Where
  one operator carries out several activities
  falling under the same subheading in the same
  installation or on the same site, the capacities
  of such activities are added together.

36
Annex 1 to IPPC Directive

• There are a few examples in Annex I where the
  word capacity is not used but an analogous
  expression is used for a technical capacity of
  the activity, for example
• 2.6. Installations for surface treatment of
  metals and plastic materials using an
  electrolytic or chemical process where the volume
  of the treatment vats exceeds 30 m³
• 6.6. Installations for the intensive rearing of
  poultry or pigs with more than (a) 40 000 places
  for poultry(b) 2 000 places for production pigs
  (over 30 kg) or(c) 750 places for sows.

37
Annex 1 to IPPC Directive

• In the case of combustion plants, Rated thermal
  input (normally kW or MW) is a specific
  technical expression analogous to capacity.
  These expressions are all considered valid in the
  context of the add-up rule. The word capacity
  does not have to be explicitly mentioned.

38
Annex 1 to IPPC Directive

• In Annex I section 6.2 and elsewhere, does the
  capacity threshold in tonnes per day refer to
  24 hours of continuous operation at rated
  capacity?
• Consumption capacity, produced material or
  similar criteria, expressed for instance as
  tonnes per day, are frequently used in Annex I to
  determine the scope of the IPPC Directive.

39
Annex 1 to IPPC Directive

• In sectors such as textiles and tanneries, most
  installations do not operate continuously for 24
  hours a day. Many smaller units do however
  operate in very close contact with market demand,
  with the result that normal working hours may be
  exceeded at very short notice. Declared working
  practice is therefore an unreliable guide to the
  real capacity of an installation and does not
  reflect the pollution potential of the
  installation.

40
Annex 1 to IPPC Directive

• The coherent meaning of capacity is the maximum
  capacity to which the installation is limited
  technically or legally.
• That is to say, it is the capacity of the
  installation to operate 24 hours a day, provided
  that the equipment is not technically or legally
  restricted from operating in that way.

41
Annex 1 to IPPC Directive

• The necessary time taken to load, unload and
  clean equipment between process batches, for
  example, may technically restrict the number of
  process cycles possible in any 24 hour period and
  thus restrict the daily capacity of the whole
  process.
• Equally, the capacity of one part of a process
  could restrict the throughput of the whole
  process.

42
Annex 1 to IPPC Directive

• However, where the technical capacity of an
  installation exceeds a threshold of an activity
  as defined in Annex I of the IPPC Directive, is
  it possible that the capacity is limited by legal
  means to a capacity below the mentioned threshold
  in Annex I of the Directive so that the
  installation does not come under the scope of the
  Directive?

43
Annex 1 to IPPC Directive

• Conclusion - A legal restriction of capacity can
  exist. It is possible that the actual capacity
  of an installation could be restricted by general
  wide ranging legal provisions or by some specific
  provision applied to the installation itself.

44
Annex 1 to IPPC Directive

• In section 4, what is the meaning of production
  on an industrial scale?
• Section 4 (chemical industry) contains no
  quantitative capacity thresholds but only a
  reference to production on an industrial scale.
  The scale of chemical manufacture can vary from a
  few grams of a highly specialised product to
  many tonnes of a bulk chemical product, yet both
  scales correspond to industrial scale for that
  particular activity.

45
Annex 1 to IPPC Directive

• In section 4,
• If the activity is carried out for commercial
  purposes, it should be considered as production
  on an industrial scale, even if the material is
  an intermediate product and therefore not itself
  traded. By contrast, some activities are
  considered not to be on an industrial scale if
  they could be described more as artisan or
  handicraft (soaps, dyes ...)

46
Annex 1 to IPPC Directive

• Does Annex I section 4.2 include gaseous oxygen?
• Even though oxygen (O2) is not explicitly
  included in the list of gases in 4.2(a), it is
  clearly a basic inorganic chemical. However,
  this list is only indicative since it begins with
  the words gases, such as.
• The production of oxygen using a chemical process
  is therefore covered. However, oxygen is usually
  produced by physically (cryogenically) separating
  it from air. Since section 4 refers to
  production...by chemical processing, such
  physical separation from a mixture of gases seems
  not to be an Annex I activity.

