1 Permitting of LCPs, Reporting Obligations on LCPs. ECENA Training Workshop Bristol, March 2008
Jan 13, 2016
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Permitting of LCPs, Reporting Obligations on LCPs.
ECENA Training Workshop
Bristol, March 2008
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Introduction
This presentation, Session 4, addresses: Permitting of LCPs in particular reporting
requirements. Reporting obligations on LCPs. E-PRTR Requirements. Streamlining of reporting obligations under proposed
Directive on Industrial Emissions.
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IPPC Process
LCPs are subject to the IPPC directive: Deadline for implementation of IPPC
directive within Member States (EU27) was 30 October 2007.
Estimated that circa. 52,000 installations fell under the directive and at this stage should have an IPPC permit.
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Irish IPPC Permits
Irish permits are all available at www.epa.ie E.g. Full file for Bord Gais Eireann’s 440 MWe
Combined Cycle Gas Turbine and, including application and public correspondence: http://www.epa.ie/terminalfour/ippcApril/ippc-view.jsp?regno=P0830-01
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Permit to Ensure Integrated Approach Specified in IPPC Directive
waste
Raw materials
SO2
CO2
Hg
BOD
water
energy
VOCs
noise
odour
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Permit Conditions
Permit must include Emission Limit Values (ELVs) based on BAT.
For plants not meeting BAT realistic timeframes to achieve BAT need to be defined.
However, techniques or specific technology can’t be specified by permit unless proposed in application, e.g. a management system can be outlined but accreditation to ISO 14001 or EMAS can’t be requested.
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BAT Conditions for a Permit
When defining BAT, particularly for an existing installation, the permit writer needs to consider carefully: Cost and benefits analysis. Time for implementation. Prevention of detrimental environmental impacts. Monitoring and reporting obligations. Control of industrial accidents.
Data supporting the above will be in the application.
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The Aarhus Convention
Best practice for environmental approval procedures: Access to information. Public participation protocols. Access to justice. Appeals. Confidentiality issues.
Articles 15 and 16 of Codified IPPC Directive 2008/1/EC. Inspector’s report dealing with issues raised by public,
see www.epa.ie for projects which received objections.
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First UK IPPC Permit
UK had operated Integrated Pollution Control for 8 years.
New Power Plant (215 MW) using gas turbine for heat and power in large paper factory.
Issued in March 2001 after 5 months and 1 request for information.
Permit was issued by Environment Agency (EA).
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Departure form Previous Authorisations
Previous authorisations issued by the EA focused on processes in isolation.
The new IPPC permits take all aspects of the site’s operations into account.
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Permit Requirements
Many reports on improvement programmes rather than full information at beginning: 1 month - Commissioning of Turbines 3 months
Demonstrate Energy Efficiency Noise Management Plans
12 months - Annual Environmental Report
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Permit Requirements
Report every 3 years on: Potential Environmental Improvements including costs and benefits against BAT criteria.
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Permit Requirements
Environmental Management System (EMS) After 9 months the company must submit a report on
progress towards certification to ISO 14001 or EMAS.
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Waste
The company EMS must contain procedures to assess the recovery options for each waste stream.
Waste oil is collected for off-site recovery or disposal.
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Emissions to Air
Turbine uses natural gas with oil as stand-by. NOX was main concern:
Limits were60 mg/m3 on gas125 mg/m3 on oilAnnual mass 640 t
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Emissions to Air
Plant uses low NOX combustion technology. Permit requires continuous monitoring of:
oxides of nitrogen carbon monoxide oxygen
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Emissions to Water
Surface water discharge to be continuously monitored for: flow oil in water pH
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Emissions to Sewer
Wastewater discharges to drained to oil separator.
Discharges to sewer continuously monitored for: flow oil in water pH
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Noise
Permit requires: The use of acoustic enclosures of the gas turbines. The use of air intake and exhaust silencers. Low noise fans on the air cooled condenser system. Acoustic shielding in design of site layout.
