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Tools for the preparation of integrated permits in serbia march 31, belgrade riccardo quaggiato

Tools for the preparation of integrated permits in serbia march 31, belgrade riccardo quaggiato. Project implemented by Human Dynamics Consortium Projekat realizuje Human Dynamics Konzorcijum. Overview of the project. September 2012–august 2014 6 components, 30 activities.

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Tools for the preparation of integrated permits in serbia march 31, belgrade riccardo quaggiato

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  1. Tools for the preparation of integrated permits in serbiamarch 31, belgradericcardoquaggiato Project implemented by Human Dynamics Consortium Projekatrealizuje Human Dynamics Konzorcijum

  2. Overview of the project • September 2012–august 2014 • 6 components, • 30 activities

  3. Transposition and implementation assessment • Assessment of the level of transposition and implementation of IPPC/IED • Identification of gaps/bottlenecks for a full accordance with the Dir. • Definition of recommendations or solutions for the future transposition and correct implementation (including a workplan) • Draft of the new Law on IPPC and related Rulebooks (future activity)

  4. Documental/operational tasks - 1 Act. 2.2 - Completion of 3 procedures manuals, one for each of the 3 thematic areas: IPPC/IED, Seveso and EMAS • analysis of existing proceduresand the administrative framework • manual for IPPC/IED procedure: • defines the responsibilities of all involved authorities and stakeholders • shows detailed flow charts of the work processes from the initial stage of identification of an installation and permit application to final reporting

  5. Documental/operational tasks - 3 Act. 5.2 Translate appropriate BREF documents into Serbian language Integral translation of 3 BREF docs, together with a glossary of specific terms. 7 National BREF Guidance will be produced

  6. Training and participation - 1 • Act. 2.4: Organise and implement a series of workshops for public Institutions onvolved in IPPC implementation • Specific training for IPPC permit writers and other Institutions involved: • 2 days on BAT assessment and ELV setting (YUHOR, Jagodina) • 2 days on Integrated permit conditions and Monitoring Plan (EPS, Kostolac)

  7. BAT assessment

  8. BAT Assessment: • WHY is it needed? • BREF • Complex No prioritization of BAT • Method to find/collect the essential information in BREF (or elsewhere)

  9. I. Baseline analysis

  10. II. Potential BATs

  11. III. Environmental performance of BAT

  12. IV. Technical performance of BAT

  13. V. Economic viability of BAT

  14. DISCUSSION WHICH IS THE MOST DIFFICULT STEP OFTHIS METHODOLOGY? WHICH IS THE MOST IMPORTANT FACTOR AMONG ENVIRONMENTAL, TECHNICAL AND ECONOMIC? DO YOU THINK YOUR COMPANY COULD GATHER THE NECESSARY INFORMATION TO APPLY THIS METHODOLOGY? DO YOU THINK THAT A PROGRESSIVE IMPLEMENTATION OF BAT COULD BE MORE FEASIBLE?

  15. setting appropriate ELV

  16. SETTING OF ELV: • How the BAT-AEL should be followed? • BAT-AEL are expressed as a range of numerical values. Which one should be adopted as ELV? • Various BAT for the same production process allow different emissions/ discharges of similar or different pollutants. Which one has to be selected as basis for setting ELV? • Local geographical conditions may ask for compatibility of ELV with EQS which will eventually ask for ELV which are different from BAT-AE • WHO DECIDES?

  17. ELvs • Only for parameters which are relevant for your facility! • To be found in the BREFs relevant for your activity • May be in terms of: • mg/Nm3 in case of air emissions mostly as daily average • g/ton of product per day, moth or even year • ton/year for the whole site as total, e.g. Shell refinery Rotterdam, bubble for NOx 3.200 ton/year, SO2 4.400 ton/year • Time average specified

  18. Question to you? • Suppose that: • A horizontal BREF specifies a BAT-ELV of 20 mg/Nm3 for dust as a daily average • A vertical BREF specifies 5-10 mg/Nm3 for dust as a daily average • Which BREF applies? • Important: try to agree with Competent Authority on which BREFs apply to your facility

  19. Decision about elv • Application must contain a.o. a list of all relevant emissions to air, water, soil, wastes, etc. • Operator may come up with a proposal for ELVs to be applied in the Permit conditions, but he is not obliged to do so • The CA evaluate the proposal and issue the final decision

