Guidelines for Air Emission Regulation 3. Recommended mass flow limits, emission limit values, and C-values3.1 Terms, definitions, and explanationsThe following is a description of the various types of limit values used in these
Guidelines. Detailed explanation
3.1.1 Mass flowThe mass flow is the substance amount per time unit that would constitute the total emission of a given substance or substance class from an installation if no limitation of emissions were carried out. This means that the mass flow must be determined before the actual purification or abatement plant, but after the processing plant. The mass flow is measured as a mean value on the basis of a single working shift (7 hours). If a mass flow limit is exceeded and if the emission concentration is greater than the emission limit value, emissions should be limited so that the specified emission limit value is complied with from each outlet. No requirements regarding limitation of emissions should be made for installations that are only operated for relatively few hours per year, even if such installations exceed the mass flow limit and emission limit value. Figure 1
3.1.2 Emission and reference conditionEmission means the emission into the atmosphere of polluting substances in solid, fluid, or gaseous form. The limit values also apply to aerosols, which are classified as dust within this context. Figure 2 Examples of other reference conditions
Usually, the polluted air is led from the plant to the stack through a flue duct as shown in Figure 3. The emission limit values apply to the polluted air in the flue duct. Figure 3 Individual installations should not be allowed to comply with the emission limit values by means of "dilution", i.e. by using inordinately large quantities or air, e.g. through dilutions using indoor air or outlet air from other processes within the installation. 3.1.3 Ground-level concentrationThis means the presence in outdoor air of solid, liquid, or gaseous pollutants usually at a height of approximately 1.5 m above ground level. Where people live or stay in taller buildings (multi-storey homes, office buildings, factory premises, etc.), the ground-level concentration should be calculated at a height relevant to the building in question. 3.1.4 The C-valueThe total maximum approved contribution from an installation to the concentration of a pollutant in the air at ground level is the "C-value". The C-value must be complied with everywhere outside the boundaries of the installation, regardless of the quantities emitted and the location of the installation. The C-value must be compared to the results of an OML-model calculation. Such a calculation should be conducted for any outlet emitting pollutants into the air. The C-value must be complied with when taking the total emission from the installation into account, cf. chapter 4. In these OML calculations, hourly average concentrations are computed. They may not exceed the C-value for more than 1 per cent of the time, ie. for more than 7 hours during a single month. Figure 4 The size of the C-value, measured as mg/m3 air for each substance is determined by the Danish EPA in accordance with procedures and principles for determining limit values for chemical substances. The C-values apply regardless of the background concentration. The C-value must not be confused with air quality requirements as specified in section 14 of the Danish Environmental Protection Act or in the method to measure such values. Air quality requirements are currently specified in:
Also of note in this connection are Council Directive 1999/30/EC of 22 April 1999 relating to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air, and European Parliament and Council Directive 2000/69/EC of 16 November 2000 relating to limit values for benzene and carbon monoxide in ambient air. These directives must be implemented in Denmark no later than 19 July 2001 and 13 December 2002, respectively. The Danish EPA will assist the authorities by determining C-values for substances where no C-value has previously been set. For more information, please contact the Danish EPA. The C-values stipulated are based upon the Danish EPAs knowledge of the relevant substances at the time of publication. The C-values for dust apply only to particles with a diameter of less than 10 m m. For wood dust, however, the C-value applies to all particle sizes. 3.1.5 Relationship between mass flow limits, emission limit values, and C-valuesThe mass flow is a measure of the potential pollution of an installation. 3.1.5.1.1 Mass flow is smaller than the mass flow limit If the mass flow for the relevant substance is smaller than the mass flow limit, no purification or abatement or adjustments to production in order to reduce emissions must be carried out. The emission should be determined by means of calculations, measurement, or similar. Outlets should be of such a height that the C-value can be complied with. A dispersion calculation for the outlet, using the OML model28 is then prepared to determine whether the C-value is complied with. This calculation is carried out with an emission corresponding to the emission limit value at the maximum flow rate. Where no emission limit value has been specified, the maximum hourly emission and the maximum flow rate are used instead. See also section 4.3. Example where mass flow is smaller than the mass flow limit
