european directives’ applicable requirements for ship ......marta walk, helena modrzejewska, cto...

Project co-funded by the European Commission within the Seventh Framework Programme (2007- 2013)

Project No.: CP-266268

Project Acronym: ECO-REFITEC

Project Title: Eco innovative refitting technologies and processes for shipbuilding

industry promoted by European Repair Shipyards

Instrument: Collaborative Project

Thematic Priority: Sustainable Surface Transport

European directives’ applicable requirements for

Ship repair processes. D 1.2

Document Id. ECOREFITEC-D-1.2-2011-05-30-CTO-Analysis EU Directives–

rev-3

Due date of Deliverable: 2011-05-30

Actual Submission Date: 2011-08-19

1

dissemination level

PU Public

PP Restricted to Programme Participants (including Commission Services)

RE Restricted to a group specified by the Consortium (including Commission

Services)

CDP As for ‗Confidential‘, but only for the duration of the Project. After final

Project Approval by the EC, status for reports classified ‗CDP‘ are

automatically down-graded to ‗Public‘

CO Confidential, only for members of the consortium (including Commission

Services)

Marta Walk, Helena Modrzejewska (CTO) Centrum Techniki Okretowej Spolka Akcyjna CTO

-document author- -organization name of lead beneficiary for this deliverable-

Pedro Osle (Astander) ; Thomas Koch (AES) FINAL

-document approved by- -revision type-

2011-08-19 PU1

-date of last update- -distribution level-

European directives‘ applicable requirements for

Ship repair processes.

D 1.2

Document Id. ECOREFITEC-D-1.2-2011-05-30-CTO-Analysis EU Directives–rev-3 of 81

Disclaimer

Use of any knowledge, information or data contained in this document shall be at the user's sole risk. The information

contained in this report is subject to change without notice and should not be construed as a commitment by any members of

the ECO-REFITEC Consortium or the authors. In the event of any software or algorithms being described in this report, the

ECO-REFITEC Consortium assumes no responsibility for the use or inability to use any of its software or algorithms.

The information is provided without any warranty of any kind and the ECO-REFITEC Consortium expressly disclaims all

implied warranties, including but not limited to the implied warranties of merchantability and fitness for a particular use.

This document no may be copied and reproduced without written permission from the ECO-REFITEC Consortium.

Acknowledgement of the authors of the document shall be clearly referenced.

All rights reserved.

Document History

Document ID. Date Description

ECOREFITEC-D-1.2-2011-05-30-CTO-Analysis EU

Directives–rev-0

2011-05-30 First Draft distributed for comments


Directives–rev-1

2011-06-20 Second Draft distributed for comments


Directives–rev-2

2011-07-29 Final Version distributed for internal

review


Directives–rev-3

2011-08-19 Final Version implementing the internal

reviewers comments.



D 1.2


Document Control Sheet

Title: European directives‘ applicable requirements for Ship repair processes

Executive Summary:

Environmental protection is one the priorities of the European Union. Directives are the main policy

instrument for achieving improvement of environmental quality.

HAVING REGARD THAT THE SHIP INDUSTRY HAS A SIGNIFICANT IMPACT ON ALL THE ELEMENTS OF THE

ENVIRONMENT, ACTIVITIES WHICH TAKE PLACE IN SHIPYARDS ARE SUBJECT TO REGULATION THOUGHT

THE EUROPEAN ENVIRONMENTAL LAW.

The main legal European instruments for protecting the environment, in regard to major operations in

shipyards are the following directives:

the Water Framework Directive (WFD) - for water protection

the Directive on the Limitation of Emissions of Volatile Organic Compound (SED) - for air

protection

the Directive on industrial emissions (integrated pollution prevention and control) (IPPC

directive) (covering among other issues, the soil protection)

the Waste Framework Directive where the issue of waste produced during shipyard operations

is covered in.

and the followings regulations:

European pollutant release and transfer register regulation, and

Regulation on the prohibition of organotin compounds on ships.

As these directives and regulations are subject to continual updating, THE VALUE ADDED TO

ECO_REFITEC BY THIS DELIVERABLE IS THE ANALYSIS OF THE MOST RECENT AND APPLICABLE

EUROPEAN REQUIREMENTS CONCERNING SHIP REPAIR PROCESSES. On the basis of conducted analysis,

they have been specified emission standards, prohibitions, responsibilities, and obligations for the ship

repair shipyards. Among others the followings:

There is a Prohibition on using harmful organotin compound in the shipyards.

Shipyards must begin to assess their use of water resources and the impact of the business on

the water environment. They should also begin to review the composition of all losses to water.

Shipyards (waste original producer) are responsible for the proper waste management even

when the waste is transferred to another legal person of the treatment chain.

Shipyards must hold a permit by each installation,

Shipyards must report annually to the European Pollutant Release and Transfer the amounts of

releases to air, water and land of any pollutant specified in Annex II of Regulation 166/2006 for

which the applicable threshold value specified in Annex II is exceeded.

Substances or mixtures which, because of their content of VOCs are assigned or need to carry the hazard

statements H340, H350, H350i, H360D or H360F shall be replaced, as far as possible by less harmful

substances or mixtures within the shortest possible time.

…

As it was indicated above, this Deliverable provides the identification of applicable regulation and their

interpretation regarding the ―needs‖ of shipyards and the Eco-REFITEC project. But, THE

IDENTIFICATION OF CHANGES IN THE LAW, AMBIGUITIES IN THE LEGISLATION, AND UNRESOLVED

PROBLEMS ARE VALUES ADDED TO ECO_REFITEC BY THIS DELIVERABLE AS WELL. To be noted that

directives as master documents cover a very broad areas of activities and ways to solve the problems



D 1.2


they set out. This often involves the ambiguity of records, requiring additional guidance and

interpretation, which may vary in each European country.

Some unresolved problems are the followings:

Ship repair industry is harmed by the lack of clear criteria for best available techniques and

supervisory authorities have difficulties in taking a decision about the use of the best available

techniques by operators.

To be noted that, in certain situation, as when the coating activities cannot be carried out under

contained conditions, the operator must demonstrate that the best available technique is being

used.

The operators, engaged in ship repair in most cases are unable to control the type and

quantities, of the substances used in the activities. It leads not only to inaccurate data in the

plans for solvent usage preparation but also to insufficiently correct final results and

conclusions regarding the environmental pollution by volatile organic compounds.

The plan to reduce emissions of volatile organic compounds which should lead to reduce the

annual VOC emissions from existing installations is not easily applicable in the ship-repair

sector as consequence of the strongly market depended ship repair work with peaks and valleys.

AS CONCLUSION, THIS DELIVERABLE RELATES TO THE FINAL TARGETED RESULTS OF ECO-REFITEC

SUPPORTING THE EUROPEAN REPAIR SHIPYARD SECTOR IN THE FIELD OF ENVIRONMENTAL

PROTECTION.

The knowledge of EU environmental requirements is essential for the accomplishment of the

project.

The study of the relevance of directives and regulation with regard to the shipyards‘ activities

help in determining the legislative limits, which the shipyards will have to operate within.

The legislation analysis has lead to the conclusion that directives are not applicable to research

activities, development activities or testing of new products and processes. Determination of

legislation rules concerning utilization of eco-innovative processes, structures, materials and

modules in the stage of testing in shipyard can be an encouragement for deciding to introduce

changes during operations.

Work carried out by Approved by

Marta Walk, Helena Modrzejewska, CTO

Rima Mickiewicz, Audrone Zukauskaite, KU

Marco Antonio Estrela, ISQ

Dig Vijay Singh, SU

Nedelcho Vichev, VSTU

Francisco del Castillo, SOERMAR

Pedro Osle (ASTANDER) - name of first internal reviewer

- signature on file -

- signature of first internal reviewer and date of acceptance -

Thomas Koch (AES) - name of second internal reviewer

- signature on file -

- signature of second reviewer and date of acceptance -



D 1.2


Contents

1 Introduction .............................................................................................................................. 6

1.1 Task description ............................................................................................................................... 7

1.2 Related Eco_REFITEC Tasks .......................................................................................................... 7

2 List of Glossary (abbreviations) .............................................................................................. 8

2.1 Abbreviations ................................................................................................................................... 8

2.2 Symbols ........................................................................................................................................... 9

3 Definitions ............................................................................................................................... 10

4 EU Waters directive applicable to repair shipyards ........................................................... 15

4.1 Water Framework Directive 2000/60/EC Analysis ....................................................................... 15

5 EU Waste directive applicable to repair shipyards ............................................................ 22

5.1 Waste Framework Directive 2008/98/EC Analysis ....................................................................... 22

6 EU directive on the limitation of emissions of VOC applicable to repair shipyards ....... 26

6.1 Council Directive 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile

organic compound due to the use of organic solvent in certain activities and installations.

/SED ............................................................................................................................................... 27

7 EU directive concerning IPPC applicable to repair shipyards .......................................... 40

7.1 Directive 2008/1/EC of the European Parliament and the Council of 15 January 2008

concerning integrated pollution prevention control (codified version) .......................................... 40

8 EU directive on industrial emissions applicable to repair shipyards ................................ 45

8.1 Directive 2010/75/EU of the European Parliament and the Council of 24 November 2010 on

industrial emissions (integrated pollution prevention and control) (Recast). ................................ 45

9 EU Regulation concerning the establishment of the European Pollutant Release

and Transfer Register ............................................................................................................ 61

9.1 Regulation (EC) No 166/2006 of the European Parliament and the Council of 18 January

2006 concerning the establishment of the European Pollutant Release and Transfer Register

and amending Council directives 91/689/EEC and 96/61/EC. ...................................................... 61

10 EU Regulation on the prohibition of organotin compounds on ships ............................... 64

10.1 Regulation (EC) No 782/2003 of the European Parliament and the Council of 14 April 2003

on the prohibition of organotin compounds on ships amended by Commission Regulation

(EC) No 536/2008 of 13 June 2008 ............................................................................................... 64

11 Conclusions ............................................................................................................................. 66

11.1 Summary of specified emission standards, prohibitions, responsibilities, and obligations for

the ship repair shipyards ................................................................................................................ 66

11.2 Changes in the law and implications.............................................................................................. 68

11.3 Ambiguities in the legislation: Unresolved problems ................................................................... 69

11.4 Utilizing of eco-innovations in ship repair sector .......................................................................... 70

12 Attachments ............................................................................................................................ 71

12.1 Attachment 1: EU list of priority substances in the field of water policy ..................................... 71

12.2 Attachment 2: Environmental quality standards for priority substances and certain other

pollutants ........................................................................................................................................ 73

12.3 Attachment 3: Categories of activities Listed in the IED Directive- Annex I ............................... 77

12.4 Attachment 3: List of References................................................................................................... 80



D 1.2


1 Introduction

Shipping and vessels are essential for international trade. Approximately 90% of goods in trade with

partners outside the European Union is transported by sea, in the case of trade within the Union the

proportion is over 40%. It has been considered that ships are the most environmentally friendly means of

transport but there is no doubt that they still affect the environment in the entire life cycle.

Aiming at decreasing ships‘ influence in the stage of exploitation International Maritime Organisation

(IMO) has been preparing environmental requirements and publishing them in conventions. An existing

fleet in order to fulfil new requirements needs to be rebuild and/or reequipped, in other words refitted and

retrofitted in repair shipyards. On the other hand repair shipyards are obliged to respect national and

international environmental law.

Neither insurance of high level of environment protection nor improvement of environmental quality can

be sufficiently achieved by one country (due to transboundary nature of pollution from industrial activities)

but can be achieved at the Union level. Therefore, the European Community has been preparing

environmental requirements and publishing them in directives, which generally have precedence over

national regulations. Directives are constantly updated having regard to development in the scope of

environmental protection.

The purpose of this task is to conduct an overview of relevant EU directives and appropriate regulations to

shape the limits of the existing legislation, showing the requirements for the ship industry, in particular:

Water Framework Directive 2006/60/EC,

Waste Framework Directive 2008/98/EC,

Directive 1999/13/EC on the limitation of emissions of volatile organic compound due to the use of

organic solvent in certain activities and installations,

Directive on industrial emissions (integrated pollution prevention and control) 2008/1/EC,

Directive on industrial emissions (integrated pollution prevention and control) (Recast).

2010/75/EU,

European pollutant release and transfer register regulation 2006/166/EC,

Regulation on the prohibition of organotin compounds on ships 2008/536/EC.

The aim of this task will be to state, basing on the EU directives and regulation, the emission standards for

the typical processes performed in repair shipyards and prohibitions to avoid harmful effects on the

environment as well as responsibilities and obligations imposed on the shipyards due to use of water and

production of waste.

The results of this task will help the shipyards to assess compliance of their process‘s performance with and

rules, as well as point activities which might require slight modification or serious changes.

Furthermore, the results of this task can be useful to determine legislation rules concerning utilizing of eco-

innovative structures, materials, modules and processes in the stage of research, development and testing in

shipyard.



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1.1 Task description

Retrofitting existing vessels with environmentally neutral technologies is a huge challenge to face by

European repair shipyards. Technological processes and technologies utilised in ships maintenance and

repair works i.e.: steel replacement (metal working and cutting, surface preparation/blasting, welding),

protective coating application, bilge and tank cleaning, shipboard equipment repairs and reconditioning

characterise with significant impact on environment. Emissions from shipyards are subject to national and

international laws. In the European Union the emissions are regulated by the European Environmental

Policy, published in 1996, and confirmed and strengthened by a series of Directives for various sources of

pollution, which have recently been substantially toughened.

European shipyards come under the legislative requirements of different directives and need to conform to

the subsequent standards laid down. The following newest and already enforced directives and regulation

have been taken into account during the study:

Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000

establishing a framework for Community action in the field of water policy,

Waste Framework Directive 2008/98/EC.

Council Directive 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile organic

compound due to the use of organic solvent in certain activities and installations/SED.

Directive 2008/1/EC of the European Parliament and the Council of 15 January 2008 concerning

integrated pollution prevention control /IPPCD.

Directive 2010/75/EU of the European Parliament and the Council of 24 November 2010 on

industrial emissions (integrated pollution prevention and control) (Recast) /IED,

Regulation (EC) No 166/2006 of the European Parliament and the Council of 18 January 2006

concerning the establishment of the European Pollutant Release and Transfer Register and

amending Council directives 91/689/EEC and 96/61/EC.

Regulation (EC) No 782/2003 of the European Parliament and the Council of 14 April 2003 on the

prohibition of organotin compounds on ships.

1.2 Related Eco_REFITEC Tasks

The deliverable 1.2 constitutes the base to the Task 1.3 ―Retrofits according to new IMO and EU

environmental regulation-risk assessment for shipyard‖.

The deliverable 1.2 can be taken into account during performance of Tasks: 2.2 - 2.4 concerning value

engineering of Eco-innovation: processes, structures, materials and modules for ship retrofit. It can come in

useful to the WP 4.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32000L0060:EN:NOT





http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=Regulation&an_doc=2006&nu_doc=166

http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=Directive&an_doc=1991&nu_doc=689


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003R0782:20080704:EN:PDF



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2 List of Glossary (abbreviations)

2.1 Abbreviations

Table 1: Abbreviations.

Abb. Term

BAT Best Available Techniques

BREF Best Available Techniques Reference Document

E-PRTR European Pollutant Release and Transfer Register

EQS Environmental quality standards

ELV Emission limit values

EU European Union

IED Directive on industrial emissions (integrated pollution prevention and control)

IPPC Integrated Pollution Prevention and Control

IMO International Maritime Organisation

NPTC Normal pressure and temperature conditions. Conditions where the pressure is

101.3 kPa (1 atmosphere) and the temperature is 25ºC (77ºF or 298.15 K).

PRTR Pollutant Release and Transfer Register

SED Directive on the limitation of emissions of volatile organic compound

VOC

Volatile organic compounds

Note:

A major source of man-made VOCs are solvents, especially paints and protective

coatings. Typical solvents are aliphatic hydrocarbons, ethyl acetate, glycol ethers, and

acetone.

WFD Water Framework Directive

R45 Special Risk Phrase attributed to dangerous substances and preparations which

May cause cancer


May cause heritable genetic damage


May cause cancer by inhalation


May impair fertility


May cause harm to the unborn child


May cause Possible risk of irreversible effects



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Table 1: Abbreviations.

Abb. Term

H340 Special Hazard Statement attributed to chemical substances and mixtures which

May cause genetic defects

H341 Special Hazard Statement attributed to chemical substances and mixtures

Suspected of causing genetic defects


May cause cancer

H351 Special Hazard Statement attributed to chemical substances and mixtures

Suspected of causing cancer


May damage fertility or the unborn child

2.2 Symbols

Table 2: Abbreviations and Symbols

Abb. Term

mg milligram

mg C Milligram of organic Carbon

m3 cubic metre

Nm3 cubic metres at NPTC

ppm parts per million by volume

mg C/Nm3 Volumetric Concentration. Milligram of solvent (VOC) by cubic metres at

NPTC (Normal pressure and temperature conditions)

mg/Nm3 Milligram of solvent (other than VOC) by cubic metres at NPTC

Note: mg/Nm3 = ppm x Molecular Weight of the gas x 0.0409



D 1.2


3 Definitions

Table 3: Definitions of Key Terms

Term Definition

AFS-Convention Means the International Convention on the control of harmful anti-fouling

systems on ships, adopted on 5 October 2001.

Atmospheric pollution Alteration of the normal composition of the air caused by the presence in

the atmosphere of one or more substances which have been added directly

or indirectly by man or by natural sources in amounts, or of a nature or

duration, which are sufficient to adversely affect flora and fauna, materials

and man himself.

Atmospheric emissions Releases or discharges into the atmosphere of particles, gases or forms of

energy, emanating from a stationary or moving source.

Best available

techniques (**)

Means best available techniques as defined in Article 2(11) of Directive

96/61/EC.

Body of groundwater (*) Means a distinct volume of groundwater within an aquifer or aquifers.

Body of surface water

(*)

Means a discrete and significant element of surface water such as a lake, a

reservoir, a stream, river or canal, part of a stream, river or canal,

transitional water or a stretch of coastal water.

Coastal water (*) Means surface water on the landward side of a line, every point of which is

at a distance of one nautical mile on the seaward side from the nearest point

of the baseline from which the breadth of territorial waters is measured,

extending where appropriate up to the outer limit of transitional waters.

Combined approach (*) Means the control of discharges and emissions into surface waters

according to the approach set out in Article 10.

Dealer (**) Means any undertaking which acts in the role of principal to purchase and

subsequently sell waste, including such dealers who do not take physical

possession of the waste;

Ecological status (*) Is an expression of the quality of the structure and functioning of aquatic

ecosystems associated with surface waters, classified in accordance with

Annex V.

Emission controls(*) Are controls requiring a specific emission limitation, for instance an

emission limit value, or otherwise specifying limits or conditions on the

effects, nature or other characteristics of an emission or operating

conditions which affect emissions. Use of the term emission control. in this

Directive in respect of the provisions of any other Directive shall not be

held as reinterpreting those provisions in any respect.



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Term Definition

Emission limit values (*) (ELV) Means the mass, expressed in terms of certain specific parameters,

concentration and/or level of an emission, which may not be exceeded

during any one or more periods of time. Emission limit values may also be

laid down for certain groups, families or categories of substances, in

particular for those identified under Article 16. The emission limit values

for substances shall normally apply at the point where the emissions leave

the installation, dilution being disregarded when determining them. With

regard to indirect releases into water, the effect of a waste-water treatment

plant may be taken into account when determining the emission limit

values of the installations involved, provided that an equivalent level is

guaranteed for protection of the environment as a whole and provided that

this does not lead to higher levels of pollution in the environment.

Environmental

objectives (*)

Means the objectives set out in Article 4.

Environmental quality

standard (*)

Means the concentration of a particular pollutant or group of pollutants in

water, sediment or biota which should not be exceeded in order to protect

human health and the environment.

EU Directive A directive is a legislative act of the European Union, which requires

member states to implement (implementation) specific regulation to

achieve, specified in the directive, the desired state of affairs. Directives

can be adopted by a variety of means of legislative procedures depending

on their subject matter.

Notes:

1. Directives normally leave member states with a certain amount of

leeway as to the exact rules to be adopted. In other words, directives oblige

member states to achieve a particular result without dictating the means of

achieving it.

2. It should be noted that the directives give guidelines and guideposts that

are transposed to the national law of member states and only the national

legislation oblige shipyards to particular proceeding within the scope of

directives.

EU Regulations In contrast to directives, regulation are self-executing and do not require

any implementing measures.

Notes:

1. Regulation apply to all member states with no need to transpose its

provisions into national legal systems.

Good surface water

chemical status (*)

Means the chemical status required to meet the environmental objectives

for surface waters established in Article 4(1)(a), that is the chemical status

achieved by a body of surface water in which concentrations of pollutants

do not exceed the environmental quality standards established in Annex IX

and under Article 16(7), and under other relevant Community legislation

setting environmental quality standards at Community level.



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Term Definition

Good surface water

status (*)

Means the status achieved by a surface water body when both its ecological

status and its chemical status are at least good.

Groundwater (*) Means all water which is below the surface of the ground in the saturation

zone and in direct contact with the ground or subsoil.

Hazard statements Form part of the Globally Harmonized System of Classification and

Labelling of Chemicals (GHS). They are intended to form a set of

standardized phrases about the hazards of chemical substances and

mixtures that can be translated into different languages. As such, they serve

the same purpose as the well-known R-phrases which they are intended to

replace.

Hazard statements are one of the key elements for the labelling of

containers under the GHS.

Each hazard statement is designated a code, starting with the letter H and

followed by three digits. Statements which correspond to related hazards

are grouped together by code number, so the numbering is not consecutive.

The code is used for reference purposes, for example to help with

translations, but it is the actual phrase which should appear on labels and

safety data sheets.

Hazardous substances

(*)

Means substances or groups of substances that are toxic, persistent and

liable to bio-accumulate, and other substances or groups of substances

which give rise to an equivalent level of concern.

Hazardous waste (**) Means waste which displays one or more of the hazardous properties listed

in Annex III.

Heavily modified water

body (*)

Means a body of surface water which as a result of physical alterations by

human activity is substantially changed in character, as designated by the

Member State in accordance with the provisions of Annex II.

Inland water (*) Means all standing or flowing water on the surface of the land, and all

groundwater on the landward side of the baseline from which the breadth of

territorial waters is measured.

Maximum permissible

limits

Values or parameters which establish the maximum degree of concentration

of pollutants which can be discharged or emitted into the atmosphere by a

stationary point source.

Pollutant (*) Means any substance liable to cause pollution, in particular those listed in

Annex VIII.

Pollution (*) Means the direct or indirect introduction, as a result of human activity, of

substances or heat into the air, water or land which may be harmful to

human health or the quality of aquatic ecosystems or terrestrial ecosystems

directly depending on aquatic ecosystems, which result in damage to

material property, or which impair or interfere with amenities and other

legitimate uses of the environment.

Priority substances (*) Means substances identified in accordance with Article 16(2) and listed in

Annex X. Among these substances there are .priority hazardous substances

which means substances identified in accordance with Article 16(3) and (6)

for which measures have to be taken in accordance with Article 16(1) and

(8).

http://en.wikipedia.org/wiki/Globally_Harmonized_System_of_Classification_and_Labelling_of_Chemicals

http://en.wikipedia.org/wiki/Globally_Harmonized_System_of_Classification_and_Labelling_of_Chemicals



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Term Definition

Risk phrases Nature of special risks attributed to dangerous substances and preparations.

Note:

R Phrases are defined in Annex III of European Union Directive

67/548/EEC. The list was consolidated and republished in Directive

2001/59/EC, where translations into other EU languages may be found.

River basin(*) The area of land from which all surface run-off flows through a sequence of

streams, rivers and, possibly, lakes into the sea at a single river mouth,

estuary or delta.

River basin district(*) The area of land and sea, made up of one or more neighbouring river basins

together with their associated ground waters and coastal waters, which is

identified under Article 3(1) as the main unit for management of river

basins.

Stationary sources Buildings, structures or plants sited permanently in a single place which

emit, or can emit, any kind of pollutant.

Stationary point source A stationary source whose emissions are discharged into the atmosphere

via a flue or chimney.

Surface water (*) Means inland waters, except groundwater; transitional waters and coastal

waters, except in respect of chemical status for which it shall also include

territorial waters.

Transitional waters (*) Are bodies of surface water in the vicinity of river mouths which are partly

saline in character as a result of their proximity to coastal waters but which

are substantially influenced by freshwater flows.

Treatment (**) Means recovery or disposal operations, including preparation prior to

recovery or disposal.

Water intended for

human consumption (*)

Has the same meaning as under Directive 80/778/EEC, as amended by

Directive 98/83/EC.

Waste (**) Means any substance or object which the holder discards or intends or is

required to discard.

Waste holder (**) Means the waste producer or the natural or legal person who is in

possession of the waste.

Waste management (**) Means the collection, transport, recovery and disposal of waste, including

the supervision of such operations and the after-care of disposal sites, and

including actions taken as a dealer or broker.

Waste oils (**) Means any mineral or synthetic lubrication or industrial oils which have

become unfit for the use for which they were originally intended, such as

used combustion engine oils and gearbox oils, lubricating oils, oils for

turbines and hydraulic oils.

Waste producer (**) Means anyone whose activities produce waste (original waste producer) or

anyone who carries out pre-processing, mixing or other operations resulting

in a change in the nature or composition of this waste.

http://en.wikipedia.org/wiki/Directive_67/548/EEC

http://en.wikipedia.org/wiki/Directive_67/548/EEC

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0059:EN:HTML

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0059:EN:HTML



D 1.2



Term Definition

Water services (*) Means all services which provide, for households, public institutions or any

economic activity: (a) abstraction, impoundment, storage, treatment and

distribution of surface water or groundwater, (b) waste-water collection and

treatment facilities which subsequently discharge into surface water.

Water use (*) Means water services together with any other activity identified under

Article 5 and Annex II having a significant impact on the status of water.

This concept applies for the purposes of Article 1 and of the economic

analysis carried out according to Article 5 and Annex III, point (b).

(*) According with DIRECTIVE 2000/60/EC definitions

(**) According with DIRECTIVE 2008/98/EC definitions



D 1.2


4 EU Waters directive applicable to repair shipyards

The purpose of this section is to establish a framework for the protection of inland surface waters,

transitional waters, coastal waters and groundwater.

4.1 Water Framework Directive 2000/60/EC Analysis

The EC Water Framework Directive, which came into force on 22nd of December 2000, establishes a new,

integrated approach to protection, improvement and sustainable use of European rivers, lakes, estuaries,

coastal waters and groundwater.

Compliance with the provisions of the directive should lead to progressive reduction of emissions of

hazardous substances into waters, and ultimately, to the elimination of the water environment the priority

hazardous substances.

Protection of groundwater against pollution caused by certain dangerous substances is an important task.

'Good chemical status' for surface water bodies is the aim included in the objectives of the Water

Framework Directive to achieve by 2015. A body would obtain ‗good chemical status‘ if it met all of the

environmental quality standards for priority substances and certain other pollutants.

For that purpose, water management plans as well as water and environmental programs in which include

repair yards are developed in individual member countries.

Compliance with the provisions of the Directives is of particular importance in the yard, since their

existence and functioning is directly related to the coastal, surface and underground waters, and thus their

impact on water quality is important.

The Directive has been amended by:

Decision No 2455/2001/EC of the European Parliament and of the Council of 20 November 2001

establishing the list of priority substances in the field of water policy and amending Directive

2000/60/EC.

Directive 2008/32/EC of the European Parliament and of the Council of 11 March 2008 amending

Directive 2000/60/EC establishing a framework for Community action in the field of water policy,

as regards the implementing powers conferred on the Commission.

Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on

environmental quality standards in the field of water policy, amending and subsequently repealing

Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and

amending Directive 2000/60/EC of the European Parliament and of the Council.

Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the

geological storage of carbon dioxide and amending Council Directive 85/337/EEC, European

Parliament and Council Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC, 2008/1/EC

and Regulation (EC) No 1013/2006.

Note:

The new Groundwater Directive (Directive 2006/118/EC) and Environmental Quality Standards Directive

(Directive 2008/105/EC) are the daughter directives to this Directive.



D 1.2


4.1.1 Detailed discussions of the Directive

Detailed discussion of the Directive in regard to repair shipyard is provided in the next table.

Table 4: Detailed discussion of Water Framework Directive 2000/60/EC.

Specification Quotations / Consequences for

shipyards Comments

Date of

entry

into

force

Introduction,

paragraph 27

The ultimate aim of this Directive is to

achieve the elimination of priority hazardous

substances and contribute to achieving

concentrations in the marine environment

near background values for naturally

occurring substances.

Shipyards must remove

pollutants from all emissions

to the water environment

Decision No 2455/2001/EC

of the European Parliament

and of the Council of 20

November 2001 establishing

the list of priority substances

in the field of water policy.

This list was later on

replaced by the text set out

in Annex II to Directive

2008/105/EC.

(See attachment 1)

2000.12.22

Introduction,

paragraph 39

There is a need to prevent or reduce the

impact of incidents in which water is

accidentally polluted. Measures with the aim

of doing so should be included in the

programme of measures.

The Directive will require

the complete cessation or

phase-out of such emissions,

particularly when these

derive from human

activities.

2000.12.22

Introduction,

paragraph 43

Pollution through the discharge, emission or

loss of priority hazardous substances must

cease or be phased out. The European

Parliament and the Council should, on a

proposal from the Commission, agree on the

substances to be considered for action as a

priority and on specific measures to be taken

against pollution of water by those

substances, taking into account all

significant sources and identifying the cost-

effective and proportionate level and

combination of controls.

2000.12.22

Introduction,

paragraph 45

Member States should adopt measures to

eliminate pollution of surface water by the

priority substances and progressively to

reduce pollution by other substances which

would otherwise prevent Member States

from achieving the objectives for the bodies

of surface water.

2000.12.22

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001D2455:EN:NOT



D 1.2




shipyards Comments

Date of

entry

into

force

Article 1.

Purpose (c, d)

This directive

- aims at enhanced protection and

improvement of the aquatic environment,

inter alia, through specific measures for

the progressive reduction of discharges,

emissions and losses of priority

substances and the cessation or phasing-

out of discharges, emissions and losses

of the priority hazardous substances;

- ensures the progressive reduction of

pollution of groundwater and prevents its

further pollution and thereby contributes

to:

- a significant reduction in pollution of

groundwater,

- the protection of territorial and

marine waters, and

- achieving the objectives of relevant

international agreements, including

those which aim to prevent and

eliminate pollution of the marine

environment, by Community action

under Article 16(3) to cease or phase

out discharges, emissions and losses

of priority hazardous substances, with

the ultimate aim of achieving

concentrations in the marine

environment near background values

for naturally occurring substances

and close to zero for man-made

synthetic substances.

Shipyards use priority

substances issues for

shipyards are mostly related

to waste water containing

priority substances like

PAHs, TBT, Mercury,

Copper and Zinc; coming

from point sources, diffuse

sources or losses.

2000.12.22



D 1.2




shipyards Comments

Date of

entry

into

force

Article 4.

Environmental

objectives, 1

(a) for surface waters

(b) for ground water

(c) for protected areas

Member States shall protect and enhance all

artificial and heavily modified bodies of

water, with the aim of achieving good

ecological potential and good surface water

chemical status at the latest 15 years.

Member States shall implement the

measures necessary to prevent or limit the

input of pollutants into groundwater and to

prevent the deterioration of the status of all

bodies of groundwater, subject to the

application of paragraphs 6 and 7 and

without prejudice to paragraph 8 of this

Article and subject to the application of

Article 11(3)(j);

Member States shall achieve compliance

with any standards and objectives at the

latest 15 years after the date of entry into

force of this Directive, unless otherwise

specified in the Community legislation

under which the individual protected areas

have been established.

The most recent publication

of the EU list of priority

water pollutants to be

controlled under the WFD,

raises concern about the cost

of reducing or removing

emissions to water of certain

specified pollutants.

(See attachment 2).

Waste water should be

treated (see references in

section 8.15 BREF).

2000.12.22

Deadline

2015



D 1.2




shipyards Comments

Date of

entry

into

force

Article 4.

Environmental

objectives,

paragraph 5 (a, b, c).

Member States may aim to achieve less

stringent environmental objectives than

those required under paragraph 1 for specific

bodies of water when they are so affected by

human activity, as determined in accordance

with Article 5(1), or their natural condition

is such that the achievement of these

objectives would be infeasible or

disproportionately expensive, and all the

following conditions are met:

(a) the environmental and socioeconomic

needs served by such human activity

cannot be achieved by other means,

which are a significantly better

environmental option not entailing

disproportionate costs;

(b) Member States ensure,

- for surface water, the highest

ecological and chemical status

possible is achieved, given impacts

that could not reasonably have been

avoided due to the nature of the

human activity or pollution,

- for groundwater, the least possible

changes to good groundwater

status, given impacts that could not

reasonably have been avoided due

to the nature of the human activity

or pollution;

(c) no further deterioration occurs in the

status of the affected body of water;

It is suppose, that shipyards

would get in that range.

2000.12.22

Article 9.

Recovery of costs for

water services,

paragraph 1

Water-pricing policies provide adequate

incentives for users to use water resources

efficiently, and thereby contribute to the

environmental objectives of this Directive.

Industry must begin to

assess their use of water

resources and the impact of

the business on the water

environment. They should

also begin to review the

composition of all losses to

water.

2000.12.22



D 1.2




shipyards Comments

Date of

entry

into

force

Article 11.

Programme of

measures,

paragraph 3

For point source discharges liable to cause

pollution, a requirement for prior regulation,

such as a prohibition on the entry of

pollutants into water, or for prior

authorisation, or registration based on

general binding rules, laying down emission

controls for the pollutants concerned,

including controls in accordance with

Articles 10 and 16. These controls shall be

periodically reviewed and, where necessary,

updated;

For diffuse sources liable to cause pollution,

measures to prevent or control the input of

pollutants.

Shipyards, like all water

consumers, will have a new

responsibility in the future to

minimise their impact on the

water environment. They

will have to remove small

amounts of contaminants

found in waste water, they

will be obliged to remove

such traces at source.

2000.12.22

Article 16. Strategies

against pollution of

water paragraph 1,2

The European Parliament and the Council

shall adopt specific measures against

pollution of water by individual pollutants or

groups of pollutants presenting a significant

risk to or via the aquatic environment,

including such risks to waters used for the

abstraction of drinking water. For those

pollutants measures shall be aimed at the

progressive reduction and, for priority

hazardous substances, as defined in Article

2(30), at the cessation or phasing-out of

discharges, emissions and losses

To be aware that nowadays

Shipyards use substances

from priority substances list.

2000.12.22

Article 16. Strategies

against pollution of

water, paragraph 6

For the priority substances, the Commission

shall submit proposals of controls for: the

progressive reduction of discharges,

emissions and losses of the substances

concerned, and, in particular the cessation or

phasing-out of discharges, emissions and

losses of the substances as identified in

accordance with paragraph 3, including an

appropriate timetable for doing so.

The timetable shall not exceed 20 years after

the adoption of these proposals by the

European Parliament and the Council in

accordance with the provisions of this

Article

Shipyards use substances

from priority substances list.

WFD (see attachment 1)

require to identify hazardous

material among the priority

substances

2000.12.22



D 1.2




shipyards Comments

Date of

entry

into

force

Article 16.

Strategies against

pollution of water,

paragraph 8

The Commission shall submit proposals, in

accordance with paragraphs 6 and 7, and at

least for emission controls for point sources

and environmental quality standards within

two years of the inclusion of the substance

concerned on the list of priority substances

Article 16 of the Water

Framework Directive

2000/60/EC (WFD) sets out

a strategy for dealing with

chemical pollution of water.

As a first step of this

strategy, a list of priority

substances was adopted

(Decision 2455/2001/EC)

identifying 33 substances of

priority concern at

Community level.

2000.12.22

Article 17.

Strategies to prevent

and control pollution

of groundwater,

paragraph 1

The European Parliament and the Council

shall adopt specific measures to prevent and

control groundwater pollution. Such

measures shall be aimed at achieving the

objective of good groundwater chemical

status in accordance with Article 4(1)(b) and

shall be adopted, acting on the proposal

presented within two years after the entry

into force of this Directive, by the

Commission in accordance with the

procedures laid down in the Treaty

Shipyards must relate to

provisions for groundwater,

when using of groundwater

resources.

2000.12.22



D 1.2


5 EU Waste directive applicable to repair shipyards

Former Directive 2006/12/EC on waste was revised by Directive 2008/98/EC in order to modernise and

streamline its initial provisions.

The revised Directive 2008/98/EC, which it is analyses below, sets the basic concepts and definitions

related to waste management and lays down waste management principles such as the "polluter pays

principle" or the "waste hierarchy".

5.1 Waste Framework Directive 2008/98/EC Analysis

Directive of the European Parliament on waste, which came into force in December 2008, establishes the

essential requirements for waste management, state obligations and responsibilities of waste generators and

defines key concepts such as waste, hazardous waste, waste oil, waste recovery and disposal.

It sets out key principles of dealing with waste in such a way that they have no a negative impact on the

environment and establishes a requirement that the cost of the waste disposal must be borne by the holder

of the waste or the waste producers.