47
Annex 1 to IPPC Directive

• In section 6.4 (b) and (c), does the term raw
  materials apply to materials (such as flour)
  that have already been processed but are used as
  the raw material for the production of a food
  product?
• The term raw materials is normally used to
  refer to any materials, processed or not, used as
  input into the overall industrial process.

48
Annex 1 to IPPC Directive

• How should the term treatment vat in section
  2.6 be understood?
• The thresholds for surface treatment of metals
  and plastics in section 2.6 are expressed as
  volume of the treatment vats. In addition to the
  main process step, vats are typically used for
  processes such as soak clean, pickling, acid dip,
  passivation and rinsing. With the exception of
  rinsing, all these process steps involve an
  alteration of the surface as a result of an
  electrolytic or chemical process, and therefore
  fall under the definition of treatment.

49
Annex 1 to IPPC Directive

• .
• Conversely, non-electrolytic, non-chemical
  surface treatments such as ultrasound, grit
  blasting, water blasting and annealing are not
  considered to fall under this definition.

50
Annex 1 to IPPC Directive

• Section 2.6, continued.
• For the purposes of determining which
  installations are covered in this section, the
  volume of the treatment vats is to be calculated
  as the total volume of vats used for those
  process steps involving alteration of the surface
  as a result of an electrolytic or chemical
  process.
• It should nevertheless be noted that, for those
  installations covered by the Directive, all steps
  including rinsing should be regarded as an
  associated activity within the meaning of
  Article 2(3).

51
Annex 1 to IPPC Directive

• AND .
• food (only human or more ?)
• crude metal
• basic chemicals
• waste, recovery, disposal
• paper and board hides and skins
• treatment and processing

52
(No Transcript)
53
Use of BREFs in settingBAT-based permit
conditions
54
Directive 96/61/EC - Article 16(2) - Exchange of
information

• The Commission shall organise an exchange of
  information between Member States and the
  industries concerned on best available
  techniques, associated monitoring, and
  developments in them. Every three years the
  Commission shall publish the results of the
  exchanges of information.

55
Directive 96/61/EC Annex IV

• 1. the use of low-waste technology
• 2. the use of less hazardous substances
• 3. recovery and recycling ..
• 4. comparable processes ..
• 5. technological advances knowledge
• 6. the nature, effects and volume of the
  emissions concerned

56
Annex IV continued

• 7. commissioning dates for installations
• 8. time to introduce BAT
• 9. consumption of raw materials and energy
  efficiency
• 10. prevent or reduce overall impact of
  emissions on environment and risks to it
• 11. prevent accidents and minimise consequences
  for the environment

57
Annex IV to Directive 96/61/EC

• Considerations to be taken into account generally
  or in specific cases when determining best
  available techniques
• 12. information published by the Commission
  pursuant to Article 16 (2) ...
• results of information exchange BREFs ( BAT
  reference documents )

58
From BREF to Permit conditions

• BREF gives BAT in a general sense determined as
  appropriate for the whole European Sector.
• BREF cannot address every local variation in any
  detail may mention some common issues.
• Art 9(4) requires that local decisions are made
  to determine appropriate permit conditions for
  the specific installation.
• Recital 18 provides that responsibility for those
  local decisions rests with MSs.
• Article 9(8) provides for general binding rules.

59
BAT in BREFs

• It is intended that the general BAT in this
  chapter are a reference point against which to
  judge the current performance of an existing
  installation or to judge a proposal for a new
  installation. In this way they will assist in
  the determination of appropriate "BAT-based"
  conditions for the installation or in the
  establishment of general binding rules under
  Article 9(8).

60
Determination of BAT with TWGs

• Review current performance with respect to key
  relevant environmental issues
• Identify techniques used to achieve the best
  current performances
• Examine economic and technical conditions under
  which the techniques are applicable
• Does the technique fit the definition of BAT?

61
From Article 9(4) - Directive 96/61/EC

• permit conditions must, without prejudice to
  compliance with environmental quality standards,
  be based on the best available techniques,
  without prescribing the use of any technique or
  specific technology, but
• taking into account the technical characteristics
  of the installation concerned
• its geographical location and
• the local environmental conditions.

62
Recital 18 - Directive 96/61/EC

• Whereas it is for the Member States to determine
  how the technical characteristics of the
  installation concerned its geographical location
  and the local environmental conditions can, where
  appropriate, be taken into consideration.

