APPLICATION FORM Application for a Permit to operate a Solvent Emissions Activity under the Pollution Prevention and Control (Scotland) Regulations 2012 Please fill in this form if you want to apply for a permit or variation to operate a Solvent Emissions Activity under the Pollution Prevention and Control (Scotland) Regulations 2012 This is NOT a standalone form and should accompany the following: If you are applying for a new Part A PPC Permit: Please also complete Part A PPC Form, Parts A, B and F; If you are applying for a variation to a PPC Part A Permit: Please also complete Part A PPC Form, A, C and F; If you are applying for a new Part B PPC Permit: Please also complete Part B PPC Form, Parts A, B and E; If you are applying for a variation to a PPC Part B Permit: Please also complete PPC Part B Form, Parts A, C and E; Your application will only be accepted when all relevant forms detailed above are submitted together PLEASE NOTE - THIS FORM SHOULD NOT BE USED BY DRY CLEANERS. A SEPARATE APPLICATION FORM FOR THE DRY CLEANING SECTOR AFFECTED BY THE POLLUTION PREVENTION AND CONTROL (SCOTLAND) REGULATIONS 2012 MUST BE USED IED-APPL –SER-001 V2 1 SER 1: Application for Solvent Emission Activities under The PPC (Scotland) Regulations 2012 FOR SEPA USE ONLY DATE RECEIVED NAME OF OPERATOR APPLICATION REFERENCE APPLICATION FOR SOLVENT EMISSION ACTIVITIES UNDER PPC (SCOTLAND) REGULATIONS 2012 INTRODUCTION TO PPC 2012 Purpose of this form Use this form to make an application for a permit or variation under the Pollution Prevention and Control (Scotland) Regulations 2012 (PPC 2012) to operate a Solvent Emissions Activity (SEA). If PPC 2012 applies, you must have due regard to the requirements it imposes and how they affect your operations. The information provided in this form will be used to determine your application and to set appropriate controls on your operation. What are the Solvent Emission Activities? PPC 2012 transposes into Scottish legislation Council Directive 2010/75/EU (Industrial Emissions Directive (IED)) on the limitations of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations. The purpose of the IED is to reduce emissions of volatile organic compounds (VOCs) to the environment from specified industrial processes. VOCs are volatile organic compounds, the name given to non-methane organic compounds which evaporate easily and contribute to pollution mainly through the production of secondary pollutants such as ozone. Implementation of IED into Scottish legislation took place on 7th January 2013 with the introduction of the PPC 2012 which supercedes the Pollution Prevention and Control (Scotland) Regulations 2000. Does PPC 2012 apply to you? A site will be affected by PPC 2012, if it carries out a solvent emissions activity listed in Schedule 2 of PPC 2012 and its annual solvent consumption is above the solvent threshold for that activity, as listed in Schedule 2 of the PPC 2012. When to use this form Please use this form if you are making an application to the Scottish Environment Protection Agency (SEPA) in respect of a solvent emissions activity falling within the scope of PPC 2012. Why SEPA requires this information The information provided in these forms will be used to determine your application for a PPC permit. It is therefore in your interest to ensure that you answer each question as fully as possible. Before you start to fill in this form There is no separate guidance document associated with this application form. Relevant guidance for each section has been included within the Appendix to this form. Completion of the form All relevant sections of the form must be completed. Incomplete forms may result in the delay of the determination process or the application being returned to you. This form should be signed and sent as a hard copy with any other relevant forms or documents. Guidance on reduction schemes and other relevant issues is provided in Process Guidance Notes for your sector, available from available from: http://www.defra.gov.uk/industrial-emissions/lasregulations/guidance/ Additional information Any additional documents you may want to submit as part of this application need to be identified in the application form with a document reference number. They must be clearly marked, also stating the: - Date of the application; - Operator's name; - Name of the installation; - Authorisation number. If you need help and advice Do not hesitate to contact your local SEPA office if you need any advice on how to set out the information required. This form has been designed help ensure that certain operational details necessary to determine any application relating to a solvents installation are provided to SEPA and should be completed in addition to the relevant standard PPC application forms. This form should be used if you undertake or propose to undertake a solvent emissions activity. The front of this form provides guidance on what additional forms are required to be completed. PLEASE NOTE - you must indicate on your PPC application form that your have completed this form. Further details on PPC 2012 can be found at the SEPA web site: http://www.sepa.org.uk/air/process_industry_regulation/pollut ion_prevention__control.aspx IED-APPL –SER-001 V2 2 A1 ABOUT YOUR APPLICATION A1.1 Please indicate the type of application you are making. If an application for variation please also state the authorisation / permit reference number. Please tick the box that applies. Application is for a PPC permit Application for variation to an existing PPC permit Permit Reference Number (where applicable) A1.2 What is the name of the installation and the site on which it is located? If you already hold any permit from the Scottish Environment Protection Agency (SEPA) please use name of the installation / site stated in the permit. Installation name Site name A1.3 What is the