what does integrated permitting mean? (presentation based on h1 method, uk, thames region)

Consultant: CMDC Joint Venture

WHAT DOES INTEGRATED PERMITTING MEAN?

(presentation based on H1 method, UK, Thames Region)


Integration of permitting work in Danish counties

Example : Ribe County: 9 employees making permits (approximately 200.000 inhabitants in the

county) Each Employee has 3 tasks:

- Making permits within his/hers specific branch knowledge- Responsible for a specific sector plan or yearly task, including

maintenance of the legislation- Maintain technical expertise within 1 specific area

For each permit there is a primary case officer and a secondary case officer. The secondary case officer shall make quality control of the permit using a questionnaire and give day to day sparring to the primary case officer

The case officer can use informal assistance from the relevant technical experts.



Specialist areas:•Industrial wastewater•Risk•Incineration techniques•Air pollution•Solid waste•Landfills•External noise•IT

Tasks (internal):•IT support•Company database•Department homepage•Paradigms

Tasks (external):•Environmental management•Noise mapping•Green accounts•User payments•Revision of IPPC installations•Inspection report•Physical planning•Industrial network



Case officer Branches Specialist area Tasks1 Fishmeal, power plants,

airfields, fodder productionIndustrial waste water

IT supportCompany database

2 Chemical production, biotechnology, risks, plastic, polluted soil

Risks EIAInspection report

3 Asphalt, waste incineration, heat supply

Incineration techniques

Industrial network, Physical planning

4 Slaughter houses, plastic, chemicals

Air pollution VOC regulationHome page

5 Landfills, waste incineration metal, recycling of waste

Solid waste Regular Revision of IPPC permits


Integration

Noise

Water

Risks

Solid waste

Energy

Raw materials

Odour

AirLimit value

BAT


Structure of Assessment

Scope & options

Emissions inventory

assess environmental impacts

assess costs

select best option

Compare impacts between options


Scope and Options - 1

Explain why you are doing the assessment:either

To conduct a cost/benefit appraisal of options to determine BAT for selected releases from an installation because:

deviating from indicative BAT in BREF several candidates for BAT no indicative BAT in BREF

or

To carry out environmental assessment of emissions resulting from the installation as a whole



Describe scope of activities to be included

Emissions from a pulp mill

Methane emissions from

a landfill site

Emissions from effluent treatment plant of a

chemicals manufacturing facility

Sulphur emissions from

a coal-fired power station



Identify key environmental issues (and

eliminate irrelevant ones) and receptors

Identify candidate options for BAT, by

considering all relevant techniques to

prevent and minimise pollution from all

activities

Types of techniques:

•Raw materials

•Abatement

•process control

•operating mode

•design


Emissions Inventory - 1

Including: Point source emissions to air Point source emissions to surface water, groundwater and sewer Waste emissions Fugitive emissions to all media Abnormal emissions from emergency relief vents, flares etc Raw material consumption including energy and water


Emissions Inventory - 2

Describe: Substances released Source, including height, location, efflux velocity and total flow Predicted normal and maximum emissions expressed on suitable basis Statistical basis Predicted frequencies (if intermittent) Plant loads at which data are applicable Check all options meet any statutory emission limit values as laid down in EU Directives


Quantify the impacts

method depends on type of impact:

local impacts: relate to level in environment

- usually a maximum “protective” level

non-local impacts: relate to relative burden

- no maximum “protective” level

considerations

• releases to air• releases to water• deposition to land• ozone creation• global warming• waste disposal• noise• odour• accidents• visual impact


local impacts - 1

1. estimate levels in environment after dispersion :- “Process Contributions” (PC)

2. compare PC against environmental benchmarks; EQSs

3. the benchmarks are based generally on a maximum “tolerable” concentration to a receptor in a medium

