Solvent Emissions (Scotland) Regulations 2004: guidance

Guidance on the Solvent Emissions (Scotland) Regulations 2004

Appendix 5: PRACTICAL EXAMPLES

SED Installation

For example, a degreasing plant which carries out a surface cleaning activity (SED Part B) at a surface treatment of metal works (PPC Part A) would normally be part of a single PPC installation for the surface treatment works. For the purposes of SED, there is still a technical connection between the surface cleaning activity and the surface treatment activity. However, operation of the surface cleaning activity is unlikely to have an effect on the emissions of VOCs from the surface treatment activity. In such a case the SED installation would only consist of the surface cleaning activity while the PPC installation would consist of both the surface cleaning and surface treatment activities.

Small SED Installation

For example for activity 10, coating of wooden surfaces, there is an emission limit value of 100mg C/Nm3 for a solvent consumption of 15 - 25 tonnes per year and a limit value of 50 mg C/Nm3 for consumption greater than 25 tonnes per year. Some activities in Annex IIA have specified consumption values of less than 10 tonnes per year, e.g. winding wire coating (activity number 9) has a solvent consumption threshold greater than 5 tonnes per year. Where the consumption threshold is less than 10 tonnes per year then these processes are also regarded as small installations.

Where Two Or More SED Activities are Carried on at the Same SED Installation

Installation containing one surface cleaning activity (greater than 1 te) and a coil coating activity where each activity uses 25tes of solvent and in terms of Appendix 2 can meet an emission limit and fugitive limit for each activity or one activity can have greater fugitive emissions (assuming that waste gases mass emissions are very small) than the other provided the total emissions from the installation are the same as if each activity was compliant with Appendix 2 i.e. the total emissions for the installation remain the same.

Examples of Two or More SEDAs in Same SEDI

Substantial Change

Practical Example 1

• An existing coating process with 2 coating lines and abatement proposes to add a third line.

• Annual solvent emissions from each of the two existing lines are 5 tonnes ie 10 tonnes in total.

• The operator then has to calculate what the total annual mass emission will be from the substantially changed part (i.e. the third line), assuming full compliance with the SED emission requirements (i.e. complying with waste gas + fugitive or total or Reduction Scheme). This is 4 tonnes in this case.

• The operator then has to add the projected SED regulated emissions from the substantially changed part to the emissions from the existing part. This is 14 tonnes in this case.

• If the existing 2 coating lines do not change their practices and the substantially changed part complies with the SED then the total emission will be 14 tonnes (i.e. the total emissions of the installation after the substantial change is equal to the sum of the original emissions plus the additional emissions from the substantially changed part if it had met the requirements of SED). This means that the third line is treated as existing and is not required to apply for a substantial variation and would not have to meet the SED requirements for monitoring and reporting until 31 October 2007.

• Alternatively if the two existing lines reduced their emissions to 8 tonnes per year and the new line did not meet SED standards but instead had emissions of 5 tonnes per year, the total emissions would still be below 14 tonnes and consequently the third line is not required to meet the SED emission limits or the monitoring and reporting requirements until 31 October 2007.

Substantial Change

Practical Example 2

• An existing refinishing process with 2 spray booths proposes to add a third booth.

• Each of the existing spray booths applies 500kg of solids using 700kg of solvent, i.e. a solvent:solids ratio of 1:1.4

• A new booth is planned which will also apply 500kg of solids, for the new booth to comply with SED the amount of solvent allowed is no more than 600kg of solvent (solvent ratio of 1:1.2). Therefore for the substantially changed part of the installation to be considered as existing the total emission from the installation as a whole of solvent must be less than or equal to 2000kgs (700 + 700 + 600).

• If the new booth can only operate such that it will use 650 kg of solvent to apply 500 kg of solids (i.e. ratio of 1:1.3). The total solvent emission would be 700 + 700 + 650 = 2050. This would then not be treated as existing. However, if solvent used on the 2 existing booths is reduced by 25 kg each (by using better cleaning techniques) then the total solvents emission would be 675 + 675 + 650 = 2000 this then could be considered as existing installation.

Derogation for Existing Abatement

Reduction Scheme