Consultant: CMDC Joint Venture
WHAT DOES INTEGRATED PERMITTING MEAN?
(presentation based on H1 method, UK, Thames Region)
Consultant: CMDC Joint Venture
Integration of permitting work in Danish counties
Example : Ribe County: 9 employees making permits (approximately 200.000 inhabitants in the
county) Each Employee has 3 tasks:
- Making permits within his/hers specific branch knowledge- Responsible for a specific sector plan or yearly task, including
maintenance of the legislation- Maintain technical expertise within 1 specific area
For each permit there is a primary case officer and a secondary case officer. The secondary case officer shall make quality control of the permit using a questionnaire and give day to day sparring to the primary case officer
The case officer can use informal assistance from the relevant technical experts.
Consultant: CMDC Joint Venture
Integration of permitting work in Danish counties
Specialist areas:•Industrial wastewater•Risk•Incineration techniques•Air pollution•Solid waste•Landfills•External noise•IT
Tasks (internal):•IT support•Company database•Department homepage•Paradigms
Tasks (external):•Environmental management•Noise mapping•Green accounts•User payments•Revision of IPPC installations•Inspection report•Physical planning•Industrial network
Consultant: CMDC Joint Venture
Integration of permitting work in Danish counties
Case officer Branches Specialist area Tasks1 Fishmeal, power plants,
airfields, fodder productionIndustrial waste water
IT supportCompany database
2 Chemical production, biotechnology, risks, plastic, polluted soil
Risks EIAInspection report
3 Asphalt, waste incineration, heat supply
Incineration techniques
Industrial network, Physical planning
4 Slaughter houses, plastic, chemicals
Air pollution VOC regulationHome page
5 Landfills, waste incineration metal, recycling of waste
Solid waste Regular Revision of IPPC permits
Consultant: CMDC Joint Venture
Integration
Noise
Water
Risks
Solid waste
Energy
Raw materials
Odour
AirLimit value
BAT
Consultant: CMDC Joint Venture
Structure of Assessment
Scope & options
Emissions inventory
assess environmental impacts
assess costs
select best option
Compare impacts between options
Consultant: CMDC Joint Venture
Scope and Options - 1
Explain why you are doing the assessment:either
To conduct a cost/benefit appraisal of options to determine BAT for selected releases from an installation because:
deviating from indicative BAT in BREF several candidates for BAT no indicative BAT in BREF
or
To carry out environmental assessment of emissions resulting from the installation as a whole
Consultant: CMDC Joint Venture
Scope and Options - 2
Describe scope of activities to be included
Emissions from a pulp mill
Methane emissions from
a landfill site
Emissions from effluent treatment plant of a
chemicals manufacturing facility
Sulphur emissions from
a coal-fired power station
Consultant: CMDC Joint Venture
Scope and Options - 3
Identify key environmental issues (and
eliminate irrelevant ones) and receptors
Identify candidate options for BAT, by
considering all relevant techniques to
prevent and minimise pollution from all
activities
Types of techniques:
•Raw materials
•Abatement
•process control
•operating mode
•design
Consultant: CMDC Joint Venture
Emissions Inventory - 1
Including: Point source emissions to air Point source emissions to surface water, groundwater and sewer Waste emissions Fugitive emissions to all media Abnormal emissions from emergency relief vents, flares etc Raw material consumption including energy and water
Consultant: CMDC Joint Venture
Emissions Inventory - 2
Describe: Substances released Source, including height, location, efflux velocity and total flow Predicted normal and maximum emissions expressed on suitable basis Statistical basis Predicted frequencies (if intermittent) Plant loads at which data are applicable Check all options meet any statutory emission limit values as laid down in EU Directives
Consultant: CMDC Joint Venture
Quantify the impacts
method depends on type of impact:
local impacts: relate to level in environment
- usually a maximum “protective” level
non-local impacts: relate to relative burden
- no maximum “protective” level
considerations
• releases to air• releases to water• deposition to land• ozone creation• global warming• waste disposal• noise• odour• accidents• visual impact
Consultant: CMDC Joint Venture
local impacts - 1
1. estimate levels in environment after dispersion :- “Process Contributions” (PC)
2. compare PC against environmental benchmarks; EQSs
3. the benchmarks are based generally on a maximum “tolerable” concentration to a receptor in a medium