For small emissions where the dispersion coefficient i.e. the ratio between the emission measured in mg/sec. and the C-value in mg/m3 is smaller than 250 m3/sec., there is no need to carry out a dispersion calculation. In this case, the outlet should be at least 1 m above roof level30 and the air stream directed upwards in order to ensure compliance with the C-value, see chapter 4 on the calculation of outlet heights. 3.1.5.1.3 Mass flow is greater than the mass flow limit If the mass flow is greater than the mass flow limit for a given substance, the emission limit value must be complied with. This means that where the emission concentration is greater than the emission limit value, purification or abatement should be carried out, or production at the installation should be adjusted to achieve compliance with the emission limit value. The outlet must be established in such a manner and with sufficient height to ensure that the C-value is complied with. In order to determine whether the C-value is complied with, a dispersion calculation using the OML model must be carried out for the outlet. The emission limit value and maximum flow rate must be used in this calculation. Example where the mass flow is greater than the mass flow limit
An example where mass flow is greater than the AMS limit can be found in chapter 5. 3.1.6 Classification of types of substanceFor the purpose of these Guidelines, the pollutants are divided into two groups. These groups are in turn divided into substance groups and classes. For more detailed information on groups, substance groups, and classes, please see the C-value Guidelines. Chart illustrating this classification
3.1.7 Simultaneous emission of several substances. Average value Cr 31 Where an installation emits several substances at the same time, it is very difficult to assess the total health impact associated with exposure to the substances in question. In principle, a combination of substances in a mixture may affect each others mode of operation and effects in the following three ways:
Re. 1. Where the substances act independently of each other, the C-values for each substance must be complied with separately. The outlet height must be determined on the basis of the substance with the greatest dispersion coefficient. Re. 2. If the substances affect each others effects and mode of operation, there is a risk that in certain mixtures, such substances may augment each others effects. However, animal tests indicate that such effects do not manifest themselves unless each substance is present in a concentration which would in itself entail effects, i.e. when a substance is present in a concentrations greater than its zero-effect concentration. In this connection, a C-value for an individual substance will typically be determined on the basis of data concerning the zero-effect concentration (animal or human test). The C-value will be set at a level equal to or lower than this zero-effect level, so that no effects are anticipated at the C-value. Compliance with the individual C-values of such substances is thus assumed to ensure that there will be no interaction between the substances, including reinforcing effects. Accordingly, the outlet height must be determined on the basis of the substance with the largest dispersion coefficient. Re. 3. Where the substances have identical effects and mode of operation, this constitutes a valid reason to total the exposure contributions for the relevant substances. In practice, C-values for substances with identical effects should be added up when:
If all three of the above points are complied with, the outlet calculation should be made on the basis of the total substance emission. This may be done by determining the resulting Cr value (Equation 1). This Cr value represents a total C-value for the mixture, calculated on the basis of the source strength and C-values of the individual substances. The procedure involving the use of a Cr value is correct when the substances are emitted from the same outlet, but it is excessively conservative if emissions come from several different outlets placed at some distance from each other, or of different heights. In such cases, an alternative method may be applied, as described in Section 4.4.2.2. Cr is determined by means of Equation 1: Equation 1
Please note that a C-value related to noxiousness, and therefore bearing an L label, cannot be converted into a health-related C-value. 3.1.8 C-value by intermittent32 operationThe C-value may be made less rigid for installations emitting Group 1 substances and sawdust or a quartz from Group 2 if the emissions from such installations are intermittent. If the intermittent operation is spread evenly throughout day and night and the annual cycle, a C-value for the intermittent operation, designated as Ci, may be used. This value is determined by means of Equation 2: Equation 2
