Consultant: CMDC Joint Venture Setting of conditions - Good practice and examples from other EU countries.

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

Scope of permitBe 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 permitExample: Avedrevrket power plantThe 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 - introductionMake a reference to the application (which is binding to the applicant)

ExampleAVV 2 will be built and operated in a way that is environmentally incompliance with the technical and environmental specification and with thebelow mentioned conditions.

IMPORTANTThe application MUST state what is applied for in ALL tables and text!

For existing enterprises also the existing figures should be given

Use of resources - generalUse of water

Use of energy

Use of raw materials and auxiliaries

Use of resources - waterPermitted 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 - energyPermitted 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 materialsMaximum amounts for each relevant raw material. Refer to application.

Consider general margin (e.g. application + 10%). Discuss withEnterprise

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 & controlTotal water intake + relevant workshopsTotal energy consumption (electricity, heat) + relevant workshops/equipmentRaw materials - production logbooks (or purchasing + registering of storage)Monitoring of product amounts may be neededConditions on how often to measure/logDefine control period (typically 1 year).Conditions on uncertainty of measuring devices ( x%)Conditions on calibration - how often + method

Use of resources - reportingAsk for annual reports which compares permitted amounts with actualconsumption

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 - general5 types of conditions in the permit :

1. Emissions (and immissions??)a. ELVs for point sources b. Conditions for diffuse sources2. Special conditions 3. Transboundary and or long distance pollution4. Monitoring and control5. Reporting

Air - emissions1. Minor emission2. Substantial emission3. Serious emission

To judge whether abatement is necessaryTo set reasonable self monitoring conditionsTo set reasonable sampling conditions - scope and frequencies

assessmentWHY necessary to assess?

Air - immissionsMake sure that the immission concentrationsare complied with

(stack heights calculation models)

Sufficient stack height shall be calculated by the applicant should be checked by you

Air emissions - Minor pollutionConditions:Max flow (g/sec) and annual amountUse of raw materialsFilter 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 pollutionDemand abatement/treatmentLimit values in g/s, mg/Nm3, tons per year

Remember the VOC directive requirements if relevant (toxic, mutagenic,carcinogenic)

Air - Special conditionsAllowed operation time if filters are not operatingEmissions under repair/maintenance Always lid on the containers with acetoneClosed doors and windowsMax content of S in fuel (or under raw and auxiliary materials)Watering the outdoor coal storage

Air - Monitoring and controlWhy To ensure compliance (low emissions) at any time !

HOW best ensure low emissions ALWAYS ?

Air - Monitoring and controlControl of equipment and/or the filters operation conditions (preventive)Emission control (reactive)Gives only a momentary picture of the emissions !(if not continous measurements)Far the most important !

Air monitoring and controlPriority 1 controlControl of equipment and filters : Frequency, method, documentation.

Air filter controlActive carbon filtersspecify indicators that decide time of replacement (emission control? physical factors?)

Bag filtersspecify how to check for holes (visual inspection and measure of pressure difference)

Electro filters

Air Emission control = measurementsWhyAbatement efficiencyTo check compliance Calculation of emissions as basis for pollution charges

WhoEnterprise control = self monitoring (self or accredited lab)Authority control (accredited lab or inspectors)

Air - measurementsMeasurements in order to test thefilter efficiency

Can be:continuous measurements performance measurement when installing new filtersspot tests

Air - measurementsIf well documented operational control, then emission measurements on a regular basis (spot measurements) should not be necessary

Measurements are expensive

Air - Checking compliance- regularSerious emission Demand 1-2 performance measurements per year first year. If theyconfirm the level (from the first measurement) then only onemeasurement per year (three readings)

Continuous measurements if required (see guidelines, legislationand BAT notes) (e.g. LCPs and large VOC polluters)

Air - Checking compliance- randomly by the inspectorsInspectors will require spot tests. Do not require in the permits leave toinspectorate to require.

Purpose:To check compliance without warning.....Random sampling? Is the inspector accredited?, is the measurement valid?

