tools for the preparation of integrated permits in serbia march 31, belgrade riccardo...

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium


Projekat realizuje Human Dynamics Konzorcijum

TOOLS FOR THE PREPARATION OF

INTEGRATED PERMITS IN SERBIA

MARCH 31, BELGRADE

RICCARDO QUAGGIATO



OVERVIEW OF THE PROJECT• September 2012–august 2014• 6 components, • 30 activities

CAPACITY BUILDING

LEGAL FRAMEWOR

K

COMMUNICATION AND

PARTICIPATION

SEVESO IMPLEMENTAT

ION

EMAS IMPLEMENTA

TION

IPPC/IED IMPLEMENTAT

ION



TRANSPOSITION AND IMPLEMENTATION ASSESSMENT• Assessment of the level of transposition and

implementation of IPPC/IED• Identification of gaps/bottlenecks for a full

accordance with the Dir.• Definition of recommendations or solutions

for the future transposition and correct implementation (including a workplan)

• Draft of the new Law on IPPC and related Rulebooks (future activity)



Documental/operational tasks - 1

Act. 2.2 - Completion of 3 procedures manuals, one for each of the 3 thematic areas: IPPC/IED, Seveso and EMAS

- analysis of existing procedures and the administrative framework- manual for IPPC/IED procedure:

- defines the responsibilities of all involved authorities and stakeholders

- shows detailed flow charts of the work processes from the initial stage of identification of an installation and permit application to final reporting



Documental/operational tasks - 3

Act. 5.2 Translate appropriate BREF documents into Serbian language

Integral translation of 3 BREF docs, together with a glossary of specific terms.7 National BREF Guidance will be produced



Training and participation - 1

Act. 2.4: Organise and implement a series of workshops for public Institutions onvolved in IPPC implementation

Specific training for IPPC permit writers and other Institutions involved:- 2 days on BAT assessment and ELV setting (YUHOR, Jagodina)- 2 days on Integrated permit conditions and Monitoring Plan

(EPS, Kostolac)



BAT ASSESSMENT



BAT Assessment: WHY is it needed? BREF

Complex No prioritization of BAT

Method to find/collect the essential information in BREF (or elsewhere)



I. Baseline analysis

Inventory of main pollutants• Data from application

tables• Monitoring or estimated

data

“Prioritization” of pollutants and emissions according to set EQS – ELV

• Identify EQS or environmental data (atmosphere, water…) (appl. Form)

• Calculate cumulative emissions and correlate with EQS

Analysis of each production process (unit operation) – “weak spots”

• Division of process in blocks

• Analysis of input/outputs generated



II. Potential BATs

Correlation of potential BAT with “weak spots”

• Compare identified UO with chapter1-4 of BREFs

• Identify potential BATs for each weak spot UO, selecting from ch.5 of BREFs

Assessment of inputs/outputs of potential BAT

• Identify information about I/O of potential BATs, according to BREFs and A.F.



III. Environmental performance of BATComparison/benchmarking of BAT outputs to “old” emissions

• From previous phases, calculate the % of reduction of main pollutants by adopting potential BATs

Comparison/benchmarking of BAT inputs to the conventional process

• From previous phases, calculate the % of reduction of main pollutants by adopting potential BATs

• Potential save of resources (preferable solution)



IV. Technical performance of BATAnalysis of BAT technical characteristics (design, equipment, manpower etc.)

• Process flow/parameters• Equipment/devices• Type of technical

modifications to introduce BATs

• Operational requirementsTechnical viability of BAT (tested in semi-industrial scale, widespread application)

• PRO/CONS analysis of the technical features from previous phase



V. Economic viability of BAT

Investment costs (civil/mechanical engineering services)

• Devices, buildings, mechanical components, electronic comp.

• Taken from design/project/feasibility study

Operational costs (manpower, raw materials etc.)

• Energy costs• Chemicals• Water• Occupational (incl. training)• Maintenance

Break-even point (“paid-back” of investment)

• Calculation of annual costs• Comparison with

investment



DISCUSSION

• WHICH IS THE MOST DIFFICULT STEP OFTHIS METHODOLOGY?

• WHICH IS THE MOST IMPORTANT FACTOR AMONG ENVIRONMENTAL, TECHNICAL AND ECONOMIC?

