VOC treatment: our analysis of the situation for the french industry
Regulatory frameworks for VOCs and other pollutants found in (exhaust) air are different all over Europe. Nevertheless, we can all learn the regulations in other European countries, as often these offer inspiration to other countries' future frameworks. This article looks at the regulatory frameworks applicable to VOCs in France.
1. What regulatory framework for VOCs?
Protocols, directives and municipal by-laws: several texts regulate emissions of volatile organic compounds and aim to reduce them. Let's take a look at the applicable texts:
At the international level, two protocols are particularly relevant to VOCs:
- the Geneva Protocol - Long-range Transboundary Air Pollution in 1991. It aims to control emissions of several air pollutants - including VOCs - and their transboundary flows.
- The Gothenburg Protocol - Reducing acidification, eutrophication and ground-level ozone in 1999. It concerns several pollutants (sulphur dioxide, nitrogen oxides, ammonia), which are responsible for acidification and eutrophication, and emissions of volatile organic compounds (VOCs) which, together with NOx, are responsible for the accumulation of ozone in the lower atmosphere.
The European regulation
A succession of complementary directives, transposed into French law in the form of decrees or orders, make up the European regulations in this area:
Directive 1996/61/EC, known as IPPC (Integrated Pollution Prevention and Control), harmonises the rules for the authorisation and control of industrial installations with a high pollution potential on a European scale. In particular, it requires operators to implement the best available techniques (BATs), which are referenced in sectoral or cross-sectoral documents called BREFs.
Directive 1999/13/EC, on VOC emissions from solvent use, imposed limit values for channelled and diffuse VOC emissions and specific obligations concerning the most toxic solvents (reduction, substitution). This directive introduces :
- emission limit values (ELVs), which distinguish between channelled, diffuse and total ELVs;
- the implementation of a solvent management plan (SMAP), a real identification tool for all incoming and outgoing solvent flows from an installation;
- the implementation of the Emissions Management Scheme (EMS), which focuses on the annual flow of VOC emissions, and enables work on reduction actions implemented on all emission sources present on the same industrial site.
These last two directives were repealed and integrated on 24 November 2010 into the Industrial Emission Directive (IED) 2010/75/EU, reinforcing the reference to BAT and the reference documents to these BATs, the BREFs.
Finally, Directive 2001/81/EC of 23 October 2001, known as the NEC (National Emission Ceilings), sets national emission ceilings for certain atmospheric pollutants, including VOCs (transposition at the European level of the Gothenburg Protocol).
The national regulation concerns Installations Classified for the Protection of the Environment (ICPE).
The ministerial decree of 2 February 1998, on which the installations subject to authorisation depend, is fundamental on three levels:
- reference to emission limit values (channelled ELVs, diffuse ELVs) and the particular case of specific VOCs;
- Solvent Management Plan (SMP): identification of the main discharge points and prioritisation of treatments according to the importance of the different flows identified;
- the Emission Control Scheme (EMS), which offers an alternative to regulation and is in no way mandatory.
On the other hand, for certain production sites, specific limits applicable only to them are determined by their prefectural operating permit order, exempted by the DREAL.
Reviews and next steps
In the coming years, several regulations will be revised. This is particularly the case for BREFs, which are being revised sector by sector, and BAT-AELs (Best Available Techniques, Associated Emissions Limits), which set stricter emission limit levels.
It is also envisaged that the Order of 2 February 1998 will be revised, although no date has yet been set.
The general trend is therefore to increase pressure on the industry to reduce pollutant concentrations in air emissions, particularly specific VOCs, which are targeted by even lower limits in many sectors.
2. How to comply?
It is difficult for the industry to navigate the complex and complicated regulations and to know which limit values apply to their site.
The first priority of industrialists is to comply with the limit values imposed by the decree of 2 February 1998 for total VOCs and specific VOCs in their sector and to refer to their prefectural operating permit decree exempted by the DREAL.
As far as molecules are concerned, two families can be distinguished:
- Total VOCs ( Emission limit value (ELV): 110 mg C/Nm³, for a total hourly flow exceeding 2 kg/h )
- Specific VOCs, are listed in appendices 3 and 4 of the decree of 2 February 1998 (halogens, amines, amides, phenol, methacrylates, aromatics (benzene), NMP, etc.)
- For hazardous substances (carcinogenic, mutagenic, toxic), the emission limit value (ELV) is set at 2 mg/m3 for VOCs if the maximum hourly flow of the entire installation is greater than or equal to 10 g/h.
- For emissions of halogenated volatile organic compounds, the emission limit value (ELV) is 20 mg/m³ if the maximum hourly flow of the whole installation is greater than or equal to 100 g/h.
These values are indicative because for some sectors of activity the limit values are stricter. This is the case, for example, in the thermal offset printing sector, with a total VOC limit value of 15 mg C/Nm3.
Legal limit values are generally much lower for specific VOCs because of the increased environmental risk posed by some specific VOCs.
On an industrial site, if a non-conformity is reported during an environmental inspection, the site manager generally has a period of three months to comply. It is then a matter of finding an urgent solution for treating atmospheric emissions in order to avoid a heavy fine or a production stoppage if the deadlines are not met.
Mobile activated carbon filtration is often an ideal technology for these emergency situations because of the flexibility of the solution and the speed of installation, without major investment.
For some sectors, additional pressure is added to the official regulations. The impact of health or odour nuisances on the neighbourhood may prompt industries to take additional emission control measures, even if the emission values are below the legal limit values. This may be the case for example in highly odorous industries such as food processing, waste management or composting.
3. What technologies are needed to treat atmospheric emissions?
There are several technologies for treating air emissions, each with its advantages and limitations.
Treatment processes fall into two broad categories:
- recovery processes, including absorption by washing, adsorption on activated carbon, condensation, or separation on membranes.
- destructive processes, which include biological treatment, thermal oxidation (RTO) and catalytic oxidation
When selecting air emission treatment technology, the choice is often between a regenerative thermal oxidiser (RTO) and activated carbon filtration:
Thermal oxidation burns all organic compounds in the air at high temperatures. For high concentrations of VOCs on a continuous basis, it is generally an efficient and cost-effective method. However, thermal oxidation is not ideal for dealing with fluctuating concentrations or batch operations. In this case, natural gas must be added to the stream to keep the temperature stable. The cost of operation can then become very high and uneconomic.
Activated carbon filters do not burn, break down or modify molecules, but simply adsorb them onto the pores of the carbon filter bed. There are different types of carbon depending on the compound to be adsorbed, and the filters are sized according to the flow rate and input concentrations. This flexibility makes activated carbon suitable for many applications, but if VOC concentrations are very high, carbon consumption may be excessive and filter replacement too frequent to be cost-effective. Thermal systems or a combination of treatments should then be considered instead.
We invite you to download our white paper on air pollution control techniques to learn more: