Annexes to COM(1996)538 - Limitation of emissions of volatile organic compounds due to the use of organic solvents in certain industrial activities

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dossier COM(1996)538 - Limitation of emissions of volatile organic compounds due to the use of organic solvents in certain industrial activities.
document COM(1996)538 EN
date March 11, 1999
ANNEX I


SCOPE

This Annex contains the categories of activity referred to in Article 1. When operated above the thresholds listed in Annex IIA, the activities mentioned in this Annex fall within the scope of the Directive. In each case the activity includes the cleaning of the equipment but not the cleaning of products unless specified otherwise.


Adhesive coating

- Any activity in which an adhesive is applied to a surface, with the exception of adhesive coating and laminating associated with printing activities.


Coating activity

- Any activity in which a single or multiple application of a continuous film of a coating is applied to:

- vehicles as listed below:

- new cars, defined as vehicles of category M1 in Directive 70/156/EEC (1), and of category N1 in so far as they are coated at the same installation as M1 vehicles,

- truck cabins, defined as the housing for the driver, and all integrated housing for the technical equipment, of vehicles of categories N2 and N3 in Directive 70/156/EEC,

- vans and trucks, defined as vehicles of categories N1, N2 and N3 in Directive 70/156/EEC, but not including truck cabins,

- buses, defined as vehicles of categories M2 and M3 in Directive 70/156/EEC,

- trailers, defined in categories O1, O2, O3 and O4 in Directive 70/156/EEC,

- metallic and plastic surfaces including surfaces of airplanes, ships, trains, etc.,

- wooden surfaces,

- textile, fabric, film and paper surfaces,

- leather.It does not include the coating of substrate with metals by electrophoretic and chemical spraying techniques. If the coating activity includes a step in which the same article is printed by whatever technique used, that printing step is considered part of the coating activity. However, printing activities operated as a separate activity are not included, but may be covered by the Directive if the printing activity falls within the scope thereof.


Coil coating

- Any activity where coiled steel, stainless steel, coated steel, copper alloys or aluminium strip is coated with either a film forming or laminate coating in a continuous process.


Dry cleaning

- Any industrial or commercial activity using VOCs in an installation to clean garments, furnishing and similar consumer goods with the exception of the manual removal of stains and spots in the textile and clothing industry.


Footwear manufacture

- Any activity of producing complete footwear or parts thereof.


Manufacturing of coating preparations, varnishes, inks and adhesives

- The manufacture of the above final products, and of intermediates where carried out at the same site, by mixing of pigments, resins and adhesive materials with organic solvent or other carrier, including dispersion and predispersion activities, viscosity and tint adjustments and operations for filling the final product into its container.


Manufacturing of pharmaceutical products

- The chemical synthesis, fermentation, extraction, formulation and finishing of pharmaceutical products and where carried out at the same site, the manufacture of intermediate products.


Printing

- Any reproduction activity of text and/or images in which, with the use of an image carrier, ink is transferred onto whatever type of surface. It includes associated varnishing, coating and laminating techniques. However, only the following sub-processes are subject to the Directive:

- flexography - a printing activity using an image carrier of rubber or elastic photopolymers on which the printing areas are above the non-printing areas, using liquid inks which dry through evaporation,

- heatset web offset - a web-fed printing activity using an image carrier in which the printing and non-printing area are in the same plane, where web-fed means that the material to be printed is fed to the machine from a reel as distinct from separate sheets. The non-printing area is treated to attract water and thus reject ink. The printing area is treated to receive and transmit ink to the surface to be printed. Evaporation takes place in an oven where hot air is used to heat the printed material,

- laminating associated to a printing activity - the adhering together of two or more flexible materials to produce laminates,

- publication rotogravure - a rotogravure printing activity used for printing paper for magazines, brochures, catalogues or similar products, using toluene-based inks,

- rotogravure - a printing activity using a cylindrical image carrier in which the printing area is below the non-printing area, using liquid inks which dry through evaporation. The recesses are filled with ink and the surplus is cleaned off the non-printing area before the surface to be printed contacts the cylinder and lifts the ink from the recesses,

- rotary screen printing - a web-fed printing activity in which the ink is passed onto the surface to be printed by forcing it through a porous image carrier, in which the printing area is open and the non-printing area is sealed off, using liquid inks which dry only through evaporation. Web-fed means that the material to be printed is fed to the machine from a reel as distinct from separate sheets,

- varnishing - an activity by which a varnish or an adhesive coating for the purpose of later sealing the packaging material is applied to a flexible material.


