WHAT DOES INTEGRATED PERMITTING MEAN? (presentation based on H1 method, UK, Thames Region)

1. WHAT DOES INTEGRATED PERMITTING MEAN?(presentation based on H1 method, UK, Thames Region)

2. 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.

3. Specialist areas: Industrial wastewater Risk Incineration techniques Air pollution Solid waste Landfills External noise IT Tasks (internal): IT support Company database Department homepage Paradigms Integration of permitting work in Danish counties • Tasks (external): • Environmental management • Noise mapping • Green accounts • User payments • Revision of IPPC installations • Inspection report • Physical planning • Industrial network

4. Integration of permitting work in Danish counties

5. Integration Air Limit value Odour Noise BAT Raw materials Water Risks Energy Solid waste

6. Structure of Assessment Scope & options Emissions inventory assess environmental impacts Compare impacts between options assess costs select best option

7. 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

8. Methane emissions from a landfill site Sulphur emissions from a coal-fired power station Emissions from a pulp mill Emissions from effluent treatment plant of a chemicals manufacturing facility Scope and Options - 2 • Describe scope of activities to be included

9. Types of techniques: • Raw materials • Abatement • process control • operating mode • design 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

10. 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

11. 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

12. Quantify the impacts • considerations • releases to air • releases to water • deposition to land • ozone creation • global warming • waste disposal • noise • odour • accidents • visual impact • 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

13. local impacts - 1 • estimate levels in environment after dispersion :- “Process Contributions” (PC) • compare PC against environmental benchmarks; EQSs • the benchmarks are based generally on a maximum “tolerable” concentration to a receptor in a medium • benchmarks for human and ecological protection are available and will be under constant revision

14. local Impacts - 2 • 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 • Add PC to background level to obtain total Predicted Environmental Concentration (PEC) • Check that PEC does not breach an EQS - these options will usually be unacceptable

15. local impacts - 3

16. local impacts - 4 • normalise against benchmark: EQ = PC/ EQS • Summarise total impact by medium • EQ water • EQ air • EQ land

17. 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

18. 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

19. 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

20. Select BAT • balance environmental benefits against costs • justify priority impacts • show decisions clearly • use expert judgement

21. Case study: A Power plant • Step 1: Scope and options • “To decide the best technique to reduce sulphur emissions from a power plant”

22. Step 2: Candidate options and key environmental issues Case study: A Power plant

23. Step 3: Emissions inventory Case study: A Power plant

24. 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).

25. 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)

26. 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

27. 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)

28. 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