Repair shipyards, due to the profile of their activities, produce waste, hazardous waste and waste oils

(hydraulic, engine, gear, lubricants, bilge from the wharves and ships). Hazardous waste produced and

collected in the yard is primarily waste from paint and varnish, waste emulsions of metalworking, brake

fluids, transformers, asbestos-containing materials.

Proper waste management is a difficult task and requires considerable knowledge about the existing

legislation.

Member states were obliged to bring into force the laws, regulations and administrative provisions to

comply with this Directive no later than 12 December 2010.



D 1.2


Detailed discussion on the Directive in regard to repair shipyard is given in the following table.

Table 5: Detailed discussion of Waste Framework Directive 2008/98/EC.


shipyards Comments

Date of

entry

into

force

Article 3.

Definition of

―waste producer‖,

paragraph 5

Shipyards are within the definition. See definition in section 2. 2010.12.12

Article 3.

Definition of

―waste holder‖,

paragraph 6

Shipyards are within the definition. See definition in section 2. 2010.12.12

Article 4. Waste

hierarchy,

paragraph 1

The following waste hierarchy shall apply as a

priority order in waste prevention and

management legislation and policy:

(a) prevention;

(b) preparing for re-use;

(c) recycling;

(d) other recovery (e.g. energy recovery);

and

(e) disposal.

Waste hierarchy to take into

account when shipyards

proceed with the

management of their own

non-hazardous waste.

2010.12.12

Article 13.

Protection of

human health and

the environment,

paragraph 1

Member States shall take the necessary

measures to ensure that waste management is

carried out without endangering human health,

without harming the environment and, in

particular:

(a) without risk to water, air, soil, plants or

animals;

(b) without causing a nuisance through noise

or odours; and

(c) without adversely affecting the

countryside or places of special interest.

Principles for the protection

of human health and the

environment to take into

account when shipyards

proceed with the

management of their own


2010.12.12

Article 14.

Responsibility for

waste management

costs , paragraph 1

In accordance with the polluter-pays principle,

the costs of waste management shall be borne

by the original waste producer (shipyards) or

by the current or previous waste holders.

In this case the shipyards are

financial responsible for the

waste management costs.

2010.12.12

Article 14.

Responsibility for

waste management

costs, paragraph 2

Member States may decide that the costs of

waste management are to be borne partly or

wholly by the producer of the product from

which the waste came and that the distributors

of the product may share these costs.

(extended producer responsibility)

In this case the shipyards

aren‘t financial responsible

for the waste management

costs.

2010.12.12



D 1.2




shipyards Comments

Date of

entry

into

force

Article 15.

Responsibility for

waste management,

paragraph 1


measures to ensure that any original waste

producer (shipyards) or other holder carries

out the treatment of waste himself or has the

treatment handled by a dealer or an

establishment or undertaking which carries out

waste treatment operations or arranged by a

private or public waste collector in accordance

with Articles 4 and 13.

The extended producer

responsibility shall be

applied without prejudice to

the responsibility for waste

management as provided in

this Article.

2010.12.12

Article 15.

Responsibility for

waste management,

paragraph 2

When the waste is transferred from the

original producer (shipyards) or holder to one

of the natural or legal persons referred to in

Article 15, paragraph 1 for preliminary

treatment, the responsibility for carrying out a

complete recovery or disposal operation shall

not be discharged as a general rule.

However, Member States may specify the

conditions of responsibility and decide in

which cases the original producer (shipyards)

is to retain responsibility for the whole

treatment chain or in which cases the

responsibility may be shared or delegated.

The shipyards may continue

to be responsible for the

proper waste management

even when the waste is

transferred to another legal

person of the treatment

chain.

2010.12.12

Article 15.

Responsibility for

waste management,

paragraph 3

Member States may decide that the

responsibility for arranging waste

management is to be borne partly or wholly by

the producer of the product from which the

waste came and that distributors of such

product may share this responsibility.

In this case the shipyards

aren‘t responsible for

arranging the waste

management.

2010.12.12

Article 18. Ban on

the mixing of

hazardous waste,

paragraph 1


measures to ensure that hazardous waste is not

mixed, either with other categories of

hazardous waste or with other waste,

substances or materials.

When dealing with

hazardous waste it can‘t be

proceeded with their

mixture.

2010.12.12

Article 19.

Labelling of

hazardous waste,

paragraph 1


measures to ensure that, in the course of

collection, transport and temporary storage,

hazardous waste is packaged and labelled in

accordance with the international and

Community standards in force.

When proceeding with the

temporary storage of

hazardous waste (or any

other activity listed) these

wastes must be packaged

and labelled in accordance

with international and

Community standards.

2010.12.12



D 1.2




shipyards Comments

Date of

entry

into

force

Article 21. Waste

oils, paragraph 1(a,

b, c)

Whenever technically feasible the waste oils

are collected separately and when technically

feasible and economically viable, waste oils of

different characteristics are not mixed and

waste oils are not mixed with other kinds of

waste or substances, if such mixing impedes

their treatment.

The waste oils must be treated in accordance

with Articles 4 and 13.

If economically and

technically feasible the oils

must be collected separately

and shouldn‘t be mixed with

waste oils of different

characteristics or which

other kind of waste or

substances that impedes

their treatment.

2010.12.12

Article 23.

Issue of permits,

paragraph 1

Member States shall require any establishment

or undertaking intending to carry out waste

treatment to obtain a permit from the

competent authority.

If shipyards intend to

proceed with the treatment

of their own waste (non-

hazardous waste) it may be

required to them to have a

permit if the Member State

decides to don‘t include

them in the exceptions of

Article 24.

2010.12.12

Article 24.

Exemptions from

permit requirements

Member States may exempt from the

requirement laid down in Article 23,

paragraph 1, establishments or undertakings

for the following operations: disposal of their

own non-hazardous waste at the place of

production or recovery of waste.

When included in the

exemptions the shipyards

don‘t need a permit to

recover or disposal their own


2010.12.12

Article 34.

Inspections and

records,

paragraph 1

Establishments or undertakings which carry

out waste treatment operations, (…), and

establishments or undertakings which produce

hazardous waste shall be subject to

appropriate periodic inspections by the

competent authorities.

When shipyards carry out

the waste treatment or

produce hazardous waste

they are subject to periodic

inspections.

2010.12.12

Article 35.

Record keeping,

paragraph 1

The establishments or undertakings referred to

in Article 23, paragraph 1, the producers of

hazardous waste, (…), shall keep a

chronological record of the quantity, nature

and origin of the waste, and, where relevant,

the destination, frequency of collection, mode

of transport and treatment method foreseen in

respect of the waste, and shall make that

information available, on request, to the

competent authorities.

When shipyards carry out

the waste treatment or

produce hazardous waste

they shall keep a

chronological record of the

quantity, nature and origin

of the waste, and, where

relevant, the destination,

frequency of collection,

mode of transport and

treatment method used and

shall make that information

available to the competent

authorities.

2010.12.12



D 1.2


6 EU directive on the limitation of emissions of VOC applicable to

repair shipyards

Volatile organic compounds (VOCs) from paints/solvents are one of the most important sources of

pollutant outputs for the shipbuilding and ship repair industry.

In this section, Directive 1999/13/EC on the limitation of emissions of volatile organic compound due to

the use of organic solvent in certain activities and installations is going to be analysed as main policy

instrument.

To be noted that:

1. The directive was amended through the following sources:

Annex I, point 17 of the Regulation (EC) No 1882/2003 of the European Parliament and of the

Council (OJ L 284, 31.10.2003, p. 1) which amends article 13,

Article 13(1) of the Directive 2004/42/EC of the European Parliament and of the Council on

the limitation of emissions of volatile organic compounds due to the use of organic solvents in

certain paints and varnishes and vehicle refinishing products(OJ L 143, 30.4.2004, p. 87)

Article 3 of the Directive 2008/112/EC of the European Parliament and of the Council(OJ L

345, 23.12.2008, p. 68. which amends article 5 paragraph 6,8,9,10 and 13.

2. This directive as amended will be repealed with effect from 7 January 2014 by the Directive

2010/75/EU of 24 November 2010 on industrial emissions (integrated pollution prevention and

control). It without prejudice to the obligations of the Member States relating to the time limits for

transposition into national law and application of the Directive as set out in the Annex IX, Part B.2

of the Directive 2010/75/EU. (See section 8).



D 1.2


6.1 Council Directive 1999/13/EC of 11 March 1999 on the limitation of

emissions of volatile organic compound due to the use of organic solvent in

certain activities and installations. /SED

The VOC Solvents Emissions Directive is the main policy instrument concerning reduction of industrial

emissions of volatile organic compounds (VOCs) in the European Union. The VOC Solvents Emissions

Directive requires installations, which such activities (source of VOC emissions) are applied in to comply

either

with the emission limit values set out in the Directive (see section 6.1.2) or

with the requirements of the so-called reduction scheme (see section 6.1.3)

The Directive sets out emission limit values for VOCs in waste gases and maximum levels for fugitive

emissions (expressed as percentage of solvent input) or total emission limit values.

The purpose of the reduction scheme is to allow the operator a possibility to achieve by other means

emission reductions, equivalent to those achieved if the emission limit values were to be applied. This

could be typically achieved by substituting high-solvent products with low-solvent or solvent-free ones and

changing to solvent free production processes. New installations have to comply with the requirements of

the VOC Solvents Emissions Directive at the time they are starting the activity. The final implementation

date for existing installations was 31 October 2007.

The VOC Solvents Emissions Directive covers a wide range of solvent using activities e.g. printing, vehicle

coating, dry cleaning and manufacture of footwear and pharmaceutical products which could be classified

as ―indoor activities‖, where the measures for reduction of VOC emissions are easier to be performed. The

painting and coating processes in the shipbuilding and ship repair are rather ―outdoor activities‖, where the

achievement of low emission limits is more problematic.



D 1.2



Table 6: Detailed discussion of Volatile Organic Compounds Directive 1999/13/EC.


shipyards Comments

Date of

entry

into

force

Article 1.

Purpose and

scope

Some of the activities carried out in shipyards

are identified in Annex I and, therefore, are

subject of this Directive whenever they are

operated above the solvent consumption

thresholds listed in Annex IIA (see 6.1.2)

The activities identified in

Annex I include:

- application of a

continuous film of a

coating on metallic and

plastic surfaces of

ships;

- coating of wooden

surfaces;

- Surface cleaning.

1999.03.29

Article 5.

Requirements,

paragraph 2

All installations shall comply with the emission

limit values in waste gases and the fugitive

emission values and other requirements laid

down in Annex IIA or the requirements of the

reduction scheme specified in Annex IIB. (see

6.1.3)

Correlate with Article 59(1)

of Directive 2010/75/EU.

Annex IIA (see section

6.1.2) has lightly been

updated in the Table

included in Part 2 of

Annex VII of the Directive

2010/75/EU (see 8.1.2)

1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 5.

Requirements,

paragraph 3

a) For fugitive emissions, Member States shall

apply fugitive emission values to

installations as an emission limit value.

However, where it is demonstrated to the

satisfaction of the competent authority that

for an individual installation this value is

not technically and economically feasible,

the competent authority can make an

exception for such an individual installation

provided that significant risks to human

health or the environment are not to be

expected. For each derogation the operator

must demonstrate to the satisfaction of the

competent authority that the best available

technique is being used.

b) Activities which cannot be operated under

contained conditions may be exempted from

the controls of Annex IIA, when this

possibility is explicitly mentioned in that

Annex. The reduction scheme of Annex IIB

is then to be used, unless it is demonstrated

to the satisfaction of the competent authority

that this option is not technically and

economically feasible. In this case, the

operator must demonstrate to the

satisfaction of the competent authority that

the best available technique is being used.

In situations where it is

demonstrated that the

compliance with the

thresholds specified in

Annex IIA for fugitive

emissions or the reduction

scheme of Annex B are not

technically and

economically feasible, the

competent authority can

make an exemption

providing that the operators

of shipyards are able to

demonstrate that the best

available techniques are

already being used.

Correlate with Article

59(2)(3) of Directive

2010/75/EU.

1999.03.29

Article 5.

Requirements,

paragraph 5

Installations where two or more activities are

carried out, each of which exceeds the

thresholds in Annex IIA shall:

a) as regards the substances specified in

paragraphs 6, 7 and 8, meet the

requirements of those paragraphs for each

activity individually;

b) as regards all other substances, either:

i) meet the requirements of paragraph 2

for each activity individually; or

ii) have total emissions not exceeding

those that would have resulted had

point (i) been applied.



1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 5.

Requirements,

paragraph 6

As amended by

Article 3 of the

Directive

2008/112/EC

‘6. Substances or mixtures which, because of

their content of VOCs classified as carcinogens,

mutagens or toxic to reproduction under

Regulation (EC) No 1272/2008 of the

European Parliament and of the Council of

16 December 2008 on classification, labelling

and packaging of substances and mixtures (*)

are assigned or need to carry the hazard

statements H340, H350, H350i, H360D or

H360F or the risk phrases R45, R46, R49, R60

or R61 shall be replaced, as far as possible and

by taking into account the guidance referred to

in Article 7(1), by less harmful substances or

mixtures within the shortest possible time.

Correlate with Article 58 of

Directive 2010/75/EU.

To be highlighted the

reference to new Regulation

(EC) No 1272/2008 of the

European Parliament and of

the Council of 16 December

2008 instead of Directive

67/548/EEC (1),

2010.12.01

Article 5.

Requirements,

paragraph 6

As amended by

Article 3 of the

Directive

2008/112/EC

‘‘6. Substances or mixtures which, because of

their content of VOCs classified as carcinogens,

mutagens or toxic to reproduction under

Regulation (EC) No 1272/2008 of the European

Parliament and of the Council of 16 December

2008 on classification, labelling and packaging

of substances and mixtures (*) are assigned or

need to carry the hazard statements H340,

H350, H350i, H360D or H360F shall be

replaced, as far as possible and by taking into

account the guidance as mentioned in Article

7(1), by less harmful substances or mixtures

within the shortest possible time



To be highlighted the

elimination of the risk

phrases R45, R46, R49, R60

or R61 by Hazard

statements.

2015.06.01

Article 5.

Requirements,

paragraph 7

For discharges of the VOCs referred to in

paragraph 6, where the mass flow of the sum of

the compounds causing the labelling referred to

in that paragraph is greater than, or equal to, 10

g/h, an emission limit value of 2 mg/Nm3 shall

be complied with. The emission limit value

refers to the mass sum of the individual

compounds.

Correlate with Annex VII,

Part 4 (1) of Directive

2010/75/EU.

1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 5.

Requirements,

paragraph 8

As amended by

Article 3 of the

Directive

2008/112/EC

For discharges of halogenated VOCs which are

assigned the risk phrase R40 or R68, where the

mass flow of the sum of the compounds causing

the labeling R40 or R68 is greater than, or

equal to, 100 g/h, an emission limit value of 20

mg/Nm3 shall be complied with. The emission

limit value refers to the mass sum of the

individual compounds.

The discharge of VOCs referred to in

paragraphs 6 and 8 shall be controlled as

emissions from an installation under contained

conditions as far as technically and

economically feasible to safeguard public health

and the environment.



2010/75/EU.

Note:

This paragraph 8 shall be

amended as follows:

(i) from 1 June 2015, the

words ‗the risk phrases R40

or R68‘ shall be replaced by

‗the hazard statements H341

or H351‘;

(ii) from 1 June 2015, the

words ‗the labelling R40 or

R68‘ shall be replaced by

‗the hazard statements H341

or H351‘;

2010.12.01

Article 5.

Requirements,

paragraph 9

Discharges of those VOCs which, after the entry

into force of this Directive, are assigned or need

to carry one of the risk phrases mentioned in

paragraphs 6 and 8, shall have to comply with

the emission limit values mentioned in

paragraphs 7 and 8 respectively, within the

shortest possible time.

Note:

from 1 June 2015, in

paragraph 9, the words ‗risk

phrases‘ shall be replaced by

‗hazard statements‘;

1999.03.29

Article 5.

Requirements,

paragraph 10

All appropriate precautions shall be taken to

minimise emissions during start-up and shut-

down.

Start-up and shut-down

operations shall mean

operations whilst bringing

an activity, an equipment

item or a tank into or out of

service or into or out of an

idling state. Regularly

oscillating activity phases

are not to be considered as

start-ups and shut-downs.



1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 5.

Requirements,

paragraph 11

Existing installations which operate existing

abatement equipment and comply with the

following emission limit values:

- 50 mgC/Nm3 in the case of incineration,

- 150 mg C/Nm3 in the case of any other

abatement equipment, shall be exempt

from the waste gases emission limit values

in the table in Annex IIA for a period of

12 years after the date referred to in

Article 15, provided the total emissions of

the whole installation do not exceed those

that would have resulted had all the

requirements of the table been met.

1999.03.29

Article 5.

Requirements,

paragraph 12

Neither the reduction scheme nor the

application of paragraph 11 nor Article 6

exempt installations discharging substances

specified in paragraphs 6, 7 and 8 from fulfilling

the requirements of those paragraphs

1999.03.29

Article 6.

National plans,

paragraph 1

Member States may define and implement

national plans for reducing emissions from the

activities and industrial installations covered by

Article 1, excluding activities 4 and 11 of

Annex IIA.

These plans shall result in a reduction of the

annual emissions of VOCs from existing

installations covered by this Directive by at least

the same amount and within the same time

frame as would have been achieved by applying

the emission limits under Article 5(2) and (3)

and Annex II, during the validity period of the

national plan. The national plan, if necessary

updated, will be resubmitted to the Commission

every three years.

Surface cleaning activities

cannot be object of National

plans.

1999.03.29

Article 8.

Monitoring,

paragraph 1

Member States shall introduce an obligation for

the operator of an installation covered by this

Directive to supply the competent authority

once a year or on request with data that enables

the competent authority to verify compliance

with this Directive.

The operators of shipyards

are obliged to supply the

competent authority once an

year, or following a request,

with data that enable the

verification of compliance

with this directive.

Correlate with Article 14

(1), point (d), Article 60 of


1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 8.

Monitoring,

paragraph 2

Member States shall ensure that channels to

which abatement equipment is connected, and

which at the final point of discharge emit more

than an average of 10 kg/h of total organic

carbon, are monitored continuously for

compliance.

Continuously monitoring is

required for channels

connected with abatement

equipments and which at the

final point of discharge emit

more than an average of 10

kg/h of total organic carbon.



2010/75/EU.

1999.03.29

Article 8.

Monitoring,

paragraph 3

In the other cases, Member States shall ensure

that either continuous or periodic measurements

are carried out. For periodic measurements at

least three readings shall be obtained during

each measurement exercise.

In the other cases the

measurements can be carried

out continuously or

periodically.



2010/75/EU.

1999.03.29

Article 8.

