Emerging Contaminants

1. Emerging Contaminants An emotional or real issue? Klaas den Haan

2. Today’s environmental status – food for thought • The European Life expectancy still demonstrating an increasing trend for all EU Member States. • David A. Leon, Trends in European life expectancy: a salutary view.International Journal of Epidemiology, 2011; 1-7 • “Considerable success has been achieved in reducing the discharge of pollutants to fresh and coastal waters, leading to considerable freshwater water quality improvements.” • 2010 State of the European Environment and Outlook Report, EEA, 2010 • Good Ecological Status and Chemical Status has been achieved or maintained for many European Water Bodies, since the publication of the Water Framework Directive • Remaining pressures are often not related to today’s industrial discharges • Evaluation of published and endorsed RBMPs (June, 2010) • Releases of new substances are expected to be very limited. • Emerging contaminants are more likely to surface from improved analytical methodology and shifting attention and are unlikely to trigger unknow impacts

3. Emerging contaminants an Industry perspective • Introduction • CONCAWE • The European regulatory environment • Substances • Emissions • Water & Groundwater • Refinery discharges • Current environmental issues • Resource efficiency • Chemical cocktails • Emerging contaminants • Enhanced monitoring efforts • Conclusions

4. European Refineries on Cross Country Pipelines

5. The EU-Refining Industry • In Europe (EU-27+), there are 41(+1) Companies with refining capacity • In 2010 these owned and operate 125 locations where crude oil was processed • The crude oil processing capacity is ~800,000 ktonne/annum • Capacity used in 2010 ~ 90% • Gasoline/Naphtha  ~ 26% • Gas Oils, Kerosenes, HFO  ~ 67% • Bitumen  ~ 5% • Other petroleum products  ~ 2% • Water discharges (2008)  612 (1,112) Mm3 • TPH discharge (2008)  993 tonne (1.3 g/tonne) • Final treatment  3-step-biox: 117 locations (94%) The amount of prodcuts manufactured comprises ~40 % of the total volume by weight placed on the EU-market by the petrochemical industry(EUROSTAT, 2010)

6. The European environmental regulatory regime • Main legislative instruments that influence the activities of today’s industry in Europe in the field of water • Substances: REACH • Substances on the EU-market (CMR, R50 or >1,000 tonnes/annum) are registered • All registered substances are required to be assessed by the registrant and demonstrated to be safe with appropriate risk management, as applicable • Evaluation of the assessments provided by Industry is on-going • Emissions: E-PRTR and Industrial Emissions Directive • E-PRTR - Reporting of emissions and transfers above regulatory thresholds • IED - Reduction of Industrial emission by use of Best Available Techniques • Environmental Quality: Water Framework Directive, Groundwater Directive, Environmental Quality Standards Directive, QA/QC-Directive, Marine Strategy Framework directive. • WFD - Member State obligation to achieve Good Water Quality (Chemical & Ecological) and reducing discharges, emission and losses of priority substances • GWD – Protection of groundwater bodies and achieving good quality • EQSD – Setting EQSs for priority substances (Cf. WFD Annex X) and Member State obligation to set-up inventories of discharges emissions and losses of these • QA/QC Directive – Member state obligations on analytical requirements for the monitoring of priority substances • MSFD – More or less equivalent legislation to the WFD for the marine ecosystem

7. Soil, Water and Waste Legislative Environment IPPC / IED Integrated Pollution Prevention and Control E-PRTR Pollutants Release and Transfer Register Chemical analysisand monitoring of water status Directive WasteIncinerationDirective Environmental Quality Standards Directive Marine Strategy Framework Directive Council Decision on Biodiversity Water Framework Directive WasteFrameworkDirective BirdsDirective REACH Substances Directive Groundwater Protection Directive Thematic Soil Strategy Environmental Liability Directive HabitatDirective Sewage Sludge Application Directive Suppression/reduction of the emissions of priority dangerous substances

