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 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 officerBranchesSpecialist areaTasks 1 Fishmeal, power plants, airfields, fodder production Industrial waste water IT support Company database 2 Chemical production, biotechnology, risks, plastic, polluted soil RisksEIA Inspection report 3 Asphalt, waste incineration, heat supply Incineration techniques Industrial network, Physical planning 4 Slaughter houses, plastic, chemicals Air pollutionVOC regulation Home page 5 Landfills, waste incineration metal, recycling of waste Solid wasteRegular Revision of IPPC permits

Consultant: CMDC Joint Venture Integration Noise Water Risks Solid waste Energy Raw materials Odour Air Limit 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 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 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

Consultant: CMDC Joint Venture local impacts - 4 normalise against benchmark: EQ = PC / EQS Summarise total impact by medium  EQ water  EQ air  EQ land

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

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

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 OptionKey environmental issues Use low sulphur coalSO2, NOx, Transport of coal Use Natural gasSO2, NOx De-sulphurising, dry methodSO2, NOx, Waste deposits De-sulphurisning, wet methodSO2, NOx, Waste water, Waste deposits SNOX methodSO2, NOx

Consultant: CMDC Joint Venture Case study: A Power plant Step 3: Emissions inventory OptionSO2NOxWasteWaste water Low S coal9,6004,500-- N-gas02,400-- De-S, Dry3,2004,500100,000 m3/y- De-S, Wet3,2004,50017,000 m3/yN-compounds, heavy metals SNOX3,2001,00030,000 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