1. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 1 Stakeholder workshop for the exchange of practical experience with the implementation of the VOC Solvent Emissions Directive 1999/13/EC Brussels 17th-18th June 2010 German approach to fugitive emissions, with a focus on coating and printing

2. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 2 Dr. Richard Schlachta Section Air Pollution Control in Bavarian State Ministry of the Environment and Public Health Responsible for enforcement of VOC Directive in Bavaria Participation as member of national ad-hoc working group on implementation of VOC Directive in Germany Dr. Heinz Baumgarten Section Air Pollution Control in the Ministry of Urban Development and Environment in Hamburg In charge for enforcement of the VOC Directive in Hamburg Participation as member of national ad-hoc working group on implementation of VOC Directive in Germany

3. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 3 Contents: 1.Fugitive Emissions – German Definition in Ordinance 2. Reasons 3.Practical Example

4. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 4 Definition Fugitive Emissions Directive Art. 2 No 10 – “Fugitive Emissions” “Any emissions not in waste gases of VOC into air, soil and water as well as, unless otherwise stated in Annex IIA, solvents contained in any products. They include uncaptured emissions, released to the outside environment via windows, doors, vents and similar openings” German Ordinance § 2 No 6: Like Directive F = Fugitive Emissions

5. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 5 Definition Fugitive Emissions Directive Art. 2 No 11 – “Waste Gas” “Final gaseous discharge containing volatile organic compounds or other pollutants, from a stack or abatement equipment into air” German Ordinance § 2 No 12: Definition “Captured Waste Gas” a)Waste gas, that is finally discharged into atmosphere from a waste gas treatment unit = captured treated (= cleaned) waste gas b)Waste gas, that is finally discharged into atmosphere by a stack or other waste gas pipes = captured untreated (= not cleaned) waste gas O1.1 O1.2 O1 = Emissions in Waste Gases O1 = O1.1 + O1.2

6. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 6 Overview about different emissions and technical constellations Captured cleaned waste gas O 1 Uncaptured emissions O 4 as part of fugitive emissions Hall Captured but not cleaned waste gas O 1 O 4 Abatement unit Maschines and technical equipment of the VOC installation Ventilation / Air conditioning Windows /Doors

7. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 7 German approach on fugitive emissions regarding waste gas Captured cleaned waste gas O 1.1 Uncaptured emissions O 4 as part of fugitive emissions Hall O 4 Abatement unit Maschines and technical equipment of the VOC installation Captured but not cleaned waste gas O 1.2 considered as part of fugitive emissions Not captured directly !

8. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 8 The calculation of the fugitive emissions F according to the Solvent Directive and for normal activities according to the German Ordinance F = O2 + O3 + O4 + O9 F = I1 – O1 – O5 –O6 – O7 – O8 German approach: Calculation for coating and printing installation F = O1.2 + O2 + O3 + O4 + O9 F = I1 – O1.1 – O5 –O6 – O7 – O8 The general legal definition in Germany is the same, but for certain installations O 1.2 has to be assigned to the fugitive emissions

9. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 9 For certain installations = generally coating installations : O1.2 = uncleaned captured waste gas is considered as fugitive emission! Heatset web offset printing installations Installations that realize other printing activities Vehicle refinishing installations Coating of road vehicles, driving cabs, commercial vehicles, and rail vehicles (solvent consumption =15 t/year) Coil coating installations Installations that coat other metallic or plastic surfaces Installations that coat wood or wood materials Installations that coat film or paper surfaces Adhesive coating installations

10. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 10 Consequences: In all these cases where no VOC exhaust gas abatement unit exists all exhaust gases are fugitive emissions ->emitted VOC content of applied materials = total solvent input = 100% fugitive emission -> always no compliance to fugitive limit value is given (fugitive limit value results from a percentage of solvent input) 100% fugitive emissions Installation of an exhaust gas abatement unit and compliance to emission limit values Application of a reduction scheme and compliance to target values

11. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 11  Problem with „dilution or cooling“ with air is left out – it is not the target of VOC Directive to comply to emission limit value (“mass concentration”) in waste gas by dilution with air!  No discussions necessary according to fugitive emissions sources!  Differentiation between O 1.2 and VOC in ventilation no more important!  Numerous installations without exhaust gas abatement technique will choose the reduction scheme = compliance of 31. BImSchV by taking primarily measurements = avoidance of VOC emissions = aim of EU Directive! Advantages:

12. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 12 Example No. 1 Captured cleaned wastegas O 1: Uncaptured emissions O 4 as part of fugitive emissions: Hall Abatement unit Coating of metal surfaces Total solvent consumption C= I 1 = 14,0 t VOC/a No VOC in waste/water O 5 = 12,0 t VOC/a O 1 = 0,450 t VOC/a (11,5 mg C/m³; factor 1,3; = 15 mg VOC/m³) F = I 1 – O 1 – O 5 F = 14,0 - 12,0 - 0,45 F = 1,55 t VOC/a O 5 Only a little part of O 4 through windows and doors: 0,20 t/a 5000 m³/h, 15 mg VOC/m³, 6000 h/a Air from ventilation system (O 4) Emissions of an existing facility, slightly simplified

13. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 13 Example No. 1 Coating of metal surfaces Uncaptured emissions O 4 as part of fugitive emissions: 26000 m³/h, 6000 h/a Hall Captured waste gas: 12,6 t VOC/a VOC in Air from Ventilation: 1,35 t VOC/a Air and waste gas merged in one stack (sum): 13,95 t VOC/a Calculated yearly average emission value 89,4 mg VOC/m³ = 68,8 mg C/m³ ELV (Annex IIA) = 100 mg C/m³ Air from ventilation: 21000 m³/h, 6000 h/a 10,7 mgVOC/m³, 1,35 t VOC/a waste gas: 5000 m³/h, 6000 h/a 420 mg VOC/m³, 12,6 t VOC /a Possible concept to comply with the requirements without any abatement equipment (depending on the real hourly average emission)

14. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 14 Example – Wood Coating

15. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 15 Case study: Coating of wood 2-layer-application: clear-coat + top-coat No exhaust abatement technique Assumption: solvents will be emitted completely out of the coating The installation falls into the scope of the 31. BImSchV because exceeding solvent consumption threshold

16. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 16 Solvent management plan: I1Purchased solvent and put in24.000 kg I2Recovered and reused solvent in the installation2.000 (solvent recovery) O1.1Captured treated waste gas emissions0 (air of the hall = fugitive emission) O1.2Captured untreated waste gas emissions0 (air of the hall = fugitive emission) O2Solvent in waste waterHere neglected O3Solvent in productHere neglected O4Uncaptured emissionsCalculation

17. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 17 Solvent management plan: O5 Destroyed solvent by an exhaust gas abatement unit Not applicable, because no abatement unit for waste gas or waste water O6Solvent in waste3.200 kg/a O7Solvent in products to be soldNot applicable O8 Recovered solvent but not as input into the process Not applicable O9Solvent released in other ways2.000 ?

18. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 18 Determination of the solvent consumption: LV = I1 – O8 = 24.000 kg – 0 kg = 24.000 kg -> Installation Nr. 8.1 of Annex I of 31. BImSchV Calculation of the fugitive emissions according Annex V Nr. 2.2.1 b: F = I1- O1.1 – O5 – O6 – O7 – O8 = 24.000 kg – 0 – 0 – 3.200 kg/a – 0 - 0 = 20.800 kg/a Calculation of the total emissions according Annex V Nr. 2.1.2 b): E = F + O1.1 = 20.800 kg/a + 0 = 20.800 kg/a

19. Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta Ministry of Urban Development and Environment, Hamburg 19 Reduction scheme according to Annex IV section B: Reference emissions: 9.000 kg solids/year * 3 (Multiplication factor) = 27.000 kg/year Target emission = Reference emission * percentage = 27.000 kg/year * (25 + 15)% = 10.800 kg/year Following total emissions may not be exceeded: - from 01.11.2005: Target emission * 1,5 = 16.200 kg/year - from 01.11.2007: Target emission = 10.800 kg/year Result: Emission reduction measures are necessary to comply to the target emission! In comparison: current total emissions 20.800 kg/year! Alternatives: Installation of an exhaust gas abatement unit or using a reduction scheme