Practical experience with the implementation of the Solvents Directive in the Czech republic

3. Practical experience with the implementation of the Solvents Directive in the Czech republic VOC Workshop, June 2010 Lucie Krejčí Air Protection Department

4. Czech legislation transposing the Solvents Directive Decree n. 355/2002 Coll., which was amended by decree n. 509/2005 Coll., setting down emission limits and other terms and conditions of the operation of other stationary air pollution sources emitting volatile organic compounds from processes using organic solvents and from petrol storage and distribution

5. Specifics of the Czech „solvents legislation“in comparison with the Solvents Directive the scope of SD was extended to the installations with lower consumption thresholds (authorisation, ELVs, reduction scheme, solvent management plan) for some activities stricter ELVs were set (e.g. printing, coating) measurement of emissions in waste gases is mandatory also for installations without abatement equipment

6. Issues we are dealing with • Solvent management plan • definition of parameter O8 (organic solvents recovered for reuse) • necessity of the general guidance • - operators have difficulties with determination of various parameters (O1, O5, O6)

7. Definition of parameter O8 Problem some operators consider as reuse of O8 also solvents handed over to third persons Consequences lower solvent consumption, lower emission limit values, less strict obligations Our approach in the new national legislation unambiguous definition saying that reuse of organic solvents is only use of recovered solvents as input in the same activity within the same installation

8. Reuse of organic solvents

9. Determination of the parameter O1 operators have problems with calculation of parameter O1 from the result of periodic measurement correctness of O1 has significant impact on calculations of fugitive and total emissions Crucial factors most significant is typical production capacity/output of measured technology during the measurement knowledge of the ratio VOC/TOC in waste gases

10. when TOC/VOC ratio is unknown, then can be used equation TOC/VOC = 0,8 Drawbacks of using universal factor 0,8 most accurate results only for simple hydrocarbons for oxygenated solvents factor TOC/VOC is in range from 0,38 (methanol) to 0,62 (acetone), that results in significantly underestimated fugitive emissions in case of solvents as toluene or xylenes (TOC/VOC is 0,91) fugitive emissions would be moderately overestimated

11. Issues we are dealing with • Aplication of reduction scheme • used rather rarely so far • recently is by local authorities preferred monitoring based on emission limit values and measurement • necessity of the guidance for operators • uncertainties on how to elaborate reduction scheme for activities other than coating???

12. Issues we are dealing with • Classification of some types of activities • e.g. lamination vs. production of composites • (fibre reinforced plastics, FRP) • resolved after the EC issued the guidances

13. Problem according to current Czech „solvents legislation“: production of composites (FRP), where styrene resins are used, is classified as lamination ELV 30 g/m2 is for many of these installations very difficult to comply with (especially when composite product is made of more layers)

14. Our aproach in the new national legislation separate activity category for production of composites consumption is set according to the input amount of VOCs, not organic solvents (styrene reacts in the polymeric reaction – is not a solvent) ELVs: - concentration ELV 85 mg/m3 TOC - ELV of total emissions of VOCs related to input amount of materials containing VOCs (resins, gelcoats, topcoats, solvents used for cleaning of equipment)

15. Thank you for your attention Lucie Krejčí E-mail: lucie.krejci@mzp.cz Tel.: 00420 267 122 877