address / location of the site of the installation? Address Postcode Ordnance Survey national grid reference for the site (10 characters, for example SJ 1234 5678). Note that the grid reference must relate to the site main entrance. A1.4 Site plans & maps Please provide suitable: Maps or plans showing the location of the site of the installation; and Maps or plans showing the location and of the solvent emissions activity(s) within the installation, including: 1. The layout of the solvent emission activities within the installation; 2. The position of any VOC abatement at the installation; 3. The location of drains within the installation and in the immediate area of the installation (that could be affected as a result of any VOC release); 4. The location of any discharge point of waste gases to atmosphere (please reference each emission point e.g. EP1, EP2, etc.). Please specify emission points where solvents classified with hazard statements are emitted. Document reference number(s) IED-APPL –SER-001 V2 3 A2 ABOUT YOUR ACTIVITIES A2.1 Solvent Emissions Activities and directly associated activities Please complete the tables below with details of the proposed solvent emission activities that are to be carried out at the site. Under ‘solvent emission activity’ please identify all activities as listed in Part 1 of Schedule 2 to the PPC 2012. Note: ‘Solvent consumption’ is the total input of organic solvents, less any VOCs that are recovered for reuse. All directly associated activities should be listed, along with the associated annual solvent consumption of each activity (see Appendix 1 for definition of DAA). Table 1 Solvent Emission Activity 1 Annual solvent consumption of activity (tonnes/year)* Solvent emission activity (SEA) Directly associated activities (DAAs) Total consumption of solvent emission activity 1 (SEA + DAAs) Table 2 Solvent Emission Activity 2 Annual solvent consumption of activity (tonnes/year)* Solvent emission activity (SEA) Directly associated activities (DAAs) Total consumption of solvent emission activity 2 (SEA + DAAs) *If you do not know your actual annual solvent consumption, please use an average figure. Please attach extra sheets if required, clearly identified using a document reference number. Document reference number(s) A2.1.1 In order to identify the total solvent consumption of your installation, please calculate the total annual solvent consumption of all of your solvent emissions activities in the box below. Total annual solvent consumption (tonnes/ year)* * Total consumption = (total in Table 1) + (total in Table 2) IED-APPL –SER-001 V2 4 A2.2 About your Solvent Emissions Activity installation If you are applying for a new PPC permit Please go to A2.2.1 If you are applying for a variation (including substantial change) Please go to A2.2.2 A2.2.1 Applications for a new PPC permit The date on which the solvent emissions activity installation started or is to begin operating should be listed. If different parts of the installation were, or are, to be brought into operation at different times, details of each should be listed with the corresponding date of operation. Table 3 SED activity 1 Solvent emissions activity (SEA) Date Directly associated activities (DAAs) Date Table 4 SED activity 2 Solvent emissions activity (SEA) Date Directly associated activities (DAAs) Date Please attach extra sheets if required clearly identified using a document reference number. Document reference number A2.2.2 Application for variation including substantial change Please provide details of any proposed changes to your Solvent Emissions Activities or operations that constitute a variation or substantial change (Please see Appendix 1 for guidance on variations). Table 5 Details of proposed change(s) Nature of proposed change Projected change in nominal capacity* Projected % change in VOC emissions Date of proposed change * Nominal capacity means the maximum mass input of organic solvents by an installation averaged over one day if the installation is operated under conditions of normal operation at its design output. This is the maximum capacity over one day, with due allowance for maintenance and start-up and shutdown. Day is a 24 hour period and nominal capacity would be on the basis that production takes place over the whole 24 hour period. Please attach extra sheets if required clearly identified using a document reference number. Document reference number IED-APPL –SER-001 V2 5 A2.3 VOC abatement Please provide details of the date of installation and nature of any VOC abatement equipment that was, or is proposed to be, brought into operation at the solvents installation. If different pieces of abatement equipment were, or are proposed to be, brought into operation at different times, details of each should be listed with the corresponding date of operation. Table 6 Name VOC abatement equipment Description Date installed Location reference on map Please attach extra sheets if required clearly identified using a document reference number. Document reference number for additional information A3 HAZARD STATEMENTS A3.1 Please identify substances or preparations used, or proposed for use, in the SEA installation that are labelled with the following hazard statements. The individual hazard statement of each substance or preparation should be listed. o o o o o o o H340 – may cause genetic defect H350 – may cause cancer H350i – may cause cancer by inhalation H360D – may damage the unborn child H360F – may damage fertility H341 – suspected of causing genetic defects H351 – suspected of causing cancer Note: This only applies where the assignment of one of these hazard statements to the substance / preparation is due to its VOC content and not a non-voc component, e.g. lead, chromate. Table 7 Hazard statement solvent(s) Name of substance/preparation & hazard statement(s) (please