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Permitting of LCPs, Reporting Obligations on LCPs. ECENA Training Workshop

Permitting of LCPs, Reporting Obligations on LCPs. ECENA Training Workshop. Bristol, March 2008. Introduction. This presentation, Session 4, addresses: Permitting of LCPs in particular reporting requirements. Reporting obligations on LCPs. E-PRTR Requirements.

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Permitting of LCPs, Reporting Obligations on LCPs. ECENA Training Workshop

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  1. Permitting of LCPs, Reporting Obligations on LCPs.ECENA Training Workshop Bristol, March 2008

  2. 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.

  3. 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.

  4. 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

  5. SO2 waste VOCs CO2 odour Hg Raw materials water noise energy BOD Permit to Ensure Integrated Approach Specified in IPPC Directive

  6. 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.

  7. 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.

  8. 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.

  9. 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).

  10. 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.

  11. 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

  12. Permit Requirements • Report every 3 years on: • Potential Environmental Improvements including • costs and benefits against BAT criteria.

  13. Permit Requirements • Environmental Management System (EMS) • After 9 months the company must submit a report on progress towards certification to ISO 14001 or EMAS.

  14. 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.

  15. Emissions to Air • Turbine uses natural gas with oil as stand-by. • NOX was main concern: • Limits were • 60 mg/m3 on gas • 125 mg/m3 on oil • Annual mass 640 t

  16. Emissions to Air • Plant uses low NOX combustion technology. • Permit requires continuous monitoring of: • oxides of nitrogen • carbon monoxide • oxygen

  17. Emissions to Water • Surface water discharge to be continuously monitored for: • flow • oil in water • pH

  18. Emissions to Sewer • Wastewater discharges to drained to oil separator. • Discharges to sewer continuously monitored for: • flow • oil in water • pH

  19. 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.

  20. 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.

  21. 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.

  22. 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.

  23. 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.

  24. 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.

  25. 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.

  26. EPER Map of South Western UK

  27. EPER E-PRTR EPER E-PRTR 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 50 Pollutants 56 IPPC Activties Reports every 3 Years Emissions into Air and Water Emissions into Water (indirect)

  28. 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

  29. 2008 2009 2010 2. Report Reported year 31.5.09(30.6.09) 31.3.2010 31.12.2009 n. Report n n + 1 Jahr n + 2 Jahre Reported year 31.5.n+1(30.6.n+1) 31.3.n+2 31.12.n+1 Annual Reporting E-PRTR 2007 2008 2009 1. Report Reported year 15.6.08(31.7.08) 15.2.2009 30.6.2009 Operator to Competent Authority National Authority to EU COM Competent Authority to National Authority 29

  30. 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/

  31. Comparison EPER vs E-PRTR • EPER represents the basis forE-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

  32. 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.

  33. Questions?

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