Monitoring,

paragraph 4

Measurements are not required in the case

where end-of-pipe abatement equipment is not

needed to comply with this Directive.



2010/75/EU.

1999.03.29

Article 9.

Compliance with

emission limit

values,

paragraph 1

Compliance with the following shall be

demonstrated to the satisfaction of the

competent authority:

a) emission limit values in waste gases,

fugitive emission values and total emission

limit values;

b) the requirements of the reduction scheme

under Annex IIB;

c) the provisions of Article 5(3).

Guidance is provided in Annex III on solvent

management plans serving to demonstrate

compliance with these parameters.

Gas volumes may be added to the waste gas for

cooling or dilution purposes where technically

justified but shall not be considered when

determining the mass concentration of the

pollutant in the waste gas.


have to prepare solvent

management plans to

demonstrate compliance

with the requirements of this

directive.



1999.03.29

Article 9.

Compliance with

emission limit

values,

paragraph 2

Following a substantial change, compliance

shall be verified again.

The definition of substantial

change can be found on

Article 2 (4).



1999.03.29



D 1.2




shipyards Comments

Date of

entry

into

force

Article 9.

Compliance with

emission limit

values,

paragraph 3

In the case of continuous measurements the

emission limit values shall be considered to be

complied with if:

(a) none of the averages over 24 hours of

normal operation exceeds the emission limit

values, and

(b) none of the hourly averages exceeds the

emission limit values by more than a factor of

1,5.



2010/75/EU.

1999.03.29

Article 9,

Compliance with

emission limit

values,

paragraph 4

In the case of periodic measurements the

emission limit values shall be considered to be

complied with if, in one monitoring exercise:

(a) the average of all the readings does not

exceed the emission limit values, and

(b) none of the hourly averages exceeds the

emission limit value by more than a factor of

1,5.



2010/75/EU.

1999.03.29

Article 9.

Compliance with

emission limit

values,

paragraph 5

Compliance with the provisions of Article 5 (7)

and (8) shall be verified on the basis of the sum

of the mass concentrations of the individual

volatile organic compounds concerned. For all

other cases, compliance shall be verified on the

basis of the total mass of organic carbon emitted

unless otherwise specified in Annex IIA.



2010/75/EU.

1999.03.29

Article 10.

Non-compliance,

paragraph 8

Member States shall take appropriate measures

to ensure that, if it is found that the

requirements of this Directive have been

breached:

(a) the operator informs the competent

authority and takes measures to ensure that

compliance is restored within the shortest

possible time;

(b) in cases of non-compliance causing

immediate danger to human health and as long

as compliance is not restored under the

conditions of paragraph (a), operation of the

activity is suspended.

Correlate with Article 8.2 of

Directive 2010/75/EU

1999.03.29



D 1.2


6.1.2 DIRECTIVE 1999/13/EC: Thresholds and emission controls.

Some of the activities carried out in shipyards are identified in Annex I and, therefore, are subject of this

Directive whenever they are operated above the solvent consumption thresholds listed in Annex IIA.

The activities identified in Annex I include:

application of a continuous film of a coating on metallic and plastic surfaces of ships;

coating of wooden surfaces;

surface cleaning.

Table 7: DIRECTIVE 1999/13/EC: Annex IIA.

Thresholds and emission controls only for those activities in Annex I carried out in shipyards.

Activity

(solvent consumption threshold in

tonnes/year)

Threshold

(solvent

consumption

threshold in

tonnes/year)

Emission limit

values in

waste gases

(mgC /Nm3)

Fugitive emission limit values

(percentage of solvent input)

New

Existing

4 Surface cleaning (1)

(> 1) 1 -5 20(2) 15

> 5 20(2) 10

5 Other surface cleaning

(> 2) 2 – 10 75(3) 20 (3)

> 10 75(3) 15 (3)

8 Other coating, including metal,

plastic, textile, fabric, film and paper

coating;

(> 5)

5-15 100 (4) (6) 20 (6)

> 15 50/75 (5) (6) 20 (6)

10 Coating of wooden surfaces

(> 15) 15-25 100 (7) 25

> 25 50/75 (8) 20

Special Provisions

(1) Using compounds specified in Article 5 (6) and (8).

(2) Limit refers to mass of compounds in mg/Nm3, and not to total carbon.

(3) Installations which demonstrate to the competent authority that the average organic solvent content of all

cleaning material used does not exceed 30% by weight are exempt from application of these values.

(4) Emission limit value applies to coating application and drying processes operated under contained conditions.

(5) The first emission limit value applies to drying processes, the second to coating application processes.

(6) Coating activities which cannot be carried out under contained conditions (such as shipbuilding, aircraft

painting) may be exempted from these values, in accordance with Article 59 (3).

―…, for coating activities which cannot be carried out under contained conditions, the competent authority may allow

the emissions of the installation not to comply with the requirements set out in that paragraph if the operator

demonstrates to the competent authority that such compliance is not technically and economically feasible and that

the best available techniques are being used.‖

(7) Emission limit applies to coating application and drying processes operated under contained conditions.

(8) The first value applies to drying processes, the second to coating application processes.



D 1.2


Note: The emission limit values in waste gases shall be calculated at a temperature of 273,15 K, and a pressure of 101,3 kPa. 6.1.3 DIRECTIVE 1999/13/EC: Reduction Schema

Table 8: DIRECTIVE 1999/13/EC: Annex IIB.

Reduction Schema

The purpose of the reduction scheme is to allow the operator the possibility to achieve by other means emission

reductions, equivalent to those achieved if the emission limit values were to be applied. To that end the operator may

use any reduction scheme, specially designed for his installation, provided that in the end an equivalent emission

reduction is achieved. Member States shall report according to Article 11 of the Directive to the Commission about

the progress in achieving the same emission reduction, including the experience from the application of the reduction

scheme.

In the case of applying coatings, varnishes, adhesives or inks, the following scheme can be used. Where the

following method is inappropriate the competent authority may allow an operator to apply any alternative exemption

scheme which it is satisfied fulfils the principles outlined here. The design of the scheme takes into account the

following facts:

(i) where substitutes containing little or no solvent are still under development, a time extension must be given

to the operator to implement his emission reduction plans;

(ii) the reference point for emission reductions should correspond as closely as possible to the emissions which

would have resulted had no reduction action been taken.

The following scheme shall operate for installations for which a constant solid content of product can be assumed

and used to define the reference point for emission reductions:

(i) the operator shall forward an emission reduction plan which includes in particular decreases in the average

solvent content of the total input and/or increased efficiency in the use of solids to achieve a reduction of

the total emissions from the installation to a given percentage of the annual reference emissions, termed the

target emission. This must be done on the following time frame:

Time period Maximum allowed total annual

emissions New installations Existing installations

By 31.10.2001 By 31.10.2005 Target emission ×1,5

By 31.10.2004 By 31.10.2007 Target emission

(ii) The annual reference emission is calculated as follows:

a. The total mass of solids in the quantity of coating and/or ink, varnish or adhesive consumed in a

year is determined. Solids are all materials in coatings, inks, varnishes and adhesives that become

solid once the water or the volatile organic compounds are evaporated.

b. The annual reference emissions are calculated by multiplying the mass determined in (a) by the

appropriate factor listed in the table below. Competent authorities may adjust these factors for

individual installations to reflect documented increased efficiency in the use of solids.

Activity Multiplication factor for use

in item (ii)(b)

….Wood coating; coating of textiles, fabric film or

paper; adhesive coating

4

Food contact coating, aerospace coatings 2,33

Other coatings and rotary screen printing 1,5



D 1.2


Table 8: DIRECTIVE 1999/13/EC: Annex IIB.

Reduction Schema

c. The target emission is equal to the annual reference emission multiplied by a percentage equal to:

— (the fugitive emission value + 15), for installations falling within item 6 and the lower threshold

band of items 8 and 10 of Annex IIA,

— (the fugitive emission value + 5) for all other installations.

d. Compliance is achieved if the actual solvent emission determined from the solvent management

plan is less than or equal to the target emission.



D 1.2


6.1.4 Directive Ambiguity and preliminary consequences

The important notice concerning ambiguity of directive phrases and consequences for shipyard are

presented in this table:

Table 9: Important notice concerning ambiguity of Volatile Organic Compounds Directive 1999/13/EC.


shipyards Comments

Article 5.

Requirements,

Paragraph 2,

point (b)

Correlate with

Article 59.1 (a) and

(b) of Directive

2010/75/EU.

The lack of definitely determined threshold

for ship repair work does not allow operators

to apply the provisions, relating to operators

of other activities and places them at a

disadvantage to them.

In addition entitle the supervisory authorities

to assess subjectively the methods and

techniques to reduce levels of exhaust

emissions and therefore misunderstandings

arise in applying the Directive.

Therefore the following proposition could be

made:

To be set a representative value of the

threshold limit emissions of volatile organic

compounds and annual reference emissions

based on the product quantities (solid

substances) consumed per coated surface unit ,

similar for instance to the coating activity for

vehicles.

According to the limits as listed in Annex

IIA of the Directive, for the activity

performed by the ship repair facilities can

be considered the limits of paragraph 8

where note 4 says:.(4) Activities coating

under controlled conditions (such as

shipbuilding, aircraft painting) may be

exempted from compliance with these

values in accordance with article 5,

paragraph 3, point b.

However, the conditions in the ship repair

activity are the so-called uncontrollable

type that means the gas emissions are

diffuse but not organized.

Therefore, the requirements for adherence

to the emissions stated, respectively 20 mg

C/N m3, are not applicable. Instead a plan

for emissions reducing is to be applied,

unless if it is conclusively demonstrated to

the competent authority, that this option is

technically and economically unfeasible.

In this case the operator must demonstrate

to the satisfaction of the competent

authority, that the best available techniques

are used.

Article 5.

Requirements,

Paragraph 3,

point (b)

Correlate with

Article 59(3) of

Directive

2010/75/EU.

Ship repair industry is harmed by the lack of

clear criteria for best available techniques and

supervisory authorities have difficulties in

taking a decision about the use of the best

available techniques by operators.

There are cases in the ship repair practice,

when an operator of installation presents

well founded evidences for actual usage of

the best available techniques

(technologies, equipment, and products)

and the possibility for father decreasing of

VOC emissions is technically and

economically impossible. According to the

Directive recommendation the operator

have to be exempted from the obligation

for annually development of a plane for

VOC emissions reducing, but some

problems with the supervisory authorities

arises.



D 1.2


Table 9: Important notice concerning ambiguity of Volatile Organic Compounds Directive 1999/13/EC.


shipyards Comments

Article 5.

Requirements,

Paragraph 6

Correlate with

Article 58 of

Directive

2010/75/EU.

The operators, engaged in ship repair in most

cases are unable to control the type and

quantities, of the substances used in the

activities. It leads not only to inaccurate data

in the plans for solvent usage preparation but

also to insufficiently correct final results and

conclusions regarding the environmental

pollution by volatile organic compounds.

For these reasons (lack of information on the

products and information about next year

activities volume) the operator of the activity

is not able to predict the presence of

substances whit prohibited for use risk

components and to ask permission for use in

the next calendar year with clear indication of

the risk components and the amounts

necessary for operation of the installation.

Due to the lack of the accompanying product

safety sheets it is difficult to be adequately

estimated the quantities of solvents used and

to be prepared sufficiently representative

solvent management plan for the competent

authorities.

Substances or preparations indicated by

the risk phrases R5, R46, R49, R60 and

R61 as possible soon are replaced as far as

possible with less harmful substances or

preparations. Practice in the country is to

receive from the supervisory authorities in

advance (before the commencement of

operations for the year) a permission

stating the kind of preparations, the kind of

the risk phrases and the necessary

quantities.

In fact, in the almost all ship repair

companies:

1. The coating activities are performed

by outsourcing companies.

2. Shipping agents themselves deliver

preparations (paint, primer and solvents)

at the time of arrival of the vessel. Often

the supplied and used products are of

unknown origin and content and without

supporting documents (identification

sheets for safe use).

Article 5.

Requirements,

Paragraph 12

The operators of the installations are

practically obstructed to timely report the use

of preparations with risk phrases and so fall

under the blows of the law.

It requires periodic annual change and

approval by the supervisory authorities of

target and reference annual emissions and

creates misunderstandings and doubts about

the subjectivity.

Operators are not exempt from the

obligation to comply with the requirements

as shown in article 5, paragraphs 6, 7 and

8.

The plan to reduce emissions of volatile

organic compounds have to lead to reduce

the annual VOC emissions from existing

installations that fall within the scope of

this Directive. At the same time for ship

repair work, which is not so predictable

and is strongly marked depended, is very

difficult to be exactly defined in advance

the volume of areas to be coated during the

year and therefore often occurs after a

weak year the emissions for the next year

to exceed several times those of previous.

Article 7.

Substitution

In the actual ship repair work are frequently

used products containing substances with the

indicated risk phrases as for example so-called

antifouling paints. Replacement of these

products is hampered by the lack of a list of

substitutes.

It has not been prepared and published a

list of preparations and solvents replacing

those that contain the listed risk phrases in

order to enable the operators to select low-

risk products.



D 1.2


7 EU directive concerning IPPC applicable to repair shipyards

In this section, Directive 2008/1/EC 2008 concerning integrated pollution prevention control is going to be

analysed as main policy instrument.

To be noted that this directive as amended by Article 37 of the Directive 2009/31/EC of the European

Parliament and of the Council (OJ L 140, 5.6.2009, p. 114), will be repealed with effect from 7 January

2014 by the Directive 2010/75/EU of 24 November 2010 on industrial emissions (integrated pollution

prevention and control). It without prejudice to the obligations of the Member States relating to the time

limits for transposition into national law and application of the Directive as set out in the Annex IX, Part

B.2 of the Directive 2010/75/EU. (See section 8).

7.1 Directive 2008/1/EC of the European Parliament and the Council of 15

January 2008 concerning integrated pollution prevention control (codified

version)

The aim of the IPPC Directive is to achieve integrated prevention and control of pollution arising from

industrial installations across the EU member states. It requires installations to operate in accordance with

permits which include emission limit values or other technical measures based on the use of Best Available

Techniques (BAT) to prevent or reduce emissions to water, air and soil, as well as to tackle other

environmental impacts.

Directive 2008/11/EC is a codified version of the first IPPC directive which came into force on 24th of

September 1996.

This Directive (2008) lays down measures designed to prevent or, where that is not practicable, to reduce

the emissions to air, water and land from activities covered under this directive, including measures

concerning waste, in order to achieve a high level of protection of the environment taken as a whole.

Member States shall take the necessary measures to ensure that new and existing installations are operated

with a permit issued in accordance with this Directive.

This Directive is concerned with installations whose potential for pollution is significant, especially listed

in Annex I of Directive. Some types of activities conducted by the repair shipyards are part of categories of

industrial activities described in the Directive. The detailed analysis of articles that may concern the

activity carried out by the repair shipyards are provided in the table below.



D 1.2


Table 10: Detailed discussion of Integrated Pollution Prevention and Control Directive 2008/1/EC.


shipyards Comments

Date of

entry

into

force

Article 1.

Purpose and scope

Shipyards are within the scope of this

directive whenever they have a solvent

consumption capacity of more than 150 kg per

hour or more than 200 tonnes per year.

2008.02.18

Article 3.

General principles

governing the basic

obligations of the

operator,

paragraph 1


measures to provide that the competent

authorities ensure that installations are

operated in such a way that:

a) all the appropriate preventive measures

are taken against pollution, in particular

through application of the best available

techniques;

b) no significant pollution is caused;

c) waste production is avoided in accordance

with Directive 2006/12/EC of the

European Parliament and of the Council of

5 April 2006 on waste (1); where waste is

produced, it is recovered or, where that is

technically and economically impossible,

it is disposed of while avoiding or

reducing any impact on the environment;

d) energy is used efficiently;

e) the necessary measures are taken to

prevent accidents and limit their

consequences;

f) the necessary measures are taken upon

definitive cessation of activities to avoid

any pollution risk and return the site of

operation to a satisfactory state.



2008.02.18

Article 4.

Permits for new

installations


measures to ensure that no new installation is

operated without a permit issued in

accordance with this Directive.

New shipyards are obliged

to have a permit issued in

accordance with this

Directive.

Correlate with Article 4 (1)


2008.02.18

Article 5.

Requirements for

the granting of

permits for existing

installations,

paragraph 1


measures to ensure that the competent

authorities see to it, by means of permits in

accordance with Articles 6 and 8 or, as

appropriate, by reconsidering and, where

necessary, by updating the conditions, that

existing installations operate in accordance

with the requirements of Articles 3, 7, 9, 10

and 13, Article 14(a) and (b) and Article 15(2)

not later than 30 October 2007, without

prejudice to specific Community legislation.

2008.02.18



D 1.2




shipyards Comments

Date of

entry

into

force

Article 5.

Requirements for

the granting of

permits for existing

installations,

paragraph 2


measures to apply the provisions of Articles 1,

2, 11 and 12, Article 14(c), Article 15(1) and

(3), Articles 17, 18 and Article 19(2) to

existing installations as from 30 October 1999.

Correlate with Article 80 (1)


2008.02.18

Article 6.

Applications for

permits,

paragraph 1


measures to ensure that an application to the

competent authority for a permit includes a

description of:

a) the installation and its activities;

b) the raw and auxiliary materials, other

substances and the energy used in or

generated by the installation;

c) the sources of emissions from the

installation;

d) the conditions of the site of the

installation;

e) the nature and quantities of foreseeable

emissions from the installation into each

medium as well as identification of

significant effects of the emissions on

the environment;

f) the proposed technology and other

techniques for preventing or, where this

not possible, reducing emissions from

the installation;

g) where necessary, measures for the

prevention and recovery of waste

generated by the installation;

h) further measures planned to comply

with the general principles of the basic

obligations of the operator as provided

for in Article 3;

i) measures planned to monitor emissions

into the environment;

j) the main alternatives, if any, studied by

the applicant in outline.

An application for a permit shall also include

a non-technical summary of the details

referred to in points (a) to (j).

Where information supplied in accordance

with the requirements provided for in

Directive 85/337/EEC or a safety report

prepared in accordance with Council Directive

96/82/EC of 9 December 1996 on the control

of major-accident hazards involving

Information that should be

provided when applying for

a permit.



2008.02.18



D 1.2




shipyards Comments

Date of

entry

into

force

dangerous substances (1) or other information

produced in response to other legislation

fulfils any of the requirements of this Article,

that information may be included in, or

attached to, the application.

Article 8.

Decisions

Without prejudice to other requirements laid

down in national or Community legislation,

the competent authority shall grant a permit

containing conditions guaranteeing that the

installation complies with the requirements of

this Directive or, if it does not, shall refuse to

grant the permit.

All permits granted and modified permits

must include details of the arrangements made

for air, water and land protection as referred to

in this Directive.