63
From BREF to Permit condition

Descriptive
MS right to choose how
Legally binding
64
From BREF to Permit conditions

• Setting ELVs !
• Variety of approaches in EU.
• 100 compliance.
• 4 samples out of 5 equals compliance.
• Annual or other longer term averages.
• Admissibility of evidence in court.
• Fundamental national legal framework.

65
Examples of actual emission profiles 1,
effluent COD from pulp mill over 30 days
66
Examples of actual emission profiles 2,
effluent COD from pulp mill over 5 months
Arithmeticmean
67
Examples of actual emission profiles 3,
continuous NOx from pulp mill black liquor boiler
over 3 days
68
Examples of actual emission profiles 4, daily
average NOx from pulp mill black liquor boiler
over 5 months
3 day range mg/MJ
69
Implementation

• BAT-based permit conditions may be expected to
  take account of time needed to introduce BAT
  measures.
• Cost of implementing BAT measures is strongly
  influenced by rate of investment.
• Prioritisation of investments can be made
  according to environmental benefits only at local
  level.

70
Conclusion on BAT to ELV (1)

• Environmental objective will not be achieved
  until BAT-based permit conditions are fully
  implemented
• In many cases the worst current performance in EU
  is about 10 times the BAT emission level
• But also, BAT emission level is typically already
  achieved by many installations in the EU
• Time allowed to introduce BAT should not
  introduce unfair competitive advantage

71
Conclusion on BAT to ELV (2)

• Range of current preferences setting ELVs on
  basis of concentration, specific load or absolute
  load per unit time.
• Different approaches often historical and
  difficult (expensive?) to change.
• Difficult to compare performances expressed in
  the different ways not impossible.
• Subject of discussion in reviewing the Directive.

72
(No Transcript)
73
Economic and cross media aspects of BAT
74
IPPC Directive 96/61/EC

• Fundamental text from Directive
• Article 1 a high level of protection of the
  environment taken as a whole
• Article 2 and Annex IV likely costs and
  benefits / advantages (both words used
  synonymously)
• Article 2 allows implementation in the
  relevant industry sector under economically and
  technically viable conditions

75
General BAT assumptions

• BAT is cost effective protection of the
  environment as a whole - so ...
• BAT may result in cost savings but also will
  often be an additional cost economically
  viable?
• BAT is not always expected to have a payback.
• Likely actual costs and benefits may differ
  greatly from site to site.
• Art 9(4) - IPPC permits must be written taking
  account of BAT and local conditions.

76
Economic and Cross Media balances within IPPC

• economically and technically viable in the
  relevant sector Art 2(11)
• implies affordable by (European) sector
• not necessarily economically viable at every
  installation or in every region
• no benchmark foreseen for affordability across
  sectors.

77
BAT at European or local level

• IPPC Directive defines BAT as best for
  environment as a whole, taking account of cost
  and advantages and economically viability in the
  relevant industry sector.
• IPPC Directive makes no provision for a test of
  economic viability at local level. Whilst the
  consideration of the environment as a whole
  (cross-media issues) can logically be valid at
  local level, cost effectiveness and affordability
  at local level is not addressed explicitly by
  Directive.

78
The environment as a whole

• Balance of different environmental effects
• inter-medium
• intra-medium
• local versus long distance
• immediate versus future
• precautionary principle
• need to incorporate political drivers

79
Cross-Media assessment

• Scope and identify alternative options
• Inventory of emissions and raw material
  consumption (including energy)
• Calculate cross-media effects over seven
  environmental themes
• Interpret the results and resolve conflict

80
The seven environmental themes

• For each alternative option under consideration,
  estimate the potential impact in respect of
• Human toxicity
• Global warming
• Aquatic toxicity
• Acidification
• Eutrophication
• Ozone depletion
• Photochemical ozone creation
• Note Abiotic depletion was considered but
  dropped as it was not considered to be critical
  for decision making.

81
Costing methodology

• Scope and identify alternative options
• Gather and validate cost data
• Define cost components investment, operating,
  maintenance, revenues, benefits and avoided costs
• Process and present cost information currency
  exchange, inflation, discount and interest rates,
  all to give a total annual cost
• Attribute costs to environmental protection

82
Evaluate the alternatives

• Cost effectiveness analysis
• Apportion costs between pollutants
• Balance costs and environmental benefits most
  contentious issue !
• Reference prices / indicative benchmarks /
  external costs (contentious issue)

83
Economic viability in the sector

• Industry structure
• Market structure
• Resilience
• Speed of implementation
• Overall - Can a potential increase in costs be
  passed on to suppliers, customers, or absorbed by
  the industry ?

84
Economic and Cross Media balances within IPPC

• bearing in mind the likely costs and benefits of
  a measure Annex IV
• to compare costs of different measures - need to
  compare same cost basket
• need to balance environmental benefits of a
  measure against standard cost
• environmental cost effectiveness of measure -
  benchmark per kg of pollutant not released.

85
Economic and Cross Media balances within IPPC

• to reduce . impact on theenvironment as a
  whole Art 2(11)
• to compare impacts of alternative techniques -
  need to compare same impact basket
• need to decide which alternative offers better
  advantage for whole environment
• some impacts local, others global
• some impacts now, some future.

86
3 original themes to ECM work

• Costing methodology
• Cost effectiveness for some pollutants
• Economic viability in industry sector.

87
Final Draft Economic and Cross-Media Doc

• 9 guidelines across 4 chapters
• Guidelines 1 to 4 on assessing cross-media (whole
  environment) issues
• Guidelines 5 to 9 on costing methodology
• How to evaluate alternative options
• How to assess economic viability in sector

88
Worked example to demonstrate application of
methodologies option 1
Base caseachieving 200 mg/m3 NOx
89
Worked example to demonstrate application of
methodologies option 2
Base case plus SNCRachieving 180 mg/m3 NOx
90
Worked example to demonstrate application of
methodologies option 3
Base case plus SCRachieving 63 mg/m3 NOx
91
Worked example to demonstrate application of
methodologies. The 3 options compared for impact
on the environment as a whole related to European
totals for each environmental theme
92
Conclusions

• No magic formula to determine BAT.
• A number of available tools and methodologies to
  structure decision making, subject to data
  availability on options.
• May only need to use methodologies to resolve
  apparent conflict not needed to determine BAT
  if all is clear.

93
(No Transcript)
94
Monitoring
95
Monitoring

• Why, What, When, Who and How
• Directive requirements.
• Exchange of information on general principles of
  monitoring (BREF).
• Local, Regional, National and International
  monitoring standards.

96
Monitoring

• Article 6
• Applications for permits must include measures
  planned to monitor emissions into the
  environment,
• Article 9(5)
• The permit shall contain suitable release
  monitoring requirements, specifying measurement
  methodology and frequency, evaluation procedure
  and an obligation to supply the competent
  authority with data required for checking
  compliance with the permit.

97
Monitoring

• Article 2(6)
• 6. emission limit values shall mean the mass,
  expressed in terms of certain specific
  parameters, concentration and/or level of an
  emission, which may not be exceeded during one or
  more periods of time. Emission limit values may
  also be laid down for certain groups, families or
  categories of substances

98
Monitoring

• Article 15(2)
• The results of monitoring of releases as required
  under the permit conditions referred to in
  Article 9 and held by the competent authority
  must be made available to the public.

99
Monitoring

• Article 15(3)
• An inventory of the principal emissions and
  sources responsible shall be published every
  three years by the Commission on the basis of the
  data supplied by the Member States. The
  Commission shall establish the format and
  particulars needed for the transmission of
  information in accordance with the procedure laid
  down in Article 19. (Committee procedure)
• Basis for EPER / PRTR

100
Monitoring

• Two aspects of what .
• What is monitoring (also part of why) and
• What to monitor
• Monitoring is not the same as measuring

101
Monitoring

• From the reference document on monitoring
• Monitoring is a systematic surveillance of the
  variations of a certain chemical or physical
  characteristic of an emission, discharge,
  consumption, equivalent parameter or technical
  measure, etc.
• Based on repeated measurements or observations,
  at an appropriate frequency in accordance with
  documented and agreed procedures, and is done to
  provide useful information. Information may
  range from simple visual observations to precise
  numerical data.

102
Monitoring

• From the reference document on monitoring
• Information can be used for several different
  purposes, the main aim being to verify compliance
  with emission limit values but it can also be
  useful for a surveillance of the correct
  operation of the plant processes, as well as for
  allowing better decision-making about industrial
  operations.

