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The “Solvent
Directive” 1999/13/EC
The Solvent Directive
identifies a group of industrial activities involving a non negligible use of
solvents (Annex I) and sets limits on solvent emissions in the air taking into
account both fugitive emissions and emissions in waste gases. These limits are
required for all new installations whereas all existing installations must comply
with the limits by 31 October 2007
at the latest.
Besides the emission
limits compliance (the so-called “end of pipe” approach), the Directive offers
another pathway to emission reductions based on a “reduction scheme”. Annex IIB
states that “the purpose of the reduction scheme is to allow the operator the
possibility to achieve by other means emission reductions, equivalent to those
achieved if the emission limit values were to be applied”. Equivalent
reductions can be achieved by means of decreases in the average solvent content
of the total input and/or increased efficiency in the use of solids. In the
case of industrial installations operating in applying coatings, varnishes,
adhesives or inks the directive sets the scheme of the mass balance to be employed
to demonstrate the actual equivalent reduction. In this approach authorized
emissions are estimated on the basis of the solid coating used by means of a
factor taking into account the industrial activity of the installation and, in
some cases, the installation size.
For a group of solvents
classified as carcinogenic, mutagenic or toxic for the reproduction stricter
rules are set and the substitution with less dangerous compounds is required as
soon as technically feasible.
“End of pipe” and
reduction scheme approaches
The freedom of choice
between the two approaches to the solvent emissions reduction is probably the
most interesting point of the Directive. Industrial operators are expected to
consider the two approaches, to draft a cost-benefit study and definitively to
choose the most appropriate path to solvent reduction.
The “end of pipe”
approach can be realized through a number of technical measures including (list
from abatement tutor and a sentence on the tutorial). Many public (UNECE, 2000)
and private bodies (ESIG, 2002) have produced detailed benchmarking and
tutorial tools to help the industrial operators to select the most appropriate
and cost-effective Best Available Techniques (BAT), (as defined in the IPPC
Directive 61/96/EC) for VOC abatement. Especially SMEs
or local SMEs associations are expected to use these
tools.
The “end of pipe”
approach to the VOC emissions control does not imply any change in the
production cycle. It obtains a downstream impact reduction, but does not
necessarily induce a reduction of the overall amount of solvents involved in
the production cycle and/or contained in the final product.
On the contrary, the
reduction scheme approach requires an integrated tuning of the production
cycle. A number of case studies (Envirowise, 2001)
shows as reduction can be achieved for example by means of solvent adsorption
and recovery systems (Entek International) or
efficient paint spray guns (ABT Products).
In the case of some
industries (coating and painting industries) the reduction scheme approach can
be easily applied by switching to materials containing a smaller percentage of
solvents. Also in these cases, extensive “good practice guidelines” have been
developed to assist industrial operators in setting up reduction schemes and
solvent management plans (Information Exchange Network, 2001).
Future developments:
the “Decopaint” Directive
Minimising the amount
of solvents in the coating products is coherent with the “reduction scheme”
approach and produces the important side advantage of decreasing the overall
amount of solvent pollutants in the environment. Furthermore, limiting the
amount of solvents in a number of products is expected to lead to important
benefits also when non-industrial sources are involved as in the case of
domestic indoor air pollution.
The feasibility of a
legislative approach based on solvent content of products depends on the
availability and cost of effective substitutes of the products employed now.
Feasibility studies
have commissioned by DG Environment have shown as decorative paints and
varnishes and vehicle refinishing activities can count on a set of less harmful
products and the substitution could lead to sensible benefits for the
environment.
The Decopaint
Directive is in the final part of its legislative path as the European
Parliament has approved the second reading without amendments. The Directive
will fix stringent limits on the content of VOC for a number of product
categories following a two-stage approach with two successive deadlines at 1/1/2007 and 1/1/2010.
Other relevant
legislative tools
Solvent emission is
considered in the “national emission ceilings” directive 2001/81/EC setting an
overall emission limit for Member States. Furthermore, VOCs
emissions have to be controlled and limited in the critical area for ozone as
they act as precursors. The “Ozone daughter directive” 2002/3/EC names 31 VOCs as ozone precursors that should be measured in the
ambient air in order to check the effectiveness of reduction strategies.
Finally, all measures involving
industrial plants relevant for the IPPC Directive (96/61/EC) have to fulfil its
requirements. |