If shipyards do not comply

with the requirements of this

directive they cannot receive

a permit and therefore are

not allowed to operate.



2008.02.18

Article 12.

Changes by

operators to

installations,

paragraph 1


measures to ensure that the operator informs

the competent authorities of any planned

change in the operation. Where appropriate,

the competent authorities shall update the

permit or the conditions.

Shipyards must inform the

competent authorities of any

planned change in the

operation.



2008.02.18

Article 12.

Changes by

operators to

installations,

paragraph 2


measures to ensure that no substantial change

planned by the operator is made without a

permit issued in accordance with this

Directive. The application for a permit and the

decision by the competent authority must

cover those parts of the installation and those

aspects listed in Article 6 that may be affected

by the change.

The relevant provisions of Article 3, Articles 6

to 10 and Article 15(1), (2) and (3) shall apply

Mutatis mutandis.

Under the scope of this

directive ―substantial

change‖ means a change in

operation which, in the

opinion of the competent

authority, may have

significant negative effects

on human beings or the

environment as stated in

article 2 (11).

For the purposes of this

definition, any change to or

extension of an operation

shall be deemed to be

substantial if the change or

extension in itself meets the

thresholds, if any, set out in

Annex I;



2008.02.18



D 1.2




shipyards Comments

Date of

entry

into

force

Article 14.

Compliance with

permit conditions

Paragraph a


measures to ensure that the conditions of the

permit are complied with by the operator

when operating the installation;

The operator of the shipyard

is obliged to:

- comply with the

conditions of the permit

while operating the

installation;



2008.02.18

Article 14.

Compliance with

permit conditions

Paragraph b


measures to ensure that the operator regularly

informs the competent authority of the results

of the monitoring of releases and without

delay of any incident or accident significantly

affecting the environment;


is obliged to:

- inform on a regular basis

the competent authority

of the results of the

monitoring and

immediately when an

incident or accident

significantly affecting

the environment occurs;

Correlate with Article 7(a)

and 14(1)(d)(i) of Directive

2010/75/EU.

2008.02.18

Article 14.

Compliance with

permit conditions

Paragraph c


measures to ensure that the operators of

installations afford the representatives of the

competent authority all necessary assistance to

enable them to carry out any inspections

within the installation, to take samples and to

gather any information necessary for the

performance of their duties for the purposes of

this Directive.


is obliged to:

- afford the

representatives of the

competent authority all

necessary assistance to

enable them to carry out

any inspections within

the installation, to take

samples and to gather

any information

necessary for the

performance of their

duties for the purposes

of this Directive.



2008.02.18



D 1.2


8 EU directive on industrial emissions applicable to repair

shipyards

8.1 Directive 2010/75/EU of the European Parliament and the Council of 24

November 2010 on industrial emissions (integrated pollution prevention and

control) (Recast).

The IED merges into a single legal instrument seven Directives.

Council Directive 78/176/EEC of 20 February 1978 on waste from the titanium dioxide industry

Council Directive 82/883/EEC of 3 December 1982 on procedures for the surveillance and monitoring

of environments concerned by waste from the titanium dioxide industry

Council Directive 92/112/EEC of 15 December 1992 on procedures for harmonising the programmes

for the reduction and eventual elimination of pollution caused by waste from the titanium dioxide

industry

Council Directive 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile organic

compounds due to the use of organic solvents in certain activities and installations

Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the

incineration of waste

Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the

limitation of emissions of certain pollutants into the air from large combustion plants, and

Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008 concerning

integrated pollution prevention and control (10) OJ L 24, 29.1.2008, p. 8..

Two of them are important ones for the Ship repair business, the IPPCD (Directive 2008/1/EC) and the

SED (Directive 1999/13/EC on the limitation of emissions of volatile organic compound). Both are

repealed with effect from 7 January 2014, without prejudice to the obligations of the Member States

relating to the time limits for transposition into national law and application of the Directives set out in

Annex IX, Part B.2.

Table 11: Annex IX, Part B.2. List of time-limits for transposition into national law and

application

Directive Time-limit for transposition Time-limit for application

1999/13/EC 1 April 2001

2008/1/EC 30 October 1999 (1) 30 October 1999

(1)Directive 2008/1/EC is a codified version of Council Directive 96/61/EC of 24 September 1996

concerning integrated pollution prevention and control (OJ L 257, 10.10.1996, p. 26) and the time-limits for

transposition and application remain in force.

The IED clarified the interaction between the included legal instruments and streamlines many important

provisions, including those related to monitoring and reporting.

The IED greatly strengthens the importance of BAT in the permitting procedure and addresses certain

shortcomings of the IPPCD, in particular with regard to permit reviews and inspections.

The IED lays down more detailed rules on the review of permits and, in particular, provides for the

compulsory reconsideration of permits within four years of publication of decisions on BAT conclusions.

The directive repeatedly refers to some activities carried out in the yard, namely:



D 1.2


In the Chapter II dedicated to Provisions for activities listed in Annex I

In the Chapter V and annex VII, dedicated to special provisions for installations and activities

using organic solvents

Detailed discussion on the Directive in terms of activity carried out in the shipyard is given in Table 12.

Having regard that under the IED, greater emphasis will be placed on the use of the BAT conclusions

derived from the BREFs for the setting of permit conditions in appendixes are given selected, relevant

issues.



D 1.2



Table 12: Detailed discussion of Directive 2010/75/EU on industrial emissions. (Analysis performed by:

SU).


shipyards Comments

Date of

entry

into

force

Chapter I.

Common

provisions,

Article 2. Scope ,

paragraph 2

This Directive shall not apply to research

activities, development activities or the testing

of new products and processes.

2011.01.06

Chapter I.

Common

provisions,

Article 4.

Obligation to hold a

permit, paragraph 1

Member states shall take the necessary

measures to ensure that no installation or

combustion plant or waste co-incineration

plant is operated without a permit.

By way of derogation from the first

subparagraph, Member States may set a

procedure for the registration of installations

covered only by Chapter V.

The procedure for registration shall be

specified in a binding act and includes at least

a notification to the competent authority by

the operator of the intention to operate an

installation.

The shipyards need to apply

for the permits under this

directive as per the

stipulated procedure and

applicable laws. Shipyards

may need to upgrade/install

new equipment along with

training the personnel.

As per the activities given in

Annex I, category 6.7, of

this directive, shipyards are

included in the installations

requiring the permits. The

permits need to be obtained

by conforming to the

stipulated requirements.

Note: There is a correlation

between this article and

article 4 of Directive

2008/1/EC.

2011.01.06

Chapter II.

Provisions for

activities listed in

annex I.

Article 10.

Scope

This Chapter shall apply to the activities set

out in Annex I and, where applicable, reaching

the capacity thresholds set out in that Annex.

Some of the activities

carried out in shipyards are

identified in Annex I (see

Attachment 2 – point 6.7)

The activities identified in

Annex I include:

Surface treatment using

organic solvents, in

particular for coating,

degreasing, waterproofing,

sizing, painting, cleaning,

with an organic solvent

consumption capacity of

more than 150 kg per hour

or more than 200 tonnes

per year

2011.01.06



D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Chapter II.

Provisions for


annex I.

Article 11.

General principles

governing the basic

obligations of the

operator.

Paragraphs a, b, c,

d, e, f.


measures to provide that installations are

operated in accordance with the following

principles:

(a) all the appropriate preventive measures are

taken against pollution;

(b) the best available techniques are applied;

(c) no significant pollution is caused;

(d) the generation of waste is prevented in

accordance with Directive 2008/98/EC;

(e) where waste is generated, it is, in order of

priority and in accordance with Directive

2008/98/EC, prepared for re-use, recycled,

recovered or, where that is technically and

economically impossible, it is disposed of

while avoiding or reducing any impact on

the environment;

(f) energy is used efficiently;

Equivalent of article 3 of

Directive 2008/1/EC.

2011.01.06

Chapter II.

Provisions for


annex I.

Article 13.

BAT reference

documents and

exchange of

information

Paragraphs 1&2

1. In order to draw up, review and, where

necessary, update BAT reference

documents, the Commission shall organise

annex change of information between

Member States, the industries concerned,

non-governmental organisations promoting

environmental protection and the

Commission.

2. The exchange of information shall, in

particular, address the following:

(a) the performance of installations and

techniques in terms of emissions,

expressed as short- and long-term

averages, where appropriate, and the

associated reference conditions,

consumption and nature of raw materials,

water consumption, use of energy and

generation of waste;

(b) the techniques used, associated

monitoring, cross-media effects, economic

and technical viability and developments

therein;

(c) best available techniques and emerging

techniques identified after considering the

issues mentioned in points (a) and (b).

Equivalent of article 6 of


See 8.1.5. BREF document.

2011.01.06



D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Chapter V.

Special provisions

for installations and

activities using

organic solvents,

Article 58.

Substitution of

hazardous

substances

Substances or mixtures which, because of

their content of volatile organic compounds

classified as carcinogens, mutagens, or toxic

to reproduction under Regulation (EC) No

1272/2008, areas signed or need to carry the

hazard statements H340, H350, H350i,

H360D or H360F, shall be replaced, as far as

possible by less harmful substances or

mixtures within the shortest possible time.

Shipyards because of using

organic solvents in

technological processes are

subjected to the

requirements of this article.

2011.01.06

Chapter V.

Special provisions


activities using

organic solvents,

Article 59.

Control of

emissions,

Paragraph 1 (a,b),

2, 3


measures to ensure that each installation

complies with either of the following:

a) the emission of volatile organic

compounds from installations shall not

exceed the emission limit values in

waste gases and the fugitive emission

limit values, or the total emission limit

values, and other requirements laid

down in Parts 2and 3 of Annex VII are

complied with;

b) the requirements of the reduction

scheme set out in Part 5 of Annex VII

provided that an equivalent emission

reduction is achieved compared to that

achieved through the application of the

emission limit values referred to in point

(a).

Shipyards may have to

upgrade or replace the

existing work practices and

or equipment in order to

conform to the latest

stipulated standards and

adopt approved techniques

to be able to comply with the

BAT guidelines in order to

minimize the waste

generation. Also in some

cases waste treatment

equipment may be needed to

be installed or upgraded.

The shipyards will have to

invest in training of the

personnel so that they are

able work and operate the

equipment conforming to the

laid emission standards of

this directive.

Though the shipyards need

not to comply with the

Emission Limit Values

(ELV) but they have to use

the best available techniques

(BAT) for the processes to

the satisfaction of the

authorities. This will lead to

the adoption of better

techniques for carrying out

the relevant activities and

using better and stricter

control of the emissions and

waste to be properly treated

before being discharged into

the environment.

2011.01.06



D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Chapter V.

Special provisions


activities using

organic solvents,

Article 59. Control

of emissions,

Paragraph 2

By way of derogation from paragraph 1(a),

where the operator demonstrates to the

competent authority that for an individual

installation the emission limit value for

fugitive emissions is not technically and

economically feasible, the competent authority

may allow emissions to exceed that emission

limit value provided that significant risks to

human health or the environment are not to be

expected and that the operator demonstrates to

the competent authority that the best available

techniques are being used.

2011.01.06

Chapter V.

Special provisions


activities using

organic solvents,

Article 59. Control

of emissions,

Paragraph 3

By way of derogation from paragraph 1, for

coating activities covered by item 8 of the

table in Part 2 of Annex VII which cannot be

carried out under contained conditions, the

competent authority may allow the emissions

of the installation not to comply with the

requirements set out in that paragraph if the

operator demonstrates to the competent

authority that such compliance is not

technically and economically feasible and that

the best available techniques are being used.

See 8.1.2 2011.01.06

Chapter V.

Special provisions


activities using

organic solvents,

Article 59. Control

of emissions,

Paragraph 5

The emissions of either volatile organic

compounds which are assigned or need to

carry the hazard statements H340,

H350,H350i, H360D or H360F or halogenated

volatile organic compounds which are

assigned or need to carry the hazard

statementsH341 or H351, shall be controlled

under contained conditions as far as

technically and economically feasible to

safeguard public health and the environment

and shall not exceed the relevant emission

limit values set out in Part 4 of Annex VII.

2011.01.06

Chapter V.

Special provisions


activities using

organic solvents,

Article 62.

Reporting on

compliance,

Paragraph a, b, c.

The operator shall supply the competent

authority, on request, with data enabling the

competent authority to verify compliance with

either of the following:

(a) emission limit values in waste gases,

fugitive emission limit values and total

emission limit values;

(b) the requirements of the reduction scheme

under Part 5 of Annex VII; (c) the

derogations granted in accordance with

Article 59(2)and (3).

2011.01.06



D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Chapter V.

Special provisions


activities using

organic solvents,

Article 63.

Substantial change

to existing

installations,

Paragraph 1 (a, b)

A change of the maximum mass input of

organic solvents by an existing installation

averaged over 1 day, where the installation is

operated at its design output under conditions

other than start-up and shut-down operations

and maintenance of equipment, shall be

considered as substantial if it leads to an

increase of emissions of volatile organic

compounds of more than:

(a) 25% for an installation carrying out either

activities which fall within the lower

threshold band of items 1, 3, 4, 5, 8, 10,13,

16 or 17 of the table in Part 2 of Annex

VII or, activities which fall under one of

the other items of Part 2 of Annex VII, and

with a solvent consumption of less than 10

tonnes per year;

(b) 10% for all other installations.

2011.01.06

Chapter V.

Special provisions


activities using

organic solvents,

Article 63.

Substantial change

to existing

installations,

Paragraph 2

Where an existing installation undergoes a

substantial change, or falls within the scope of

this Directive for the first time following a

substantial change, that part of the installation

which undergoes the substantial change shall

be treated either as a new installation or as an

existing installation, provided that the total

emissions of the whole installation do not

exceed those that would have resulted had the

substantially changed part been treated as a

new installation.

2011.01.06

Chapter VII.

Committee,

transitional and

final provisions

Article 72.

Reporting by

Member States

Paragraph 1

Member States shall ensure that information is

made available to the Commission on the

implementation of this Directive, on

representative data on emissions and other

forms of pollution, on emission limit values,

on the application of best available techniques

in accordance with Articles 14 and 15, in

particular on the granting of exemptions in

accordance with Article 15(4), and on

progress made concerning the development

and application of emerging techniques in

accordance with Article 27. Member States

shall make the information available in an

electronic format.

There are correlations

among this article and

articles 17 of Directive

2008/1/EC and 11 of




D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Chapter VII.

Committee,

transitional and

final provisions

Article 81

Repeal

Paragraph 1 and 3

Directives 78/176/EEC, 82/883/EEC,

92/112/EEC, 1999/13/EC, 2000/76/EC

and 2008/1/EC, as amended by the acts listed

in Annex IX, Part A are repealed with effect

from7 January 2014, without prejudice to the

obligations of the Member States relating to

the time limits for transposition into national

law and application of the Directives set out in

Annex IX, Part B.

References to the repealed Directives shall be

construed as references to this Directive and

shall be read in accordance with the

correlation table set out in Annex X.

The IED merges into a

single legal instrument seven

Directives, among others the

IPPCD (Directive

2008/1/EC) and the SED

(Directive 1999/13/EC on

the limitation of emissions

of volatile organic

compound).

2014.01.07

Annex I.

Categories of

activities referred to

in Article 10,

Activity category

6.7

Surface treatment of substances, objects or

products using organic solvents, in particular

for dressing, printing, coating, degreasing,

waterproofing, sizing, painting, cleaning or

impregnating, with an organic solvent

consumption capacity of more than 150 kg per

hour or more than 200 tonnes per year

The painting activities

carried out on the ships

cause the shipyards to be

included in the framework

regulations.

Shipyards carrying out

building and repair/retrofit

activities fall under this

category due to the painting

& other activities carried out

on the hull and other

equipment.

2011.01.06

Annex VII.

Technical

provisions relating

to installations and

activities using

organic solvents,

Part 1.

Activities, Activity

3b

Coating activity

(b) metallic and plastic surfaces including

surfaces of airplanes, ships, trains, etc.;

Shipyards need to carry out

all the activities in a manner

that least amount of

emissions and waste is

generated in the coating

activities which are

applicable to the shipyard

activities with a minimum

impact on air, water and land

as a whole.

Painting and surface

treatment activities are

carried on ships in shipyards

and are regulated as per this

directive.

2011.01.06



D 1.2



SU).


shipyards Comments

Date of

entry

into

force

Annex VII.

Technical

provisions relating


activities using

organic solvents,

Part 2. Thresholds

and emission limit

values,

Paragraph 8

See 8.1.2 2011.01.06

Annex VII.

Technical

provisions relating


activities using

organic solvents,

Part 4. Emission

limit values relating

to volatile organic

compounds with

specific risk

phrases,

Paragraph 2

For emissions of halogenated volatile organic

compounds which are assigned or need to

carry the hazard statements H341 or H351,

where the mass flow of the sum of the

compounds causing the hazard statements

H341 or H351 is greater than, or equal to, 100

g/h, an emission limit value of 20 mg/Nm3

shall be complied with. The emission limit

value refers to the mass sum of the individual

compounds.

2011.01.06

Annex VII.

Technical

provisions relating


activities using

organic solvents,

Part 5. Reduction

scheme,

Paragraph 1

The operator may use any reduction scheme,

specially designed for his installation.

2011.01.06

Annex VII.

Technical

provisions relating


activities using

organic solvents,

Part 7.

Solvent

management plan,

Paragraph 1

1. Principles

The solvent management plan shall be used to:

(a) verify compliance as specified in Article

62;

(b) identify future reduction options

2011.01.06



D 1.2


8.1.2 DIRECTIVE 2010/75/EU: Thresholds and emission limit values of activities

using organic solvents.

The following table set out, for activities using organic solvents, the maximum permissible limits for

emissions from stationary point sources and also for fugitive emission from not stationary point sources.

Table 13: DIRECTIVE 2010/75/EU: Table in Part 2 of Annex VII.

Thresholds and emission limit values of activities using organic solvents

Activity

(solvent consumption threshold in

tonnes/year)

Threshold

(solvent

consumption

threshold in

tonnes/year)

Emission limit

values in

waste gases

(mgC/Nm3)

Fugitive emission limit values

(percentage of solvent input)

New

installations

Existing

installations

4 Surface cleaning using components

specified in Article 59(1)

(> 1)

1 -5 20 (2) 15

> 5 20 (2) 10

5 Other surface cleaning

(> 2) 2 – 10 75 (3) 20 (3)

> 10 75 (3) 15 (3)

8 Other coating, including metal,

plastic, textile, fabric, film and paper

coating;

(> 5)

5-15 100 (4) (6) 25 (6)

> 15 50/75 (5) (6) 20 (6)

10 Coating of wooden surfaces

(> 15) 15-25 100 (7) 25

> 25 50/75 (8) 20

Special Provisions

(1) Using compounds specified in Article 5(6) and (8).