8. Water Framework and Groundwater Directives • These legislations: • Represents the most substantial and ambitious piece of European Commission water legislation to date • Requires all Member States to achieve “good chemical and ecological status” for their surface and ground waters by 2015 • Will result in increasing pressure to reduce priority substances from waste water streams levels below set EQSs • Expects the elimination of priority hazardous substances from wastewater streams by 2027 (first list substances) • Will review the PS/PHS list every four years • Will result in a water pricing policy for water use and discharge in 2010 • Will prohibit the direct or indirect discharge into groundwater of List I substances with limits on discharges of List II substances • Issues • Complete cessation of discharges is not feasible and many of the Environmental Quality Standards (EQS) will be difficult to achieve due to historic and non-industrial sources

9. Water Framework Directive Implementation

10. WFD Planning Process and Affecting Factors Pressures leadingto GES failures Sources of pressuresand roles Economics ofwater use Ecology Chemistry Hydromorphology Definition of High and Good status Other choicefor measures Analysis ofPressuresand Economics Defining WaterBody Defining currentstatus Role ofexisting Law Characterisation Monitoring Prgrammes Programme ofmeasures Publicparticipation Issues notachieved inearlier cycles InvestigativeMonitoring SurveillanceMonitoring Public views Review River BasinManagementPlan New legalobligations Practical limits onwhat is achievablein the cycle Implementation ofMeasuresMonitoring Inventory of other Regulatory regimes Improved understanding:Ecology, StatusPressures & Impcats Areas covered by CONCAWEactivities and research Adaptive managementresponding to changingcircumstances andknowledge From 2011 Deloitte & IEEP report “Support to Fitness Check Water Policy”

11. Refineries and River Basin Management Plans • For those Countries that have complied with the WFD obligations to timely publish their River Basin Management plans, CONCAWE has performed an evaluation of the status of the River Basin districts where refineries are present • The results for 88 refineries are: • Surface water: • Only 38 are in RBDs that fail Good Ecological Status • 53 are in RBDs that fail Good Chemical status • Only 5 might be linked to probable causes for these failures, as IPPC/IED facilities were explicitly mentioned to may have contributed • Ground water: • Only 18 are above or close to GWBs that fail Good Quantative status • 44 are above or close to GWBs that fail Good Chemical status • Only 5 are potentially linked to probable causes for these failures • Improving the WFD-status appears not to require a lot of additional Industrial efforts

12. Refinery discharges • Type of discharges • Process water (Treated or transferred) • Cooling water (Treated, monitored or untreated) • Once-through or recycle bleeds (always treated) • Domestic water (via in-house WWTP or into public sewer system) • Pluvial water (Treated or as received) • Other water • Ground water remediation projects, etc. • Monitoring • Only known and relevant parameters • E-PRTR reportable (Although reporting on estimations are allowed) • Parameters specifically mentioned in operating permits • Company policy requirements • For 2010 CONCAWE is analysing refinery discharges on quantity and 50 quality parameters including the WFD-PSs • As a mature Industry understanding of the activities and discharges exists

13. Trend in refinery effluent loads Example oil in water (Data gathered since 1969) CONCAWE Report 2/11

14. Mean values for speciated HCBs (µg/l) After treatment into the freshwater environment CONCAWE Report 3/10

15. Fate of hydrocarbon data Discharge to freshwater Discharge to marine water All median concentrations in µg/l Discharge to off-site WWTP CONCAWE Report 3/10

16. Current environmental issues I • Resource efficiency: • Enhancement of production from feedstocks • Reduction of energy use • Efficient water use • Q1 does not include: • Fresh water, used for once-through cooling water, returned unchanged (excluding thermal effects); • Water provided from another facility within the company (no double counting); • Storm water (that is not utilised) and • fresh groundwater extracted for remedial control contaminated groundwater • Reduction of discharge can enhance contaminant concentrations • Fresh water withdrawn (Q1) * • Purchased potable water • Purchased raw water • Groundwater • Surface water • Purchased steam • Purchased other • Harvested rainwater • Recycle from external source Fresh water returned (Q2) Fresh wastewater returned to a fresh water source directly by the company or indirectly via a third-party treatment facility Operational use including internal recycle Fresh water consumed = Q1 – Q2 http://www.ipieca.org/system/files/publications/voluntary_sustainability_reporting_guidance_2010_1.pdf

