Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten,...

Bavarian State Ministry of the Environment and Public Health

17./18.06.2010 Dr. Heinz Baumgarten, Dr. Richard Schlachta

Ministry of Urban Developmentand Environment, Hamburg

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Stakeholder workshop for the exchange of practical experience

with the implementation of the VOC Solvent Emissions

Directive 1999/13/EC

Brussels 17th-18th June 2010

German approach to fugitive emissions,

with a focus on

coating and printing




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Dr. Richard Schlachta

• Section Air Pollution Control in Bavarian State Ministry of the Environment and Public Health

• Responsible for enforcement of VOC Directive in Bavaria

• Participation as member of national ad-hoc working group on implementation of VOC Directive in Germany

Dr. Heinz Baumgarten

• Section Air Pollution Control in the Ministry of Urban Development and Environment in Hamburg

• In charge for enforcement of the VOC Directive in Hamburg

• Participation as member of national ad-hoc working group on implementation of VOC Directive in Germany




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Contents:

1. Fugitive Emissions – German Definition in Ordinance

2. Reasons

3. Practical Example




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Definition Fugitive Emissions

Directive Art. 2 No 10 – “Fugitive Emissions”

“Any emissions not in waste gases of VOC into air, soil and water as well as, unless

otherwise stated in Annex IIA, solvents contained in any products. They include

uncaptured emissions, released to the outside environment via windows, doors, vents

and similar openings”

German Ordinance § 2 No 6:

Like Directive

F = Fugitive Emissions




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Definition Fugitive Emissions

Directive Art. 2 No 11 – “Waste Gas”

“Final gaseous discharge containing volatile organic compounds or other pollutants, from

a stack or abatement equipment into air”

German Ordinance § 2 No 12: Definition “Captured Waste Gas”

a) Waste gas, that is finally discharged into atmosphere from a waste gas treatment

unit = captured treated (= cleaned) waste gas

b) Waste gas, that is finally discharged into atmosphere by a stack or other waste gas

pipes = captured untreated (= not cleaned) waste gas

O1.1

O1.2

O1 = Emissions in Waste Gases

O1 = O1.1 + O1.2




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Overview about different emissions and technical constellations

Captured cleaned waste gas O 1 Uncaptured emissions

O 4 as part of fugitive emissions

Hall

Captured but not cleaned waste gasO 1

O 4

Abatement unit

Maschines and technical equipment of the VOC installation

Ventilation / Air conditioning

Windows/Doors




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German approach on fugitive emissions regarding waste gas

Captured cleaned waste gas O 1.1 Uncaptured emissions

O 4 as part of fugitive emissions

Hall

O 4

Abatement unit

Maschines and technical equipment of the VOC installation

Captured but not cleaned waste gas O 1.2 considered as partof fugitive emissions

Not captured directly !




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The calculation of the fugitive emissions F according to the Solvent Directive and for normal activities according to the German Ordinance

F = O2 + O3 + O4 + O9 F = I1 – O1 – O5 –O6 – O7 – O8

German approach: Calculation for coating and printing installation

F = O1.2 + O2 + O3 + O4 + O9 F = I1 – O1.1 – O5 –O6 – O7 – O8 The general legal definition in Germany is the same, but for

certain installations O 1.2 has to be assigned to the fugitive emissions




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For certain installations = generally coating installations:

O1.2 = uncleaned captured waste gas is considered as fugitive

emission!

• Heatset web offset printing installations

• Installations that realize other printing activities

• Vehicle refinishing installations

• Coating of road vehicles, driving cabs, commercial vehicles, and rail vehicles (solvent consumption =15 t/year)

• Coil coating installations

• Installations that coat other metallic or plastic surfaces

• Installations that coat wood or wood materials

• Installations that coat film or paper surfaces

• Adhesive coating installations




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Consequences:

In all these cases where no VOC exhaust gas abatement unit exists all exhaust gases are fugitive

emissions ->emitted VOC content of applied materials = total solvent input = 100% fugitive

emission

-> always no compliance to fugitive limit value is given

(fugitive limit value results from a percentage of solvent input)

100% fugitive emissions

Installation of an exhaust gas abatement unit and compliance to emission limit values

Application of a reduction scheme and compliance to target values




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Problem with „dilution or cooling“ with air is left out – it is not the target of VOC

Directive to comply to emission limit value (“mass concentration”) in waste gas by

dilution with air!

No discussions necessary according to fugitive emissions sources!

Differentiation between O 1.2 and VOC in ventilation no more important!