(2) Limit value refers to mass of compounds in mg/Nm3, and not to total carbon.

(3) Installations which demonstrate to the competent authority that the average organic solvent content of all

cleaning material used does not exceed 30% by weight are exempt from application of these values.

(4) Emission limit value applies to coating application and drying processes operated under contained conditions.

(5) The first emission limit value applies to drying processes, the second to coating application processes.

(6) Coating activities which cannot be carried out under contained conditions (such as shipbuilding, aircraft

painting) may be exempted from these values, in accordance with Article 59(3).

―…, for coating activities which cannot be carried out under contained conditions, the competent authority may allow

the emissions of the installation not to comply with the requirements set out in that paragraph if the operator

demonstrates to the competent authority that such compliance is not technically and economically feasible and that

the best available techniques are being used.‖

(7) Emission limit applies to coating application and drying processes operated under contained conditions.

(8) The first value applies to drying processes, the second to coating application processes.

Note: The emission limit values in waste gases shall be calculated at a temperature of 273,15 K, and a pressure of 101,3 kPa.



D 1.2


8.1.3 DIRECTIVE 2010/75/EU: Emission limits values relating to volatile organic

compounds (VOC) with specific hazard statements.

When in a shipyard are used Substances or mixtures which have assigned any of the below hazard

statements, the following Emission limits values relating to volatile organic compounds (VOC) must be

meet in any case, according with the DIRECTIVE 2010/75/EU, Part 4 of Annex VII.

Table 14: DIRECTIVE 2010/75/EU: Part 4 of Annex VII.

Hazard Statements ELV* (mg /Nm³)

H340, H350, H350i, H360D or

H360F.

2

where the mass flow of the sum of the compounds causing the

labelling referred to in the Article58 is greater than, or equal to,

10 g/h

H341 or H351

20 For emissions of halogenated volatile organic compounds where

the mass flow of the sum of the compounds causing the hazard

statements is greater than, or equal to, 100 g/h

*ELV, refers to the mass sum of the individual compounds.



D 1.2


8.1.4 Best Available Techniques (BREF)

Below some relevant sections are quoted form the ‗Reference Document on Best Available Techniques

(BREF) on Surface Treatment using Organic Solvents (August 2007)‘, pertaining to the shipyard activities

within the scope of the IPPC Directive 2008/1/EC.

Detailed guidelines regarding the BATs for shipyard activities involving painting and the use of organic

solvents on ships can be referred to the sections 1, 11, 21.11 and 22.10 from the quoted BREF document.

Best Available Techniques for painting activities carried on ships and yachts

Source: Reference Document on Best Available Techniques on Surface Treatment using Organic Solvents

(August 2007)

Chapter 11

Coatings of Ships and Yachts

Paragraph:

11.4.8 Waste gas treatment

Description: For a general description, see Section 20.11.

Emissions from painting and blasting activities can be reduced effectively by using closed

workshops (see Sections 11.4.2.3 and 20.11.2.1). These can be equipped with waste gas treatment

techniques as described in Section 20.11.

For example, VOC containing waste gases from spraying can be adsorbed via activated carbon

(see Section 20.11.6.1). Alternatively, the organic solvents can be treated in a thermal oxidiser

(see Section 20.11.4.4). Where concentrations of VOC allow, the solvent can be regenerated from

absorption, or the thermal oxidiser used can be regenerative and recover the heat from the

oxidation process.

Dust and overspray particles may be treated by techniques described in Section 20.11.3.

Achieved Environmental Benefits: Significant reduction in VOCs and/or dust emissions.

At the example plant, a waste gas treatment installation of 300000 m3/hr capacity is used. VOC

emissions are reduced by 75% and an average clean gas concentration of 23 mg/m3 is achieved.

Efficient ventilation and dust abatement systems enable a five-fold change of air each hour and in

the cleaned air, dust concentrations of less than 5 mg/m3 can be achieved.

Cross-media effects: Energy consumption for waste gas treatment.

Operational data: Dust levels may have to be reduced prior to VOC abatement.

Applicability: Applicable to the refurbishment of shipyards.

Economics: High costs are involved.

11.4.9 Waste water treatment

Description: Waste water can be treated prior to discharge, either at the source (e.g. when slurry

blasting) or collected and sent to a waste water treatment plant, either on or off-site. The treatment

required will depend on the substances present and the discharge point (to surface waters such as

the harbour, or to the municipal foul sewer). Section 20.12 discusses several waste water treatment

techniques and provides other sources of information.



D 1.2


Achieved Environmental Benefits: Reduction in water pollution, particularly in enclosed

harbours or estuarial areas.

Cross-media effects: Any energy and chemicals used in treatment.

Operational data: For example:

(i) When using water blasting techniques, the waste water can be collected in the dock, put into

tanks and fed into waste water treatment plants (see Section 11.3.2.2).

(ii) At one installation, the waste water treatment is in several steps consisting of precipitation and

flocculation (such as by using iron (III) chloride), followed by separation and filtration. To

reduce the volume and weight of waste produced, the separated sludge is pressed prior to

disposal. The cleaned waste water is re-used or, in the case of surplus water, discharged as

waste water. With this system, emission levels for filterable substances of 10 mg/l can be

achieved after treatment.

Applicability: Readily applied.

11.4.10 Waste management

Description: The following residues are collected and their disposal is managed according to the

relevant legislation and procedures. This is particularly important prior to flooding a dry dock:

- paint residues that have been removed

- paint leftovers, and used paint recipients

- coating overspray

- used and contaminated blasting abrasives

- cleaning materials

- Mud, oily residues and other materials that have been scraped off or removed.

Some materials, such as used abrasives and scrap materials may be collected separately to assist

their recycling and re-use.

Achieved environmental benefits: Prevents contamination of the water environment



D 1.2




(August 2007)

Chapter 21

Best Available Techniques for Surface Treatment using Organic Solvents

Paragraph:

21.11 Best available techniques for the coating of ships and yachts

The Introduction to this chapter (in the section ‗Some aids to understand this chapter‘, Paragraph

2) sets out how the BAT in this section relate to the generic BAT in Section 21.1.

The sale and use of antifouling containing tri-butyl-tin oxide (TBTO) is controlled by EU

legislation, see Section 11.2.3. Options for less eco-toxic antifouling coatings are described in

Section 11.4.5.

BAT is to minimise the emissions to the environment by ensuring that the BAT in this section are

included in the dry dock discipline for the installation.

Solvent emissions to air

BAT is to reduce VOC emissions by a combination of the following techniques in conjunction

with the generic BAT described in Section 21.1:

- Using water-based, high solids or 2-component paints (with or without using hot spraying,

see Section 11.4.4.2) instead of traditional solvent-based paints (see Section 11.4.2). The

extent of substitution may be limited by the customer requirements and the technical

requirements for the coating

- reducing overspray and increasing application efficiency (see Section 11.4.6) by keeping the

overspray at the bottom of the dry dock by:

- the use of nets, water curtains or other methods

- limiting spraying in weather conditions where the wind intensity and direction will

increase overspray

- for new construction, spraying the sections constructed prior to assembly (‗block stages‘) in

enclosed areas (see Section 11.2.1)

- extracting air from enclosed areas where spraying is carried out and applying a suitable

combination of the waste gas treatment techniques described in Section 20.11 (see also

Section 11.4.6.3).

Particulate emissions to air

BAT is to reduce dust particulate emissions to air by one or more of the following techniques:

- containing the dust and any abrasive and removed paint particles within the dock or the

slipway by:

- the use of nets and/or water curtains or another similar method

- limiting paint removal with an abrasive in weather conditions where the wind

intensity and direction will increase dust drift

- The use of shroud blasting or vacuum blasting, high pressure water or slurry blasting,

(see Sections 11.4.3.2, 11.4.3.3, 11.4.3.4) according to technical requirements.

BAT is to reduce waste water contamination by removing paint residues, leftovers and containers,



D 1.2


used abrasives, mud, oil residues and any other scrap materials from the dock before flooding.

These materials are to be kept in containers for proper management, e.g. re-use and/or disposal

(see Sections 11.3.3.1 and 20.12).



(August 2007)

Chapter 22

Emerging Techniques for Surface Treatment using Solvents

22.10 Coating of ships and yachts

22.10.1 Hot electrostatic air mix

Description: This technique can be used indoors and outdoors. Because of the heating of the

paint, the right viscosity can be gained so less VOC is emitted. Note that production can be lower

than with conventional techniques.

Achieved Environmental Benefits: Reduced VOC emissions.

Applicability: Applicable indoors, for example with maintenance and repair work, and outdoors,

in combination with S-shaped windscreens.

Example plant: In the Netherlands, a pilot is being carried out to use hot electrostatic air mix

techniques on ships.

22.10.2 Replacement of antifouling paints based on biocides (substitution)

22.10.2.1 Paints with natural biocides

Description: Natural biocides are produced, for example, by some coral species as a protection

against fouling

Achieved Environmental Benefits: This antifouling system does not contain heavy metals or

biocides.

Operational data: These substances show a lower persistence due to a better biodegradability

rating compared to inorganic materials such as copper compounds or TBT.

Applicability: Paints containing natural biocides are still being tested.

22.10.2.2 Coatings with special surface properties for a reduction of fouling

Description: Coatings with a special surface structure such as micro-roughness can be used for a

reduction of fouling.

Achieved Environmental Benefits: This antifouling system does not contain heavy metals or

biocides.

Operational data: A pilot project for the testing of environmentally sound antifouling paints was

carried out by an environmental regulator, a green NGO and paint manufacturers. During the

study, this type of coating performed the best out of all biocide-free materials.

Applicability: Applicable to all ships.

Economics: Costs are claimed to comparable to other tin- and copper-free antifoulings.

Driving Forces for Implementation: SED, Water pollution legislation and policies.



D 1.2


In the following text a section of chapter 23 has been quoted which shows that the data available is very

limited and calls for more data to better understand the processes and issue BATs.



(August 2007)

Chapter 23

Concluding Remarkss

Paragraph: 23.4.2

‘Coating of trains, agricultural and construction equipment, ships and yachts, aircraft, other metal

surfaces, plastics: Very little information was received on these topics, although significant additional

information was provided after Draft 2 for ship repair. Conclusions were drawn for other metal surfaces

and plastics based on the automotive (OEM) installations and the expert opinion of the TWG.

Recommendation: More data are required in these areas to improve the quality of the BAT conclusions.

Data on the manufacturing and coating of new ships and yachts (particularly using polyester resins) are

needed. The shipping industry (and others) may not understand that high solids paints (with lower solvent

emissions) may be more expensive per kg, but the same price per m2 treated: more information needs to

be made available on this‘.



D 1.2


9 EU Regulation concerning the establishment of the European

Pollutant Release and Transfer Register

9.1 Regulation (EC) No 166/2006 of the European Parliament and the Council

of 18 January 2006 concerning the establishment of the European Pollutant

Release and Transfer Register and amending Council directives 91/689/EEC

and 96/61/EC.

This Regulation establishes an integrated pollutant release and transfer register at Community level (‗the

European PRTR‘) in the form of a publicly accessible electronic database and lays down rules for its

functioning.

Under this regulation, operators of industrial installations, leading at least one of the activities listed in

Annex I to Regulation, are required to prepare annual reports on the quantities:

releases to air, water and land of any pollutant specified in Annex II of Regulation for which the

applicable threshold value specified in Annex II is exceeded;

off-site transfers of hazardous waste for any operations of recovery or disposal for which the

applicable threshold value specified in Annex II is exceeded;

any pollutant specified in Annex II in waste water destined for waste-water treatment for which the

threshold value specified in Annex II column 1b is exceeded.

Pollutant release and transfer registers (‗PRTRs‘) provide public access with information on releases of

pollutants and off-site transfers of pollutants and waste, and can be used in tracking trends, demonstrating

progress in pollution reduction, monitoring compliance with certain international agreements, setting

priorities and evaluating progress achieved through Community and national environmental policies and

programs.

The reporting for E-PRTR concerns operator of installations requiring integrated permits. Besides them,

also includes among other things: installations for the building of, and painting or removal of paint from

ships with a capacity for ships 100 m long. The requirements for repair shipyards resulting from this

regulation are presented in Table 15.

Table 15: Detailed discussion of European Pollutant Release And Transfer Register Regulation

2006/166/EC.


shipyards Comments

Date of

entry into

force

Article 3.

Content of the

European PRTR

The European PRTR shall include information

on:

(a) releases of pollutants referred to in Article

5(1)(a) that must be reported by the

operators of the facilities carrying out the

activities listed in Annex I;

(b) off-site transfers of waste referred to in

Article 5(1)(b) and of pollutants in waste

water referred to in Article 5(1)(c), that must

be reported by the operators of the facilities

carrying out the activities listed in Annex I;

Shipyards cover a range of

Annex I, issues 9 c and e.

2006.02.24



D 1.2



2006/166/EC.


shipyards Comments

Date of

entry into

force

Article 5.

Reporting by

operators,

paragraph 1

The operator of each facility that undertakes one

or more of the activities specified in Annex I

above the applicable capacity thresholds specified

therein shall report the amounts annually to its

competent authority, along with an indication of

whether the information is based on

measurement, calculation or estimation, of the

following:

(a) releases to air, water and land of any

pollutant specified in Annex II for which the

applicable threshold value specified in

Annex II is exceeded;

(b) off-site transfers of hazardous waste

exceeding 2 tonnes per year or of non

hazardous waste exceeding 2 000 tonnes per

year, for any operations of recovery or

disposal with the exception of the disposal

operations of land treatment and deep

injection referred to in Article 6, indicating

with ‗R‘ or ‗D‘ respectively whether the

waste is destined for recovery or disposal

and, for transboundary movements of

hazardous waste, the name and address of

the recovered or the disposer of the waste

and the actual recovery or disposal site;

(c) off-site transfers of any pollutant specified in

Annex II in waste water destined for waste-

water treatment for which the threshold

value specified in Annex II, column 1b is

exceeded.

The operator of each facility that undertakes one

or more of the activities specified in Annex I

above the applicable capacity thresholds specified

therein shall communicate to its competent

authority the information identifying the facility

in accordance with Annex III unless that

information is already available to the competent

authority.

In the case of data indicated as being based on

measurement or calculation the analytical method

and/or the method of calculation shall be reported.

The releases referred to in Annex II reported

under point (a) of this paragraph shall include all

releases from all sources included in Annex I at

the site of the facility.

Shipyards are covered by

this regulation when they

perform the following

activities, above the

mentioned applicable

capacity:

1.f) Installations for

surface treatment of metals

and plastic materials using

an electrolytic or chemical

process where the volume

of the treatment vats

equals 30 m3;

6.c) Industrial plants for

the preservation of wood

and wood products with

chemicals with a

production capacity of 50

m3 per day;

9.c) Installations for the

surface treatment of

substances, objects or

products using organic

solvents, in particular for

dressing, printing, coating,

degreasing, waterproofing,

sizing, painting, cleaning

or impregnating with a

consumption capacity of

150 kg per hour or 200

tonnes per year;

9.e) Installations for the

building of, and painting or

removal of paint from

ships with a capacity for

ships 100 m long.

2006.02.24



D 1.2



2006/166/EC.


shipyards Comments

Date of

entry into

force

Article 5.

Reporting by

operators,

paragraph 2

The information referred to in paragraph 1 shall

include information on releases and transfers

resulting as totals of all deliberate, accidental,

routine and non-routine activities.

In providing this information, operators shall

specify, where available, any data that relate to

accidental releases.

(e) the necessary measures are taken to prevent

accidents and limit their consequences;

(f) the necessary measures are taken upon

definitive cessation of activities to avoid any

pollution risk and return the site of operation to a

satisfactory state.

2006.02.24

Article 5.

Reporting by

operators,

paragraph 3

The operator of each facility shall collect with

appropriate frequency the information needed to

determine which of the facility‘s releases and off-

site transfers are subject to reporting requirements

under paragraph 1.

2006.02.24

Article 5.

Reporting by

operators,

paragraph 4

When preparing the report, the operator

concerned shall use the best available

information, which may include monitoring data,

emission factors, mass balance equations, indirect

monitoring or other calculations, engineering

judgments and other methods in line with Article

9(1) and in accordance with internationally

approved methodologies, where these are

available.

2006.02.24

Article 5.

Reporting by

operators,

paragraph 5

The operator of each facility concerned shall keep

available for the competent authorities of the

Member State the records of the data from which

the reported information was derived for a period

of five years, starting from the end of the

reporting year concerned. These records shall also

describe the methodology used for data gathering.


must keep the records of the

data included in the reports

as well as the methodology

used for data gathering.

2006.02.24

Article 7.

Reporting by

Member States,

paragraph 1

The Member States shall determine, having

regard to the requirements set out in paragraphs 2

and 3 of this Article, a date by which operators

shall provide all the data referred to in Article

5(1) and (2) and the information referred to in

Article 5(3), (4) and (5) to its competent

authority.


should provide all the data

and information referred to

in Article 5, on the date

specified by each Member

State.

2006.02.24

Article 9.

Quality

assurance and

assessment,

paragraph 1

The operator of each facility subject to the

reporting requirements set out in Article 5 shall

assure the quality of the information that they

report.

2006.02.24



D 1.2


10 EU Regulation on the prohibition of organotin compounds on

ships

10.1 Regulation (EC) No 782/2003 of the European Parliament and the Council

of 14 April 2003 on the prohibition of organotin compounds on ships

amended by Commission Regulation (EC) No 536/2008 of 13 June 2008

Organotin compounds used as anti-fouling systems on ships, and in particular of tributyltin(TBT) coatings

turned out to have a harmful environmental effects. The regulation on the prohibition of organotin

compounds on ships is an instrument imposing on shipowners and member states of EU, directly and

within a short time frame, precise requirements to be implemented at the same time and in the same manner

throughout the Community. This regulation seek solely to prohibit organotin compound and should not

duplicate the Antifouling System Convention (AFS Convention).

Regulation entered into force on 17th of September, 2008 and introduced prohibition antyfouling paints

and system with oraganotin by shipyards for applying on ships. Detailed discussion on the regulation in

terms of repair shipyards is given in Table 16.

Table 16: Detailed discussion of Regulation of The Prohibition of Organization Compounds on Ships

782/2003/EC.


shipyards Comments

Date of

entry

into

force

Article 1.

Objective

Reduce or elimination adverse effects on the

marine environment and human health caused

by organotin compounds, which act as active

biocides in anti-fouling systems used on ships

2003.05.10

Article 3.

Scope,

paragraph 1 and 2

1. This Regulation shall apply to:

(a) ships flying the flag of a Member State,

(b) ships not flying the flag of a Member

State but operating under the authority of a

Member State, and

(c) ships that enter a port or offshore

terminal of a Member State but do not fall

within points (a) or (b).

