Solvent Emissions (Scotland) Regulations 2004: guidance

Guidance on the Solvent Emissions (Scotland) Regulations 2004

Appendix 4: SOLVENT MANAGEMENT PLAN

Copy of Annex III from the SED

1. Introduction

This Appendix provides guidance on undertaking a solvent management plan. It identifies the principles to be applied (item 2) and provides a framework for the mass balance (item 3) and an indication of the requirements for verification of compliance (item 4).

2. Principles

The solvent management plan serves the following purposes:

(i) Verification of compliance as specified Article 9(1) of the SED;

(ii) Identification of future reduction options;

(iii) Enabling of the provision of information on solvent consumption, solvent emissions and compliance with the SED to the public.

3. Definitions

The following definitions provide a framework for the mass balance exercise.

Inputs of organic solvents (I):

I1 The quantity of organic solvents or their quantity in preparations purchased which are used as input into the process in the time frame over which the mass balance is being calculated.

I2 The quantity of organic solvents or their quantity in preparations recovered and reused as solvent input into the process. (The recycled solvent is counted every time it is used to carry out the activity)

Outputs of organic solvents (O):

O1 Emissions in waste gases.

O2 Organic solvents lost in water, if appropriate taking into account waste water treatment when calculating O5.

O3 The quantity of organic solvents which remains as contamination or residue in products output from the process.

O4 Uncaptured emissions of organic solvents to air. This includes the general ventilation of rooms, where air is released to the outside environment via windows, doors, vents and similar openings.

O5 Organic solvents and/or organic compounds lost due to chemical or physical reactions (including for example those which are destroyed, e.g. by incineration or other waste gas or waste water treatments, or captured, e.g. by absorption, as long as they are not counted under O6, O7 or O8).

O6 Organic solvents contained in collected waste.

O7 Organic solvents, or organic solvents contained in preparations, which are sold or are intended to be sold as a commercially valuable product.

O8 Organic solvents contained in preparations recovered for reuse but not as input into the process, as long as not counted under O7.

O9 Organic solvents released in other ways.

4. Guidance on use of the solvent management plan for verification of compliance

The use made of the solvent management plan will be determined by the particular requirement which is to be verified, as follows: expressed in solvent emissions per unit product, or otherwise stated in Annex IIA.

(a) For all activities using the reduction scheme in Annex IIB, the solvent management plan should be done annually to determine consumption (C). Consumption can be calculated according to the following equation:

C = I1 - O8

A parallel exercise should also be undertaken to determine solids used in coating in order to derive the annual reference emission and the target emission each year.

(b) For assessing compliance with a total emission limit value expressed in solvent emissions per unit product or otherwise stated in Annex IIA the solvent management plan should be done annually to determine emissions (E). Emissions can be calculated according to the following equation:

E = F + O1

where F is the fugitive emission as defined in section (ii)(a). The emission figure should then be divided by the relevant product parameter.

(c) For assessing compliance with the requirements of Articles 5(5)(b)(ii) the solvent management plan should be done annually to determine total emissions from all activities concerned, and that figure should then be compared with the total emissions that would have resulted had the requirements of Annex II been met for each activity separately.

(ii) Determination of fugitive emissions for comparison with fugitive emission values in Annex IIA

Methodology

The fugitive emission can be calculated according to the following equation:

F = I1 - O1 - O5 - O6 - O7 - O8

Or

F = O2 + O3 + O4 + O9

This quantity can be determined by direct measurement of the quantities. Alternatively, an equivalent calculation can be made by other means, for instance by using the capture efficiency of the process.

The fugitive emission value is expressed as a proportion of the input, which can be calculated according to the following equation:

I = I1 + I2

(b) Frequency

Determination of fugitive emissions can be done by a short but comprehensive set of measurements. It need not be done again until the equipment is modified.