Industrial Emissions Directive 2010/75/EU 2010/75/EU - Industrial Emissions Directive (IED) Pillars of the IED Best Available Techniques (BAT) IED/Differences to IPPC Dairy Productions

The project is funded

by the European Union

Twinning Project MK 11 IB EN 01 R Strengthening the administrative capacity on the central and

local level for the transposition and implementation of the new

Industrial Emission Directive 2010/75/EU

Industrial Emissions Directive

2010/75/EU Short-Term Training Programme - Workshop on Pilot

B Permits (Dairy Product Production)

Maria Buchner

© iStockphoto.com/cmisje



19.12.2016






Presentation content

2

Directive 2010/75/EU - Industrial Emissions Directive (IED)

Pillars of the IED

Best Available Techniques (BAT)

IED/Differences to IPPC

Dairy Productions Plants

Relevant Emission

State of the Art

(Pre)treatment of wastewater

Application for a legal permit and permission

Dairy Productions Plants/Austria

Key Features of Permits in Austria

Legal Background

Emission Limit Values for Dairy production Plants in Austria

Status of the Austrian Dairy Production Plants

http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1480870063803&uri=CELEX:02010L0075-20110106





Industrial Emission Directive 2010/75/EU 3

Directive 2010/75/EU - Industrial

Emissions Directive (IED):

IED is the main EU instrument

regulating pollutant emissions • air pollutants

• soil pollutants

• discharges of waste water and

• waste generation

from industrial installations. Source: Land OÖ.

IED entered into force on 6 January 2011 and had to be transposed by Member States by 7 January 2013.

http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1480870063803&uri=CELEX:02010L0075-20110106






Why IED?

4

The IED repealed and replaced 7 existing

directives in order to simplify and clarify

legislation on industrial plants:

• Integrated Pollution Prevention and Control (IPPC)

Directive (2008/1/EC)

• Directive on VOC (Volatile Organic Compounds)

(1999/13/EC)

• Directive on large combustion plants (2001/80/EC)

• Directive on incineration of waste (2000/76/EC) and

• three directives concerning the production of

Titandioxid (78/176/EEC, 82/883/EEC, 92/112/EEC)

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:024:0008:0029:EN:PDF






Pillars of the IED

5

an integrated approach

use of best available techniques

(BAT)

flexibility

inspections

public participation






Pillars of the IED

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The integrated approach means that the permits

must take into account the whole environmental

performance of the plant, covering e.g. emissions

to air, water and soil, generation of waste, use of

raw materials, energy efficiency, noise, prevention

of accidents, and restoration of the site upon

closure.

The permit conditions including emission limit

values (ELVs) must be based on the Best

Available Techniques (BAT). BAT conclusions

are the reference for setting permit conditions.






Pillars of the IED

7

The IED allows competent authorities some

flexibility to set less strict emission limit

values. This is possible only in specific cases where an assessment shows that

achieving the emission levels associated with BAT described in the BAT

conclusions would lead to disproportionately higher costs compared to the

environmental benefits due to the geographical location or the local

environmental conditions or the technical characteristics of the installation.

The competent authority shall always document its justification for

granting such derogations.

The IED contains mandatory requirements on

environmental inspections (site visit at least every 1

to 3 years, depending from risk-based criteria).






Pillars of the IED

8

The IED ensures that the public has a right to

participate in the decision-making process, and to

be informed of its consequences, by having access

to permit applications, permits and the results of the

monitoring of releases.

In addition, through the European Pollutant Release

and Transfer Register (E-PRTR) Regulation

166/2006 detailed information on the emissions and

the off-site transfers of pollutants and waste from

around 30 000 industrial facilities are made

accessible in a public register.

http://prtr.ec.europa.eu/
















Installations, which need a permit

according to IED

9

In Annex I of the IED industrial activities

are listed which require a permit,

containing conditions in accordance with

the principles and provisions of the IED.

Important

• Permit has to include all measures necessary for compliance

(Art. 14, 11, 18)/ monitoring

• Permit conditions have to be periodically reconsidered and

updated by the competent authority






Best Available Techniques (BAT)

10

Best: The most efficient way of achieving a "high general level of

protection of the environment as a whole". High general level is

not defined in the IED but in several other EU legislation (e.g. Air

Quality/Water Framework Directive and daughter directives,

Waste Framework Directive, chemical legislation like REACH,...)

Available: Available techniques are already developed in terms of scale,

economic viable, efficient and accesible.

Techniques: Techniques refers to the way, in which the installation is

designed, build, maintained, operated and decommissioned.