2. This Regulation shall not apply to any

warship, naval auxiliary or other ship owned

or operated by a State and used, for the time

being, only on government non-commercial

service.

Shipyards cannot utilize for

applying on ships

antifouling systems and

antifouling paints composed

of organotin compounds

such as e.g. tributyltin

(TBT). with exception of

any warship, naval auxiliary

or other ship owned or

operated by a State and used

only on government non-

commercial service

2003.05.10

Article 4.

Prohibition of the

application of

organotin

compounds which

act as biocides,

paragraph 1

As from 1 July 2003, organotin compounds

which act as biocides in anti-fouling systems

shall not be applied or re-applied on ships.

However, during the interim period this

provision shall only apply to ships referred to

in points (a) or (b) of Article 3(1).

Shipyards cannot utilize for

applying on ships

antifouling systems and

antifouling paints composed

of organotin compounds

such as e.g. tributyltin

(TBT).

2003.05.10



D 1.2


Table 16: Detailed discussion of Regulation of The Prohibition of Organization Compounds on Ships

782/2003/EC.


shipyards Comments

Date of

entry

into

force

Article 5.

Prohibition of the

bearing of

organotin

compounds which

act as biocides,

paragraph 1

Ships entitled to fly the flag of a Member

State as from 1 July 2003, and whose anti-

fouling system has been applied, changed or

replaced after that date, shall not bear

organotin compounds which act as biocides in

anti-fouling systems on their hulls or external

parts and surfaces, unless they bear a coating

that forms a barrier to such compounds to

prevent them leaching from the underlying

noncompliant anti-fouling system

Repair shipyards should be

prepared for applying

coatings that forms a barrier

to organotin compounds

leaching from the underlying

non-compliant anti-fouling

system.

2003.05.10

Article 5.

Prohibition of the

bearing of

organotin

compounds which

act as biocides,

paragraph 2

As from 1 January 2008 the ships referred to

in Article 3(1) shall either not bear organotin

compounds which act as biocides in

antifouling systems on their hulls or external

parts and surfaces, or bear a coating that forms

a barrier to such compounds leaching from the

underlying non-compliant anti-fouling system

As above. 2003.05.10

Article 5.

Prohibition of the

bearing of

organotin

compounds which

act as biocides,

paragraph 3

Paragraphs 1 and 2 shall not apply to fixed

and floating platforms, FSUs and FPSOs

constructed prior to 1 July 2003 that have not

been in dry-dock on or after that date

Repair shipyards should be

prepared for maintenance

fixed and floating platforms,

FSUs and FPSOs

constructed prior to 1 July

2003 that have not been in

dry-dock yet and can still

use harmful antifouling

system (containing organotin

compounds)

2003.05.10



D 1.2


11 Conclusions

On the basis of conducted analysis of EU directives and regulation, there have been specified emission

standards, prohibitions, responsibilities, and obligations for the ship repair shipyards.

But also have been identified changes in the law, ambiguities in the legislation, and unresolved problems.

11.1 Summary of specified emission standards, prohibitions, responsibilities, and

obligations for the ship repair shipyards

A) Emission Standards

For the activity performed in shipyard described as: ―Other coating, including metal, plastic, textile, fabric,

film and paper‖ shipyards should meet or with a) or with b)

a) With the following Fugitive emission limit values

- If Threshold (solvent consumption threshold in tonnes/year) is between 5-15 tonnes per

year, for new and existing installation, the Fugitive emission limit values equals 25% of

solvent input.

- If Threshold > 15 tonnes per year, for new and existing installation, the Fugitive emission

limit values equals 20% of solvent input.

Wherein:

Coating activities which cannot be carried out under contained condition (such as: shipbuilding,

aircraft paintings) may be exempted from these value in accordance with Article 59 (3) of Directive

2010/75/EU (IED)

b) With the requirements of the reduction scheme set out in Part 5 of Annex VII of Directive

2010/75/EU (IED) provided that an equivalent emission reduction is achieved compared to that

achieved through the application of the emission limit values referred to in point (a).

B) Prohibitions

There is a Prohibition on using harmful organotin compound in the shipyards.

C) Responsibilities

Shipyards must manage waste and use of water according to the relevant requirements.

Shipyards must begin to assess their use of water resources and the impact of the business on the

water environment. They should also begin to review the composition of all losses to water.



D 1.2


Shipyards, like all water consumers, will have a new responsibility in the future to minimise their

impact on the water environment. They will have to remove small amounts of contaminants found

in waste water; they will be obliged to remove such traces at source.

Shipyards (waste original producer) are responsible for the proper waste management even when

the waste is transferred to another legal person of the treatment chain.

D) Obligations

Shipyards must hold a permit by each installation, or by way of derogation, member states may set

a procedure for the registration of installations covered only by Chapter V of Directive 2010/75/EU

(IED).

Shipyards that undertakes activities described below,

- ―Installations for the surface treatment of substances, objects or products using organic

solvents, in particular for dressing, printing, coating, degreasing, waterproofing, sizing,

painting, cleaning or impregnating‖ with capacity threshold: ―a consumption capacity of

150 kg per hour or 200 tonnes per year‖.

- ―Installations for the building of, and painting or removal of paint from ships‖ with

capacity threshold ―a capacity for ships 100 m long‖.

must report annually to the European Pollutant Release and Transfer Register (E-PRTR) the

amounts of the following:

a) releases to air, water and land of any pollutant specified in Annex II of Regulation 166/2006

for which the applicable threshold value specified in Annex II is exceeded;

b) off-site transfers of hazardous waste exceeding 2 tonnes per year or of non hazardous waste

exceeding 2000 tonnes per year, for any operations of recovery or disposal with the exception

given in Article 5 of the Regulation

c) off-site transfers of any pollutant specified in Annex II of the Regulation in waste water

destined for waste-water treatment for which the threshold value specified in Annex II, column

1b is exceeded.

A shipyard that undertakes activities mentioned above, over the specified applicable capacity

threshold shall communicate to its competent authority the information identifying the facility in

accordance with Annex III of the Regulation.



D 1.2


11.2 Changes in the law and implications

Analysis of legislation relating to the activities of the shipyard has revealed that the introduction into force

of DIRECTIVE 2010/75/EU on industrial emissions (IED) may have implications for shipyards.

Particularly noteworthy is the fact that two Directives 1999/13/EC and 2008/1/EC are repealed with effect

from 7 January 2014.

According to IED Article 82 Transitional provisions concerning shipyards activities should be taken into

account that:

For Installations carrying out activities referred to in point 6.7 of the IED-Annex I, (which are in

operation and hold a permit before 7 January 2013 or the operators of which have submitted a

complete application for a permit before that date, provided that those installations are put into

operation no later than 7 January 2014); Member States shall apply the laws, regulations and

administrative provisions adopted in accordance with IED Article 80(1) from 7 January 2014.

Notes:

1. The Activities included in point 6.7 are: Surface treatment of substances, objects or products using

organic solvents, in particular for dressing, printing, coating, degreasing, waterproofing, sizing,

painting, cleaning or impregnating, with an organic solvent consumption capacity of more than

150 kg per hour or more than 200 tonnes per year.

IED Article 58 shall apply from 1 June 2015. Until that date, substances or mixtures which,

because of their content of volatile organic compounds classified as carcinogens, mutagens, or

toxic to reproduction under Regulation (EC) No 1272/2008, areas signed or need to carry the

hazard statements H340, H350, H350i, H360D or H360F or the risk phrases R45, R46, R49, R60

or R61, shall be replaced, as far as possible, by less harmful substances or mixtures within the

shortest possible time.

IED Article 59, paragraph 5 shall apply from 1 June 2015. Until that date, the emissions of either

volatile organic compounds which areas signed or need to carry the hazard statements H340, H350,

H350i, H360D or H360F or the risk phrases R45, R46, R49, R60or R61 or halogenated volatile

organic compounds which areas signed or need to carry the hazard statements H341 or H351or the

risk phrases R40 or R68, shall be controlled under contained conditions, as far as technically and

economically feasible, to safeguard public health and the environment and shall not exceed the

relevant emission limit values set out in Part 4 of Annex VII.

IED Point 2 of Part 4 of Annex VII shall apply from 1 June 2015. Until that date, for emissions

of halogenated volatile organic compounds which are assigned or need to carry the hazard

statements H341 or H351 or the risk phrases R40 or R68, where the mass flow of the sum of the

compounds causing the hazard statements H341 or H351 or the labelling R40 or R68 is greater

than, or equal to, 100 g/h, an emission limit value of 20 mg/Nm3 shall be complied with. The

emission limit value refers to the mass sum of the individual compounds.



D 1.2


11.3 Ambiguities in the legislation: Unresolved problems

Directives as master documents cover a very broad areas of activities and ways to solve the problems they

set out. This often involves the ambiguity of records, requiring additional guidance and interpretation,

which may vary in each European countries.

To be highlighted that as indicated in section 6.1.4

According with DIRECTIVE 2010/75/EU Table in Part 2 of Annex VII, Coating activities which

cannot be carried out under contained conditions (such as shipbuilding painting) may be exempted

from the thresholds and emission limit values of activities using organic solvents. For these coating

activities which cannot be carried out under contained conditions, the reduction scheme of Annex

IIB is then to be used, unless it is demonstrated to the satisfaction of the competent authority that

this option is not technically and economically feasible. In this case, the operator must demonstrate

to the satisfaction of the competent authority that the best available technique is being used.

As the conditions in the ship repair activity are the so-called uncontrollable type that means the gas

emissions are diffuse but not organized, the requirements for adherence to the emissions stated,

respectively 20 mg C/N m3, are not applicable. In this case the operator must demonstrate to the

satisfaction of the competent authority, that the best available techniques are used, but it is not an

easy task.

Ship repair industry is harmed by the lack of clear criteria for best available techniques and

supervisory authorities have difficulties in taking a decision about the use of the best available

techniques by operators.

The operators, engaged in ship repair in most cases are unable to control the type and quantities, of

the substances used in the activities. It leads not only to inaccurate data in the plans for solvent

usage preparation but also to insufficiently correct final results and conclusions regarding the

environmental pollution by volatile organic compounds.

By other hand, the plan to reduce emissions of volatile organic compounds have to lead to reduce

the annual VOC emissions from existing installations that fall within the scope of this Directive. At

the same time for ship repair work, which is not so predictable and is strongly market depended, is

very difficult to be exactly defined in advance the volume of areas to be coated during the year and

therefore often occurs after a weak year the emissions for the next year to exceed several times

those of previous

Therefore the following proposition could be made:

To set a representative value of the threshold limit emissions of volatile organic compounds and annual

reference emissions based on the product quantities (solid substances) consumed per coated surface unit ,

similar for instance to the coating activity for vehicles.



D 1.2


11.4 Utilizing of eco-innovations in ship repair sector

The legislation analysis has lead to the conclusion that directives are not applicable to research activities,

development activities or testing of new products and processes. Determination of legislation rules

concerning utilization of eco-innovative processes, structures, materials and modules in the stage of testing

in shipyard can be an encouragement for deciding to introduce changes during operations.

Meeting new requirements of environmental protection, resulting from tightening of the law, is a great

challenge for the shipyards, because two kinds of aspects are valid for the shipyard when the decision is to

be taken:

environmental considerations – scale, severity, probability, duration;

Business considerations – difficulty of changing impact; effect on public image/perception,

outcome of change on activities, products, or services; cost of changing impact.

The best solution for shipyards would be to find a balance between these two considerations and ECO-

REFITEC is aimed to provide the useful tools making this goal reachable.



D 1.2


12 Attachments

12.1 Attachment1: EU list of priority substances in the field of water policy

Decision No 2455/2001/EC of the European Parliament and of the Council of 20 November 2001

established the first list of priority substances in the field of water policy.

That list of priority substances, including substances identified as priority hazardous substances provided

for in Article 16(2) and (3) of Directive 2000/60/EC, was then added to Directive 2000/60/EC as Annex X.

Annex X was recently replaced by the text set out in Annex II to the Directive 2008/105/EC.

Table 17: List of priority substances in the field of water policy adopted by Decision No 2455/2001/EC

of the European Parliament and replaced by Annex II to the Directive 2008/105/EC.

Present Annex X of Directive 2000/60/EC

Number CAS number

(1)

EU number

(2)

Name of priority substance

(3)

Identified as priority

hazardous substance

(1) 15972-60-8 240-110-8 Alachlor

(2) 120-12-7 204-371-1 Anthracene X

(3) 1912-24-9 217-617-8 Atrazine

(4) 71-43-2 200-753-7 Benzene

(5) not applicable not applicable Brominated diphenylether (4) X (5)

32534-81-9 not applicable Pentabromodiphenylether (congener

numbers 28, 47, 99, 100, 153 and

154)

(6) 7440-43-9 231-152-8 Cadmium and its compounds X

(7) 85535-84-8 287-476-5 Chloroalkanes, C10-13 (4) X

(8) 470-90-6 207-432-0 Chlorfenvinphos

(9) 2921-88-2 220-864-4 Chlorpyrifos (Chlorpyrifos-ethyl)

(10) 107-06-2 203-458-1 1,2-dichloroethane

(11) 75-09-2 200-838-9 Dichloromethane

(12) 117-81-7 204-211-0 Di(2-ethylhexyl)phthalate (DEHP)

(13) 330-54-1 206-354-4 Diuron

(14) 115-29-7 204-079-4 Endosulfan X

(15) 206-44-0 205-912-4 Fluoranthene (6)

(16) 118-74-1 204-273-9 Hexachlorobenzene X

(17) 87-68-3 201-765-5 Hexachlorobutadiene X

(18) 608-73-1 210-158-9 Hexachlorocyclohexane X

(19) 34123-59-6 251-835-4 Isoproturon

(20) 7439-92-1 231-100-4 Lead and its compounds



D 1.2


Table 17: List of priority substances in the field of water policy adopted by Decision No 2455/2001/EC

of the European Parliament and replaced by Annex II to the Directive 2008/105/EC.

Present Annex X of Directive 2000/60/EC

Number CAS number

(1)

EU number

(2)

Name of priority substance

(3)

Identified as priority

hazardous substance

(21) 7439-97-6 231-106-7 Mercury and its compounds X

(22) 91-20-3 202-049-5 Naphthalene

(23) 7440-02-0 231-111-14 Nickel and its compounds

(24) 25154-52-3 246-672-0 Nonylphenol X

104-40-5 203-199-4 (4-nonylphenol) X

(25) 1806-26-4 217-302-5 Octylphenol

140-66-9 not applicable (4-(1,1′,3,3′-tetramethylbutyl)-phenol)

(26) 608-93-5 210-172-5 Pentachlorobenzene X

(27) 87-86-5 231-152-8 Pentachlorophenol

(28) not applicable not applicable Polyaromatic hydrocarbons X

50-32-8 200-028-5 (Benzo(a)pyrene) X

205-99-2 205-911-9 (Benzo(b)fluoranthene) X

191-24-2 205-883-8 (Benzo(g,h,i)perylene) X

207-08-9 205-916-6 (Benzo(k)fluoranthene) X

193-39-5 205-893-2 (Indeno(1,2,3-cd)pyrene) X

(29) 122-34-9 204-535-2 Simazine

(30) not applicable not applicable Tributyltin compounds X

36643-28-4 not applicable (Tributyltin-cation) X

(31) 12002-48-1 234-413-4 Trichlorobenzenes

(32) 67-66-3 200-663-8 Trichloromethane (chloroform)

(33) 1582-09-8 216-428-8 Trifluralin

(1) CAS: Chemical Abstracts Service.

(2) EU number: European Inventory of Existing Commercial Substances (Einecs) or European List of Notified

Chemical Substances (Elincs).

(3) Where groups of substances have been selected, typical individual representatives are listed as indicative

parameters (in brackets and without number). For these groups of substances, the indicative parameter must be

defined through the analytical method.

(4) These groups of substances normally include a considerable number of individual compounds. At present,

appropriate indicative parameters cannot be given.

(5) Only Pentabromobiphenylether (CAS-number 32534-81-9).

(6) Fluoranthene is on the list as an indicator of other, more dangerous polyaromatic hydrocarbons.’



D 1.2


12.2 Attachment 2: Environmental quality standards for priority substances and

certain other pollutants

In accordance with Article 1 of Directive 2008/105/EC and Article 4 of Directive 2000/60/EC, Member

States shall apply the EQS laid down in Table 18 below for bodies of surface water.

Member States shall apply the EQS for bodies of surface water in accordance with the requirements laid

down in Part B of Annex I.

Table 18: Environmental quality standards (EQS) for priority substances and certain other pollutants adopted by

Directive 2008/105/EC, Annex I – PART A and B

AA: annual average;

MAC: maximum allowable concentration.

