Solvent Emissions (Scotland) Regulations 2004: guidance

Guidance on the Solvent Emissions (Scotland) Regulations 2004

8. SUMMARY OF TECHNICAL COMPLIANCE REQUIREMENTS

8.1 Introduction and Options for Compliance

The SER 2004 require SEPA to include such necessary conditions in authorisations/permits to deliver the technical requirements of the SED. Accordingly, in this section of the guidance, reference will be made in most cases to the explicit technical requirements of the SED.

Compliance Timescales:

In general terms there are two main compliance timeframes:-

New installations have to comply with the SED requirements prior to being brought into operation.

Existing installations have until 31 October 2007 to fully comply with the SED requirements.

Compliance timeframes should always be determined on a site specific basis. In particular specific compliance timeframes apply to operators who use substances or preparations described in Article 5(6) or 5(8) of the SED.

Additional technical guidance has been issued by DEFRA and the devolved administrations which identifies the technical compliance requirements for each specific industrial sector which falls within the scope of the SED. This guidance can be viewed via the following web link:
http://www.defra.gov.uk/environment/airquality/lapc/pgnotes/default.htm

8.2 Options for Compliance (overview)

The SED allows three options for compliance: the operator may choose, where available, any one of these three options.

The three compliance options are:

Emission limit values in waste gases and fugitive emission values contained within Annex IIA of the SED (see Appendix 2 to this document), or

The total emission limit detailed in Annex IIA of the SED (see Appendix 2 to this document), or

The requirements of the reduction scheme detailed in Annex IIB of the SED (see Appendix 3 to this document).

8.3 Solvent Management Plans

Operators of all SEDIs are required to submit an annual Solvent Management Plan ('SMP') to SEPA. The SMP must include the following information;

a) The Annual Solvent Consumption of the SEDI;

b) Demonstration of compliance.

Further guidance on solvent management plans is given in Appendix 4 of this document.

8.4 Two or More Activities on the Same Installation

Where two or more SED activities are carried on at the same SED installation,

- Compliance is required individually for each activity as regards controls specified in Articles 5(6), 5(7) and 5(8) of the SED for the potentially more harmful VOCs.

For all other substances the SED installations are,

Required to meet the emission limits values for waste gases and fugitive emissions or the total emission limit values as listed in Annex IIA of the SED for each activity individually; or

To have total emissions not exceeding those that would have resulted had each activity been required to meet the above requirements individually ( Note: In such a situation the Solvent Management Plan will have to be calculated in a manner which determines the total emissions from all activities concerned).

This allows some flexibility as to how the burden in meeting SED requirements is spread amongst two or more SED activities forming part of the same SED installation. Such flexibility is conditional on total emissions not exceeding that which would have occurred if the SED requirements regarding emissions had been met by each SED activity (See Appendix 5 for a worked example).