If the operation is not evenly distributed, Equation 3 is used instead: Equation 3
If the C-value is relaxed in accordance with these regulations, the installations approved operation time must be specified in the requirements applying to the installation. 3.2 Mass flow limits and emission limit values3.2.1 IntroductionPollutants are divided into two groups (see section 3.1.6 on classification of substances). Examples of Group 1 substances are listed in table 2 and table 2a. Group 2 is divided into several substance groups. Some substance groups are divided into classes. A recommended mass flow limit and a recommended emission limit value are indicated for each substance or substance class. 3.2.2 Group 1 substancesGroup 1 includes chemical substances currently known to be especially harmful to health or the environment. Various dangerous chemical substances are assigned to Group 1 on the basis of one of the following: their toxicity, their long-term impact on human health, and/or their unacceptable impact on nature. The substances within Group 1 are divided into 2 classes (I and II) on the basis of the C-value. Chart illustrating the division into classes
Table 2 features examples of particularly dangerous substances used in large quantities in Denmark (i.e. more than 1 tonne a year). Table 2a features examples of particularly dangerous substances used in quantities smaller than 1 tonne per year in Denmark. C-values have been determined for these substances, depending on the risk class in which a given substance is included according to the provisions on labelling. Basically, very potent biologically active substances are regarded as Group 1 substances. The final classification of these substances, and their C-values is carried out by the Danish EPA on the basis of a specific assessment of the toxicological and eco-toxicological documentation available. 3.2.3 Limiting emissions, Group 1 substances3.2.3.1 Emissions of dust, Group 1 substances For emissions of dust, pre-purification or abatement should normally be carried out, using filtering processes with a relatively low filter surface load. Subsequently, the filtered air should be purified in an absolute filter with a retention degree of at least 99.97 per cent for particles of 0.3 µm. This purification or abatement technique means that emissions can be reduced to concentrations well below 0.01 mg/normal m3. Please see chapter 5 regarding the inspection of filters. 3.2.3.2 Emissions of flammable substances, Group 1 substances For emissions of flammable substances, purification or abatement should normally be carried out by means of thermal combustion or other, equally effective methods. Where necessary, this may be combined with absorption or adsorption methods. By these means, such emissions can normally be brought to concentrations less than 0.1 mg/normal m3. The installation is responsible for deciding which method to use to limit emissions. The installation should be able to choose freely among other purification or abatement methods, as long as such methods are of a quality corresponding to that of the methods specified in these Guidelines. The effectiveness of the purification or abatement methods chosen should be checked using appropriate means. See also chapter 5. 3.2.3.3 If neither absolute filtering nor combustion can be used If neither absolute filtering nor combustion can be used, the mass flow limits and emission limit values specified in table 1 should be used instead. Table 1
Some substances are, however, so unsafe that particularly low emission limit values should be used. These substances are specified in sections 3.2.3.4 3.2.3.8 below. PCB is subject to an emission limit value33 of 0.0001 mg/normal m3. Emissions of dioxins (polychlorinated dibenzodioxins and polychlorinated dibenzofuranes) should be limited as much as possible. Emission limit values of dioxins should apply to measurements carried out using the CEN measurement method and the international toxicity factors that have now been implemented in Denmark. The CEN method is the measurement method given in the EU Waste Incineration Directive. Please refer to CEN standards EN 1948-1, EN 1948-2, and EN 1948-3. 3.2.3.5.2 Incineration of non-hazardous waste Experience from waste-incineration plants shows that it is technically and financially feasible to limit emissions of dioxins to less than 0.1 ng I-TEQ/normal m3 air (11 per cent O2)34. This limit value is included in the protocol on limitation of persistent, organic compounds under the UN convention on Long-Range Transboundary Air Pollution, as well as in the new EU directive relating to waste incineration. 3.2.3.5.3 Incineration of dangerous waste The Statutory Order on incineration of hazardous waste35 sets an emission limit value for dioxins of 0.1 ng I-TEQ/normal m3(11% O2). The new EU directive on waste incineration also extends in scope to incineration of dangerous waste. 