VOC Directive: VOC Directive: implementation, the implementation, the

practicepracticeNational Environmental GuardNational Environmental GuardRegional Commissariat ClujRegional Commissariat ClujCluj County CommissariatCluj County Commissariat

MSc Costa STANISAVMSc Costa STANISAVEmail: Email: cjcluj@gnm.rocjcluj@gnm.ro

ECENA Exchange Programme -Ohrid, FYR Macedonia June 30th- July 2nd

VOC Directive: implementation, VOC Directive: implementation, the practicethe practice

General requirementsGeneral requirements

Practical implementationPractical implementation

Necessity of the VOC directivesNecessity of the VOC directivesOnce in the atmosphere, VOCs released Once in the atmosphere, VOCs released into the air contribute to the formation of into the air contribute to the formation of trophospheric ozone (ozone in the lower trophospheric ozone (ozone in the lower atmosphere). atmosphere). Large quantities of this ozone can be Large quantities of this ozone can be very harmful to human health, very harmful to human health, vegetation, forests and crops. vegetation, forests and crops. Sensitive people may suffer irritation of Sensitive people may suffer irritation of the throat and eyes as well as respiratory the throat and eyes as well as respiratory problems.problems.Tropospheric ozone is also a greenhouse Tropospheric ozone is also a greenhouse gas gas

““The is no evident trend in The is no evident trend in decreasing of tropospheric decreasing of tropospheric Ozone concentration in Ozone concentration in SouthSouth--East EuropeEast Europe””

Final conference IntegaireFinal conference Integaire-- Sevilla Sevilla --20052005

Purpose of the Purpose of the Council Directive Council Directive 1999/13/EC1999/13/EC

on the limitation of emissions on the limitation of emissions

of volatile organic compounds due to the of volatile organic compounds due to the use of organic solvents in certain activities use of organic solvents in certain activities

and installationsand installationsIn the framework of the global strategy to reduce In the framework of the global strategy to reduce pollution due to tropospheric ozone: pollution due to tropospheric ozone:

The purpose of this Directive is to prevent or reduce The purpose of this Directive is to prevent or reduce the direct and indirect effects of emissions of volatile the direct and indirect effects of emissions of volatile organic compounds (VOCs) on the environment and organic compounds (VOCs) on the environment and human health, by setting emission limits for such human health, by setting emission limits for such compounds and laying down operating conditions for compounds and laying down operating conditions for industrial installations using organic solventsindustrial installations using organic solvents

Existing installationsExisting installationsExisting installations must be registered or Existing installations must be registered or their activities authorised if they have not their activities authorised if they have not yet been authorised under Council Directive yet been authorised under Council Directive 96/61/EC96/61/EC. .

They must comply with the same They must comply with the same requirements as for new installations no requirements as for new installations no later than later than 30 October 200730 October 2007. . Where part of an existing installation Where part of an existing installation undergoes a substantial change, it must undergoes a substantial change, it must comply with the requirements applicable to comply with the requirements applicable to new installations.new installations.

New installationsNew installations

Member States must take the Member States must take the necessary measures to ensure that necessary measures to ensure that all new installations comply with the all new installations comply with the provisions of the Directive. provisions of the Directive. Moreover, all new installations not Moreover, all new installations not already covered by Directive already covered by Directive 96/61/EC96/61/EC concerning concerning integrated integrated pollution prevention and controlpollution prevention and control must must be registered or authorised before be registered or authorised before being put into service.being put into service.

Obligations of Member statesObligations of Member states

The Member States must take the necessary measures to The Member States must take the necessary measures to ensure that the public has access to information ensure that the public has access to information concerning:concerning:•• applications for authorisation for new installations or for applications for authorisation for new installations or for

substantial changes to installations, substantial changes to installations,

•• the decision of the competent authority, including at the decision of the competent authority, including at least a copy of the authorisation, and any subsequent least a copy of the authorisation, and any subsequent updates, updates,

•• the general binding rules applicable to installations and the general binding rules applicable to installations and the list of registered and authorised activities, the list of registered and authorised activities,

•• the results of emissionthe results of emission--monitoring as required under monitoring as required under the authorisation or registration conditions. the authorisation or registration conditions.

Every three years, Member States must submit a report to Every three years, Member States must submit a report to the Commission on the implementation of the Directivethe Commission on the implementation of the Directive

NNational plans for reducing emissions from the activities and indational plans for reducing emissions from the activities and industrial ustrial installations covered by Article 1 (excluding activities 4 and 1installations covered by Article 1 (excluding activities 4 and 11 of Annex 1 of Annex

IIA).IIA).

TThe plans must result in a reduction of the annual emissions of Vhe plans must result in a reduction of the annual emissions of VOCs OCs by at least the same amount and within the same timeby at least the same amount and within the same time--frame as frame as would have been achieved by applying the emission limits under twould have been achieved by applying the emission limits under the he Directive.Directive.

The national plan must include:The national plan must include:•• a list of the measures taken or to be taken; a list of the measures taken or to be taken;

•• binding interim reduction targets against which progress binding interim reduction targets against which progress towards the aim can be measured; towards the aim can be measured;

•• a full description of the range of instruments through a full description of the range of instruments through which its requirements will be achieved,which its requirements will be achieved,

•• evidence that these instruments will be enforceableevidence that these instruments will be enforceable

•• details of the means by which compliance with the plan details of the means by which compliance with the plan will be demonstrated. will be demonstrated.

The operator has the free choice of:The operator has the free choice of:

TTo reduce emissionso reduce emissions (eg. by i(eg. by installing equipmentnstalling equipment)) to comply to comply with the emission limit values and the fugitive emission values,with the emission limit values and the fugitive emission values,or total emission limit values; or total emission limit values; ““end of pipeend of pipe””--technology (waste technology (waste gas cleaning) gas cleaning)

IIntroducing a reduction scheme to arrive at an equivalent ntroducing a reduction scheme to arrive at an equivalent emission level, in particular by replacing conventional productsemission level, in particular by replacing conventional productswhich are high in solvents with lowwhich are high in solvents with low--solvent or solventsolvent or solvent--free free products. ( ART 5)products. ( ART 5)

Combination between the previous two are also possiblyCombination between the previous two are also possibly

Replacing highReplacing high--solvent substances by lowsolvent substances by low--solvent substances. solvent substances. Especially for small and mediumEspecially for small and medium--sized companies, employing a waste sized companies, employing a waste gas cleaning facility is not sensible due to high costs. gas cleaning facility is not sensible due to high costs.

Annex 2 B REDUCTION SCHEMEAnnex 2 B REDUCTION SCHEME

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 lowerthreshold band of items 8 and 10 of Annex IIA,— (the fugitive emission value + 5) for all other installations.

Compliance is achieved if the actual solvent emission determined from the solvent management plan is less than or equal to the target emission.

Annnex 3 Solvent

management plan

The solvent management plan serves the following purposes:(i) verification of compliance as specified in Article 9(1);(ii) identification of future reduction options;(iii) enabling of the provision of information on solvent consumption, solvent emissions andcompliance with the Directive to the public.

Determination of the total Determination of the total emissionsemissions

The determination of the total emissions is The determination of the total emissions is important for installation types which important for installation types which must comply with a total emissions limit must comply with a total emissions limit value, or for operations with a reduction value, or for operations with a reduction plan. plan. The total emission (E) is the sum of all The total emission (E) is the sum of all fugitive emissions (F) and the emissions in fugitive emissions (F) and the emissions in the composed waste gases (O1)the composed waste gases (O1)

E = F + O1E = F + O1

The fugitive emissions (F) can be The fugitive emissions (F) can be determined with two methods: Direct and determined with two methods: Direct and

IndirectIndirectDirect method is to add the emitted Direct method is to add the emitted

solvent in the wastewater (O2), in the solvent in the wastewater (O2), in the product (O3), as well as the fugitive product (O3), as well as the fugitive emissions into the air (O4) and the emissions into the air (O4) and the solvents released in other manners solvents released in other manners (O9).(O9).

Direct method: Direct method: F = O2 + O3 + O4 + O9F = O2 + O3 + O4 + O9Little used in practice (many emission point, Little used in practice (many emission point,

hard for mathematical calculationhard for mathematical calculation))

Indirect method (Difference method)Indirect method (Difference method)It is generally more advantageous to It is generally more advantageous to determine the diffuse emissions indirectly, determine the diffuse emissions indirectly, by subtracting those solvents from the input by subtracting those solvents from the input solvents (solvents (except I2except I2 ––reused solventreused solvent) which ) which are not regarded as fugitive emissions.are not regarded as fugitive emissions.These are emissions in the composed waste These are emissions in the composed waste gas (O1), in the waste (O6), in the sales gas (O1), in the waste (O6), in the sales products (O7), and the recycled solvents products (O7), and the recycled solvents (O8), as well as the solvents destroyed or (O8), as well as the solvents destroyed or bound in the treatment facilities (O5).bound in the treatment facilities (O5).

F = I1 F = I1 -- O1 O1 -- O5 O5 -- O6 O6 -- O7 O7 -- O8O8

In practice, in many cases remain only O6 or In practice, in many cases remain only O6 or O8O8

FUTUREFUTURE

The interaction of the VOC Solvents The interaction of the VOC Solvents and IPPC Directives is considered and IPPC Directives is considered within the scope of the within the scope of the Commission's Commission's proposal for a Directive on Industrial proposal for a Directive on Industrial EmissionsEmissions that recasts the VOC that recasts the VOC Solvents Directive and six other Solvents Directive and six other existing Directives related to existing Directives related to industrial emissions into a single clear industrial emissions into a single clear and coherent legislative instrument.and coherent legislative instrument.

For all activities using Annex IIB the solvent management plan should be done annually to determine consumption (C). Consumption can be calculated according to the following equation:

C = I1 − O8

Romanian involved institutionsRomanian involved institutions

Local and Regional EPAsLocal and Regional EPAs

National Environmental Guard National Environmental Guard (regional and local structures)(regional and local structures)

Elements of a VOC installation inspectionElements of a VOC installation inspection

Identification of activity related to VOC Identification of activity related to VOC directivedirectiveSetting the main points of inspection: The Setting the main points of inspection: The authorization is authorization is the base of inspectionsthe base of inspectionsBalance of used solvents/12 months (% of Balance of used solvents/12 months (% of VOC from compounds that are used)VOC from compounds that are used)Checking Checking the the balance of solventsbalance of solventsVerification Verification of of -- Solvents ManagementSolvents Management Plan Plan (containing VOC) (containing VOC) -- containing the containing the measurement of emissionsmeasurement of emissions (quantity of (quantity of VOC /year + inputs/outputs of VOC => VOC /year + inputs/outputs of VOC => Total VOC emission) = Evaluation of Total VOC emission) = Evaluation of conformation with the Directiveconformation with the Directive

Elements of a VOC installation Elements of a VOC installation Inspection Inspection --22

Discussion with the operator: Discussion with the operator: analyzing of analyzing of documentation / reportsdocumentation / reports

Quantity of active carbon used (if this method is Quantity of active carbon used (if this method is used) and comparison with time it is active used) and comparison with time it is active (usually maxim 7 days)(usually maxim 7 days)

SSiteite inspectioninspection

DDetermining the need foretermining the need for futurefuture actionaction

Elaboration of inspection report (including Elaboration of inspection report (including mandatory mmandatory measureseasures))

Elements of a VOC installation Elements of a VOC installation Inspection Inspection --33

Both ELV and fugitive emissions have Both ELV and fugitive emissions have to be respected at the same time (if to be respected at the same time (if the operator choose to respect the the operator choose to respect the requirements from Annex 2) requirements from Annex 2)

If the operator choose to implement If the operator choose to implement a reduction plan, it sa reduction plan, it shohouulld be verified d be verified only the respecting of target emission only the respecting of target emission valuevalue

Non conformities/problems identified in Non conformities/problems identified in RomaniaRomania

Errors in the VOC companies list until each company was Errors in the VOC companies list until each company was inspectedinspected

Lack of knowledge on legal/technical requirementsLack of knowledge on legal/technical requirements

Wrong calculation of Balance of solvents, and Solvent Wrong calculation of Balance of solvents, and Solvent management plan management plan -- input and output)input and output)

Legal aspects regarding the reLegal aspects regarding the re--authorization of new authorization of new companies initially reporting quantities lower than companies initially reporting quantities lower than threshold and than suddenly above, being not conform with threshold and than suddenly above, being not conform with VOC directive (under Romanian HG 699/2003 VOC directive (under Romanian HG 699/2003 –– companies companies should be prepared to conform with the directive)should be prepared to conform with the directive)

Monitoring is still difficult, on technical aspects. A Monitoring is still difficult, on technical aspects. A Romanian law regarding the monitoring is still under Romanian law regarding the monitoring is still under discussiondiscussion