• DO YOU THINK YOUR COMPANY COULD GATHER THE NECESSARY INFORMATION TO APPLY THIS METHODOLOGY?

• DO YOU THINK THAT A PROGRESSIVE IMPLEMENTATION OF BAT COULD BE MORE FEASIBLE?



SETTING APPROPRIATE ELV



SETTING OF ELV:How the BAT-AEL should be followed? BAT-AEL are expressed as a range of numerical

values. Which one should be adopted as ELV? Various BAT for the same production process allow

different emissions/ discharges of similar or different pollutants. Which one has to be selected as basis for setting ELV?

Local geographical conditions may ask for compatibility of ELV with EQS which will eventually ask for ELV which are different from BAT-AE

WHO DECIDES?



ELVS

• Only for parameters which are relevant for your facility!

• To be found in the BREFs relevant for your activity

• May be in terms of:mg/Nm3 in case of air emissions mostly as daily average

g/ton of product per day, moth or even yearton/year for the whole site as total, e.g. Shell refinery Rotterdam, bubble for NOx 3.200 ton/year, SO2 4.400 ton/year

• Time average specified



QUESTION TO YOU?

Suppose that:• A horizontal BREF specifies a BAT-ELV of 20

mg/Nm3 for dust as a daily average• A vertical BREF specifies 5-10 mg/Nm3 for

dust as a daily average• Which BREF applies?

Important: try to agree with Competent Authority on which BREFs apply to your facility



DECISION ABOUT ELV

• Application must contain a.o. a list of all relevant emissions to air, water, soil, wastes, etc.

• Operator may come up with a proposal for ELVs to be applied in the Permit conditions, but he is not obliged to do so

• The CA evaluate the proposal and issue the final decision



INTEGRATED PERMIT TEMPLATES AND MANUAL



INTEGRATED PERMIT TEMPLATE

• General template and 2 sectoral templates

• Manual on how to fill in items of permit structure

• Manual provides explanations and risks description in order to understand background of items

• Serbian permit scheme (existing) given in legislation is the base, starting point



Features taken into account for permit scheme elaboration

1. Administrative data having the same importance as technical2. Strenghtening the Administrative part 3. Permit to be prepared as easy-to-be-read and easy-to-be-

used4. Well structured permit, unequivocally defined items5. Providing transparent permit scheme and template6. For operators, easy implementation and self-check of

compliance



Structure of the integrated permit

Administrative part- data related to the IP- general information- activity and application analysis

Conditions- general- environmental issues affected

Monitoring planEnclosures

- supporting documents- maps and blueprints



CONDITIONS- 1

III. CONDITIONSValidity of integrated permit and deadline for submission of a new applicationFacility operation and management1. Operation and management2. Working hours3. Conditions for environmental protection managementBest available techniques determinationResource utilization1. Raw materials (ancillary materials, other)2. Water3. EnergyAir protection1. Operation process and treatment facilities2. Emission limit values3. Point sources of emission4. Diffuse sources of emission5. Smells6. Concentration of pollutants in air and impact on air quality

(emission limit values)7. Control and measurement performed by the operator8. Reporting



CONDITIONS - 2III. CONDITIONS

Waste water1. Operation process and treatment facilities2. Emission limit values3. Concentration of harmful and dangerous substances in

waters4. Bodies of water collect discharged waste waters5. Control and measurement performed by the operator6. ReportingProtection of soil and underground water against pollutionWaste management1. Waste production2. Waste collection and removal3. Waste temporary storing4. Waste transport5. Waste processing, treatment and recycling6. Waste disposal7. Waste control and measures8. Waste sampling9. Documenting and reporting



CONDITIONS - 3

III. CONDITIONSNoise and vibrations1. Operation process and ancillary equipment2. Emission types3. Control and measurement (locations, frequency, methods)4. Reporting

Accident prevention and response 1. Reporting in case of accidentsUnstable (transition) operation modesDefinite closure of facility or parts thereof




Projekat realizuje Human Dynamics Konzorcijum

MONITORING PLAN TEMPLATE



Main objective

Develop a Monitoring Plan template to guide the elaboration of the Monitoring Plans to be included in the future IPPC permits issued by MERZ.