Air - ReportingRegular 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 - general5 sections of conditions in the permit guideline:

1. Emissions2. Special conditions 3. Trans-boundary and or long distance pollution4. Monitoring and control5. Reporting

Wastewater - process emissionsFill 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 emissionsStorm 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 treatmentDischarge to the ground - special regulation

Wastewater - Special conditionsProcess wastewater and sanitary water shall always be treated in enterprise sown treatment plant (example)

Some process wastewater must be treated as hazardous waste. Dischargeprohibited

Recycling of wastewater (from one process to another)

Demands for sand- and/or oil trap on storm water

Wastewater - monitoring & controlWhyAbatement efficiencyTo check compliance Calculation of discharge as basis for pollution charges

WhoEnterprise control = self monitoring (self or accredited lab). Conditions onmaintainance and calibration of enterprise measuring equipmentAuthority control (Inspectorate or accredited lab?)

Wastewater - monitoring & controlWhere and how:Operational control: temperature and oxygen etc.Specify exact measuring points, refer to site map (no storm waterinfluence when measuring process wastewater).Always flow-proportional measuring unless flow is constant or inspecial cases

Wastewater - monitoring & controlFrequency:Minor pollution: On request / performance (max. once per year)Major pollution: 4-24 times per year. Change in frequency should bepossible based on experience

Control period:Normally 1 yearSuccessive period

Wastewater - monitoring & controlCompliance, for example:When mean value over the evaluation period does not exceed thespecified ELVWhen no single measurement exceeds ELV more than e.g. 50% (requiresknowledge of variation)

Other:Monitoring program for recipient water bodies - only in certain cases

Wastewater - reportingAnnual or quarterly reportsReport should compare ELVs and actual measurementsDefine report format in co-operation with enterprise The enterprise must comment in case of non-complianceIf relevant, set conditions on filing of information, that are not reported(e.g. calibration sheets)Measurement reports should indicate any special production conditionsduring measurement

WasteFill in the tables (type, amount and disposal)

Special conditionsStorageSorting (better sorting)Re-use (cement dust, hide trimmings and fleshing etc) Re-cycling (filter dust)Investigate further reuseMinimisation: (emptying drums completely)

Soil and groundwaterDrip trays under taps (out door tapping)Storage tanks shall be bundedBund shall be tight (no cracks)Ground shall be consolidated where risk of spillsProtect containers against damage collisions

Spills and accidentsDrip trays under taps indoorGround shall be consolidated where risk of spillsProtect containers against damage collisionsBunded storage and process areas. No open drainage (closing/openingvalves)Closing valve in the drainage cesspoolFire protection (goods storage)Fire water retention

Abnormal situations = All situations different from normal operation1. Planned abnormal situations2. Not planned = accidents

What to do if water treatment breaks down (low temp in winter, spill ofchemicals)What to do if filters do not not workWhat to do if spilling chemicals

NoiseExisting enterprisesAssess the night level ; problem if > 40 dB at residential areas Pumps, ventilators, compressors shall be placed indoor or behind ashieldNew machinery should be noise weakAvoid night transports of raw materials or products (noisy trucks)New enterprises: noise weak equipment, daily limits under 45/60/70 dB depending onlocation, nights 35-40 dB

General pieces of good advice

Further investigationsSpecify 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)

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

MeasurementsGreat fluctuations: many measurementsSmall fluctuations: few measurements

Sampling and analysesSpecify methods of samplingSpecify time (spot sampling/24 hour)Specify analysis methods

Consult the labs for advice

Preventive behaviour

IS

Control of process equipment Control of filters etc Control of treatment facility

Reactive behaviour

IS

Measuring emissions

Conditions For each condition check:

Is it relevant (the purpose is clear)Is it preciseCan it be controlled for compliance

You might want to start with the special conditions any conditions which do not fit under the other headlinesSee the exampleHow to set the ELV if it is a minoir air pollution

Examples form Sadolin ??

Frese: No abatement because the flow is low Sadolin: control of the operation of the filters should be enough no regular measurements necessary.Kunda: Control of 02, CO, temperature as control of operation )If the filters are working, then they will emit a constant level focus on the filter control.Serious emissions: 1 to 2 Kunda: To few measurements they agreed that two per year would be ok. Do not here write e.g. That the cyclones shall be replaced by electrofilters by.........

Indicate this by giving reduced emissions