Rubber conversion

- Any activity of mixing, milling, blending, calendering, extrusion and vulcanisation of natural or synthetic rubber and any ancillary operations for converting natural or synthetic rubber into a finished product.


Surface cleaning

- Any activity except dry cleaning using organic solvents to remove contamination from the surface of material including degreasing. A cleaning activity consisting of more than one step before or after any other activity shall be considered as one surface cleaning activity. This activity does not refer to the cleaning of the equipment but to the cleaning of the surface of products.


Vegetable oil and animal fat extraction and vegetable oil refining activities

- Any activity to extract vegetable oil from seeds and other vegetable matter, the processing of dry residues to produce animal feed, the purification of fats and vegetable oils derived from seeds, vegetable matter and/or animal matter.


Vehicle refinishing

- Any industrial or commercial coating activity and associated degreasing activities performing:

- the coating of road vehicles as defined in Directive 70/156/EEC, or part of them, carried out as part of vehicle repair, conservation or decoration outside of manufacturing installations, or

- the original coating of road vehicles as defined in Directive 70/156/EEC or part of them with refinishing-type materials, where this is carried out away from the original manufacturing line, or

- the coating of trailers (including semi-trailers) (category O).


Winding wire coating

- Any coating activity of metallic conductors used for winding the coils in transformers and motors, etc.


Wood impregnation

- Any activity giving a loading of preservative in timber.


Wood and plastic lamination

- Any activity to adhere together wood and/or plastic to produce laminated products.


(1) OJ L 42, 23.2.1970, p. 1. Directive as last amended by Directive 97/27/EC (OJ L 233, 25.8.1997, p. 1).


ANNEX IIA


I. THRESHOLDS AND EMISSION CONTROLS

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II. THE VEHICLE COATING INDUSTRY

The total emission limit values are expressed in terms of grams of solvent emitted in relation to the surface area of product in square metres and in kilograms of solvent emitted in relation to the car body.

The surface area of any product dealt with in the table below is defined as follows:

- the surface area calculated from the total electrophoretic coating area, and the surface area of any parts that might be added in successive phases of the coating process which are coated with the same coatings as those used for the product in question, or the total surface area of the product coated in the installation.

The surface of the electrophoretic coating area is calculated using the formula:

>NUM>2 × total weight of product shell

>DEN>average thickness of metal sheet × density of metal sheet

This method shall also be applied for other coated parts made out of sheets.

Computer aided design or other equivalent methods shall be used to calculate the surface area of the other parts added, or the total surface area coated in the installation.

The total emission limit value in the table below refers to all process stages carried out at the same installation from electrophoretic coating, or any other kind of coating process, through to the final wax and polish of topcoating inclusive, as well as solvent used in cleaning of process equipment, including spray booths and other fixed equipment, both during and outside of production time. The total emission limit value is expressed as the mass sum of organic compounds per m² of the total surface area of coated product and as the mass sum of organic compounds per car body.

>TABLE>

Vehicle coating installations below the solvent consumption thresholds in the table above shall meet the requirements for the vehicle refinishing sector in Annex IIA.


ANNEX IIB


REDUCTION SCHEME


1. Principles

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. To that end the operator may use any reduction scheme, specially designed for his installation, provided that in the end an equivalent emission reduction is achieved. Member States shall report according to Article 11 of the Directive to the Commission about the progress in achieving the same emission reduction, including the experience from the application of the reduction scheme.


2. Practice

In the case of applying coatings, varnishes, adhesives or inks, the following scheme can be used. Where the following method is inappropriate the competent authority may allow an operator to apply any alternative exemption scheme which it is satisfied fulfils the principles outlined here. The design of the scheme takes into account the following facts:

(i) where substitutes containing little or no solvent are still under development, a time extension must be given to the operator to implement his emission reduction plans;

(ii) the reference point for emission reductions should correspond as closely as possible to the emissions which would have resulted had no reduction action been taken.

The following scheme shall operate for installations for which a constant solid content of product can be assumed and used to define the reference point for emission reductions:

(i) the operator shall forward an emission reduction plan which includes in particular decreases in the average solvent content of the total input and/or increased efficiency in the use of solids to achieve a reduction of the total emissions from the installation to a given percentage of the annual reference emissions, termed the target emission. This must be done on the following time frame:

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(ii) The annual reference emission is calculated as follows:

(a) The total mass of solids in the quantity of coating and/or ink, varnish or adhesive consumed in a year is determined. Solids are all materials in coatings, inks, varnishes and adhesives that become solid once the water or the volatile organic compounds are evaporated.