4. benchmarks for human and ecological protection are available and will be under constant revision


local Impacts - 2

5. Identify whether detailed modelling of emissions is needed , eg if local receptors present which are sensitive to any of the

significant emissions if there is a risk of breaching an EQS

6. Add PC to background level to obtain total Predicted Environmental Concentration (PEC)

7. Check that PEC does not breach an EQS - these options will usually be unacceptable


local impacts - 3

PC ambient PEC

% P

C /

EQ

S100%

1%

80


local impacts - 4

normalise against benchmark:

EQ = PC / EQS

Summarise total impact by medium EQ water EQ air EQ land

EQ air

00,05

0,10,15

0,20,25

0,3

1 2 3

option

PC

/EQ

S

NOx

SO2


Non-local

Quantify Non-Local Impacts

Use relative Indices for Global Warming Ozone Creation

Waste: quantify by category describe disposal route

Summarise as total burden

global warming potential

0.E+00

1.E+08

2.E+08

3.E+08

1 2 3

optionco

ntrib

utio

n

N2O

CO2


Compare Options If PCs from options are low compared to EQSs this has less influence on decision than when they are high

If existing environmental quality is poor then greater importance placed on this consideration in the assessment

Local proximity of sensitive receptors to certain environmental impacts may be important

Long term irreversible effects are less desirable than short term reversible effects

How big the contribution of the impact is in relation to national or EU targets

Bear in mind risk/accidents


Evaluate the Costs

Estimate the costs of implementing each of the options carried forward from the assessment, to allow a balanced judgement of the costs of controlling releases of substances against the environmental benefits

Not necessary if the operator proposes to implement the option which clearly represents the lowest environmental impact


Select BAT

balance environmental benefits against costs justify priority impacts show decisions clearly

use expert judgement

0

25

50

75

100

125

0 5 10 15 20

pollution reductionco

st

12

3

4


Case study: A Power plant

Step 1: Scope and options

“To decide the best technique to reduce sulphur emissions from a power plant”



Step 2: Candidate options and key environmental issues

Option Key environmental issues

Use low sulphur coal SO2, NOx, Transport of coal

Use Natural gas SO2, NOx

De-sulphurising, dry method SO2, NOx, Waste deposits

De-sulphurisning, wet method SO2, NOx, Waste water, Waste deposits

SNOX method SO2, NOx



Step 3: Emissions inventory

Option SO2 NOx Waste Waste water

Low S coal 9,600 4,500 - -

N-gas 0 2,400 - -

De-S, Dry 3,200 4,500 100,000 m3/y -

De-S, Wet 3,200 4,500 17,000 m3/y N-compounds, heavy metals

SNOX 3,200 1,000 30,000 m3/y -



Step 4: Assess local impacts•Impossible to find locations for deposit of up to 30 mio. m3 solid waste (dry method over 30 years)•Gypsum (wet method) deposits has a risk for leaching of heavy metals to ground water, which is not acceptable. •Discharge of wastewater with heavy metals from the wet method is not in accordance with the hazardous substances directive (list I substances which should be eliminated).



Step 5: Assess regional and global impacts

Acidification:

Low – S Coal > End-of-pipe > N-gas (best option)

Eutrophication:

De-S, wet > low –S coal > De-S, dry > N-gas > SNOX (best option)

(assessed directly from emissions and discharges)



Step 6: Compare options

Due to unacceptable local impacts from heavy metals a deposit free solution is preferred and from assessment of regional and global impacts the following 2 methods is selected for further cost investigations:•N-gas•SNOX method



Step 7: Assess the cost

It is assessed that use of N-gas will raise the current power price with approx 7% compared to present price and cost 12 mio. EUR in installation of new burners etc.

The SNOX method is comparable in price to the other end-of-pipe solutions, but the method is not developed to a commercial level yet (only demo installations)



Step 8: Select BAT

BAT is the SNOX process when it is developed to a commercial level.

Until then N-gas firing is BAT

what does integrated permitting mean? (presentation based on h1 method, uk, thames region)

Documents

maximum emissions

secondary case officer

air point source emissions

media abnormal emissions

permitting mean

environmental benchmarks

batno indicative bat

danish countiesexample