IED/differences to IPPC

11

• Stricter controls on nitrogen oxides, sulphur dioxide and dust

• Stronger role for BAT - Permit conditions must be based on BAT (permit conditions outside BAT must be justified) and requirement to be kept up to date

• Soil and groundwater protection: obligation to produce a baseline report, monitoring obligation, site remediation obligations

• Environmental inspection framework

• Minimum emission limit values tightened, e.g. for large composting plants

• Changes in minimum requirements e.g. for waste (co) incineration

• Some general rules have new, enhanced status and importance changes to scope – exemptions and newly included activities, e.g. pre-treatment of waste is included





Industrial Emission Directive 2010/75/EU 12

Source: Berglandmilch

Dairy Product Production







13

Generally key environmental issues:

water consumption,

energy consumption (cooling, heating,

compressed air,...)

waste water generation and

to a lesser extent - solid waste generation

- odour generation (for example from: the cheese maturation

warehouse, the smoke chamber, the waste water (pre)treatment

plants/precipitator, the sewage system) and

- noise (compressors, incoming and outgoing deliveries)







14

Relevant environmental parameters

respectively emissions

• Waste water emissions (especially COD, TOC,

BOD5, AOX, lipophilic substances, seatleable

substances/ total suspended solids, total

chlorine, nitrogen, ammonium, total phoshorus,

total hydrocarbons (external cleaning of trucks))

• Emissions into the air (CO, NOx, SO2, dust,

soot)







15

Possible environmental emissions

• Odour emissions (for example from: the

cheese maturation warehouse, the smoke

chamber, the waste water (pre)treatment

plants/precipitator, the sewage system)

• waste disposal

• noise (e.g. compressors, incoming and

outgoing deliveries, cleaning station for tank-

vehicles)






State of the Art (BAT)

16

General BAT for whole Food, Drink and Milk (FDM) sector • implementation of an energy management system or an audit

every 4 years

• collaborate with up- and downstream partners, to create a chain of environmental responsibility, to minimise pollution and to protect the environment as a whole

• Equipment and installation cleaning e.g. - remove raw material residues as soon as possible after processing and clean materials storage areas frequently - provide and use catchpots over floor drains and ensure they are inspected and cleaned frequently, to prevent entrainment of materials into waste water system - use dry cleaning prior to wet cleaning







17

Additional BAT for some processes

• switching off the vehicle engine and provide an alternativ power

supply for the refrigerator unit while parking and during loading

and unloading

• when smoking - achieve a TOC air emission level of <50 mg/Nm3

• Freezing and refrigeration

- prevent emissions of substances that deplete the ozone layer

by, e.g. not using halogenated substances as refrigerants

- optimise the condensation pressure

- regularly defrost the entire system or use automatic defrosting

- minimise transmission and ventilation losses from cooled rooms

and coldstores







18

General BAT for energy consumption and energy effiency: use of high-efficient boilers (including economiser for

preheating of water and/or air)

to emplement an energy managment system or an audit

recover heat from waste- or cooling water by heat exchangers and/or heat pumps

use of renewable energy sources

use of fuels with low carbon intensity

to use frequenca-controlled air compressors with heat recovery (except for base load coverage)

switch equipment off when it is not needed







19

General BAT for water consumption and wastewater emissions (I) separate collection and treatment of polluted and non-polluted

wastewater (e.g. wastewater from the process, cooling water, run-off water , sanitary wastewater)

to reduce water consumption and wastewater generation by e.g. - recirculation of process- and cleaning water and of cleaning/disinfection solutions, if required: appropriate pre-treatment (e.g. settling tank) - reuse of cooling water or condensates for cleaning purposes, boiler feed water preparation or as process water if possible - apply industrial automation in processing and cleaning steps - to use water-saving fittings and devices for the production process - apply dry cleaning before wet cleaning of workspaces and facility components







20

General BAT for water consumption and wastewater

emissions (II) to use a CIP cleaning system if applicable (including recirculation

system based on conductivity measurements); to use CIP also

for cleaning of containers

to clean trucks and vehicles in dedicated areas only; accruing

wastewaters need to be collected and sent into wastewater

treatment (oil separator)

use of halogen-free disinfectants and cleaning agents (e.g.

peracetic acid) and record their consumption; if the use of

chloroorganic cleaning agents cannot be avoided: demand-

orientated use of chloroorganic cleaning agents

to perform leakage tests at the wastewater system (e.g. every 5 –

10 years) or regular optical inspection of the sewage and

wastewater treatment system







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General BAT for water consumption and

wastewater emissions (III)

to avoid the use of organic working or auxiliary materials,

especially organic complexing agents which exhibit a

degradation through aerobe microorganisms in an aqueous

medium of not bigger than 80 % after a testing period of 28

days (norm EN ISO 7827:2013 04 15).