  20. integrated permit templates and manual

  21. INTEGRATED PERMIT TEMPLATE • General template and 2 sectoral templates • Manual on how to fill in items of permit structure • Manualprovidesexplanations and risksdescription in order to understandbackgroundofitems • Serbianpermitscheme (existing) given in legislationisthe base, starting point

  22. Features taken into account for permit scheme elaboration • Administrative data having the same importance as technical • Strenghtening the Administrative part • Permit to be prepared as easy-to-be-read and easy-to-be-used • Well structured permit, unequivocally defined items • Providing transparent permit scheme and template • For operators, easy implementation and self-check of compliance

  23. Structure of the integrated permit • Administrative part • - data related to the IP • - general information • - activity and application analysis • Conditions • - general • - environmental issues affected • Monitoring plan • Enclosures • - supporting documents • - maps and blueprints

  24. CONDITIONS- 1

  25. CONDITIONS - 2

  26. CONDITIONS - 3

  27. MONITORING PLAN TEMPLATE Project implemented by Human Dynamics Consortium Projekat realizuje Human Dynamics Konzorcijum

  28. Main objective Develop a Monitoring Plan template to guide the elaboration of the Monitoring Plans to be included in the future IPPC permits issued by MERZ. The Monitoring Plan template can be defined as the part of the IPPC permit where all the monitoring requirements are resumed

  29. Method Gap analysisphase Elaborationof a MonitoringPlantemplateaccordingto the resultsof gap analysis

  30. What and How to monitor? • BREF/ELV leading • Approaches to monitoring: • Direct measurement • Surrogate parameters (ERPs) • Mass balances • Calculations • Emission factors

  31. Which monitoring system? • Continuous in case of yearly, monthly or daily ELV: expensive for Operator • Two times a year 3x0,5 hour of sampling and weighing in the lab (own lab or external lab) combined with continuous pressure drop measurement, recording, delta P warning, logbook for filter checking every month: less expensive for Operator • Once every two years 3x0,5 hour of sampling and weighing in the lab (own lab or external lab) combined with continuous pressure drop measurement, recording, delta P warning minimum 3 years, logbook for filter checking every week: even cheaper • Check of suitability of filter after commissioning under representative conditions and repetition once every 5 years, combined with continuous pressure drop measurement, recording, delta P warning minimum 3 years, logbook for filter checking every week: cheapest

  32. Which monitoring system? • In the example above: surrogate parameters like pressure drop over the filter • Operator: be careful which ELVs and self monitoring system you propose in your Application • Investment and operational costs differ substantially

  33. Typical monitoring requirements • Air: • Stack emissions • Odours • Ambient air quality • Water • Discharge outlet (process effluent and surface water) • Ambient monitoring (River) • Groundwater • Groundwater wells • Soil monitoring • Noise • Point measurement • Ambient monitoring (sensitive receptor) • Energy • Fuel usage / carbon dioxide discharge (greenhouse gas permit)

  34. Example: abatement system to monitor/maintain (non ferrous metal sector) MONITORING

  35. Example: abatement system to monitor/maintain (non ferrous metal sector) EQUIPMENT

  36. Example: abatement system to monitor/maintain (non ferrous metal sector) Management of Abatement Equipment

  37. Mp TEMPLATE: structure Section 1. Introduction, aims of the Monitoring Plan, reference persons Section 2. Environmental aspects 1.1 AIR EMISSIONS 1.2 WATER CONSUMPTION 1.3 WATER EMISSIONS 1.4 WASTES 1.5 NOISE EMISSIONS 1.6 ODOURS 1.7 RAW MATERIALS AND FUELS 1.8 ENERGY CONSUMPTION 1.9 PROTECTION OF SOIL AND GROUNDWATER Section 3. Monitoring campaign of the state of the surrounding environment Section 4. Public inspections Section 5. Monitoring requirements for the closure/decommissioning phase Section 6. Environmental performance indicators and reporting

  38. DISCUSSION DO YOU THINK THAT YOUR CURRENT MONITORING PRACTICES ARE SIMILAR/COMPLIANT WITH THE SCHEME OF THE MONITORING PLAN? DO YOU HAVE A SYSTEM TO MONITOR PERIODICALLY YOUR ENVIRONMENTAL DATA (APART THE SYSTEM IMPOSED BY THE PERMITS)? DO YOU USE THE COLLECTED ENVIRONMENTAL DATA TO ASSESS YOUR ENVIRONMENTAL PERFORMANCE?

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