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S21 Notice. Submission by CAIA. Outline. National Air Quality Management Framework Current status of Notice Combustion installations Chemicals Waste Conclusions and Way forward. National Air Quality Management Framework. Standard setting factors to be considered - PowerPoint PPT Presentation
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S21 NoticeS21 Notice
Submission by CAIASubmission by CAIA
OutlineOutline National Air Quality Management FrameworkNational Air Quality Management Framework
Current status of NoticeCurrent status of Notice
Combustion installationsCombustion installations
ChemicalsChemicals
WasteWaste
Conclusions and Way forwardConclusions and Way forward
National Air Quality National Air Quality Management FrameworkManagement Framework
• Standard setting factors to be consideredStandard setting factors to be considered√√ XX Health, safety and environmental objectives Health, safety and environmental objectives√√ Analytical methodologyAnalytical methodologyXX Technical feasibilityTechnical feasibilityX X Monitoring capabilityMonitoring capabilityX X Socio economic consequencesSocio economic consequences
National Air Quality National Air Quality Management Framework (2)Management Framework (2)• Listed activitiesListed activities
XX Informed by cost benefit analysisInformed by cost benefit analysisXX Approach to ensure no unjustified economic Approach to ensure no unjustified economic
impactsimpactsX√X√ BPEO based on BATBPEO based on BATX √ X √ Used for point sources i.e. stacks and ventsUsed for point sources i.e. stacks and vents
National Air Quality National Air Quality Management Framework (3)Management Framework (3)• Compliance timeframesCompliance timeframes
XX Informed by industry cyclesInformed by industry cyclesXX Minimum timeframes ; more restricted Minimum timeframes ; more restricted by by licenselicense√ √ Possible extensionsPossible extensions√√ Atmospheric impact reportAtmospheric impact report
Status of current noticeStatus of current notice• List intended to target activities where List intended to target activities where
economic benefits of regulation outweigh cost economic benefits of regulation outweigh cost of regulation (largely derived from APPA)of regulation (largely derived from APPA)
• Intention to address errors in 2010 Notice Intention to address errors in 2010 Notice • Revised version published for comment in Revised version published for comment in
2012 for comment over December2012 for comment over December• Extension granted to 23 January 2013Extension granted to 23 January 2013• New activities and requirementsNew activities and requirements
Included resulted in significant challengesIncluded resulted in significant challenges
Status of current notice (2)Status of current notice (2)• Compliance timeframesCompliance timeframes
– No recognition given for the fact that errors in No recognition given for the fact that errors in 2010 notice prevented upgrade or that new 2010 notice prevented upgrade or that new requirements have been addedrequirements have been added
– Extent of re-engineering required not possible in Extent of re-engineering required not possible in less than 2 yearsless than 2 years
– Legal certainty essential for planningLegal certainty essential for planning– Multiple postponements do not provide certaintyMultiple postponements do not provide certainty– New requirements in this notice New requirements in this notice
NOx emissions/productionNOx emissions/production
Combustion installationsCombustion installations• Waste as a fuel was not excluded in 2010Waste as a fuel was not excluded in 2010• Consequences of exclusion were not discussedConsequences of exclusion were not discussed• Internationally waste of known composition used Internationally waste of known composition used
as fuel on same site is treated differently from as fuel on same site is treated differently from when incinerated by service provider along with when incinerated by service provider along with other waste of unknown originother waste of unknown origin
• Current practice should be permitted to continue Current practice should be permitted to continue until technical and economic feasibility has been until technical and economic feasibility has been assessedassessed
• Waste regulations prohibit landfill disposal of Waste regulations prohibit landfill disposal of waste that can be used as fuelwaste that can be used as fuel
ChemicalsChemicals10 MARCH 2010 23 NOVEMBER 2012 COMMENT
Organic chemicals industry
Description Minor changes to wording
Limits Total volatile organic compounds (non thermal) mg/Nm3: 40
Total volatile organic compounds (non thermal) mg/Nm3: 40 000
The March 2010 limit was a typing error. It should have been 40g / Nm3. The Department was informed of this error in 2010 and they agreed that it was in fact a mistake.NAQF proposes alternative approach to controlling emissions from bulk storage
Inorganic chemical industry
Production and use in manufacturing of ammonia, fluorine and chlorine gas
Production and use in manufacturing of ammonia, fluorine and chlorine gas, hydrogen cyanide
New process added with limits. Not opposed except for storage
Chemicals (2)Chemicals (2)10 MARCH 2010 23 NOVEMBER 2012
Inorganic
Storage tanks New activity on storage tanks added. Extension beyond chemical industry
Primary production of acids in concentrations exceeding 10%
Production, bulk handling and or use of acids in concentrations exceeding 10%
New activities added which extend beyond chemical industry by the removal of “primary” and inclusion of “use”
Limits: Hydrogen fluoride new and existing
Limit for new plant omitted Assumed to be an error
Production of phosphorus and phosphate salts
Production or use of phosphorus and phosphate salts
New activity on use added
Chemicals (3)Chemicals (3)10 MARCH 2010 23 NOVEMBER 2012
Inorganic
Production of caustic soda New activity added. Caustic soda is made as part of the chlorine production process. No separate process possible.
Burning groundsBurning grounds
• New activity: consequences not discussedNew activity: consequences not discussed• Very specialised activity to achieve Very specialised activity to achieve
compliance with Explosives Actcompliance with Explosives Act• Should not be regulated in a manner Should not be regulated in a manner
conflicting with Explosives Actconflicting with Explosives Act• Should be removed until requirements of Should be removed until requirements of
NAQF are complied with.NAQF are complied with.
ConclusionsConclusions
NAQF not complied with:NAQF not complied with:•Cost benefit analysis of listing not doneCost benefit analysis of listing not done•Best available technology not always Best available technology not always recognisedrecognised•Technical feasibility not doneTechnical feasibility not done•Socio economic consequences not determineSocio economic consequences not determinedd
Way forwardWay forward
• All new activities to be removed until All new activities to be removed until requirements of NAQF have been metrequirements of NAQF have been met
• Compliance timeframes to be reviewedCompliance timeframes to be reviewed• Finalisation of Notice to be done in Finalisation of Notice to be done in
compliance with technical process in NAQFcompliance with technical process in NAQF