Environmental Brief Note 2008-02

EUROPEAN POLLUTANT RELEASE AND TRANSFER REGISTER (E-PRTR) REGULATION

E-PRTR Reporting Requirements

Under the European Commission’s E-PRTR Regulation, all companies operating A2 processes are required to report on certain pollutant releases to air, water or land. This information, which will be collected on an annual basis, is required by DEFRA for the first time this year (by June 2nd). Local Authorities (LA’s) are responsible for gathering the data from all A2 operations in their area and are required to collect all the data by April 28th 2008. Failure to provide the information to the local authorities by the due date could result in a fine of up to £5,000 or a prison sentence for responsible company executives.

A2 operations for foundries are defined as follows:

European Regulation (EC)No 166/2006 refers to operators of installations in the category of ‘Production and processing of metals’.

Ferrous metal foundries -With a production capacity of 20 tonnes per day

Non-ferrous -Installations for the smelting, including the alloying, of non-ferrous metals, including recovered products (refining, foundry casting, etc.) -With a melting capacity of 4 tonnes per day for lead and cadmium or 20 tonnes per day for all other metals.

Members operating A2 processes under Pollution Prevention and Control Regulations 2000 may have been contacted by their local authority and asked to report on emissions to air, water or land from their premises of a list of 91 pollutants. All prescribed substances, exceeding a threshold amount specified in annex II of the regulation, must be reported as a mass emission (kg per year). It will be necessary to provide entries for all of the substances which exceed their thresholds (threshold values are given in the reporting spreadsheet provided by the local authority). No entry is required for those below the threshold.

There is no requirement to arrange for extra monitoring to gain emission data for this year’s return, although in future years DEFRA and the LA’s may well expect more detailed monitoring. Most foundries will have very little measured emission data suitable for use in the returns. Where no measured data is available, the information required must be provided from calculated or estimated data, and foundries may need to provide to the local authorities the source of the information, methods by which calculations have been made and any assumptions used in estimates or calculations.

Guide to completing the E-PRTR reporting forms

Complete the reporting form spreadsheet as indicated in the guidance issued by the local authority.

In completing the release tables for the pollutants covered in the Indicative Lists for iron and steel (column 3), supplied by the local authority, measured data should be always be used. However, where Emission Factors are needed, the information in the following locations should be helpful.

For Releases to Air

It is suggested that for all the substances in the Indicative List, the entry in the method column (which must be entered whether or not the threshold for the substance is exceeded) should be as follows,

- where measured data is used, for example with particulate matter for which most foundries will have some emission data, the entry should be ‘measured’, qualified by ‘other’ (on the drop down menus).

- where emission factors are used then the entry should be ‘estimated’ and no further qualification is required.

For Releases to Water, foundries should use information from their Discharge Consents – permitted flow rates and maximum concentrations of listed pollutants will be given. These coupled with annual reported analyses of waste water will enable the release information to be calculated. As Discharge Consents vary according to water course and local industry and other discharges, emission factors are not relevant. Few foundries have discharges of process water.

For Releases to Land, foundries should use their waste analysis data obtained for waste classification purposes (for landfill) coupled with their annual waste arisings audit data to obtain the relevant quantities of material deposited on land. As waste varies so much in nature there are no suitable Emission Factors available.

The later entries on Waste Transfers can be completed by reference to the annual waste figures for the company – there are no waste transfer thresholds.

If foundries experience difficulty in completing the forms please contact Jon Donohoe at Castings Technology International on 0114 2728647.

Use of Emission Factors

For some years A1 foundries have been reporting on pollution emissions under the EPER regulations and DEFRA has completed returns to Europe on behalf of the A2 foundries. As A2 emissions data is sparse for many of the pollutants listed DEFRA has contracted AEA Technology to calculate the emissions on its behalf. The Environmental Committee has obtained the emission factors used by AEAT for the earlier work and we suggest that A2 foundries now make use of this data; when they have no suitable measured emission data for their own operations and release points, and in the interests of continuity in the estimating procedure.

The industry Environmental Committee has discussed the issues and DEFRA has been contacted to establish whether it is possible to agree a set of appropriate emission factors which could be used by foundries where actual emission data is not available.

Where a pollutant exceeds a particular threshold figure the record in the report must contain a measured, calculated or estimated value for the amount released by the foundry in a year. This amount should be entered in the appropriate column of the reporting spreadsheet.

Foundries will need to estimate the total emissions from their operations and there will therefore be a need for an assessment of each process (probably based on each emission stack from the foundry plus any estimates of fugitive amounts).

If the emission is below the threshold no entry is required in the spreadsheet. For those pollutants which DEFRA has indicated are likely to be released by the sector (see the ‘Indicative Substance List’ table -SG3 foundries column), it is recommended that even if the measured, calculated or estimated emission is below the threshold and no entry is made in the spreadsheet for the report, that foundries keep a record of the data as they may be required by the local authority to justify their entries.

One way of estimating emissions is to use emission factors, which generally give a mass of material released per tonne of metal melted or per tonne of castings produced.

The relevant UK emission factors are listed in Table 1. These are published on the NETCEN website. They are very general in nature and foundries may find the data in Tables 2 to 4 more helpful, especially for particulates and PM10, although for emissions of metals from melting operations the UK factors for metals are relevant.

In Table 2 the US emission factors for grey iron foundries have been included to estimate the approximate percentage of other pollutants released for various foundry operations.

Table 3 shows particulate releases from various foundry operations, again from the US emission factors. Most foundries will have particulate emission data for their own stacks, but few will have corresponding PM10, fine particulate emission data. The final column of this table gives the appropriate estimates of PM10 for each operation / release. These values seem representative of PM10 emissions. Limited CTI data on PM10, evaluated after particle size analysis of collected dusts from a few foundry operations, confirm the estimates.

Using the Emission Factors and associated data

It is suggested that foundries will make most use of the factors in Table 1. The metal emission factors should be used for the melting operation and possibly for welding operations. It is assumed that the emissions from other processes such as knockout, shot blast and fettling will be mainly particulate. Where foundries have detailed particulate emission data the information in the fourth column of table 3 should help to assess the likely levels of PM10 present in these dust releases.

Each emission factor is given as a mass release per unit of production, usually per tonne of metal melted or per tonne of castings produced.

To obtain an estimate of the total emission from a process the appropriate emission factor is multiplied by the annual production rate for the process.

Tables 1, 2 and 3 are for foundry processes and Table 4 relates to emissions from fuels in combustion processes.

The figures for coke in Table 4 could be used to estimate some of the emissions from the cupola, for example nitrogen oxides, methane, non-methane volatile organic compounds (NMVOC) etc., but it should be recognised that the combustion in the cupola is much affected by operating conditions so estimates could be of low accuracy.

Estimates can be made using these factors (Table 4) for combustion in gas or oil-fired furnaces, heating units, ladle heaters etc and also for boilers used for on-site heating, power generation etc. Factors are not given for the energy used in electric furnaces as the emissions for power generation are off-site.

The factors in these tables should enable foundries to provide estimates of emissions for all the substances indicated by DEFRA to be important for foundries. We are aware that some local authorities have asked for extra data, such as for naphthalene and anthracene. There are other factors available in the literature which might be used, but they are less well defined and we are advising members to indicate that they will expect to be able to provide better estimates next year, based on actual measurement.

CTI will shortly issue new advice to members on which substances could / should be measured at the annual emission tests in the forthcoming year to provide better data next year.

Table 1 - UK emission factors for foundries

*Relevant to cupola emissions only

It is assumed that these factors for metal emissions apply to melting processes principally.

These emission factors for the metals are generic to iron and steel operations and they cannot reflect the variations between foundries, affected by such factors as metal alloy composition, scrap quality, melting process or metal temperatures. They are the best available at present. As more data is gathered for the E-PRTR reporting function then our knowledge on emissions will improve and the emission factors could be refined.

Clearly some of the metals, for example, nickel and chromium may not be present in the melt (and unlikely to be present at significant levels in scrap). Where this can be demonstrated by analysis of melt samples it would be reasonable to assume a negligible emission. This cannot be assumed however for the lower boiling metals such as lead, zinc, arsenic or cadmium, which are frequently present in scrap and are evaporated readily during melting.


Table 2 - US emission factors for foundry operations - gases

*based on 1% sulphur in coke

Table 3 - US emission factors for foundry operations – particulates & PM10

*unabated

** This assumption is made by CTI on the basis of its experience of the typical efficiency of these abatement devices at removing the coarser fractions of the particulates.

***These ‘Baghouse’ entries were not included in the original US emission factor table, but as the normal UK practice for these operations, especially from the shakeout, is to clean the exhaust air an assumed value is given for the percentage PM10 in the total dust emitted after the filter.

Table 4 -Fuel Combustion Emission Factors (UK)

For further information or assistance with completion of forms, please contact Jon Donohoe at Castings Technology International (0114 2537801).