103
Monitoring

• From the reference document on monitoring
• measuring involves a set of operations to
  determine the value of a quantity, and therefore
  implies that an individual quantitative result is
  obtained.
• monitoring includes the measurement of the value
  of a particular parameter and also the follow-up
  into variations in its value (so as to allow the
  true value of the parameter to be controlled
  within a required range). Occasionally,
  monitoring may refer to the simple surveillance
  of a parameter without numerical values, i.e.
  without measuring.

104
Monitoring

• Monitoring can be based on
• direct measurements
• surrogate parameters
• mass balances
• other calculations
• emission factors.
• Choosing one of these approaches for monitoring
  involves a balance between the availability of a
  method, reliability, level of confidence, costs
  and the environmental benefits.

105
Monitoring

• Issue to consider
• How accurate do you need the result to be?
• Generally, the more precise the answer, the
  higher cost involved in getting the answer.
• Geographical analogy
• When in the middle of a lake 100 km across, do
  you need to know your position within 1m?
• Probably not, but what if .

106
Monitoring

• What if .
• There are some dangerous rocks somewhere in the
  middle of the lake.
• You are moving at high speed from the middle of
  the lake and you need a long time to slow down or
  alter your course.
• You need to return to the same place in the lake
  at some time in the future.

107
Monitoring

• When you decide how accurate you really need the
  result, then you are better placed to select an
  option which meets your needs.
• Direct measurements can be accurate but tend to
  be most expensive.
• Surrogate measurements often much cheaper and
  they can catch a basket of chemicals.
• Mass balances or other calculations can be more
  accurate than direct measurements.

108
Monitoring

• Issues to consider
• Accuracy may cost more but then the result may
  serve more purposes.
• Real time process control needs rapid feedback of
  monitoring results.
• Knowledge of the process to be monitored is
  fundamental to determine which pollutants could
  be of concern.

109
Monitoring

• Issues to consider when to monitor ?
• General frequency of monitoring
• Once per day once per year every 8 days
• Exact timing of measurements
• Spot measurement 3 repeated measurements each
  time average sample over hours, days or weeks.
  Average over time or a process cycle. Related to
  process activity or random.

110
Monitoring

• Issues to consider when to monitor ?
• In order to decide on monitoring regime, it may
  be useful to characterise the process and
  parameter(s) to be monitored by an initial
  intensive campaign.
• Likelihood of variation in monitored parameter(s)
  should be considered.
• Statistical risk-based approach is possible
  relating to required confidence in result.

111
Monitoring

• Issues to consider - Who monitors ?
• Operator is always on-site and will probably be
  observing process as part of routine day to day
  management. Operator also knows full details of
  process schedules and any problems on site.
• Authority is more independent but is limited to a
  central time window during working day allowing
  for time of travel. External monitoring is less
  random than it might seem at first.
• Does it affect the usefulness of results ?

112
Monitoring

• Issues to consider how to monitor
• Number of sources to monitor.
• Large point sources, multiple sources, fugitives.
• Availability of standard methods.
• Correction to standard conditions.
• Usefulness of results comparability.
• Data management how to deal with results less
  than limit of detection. How to deal with
  outliers in general.

113
Monitoring

• Surrogate parameters
• Can often be much lower cost and quicker to get
  result.
• Not limited to specific chemical but can be more
  effect-based assessment (BOD, COD).
• May be qualitative or quantitative.
• May need to be calibrated for the specific
  process being monitored.
• Often easier and cheaper to carry out continuous
  or on-line measurements for surrogate parameter.
• Examples .

114
Monitoring

• Surrogate parameters - examples
• For a combustion process. Residence time and
  turbulence of gas in combustion chamber is a
  (fixed) function of design. Once the process is
  initially proven at start-up for good combustion
  efficiency, simply measuring temperatures and
  oxygen content at critical points in process
  gives reliable (possibly continuous) indication
  of good combustion conditions.
• Monitoring turbidity of effluent after treatment
  does not quantify suspended solids but gives good
  indication of effective solids removal and
  rapid alarm function if something goes wrong.

115
Monitoring

• Surrogate parameters - examples
• Where a chemical scrubber is installed on an
  exhaust gas, monitoring the conductivity and/or
  pH plus flowrate of the recirculating scrubber
  liquid gives good indication that the scrubber is
  working. Also provides for rapid alarm function
  in case of failure.
• Measuring level of liquid in a tank allows to
  control filling and emptying operation plus also
  provides indication of leaks and alarm to prevent
  overfilling.
• A change in a continuous surrogate measurement
  may trigger a sample of the emission for detailed
  analysis.

