Transposition of the industrial emissions directive in Scotland: consultation

Public consultation on draft regulations to transpose the Industrial Emissions Directive into Scottish law.


APPENDIX D - legacy activities - retain in PPC Part A because they are environmentally justified

1. The activity descriptions tabulated here are proposed to be retained in Part 2 of Schedule 1 to the draft Regulations.

2. References to the PPC Regulations are to the existing 2000 Regulations and the new draft Regulations.

Sch. 1, Part 2, Section…2000 Regs Draft Regs Environmentally justified activities (The section heading under which the activity is listed is quoted in italics. Justification for retention is given in bold italics after each description.)
1.2 A (f)(i) 1.2 A (d)(i) Refining Mineral Oil and Gas, Operating Coke Ovens and Coal Gasification and Liquefaction Activities - loading, unloading, handling or storage, or the physical, chemical or thermal treatment of crude oil. 10 permits - large scale operations with high pollution potential. Significant releases of methane, non-methane volatile organic compounds and other organic compounds to air, and of toluene and benzene to water. Obvious potential for environmental damage if not regulated.
1.2 A (f)(ii) 1.2 A (d)(ii) Refining Mineral Oil and Gas, Operating Coke Ovens and Coal Gasification and Liquefaction Activities - loading, unloading, handling or storage, or the physical, chemical or thermal treatment of stabilised crude petroleum. 1 permit - large scale operations with high pollution potential. Activity very similar to that involving crude oil
1.2 A (h) 1.2 A (e) Refining Mineral Oil and Gas, Operating Coke Ovens and Coal Gasification and Liquefaction Activities - pyrolysis, carbonisation, distillation, liquefaction, gasification, partial oxidation or other heat treatment of coal, lignite, oil or other carbonaceous material. 3 permits - large scale operations with high pollution potential, in view both of the raw material and the intensive treatment applied to it.
2.1 A (d) 2.1 A (d) Ferrous Metals - loading, unloading or otherwise handling or storing more than 500,000 tonnes in any 12-month period of iron ore. No current permits - the activity can potentially given rise to considerable local concern.
2.2 A (f) 2.2 A (c) Non-Ferrous Metals - producing, melting or recovering cadmium or mercury or any alloy containing more than 0.05% of either metal or of both in aggregate. No current permits - significant releases of cadmium to air. There is no other suitable environmental control upon these activities which use very notorious pollutants.
3.2 A (b) 3.2 A (b) Activities Involving Asbestos - stripping asbestos from railway vehicles No current permits - no other suitable means of environmental regulation in respect of this highly notorious pollutant.
4.2 A (b) 4.2 A (b) Inorganic Chemicals - activity (other than water treatment and other specified activities) likely to release halogens (chlorine et al.), interhalogens or hydrogen halides to air. 10 permits - chlorine and the other halogens are notoriously toxic and they and the compounds covered are potentially damaging to all three media if released.
4.2 A (d) 4.2 A (d) Inorganic Chemicals - production, use or recovery of any compound of a range of metallic elements (including arsenic and lead) where the activity may result in releases of the elements or their compounds to air or to water. 3 permits - significant releases to both air and water. The elements covered and their compounds are toxic.
4.2 A (e) 4.2 A (e) Inorganic Chemicals - use or recovery of mercury or cadmium or any compound thereof which may result in releases to air. 1 permit -large scale operation with high pollution potential. significant releases of cadmium to water and the need to maintain regulation of activities involving these notorious substances justify retention of IPPC.
4.2 A (g) 4.2 A (f) Inorganic Chemicals - any activity, other than combustion or incineration of carbonaceous material, which is likely to result in the release to air of any acid-forming oxide of nitrogen. No current permits - potentially significant releases of nitrogen oxides to air are controlled under present arrangements.
4.7 A (b) 4.7 A (b) Manufacturing activities involving carbon disulphide or ammonia - any activity for the manufacture of a chemical which may result in the release of ammonia into the air (other than where used as a refrigerant). No current permits - potentially significant releases of ammonia to air controlled under present arrangements.
5.1 A (i) 5.1 A (e) Incineration and co-incineration of waste - thermal treatment other than incidentally in the course of burning solid or liquid waste of any gaseous compound containing halogens. No current permits, but needed to cover the possibility that the activity might arise from removal of CFCs and similar compounds from refrigeration and air conditioning plant - particularly since the requirements concerning waste incineration of Chapter IV of the IED do not apply to gaseous waste.
5.5 A 5.5 A The production of fuel from waste - making solid fuel from waste by using heat. 3 permits for sewage sludge drying - energy intensive and liable to produce significant odour
6.3 A (i) 6.3 A Tar and Bitumen Processes - distilling tar or bitumen in connection with any process of manufacture. No current permits - highly significant releases of naphthalene to air: no other suitable means of environmental regulation.

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