1.1 List the principal environmental regulations (national and, if applicable, EU) and any associated technical guidance applicable to paint spraying operations of this kind;
UK regulations:
The client must obtain an environmental permit for their solvent emissions activity: specifically in this case for the VOC emissions. It will be issued by the local authority under the Environmental Permitting Regulations Act 2007 Part B (Local Authority Pollution Prevention and Control) and in conjunction with the Pollution Prevention and Control Act 1999.
An environmental assessment of releases of VOC emissions to the air must be carried out which will include an investigation into the quality of the receiving environment, and integrated pollution control.
EU regulations
The Industrial Emissions Directive (IED), is the main tool to regulate polluting emissions that the EU measures in industrial installations.
According to this, the company must look to comply with:
- VOC emission limit values
- reduction scheme targets
- Best Available Techniques
Guidelines:
- It is recommended to use abatement strategies, and a management scheme or a reduction plan.
- The emissions guidelines for this process are subject to the new emission limit which is set at 55g/m2, and the existing limit is 75g/m3, if production exceeds 5000 annually. However if the process production is less than 5000 annually then the new total emissions requirement is less than 65g/m2 and the existing limit is 85g/m2.
- The total emission from the paint-spraying process divided by the surface area of the coated item must be equal to or less than the total emission limit value.
According to the EU BAT guidelines, you should be monitoring the VOCs a minimum of once a month.
There must be containment strategies in place in all organic solvent handling areas.
A high standard of housekeeping and maintenance should be kept at all times.
Management techniques should be put in place including: proper management, supervision and training for process operations, and proper use of equipment.
All staff whose functions could impact on air emissions from the activity should receive appropriate training on those functions.
UNIDO CP policy guidelines:
- Efficiently use raw materials, energy, and water in the process
- Incorporate environmental concerns into the process
- Reduce the environmental impacts of products throughout their lifecycle by using environmentally friendly but cost-effective products
1.2 Explain what information you would require from the client to enable you to clarify the exact regulatory requirements applicable to these operations;
In order to acquire an environmental permit, there are different areas for which the local authorities require information which will aid in acquiring a permit.
Plant characteristics are incredibly important:
- the size of the plant
- the size of the process itself
- Will this operation be growing or downsizing in the future?
- Will there be any changes in the process or in the products?
- The location of the plant, as this will determine which compliance steps are necessary.
- Are there any SSSIs or any other protected sites near to the installation?
- What monitoring systems are in place already?
- Are there provisions in place against failures and/or accidental spillages and releases?
Personnel
In order to specify the information required, the company must be able to supply the following information about the personnel involved in paint spraying:
- Who is undertaking the painting?
- What qualifications do they have for handling the paint?
- Is anyone likely to be affected by the painting process?
Paint
What exactly the product consists of?
A full list of the raw materials used in the paint spraying processes is essential to know, and how they are delivered, stored, used, and what happens after they’ve been used.
- How high is the solvent content in the paint?
- How long does the process take?
- How much of the paint is used? If the process is longer it will put more solvents into the air, how big is the area covered in the process?
- Where is this taking place? The smaller the space, the more risk involved. Is there proper ventilation?
- What pollutants (including odour) and how much are expected to be emitted into the atmosphere?
1.3 Identify the main practical compliance requirements these regulations impose (i.e. what does your client need to do in practical terms to comply with the regulations; consider too whether there are any optional routes available for compliance in this instance); and
In order to achieve compliance, the company can either choose from a list of abatement strategies with a solvent management plan as set out in Article 5(2)(a) and Annex IIA, or can opt for a solvent reduction plan as set out in Article 5(2)(b) and Annex IIB.
Abatement strategies include: catalytic oxidisers, thermal oxidisers, bio scrubbers and reactors, turbines, reciprocating engines, and boilers.
Perhaps the company could invest in Dürr products in order to implement BATs, as they have developed an EcoDryScrubber which can reduce C0² emissions in the booths by 50% and thus allows for extremely low particle emissions, as well as neutralising any odours that will arise from the VOCs in the process. However there are different types of spray booth including: dry, whisper, water wash, bench level, etc and these all have different benefits so may be more efficient than the existing spray booth, and may be a useful tool to help reduce emissions.
Compliance will be achieved by using coating products that have been approved. In addition to this, keeping a solvent inventory which includes the quality of the paint, and the quantity of emissions is essential to help comply.
A solvent management plan alongside the abatement strategies will be the most effective in reducing and controlling emissions, as well as monitoring the emissions outputs. Figure 4.1, shows the example from the DEFRA website for a plan. Implementing this type of plan will help the company to identify: areas that need work, areas to incorporate abatement strategies and BATs to use into one simple diagram.
Another route to compliance is a solvent reduction plan. The company must identify whether the existing paint contains any of the following VOCs: (non-halogenated) H340, H350, H350i, H360D, H360F, or (halogenated) H341 or H351. If so, you must replace them as soon as possible with less harmful alternatives. The company might like to start looking into using water-based paints, or paints with a lower VOC content.
Additional aids to compliance:
The staff involved in the process must be highly qualified and be able to keep a statement of their training requirements and training received. They must be aware of their responsibilities under the permit, have a plan of action for abnormal conditions, accidents or spillages that could occur as all of this will help to reduce emissions.
Effective preventative maintenance plays a key part in achieving compliance with emission limits and other provisions. A written programme of all pollution control must be available alongside a record of maintenance and how the paint is handled and stored.
Maintenance can be improved by using certain BATs: use of enclose mixing and storage vessels, siting of storage tanks, and back venting deliveries if needed, capture, capture and disposal or capture and destruction.
Monitoring and reporting must be put in place as this will help to control emissions and potentially reduce them. A BAT to implement here is to use officers who have been on an emissions monitoring course to audit monitoring; and to use somebody who has produced a guide to emission sampling at authorised processes and permitted installations which has been sent to all regulated processes.
Checking the DEFRA website periodically will help the company to see if any guidance has been updated, or if there have been any developments.
Setting up a peer review system with another company will help to assess the competence of those conducting the pollution control function. Both the DEFRA and the LACOR websites include guidance to facilitate networking and communications opportunities within your sector.
The CIEH operates a web-based noticeboard by which authorities can communicate questions and answers, and information, with one another.
1.4 Explain the range of potential sanctions that could be applied for non-compliance with these regulatory requirements.
Non-compliance can take different forms and can result in a criminal offence by: failing to provide information when requested in relation to a permit you are trying to acquire or in relation to a permit you have, forging or using a forged document or permit, making a false entry into any records that are kept, or providing false or misleading information whilst acquiring or once having acquired the permit.
If the local authority thinks that you are subject to non-compliance, you could be threatened with an enforcement notice. This notice will outline why the authority thinks you have breached the requirements, how can you fix this breach, and the length of time you have to correct the breach.
Before the permit:
If any of these occur whilst applying for the permit, the local authorising body has the right to withdraw the application. If you can remedy this breach, you will be able to take steps to remedy it, you may occur still a potential fine or imprisonment.
After getting the permit:
If you are found to be non compliant within your permit, the authorities may issue a suspension notice which will result in your permit being taken away if there is sufficient evidence that you are causing pollution. If the local authority has to take action in order to rectify this, they may charge you for this.
In the most serious causes, a prison sentence can be issued for up to 5 years if you are found to be non-compliant whilst holding an environmental permit.