116
Monitoring

• Issues to consider data management
• 100 results with 60 numbers and 40 less than
  results (eg 60 numbers ranging from 20 units to
  30 units and 40 results lt20 units)
• Mathematical average of the 60 numbers is
  straightforward but what to do with the 40
  results lt20?
• Express them as 0, somewhere 0 to 20, or 20 ?
• If 59 of the numbers are in range 20 to 30 and
  one result is 75, include or exclude the 75 ?

117
Monitoring

• Issues to consider data management
• Including high outlier may overestimate result.
• Excluding high outlier may underestimate result.
• Express lt20 as 0 will underestimate result.
• Express lt20 as 20 will overestimate result.
• Some compromise approaches are used to allocate a
  number 0ltxlt20 for purposes of data management.
• Different approaches not comparable results.

118
Monitoring

• Example of multiple sources / fugitive losses
• A refinery or petrochemical complex can have
  thousands of pipes, flanges, pumps, valves and
  vents.
• VOCs can be emitted from large numbers of small
  point sources such as vents but also from
  flanges, pumps and valves if they develop a leak.
• Good practice for such a process is to have some
  sort of leak detection and repair program
  LDAR but what in detail ?

119
Monitoring

• Example of multiple sources / fugitive losses
• Manually inspect whole process using sniffers.
• Mass balances and pressure drops are too
  insensitive to detect small leaks.
• Possible to deploy laser scanning equipment
  down-wind and map the VOC concentration back to
  point sources within the refinery or
  petrochemical complex, but available only in
  limited numbers, effective, costly.

120
Monitoring

• Standard methods preference for hierarchy
• Standard methods required by EU Directives
• CEN standards
• Other international standards
• National standards
• Alternative methods on case by case may need to
  be proven and calibrated against some more
  recognised standard.

121
Monitoring

• Conclusions
• Good monitoring practice includes proper design
  of a monitoring regime with objectives.
• Purpose of monitoring is to provide specific
  information useful for specific purpose(s).
• Cost effectiveness improved when one measurement
  is used for many purposes
• Compliance assessment, reporting and process
  control all require different aspects to consider.

122
(No Transcript)
123
Direct and indirect emissions to water
124
Direct and Indirect Emissions to Water

• From Article 2(6)
• The emission limit values for substances shall
  normally apply at the point where the emissions
  leave the installation, any dilution being
  disregarded when determining them.
• With regard to indirect releases into water, the
  effect of a water treatment plant may be taken
  into account when determining the emission limit
  values of the installation involved, provided
  that an equivalent level is guaranteed for the
  protection of the environment as a whole and
  provided this does not lead to higher levels of
  pollution in the environment, without prejudice
  to Directive 76/464/EEC or the Directives
  implementing it

125
Direct and Indirect Emissions to Water

• So .
• Direct discharge to water means discharge from
  the installation to some water body which is part
  of the aquatic environment river, stream,
  groundwater, lake, canal, estuary, sea.
• Indirect discharge means from the installation
  to a sewer or pipe which assumes some further
  treatment or management before discharging to the
  aquatic environment.

126
Direct and Indirect Emissions to Water

• Technically
• Treating degradable industrial wastewater in
  mixture with municipal wastewater may offer a
  higher and more consistent level of treatment
  without the need for flow balancing and
  additional nutrients.
• Mixing wastewaters generally reduces the
  possibilities for recovery and reuse of
  substances dissolved or suspended in the
  wastewater.
• Metals are 100 conservative and their fate eg
  via wastewater sludge treatment is highly site
  specific.

127
Direct and Indirect Emissions to Water

• Technically
• Certain treatment steps are always more effective
  on small volume (unmixed) wastewater.
• Examples
• Trapping / skimming of oil and hydrocarbons.
• Breaking oil emulsions
• Chemical oxidation (wet oxidation can be
  autothermic on very high COD wastewaters)
• Chemical precipitation, absorption, filtering.

128
Direct and Indirect Emissions to Water

• Technically, biological treatment plants perform
  better with
• Steady state input. Less hydraulic, temperature,
  pH or organic load shock.
• Good balance of C, N, P.
• Absence or very low presence of any inhibiting
  substances.
• Acclimated organisms.

