Deadline for Solvent Emission Directive Compliance Approaching
18 May 2007, News release from Envirocare Technical Consultancy Ltd
Companies that use unprocessed solvents have had to abide by the Solvent Emissions Directive (SED) since it was introduced into UK legislation in March 2002. The Directive was introduced with the intent to prevent or reduce emissions of volatile organic compounds (VOCs) and their resultant impacts upon human health and the environment.
Those companies affected by the directive should have already had their existing PPC or LAPPC permit amended to include the relevant requirements of the SED. All existing installations that use unprocessed solvents should, by October 2005 have had to demonstrate compliance with SED. Under the new legislation, two methods of compliance are available to the installation: Emission and Fugitive Limits, or Reduction Scheme. Companies are encouraged to seek the most suitable method of compliance by undertaking a cost/benefit study. Emission and Fugitive Limits requires that emissions from point sources be directly monitored and uncaptured emissions calculated to illustrate that they are below specified limits related to the specific industry sector. The Reduction Scheme is used to generate a target emission (equivalent to those that would have been achieved if emission limits had been applied), which should not be exceeded by the actual solvent emission. In addition, any operator using a substance having a risk phrase in the group R40, R45, R49, R60 and R61, must either substitute it or control it.
In each instance, a Solvent Management Plan (SMP) is required, and is used as a tool to model solvent movement through the installation's process(s). It is used in the Emission and Fugitive Limit route to quantify fugitive emissions, and need be done only once (unless modifications are made to the equipment/process); and used in the Reduction Scheme to quantify both the target and actual solvent emissions. This process needs to be reviewed annually. The SMP showing annual data requires submission to the regulator to demonstrate compliance. From the end of October 2007, there will be a tightening of the SED regulations to obligate installations to reduce their solvent emissions further.
Although it appears that regulators have been lenient in enforcing the SED, with the tightening of the regulations, there is the expectation that this is set to change. By the end of October 2007, all installations (existing and new) should have selected the route of compliance they wish to take, and submitted an SMP for review by the appropriate regulator. Those installations that have failed to produce the necessary data will be under increased pressure from their regulator to demonstrate compliance.
Envirocare Case Study
Envirocare's technical expertise has been applied to produce Solvent Management Plans for a number of clients operating in various branches of the solvents usage sector.
A Yorkshire based coating installation procured Envirocare's services to investigate and quantify the solvent emissions from their operations and advise them on which method of compliance would best suit their circumstances.
Working closely with the client and their suppliers, an accurate assessment of solvent consumption was determined. From this point, a range of techniques were used to categorise the solvent outputs. VOC emissions monitoring was undertaken to generate accurate test results from each of the installations captured emission points. With all other known solvent outputs accounted for, the fugitive emissions from the installation were calculated and applied to the total solvent input to demonstrate compliance. The service was completed by providing the client with a report of the findings of the SMP, and appropriate recommendations and advice to increase the efficiency of solvent usage in the process. The results of the monitoring and SMP were successfully accepted by the regulator to comply with their permit.
Statement by the Managing Director
'Envirocare provided an excellent service covering all aspects of the work from consultancy and advice to emission monitoring. This allowed us to make the correct decision on which route to take and obtain compliance with the best option'
To discuss your solvent management plan queries/needs please contact Craig Batty on 01274 738668 and for more information on Envirocare click on www.envirocare.org.
For further information please email Envirocare Technical Consultancy Ltd