The Monitoring Plan template can be defined as the part of the IPPC permit where all the monitoring requirements are resumed



MethodAnalysis of Monitoring Plans of different Member States and identification of key

contents

Comparison between EU Monitoring Plans and a Monitoring Plan issued by

MERZ

Identification of the “gaps” between EU and Serbian Monitoring Plan

Gap analysi

s phase

Elaboration of a Monitoring Plan

template according to the results of gap

analysis



WHAT AND HOW TO MONITOR?

• BREF/ELV leading• Approaches to monitoring:

Direct measurementSurrogate parameters (ERPs)Mass balancesCalculations Emission factors



WHICH MONITORING SYSTEM? • Continuous in case of yearly, monthly or daily ELV: expensive for

Operator• Two times a year 3x0,5 hour of sampling and weighing in the lab

(own lab or external lab) combined with continuous pressure drop measurement, recording, delta P warning, logbook for filter checking every month: less expensive for Operator

• Once every two years 3x0,5 hour of sampling and weighing in the lab (own lab or external lab) combined with continuous pressure drop measurement, recording, delta P warning minimum 3 years, logbook for filter checking every week: even cheaper

• Check of suitability of filter after commissioning under representative conditions and repetition once every 5 years, combined with continuous pressure drop measurement, recording, delta P warning minimum 3 years, logbook for filter checking every week: cheapest



WHICH MONITORING SYSTEM? • In the example above: surrogate parameters

like pressure drop over the filter• Operator: be careful which ELVs and self

monitoring system you propose in your Application

• Investment and operational costs differ substantially



33

Typical monitoring requirements

Air:Stack emissionsOdoursAmbient air quality

WaterDischarge outlet (process effluent and surface water)Ambient monitoring (River)

GroundwaterGroundwater wellsSoil monitoring

NoisePoint measurementAmbient monitoring (sensitive receptor)

EnergyFuel usage / carbon dioxide discharge (greenhouse gas permit)



CONTROL PARAMETER

MONITORING TO BE CONDUCTED

MONITORING EQUIPMENT

Cyclone air velocity Bag filter pressureTemperature

Fan operation ContinuousContinuous

VisualPressure sensor & alarmTemperature sensor alarm

MONITORING

Example: abatement system to monitor/maintain (non ferrous

metal sector)



CONTROL EQUIPMENT BACKUP EQUIPMENT

Cyclone air velocity

Bag filter pressure

Temperature

Fan operation

Pressure sensor & alarm

Temperature sensor alarm

Spare fan

System shutdown if failure

System shutdown if failure

EQUIPMENT


metal sector)



Management of Abatement Equipment

FILTER PLANT INSPECTION FREQUENCY FILTER CLEANING METHOD FREQUENCY OF VISUAL

INSPECTION Fitted with reverse jets at least once a monthFitted with mechanical shakers

at least once a week

Requiring manual shaking daily inspection or prior to any delivery being made if deliveries are not daily


metal sector)



Mp TEMPLATE: structure

Section 1. Introduction, aims of the Monitoring Plan, reference personsSection 2. Environmental aspects

1.1 AIR EMISSIONS1.2 WATER CONSUMPTION1.3 WATER EMISSIONS1.4 WASTES1.5 NOISE EMISSIONS1.6 ODOURS1.7 RAW MATERIALS AND FUELS1.8 ENERGY CONSUMPTION1.9 PROTECTION OF SOIL AND GROUNDWATER

Section 3. Monitoring campaign of the state of the surrounding environmentSection 4. Public inspectionsSection 5. Monitoring requirements for the closure/decommissioning phaseSection 6. Environmental performance indicators and reporting



DISCUSSION

• DO YOU THINK THAT YOUR CURRENT MONITORING PRACTICES ARE SIMILAR/COMPLIANT WITH THE SCHEME OF THE MONITORING PLAN?

• DO YOU HAVE A SYSTEM TO MONITOR PERIODICALLY YOUR ENVIRONMENTAL DATA (APART THE SYSTEM IMPOSED BY THE PERMITS)?

• DO YOU USE THE COLLECTED ENVIRONMENTAL DATA TO ASSESS YOUR ENVIRONMENTAL PERFORMANCE?

tools for the preparation of integrated permits in serbia march 31, belgrade riccardo...

Documents

european union project

elsewherethis project

activitiesthis project

human dynamics consortiumi

final reportingthis

bref docs

permit application

correct implementation