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Permitting of LCPs, Reporting Obligations on LCPs.

ECENA Training Workshop

Bristol, March 2008

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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.

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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.

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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

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Permit to Ensure Integrated Approach Specified in IPPC Directive

waste

Raw materials

SO2

CO2

Hg

BOD

water

energy

VOCs

noise

odour

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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.

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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.

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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.

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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).

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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.

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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

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Permit Requirements

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

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Permit Requirements

Environmental Management System (EMS) After 9 months the company must submit a report on

progress towards certification to ISO 14001 or EMAS.

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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.

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Emissions to Air

Turbine uses natural gas with oil as stand-by. NOX was main concern:

Limits were60 mg/m3 on gas125 mg/m3 on oilAnnual mass 640 t

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Emissions to Air

Plant uses low NOX combustion technology. Permit requires continuous monitoring of:

oxides of nitrogen carbon monoxide oxygen

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Emissions to Water

Surface water discharge to be continuously monitored for: flow oil in water pH

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Emissions to Sewer

Wastewater discharges to drained to oil separator.

Discharges to sewer continuously monitored for: flow oil in water pH

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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EPER Map of South Western UK

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EPER E-PRTR

50 Pollutants

56 IPPC Activties

Reports every 3 Years

Emissions into Air and Water

Emissions into Water (indirect)

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

EPER E-PRTR

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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

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Annual Reporting E-PRTR

1. Report2007 2008 2009

Reported year15.6.08

(31.7.08)

Operator to Competent Authority

Competent Authority to National Authority

National Authority to EU COM

15.2.2009

30.6.2009

2. Report2008 2009 2010

Reported year 31.5.09(30.6.09)

31.12.2009

31.3.2010

n. Reportn n + 1 Jahr n + 2 Jahre

Reported year 31.5.n+1(30.6.n+1)

31.3.n+2

31.12.n+1

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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/

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Comparison EPER vs E-PRTR

EPER represents the basis for E-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

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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.

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Questions?