17. Current environmental issues II • Chemical cocktails • SCHER, SCCS & SCENIHR scientific opinion on “Toxicity and Assessment of Chemical Mixtures” (May, June, 2011) • “Under certain conditions, chemicals may act jointly in a way that the overall level of toxicity is being affected.” • “Chemicals with common modes of action may act jointly to produce combination effects that are larger than the effects of each mixture component applied singly. These effects can be described by dose/concentration addition.” • “For chemicals with different modes of action (independently acting), no robust evidence is available that exposure to a mixture of such substances is of health concern if the individual chemicals are present at or below their zero-effect levels.” • “Interactions (including antagonism, potentiation, synergies) usually occur at medium or high dose levels (relative to the lowest effect levels). At low exposure levels, they are either not occurring or toxicologically insignificant.” • Refinery products and effluents complex mixtures • CONCAWE assesses the risks of their member’s products with the PETRORISK & PETROTOX models that uses the HCB-method to incorporate effect addition. • Are today’s cocktails are different from those of the past? • Yes, however, as the contaminants loads have diminished over the past 20 years, these are unlikely to trigger effects not already observed and declining

18. Current environmental issues III • Emerging* contaminants: • The selected term is unfortunate as it might induce misperception on presence of substances that were not already present • Emerging contaminants are the result of attention to classes of substances that were not assessed earlier or the fact that progress in analytical techniques enable these to be observed and quantified. • The only exception might be registered new substances • Under REACH these should never become prominent when uncontroled risks are identified • For the Refining Industry is unlikely that new chemical substances will enter the environment • There are no developments to create new molecules that require registration • The number of new substances registered in the past 10 years has been a fraction of the Registered Substances • Enhanced enviromental and human health impacts from “Emerging Contaminants” are unlikely to be expected given the fact that emission loads continue to decrease. * Emerging: (adj) Newly formed or just coming into prominence

19. Current environmental issues IV • Enhanced monitoring: • The obligations to assess the water quality under the WFD and associated legislation lies with the Member States • Industry will only monitor inside the environment for which they are responsible • Discharge monitoring will be constrained to the techno sphere • Analytes included in this monitoring can only be restricted to those contaminants that are potentially present in their effluents • A causal relation between an observed environmental stressor and the activities of an Industrial site before a requirement to expand any monitoring effort can be substantiated • In today’s regulatory scenery the REACH activities should be exploited to determine which additional substances require RBD monitoring efforts Manufacturer of substance requests authorisation Does monitoring show a risk? No Yes Identification as priority substance (if EU wide) Risk assessment Is the use safe? WFD Monitoring Authorisation Yes, and if appropriate mitigation measures are implemented No REACH WFD Not authorised

20. CONCLUSIONS • Todays regulatory environment has all the elements to achieve its intended goals but consistent implementation and delivery may impair this. • Europe’s waters are constantly improving • The Industry has been and is delivering actively and their contributions as can be seen by the factual decrease of relative and absolute emissions and discharges, over time • Chemical Cocktails are unlikely to trigger environmental or human health impacts that are not already observed • Emerging contaminants are not resulting from new emissions and discharges except of new products and, therefore, unlikely to cause impacts not already observed and declining • Extended monitoring efforts under the WFD are a Member State Obligation and should be steered by integration of legislative schemes

21. Today’s environmental status – food for thought • The European Life expectancy still demonstrating an increasing trend for all EU Member States. • David A. Leon, Trends in European life expectancy: a salutary view.International Journal of Epidemiology, 2011; 1-7 • “Considerable success has been achieved in reducing the discharge of pollutants to fresh and coastal waters, leading to considerable freshwater water quality improvements.” • 2010 State of the European Environment and Outlook Report, EEA, 2010 • Good Ecological Status and Chemical Status has been achieved or maintained for many European Water Bodies, since the publication of the Water Framework Directive • Remaining pressures are often not related to today’s industrial discharges • Evaluation of published and endorsed RBMPs (June, 2010) • Releases of new substances are expected to be very limited. • Emerging contaminants are more likely to surface from improved analytical methodology and shifting attention and are unlikely to trigger unknow impacts