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Land Contamination
Application form showed some contamination because of former use as steelworks. The Permit prohibits releases to land.
Requires operator to get approval from the Agency for changes to the site.
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Reporting Obligations - Operators
Article 13 of LCP Directive 2001/80/EC requires that the operator informs the competent authority within reasonable time limits about: Results of continuous measurement. Checking of the measuring equipment, required by
Annex VIII at least every year. The individual measurements and all other
measurements carried out for compliance.
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Reporting Obligations - Authorities
Annex VIII of LCP Directive 2001/80/EC requires that the Member States shall establish each year an: An inventory of SO2, NOx and dust for each plant.
The competent authority shall obtain for each plant: Total annual emissions of SO2, NOx and dust. Total annual energy input in categories of fuel: Biomass, other
solid fuels, liquid fuels, natural gas, other gases. Year by year plant data to be made available to the
Commission on request.
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Reporting Obligations - Authorities
Annex VIII of LCP Directive 2001/80/EC requires that the Member States shall provide to the Commission an annual report on ‘End of Life’ plants, Article 4(4): A record of used and unused time allowed for the
plants’ remaining operational life. Same annual report required for plants on
derogations; Article 5 or Annex III and VIA.
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Reporting Obligations - Authorities
Article 15 of LCP Directive 2001/80/EC requires that the competent authority provide the Commission with a summary report on the progressive reduction of total annual emissions from existing plants: At the latest one year after the end of the different phases for
reduction of emissions from existing plants. An intermediate report is required
in the middle of each phase.
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Reports – Where do they end up?
Most of the reports submitted on environmental data from Member States and other European Countries can be found on European Environment Agency’s data repository: http://cdr.eionet.europa.eu/
Note first annual LCP submission was 31/12/07.
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EPER Map of South Western UK
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EPER E-PRTR
50 Pollutants
56 IPPC Activties
Reports every 3 Years
Emissions into Air and Water
Emissions into Water (indirect)
91 Pollutants
65 Annex I-Activities
Annual Reporting
Emissions into Air, Water and Land
Accidential Release
Transfer of Pollutants into Waste Water
Waste Transfer (non-haz./haz. waste)
Emissions from diffuse Sources
Public Participation
EPER E-PRTR
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Relevant E-PRTR Compounds for LCPs
Main Compounds Carbon monoxide: CO Carbon dioxide: CO2
Nitrogen oxides: NOx/NO2
Sulphur oxides: SOx/SO2
Particulate Matter: PM10
Trace compounds Heavy metals such as Hg, Cd. Dioxins
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Annual Reporting E-PRTR
1. Report2007 2008 2009
Reported year15.6.08
(31.7.08)
Operator to Competent Authority
Competent Authority to National Authority
National Authority to EU COM
15.2.2009
30.6.2009
2. Report2008 2009 2010
Reported year 31.5.09(30.6.09)
31.12.2009
31.3.2010
n. Reportn n + 1 Jahr n + 2 Jahre
Reported year 31.5.n+1(30.6.n+1)
31.3.n+2
31.12.n+1
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Useful Links on E-PRTR
Commission PRTR Site: http://ec.europa.eu/environment/ippc/eper/index.htm
German PRTR site: www.prtr.de Irish PRTR Site: http://
www.epa.ie/whatwedo/enforce/lic/prtr/ EPER Site: http://www.eper.ec.europa.eu/eper/
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Comparison EPER vs E-PRTR
EPER represents the basis for E-PRTR Supplementary information in E-PRTR
Additional + Pollutants, Waste, etc. Diffuse Emission Sources
Traffic, Agriculture, Aviation, etc. E-PRTR involves more that the operators & Authorities Annual Reporting More Data
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Reporting Requirements for New Directive on Industrial Emissions
EU recognises that existing requirements are bureaucratic with duplication of effort.
Goal of new directive is to streamline reporting requirements for both operators and authorities: Estimated savings €105 to €255 million per year.
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Questions?