supply MSDS for each substance named) Annual consumption of hazard statement substance (tonnes/year) Date began or intend to begin using hazard statement substance (Please refer to Appendix 1, AP3 for guidance on hazard statements and MSDS) IED-APPL –SER-001 V2 6 A3.2 Please provide an assessment of substitution for any substances or preparations identified in A3.1, excluding substances with hazard statement H341 & H351. Please refer to AP3 for more detailed guidance on substitution. Table 8 Substitution Programme Solvent name & hazard Proposed statement(s) substitution date Substitute substance name Description of programme / action Document reference number Please attach extra sheets if required clearly identified using a document reference number. Document reference number for additional information A3.2.1 Explanation if NOT intending to implement a substitution programme Please attach a full explanation to demonstrate why any substance identified in A3.1 cannot be substituted. Factors to be considered may include the potential effects on human health and the environment, fitness for use, and the costs and benefits associated with using alternatives. Document reference number A3.3 Please identify any part of the solvents Installation where there may be a discharge of a halogenated VOC which; 1. is assigned the hazard statement H341 and/or H351, and 2. where the mass emission of the H341 or H351 compound is greater than, or equal to, 100g/h. (See guidance note AP3.3 for how to calculate the mass emission of the H341/H351 compound) Please contact SEPA if you require further advice. Document reference number A3.3.1 Where applicable please explain how the emission limit value of 20mg/m3 specified in Part 4 of Annex VII of the Industrial Emissions Directive will be complied with at the discharge point of waste gases to atmosphere. Document reference number A4 VOC CONTROL METHODS A4.1 Please identify which of the following VOC control methods * you propose to use at the solvent emissions activity installation. Table 9 VOC control methods VOC control methods a) Meet an emission limit value (ELV) for VOCs in waste gases (measured in mg/CNm3) and a fugitive ELV (measured as % of solvent use) b) Meet a total emission limit value for VOCs (e.g. solvent emissions per unit product) c) Implement a solvent reduction scheme to reduce VOCs emissions * Please tick Please go to A6 Please go to A6 Please go to A5 and A6 Not all of these options will be applicable to each SED activity (see notes AP4 Appendix 1). IED-APPL –SER-001 V2 7 A5 SOLVENT REDUCTION SCHEME A5.1 If you intend to comply by implementing a solvent reduction scheme (Table 9, option c), please give details in the box below of the proposed scheme and how compliance will be achieved including dates, etc. Further information on the reduction scheme can be found in the relevant Technical Guidance or Process Guidance Note for your solvent emissions activity. Document reference number A6 DEMONSTRATING COMPLIANCE A6.1 Please provide a summary of how the installation is designed, equipped and will be operated in a manner which ensures compliance with PPC 2012. We need this information to determine whether the way you operate the installation will meet all the requirements of PPC 2012. You should: • demonstrate that your installation is designed, equipped and will be operated in a manner which will ensure compliance with PPC 2012; and • provide any other information about the installation which you think is relevant to that issue. Document reference number B1 ADDITIONAL INFORMATION You may attach any information that you consider relevant to your application. Please provide this information in electronic form wherever possible. Additional documentation provided should be clearly referenced, and the number provided below. Document Reference Number(s) (and file name(s) if appropriate). IED-APPL –SER-001 V2 8 B2 SIGNATURES AND DECLARATION I accept that the Data Protection Notice contained in the associated PPC application forms applies to the information contained within this form. I have read it and I have brought it to the attention of all persons named on the form. Under the Pollution Prevention and Control (Scotland) Regulations 2012 it will be an offence to: Make a statement which you know to be false or misleading in a material particular; Recklessly make a statement, which you know to be false or misleading in a material particular, for the purpose of obtaining a permit for yourself or any other person. Declaration I/ we certify that the information in this application is correct. I/ we apply for a permit in respect of the particulars described in this application (including supporting documentation I/ we have supplied). Signature(s) of applicant(s): Please note that each individual applicant must sign the declaration himself or herself, even if an agent is acting on their behalf. IED-APPL –SER-001 V2 9 APPENDIX 1: GUIDANCE NOTES FOR SOLVENT EMISSIONS ACTIVITIES AP2 ABOUT YOUR ACTIVITIES The requirements of the Pollution Prevention and Control (Scotland) Regulations 2012 apply to the ‘solvents installation’ rather than to the ‘site’. The solvents installation is defined in the Pollution Prevention and Control (Scotland) Regulations 2012, Regulation 12(1) as; “an installation where an activity listed in the table in Part 1 of Schedule 2 is operated above the solvent consumption threshold for that activity.” Directly associated activity in relation to a solvent emission activity is defined in the Pollution Prevention and Control (Scotland) Regulations 2012, Regulation 2(1) as; “any directly associated activity which has a technical connection with the solvent emission activity carried out on the same site and which could have an effect on any discharge of volatile organic compounds into the environment”. In order to determine what constitutes