Setting of conditions

1
Setting of conditions

• - Good practice and examples from other EU
  countries

2
Scope of permit

• Be careful to tell what the permit covers !
• Be careful to tell what the permit allows (annual
  production or use of raw materials !
• Refer to the list of equipment (page no and date
  of application) when telling what the permit
  covers

3
Scope of permit

• Example Avedøreværket power plant
• The approval comprises establishing and
  operation of AVV 2 with the accompanying
  auxiliary plants and installations described in
  the environmental report..
• Moreover, the approval includes permission for
  increased use of AVV 1's facilities, provided
  that it is done in observance of the conditions
  included in the approval granted for the AVV 1
  (Decision taken by the Environmental Board of
  Appeal on 24 May 1985) with the succeeding
  approvals, unless the conditions were changed in
  the existing approvals, as well as ammonia store
  and ammonia installations.

4
Conditions - introduction

• Make a reference to the application (which is
  binding to the applicant)
• Example
• AVV 2 will be built and operated in a way that
  is environmentally in
• compliance with the technical and environmental
  specification and with the
• below mentioned conditions.

5
IMPORTANT

• The application MUST state what is applied for in
  ALL tables and text!
• For existing enterprises also the existing
  figures should be given

6
Use of resources - general

• Use of water
• Use of energy
• Use of raw materials and auxiliaries

7
Use of resources - water

• Permitted amounts per source (lake, ground water
  etc). Fill in table
• Consider conditions on stepwise reduction
• If possible/relevant, set conditions per
  produced/processed unit
• If relevant, set special conditions Washing
  shall be done in batches, High pressure
  flushing shall be used for cleaning etc

8
Use of resources - energy

• Permitted consumption for technological purposes
  if relevant (electricity steam). If possible
  per produced/processed unit
• Consider conditions on stepwise reduction
• If relevant, set special conditions
• - Conditions on replacement of specific
  machinery
• - No later than dd.mm.yyyy all steam and hot
  water pipes in workshop X shall be insulated
• - All equipment shall remain shut off when not
  in use

9
Use of resources - raw materials

• Maximum amounts for each relevant raw material.
  Refer to application.
• Consider general margin (e.g. application 10).
  Discuss with
• Enterprise
• Conditions on banning or phasing out specific
  substances.
• Special conditions, for example
• Sulphur content in oil for the KAD boiler
  cannot exceed the limit given in the valid
  decision on limiting the sulphur content in fuels
  used for firing, unless the environmental
  authorities have granted exemption from the
  limits set by the decision. Regardless of the
  exemption, the sulphur content cannot exceed the
  level of 4.

10
Use of resources - monitoring control

• Total water intake relevant workshops
• Total energy consumption (electricity, heat)
  relevant workshops/equipment
• Raw materials - production logbooks (or
  purchasing registering of storage)
• Monitoring of product amounts may be needed
• Conditions on how often to measure/log
• Define control period (typically 1 year).
• Conditions on uncertainty of measuring devices (
  x)
• Conditions on calibration - how often method

11
Use of resources - reporting

• Ask for annual reports which compares permitted
  amounts with actual
• consumption
• Define reporting format in co-operation with
  enterprise
• The enterprise must comment in case of
  non-compliance
• If relevant, set conditions on filing of
  information, that are not reported
• (e.g. log-books)

12
Air - general

• 5 types of conditions in the permit
• 1. Emissions (and immissions??)
• a. ELVs for point sources
• b. Conditions for diffuse sources
• 2. Special conditions
• 3. Transboundary and or long distance pollution
• 4. Monitoring and control
• 5. Reporting

13
Air - emissions

• 1. Minor emission
• 2. Substantial emission
• 3. Serious emission
• To judge whether abatement is necessary
• To set reasonable self monitoring conditions
• To set reasonable sampling conditions - scope
  and frequencies

? assessment
WHY necessary to assess?
14
Air - immissions

• Make sure that the immission concentrations
• are complied with
• (stack heights calculation models)
• Sufficient stack height shall be calculated
  by the applicant should be checked by you

15
Air emissions - Minor pollution

• Conditions
• Max flow (g/sec) and annual amount
• Use of raw materials
• Filter demand only if reasonable - see IPPC
  guidelines and BAT notes
• (cost benefit assessment)
• Note
• mg/Nm3 is only relevant of there is
  abatement - filter, cyclone etc

16
Air emissions - Substantial or serious pollution

• Demand abatement/treatment
• Limit values in g/s, mg/Nm3, tons per year
• Remember the VOC directive requirements if
  relevant (toxic, mutagenic,
• carcinogenic)

17
Air - Special conditions

• Allowed operation time if filters are not
  operating
• Emissions under repair/maintenance
• Always lid on the containers with acetone
• Closed doors and windows
• Max content of S in fuel (or under raw and
  auxiliary materials)
• Watering the outdoor coal storage

18
Air - Monitoring and control

• Why
• To ensure compliance (low emissions) at any time
  !
• HOW best ensure low emissions ALWAYS ?

19
Air - Monitoring and control

• Control of equipment and/or the filters
  operation conditions (preventive)
• Emission control (reactive)

Far the most important !
Gives only a momentary picture of the emissions
! (if not continous measurements)
20
Air monitoring and control

• Priority 1 control
• Control of equipment and filters Frequency,
  method, documentation.

21
Air filter control

• Active carbon filters
• specify indicators that decide time of
  replacement (emission control? physical factors?)
• Bag filters
• specify how to check for holes (visual
  inspection and measure of pressure difference)
• Electro filters

22
Air Emission control measurements

• Why
• Abatement efficiency
• To check compliance
• Calculation of emissions as basis for pollution
  charges
• Who
• Enterprise control self monitoring (self or
  accredited lab)
• Authority control (accredited lab or
  inspectors)

23
Air - measurements

• Measurements in order to test the
• filter efficiency
• Can be
• continuous measurements
• performance measurement when installing new
  filters
• spot tests

24
Air - measurements

• If well documented operational control, then
  emission measurements on a regular basis (spot
  measurements) should not be necessary
• Measurements are expensive

25
Air - Checking compliance- regular

• Serious emission
• Demand 1-2 performance measurements per year
  first year. If they
• confirm the level (from the first measurement)
  then only one
• measurement per year (three readings)
• Continuous measurements if required (see
  guidelines, legislation
• and BAT notes) (e.g. LCPs and large VOC
  polluters)

26
Air - Checking compliance- randomly by the
inspectors

• Inspectors will require spot tests. Do not
  require in the permits leave to
• inspectorate to require.
• Purpose
• To check compliance without warning.....Random
  sampling? Is the inspector accredited?, is the
  measurement valid?

27
Air - Reporting

• Regular reports with
• Emissions (average/max/min figures and graphs
  as relevant)
• Special situations (filter fall outs, change of
  filters, etc)
• A good report summarises in a table the results
  and tells if the conditions are complied with

28
Wastewater - general

• 5 sections of conditions in the permit guideline
• 1. Emissions
• 2. Special conditions
• 3. Trans-boundary and or long distance pollution
• 4. Monitoring and control
• 5. Reporting

29
Wastewater - process emissions

• Fill in table with relevant substances (mg/l
  t/q t/y). Note that in
• some cases only the amounts are important, not
  the concentrations.
• Remember to include flow, pH and Temp.
• ELV per ton product/raw material (e.g. 0,004 kg
  Cr/t rawhide) ??

30
Wastewater - other emissions

• Storm water
• - Consider ELVs for pH, oil, SS, BOD, N, P.
• - ELVs depending on recipient.
• Cooling water
• - By-pass treatment plant
• - Additives ?
• Sanitary water
• - Own or municipal treatment
• Discharge to the ground - special regulation

31
Wastewater - Special conditions

• Process wastewater and sanitary water shall
  always be treated in enterprise s
• own treatment plant (example)
• Some process wastewater must be treated as
  hazardous waste. Discharge
• prohibited
• Recycling of wastewater (from one process to
  another)
• Demands for sand- and/or oil trap on storm water