But note: the required food safety and hygiene standards have to

be achieved.

(http://eippcb.jrc.ec.europa.eu/reference/BREF/fdm_bref_0806.pdf)

http://eippcb.jrc.ec.europa.eu/reference/BREF/fdm_bref_0806.pdf






(Pre)Treatment of waste water

from Dairy Production Plants

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buffer tanks for flow and load equalization and partially neutralisation

neutralisation

sieving (perforated screen)

dissolved air flotation

biological treatment (waste water treatment plant with nitrification/denitrification and phosphorus removal)

discharge into a river (after full biological treatment, emissions limit levels: T 30 °C, pH 6,5 – 8,5, COD 75 mg/l, BOD5 20 mg/l, TOC 25 mg/l, total N > 75 reduction (T>12°C), NH4-N 5 mg/l, total P 2 mg/l, settable substances 0.3 ml/l, AOX 0.1 mg/l, lipophilic subtances 10 mg/l) or indirect discharge in an external municipal sewer system and waste water treatment plant.






Application for a legal permit

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description of the equipment/maschines (incl. technical description) and their

probable emissions to air, water and soil

- description of the production processes, which may influence wastewater, air or

soil or make noise (also transport for incoming and delivery)

- description of the energy consumption, and production time (beginning and

ending) for every day a week

- list of the chemicals in use , the yearly consumption and the safety-sheets

- fresh water supply (public or own fountain)

- actual plan of the production plant, the sewage system and exhaust air system

- measures for reduction of water consumption, energy consumption, amount

and emissions into waste water, emissions into air, noise and for emissions

prevention into soil and groundwater

- amount and specific composition of waste water, exhausted air/gas, waste and

their treatment/disposal

- monitoring plan and maintainance of the (pre)cleaning plants including clear

responsibility (name of the persons, who are responsible for the maintainance)

- if ist´s an existing plant, analytic results (of the latest three years)

- prevention of accidents






Permission

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Permit conditions - emission limit levels

Permit has to include all measures necessary

for compliance (e.g. maintenance) and clear

responsibility for maintainance of the waste

water (pre)treatment plants

conditions for self-monitoring, external

monitoring

time limitation of the permission






Dairy Production Plants Key Features in Permittings in Austria

25

Legal background (I) "Industrial Code" (Federal Legal Gazette No.

194/1994 as amended)

Water and Waste water: - "Water Act" (Federal Legal Gazette No. 215/1959 as amended; is the legal basis for the use of water, the water quality and the protection against natural hazards) and specific Ordinances (Ordinance for waste water emissions in milk processing and Quality Target Ordinances of the Water Act) - "Water Frame Directive" (Directive 2000/60/EC of 23 October 2000 establishing a framework for Community action in the field of water policy)







26

Legal background (II) Air:

"Ordinance on firing installations" (Federal Legal Gazette II No. 331/1997 as amended by II No. 312/2011) and the "Emission Protection Act for Steam Boilers" (Federal Legal Gazette I No. 127/2013) as well as the "Ordinance for Steam Boilers" (Federal Legal Gazette I No. 127/2013) "Pollutants Directive" (Directive 2001/80/EC of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants) Commission REGULATION (EC) No 1005/2009 of 16 September 2009 on substances that deplete the ozone layer COMMISSION REGULATION (EC) No 1516/2007 of 19 December 2007 establishing, pursuant to Regulation (EC) No 842/2006, standard leakage checking requirements for stationary refrigeration, air conditioning and heat pump equipment containing certain fluorinated greenhouse gases REGULATION (EU) No 517/2014 of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006

http://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=celex:32001L0080







27

Legal background (III) Air

Directive (EU) 2016/802 of 11 May 2016 relating to a reduction in the sulphur content of certain liquid fuels Directive 2001/81/EC of 23 October 2001 on national emission ceilings for certain atmospheric pollutants (A set of national ceilings for each Member State for emissions of sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia is a cost-effective way of meeting interim environmental objectives; SO2, NOx, VOC, NH3)

Noise: " Directive Noise – Environment" (Directive 2002/49/EC of 25 June 2002 relating to the assessment and management of environmental noise)

Waste:

"Waste Management Act" (Federal Legal Gazette I No. 102/2002 as amended)






Emission limit values for Dairy

Production Plants in Austria

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Air (steam boilers): Emission limit values: soot, dust, SO2, CO, NOx, (HC and HCl for using straw or plant products as fuel; NH3, if NH3 or Ammonium compounds are used to reduce NOx) depends on used fuel. Threshold values for the need of continuous measurement (self-monitoring, > 15 MW dust, CO; > 30 MW: SO2, NOx) or external monitoring (every 5th year (1-2 MW), every 3rd year (> 2 MW)) – normally external measurement (< 15 MW)

