Title: Setting of conditions
1Setting of conditions
- - Good practice and examples from other EU
countries
2Scope 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 -
3Scope 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.
4Conditions - 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.
5IMPORTANT
- The application MUST state what is applied for in
ALL tables and text! - For existing enterprises also the existing
figures should be given
6Use of resources - general
- Use of water
- Use of energy
- Use of raw materials and auxiliaries
7Use 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
8Use 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
9Use 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.
10Use 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
11Use 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)
12Air - 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
13Air - 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?
14Air - 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
15Air 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
16Air 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)
17Air - 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
18Air - Monitoring and control
- Why
- To ensure compliance (low emissions) at any time
! - HOW best ensure low emissions ALWAYS ?
19Air - 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)
20Air monitoring and control
- Priority 1 control
-
- Control of equipment and filters Frequency,
method, documentation.
21Air 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
22Air 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)
23Air - measurements
- Measurements in order to test the
- filter efficiency
- Can be
- continuous measurements
- performance measurement when installing new
filters - spot tests
24Air - measurements
- If well documented operational control, then
emission measurements on a regular basis (spot
measurements) should not be necessary - Measurements are expensive
-
25Air - 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)
26Air - 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?
27Air - 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
28Wastewater - 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
29Wastewater - 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) ??
30Wastewater - 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
31Wastewater - 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
32Wastewater - 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?)
33Wastewater - 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
34Wastewater - 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
35Wastewater - 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
36Wastewater - 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
37Waste
- 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)
38Soil 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
39Spills 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
40Abnormal 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
41Noise
- 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
42General pieces of good advice
43Further 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)
44Transboundary 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
45Evaluation of Compliance
- ALWAYS define
- when the condition is complied with
46Measurements
- Great fluctuations many measurements
- Small fluctuations few measurements
47Sampling and analyses
- Specify methods of sampling
- Specify time (spot sampling/24 hour)
- Specify analysis methods
- Consult the labs for advice
48Preventive behaviourIS
Control of process equipmentControl of filters
etcControl of treatment facility
49Reactive behaviour
50Conditions
- For each condition check
- Is it relevant (the purpose is clear)
- Is it precise
- Can it be controlled for compliance
-