3.2.3.5.4 Industrial installations Steps should be taken to limit dioxin emissions from industrial installations if the annual mass flow of dioxins is greater than 0.01 g I-TEQ. The emission limit value should be set at 0.1 ng I-TEQ/normal m3. In some cases, technical and financial considerations may render it necessary to accept an emission limit value of 0.2 ng I-TEQ/normal m3 for certain installation types. Statutory Order No. 792 of 15 December 1988 on limitations of emissions of asbestos to air from industrial plants applies to emissions of asbestos36. An emission limit value of 5 mg/normal m3 at a mass flow greater than 25 g/hr applies to emissions of formaldehyde. An emission limit value of 20 mg/normal m3 at a mass flow greater than 100 g/hr applies to rockwool and glasswool factories, and wood/furniture factories. 3.2.3.8 Polyaromatic hydrocarbons, PAH A mass flow limit at 25 mg benzo[a]pyrene equivalents/hr applies to emissions of PAHs. The emission limit value for PAH substances is 0.005 mg benzo[a]pyrene equivalents/normal m3. The list below of PAH substances specifies the PAH substances included in this requirement and how each PAH compound is weighted when calculating benzo[a]pyrene equivalents. Definition
The C-value for PAH compounds is set at 2.5 ng benzo[a]pyrene equivalents/ m3, by adding up all the contributions from the substances listed, measured as benzo[a]pyrene equivalents. The basis for this is that all of these substances are considered carcinogenic or are deemed to promote the carcinogenic process. The PAH substances listed here were originally selected by the US EPA and are now widely used internationally in connection with characterisation and assessment of PAH mixtures. The Danish Veterinary and Food Administration, Institute for Food Safety and Toxicology has prepared the equivalence coefficients in connection with efforts to update the existing equivalence systems developed for PAH substances. For further information on the setting of emission limit values of PAH to air, please see the background document (June 2000) at the homepage of the Danish EPA reference laboratory. http://www.dk-teknik.dk/ref-lab/Rapporter/tekniske-undersogelser.asp. 3.2.4 Examples of Group 1 substancesTable 2
3.2.5 Group 2Group 2 encompasses substances that are harmful to human health or the environment other than those included in Group 1. Group 2 substances are divided into 6 substance groups, and some substance groups are sub-divided into classes.
The division into classes is based partly on knowledge of the health risk/harmful impact on the environment associated with a given substance, and partly on the technical and financial feasibility of emission limitation. The following tables specify examples of mass flow limits, emission limit values, and C-values. 3.2.5.1 Dangerous types of inorganic dust Table 3 includes examples of emission limit values, mass flow limits, and C-values for dangerous types of inorganic dust. If a given outlet emits several substances within this substance group, and these substances belong to the same class, the emission limit value of this class applies to the sum of the concentrations of the substances emitted. If a given outlet emits several substances that belong to several different classes, the emission limit value for each individual class should be complied with, and the total emission concentrations should not exceed 5 mg/normal m3. Table 3
*) Small amounts of the emission of Hg, Pb, etc., may occur in gas phase, but are included as dust. NOx is a designation for the total sum of the following nitrogen oxides: nitrogen oxide, NO, and nitrogen dioxide, NO2. Table 4
The mass flow limit and the emission limit value apply to the emitted quantities of NOX, calculated as NO2. The C-value applies to the part of the amount of NOX that is emitted as NO2. The outlet height is calculated by counting all NOX as NO2 if no information on the distribution of the NOx contents is available. If less than half of a given amount of NOX is NO2, calculations should always be made on the assumption that at least half of the NOX emitted is NO2. Example of conversion of NOX to NO2
NOX for such installations are set on the basis of BAT notes. Generally speaking, however, an emission limit value of 500 mg/normal m3 measured as NO2 should be aimed for. Table 5
See also Statutory Order No. 901 of 31 October 1994 on the limitation of sulphur content in fuels for heating and transport, and Statutory Order No. 532 of 25 May 2001 on the limitation of sulphur content in certain liquid and solid fuels. Special conditions apply to lime works, moler works, leca works, rockwool plants, and tile works, as the SO2 emitted comes largely from the raw materials used. In these cases, a specific assessment must be carried out to determine the emission limit. 3.2.5.4 Other vaporous or gaseous inorganic substances Table 6 presents examples of emission limit values, mass flow limits, and C-values for installations that emit vaporous or gaseous inorganic substances other than NOX and SO2. Table 6
Organic substances are divided into three classes, usually in accordance with the criteria outlined below: Outline of the classification of organic substances