A List of EN or ISO standards for the measurement of emissions to air and to water is published in http://eippcb.jrc.ec.europa.eu/reference/BREF/ROM_FD_102013_online.pdf)

http://eippcb.jrc.ec.europa.eu/reference/BREF/ROM_FD_102013_online.pdf








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Waste-water: - partial waste water streams: "surface water" and waste water from the cleaning station for tank-vehicles – pretreatment over an oil-separator (usually external monitored once a year via a spot sample – pH, settleable subtances, sum of hydrocarbons) "cooling water" and "condensate"/permeat from whey thickening - if possible reuse or direct discharge into a river (continuous measurements of conductivity and turbidity; usually external monitored once a year via a spot sample – BOD5, COD, total P, TOC, pH, T) "blowdown water" from cooling systems (usually external monitored once a year via a spot sample – sum of hydrocarbon, Cu, total P, pH and suspended solids) "process" wastewater - (pre)treatment before discharging; self monitoring – continuous: T, pH, Flow rate, daily: indirect discharge COD/direct discharge: COD, NH4-N, total P, settleable substances via an an unsettled,homogenised flow-proportional daily composite sample; external monitoring: once a year every day within a week – spot samples and unsettled, homogenised flow-proportional daily composite sample; stationary sampling unit (fpdcs)








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Waste-water

Emission limit values for direct discharged wastewater: T (30 °C), pH (6,5 – 8,5), COD (75 mg/l), BOD (20 mg/l), TOC (25 mg/l), total N (75 % reduction by T>12°C), total P (2.0 mg/l), lipophlic substances (10 mg/l), settleable substances (0.3 ml/l), NH4-N (5.0 mg/l), AOX (reported as Cl; 0.1 mg/l), Total Cl (0.4 mg/l) for indirect discharged wasterwater: T (35 °C), pH (6,5 – 10,5), lipophlic substances *) (100 mg/l), settleable substances (10 ml/l), AOX (reported as Cl; 1.0 mg/l), Total Cl (0.4 mg/l) pH, T – measured continuously or by means of frequent spot samples (also Total Cl); the other parameters are based on an unsettled, homogenised flow-proportional daily composite sample

*) separable lipophilic substance – for plants in Upper Austria: regulation, that the emission limit value of 100 mg/l is not exceeded, if the amount of "low-volatile lipophilic subtances" is below 300 mg/l.






Status of the Austrian Dairy

Production Plants

31

Steam production: Fuel: natural gas/"extra light" heating oil/wood and bark (biomass heating plant)/biogas (from whey fermentation)

cooling: ammonia based cooling plants/water cooling plants

Noise prevention: installation of noise-reduction barriers/housing/reduced truck traffic during night - control: sound level meters, neighbours (complaints)

Odour: biofilter (e.g. housing of parts of the waste-water treatment plant with the use of biofilters)







Production Plants

32

Energy consumption: main energy consumption is needed for cooling (ice water production) and the main supply for milk products (e.g. pasteurisation), others are compressed air and whey thickening

Water and waste water: fresh water from own wells/public grids reduction (see page 18 – 20)

(Note: in BREF Food, Drink an Milk Industries, August 2006, the consumption and emission levels associated with the production of market milk from1 litre of received milk is given as follows: Energy consumption (kWh/l) Water consumption (l/l) Waste water (l/l) 0.07 – 0.2 0.6 – 1.8 0.8 – 1.7)

Waste: disposal to - an authorised company: packaging and cartons, plastic films - an authorised biogas plant (extern): oil and fat, flotation sludge, expired foods Whey, which can´t be used for human consumption usually is used as animal feed. Minimise the discharge of product in the waste stream (in Austria it is also prohibited to discharge whey)







Production Plants

33

Measures in case of other than normal coditions:

retention tank, reduntant pump systems,

automatically stopping of discharge into the

sewing system if a malfunction is detected (T,

pH)

over-dimensioning of the aeration system

(activated sludge basin)

Note: it is necessary, that the company has clear

regulations of responsibilities (e.g. for

maintainance)






Thank you four your attention! Maria Buchner

Office of the

Upper Austrian Government

Directorate of Environment

and Water Management

Linz, Austria

© iStockphoto.com/cmisje



Documents

Industrial Emissions Directive 2010/75/EU 2010/75/EU - Industrial Emissions Directive (IED) Pillars of the IED Best Available Techniques (BAT) IED/Differences to IPPC Dairy Productions