Numerous installations without exhaust gas abatement technique will choose the

reduction scheme = compliance of 31. BImSchV by taking primarily

measurements = avoidance of VOC emissions = aim of EU Directive!

Advantages:




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Example No. 1

Captured cleaned

wastegas O 1:

Uncaptured emissions O 4 as part of fugitive emissions:

Hall

Abatement unit

Coating of metal surfaces

Total solvent consumptionC= I 1 = 14,0 t VOC/a

No VOC in waste/water

O 5 = 12,0 t VOC/a

O 1 = 0,450 t VOC/a(11,5 mg C/m³; factor 1,3; = 15 mg VOC/m³)

F = I 1 – O 1 – O 5

F = 14,0 - 12,0 - 0,45

F = 1,55 t VOC/a

O 5

Only a little part of O 4 through windows and doors: 0,20 t/a

5000 m³/h, 15 mg VOC/m³, 6000 h/a Air from

ventilation system (O 4)

Emissions of an existing facility, slightly simplified




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Example No. 1Coating of metal

surfaces

Uncaptured emissions O 4 as part of fugitive emissions:26000 m³/h, 6000 h/a

Hall

Captured waste gas:12,6 t VOC/a

VOC in Air from Ventilation: 1,35 t VOC/a

Air and waste gas merged in one stack (sum): 13,95 t VOC/a

Calculated yearly average emission value

89,4 mg VOC/m³ = 68,8 mg C/m³

ELV (Annex IIA) = 100 mg C/m³

Air from ventilation:21000 m³/h, 6000 h/a10,7 mgVOC/m³, 1,35 t VOC/a

waste gas: 5000 m³/h, 6000 h/a420 mg VOC/m³, 12,6 t VOC /a

Possible concept to comply with the requirements without any abatement equipment (depending on the real hourly average emission)




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Example – Wood Coating




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Material Consump-tion [kg]

VOC-content [%] [kg]

Content solids [%] [kg]

Manual operated cleaning 3000 100 3.000 0 0 Clear-coat 20.000 80 16.000 20 4.000 Top-coat 10.000 50 5.000 50 5.000 Total 24.000 9.000

Case study: Coating of wood• 2-layer-application: clear-coat + top-coat

• No exhaust abatement technique

• Assumption: solvents will be emitted completely out of the coating

• The installation falls into the scope of the 31. BImSchV because exceeding solvent consumption threshold




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Solvent management plan:

I1 Purchased solvent and put in 24.000 kg

I2 Recovered and reused solvent in the installation 2.000 (solvent recovery)

O1.1 Captured treated waste gas emissions 0 (air of the hall = fugitive emission)

O1.2 Captured untreated waste gas emissions 0 (air of the hall = fugitive emission)

O2 Solvent in waste water Here neglected

O3 Solvent in product Here neglected

O4 Uncaptured emissions Calculation




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Solvent management plan:

O5 Destroyed solvent by an exhaust gas abatement

unit

Not applicable, because no

abatement unit for waste gas or

waste water

O6 Solvent in waste 3.200 kg/a

O7 Solvent in products to be sold Not applicable

O8 Recovered solvent but not as input into the

process

Not applicable

O9 Solvent released in other ways 2.000 ?




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Determination of the solvent consumption:

LV = I1 – O8 = 24.000 kg – 0 kg = 24.000 kg

-> Installation Nr. 8.1 of Annex I of 31. BImSchV

Calculation of the fugitive emissions according Annex V Nr. 2.2.1 b:

F = I1- O1.1 – O5 – O6 – O7 – O8 =24.000 kg – 0 – 0 – 3.200 kg/a – 0 - 0 = 20.800 kg/a

Calculation of the total emissions according Annex V Nr. 2.1.2 b):

E = F + O1.1 = 20.800 kg/a + 0 = 20.800 kg/a




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Reduction scheme according to Annex IV section B:

Reference emissions: 9.000 kg solids/year * 3 (Multiplication factor) = 27.000 kg/year

Target emission = Reference emission * percentage = 27.000 kg/year * (25 + 15)% = 10.800

kg/year

Following total emissions may not be exceeded:

- from 01.11.2005: Target emission * 1,5 = 16.200 kg/year

- from 01.11.2007: Target emission = 10.800 kg/year

Result:

Emission reduction measures are necessary to comply to the target emission! In comparison:

current total emissions 20.800 kg/year!

Alternatives: Installation of an exhaust gas abatement unit or using a reduction scheme

Bavarian State Ministry of the Environment and Public Health 17./18.06.2010 Dr. Heinz Baumgarten,...

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