Table 8 features examples of C-values and classifications for organic substances. If an installation emits substances that belong to several classes, and if the mass flow for all substances is > 6,250 g/hr, the emission limit value for each class should be complied with, and the sum of the emission concentrations should not exceed 300 mg/normal m3. Table 7
The definition of thinner mixes has been changed as a consequence of a review of the use and composition of thinner mixes. A new C-value of 0.15 mg/m3 has been set for thinner mixes. Thinner mixes are still classified as belonging to Group 2, organic substances, class III. Hereafter, "thinner mixes" include organic solvents in paint products used in paint shops (iron, metal, plastic), at car paint shops, in furniture manufacture, etc. Thinner mixes are defined as a mixture of at least three organic solvents or at least two organic solvents for water-based paints of which the relative proportion of a single organic solvent does not exceed 80 per cent by weight. If the mix contains three or more organic solvents, three of these organic solvents must each account for more than 2 per cent by weight39. None of the organic solvents included in the mix may be substances belonging to Group 1 or Group 2, class I. The C-value of 0.15 mg/m3 has been set on the basis of odour thresholds set for a representative selection of the thinner mixes currently available. For emissions of thinner mixes, requirements on outlet heights are based exclusively on the C-value. This means that there is no need to supplement this by requirements based on the concentration of substance odorants (LE/m3) in the surroundings of outlets emitting thinner mixes. The C-value of 0.15 mg/m3 applies to new installations. This includes the establishment of new paint shops at existing installations that have not previously included a paint shop. As a general rule, the 0.15 mg/m3 C-value should also be complied with in connection with extensions to existing paint shops. For existing paint shops where the outlets have been dimensioned on the basis of a C-value of 0.3 mg/m3, orders to increase outlet heights, etc., with a view to ensuring compliance with a 0.15 mg/m3 C-value should only be given if there are significant odour problems. Detailed explanation
On 11 March 1999, the European Council adopted Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations (The VOC Directive). In Denmark, the VOC Directive will be implemented by means of a Statutory Order on limitations of emissions of volatile organic compounds from the use of organic solvents in certain installations and activities (the VOC Statutory Order). This Statutory Order applies to installations where one or more of the industrial processes and activities specified in appendix 1 are carried out and where the threshold values for use of organic solvents specified in appendix 2 A are exceeded. As a point of departure, the VOC Statutory Order is exhaustively regulates emissions of volatile organic compounds from installations. It should, however, be observed whether an installation emits Group 1 substances which do not fall within the scope of the special provisions laid down in the VOC Statutory Order on substitution and limitation of emissions of certain substances that are particularly harmful to health, i.e. substances with the R phrases R45, R46, R49, R60 and R61. It should also be observed whether any emissions of organic substances that belong to Group 2, organic substances, class I, and which have a health-related C-value, are emitted from the installation. In these cases, the recommendations in these Guidelines should be followed. Such situations are expected to be rare, as installations often use thinner mixes. Phenol is a class I substance with an emission limit value of 5 mg/normal m3. For rockwool and glasswool factories, special technical production conditions may mean that a higher emission limit value must be accepted, e.g. up to 20 mg/normal m3. Table 8
General The mass flow limits, emission limit values, and C-values specified in tables 9 and 9a apply to installations emitting types of dust that do not belong under any of the other sections in these Guidelines. Emission limit values for agricultural companies appear in the Danish EPA Guidelines No. 4/1991, Retningslinier for grovvarebranchen ("Guidelines for produce and foodstuffs companies"). Table 9
For a number of processes involving wet dust, reducing the relevant emission to a level below the specified emission limit values can be very problematic, either because the technology necessary to do so simply does not exist, or it is financially unfeasible for the relevant type of installation. For installations with mass flows greater than 0.5 kg/hr, a higher emission limit value for total dust emissions may be set within the framework specified below. Table 9a
The emission limit values specified in table 9a must apply where there is a valid reason for emissions not being brought below the normal emission limit. The C-value for particles with a diameter of less than 10 mm is 0.08 mg/m3.
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