(b) The annual reference emissions are calculated by multiplying the mass determined in (a) by the appropriate factor listed in the table below. Competent authorities may adjust these factors for individual installations to reflect documented increased efficiency in the use of solids.

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(c) The target emission is equal to the annual reference emission multiplied by a percentage equal to:

- (the fugitive emission value + 15), for installations falling within item 6 and the lower threshold band of items 8 and 10 of Annex IIA,

- (the fugitive emission value + 5) for all other installations.

(d) Compliance is achieved if the actual solvent emission determined from the solvent management plan is less than or equal to the target emission.


ANNEX III


SOLVENT MANAGEMENT PLAN


1. Introduction

This Annex provides guidance on carrying out a solvent management plan. It identifies the principles to be applied (item 2) and provides a framework for the mass balance (item 3) and an indication of the requirements for verification of compliance (item 4).


2. Principles

The solvent management plan serves the following purposes:

(i) verification of compliance as specified in Article 9(1);

(ii) identification of future reduction options;

(iii) enabling of the provision of information on solvent consumption, solvent emissions and compliance with the Directive to the public.


3. Definitions

The following definitions provide a framework for the mass balance exercise.

Inputs of organic solvents (I):

I1 The quantity of organic solvents or their quantity in preparations purchased which are used as input into the process in the time frame over which the mass balance is being calculated.

I2 The quantity of organic solvents or their quantity in preparations recovered and reused as solvent input into the process. (The recycled solvent is counted every time it is used to carry out the activity.)

Outputs of organic solvents (O):

O1 Emissions in waste gases.

O2 Organic solvents lost in water, if appropriate taking into account waste water treatment when calculating O5.

O3 The quantity of organic solvents which remains as contamination or residue in products output from the process.

O4 Uncaptured emissions of organic solvents to air. This includes the general ventilation of rooms, where air is released to the outside environment via windows, doors, vents and similar openings.

O5 Organic solvents and/or organic compounds lost due to chemical or physical reactions (including for example those which are destroyed, e.g. by incineration or other waste gas or waste water treatments, or captured, e.g. by adsorption, as long as they are not counted under O6, O7 or O8).

O6 Organic solvents contained in collected waste.

O7 Organic solvents, or organic solvents contained in preparations, which are sold or are intended to be sold as a commercially valuable product.

O8 Organic solvents contained in preparations recovered for reuse but not as input into the process, as long as not counted under O7.

O9 Organic solvents released in other ways.


4. Guidance on use of the solvent management plan for verification of compliance

The use made of the solvent management plan will be determined by the particular requirement which is to be verified, as follows:

(i) Verification of compliance with the reduction option in Annex IIB, with a total emission limit value expressed in solvent emissions per unit product, or otherwise stated in Annex IIA.

(a) For all activities using Annex IIB the solvent management plan should be done annually to determine consumption (C). Consumption can be calculated according to the following equation:

C = I1 - O8

A parallel exercise should also be undertaken to determine solids used in coating in order to derive the annual reference emission and the target emission each year.

(b) For assessing compliance with a total emission limit value expressed in solvent emissions per unit product or otherwise stated in Annex IIA, the solvent management plan should be done annually to determine emissions (E). Emissions can be calculated according to the following equation:

E = F + O1

where F is the fugitive emission as defined in section (ii)(a). The emission figure should then be divided by the relevant product parameter.

(c) For assessing compliance with the requirements of Article 5(5)(b)(ii), the solvent management plan should be done annually to determine total emissions from all activities concerned, and that figure should then be compared with the total emissions that would have resulted had the requirements of Annex II been met for each activity separately.

(ii) Determination of fugitive emissions for comparison with fugitive emission values in Annex IIA:

(a) Methodology

The fugitive emission can be calculated according to the following equation:

F = I1 - O1 - O5 - O6 - O7 - O8

or

F = O2 + O3 + O4 + O9

This quantity can be determined by direct measurement of the quantities. Alternatively, an equivalent calculation can be made by other means, for instance by using the capture efficiency of the process.

The fugitive emission value is expressed as a proportion of the input, which can be calculated according to the following equation:

I = I1 + I2

(b) Frequency

Determination of fugitive emissions can be done by a short but comprehensive set of measurements. It need not be done again until the equipment is modified.