32
Wastewater - monitoring control
Why Abatement efficiency To check compliance
Calculation of discharge as basis for pollution
charges Who Enterprise control self
monitoring (self or accredited lab). Conditions
on maintainance and calibration of enterprise
measuring equipment Authority control
(Inspectorate or accredited lab?)
33
Wastewater - monitoring control

• Where and how
• Operational control temperature and oxygen etc.
• Specify exact measuring points, refer to site map
  (no storm water
• influence when measuring process wastewater).
• Always flow-proportional measuring unless flow is
  constant or in
• special cases

34
Wastewater - monitoring control

• Frequency
• Minor pollution On request / performance (max.
  once per year)
• Major pollution 4-24 times per year. Change in
  frequency should be
• possible based on experience
• Control period
• Normally 1 year
• Successive period

35
Wastewater - monitoring control

• Compliance, for example
• When mean value over the evaluation period does
  not exceed the
• specified ELV
• When no single measurement exceeds ELV more than
  e.g. 50 (requires
• knowledge of variation)
• Other
• Monitoring program for recipient water bodies -
  only in certain cases

36
Wastewater - reporting

• Annual or quarterly reports
• Report should compare ELVs and actual
  measurements
• Define report format in co-operation with
  enterprise
• The enterprise must comment in case of
  non-compliance
• If relevant, set conditions on filing of
  information, that are not reported
• (e.g. calibration sheets)
• Measurement reports should indicate any special
  production conditions
• during measurement

37
Waste

• Fill in the tables (type, amount and disposal)
• Special conditions
• Storage
• Sorting (better sorting)
• Re-use (cement dust, hide trimmings and fleshing
  etc)
• Re-cycling (filter dust)
• Investigate further reuse
• Minimisation (emptying drums completely)

38
Soil and groundwater

• Drip trays under taps (out door tapping)
• Storage tanks shall be bunded
• Bund shall be tight (no cracks)
• Ground shall be consolidated where risk of spills
• Protect containers against damage collisions

39
Spills and accidents

• Drip trays under taps indoor
• Ground shall be consolidated where risk of spills
• Protect containers against damage collisions
• Bunded storage and process areas. No open
  drainage (closing/opening
• valves)
• Closing valve in the drainage cesspool
• Fire protection (goods storage)
• Fire water retention

40
Abnormal situations

• All situations different from normal operation
• 1. Planned abnormal situations
• 2. Not planned accidents
• What to do if water treatment breaks down (low
  temp in winter, spill of
• chemicals)
• What to do if filters do not not work
• What to do if spilling chemicals

41
Noise

• Existing enterprises
• Assess the night level problem if gt 40 dB at
  residential areas
• Pumps, ventilators, compressors shall be placed
  indoor or behind a
• shield
• New machinery should be noise weak
• Avoid night transports of raw materials or
  products (noisy trucks)
• New enterprises
• noise weak equipment, daily limits under
  45/60/70 dB depending on
• location, nights 35-40 dB

42
General pieces of good advice
43
Further investigations

• Specify under the relevant sections if further
  investigations are relevant e.g.
• H2S emissions
• More air measurements
• Mapping of drainage system
• Leakage test of drainage systems
• Costs of certain pollution prevention measures
• Optimisation of burning process
• Specify that new conditions might be applied
  depending on the results
• (emissions, costs)

44
Transboundary and long distance

• Relevant for high stacks and long pipe lines into
  the sea/big lakes/rivers
• Not an option to live up to the immission limits
  by heightening the stacks or prolonging the pipes
  (water pipes into the sea) to dilute

45
Evaluation of Compliance

• ALWAYS define
• when the condition is complied with

46
Measurements

• Great fluctuations many measurements
• Small fluctuations few measurements

47
Sampling and analyses

• Specify methods of sampling
• Specify time (spot sampling/24 hour)
• Specify analysis methods
• Consult the labs for advice

48
Preventive behaviourIS
Control of process equipmentControl of filters
etcControl of treatment facility
49
Reactive behaviour

• IS
• Measuring emissions

50
Conditions

• For each condition check
• Is it relevant (the purpose is clear)
• Is it precise
• Can it be controlled for compliance
•