Regulations test industry's mettle
The surface treatment sector is scheduled to come under the PPC regulations next year. Envirowise is working with the regulators, trade bodies and consultants in gearing up to provide the answers.Surface treatment facilities where the aggregate treatment volume is over 30m3 will need to submit an application for a PPC permit between 1 May and 31 July 2004. In essence the 30m3 threshold applies to any treatment which modifies the surface, such as plating, anodising, phosphating etc, but would not include rinsing, removal of residual acidity or alkalinity, or various types of cleaning.
The majority of companies within this sector are small (e.g. 30-40 staff), with similar processing units and environmental impacts, and so a PPC club approach is being adopted in order to simplify the application process. Led by the Surface Engineering Association (SEA), the four regional PPC clubs are being fully supported by the Environment Agency (EA). Club members will attend a series of six one-day training sessions where they will be provided with appropriate tools and guidelines. A model PPC application is also being developed at South West Metal Finishing which will help club members to write their own application.
As well as providing a cost-effective way of compiling a PPC application, the club will allow operators to remain directly involved in their own applications. Extensive use will also be made of the free help and advice available from the government's Envirowise and Action Energy programmes. This good practice advice on materials, utilities and wastes costs should allow operators to make significant cost savings through waste minimisation. Club members will also be provided with three one-day on-site support visits to help them with any aspect of their application.PPC applications
Envirowise provides a range of advice and guidance which can help surface treatment companies with their PPC applications.
Section B2.2 of the PPC application, and associated Environment Agency technical guidance, requires operators to report findings from recent waste minimisation audits and water efficiency audits. In particular, the guidance indicates that operators should analyse the use of raw materials and water, assess the opportunities for reductions and provide an action plan for improvements. For small companies (fewer than 250 employees on site) Envirowise can provide a free FastTrack visit to help the company identify opportunities to reduce its materials, water and waste costs. The visit is carried out by an independent environmental advisor, who will spend a full day at the site. At the end of the visit, the company will be provided with a report on the day's findings and a suggested action plan. Companies can submit the FastTrack action plan as part of Section B2.2 of their PPC application.Good practice
Several Envirowise good practice publications are directly relevant to surface treatment companies in helping them to prepare their PPC applications. GG359 Finishing with a Profit was developed in partnership with the SEA and provides summary information and signposts to further guidance on the main environmental issues that surface treatment companies will need to address in their PPC applications.
GG160 Minimising Chemical and Water Waste in the Metalfinishing Industry provides practical advice on how companies can save money by minimising their consumption of chemicals and water, and improving their end-of-pipe treatment facilities.
GG354 Surface Cleaning and Preparation: choosing the best option was developed in partnership with the Metal Finishing Association (a member organisation of the SEA) and helps surface treatment companies to:
- Reduce operating costs, volatile organic compound (VOC) emissions, solvent consumption and waste by improving the management of their pre-treatment and surface cleaning processes,
- choose the most appropriate cleaning method for their needs,
- work towards the requirements of the Solvent Emissions Directive and deal with the consequences of the reclassification of trichloroethylene (trike) as a category 2 carcinogen.
GG118 Environmental Management Systems Workbook for Metalfinishers was developed with the SEA and provides a useful resource library of worksheets and examples to assist surface treatment companies to implement the management techniques required by PPC.
Further details about the PPC club approach will be provided at a free one-day workshop to be held by Envirowise and the SEA on 16 October in Birmingham. The workshop will highlight how managing resource efficiency will help surface engineering companies to reduce costs and prepare for PPC requirements.
Managing director Dr William Southall will explain how the continual environmental improvement programme at Frost Electroplating has used proven techniques to reduce water consumption, minimise effluent generation, reduce metal and chemical losses to effluent, minimise overplating and recover metal. These measures have enabled Frost Electroplating to make £1.5 million of resource efficiency savings during the past five years. The results are promoted in Envirowise case study CS389: Over £1million of efficiency savings achieved by an electroplating company.
Process technical advisor, Aidan Whitfield will highlight the Environment Agency's views and requirements for IPPC applications and the role of sector coordinator David Jacobi to facilitate the application and permitting process. In particular, he will discuss the Agency's guidelines for companies to follow and the new requirements for site reports.
There will be a presentation about how companies can take a streamlined approach to environmental management systems (EMS) to meet the management techniques required for IPPC. Quality of management and systems is one of the most important aspects of IPPC. It can also be one of the most time-consuming aspects and this workshop will help companies to get started.