Transcript Document

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:
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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.
Irish IPPC Permits
Irish permits are all available at www.epa.ie
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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/ippcview.jsp?regno=P0830-01
Permit to Ensure Integrated Approach
Specified in IPPC Directive
SO2
waste
VOCs
CO2
odou
r
Hg
nois
e
BOD
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water
energy
Raw
materials
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:
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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:
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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
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Many reports on improvement programmes
rather than full information at beginning:
1 month - Commissioning of Turbines
 3 months
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 Demonstrate
Energy Efficiency
 Noise Management Plans
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12 months - Annual Environmental Report
Permit Requirements
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Report every 3 years on:
Potential Environmental Improvements including
 costs and benefits against BAT criteria.
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Permit Requirements
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Environmental Management System (EMS)
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After 9 months the company must submit a report on
progress towards certification to ISO 14001 or EMAS.
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:
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Limits were
 60 mg/m3 on gas
 125 mg/m3 on oil
 Annual mass 640 t
Emissions to Air
Plant uses low NOX combustion technology.
 Permit requires continuous monitoring of:
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oxides of nitrogen
 carbon monoxide
 oxygen
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Emissions to Water
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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:
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flow
 oil in water
 pH
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Noise
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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
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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
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Annex VIII of LCP Directive 2001/80/EC requires that the
Member States shall establish each year an:
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The competent authority shall obtain for each plant:
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An inventory of SO2, NOx and dust 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.
Reporting Obligations - Authorities
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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):
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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.
Reporting Obligations - Authorities
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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:
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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.
Reports – Where do they end up?
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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:
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http://cdr.eionet.europa.eu/
Note first annual LCP submission was 31/12/07.
EPER Map of South Western UK
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EPER  E-PRTR
EPER
50 Pollutants
56 IPPC Activties
Reports every 3 Years
E-PRTR
91 Pollutants
65 Annex I-Activities
Annual Reporting
Emissions into Air, Water and Land
Emissions into Air and Water
Emissions into Water (indirect)
Accidential Release
Transfer of Pollutants into Waste
Water
Waste Transfer (non-haz./haz. waste)
Emissions from diffuse Sources
Public Participation
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Relevant E-PRTR Compounds for LCPs
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Main Compounds
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Trace compounds
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Carbon monoxide: CO
Carbon dioxide: CO2
Nitrogen oxides: NOx/NO2
Sulphur oxides: SOx/SO2
Particulate Matter: PM10
Heavy metals such as Hg, Cd.
Dioxins
Annual Reporting E-PRTR
2007
2008
Reported year
1. Report
2009
15.6.08
(31.7.08)
15.2.2009
30.6.2009
2008
2009
Reported year
31.5.09
(30.6.09)
2. Report
2010
31.3.2010
31.12.2009
n
n + 1 Jahr
n + 2 Jahre
Reported year 31.5.n+1
(30.6.n+1)
n. Report
31.3.n+2
31.12.n+1
Operator to Competent Authority
National Authority to EU COM
Competent Authority to National Authority
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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
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EPER represents the basis for E-PRTR
Supplementary information in E-PRTR
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 Additional + Pollutants, Waste, etc.
Diffuse Emission Sources
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 Traffic, Agriculture, Aviation, etc.
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E-PRTR involves more that the operators & Authorities
Annual Reporting  More Data
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:
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Estimated savings €105 to €255 million per year.
Questions?
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