Setting of conditions

Setting of conditions - Good practice and examples from other EU countries

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

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”.

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.”

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

Use of resources - general • Use of water • Use of energy • Use of raw materials and auxiliaries

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

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”

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%.”

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

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)

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

Air - emissions  assessment • 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 WHY necessary to assess?

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

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

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)

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

Air - Monitoring and control • Why • To ensure compliance (low emissions) at any time ! • HOW best ensure low emissions ALWAYS ?

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)

Air – monitoring and control • Priority 1 control • Control of equipment and filters : Frequency, method, documentation.

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

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)

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

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

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. LCP´s and large VOC polluters)

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?

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

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

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”) ??

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

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

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?)

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

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

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

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

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)

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

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

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

Noise • Existing enterprises • Assess the night level ; problem if > 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

General pieces of good advice

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 applieddepending on the results • (emissions, costs)

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

Evaluation of Compliance • ALWAYS define • when the condition is complied with

Measurements • Great fluctuations: many measurements • Small fluctuations: few measurements

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

Preventive behaviourIS Control of process equipmentControl of filters etcControl of treatment facility

Reactive behaviour • IS • Measuring emissions

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

Setting of conditions