4. benchmarks for human and ecological protection are available and will be under constant revision
Consultant: CMDC Joint Venture
local Impacts - 2
5. Identify whether detailed modelling of emissions is needed , eg if local receptors present which are sensitive to any of the
significant emissions if there is a risk of breaching an EQS
6. Add PC to background level to obtain total Predicted Environmental Concentration (PEC)
7. Check that PEC does not breach an EQS - these options will usually be unacceptable
Consultant: CMDC Joint Venture
local impacts - 3
PC ambient PEC
% P
C /
EQ
S100%
1%
80
Consultant: CMDC Joint Venture
local impacts - 4
normalise against benchmark:
EQ = PC / EQS
Summarise total impact by medium EQ water EQ air EQ land
EQ air
00,05
0,10,15
0,20,25
0,3
1 2 3
option
PC
/EQ
S
NOx
SO2
Consultant: CMDC Joint Venture
Non-local
Quantify Non-Local Impacts
Use relative Indices for Global Warming Ozone Creation
Waste: quantify by category describe disposal route
Summarise as total burden
global warming potential
0.E+00
1.E+08
2.E+08
3.E+08
1 2 3
optionco
ntrib
utio
n
N2O
CO2
Consultant: CMDC Joint Venture
Compare Options If PCs from options are low compared to EQSs this has less influence on decision than when they are high
If existing environmental quality is poor then greater importance placed on this consideration in the assessment
Local proximity of sensitive receptors to certain environmental impacts may be important
Long term irreversible effects are less desirable than short term reversible effects
How big the contribution of the impact is in relation to national or EU targets
Bear in mind risk/accidents
Consultant: CMDC Joint Venture
Evaluate the Costs
Estimate the costs of implementing each of the options carried forward from the assessment, to allow a balanced judgement of the costs of controlling releases of substances against the environmental benefits
Not necessary if the operator proposes to implement the option which clearly represents the lowest environmental impact
Consultant: CMDC Joint Venture
Select BAT
balance environmental benefits against costs justify priority impacts show decisions clearly
use expert judgement
0
25
50
75
100
125
0 5 10 15 20
pollution reductionco
st
12
3
4
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 1: Scope and options
“To decide the best technique to reduce sulphur emissions from a power plant”
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 2: Candidate options and key environmental issues
Option Key environmental issues
Use low sulphur coal SO2, NOx, Transport of coal
Use Natural gas SO2, NOx
De-sulphurising, dry method SO2, NOx, Waste deposits
De-sulphurisning, wet method SO2, NOx, Waste water, Waste deposits
SNOX method SO2, NOx
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 3: Emissions inventory
Option SO2 NOx Waste Waste water
Low S coal 9,600 4,500 - -
N-gas 0 2,400 - -
De-S, Dry 3,200 4,500 100,000 m3/y -
De-S, Wet 3,200 4,500 17,000 m3/y N-compounds, heavy metals
SNOX 3,200 1,000 30,000 m3/y -
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 4: Assess local impacts•Impossible to find locations for deposit of up to 30 mio. m3 solid waste (dry method over 30 years)•Gypsum (wet method) deposits has a risk for leaching of heavy metals to ground water, which is not acceptable. •Discharge of wastewater with heavy metals from the wet method is not in accordance with the hazardous substances directive (list I substances which should be eliminated).
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 5: Assess regional and global impacts
Acidification:
Low – S Coal > End-of-pipe > N-gas (best option)
Eutrophication:
De-S, wet > low –S coal > De-S, dry > N-gas > SNOX (best option)
(assessed directly from emissions and discharges)
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 6: Compare options
Due to unacceptable local impacts from heavy metals a deposit free solution is preferred and from assessment of regional and global impacts the following 2 methods is selected for further cost investigations:•N-gas•SNOX method
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 7: Assess the cost
It is assessed that use of N-gas will raise the current power price with approx 7% compared to present price and cost 12 mio. EUR in installation of new burners etc.
The SNOX method is comparable in price to the other end-of-pipe solutions, but the method is not developed to a commercial level yet (only demo installations)
Consultant: CMDC Joint Venture
Case study: A Power plant
Step 8: Select BAT
BAT is the SNOX process when it is developed to a commercial level.
Until then N-gas firing is BAT
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