129
Direct and Indirect Emissions to Water

• On a case by case basis, treatment of
  wastewaters on-site as part of the IPPC
  installation may provide the best level of
  environmental protection.
• Treatment off-site in admixture with municipal
  wastewater can avoid the need to add nutrients
  for biological treatment but the fate of
  persistent substances should be considered.
• Danger exists of losing substances by dilution.

130
(No Transcript)
131
Interaction of IPPC Directive and other
Directives
132
IPPC and other Directives

• Some Directives prescribe minimum standards for
  all
• Large Combustion Plant
• Waste Incineration
• IPPC permit to be based on BAT but taking account
  of
• technical characteristics of installation
• geographical location
• local environmental conditions

133
BAT for Large Combustion Plants

• IPPC Directive applies to combustion
  installations exceeding 50 MW thermal input
  (LCP).
• 50 MW installation may have multiple combustion
  units, each of less than 50 MW.
• LCP covers both electricity power plants (can be
  highly variable demand for power) and process
  power plants.
• Range of operation from standby to 100 base
  load.
• Rapid response to fluctuation in demand may be
  needed.
• Economics tend to apply to network of power
  plants not so much each individual plant.

134
BAT for Large Combustion Plants

• Technical options for base load plants are
  different to technical options for peak load
  plants.
• e.g. stable temperature window for SCR de-NOx.
• Economics of power plants linked to local
  economy.
• Basic fuel choice can be highly dependent on
  local availability, transport, flexibility
  requirements.
• Electricity deregulation, security of supply
  issues.
• Separate BAT determination for different fuel and
  combustion technologies (IPPC permit for
  installation).

135
BAT for Large Combustion Plants

• Issues for LCP
• Directive 2001/80/EC sets mandatory emission
  limits for some parameters to air.
• Best energy efficiency achievable more easily on
  new plants than existing. Function of design,
  location e.g. CHP needs user for heat.
• Each plant specifically designed and operated to
  meet local needs.
• Sector is infrastructural and often public owned
  now or historically.

136
BAT for Large Combustion Plants
LCP Directive 2001/80/EC Recital 8 Compliance
with the emission limit values laid down by this
Directive should be regarded as a necessary but
not sufficient condition for compliance with the
requirements of Directive 96/61/EC regarding the
use of best available techniques. Such compliance
may involve more stringent emission limit values,
emission limit values for other substances and
other media, and other appropriate conditions.
137
BAT for Large Combustion Plants
LCP Directive 2001/80/EC Article 4(3) and 4(6)
provide for the possibility for Member States to
establish a national emission reduction plan for
existing installations, as an alternative to
applying the emission limit values specified in
the LCP Directive to existing plant. However,
the plan may under no circumstances exempt a
plant from the provisions laid down in relevant
Community legislation, inter alia Directive
96/61/EC.
138
IPPC and Landfill Directive

• Some landfills covered by Council Directive
  1999/31/EC on the landfill of waste also fall
  within the scope of Council Directive 96/61/EC
  concerning integrated pollution prevention and
  control (categories 5.1 and 5.4 in annex I).
• What are the IPPC provisions competent
  authorities have to take into account for these
  landfills, in addition to the requirements of the
  Landfill Directive?

139
IPPC and Landfill Directive

• Art. 18(2) - the technical requirements
  applicable for the landfills shall be fixed by
  the Council in accordance with the procedures
  laid down in the Treaty.
• Mirrored by Art. 1(2) of the Landfill Directive
  stating that in respect of the technical
  characteristics of landfills, this Directive
  contains, for those landfills to which Directive
  96/61/EC is applicable, the relevant technical
  requirements in order to elaborate in concrete
  terms the general requirements of that Directive.
  The relevant requirements of Directive 96/61/EC
  shall be deemed to be fulfilled if the
  requirements of this Directive are complied with.

140
IPPC and Landfill Directive

• As a consequence, the requirements laid down in
  Annex I to the Landfill Directive take the place
  of the emission limit values, equivalent
  parameters and technical measures based on best
  available techniques required by Art. 9 (4) IPPC
  in the permit conditions.
• But there are issues on dates by which permits
  are required and conditions met.

141
(No Transcript)