Reference: 1999/13/EC
Last Update: 18/05/2012
ENVIRONMENTAL PERMITTING: SOLVENT EMISSIONS
The Solvent Emissions Directive (1999/13/EC) limits the emission of volatile organic compounds (VOCs) from the use of organic solvents in certain activities and installations.
The Directive is implemented in England and Wales via the Environmental Permitting (England and Wales) Regulations 2010. The requirements of the SED have largely been included in permits or authorisations for installations under these regulations. Note, the Solvent Emissions (England and Wales) Regulations 2004 have been repealed by the Environmental Permitting (England and Wales) Regulations.
Activities falling within Annex 1 of the SED and with a solvent consumption above the threshold specified must be covered by a permit. Typical activities that fall within the scope of the Directive are coating, printing and surface cleaning.
New installations must comply with the Directive with immediate effect. Existing installations covered by the Directive do not have to comply until 31 October 2007. Installations already operating with solvent abatement equipment do not fall under the Directive's remit until 2012 if it can be shown that emissions do not exceed certain specified levels.
Schedule 14 of the Environmental Permitting (England and Wales) Regulations 2010 sets out measures in relation to SED installations and requires the regulator to carry out its functions in relation to the following Articles:
Article 5 states that all installations shall comply with either:
- the emission limit values in waste gases and the fugitive emission values as a percentage of solvents input into the process (Annex IIA of the Directive), or
- the total emission limit related to production e.g. 25g of VOCs can be released per pair of footwear manufactured,
- or an alternative reduction scheme (meeting the requirements of such a scheme specified in Annex IIB.
Annex IIA also sets out requirements for abatement equipment for those opting to comply with emission limit values. Where two or more SED activities are carried out in an installation, they must meet the requirements for each activity individually.
This article also specifies particularly harmful VOCs classified as carcinogens, mutagens or toxic to reproduction (R45, R46, R49, R60, R61) to be replaced by less harmful substances as soon as possible. Emission limit values are set specifically for these VOC’s where they are used and for VOC’s assigned the risk phrase R40. Provisions are also made for existing installations, which, if they meet emission limit values set out in this Article, are exempt from emission limit values set out in Annex IIA for 12 years after April 2001.
Article 8 requires operators to provide monitoring data to the regulator which proves compliance with the Directive annually.
Article 9 sets out how the operator is to demonstrate compliance. Guidance in provided in Annex III on solvent management plans which serve to demonstrate compliance with the requirements of the Directive. In the case of continuous measurements, the emission limits values shall be considered to be complied with if (a) none of the averages over 24 hours of normal operation exceeds the emission limit values, and (b) none of the hourly averages exceeds the emission limit values by more than a factor of 1.5. In the case of periodic measurements the emission limits values shall be considered to be complied with if, in one monitoring exercise (a) the average of all the readings does not exceed the emission limit values and (b) none of the hourly averages exceeds the emission limit value by more than a factor of 1.5.
Article 10 requires operators to inform the regulator in the event of a permit breach and take measures to restore compliance in the shortest possible time.
Guidance produced by DEFRA is available here.
Directive 2008/112/EC updates the SED in light of the new globally harmonised system of labelling regulation (EC/1272/2008). Also, halogenated VOCs with risk phrase R68 (possible risk of irreversible effects) are set a specific emission limit of 20 mg/Nm3, where the mass flow of the sum of the compounds is greater than, or equal to, 100 g/h.
Last Update: 23/02/2011
By: Waterman
Applicability
The labelling plant at the Barnsley site is regulated as a Part B process (permit ref: PPC/B/59). Under the permit the company is required to monitor emissions of particulate matter from the stack and compile an inventory of solvent emissions from paints used in the process.
Monitoring must be undertaken every three years. The last stack monitoring exercise was conducted on 14 October 2010 by RPS and monitored for particulate matter and organic compounds. The modelling demonstrated compliance with the permit. The solvent inventory is compiled by the company using the known solvent content of the paint and quantity of paint used. Data shows that solvent consumption has decreased of the past 12 month period due to business changes. This data is submitted to the local authority.
The Local Authority requested that a Solvent Reduction Plan be submitted in 2009. However the painting process has only operated for a few days over the past two years and as such, any figures submitted would be unrepresentative. It has therefore been agreed with the Local Authority to shelve this requirement and review it when production levels change.
The site representative stated that there are no issues in complying with the permit.
The company has made other improvements to solvent emissions onsite by changing solvent cleaning supplier. The new supplier provides an odourless kerosene based solvent cleaner, which the supplier also takes back and recycles on behalf of the company. This process does not fall under the regulations.
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