Exchange of practical experience with the implementation of the VOCs Solvents Directive 1999/13/CE: Technical instruction for how to demonstrate equivalent emission reductions Servei de Vigilància i Control de l’Aire Direcció General de Qualitat Ambiental Environmental and Housing Department. Catalonian Government. Brussels, June 2010

2 Reason for alternative methodology in equivalency emission reduction principle. Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/2003. (Spanish transposition of Dir 1999/13/CE). 2.1 Operator Requirements. 2.2 Reduction scheme approval. 2.3 Target emission. Practice on rubber conversion successful case. 2.4 Reduction scheme monitoring. 2.5 Pros and cons. 3. General questions concerning reduction schemes. Technical instruction for how to demonstrate equivalent emission reductions. Index

3 1. Reason for alternative methodology in equivalency emission reduction principle.  Generally, all solicitors have to comply individually with either the emission limit values in waste gases and the fugitive emission values. Mainly printing or painting activities (Annex IIA: Activities 3 and 8).  When applying coatings, varnishes, adhesives or inks with a constant solid content of product, companies tend to use practice scheme set on annex IIB of SED.  At defining reduction scheme, target emission may rise over annual solvent input I1. Ex VOC070344: Coating of wooden surfaces. Toilet seat covers manufacturing. Year/tonnesCoating input Total mass of solids Solvents input I1 Target emission Actual emission (55,5%) (60%)

4 1. Reason for alternative methodology in equivalency emission reduction principle.  Lack of knowledge on multiplying factors established on Annex IIB of SED and/or technical support to adjust equivalent reduction factors for individual installations, including activities different than applying coatings, varnishes, adhesives or inks with a constant solid content of product.  Draft on new proposed Directive on Industrial Emissions does not clarify reduction scheme annex. BUT  Reduction scheme is the preferred method of preventing and minimising emission of VOCs using non-abatement techniques.  Need of consistent reduction scheme model non activity dependant.  Although notifying period ended by , current solicitudes are accepted, following recommendations of Spanish Environmental Ministry.

5 2. Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Operator Requirements.  Application must be held to justify a reduction of solvent consumption (including average solvent content of total input) and/or solvent emissions.  Solely abatement equipments are not acceptable as reduction scheme. PLUS  The ultimate goal of reducing scheme shall ensure actual emissions not exceeding “target emission”. E = I1 - O8 - O7 - O6 - O5. PLUS  A phased plan shall be established to achieve emission reduction, considered as a commitment. Operator shall seek for key processes / products to focus on in order to set effective reduction strategy. 2.2 Reduction scheme approval.  Reduction scheme must be approved by regulator.

6 2. Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Target emission.  Target emission: maximum total emissions that an installation is allowed when applying emission limit values set on annex IIA: a)E c : maximum solvent emission permitted in waste gases. (kg/year)  i = every final waste discharge containing VOCs from a stack or abatement equip into air.  VLE = emission limit value allowed in waste gases (mgC/Nm3)  Q = volumetric flow in final gaseous discharges containing VOCs (Nm3/hour)  H = operating time (hour/year)  PM = weighted average molecular weight of solvents discharged  C = weighted average carbon number of solvents discharged b)E d : maximum solvent fugitive emission permitted. (kg/year)  I1 = used solvents during the accounting period (kg /year)  I2 = recovered and reused solvents during the accounted period (kg /year)  VLE = Fugitive emission value: percentage of solvent input allowed. c) E eq : Target emission: total emission permitted. (kg/year)

7 Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Target emission. Ex: VOC – Activity 18: Rubber conversion. Substitution of solvent base tackifier by aqueous based solution during assembly steps in tyre production. Starting year  E c : maximum solvent emission permitted in waste gases. (kg/year)  E d : maximum solvent fugitive emission permitted. (kg/year): 25% of total solvent input 2005: kg.  E eq : Target emission: kg. ELV in waste gases

8 Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Target emission.  Installations listed in Annex IIA nº 9, 11, 12, 13, 14, 15, 19 i 21 of SED shall use manufacturing data to calculate target emission according to:  VLE = Limit emission value.  P = Facility manufacturing (kg, m3, m2, pair of footwear produced, tonnes of seed)

9 Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Reduction scheme monitoring.  Compliance is achieved if the actual solvent emission determined from the solvent management plan is less or equal to the target emission.  Operators shall provide annually:  Solvent management plan  Compliance data: VOC – Activity 18: Rubber conversion – Target emission = 32 tonnes  1) Data from solvent management plan.  2) % Compliance: (target solvent emission / actual solvent emissions) x 100. YearSolvent consumption (tonnes/year) 1) Total emissions (tonnes/year) 1) Reduction Scheme compliance (%) 2) < threshold

10 Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Reduction scheme review.  Phased plan: Implementation degree YearActionImplementation degree 2006Bead solution tank elimination.Completed. 2006Change to co-extrusion technology using rubber compounds with more natural stickiness. Completed. 2007Tests to replace the solutions with organic solvents as stickiness agent in the process of bead solution. Completed. Arising problems in manufacturing area. 2007Install an auxiliary bead drying system.Completed. Not enough improvement. 2007Test in the chemical formulation of water based solutions. Completed. Not enough improvement. 2008Improvement in the bead filler application process.Completed. 2009Introduction of three filler extruders.Completed Total solvent substitution.Completed.

11 Criteria to apply an emission reduction scheme as a compliance option of Royal Decree 117/ Pros and cons. PROS:  Easy methodology non activity dependant.  Fulfilment of emission reduction equivalent to those achieved if emission limit values set on annex IIA were to be applied. CONS:  Installations with a significant number of VOC discharges may lead to high target emissions. Convenience of re-calculate target emission yearly.  Determination of VOC emission in waste gases may result in over or underestimations of target emission.

12 3. General questions concerning reduction schemes.  Suitable reduction scheme timing.  Installations listed in Annex IIA nº 1, 2, 3,4,5,6,7, 8,10,16: when reduction scheme finishes, should facilities continue indefinitely with a target emission as a total limit emission value or should they comply with individual limit emission values set on annex IIA.  Scope of the reduction scheme. How to deal with provisions of a reduction scheme not applying to the whole installation.  How to deal with installations where two or more activities are carried out, (exceeding thresholds).  Difficulties to assess requirements set on Article 5.3.b of SED concerning activities which cannot be operated under contained conditions. A reduction scheme should be applied unless it is demonstrated that this option is not technically and economically feasible. In this case operator must demonstrate that the best available technique is being used.  How to deal with changes in the approach and planned actions by operator.

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