Unit: [μg/l]

(1) (2) (3) (4) (5) (6) (7)

No Name of substance CAS number

(1)

AA-EQS(2)

Inland

surface

waters (3)

AA-EQS(2)

Other surface

waters

MAC-EQS(4)

Inland

surface

waters (3)

MAC-EQS(4)

Other

surface

waters

(1) Alachlor 15972-60-8 0,3 0,3 0,7 0,7

(2) Anthracene 120-12-7 0,1 0,1 0,4 0,4

(3) Atrazine 1912-24-9 0,6 0,6 2,0 2,0

(4) Benzene 71-43-2 10 8 50 50

(5) Brominated diphenylether

(5) 32534-81-9

0,0005 0,0002 not applicable not applicable

(6) Cadmium and its

compounds (depending on

water hardness classes)

(6)

7440-43-9 ≤ 0,08 (Class1)

0,08 (Class 2)

0,09 (Class 3)

0,15 (Class 4)

0,25 (Class 5)

0,2 ≤ 0,45 (Class1)

0,45 (Class 2)

0,6 (Class 3)

0,9 (Class 4)

1,5 (Class 5)

≤ 0,45 (Class1)

0,45 (Class 2)

0,6 (Class 3)

0,9 (Class 4)

1,5 (Class 5)

(6a) Carbon-tetrachloride (7) 56-23-5 12 12 not applicable not applicable

(7) C10-13 Chloroalkanes 85535-84-8 0,4 0,4 1,4 1,4

(8) Chlorfenvinphos 470-90-6 0.1 0.1 0.3 0.3

(9) Chlorpyrifos

(Chlorpyrifos-ethyl) 2921-88-2

0,03 0,03 0,1 0,1

(9a) Cyclodiene pesticides:

Aldrin (7)

Dieldrin (7)

Endrin (7)

Isodrin (7)

309-00-2

60-57-1

72-20-8

465-73-6

Σ = 0,01 Σ = 0,005 not applicable not applicable

(9b) DDT total (7)(8) not applicable 0,025 0,025 not applicable not applicable

para-para-DDT (7) 50-29-3 0,01 0,01 not applicable not applicable

(10) 1,2-Dichloroethane 107-06-2 10 10 not applicable not applicable

(11) Dichloromethane 75-09-2 20 20 not applicable not applicable



D 1.2




AA: annual average;


Unit: [μg/l]

(1) (2) (3) (4) (5) (6) (7)


(1)

AA-EQS(2)

Inland

surface

waters (3)

AA-EQS(2)

Other surface

waters

MAC-EQS(4)

Inland

surface

waters (3)

MAC-EQS(4)

Other

surface

waters

(12) Di(2-ethylhexyl)-

phthalate (DEHP) 117-81-7

1,3 1,3 not applicable not applicable

(13) Diuron 330-54-1 0,2 0,2 1,8 1,8

(14) Endosulfan 115-29-7 0,005 0,0005 0,01 0,004

(15) Fluoranthene 206-44-0 0,1 0,1 1 1

(16) Hexachloro-benzene 118-74-1 0,01 (9) 0,01 (9) 0,05 0,05

(17) Hexachloro-butadiene 87-68-3 0,1 (9) 0,1 (9) 0,6 0,6

(18) Hexachloro-cyclohexane 608-73-1 0,02 0,002 0,04 0,02

(19) Isoproturon 34123-59-6 0,3 0,3 1,0 1,0

(20) Lead and its compounds 7439-92-1 7,2 7,2 not applicable not applicable

(21) Mercury and its

compounds 7439-97-6

0,05 (9) 0,05 (9) 0,07 0,07

(22) Naphthalene 91-20-3 2,4 1,2 not applicable not applicable

(23) Nickel and its compounds 7440-02-0 20 20 not applicable not applicable

(24) Nonylphenol (4-

Nonylphenol) 104-40-5

0,3 0,3 2,0 2,0

(25) Octylphenol ((4-(1,1′,3,3′-

tetramethylbutyl)phenol))

140-66-9 0,1 0,01 not applicable not applicable

(26) Pentachloro-benzene 608-93-5 0,007 0,0007 not applicable not applicable

(27) Pentachloro-phenol 87-86-5 0,4 0,4 1 1

(28) Polyaromatic

hydrocarbons (PAH) (10) not applicable

not applicable not applicable not applicable not applicable

Benzo(a)pyrene 50-32-8 0,05 0,05 0,1 0,1

Benzo(b)fluor-anthene 205-99-2 Σ = 0,03 Σ = 0,03 not applicable not applicable

Benzo(k)fluor-anthene 207-08-9

Benzo(g,h,i)-perylene 191-24-2 Σ = 0,002 Σ = 0,002 not applicable not applicable

Indeno(1,2,3-cd)-pyrene 193-39-5

(29) Simazine 122-34-9 1 1 4 4

(29a) Tetrachloro-ethylene (7) 127-18-4 10 10 not applicable not applicable

(29b) Trichloro-ethylene (7) 79-01-6 10 10 not applicable not applicable

(30) Tributyltin compounds

(Tributhyltin-cation) 36643-28-4 0,0002 0,0002 0,0015 0,0015



D 1.2




AA: annual average;


Unit: [μg/l]

(1) (2) (3) (4) (5) (6) (7)


(1)

AA-EQS(2)

Inland

surface

waters (3)

AA-EQS(2)

Other surface

waters

MAC-EQS(4)

Inland

surface

waters (3)

MAC-EQS(4)

Other

surface

waters

(31) Trichloro-benzenes 12002-48-1 0,4 0,4 not applicable not applicable

(32) Trichloro-methane 67-66-3 2,5 2,5 not applicable not applicable

(33) Trifluralin 1582-09-8 0,03 0,03 not applicable not applicable

(1) CAS: Chemical Abstracts Service.

(2) This parameter is the EQS expressed as an annual average value (AA-EQS). Unless otherwise specified, it applies to the

total concentration of all isomers.

(3) Inland surface waters encompass rivers and lakes and related artificial or heavily modified water bodies.

(4) This parameter is the EQS expressed as a maximum allowable concentration (MAC-EQS). Where the MAC-EQS are

marked as ‗not applicable‘, the AA-EQS values are considered protective against short-term pollution peaks in continuous

discharges since they are significantly lower than the values derived on the basis of acute toxicity.

(5) For the group of priority substances covered by brominated diphenylethers (No 5) listed in Decision No 2455/2001/EC, an

EQS is established only for congener numbers 28, 47, 99, 100, 153 and 154.

(6) For cadmium and its compounds (No 6) the EQS values vary depending on the hardness of the water as specified in five

class categories (Class 1: < 40 mg CaCO3/l, Class 2: 40 to < 50 mg CaCO3/l, Class 3: 50 to < 100 mg CaCO3/l, Class 4:

100 to < 200 mg CaCO3/l and Class 5: ≥ 200 mg CaCO3/l).

(7) This substance is not a priority substance but one of the other pollutants for which the EQS are identical to those laid down

in the legislation that applied prior to 13 January 2009.

(8) DDT total comprises the sum of the isomers 1,1,1-trichloro-2,2 bis (p-chlorophenyl) ethane (CAS number 50-29-3; EU

number 200-024-3); 1,1,1-trichloro-2 (o-chlorophenyl)-2-(p-chlorophenyl) ethane (CAS number 789-02-6; EU number 212-

332-5); 1,1-dichloro-2,2 bis (p-chlorophenyl) ethylene (CAS number 72-55-9; EU number 200-784-6); and 1,1-dichloro-2,2

bis (p-chlorophenyl) ethane (CAS number 72-54-8; EU number 200-783-0).

(9) If Member States do not apply EQS for biota they shall introduce stricter EQS for water in order to achieve the same level

of protection as the EQS for biota set out in Article 3(2) of this Directive. They shall notify the Commission and other

Member States, through the Committee referred to in Article 21 of Directive 2000/60/EC, of the reasons and basis for using

this approach, the alternative EQS for water established, including the data and the methodology by which the alternative

EQS were derived, and the categories of surface water to which they would apply.

(10

) For the group of priority substances of polyaromatic hydrocarbons (PAH) (No 28), each individual EQS is applicable, i.e.

the EQS for Benzo(a)pyrene, the EQS for the sum of Benzo(b)fluoranthene and Benzo(k)fluoranthene and the EQS for the

sum of Benzo(g,h,i)perylene and Indeno(1,2,3-cd)pyrene must be met.

APPLICATION OF THE EQS SET OUT ABOVE (PART B)

1. Columns 4 and 5 of the table: For any given surface water body, applying the AA-EQS means that, for each representative

monitoring point within the water body, the arithmetic mean of the concentrations measured at different times during the

year does not exceed the standard.

The calculation of the arithmetic mean, the analytical method used and, where there is no appropriate analytical method

meeting the minimum performance criteria, the method of applying an EQS must be in accordance with implementing acts

adopting technical specifications for chemical monitoring and quality of analytical results, in accordance with Directive

2000/60/EC.

2. Columns 6 and 7 of the table: For any given surface water body, applying the MAC-EQS means that the measured

concentration at any representative monitoring point within the water body does not exceed the standard.



D 1.2




AA: annual average;


Unit: [μg/l]

(1) (2) (3) (4) (5) (6) (7)


(1)

AA-EQS(2)

Inland

surface

waters (3)

AA-EQS(2)

Other surface

waters

MAC-EQS(4)

Inland

surface

waters (3)

MAC-EQS(4)

Other

surface

waters

However, in accordance with section 1.3.4 of Annex V to Directive 2000/60/EC, Member States may introduce statistical

methods, such as a percentile calculation, to ensure an acceptable level of confidence and precision for determining

compliance with the MAC-EQS. If they do so, such statistical methods shall comply with detailed rules laid down in

accordance with the regulatory procedure referred to in Article 9(2) of this Directive.

3. With the exception of cadmium, lead, mercury and nickel (hereinafter ‗metals‘) the EQS set up in this Annex are

expressed as total concentrations in the whole water sample. In the case of metals the EQS refers to the dissolved

concentration, i.e. the dissolved phase of a water sample obtained by filtration through a 0,45 μm filter or any equivalent

pre-treatment.

Member States may, when assessing the monitoring results against the EQS, take into account:

a. natural background concentrations for metals and their compounds, if they prevent compliance with the EQS value;

and

b. hardness, pH or other water quality parameters that affect the bioavailability of metals.



D 1.2


12.3 Attachment 3: Categories of activities Listed in the IED Directive- Annex I

Table 19: Categories of activities Listed in the IED Directive –Annex 1.

General Activity Identified

Shipyard

Activity

1 Energy industries

…..

2 Production and processing of metals

2.1 Metal ore (including sulphide ore) roasting or sintering

2.2 Production of pig iron or steel (primary or secondary fusion) including continuous casting,

with a capacity exceeding 2,5 tonnes per hour

2.3 Processing of ferrous metals:

(c) Operation of hot-rolling mills with a capacity exceeding 20 tonnes of crude steel

per hour;

(d) Operation of smitheries with hammers the energy of which exceeds 50 kilo-joule

per hammer, where the calorific power used exceeds 20 MW;

(e) Application of protective fused metal coats with an input exceeding 2 tonnes of

crude steel per hour.

2.4 Operation of ferrous metal foundries with a production capacity exceeding 20 tonnes per day

2.5 Processing of non-ferrous metals:

a. production of non-ferrous crude metals from ore, concentrates or secondary raw

materials by metallurgical, chemical or electrolytic processes;

b. melting, including the alloy age, of non-ferrous metals, including recovered

products and operation of non-ferrous metal foundries, with a melting capacity

exceeding 4 tonnes per day for lead and cadmium or 20 tonnes per day for all other

metals.

2.6 Surface treatment of metals or plastic materials using an electrolytic or chemical process

where the volume of the treatment vats exceeds 30 m3

3 Mineral industry

….

4 Chemical industry

…..

5 Waste management

5.1 Disposal or recovery of hazardous waste with a capacity exceeding 10 tonnes per day

involving one or more of the following activities:

(a) biological treatment;

(b) physico-chemical treatment;

(c) blending or mixing prior to submission to any of the other activities listed in

points 5.1 and 5.2;

(d) repackaging prior to submission to any of the other activities listed in points 5.1

and 5.2;

(e) solvent reclamation/regeneration;

(f) recycling/reclamation of inorganic materials other than metals or metal

compounds;

(g) regeneration of acids or bases;

(h) recovery of components used for pollution abatement;

(i) recovery of components from catalysts;

(j) oil re-refining or other reuses of oil;



D 1.2




Shipyard

Activity

(k) surface impoundment.

5.2 Disposal or recovery of waste in waste incineration plants or in waste co-incineration plants:

(a) for non-hazardous waste with a capacity exceeding 3 tonnes per hour;

(b) for hazardous waste with a capacity exceeding 10 tonnes per day.

5.3 (a) Disposal of non-hazardous waste with a capacity exceeding 50 tonnes per day involving

one or more of the following activities, and excluding activities covered by Council

Directive 91/271/EEC of 21 May 1991 concerning urban waste-water treatment

(i) biological treatment;

(ii) physico-chemical treatment;

(iii) pre-treatment of waste for incineration or co-incineration;

(iv) treatment of slags and ashes;

(v) treatment in shredders of metal waste, including waste electrical and

electronic equipment and end-of-life vehicles and their components.

(b) Recovery, or a mix of recovery and disposal, of non-hazardous waste with a capacity

exceeding 75 tonnes per day involving one or more of the following activities, and

excluding activities covered by Directive 91/271/EEC:

(i) biological treatment;

(ii) pre-treatment of waste for incineration or co-incineration;

(iii) treatment of slags and ashes;

(iv) treatment in shredders of metal waste, including waste electrical and

electronic equipment and end-of-life vehicles and their components.

When the only waste treatment activity carried out is anaerobic digestion, the capacity

threshold for this activity shall be 100 tonnes per day.

5.4 Landfills, as defined in Article 2(g) of Council Directive 1999/31/EC of 26 April 1999 on the

landfill of waste receiving more than 10 tonnes of waste per day or with a total capacity

exceeding 25 000 tonnes, excluding landfills of inert waste

5.5 Temporary storage of hazardous waste not covered under point 5.4 pending any of the

activities listed in points 5.1, 5.2, 5.4 and 5.6 with a total capacity exceeding 50 tonnes,

excluding temporary storage, pending collection, on the site where the waste is generated

5.6 Underground storage of hazardous waste with a total capacity exceeding 50 tonnes

6 Other activities

6.1 Production in industrial installations of:

(a) pulp from timber or other fibrous materials;

(b) paper or card board with a production capacity exceeding 20 tonnes per day;

(c) one or more of the following wood-based panels: oriented strand board,

particleboard or fibreboard with a production capacity exceeding 600 m3 per day.

6.2 Pre-treatment (operations such as washing, bleaching, mercerisation) or dyeing of textile

fibres or textiles where the treatment capacity exceeds 10 tonnes per day



D 1.2




Shipyard

Activity

6.3 Tanning of hides and skins where the treatment capacity exceeds 12 tonnes of finished

products per day

6.4 a. Operating slaughterhouses with a carcass production capacity greater than 50 tonnes per

day

b. Treatment and processing, other than exclusively packaging, of the following raw

materials, whether previously processed or unprocessed, intended for the production of

food or feed from:

(i) only animal raw materials (other than exclusively milk) with a finished product

production capacity greater than 75 tonnes per day;

(ii) only vegetable raw materials with a finished product production capacity greater

than 300 tonnes per day or 600 tonnes per day where the installation operates for a

period of no more than 90 consecutive days in any year;

(iii) animal and vegetable raw materials …

Packaging shall not be included in the final weight of the product.

6.5 Disposal or recycling of animal carcases or animal waste with a treatment capacity exceeding

10 tonnes per day

6.6 Intensive rearing of poultry or pigs:

(a) with more than 40 000 places for poultry;

(b) with more than 2 000 places for production pigs (over 30 kg), or

(c) with more than 750 places for sows.

6.7 Surface treatment of substances, objects or products using organic solvents, in

particular for dressing, printing, coating, degreasing, waterproofing, sizing, painting,

cleaning or impregnating, with an organic solvent consumption capacity of more than

150 kg per hour or more than 200 tonnes per year

X

6.8 Production of carbon (hard-burnt coal) or electrographite by means of incineration or

graphitisation

6.9 Capture of CO2 streams from installations covered by this Directive for the purposes of

geological storage pursuant to Directive 2009/31/EC

6.10 Preservation of wood and wood products with chemicals with a production capacity

exceeding 75 m3 per day other than exclusively treating against sapstain

6.11 Independently operated treatment of waste water not covered by Directive 91/271/EEC and

discharged by an installation covered by Chapter II

Note: The threshold values given below generally refer to production capacities or outputs. Where several activities

falling under the same activity description containing a threshold are operated in the same installation, the

capacities of such activities are added together. For waste management activities, this calculation shall apply at the

level of activities 5.1, 5.3(a) and 5.3(b).



D 1.2


12.4 Attachment 3: List of References

[1] Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000

establishing a framework for Community action in the field of water policy.

In OJ L 327 of 22.12.2000

[2] Decision No 2455/2001/EC of the European Parliament and of the Council of 20 November 2001

establishing the list of priority substances in the field of water policy and amending Directive

2000/60/EC.

In OJ L 331, 15.12.2001

[3] Directive 2008/32/EC of the European Parliament and of the Council of 11 March 2008 amending

Directive 2000/60/EC establishing a framework for Community action in the field of water policy,

as regards the implementing powers conferred on the Commission.

In OJ L 81 of 20.3.2008

[4] Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on

environmental quality standards in the field of water policy.

In OJ L 348, 24.12.2008

[5] Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the

geological storage of carbon dioxide.

In OJ L 140, 5.6.2009

[6] Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the

protection of groundwater against pollution and deterioration.

In OJ L 372, 27.12.2006

[7] European Commission - Environment – Waste – Waste Shipments

http://ec.europa.eu/environment/waste/shipments/index.htm

[8] Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste.

In OJ L 114,27.4.2006, p.9–21.

[9] Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on

waste and repealing certain Directives. In OJ L 312, 22.11.2008, p. 3–3.

[10] Commission Decision of 17 July 2000 on the implementation of a European pollutant emission

register (EPER) according to Article 15 of Council Directive 96/61/EC concerning integrated

pollution prevention and control (IPPC)

(notified under document number C(2000) 2004) (OJ, L 192, 28/07/2000 p.36)

http://europa.eu.int/eurlex/en/lif/dat/2000/en_300D0479.html

[11] Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention

control. In: (OJ, L 257, 10/10/1996, pp 26-40).

[12] Directive 1999/13/EC on the limitation of emissions of volatile organic compound due to the use of

organic solvent in certain activities and installations

In OJ L 85 of 29.3.1999

[13] Regulation (EC) No 1882/2003 of the European Parliament and of the Council

In OJ L 284, 31.10.2003, p. 1


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001D2455:EN:NOT





http://ec.europa.eu/environment/waste/shipments/index.htm



http://europa.eu.int/eurlex/en/lif/dat/2000/en_300D0479.html


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32003R1882:EN:NOT



D 1.2


[14] Directive 2004/42/EC of the European Parliament and of the Council on the limitation of emissions

of volatile organic compounds due to the use of organic solvents in certain paints and varnishes and

vehicle refinishing products

In OJ L 143, 30.4.2004, p. 87

[15] Directive 2008/112/EC of the European Parliament and of the Council

In OJ L 345, 23.12.2008, p. 68

[16] Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and

control. In OJ L 257, 10.10.1996, p. 26–40

[17] Directive 2008/1/EC of the European Parliament and the Council of 15 January 2008 concerning

integrated pollution prevention control. In OJ L 24, 29.1.2008, p. 8–29

[18] Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on

industrial emissions (integrated pollution prevention and control).

In OJ L 334, 17.12.2010, p. 17–119

[19] Regulation (EC) No 166/2006 of the European Parliament and the Council of 18 January 2006

concerning the establishment of the European Pollutant Release and Transfer Register and

amending Council directives 91/689/EEC and 96/61/EC

In OJ L 33, 4.2.2006, p. 1–17

[20] Regulation (EC) No 782/2003 of the European Parliament and the Council of 14 April 2003 on the

prohibition of organotin compounds on ships amended by Commission Regulation (EC) No

536/2008 of 13 June 2008.

In OJ L 115, 9.5.2003, p. 1)

[21] Best Available Techniques on Surface Treatment using Organic Solvents (August 2007)

http://www.ineris.fr/ippc/sites/default/files/files/sts_bref_0807.pdf






http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=Regulation&an_doc=2006&nu_doc=166



http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003R0782:20080704:EN:PDF

http://www.ineris.fr/ippc/sites/default/files/files/sts_bref_0807.pdf

european directives’ applicable requirements for ship ......marta walk, helena modrzejewska, cto...

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