the solvents installation you must therefore identify what solvent emission activity is undertaken and any relevant directly associated activities. If you carry out more than one Solvent emissions Activity, you must identify each Solvent emission activity and its directly associated activities separately. AP2.2.2 Application for variation including substantial change PPC 2012 defines substantial change in operation as; ”a change in operation which SEPA considers may have a significant negative effect on human health or the environment, or which in itself constitutes the carrying out of an activity described in Part 1 of Schedules 1 or 2 that exceeds any threshold capacity specified in those Schedules, and includes the(a) Carrying out of solvent emissions activity(i) (ii) at a small solvents installation, where there is a change of the nominal capacity leading to an increase in emissions of volatile organic compounds of more than 25 percent, at any other solvents installation, where a change of the nominal capacity leads to an increase in emissions of volatile organic compounds of more than 10 percent…” AP3 HAZARD STATEMENTS Hazard statement substances are defined in PPC 2012, Schedule 2 as: in relation to a solvent emissions activity (other than dry cleaning) a substance which, is classified as a carcinogen, mutagen or toxic to reproduction under Regulation (EC) No. 1272/2008, and in the case where the contents include a – (i) volatile organic compound, is assigned or needs to carry the hazard statements H340, H350, H350i, H360D and H360F or, (ii) halogenated volatile organic compounds, is assigned or needs to carry the hazard statements H341 and H351.” NOTE: You should be aware that such substances may be regulated under the Chemicals (Hazard Information and Packaging for Supply) Regulations 1994 (as amended) (the CHIP Regulations), which require that material safety data sheets (MSDS) are available for risk phrase substances. The MSDS should provide information needed to complete this section. The Control of Substances Hazardous to Health (COSHH) Regulations may also apply. AP3.2 An assessment of substitution for any substances or preparations identified in A2.1, excluding substances with hazard statement H341 or H351. The purpose of this assessment shall be to examine the opportunities for the replacement of the substances or preparations assigned H340, H350, H350i, H360D and H360F, as far as possible and within the shortest possible time, by less harmful substances and preparations. Where the applicant considers that replacement of any of the substances or preparations is not possible, the assessment shall include a reasoned argument, including technical and/or economic reasons, for the continued use of such substances or preparations. The assessment should detail how each hazard statement substance or preparation will be replaced and within what timescale. Full justification for all findings/proposals must be provided as part of the assessment. In particular, where you consider that substitution of any such substance or preparation is not possible, a technical and economic justification should be provided. AP3.3 Please identify any part of the solvent emission Installation where there may be a discharge of a halogenated VOC which: is assigned the risk phrase H341 or H351; and where the mass emission of the H341 or H351 compound causing the labelling is greater than, or equal to, 100g/h. IED-APPL –SER-001 V2 10 Mass emission can be produced by: a) using a mass balance calculation, b) carrying out testing and flow measurement of the process emissions. This may require speciation of the risk phrase component Details of the method used and, in the case of b), process-operating conditions should be provided. Please contact SEPA if you require further advice. AP4 VOC CONTROL METHODS VOC Controls are required for ALL solvent emission Installations. There are three VOC control methods that are specified in PPC 2012, namely; a) b) c) Meet an emission limit value (ELV) for VOCs in waste gases (measured in mgC/Nm3) and a fugitive ELV (measured as % of solvent use); or Meet a total emission limit value for VOCs (e.g. solvent emissions per unit product); or Implement a solvent reduction scheme to reduce VOCs emissions. Not all of these options will be applicable to each solvent emissions activity. However, the relevant Technical Guidance or Process Guidance Note for your installation will detail which option(s) apply to you and how compliance is achieved. SEPA will set relevant permit conditions and VOC limits for your installation based on the control method that you select. B2 DATA PROTECTION NOTICE The information you give will be used by the Scottish Environment Protection Agency to process your application. It will be placed on the relevant public register(s), and used to monitor compliance with licence/permit conditions, or to process renewal applications. We may also use and/or disclose any of the information you give us in order to: • Offer/provide you with our literature/services relating to environmental matters; • Consult with the public, public bodies and other organisations (for example Health and Safety Executive, local authorities, emergency services, Food Standards Agency); • Carry out statistical analysis, research and development on environmental issues; • Provide public register information to enquirers; • Investigate possible breaches of environmental law and take any resulting action; • Prevent breaches of environmental law; • Access customer service satisfaction and improve our service. We may pass on the information to agents/representatives who we ask to do any of these things on our behalf. Individuals have a right to see the information we hold about them. We will correct if it is inaccurate. Please contact SEPA if you require further advice IED-APPL –SER-001 V2 11